According to a February 2012 EPA report, approximately 55% of 3,700 facilities inspected from 2007-2010, were not in compliance with existing Spill Prevention, Control, and Countermeasure (SPCC) guidelines. If these regulations are applicable to operations, companies need to prioritize plan compliance with facility management in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. New production facilities have 6 months to prepare and submit their site-specific SPCC plan in order to be in compliance with the regulation.
According to the EPA, most SPCC enforcement actions are due to incorrect or missing required documentation or nonexistent plans. If a facility does not have a documented plan, it will not be entitled to “informal enforcement” (verbal feedback and check sheet documenting potential violations). By utilizing a template as an outline, companies can begin the process of creating a compliant plan.
In order for a standardized template to be a compliant document, it is essential to evaluate and incorporate site-specific variables and applicable requirements. Development of an effective plan requires detailed knowledge of the facility and the potential effects of an oil spill. While each plan must be unique to the facility it covers, certain standard elements must be included to ensure regulatory compliance.
Typical elements of an SPCC plan include:
- Professional Engineer Certification
- Conformance declaration
- Certification of the Applicability of the Substantial Harm Criteria
- Facility description, plot plan, and contacts
- Potential spill volume and flow rates
- Inspections, tests and record keeping processes
- Personnel training requirements
- Loading/Unloading and transfer details
- Discharge prevention measures
- Security Measures
- Recovered material drainage and disposal methods
- Bulk Storage tanks details
- Secondary containment locations and volumes
- Discharge notification information and procedures
An SPCC plan template should be supplemented with the following site-specific information:
Description of Facility Infrastructure and Physical Attributes:
Plans should include site-specific details of the designated facility. This includes:
- Facility Name
- Contact Number
- Contact Person (and/or facility manager)/contact number(s)
- Site operations
- Products handled
- Number of employees
- Identification of waterways in the vicinity
- Summary of site drainage properties
- Site topography
- Details of tanks, pipelines, utilities, etc.
- Site security features, including fencing, visitor access, and lighting
Plan distribution list: Include the names and addresses of those that maintain paper plan copies.
Key contacts: Identify all primary and secondary key contacts that may be included in a response. It is crucial to routinely verify contact information for accuracy. Response equipment and alternate response equipment suppliers should be identified. (Key contacts may include 911, National Response Center, and internal and external response teams.)
Alarm Identification and Notification Process: Specific alarm signals that may signal an emergency, evacuation, or shelter in place. It is imperative to perform exercises with alarms to confirm they are in proper working condition and employees react accordingly. Ensure employees are trained in immediate notification response actions per roles and responsibilities.
Pertinent and updated contact numbers should be listed in the plan and verified. Plan administrators must be certain that all applicable contacts listed in notifications are accurate and/or phone numbers, especially in case of an evacuation. Verification of contact information for both personnel and external responders should be done on a periodic basis.
If maintaining accurate contact information is challenging, consider opting for an e-mail notification verification system that enables individuals to verify their own information.
Response Actions: Checklists and procedures detailing specific key response actions should be listed in the plan. In addition to these requirements, task teams should be formed, at a minimum, to cover each process. It is crucial to train employees on each site-specific component of the plan. Companies often provide extended training in case primary emergency management team members are not available.
Hazardous Waste Storage and Disposal: Applicable contact information for external suppliers should be reviewed and verified. The consequences of a supply chain failure on response components can exacerbate an emergency scenario. Transportation delays could affect necessary equipment delivery times. As a result, facilities should plan and mitigate accordingly.
For a free download on compliant facility preparedness, click the image below: