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At the Connecticut Business and Industry Association’s (CBIA) 2018 Energy and Environment Conference, a panel of industry experts recommended several best practices and business strategies that companies should consider as part of their spill response preparation process beyond the mandatory Spill Prevention, Control, and Countermeasure (SPCC) requirements.
An oil production company operating in Big Horn County, Wyoming was recently fined for the discharge of approximately 162 barrels of oil into a tributary of a major river. The discharge came from a leak in a pipeline at its pumping facility. The facility is on an onshore oil gathering, pumping, and storage station that […]
There is much confusion surrounding the applicability of SPCC requirements. A question that recently came across the desk of one environmental expert involved oil in flavorings. The person asked if flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine SPCC applicability if they are stored […]
Facilities that are required to develop a Facility Response Plan (FRP) must include a facility response training program with drills and a testing program, and document the program in the FRP. Draft PREP Changes The requirement to develop and implement a program of response drills and exercises, including evaluation procedures, can be met by implementing […]
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 […]
Standard SPCC plans must describe security procedures for their operation (excluding oil production facilities). The security requirements are meant to prevent oil discharges that result from vandalism or other unauthorized access to oil containers or equipment. Security procedures must include provisions to: Secure and control access to each facility’s handling, processing, or storage areas. Secure […]
The following Table outlines the inspection requirements for tanks and associated piping at onshore nonproduction facilities that store petroleum and nonpetroleum oils—except animal fats and vegetable oils, which have their own set of inspection requirements. Note: The SPCC rule also contains integrity testing provisions for tanks, which are not included in this table. In addition, […]
Civil Penalties With a few exceptions, most violations of the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) hazardous materials regulations (HMRs) carry a civil penalty of up to $75,000 per day per violation for knowingly violating one of the HMRs. If the violation results in death, serious illness, or severe injury to any person or […]
There is much confusion concerning who an offeror is under the Pipeline and Hazardous Materials Safety Administrations (PHMSA) Hazardous Materials Regulations (HMRs). PHMSA has numerous interpretation letters that attempt to clarify this issue for individual scenarios. We found two letters we think are pertinent to help you determine whether you are an offeror under the […]
Used oil generators include all persons who produce used oil through commercial or industrial operations and vehicle services. The regulations exempt household “do-it-yourselfers,” farmers under certain conditions, vessels at sea or at port, and mixtures of used oil and diesel fuel under certain conditions. If used oil is mixed with hazardous waste, it must be managed […]