Questions about SPCC answered
Created: 8/25/10 (Wed) | Topic: Issues
If you've heard about the EPA's Oil Spill Prevention, Control, and Countermeasure Program (SPCC) and wondered how (or if) it affects you, wonder no more. Here is an explanation of who must comply, and when.
Oil spill prevention regulations that initially covered large industrial facilities have been expanded to cover many agricultural operations starting this November. Under the Spill, Prevention, Control, and Countermeasures (SPCC) rule, farms that store oil of any kind – petroleum, vegetable, animal fats, etc. – amounting to more than 1,320 gallons above-ground or 42,000 gallons of buried storage capacity will have to have an SPCC plan and maintain records that show they are following the plan. Otherwise, if a spill occurs they will face legal liability. Spill prevention plans must describe the preventative control measures that are in place and the response actions that would be taken in case of a spill.
The goal of the SPCC program is to prevent oil spills into waters of the United States. A key element of the program is for farmers and others to have an oil spill prevention plan. If your operation normally sells $1,000 or more of agricultural products per year it is considered a farm.
The SPCC program applies to farms that: 1) store, transfer, use or consume oil or oil based products and, 2) stores mor than 1,320 gallons in aboveground storage or 42,000 gallons in completely buried containers and, 3) could reasonably be expected to discharge oils to waters of the U.S. or adjoining shorelines. If your farm meets all of these criteria, then it is covered by SPCC.
The SPCC program requires you to prepare and implement a SPCC Plan. If you already have a plan, maintain it. If you don’t have a SPCC Plan, you should prepare and implement one. Many farmers need to have a Professional Engineer (PE) certify their plan. However, you may be able to self-certify your amended plan if: 1) your farm’s total capacity is between 1,320 gallons and 10,000 gallons in above ground storage, 2) no container has a capacity of more than 5,000 gallons and 3) the farm has a good spill history.
Note: Only containers capable of holding 55 gallons or more are counted in the SPCC Plan.
If your farm does not meet these criteria, you will need to engage a PE.
If your farm was established prior to August 16, 2002, you must maintain or amend an existing SPCC Plan. That plan must be in place now. If your farm was established after August 16, 2002 you must have a SPCC Plan in place by November 10, 2010.
Information needed to prepare a SPCC Plan
· A list of containers at the farm including contents and location of each container.
· A brief description of procedures you will use to prevent oil spills.
· A brief description of measures you installed to prevent spills from reaching water.
· A brief description of measures you will use to contain and clean up an oil spill to water.
· A list of emergency contacts and first responders.
Spill prevention measures to implement and include in the SPCC Plan
· Use containers suitable for the oil stored.
· Identify contractors and other personnel that can help you clean up an oil spill.
· Provide overfill prevention on your storage containers such as a high level alarm, audible vent or establish a procedure to fill containers.
· Provide effective, sized secondary containment for bulk storage containers, such as dikes or a remote impoundment. The containment must be able to hold the full capacity of the container plus possible rainfall. The dike can be constructed of earth or concrete. A double-walled container may suffice.
· Provide effective, general, secondary containment to address the most likely discharge where you transfer oil to or from containers and for mobile refuelers, such as nurse tanks mounted on trucks or trailers. You may use sorbent materials, drip pans, or curbing for these areas.
· Periodically inspect and test pipes and containers. You should visually inspect above ground pipes and containers following industry standards. You must “leak test” buried pipes when they are installed or repaired. EPA recommends you keep a written record of your inspections.
Maintaining a SPCC Plan
Amend and update your SPCC Plan whenever changes are made to the farm, such as adding new storage tanks larger than 55 gallon capacity. You must review your plan every five years to include any oil storage changes at your farm.
In case of a oil spill
Activate your SPCC Plan procedures to prevent the oil spill from reaching a creek or river.
Implement spill clean-up and mitigation procedures outlined in your Plan.
Notify the National Response Center (NRC) at 800-424- 8802 if you have an oil discharge to water.
If the amount of oil spilled is more than 42 gallons on two different occasions with in a twelve month period or more than 1,000 gallons in a single spill event, then notify your EPA Regional Office in writing.
For more information visit the EPA website: www.epa.gov/emergencies/spcc.