ECA
SPCC Plans for Farmers



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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

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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


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.

 

Environmental Compliance Associates, LLC

WASHINGTON OFFICE
8524 West Gage Boulevard, Bldg A-132, Kennewick, WA 99336
Voice: (509) 628-9959

IDAHO OFFICE
372 South Eagle Road, Suite 146, Eagle, ID 83616
Voice: (208) 968-9705

ecabrett@cableone.net
Cell: (208) 501-9984