EPA RCRA & SPCC in Oklahoma & Texas: 8 Compliance Fails That Trip Up Small Operators (Plus the Quick Fixes)

One missed EPA requirement can shut down your operation faster than a lightning strike on a tank farm.

In Oklahoma and Texas, small oil and gas operators face a maze of EPA regulations that can feel overwhelming: especially when you're trying to run a profitable business while keeping your people safe. The Resource Conservation and Recovery Act (RCRA) and Spill Prevention, Control, and Countermeasure (SPCC) rules aren't just bureaucratic paperwork. They're designed to protect your community, your workers, and your bottom line from catastrophic environmental incidents.

But here's the reality: most compliance failures aren't caused by malicious intent or gross negligence. They happen because small operators get buried in the details, miss subtle requirements, or simply don't know what they don't know.

After working with hundreds of operators across Oklahoma and Texas, we've seen the same compliance mistakes repeated again and again. The good news? Every single one has a straightforward fix that won't break your budget or shut down your operations.

Let's walk through the eight most common EPA compliance fails that trip up small operators: and the quick fixes that can save you thousands in fines, delays, and headaches.

1. Missing Professional Engineer Certification on SPCC Plans

The Problem: Your SPCC plan sits in a filing cabinet, complete and detailed: but it's not worth the paper it's printed on because a registered Professional Engineer (PE) never certified it.

This isn't a suggestion or a best practice. EPA requires PE certification for every SPCC plan, regardless of facility size. Small operators often assume they can create their own plans or use generic templates without professional review.

The Quick Fix: Partner with a qualified PE who understands oil and gas operations. Don't just find the cheapest option: find someone who knows your industry and can spot potential issues before EPA does. The upfront investment in proper certification prevents costly violations and demonstrates good faith compliance efforts.

2. Inadequate Secondary Containment Sizing

The Problem: Your secondary containment looks sufficient, but the math doesn't add up when EPA runs the calculations.

SPCC regulations require secondary containment to hold 110% of the largest tank's capacity or 100% of the largest tank plus 10% of the remaining tanks' aggregate capacity: whichever is greater. Small operators frequently miscalculate these requirements, especially when dealing with multiple tank configurations or when adding new storage capacity.

The Quick Fix: Audit your containment calculations annually and whenever you modify tank configurations. Include rainfall considerations and account for displaced volume from equipment within the containment area. When in doubt, oversize rather than cut corners: the extra capacity costs less than EPA fines and environmental cleanup.

3. Poor Inspection Documentation and Scheduling

The Problem: You inspect your equipment regularly, but your documentation tells a different story to EPA inspectors.

Both RCRA and SPCC regulations require specific inspection frequencies and detailed record-keeping. Small operators often conduct informal "eyeball" inspections without creating written records, or they maintain inconsistent documentation that can't demonstrate compliance patterns over time.

The Quick Fix: Create simple inspection checklists tailored to your specific equipment and regulatory requirements. Train your staff to document findings consistently, including date, time, inspector name, and specific observations. Use digital tools or apps to streamline the process and ensure records are complete and accessible.

4. Training Gaps and Incomplete Records

The Problem: Your experienced crew knows how to handle spills and waste, but you can't prove they received proper training to EPA's standards.

EPA requires documented training for personnel handling hazardous waste under RCRA and for spill response under SPCC regulations. Small operators often rely on informal mentorship or assume that experience equals compliant training.

The Quick Fix: Develop structured training programs that cover regulatory requirements, not just operational procedures. Document all training with attendance records, training content, dates, and instructor qualifications. Schedule annual refresher training and ensure new hires receive training before working independently with regulated materials.

5. Facility Changes Without Plan Updates

The Problem: You installed new storage tanks, modified piping, or changed operational procedures: but your SPCC plan still describes your old configuration.

SPCC plans must reflect current facility conditions. Any change that affects spill potential, containment capacity, or response procedures triggers a plan review and potential update requirement. Small operators often make practical operational changes without considering regulatory implications.

The Quick Fix: Establish a formal change management process that includes regulatory review before implementing modifications. Treat your SPCC plan like a living document that evolves with your facility. Schedule annual plan reviews even when no major changes occur: small modifications can accumulate into significant compliance gaps.

6. RCRA Waste Characterization Errors

The Problem: You're managing waste streams based on assumptions or outdated testing, potentially misclassifying hazardous waste and facing serious regulatory violations.

Proper waste characterization under RCRA requires either analytical testing or detailed knowledge of waste generation processes. Small operators sometimes rely on generic waste profiles or skip periodic re-testing, especially when waste streams appear consistent over time.

The Quick Fix: Develop waste characterization procedures based on actual facility operations and waste generation patterns. Test waste streams when processes change or at minimum intervals specified by regulations. Work with qualified laboratories that understand RCRA testing requirements and can help interpret results for compliance purposes.

7. Improper Container Management and Labeling

The Problem: Your waste containers meet basic storage needs, but they don't meet EPA's specific requirements for container condition, labeling, and closure.

RCRA container management rules are detailed and specific. Small operators often use whatever containers are available, store them longer than permitted, or fail to maintain proper labeling throughout the storage period.

The Quick Fix: Implement container management procedures that address selection, inspection, labeling, and storage time limits. Use containers designed for hazardous waste storage, not makeshift alternatives. Train staff on proper container handling and establish regular inspection schedules to identify problems early.

8. Emergency Response Plan Deficiencies

The Problem: Your emergency response plan looks comprehensive on paper, but it won't work in a real emergency because it's not tailored to your specific facility and local resources.

Both RCRA and SPCC regulations require emergency response planning, but generic templates often don't address site-specific conditions, local emergency services capabilities, or realistic response scenarios for small operations.

The Quick Fix: Work with local emergency responders to develop realistic response procedures. Include specific contact information, equipment locations, and step-by-step response actions for your most likely incident scenarios. Test your plan through tabletop exercises and update it based on lessons learned.

Making Compliance Work for Your Operation

These eight compliance fails might seem overwhelming, but remember: every successful operator started somewhere. The key is building compliance into your daily operations rather than treating it as a separate burden.

Think of EPA compliance like preventive maintenance on critical equipment. You wouldn't skip routine inspections on your compressors or pumps because the consequences are too expensive. Environmental compliance deserves the same systematic attention because the stakes are just as high.

Start with the areas where you're most vulnerable, then systematically address remaining gaps. Focus on creating sustainable procedures that your team can maintain consistently rather than complex systems that fall apart during busy periods.

How PSR Takes the Compliance Hassle Off Your Plate

At Premier Safety Resources, we understand that small operators need compliance solutions that work in the real world. Our team has worked with hundreds of oil and gas operators across Oklahoma and Texas, and we've seen what actually works: not just what looks good on paper.

Whether you need help with PE certification for your SPCC plan, RCRA waste characterization, or comprehensive compliance audits, we provide practical solutions that fit your operation and your budget. Our approach focuses on building compliance systems that protect your business while allowing you to focus on what you do best: safely producing energy resources.

Don't let compliance failures shut down your operation or expose you to unnecessary risks. Contact Premier Safety Resources today to schedule a compliance assessment and discover how we can help you turn regulatory requirements from a burden into a competitive advantage.

Your operation is too important to leave compliance to chance.