ECA prepares SPCC Plans
for farms in Idaho, Oregon Washington and the rest of
the United States.
SP001
Tank Inspections and Certifications
NEWS: Idaho
farm fined $9,500 for not having an SPCC Plan
Learn More
(most) Everything you wanted to know
about the SPCC Rule but were afraid to ask - by Brett D. Smith, PE
ECA's talk
on The Final Spill Rule at the 2011
Tri-State Grain Growers Convention in Spokane, WA.
ECA's talk
on The Final Spill Rule at the 2007
NWPPA's Engineering and Operations Conference in
Tacoma, WA.
SP001
Tank Inspections brochure
EPA Tank Inspection
fact sheet
PEI
Journal's Integrity Testing Shop-Fabricated
Aboveground Storage Tanks
A PDF reader is required to view
these documents.
Go to Adobe Acrobat Reader (http://get.adobe.com/reader) or
Primo PDF (http://www.primopdf.com) for
FREE downloads.
NEW 2015 SPCC LAW FOR
FARMS!
June 10, 2014 - President
Barack Obama signs H.R. 3080, the Water Resources
Reform & Development Act of 2014. Vice President
Joe Biden
and stakeholders share the stage with the President
in the Eisenhower Executive Office Building South
Court Auditorium (Official White House Photo by Pete
Souza).
The June 2014 Water
Resources Reform and Development Act (WRRDA) eases
the burden of the SPCC Rule for farms.
The Spill Prevention, Control
and Countermeasure (SPCC) Rule requires compliance
for any farm having an aggregate (combined)
aboveground oil or fuel storage of 6,000 gallons or
more and allows farms to self-certify, when this
limit doesn’t exceed 10,000 gallons. An
“oil” includes animal fat, oil and/or
grease, as well as vegetable oils. Some of these oils
make up the base of liquid cattle feeds. By
the way - “oil” does not include pure
ethanol or antifreeze.
The WRRDA legislation does NOT exempt farms from the
SPCC Rule BUT it does give them a regulatory break,
by raising the combined aboveground oil / fuel limit
to 6,000 gallons, when a clean spill history is
demonstrated.
So,
farms having less than 6,000 gallons oil / fuel do
NOT need an SPCC Plan!
The WRRDA legislation modifies the EPA requirement
for a self-certified SPCC Plan (Plan) to farms that
can demonstrate a clean spill history and combined
aboveground oil / fuel storage between 6,000 and
20,000 gallons, with no single tank exceeding 10,000
gallons in capacity. WRRDA also exempts oil / fuel
tanks with a capacity of 1,000 gallons or less from
being included in the “combined”
calculation.
These farms may
self-certify as Tier 1 / Tier 2 facilities, using the
FREE Plan templates provided online by the EPA. Click this link for
templates - Tier I Qualified
Facility SPCC Plan Template | US
Tier 1 or Tier 2? A
Tier 1 farm has a combined oil / fuel storage of less
than 10,000 gallons and no single tank greater than
5,000 gallons capacity, whereas a Tier 2 farm is
basically a Tier 1 farm with one or more tanks having
a capacity that exceeds 5,000 gallons.
All
other farms need a Plan that's certified by a
Professional Engineer (PE).
We'll
help you comply with the SPCC Rule, in one of the
following ways:
Do-it-yourself
Tier 1 / Tier 2 Plan (Cost: $350 - $500) - Because the EPA already provides the
necessary Tier 1 / Tier 2 Plan templates, we will
help you complete the appropriate Tier 1 / Tier 2
form for only $350. If you wish to include photos (not
necessary) and also replace the EPA's
attachments with our time-tested appendices
(attachments), we will create a customized, editable
Plan template for $500.
We-do-it-for-you
Tier 1 / Tier 2 Plan (Cost: $950
- $1,500) -
Utilizing Tier 1 / Tier 2 templates and phone / email
discussions with you, we will complete the
appropriate form for $950. If you wish to include
photos (not necessary) and
also replace the EPA's attachments with our
time-tested appendices, we will create a customized,
finished Plan for $1,500.
The
SPCC Rule does NOT require a "third party
expert" / PE to visit / inspect self-certified
Tier 1 / Tier 2 facilities (farms), as such
inspections only apply to Tier 3 facilities! Since we don't do an unnecessary facility
visit, our fee for this service is often lower than
other SPCC consultants.
