A Step-by-Step Walkthrough for Tier I Facilities, From Counting Your Oil Storage to Signing a Plan That Holds Up
If your New Jersey facility stores a modest amount of oil, EPA offers a shortcut: a fill-in Tier I Qualified Facility SPCC Plan template that, once completed and signed by the owner or operator, is your plan. No engineer's stamp and no custom document. The answer to the title question is yes, you can complete it yourself if you meet the Tier I criteria, but the template is only as good as the facts you put in it, and an inspector will compare what you wrote to what's sitting in your yard.
This article walks through the template section by section, shows where New Jersey's rules add to the federal ones, and covers when the template stops being the right tool. If you'd rather have experienced people check your work or handle the whole thing, you can reach out to RMA at any point, though plenty of small facilities can do this on their own.
Table of Contents
TL;DR
Yes. If your facility stores 10,000 gallons or less of oil aboveground, has no single container over 5,000 gallons, and hasn't had a qualifying discharge to water in the past three years, you can complete EPA's Tier I template and sign it yourself. Count your capacity carefully, make sure every statement you check is true on your site, and keep the logs the template calls for. New Jersey adds its own immediate spill reporting duty and separate rules for larger operations, so read those alongside the federal template.
Can You Use EPA's Tier I SPCC Template at Your New Jersey Facility?
The SPCC rule is EPA's oil spill prevention rule, found in 40 CFR Part 112. It applies to facilities that store more than 1,320 gallons of oil aboveground, counting containers of 55 gallons or more, and EPA Region 2 enforces it in New Jersey. Facilities at the smaller end get a streamlined option. If you're a Tier I qualified facility, you can complete EPA's template and self-certify, which means the owner or operator signs the plan instead of having a licensed Professional Engineer (PE) certify it. You have to meet every criterion in the table below.
| Tier I criterion |
What the rule requires |
Where people trip |
| Total aboveground oil storage |
10,000 gallons or less, in containers of 55 gallons or more |
Leaving out transformers, generator tanks, and drums |
| Largest single container |
No aboveground container over 5,000 gallons |
One big tank that quietly disqualifies the whole site |
| Discharge history |
In the three years before you certify, no single discharge over 1,000 gallons and no two discharges over 42 gallons within 12 months, to navigable waters or adjoining shorelines |
Counting what spilled instead of what reached the water |
Using the template is optional. EPA also lets a Tier I facility prepare a Tier II style plan or a full PE-certified plan. Our guides on what a Tier I self-certified SPCC plan is and the different types of SPCC plans compare the routes. EPA's template page also notes that some states don't allow self-certification, so confirm with your state if your situation is unusual.
How Do You Count Oil Storage Capacity Before Filling Out the Template?
Qualification turns on aggregate aboveground storage capacity, and capacity means what a container can hold, not what's in it today. A 5,000 gallon tank that's one-third full is still a 5,000 gallon tank. Only containers of 55 gallons or more count toward the total, but that includes drums, totes, and oil you wouldn't call fuel.
| Counts toward the total |
Doesn't count |
| Aboveground tanks, totes, and mobile or portable containers of 55 gallons or more |
Propane |
| 55-gallon drums of lube oil, hydraulic oil, and used oil |
Containers under 55 gallons |
| Oil-filled equipment such as transformers and hydraulic reservoirs |
Fuel tanks that power the vehicle or engine they're attached to |
| Generator sub-base and day tanks |
Completely buried tanks covered by underground storage tank (UST) rules |
| Vegetable oil and used cooking oil |
|
Here's how that adds up at a typical machine shop. A 2,000 gallon diesel tank for the generator, a 1,000 gallon hydraulic oil tank, ten 55-gallon drums (550 gallons), and a 400 gallon transformer total 3,950 gallons. That's comfortably inside Tier I limits and far above the 1,320 gallon line that triggers the SPCC rule in the first place.
SPCC applies only if a discharge could reasonably be expected to reach navigable waters or adjoining shorelines, and you can't count manmade features like dikes when you make that call.
What Should You Gather Before Starting the SPCC Template?
Most template mistakes happen before anyone opens the file. Walk the site with a clipboard first and collect the following.
- Every container of 55 gallons or more, with its oil type and shell capacity from the nameplate or your own measurements.
- Dimensions of each dike, berm, or containment pit, plus anything inside it that takes up space.
