How to Fill Out the Spill Prevention Control and Countermeasure Plan + FAQs

The Spill Prevention, Control, and Countermeasure (SPCC) Plan is a written document that the U.S. Environmental Protection Agency (EPA) requires from facilities that store oil above set limits, so they can prevent oil from reaching rivers, lakes, and shorelines. You must prepare and follow this Plan if your facility stores more than 1,320 gallons of oil aboveground (or more than 42,000 gallons underground), is not a transportation operation, and could reasonably spill oil into nearby waters.

If your facility is small and has a clean spill record, you may not need a costly engineer. You can fill out the EPA’s free Tier I Qualified Facility SPCC Plan Template and sign it yourself. EPA estimates that hundreds of thousands of facilities across the country fall under this rule, and a single missed requirement can lead to federal penalties that climb past $25,000 per day, which is why getting each box right matters.

Here is what you will learn in this guide:

• 🛢️ How to know if your facility must file an SPCC Plan and which tier fits you
• 📋 A line-by-line walkthrough of every section, table, and box on the EPA template
• 👷 Who can self-certify and when you must hire a Professional Engineer
• 🗂️ The exact documents and numbers to gather before you start writing
• ⚠️ The most common mistakes that trigger EPA fines and how to dodge them

This guide uses the EPA Tier I Qualified Facility SPCC Plan Template, version dated 3-18-10 (printed as Ver. 1-L-doc-3-18-10 on each page), which mirrors Appendix G of 40 CFR Part 112. Check that you have this version before you start.

What the SPCC Plan Is and Who Must File It

The SPCC Plan is a spill prevention document required by the EPA under the Clean Water Act and detailed in 40 CFR Part 112. It is not a one-page form you mail in. It is a full written plan that you keep on site, sign, and put into action. The plan describes your tanks, your secondary containment, your inspection routine, and the steps your team takes the moment oil spills.

You must prepare an SPCC Plan if your facility meets all three of these tests. First, your facility is non-transportation-related, meaning it is a fixed site and not a pipeline, truck, or vessel in transit. Second, your aboveground oil storage capacity is more than 1,320 gallons, or your completely buried storage is more than 42,000 gallons, counting only containers that hold 55 gallons or more. Third, the facility could reasonably be expected to discharge oil into navigable waters or adjoining shorelines, as explained by EPA on its SPCC qualified facility page.

The agency that receives and enforces this rule is the EPA, through its Regional Administrator. The statute behind it is Section 311 of the Clean Water Act, carried out through 40 CFR Part 112. The deadline is firm: a facility that started operating after August 16, 2002, must have a Plan in place before it begins handling oil, and existing facilities must keep one current at all times. The penalty for ignoring this rule is steep, since EPA can assess civil fines of more than $25,000 for each day a violation continues.

There are two streamlined tiers for smaller sites. A Tier I qualified facility has 10,000 gallons or less of total aboveground oil storage, no single aboveground container larger than 5,000 gallons, and a clean three-year spill record. A Tier II qualified facility also stays at or below 10,000 gallons with the same clean record but may have a single tank over 5,000 gallons. Both tiers let the owner self-certify, while larger or higher-risk sites must use a Professional Engineer.

Before You Start: Documents and Information You Need

Filling out the template goes faster when you gather your facts first. Walking your site once with a clipboard saves hours of guessing later. Here is the pre-filing checklist of everything to collect before you open the template.

• Total aboveground oil storage capacity. You need the shell capacity of every container 55 gallons or larger, because this number decides if you even qualify, and a wrong total can push you out of Tier I eligibility.
• A list of each oil container. Note the type of oil and gallon size for each tank, drum, tote, and oil-filled machine, since the template’s Table G-2 demands a complete inventory and a missing tank makes the Plan invalid.
• Your three-year spill history. You must confirm no single spill over 1,000 gallons and no two spills over 42 gallons each in any 12-month window reached water, because any such spill disqualifies you from self-certifying.
• A facility diagram or site sketch. A simple map showing where tanks sit relative to drains and water helps you complete the discharge-flow columns, and inspectors expect to see one.
• Secondary containment details. Measure the dikes, berms, or curbing around each tank, because Table G-4 asks for containment capacity in gallons and missing this leaves a key box blank.
• Owner and facility contact information. Have the legal facility name, full address, county, and phone ready, since a mismatch between owner and facility records can confuse an inspector.
• The name of your discharge-prevention person. You must name one accountable person, because the rule under §112.7(f) requires it and an empty name line is a citable gap.
• Inspection and testing procedures. Write down how and how often you check tanks and piping, because the Plan must reference a written inspection program and “we look sometimes” will not pass.
• Emergency contact numbers. Collect your cleanup contractor, local fire, police, hospital, and state agency numbers for the contact list, since you will not have time to find them during a real spill.

If any single item is missing when an inspector visits, the Plan can be judged incomplete, and an incomplete Plan is treated like no Plan at all.

Where to Get the Form and How to Access It

The EPA hosts the official template for free, so you never need to buy one. Download the fillable Tier I Qualified Facility SPCC Plan Template directly from the EPA website as a PDF. The same page links to completed example Plans you can study before you start your own.

You can complete the template two ways. You may type into the PDF on a computer and save it, or you may print it and write by hand in ink. Either way, the finished, signed document is your SPCC Plan, so there is no separate form to submit to the EPA in normal cases.

If your facility is not a Tier I qualified facility, you use a different path. A Tier II facility prepares a Plan that meets the §112.6(b) requirements, while a non-qualified facility must use a Plan reviewed and stamped by a licensed Professional Engineer. Confirm your tier first using EPA’s qualified facility guidance, because using the wrong template wastes time and can leave required elements uncovered.

Note one state catch. Some states do not allow self-certification and require a PE for every Plan. In California, for example, facilities also fall under the state’s Aboveground Petroleum Storage Act (APSA), so check your state rules before you sign your own Plan.

Step-by-Step: How to Fill Out the Tier I SPCC Plan Template Line by Line

The template is organized into a Facility Description header, three required sections (I, II, and III), one of three facility-type sections (A, B, or C), and several attachments. Work through them in order. Every box below tells you what it asks, how to answer, an example, an edge case, a common mistake, and a myth to drop.

Facility Information Block (Section I header)

This block sits at the top of Section I and asks for your Facility Name, Facility Address, City, State, ZIP, County, Tel. Number, and the matching Owner or Operator Name and address.

To answer it, write the legal name of the facility exactly as it appears on your business records, then fill the full street address with no abbreviations that could confuse a responder. Use the format the boxes show, such as a 10-digit phone number in the () -____ pattern.

For example, Green Valley Farm, located at 4820 County Road 12, Modesto, CA 95358, Stanislaus County, (209) 555-0142, lists owner Green Valley Farm LLC at the same address.

A common edge case is a facility with no street address, such as a rural pump site. Here you write a clear location description, like “NE corner of County Road 12 and Highway 99,” so first responders can find it.

A frequent mistake is leaving the County line blank because it feels minor. The county tells the EPA Region and state agency which office handles your area, and a blank line slows any spill report to the wrong desk.

People often believe the owner and operator must be the same entity. They do not have to match; a landlord may own the site while a tenant operates it, and you list both honestly.

Section I — Self-Certification Statement (§112.6(a)(1))

This section asks you to swear that eight specific statements about your facility and your Plan are true, then sign your name. It is the legal heart of the document.

To answer it, read each of the eight numbered statements and confirm each one fits your facility before you sign. The key items are that your aggregate aboveground capacity is 10,000 U.S. gallons or less, you have had no single spill over 1,000 gallons and no two spills over 42 gallons each in any 12-month period during the last three years, and no single container is larger than 5,000 gallons.

For example, Tom Reyes, owner of a small fuel depot with 6,500 gallons of total aboveground storage and a clean spill record, signs the statement, prints his name and title, and dates it 06 / 03 / 2026.

An edge case is a facility less than three years old. Here you certify a clean record only “since becoming subject to” the rule, not a full three years, which the statement allows.

A serious mistake is signing the certification when one tank actually holds 6,000 gallons. That single container over 5,000 gallons disqualifies you from Tier I, and a false certification is itself a violation that can trigger penalties.

Many filers think self-certifying means the EPA pre-approves their Plan. It does not; self-certification simply shifts responsibility to you, and the EPA can still inspect and cite the Plan at any time.

Section II — Record of Plan Review and Amendments (§§112.5, 112.6(a)(2))

This section records your promise to review the Plan at least every five years and to amend it within six months whenever the facility changes in a way that affects spill potential.

To answer it, you do not write much here at the start; you confirm you understand the review duty and you log future reviews and amendments in Attachments 1.1 and 1.2 as they happen. Note that adding a tank, changing the oil stored, or rebuilding containment all count as material changes.

For example, when Green Valley Farm adds a 1,000-gallon diesel tank in 2027, the owner records the change in the Technical Amendment Log within six months and re-signs.

An edge case is a facility that grows past Tier I limits. If a change pushes you over 10,000 gallons or adds a tank over 5,000 gallons, you must move to a Tier II Plan or a PE-certified Plan, not just amend.

A common mistake is treating the five-year review as optional paperwork. Skipping it is a standalone violation, and inspectors check the review log date first.

People often assume an amendment can wait until the next five-year review. It cannot; material changes require an amendment within six months, regardless of where you are in the review cycle.

Section III, Item 1 — Oil Storage Containers and Table G-2 (§112.7(a)(3)(i))

This item, completed through Table G-2 (Oil Storage Containers and Capacities), asks for a complete list of every oil container of 55 gallons or more, marked as aboveground (A) or completely buried (B), with the type of oil and shell capacity in gallons.

To answer it, list each tank, drum, tote, and oil-filled equipment item on its own row, enter the oil type, and write the shell capacity. Then total the Total Aboveground Storage Capacity, the Total Completely Buried Storage Capacity, and the Facility Total Oil Storage Capacity at the bottom.

For example, Green Valley Farm lists a row reading Diesel AST (A), Diesel, 2,000 and another reading Motor Oil Drum (A), Lubricating Oil, 55, then sums an aboveground total of 4,055 gallons.

An edge case is mobile or portable containers. The rule lets you give an estimated count, the oil types, and anticipated capacities instead of listing each one separately.

A costly mistake is forgetting oil-filled operational equipment like transformers or hydraulic units. These count toward your capacity, and leaving them off can understate your total and hide a missing containment requirement.

A common myth is that buried tanks never count. Buried tanks do not count toward your Tier I 10,000-gallon eligibility number, but they are still subject to the rule and must be listed and addressed in the Plan.

Section III, Item 2 — Secondary Containment and Table G-4 (§§112.6(a)(3), 112.7(c))

This item, with Table G-3 and Table G-4 (Containers with Potential for an Oil Discharge), asks you to describe how you stop a spill from leaving each tank and reaching water.

To answer it, list each area, the type of failure (the discharge scenario), the potential discharge volume in gallons, the direction of flow if uncontained, the secondary containment method, and the containment capacity in gallons. Choose a containment method from the rule’s list, such as dikes, berms, curbing, or sorbent materials.

For example, Green Valley Farm enters Diesel AST, tank rupture, 2,000, toward east drainage ditch, earthen dike, 2,300 gallons, showing the dike holds the full tank plus rainfall room.

An edge case is oil-filled operational equipment without containment. The rule lets you use an oil spill contingency plan instead of containment for qualified oil-filled equipment under §112.7(k), which you document in this table.

A frequent mistake is sizing containment to only the tank volume. For bulk containers, containment must hold the largest container plus extra capacity for rainfall, and a dike with no freeboard fails the test.

People often think gravel under a tank counts as containment. Bare gravel is not impervious, so oil soaks through, and it does not meet the secondary containment standard on its own.

Section III, Item 3 — Inspections, Testing, Recordkeeping and Training, Table G-5 (§§112.7(e), (f))

This item, captured in Table G-5, asks you to describe your inspection and testing program for all aboveground bulk containers and piping, and to confirm training for oil-handling staff.

To answer it, write a short description of what you inspect, how often, the method, and who does it, then name the person accountable for discharge prevention. Confirm that records are signed and kept for three years in Attachment 3.1 and that staff get an annual discharge-prevention briefing.

For example, Green Valley Farm writes “Monthly visual inspection of tank, dike, and piping by farm manager using a written checklist; records kept in Attachment 3.1,” and names Maria Lopez as the accountable person.

An edge case is a facility with very few tanks. Even one tank needs a written, repeatable procedure; “the owner glances at it” is not a documented program.

A common mistake is leaving the inspection description box blank and assuming the checkbox alone is enough. An empty description means there is no program of record, which inspectors cite directly.

Many owners think keeping records only one year is fine. The rule requires signed inspection and test records for a full three years, and shorter retention is a violation.

Section III, Item 4 — Security and Table G-6 (§112.7(g))

This item, with Table G-6, asks how you keep unauthorized people away from oil handling, processing, and storage areas. It does not apply to oil production facilities.

To answer it, describe how you control access, secure master flow and drain valves, prevent tampering with pump starter controls, secure out-of-service connections, and use lighting to deter vandalism and help spot spills.

For example, Green Valley Farm writes “Tank area fenced and locked after hours; drain valve padlocked closed; motion-sensor light over the tank pad.”

An edge case is a remote, unattended site. You may rely more on locks and fencing than lighting, but you still describe whatever realistic measures fit the location.

A mistake is writing only “gated” with no detail on valves or lighting. The rule lists several security elements, and a one-word answer leaves required points unaddressed.

People often think security here is about theft. The real goal is preventing tampering and vandalism that could cause an oil discharge, so the focus is on valves and controls, not just the fence.

Section III, Items 5 through 8 — Emergency Procedures, Contacts, and Reporting (§§112.7(a), 112.4)

These items cover Table G-7 (emergency procedures), Table G-8 (contact list), Table G-9 (NRC notification procedure), and the 60-day spill reporting rule.

To answer them, describe the immediate steps your staff take when oil reaches water, fill the contact list with real names and numbers, and confirm you will report the listed details to the National Response Center. The NRC number is preprinted: 1-800-424-8802.

For example, Green Valley Farm writes that staff “stop the source, deploy sorbent booms from the spill kit, and call the NRC,” then lists its cleanup contractor, the Stanislaus County Fire Department, and the state oil pollution agency.

An edge case is a spill that stays fully inside containment and never reaches water. You still follow cleanup steps, but NRC notification is triggered only by a discharge to navigable waters or shorelines.

A serious mistake is leaving the cleanup contractor and state agency lines blank. During a real spill you have minutes, not hours, and an empty contact list delays response and cleanup.

Many filers confuse the immediate NRC call with the 60-day report. They are separate: you call the NRC right away for any discharge to water, and you file the written report to the EPA Regional Administrator within 60 days only for a spill over 1,000 gallons or two spills over 42 gallons each in 12 months.

Section A — Onshore Facilities (Tables G-10), §§112.8(b)–(d)

If your site is an onshore facility that is not oil production, you complete Section A and its checklist in Table G-10, in addition to Sections I through III.

To answer it, check each box that applies and write “N/A” for any requirement that does not fit your facility. The items cover diked-area drainage valves, container compatibility, overfill prevention, rainwater drainage procedures, buried tank corrosion protection, and regular integrity inspections.

For example, Green Valley Farm checks the overfill-prevention box and describes a “high-level shutoff and a written gauging procedure before each delivery,” and marks the buried-tank items “N/A” since it has no buried tanks.

An edge case is a facility with completely buried metallic tanks installed after January 10, 1974. Those tanks need corrosion protection and regular leak testing, so you check those boxes instead of marking N/A.

A common mistake is checking every box without reading it. Checking a box for equipment you do not have creates a false statement, while a genuine “N/A” is honest and accepted.

