Here is what we learned at the meeting. These rules are Federally mandated under the SPCC program.

A containment can consist of a concrete structure, a steel structure with the bin sheets such as Ramsdells sells, an earthen dike, or a combination of the above. The earthen dike should be composed of clay, and when placing it you should dig down to clay sub soil and build it back up. This is the least favored method and I would be surprised if this one is allowed for many more years. Your containment must hold 110% of your largest tanks capacity, plus the displacement of the other tanks in the containment. Anotherwards, if you have a 10,000 gallon tank as your largest tank, your containment will have to be able to hold 11,000 gallons plus the volume that the other tanks will displace in it.

All tanks must be vented properly according to size and have double vents. I think our 10,000 gallon tank needs to have something like an 8" main vent in the roof (we will cut it in the manhole). Apparently that 2" vent in the middle we've used for 25 years isn't good enough. Sight gauges like we've all been using are NOT allowed. You need to install a tape and float system to indicate tank level and mark the tank with paint or vinyl stickers as to how full you can fill it as well as marking the tank as to what it contains. I don't have it in my notes, but you can only fill a tank to 80 or 90% of capacity.

The SPCC applies to farms which store petroleum products (Liquid Propane is not included by my understanding) in quantities greater than 1320 gallons above ground or 42,000 gallons below ground and if a spill occurs, the water could reach waters of the US, such as lakes, rivers, or creeks. If you're thinking your underground tanks get you out of this, think again. They need to be double walled tanks if they are underground. Period. The reason for the 42,000 statement is that if you have over that you need to have a SPCC plan in place which is a spill prevention plan. Only containers with a capacity equal to or greater than 55 gallons are counted at a facility.

Your storage capacity equals shell capacity. It doesn't matter if you pinky swear that you'll never put over 1,000 gallons in that 10,000 gallon tank, you are subject to the regulations with that tank in the yard. Many farmers will need to have a professional engineer certify their plan, and many will be able to certify their own. You will need to have this done by or before November 10th, 2011. Your plan will include specific facility information, list of containers, spill prevention measures, etc.

In 2009 some exemptions were made to the regulations. Exempt equipment includes: sprayers, crop dusters, and related mix containers and residential heating oil tanks. Farms are also not required to have a loading rack containment- you don't need a sloped pad and sump where you park your tractors when you fill.

The owner has discretion in determining which buildings, properties, parcels, structures, etc. make up a facility. This provides some room to work in that, say you have two 1000 gallon tanks on your farm and your farm sits on a quarter line, or you have buildings on both sides of the road, or whatever. You can place one tank by your shop, and another across the road at your shop and they can be considered two different facilities. A boundary, be it physical or non-physical is going to work best for this. Say a section line, road, tree grove, etc.

Security requirements: You need to secure and control access to the area, valves, and prevent unauthorized access. Basically this means if it's in your yard, you should have the area well lit, and if it's out by a road, you should place a fence around it.

Manmade structures: This one will cover most guys who use bulk oil. If you have your oil placed within a building, and your building has a splash board around the outside, or a concrete stub wall, you can use it as a containment. A 40+ x 40+ building with a 6" stub wall will hold an unbelievable amount of liquid. All you need is a way of plugging the floor drain outlet or to not have one at all.

Tier I facilities are those that may complete and self implement a SPCC plan. All others are considered Tier II facilities. In order to qualify for Tier I, you must have 10,000 gallons or less of above ground storage capacity and have good standing with the EPA.....as in no spills within the last 3 years. Maximum individual container capacity to qualify for Tier I is 5,000 gallons.

Tier I Template


Category 1- A tank with secondary containment in which a release would be immediately detected with no danger of escaping. (concrete, plastic liner, etc.)
Category 2- Earthen secondary containment or combination.
Category 3- No means of secondary containment

P- Periodic AST inspection
E- Formal exteernal inspection by certified inspector
I- Formal interior inspection by certified inspector
L- Leak test

() = denotes years between inspections 

(Inspection Schedule.JPG)

Inspection Schedule.JPG (30KB - 108 downloads)