Tank Talk - Bulk Fuel Podcast
Tank Talk - Bulk Fuel Podcast is a podcast that delves into various aspects of environmental management and regulations, mainly focusing on bulk fuel storage, fish processing, and utility facilities across the Pacific Northwest. Hosted by industry expert Shannon Oelkers, Tank Talk features discussions with industry leaders to answer questions commonly asked by terminal managers. Episodes cover various topics involving State and Federal regulations, tank inspections and permits, and industry vendors. Tune in to navigate the complexities of rules and operations, offering insights and information to listeners involved or interested in environmental compliance and best practices within specialized industries.
Tank Talk - Bulk Fuel Podcast
SPCC Basics: Compliance Tables
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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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Welcome And SPCC Series Setup
Haley HallWelcome to Tang Talk with Integrity Environmental. Join us as we sit down with founder, principal consultant, and bulk fuel storage expert Shannon Olfers to explore regulations, safety, and essential tips for navigating the bulk fuel storage industry. Join us as we explore the unique joys of work and life in Alaska with industry experts, including our team, vendors we work with, and the companies we support.
Why Compliance Tables Exist
SPEAKER_03Shannon, I want to continue our series on SPCC plans. Roger that. You want to talk about compliance tables?
SPEAKER_01Compliance tables, remind me, what are those? They are a weird result of the intersection of the inflexibility of the SPCC regulation and reality.
SPEAKER_03Yeah, that does sound pretty important. And maybe expensive too, since the word compliance is in there.
SPEAKER_01Yeah, but expensive like taxes, not like a boat or anything.
SPEAKER_03Oh, the unfun, expensive.
SPEAKER_01Bingo.
SPEAKER_03So tell me a little bit more about this weird intersection.
SPEAKER_01Sure. So 40 CFR 112 requires facilities to be compliant always and at all times. If a change occurs at a facility, you have six months to update your SPCC, but you are required to be in compliance always at all times.
SPEAKER_03So what is an SPCC plan writer supposed to do if they perform a site inspection and they observe something that's not in compliance?
SPEAKER_01Yeah, I believe, although I cannot be sure, it was not in the room where it happened, that the regulation was originally written so that an engineer would not stamp the plan until the facility was compliant. A lever for action from the EPA with love, if you will. But as you know from this podcast, some problems are really big or complex or difficult to solve, and they take more than a couple days or weeks to fix. So how does a plan writer and the professional engineer complete an SPCC plan as a contract project within a normal time frame? From that weird intersection of reality and regulatory intent was born this compliance table. Sometimes PEs will call it implementation items because I think that sounds better, but it's integrity. We call it what it is. So potato potato, compliance table or implementation item. It's the same thing. Wow. I know, right?
SPEAKER_03Every villain needs a good origin story. So explain to me, Shannon, how does this compliance table work? Do you want theory or reality? Because they're a little different. Of course they are. Well, let's just start with theory, and then you can help me pull it all apart with reality. Okay, yeah.
SPEAKER_01Sounds good. Reality always brings the
The Clean Theory Behind The Table
SPEAKER_01chaos. Okay. In theory, the compliance table works like this: the engineer or their qualified designee visits your site, checks the real life facility conditions against the SPCC requirements, and any discrepancies are written down in a table for the facility owner to resolve. That table usually includes a certain timeframe, usually six months, to complete repairs, resolve the issue, and get your SPCC updated. This allows the engineer to stamp the plan and release it to the facility owner without perjuring themselves or risking their PE license for attesting that everything was compliant at the facility when it really wasn't. It also allows the SPCC project to be completed, and the facility owner will work diligently to resolve all these compliance issues as quickly as possible, updating the SPCC as soon as something is crossed off that list.
SPEAKER_03Wow, that sounds really nice and very neat and tidy, but we did say this is the theory, right?
SPEAKER_01Yeah, reality is hardly ever like the story I just painted. And there are good reasons for that.
SPEAKER_03So walk me through what goes wrong and why.
SPEAKER_01Okay.
