SPCC Plan Development and Certification for California Facilities

If you store oil at a California facility, federal law may require you to have a Spill Prevention, Control, and Countermeasure (SPCC) plan on site. The rule lives at 40 CFR Part 112. The EPA writes and enforces it. It applies to any facility with more than 1,320 gallons of aboveground oil storage (or more than 42,000 gallons underground) that could reasonably discharge into navigable waters. CDMS develops PE-certified SPCC plans for industrial and commercial facilities throughout California, sets up the inspection program that goes with the plan, and tracks the 5-year review cycle on a compliance calendar so the next update does not catch you by surprise.

If you already know you need an SPCC plan and you are looking for a consultant, the sections below describe what we deliver, what your facility needs to provide, and the California-specific layer (APSA) that most national templates miss. If you are not sure whether the rule applies to you, the self-identification section walks through the common triggers we see and the thresholds that determine applicability.

Why Facilities Call Us About SPCC Plans

Most SPCC engagements start one of five ways. Recognizing the trigger usually tells you what scope you need and how quickly it has to happen.

• The fire department asked for it. Your local CUPA (the agency that enforces hazardous materials rules in California, usually the fire department) inspected your facility, saw aboveground oil storage, and asked to see your SPCC plan. You may also have received a written notice citing APSA, the California parallel program.
• You found out you have one but you have never seen it. A previous consultant prepared the plan, uploaded a reference to your CERS account (CERS is the state’s online environmental reporting portal), and never gave you a copy. No one set up monthly inspections. No one trained your staff. You did not know any of this until someone went looking.
• It is the 5-year update. Your last plan was certified five or more years ago. SPCC requires a technical review on that cadence, and many facilities have added tanks, moved equipment, or changed ownership since the original plan was written.
• A gap assessment found a problem. During an EHS gap assessment or CERS onboarding, we (or a regulator) found that you have oil storage over the threshold and no plan, or an expired plan, or a plan that does not match what is on site.
• A legal or insurance review surfaced it. A property transaction, a financing condition, an insurance audit, or pending litigation requires you to produce a current SPCC plan.

If any of these match where you are, the next sections cover the regulation, the deliverable, and the parts most consultants leave out.

What Is an SPCC Plan

An SPCC plan is a facility-specific written document that describes how you prevent oil discharges, how you contain them if they happen, and how you respond. It includes:

• A description of the facility, the oil-handling equipment, and the storage containers
• Containment and drainage measures (dikes, berms, double-walled tanks, retention areas)
• Inspection and recordkeeping requirements (CDMS implements these through monthly visual and annual comprehensive inspections per STI SP001)
• Transfer procedures for loading and unloading
• Training requirements for oil-handling personnel
• Discharge prediction and reporting procedures
• Site drawings showing tanks, transfer points, pipes, drainage, and spill response equipment

Under SPCC, “oil” is defined broadly. The federal rule covers petroleum products, vegetable oil, animal fat, synthetic oils, mineral oils, and any other oil of any kind. A food processor with a 2,000-gallon used cooking oil tank is regulated the same way as a manufacturer with a diesel storage tank.

This broad oil definition is one of the differences between federal SPCC and California’s APSA program. APSA covers petroleum only, which means a California facility with non-petroleum oil storage may have federal SPCC obligations without any state APSA layer. We cover the distinction in detail in our piece on SPCC vs APSA in California, and we also explain the overlap with stormwater plans in SPCC vs SWPPP, since those two get confused often.

Do You Need an SPCC Plan

The federal rule applies to your facility if all three of the following are true:

1. Your aggregate aboveground oil storage capacity exceeds 1,320 gallons, counting only containers of 55 gallons or larger, OR you have more than 42,000 gallons of completely buried oil storage.
2. You are a non-transportation-related facility (manufacturing, processing, storage, fueling, equipment maintenance).
3. A discharge from your facility could reasonably reach navigable waters or adjoining shorelines. EPA reads “reasonably could” broadly. Storm drains that flow to a creek count. Drainage swales that empty into a river count.

If you are not sure whether you cross the threshold, the applicability piece walks through the count. The most common surprise: equipment most people forget to add up. Backup generator base tanks, oil-filled transformers (if you own them), machining oil reservoirs of 55 gallons or larger, hydraulic tanks, transformer cooling oil, and waste oil drums all count toward the aggregate.

A short list of facility types we routinely confirm into SPCC scope:

• Manufacturers with diesel-fueled backup generators
• Food processors with cooking oil storage or animal fat tanks
• Cold storage and refrigerated warehouses (ammonia compressor oil systems, backup power)
• Data centers with generator fuel tanks
• Fleet maintenance shops with waste oil and motor oil drums
• Aerospace and machining shops with cutting and cooling fluid reservoirs
• Chemical distributors with petroleum products in their inventory

What an SPCC Plan Must Include

CDMS organizes PE-certified SPCC Plans into the following 14-section structure to address the applicable requirements of 40 CFR 112.7 and the facility-specific sections that follow it. The headings below match what your finished binder will contain.

