“I didn’t even know what a Spill Plan is, let alone that I needed one!” This is something we have heard often, and it is understandable. Successful small businesses invest a lot of time and money establishing infrastructure, procedures and employee training to safely manage their process liquids and waste streams. However, they are sometimes unaware of specific regulatory requirements for a Spill Plan, and the benefits that they can provide.
Benefits of a Spill Plan – Some of the benefits of a plan include:
- Spill prevention helps to protect workers
- Timely and appropriate spill response can prevent discharges to the environment
- Both of the above help reduce liability and costs
- Regulatory compliance can avoid fines and/or shutdowns
Types of Spill Plans – Some of the more typical spill plans and their regulatory triggers are:
- Spill Prevention, Control and Countermeasure (SPCC) Plan: The EPA requires Facilities with a total aggregate capacity of above-ground oil storage containers greater than 1,320 gallons of oil (containers 55-gallons or greater) or 42,000 gallons of oil stored in buried tanks, which could discharge to navigable water or shorelines, to maintain a SPCC Plan.
Note: “Navigable waters” can include perennial or intermittent streams and/or wetlands.
- Facility Response Plan (FRP): The EPA requires Facilities that could reasonably be expected to cause “substantial harm” to the environment by discharging oil into or on navigable waters to prepare and submit Facility Response Plans (FRPs).
- State-Specific Spill Plans: Individual states also have their own spill and emergency response plan, which are typically required by various stormwater, water quality, oil & gas, and waste management permits and regulations. For example, Pennsylvania has the Preparedness, Prevention and Contingency (PPC) Plan and New jersey has the Stormwater Pollution Prevention Plan (SPPP). These plans can typically be combined with a SPCC Plan.
- Additional State-Specific Plans Related to Storage Tanks: For example Pennsylvania’s Spill Prevention Response (SPR) Plan, pertains to aboveground storage facilities with greater than 21,000-gallons of regulated substances.
- RCRA Contingency Plan Quick Reference Guide: Recently, the EPA started requiring Small and Large Quantity Generators of Hazardous Waste to maintain a Quick Reference Guide in their RCRA Contingency Plan to better respond to hazardous waste releases and accidents.
Although mandated by different regulations, these spill plans share some common elements. They are created to prevent and respond to releases of oil, or other regulated substances, which could impact human health or the environment. The regulated substances are inventoried and required to be safely stored, such as in a fire box or secondary containment structure. They contain detailed worker training, response, countermeasures and public notification requirements in the event of a release. Finally, spill plans identify the manpower, procedures and equipment dedicated to preventing a spill from occurring or reaching the environment.
Who needs a Spill Plan:
- Facilities that generate, manage or store significant amounts of oils or chemicals;
- Facilities with greater than 1,320 gallons of aboveground oil storage or 42,000 gallons of below ground storage;
- Facilities that require stormwater, water quality, oil & gas, or waste management permits;
- Facilities required to implement a spill plan by state or federal regulators (this is often initiated after a spill or leak response); and
- Small and Large Quantity Generators of Hazardous Waste.
Brickhouse Environmental’s experienced staff of Professional Engineers, Geologists and Scientists are able to quickly identify the need for a spill plan, and implement the required industrial compliance and reporting solutions. For more information, please contact Al Yates, P.E.