Compliance Assistance Resources
FEDERAL SPILL PREVENTION, CONTROL,
Information for Farmers
containers of oil that
have a storage capacity of 55 gallons or more)
Containers on separate parcels (that the farmer identifies as separate facilities based on how they are operated) do not need to be added together in determining whether the 1,320-gallon applicability threshold is met.
**The key word being "capacity" - Regulations apply regardless of whether the aboveground tank is full or nearly empty.
SPCC Plan for Farms (Tier 1 Template, Blank) in Word doc
SPCC Powerpoint Presentation for Farms 01/2012 new!
Aboveground Tank Rules (includes requirements for new tank installations) new!
Workshops (check with VAAFM for the latest schedule!)
Who can use the Tier I Template to "Self Certify" and who has to hire a Professional Engineer? *
In order to Self-Certify using the Tier I Template, you must meet the eligibility criteria:
• a total aboveground oil storage capacity of 10,000 U.S. gallons or less;
• no aboveground oil storage containers with a capacity greater than 5,000 U.S. gallons; and
• in the 3 years prior to the date the SPCC Plan is certified, had no single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, or no two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 U.S. gallons within any 12-month period.*
Tier I qualified facility has the option to complete an SPCC Plan template (in Appendix G to 40 CFR part 112) in lieu of a full SPCC Plan, use the Tier I Template, or hire a Professional Engineer.
Tier II facilities must hire a Professional Engineer to certify their SPCC Plans.
What is Considered “Oil”?
Any kind of oil in any form such as crude oil; refined petroleum products (gasoline & diesel fuel); sludge; waste oil; oil emulsions; lube oils; grease; fats, oils or greases from animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and other oils and greases, including synthetic oils and mineral oils.*
What is Considered “Bulk Storage”?
A container with a capacity of 55-gallons or more.*
What does the basic SPCC Plan include?
The plan must include information on storage containers, maps and diagrams of the facility, secondary containment structures, site drainage, preventative measures, containment procedures, clean-up equipment and material, employee training, routine inspections and recordkeeping.*
Will I have to provide Security?
Yes. You will have to address how will you prevent unauthorized access and secure and control storage areas.*
Will I have to provide secondary containment for all my bulk oil containers?
YES. Secondary containment is required and must hold the contents of the largest container plus freeboard for precipitation, if outdoors (see 24-hr, 25-yr rain chart). Double-walled storage tanks meet the requirement for containment.*
If I have secondary containment in place, do I still need an SPCC Plan?
Yes. You still must have a SPCC plan.*
I don’t have secondary containment where we load and unload mobile refuelers. Am I compliant?
Maybe - if you provide effective, general secondary containment to address the most likely discharge where you transfer oil to and from containers and for mobile refuelers, such as fuel nurse tanks mounted on trucks or trailers then you meet compliance. For example, you may use sorbent materials, drip pans or curbing for these areas; and
You must “leak test” buried pipes when they are installed or repaired. EPA recommends you keep a written record of your inspections.*
Integrity Tank Testing.. Is it Required?
Yes. There is flexibitly in inspection and integrity testing, but you must use industry standards to determine the appropriate qualifications for testing.*
Do my employees need to be trained?
YES. All employees handling oil will need to be trained (at least once a year). Training should include: oil handling procedures to prevent spills and the proper response to control, contain, and clean up a spill. Training can be done in-house (third party training is not required).*
What are the certification requirements?
If a facility has 10,000 gallons or less in aboveground oil storage capacity and is able to comply with the oil spill history criteria (see following question), then the facility may prepare a self-certified plan. If a facility has oil vessels over 5,000 gals and/or has more than 10,000 gallons or fails to meet the spill history requirements, then the plan must be reviewed and certified by a Professional Engineer.*
In Order to Self-Certify a facility must meet the following “Eligibility Criteria”
Facilities must have 10,000 gals or less in aggregate aboveground oil storage capacity*
For 3yrs prior to plan certification, or if it has operated for less than 3yrs – the facility must not have had:
- A single discharge of oil to waters of the state exceeding 1,000 gals or
- Two discharges of oil to waters of the state each exceeding 42-gals (within any 12 month period).
What are “multi-media or multi-sector” inspections?
Environmental inspector’s who come to your facility may be carry a “checklist” and can ask about other activities at your facility that are regulated. The inspector may be with EPA, a state agency or even the local government. Sometimes a "team" inspection occurs, where you will be visited by 2,3, or more program inspectors at a time. These other regulated areas may include (but are not limited to):
· Air Pollution Control
· NPDES (wastewater) Permits
Water Quality (stormwater, wetlands, etc.)
· Hazardous Waste Generation (RCRA)
· Underground Storage Tanks
· Hazardous Sites
· Solid Waste
* For More Details on the SPCC Regulation for Farms, Please View Our SPCC Powerpoint Presentation For Farms 01/2012 new!
Agency of Agriculture contact for SPCC Regulation (farms):
Anne Macmillan, Agrichemical Toxicologist
A R M E S Division
116 State Street, Drawer 20
Montpelier, VT 05602-2901
Agency of Natural Resources contact for SPCC Regulation (businesses/municipalities):
Environmental Assistance Office
103 South Main Street
Waterbury, VT 05671-4911
Example and blank worksheets used to calculate secondary SPCC containment capacity can help you comply with the secondary containment requirements of the SPCC rule. These blank worksheets address four specific scenarios and may not be valid for every facility. Although the SPCC rule does not require you to show the calculations of sized secondary containment in your Plan, you should maintain documentation of secondary containment calculations to demonstrate compliance to an EPA inspector.
*Disclaimer: Please note that these are simplified calculations that assume:
1) the secondary containment is designed with a flat floor;
2) the wall height is equal for all four walls; and
3) the corners of the secondary containment system are 90 degrees.
Additionally, the calculations do not include displacement for support structures or foundations.
For Professional Engineer (PE) certified Plans, the PE may need to account for site-specific conditions associated with the secondary containment structure which may require modifications to these sample calculations to ensure good engineering practice.
*Please note: Word versions are fill-in the blank only. The PDF forms compute the calculations for you.
See State Wide Map of available spill cleanup contractors - Click here
A Facility Owner/Operator's Guide to Oil Pollution Prevention ( EPA Brochure)
Report an Environmental Violation (Vermont)
The Small Business Ombudsman (SBO) serves as an effective conduit for small businesses to access EPA and facilitate communications between the small business community and the Agency. The SBO reviews and resolves disputes with EPA and works with EPA personnel to increase their understanding of small businesses in the development and enforcement of environmental regulations. The SBO function was established in 1982 and is currently a part of EPA's Office of Small and Disadvantaged Business Utilization located within the Office of the Administrator. The SBO's primary customer group is the nation's small business community. Significant secondary customer groups include state and EPA regional small business ombudsmen and national trade associations serving small businesses.
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