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Environmental Services Spill Control The SPCC rule requires oil spill prevention, preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines By Stephen Bennett Fuel oil dealers may update their plans and make control and containment improvements to their properties periodically or regularly. "Any improvements you do regarding these [SPCC] measures should be addressed with your insurance company," Savage advised. Two fuel oil dealers that do so are Fredericks Fuel & Heating Service, Oak Ridge, N.J., and F.C. Haab Co., Philadelphia, Pa., Savage said. Both dealers have made a number of updates to their plans and corresponding improvements on their properties in accordance with SPCC and other regulations, Savage said. The actions can include preventative maintenance, improving spill prevention and containment, and tank inspection. The fuel oil dealers keep their insurance providers apprised of improvements, Savage said, with the hope that the upgrades will weigh in their favor when time comes to discuss insurance renewal and the This photo shows a storage valve that is not secure as well as corrosion of the tank shell. cost of monthly premiums. Photo courtesy of Brian Savage. But that can depend on a number of variables, not the least of which is the state of the insurance market. After being notified this spring that premiums for Fredericks pill control plans have grown in detail and length since the Environmental Protection Agency (EPA) Fuel & Heating's existing coverage would increase more than 20 began requiring them in 1973, said Brian Savage, a con- percent, Mark Fredericks said, "The insurance market stiffened sultant who specializes in devising the plans for fuel oil dealers up, I think." Fredericks added, "I don't shop this every year" – meaning he didn't routinely seek to review and reconsider and other businesses. "Over the past forty years, spill plans for fuel oil dealers have his company's insurance annually. But in light of the pending grown from three or four pages to upwards of fifty pages," said increase, he decided to do just that. Working with an independent agent, Scott Rothstein of Savage, president of Savage Associates Inc., Watchung, N.J. Vreeland Insurance, Rockaway, N.J., Fredericks ended up switchThe rule requiring spill plans – officially "Spill Prevention, Control and Countermeasure" plans, or SPCC for short – has ing to Energi, a reinsurance company in Peabody, Mass., that been subject to various interpretations over time, Savage said. specializes in programs for fuel distribution and fuel transport, That is the main reason for the increased detail and length of the along with other energy-related businesses, according to its website. Fredericks said the premiums still represented an increase plans, he said. The rule includes requirements for oil spill prevention, pre- over what his company had been paying, but less of an increase paredness, and response to prevent oil discharges to navigable than was to be levied by the previous insurance provider. The oil waters and adjoining shorelines, the EPA states on its website. dealer's SPCC plan, as well as a state-required plan, and docuIt requires facilities to "prepare, amend, and implement" mented performance of safety drills, contributed to the securing SPCC plans. (For details on the rule and what it requires, visit of a lesser increase, Fredericks and Rothstein said. Savage, the consultant, pointed out that complying with the the EPA online: http://www.epa.gov/emergencies/content/ SPCC rule can be complicated by a federal regulatory structure spcc/index.htm.) S 20 June 2013 | FUEL OIL NEWS | www.fueloilnews.com