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EPA Fines Multiple Companies for SPCC Plan Violations

Posted on Thu, Aug 13, 2015

Multiple California companies are in non-compliance with the U.S. Environmental Protection Agency’s Spill Prevention, Control, and Countermeasure (SPCC) regulation. The agency recently announced a series of financial penalties totaling more than $140,000 from both large and small facilities.

The SPCC regulation was created under the Clean Water Act to prevent oil from reaching navigable waters and adjoining shorelines, and to contain and respond to discharges of oil. It requires onshore oil storage facilities with identified capacities to develop and implement SPCC plans, identifying established procedures, methods, and equipment requirements to prevent and effectively respond to spills.

Under EPA’s Clean Water Act, facilities with aboveground storage tank capacities exceeding 1,320 gallons or underground tanks with capacities above 42,000 gallons, are required to comply with SPCC regulations.

“All companies who store oil must comply with federal standards. Facilities are required to prevent spills and be prepared to respond to a worst case oil discharge emergency," said Jared Blumenfeld, EPA’s Regional Administrator for the Pacific Southwest. “Preventing spills and protecting our waterways from oil spills is essential.”

True_cost_of_incidentsWhile it is not possible for EPA to identify and inspect every SPCC facility, owners and operators need to be proactive in developing and maintaining accurate plans. Despite inspection probabilities, companies must prioritize regulatory compliance in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. Recent California SPCC violations include:

  • A waste oil recycler facility in Newark, CA was ordered to pay a $90,000 penalty for failing to provide secondary containment around an oil storage area; failing to secure and control access to oil handling, processing and storage areas; failing to use safe containers and good engineering practices, including liquid level alarms to avoid discharges; and failing to develop a complete Facility Response Plan.
  • A vegetable oil terminal operator and packaging facility in Fullerton, CA, was fined $45,000 by failing to update and recertify its spill prevention plan; failing to provide adequate oil containment and drainage controls; failing to ensure that the secondary containment walls of a tank farm could contain spilled oil; and failing to remove accumulations of oil outside tanks and piping, transfer areas and process area collection trenches.
  • A building materials company in Pittsburg, CA was fined $2,775 for failure to provide a proper spill prevention plan, implement tank inspection and integrity testing programs, and provide documentation of employee training.
  • A grease service and disposal service facility in Riverside, CA was fined $2,400 for failure to provide a proper SPCC plan, for storing oil in improper storage containers, and for failing to implement a tank integrity testing program to prevent releases.
  • A food products facility in La Mirada, Calif. was fined $2,250 for failure to provide a proper SPCC plan and have adequate secondary containment for vegetable oil storage tanks.
  • A grease service and disposal facility in Riverside, CA was fined $1,900 for failing to provide a proper SPCC plan, and complete inspection records, The facility also lacked an adequate tank integrity testing program and proper oil drum secondary containment. 

Managing SPCC plans and associated compliance can be achieved through a cohesive, yet site-specific, standardization of best practices. The costs associated with effective emergency management, planning efforts, and overall spill prevention are often much less than the costs associated with fines, spill clean-up, and other civil liabilities. By utilizing available technology, companies can enhance accessibility, portability, and redundancy, and potentially ease communication barriers with responders and regulatory audits.

TRP - SPCC and FRP

Tags: SPCC, EPA, Regulatory Compliance

Oil Spills and Water Do Not Mix: Guidance for Company SPCC Plans

Posted on Thu, Jul 02, 2015

Most analogies regarding oil and water convey an image of chaotic polarity. If oil comes in contact with water in an industrial setting, it can be destructive and costly. Oil spills that discharge into waterways have adversely affected environments and wildlife, caused substantial economic losses to communities, and inflicted financial penalties on companies.

If a company is subject to the Environmental Protection Agency’s Spill Prevention, Control, and Countermeasure (SPCC) rule, they must ensure plans are established, accurate, and compliant. The EPA estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the following rule:

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires these plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.

Since 1974, owners and operators of certain oil-handling facilities have been subject to the regulation. When referring to a recently plan delinquent and fined rail facility, the EPA stated that the failure to “maintain and fully implement an adequate SPCC plan leaves a facility unprepared to deal with an oil spill and to prevent a spill from having potentially serious consequences.”