• Section I, Introduction: Purpose, scope, and applicability
• Section II, Facility Information: Owner, operator, address, contacts
• Section III, Amendment of the Plan: Record of revisions, what triggers an amendment
• Section IV, Discharge Prevention Measures: Spill controls, signage, equipment specifications
• Section V, Discharge and Drainage Controls: Containment design and capacity, drainage routes
• Section VI, Bulk Storage Containers: Tank inventory, integrity testing, overfill prevention
• Section VII, Facility Transfer Operations: Loading and unloading procedures, transfer area design
• Section VIII, Countermeasures and Spill Mitigation: Spill kits, response procedures, reporting
• Section IX, History of Releases: Past spills and corrective actions
• Section X, Prediction of Release: Reasonable spill scenarios from each container type
• Section XI, Inspections, Tests, and Records: Inspection program per written facility procedures and applicable industry standards (CDMS implements through monthly visual and annual comprehensive inspections)
• Section XII, Security: Access control, lighting, valve security, signage
• Section XIII, Training: Initial and annual training program for oil-handling personnel
• Section XIV, Certifications: PE certification or owner self-certification (Tier I/II)

Appendices include the Substantial Harm Checklist (which determines whether your facility also needs a Facility Response Plan), inspection log templates in STI format, training sign-off forms, secondary containment calculations, and facility drawings.

The SPCC plan requirements piece walks through each section in more depth. The secondary containment piece covers the math behind Section V, including how containment capacity is calculated against the largest single container plus freeboard for precipitation.

Tier I, Tier II, or PE-Certified: Which Plan Type You Need

Federal SPCC offers three plan formats. Which one applies depends on your total oil storage and your spill history.

CDMS provides PE-certified plans as a conservative practice, even when your facility qualifies for self-certification. While the qualified-facility rule allows Tier I and Tier II self-certification, our position is that a PE-certified plan provides stronger legal protection. The self-certification statements require the facility owner to attest, under penalty of law, that the plan was prepared in accordance with accepted industry practices and that the owner is familiar with the requirements of 40 CFR Part 112. When a consultant prepared the work, we believe PE certification is the more defensible path. It removes ambiguity about who did the technical analysis and puts a licensed engineer’s stamp behind the document.

PE certification also gives you a document that holds up under regulatory scrutiny, lender review, insurance audits, and litigation. The tier comparison piece explains the trade-offs in more detail, and the cost piece covers how plan type affects scope.

The CDMS Process: What Happens From Start to Finish

The SPCC engagement runs through four stages. We come to your facility for the field work. You do not visit our office.

1. Scoping and information collection. We send a data collection sheet that asks for tank inventory (names, locations, capacities, construction materials, oil types), loading and unloading procedures, prior SPCC plans, tank certifications, inspection logs (if any exist), and a facility diagram. The previous plan, if one exists, is the most important input. It tells us what changed.

2. Site visit. A CDMS consultant walks the facility with your team. We photograph and measure every container at or above 55 gallons. We measure secondary containment volumes against the regulatory standard. We trace drainage paths from oil-handling areas to property boundaries and storm drains. We look at transfer areas, oil-handling equipment placement, and equipment inside containment. If we find deficiencies (containment that does not meet the capacity requirement, oil-handling areas with no curbing, valves that should be locked), we document them and discuss correction options before the plan is finalized.

3. Plan writing and PE certification. We draft the plan, run an internal QC review, and send it to a California-licensed Professional Engineer for certification. Section drawings show your facility as it actually is, not a generic template.

4. Implementation. We deliver the bound plan with appendices and inspection logs in STI format. We set up the monthly visual inspection routine and the annual comprehensive inspection. We train the personnel who will be doing the inspections. We add your 5-year renewal date to our compliance calendar so the next update does not come as a surprise.

This last step is the one that consistently separates CDMS engagements from the plans we inherit. Many facilities have a binder on a shelf and no inspection program because the previous consultant disappeared after PE signature. An SPCC plan with no active inspection program is a compliance deficiency, even if the plan itself is current.

SPCC Inspections: What the Plan Requires You to Do

The plan is the document. The inspection program is what keeps you in compliance month to month. Two cadences run in parallel:

• Monthly visual inspections of all aboveground tanks, containment areas, transfer points, and oil-handling equipment. Documented on STI-format inspection logs. Usually performed by facility staff after we train them.
• Annual comprehensive inspections that go deeper into containment integrity, tank condition, drainage, and equipment performance.

Tank integrity testing on a defined schedule (per STI SP001 or equivalent industry standard) is also part of Section VI for shop-built aboveground tanks. We coordinate with hazardous waste tank certification and tank integrity work when the two services overlap. The SPCC inspection piece covers the inspection requirements in more depth, and the inspection prep piece walks through what to expect when a CUPA inspector arrives.

