When is an SPCC Plan required, and how do you determine whether the SPCC rule applies to your facility?

In this episode of Tank Talk, “SPCC Applicability,” we break down the fundamentals of Spill Prevention, Control, and Countermeasure (SPCC) applicability under 40 CFR Part 112.

An SPCC Plan may be required when a facility is non-transportation-related, could reasonably be expected to discharge oil to navigable waters or adjoining shorelines in quantities that may be harmful, and exceeds applicable oil storage capacity thresholds.

In this episode, we discuss:

• The 1,320-gallon aboveground oil storage capacity threshold for SPCC applicability
• The 42,000-gallon completely buried oil storage capacity threshold
• Transportation-related vs. non-transportation-related facilities
• How the potential for a discharge to navigable waters affects SPCC applicability
• Which aboveground tanks and containers count toward oil storage capacity
• When regulated underground storage tanks are excluded
• How used oil, lubricants, hydraulic oil, fish oil, soybean oil, and other oils can factor into SPCC applicability
• Common misconceptions about determining whether a facility needs an SPCC Plan

We also explain why the 1,320-gallon SPCC threshold exists and how seemingly small containers of oil can push a facility over the applicability threshold.

If your facility stores oil and you aren't sure whether you need an SPCC Plan, this episode provides a practical starting point for understanding SPCC applicability and the factors that should be considered.

References & Resources:

40 CFR Part 112 – Oil Pollution Prevention
b_40cfr112.pdf

1971 EPA–DOT Memorandum of Understanding / Appendix A to 40 CFR Part 112
eCFR :: Appendix A to Part 112, Title 40 -- Memorandum of Understanding Between the Secretary of Transportation and the Administrator of the Environmental Protection Agency

EPA SPCC Guidance for Regional Inspectors
SPCC Guidance for Regional Inspectors | US EPA

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We’re heading back into the Tank Talk archives for a conversation that’s still an important one for anyone managing bulk fuel storage: how do SPCC plans and STI SP001 inspections work together?

In this episode, Shannon breaks down the connection between SPCC requirements and tank inspection programs, including why STI SP001 is commonly used as the industry standard for many facilities. She walks through the difference between routine in-house inspections and inspections performed by a certified STI inspector, what can trigger additional inspection requirements, and why keeping good inspection records matters.

We also dig into what to look for when an STI inspection report comes back - from secondary containment and overfill prevention to inspection intervals - and why meeting the STI standard doesn’t automatically mean every SPCC requirement has been satisfied.

Plus, Shannon explains how these requirements can extend beyond traditional tanks to portable containers such as drums and totes, and where facility managers can find additional inspection guidance and resources.

Whether you’re reviewing your SPCC plan, managing an existing inspection program, or trying to make sense of when your tanks are due for inspection, this episode is a good one to keep in your compliance toolbox.

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You receive your updated SPCC Plan and notice a compliance table attached ... now what?

In this episode of Tank Talk, Shannon and Haley break down one of the most misunderstood parts of an SPCC Plan: the compliance table (sometimes called implementation items). They discuss what these findings mean, why they exist, and what facility managers should do after receiving one.

You'll learn:

• What an SPCC compliance table actually is
• The difference between required and recommended items
• How to prioritize corrective actions
• Why documenting progress matters
• Some of the most common compliance issues found during SPCC inspections

Plus, we've created a downloadable SPCC Compliance Quick Reference Guide (https://www.integrity-env.com/spcc-basics-compliance-tables) to help you prioritize findings and stay on track toward compliance.

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Most industrial property acquisitions include a Phase I Environmental Site Assessment. Many also include a Phase II. But what if some of the biggest environmental liabilities aren't covered by either?

In this episode of Tank Talk, Shannon and Haley explore the environmental compliance risks that often go unnoticed during due diligence and why those risks can impact valuation, profitability, financing, insurance, and future operations long after a deal closes.

From missing permits and poor recordkeeping to overdue inspections, infrastructure documentation gaps, and compliance history, the team discusses the operational environmental issues that buyers, sellers, lenders, and investors should evaluate before acquiring industrial assets.