Compliant "spill prevention" plans can prevent spills from occurring, as well as speed up necessary response and recovery actions. For EPA compliance, plans should provide site-specific details that allow responders to best access, assess, and quickly respond to off-site spills, limiting the effects of a spill on sensitive environments. The plans also relay site specific information related to the storage and management of oil. These plans require that facilities identify sufficient containment and/or other applicable countermeasures to reduce the potential for oil spills to reach navigable waters.

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Typical elements of an SPCC Plan include:

  • Professional Engineer Certification
  • Discussion of conformance with federal regulations
  • 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 procedure
If a facility has more than 10,000 gallons of aggregate aboveground oil storage capacity, the plan must be inspected and certified by a professional engineer (PE). The certifying engineer must:
  • Be familiar with plan requirements
  • Visit applicable site and examine the facility
  • Certify that the plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards
  • Confirm that procedures for required inspections and testing have been established
  • Certify that the plan is adequate for the specific facility

Facilities that require these plans, yet have an aboveground oil storage capacity of less than 10,000 gallons, may self-certify these plans if they meet the following criteria;

The facility must not have had

  1. A single discharge of oil to navigable waters exceeding 1,000 U.S. gallons
  2. Two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any twelve-month period, in the three years prior to the SPCC Plan certification date, or since becoming subject to Title 40, Part 112 of the Code of Federal Regulations (CFR) if facility has been in operation for less than three years.

If a facility owner meets the above criteria, then the company may;

  • Prepare a self-certified plan
  • Meet tailored facility security and tank integrity inspection requirements without PE certification
  • Prepare a Plan which includes required PE certification for only the portions dealing with environmental equivalence and impracticability determinations. The remaining portions of the plan could be self-certified by the facility owner/operator.

TRP - SPCC and FRP

Tags: SPCC

Company FRP and SPCC Compliance within Proposed 2016 EPA Budget

Posted on Thu, Jun 04, 2015

As part of the proposed $8.6 billion Environmental Protection Agency (EPA) 2016 budget, the agency is allocating $18.5 million for the Oil Spill Prevention, Preparedness and Response program. The program aims to protect U.S. environment by effectively preventing, preparing for, responding to, and monitoring oil spills.

According to the EPA’s Budget in Brief, the agency “will perform inspections of regulated high-risk oil facilities to better implement prevention approaches and to bring 60 percent of Spill Prevention, Control, and Countermeasure (SPCC) and Facility Response Plan (FRP) inspected facilities found to be non-compliant during the FY 2010 through FY 2015 inspection cycle into compliance.”

Oil spills can threaten human health, cause severe environmental damage, and create financial loss to businesses and the public. According to the EPA, there are currently over 600,000 SPCC-regulated facilities under the EPA’s jurisdiction, including a subset of roughly 4,300 facilities subject to FRP requirements. Rather than be susceptible to fines, penalties, and negative publicity, companies that are required to comply with SPCC and FRP regulations should ensure response plans are up-to-date and effective. Evaluating company operations and each facility’s site-specific information will determine necessary elements for regulatory compliance and response plan requirements.

Compliance monitoring is comprised of all activities that determine whether regulated entities are in compliance with applicable laws, regulations, permit conditions, and settlement agreements. In coordination with these governances, the EPA’s Compliance Monitoring program’s goal is to determine whether conditions exist that may present imminent and substantial threat to public health or welfare of the United States.

The 2016 proposed budget enables the EPA to have a greater emphasis on emergency preparedness, particularly through the use of unannounced drills and exercises. It is imperative that facilities and responders can effectively implement established response plans according to regulations. In FY 2014, the EPA was able to bring 79% of FRP and 72% of SPCC facilities into compliance due to the development of improved guidance and procedures. The compliance program will continue to focus resources on bringing non-compliant facilities into compliance.

EPA_OIl_Facility_ComplianceSource: EPA (Chart presents data as of end of FY2014. Data represent the percentage of facilities found initially compliant in a particular year and facilities previously found to not be in compliance that were brought into compliance out of the respective sets of facilities inspected. Therefore, the numbers do not total to 100 percent.)

