Bulk oil storageAuthored by Genevieve Reynolds, Senior Project Manager, The Vertex Companies, Inc. (VERTEX) – Spill Prevention, Control, and Countermeasures (SPCC) Plans are required under §311 of the Clean Water Act. The SPCC Plan includes information about oil storage at a facility, including spill prevention practices, and provides guidelines for spill response and containment.

SPCC plans are required at facilities with oil storage capacity greater than 1,320-gallons (abovegrade storage in containers of 55-gallons or above) or 42,000-gallons (belowgrade) where there is a reasonable expectation of a potential oil discharge to the navigable waters of the United States. Plans may be required at a wide variety of facilities, including automotive maintenance shops, food processing plants, oil storage depots, airport fueling facilities, facilities with diesel storage for emergency generators, and even colleges and universities.

SPCC plans include secondary containment requirements, facility inspections and recordkeeping requirements, procedures for oil transfers, and personnel training requirements.

Certain facilities may be able to self-certify their SPCC plan if they meet certain requirements regarding oil storage capacity and previous spills. If the facility does not meet these requirements, the plan must be certified by a licensed Professional Engineer (PE). 

VERTEX’s initial compliance assessments during the Due Diligence phase include the assessment of existing SPCC plans.


  • SPCC plans need to include all oils stored at a property– not just petroleum-based oils. This means that sites with food-grade oils such as soybean oil in containers of 55-gallons or greater may need to maintain SPCC plans.
  • SPCC plans may also need to include equipment, such as hydraulic presses or pad-mounted transformers, if the oil storage capacity of the equipment is greater than 55-gallons.
  • The need for an SPCC plan is judged by potential storage capacity – not actual storage. A site with three 500-gallon oil storage ASTs will still need an SPCC plan – even if one of them is out of use.

Genevieve Reynolds, Senior Project Manager at VERTEX, has over a decade of experience performing environmental consulting including Phase I Environmental Site Assessments (ESAs), Phase II ESAs, and other environmental consulting services. For more information on environmental consulting services or to schedule a training for your office on this or other topics, please contact us