No. EPA suggests you use a common sense approach. If one of your oil storage tanks leaks, and the spilled oil would not flow into navigable waters or adjoining shorelines, you do not have to prepare a Plan. Remember that you still have the responsibility to clean up any spilled oil and a containment system (for example, a dirt berm around the tank) makes this easier. EPA recommends that you check with your state environmental contacts to determine if there are requirements when oil is spilled to soil only. Also, EPA recommends that you document the reasons why you think an oil spill would not reach water to demonstrate to regional inspectors, if necessary, that your facility is not subject to the SPCC rule.