ECA
SPCC Compliance



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Environmental Compliance Services by ECA

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ECA prepares SPCC Plans for oil and fuel storage facilities throughout Idaho, Oregon Washington and the United States.

SPCC Plans for Farmers
SP001 Tank Inspections and Certifications

NEWS: Fuel Companies Fined for SPCC Regulation Violations

 

Learn More ...

(most) Everything you wanted to know about the SPCC Rule but were afraid to ask - by Brett D. Smith, PE

ECA's presentation of The Final Spill Rule at the 2007 NWPPA's Engineering and Operations Conference in Tacoma, Washington.
ECA's presentation of The Final Spill Rule at the 2011 Tri-State Grain Growers Convention in Spokane, Washington.
ECA's SP001 Tank Inspections brochure

EPA Tank Inspection fact sheet
PEI Journal's Integrity Testing Shop-Fabricated Aboveground Storage Tanks

A PDF reader is required to view these documents. Go to Adobe Acrobat Reader (http://get.adobe.com/reader) or Primo PDF (http://www.primopdf.com) for FREE downloads.

 

The Regulatory Environment
The United States Environmental Protection Agency (EPA) Spill Prevention Control and Countermeasure (SPCC) Rule, 40CFR112, requires all facilities that COMBINED storage of at least 1,320 gallons of oil-based liquids in containers 55 gallons capacity and larger, to have an SPCC Plan for each facility that has the potential to contaminate a nearby stream, river, pond, lake or other water body ("navigable water"). Very few facilities with 1,320-gallon storage capacity are exempt from the navigable water criterion and the cost to prove exempt status typically equals the cost of preparing an SPCC Plan.

The SPCC Rule [40CFR112.8(c)(6)] requires facility owners to perform tank integrity inspections by way of "accepted industry standards", namely the Steel Tank Institute's SP001 (5th Edition) Standard and/or the API-653 Standard created by the American Petroleum Institute (API), where shop-built / field-erected steel tanks having 0 to 50,000 gallons storage capacity are addressed by SP001 and tanks larger than 50,000 gallons capacity are addressed by API-653.
We perform the SP001 Standard, which applies to tanks that store flammable / combustible liquids (specific gravity < 1.0) at atmospheric pressure.

How We Can Help
We'll help you STAY IN COMPLIANCE with the EPA's Spill Rule, by inspecting your facility and preparing an SPCC Plan. As needed, our SP001 certified inspectors and UTT professionals will perform tank inspections mandated by Section 40CFR112.8(c)(6) of the SPCC Plan. Our certified SP001 tank inspectors strictly follow all elements of the SP001 Standard and provide inspection reports having detailed findings and offering cost-effective recommendations that will keep your tanks in compliance with the EPA.

And by the way...
The 5-year Plan Reviews required by 40CFR112.5(b), do NOT need to be performed by a registered Professional Engineer (PE)! You only need a PE when TECHNICAL amendments are made at your SPCC-regulated facility, whereby the PE certifies all updates in the Amendments Log. Such technical certifications are ONGOING and documented in the Amendments Log, whereas the 5-year Plan Review can be entirely INDEPENDENT of such certifications. Please note that ADMINISTRATIVE changes (amendments) do NOT need PE certification, as they can be signed-off by company management.

To recap - technical / administrative amendments are made on an ongoing basis. The independent 5-year Plan Review may be performed by management, with ONLY the technical changes being certified by a PE.

NEWS: Fuel Companies Fined for SPCC Regulation Violations


Typical SPCC Compliance Projects

 

CLIENT: H T Rea Farms
PROJECT: Spill Prevention, Control and Countermeasure (SPCC) Plan
LOCATION: Milton-Freewater, Oregon

PROJECT DESCRIPTION: ECA inspected two commonly-owned farming operations located in northeastern Oregon and prepared a cost-effective multi-facility SPCC Plan.

CLIENT: Heller and Sons Distributing
PROJECT: Spill Prevention, Control and Countermeasure (SPCC) Plan
LOCATION: Hermiston, Oregon

PROJECT DESCRIPTION: ECA inspected this north-central Oregon Bulk Fuel Storage Facility and prepared an SPCC Plan.

CLIENT: K & M Fuel, LLC
PROJECT: Spill Prevention, Control and Countermeasure (SPCC) Plan
LOCATION: Colville, Washington

PROJECT DESCRIPTION: ECA inspected the Refueling Facility and prepared an SPCC Plan for this northeastern Washington facility.