Training Requirements

40 CFR 112 requires training for personnel who handle oil. Initial training covers spill response procedures, discharge prevention, applicable laws, and inspection protocols. Refresher training is required on a defined cadence, and any time the plan is amended in a way that affects personnel responsibilities.

CDMS delivers SPCC training in-person at your facility, scheduled around shift coverage. We can deliver training as part of plan implementation, on its own, or as one of the annual trainings in an ongoing compliance package. The SPCC training piece covers who needs training, what it includes, and how often it is required.

The California Layer: APSA, CERS, and CUPA

In California, petroleum-product facilities that meet the SPCC threshold also fall under the Aboveground Petroleum Storage Act (APSA), enforced by your local CUPA (which may be a county environmental health department, fire department, or another local agency depending on jurisdiction). APSA has separate requirements: a Tank Facility Statement filed annually through CERS, CUPA inspections every three years, and California-specific reporting for releases over 42 gallons.

Two things matter for the plan itself:

• The SPCC plan stays on site. APSA-related data goes into CERS as part of the Tank Facility Statement, but the SPCC plan document itself is not uploaded. CUPA inspectors expect to find the bound, signed plan at the facility during inspections.
• APSA covers petroleum only. If your oil storage is non-petroleum (vegetable oil, animal fat, synthetic), the federal SPCC rule still applies, but APSA does not. This trips up California facilities with mixed oil inventories.

The APSA program was updated through new Title 19 regulations effective December 17, 2024. The detailed comparison and decision flow lives in SPCC vs APSA in California.

What Affects the Cost of an SPCC Plan

We do not publish a price list, but the scope drivers are the same on every engagement:

• Tank count and complexity. More containers, more secondary containment areas, and more transfer points add field time and writing time.
• New plan vs update. Updates that follow an existing CDMS plan are usually faster than starting from scratch. Updates to plans we did not write require a fresh field visit and a baseline review.
• Plan tier. PE-certified plans take longer than self-certified plans because of the engineering review.
• Containment status. If existing containment is adequate, the plan reflects what is on site. If containment needs to be designed or upgraded, scope grows.
• Geographic distance. Field time includes travel. Single-day visits within Northern or Southern California carry less travel overhead than multi-day or remote-site engagements.
• Bundle scope. SPCC plans bundled with tank certification, training, HMBP work, or ongoing compliance management qualify for multi-service discounts.

The cost factors piece covers the variables in more depth.

When and Why to Update Your Plan

40 CFR 112 requires a technical review of the SPCC plan at least every five years. The plan also must be amended whenever a material change occurs:

• New tanks installed, existing tanks removed, capacity changes
• Configuration changes (containment, transfer areas, drainage)
• Ownership changes
• Personnel changes that affect designated responsibilities
• A discharge event over reportable thresholds

The update requirements piece covers what each trigger requires and what the amendment process looks like.

Frequently Asked Questions

When is an SPCC plan required?

When you store more than 1,320 gallons of oil aboveground (in containers of 55 gallons or larger), or more than 42,000 gallons underground, at a non-transportation-related facility that could reasonably discharge into navigable waters. The 1,320-gallon threshold is the aggregate of all qualifying containers, not a per-tank limit.

Who needs to certify the SPCC plan?

For Tier I and Tier II plans (≤10,000 gallons total, no significant spill history), the facility owner or operator can self-certify if they prepared the plan and are familiar with 40 CFR Part 112. For all other facilities, a licensed Professional Engineer must certify the plan. CDMS PE-certifies every plan we develop by default.

How often does the SPCC plan need to be reviewed?

At least once every five years, with a documented technical review. Amendments are required sooner if facility conditions change in a way that affects the plan. If your 5-year review date has passed and nothing has been signed, the plan is out of compliance even if no facility changes have occurred.

Does CERS replace the SPCC plan?

No. CERS holds APSA-related data (your Tank Facility Statement) for California petroleum facilities. The SPCC plan itself is kept on site, in hard copy or accessible electronically, and produced for CUPA or EPA inspectors during inspections.

What is the difference between SPCC and APSA?

SPCC is federal (40 CFR Part 112, EPA) and covers all oils. APSA is California (Health & Safety Code §25270, enforced by CUPAs) and covers petroleum only. California petroleum facilities over the SPCC threshold typically have both. Non-petroleum oil facilities (food processors with cooking oil, manufacturers with synthetic oils) may have federal SPCC obligations without APSA. The full breakdown is in SPCC vs APSA in California.

Is SPCC the same thing as our stormwater plan?

No. SPCC (40 CFR 112) covers oil discharges to navigable waters. A stormwater plan (typically a SWPPP under the General Industrial Permit) covers general stormwater discharges and is enforced by the State and Regional Water Boards. Many industrial facilities need both. The two get confused often, and the scoping comparison lives in SPCC vs SWPPP.

Ready to Move Forward