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The top violation DOT inspectors have found so far in FY 2015 is that packages are not secured in vehicles. At 1,207 violations, this mistake accounted for 8.12% of the total violations. Following at a close second, inspectors have found 1,197 instances when there was no copy of the U.S. DOT registration number in the […]
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: Problems with the Plan itself: The facility diagram was inadequate. The […]
A Look at Common Ski Area SPCC Violations Having an SPCC Plan that was not fully implemented. 40 CFR Section 112.3, states, “The owner or operator or an onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention, Control, and Countermeasure Plan … in accordance with 112.7 [General […]
Multiple Ski Areas Learn SPCC Compliance Lesson Over the past few years, the U.S. Environmental Protection Agency (EPA) has reached settlements with a number of ski areas in New England communities throughout Maine, New Hampshire, and Vermont. According to the EPA, the settlements “were reached under an expedited settlement program whereby EPA agreed to resolve […]
SPCC Inspection, Evaluation, and Testing—5 Specific Things Inspectors Are Looking For 1) Regular leak testing of tanks that are completely buried. Any completely buried tank that was installed on or after January 10, 1974, must be leak tested regularly “in accordance with industry standards or at a frequency sufficient to prevent leaks.” While there are […]
SPCC Inspection, Evaluation, and Testing—5 General Things Inspectors Are Looking For 1) A complete SPCC Plan that contains a description of “the scope and schedule of inspection, evaluation, and testing to be performed on bulk containers.” In its SPCC Guidance for Regional Inspectors, the EPA references the following sections of 40 CFR 112 that address […]
UST O&M—Changes in the Works Historically, the Environmental Protection Agency’s (EPA) UST regulations were focused on improved equipment, with not a lot of attention given to O&M practices. However, based on more than 20 years of regulatory experience, the EPA acknowledges that a higher level of O&M, in addition to better equipment, is required to […]
Managing UST compliance takes a long-term commitment for facility operators who have to fill out dozens of forms and checklists and maintain accurate records, to mention a few of the many requirements. But even those facilities that are doing everything right should anticipate an inspection at some point, with or without prior notice.