Spill Prevention Control & Countermeasure (SPCC) for Farms

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1 Spill Prevention Control & Countermeasure (SPCC) for Farms Ag View FS, Inc. & Marshall-Putman Farm Bureau March 19, 2013 Oil Storage on the Farm Today s Topics: EPA SPCC Regulation Secondary Containment Illinois Fire Marshal Regulations Tier I SPCC Plan Template Owner/operator Inspections 1

2 Spill What does SPCC mean? Prevention Control and Countermeasure USEPA Oil Spill Prevention Program regulations under the Clean Water Act What is SPCC? Spill Prevention Control and Countermeasure Federal regulation 40 CFR Part 112 Administered by the US Environmental Protection Agency Goal of SPCC program - prevent oil spills into waters of the US and adjoining shorelines. Key element - calls for farmers and other facilities to have an oil spill prevention plan, called an SPCC Plan. 2

3 US EPA Region 5 3

4 What is an SPCC Plan? Written plan that may be: 1) Reviewed and certified by a Professional Engineer; or 2) Prepared & self-certified by an owner/operator (farmer) Plan not submitted to USEPA Plan maintained at facility (farm) or nearest office Plan reviewed every 5 years by owner or operator 4

5 What types of oil? Oil means oil of any kind or in any form, including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils (e.g. soy), including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including synthetic oils and mineral oils. Also: kerosene, used oil, biodiesel, lube oil, hydraulic oil Is my farm regulated by SPCC? Yes, if your farm: Stores, transfers, uses, or consumes oil or oil products, such as diesel fuel, gasoline, lube oil, hydraulic oil, adjuvant oil, crop oil, vegetable oil, or animal fat; and Stores more than 1,320 US gallons in aboveground containers or more than 42,000 US gallons in completely buried containers; and Could reasonably be expected to discharge oil to waters of the US or adjoining shorelines, such as interstate waters, intrastate lakes, rivers, and streams. USEPA Fact Sheet, November, gallon 5

6 Waters of the US Consider the geography and location of the facility relative to nearby navigable waters (such as streams, creeks, and other waterways); Determine if ditches, gullies, storm sewers, or other drainage systems may transport an oil spill to nearby streams Consider frozen ground & tile lines A.k.a. navigable waters Farm Oil Storage Areas 6

7 When Must Farms Comply? Current compliance deadline is: May 10, 2013 Note: If your facility (e.g. farm) was in operation before August 16, 2002, and you do not already have an SPCC Plan, you must prepare an SPCC Plan now. Do not wait until May 10, USEPA Fact Sheet - November,2011 3/15/ FOUR MONTH SPCC DELAY LIKELY : Yesterday, the Senate adopted an amendment by voice vote to the Continuing Resolution (CR) funding bill which, when approved by the House, will delay SPCC compliance deadlines for farmers. The Senate is expected to finish up work on the CR early next week and it s likely the House will pass the CR before March 27 when the current CR expires. The amendment prevents funds from being used through Fiscal Year 2013 to implement requirements of EPA s SPCC rule slated to go into effect on May 10, 2013 for farmers. Recently, Senator Mark Pryor (D-AR) introduced a bill which would increase threshold sizes for Aboveground Storage Tank (AST) regulation at the farm level, and allow more farms to self-certify. It provides an exemption from the SPCC rule to any farmer who has less than 42,000 total gallons of oil storage capacity and no single tank larger than 10,000 gallons. Similar legislation was introduced by Rep. Rick Crawford (R-AR) in the House. The measure adopted in the Senate yesterday only provides a compliance delay until September 30, On October 1, 2013, farms will have to comply with SPCC rules unless additional delays are legislated or provided by EPA. 7

8 Compliance Dates for Farms A facility starting operation On or before August 16, 2002 Owner/Operator must Maintain its existing SPCC Plan Amend and implement the SPCC Plan no later than May 10, 2013 Compliance Dates for Farms A facility starting operation On or before August 16, 2002 Owner/Operator must Maintain its existing SPCC Plan Amend and implement the SPCC Plan no later than May 10, 2013 After August 16, 2002 through May 10, 2013 Prepare and implement the SPCC Plan no later than May 10,

9 Compliance Dates for Farms A facility starting operation On or before August 16, 2002 Owner/Operator must Maintain its existing SPCC Plan Amend and implement the SPCC Plan no later than May 10, 2013 After August 16, 2002 through May 10, 2013 After May 10, 2013 Prepare and implement the SPCC Plan no later than May 10, 2013 Prepare and implement a SPCC Plan before beginning operations. Compliance Dates Timeline of Important Dates DECEMBER, 1973 AUGUST 16, 2002 May 10, 2013 Existing Facilities Must have SPCC Plan now Must have secondary containment now New Facilities Must have SPCC Plan by 5/10/2013 Need secondary containment by 5/10/2013 9

10 Secondary Containment Secondary Containment USEPA SPCC rules: Provide a secondary means of containment for the entire capacity of the single largest container (e.g. storage tank) Plus sufficient freeboard to contain precipitation Minus the displacement of adjacent tanks Volume below the height of the dike Diked areas sufficiently impervious 10

