The EPA extended the deadline date by which owners or operators of a farm must prepare or amend and implement a SPCC Plan from November 10, 2011 to May 10, 2013. The additional 18 months allows time for farms to come in compliance with this regulation.
Farms in operation on or before Aug. 16, '02, must maintain (have a plan in place now) and amend their existing plan if needed by May 10, '13. Farms in operation after Aug. 16, '02, but before May 10, '13 must prepare and implement a Plan on or before May. 10, '13. Farms that start operations after May 10, '13 will be required to have a plan in place before they begin operations.
Gins were excluded from this compliance date extension. Currently, gins in operation on or before Aug. 16, '02, must have a plan in place. Gins in operation after Aug. 16, '02, but before Nov. 10, '11 are also required to have a plan in place at this time. Gins that start operations after Nov. 10, '11 must have a plan in place before they begin operations.
The EPA page on the SPCC Rule site, SPCC for Agriculture, is a valuable resource. This page is dedicated to helping prevent oil spills, as well as control a spill should one occur. Detailed information regarding this compliance date extension may be found on this site. The current example template and newly added documents, including one on how to fill out the template, contain background information for the example farm -- making this process much more understandable.
The EPA's SPCC Farms Fact Sheet is perhaps the best place to start when evaluating responsibilities under the SPCC Program. Owners and operators of farms or gins should first establish whether they qualify as a regulated facility. Owners and operators are reminded that containers on separate facilities are not to be added together when determining total oil storage capacity. It is not uncommon for a farm to be comprised of multiple facilities with respect to oil storage. It is also recommended that owners and operators document and file any circumstances that exclude them from this rule. Exemption from this rule does not exclude responsibilities for cleanup of oil spills or any containment requirements for storage containers.
Owners or operators of qualified facilities should know when their Plan should be in place. They are also urged to contact a qualified Professional Engineer as soon as possible if self-certification is not an option. Don't wait until May 10, 2013 to prepare a plan.
The NCC has developed a General Summary (99k pdf and contains Federal Register notice) of the requirements for a typical cotton gin that has only press pump tanks and possibly small above ground fuel tanks. It is important to remember that contiguous or non-contiguous buildings, properties, parcels, leases, or structures under the ownership or operation of the same person may be considered separate facilities.
NCC staff also has developed a slide set (4k pdf) and a powerpoint presentation that may be useful in helping explain the basics of the SPCC Program. The slides include information regarding who is covered, what a covered facility should do, current deadlines and where to get additional information.