ABSTRACT

The Oil Spill Prevention Program of the Environmental Protection Agency is discussed as it has evolved from the implementing legislation: section 311(j)(l)(C) of the Federal Water Pollution Control Act. The regulations apply to all non-transportation-related facilities with oil storage in excess of certain minimum amounts from which spilled oil could reasonably be expected to reach navigable waters. The prevention program centers around a requirement in the regulation that these facilities must prepare and implement a Spill Prevention Control and Countermeasure (SPCC) plan. The type of engineering analysis needed to prepare or review a plan is discussed along with an outline of what EPA considers to be the elements of a good plan. After the period for plan implementation is past, a facility must submit its SPCC plan to EPA for review if it experiences spill problems. After review, EPA may require revisions to the plan in the form of amendments, but there are several levels of technical appeal on amendments. The paper discusses EPA plan reviews, amendment procedures, appeals on amendments, and finally, penalty procedures and appeals from penalties.

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