SPCC plans for fuel jobbers: the 1,320-gallon rule and secondary containment

If you store more than 1,320 gallons of oil in aboveground tanks and containers at a single facility, EPA's SPCC rule says you need a written Spill Prevention, Control, and Countermeasure plan before you can operate. Gasoline, diesel, biodiesel, lube oil, and used oil all count as oil. The good news for most jobbers with a bulk plant: if your total aboveground capacity is 10,000 gallons or less and you meet a clean spill-history test, you can write and sign the plan yourself without paying a professional engineer.

The number that triggers a plan: 1,320 gallons

The SPCC rule lives in 40 CFR Part 112. It applies to non-transportation facilities that could reasonably discharge oil into navigable waters or nearby shorelines, which covers just about any bulk plant, cardlock, or tank farm in the country. The threshold that pulls you in is 1,320 gallons of aggregate aboveground oil storage capacity. That is capacity, not what happens to be in the tank today. A 2,000-gallon tank sitting half empty still counts as 2,000 gallons.

One separate line covers buried tanks. If your completely buried storage capacity tops 42,000 gallons, that triggers a plan too. Most jobbers hit the 1,320 aboveground number long before they get near the buried figure.

What actually counts toward the 1,320

You add up every aboveground container that holds oil, but only those with a capacity of 55 gallons or more. The 55-gallon-and-up rule keeps your quart cans of two-stroke and your grease tubes out of the math. Almost everything else at a working plant is in play:

• Bulk fuel tanks. Gasoline, diesel, kerosene, heating oil, ethanol-blended product.
• Lube and used oil. The 250-gallon used-oil tank behind the shop and any bulk lube storage.
• Ancillary containers. Totes, drums 55 gallons and larger, and oil-filled equipment like hydraulic reservoirs and some transformers.
• Tank trucks parked at the plant. A transport truck in transit is transportation-related and exempt, but a mobile refueler stationed at your facility can count toward capacity, so know how EPA treats your fleet.

Propane and other liquefied petroleum gases are not oil under this rule, so an LP bobtail or a bulk propane tank does not count toward your 1,320. Propane carries its own NFPA 58 and state fire-marshal requirements instead. If you run both fuels, our guide to propane and LP-gas distribution covers where those rules sit.

Can you sign it yourself? Tier I and Tier II

By default an SPCC plan has to be reviewed and certified by a licensed professional engineer. EPA carved out a self-certification path for smaller sites it calls qualified facilities. You qualify on capacity and on spill history:

• Capacity. Total aggregate aboveground oil storage of 10,000 US gallons or less.
• Spill history. In the three years before you certify, no single discharge to water over 1,000 gallons, and no two discharges each over 42 gallons within any twelve-month period.

Meet both and you can self-certify. Which template you use then depends on your largest tank. If no single container is larger than 5,000 gallons, you are a Tier I facility and you can fill out EPA's streamlined Appendix G form and sign it. If you are under 10,000 gallons total but have at least one container over 5,000 gallons, you are Tier II: you still self-certify, but you prepare a full-format plan instead of the short template. Over 10,000 gallons total, or with a spill history that fails the test, and you are back to needing a PE stamp.

Secondary containment: the 110% rule

The heart of the plan is keeping a spill from reaching water. For your bulk tanks that means sized secondary containment, usually a dike, berm, or lined basin around the tank. The rule is that containment has to hold the volume of the largest single container in that area, plus enough freeboard to catch rain.

In practice engineers size the wall to about 110% of the largest tank: the full tank volume plus 10% for precipitation. So a 12,000-gallon diesel tank needs a containment area good for roughly 13,200 gallons. Note it is the largest tank, not the sum of every tank inside the dike. Where you load and unload, you also need containment or a way to catch drips at the truck connection, and a plan for how you close a drainage valve so rainwater does not carry oil out of the dike untreated.

What the plan has to say, and the records behind it

A plan is a working document, not a binder you file once. It describes each tank and its contents, the containment around it, your loading and unloading procedures, your inspection schedule, spill response steps, and who to call. You keep it at the facility (or at the nearest field office for an unattended site) and make it available to EPA on request. You do not mail it in for approval. You review and update it at least every five years, and you amend it whenever you add a tank or change the layout in a way that matters.

The part that trips people up is the ongoing evidence: monthly and annual tank inspections, integrity testing on schedule, and dated records that a spill got cleaned up and a drainage valve got closed. Inspectors look for the logs, not just the plan. Keeping those inspection records, tank details, and dates in one place instead of a clipboard in the shop is exactly the kind of back-office housekeeping FastDragon is built to hold alongside your fuel and accounting data. However you track it, missing records are the most common finding, so build the habit before an inspector asks.

Where this sits in the bigger compliance picture

SPCC is federal and it is about spills reaching water. It sits next to a stack of other tank rules you already live with: state aboveground storage tank programs, fire-marshal permits, and the tax and product-accounting side of moving fuel. If you are weighing a plant purchase, containment and an up-to-date SPCC plan belong on the diligence list right beside the tanks and the supply contract, which is one reason we flag them in buying or selling a fuel jobber business. And if you are still sorting out where a bulk plant fits against terminals and stations, start with what a fuel jobber actually does.

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