Whether you're involved in mergers and acquisitions, private equity, commercial lending, or industrial facility operations, this episode provides practical insight into the environmental risks that may not appear in a traditional Phase I or Phase II assessment.

Because when it comes to industrial acquisitions, contamination isn't the only environmental liability worth investigating.

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Agency inspections are a routine part of operating a bulk fuel facility, but that doesn’t make them any less stressful. In this episode of Tank Talk, Shannon breaks down what inspectors are actually looking for, how facilities can prepare ahead of time, and the common issues that can turn a smooth inspection into a difficult one.

From recordkeeping and staff preparedness to housekeeping, secondary containment areas, and spill response equipment, this episode walks through practical steps terminal managers can take before inspectors arrive on site. Shannon also shares insights from her time as a former state inspector, including real-world examples of inspection responses that help - and ones that definitely don’t.

Whether you’re preparing for a Coast Guard, EPA, or State of Alaska inspection, this episode offers straightforward guidance to help your team feel more confident, organized, and ready.

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SPCC plans are one of the most common - and most misunderstood - regulatory requirements in the bulk fuel industry. While the plan itself may seem straightforward, proving compliance is where things get complicated.

In this episode, we kick off a new SPCC Basics series by breaking down one of the biggest pain points for facility operators: recordkeeping. From routine inspections to “as-needed” documentation, understanding what needs to be recorded - and when - is critical to staying compliant.

We walk through how recordkeeping is typically structured by frequency (daily, monthly, annual), where facilities commonly miss the mark, and why simply having a checklist isn’t always enough. We also cover the often-overlooked records that don’t fall neatly into a form but are still expected during an audit.

If you’re responsible for implementing an SPCC plan, this episode will help you better understand your role, reduce uncertainty, and avoid getting caught off guard when it’s time to prove compliance.

🎧 Tune in as we break down the essentials and set the foundation for the rest of the SPCC Basics series.

Shield Training

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Ever feel confident you’re following the rules… only to find out the rules changed?

In this episode of Tank Talk, Shannon and Haley talk about one of the most common compliance pitfalls in environmental operations: regulations evolving quietly in the background while day-to-day operations keep moving.

Just like driving down a familiar road where the speed limit suddenly changed, facilities can unknowingly fall out of compliance when regulations are updated after a plan, permit, or audit was completed.

We’re seeing this happen more and more in air and water regulations, where updates can occur on unpredictable timelines. A report that confirmed compliance a few years ago may no longer reflect the current regulatory landscape.

So how do operators avoid getting blindsided?

Shannon shares seven practical strategies that facility managers and environmental professionals can use to stay ahead of regulatory changes.

The conversation also covers what happens when regulations change, how transition periods typically work, and what to do if you discover you’re already past a compliance deadline.

If you manage fuel facilities, environmental programs, or regulatory plans, this episode offers practical steps to help ensure your compliance program doesn’t quietly expire in the background.

We’ve included a resource list with helpful agency webpages, industry groups, and notification lists that can help you stay informed when regulations change.

Remember: compliance is a point in time — and it can change without warning.

Download the guide: 7 Ways To Stay Ahead of Regulatory Changes — Integrity Environmental

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In this episode of Tank Talk, we sit down with Senior Environmental Consultant Leslie Pearson for a first-person account of the Exxon Valdez oil spill and how it reshaped spill prevention and response in Alaska and across the nation.

Leslie shares her firsthand experience working on the response in 1989, from documenting shoreline impacts in Seward to navigating the early days of incident command and emergency operations. She reflects on the gaps in preparedness that were exposed, the challenges of working in remote environments, and what it was like to learn on the fly during one of the largest environmental disasters in U.S. history.

The conversation explores how the spill led to the creation of the Oil Pollution Act of 1990 (OPA 90), major revisions to SPCC and Facility Response Plan requirements, and Alaska’s decision to implement some of the strictest spill prevention regulations in the country under 18 AAC 75.

With decades of experience as both a regulator and consultant, Leslie explains why these regulations are more than paperwork - they are institutional memory designed to prevent history from repeating itself.

This episode offers valuable perspective for environmental professionals, facility operators, and anyone working in spill prevention, preparedness, and compliance.

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