Do You Need an SPCC Plan? What Every Fuel Storage Facility Owner Should Know

If you store oil or fuel at your facility, there’s a good chance the EPA requires you to have a written spill prevention plan — and the threshold is lower than most people expect. Six standard 55-gallon drums. That’s all it takes.

An SPCC plan (Spill Prevention, Control, and Countermeasure) is one of those regulations that catches facility owners off guard. Not because it’s obscure — it’s been federal law since 1973 — but because the word “oil” covers far more than diesel and gasoline, and the storage threshold of 1,320 gallons is easy to hit without realizing it.

If you’re unsure whether your facility needs one, you’re not alone. A large percentage of the facilities we work with in the Pacific Northwest either don’t have a plan, have one that’s expired, or have one that doesn’t reflect their current operations. All three of those scenarios carry the same penalty exposure.

Want a quick answer? Run your facility through Compliance Genius — it takes 60 seconds and tells you exactly which federal, state, and industry regulations apply to you, including SPCC.

What Is an SPCC Plan?

An SPCC plan is a written document required by the EPA under 40 CFR Part 112, authorized by Section 311 of the Clean Water Act. Its purpose is straightforward: prevent oil from reaching navigable waters and shorelines, and have a plan in place if it does.

The regulation has been in effect since 1973, with major amendments in 2002. It applies to facilities that store, process, refine, use, transfer, or consume oil — which the EPA defines broadly.

Do You Need One? Three Conditions

Your facility needs an SPCC plan if all three of these conditions apply:

1. You Store Enough Oil

2. “Oil” Includes More Than You Think

The EPA definition of “oil” covers:

• Petroleum fuels: diesel, gasoline, kerosene, jet fuel, heating oil

• Lubricants: motor oil, hydraulic fluid, transmission fluid, gear oil

• Electrical: transformer oil, dielectric fluid

• Food production: cooking oil, vegetable oil, animal fats

• Agricultural: crop oil

If your facility has a backup generator with a 500-gallon diesel tank, a 300-gallon waste oil tank, a 200-gallon hydraulic reservoir, and a few drums of motor oil — you’ve crossed 1,320 gallons.

3. Your Facility Could Discharge to Water

Your facility must have a reasonable expectation of discharging oil to navigable waters. In practice, this means almost every facility in the Pacific Northwest. The EPA’s definition of “navigable waters” extends well beyond rivers and oceans — it includes streams, wetlands, ditches, storm drains, and seasonal waterways. In a region that averages 37 inches of rain per year, the pathway from your tank to a waterway is shorter than you think.

Bottom line: If you store more than 1,320 gallons of any oil product aboveground in containers 55 gallons or larger, you almost certainly need an SPCC plan.

Common Surprises

These are the situations that catch facility owners off guard:

The most common scenario we see: a facility has a 1,000-gallon generator tank, a 500-gallon waste oil tank, and a few drums of hydraulic fluid. They’ve never considered SPCC because they don’t think of themselves as a “fuel storage facility.” But at 1,600+ gallons aggregate, they need a plan.

Self-Certified vs. PE-Certified: Which Do You Need?

The EPA created a tiered system that reduces the burden for smaller facilities. The key question is your total aboveground storage capacity and your spill history.

For most fuel storage facilities in the Pacific Northwest, a PE-certified plan is required. A single 10,000-gallon fuel tank — common at fleet operations, marinas, and construction yards — puts you in the PE tier.

A “reportable discharge” means a single spill over 1,000 gallons, or two spills each over 42 gallons within any 12-month period, in the past 3 years.

What’s in an SPCC Plan?

A compliant SPCC plan includes:

• Facility diagram — site map showing every oil container, transfer area, drainage path, and proximity to waterways

• Oil discharge history — record of all spills in the past 12 months with corrective actions

• Spill predictions — assessment of what could spill from each container and where it would go

• Secondary containment — how you contain spills (berms, dikes, double-walled tanks) — must hold 110% of the largest tank’s volume

• Overfill prevention — alarms, automatic shutoffs, transfer procedures

• Inspection schedule — written procedures for regular visual and integrity inspections, with documentation

• Personnel training — annual training on spill prevention, equipment operation, and the plan itself

• Security measures — fencing, locked valves, lighting, access controls

• Emergency procedures — notification contacts, spill response equipment, cleanup procedures

The plan must be kept on-site and available to facility personnel. Records of inspections, tests, and training must be retained for at least 3 years.

How Often Must You Update It?

The 5-year review is not optional, even if nothing has changed. Failure to document the review is itself a citable violation.

What Happens If You Don’t Have One?

The penalties are significant — and they apply whether or not a spill has actually occurred.

Recent Enforcement

The EPA actively enforces SPCC through both inspections and its Expedited Settlement Agreement program. Recent examples:

• Q4 2024: EPA cited 24 entities for Clean Water Act violations including SPCC deficiencies, totaling $724,270 in penalties

• Eastern Oregon fuel distributor: Settled with EPA for storage violations including inadequate secondary containment and uncontrolled drainage

• Triangle Oil, Inc.: $27,000 penalty via Consent Agreement for fuel storage violations

Washington State adds its own layer: Under state law, there is no statutory limit on oil spill cleanup liability. New financial responsibility rules adopted in June 2024 (Chapter 173-187 WAC) ensure facility owners demonstrate adequate financial resources for cleanup.

For a broader view of all the federal and state regulations that may apply to your facility — beyond just SPCC — see our complete fuel compliance regulations guide.