People often skip the overfill description, thinking the checkbox covers it. The rule asks you to describe the overfill method, so a checked box with no words is incomplete.

Sections B and C — Production, Drilling, and Workover Facilities (§§112.9, 112.10)

If your facility produces oil, you complete Section B and Table G-11; if it drills or does workover, you complete Section C and Table G-12. Most small non-oilfield sites skip both.

To answer them, work the same checkbox-and-N/A method. Section B covers tank battery drainage, flow-through process vessels, and flowline maintenance programs, while Section C covers mobile equipment placement, catchment basins, and blowout prevention (BOP) systems.

For example, an oil production site run by Dale Hutchins checks the flowline maintenance box and attaches an oil spill contingency plan as Attachment 2 because his flowlines have no secondary containment.

An edge case is flow-through process vessels. You may choose either standard containment or a documented inspection-and-repair routine, and you mark which path you take.

A mistake is a production facility using Section A by habit. Production facilities follow §112.9, not §112.8, and using the wrong section leaves required production rules unaddressed.

Many operators think flowlines are exempt. Flowlines need either secondary containment or a contingency plan plus a maintenance program, so they are squarely covered.

Attachments 1 through 4 — Logs and Notification Form

The template ends with Attachment 1 (five-year review and technical amendment logs), Attachment 2 (oil spill contingency plan and checklist), Attachment 3 (inspection, dike drainage, and training logs), and Attachment 4 (discharge notification form).

To complete them, print the logs and use them to record real activity over time. Fill the discharge notification form fields now so the information is ready before a spill, not during one.

For example, Maria Lopez signs each monthly inspection entry in Attachment 3.1 and files the dike drainage log in Attachment 3.3 each time rainwater is released.

An edge case is qualified oil-filled equipment with no containment, which requires the Attachment 2 contingency plan even at a non-production site.

A mistake is leaving the logs blank for months. Empty logs suggest no inspections happened, and inspectors read that as noncompliance even if you did the work.

People often think attachments are optional extras. The logs are part of the Plan, and missing logs make the Plan incomplete.

Three Filled-Out Examples Using Real Scenarios

These three named scenarios show how different facilities move through the template from start to finish.

Scenario 1: Maria Lopez, small farm with diesel tanks (Tier I self-certified)

Form Section	What Maria Enters
Facility Information	Green Valley Farm, 4820 County Road 12, Modesto, CA, Stanislaus County
Section I qualification	Aggregate aboveground capacity 4,055 gallons; no tank over 5,000; clean record
Self-certification signature	Signs, title Owner, date 06 / 03 / 2026
Table G-2 containers	Diesel AST (A) 2,000; Gasoline AST (A) 2,000; Oil drum (A) 55
Table G-4 containment	Earthen dike, 2,300-gallon capacity, flow toward east ditch
Table G-5 inspections	Monthly visual checks by farm manager, records kept 3 years
Table G-8 contacts	NRC 1-800-424-8802, county fire, state oil agency
Section A checklist	Overfill shutoff described; buried-tank items marked N/A

Scenario 2: Marcus Bell, small manufacturing plant (Tier II, one large tank)

Form Section	What Marcus Enters
Facility Information	Bell Coatings Inc., 215 Industrial Way, Akron, OH, Summit County
Qualification basis	Total aboveground 8,200 gallons; one 6,000-gallon tank, so Tier II not Tier I
Table G-2 containers	Heating oil AST (A) 6,000; Hydraulic units (A) 200; Drums (A) 2,000
Oil-filled equipment	Hydraulic presses listed as oil-filled operational equipment
Table G-4 containment	Concrete dike sized to 6,600 gallons around the large tank
Table G-5 inspections	Weekly checks plus annual integrity testing per industry standard
Section A overfill	High-level alarm on the 6,000-gallon tank
Certification path	Uses Tier II Plan because a tank exceeds 5,000 gallons

Scenario 3: Dale Hutchins, onshore oil production site (Section B)

