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Dealers above EPA threshold must have written plan, training against spills

November 23, 2010
Recent news releases about a U.S. Environmental Protection Agency deadline are incorrect and could lead to costly mistakes by dealers. The releases indicated the EPA had extended its deadline for SPCC Plan implementation. In fact, the deadline concerns updated plans, not new ones. SPCC is an acronym for Spill Prevention, Control and Countermeasures. The rule intends to keep an oil spill from infiltrating the nation's waterways by putting spill prevention measures in place and teaching employees what to do if the measures fail or are circumvented. The SPCC rules, first enacted in 1973 and recently revised, apply to dealerships with above-ground storage tanks in excess of 1,320 gallons, and drums containing oil or oilrelated materials. Considering the various new oils, used oils, transmission fluids and brake cleaning materials, it is easy to exceed the threshold limit of 1,320 gallons. The director of the U.S. EPA's SPCC division even wants emptied antifreeze containers included in the materials inventory because the containers invariably become contaminated with oil. Dealerships with more than 1,320 gallons must develop a written SPCC plan and implement staff training in support of that plan. Recent SPCC news mentioned a delay provided to dealers for SPCC plan implementation. However, that delay con- cerned updates to existing plans. Any dealer who has more than the threshold quantity of storage containers but no plan already is in violation and subject to substantial fines. A dealer who suffers an uncontained spill but has neither a written SPCC plan or proper training could be subject to sizable penalties. A few years ago, a dispenser seal on a CATA dealer's oil tank failed while the compressor was turned on. Before anyone could act, more than 300 gallons of lube oil covered the service department floor and was running down the drain. Fortunately, the dealership was less than 1 month old, so the triple traps were empty and they contained the spill. Other dealerships have not been so lucky, and the EPA does not want dealers to depend on luck. CATA allied member ComplyNet Corporation can perform free evaluations to help dealers determine if they need an SPCC plan. Call 847-655-2907 to speak to a consultant.