Monday, May 20, 2024

The Right Plan

By Mark Lange
NCC President/CEO

The National Cotton Council is reminding farm and gin owners/operators to determine if they must implement a Spill Prevention, Control and Countermeasure (SPCC) plan.

Why is compliance necessary?

EPA says the SPCC rule is to help farms and facilities prevent a discharge of oil into navigable waters or adjoining shorelines as well as control a spill should one occur. The agency says oil spills endanger public health, affect drinking water, devastate natural resources and disrupt the economy.

Who specifically needs a plan?

You need a SPCC plan if an oil spill from your farm could reach navigable water and you store oil (such as diesel, gasoline, hydraulic oil, lube oil, crop oil or vegetable oil, etc.) in either: 1) aboveground quantities of more than 1,320 gallons; or 2) completely buried tanks with more than 42,000 gallons of oil. You do not need a plan if an oil spill from your farm could not reach navigable water or you store less than 1,320 gallons of oil aboveground or less than 42,000 gallons below ground on any facility or the entire farm.

Are there plan options?

Yes. First, add up the oil storage capacity of each aboveground tank on each facility on your entire farm (only count tanks with the capacity to hold 55 gallons or more). If your farm or individual facility has 10,000 gallons or less of aboveground storage capacity; and in the three years before developing and certifying your plan you had no oil spills to water larger than: 1) 1,000 gallons in a single spill or 2) 42 gallons each from two spills within any 12-month period, then your farm is a “Tier II” farm. Thus, you must create a full SPCC plan that you may self-certify. If your farm or individual facility meets the above criteria and has no aboveground oil storage containers with a capacity greater than 5,000 gallons, then your farm is a “Tier I” farm. You may use the shorter SPCC plan template to create your SPCC plan that you may self-certify. Individual facilities with more than 10,000 gallons of aboveground storage capacity are a “Tier III” facility and will require a professional engineer’s services to develop a plan. Detailed information on responsibilities, certification and filling out plan templates are at EPA’s SPCC for Agriculture site at The NCC also has posted a number of information documents at

What are the specific deadlines?

Farms in operation on or before Aug. 16, 2002, must maintain their existing plan and amend that plan if needed by May 10, 2013. Farms in operation after that date but before May 10, 2013, must prepare and implement a plan on or before May 10, 2013. Farms that begin operations after May 10, 2013, will be required to have a plan in place before operations begin. Operating gins are required to have a plan in place at this time. New gins must have a plan in place before they can begin operations.

Mark Lange is president and chief executive officer for the National Cotton Council of America. He and other NCC leaders contribute columns on this Cotton Farming page.

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