We-do-it-all
Tier 3 (> 20,000-gallon) Plan (Cost: $3,000 -
$3,950) - We visit
your farm and discuss noteworthy best management
practices with you, then return to our office and
prepare a customized Plan for you, using our
time-proven templates. Your Plan is stamped /
certified by an experienced PE in good standing with
the Board of Professional Engineers that oversees the State where your
farm is located.
Do
I need SPCC training?
NO! A well-written Plan clearly provides you
with sufficient detailed oil / fuel handling
procedures, to eliminate the need for in-person
training, when dealing with relatively simple farming
operations. However, complicated facilities having
numerous, high-capacity tanks (jobbers and chemical
plants) quite often want third-party training but
farms typically do not! Nonetheless, if you need
additional assistance with the oil-handling
procedures or anything else discussed in your Plan,
we'll gladly walk you through them (1 hour free via
phone) and if you STILL need further assistance,
we'll happily visit your farm and conduct onsite
oil-handling and SPCC (understanding your Plan)
training for a reasonable fee (zero mark-up time /
materials costs). In such circumstances, we suggest
that you gather up a group of peers, to help
"co-op" the training cost!
Tank Inspections
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Section 112.8(c)(6) of
the SPCC Rule requires facility owners to perform
tank integrity inspections by way of "accepted
industry standards", namely the Steel Tank
Institute's SP001 (5th Edition) Standard and/or the
API-653 Standard created by the American Petroleum
Institute (API). All shop-built or field-erected
steel tanks greater than 30 feet in diameter and
taller than 50 feet are addressed by API-653, whereas
smaller sized tanks are addressed by SP001.
We are
trained (certified) to perform formal tank
inspections via the SP001 Standard.
Our certified SP001 tank
inspectors and ultrasonic thickness testing (UTT)
professionals strictly follow the SP001 Standard and
provide inspection reports containing detailed
findings and cost-effective recommendations that will
keep your tanks in compliance with the EPA for years
to come.
Can
all SPCC contractors inspect your aboveground tanks?
NO! Only certified SP001 tank
inspectors are allowed to "assess" or
inspect tanks! A proper tank inspection
typically involves a UTT professional and an
SP001-trained inspector, who is the only person
allowed to prepare a tank inspection or
"assessment" report!
Call
the Steel Tank Institute at (847)
438-8265, for a current listing of certified
aboveground tank inspectors.
WHY
HIRE US? For more than 12 years, ECA
has
helped clients address SPCC compliance issues, by
performing facility inspections, writing Plans,
offering best management practice recommendations and
interacting (as needed) with the EPA on behalf of our
clients. Our managing principal is a registered PE and
certified SP001 tank inspector and has authored
articles and given talks / seminars on the SPCC Rule
since 2002.
For
these reasons, ECA is your best
resource regarding all aspects
of SPCC compliance!
Typical
SPCC Compliance Projects
CLIENT:
Port of Othello
PROJECT: Spill Prevention, Control and
Countermeasure (SPCC) Plan
LOCATION: Othello, Washington
PROJECT
DESCRIPTION: ECA inspected the Port of
Othello Refueling Facility located at the Municipal
Airport and prepared an SPCC Plan for this eastern
Washington facility.
CLIENT:
Bernt Lehn Farm
PROJECT: SPCC Plan
LOCATION: Farmington, Washington
PROJECT
DESCRIPTION: Prepared SPCC Plan for an eastern
Washington dry-land farming operation.
CLIENT:
Grant County PUD
PROJECT: STI Standard SP001 Aboveground
Storage Tank Inspections
LOCATION: Wanapum and Priest Rapids Dams,
Columbia River, Washington
PROJECT
DESCRIPTION: ECA staff performed
inspections of horizontal Category 1 fuel storage
tanks located within Oil Storage Rooms for two
hydroelectric facilities along the Columbia River,
following STI's SP001 (5th Ed) tank integrity
inspection Standard. Ultrasonic testing measurements
were performed with industry standard QA/QC regarding
thickness calibrations and instrument functionality.
Tanks that met Steel Tank Institute inspection
criteria were certified, whereas cost-conscious
recommendations were provided regarding deficient
tanks.
CLIENTS:
Busch Distributors, Byrnes Oil, Coleman Oil Company
(regional oil companies / petroleum marketers)
PROJECT: Numerous SPCC Plans
LOCATION: Idaho and Washington
PROJECT
DESCRIPTION: Performed inspections of numerous
fuel storage facilities and prepared SPCC Plans for
same. Utilized geotechnical soil sampling to provide
secondary containment alternatives that often
precluded expensive concrete flooring for established
tank farm containment systems, thus saving clients
considerable capital costs.
