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 · B.S. Civil Engineering, Georgia Tech · 15+ years in fuel systems · 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 are in scope: that you store oil, that you are over a capacity threshold, and that a spill could realistically reach waters.
The capacity condition
Capacity is one of the conditions, not a standalone trigger. The capacity condition is met at either of the following, and the facility is only in scope when the oil-storage and discharge-potential conditions above are met as well.
- 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.
Self-certification, Tier I and Tier II, and PE certification
Qualified facilities can self-certify their own plan, in both Tier I and Tier II. The difference between the two tiers is the facility's characteristics, primarily whether any single aboveground container holds more than 5,000 gallons and the plan format that follows from it, not who signs the plan. A facility that does not meet the qualified-facility criteria, including once aggregate aboveground capacity is over 10,000 gallons, needs a plan certified by a licensed Professional Engineer. Either way the plan has to carry secondary containment sized and documented, integrity testing scheduled, and inspections logged. Zambrano Enterprises provides specialized fuel-system design and technical consulting services. When professional engineering review or certification is required, ZE coordinates with appropriately licensed Professional Engineers through established professional relationships nationwide.
Common questions
What is the SPCC capacity condition?
Capacity is one of the conditions, not the whole test. The capacity condition is met when aggregate aboveground oil storage capacity is more than 1,320 US gallons, counting only containers of 55 gallons or larger, or when 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. A facility is only covered once it also stores, uses or transfers oil as a non-transportation-related facility and could reasonably be expected to discharge oil to navigable waters or adjoining shorelines.
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?
Qualified facilities can self-certify their own plan, in both Tier I and Tier II. The difference between the two tiers is the facility's characteristics, primarily whether any single aboveground container holds more than 5,000 gallons, not who signs the plan. A facility that does not meet the qualified-facility criteria, including once aggregate aboveground capacity is over 10,000 gallons, needs a plan certified by a licensed Professional Engineer. Zambrano Enterprises prepares SPCC plans and coordinates Professional Engineer certification when required.
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 are 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?
Send the facility details and tank inventory. Matt will confirm whether you are in scope. Zambrano Enterprises prepares SPCC plans and coordinates Professional Engineer certification when required.