The Six Month Myth
SPEAKER_01Well, first off, that six-month time frame given to update those compliance items in your SPCC is confusing and misleading. Remember, back to 40 CFR 112. You must be compliant at all times, always. You don't have six months to fix the compliance issue. You have a ticking compliance clock racking up days. So you're required to resolve that compliance issue immediately, or the EPA likes to say as soon as practicable. The SPCC writer puts that time frame into the compliance table to end their responsibility and to indicate when you should have the SPCC plan updated. That's where the six months comes from. But you, as the owner or operator, are on the hook for immediate resolution. Like if it's wrong, immediately and always has to be in compliance. You got to fix it. But remember, a lot of these problems can take weeks or months or even years to get fixed. You have to schedule a contractor or schedule the tank for drawdowns so you can pull apart your piping to install that missing overfill prevention device. These things can take a mo. So this compliance table can become a way to show the EPA that once you knew about this problem, you began addressing it and you have a plan, but you actually have to take action on the table and document your progress towards the problem resolution.
SPEAKER_03Would you say that this is how it always plays out? No.
SPEAKER_01No. There are other ways reality does not match theory here. The biggest one I think is that just people ignore the table completely and sometimes for decades. We've definitely done SPCC renewals where things from 15 years ago still are not corrected. We also see that the plan does not get updated even if the work gets done. Somebody was a busy beaver, went through the whole list, got everything reconciled, but it never made it back into the plan. That in and of itself is a violation. So a little funky there. And then we also see different engineers using these tables differently. So our firm includes it in the plan. It's an actual section of the plan, but some firms issue it more like a cover letter or they put it in the email. It doesn't always come with the SPCC. So they might send it to your manager and they get the email with the compliance table, but the SPCC you receive in the mail does not have that compliance table attached to it. They kind of get separated or lost.
SPEAKER_03So if you are a facility or environmental manager and your SPCC comes back with a compliance table, what should
How To Review Findings Correctly
SPEAKER_03you do?
SPEAKER_01Well, first, do not throw that plan in a drawer and forget about it or leave it in your email on red. You'll need to take that table as seriously as a violation list from the EPA because it can become that if you get audited or you have a spill event. We recommend when you receive that table, the first thing you do is review the findings and make sure you agree with them and that they accurately reflect the conditions at the site. I mean, plan writers are they make wrong assumptions and mistakes too. At integrity, we thoroughly discuss these tables with clients while on site. We call it our preliminary inspection findings, and then we do it again during our draft review process. We review all those items again. But not every plan writer does that. So it's important to get that table as correct as you can to avoid unnecessary potential violations. You don't want that in there if it's not right, right? Get it fixed. And I have a pro tip here. Make sure you understand the difference between recommended and required during this review.
SPEAKER_03Okay, I'll bite. What's the difference?
SPEAKER_01Required means it has to happen. It's part of the regulation or part of the engineering standard or the fire code. Like it has to happen. Recommended is optional, but probably a good idea. I always suggest getting all the required stuff done first and then looking at your recommended items and deciding if or when you'll do them. Sometimes the plan writer isn't super clear if something is required or recommended. So if you can't tell, like if it's not saying per fire code this is required, if it just says fix this, you may want to call them back and clarify is this a requirement or a recommendation?
SPEAKER_03So this list of compliance items seems like it can vary quite a bit. So
A Simple Way To Prioritize Fixes
SPEAKER_03tell me how do you decide what to tackle first?
SPEAKER_01Yeah, that can be a little overwhelming sometimes if you have a lot of compliance items. Sometimes it's only one or two things, you know, no big deal. But if you do have a larger list, some firms like ours will prioritize that table by risk, severity, and then also required or recommended. But if your plan writer doesn't do that, you can just sit down and prioritize it yourself. I have three ways that I think makes it easier to think about. First off, anything that can be done on site within a week, just do it. Rip that band-aid off and do it. Congratulations, you just resolved all those potential issues. Get credit, document it in writing in your SPCC plan. That's the easy stuff. Stuff that takes longer needs to be sorted into two categories. One is things you can do within your operating budget, and the second is things that need capital expenditure resources. So anything that can be paid for out of your operating budget and with your staff, get it scheduled and document that in your daily or monthly records. An example of this is ordered a replacement tank gauge on July 1st, will arrive on site between July 10th and 12th. And then once it arrives and you install it, you're gonna note on that daily or monthly inspection sheet that the tank gauge was replaced on July 13th. And then you're gonna go into your SPCC and update that compliance table to show that the issue was resolved on that specific date. For problems that need capital expenditure level of resources, those need to be elevated to your management. Funds have to be requested and set aside. And usually if it's this big, management and legal need to be aware of the risk, right? And they need to help manage that risk. So an example of this might be that your secondary containment was found to be too small and the entire containment area needs to be enlarged by 15%. I mean, you're gonna need a proposal, contractors, maybe logistics and shipping if you're remote. That takes a lot of time and capital.
