SPCC plan template › SPCC plans for farms
SPCC plans for farms
A farm that could spill oil into water needs an SPCC plan once it has 6,000 gallons or more of aboveground storage capacity, or 2,500 gallons or more with a reportable spill history. The farmer may sign it below 20,000 gallons if no single tank holds more than 10,000 and there's no spill history. Otherwise a Professional Engineer must certify it. These numbers come from Congress in 2014, not the farm FAQ EPA still posts.
Is it a farm?
Under the rule, a farm is a facility on land used to grow crops or raise animals, including fish, that produced and sold, or normally would have, $1,000 or more of agricultural products in a year (40 CFR 112.2). The rule's other two tests still apply: you handle oil (diesel, gasoline, lube, hydraulic, adjuvant or crop oil, vegetable oil, animal fat), and a spill could reasonably reach a creek, river, lake or other water of the United States (see who needs an SPCC plan).
The farm thresholds
| Your farm | What you need |
|---|---|
| Less than 2,500 gal | No SPCC plan |
| 2,500 to under 6,000 gal, no spill history | No SPCC plan |
| 2,500 to under 6,000 gal, with a spill history | A plan certified by a PE |
| 6,000 to under 20,000 gal, no tank over 10,000, no spill history | A plan you self-certify |
| Any tank over 10,000 gal, or 20,000 gal or more in total, or a spill history | A plan certified by a PE |
The Water Resources Reform and Development Act of 2014 (section 1049) set these numbers. It let EPA lower the 6,000-gallon line to as little as 2,500 after a study. EPA's June 2015 study concluded 2,500 was the right threshold, but as of this writing EPA has not changed the rule, and the regulation text on eCFR still shows the general 1,320-gallon line. EPA's agriculture page says it "expects to promulgate a rule." Until it does, 6,000 is the line EPA's fact sheet applies.
What a farm leaves out of the count
- Small tanks on separate parcels. Containers of 1,000 gallons or less on separate parcels are left out. Since the WIIN Act of December 16, 2016, such containers (each 1,000 gallons or less, together 2,500 gallons or less) are outside the rule entirely, not just left out of the count. The rule doesn't define "parcel," so note in your records why you treat a parcel as separate.
- Animal feed ingredients approved for livestock feed by the FDA.
- Heating oil used only at a single-family home, such as the farmhouse.
- Pesticide application equipment and its mix containers, adjuvant oil included.
- Milk and milk product containers and their piping.
- Buried tanks fully regulated under EPA's underground tank rules.
- Equipment fuel tanks. A tractor's or combine's own tank is a motive power container under the general rule.
What does count: fuel tanks on trailers, fuel trucks used only on the farm, transfer tanks in pickups, and 55-gallon drums, as EPA's farm answers say. If your parcels have separate farm identification numbers, EPA's answers say to total capacity separately for the central fueling area and for each parcel, tract or field.
A worked example
A grain farm. At the shop: two 1,000-gallon diesel tanks, a 500-gallon gasoline tank and six 55-gallon drums of hydraulic and engine oil. A 1,000-gallon fuel truck that never leaves the farm. A 100-gallon transfer tank in a pickup. A 500-gallon diesel tank on a separate rented parcel.
Shop: (2 × 1,000) + 500 + (6 × 55) = 2,830 gal Fuel truck: 1,000 gal Pickup tank: 100 gal Rented parcel: 500 gal, 1,000 or less on a separate parcel: not counted Total: 3,930 gal
Over 2,500 but under 6,000, and no spills to water: no federal SPCC plan today. Add a 3,000-gallon diesel tank and the farm reaches 6,930 gallons: it needs a plan, and the farmer may sign it. With no container over 5,000 gallons and the total under 10,000, it can use EPA's Tier I template.
Which plan a farm can sign
EPA hasn't updated the Tier I template for the 2014 law. Its certification still has you confirm the facility meets the Tier I criteria in 40 CFR 112.3(g)(1): 10,000 gallons or less in total and no container over 5,000. So:
- Up to 10,000 gallons, no container over 5,000: EPA's Tier I template fits.
- A container over 5,000 (but none over 10,000), or 10,000 to under 20,000 in total: the law lets you self-certify, but not on the template as written. The cautious route is a full self-certified plan written to 112.6(b), the Tier II format (see Tier I vs Tier II). Ask your EPA regional office if you're unsure.
- Any tank over 10,000, 20,000 or more in total, or a spill history: a PE-certified plan.
EPA's own pages disagree
EPA's "Frequent SPCC Questions for Farms" page still says to count toward 1,320 gallons and that a farm over 10,000 gallons needs a PE. Those were the numbers before 2014. EPA's agriculture page marks its older farm fact sheet "currently out of date" and points to the WRRDA fact sheet, which is what this page follows. The FAQ's other answers hold: an unlined clay dike or berm that holds the largest tank is sufficient (the rule still wants room for rain on top), and you don't file the plan with EPA.
Help EPA publishes for farms
- An example Tier I plan for a farm, with a farm diagram, and a presentation on filling in the template.
- The Tier I template itself and four containment worksheets.
- The Oil Information Center, (800) 424-9346, for questions.
Farms have had to keep a plan since May 10, 2013. EPA enforces SPCC through its regional offices; your state may have separate tank rules on top. If you'd like a filled-in draft for a qualified farm, ePlan drafts SPCC plans for farms, yards and shops from your address and tank list, for sites of 10,000 gallons or less; it doesn't cover the 10,000 to 20,000 gallon band the farm law allows. If oil from the farm reaches water, the reporting rules are the same as anywhere: see spill reporting and contacts.
Questions
Does my farm need an SPCC plan?
Only if a spill could reasonably reach water and the farm stores 6,000 gallons or more aboveground (or 2,500 or more with a reportable spill history), after leaving out small containers on separate parcels, feed ingredients, farmhouse heating oil, pesticide equipment and milk containers.
Can a farmer write their own SPCC plan?
Yes, below 20,000 gallons in total with no tank over 10,000 and no reportable spill history. Above that, a PE must certify it.
Do fuel trucks and pickup tanks count?
Yes, if they're used only on the farm. A machine's own fuel tank does not.