Emerson Exchange 365

I ran across this list from the Environmental Daily Advisor that summarized the EPA's top 12 SPCC violations as presented at the 2013 National Institute  for Storage Tank Management’s (NISTM) 15th annual conference in Orlando.

• Container  incompatibility. Some examples include using underground storage tanks as  aboveground storage tanks and using heating oil tanks to store gasoline. This  is a big no-no with the EPA.
• Containment  drain valves left open.
• Poor  integrity of tanks.
• No  or inoperative overfill device(s) and/or no inspection of the device(s).
• Failure  to address facility tanker trucks/refuelers in the SPCC Plan.
• Small  containers located in buildings that don’t have proper secondary containment.  Some facilities think that because a container is in a building it doesn’t need  containment, but it does.
• Improper  maintenance and inspection of containment structures. For example, at one  facility the EPA had found that a groundhog chewed through the wall of a tank  causing it to leak.
• Poor  piping support.
• Buried  piping after August 16, 2002, that has not complied with cathodic projection  requirements.
• Poor  double-wall piping.
• Poor  drainage in buildings.
• Not  permanently closing containers.

The attached presentation from the EPA on "What to Expect during an SPCC inspection" under 40 CFR 112 and provides some insights into what to expect and some pretty amazing photos of SPCC compliance issues.