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EPA asks, "Where Are the SPCC Facilities?"

Posted on Mon, Jul 02, 2012

In 1973, the Environmental Protection Agency (EPA) issued the Spill Prevention, Control, and Countermeasure (SPCC) Rule to establish procedures, methods, and equipment requirements to prevent oil discharges from non­ transportation-related facilities. Maintaining SPCC compliance requires preparing plans that outline spill prevention procedures, equipment to prevent spills from occurring, and countermeasures to address the effects of  oil spills.

Despite the regulation, according to a February 2012  EPA report, approximately 55 percent of 3,700 facilities inspected from 2007-2012 were not in compliance with the SPCC guidelines. The EPA estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule, yet less than 1 percent of the facilities have been inspected. The report highlights the difficulty in SPCC oversight due to lack of facility self identification requirements. Only SPCC facilities that are required to submit Facility Response Plans (FRP) are identified by the EPA.

EPA regions are continually discovering facilities that have been previously unknown as SPCC facilities.  Recently in New Mexico, which is covered by EPA Region 6, 45 previously unknown SPCC-regulated oil and gas production facilities were identified while conducting inspections at other known facilities.

EPA regions have attempted to increase their knowledge of SPCC facilities by using state aboveground storage tank databases, industry databases such as Dun and Bradstreet, and other federal databases. However, the databases are separate and incompatible with EPA’s databases.

Compiling a list of facilities that come under the SPCC Rule is complicated because limited or incomplete facility data lead to difficulties in determining the facility’s proximity to U.S. navigable waters, the type and capacity of product stored, and facility type (i.e., production or storage).”

While limited resources and staffing strain the EPA’s efforts to identify and inspect every SPCC relevant facility, responsible owners and operators need to be proactive in developing and sustaining accurate plans. Companies must have an SPCC Plan for each facility that has at least one 1,320-gallon aboveground storage tank and/or underground storage of at least 42,000 gallons, and be in such a location that a spill could reasonably be expected to discharge oil into navigable waters. These plans must be certified by a professional engineer . These rules apply regardless of whether the applicable tanks are full or nearly empty.

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

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Tags: SPCC, EPA, Oil Spill, Regulatory Compliance, Chemical Industry

Certification Requirements of SPCC Plans

Posted on Thu, Mar 22, 2012

A spill prevention, control, and countermeasure plan, commonly know as an SPCC plan, identifies site specific details related to the storage and management of oil and oil tanks, and response procedures in the event of a spill. The Environmental Protection Agency (EPA) requires SPCC Plans for facilities that could reasonably be expected to discharge oil into navigable waters if their facility has more than a 1,320 gallon capacity aboveground storage tanks and/or more than 42,000 gallons capacity in underground storage tanks.

SPCC plans provide specific site details that allow responders to best access, assess, and quickly respond to off-site spills, limiting the effects of a spill on sensitive environments. If a facility has more than 10,000 gallons of aggregate aboveground oil storage capacity, the SPCC must be inspected and certified by a professional engineer (PE). The certifying engineer must:

  • Be familiar with SPCC 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 SPCC plans yet have an aboveground oil storage capacity of less than 10,000 gallons, may self-certify SPCC 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 or (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 SPCC 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.

For more details on self-certification, see Option for Qualified Facilities that Store or Handle 10,000 Gallons or Less of Oil.

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

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Tags: Emergency Management, SPCC, EPA, Oil Spill, Emergency Management Program

Informative Videos for EHS Professionals and Emergency Managers

Posted on Mon, Feb 20, 2012

Below are a various informative videos that may assist professionals in emergency response planning.
Note: These video are meant to be informative, and do not replace mandated training.

OSHA Construction Hazard Prevention videos: These based on actual event series of videos demonstrate work site incidences that resulted in an employee injury or death. Corrective actions for preventing these types of accidents are discussed.

How to Use a Portable Fire Extinguisher Training Video: This video was created by the Fire Equipment Manufacturers' Association to train viewers on how to assess a potential fire situation and use a portable fire extinguisher in the event of a fire emergency.

Oil Spill 101: Blocking with boom: National Oceanic and Atmospheric Administration video on how boom contains an oil spill, including the four main types of boom used

2012 Emergency Response Guidebook (ERG): The 2012 Emergency Response Guidebook contains the latest dangerous goods lists from the United Nations Recommendations, as well as from other international and national regulations. The 2012 ERG is designed for emergency responders to quickly and accurately access a HAZMAT incident.

Exxon Valdez: 20 Year later: Detailed video of the historical events regarding the Exxon Valdez spill that resulted in the passing of the Oil Pollution Act of 1990 (OPA 90 ).

Incident Command System: Positions & Responsibilities: With the Salvation Army as the backdrop organization, this video highlights the roles and responsibilities of key positions within the Incident Command System.

