At the 2013 National Institute for Storage Tank Management’s (NISTM) 15th annual conference and trade show, an EPA regulator from the Office of Emergency Management (OEM) revealed the most common SPCC violations he finds on field inspections. Yesterday, we told you about common violations for nonproduction facilities, here are some typical violations from all facility types.
- Container incompatibility. Some examples include using underground storage tanks as aboveground storage tanks and using heating oil tanks to store gasoline. This is a big no-no with the EPA.
- Containment drain valves left open.
- Poor integrity of tanks.
- No or inoperative overfill device(s) and/or no inspection of the device(s).
- Failure to address facility tanker trucks/refuelers in the SPCC Plan.
- Small containers located in buildings that don’t have proper secondary containment. Some facilities think that because a container is in a building it doesn’t need containment, but it does.
- Improper maintenance and inspection of containment structures. For example, at one facility the EPA had found that a groundhog chewed through the wall of a tank causing it to leak.
- Poor piping support.
- Buried piping after August 16, 2002, that has not complied with cathodic projection requirements.
- Poor double-wall piping.
- Poor drainage in buildings.
- Not permanently closing containers.
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
What to Expect from an SPCC Inspection
The SPCC inspection process generally consists of these activities:
- Opening conference
- A discussion of facility operations and site
- Review of a detailed SPCC checklist
- On-site review of the facility’s SPCC Plan
- Review of the facility’s records
- Facility walk-through
- Closing conference in which the EPA will give verbal feedback about the findings of the inspection
- Follow-up letter discussing deficiencies
- Enforcement (in certain cases)
After the closing conference, the EPA will send a notice describing the SPCC deficiencies found on inspection within 45 days. Within that 45-day period, it is highly recommended by the EPA that a facility corrects any issues and sends a letter back to the Agency stating what was corrected. This will typically reduce a facility’s chances of being pursued by the office of enforcement.
For more information on SPCC inspections, check out this popular Advisor article.
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You do not want to be pursued by EPA’s enforcement office. Penalties for SPCC violations can be as high as $37,500 per day, per violation with no cap. In many cases, it simply makes good financial sense for a facility to correct any issues immediately and follow the rules than to take the chance of falling out of compliance.
Be certain your SPCC plan is compliant with EHS Essentials Kit–SPCC Plan Compliance. This kit covers all the latest regulation changes with expert analysis, important FAQs, and comprehensive checklists. Create or update your SPCC plan with confidence. A sample plan will guide you in the development of a finished, usable document to achieve and sustain compliance.
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