Stay Ahead, Stay Compliant: EPA Revises its SPCC Expedited Enforcement Program

Posted Jan 14, 2020Stay Ahead, Stay Compliant:  EPA Revises its SPCC Expedited Enforcement Program

The U.S. Environmental Protection Agency (EPA) oversees and manages the Spill Prevention, Control and Countermeasures (SPCC) program with regulations established at 40 CFR Part 112.  Part of EPA’s efforts include audit and enforcement.  Wilcox & Barton, Inc.  continues to provide our clients across New England with engineering support for SPCC compliance. Like every regulatory program, the key is a proactive approach to SPCC compliance.

Recently, the EPA rolled out its SPCC Expedited Enforcement Program to increase compliance with the rules.  EPA estimates 86% of facilities are not in full compliance with the regulations.  At Wilcox & Barton, Inc.  we have seen increased focus on regulatory enforcement.  Here a just a few helpful compliance tips:

  1. Keep your SPCC Plan updated.  The Plan should be amended and re-certified when there is any “technical change” at the facility.  This could be as basic as adding  an oil drum storage area.
  2. Perform self-inspections.  More than 10% of EPA audit citations are related to inadequate inspections.
  3. Make sure there is adequate secondary containment.  Once your facility is subject to the rules, all oil stored or in use needs to be addressed in terms of secondary containment.
  4. Conduct SPCC training.  The rule requires oil-handling personnel be trained to prevent oil discharges and to be familiar with pollution control laws.  Nearly 20% of EPA audit citations relate to insufficient training.

From bulk storage plants to factories to utilities, at Wilcox & Barton, Inc.  we understand how to keep our clients in compliance. If you have any questions, please contact Tim Keane., P.E., LSP at (413) 519-6653 or tkeane@wilcoxandbarton.com