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Inadequate Tank Inspection Records
One of the biggest compliance problems industry has with SPCC is keeping good records of oil tank inspections. Thirteen percent of the citations of the bulk storage facilities were regarding tank inspections. These citations included records not being kept for the required 3 years and having no inspection records at all. Of the facilities that did have records to show the regulators, the majority of the citations were because the records did not include inspections of tank supports/foundations, deterioration, discharges, and/or accumulations of oil.
Although the majority of the 276 citations for onshore production facilities were also for lacking or inadequate tank inspection records, the citations for these facilities mainly included:
- Aboveground valves and pipelines are not examined periodically on a scheduled basis for general condition (includes items such as flange joints, valve glands and bodies, drip pans, pipeline supports, bleeder and gauge valves, polish rods/stuffing box).
- Visual inspections of containers, foundations, and supports are not conducted periodically for deterioration and maintenance needs.
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Tackling Training
More than 16 percent of the 281 citations for bulk storage facilities included SPCC training citations. What seems to be the most trying for these facilities are training workers on a regular basis, keeping training records for the required 3 years, and training them properly on the SPCC rules and regulations.
Eighteen percent of the citations for onshore oil production facilities were for personnel training. The crux of training for these facilities is really in training record maintenance; however, other common citations were:
- No training on the operation and maintenance of equipment to prevent discharges
- No training on discharge procedure protocols
- No training on the applicable pollution control laws, rules, and regulations
- No training on the contents of the SPCC Plan
- Spill prevention briefings not scheduled and conducted periodically
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Remember, a U.S. Environmental Protection Agency inspector will most likely talk to your facility’s oil-handling personnel about your SPCC Plan. If workers cannot speak accurately to the oil spill prevention measures, you’ll have a hard time convincing a regulator that you are training your workers properly.