A small-town Tennessee convenience store was storing 22,000 gallons of oil with no functioning spill plan, no trained staff, no secured valves, and no inspection records, every single required layer of federal protection was absent, and the owner paid less than $2,000 to make it go away.

One Store. Five Pages of Failures.

The Red Boiling Springs Market at 101 Lafayette Road, Red Boiling Springs, Tennessee, is a bulk storage facility. That means it holds large quantities of oil products that, if released, can devastate local waterways, poison drinking water, and kill aquatic ecosystems for years. Federal law under the Clean Water Act requires any such facility to maintain a detailed, professionally certified Spill Prevention Control and Countermeasure (SPCC) plan, keep inspection records, train its personnel, and install physical containment systems that can stop a catastrophic spill before it reaches water.

On October 18, 2023, EPA Region 4 inspector Ted Walden walked through this facility and found violations covering every single mandatory category. The resulting inspection form ran five full pages. The facility had no proper SPCC plan, no management approval of any plan, no professional engineer certification, and no evidence of a five-year review. It had inadequate secondary containment, unsecured master valves, no inspection records available for review, and no designated person accountable for spill prevention.

This facility stored up to 22,000 gallons of oil products. To put that in perspective: the Exxon Valdez disaster, which coated 1,300 miles of Alaskan coastline and killed an estimated 250,000 seabirds, involved roughly 11 million gallons. One uncontrolled release from a facility like this, into the local drainage system feeding a small Tennessee town, could be regionally catastrophic on a human and ecological scale that a community of this size would not have resources to address.

The Full Scope: Violations By Category

The EPA’s inspection form is organized by regulatory category. Every single one of the following categories contained at least one confirmed violation at this facility. This chart shows the proposed penalty weight assigned to each violation category based on the inspection findings form.

What Money Can’t Measure: The Human Cost of Zero Accountability

Red Boiling Springs is a small community in Macon County, Tennessee. It is not a city with a robust environmental enforcement agency, a well-funded legal team, or a constituency that makes national news. It is exactly the kind of place where regulatory failures accumulate quietly, where the machinery of environmental protection operates at a low priority, and where the people most likely to suffer a spill are the least equipped to respond to one. The residents of this town were sitting downstream of 22,000 gallons of stored oil products held at a facility with no functioning spill containment infrastructure.

Consider what “no inspection records available for review” actually means in human terms. It means that for the entire operational history of this facility leading up to the October 2023 inspection, nobody with authority was formally checking whether the containment systems were intact, whether the tanks were leaking, whether the valves were degrading, or whether a slow seep was already moving toward local groundwater. That is years of accumulated risk, absorbed silently by the community around that facility.

The violations documented under “Security” are particularly chilling for anyone who has seen what uncontrolled oil release does to a small town. Master flow and drain valves were not secured. That means an unauthorized person, mechanical failure, or simple negligence could have opened those valves without any physical barrier to stop it. There were no interlocked warning lights. No physical barrier system. No vehicle brake interlock to prevent a tank truck from pulling away before the transfer line was disconnected. These are systems specifically designed to prevent the kind of catastrophic accident that contaminates soil and groundwater for decades. Every single one was absent or inadequate.

The personnel training failures compound the physical ones. Federal regulations require that someone at the facility be designated as accountable for spill prevention. That person must receive training on how to respond to a discharge, what laws apply, and when to call for help. The inspection found none of this. There was no designated person. Spill prevention briefings had not been scheduled or conducted at least once a year as required. There was no training on discharge procedure protocols and no training on applicable pollution control laws. The people working at this facility every day, handling fuel deliveries, managing the pumps, working the loading and unloading operations, were doing so without any formal instruction on what to do if something went catastrophically wrong.

Straight From the Document: The Government’s Own Words

“EPA determined that Respondent, as owner and operator of the Facility, violated the Oil Pollution Prevention regulations as noted on the attached ‘Spill Prevention Control and Countermeasure Inspection Findings, Alleged Violations, and Proposed Penalty Form.'” EPA Expedited Settlement Agreement, CWA-04-2025-1101(b) — Statement of Findings

“Failure to have a Spill Prevention Control and Countermeasure Plan 112.3 — ($1,750)” SPCC Inspection Form, Page 1 of 5 — First and most fundamental violation listed

“No Inspection records were available for review — ($225). No designated person accountable for spill prevention — ($100). Spill prevention briefings are not scheduled and conducted at least once a year — ($100).” SPCC Inspection Form, Pages 3–4 of 5 — Personnel Training and Inspection Records sections

“Master flow and drain valves not secured — ($350). There are no interlocked warning lights, or physical barrier system, or warning signs, or vehicle brake interlock system to prevent vehicular departure before complete disconnect from transfer lines — ($350). There is no inspection of lowermost drains and all outlets prior to filling and departure of any tank car or tank truck — ($175).” SPCC Inspection Form, Pages 3–4 of 5 — Security and Tank Car/Truck Loading sections

“Inadequate secondary containment, and/or rack drainage does not flow to catchment basin treatment system, or quick drainage system — ($850). Secondary containment is inadequate — ($850). Secondary containment systems are not sufficiently impervious to contain oil — ($425).” SPCC Inspection Form, Pages 3–4 of 5 — Tank Car Loading/Unloading and Bulk Storage Container sections

