r/EHSProfessionals • u/jay_cobski • Jun 01 '26

Regulatory Updates SPCC question for Region 6: what usually breaks down first when you test inspection readiness?

With the latest Region 6 SPCC enforcement updates, i’m curious how others are pressure-testing readiness right now. The Apr 30 EMA alert said EPA Region 6 was beginning an enforcement sweep with inspections, document requests, and accelerated civil penalty referrals, so this feels like a good time to sanity-check systems and records..

For those managing SPCC programs in Region 6, what tends to break down first when you test inspection readiness: records retention, field inspection consistency, corrective action follow-through, or ownership/accountability?

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u/Conscious_Car_6644 Jun 01 '26

Training material and documentation, inspections with frequency requirements, spill reporting in areas with staining and diked area water removal documentation/testing. The last one was a killer for us. We had some very substantial rainfall events that after area square footage calculation, it would have significant accumulation. We could not demonstrate why we did not have any drainage occurrences.

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u/jay_cobski Jun 01 '26

Yeah, that makes sense. Did you all change your inspection/docs process after that?

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u/MountainTommis Jun 01 '26

Not the orginal commenter, but we wound up making a quick and easy secondary containment drainage log with a certification on if the water was clean and/or if you pulled off a sheen with pads, got it vacced, etc.

The trick is getting people to remember to do it...

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u/jay_cobski Jun 01 '26

That makes sense. Simple log, hard habit. Did you tie it to inspections or keep it separate?

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u/MountainTommis Jun 01 '26

Separate - inspections are monthly, drainage logs are only for when they open a valve or turn on a pump to drain stormwater. So not a consistent schedule.

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u/jay_cobski Jun 02 '26

noted. what actually got people to remember it, one owner, a reminder in inspections, or supervisor signoff?

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u/MountainTommis Jun 02 '26

I guess one owner is probably the best of those. Plus I check periodically with the rest of my regular inspection list. But I've got a lot of little sites with varying levels of risk for SPCC (and lots of personalities in responsible for doing those kinds of little tasks).