Compliance monitoring activities include data collection, analysis, data quality review, on-site compliance inspections/evaluations, investigations, and reviews of facility records and reports.
The EPA ensures that the management and oversight of the compliance monitoring program is enhanced by the exchange of information from the FRP and SPCC data systems to the EPA’s Integrated Compliance Information System (ICIS). This exchange provides the EPA the opportunity to focus compliance monitoring resources on areas of highest risk, and increase transparency to the public of this enforcement, and compliance data. In addition, submitting information into ICIS electronically improves data coverage and quality.

The ability to streamline the regulatory submission process is advantageous for both industry and regulatory agencies. As opposed to paper plans, web-based planning is extremely beneficial for organizations that are subject to multiple applicable regulatory requirements. A web-based planning system with a regulatory tracking element can eliminate redundancies across converging compliance requirements, which maximizes informational consistency and administrative productivity. Many companies have embraced the benefits of streamlined web-based preparedness programs because of cost efficiency, information accessibility, and the ability to verify compliance. By advancing submission practices and raising industry standards, the EPA embraces a higher level of accuracy, availability, and consistency.

As part of the 2016 budget, the EPA states it will finalize the development and begin implementation of the National Oil Database including identifying requirements for electronic submission of Facility Response Plans (FRP) in order to create reporting efficiencies for the agency, states, local government and industry. The ICIS and database will support a more comprehensive analysis and better management of the FRP and SPCC compliance programs.

Note: FRP facilities are currently required to submit their plans to the EPA Regional Offices, while SPCC facilities maintain their plans onsite.

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, SPCC, EPA

The SPCC Plan Template and Compliance Components

Posted on Thu, Nov 13, 2014

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
SPCC - TRP Corp

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
  • Address
  • Latitude/Longitude
  • 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:

Preparedness and Emergency Management - TRP Corp


Tags: SPCC, Regulatory Compliance, Facility Management

Maintaining Regulatory Compliance in an Oil Industry Acquisition

Posted on Thu, Oct 30, 2014

Oil companies are not stagnant entities.  Every year, the industry experiences acquisitions, mergers, and systemic transformations. The dynamic nature of the energy sector requires environmental, health, and safety departments, as well as facility managers, to periodically review and adjust their approach to emergency management and regulatory compliance.

Whether a facility is located in the U.S. or abroad, ensuring compliance, employee safety, and an effective response requires a streamlined, coordinated, and exercised response plan. All response plans, including SPCC's and facility response plans, within the corporate enterprise should address site-specific facility details, applicable and tested response processes, and standardized company-wide best practices while maintaining location-specific regulatory compliance. A customizable response plan template can enable the development of a streamlined, site-specific preparedness program that consistently delivers company-standard guidelines and practices while providing a medium for rapid assimilation of merging or acquired facilities.

Industrial operations are required by law to institute site-specific emergency response plans, and train employees according to their response roles and pertinent response methods. Acquiring one or more new facilities typically presents challenges that generic or static response plan templates do not account for. Failure to incorporate site-specific details may result in incomplete, ineffective, and costly non-compliant plans.  Companies with multi-facility operations should utilize a customizable template with the ability to inject distinct facility information and hazards for each operation, pre-approved company best practices, as well as applicable local, state, and federal requirements.

Integrating response plans under one centralized format enables consolidated preparedness and response objectives. Acquired facilities must be absorbed into the company-wide emergency management program. If response plans exist, companies should perform a gap analysis or audit to identify any procedural, company policy, or compliance deficiencies that may be applicable to the new facilities. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion.  Responsible parties must apply new data, site assessments, and validated information into cohesive, compliant, and effective response plans for the new enterprise.

New or outlying facilities may present preparedness and response challenges. Cultural differences, infrastructure challenges, response equipment availability, minimal response knowledge and training, and security priorities may require heighten preparedness priorities and planning efforts. As a result, new locations may be particularly vulnerable to crisis or emergency response situations.

Regulatory compliance - TRP Corp

The following fundamental preparedness and response questions may assist companies in absorbing facilities into an established emergency management program. Determining site-specific information, possible mitigation efforts, and response capabilities can mobilize stakeholders to develop necessary and required response planning objectives. (Note: The questions below are meant to initialize conversations and should not be considered a thorough checklist for preparedness and response planning)

Who will be in charge of the response and how will it be organized?

