Special Topics in Environmental Management

SPCC: The Real Cost of Coming into Compliance

Penalty—$3,650; Cost to Come into Compliance—$30,000

An onshore oil production company in Illinois racked up a rather small penalty of $3,650 for SPCC violations. However, its cost to come into compliance was a substantial $30,000.

Their violations can be divided into seven main categories:

  1. Problems with the Plan itself:
    • The facility diagram was inadequate.
    • The Plan’s prediction of equipment failure that could result in discharges was inadequate.
    • The Plan did not discuss, and the facility did not implement, appropriate containment/diversionary structures/equipment (including truck transfer areas).
  1. Problems with training:
    • There was no training on the operation and maintenance of equipment to prevent discharges.
    • There was no training on discharge procedure protocols.
    • There was no training on applicable pollution control laws and regulations.
    • There was no training on the contents of the facility’s SPCC Plan.
    • Spill prevention briefings were not scheduled or conducted periodically.
  1. Tank truck loading/unloading: There was inadequate containment for the loading area.
  2. Problems with facility drainage:

    • Before the drainage of diked areas, rainwater was not inspected, valves were not opened and resealed under responsible supervision, and records were not kept.
    • Accumulated oil on the rainwater was not removed and returned to storage or disposed of appropriately.
    • Field drainage system (drainage ditches and road ditches) oil traps, sumps, and/or skimmers were not regularly inspected and/or oil was not promptly removed.
  1. Bulk storage containers: Visual inspections of containers, foundation, and supports were not conducted periodically for deterioration and maintenance needs.
  2. Transfer operations: Aboveground valves and pipelines were not examined periodically on a scheduled basis for general condition.
  3. Substantial harm: The plan did not include a signed copy of the Certificate of the Applicability of the Substantial Harm Criteria.


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Penalty—$1,500; Cost to Come into Compliance—$65,000

A bulk storage facility in Alaska paid a measly $1,500 for SPCC violations. But the facility’s cost to come into compliance was $65,000.

This facility’s SPCC violations can be divided into six main categories:

  1. Problems with the Plan itself:
    • There was evidence of a 5-year review of the Plan by the owner or operator.
    • The Plan did not discuss additional procedures/methods/equipment not yet fully operational.
  1. Problems with inspections:
    • Inspections were not carried out according to the written procedures developed by the facility.
    • The written procedures and inspection records were not signed by the appropriate supervisor or inspector.
    • The written procedures and records of inspections were not maintained for 3 years.
  1. Problems with training:
    • There was no training on the operation and maintenance of equipment to prevent discharges.
    • There was no training on applicable pollution control laws and regulations.
    • Spill prevention briefings were not scheduled or conducted periodically.
  1. Drainage: The Plan had inadequate discussion of drainage.
  2. Problems with tanks:
    • Aboveground tanks were not subject to visual inspections.
    • Records of aboveground tank inspections were not maintained.
    • Outside of tanks were not frequently observed for signs of deterioration, leaks that might cause a spill, or accumulation of oil inside diked area.
    • There was no testing of liquid level sensing devices to ensure proper operation.
    • The Plan has inadequate or no discussion of bulk storage tanks.
  1. Problems with facility operations:
    • Aboveground valves and pipelines were not inspected regularly.
    • The Plan had inadequate or no discussion of facility transfer operations, pumping, and facility processes.

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