Form Section	What Dale Enters
Facility Information	Hutchins Lease 4, Rural Route 3, Midland, TX, Midland County
Section completed	Sections I–III plus Section B for production
Table G-2 containers	Crude oil stock tank (A) 4,000; Produced water tank (A) 3,000
Table G-4 containment	Tank battery firewall sized to largest tank plus rainfall
Table G-11 flowlines	Flowline maintenance program described; contingency plan attached
Attachment 2	Oil spill contingency plan for uncontained flowlines
Table G-5 inspections	Scheduled visual checks of tank battery and field drainage
Certification	Self-certifies as Tier I production facility, clean spill record

How to File the Completed Form

The SPCC Plan is not mailed to the EPA in routine cases; it is kept on site and made available on request. Still, where you keep it and how you prove it exists matter as much as filing does for other forms.

• On-site retention (the normal channel). Keep a complete, signed copy at the facility if the site is attended at least four hours a day. There is no fee, no portal, and no submission, and your proof is the signed, dated Plan itself ready for any EPA inspector.
• Unattended sites. For a facility staffed fewer than four hours a day, keep the Plan at the nearest field office instead. Again there is no fee, and the proof is the maintained copy plus your inspection logs.
• Spill report to the EPA Regional Administrator (only after certain spills). If you have a single spill over 1,000 gallons to water, or two spills over 42 gallons each within 12 months, you must send a written report to your EPA Regional office within 60 days, with no fee, and keep a dated copy as your proof.
• Immediate NRC call (after any discharge to water). Call the National Response Center at 1-800-424-8802 right away for any oil discharge to navigable waters; there is no fee, and you record the report number and time as proof.

Processing time does not apply the way it does for a permit, because there is no approval step. The Plan is effective the moment you sign it and begin following it.

What Happens After You File

Once your Plan is signed, it becomes a living document you must actually follow, not a binder that sits on a shelf. The EPA can inspect your facility at any time and ask to see the Plan, the inspection logs, and the training records. Inspectors compare what the Plan says against what they see on the ground.

You must review the Plan at least once every five years and amend it within six months of any material change, such as adding a tank or changing the oil you store. Each technical amendment must be re-certified the same way you signed the original. Skipping reviews or amendments is a violation even if no spill ever happens.

If you do have a spill, the Plan drives your response. You make the immediate NRC call, follow your written cleanup steps, and, for larger spills, file the 60-day report to the EPA Region. After a reportable spill, expect closer EPA attention and possible enforcement, especially if the Plan was incomplete or ignored.

Mistakes to Avoid When Filling Out the Form

Small errors on this Plan carry real consequences. Watch for these specific mistakes.

• Undercounting total oil capacity by skipping oil-filled equipment, which can wrongly place you in Tier I and void your certification.
• Listing a single container over 5,000 gallons while self-certifying as Tier I, which makes the certification false.
• Leaving the secondary containment capacity boxes blank, which leaves a core rule requirement unaddressed and citable.
• Sizing a dike to only the tank volume with no rainfall freeboard, which means the containment legally fails.
• Forgetting to name a person accountable for discharge prevention, which violates §112.7(f) outright.
• Leaving the inspection description blank and relying on the checkbox alone, which shows no program of record.
• Keeping inspection records less than three years, which breaks the §112.7(e) retention rule.
• Skipping the five-year review, which is a standalone violation regardless of spill history.
• Leaving the cleanup contractor and state agency contacts empty, which cripples your real spill response.
• Using Section A at an oil production site, which leaves the §112.9 production rules unaddressed.
• Treating buried tanks as fully exempt, which leaves required tank elements out of the Plan.
• Signing the Plan but never implementing it, which the EPA treats the same as having no Plan.

Do’s and Don’ts

Do:

• Do download the current EPA template so your version matches the rule, because outdated forms can miss required elements.
• Do walk the entire site and count every container of 55 gallons or more, because a missed tank invalidates the inventory.
• Do measure your containment and record gallons, because inspectors check that the math holds the largest tank plus rainfall.
• Do name one accountable discharge-prevention person, because the rule demands a clear point of responsibility.
• Do keep signed inspection logs for three full years, because records are the proof your program is real.
• Do confirm your state allows self-certification before you sign, because some states require a PE.

