The Agrichemical Containment program requires the use of approved containment structures to help prevent spills of pesticides and fertilizers from contaminating soil and groundwater. Fertilizers and pesticides stored in bulk quantities at agricultural chemical storage facilities must comply with agency bulk storage rules, ch. ATCP 33 Wis. Adm. Code. Generally, these rules apply to bulk storage of fertilizers and pesticides where the products are being stored for distribution. The term “bulk” refers to more than 55 gallons of liquid or 100 pounds of dry fertilizer or pesticide. An example where the bulk storage rules do not apply is when bulk product is stored on a farm for the owner’s use, with no further distribution of those products.
Chart 1 summarizes inspections completed by DATCP’s containment program over the last five years. The containment program has emphasized inspections at bulk facilities over the last several years, but the program also oversees compliance for mixing and loading of non-bulk pesticides under ch. ATCP 29.
In 2014, new construction plans were submitted continuously throughout the year, with 41 plan reviews on 20 projects. To help ensure construction was being performed in compliance with project plans submitted for review, DATCP continued construction observation activities, with engineering staff from the Bureau of Land and Water Resources Management (LWRM) assisting the Bureau of Agrichemical Management in spot-checking construction of new containment structures. Performing these spot observations allows the Department to point out any errors or deficiencies of pre-pour construction. This allows the contractor to bring the project into compliance with the engineer’s design and state requirements.
Our observations have been that both the managers and contractors at these under-construction facilities appreciate the guidance and efforts of the attending LWRM field engineers. It is worth adding that construction oversight often required more than one visit and a significant time commitment on the part of multiple LWRM engineering staff. With just one containment engineer in the ACM Bureau, these inspections could not have occurred were it not for the inter-bureau collaboration.
In 2014, only 2 of the 32 facilities where sumps were inspected had a leaking sump. One of the leaking sumps was constructed before the minimum design standards were required. The other was created without facility personnel realizing their operations require compliance with the bulk rules, so it is probable the design and construction did not comply with the bulk rules and minimum design standards. As noted in previous years, DATCP also tested several sumps at facilities that submitted design plans according to the revised rules and minimum design standards. None of these new sumps have been found to be leaking.
Direction for the Coming Year
Based on the number of new construction plans reviewed in 2014, DATCP anticipates that there will be year-long demand for design plan reviews and construction observations in the coming year. Considering the value of these observations to both construction contractors and owners, DATCP will continue to utilize LWRM engineers to perform new construction spot checks in 2015. However, due to workload issues, LWRM engineers will not perform such observations at sites where the owner hires a private design engineer/architect or qualified third-party inspector to oversee and inspect the construction.
DATCP will also be emphasizing the requirement for minibulks to be located in a secondary containment structure. Many facilities in 2014 were found to be overlooking this requirement. Further, DATCP will be placing more emphasis on dry fertilizer handling and spillage recovery at bulk storage facilities, as well as systems for unloading liquid fertilizer from railcars to storage containers. Inspections in 2014 showed several sites with spilled dry fertilizer that had not been adequately or promptly cleaned up and several railcar unload systems that did not satisfy the minimum requirements of the rule.
For more information about any of the bureau programs you may email the department.
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