Prevent Your Company From Having Spill Prevention, Control, and Countermeasure (SPCC) Violations From the EPA

SPCC Inspections by the EPASPCC is the abbreviation for the Spill Prevention, Control, and Countermeasure (SPCC) Rule.  An EPA regulator from the Office of Emergency Management (OEM) recently revealed the most common SPCC violations he finds on field inspections.

Typical Violations from All Facility Types…

  1. Container incompatibility. Some examples include using underground storage tanks as aboveground storage tanks and using heating oil tanks to store gasoline. This is a big no-no with the EPA.
  2. Containment drain valves left open.
  3. Poor integrity of tanks.
  4. No or inoperative overfill device(s) and/or no inspection of the device(s).
  5. Failure to address facility tanker trucks/refuelers in the SPCC Plan.
  6. Small containers located in buildings that don’t have proper secondary containment. Some facilities think that because a container is in a building it doesn’t need containment, but it does.
  7. Improper maintenance and inspection of containment structures. For example, at one facility the EPA had found that a groundhog chewed through the wall of a tank causing it to leak.
  8. Poor piping support.
  9. Buried piping after August 16, 2002, that has not complied with cathodic projection requirements.
  10. Poor double-wall piping.
  11. Poor drainage in buildings and not doing regular drain cleaning.
  12. Not permanently closing containers.

The SPCC Inspection Will Generally Consists of These Activities…

  • Opening conference
  • A discussion of facility operations and site
  • Review of a detailed SPCC checklist
  • On-site review of the facility’s SPCC Plan
  • Review of the facility’s records
  • Facility walk-through
  • Closing conference in which the EPA will give verbal feedback about the findings of the inspection
  • Follow-up letter discussing deficiencies
  • Enforcement (in certain cases)

The EPA will send a notice describing the SPCC deficiencies found on inspection within 45 days of the closing conference, so it’s highly recommended that a facility corrects any issues and sends a letter back to the Agency stating what was corrected.