SPCC plan applicability starting conditions

Short answer

For the general SPCC starting test, a non-transportation-related facility that handles oil and could reasonably discharge harmful quantities into navigable waters or adjoining shorelines must check its counted oil-storage capacity. The general thresholds are more than 1,320 US gallons aboveground or more than 42,000 US gallons completely buried. Applicability is addressed in 40 CFR 112.1; 40 CFR 112.3 requires covered owners/operators to prepare and implement a plan.

Count capacity, not today's inventory

For the general aboveground test, count containers with capacity of at least 55 gallons, subject to exclusions. EPA's checklist excludes smaller containers, permanently closed containers, motive-power containers and containers used exclusively for wastewater treatment. The buried-capacity test has its own exclusions, including tanks subject to all technical requirements of Parts 280/281. Farms and other special categories need separate checks.

To apply it

Provide facility use, container types and capacities, applicable exclusions, and the potential discharge path to water. Capacity alone does not establish coverage or which certification option applies. State requirements can add obligations.