Don’t:

• Don’t self-certify if any tank tops 5,000 gallons, because that forces you to Tier II or a PE Plan.
• Don’t leave description boxes blank, because a checked box with no words is incomplete.
• Don’t assume gravel or bare soil counts as containment, because it is not impervious to oil.
• Don’t wait until the five-year review to amend after a change, because amendments are due within six months.
• Don’t store the only copy off site at an attended facility, because the Plan must be on hand for inspectors.
• Don’t forget the immediate NRC call after a discharge to water, because delay can multiply penalties.

Pros and Cons of Filing on Your Own vs. With a Professional Engineer

Choosing between self-certification and hiring a PE depends on your size, your risk, and your comfort with the rule.

Pros of self-certifying (Tier I or II):

• It is free, since you skip engineering fees that often run into the thousands.
• It is fast, because you can finish the template in a day once your facts are gathered.
• It keeps you in control of your own facility knowledge and timeline.
• It is fully legal for qualified facilities under §112.6, so you lose no compliance standing.
• It builds your own understanding of the rule, which helps during inspections.

Cons of self-certifying:

• You carry full legal responsibility for every statement and any error.
• A mistake in capacity or containment can void the certification and expose you to penalties.
• Some states bar self-certification and require a PE anyway.
• Complex sites can exceed your expertise, leaving gaps you may not spot.
• You get no independent engineering review to catch design weaknesses.

FAQs

Do I need an SPCC Plan if I store exactly 1,320 gallons?

No. The threshold is more than 1,320 gallons of aboveground oil capacity. At exactly 1,320 gallons you are at the line but not over it, so the rule does not require a Plan.

Do oil-filled transformers count toward my storage total?

Yes. Oil-filled operational equipment like transformers and hydraulic units counts toward your facility total and must be listed in Table G-2, even though it is not a traditional storage tank.

Do I submit my SPCC Plan to the EPA?

No. You keep the signed Plan on site and show it during an inspection. You only send a written report to the EPA Region after specific large spills, within 60 days.

Do completely buried tanks count toward Tier I eligibility?

No. Buried tanks do not count toward the 10,000-gallon Tier I threshold, but they are still regulated and must be listed and addressed in the Plan.

Do I mark a requirement “N/A” if it does not fit my facility?

Yes. Write “N/A” in the box or check the N/A column for any rule element that does not apply, such as buried-tank items at a site with no buried tanks.

Do I write capacity in shell gallons or actual oil volume in Table G-2?

Yes, use shell capacity. The table asks for each container’s shell capacity in gallons, not the amount of oil currently inside it.

Do I need to size my dike larger than the tank?

Yes. Secondary containment must hold the largest container plus extra room for rainfall, so a dike equal to only the tank volume does not meet the rule.

Do I have to name a specific person for discharge prevention?

Yes. Section III, Item 3 requires you to name one accountable person by name and title under §112.7(f), and leaving it blank is a violation.

Do I qualify for Tier I if I had a 1,200-gallon spill last year?

No. A single spill over 1,000 gallons reaching water in the last three years disqualifies you from self-certifying as a qualified facility.

Do I call the EPA first or the National Response Center after a spill?

No, not the EPA first. For any discharge to navigable waters, call the National Response Center at 1-800-424-8802 immediately, then handle EPA reporting later if required.

Do I need a Professional Engineer if my state requires it?

Yes. Some states do not allow self-certification, so even a Tier I facility there must have a PE review and stamp the Plan before it is valid.

Do I have to redo the whole Plan when I add one tank?

No. You prepare a technical amendment within six months, log it, and re-certify that change rather than rewriting the entire Plan.

Do I keep inspection records forever?

No. You must keep signed inspection and test records for three years under §112.7(e); after that you may retire them, though keeping longer is fine.

Do mobile and portable containers need to be listed individually?

No. You may provide an estimated number of mobile or portable containers, the oil types, and anticipated capacities instead of listing each one separately.