Do I need an SPCC plan?
Answer four quick questions to see whether your facility falls under the federal Spill Prevention, Control, and Countermeasure rule — and what to do about it.
Question 1 of 4
Does the facility store oil of any kind?
Fuel, diesel, gasoline, heating oil, motor oil, hydraulic oil, lubricants, or used oil all count.
Written by Matt Zambrano
Managing Member · Georgia Tech engineer · 15+ years in petroleum bulk storage · Updated June 2026
How the SPCC test actually works
SPCC is a federal rule under 40 CFR Part 112, enforced by the EPA. It applies to non-transportation-related facilities that store oil and that, because of their location, could reasonably discharge oil into navigable waters or adjoining shorelines. Three things decide whether you're in scope: that you store oil, that you're over a capacity threshold, and that a spill could realistically reach waters.
The thresholds
- More than 1,320 gallons aggregate aboveground capacity (counting only containers 55 gallons or larger), or
- More than 42,000 gallons of completely buried oil storage not otherwise regulated as USTs.
Tier I, Tier II, or PE-certified
Qualifying smaller facilities can often self-certify a streamlined Tier I or Tier II plan. Larger facilities — generally those over 10,000 gallons aggregate aboveground — need a plan prepared and certified by a Professional Engineer, with secondary containment sized and documented, integrity testing scheduled, and inspections logged.
Common questions
What is the SPCC capacity threshold?
A facility needs an SPCC plan if its aggregate aboveground oil storage capacity is more than 1,320 US gallons, counting only containers of 55 gallons or larger, or if completely buried storage exceeds 42,000 gallons. Capacity is measured by the container's shell size, not by how much oil is actually in it.
Does the type of oil matter?
No. SPCC covers all kinds of oil — petroleum fuels, diesel, gasoline, heating oil, motor and hydraulic oils, used oil, and even animal and vegetable oils. Oil-filled equipment like transformers and hydraulic systems counts toward your total.
Who has to certify the plan?
Facilities over 10,000 gallons of aggregate aboveground capacity (or with certain spill history) must have the plan certified by a licensed Professional Engineer. Smaller, qualifying facilities may be able to self-certify a Tier I or Tier II plan.
How fast can a plan be put in place?
For a straightforward site, a compliant plan can usually be prepared in a couple of weeks. If you're already operating without one, that timeline matters — operating an oil-storage facility without a required SPCC plan is itself a violation.
Need an SPCC plan prepared and certified?
Send the facility details and tank inventory. Matt will confirm whether you're in scope and prepare a plan that holds up to inspection.