SPCC Plans (40 CFR 112) & Facility Response Plans
SPCC Plan development, Tier I and Tier II qualified-facility plans, Facility Response Plans (FRPs), 5-year reviews, and personnel training under 40 CFR 112 for facilities with bulk oil storage.
Capabilities
Spill Prevention, Control, and Countermeasure plan development
Secondary-containment evaluation
Aboveground storage tank compliance
Plan certification support
Frequently asked questions
Does my facility need an SPCC plan?
Under 40 CFR 112, you need an SPCC plan if your aggregate aboveground oil storage capacity exceeds 1,320 gallons (or completely buried storage exceeds 42,000 gallons) and there is a reasonable expectation that a discharge could reach navigable waters or adjoining shorelines. 'Oil' is broad — fuels, lubricants, hydraulic oil, transformer oil, and many others count toward the threshold.
What's the difference between a Tier I, Tier II, and PE-certified plan?
Qualified facilities (generally 10,000 gallons or less aggregate aboveground capacity with a clean discharge history) may self-certify: Tier I uses EPA's template when no single container exceeds 5,000 gallons; Tier II covers more complex qualified facilities. Facilities above those thresholds need a plan certified by a licensed Professional Engineer. SafetyNet scopes the correct tier and coordinates PE certification when the rule requires it.
What is a Facility Response Plan (FRP), and do I need one?
Under 40 CFR 112.20, facilities that could cause 'substantial harm' from a discharge must also prepare a Facility Response Plan and submit it to EPA. It's a separate, more detailed document than the SPCC plan. We evaluate the substantial-harm criteria and prepare the FRP when it applies.
How often must the SPCC plan be reviewed and updated?
The plan must be reviewed at least once every five years and amended within six months if the review identifies needed changes. It must also be amended whenever there's a material change in facility design, construction, operation, or maintenance that affects discharge potential. The rule additionally requires recurring container inspections and employee training.
What are the penalties for non-compliance?
SPCC is enforced under the Clean Water Act, where civil penalties can accrue per day and per violation. An actual discharge without a compliant plan compounds liability substantially, on top of cleanup costs and potential third-party claims.