SPEAKER_03I think that sounds pretty straightforward and mostly common sense.
SPEAKER_01Yeah, it is, but you would be surprised, Haley, how many people get hung up or overwhelmed and don't actually get much done on this table? Oh, that's not good. No, it's really not. So, with that in mind, I want to flip this around for a minute. Let's pretend you're a terminal or environmental manager and you receive a compliance table, but you don't do the three things that I just talked about. How's it gonna feel to tell your manager you could have fixed certain items within seven or thirty days, but didn't? And how would it feel to report to your CEO that you knew about this CapEx project level compliance issue, but didn't move it up the chain? And now, because you got audited by the EPA, it has to be resolved within 30 days for double the cost, or else big bad fines are coming. Facility and environmental managers have regulatory and employment obligations to follow up on these compliance items. And I know, I know management can still ignore you and under-resource you. I hear those folks in the back. But what I'm telling you as a facility or environmental manager, these are your CYA actions. Do what you can within your power and elevate the rest up.
When Findings Become EPA Violations
SPEAKER_03Well, I want to be very careful and extra clear on this. These compliance tables aren't actual violations, right?
SPEAKER_01Correct. At least not yet. And thank you for bringing that up. So it is a list of recognized compliance issues provided by your plan writer that must be addressed to bring your facility back into compliance with 40 CFR 112.
SPEAKER_03So when does the violation part come in?
SPEAKER_01Well, it might not if enough time goes by between your SPCC renewal and a visit from the EPA inspector. They've got a five-year look back period. If this happens, congratulations, you've dodged a bullet. But what can also happen is that you get audited as part of a routine EPA compliance check, or you have a significant spill and the EPA and the state start investigating. You can potentially receive violations for having unresolved compliance issues if you never fixed them. You can also get potential violations for the length of time you took to resolve the compliance issue, even if you did get it fixed or addressed. And this is the biggest misunderstanding about these tables. Just because the engineer gives a six-month window in that table to get these findings corrected and updated in the SPCC plan, that does not mean that you have six months to fix these non-compliant issues with the EPA. It doesn't mean that these are no longer violations. They are violations and they occurred. So keep in mind the EPA will look back five years for all findings and they are very inflexible on this because they have to be national consistency and all that. We've covered this on past podcasts pretty well. Also, keep in mind that the EPA can assess fines by the day as well as overall, based on severity, risk to human health and the environment, criminal intent, all these things. So these compliance tables are pretty serious business.
2026 MSGP Training Announcement
CommercialNew benchmark monitoring requirements are coming with the 2026 Alaska Multisector General Permit. Is your facility ready? This virtual online training helps operators avoid costly sampling mistakes, missed deadlines, and compliance headaches. Visit integrity-env.com to learn more about our MSGP benchmark monitoring course and other compliance trainings related to the 2026 MSGP.
Common SPCC Findings In The Field
SPEAKER_03Well, now that we know how serious these compliance tables need to be taken, I'm sure our listeners are wondering about what the most common compliance findings integrity sees in the field. Shannon, are you up for a quick round of common compliance issues? Yeah, let's do it. Great. Let's start with secondary containment areas.
