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Q: What are the basic requirements for reporting an oil discharge for facilities covered by the Spill Prevention, Control, and Countermeasure (SPCC) regulations of the Oil Spill Prevention Act?
A: If a discharge of oil reaches waters of the United States, it is reportable to the National Response Center (NRC) under 40 CFR 110 if it causes “a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.”
In addition, thel reporting requirements established in 40 CFR 112.4. require reporting to the EPA Regional Administrator with jurisdiction when a facility experiences a discharge of:
- More than 1,000 U.S. gallons of oil in a single discharge to navigable waters or adjoining shorelines, or
- More than 42 U.S. gallons of oil in each of two discharges to navigable waters or adjoining shorelines occurring within any 12-month period.
Note that this requirement is only applicable to the amounts of oil that actually reach navigable waters or adjoining shorelines, not necessarily the total amount of oil discharged.
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Q: What information should I be prepared to provide the EPA Regional Administrator when reporting an oil discharge?
A: The EPA Regional Administrator will require the following information, and facility owners and operators must also forward a copy of it to the state oil pollution control agency or agencies with jurisdiction for the facility.
1) Name and location of the facility
2) Owner/operator name
3) Maximum storage/handling capacity of the facility and normal daily throughput
4) Corrective actions and countermeasures taken, including descriptions of equipment repairs and replacements
5) Adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary
6) Cause of the discharge to navigable waters, including a failure analysis
7) Failure analysis of the system where the discharge occurred
8) Additional preventive measures taken or planned to take to minimize discharge reoccurrence
9) Any additional information the EPA Regional Administrator may reasonably require
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Q: What information should I be prepared to provide the NRC when reporting an oil discharge?
A: The National Response Center will require the following information, some of which can be prepared in advance to help expedite reporting and response activities.
1) Name, organization, and telephone number
2) Name and address of the party responsible for the incident
3) Date and time of the discharge incident
4) Location of the discharge incident
5) Source and cause of the discharge
6) Types of material(s) discharged
7) Quantity of materials discharged
8) Danger or threat posed by the discharge
9) Number and types of injuries (if any)
10) Weather conditions at the incident location
11) Any additional information to help emergency personnel respond to the incident
Q: How do the NRC and EPA define a reportable discharge?
A: Both the NRC and the EPA use the following definition (commonly referred to as “the sheen rule”) under the authority of the Clean Water Act:
Any discharges of oil that “cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.”