  • Identify Incident Commander
  • Create Emergency Management Team organizational chart
  • Identify Emergency Management Team activation measures
  • Create Emergency Management Team roles and responsibilities checklists

Does the facility have a current response plan to draw from?

  • Update necessary contact information and notifications
  • Perform a gap analysis of the current plan(s) against new operations, equipment, company policies, industry best practices and applicable regulations
  • Review agency approval and submittal processes and comply as necessary

What threats affect the new facility and its employees?

  • Perform a detailed hazard and risk analysis
  • Verify or create response procedures for each identified threat
  • Identify process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and necessary equipment necessary for response

What regulatory requirements apply to this facility?

  • Evaluate operations for compliance
  • Identify required training and confirm documentation
  • Review submitted response plan information
  • Perform a compliance audit

If necessary, what organization will conduct additional response duties?

  • Identify response capabilities and determine if additional resources are necessary
  • Initiate a Memorandum of Understanding or contract specific response needs
  • Confirm contact information, availability, and response times

How will the emergency be reported and response initiated?

  • Create site-specific notification procedures
  • Identify site-specific alarms that signal employee evacuation or shelter in place.
  • Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in alarm procedures and immediate response actions per designated roles and responsibilities
  • Implement company approved emergency classification levels to associated response procedures with emergency conditions to prevent the incident from escalating

What incidents or classification level require evacuation/shelter in place

  • Establish multiple evacuation routes.
  • Does the evacuation go beyond facility borders?
  • Identify the muster point(s) and head count procedures?

How are response actions sustained?

  • Establish command post location
  • Identify internal and external response resources and equipment for a sustained response
  • Share response plan with appropriate responders/stakeholders
For a free Audit Preparedness Guide, click the image below:
Regulatory Compliance with TRP Corp
TRP offers a variety of free resources at http://www.emergency-response-planning.com/downloads/

Tags: Facility Response Plan, SPCC, Oil Spill, Emergency Management Program

SPCC Planning and Regulatory Compliance Inspections

Posted on Thu, Oct 16, 2014

The challenge of managing and ensuring compliance of Spill Prevention, Control and Countermeasure (SPCC) plans for multiple facilities can be complex. Detailed government inspections, enforcement mandates, costly non-compliance fines, and negative publicity may result from the lack of implemented, site-specific, and up-to-date plans. By utilizing available technology to manage multiple SPCC plans, companies can verify compliance through a cohesive, yet site-specific, standardization of best practices.

For facilities with aboveground storage tank capacities exceeding 1,320 gallons or underground tanks with capacities above 42,000 gallons, Environmental Protection Agency (EPA) compliance requires accurate and up-to-date SPCC plans. A professional engineer must certify SPCC plans if your facilities have more than 10,000 gallons of aboveground oil storage capacity.

Maintaining SPCC compliance requires preparing plans that outline facility-specific spill prevention procedures, associated equipment to prevent spills from occurring, and countermeasures to address the effects of potential oil spills on sensitive environments. For organizations that have many facilities, web-based response planning provides seamless integration of approved enterprise-wide procedures and policies with site-specific, SPCC required information. This optimizes the potential for every location to remain in compliance with SPCC regulations.

Since 1973, the EPA has conducted scheduled or unannounced facility inspections to ensure that facilities identify site-specific practices related to the storage and management of oil and oil tanks, and response procedures in the event of an oil spill. According to the EPA, the SPCC Inspections serve two primary functions:

  1. To ensure that oil storage facilities, refineries, electrical utilities and oil production fields, among other subject industries, are in compliance with 40 Code of Federal Regulations (CFR) part 112.
  2. To give U.S. Environmental Protection Agency representatives the opportunity to educate owners and operators about the regulations and ways to ensure compliance.