SPEAKER_01Okay. I think the number one that we see is that there's no documentation of how big your containment area is. You have to be able to prove that your secondary containment area is the size you say it is. And a whole lot of facilities have lost the schematics or construction documents and they don't have surveyed as built. You can tell me it's a 6,000-gallon SCA, but I need to know. How do I know? I have to be able to either measure it in the field or have some kind of documentation. Another one is that the containment area is too small because at some point in the history of the facility, you put a larger tank into it. Classic example of this is when the facility was built, they had a 5,000-gallon single-walled tank and a 6,000-gallon containment. And at some point they replaced that 5,000-gallon tank with a 10,000-gallon tank because they needed more fuel for whatever operations they were doing, right? Well, now that 6,000 gallon containment area is 4,000 gallons too small. So we see that quite a bit. We also see really commonly is that the containment is not liquid tight or it's damaged, the liner has rips and tears, the berm is shorter than it used to be or has gaps that allow water or fuel to come out. Excessive vegetation, nobody's doing the yard work, poor housekeeping, a lot of stuff in your secondary containment area is never a good look. And then we also kind of the inverse of this: if people leave water in their containment areas too long, you see kind of evidence of excessive water held against the tank, like really rusty tank bottoms on horizontal tanks. Or you show up in November and there's a foot and a half of ice over every pipe and valve in the containment, and then that's not a good look either.
SPEAKER_03Shannon, how about for the tanks themselves?
SPEAKER_01Yeah, far and away, the most common one is the tank is not grounded. They're supposed to be grounded upon installation, but those grounding wires and rods can get ripped out. Sometimes installers don't know that they need to be grounded. So tanks not being grounded is number one. The tank itself not being level, you know, they move around a lot and on gravel pads or new installations. They can sink or rise. Coating damage is another one. I mean, minor coating damage is acceptable, but if you've got 90% coating loss and blistering and corrosion cells, I mean, severely damaged coatings is a pretty frequent flyer. We also see damage to supports or foundations. We're really looking for like why they got damaged. If it was during installation and it's stable, no big deal. But if your jersey berry is only three and a half feet and you've got a loader that continuously strikes the tank or the piping because it extends over at the five-foot level, well, that's something you need to get fixed. We also across the board see missing and damaged labeling on all the tanks. Labels fall off, they have to be constantly refreshed. That's a pretty big one. We also see those third-party inspections under STI SP001 or API 653, your cathodic protection annual under NACE. All those third-party inspections kind of get inconsistently adhered to. If you've got 20 years between an inspection, it's real easy to forget when it's due. We also see single-walled tanks not having any size containment whatsoever. This is really common with heating oil tanks, and there's this pervasive myth that heating oil tanks are exempt from SPCC coverage. That is not true for commercial properties subject to 40 CFR 112. It is true for single family residences, but it is not true for commercial properties. And this might actually be a good podcast episode later, Haley. Interesting.
SPEAKER_03Well, moving on, how about appartenances, valves, and piping?
SPEAKER_01Yep. Big one is that pipe supports are not supporting. They're lifting the pipe up or they've fallen away and are dragging on the pipe or no longer contacting the pipe. We also see frozen pressure relief valves or water draw valves. They don't get operated a lot, so they become inoperable. We also see unchanged filters, over-pressurizing systems. So the filters all clogged up, the whole system is over-pressurized. Every threaded fitting you've got has got a wet spot around it. The whole system is just over-pressurized from that filter. So do your filter changes. We also see leaks and weeps from flanges, gaskets, valves. In fact, under 40 CFR 112, you're supposed to be looking for these every month. It's part of your monthly inspection. We also see excessive vegetation along pipe runs. If you can cut a Christmas tree down along your piping corridor, it's time. Get the weed whacker out, get the saw out, get rid of all that junk. Most appurtenances, I mean, their caps come off for so many different reasons. They're removed for maintenance or coating and they never get put back on. The wind blows them away. We see a lot of damaged or missing caps from our appurtenances. And then we see incorrect plumbing or venting over pressurizing the systems. Specifically, someone takes out the normal vent and installs a supply and return line in that vent that blocks off your normal venting for your day tank. And again, every threaded fitting you've got's got a wet spot around it because that tank is getting pressurized on the daily. Severe coating failure can impact piping valves and appurtenances as well. They're supposed to be coated and protected from corrosion. We also, again, see ice or vehicle damage from poorly protected pipe runs. And sometimes, you know, you get a taco tank where the ice has fallen off the building and made a nice little dent in the middle of the tank. Those need to be protected. And then we see some missing things too. If you've got a double-walled tank outside a containment, it's supposed to have per this Annex H, this thing that got issued in 2002 by the EPA, it has to have an overfill prevention valve of some kind and some sort of audible or visual indicator for high-level alarm. Usually people have an overfill prevention valve and some kind of whistle vent or overfill alarm system in place. We see a lot of double walls outside containment missing those two pieces. So that's almost always a critical finding. We also see missing damaged or disabled emergency vents. These are passive systems. And so sometimes we see they didn't get installed correctly, like they arrived on site, but they never actually put the weighted cap in. We also see some emergency venting is through a manway lid, and there's these long bolt and springs that provide emergency venting, but the springs are completely rusted or coated with there's no way those springs are engaging. So make sure to check your emergency vents. And then again, we see missing or plugged normal vents. They still have the shipping cap in place. Like just they just never got installed.
