EPA Names Most Common SPCC Plan Deficiencies – Do You Have Any of These?

EPA recently reviewed inspection data from its regional offices to get an idea of the most common SPCC (Spill Prevention, Control and Countermeasures) Plan deficiencies. The goal of the review was to help EPA determine how clear their rules were to help companies comply with the regulations. The data was reviewed for companies who had SPCC Plan issues, with a preference for companies with higher oil storage capacity and who also had to have Facility Response Plans (FRPs) onsite as well.

⚡ TL;DR: EPA found that 99% of inspected facilities (119 of 120) had SPCC plan deficiencies, primarily missing five-year reviews, inadequate secondary containment, and incomplete piping management. These gaps expose facilities to penalties averaging $150,000+ and potential environmental liability—conduct a compliance audit of your SPCC plan now.

Inspection data was reviewed for 120 companies with oil storage capacity between 4,000 gallons and 857,000,000 gallons. Of those, 10 companies didn’t have an SPCC Plan. Of the remaining, they found that the companies averaged 4 issues with their plans.

Top 9 SPCC Plan Deficiencies (in Order)

1. Plan Content, Certifications & Reviews (112.3, 112.5, 112.7) – 119 of the 120 had this deficiency
2. General Secondary Containment (112.7)
3. Testing and Inspection: Integrity Testing (112.8, 112.12)
4. Sized Secondary Containment (112.8, 112.9, 112.12)
5. Drainage (112.8)
6. Piping: General (112.8)
7. Piping: Inspections (112.8, 112.9)
8. Discharge Prediction (112.7)
9. PE Certification (112.3)

Some examples of these include:

• Inadequate or no documentation of the required 5-year review of the plan;
• Failure to address required containment for piping;
• Failure to address integrity testing of bulk storage containers;
• Failure to demonstrate that secondary containment met the requisite size of design requirements; and,
• Failure to provide procedures for controlling stormwater discharges from diked areas.

⚠️ What’s at stake: SPCC plan violations result in EPA civil penalties up to $60,000-100,000 per facility, criminal penalties up to $25,000 per day for non-compliance, and potential environmental liability if a spill occurs. An uncontrolled oil discharge triggers mandatory federal notification, damage assessment, and possible facility shutdown pending remediation.

Do you have these issues with your own SPCC plan? Are you required to have an SPCC Plan? Check out our blog about SPCC plans, or contact us today to help. We can review your plan for compliance to these issues, conduct the required 5-year update, or provide the required training you need to conduct to your employees. Contact us today!

Does your SPCC plan actually meet EPA design and certification standards—or is it just filed away without current review? iSi’s environmental compliance team helps petroleum and chemical storage facilities identify and correct the exact deficiencies EPA inspectors find most frequently: secondary containment sizing, integrity testing, piping management, and PE certification. Get started →

Frequently Asked Questions

Q: What are the most common SPCC plan deficiencies identified in EPA inspections?

EPA’s analysis of 120 facilities found that 119 had deficiencies in plan content, certifications, and five-year reviews (40 CFR 112.3, 112.5, 112.7). Other common deficiencies include inadequate secondary containment design and sizing, missing or inadequate integrity testing of bulk storage containers, failures to address containment for piping, inadequate drainage procedures, missing professional engineer certifications, and failure to provide stormwater discharge control procedures. Ten of the 120 facilities had no SPCC plan at all. Facilities averaged four documented compliance issues. iSi Environmental helps facilities correct these common deficiencies through SPCC reviews and updates.

Q: Is documentation of the required five-year SPCC plan review a common compliance issue?

Yes. Inadequate or missing documentation of the required five-year SPCC plan review and update is the most common SPCC deficiency, identified in 119 of 120 inspected facilities. Facilities must document that they reviewed and updated their plans on a five-year cycle. Documentation must include the date of review, findings, updates made, personnel involved, and certification by responsible officers. Failure to document reviews can result in EPA citations even if actual compliance is adequate. iSi Environmental helps facilities maintain compliant SPCC review and update documentation.

Q: What secondary containment requirements are most frequently violated?

EPA found two secondary containment deficiencies: general secondary containment configuration failures and inadequate sizing to meet design requirements. Secondary containment must be sized to hold 110% of the largest tank plus freeboard, be constructed with impermeable materials, have proper drainage (collected and managed as hazardous waste or disposed appropriately), and be inspected and integrity-tested. Facilities must demonstrate that secondary containment meets sizing and design specifications. Piping within secondary containment areas must be addressed in plans. iSi Environmental conducts secondary containment assessments to ensure compliance.

💰 The cost of non-compliance: EPA SPCC violations result in civil penalties of $60,000-100,000 per facility, plus emergency response costs ($50,000-500,000+) if a discharge occurs. Remediation, regulatory fines, and business interruption often exceed $1 million.

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SPCC compliance starts with an honest audit of your plan against EPA’s nine most common deficiency categories. iSi Environmental helps facilities conduct comprehensive SPCC reviews, manage five-year updates, and ensure PE-certified plans that hold up under inspection. Schedule a compliance review →

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