SPCC TRP Corp

In order to meet SPCC regulatory requirements, every applicable facility in your organization is required to regularly update and maintain SPCC plans per EPA regulation 40 CFR 112.20. The following is an abbreviated checklist of SPCC associated planning elements that EPA representatives may evaluate during facility inspections:

  • Storage tanks and other equipment containing oil
  • Storage tank integrity testing requirements
  • Truck loading/unloading areas
  • Transfer procedures and equipment (including piping)
  • Facility layout and diagram
  • Drainage patterns and oil discharge predictions
  • Secondary containment or diversionary structures and their ability to contain a release of oil
  • Site security measures
  • Operating procedures
  • Personnel training and oil discharge prevention briefings
  • Plan certification (by a Professional Engineer (PE) or in certain cases by the facility owner/operator)
  • Recordkeeping

Since the prevention and countermeasures identified in SPCC plans must be implemented throughout the facility in order to be in compliance with regulations, a copy of your SPCC plans must be available to inspectors for reference at all times. In addition, it is essential to provide inspectors with relevant documentation of all operating and inspection procedures, spill prevention measures, training records and other compliance verification information.

With a comprehensive, web-based, database-driven SPCC plan management system, emergency managers and health, environmental, and safety departments can:

  1. Simplify audits
  2. Easily identify required information
  3. Verify accuracy of plan contents through secured access
  4. Revise information in real-time, as necessary
  5. Identify regulatory compliance gaps
  6. Account for necessary mitigation endeavors
  7. Ease maintenance and administrative efforts
  8. Provide electronic copies of plans to government agencies

Proactive responsive, procedural, and preparedness measures, in conjunction with innovative planning system technologies can maximize compliance efforts and minimize accidents and catastrophes. Transitioning to a web-based system to maintain SPCC plans can enhance accessibility, portability, and redundancy, potentially easing communication barriers with responders and regulatory audits.

For a free download entitled, "The Facility Response Plan and the Spill Prevention, Control, and Countermeasure Plan", click here or the image below:

TRP - SPCC and FRP

Tags: SPCC, EPA, Regulatory Compliance, Facility Management, Emergency Management Program

Improving SPCC and Facility Response Plan Compliance

Posted on Mon, Apr 21, 2014

Regulatory non-compliance has proven to be expensive, time-consuming, and potentially dangerous to company employees and the surrounding communities. As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, companies may be required to develop, maintain, and submit an approved Facility Response Plan (FRP) and/or a Spill prevention, Control, and Countermeasures Plan (SPCC).

If government regulations are applicable to operations, companies need to prioritize response plan compliance in order to minimize fines, negative public perceptions, and potential government mandated shutdown of operations.  A compliant and exercised response plan can be the foundation to an efficient preparedness program.

By systematically aligning emergency plans and their components with corresponding regulations, companies can identify and amend plan deficiencies. Response plan compliance can be improved by the following:

  • Evaluate regulatory applicability across all company operations
  • Perform audits or gap analysis of response plans against regulatory requirements
  • Identify new planning requirements as regulations evolve
  • Maintain up-to-date plans that reflect facility, personnel, or operational changes
  • Exercise plans to ensure plan accuracy
  • Confirm regulatory response plan submittal requirements

Determining response plan requirements for each facility will determine the site-specific information required by the corresponding regulatory agency. A “substantial harm” facility is a facility that, because of its location, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on navigable waters or adjoining shorelines. These facilities are required to develop, maintain, and submit a facility response plan.

Certain facilities that store and use oil are required to prepare and submit facility response plans to respond to a worst case discharge of oil and to a substantial threat of such a discharge.” - EPA

TRP Corp - Substantial Harm

In addition to maintaining a site-specific plan, an FRP mandated facility must keep a log of response training drills and exercises, along with plan updates reflecting material changes. Records of inspections of response equipment must be kept for five years. If response-planning requirements under 40 CFR 112.20 are not applicable, a facility must complete the certification form in 40 CFR Part 112 Appendix C Attachment C-II.

