EPA conducted several compliance inspections in 2019 focused on the requirements of 40 CFR Part 112, Oil Pollution Prevention. Part 112 applies to facilities with aggregate aboveground storage capacity greater than 1,320 gallons of oil, which is the sum of all containers (drums, totes, tanks, oil-filled equipment, etc.) with capacity 55 gallons or more. One requirement of Part 112 is to develop and implement a Spill Prevention, Control, and Countermeasures (SPCC) plan. Trinity has assisted with the review and response to several recent EPA inspections. Some of the common findings are provided below.
- Tank inspection program deficiencies, including failure to discuss inspector qualifications
- Incomplete inventory of oil-filled operational and oil-filled manufacturing equipment
- Missing PE re-certifications after completion of corrective actions
- Incorrect contact information for facility personnel, spill response contractors, and/or government agencies
- Incomplete information related to spills from equipment failures, including oil-filled operational equipment or loading/unloading operations (e.g., direction of flow, rate of flow, quantity of oil)
- Missing information related to containment methods for equipment not requiring sized secondary containment, including piping and loading/unloading operations
- Insufficient detail related to drainage of rain water from diked areas (e.g., discussion of all pumps used to drain rain water, discussion of inspections of rain water prior to pump out, etc.)
- Failure to explicitly state that diked areas are sufficiently impervious to contain discharged oil
Each facility should review and update their SPCC plan after any change at the facility, including changes in personnel. The SPCC rule also requires a complete review and evaluation of the SPCC plan at least every five years. Based on these recent findings from EPA, Trinity recommends that any facility subject to SPCC, or potentially subject to SPCC, evaluate their respective plans or applicability documentation to determine if their facility is in compliance with all aspects of 40 CFR 112. If you have questions about the applicability criteria for SPCC or the requirements of the regulation, please contact us and we can assist you with your evaluations. Also please see our recent article “ 12 Common SPCC Misconceptions”.