Highlighting the Importance of SPCC and Response Plans

Highlighting the Importance of SPCC and Response Plans

“Companies storing large amounts of fuel must be prepared to prevent and respond to fuel spills to protect people’s health and the environment,” said Jeff KenKnight, manager of EPA Region 10 wastewater permits compliance unit. “With strong spill prevention and response plans in place, accidental fuel spills are far less likely to occur.”

The the Clean Water Act is intended to protect people and the environment. When the EPA inspects facilities and finds multiple violations of federal spill prevention rules and spill response requirements under the Clean Water Act, large fines and costs to get facilities into compliance may occur.

  • One company that failed to install sufficient containment to prevent and contain fuel spills at two of its facilities and failed to develop a federal Facility Response Plan at one facility, then spilled nearly 300 gallons of diesel fuel at one facility, some of which reached a river will pay a $27,920 federal fine, a $2,080 state fine, and complete $200,000 in secondary containment system upgrades to their transload facility that had the spill.
  • Another company that failed to install sufficient containment to prevent and contain fuel spills at one of its facilities spilled 29 gallons of diesel fuel, some of which reached another water source – a bay. That company will pay a $29,843 federal fine and complete $35,000 in stormwater control upgrades to their facility. 
  • A fuel network that failed to install sufficient containment to prevent and contain fuel spills at its facility will pay a $28,200 federal fine.

SPCC Plans

These are just a few examples that show the importance of having a strong SPCC Plan. Federal law requires that facilities with the potential for oil spills take every possible step to prevent discharges to rivers, lakes, or oceans by implementing Spill Prevention, Control, and Countermeasure plans.

Facilities with more than 1,320 gallons of aboveground fuel storage capacity must have plans to prevent and contain spills, such as installing secondary containment around fuel storage tanks and transfer areas. There are two types of qualified facilities, Tier I and II. To determine if you have a qualified facility you need to know the total capacity of aboveground oil storage containers at the facility and information on oil spills from the facility for the past three years.

Facility Response Plans

Facilities are also required by federal law to minimize environmental damage if oil spills do occur. Facility Response Plan rules under the Clean Water Act require facilities that store and distribute oil be prepared for containing and cleaning up spills. To safely respond to a spill, a facility must have adequate employee training, spill response equipment, and a contingency plan for containing and cleaning up a release. For more information on Facility Response Plans, please contact the Superfund, TRI, EPCRA, RMP & Oil Information Center.

Tank Inspections

If you are the owner or operator of a qualified facility with aboveground oil storage containers, you must inspect these containers for integrity on a regular basis in accordance with industry standards. For more information on tank inspection requirements see Chapter 7 of the SPCC Guidance for Regional Inspectors. It is a good idea to know what the inspectors will be looking for.

The SPCC Inspection Checklists in Appendix G of the guidance have been updated to reflect multiple regulatory amendments. These checklists are designed to assist EPA inspectors in conducting a thorough and nationally consistent inspection of a facility’s compliance with the SPCC rule at 40 CFR part 112.

TAIT is a Resource for Your SPCC and Response Plans

Tait Environmental Services creates, reviews, and updates SPCC and Facility Response Plans across the country. Whether you are a national client with hundreds of sites, or are someone with one facility, TAIT can help to ensure your compliance. Review our website, and read more about of TAIT’s qualifications. Not sure about your facility’s existing plans? Perhaps you know you need a new or udpated plan? Contact Us for more information.