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Environmental Compliance Associates, LLC

The 2011 SPCC Rule

Tri-State Grain Growers Convention November 2011

Spokane, WA


OVERVIEW

NEW DEADLINE!

Oils or not?

Navigable water or not?

Exempt or not?

Definition of a facility

Secondary containment

Tier 1 SPCC Plan walk through

QUESTIONS


Spokane, WA


On October 18, 2011, due to unusual fires and flooding across the United States,

the USDA pressured the EPA to extend the SPCC compliance deadline

FOR FARMS ONLY to…

May 10, 2013*

Keep posted by frequently going to EPA’s Emergency Management website at:

http://www.epa.gov/emergencies/content/spcc/index.htm http://www.epa.gov/emergencies/content/spcc/index.htm

* From EPA’s EM website – “The amendment does not remove the regulatory requirement for owners or operators of farms in operation before August 16, 2002, to maintain and continue implementing an SPCC Plan in accordance with the SPCC regulations then in effect.”


Spokane, WA

http://www.epa.gov/emergencies/content/spcc/index.htm


OILS

FUEL Diesel fuel additives

Lube oil Waste oil

ATF Grease

Solvents (ie, naphtha) Animal fats

Oils from seeds and nuts

Source – Clean Water Act


Spokane, WA


NOT OILS

Antifreeze Alcohols

Solvents (ie, benzene, xylene)

Source – Clean Water Act


Spokane, WA


NAVIGABLE WATERS

Permanent waterways

Interstate waters

Waters used for recreational purposes

Waters from which fish or shellfish are taken

Tributaries (intermittent streams)


Spokane, WA


NOT NAVIGABLE WATERS

Wastewater treatment ponds

Prior converted cropland

Water-filled manmade depressions

Erosional gullies and ditches (not tributaries)


Spokane, WA


EXEMPT or not? Your farm is subject to 40CFR112 if:

1,320 total gallons per facility but you can ignore…

containers less than 55 gallons capacity HOME (only) heating oil tanks mobile fuel tanks

A spill can reach a navigable water (not “Old Man River” anymore!)


Spokane, WA


WHAT is a facility? 40CFR112.2 (Definitions)

A facility is any building, structure, installation or equipment used to store oil.

Several nearby locations with common or interdependent operational activities would probably be considered a single facility.


Spokane, WA


Sized secondary containment (only for containers ≥ 55 gallons capacity)

Any structure or system that is “sufficiently impervious” to impede oil flow.

EXAMPLES are: soil floor + soil berms soil floor + concrete berms soil floor + membrane-covered berms concrete floor + membrane-covered berms concrete floor + concrete berms whatever works best for specific setting

≥ means “greater than or equal to”


Spokane, WA


Example of a sufficiently impervious liner


Spokane, WA


Tier 1 and 2 Facilities

Qualified facilities having a total oil storage capacity ≤ 10,000 gallons, as follows:

Tier 1 – all containers ≤ 5,000 gallons

Tier 2 – any container > 5,000 gallons

≤ means “less than or equal to”

> means “greater than”


Spokane, WA


Qualified Facilities may self-certify, provided they: Have an aggregate oil storage capacity of 10,000 gallons or less

Have not experienced reportable spills for past 3 years

Environmentally equivalent alternatives are made by a PE inre:

Secondary Containment

Loading Racks

Oil-filled equipment doesn’t need secondary containment

Electrical transformers

Motive power containers are exempt from the Rule Fuel tanks

Mobile refuelers don’t need secondary containment Fuel supply (tanker) trucks


Spokane, WA


Tier 1 SPCC Plan Template



http://www.epa.gov/emergencies/content/spcc/spcc_agtrain.htm

http://www.epa.gov/emergencies/content/spcc/spcc_agtrain.htm




Spokane, WA

A complete (not streamlined) SPCC Plan.

For step-by-step guidance go to:

http://www.dtsc.ca.gov/HazardousWaste/CUPA/upload/SPCC_Tier _II_Qualified_Facility.pdf


www.e-c-associates.com [email protected]

(509) 628-9959


Spokane, WA

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