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Creating a Tier I template for farms

This guide outlines the elements needed to create a Spill Prevention, Control, and Countermeasure (SPCC) Tier I template for farms. The goal of the SPCC program is to prevent oil spills into waters of the United States and adjoining shorelines. Oil spills can cause injuries to people and damage to the environment. A key element of this program calls for farmers and other facilities to have an oil spill prevention plan, called an SPCC Plan. These Plans can help farmers prevent oil spills which can damage water resources needed for farming operations.

What is considered a farm under SPCC?

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.”

Is my farm covered by SPCC?

SPCC applies to a farm which:

  • 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.

If your farm meets all of these criteria, then your farm is covered by SPCC.

Many farmers will need to have their Plan certified by a Professional Engineer (“PE”). However, you may be eligible to self-certify your amended Plan. If your farm has a total oil storage capacity between 1,320 and 10,000 gallons in aboveground containers, and the farm has a good spill history (as described in the SPCC rule), you may prepare and self-certify your own Plan.

Here’s a step-by-step guide on how to create a SPCC Tier I template for farms:

1. Introduction:

  • Name of the facility
  • Location
  • Owner/Operator name and address
  • Date of Plan creation
  • Regulatory Reference: This Tier I SPCC Plan is developed in accordance with 40 CFR 112.3(g)(1) of the SPCC Rule and the Self-Certification Statement in accordance with 112.6(a)(1))

2. Record of Plan Review and Amendments Five Year Review (112.5(b)):

  • Describe the process for reviewing and revising the Tier I SPCC Plan, including the frequency of reviews.
  • Mention that any changes to the facility’s operations or oil storage capacity that exceed the Tier I thresholds will necessitate an update to the plan.

3. Plan requirements

Oil Storage Containers (112.7(a)(3)(i)):

  • Nature of operations.
  • Types of oils stored (e.g., diesel, gasoline, vegetable oils).
  • Total oil storage capacity (aggregate capacity should be less than or equal to 10,000 gallons).

Secondary Containment and Oil Spill Control (112.6(a)(3)(i) and (ii), 112.7(c) and 112.9(c)(2)):

  • Identify the tanks and containers at the facility with the potential for oil discharge.
  • Note the mode of failure, the flow direction and potential quantity of the discharge.
  • List appropriate secondary containment and/or diversionary structures or equipment

4. Inspections, Testing, Recordkeeping and Personnel Training (112.7(e) and (f), 112.8(c)(6) and (d)(4), 112.9(c)(3), 112.12(c)(6) and (d)(4)):

Inspection and Recordkeeping:

  • Explain the schedule for inspections and recordkeeping practices. Ensure that records of inspections and maintenance activities are kept for at least three years.
  • Specify the location where these records are maintained.

Employee Training:

  • Briefly describe your employee training program related to SPCC requirements and spill response.
  • Mention who conducts the training and how often it is provided.

5. Security (excluding oil production facilities) 112.7(g):

  • Describe the measures taken to prevent unauthorized access to oil handling, processing, and storage area

6. Emergency Procedures and Notifications (112.7(a)(3)(iv) and 112.7(a)(5)): • Describe the basic steps to be taken in the event of an oil spill, including:

  • Immediate response actions.
  • Notification procedures (local authorities, response teams, etc.).
  • Cleanup and containment measures.
  • Documentation of spills and response actions taken.

7. Contact List (112.7(a)(3)(vi)):

  • List key contacts for the facility, including emergency contacts, regulatory agency contacts, and local emergency responders.

8. NRC Notification Procedure (112.7(a)(4) and (a)(5)):

  • Complete the EPA’s Discharge Notification Form. In the event of a discharge of oil to navigable waters or adjoining shorelines the form will be provided to the Nation Response Center.

9. Appendices:

  • Include any necessary appendices, such as site maps or diagrams, but keep it concise as Tier I plans are simplified.

10 . Signature:

  • Provide space for the authorized individual to sign and date the Tier I SPCC Plan.

This template offers a simplified approach tailored to Tier I qualified facilities. Remember that while Tier I plans have reduced requirements compared to Tier II plans, they must still comply with all applicable regulations and be kept up-to-date as per the SPCC rule.