CLIENT: Port of Othello
PROJECT: Spill Prevention, Control and Countermeasure (SPCC) Plan
LOCATION: Othello, Washington

PROJECT DESCRIPTION: ECA inspected the Port of Othello Refueling Facility located at the Municipal Airport and prepared an SPCC Plan for this eastern Washington facility.

CLIENT: Bernt Lehn Farm
PROJECT: SPCC Plan
LOCATION: Farmington, Washington

PROJECT DESCRIPTION: Prepared SPCC Plan for an eastern Washington dry-land farming operation.

CLIENT: Grant County PUD
PROJECT: STI Standard SP001 Aboveground Storage Tank Inspections
LOCATION: Wanapum and Priest Rapids Dams, Columbia River, Washington

PROJECT DESCRIPTION: ECA staff performed inspections of horizontal Category 1 fuel storage tanks located within Oil Storage Rooms for two hydroelectric facilities along the Columbia River, following STI's SP001 (5th Ed) tank integrity inspection Standard. Ultrasonic testing measurements were performed with industry standard QA/QC regarding thickness calibrations and instrument functionality. Tanks that met Steel Tank Institute inspection criteria were certified, whereas cost-conscious recommendations were provided regarding deficient tanks.

CLIENTS: Busch Distributors, Byrnes Oil, Coleman Oil Company (regional oil companies / petroleum marketers)
PROJECT: Numerous SPCC Plans
LOCATION: Idaho and Washington

PROJECT DESCRIPTION: Performed inspections of numerous fuel storage facilities and prepared SPCC Plans for same. Utilized geotechnical soil sampling to provide secondary containment alternatives that often precluded expensive concrete flooring for established tank farm containment systems, thus saving clients considerable capital costs.

CLIENT: Snokist Growers
PROJECT: SPCC Plan
LOCATION: Yakima, Washington

PROJECT DESCRIPTION: Performed inspection of canning facility and prepared SPCC Plan for same.

CLIENT: Grannis Petroleum Products, Inc.
PROJECT: STI Standard SP001 Aboveground Storage Tank Inspections
LOCATION: Coeur d'Alene, Idaho

PROJECT DESCRIPTION: ECA staff performed inspections of vertical Category 1 fuel storage tanks located within a Tank Farm for a bulk fuel storage facility, following STI's SP001 (5th Ed) tank integrity inspection Standard. Ultrasonic testing measurements were performed with industry standard QA/QC regarding thickness calibrations and instrument functionality. Tanks that met Steel Tank Institute inspection criteria were certified, whereas cost-conscious recommendations were provided regarding deficient tanks.

CLIENT: Calbag Metals Company
PROJECT: SPCC Plans
LOCATION: Portland, Oregon and Tacoma, Washington

PROJECT DESCRIPTION: Performed inspections of two metals recycling facilities and prepared SPCC Plans for same.

CLIENT: Puget Sound Energy (major electric utility)
PROJECT: SPCC Multi-facility Plans for ~50 Substation Sites
LOCATION: Western and Central Washington

PROJECT DESCRIPTION: Currently assisting client with the inspection of approximately 50 substation sites and the inclusion of same into several multi-facility SPCC Plans that are bringing them into full compliance with the most current elements of the Spill Rule (40CFR112).

CLIENT: CHS Inc.
PROJECT: STI Standard SP001 Aboveground Storage Tank Inspections
LOCATION: Moses Lake, Washington

PROJECT DESCRIPTION: ECA staff performed inspections of vertical Category 1 fuel storage tanks at the Bulk Plant and Ag Facility following STI's SP001 (4th Ed) tank integrity inspection Standard. Ultrasonic testing measurements were performed with industry standard QA/QC regarding thickness calibrations and instrument functionality. Tanks that met Steel Tank Institute inspection criteria were certified, whereas cost-conscious recommendations were provided regarding deficient tanks. Intelligent troubleshooting identified solutions that prevented costly modifications and repairs while achieving compliance with SP001 criteria.

CLIENT: Battelle Toxicology Northwest
PROJECT: SPCC Plan
LOCATION: Benton County, Washington

PROJECT DESCRIPTION: Inspected the facility and prepared a multi-facility SPCC Plan that brings Battelle into compliance with the most current elements of 40CFR112.

