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SPCC plan template › Tier I vs Tier II SPCC plan

Tier I vs Tier II SPCC plan: which one can you sign?

Both tiers are "qualified facilities": 10,000 gallons or less of aboveground oil and no reportable spill in three years, so the owner may certify the plan instead of an engineer. The difference is one container. If none holds more than 5,000 gallons, you're Tier I and may sign EPA's template. If any does, you're Tier II and must write a full plan.

Updated November 2026. From 40 CFR 112.6 and 112.3(g) on eCFR and EPA's qualified facility page, read November 13, 2026.

The three plans side by side

Farms use different capacity numbers under the 2014 water resources law; see the farm guide.
Tier ITier IIPE-certified
Aboveground total10,000 gal or less10,000 gal or lessAny
Largest container5,000 gal or lessAt least one over 5,000 galAny
Spill history (3 years)None reportableNone reportableAny
FormatEPA's Appendix G template, or an equivalent plan with a cross-reference sectionFull plan meeting 112.7 and subpart B or CFull plan
Who certifiesOwner or operatorOwner or operator, plus a PE for any deviation or impracticability sectionA licensed PE after a site visit
May include an "environmentally equivalent" alternative to a rule?NoOnly if a PE certifies that sectionYes, with reasons
May declare containment impracticable?NoOnly if a PE certifies that sectionYes, with a contingency plan
Containment sizingLargest container plus room for rain, at every bulk container except mobile refuelersSame rule (112.8(c)(2) and (c)(11))Same rule

What "reportable spill history" means

You qualify only if, in the three years before you sign (or since the facility became subject to the rule, if that's shorter), it had no single discharge of more than 1,000 gallons and no two discharges of more than 42 gallons each within any 12 months. Two details trip people up. First, the gallons are what reached water or a shoreline, not the total spilled: 500 gallons on a gravel pad that never left the site doesn't count. Second, discharges caused by natural disasters, acts of war or terrorism are excluded. EPA explains both on its qualified facility page.

Tier I: what you're signing

A Tier I owner who completes EPA's template certifies eight things under 112.6(a)(1), including that you are familiar with 40 CFR 112, that you visited and examined the facility, that you set up inspection and testing procedures to industry standards, that you'll fully implement the plan, and that management has committed the money to do it. The template already contains every requirement a Tier I site must meet, a shorter list than the full rule (no facility diagram, for one), with three of them simplified:

You don't have to use the template. A Tier I site may instead write a Tier II-style plan or have a PE certify a full plan. But if you self-certify in any format other than EPA's template, the plan must include a section cross-referencing where each rule requirement is met.

Tier II: a full plan without the engineer

A Tier II owner signs the same kind of eight-point certification, but the plan itself must meet all of 112.7 and the subpart for the oil you store (subpart B for petroleum and most oils, subpart C for animal fats and vegetable oils). There's no federal form. California's Office of the State Fire Marshal offers a Tier II template built on EPA's Tier I layout, and general templates such as Ecesis's give you the section structure.

The limit is judgment calls. If your plan says some rule doesn't fit and you'll achieve "equivalent environmental protection" another way (112.7(a)(2)), or that building containment around something is impracticable (112.7(d)), a licensed PE must review and certify that section in writing, after the PE or an agent visits the site. The rest of the plan stays self-certified.

Three facilities sorted

Equipment yard: two 2,000-gallon diesel tanks and twenty 55-gallon drums.

(2 × 2,000) + (20 × 55) = 4,000 + 1,100 = 5,100 gal; largest 2,000 gal

Under 10,000 total, nothing over 5,000, no spills: Tier I. EPA's template works.

Fleet fueling site: one 6,000-gallon diesel tank, one 1,000-gallon gasoline tank and ten drums.

6,000 + 1,000 + (10 × 55) = 7,550 gal; largest 6,000 gal

Under 10,000 total but one container over 5,000: Tier II. Full self-certified plan.

Asphalt contractor: an 8,000-gallon diesel tank and a 4,000-gallon fuel oil tank.

8,000 + 4,000 = 12,000 gal

Over 10,000: PE-certified plan (for a non-farm site), however clean the record.

When you outgrow your tier

Adding a tank is a technical amendment, which you self-certify the same way as the plan. But if the change pushes a Tier I site over 5,000 gallons in one container or 10,000 in total, then within six months of preparing the amendment you must switch to a Tier II plan (if you still qualify) or a PE-certified plan. A Tier II site that goes over 10,000 gallons has six months from the change to get a PE-certified plan in place. If a PE certified part of a Tier II plan and the change touches that part, the PE re-certifies it (112.6(a)(2) and (b)(2)).

Check before you sign

If you'd rather start from a filled-in draft than a blank form, ePlan drafts Tier I and Tier II plans from your address and tank list; you still review and sign it, and it doesn't write the sections only a PE may certify. What each route costs is in how much an SPCC plan costs.

Questions

Can a Tier I facility use a Tier II plan?

Yes. Under 112.6(a)(1) a Tier I owner may complete EPA's template, write a plan that meets the Tier II requirements, or have a PE certify a full plan.

Is there an SPCC plan template for Tier II?

Not from EPA. California's Office of the State Fire Marshal offers one based on the CalCUPA Forum's APSA working group template; otherwise a Tier II plan is written to 40 CFR 112.7 and subpart B or C.

What happens if my facility outgrows its tier?

If a new or bigger container pushes it past the capacity limits, you have six months to move to the right plan: Tier II if you still qualify, otherwise a PE-certified plan. A reportable spill is different: it counts against qualifying the next time you certify the plan or an amendment.