Farm Horizons, October 2012

Oil spill prevention: it’s time to prepare a plan

By Starrla Cray

As part of the Environmental Protection Agency’s oil spill prevention, control, and countermeasure (SPCC) program, many farmers are required to prepare and implement an SPCC plan.

Although legislators have introduced a bill in an attempt to ease the regulations, current SPCC measures are as follows:

Farms in operation before Aug. 16, 2002 that do not have a plan need to prepare one immediately, according to the SPCC rule amendments overview.

Farms that started operation after Aug. 16, 2002 must prepare and use a plan before May 10, 2013.

Under SPCC, a farm is “a facility on a tract of land devoted to the production of crops or raising of animals, including fish, which produced and sold, or normally would have produced and sold, $1,000 or more of agricultural products during a year.”

SPCC only applies to farms that meet all of the following criteria:

• 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 above-ground 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.

To determine SPCC applicability, farmers only need to count containers of oil that have a storage capacity of 55 US gallons or more. Also, adjacent or non-adjacent parcels may be considered separate facilities for SPCC purposes.

All farms that meet SPCC criteria must develop an SPCC plan. Many farms will be able to self-certify their plans. However, farms that have a storage capacity of more than 10,000 gallons of oil, or have had an oil spill, may need to prepare an SPCC plan certified by a professional engineer (PE).

All SPCC plans need to include a detailed list of the farm’s oil containers, as well as a description of the procedures one would use to prevent oil spills, measures that have been installed to prevent oil from reaching water, measures one would use to contain and clean an oil spill to water, and a list of emergency contacts and first responders.

A few spill prevention measures that should be included in a farm’s SPCC plan include using containers suitable for the oil stored, periodically inspecting and testing pipes and containers, and providing secondary containment for bulk storage containers.

Plans should be updated as changes are made to the farm, or at least every five years.

According to the SPCC fact sheet, the goal of the program is to prevent oil spills into water. Oil spills can cause injuries to people and damage water resources needed for farming operations.

If an oil spill with discharge to water or adjoining shorelines occurs, notify the National Response Center at 800-424-8802.

Proposed SPCC changes

A bill has been introduced to ease some of the SPCC restrictions. If approved, farms would be divided into three classes.

Those with individual tanks storing more than 10,000 gallons of oil, with an aggregate storage capacity of at least 42,000 gallons or spill histories, would need professional engineers to certify their SPCC plans.

Farms with no history of spills, and aggregate storage of between 10,000 and 42,000 could be self-certified.

The third classification, which includes farms with aggregate storage capacity of less than 10,000 and no history of spills, would be exempt from SPCC requirements.

Assistance available

For more information, or for SPCC advice, contact John Hendel at Mid-County Energy, (952) 466-3731.

“Mid-County has a team of three or four people who are experts in this area – including an outside engineer with 20-plus years of experience,” Hendel said.

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