Sorting Out SPCC: Video that details the EPA regulated SPCC plans.  Video is directed at new farm regulations, however, the it provides an overview of the EPA's Oil Spill Prevention, Control and Countermeasure Program.

Iron in the Fire: U.S. Chemical Safety Board reviews of chemical dust fires in 2011.

For a sample Emergency Response Checklist, download our helpful and informative guide.

Tags: NOAA, Fire Preparedness, Emergency Management, Incident Management, SPCC, OPA 90, Oil Spill, Video

SPCC and Oil Spill Contingency Plans

Posted on Thu, Jan 12, 2012

40 CFR Part 112, requires that certain facilities develop and implement oil spill prevention, control, and countermeasure, or SPCC Plans.

SPCC Plans ensure that facilities establish sufficient containment and/or other applicable countermeasures to reduce the potential for oil spills to reach navigable waters. However, oil spills typically result from accidents or human error, which can occur at any place, time, or location. SPCC plans can often be confused with oil spill contingency plans, which typically address response measures after a spill has occurred.

Once a spill occurs, the best approach for containing and controlling the spill is to respond quickly and in a well-organized manner. According to the EPA, a contingency plan "looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill." A spill contingency plan is required as part of the SPCC Plan if a facility is unable to provide adequate secondary containment.

SPCC Elements

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

SPCCplans.jpg

The Oil Spill Contingency Plan

Elements of a Contingency Plan include:

  1. Hazard identification
    1. Types of oils stored
    2. Transport details
    3. Extreme weather conditions
    4. Response equipment and personnel details
  2. Vulnerability analysis
    1. Identification of resources and communities potentially affected by a spill
  3. Risk assessment
    1. Comparing the hazard and the vulnerability for a specific site(s) to determine potential controls, prevention, and necessary repairs
  4. Response actions
    1. Description of actions required in the event of a spill.

Although "prevention is the best medicine", companies should investigate each spill to determine how future occurrences can be eliminated.

TRP - SPCC and FRP

 

Tags: Emergency Response, SPCC, Facility Management, Disaster Response

Identifying Sensitive Environments in the Path of an Oil Spill

Posted on Mon, Oct 17, 2011

While oil spills can effect the immediate area, migrating spills that extend beyond its containment measures can greatly affect the surrounding areas and possibly damage sensitive environments. A critical step in protecting sensitive resources is identifying the presence and types of resources that are in the likely path of an oil spill.

Analyzing possible spill trajectories through topographical features, wind speeds, and water flow rates allows planners to identify which areas are most likely to be impacted by a spill.  Once these resources have been identified, decisions need to be made as to the proper protection techniques for each locale and the priority for application of resources to each sensitive site.

Sensitive_Environments_TRP.jpgTypes of sensitive areas to evaluate include, but are not limited to:

  • Ecological: Examples of sensitive species include shore birds and other water fowl, seals and other marine mammals, shellfish, commercially important wildlife, and species with limited distribution or populations. Sensitive habitats range from protected bays with marshes and tidal flats to open coast areas used as marine mammal or bird breeding sites.
  • Cultural: Areas of direct importance to humans including, but not limited to native lands, historical land marks, waterfront parks, and recreational areas.
  • Economical: Populated areas that are highly valued because of their ability to generate income. Area’s include tourist sites, real estate developments, urban developments, marinas, parks and other locations.
  • Specific sensitive resources: Specific resources that are only available at that particular location, such as specialized suppliers, water sources, transportation systems, food sources.

Once the sensitive areas in the path of a potential oil spill are identified, tactical plans and processes should be developed to limit the duration of impact. Tactical planning provide site-specific focus to emergency response plans, and applies a response perspective with specific, short-term actions and responses. These plans provide details that allow responders to best access, assess, and quickly respond to off-site spills, limiting the effects of a spill on sensitive environments.

 

Be prepared! Receive a Incident Preparedness Guide!

Preparedness and Emergency Management - TRP Corp

Tags: USCG, Pipeline, OSHA HAZWOPER, Emergency Preparedness, SPCC, OPA 90, Oil Spill, Emergency Management Program, HAZWOPER

Does Your Facility Require a SPCC Plan?

Posted on Thu, Jun 16, 2011

Under the Federal Rule 40 CFR 112, facilities that store more that 1,320 gallons of oil or petroleum-based liquids aboveground or more than 42,000 gallons of oil underground is are required to have a SPCC (Spill Prevention, Control, and Countermeasure Plan).  A SPCC Plan identifies practices related to the storage and management of oil and oil tanks, and response procedures in the event of a spill.

SPCC plans may be necessary for oil production facilities, bulk storage terminals, power plants, automotive plants, chemical plants, power plants, transportation center, laboratories, compressor stations, and more. Each SPCC Plan must be unique to a specific facility. 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 compliance with the regulations.

