Agricultural SPCC Compliance

Challenge

Mundell was asked to assist the members of Indiana Farm Bureau (IFB) in becoming compliant with the United States Environmental Protection Agency (U.S. EPA) Spill Prevention, Control and Countermeasure Plans (SPCC) regulations found in Part 40 of the Code of Federal Regulations Section 112. Prior to 2006, farmers had been exempt from SPCC regulations. The US EPA SPCC regulations amended in 2006 and 2009 resulted in certain types of farms (those not triggered by animal fat storage) being required to comply with the regulation by November 10, 2010. The challenge to bring IFB members into SPCC compliance was brought to MUNDELL during the fall of 2010, approximately three months prior to the compliance deadline.

Action

Mundell worked with IFB members at a fixed rate to educate and provide SPCC compliance services to farmers across Indiana. Mundell  personal have performed inspections in the following areas at each site: drainage control; bulk storage tanks/secondary containment; facility transfer operations; facility truck loading/unloading operations; inspections/record keeping; site security; personnel training and spill prevention procedures; spill control equipment; and emergency contacts. Following the site visits, Mundell prepared Tier I (oil storage capacity between 1,320 and 10,000 gallons in aboveground containers) or a Tier II Professional Engineer (storage capacity of more than 10,000 gallons) SPCC plans for contracted farmers. The SPCC plan included information gathered during Site visit and gave recommendations based on the latest federal regulations and best management practices.

Results

Mundell personnel successfully developed and implemented a SPCC Program with the IFB, providing reduced cost SPCC Plans for farmers across Indiana. SPCC plans were created at a variety of agricultural farms including farms that produced crops, distilled mint and live stock. Mundell was able to successfully assist farmers in the design and construction of secondary containment structures at Sites that did not have the necessary structures already in place, thereby reducing their risks and strengthening compliance.