We explain the different types of SPCC plans that exist.
If you’re trying to figure out what type of SPCC plan you need, you’ve probably already realized something, it’s not as straightforward as it should be.
You start searching online, and suddenly you’re seeing different terms, different thresholds, and different opinions. Some people say you need an engineer. Others say you don’t. And depending on who you talk to, you might get completely different answers.
We hear this all the time. SPCC is a federal regulation, but it gets interpreted in different ways by consultants, state agencies, and even professional engineering boards. On top of that, it applies to a huge range of facilities. Everything from farms and hospitals to data centers and concrete plants.
The issue here is folks generally know about SPCC plans but not the different types of them. So, lets dive in and cover the three types of SPCC Plans.
The different types of SPCC plans.
At a high level, there are three types of SPCC plans, but they really fall into two categories:
- Self-certified plans, meaning you can develop and then sign off on them
- Professionally certified plans, meaning you either need to be a PE, or have a PE involved, in the development and certification of your documentation.
Let’s break each one down.
1. Tier I Self Certified SPCC Plans
A Tier 1 plan is the most straightforward version.
This typically applies to facilities that have at least 1,320 gallons of oil on site, but less than 10,000 gallons total, and no single tank larger than 5,000 gallons. There are a few additional conditions related to spill history, but for most people, those three thresholds are what matter.
If you fall into this category, you can usually self-certify your plan. That means you don’t need a professional engineer to sign off on it, and you can often use a more standardized template to build the document. In fact, you can use the EPA's Tier I SPCC template if you choose to do so, but fair warning, it's a piece of junk.
This is why Tier 1 plans tend to be the simplest and most cost-effective to put together.
We go over these plans in more detail in this article on Tier I SPCC Plans.
2. Tier II Self-Certified SPCC Plans
Tier 2 is where things start to get a little less obvious.
You can still be under 10,000 gallons total and still qualify for self-certification, but if you have even one tank larger than 5,000 gallons, you’re no longer Tier 1. That automatically bumps you into Tier 2. And there's no free template to use anymore.
You’re still allowed to self-certify, but you can’t rely on the simplified Tier 1 approach anymore. The plan becomes more detailed, more customized, and generally requires a bit more thought.
This is one of the most common areas where people get confused. They assume that staying under 10,000 gallons is all that matters, but tank size plays a big role too.
We go over this plan more in our article on Tier II Self-Certified SPCC Plans.
A Quick Clarification on “Tier 2”
It’s worth pausing here for a second because this trips people up all the time. There is also something called Tier II reporting under Community Right-to-Know regulations, aka EPCRA. That has nothing to do with Tier II SPCC plans.
Similar name, completely different requirement.
3. Professional Engineered Certified SPCC Plan
This plan applies to facilities that have over 10,000-gallons of oil or petroleum products, regardless of tank sizes. This plan is the biggest & most complex of the three.
While this plan can be prepared by anyone, only a professional engineer can review & certify the plan. A PE needs to certify the plan because they're signing off that the practices in place adhere to the EPA's regulations. As a side note, since this plan has to be certified by a PE, it goes without saying that this plan usually is the most expensive out of the main three.
We cover this plan more in our article on Full Professional Engineered Certified SPCC Plans.
How much does an SPCC plan cost?
Once you understand the different types of plans, the cost differences start to make more sense.
A smaller, straightforward Tier 1 plan is usually on the lower end of the spectrum. As you move into Tier 2 and especially into PE-certified plans, the cost increases along with the complexity.
In general, you might see something in the range of a couple thousand dollars for a simple plan, while larger or engineered plans can climb significantly higher depending on the facility.
There’s no one-size-fits-all number, but the type of plan you need is one of the biggest drivers of cost.
Use our calculator below to find out!
Additional SPCC Considerations
Even if you’re under 10,000 gallons, there are situations where a professional engineer still needs to be involved.
If a facility has a history of significant oil spills, complex operations, or more advanced transfer systems, that can trigger additional requirements. The same goes for facilities that fall under Facility Response Plan requirements or have particularly high-risk operations.
Location matters too.
Some states have taken a stricter stance and require professional engineer certification regardless of federal self-certification allowances. North Carolina and Kentucky are two examples where this comes up frequently.
So while SPCC is a federal rule, how it’s applied can still vary depending on where you are.
Guidelines on Types of SPCC Plans
There are three types of SPCC plans, but the real distinction is whether you can certify the plan yourself or need a professional engineer to do it.
Tier I is the simplest and most flexible. Tier II is still self-certified but more involved. And once you cross into larger or more complex operations, you’re looking at a PE-certified plan.
Most of the confusion comes from misunderstanding those thresholds or getting inconsistent advice from different sources. And unfortunately, that happens more often than it should.
Let's visualize this one last time:
- Tier I Plans
- Over 1,320-gallons
- Less than 10,000-gallons
- No tanks over 5,000-gallons
- Tier II Plans
- Over 1,320-gallons
- Less than 10,000-gallons
- At least one tank over 5,000-gallons
- Full PE Certified Plans
- Over 10,000-gallons
- Or, if you've had spills.
- Or, if you deviate from the regulations.
- Or, if you have over 42,000-gallons in underground storage tanks.
- Or, if state requirements dictate otherwise.
- Other Plans – 1,000,000-gallons or up, boats, and other unique circumstances.
So in reality, there are 3 main types of SPCC plans, with additional considerations for large facilities, and vessels. Simple enough, right?
To learn more about SPCC Plans and figure out which plan your facility needs, click here to contact us or give us a call anytime at 609-693-8301. We’ll help you figure out where you fall, whether you can self-certify, and what your next step should be.
