A Spill Prevention, Control, and Countermeasure (SPCC) plan is a written, engineered plan for keeping oil out of navigable waters. For Texas operators, it is one of the most commonly required federal environmental obligations, and one of the most commonly cited during an EPA inspection. This guide answers the questions operators ask most: what an SPCC plan is, whether your facility needs one, when a Professional Engineer has to certify it, what the plan must contain, and how often it has to be updated.
What is an SPCC plan?
An SPCC plan is a written, facility-specific document that describes how a facility prevents, contains, and responds to oil spills. It is required by the EPA's Oil Pollution Prevention regulation at 40 CFR Part 112, which draws its authority from the Clean Water Act. The plan documents your containment, inspection, and response measures, and it must be kept current and available for EPA review.
Two definitions decide how broadly the rule reaches:
- Oil is defined broadly: crude oil, refined products, condensate, synthetic and lubricating oils, fuel oil, and oil mixed with other wastes. It is not limited to what you produce; it includes fuel for backup generators, hydraulic reservoirs, transformers, and drummed product.
- Navigable waters is interpreted broadly by the EPA. Operators should assume it includes the intermittent streams, drainage ditches, and arroyos common across the Texas basins that can eventually reach a larger body of water.
Does my facility need an SPCC plan?
Your facility needs an SPCC plan if it is non-transportation-related, stores more than 1,320 US gallons of oil aboveground in aggregate (or more than 42,000 gallons completely buried), and could reasonably be expected to discharge oil to navigable waters. Only containers of 55 gallons or larger count toward the 1,320-gallon aggregate. Most Texas tank batteries and production facilities clear this threshold easily.
A common and costly mistake is confusing the 1,320-gallon applicability threshold with the 10,000-gallon figure. The 10,000-gallon number does not decide whether you need a plan; it decides whether you may self-certify it. The table below separates the thresholds that actually matter.
| Threshold | Value | What it determines |
|---|---|---|
| Aggregate aboveground oil storage | More than 1,320 gallons | Whether the SPCC rule applies to you |
| Completely buried storage | More than 42,000 gallons | Whether the SPCC rule applies to you |
| Smallest container counted | 55 gallons and larger | Which containers count toward the 1,320-gallon aggregate |
| Self-certification cutoff | 10,000 gallons or less | Whether you may self-certify as a qualified facility |
| PE certification required | More than 10,000 gallons, or a disqualifying spill history | Whether a licensed PE must certify the plan |
Does an SPCC plan have to be certified by a Professional Engineer?
Not always. A facility with more than 10,000 gallons of aggregate aboveground storage, or a spill history that disqualifies it, must have its plan certified by a licensed Professional Engineer (PE) after a site visit. Smaller qualified facilities can self-certify. Whether you fall into the Tier I, Tier II, or PE-certified category depends on your total storage, your largest single container, and your recent spill history.
| Requirement | Tier I qualified facility | Tier II qualified facility | PE-certified plan |
|---|---|---|---|
| Aggregate aboveground storage | 10,000 gallons or less | 10,000 gallons or less | More than 10,000 gallons |
| Largest single container | 5,000 gallons or less | May have a container over 5,000 gallons | No limit |
| Spill history (prior 3 years) | No single discharge over 1,000 gal; no two discharges over 42 gal each | Same clean-history criteria | Applies to all facilities |
| Who certifies? | Owner/operator self-certifies | Owner/operator self-certifies | Licensed PE, after a site visit |
| Plan format | Streamlined EPA template (Appendix G) | Full self-certified plan | Full, facility-specific PE plan |
What must an SPCC plan include?
Every SPCC plan must document the engineering and operational controls that prevent and contain a discharge. It is a technical document specific to your facility, not a generic safety manual. The required elements fall into two groups: engineered controls and operating procedures.
Engineered controls: secondary containment and overfill prevention
The plan must show sized secondary containment for bulk storage. Berms and dikes must hold the entire volume of the largest single container plus enough freeboard for a precipitation event. This is also where SPCC overlaps directly with RRC Statewide Rule 8 on water protection, which is why a coordinated approach across the two rules avoids conflicting records. The plan must also document overfill prevention, such as high-level alarms or automatic shutoffs. For the sizing details, see our guide to secondary containment requirements for oilfield tanks.