- A site sketch showing containers, loading areas, drains, and which way water flows toward the nearest stream, storm sewer, or wetland.
- Your spill history for the past three years, plus existing inspection and training records.
EPA publishes two completed sample plans, one for a farm and one for an automotive service garage. They show how much detail to include, though EPA is clear that nobody can adopt them for a real facility.
How Do You Complete the Facility Description and Self-Certification Statement?
The front of the template asks for the owner or operator's name and address, the facility name, county, and phone number. Every Tier I facility completes Sections I, II, and III. Onshore facilities that aren't oil production sites, which covers nearly everyone reading this, also complete Section A. Four attachments follow: review and amendment logs, an optional contingency plan, inspection and training logs, and a discharge notification form.
The self-certification statement has eight parts, and you're attesting to each one. You know the applicable requirements of Part 112. You've visited and examined the facility. The plan follows accepted and sound industry practices. Inspection and testing procedures are set up under industry standards. You'll fully implement the plan. The facility meets the Tier I criteria. The plan has no deviations or alternative measures that would need a PE. And management approves the plan and has committed the resources to carry it out.
Take each one literally. The site visit means walking the property, not filling this out from your desk. If the plan promises monthly inspections, an inspector will ask for the logs. The management statement is why the signer needs authority over budget and not only over the tanks.
It's tempting to feed the template to a chatbot and sign whatever comes back. A chatbot hasn't seen your yard, and you're the one certifying that you have. If you're curious how that goes, we tested whether ChatGPT can write an SPCC plan.
How Do You Complete the Oil Storage Container Table and Secondary Containment Section?
Section III starts with the container table. List every container separately with its type, the oil it holds, and its shell capacity. Group identical drums on one line only if they're stored together and you note the count. The numbers here must match what you used to qualify, so total them and confirm you're still at or under 10,000 gallons with nothing over 5,000.
Sizing Secondary Containment
For bulk storage containers, the rule requires secondary containment for the entire capacity of the largest single container plus additional capacity for precipitation. That applies to mobile and portable containers too. The rule doesn't set a rainfall number, so the extra volume depends on your site and on whether the containment is covered. The template lists acceptable methods, including dikes, berms, curbing, drainage systems, and sorbent materials. EPA's simplified worksheets assume a flat floor, equal wall heights, and square corners, so odd-shaped containment needs more careful math. Our guide covers how big your SPCC containment needs to be.
Failure Analysis and Overfill Prevention
Where experience points to a reasonable chance of equipment failure, such as loading equipment, tank overflow, rupture, or leakage, the plan must predict the direction and total quantity of oil that could be discharged. Write what would really happen: a tank rupture on the north side sends oil toward the loading dock drain, and the volume is the tank's capacity. Each container also needs overfill prevention, either a system or a documented procedure, described in the plan and regularly tested.
How Do You Handle Inspections, Training, Security, and Spill Procedures in the Template?
The rest of Section III and Section A cover what you do day to day: facility drainage, container construction and integrity testing, inspections, transfer operations, security, personnel training, and emergency notifications. Test and inspect containers using industry standards, keep inspection records for three years, hold discharge prevention briefings for oil-handling staff at least once a year, and describe your security measures, like fencing, locked valves, and lighting. Our guides cover monthly SPCC inspections and annual SPCC training, and our online training library has courses if you'd rather not build training yourself.
| Template attachment |
What goes in it |
| Attachment 1: Five Year Review Log and Technical Amendment Log |
Date and result of each review, plus every facility change that needed re-certification |
| Attachment 2: Oil Spill Contingency Plan and Checklist |
Only if you use the optional contingency plan for qualifying oil-filled operational equipment, such as a transformer |
| Attachment 3: Inspection, dike drainage, and training logs |
Inspection schedule and records, rainwater drained from containment, and annual briefing sign-ins |
| Attachment 4: Discharge Notification Form |
The information to have ready when you call the National Response Center |
Print the attachments and keep them where the inspections happen. An empty log tells an inspector the plan exists and isn't being followed.
What Does New Jersey Add on Top of the Federal SPCC Template?