“The parties enter into this ESA to settle the civil violations described in the Form for a penalty of $1,925.” EPA Expedited Settlement Agreement, CWA-04-2025-1101(b) — Settlement Terms

What $1,925 Buys You

The Stakes for Everyone Living Downstream

Environmental Degradation: What Happens When It All Goes Wrong

The specific violations documented at this facility represent failures at every stage of the environmental protection system. Secondary containment, the physical barrier that catches oil before it can escape into soil or drainage, was documented as inadequate in multiple sections of the inspection form. The document notes that “secondary containment systems are not sufficiently impervious to contain oil,” that “drainage from undiked areas do not flow into catchment basins ponds or lagoons,” and that there was “no diversion system to retain or return a discharge to the facility.” This is a complete chain of failure: if oil were released, there was no reliable mechanism to stop it from reaching the ground and moving toward local waterways.

Red Boiling Springs sits in a rural landscape with streams and drainage systems that feed into larger waterways. An uncontrolled release of even a fraction of the 22,000 gallons stored at this facility could contaminate local wells, kill stream ecosystems, and persist in soil for years. The inspection form specifically notes failures around buried piping, including that “corrective action is not taken on exposed sections of buried piping when deterioration is found,” and that buried sections of partially buried metallic tanks are not protected from corrosion. Corrosion-related leaks from buried infrastructure are the silent killer of local water quality: they often go undetected for months or years before the damage becomes visible.

Public Health: Undetected, Unreported, Unprotected

The absence of inspection records is a public health failure with cascading consequences. Federal regulations require written inspection procedures and records precisely because human memory and informal observation are not reliable systems for detecting the early signs of equipment failure. The form documents that the facility had no written inspection procedures, no records of inspections, and no evidence that inspection records were maintained for three years as required. This means there is no documented history of the condition of these tanks, pipes, valves, and containment systems over time.

The inspection also found that there were no “high liquid level alarms with audible or visual signal,” no “high liquid level pump cutoff devices set to stop flow at a predetermined level,” and no “fast response system for determining liquid level of each bulk storage container.” These are the early-warning systems that give operators the few minutes they need to prevent a spill from becoming a catastrophe. Without them, an overfill event, a pump failure, or a tank crack could go undetected until oil was already flowing somewhere it should not be.

Residents who rely on private wells in rural Macon County are particularly vulnerable. Unlike municipal water systems that are tested regularly, private well water quality depends heavily on the absence of nearby contamination sources. A slow, undetected leak from a corroding buried tank at a facility with no monitoring program could compromise a neighbor’s drinking water before anyone knew it was happening. There would be no alarm. There would be no inspection record to trace back. There would be nothing but the contamination itself.

Economic Inequality: Small Towns Pay the Full Price, Corporations Pay the Discount

The penalty structure documented in this settlement reveals a fundamental imbalance in how environmental accountability works for small businesses versus the communities they serve. The proposed per-line-item penalties on the inspection form, which represent the theoretical maximum exposure for each individual violation, include amounts like $850 for inadequate secondary containment and $1,750 for having no SPCC plan at all. These are not large numbers. They are designed for a regulatory system that prioritizes rapid settlement and compliance over deterrence.

The final settlement figure of $1,925 (less than a month’s wages for many workers in Macon County) does nothing to compensate the community for the years of elevated risk it absorbed while this facility operated without proper safeguards. Environmental cleanup of a significant oil spill in a rural community can cost hundreds of thousands to millions of dollars, costs that would fall on local governments, state agencies, and affected residents, not on the facility owner. The penalty paid here represents a tiny fraction of the potential liability the community faced, and zero fraction of any cleanup cost that might have resulted from a spill that, fortunately, did not occur.

Who Is Watching. What You Can Do.

The People Named in This Document

• Maulik Patel — Owner, Red Boiling Springs Market. Signed the settlement and certified violations were corrected.
• Ted Walden — EPA Inspector who conducted the October 18, 2023 inspection.
• Keriema S. Newman — EPA Approving Official. Digitally signed July 25, 2025.
• William Joyner — EPA Region 4 Environmental Engineer and Enforcement Contact.
• Andrew Teodorescu — EPA Region 4 Associate Regional Counsel.

Regulatory Bodies With Jurisdiction Over This and Similar Facilities

• EPA Region 4 (Atlanta, GA) — Enforces Clean Water Act Oil Pollution Prevention regulations for Tennessee. Contact: 61 Forsyth Street SW, Atlanta, GA 30303.
• Tennessee Department of Environment and Conservation (TDEC) — State-level environmental oversight. File public records requests for state-level inspection histories.
• EPA’s SPCC Program — Governs all bulk oil storage facilities nationwide. EPA is required to make enforcement actions public. You can search EPA’s ECHO database (echo.epa.gov) for your local facilities.

What You Can Actually Do Right Now

Search the EPA’s ECHO enforcement database at echo.epa.gov for every bulk storage facility near you. File Freedom of Information Act (FOIA) requests to get the full inspection records for any facility in your community. Connect with your local watershed council or environmental justice organization. If you live near a fuel storage facility and have noticed unexplained odors, sheen on water, or dying vegetation near drainage areas, report it to the EPA’s environmental violations tip line: 1-800-424-4372. The system only works when people refuse to stay quiet about what they see.