According to EPA, key elements of an FRP should include:

  • A stand alone Emergency Response Action Plan
  • Facility name, type, location, owner and operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and evaluation of potential spill hazards and precious spills
  • Identification of small, medium and worst case discharge scenarios and response actions.
  • Description of discharge detection procedures and equipment
  • Detailed implementation plan for containment and disposal
  • Facility and response self-inspection, training, exercises and drills, and meeting logs
  • Diagrams of facility and surrounding layout, topography, and evacuation paths
  • Description of site-security and security equipment

In addition to an FRP, facilities such as oil production facilities, bulk storage terminals, power plants, automotive plants, chemical plants, power plants, transportation centers, laboratories, and compressor stations may be required to submit SPCC plans. SPCC Plans identify prevention practices related to the storage of oil and management of tanks and other storage equipment. SPCC plans can often be confused with oil spill contingency plans, which typically address response measures after a spill has occurred.

Under the Federal Rule 40 CFR 112, facilities that store more than 1,320 gallons of oil or petroleum-based liquids aboveground or more than 42,000 gallons of oil underground s are required to have a SPCC (Spill Prevention, Control, and Countermeasure Plan). - EPA

Development of a unique SPCC Plan requires detailed knowledge of the facility and the potential effects of any oil spill. While each SPCC 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
  • Discussion of conformance with federal regulations
  • 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

Response plan standardization across a company enterprise allows for a familiar format, a synchronized response, and is the best option for ensuring regulatory compliance across multiple response plans.

Be prepared for your next incident! Click the image below to download your free guide.

Preparedness and Emergency Management - TRP Corp

Tags: Facility Response Plan, SPCC, EPA, Regulatory Compliance, Facility Management

The SPCC Plan Hybrid Inspection Program

Posted on Thu, Sep 12, 2013

The Environmental Protection Agency (EPA) estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule:

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires SPCC plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.

The SPCC inspection program is designed to detect oil leaks, spills, or other potential integrity or structural issues before a  spill occurs.  The type of inspection program, scope, and frequency will depend on site-specific conditions, spill history, and type of facility. Typically, inspection programs are in accordance with industry standards. However, companies can decide to deviate from industry standards when another approach would be more appropriate or cost effective, based on site-specific factors. The result may be a Hybrid Inspection Program.

The EPA classifies a Hybrid Inspection Program as a customized, site-specific inspection program based on relevant industry standards (in whole or in part) and other good engineering principles. According to the EPA, the components of a Hybrid Inspection Program would likely include frequent visual inspections by the operator, as well as periodic inspections (plus testing as appropriate) by an EPA certified inspector. A company must document environmentally equivalent inspection and testing alternatives, the reason for the deviation, and describe the alternative method in detail, including how it is environmentally equivalent in the SPCC Plan.

It is recommended that formal container test records or reports be retained for the life of a container under the Hybrid Inspection Program. When implementing a Hybrid Inspection Program, the EPA recommends the following elements:

Inspection elements for shop-built tanks:

  • Visually inspect exterior of tank
  • Evaluate external pitting
  • Evaluate “hoop stress and longitudinal stress risks” where corrosion of the shell is present
  • Evaluate condition and operation of appurtenances
  • Evaluate welds
  • Establish corrosion rates and determine the inspection interval and suitability for continued service
  • Evaluate tank bottom where it is in contact with ground and no cathodic protection is provided
  • Evaluate the structural integrity of the foundation
  • Evaluate anchor bolts in areas where required
  • Evaluate the tank to determine it is hydraulically sound and not leaking

Inspection elements for field-erected tanks:

  • Evaluate foundation
  • Evaluate settlement
  • Determine safe product fill height
  • Determine shell corrosion rate and remaining life
  • Determine bottom corrosion rate and remaining life
  • Determine the inspection interval and suitability for continued service
  • Evaluate welds
  • Evaluate coatings and linings
  • Evaluate repairs for risk of brittle fracture
  • Evaluate the tank to determine it is hydraulically sound and not leaking.

When industry standards do not apply to a container or the container is outside the scope of the standard, a PE does not need to provide and certify an environmental equivalence justification. However, specific inspection protocols must be described in the SPCC Plan, and records of inspections and tests must be maintained for three years. Containers included outside the scope of industry standard can include, but are not limited to:

  • Containers storing oils that have a specific gravity greater than 1.0
  • Oil containers operated at elevated temperatures
  • Animal fat or vegetable oils (AFVOs) containers

Regional EPA representative(s) conduct both announced and unannounced inspections at facilities. A copy of the facility’s SPCC Plan with site-specific inspection procedures should be available for inspector(s) to review at all times. Additional documentation,  including operating procedures, spill prevention measures, personnel training, drainage discharges, and spills should be provided to inspector(s), as well as site plans for tankage, diversionary structures, and drainage patterns.

