The SPCC rule (40 CFR part 112) requires facilities that store meaningful quantities of oil to prepare and implement a plan to prevent discharges from reaching navigable waters. In the Permian Basin, that sweeps in a large share of tank batteries, produced-fluid storage, and fuel storage at yards and facilities.
The Thresholds That Matter
- Aggregate aboveground oil storage greater than 1,320 U.S. gallons — counting only containers of 55 gallons or larger.
- Or completely buried storage capacity greater than 42,000 U.S. gallons.
- Plus a reasonable expectation that a discharge could reach navigable waters or adjoining shorelines.
- Self-certification tiers: 10,000 gallons aggregate or less with a qualifying discharge history (Tier I additionally requires no single container over 5,000 gallons).
The Checklist
Confirm applicability
Add up aboveground oil storage counting every container of 55 gallons or larger — tanks, drums, totes, oil-filled equipment. Over 1,320 gallons aggregate (or over 42,000 gallons completely buried) with a reasonable path for a discharge to reach navigable waters means the rule applies.
Determine your facility tier
10,000 gallons or less in aggregate with a clean discharge history qualifies the facility for self-certification: Tier I (no single container over 5,000 gallons) can use the EPA Appendix G template; Tier II self-certifies a full-format plan. Larger facilities need a Professional Engineer to certify the plan.
Provide secondary containment
Bulk storage containers need containment sized for the largest single container with sufficient freeboard for precipitation — dikes, berms, or remote impoundment. Transfer areas and oil-filled equipment need appropriate general containment.
Set inspection and testing routines
Document routine visual inspections of tanks, containment, and valves, plus integrity testing where required. Keep the records with the plan — inspections you cannot document did not happen, as far as an inspector is concerned.
Train personnel and designate a coordinator
Oil-handling personnel need discharge prevention briefings, and the plan should name who is accountable for spill prevention at the facility.
Keep the plan alive
Review at least every five years, amend when the facility changes materially, and keep the plan on site (or at the nearest field office for unattended facilities) where it can be produced on request.
Disclaimer: This checklist is general information, not legal or engineering advice. Applicability and plan requirements are facility-specific — verify against EPA's SPCC applicability guidance and 40 CFR part 112.
Quick Answers
Which facilities need an SPCC plan?
A non-transportation-related facility needs an SPCC plan when its aggregate aboveground oil storage capacity exceeds 1,320 U.S. gallons (counting only containers of 55 gallons or larger) — or its completely buried storage exceeds 42,000 gallons — and it could reasonably be expected to discharge oil in harmful quantities into navigable waters or adjoining shorelines.
What is a Tier I qualified facility?
A facility with aggregate aboveground oil storage of 10,000 U.S. gallons or less, no single aboveground container larger than 5,000 gallons, and a qualifying discharge history. Tier I facilities may complete the streamlined self-certified plan template in 40 CFR part 112, Appendix G, instead of a full PE-certified plan.
What is the difference between Tier I and Tier II?
Both have 10,000 gallons or less in aggregate aboveground storage and meet the discharge history criteria. Tier II facilities have at least one container larger than 5,000 gallons — they may self-certify a full-format plan, while Tier I facilities (no container over 5,000 gallons) can use the simpler Appendix G template.
How often must an SPCC plan be reviewed?
The plan must be reviewed at least once every five years, and amended when the facility changes in a way that materially affects its potential to discharge oil (new tanks, changed containment, different products). Amendments generally require re-certification.