ECA’s
Managing Principal (Brett Smith, PE) left the Oil Industry 33 years ago and successfully retooled himself into a registered Professional Environmental Engineer (PE) who is currently licensed in Idaho, Nevada, Oregon and Washington, where he provides myriad commercial / retail / oil clients with leading-edge assistance in complying with the SPCC Rule (40CFR112). In addition to preparing Spill Prevention, Control and Countermeasure (SPCC) Plans, Mr. Smith has been inspecting aboveground
liquid storage tanks since 2003 and currently holds an Aboveground Tank
Inspector SP001 certificate with the Steel Tank Institute (STI). Mr. Smith also conducts an 8-hour SPCC Training Workshop for his SPCC-regulated clients and their oil-handling staff, which keeps clients in compliance with 40CFR112.7(f).
The Regulatory Environment
The United States Environmental Protection Agency (EPA) Spill Prevention Control and Countermeasure (SPCC) Rule, 40CFR112, requires all facilities with COMBINED storage of at least 1,320 gallons of oil-based liquids in containers 55 gallons capacity and larger, to have an SPCC Plan for each facility that has the potential to contaminate a nearby stream, river, pond, lake or other water body (“navigable water”). Very few facilities with 1,320-gallon storage capacity are exempt from the navigable water criterion and the cost to prove exempt status typically equals the cost of preparing an SPCC Plan.
LATEST NEWS! – On January 23, 2020, the EPA and the Department of the Army redefined the meaning of a navigable water, to be 1) a territorial sea or traditional navigable water (TNW) water like the Mississippi River, 2) an intermittent / perennial tributary that empties into a TNW, a lake, pond or manmade water conveyance system (ie, canal) or 4) a wetlands.
How We Can Help
We’ll help you stay in compliance with the EPA, by inspecting your facility and preparing a comprehensive, up-to-date SPCC Plan. As needed, our SP001 certified inspectors and UTT professionals will perform tank inspections mandated by Section 40CFR112.8(c)(6) of the SPCC Plan (see SP001 Tank Inspections under the Projects tab).
Some typical SPCC projects performed by ECA are listed below:
Client: H T Rea Farms
PROJECT: Spill Prevention, Control and Countermeasure (SPCC) Plan
LOCATION: Milton-Freewater, Oregon
DESCRIPTION: ECA inspected two commonly-owned farming operations located in northeastern Oregon and prepared a cost-effective multi-facility SPCC Plan. 
Client: Snokist Growers
PROJECT: SPCC Plan
LOCATION: Yakima, Washington
DESCRIPTION: Performed inspection of canning facility and prepared SPCC Plan for same. 
Client: Heller and Sons Distributing
PROJECT: SPCC Plan
LOCATION: Hermiston, Oregon
DESCRIPTION: ECA inspected this north-central Oregon Bulk Fuel Storage Facility and prepared an SPCC Plan. 
Client: Benton Public Utility District
PROJECT: Spill Prevention, Control and Countermeasure (SPCC) Plan Multi-facility Plans
LOCATION: Benton County, Washington
DESCRIPTION: Prepared single-facility and multi-facility SPCC Plans that address the latest requirements of 40CFR112.
Client: K & M Fuel, LLC
PROJECT: SPCC Plan
LOCATION: Colville, Washington
DESCRIPTION: ECA inspected the Refueling Facility and prepared an SPCC Plan for this northeastern Washington facility. 
Client: Franklin Public Utility District (Franklin PUD)
PROJECT: SPCC Compliance Review + SPCC Plans
LOCATION: Franklin County, Washington
DESCRIPTION: Inspected a total of 25 electrical substation and pumping station sites, regarding their compliance with 40 CFR 112 (the Spill Prevention Regulation). Ten (10) sites lacked sufficient aggregate capacity to warrant further analysis, and were deemed exempt from 40 CFR 112. A detailed and thorough analysis of the remaining 15 sites was performed, to determine whether a spill would reach a navigable water of the United States. After a detailed, flow regime analysis was performed for each site, 5 sites were found to be in need of SPCC Plans, whereas 10 sites were found exempt. This process saved the client considerable money that would have been wasted on the preparation of unnecessary SPCC Plans.
Prepared five SPCC Plans that met the requirements of 40 CFR 112.
Client: Port of Othello
PROJECT: SPCC Plan
LOCATION: Othello, Washington
DESCRIPTION: ECA inspected the Port of Othello Refueling Facility located at the Municipal Airport and prepared an SPCC Plan for this eastern Washington facility. 
Client: Puget Sound Energy (major electric utility)
PROJECT: SPCC Multi-facility Plans for ~50 Substation Sites
LOCATION: Western and Central Washington
DESCRIPTION: Currently assisting client with the inspection of approximately 50 substation sites and the inclusion of same into several multi-facility SPCC Plans that are bringing them into full compliance with the most current elements of the Spill Rule (40CFR112).
Client: Battelle Toxicology Northwest
PROJECT: SPCC Plan
LOCATION: Benton County, Washington
DESCRIPTION: Inspected the facility and prepared a multi-facility SPCC Plan that brings Battelle into compliance with the most current elements of 40CFR112.
Client: Calbag Metals Company
PROJECT: SPCC Plans
LOCATION: Portland, Oregon and Tacoma, Washington
DESCRIPTION: Performed inspections of two metals recycling facilities and prepared SPCC Plans for same. 
Client: Busch Distributors, Byrnes Oil, Coleman Oil Company (regional oil companies / petroleum marketers)
PROJECT: Numerous SPCC Plans
LOCATION: Idaho and Washington
DESCRIPTION: Performed inspections of numerous fuel storage facilities and prepared SPCC Plans for same. Utilized geotechnical soil sampling to provide secondary containment alternatives that often precluded expensive concrete flooring for established tank farm containment systems, thus saving clients considerable capital costs.
Client: SeaWest WindPower, Inc.
PROJECT: SPCC Plan Rewrite
LOCATION: Condon, Oregon
DESCRIPTION: Performed an extensive rewrite of an existing SPCC Plan for a wind farm facility comprising 83 wind turbine sites. Although each wind turbine site only contained approximately 520 gallons of lubricating / coolant oils, the facility-wide aggregate greatly exceeded the 1,320-gallon capacity that mandates the Spill Prevention Regulation 40 CFR 112. Evaluated the site and incorporated considerable additional text and appendices to satisfy the latest (7/17/02) version of 40 CFR 112. Developed a plausible alternative to secondary containment that satisfies 40 CFR 112.7(c), yet realistically meets the worst-case (free-flowing) conditions that can occur at the facility.
