Federal Spill Prevention Control & Countermeasures regulations found in 40 CFR 112 are applicable to the vast majority of operations associated with crude oil and natural gas development offshore and onshore in all areas of continental development.  Additionally, these regulations are also applicable to many other industry sectors storing petroleum hydrocarbons, refined and unrefined, on site.  Facilities that have a single tank of 660 gallons or greater or 1320 gallons in aggregate storage on site, consisting of 55 gallon containers or greater, are required to have a specific “living” SPCC plan that is compliant with the regulations and that is “fully” implemented annually.             

The Environmental Protection Agency, EPA, the federal agency designated for compliance oversight, is presently implementing an inspection initiative targeting oil & gas operators and related service companies in all EPA regions of the country.  Targeted during these inspections is first a very thorough inspection to determine if the facility SPCC Plan and/or Facility Response Plan is fully compliant with the intent of the regulations.  Operators with response plans that are found to be not compliant are receiving civil fines.  Additionally, inspections that reveal proper facility maintenance is not being conducted and the “living” spill prevention programs are not being implemented on site are also resulting in substantial civil fines through the issuance of proposed Consent Agreements and Final Orders Under 40 CFR 22.13 (b).  The ability to substantiate by record the annual SPCC training requirement is being assessed as well.

   During this current era of federal implementation of the SPCC regulations, please know that our firm’s SPCC and Facility Response Plans are fully compliant with the intent of the regulations and are passing EPA inspections each week.  Additionally, our team of professionals is available to assist with field federal compliance evaluations designed to evaluate compliance with the written programs along with providing assistance with the annual training requirement.

For assistance, please contact any ES&H Consulting & Training Office using the direct contact information below and please check out ES&H’s website for other professional services being offered by the firm and by ES&H’s family of environmental/HAZMAT/emergency response companies.

1730 Coteau Rd.                                                           

Houma, LA 70364

Office: (985) 851-5350

2345 Atascocita Rd.

Humble, TX 77346

Office: (281) 448-6600