SPCC Plan Development

What the SPCC Rule Actually Requires

The Spill Prevention, Control, and Countermeasure (SPCC) rule, codified at 40 CFR Part 112, applies to any facility that stores oil above threshold quantities and has a reasonable potential to discharge to navigable waters or adjoining shorelines. For most Texas upstream operators, that means the rule applies.

SPCC compliance means having a written plan that documents your oil storage containers, secondary containment systems, inspection procedures, and emergency response protocols. For facilities that exceed the Qualified Facility threshold, the plan must be certified by a licensed Professional Engineer (PE). EPA Region 6 and the Railroad Commission of Texas both enforce the rule, and fines for inadequate or outdated plans can reach tens of thousands of dollars per day per violation.

What We Deliver

Tektite develops SPCC plans that meet the specific requirements of your facility and hold up under regulatory scrutiny. Every plan we produce includes a thorough on-site assessment to capture accurate storage volumes, tank configurations, secondary containment dimensions, and drainage pathways. We do not work from templates.

Initial SPCC Plan Development: Full plan written to 40 CFR Part 112 requirements, including facility diagrams, oil discharge potential analysis, containment design verification, and inspection and training procedures.
PE Certification: We provide the mandatory Professional Engineer certification for Tier II qualified facilities, confirming the plan was prepared in accordance with sound engineering practice.
Five-Year Reviews: The rule requires a PE review at least every five years. We conduct the review, update the plan to reflect operational changes, and re-certify.
Amendment Support: Any material change to your facility (new tanks, modified drainage, changed oil storage volumes) triggers an amendment requirement. We identify those triggers and handle the update.
SPCC Compliance Audits: If you already have a plan, we audit it for accuracy and regulatory completeness before an inspector does.

SPCC Compliance in Texas

Texas operators face dual regulatory oversight. EPA Region 6 enforces the federal SPCC rule, while the Railroad Commission of Texas enforces its own spill reporting requirements under Statewide Rule 91. An SPCC plan that addresses federal requirements but overlooks RRC reporting thresholds is still a compliance gap. Tektite writes plans that satisfy both frameworks.

SPCC compliance in Texas also intersects with TCEQ stormwater permitting and NPDES discharge requirements. We account for these overlapping obligations during plan development so your documentation does not create contradictions across permit records.

Frequently Asked Questions

Does my facility need an SPCC plan?

If your facility stores oil (crude oil, refined products, produced water with oil content) in aggregate quantities above 1,320 gallons aboveground, or above 42,000 gallons underground, and has a reasonable potential to discharge to navigable waters, the SPCC rule applies. Most Texas upstream production facilities meet this threshold. We can confirm applicability during an initial consultation.

How often does an SPCC plan need to be updated?

A PE review is required at least every five years. In addition, any material change to the facility (new or modified storage tanks, changes to secondary containment, changes in oil storage volume, new drainage configurations) requires a plan amendment and PE re-certification before the change is implemented.

What is SPCC compliance and how do we demonstrate it?

SPCC compliance means your facility has a current, PE-certified plan that accurately reflects your operations, your employees have been trained on it, and you maintain complete inspection records. During an inspection, regulators will review the plan document, your containment structures, and your inspection logs. All three need to be consistent and current.

We already have an SPCC plan. Do we need a new one?

Not necessarily. We can audit your existing plan to determine if it is current, accurate, and complete. In many cases, an amendment or targeted update is sufficient. We will tell you honestly what is needed rather than defaulting to a full redraft.