For a free download on Tips on Conducting an Effective Eercise, click the image below:

TRP Corp Emergency Response Planning Exercises

Tags: SPCC, Oil Spill, Training and Exercises, Regulatory Compliance, Chemical Industry

Industrial SPCC Plans Accessible in Cloud Technology

Posted on Thu, Feb 07, 2013

As web-based technologies become more accessible and mobile, different options for hosting and managing response plans have evolved. Transitioning to a web-based cloud system to maintain your Spill Prevention, Control, and Countermeasure (SPCC) plans can enhance accessibility, portability, and redundancy, potentially easing communication barriers with responders and regulatory audits.

Environmental, health, and safety (EHS) managers responsible for maintaining regulatory compliance for multiple sites may benefit from web-based cloud computing for emergency management. While cloud technology isn’t a new concept, a recent survey conducted by IT industry association CompTIA, found that more than 80% of companies use or have transitioned to some form of cloud technology. The survey revealed that costs, increased flexibility, and newly available resources are the main motivation for moving to a cloud.  The costs associated with effective emergency management, planning efforts, and overall spill prevention are often much less than the costs associated with spill clean up, fines, and other civil liabilities.

The Environmental Protection Agency (EPA) estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule:

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires SPCC plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.

EHS managers responsible for maintaining SPCC compliance can maximize department efforts and communication. With budgets restraints and increasing workloads, reducing plan maintenance costs, improving communication methods, and minimizing preparedness disparities is critical. Word documents, PDF files, and printed binders are burdensome, administratively time-consuming, and possibly inaccurate or non-compliant.

Here are some questions to determine if web-based cloud technology SPCC plan system is right for your company?

  1. Do you have multiple facilities that are governed by SPCC and/or other regulatory requirements?
  2. Is there repetitive company information in multiple response plans?
  3. When was your last SPCC or facility response plan (FRP) audit and would you be ready if an auditor appeared tomorrow?
  4. Does your company already utilize cloud-based technology?
  5. How effectively do you handle contact information updates and verification? How often does this occur?
  6. How often do you print updated plan copies for distribution, and what costs are involved?
  7. How audit-friendly are your plans?
  8. How many individuals have access to your plans and are authorized to make updates?
  9. Are your plans updated quarterly or annually?
  10. How are new regulatory requirements incorporated into plans?
  11. How much time is dedicated to maintaining and updating your plans?
  12. Do you have a record of changes and revisions?

But with a cloud system, redundancy and back up efforts are essential.  In the event Internet connectivity is terminated or inaccessible, emergency managers must have alternative means to access plans. Redundant data centers, scheduled downloads, and security measures must be a part of any emergency management program based on an intranet or cloud.

Response plans housed in cloud technology also has numerous benefits. When employees are equipped with Wi-Fi enabled devices, authorized users can access response plans information from any location. This can aid in response measures if the incident is isolated to a particular location. SPCC plans can also be readily shared with other company locations and external responders who can relay important detailed facility information to those onsite. Additionally, dedicated administrative time associated with plan maintenance, updating, access, and regulatory submission can be minimized.  

The following EPA list highlights some important elements of an SPCC Plan:

  • Facility diagram and description of the facility
  • Oil discharge predictions
  • Appropriate secondary containment or diversionary structures
  • Facility drainage
  • Site security
  • Facility inspections
  • Requirements for bulk storage containers including inspections, overfill, and integrity testing requirements
  • Transfer procedures and equipment (including piping)
  • Requirements for qualified oil-filled operational equipment
  • Loading/unloading rack requirements and procedures for tank cars and tank trucks
  • Brittle fracture evaluations for aboveground field constructed containers
  • Personnel training and oil discharge prevention briefings
  • Recordkeeping requirements
  • Five-year Plan review
  • Management approval
  • Plan certification (by a Professional Engineer (PE) or in certain cases by the facility owner/operator)

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

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Tags: SPCC, EPA, Redundant Systems, Cloud Computing

30 Questions Oil Spill Response Plans Should Reveal

Posted on Thu, Oct 18, 2012

Oil spill response planning should provide site-specific details to enhance oil spill response plans and incorporate a response perspective with specific short-term and long term actions and procedures. If properly planned, exercised, and executed in a timely and effective manner, oil spill response plans can protect lives, communities, and the environment and limit the financial burdens associated with an oil spill. 

