In this case, citations hit all of the SPCC pain points–inadequate training, poor recordkeeping, and a lacking SPCC plan.
Insufficient SPCC training. EPA inspectors said personnel working at two of the facilities had no training on discharge procedure protocols; no training on applicable pollution control laws, rules, and regulations; and the company did not maintain training records for 3 years as required by federal law.
See this Environmental Daily Advisor video on the SPCC training requirements.
Poor recordkeeping. EPA found that inspection records were not available for review.
No SPCC plan. One of the three oil production facility was found to have no contingency plan.
EPA reports that the company has since corrected the above issues and is no longer in violation of SPCC regulations.
SPCC regulations require onshore oil production facilities to provide spill prevention, preparedness and response to prevent oil spills. Looking out for SPCC compliance is one of EPA’s highest enforcement priorities because a spill of only 1 gallon of oil can contaminate 1 million gallons of water.
EPA’s SPCC regulation affects over 630,000 facilities. Is yours one? Download your EHS Essentials Kit—SPCC Plan Compliance now for all the tools you need to be in compliance. Download Now
Why Are SPCC Plans Needed?
The results of a nationwide EPA analysis indicate that facilities with larger storage capacity are likely to have a greater number of oil spills, to have larger volumes of oil spilled, and to incur greater cleanup costs. Similar increases may be found at facilities with more tanks and greater annual throughput.
In addition, EPA’s analysis shows that oil storage facilities in different industry sectors vary in their total storage capacity, number of tanks, and annual throughput volume. Consumption facilities, distribution facilities, production facilities, farms, and institutional facilities, all of which may store oil, do not necessarily conduct their storage operations in the same way.
EPA studies and field experience have shown that being prepared with a complete and up-to-date SPCC plan reduces both the number and volume of spills. In addition, releases are better contained and impacts to waterways and significant habitats can be significantly reduced.
Standard facility practices created as part of the SPCC process, such as leak detection for tanks, spill and overfill protection, external pipe protection, and secondary containment, also reduce the number and magnitude of oil spills.
Don’t risk an EPA fine! Stay in compliance with our EHS Essentials Kit—SPCC Plan Compliance. Download now for instant access to comprehensive checklists, common violations, training materials, forms, and more. Download Now
Reduce Your Chances of Having a Spill
As a general rule of thumb, the propensity to have an oil spill, the severity of spills, and the costs of cleaning up the spill go up with the total:
- Oil storage capacity at the facility
- Number of tanks at the facility
- Throughput and transfer of oil at the facility
As such, it may be prudent for facility owners and operators to reduce, where possible, these items.
Just in case you’re not sure—find out how you can tell if you are subject to SPCC rules.
If inspecting your SPCC regulated containers is a problem for you too, see tomorrow’s Advisor for help with developing an inspection program before EPA comes looking for you.