US EPA Oil Spill Prevention Program—How it affects Illinois farmers
By: Ted Funk, PhD, PE
ph. 217-369-7716
Oil spills make big news. Spills we hear most about involve oceangoing tankers, rail cars, or pipelines. However, the US Environmental Protection Agency is also concerned about the potential for smaller-scale spills, and the ones that could occur closer to home here in rural Illinois.
A water quality protection program that’s been on the books for many years has some new twists to it, and it can apply to many farmsteads in our state. It also has a deadline for compliance—and that date for farms is May 10, 2013. EPA moved the original 2011 deadline in response to the widespread flooding prior to the time plans were due. Because the deadline was moved twice, many of us in the producer education business let the program slip off our radar. Now it’s back, and the time is pretty close.
The program is called Spill Prevention, Control, and Countermeasure (SPCC); it’s designed to prevent or reduce impacts of oil spills to waters of the US. Lest you think the only rural areas in Illinois that would be affected are the myriad oil wells and tanks sprinkled across the landscape, read on.
Some Illinois farm groups have already held meetings on the SPCC program over the last couple of years. Industrial customers who store, transport, and sell oil products are familiar with SPCC. The SPCC program is operated by US EPA (Illinois is in Region 5, and the main regional office is in Chicago). Illinois EPA is not involved.
As with many regulatory pollution-prevention programs, the SPCC program has some threshold numbers and some exemptions. Farmers really need to know if their operations qualify to put them into the program; if they should be participating but don’t have a valid SPCC plan for the farm, there could be greater monetary penalties in the case of an oil spill that pollutes waters of the US.
The requirement is to have an SPCC plan in certain cases. Here’s the language from the EPA website, Oil Spills and Farms: Protecting your Business.“You need an SPCC Plan ifan oil spill from your farm could reach water and you store oil (such as diesel, gasoline, hydraulic oil, lube oil, crop oil or vegetable oil, etc.) in aboveground quantities of more than 1,320 gallons, or completely buried tanks with more than 42,000 gallons of oil.
You do not need an SPCC Plan ifyou store less than 1,320 gallons of oil aboveground, or less than 42,000 gallons below ground.”
Suffice it to say that, if you qualify for the program based on capacity, an oil spill from your farm could reach water (that’s a short way of saying navigable waters of the US). It’s hard to argue for Illinois situations that an oil spill could never reach water.
Sounds simple enough to determine for your case, but you do need a couple of definitions. First, what’s counted as “oil”? Liquid fuels, heating oil (not residential), lubricating oil, hydraulic oil, crop oil, and even some feeds such as whey and liquid fats, should be counted.Your propane tank doesn’t count. Second, how you calculate the size—it’s shell capacity, not current contents. You add up the capacities of all containers bigger than 55 gallons. Exempted are bulk milk tanks on dairies, and heating oil tanks used exclusively for heating your residence. There are other exemptions, such as a new tank that’s never had oil in it.
Farms that need a plan also may fall into one of two plan tiers, based on capacity and oil-spill history. Tier I farms have less than 10,000 gallons of oil storage above ground, no single container larger than 5,000 gallons, and no disqualifying oil spill history. Your farm needs a Tier II plan, but you can write the plan yourself and self-certify without a professional engineer stamping the plan, if the farm has less than 10,000 gallons storage above ground but a single container of more than 5,000 gallons, and no disqualifying oil spill history. Other situations may require a professional engineer to develop and stamp the SPCC plan.
The EPA website ( has a template for a farm Tier I plan. As you’d expect, it requires maps, descriptions of containers and equipment, inspection checklists, training records, and emergency response plans.
For more information, check out the U of I Extension website The last word is, of course, the US EPA (website noted above.) Illinois livestock producers should feel free to contact the author of this article, Ted Funk, with general questions and further guidance on the SPCC plan process.
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