11 Secondary Containment Capacity for storm water precipitation (6 inches) 1000 GALLON SINGLE WALL TANK Storm Water 6 inches Dyed Diesel Fuel Capacity for the largest container (1000 gallon tank) Secondary Containment Capacity for storm water precipitation (6 inches) Two 1000 gallon Single Wall Tanks Displacement of 2 nd Tank Displacement Dyed Diesel Fuel Capacity for the largest container (1000 gallon tank) 11

12 Secondary Containment Must be sufficiently impervious to contain oil [112.7(c)(1)(i)] Concrete Wall & floor Steel Double wall for single tank or dike wall & floor Geo-membrane Liner HDPE Compacted clay soil Rule of thumb: permeability less than 1 X 10-6 centimeters per second May be compromised by: Vegetation roots, animal burrowing, desiccation cracking, and freeze/thaw effects 12

13 Secondary Containment Pre-cast Concrete Walls & Floor with Roof 13

14 Secondary Containment Steel Dike with Rain Shield Steel Dike Walls & Floor Secondary Containment Synthetic Liners J.C. Ramsdell Enviro Services, Inc. 14

15 Secondary Containment Engineered Earth Secondary Containment Double Wall Steel Tank 15

16 Secondary Containment This is a photo of a concrete block containment wall. Note both the overfill of the tank and leakage of oil through the wall. This is a common problem with concrete block containment walls. USEPA PowerPointPresentation SPCC 101 for Agriculture Illinois Office of the State Fire Marshal 16

17 State Fire Marshal Illinois Farms Fire Marshal rules limit the number of dispensing tanks at farms to four (4) aboveground storage tanks up to 2,500 gallon each and any single type of fuel up to 5,000 gallons Example gal Gasoline 2500 gal Gasoline 2500 gal Diesel 2500 gal Diesel 5000 gal Gasoline 5000 gal Diesel State Fire Marshal Commercial, Industrial, Government, & Construction Fire Marshal rules limit the number of dispensing tanks to two (2) aboveground storage tanks per facility up to 2,500 gallon each Example: gal Gasoline 2500 gal Diesel 17

18 Tier I SPCC Plan Template SPCC Plan for Farms Tier I SPCC Plan template is a fill-in-theblank document A self-certified SPCC Plan for smaller aboveground oil storage facilities Smaller facilities: Greater than 1,320 gallons and less than or equal to 10,000 gallons 18

19 3/19/

20 3/19/2013 Tier I Self-certified Sample Plan 20

21 3/19/2013 Tier I Self-certified Eligibility Criteria If your facility has 1) Total Oil Storage Capacity: less than or equal to 10,000 gallons, and 2) Spill History: For the 3 years prior to plan certification, or For new facility operated less than 3 years, the facility must not have had: A single discharge of oil to navigable waters of 1000 gallons or more, or Two 42 gallon or greater oil spills within a 12 month period to navigable waters, and Tier I Self-certified Eligibility Criteria 3) No individual aboveground oil storage container greater than 5,000 gallons Then you are eligible to Complete and self-certify the SPCC Plan template (found in 40 CFR Part 112, Appendix G) 21

22 3/19/2013 Exemptions Single-residence heating oil tanks; Milk & milk product containers; Pesticide application equipment and related mix containers; Motive Power Containers; Nurse Tanks; Permanently Closed Containers Milk & Milk Products Milk and Milk product containers are now exempt from the SPCC capacity calculations and rule requirements Milk spills must be immediately reported to the National Response Center (NRC) at or ; Because milk contains oil, the owner or operator of milk facility may be liable to clean up a spill and/or pay penalties 22

23 3/19/2013 Pesticide Application Equipment Pesticide application equipment and related mix containers include: Ground boom applicators Airblast sprayers Specialty aircraft that apply measured amounts of pesticides to crops and/or soil Related mix containers Motive Power Containers Defined as:...onboard bulk storage containers used solely to power the movement of a motor vehicle, or ancillary onboard oil-filled operational equipment used solely to facilitate its operation. Fuel tanks on equipment Large combine fuel tank capacity gal. Deere & Company 55 gallons or greater 23

24 3/19/2013 Farm Nurse Tanks Nurse tanks are mobile/portable containers used at farms to store and transport fuel for transfers to or from farm equipment and to other bulk storage containers. Nurse tanks are counted toward the storage capacity threshold (i.e. greater than 1,320 gal). Nurse tanks are exempt from sized secondary containment. Must meet general secondary containment requirements at 112.7(c) Permanently Closed Containers SPCC rule exempts any oil storage container that is permanently closed. Permanently closed means any container or facility for which: (1) All liquid and sludge has been removed from each container and connecting line; and (2) All connecting lines and piping have been disconnected from the container and blanked off, all valves (except for ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stating that it is permanently closed and noting the date of closure. 24

25 3/19/2013 Owner/Operator Inspections Owner/Operator Inspections An inspection and/or testing program is required for all aboveground bulk storage containers (including portable containers) and piping Recommended visual inspection checklists available at: 25

26 3/19/2013 For More Information Barb Carr, USEPA Region 5:(312) Read the SPCC rule and additional resources: Call or send an to the EPA Ag Compliance Assistance Center: Call the Oil Information Center: (800) or (703) htm For More Information SPCC for Farmers Fact Sheet Tier I SPCC Plan templates: Sample Tier I SPCC Plan for Farms Steel Tank Institute Inspection Checklists docx 26

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