SPCC Presentation to VT Fuel Dealers

1. SPCC Compliance
without
Breaking the Bank
Dan Felten, PE & Tom Murphy
2012 Vermont Fuel Dealer Conference
May 31, 2012

2. The Cost of Non-Compliance…
PLUS…
The ADDITIONAL Cost to Come into Compliance

3. Personal Experience with
EPA Enforcement Actions
• Bulk Fuel Distributor in MA
– Unannounced EPA inspection
– RFI covered 4 facilities
– Nearly full compliance achieved in < 90 days
– No penalty assessed
• Bulk Fuel Distributor in VT
– Oil released to river in 2003
– Second release in 2007
– RFI covered 5 facilities
– Multiple violations resulted in $157,500 penalty
– PLUS, structural and administrative upgrades

4. Personal Experience with
EPA Enforcement Actions (cont)
• Transportation Company in MA
– failure to prepare SPCC and submit MSGP
– RFI covered 7 facilities
– Multiple violations resulted in $237,000 penalty
– PLUS, structural and adminstrative upgrades
• Bulk Fuel Distributor in VT
– Multiple violations
– $3000 penalty settlement
– Upgraded bulk plant and SPCC Plan

5. Findings and Violation Form
Page 1

7. Case Study 1: Unannounced EPA
Inspection in Western MA
• EPA arrives and asks for SPCC Plan
• Manager was on vacation and Office
staff didn’t know what an SPCC Plan was
• Terminal Manager faxed to EPA on his
return
• The Plan was >10 years old and
inadequate
• EPA issued Request for Information (RFI)

8. Case Study 1: Client Response
• Self disclosure for four bulk plants
– All had outdated SPCC Plans
– Three required SWPP Plans
– Most required upgrades
• Approx $40K for administrative compliance:
– New/updated plans
– Training
– Engineering for upgrades
• Upgrades included
– New OWS
– Dike upgrades
– Tank maintenance

9. Case Study 1: EPA Response
No penalty based upon customer response
– All information was presented in a timely
fashion
– 90% of the work (administrative and structural)
completed in less than 90 days
– Major upgrades were scheduled and
completed within 6 months, including:
• New oil/water separator
• Upgrade to secondary containment at two locations

10. Findings and Violation Form
Page 2

11. Before Upgrade
DIKE TOO
SHORT
DIRT BOTTOM
(UNDER TANK
TOO)

12. After Upgrade
Sheet Piling
and Spray
Liner
Angled
monitoring
well

13. Drum Storage Options
Spill Pallet Field Constructed

14. Fuel Delivery Truck Containment
(stored full overnight)
Flexible Berm Turns Garage into Full Containment

15. Findings and Violation Form
Page 3

16. Loading/Unloading Area
Before Upgrade

17. Loading/Unloading Area
After Upgrade
New OWS
New Strip Drain

18. Findings and Violation Form
Page 4
X
X

19. Unloading Area
Before Upgrade
Improve Pipe
Supports
Add Lock
Add Jersey
Barrier(s)

20. Findings and Violation Form
Page 5

21. Before Upgrade

22. After Upgrade

23. TAKE HOME MESSAGES
• Your best defense is a good offense
– Be proactive with compliance
– During or after a spill is NOT the time to start your
compliance program!
• Collaborate with the regulators
– Their main objective is to prevent releases
– They will help you if asked
– A cooperative attitude and quick response goes a long way
• There are many ways to achieve compliance
– Evaluate your options first
– Bring in the professionals!