What is the SPCC threshold for IBC totes?

The EPA SPCC threshold is 1,320 gallons of total aboveground oil storage at a facility. For 275-gallon IBC totes, 5 or more totes triggers SPCC. For 330-gallon totes, 4 or more totes exceeds the threshold. All aboveground containers count toward the total.

Do I need an SPCC Plan?

You need an SPCC Plan if your facility has more than 1,320 gallons of total aboveground oil storage capacity AND there is a reasonable expectation of oil discharge to navigable waters or adjoining shorelines. Underground tanks have a separate 42,000-gallon threshold.

SPCC Threshold Calculator for IBC Totes — Does My Facility Need an SPCC Plan?

⚗️ Your Aboveground Oil Storage

IBC Totes

275-gallon IBC totes

Most common size

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330-gallon IBC totes

Larger composite IBC

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Other size IBC totes

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Drums & Portable Containers

55-gallon drums

Steel or poly drum

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30-gallon drums

Half-drum, lube drums

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Fixed Aboveground Tanks

Total fixed tank capacity (gallons)

Include all ASTs — diesel, lube oil, hydraulic fluid, process oil, waste oil

What counts as "oil" under SPCC?

Counts: petroleum (diesel, gasoline, fuel oil, lube oil, hydraulic fluid, mineral oil), vegetable oils, animal fats, synthetic oils, used motor oil.

Does not count: water, aqueous solutions, food-grade beverages, dry goods, pesticides (regulated under FIFRA separately).

SPCC STATUS

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aboveground oil

0 1,320 gal threshold

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Storage Breakdown

Results based on EPA 40 CFR Part 112 thresholds (verified Aug 2026). SPCC also requires reasonable expectation of discharge to navigable waters. Consult a licensed PE or environmental consultant for site-specific compliance. Verify current thresholds at ecfr.gov.

SPCC Thresholds — IBC Tote Reference

The EPA's Spill Prevention, Control, and Countermeasure rule (40 CFR Part 112) applies to facilities with aboveground oil storage above 1,320 gallons — or any single container over 660 gallons — where there is a reasonable expectation of discharge reaching navigable waters. All aboveground containers count toward the total, not just IBC totes.

Tier	Total Aboveground Storage	275-gal IBC Equivalent	Plan Required	PE Required?
Exempt	< 1,320 gal total AND no single container > 660 gal	Up to 4 × 275-gal totes (1,100 gal)	No SPCC Plan required	No
Tier I Qualified Facility	1,320 – 10,000 gal	5 – 36 × 275-gal totes	Self-certified SPCC Plan	No — owner/operator certifies
Tier II Qualified Facility	10,001 – 999,999 gal	37 – 3,636 × 275-gal totes	PE-certified SPCC Plan	Yes — PE stamp required
Major Facility	≥ 1,000,000 gal	3,637+ × 275-gal totes	Full SPCC Plan + PE + EPA reporting	Yes — PE required

Secondary Containment: The 110% Rule

Every aboveground oil container subject to SPCC must have secondary containment sized for 110% of the largest single container's volume. For a 275-gallon IBC tote, that means at least 303 gallons of containment. For a 330-gallon tote, at least 363 gallons. Most purpose-built IBC spill pallets are rated at 360–400 gallons and comply for single-tote use.

Setup	Min. Containment Required	Compliant Options
1 × 275-gal IBC tote	303 gallons (110% of 275)	IBC spill pallet ≥ 303 gal; containment berm
2–4 × 275-gal IBC totes	303 gallons (110% of largest single)	Shared berm ≥ 303 gal; double IBC pallet
1 × 330-gal IBC tote	363 gallons (110% of 330)	IBC spill pallet ≥ 363 gal
Mixed sizes — largest is 330 gal	363 gallons minimum	Shared containment berm ≥ 363 gal

Some states require containment of 110% of the total group volume, not just the largest container. Check your state environmental agency's requirements in addition to federal SPCC rules.

Related Compliance Guides

→ Secondary Containment Guide → Industrial Compliance Hub → IBC Tote Dimensions → IBC Cleaning Services

SPCC Threshold Calculator

SPCC Thresholds — IBC Tote Reference

Secondary Containment: The 110% Rule

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