DEP Requires Corrective Actions from PLPT Logistics Terminal for Storage Tank and Clean Streams Law Violations, Assesses $1 Million Penalty

Norristown, PA – The Pennsylvania Department of Environmental Protection (DEP) announced today it has reached two agreements with PLPT Logistics Products Terminals, LLC (PLPT), for violations of the Storage Tank and Spill Prevention Act and the Clean Streams Law. DEP has ordered PLPT to perform a number of corrective actions and will collect over $1 million in civil penalties.

The PLPT facility subject to these agreements includes, among other infrastructure, 37 aboveground storage tank systems (ASTs) and 2 underground storage tank systems (USTs), all of which are regulated by DEP. PLPT also owns and operates a stormwater collection system, permitted under a state discharge permit.

“DEP takes matters of environmental protection seriously,” said DEP’s Southeast Regional Director Pat Patterson. “Whether it be through a penalty, corrective action, or both, DEP will always work to ensure that facilities are brought into compliance.”

Storage Tank and Spill Prevention Act 

In January 2019, PLPT excavated a 38-foot section of corroded pipe buried near an emergency containment structure. Upon excavation, PLPT identified a pinhole leak in the piping from which petroleum had been leaking slowly for many years. The pipe and associated systems were replaced and repaired. DEP requested that PLPT evaluate all buried AST system piping and have certain structures recertified by a Professional Engineer.  

After numerous attempts to bring the facility into compliance, DEP entered into a Consent Order and Agreement (COA) with PLPT to outline enforceable corrective actions, along with additional remedies, stipulated civil penalties, and an $800,000 civil penalty to be paid directly to the Commonwealth’s Storage Tank Fund. 

Under the COA, PLPT must: 

• implement an enhanced preventative maintenance program, which will include daily monitoring of the AST systems to ensure no potentially hazardous environmental conditions exist 

• provide DEP an operation and maintenance plan that identifies how PLPT will establish and maintain compliance with all applicable laws and regulations, as well as in-service and out-of-service inspection requirements of AST systems

• make all necessary installations, upgrades, and repairs to the AST system with appropriate documentation 

• have the northernmost emergency containment structure certified by a Professional Engineer to verify it meets performance standards and capacity requirements 

• complete piping inspections, which include all UST and AST piping for regulated tanks within the emergency containment structures 

• pay $800,000 to the Commonwealth of Pennsylvania Storage Tank Fund 

 

Clean Streams Law 

 

In January 2019, DEP conducted an inspection of the PLPT Facility and observed oil discharging into the Schuylkill River from two distinct seeps located below the waterline.  An additional seep was later located in a ditch of a backwater tributary of the river. These discharges resulted in an oil sheen on the Schuylkill River. During its inspection, DEP also noted improper maintenance and operation of an oil water separator, effluent limitation exceedances, and inadequate record keeping of required system monitoring, all violations of conditions of PLPT’s National Pollutant Discharge Elimination System (NPDES) permit. 

 

DEP entered into a Consent Assessment of Civil Penalty with PLPT for Clean Streams Law violations and noncompliance with its NPDES permit. A $250,000 civil penalty will be paid to the Clean Water Fund.