If your California facility stores oil or petroleum products in above-ground tanks, you may need a Spill Prevention, Control, and Countermeasure (SPCC) plan. This is a federal requirement under the Clean Water Act, administered by the EPA, that applies to facilities with total above-ground oil storage capacity exceeding 1,320 gallons.
Many facilities that need SPCC plans also need hazardous waste tank certification, and the overlap is more common than most people realize.
Who Needs an SPCC Plan?
The threshold is straightforward: if your facility stores more than 1,320 gallons of oil in above-ground containers (total aggregate capacity, not just one tank), you need an SPCC plan. “Oil” includes:
- Petroleum products: motor oil, hydraulic fluid, diesel fuel, gasoline
- Used oil and waste oil
- Vegetable oils and animal fats (for food processing facilities)
- Any oil that could reasonably be expected to discharge into navigable waters
This captures a wide range of facilities: auto dealerships, fleet shops, industrial and manufacturing facilities, food processors, warehouses with backup generators, and any facility with fuel storage.
What an SPCC Plan Includes
An SPCC plan documents your facility’s oil storage configuration and the measures in place to prevent spills from reaching waterways. A compliant plan covers:
- Facility description and oil storage inventory: every container, its location, capacity, and contents
- Potential spill scenarios and discharge predictions
- Containment and diversionary structures (berms, dikes, drainage controls)
- Inspection and monitoring procedures
- Personnel training requirements
- Emergency response procedures
- Management approval and PE certification (for facilities storing more than 10,000 gallons or with a history of spills)
If your total above-ground oil storage exceeds 10,000 gallons, or if your facility has had a reportable spill, the SPCC plan must be certified by a Professional Engineer. For smaller facilities with a clean spill history, a self-certified plan may suffice, but many facilities opt for PE certification regardless.
How SPCC Connects to Tank Certification
Here is where it gets practical: many facilities need both an SPCC plan and a hazardous waste tank certification. The overlap happens because:
- Used oil tanks at auto and fleet shops trigger both requirements. SPCC because it is oil storage, and Title 22 because used oil is hazardous waste
- Secondary containment is evaluated under both programs, the containment you build for SPCC compliance often satisfies Title 22 requirements too
- Both may require PE certification: the engineer reviewing your tank system can address SPCC requirements in the same engagement
If you need both, it makes sense to handle them together. The site visit can cover both assessments, and the documentation package addresses both regulatory programs.
SPCC Inspections and Updates
An SPCC plan is not a one-time document. It requires:
- Regular facility inspections to confirm containment and equipment are in working order
- Updates whenever you add, remove, or modify oil storage containers
- Review and amendment after any spill event
- Complete review at least every five years
Keeping the plan current is as important as having one in the first place. An outdated SPCC plan is a compliance gap that inspectors will flag.
Penalties for Non-Compliance
EPA enforcement for SPCC violations can be significant. Facilities found operating without a required plan (or with a plan that does not reflect current conditions) face administrative penalties. If a spill occurs and the facility lacks a compliant SPCC plan, the consequences are more severe. The plan’s purpose is to demonstrate that you took reasonable steps to prevent and prepare for spills.
Frequently Asked Questions
Can the same firm handle my SPCC plan and tank certification?
Yes. We handle both SPCC plan preparation and Title 22 hazardous waste tank certification. When a facility needs both, we coordinate them together so you are not managing two separate processes with two different firms.
How often does an SPCC plan need to be updated?
You must review and amend your SPCC plan whenever there is a significant change at your facility (new tanks, modified operations, layout changes). The EPA also requires updates if a facility experiences a reportable spill. At a minimum, you should review the plan annually to confirm it still reflects your current operations.
What is the storage threshold for needing an SPCC plan?
If your facility stores more than 1,320 gallons of oil or petroleum products in above-ground containers, you are required to have an SPCC plan. This includes all containers over 55 gallons. The threshold applies to total aggregate capacity, not individual tank size.
Is an SPCC plan the same as a hazardous waste contingency plan?
No. An SPCC plan covers oil and petroleum spill prevention under EPA regulations (40 CFR Part 112). A hazardous waste contingency plan covers hazardous waste emergencies under RCRA. Many facilities need both, but they are separate regulatory requirements.
