SPCC—Regulated Oil-Storage Facilities Must Comply!
SPCC (Spill Prevention, Control, and Countermeasure) plans are required by EPA’s SPCC regulations for thousands of facilities that store oil. EPA requires regulated facilities to develop and implement an SPCC plan to avoid oil spills and minimize impacts of spills on public health and the environment. The plans must include provisions for oil spill prevention, spill response, and SPCC training. As defined in the SPCC regulations at 40 CFR 112, regulated facilities are non-transportation-related facilities with an aboveground oil storage capacity greater than 1,320 gallons or underground tanks with an oil storage capacity greater than 42,000 gallons that can be reasonably expected to discharge oil into navigable U.S. waters or shorelines.
According to EPA, more than 640,000 facilities are potentially regulated under the SPCC regulations. Many of those must have a written SPCC plan. Not having an SPCC plan can and will hurt you. Consider:
- A Maine energy corporation was fined $157,500 by EPA for failing to implement SPCC plans for six of its facilities.
- EPA fined an Oklahoma company $32,940 for not having an SPCC plan.
You can't risk any confusion about what the regulations require. EPA has increased its enforcement efforts, and SPCC plan compliance has become a top priority since the passage of the 2010 amended regulations.
Training, Inspections, and Recordkeeping: Creating Useful and Compliant Plans
SPCC-regulated facilities are subject to EPA inspections. In fact, EPA performs hundreds of SPCC inspections annually! Having a complete and implemented SPCC Plan at a facility is essential to a successful inspection. Compliance with SPCC regulations is more than environmental protection. It's also necessary to prevent penalties that could cost up to $37,500 per day.
SPCC plans also help save you time. By implementing your SPCC plan properly, you can provide effective training to employees and organize inspection checklists and records. It’s not enough to just write an SPCC plan—its procedures must be followed in order to comply with SPCC regulations! EPA inspectors are looking for implementation through proper spill prevention, spill response, training, documentation and recordkeeping, and spill containment measures when they visit a facility.
SPCC Plan Builder and Other Tools to Help You
BLR’s TRAC360 for SPCC provides all of the PE-written and reviewed templates that you need to create your facility-specific required plans, checklists, and training. Simply enter your facility’s information one time to create all of your required documents. Your information is protected and your materials are accessible anytime, anywhere from TRAC360’s secure servers.
Some of other SPCC compliance tools available through TRAC360 include:
- Online access to Professional Engineers who will answer your plan-related questions
- Alerts on changing regulations, so that you can be sure you’re up to date
- A customizable tank inspection checklist builder that includes templates for a variety of tank types
- A mobile application that enables you to instantly report a spill to state and federal regulators
- A database of enforcement activity in your EPA Region with details on what the inspector found lacking in SPCC plans and the penalties they assigned
If you need an SPCC compliance solution, BLR has it!
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