Special Topics in Environmental Management

Nonpetroleum Oils and Your SPCC Plan

A nonpetroleum oil is defined as any kind of oil that is not petroleum based, including but not limited to, fats, oils, and greases of animal, fish, or of marine mammal origin, and vegetable oils, including oils from seeds, nuts, fruits, and kernels. Like petroleum-based oils, nonpetroleum oils can have adverse effects on the environment. Nonpetroleum oil spills into water can result in depleted dissolved oxygen levels, which can then harm aquatic organisms. The oil can also coat the fur or feathers of wildlife

Animal fats and vegetable oils. Non-transportation-related facilities that handle, store, or transport animal fats and vegetable oils are required to develop and implement a Facility Response Plan (FRP). The FRP must identify specific methodology for calculating volumes for “worst case” discharges of animal fats and vegetable oils. Animal fats and vegetable oils are broken down into three groups on the basis of their specific gravity, as follows:

__ Group A (specific gravity of less than 0.8)
__ Group B (specific gravity equal to or greater than 0.8 and less than 1.0)
__ Group C (specific gravity equal to or more than 1.0)

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Deadline Reminder! Farms in operation on or before August 16, 2002, must maintain or amend their existing Plan by May 10, 2013. Any farm that started operation after August 16, 2002, but before May 10, 2013, must prepare and use an SPCC Plan on or before May 10, 2013.

Extension for Farmers Who Can’t Meet the May 10, 2013 Deadline

The EPA Regional Administrator (RA) for the state where the farm is located may be able to provide a time extension to the farmer to amend or prepare an SPCC Plan. Farmers who cannot meet the May 10, 2013, compliance date because a Professional Engineer (PE) isn’t available, are located in areas impacted by floods, or that must make facility modifications that will not be completed in time, may request an extension by submitting a written request to the RA.

Your request must include:

(i) An explanation of the cause for the delay and the specific aspects of the Plan affected by the delay;
(ii) A discussion of actions being taken or contemplated to minimize the delay; and
(iii) A proposed time schedule for the implementation of any corrective actions being taken, including interim dates for completion of tests or studies, installation and operation of any necessary equipment, or other preventive measures.

In addition you can provide additional oral or written statements in support of your extension request.

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If you were required to have an SPCC Plan because you were operating before August 16, 2002, the RA may request a copy of your SPCC Plan to evaluate your extension request. The RA may grant an extension when he finds that a farmer cannot fully comply with the SPCC requirements because either qualified personnel are not available, or there are delays in construction or equipment delivery beyond the control and without the fault of the farmer.

Please note that farmers who submit an extension request must still comply with SPCC requirements. If the RA authorizes an extension of time for particular equipment or specific aspects of your Plan, you must still comply with the requirements related to other equipment or other specific aspects of your Plan for which the RA has not authorized an extension.

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