The #1 Violation: Undocumented Inspections

Of all the SPCC violations EPA inspectors cite, failure to document regular inspections is the most common. Not that inspections aren’t happening — but that there’s no written record.

The top violations EPA inspectors find:

1. No documented monthly inspections of tanks and containment

2. SPCC plan not available on-site or not current

3. Secondary containment not maintained — cracks in berms, drainage valves left open

4. No annual training records for oil-handling personnel

5. Plan doesn’t match actual facility — new tanks added but plan not updated

Every one of these is independently citable, even without a spill. The fix is straightforward: inspect on schedule, document it, and keep the records for 3 years.

SPCC and UST: Two Programs, One Facility

If your facility has both aboveground and underground tanks, you may be subject to both SPCC (40 CFR Part 112) and the UST Rule (40 CFR Part 280).

The key distinction: Completely buried tanks that are fully regulated under the UST Rule are generally exempt from SPCC’s tank-specific requirements. However:

• Transfer areas (loading racks, fill ports, dispensers) associated with UST-exempt tanks may still trigger SPCC requirements

• Heating oil tanks, septic tanks, and certain farm tanks are exempt from UST but do count toward the 42,000-gallon SPCC underground threshold

• If your facility has any aboveground storage over 1,320 gallons, SPCC applies to those tanks regardless of your UST compliance

For Washington State’s three-layer UST regulatory environment — annual, triennial, and 5-year inspection cycles — see our Washington fuel tank compliance guide.

Healthcare facilities with generator fuel often face additional requirements from Joint Commission, CMS, and NFPA 110 on top of SPCC.

What You Should Do Now

Step 1: Determine if SPCC applies. Count every oil container 55 gallons or larger at your facility. If the aggregate exceeds 1,320 gallons aboveground, you need a plan. Compliance Genius can tell you in 60 seconds.

Step 2: If you have a plan, check the date. Has it been reviewed in the past 5 years? Does it reflect your current facility layout, tank inventory, and operations? If not, it needs to be amended.

Step 3: Check your records. Do you have documented inspections, training records, and spill logs for the past 3 years? Missing records are the most common citation.

Step 4: If you don’t have a plan, get one. Determine whether you qualify for self-certification (Tier I or Tier II) or need a PE-certified plan. Most commercial fuel facilities need PE certification.

Already know your requirements? Check your facility’s preparedness with our Fuel Readiness Score.

Frequently Asked Questions

Does my backup generator’s fuel tank trigger SPCC?

Yes — if the tank is 55 gallons or larger and your facility’s total aboveground oil storage exceeds 1,320 gallons in aggregate. This includes the generator’s day tank, any bulk storage tank feeding the generator, and any other oil containers on-site. Many hospitals, data centers, and commercial buildings hit the threshold from generator fuel alone.

My tanks are empty. Do they still count?

Yes. An empty tank that has not been formally decommissioned counts at its full shell capacity. To remove a tank from the aggregate count, it must be properly closed per applicable regulations — simply draining it is not sufficient.

What’s the difference between an SPCC plan and a Facility Response Plan (FRP)?

An SPCC plan is required for facilities that store oil above the threshold amounts and focuses on preventing discharges. A Facility Response Plan (FRP) is required under 40 CFR Part 112.20 for larger facilities (typically 1 million gallons or more in aboveground storage, or with certain transfer history) and focuses on responding to worst-case discharge scenarios. Many facilities need an SPCC plan but not an FRP.

Can I write my own SPCC plan?

If your facility qualifies as Tier I (1,320–10,000 gallons aboveground, no tank over 5,000 gallons, no reportable discharges in 3 years), you can use the EPA’s Tier I template and self-certify. Tier II facilities can also self-certify but must prepare a full plan. Facilities over 10,000 gallons aggregate or with reportable discharge history require a Professional Engineer to certify the plan.

How is SPCC different from state regulations?

SPCC is a federal regulation that establishes the baseline. States can add requirements on top of it. Washington State, for example, requires Class 1 facilities to submit state-approved prevention plans, adopted new financial responsibility rules in 2024, and imposes no statutory limit on spill cleanup liability. Oregon enforces through DEQ with its own inspection and reporting requirements — including 24-hour failure reporting, mandatory licensed testers, and an AST permit threshold (1,000 gal) that’s lower than SPCC’s 1,320-gallon trigger. Federal SPCC compliance does not exempt you from state obligations — and vice versa.

What counts as a “reportable discharge”?

Under SPCC, a discharge is reportable if it creates a sheen on water, violates water quality standards, or causes a sludge deposit. For determining your facility’s qualified status (Tier I/II vs. Full plan), the threshold is: any single discharge exceeding 1,000 gallons, or two discharges each exceeding 42 gallons within any 12-month period, in the past 3 years.

Related Posts

• Which Fuel Compliance Regulations Apply to Your Facility? The Complete 2026 Guide — Overview of all federal, state, and industry regulations for fuel storage facilities

• Healthcare Generator Fuel Compliance: What Joint Commission, CMS & NFPA 110 Actually Require — Healthcare-specific generator compliance requirements

• Washington State Fuel Tank Compliance: UST, AST & Environmental Regulations Explained — Washington’s three-layer regulatory environment

• Oregon Fuel Tank Compliance: UST, AST & DEQ Regulations Explained — Oregon DEQ’s single program with stricter administrative requirements

FuelCare USA provides fuel tank compliance testing, inspections, and maintenance throughout the Pacific Northwest. Contact us for SPCC compliance assessments and ongoing inspection programs.I’m not a man I’m a human.