Operating procedures: inspections, testing, training, and response
The plan sets mandatory procedures for the people running the facility, and the records prove compliance during an audit.
| Activity | Frequency | Key requirement |
|---|---|---|
| Routine visual inspections (tanks, piping, containment) | Monthly at minimum, or per the plan | Check for deterioration, leaks, staining, and damage. Document every inspection. |
| Container integrity testing (e.g. API 653) | Per industry standard and PE recommendation | Formal, documented testing of tank shell, bottom, and roof. |
| Personnel training | Annually at minimum | Train oil-handling staff on the plan, spill procedures, and pollution-control law. Document attendance. |
| Plan review and evaluation | Every 5 years, or after a facility change | Amend within 6 months of any change that materially affects discharge potential. |
How often must an SPCC plan be reviewed or updated?
The full plan must be reviewed and evaluated at least every five years. Separately, it must be amended within six months of any change that materially affects the facility's potential to discharge, including new or modified storage tanks, changes to secondary containment, or new drainage configurations. For a PE-certified plan, those amendments require PE re-certification before the change is put into service. A common way to stay ahead of this is an annual self-review; see how to conduct an SPCC plan self-audit.
What happens if you don't have an SPCC plan?
A missing, outdated, or unimplemented SPCC plan is one of the most frequently cited violations in the EPA's oil program. Civil penalties can reach into the tens of thousands of dollars per day, per violation, and that exposure sits on top of RRC penalties and cleanup costs if a discharge actually occurs. Because inspectors evaluate the plan document, the physical containment, and the inspection records together, a plan that exists on paper but does not match field conditions is treated as non-compliance.
Getting an SPCC plan in place
Tektite Energy provides PE-certified SPCC plan development, plan review, and third-party audits for independent Texas operators. If you are not sure whether your facility crosses the 1,320-gallon threshold, whether you qualify to self-certify, or whether your existing plan still matches your tanks, a focused review will tell you where you stand before an inspector does. Facility owners still working out their tier can start with Tier I vs Tier II: which SPCC plan you need.
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Frequently Asked Questions
What is an SPCC plan and what regulation requires it?
An SPCC (Spill Prevention, Control, and Countermeasure) plan is a written, facility-specific plan for preventing and containing oil spills. It is required by the EPA's Oil Pollution Prevention regulation at 40 CFR Part 112, under the authority of the Clean Water Act, for facilities that meet the oil storage threshold and could discharge oil to navigable waters.
What oil storage threshold requires an SPCC plan?
The SPCC rule applies to a non-transportation-related facility with more than 1,320 US gallons of aggregate aboveground oil storage (counting only containers of 55 gallons or larger), or more than 42,000 gallons completely buried, that could reasonably discharge oil to navigable waters. The 10,000-gallon figure people often cite is a separate cutoff that determines whether you may self-certify, not whether the rule applies.
Does an SPCC plan have to be certified by a Professional Engineer?
Not always. A facility with more than 10,000 gallons of aggregate aboveground storage, or a disqualifying spill history, must have its plan certified by a licensed Professional Engineer after a site visit. Smaller qualified facilities (10,000 gallons or less with a clean spill history) may self-certify. Many operators still use PE-certified SPCC plan development for defensibility.
How often must an SPCC plan be reviewed or updated?
The full plan must be reviewed at least every five years, and it must be amended within six months of any change that materially affects the facility's discharge potential, such as new or modified tanks or changes to secondary containment. Amendments to a PE-certified plan require PE re-certification.
What is the difference between an SPCC plan and a Facility Response Plan (FRP)?
An SPCC plan focuses on preventing and containing discharges and is required for most facilities over the storage threshold. A Facility Response Plan (FRP) is an additional, separate plan required only for larger facilities that could cause substantial harm to the environment from a worst-case discharge. A facility can need both.