CLIENT: Ponderay Newsprint Company
PROJECT: STI Standard SP001 Aboveground Storage Tank Inspections
LOCATION: Usk, Washington

PROJECT DESCRIPTION: ECA staff inspected a single vertical Category 1 liquid waste storage tank following STI's SP001 (5th Ed) tank integrity inspection Standard. Ultrasonic testing measurements were performed with industry standard QA/QC regarding thickness calibrations and instrument functionality. Tank wall thickness exceeded nominal wall thickness requirements.

CLIENT: Benton Public Utility District
PROJECT: Spill Prevention, Control and Countermeasure (SPCC) Plan Multi-facility Plans
LOCATION: Benton County, Washington

PROJECT DESCRIPTION: Prepared single-facility and multi-facility SPCC Plans that address the latest requirements of 40CFR112.

CLIENT: Goodrich Corporation
PROJECT: STI Standard SP001 Aboveground Storage Tank Inspections
LOCATION: Spokane, Washington

PROJECT DESCRIPTION: ECA staff inspected a single vertical Category 1 liquid waste storage tank following STI's SP001 (4th Ed) tank integrity inspection Standard. Ultrasonic testing measurements were performed with industry standard QA/QC regarding thickness calibrations and instrument functionality. Tank wall thickness exceeded nominal wall thickness requirements.

CLIENT: Franklin Public Utility District (Franklin PUD)
PROJECT: SPCC Compliance Review + SPCC Plans
LOCATION: Franklin County, Washington

PROJECT DESCRIPTION: Inspected a total of 25 electrical substation and pumping station sites, regarding their compliance with 40 CFR 112 (the Spill Prevention Regulation). Ten (10) sites lacked sufficient aggregate capacity to warrant further analysis, and were deemed exempt from 40 CFR 112.  A detailed and thorough analysis of the remaining 15 sites was performed, to determine whether a spill would reach a navigable water of the United States.  After a detailed, flow regime analysis was performed for each site, 5 sites were found to be in need of SPCC Plans, whereas 10 sites were found exempt.  This process saved the client considerable money that would have been wasted on the preparation of unnecessary SPCC Plans.
Prepared five SPCC Plans that met the requirements of 40 CFR 112.

CLIENT: University of Idaho
PROJECT: STI Standard SP001 Aboveground Storage Tank Inspections
LOCATION: Moscow, Idaho

PROJECT DESCRIPTION: Performed inspections of double-walled fuel storage tanks at three on-campus locations. Inspected tanks, following STI's SP001 (3rd Ed) tank integrity inspection Standard. Ultrasonic testing measurements were performed with industry standard QA/QC regarding thickness calibrations and instrument functionality. Certified tanks that met Steel Tank Institute inspection criteria and submitted cost-conscious, yet effective, recommendations regarding tanks meeting SP001certification criteria. Intelligent troubleshooting identified solutions that prevented costly tank replacements.

CLIENT: Franklin PUD
PROJECT: Secondary Containment Design
LOCATION: Franklin County, Washington

PROJECT DESCRIPTION: Prepared a "multi-option" sheet, to let the client choose one of several containment and/or diversionary methods that would adequately meet the requirements of 40CFR112.7(c), also known as the General Secondary Containment option.  Upon selecting the impoundment method, ECA designed a low-maintenance asphalt liner / berm system that contains the contents of the largest transformer plus the rainfall associated with a worst-case storm event.

CLIENT: SeaWest WindPower, Inc.
PROJECT: SPCC Plan Rewrite
LOCATION: Condon, Oregon

PROJECT DESCRIPTION: Performed an extensive rewrite of an existing SPCC Plan for a wind farm facility comprising 83 wind turbine sites.  Although each wind turbine site only contained approximately 520 gallons of lubricating / coolant oils, the facility-wide aggregate greatly exceeded the 1,320-gallon capacity that mandates the Spill Prevention Regulation 40 CFR 112. Evaluated the site and incorporated considerable additional text and appendices to satisfy the latest (7/17/02) version of 40 CFR 112. Developed a plausible alternative to secondary containment that satisfies 40 CFR 112.7(c), yet realistically meets the worst-case (free-flowing) conditions that can occur at the facility.


 

Environmental Compliance Associates, LLC

WASHINGTON OFFICE
8524 West Gage Boulevard, Bldg A-132, Kennewick, WA 99336
Voice: (509) 628-9959

IDAHO OFFICE
372 South Eagle Road, Suite 146, Eagle, ID 83616
Voice: (208) 968-9705

ecabrett@cableone.net
Cell: (208) 501-9984