SPEAKER_03Oh my gosh. Yeah, and shipping caps, really. Yeah, yeah, really.
SPEAKER_01Hayley, I would be a rich woman if I had $100 for every shipping cap I found on a tank.
SPEAKER_03Wow. Moving on, let's do warehouses and yard areas.
SPEAKER_01Okay. Yeah, the number one here is drums and portable containers stored without containment. Just like tanks, they have to have size containment. They need to be on a spill pallet, a concrete pad with a barrier or a lip. A lot of them are just stored under the eaves of a warehouse on the ground. Those same drums and portable containers are leaking. They've got to be intact and not leaking. We also strangely see used oil storage and decanting areas being left out of SPCC plans. I think there's this thought that if the used oil management regulations apply, so that maybe they don't need to be under the SPCC as well. But if you're storing used oil in containers of 55 gallons or larger, which most of you are decanting into a 55-gallon drum, and you might have a waste oil burner with a 300-gallon tank, all of that infrastructure related to used oil, if it meets the SPCC regulations for oil storage of 55 gallons or greater, has to be included in the SPCC. And then sidebar, the decanting area is always a frequent flyer on really messy stuff that needs to be cleaned up. It's something about taking small containers into big containers makes a huge mess. All kinds of shenanigans in the used oil storage area. And then lastly, just gravel areas in the yard being stained from frequent leaks and spills from unmaintained equipment. Those things need to be cleaned up periodically. You shouldn't have a constellation of oil patches all over your yard. You need to be removing them and treating them as you go along.
SPEAKER_03Thank you so much, Shannon. I think that this is a great list to make into a handout. What do you think?
SPEAKER_01I would love it if these frequent flyer items became less frequent across our industry. So yeah, let's make this into a quick checklist reference document. And everyone out there wanting to get ahead on compliance, I'm down for
Key Takeaways And Resources
SPEAKER_01that.
SPEAKER_03Shannon, to wrap up this episode, let's just hit all of the high points. If there are compliance issues present at your facility during an SPCC renewal, you could get some kind of compliance table from the signing engineer issued with your SPCC. And all those items identified as required, they need to be addressed as soon as possible and documented when completed or resolved.
SPEAKER_01Yep. You got it, Haley. And then you're going to need to sort those items into those three categories we talked about. Can you fix it now? Can you fix it within your operating budget or as soon as possible? And then does it need to be fixed as a capital expenditure project? Doing that sorting can really help you make headway on that list fast. But the biggest takeaway I want our listeners to bring with them today is to not ignore this table. It's potentially a future landmine of compliance issues.
SPEAKER_03Great point, Shannon. I really hope everyone listening is double checking their SPCC for a compliance table and downloading our common compliance hit list. Also remember that our website, integrity-env.com, has other useful resources like tank labeling guidance downloads that also can help you. Thank you so much for listening today.
SPEAKER_01Yeah, thank you, everyone. Goodbye.
Informational Disclaimer And Help Offer
SPEAKER_01Hi there. This is Shannon Olkers. And as the owner of Integrity Environmental, I wanted to take a minute here at the end of the podcast to make sure that you knew the following. This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may arise from the use of this podcast. This podcast is not intended to replace professional regulatory or legal advice. And the views expressed in this podcast may not be those of the host. That would be me for integrity environmental. Thank you very much for listening. And if you do need professional regulatory advice, we'd be happy to help you as part of our consulting services.
