SPCC plan template › SPCC review and amendments
SPCC 5-year review and plan amendments
Amend your SPCC plan within six months of any change that materially affects your potential for a spill, and put the change in place within six months after that. Separately, review the whole plan at least every five years and sign a short statement saying whether you'll amend it. At a qualified facility the owner certifies amendments; otherwise a PE does.
The clocks at a glance
| Trigger | Prepare by | Implement by | Rule |
|---|---|---|---|
| A change that materially affects spill potential | 6 months after the change | As soon as possible, at most 6 months after the amendment | 112.5(a) |
| Five-year review | At least every 5 years; any resulting amendment within 6 months of the review | At most 6 months after the amendment | 112.5(b) |
| EPA's Regional Administrator requires an amendment | 30 days after the final notice, unless EPA sets another date | At most 6 months after amending, unless EPA sets another date | 112.4(d)–(e) |
| A Tier I site outgrows Tier I | Tier II or PE-certified plan within 6 months following preparation of the amendment | 112.6(a)(2) | |
| A Tier II site goes over 10,000 gal | PE-certified plan prepared and implemented within 6 months following the change | 112.6(b)(2)(ii) | |
What counts as a change
The rule's examples: commissioning or decommissioning containers; replacing, rebuilding or moving them; rebuilding, replacing or installing piping; construction or demolition that could alter containment; changing the product or service; and revising standard operating or maintenance procedures. Adding a 500-gallon tank, switching a tank from diesel to used oil, or paving over a drainage path all qualify.
The rule ties an amendment to changes that affect spill potential. A new phone number or a new name on the contact list doesn't, so it isn't a technical amendment needing certification, but update the plan anyway: an out-of-date contact list costs time in a real spill.
Who certifies an amendment
- Tier I: the owner or operator re-certifies, using the same eight-point statement as the plan (112.6(a)(2)). EPA's template has a Technical Amendment Log (Attachment 1.2) for this.
- Tier II: the owner or operator, except that if a PE certified part of the plan (an alternative measure or an impracticability finding) and the change touches that part, a PE re-certifies it (112.6(b)(2)(i)).
- PE-certified plans: a PE certifies every technical amendment (112.5(c)). EPA's answer on this: the PE inspects and certifies only the amended portion, not the whole plan.
Re-certifying means stating again that the facility meets the qualification criteria. The spill-history test looks back three years from the date you certify, so a spill that reached water since your last signature matters the next time you sign. If you're unsure whether you still qualify, ask your EPA regional office before you sign.
The five-year review
Review and evaluate the whole plan at least once every five years, counted from when your facility became subject to the rule (or, for a facility operating on or before August 16, 2002, from the last review the rule required). As part of it, look for "more effective prevention and control technology" that is field-proven and would significantly reduce the chance of a spill; if there is some, amend the plan within six months to include it.
Then document it. The rule gives the words, which you sign at the beginning or end of the plan or in a log:
EPA's template has a Five Year Review Log for it (Attachment 1.1). A review that finds nothing to change still needs the signed statement. EPA has also answered that a PE doesn't need to review a plan that hasn't changed: the owner documents the review and decides whether any change needs a technical amendment.
What to look at in a review
- Container list and diagram against what's on the ground today.
- Total capacity and largest container: are you still in the same tier?
- Spill history for the last three years.
- Containment sizing, especially if a tank or the dike changed (see secondary containment).
- Inspection records and the schedule's industry standard: still current, and actually followed?
- Training and briefing logs, the accountable person, the contact list.
- Newer, field-proven equipment, such as better overfill alarms or double-walled replacements.
- State rules that changed since the last review.
An example timeline
A Tier I contractor's yard became subject to the rule and signed its plan on March 1, 2024.
Mar 1, 2024 Plan certified; review clock starts Jun 10, 2026 New 1,000-gal diesel tank installed (total 3,210 gal) Dec 10, 2026 Latest date to prepare and self-certify the amendment (if prepared Oct 1, 2026: implement by Apr 1, 2027) Mar 1, 2029 Five-year review due; sign the review statement Mar 1, 2034 Next review due
The new tank keeps the yard under 5,000 gallons in any container and 10,000 in total, so it stays Tier I. Had the owner added a 6,000-gallon tank instead, the yard would need a Tier II plan within six months of preparing the amendment (see Tier I vs Tier II).
After a reportable spill
If the facility discharges more than 1,000 gallons to water in one event, or more than 42 gallons in each of two events within 12 months, send EPA's Regional Administrator the information listed in 112.4(a) within 60 days, and a copy to the state agency. EPA may then require an amendment: you get 30 days to comment on the proposed change, and once EPA gives final notice you have 30 days to amend. How to report the spill itself is in spill response and contacts.
ePlan redrafts a qualified facility's plan from an updated tank list; you still review the change, date it and certify it yourself.
Questions
How often does an SPCC plan need to be updated?
Within six months of any change that materially affects spill potential, and reviewed at least every five years even if nothing changed.
Does an SPCC plan expire?
No. It stays in force as long as it's current, amended when needed and reviewed at least every five years.
Does the five-year review need a PE?
No. The owner or operator documents the review. A PE is needed only if the review leads to a technical amendment of a PE-certified plan or PE-certified section.