The EPA’s Spill Prevention, Control and Countermeasure Rule (SPCC) do not just apply to permanent facilities using fixed storage and equipment.
Temporary, seasonal, and other “standby”-type facilities, including construction sites, mobile fueling stations, and drilling sites, are fair game for EPA enforcement. In addition, these mobile facilities could be the sources of substantial environmental damage, which could result in costly cleanups, penalties, and litigation.
It’s, therefore, imperative for temporary facility owners and operators to have a solid game plan for tackling the logistical challenges that are inherently at play due to the transient nature of their operations.
As a best practice under the EPA’s SPCC guidelines, owners and operators should have a general plan in place, so they’re prepared each time the facility sets up shop at a new location. That general plan is a key compliance tool that’s necessary when a mobile facility moves. Specifically, under the applicable regulations, the mobile facility must be located and installed with the spill prevention practices outlined in that general plan.