SPCC compliance is not just about paperwork. It is about operational awareness and understanding your obligations before an inspection, or worse, a spill. While that sounds straightforward, a compliant SPCC Plan is not a generic template. It is a site-specific document that reflects your operations, equipment, and the potential risks therein. Regulators expect your plan to demonstrate two things. The first thing is that you’ve evaluated how oil could be released at your facility, and that considerable steps have been taken to prevent it from happening. The second thing is that you have planned to ensure that if a spill does happen, you are prepared to prevent it from reaching and contaminating waterways.

The plan is required to describe your facility layout and identify all oil storage containers, along with their capacities. It also needs to outline spill prevention measures such as equipment design, secondary containment, and standard operating procedures. Just as importantly, it must address drainage patterns, showing how a spill would move across your site and what controls are in place or available to stop it.

Secondary containment is also a central requirement. Facilities must have physical systems capable of containing the contents of their largest container, plus additional capacity to account for precipitation if the oil is stored outdoors. This could include berms, dikes, double-walled tanks, or spill containment pallets, depending on the setup.