If your facility can store more than 1,320 gallons of oil aboveground — counting every container of 55 gallons or larger, at shell capacity, full or empty — and a spill could reasonably reach navigable waters, federal rule 40 CFR Part 112 requires a Spill Prevention, Control, and Countermeasure plan. Twenty-four drums is enough to cross the line.
Three tests, all must be true. First, the facility drills, produces, stores, processes, uses, or consumes oil and is non-transportation-related. Second, aggregate aboveground storage capacity exceeds 1,320 gallons (or completely buried capacity exceeds 42,000 gallons) — counting only containers of 55 gallons or more. Third, a discharge could reasonably be expected to reach navigable waters or adjoining shorelines — and “reasonably” is read broadly: storm sewers, ditches, and drainage paths count. “Oil” is equally broad: diesel and gasoline, hydraulic and lube oil, oil-filled transformers and equipment, even vegetable oil.
Shell capacity, not contents — a 2,000-gallon tank that’s never more than half full still counts as 2,000 gallons, and an empty tank counts until it’s properly decommissioned. Drums, totes, and IBCs of 55 gallons or more all count, which is how maintenance shops and fleet operations cross the threshold without ever installing a “tank”: twenty-four 55-gallon drums is 1,320 gallons. Add the diesel for the backup generator, the hydraulic reservoirs on big equipment, and the used-oil collection, and a surprising share of ordinary industrial facilities are covered facilities that have never written a plan.
For facilities with 10,000 gallons or less, no single container over 5,000 gallons, and a clean recent spill history: the EPA template plan, self-certified by the owner/operator. The lightest lift — if you honestly qualify.
Same eligibility as Tier I but written to the general rule requirements instead of the template — more flexibility for facilities whose configuration doesn’t fit the template’s boxes.
Everyone else — over 10,000 gallons, a large container, or a disqualifying spill history — requires a plan reviewed and certified by a licensed Professional Engineer, with the engineering (secondary containment sized to the largest container plus precipitation) to match.
An SPCC plan is a living document: reviewed and re-evaluated at least every five years, amended when the facility changes — new tanks, moved containers, changed drainage — with inspections and personnel training conducted and documented on the plan’s schedule. And a qualified facility that has a significant discharge loses its self-certification eligibility and must obtain PE certification within six months. This is exactly the calendar-and-conditions work that dies when environmental compliance is a side duty — the argument made in full on the fractional environmental manager page. Verify your specific applicability against the current rule text and your state’s requirements — this page is orientation, not certification.
More than 1,320 gallons of aggregate aboveground oil storage capacity in containers of 55 gallons or larger — measured at shell capacity, regardless of how full the containers are — or more than 42,000 gallons of completely buried storage.
Yes — every container of 55 gallons or more counts at full capacity. Twenty-four standard drums alone reach the 1,320-gallon threshold, which is how shops without any bulk tank end up covered.
Full plans do. Qualified facilities — 10,000 gallons or less, no container over 5,000 gallons, and a clean recent spill history — may self-certify under Tier I (EPA template) or Tier II (general requirements) instead.
At least every five years, plus amendment whenever the facility changes in a way that materially affects spill potential — new or relocated storage, changed drainage, modified containment.
Walk your site counting shell capacity — tanks, drums, totes, equipment reservoirs — and if the number is anywhere near 1,320, the applicability conversation is worth thirty minutes before a regulator or insurer has it for you.
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