How to Avoid EPA Citations? Keep Good Oil Tank Inspection Records.
One of the biggest compliance problems the oil and gas industry has with the EPA’s Spill Prevention, Control, and Countermeasure (SPCC) inspections involves maintenance of records related to oil tank inspections, says environment, health and safety services consultants BLR.
The firm analyzed 93 SPCC expedited settlements at 46 bulk storage facilities and 47 onshore oil production facilities in the first half of 2013.
At bulk storage facilities, 13 percent of the citations involved tank inspections. These citations included records not being kept for the required three years and having no inspection records at all.
Of the facilities that did have records to show the regulators, the facilities received citations because the records did not include inspections of tank supports/foundations, deterioration, discharges, and/or accumulations of oil, BLR says.
At onshore production facilities, the majority of the 276 citations also centered on inadequate environmental data and inspection records.
The citations at these facilities included aboveground valves and pipelines that were not examined periodically on a scheduled basis for general condition, and visual inspections of containers, foundations and supports that were not conducted periodically for deterioration and maintenance needs.
Worker training accounted for more than 16 percent of the 281 citations for bulk storage facilities, included SPCC training citations, according to BLR.
The analysis of onshore oil production facilities indicated that 18 percent of the citations were for personnel training. Common citation included a lack of training record maintenance, no training on the operation and maintenance of equipment to prevent discharges, no training on the applicable pollution control laws, rules and regulations, and no training on the contents of the SPCC Plan.
The group further analyzed citations facilities received related the SPCC Plan. At bulk storage facilities, the majority were fined for not having an SPCC Plan at all. This was possibly due to the fact that SPCC applicability is determined by oil storage capacity – not necessarily how much oil the facility currently stores.
The minimum penalty for not having a required SPCC plan is $1,500. Fines increase substantially – $37,500 per day, per violation, with no cap – if a facility has spill and does not have and SPCC plan, BLR says.
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