The primary objectives of oil spill response plans are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for combating the spill at a specific location
  • Improve regulatory compliance efforts

While oil spill response plans are necessary to satisfy applicable regulatory requirements, different regulatory agency require specific plans depending the facility’s operations (oil producing, storage, or transport) and location. The Bureau of Safety and Environmental Enforcement (BSEE) is responsible for oil spill planning, preparedness, and other select response activities for facilities located seaward of the coastline.  Oil Spill Response Plans” (OSRP) are necessary to satisfy BSEE regulatory requirements for facilities in this geographic area.

“Facility Response Plans” are required by the Environmental Protection Agency (EPA) for certain oil storage facilities that store and use oil that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on navigable waters. EPA regulated facilities must submit plans that reveal details of policies and procedures to respond to a substantial threat of a discharge and a worst-case discharge. The EPA may also require ‘Spill Prevention, Control, and Countermeasure” (SPCC) plans and “Contingency Plans” depending on site location and quantity of oil at the site.

According to the EPA, a regional administrator may consider additional factors to determine if facility response plans are required. Those factors include, but are not limited to:

  • Type of transfer operations
  • Oil storage capacity
  • Lack of secondary containment
  • Proximity to fish, wildlife, and sensitive environments or drinking-water intakes
  • Spill history

Through facility assessments, best practices, and responder input, effective oil spill response plans should incorporate a variety aspects and perspectives of a response. The following 30 questions can be used as planning discussion points to develop or assess oil spill response plans:

  1. Have high-risk activities been identified, assessed and, if possible, mitigated?
  2. Have high sensitive areas been identified and potential consequences been assessed?
  3. How would a potential spill affect both internal and external resources?
  4. Did risk assessment utilize realistic scenarios to define oil volumes and release locations?
  5. Have trajectory estimates been completed and do they include potential weather scenarios?
  6. Do trajectory maps mimic local observations and historical tendencies?
  7. Have trajectory-timing estimates and recovery location points been included in oil spill planning process?
  8. Have material safety data sheets (MSDS) been updated and properties included in the planning process?
  9. Have processes been established for updating planning information prior to an emergency and during a response?
  10. Have plot plans and area mapping been integrated with GIS data and knowledge?
  11. Are sensitive sites prioritized for protection?
  12. Have response times and limitations been set?
  13. Have alternate strategies and response procedures been identified?
  14. Is there an agreement over response strategies and priorities between personnel and responders?
  15. Does the planning process incorporate best practices ecological risk assessment principles?
  16. Have response equipment needs been evaluated and defined?
  17. Is external spill response support available and are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
  18. Are staff roles and responsibilities specified and communicated?
  19. Are personnel appropriately trained for allocated roles?
  20. Do plans include specific criteria for provisional tiered responses?
  21. Have the plans be thoroughly exercised with realistic scenarios?
  22. Is the response management team structure clear and able to be communicated?
  23. Is there an internal and external communication method established?
  24. Is feedback from exercises incorporated into plan revisions?
  25. Are clear procedures in place to notify, assess and initiate a response?
  26. Are communications backup systems available and described in the plan?
  27. How is information accessed during a response to determine size, shape, type, location, and movement of the oil?
  28. Are procedures in place for monitoring spill size, shape, type, location, movement, and impact?
  29. Are waste management and demobilization processes communicated?
  30. Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?

Oil Spill response plans are an effective collaborative response tool that should be shared with contracted response groups and local authorities.  Collaborative efforts in developing and exercising the plan provides opportunities for the response community to work together as a team and develop the interpersonal relationships that can effectively promote smooth functioning during a response.

For information about SPCC Plans, download TRP Corp's free SPCC and FRP Inspections guide.

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Tags: Emergency Preparedness, SPCC, EPA, Oil Spill, Regulatory Compliance