EPA's template is a federal document, and New Jersey layers its own rules on top. The biggest difference is spill reporting. Under the Spill Compensation and Control Act (the Spill Act), anyone responsible for a discharge must report it immediately, and NJDEP says that applies to all facilities and even homeowners.
| |
Federal SPCC |
New Jersey |
| Who you call |
National Response Center, 1-800-424-8802 |
NJDEP hotline, 1-877-WARNDEP (1-877-927-6337) |
| What triggers the call |
Oil reaching navigable waters or adjoining shorelines, including a sheen |
A discharge of a hazardous substance, petroleum included, to the environment |
| What follows |
A 60-day report to the EPA Regional Administrator and the state if you pass 1,000 gallons, or two discharges over 42 gallons in 12 months |
Cleanup under the Spill Act, which may involve a Licensed Site Remediation Professional (LSRP) |
A spill that stays inside secondary containment is generally treated differently from a discharge to land or water, but when you're unsure, call. Spill Act liability is strict and can be joint and several, meaning responsibility doesn't depend on fault and can fall on more than one party. For discharges, enforcement questions, or liability, an environmental attorney may be appropriate. We cover the federal side in the sheen rule, and our overview of SPCC plans in New Jersey ties the two together.
Larger operations face another layer. NJDEP's rules at N.J.A.C. 7:1E require Discharge Prevention, Containment and Countermeasure (DPCC) and Discharge Cleanup and Removal (DCR) plans for "major facilities." NJDEP guidance describes a major facility as one storing 20,000 gallons or more of hazardous substances other than petroleum, or 200,000 gallons or more of all hazardous substances including petroleum. A Tier I facility is usually far below those numbers, but chemical storage counts too, so check the current rule against your own inventory.
Other programs sit beside SPCC. Buried tanks fall under NJDEP's UST program, and installing one requires an NJDEP-certified contractor. Your local fire official enforces the Uniform Fire Code. If you're building or expanding, construction stormwater coverage, soil erosion approvals, and building permits are separate, and RMA doesn't handle them. Your engineer or contractor will. Once the facility is running, you'll need operating plans like this one.
How Much Does a Tier I SPCC Plan Cost, and Should You Do It Yourself?
The template is free, so the cost of doing it yourself is your time and your risk. The cost of hiring help depends on how many containers you have, how complicated your containment is, and whether any part of the plan needs a PE's review. RMA's published range for SPCC plans runs from $2,500 to $15,000, and simple Tier I updates run about $1,500. Our article on SPCC plan costs breaks down what moves the price.
If you have a few tanks and a patient person who can follow the template, doing it yourself is reasonable. The usual trouble spots are miscounted capacity, containment math, and plans nobody follows. If you want a ballpark for having us help, the pricing calculator below gives one based on your facility, and our piece on getting an SPCC plan online covers the remote option.
How Do You Keep a Tier I SPCC Plan Current, and When Does the Template Stop Working?
Signing the plan starts the clock on two ongoing obligations. First, you must review and evaluate the plan at least once every five years and record it in the review log. Amendments that come out of the review need to be made within six months. Our guide to the five-year review covers update versus redo. Second, whenever a change in design, construction, operation, or maintenance affects your discharge potential, such as a new tank or relocated equipment, you must certify a technical amendment. Tier I facilities can self-certify those too.
The template stops fitting when your facility changes. If one container grows past 5,000 gallons or your total passes 10,000 gallons, you have six months to move to a Tier II plan, if you still qualify, or a full PE-certified plan. The same applies if you need an alternative measure or an impracticability determination for secondary containment, because those can't be self-certified. A spill history that crosses the 1,000 and 42 gallon lines also costs you Tier I eligibility the next time you certify.
When you land on the PE path, the key is having a licensed PE review and approve the plan. Some firms keep a PE on staff and others work with a trusted outside engineer, so ask how it's handled before you hire anyone. Our pieces on when a Professional Engineer is involved and who enforces SPCC plans explain what to expect, and the most overlooked SPCC requirements are worth a read before your next inspection.
How Can RMA Help You Complete Your SPCC Plan Template?
We help New Jersey facilities and facilities across the country sort out whether the Tier I template fits, count their storage correctly, and complete or review the plan. We can also walk your site with your team, show you what an inspector looks for, and set up the logs so they get used. If the template turns out to be all you need, we'll tell you that.
There's no pressure and no obligation. You can call, email, or fill out the form on our website, and a member of our team will talk through your situation. When you're ready, contact RMA and we'll take it from there.
