Issue link: https://read.dmtmag.com/i/122447
What spill prevention measures are required to be in my SPCC plan? • Use containers suitable for the oil stored. For example, use a container designed for flammable liquids to store gasoline; • Identify contractors or other local personnel who can help you clean up an oil spill; • Provide overfill prevention for your oil storage containers. You could use a high-level alarm, or audible vent, or establish a procedure to fill containers; • Provide effective, sized secondary containment for bulk storage containers, such as a dike or a remote impoundment. The containment must be able to hold the full capacity of the container plus possible rainfall. The dike may be constructed of earth or concrete. A double-walled tank may also suffice; • 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. For example, you may use sorbent materials, drip pans or curbing for these areas; and • Periodically inspect and test pipes and containers. You should visually inspect aboveground pipes and inspect aboveground containers following industry standards. You must "leak test" buried pipes when they are installed or repaired. EPA recommends you keep a written record of your inspections. Where can I get more information? Contact the EPA at http://www.epa.gov/osweroe1/content/spcc/ spcc_ag.htm or contact your local farm bureau or co-op. Finally, many farmers are under the mistaken belief that their fuel supplier is responsible for bringing their farm tanks into compliance with SPCC. This is not the case. The EPA rule requires the "owner or operator of the facility" (in this case the farm) to comply with SPCC. Of course, if the tank located at the farm is a skid tank owned by the fuel supplier, then the responsibility for SPCC compliance could arguably reside with the supplier and not the farmer – unless responsibility for compliance is assigned to the farmer through a supply contract or other written agreement in which case the farmer won't likely remain a customer for long. But, the general standard for the industry is for skid tank owners to make their tanks fully compliant with all regulations before deploying them for service in the field. It is also important to note there is no specific delivery prohibition in the federal regulations preventing marketers from placing product in a farm tank that is not SPCC compliant. The farmer remains legally responsible for spills from the tank not caused by the negligence of the supplier. In the end, providing general SPCC information to farmers will help ensure that farm tanks supplied with fuel are SPCC compliant, fuel supply deliveries will continue uninterrupted and customer loyalty bonds strengthened. S SPRING 2013 OIL PROPHETS 19