Common standards include, but are not limited to:

  • Management approval.
  • A licensed Professional Engineer certification for facilities that store more than 10,000 aggregate gallons of oil
  • Identification of potential spill sources and secondary containment devices.  

The EPA states “Oil spills endanger public health, impact drinking water, devastate natural resources, and disrupt the economy. Every effort must be made to prevent oil spills and to clean them up promptly once they occur.” According to Section 112.2 of 40 CFR 112,  "Oil means oil of any kind or in any form... .".  On-site materials to be included in an SPCC plan and subject to regulations, include but are not limited to:

  • Animal fats and oils
  • Crude oil
  • Diesel fuel
  • Fuel oil
  • Leaded and unleaded gasoline
  • Hydraulic oils
  • Jet fuel
  • Kerosene
  • Lubricating oils
  • Nut oils
  • Vegetable oils, including oils from seeds, fruits, or kernels

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

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Tags: Pipeline, SPCC, EPA, Emergency Management Program

Regulatory Compliance - It's the Law!

Posted on Fri, Mar 11, 2011

An organization can have numerous locations that cross county, state, and/or country borders. Despite operating within the same industry, each site may need to comply with specific applicable local, state, and/or federal regulatory mandates.

Organizations must comply with an ever increasing number of regulations. For example, one specific industrial facility in Louisiana has to meet as many as 700 individual requirements. Non-compliance can cost organizations thousands of dollars, yet documenting and managing these mandates within day to day operations can be a daunting task. 

The implementation of a tracking management system that can eliminate redundancies across converging compliance specifications is extremely beneficial for organizations that have multiple applicable regulatory requirements.

A tracking system should itemize applicable federal, state and local regulations and include categorical information that satisfies that regulation.  A tracking system should contain the following components, at a minimum:

  • Operational category: Categories can range from air quality and hazardous materials, to construction safety and general safety and health. Depending on the detail required by the regulations, further breakouts by subcategories may also be required.
  • Applicable Regulation Level:  Regulations should be further broken down to Federal, state or local regulation categories. 
  • Last update: Date that each regulation was last updated.
    Compliance Task:  Tasks that needs to be completed for compliance.
  • Compliance Feedback:  Applicable notes.
  • Industry Standard:  Industry standards or best practices that apply to the specific  regulatory requirement
  • Cross reference: Itemize list of additional regulations that may be applicable to the information provided.
  • Facility Compliance responsibility: Person(s) responsible to maintain compliance for each regulatory requirement.
  • Action Item Reporting: Provides a list of outstanding and completed action items, along with due dates and persons assigned. Reports should have filters to customize queries as required by the users. 

The results of an effective compliance tracking system is an efficient and integrated program that optimizes the efforts of all stakeholders and allows for optimum compliance.

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

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Tags: USCG, DOT, CFATS, Emergency Preparedness, Crisis Management, SPCC, EPA, Regulatory Compliance, Emergency Management Program

School Safety Planning May Include SPCC Plans

Posted on Tue, Feb 01, 2011

Every day across the United States, millions of students are safely transported on school district buses to their destinations. Districts must extend school emergency operations planning to their transportation centers and associated on-site fueling operations. Depending on the quantities stored, these transportation centers may be required to have Spill Prevention Control and Countermeasure (SPCC) Plans (40CFR 112.8).

The Environmental Protection Agency (EPA) requires SPCC Plans for facilities that could discharge oil into navigable waters and store more than 1,320 gallons above ground or more than 42,000 gallons underground.

Many school districts store diesel and/or gasoline, in addition to bulk transportation fluids, such as antifreeze and motor oil. Every school district that requires an SPCC Plan should develop and maintain a plan, and periodically:

  • Inspect fuel storage equipment condition
  • Evaluate operational procedures, and ensure best practices are being followed
  • Ensure that SPCC training is conducted
  • Review maintenance and documentation practices
  • Perform spill response training and exercises

SPCC_Transportation.jpg

In additional to being a regulatory requirement, a well-designed SPCC plan can be used as a guide for proper spill response procedures. The plan should include best practices for preventing and responding to discharges, notification and reporting procedures, and emergency communication to district employees and emergency responders.

Sharing SPCC information with responders prior to an emergency could potentially reduce hazardous impacts if a spill were to occur. Incorporating external responders in drills and exercises is also crucial. Response protocols can be effectively reviewed during exercises with the emergency response team resulting in a strong, synchronized unit.

TRP - SPCC and FRP

Tags: SPCC, School Emergency Planning

Spill Resonse Planning Must Include Waste Management Responses

Posted on Fri, Nov 12, 2010

Spill response planning should include detailed waste management procedures. Each hazardous spill situation is unique and must be treated according to the circumstance presented. However, hazardous material handling and necessary disposal needs may be overlooked in the initial phase of a response, which could result in delays and interruptions of cleanup operations.

OSHA defines clean up operation as “an operation where hazardous substances are removed, contained, incinerated, neutralized, stabilized, cleared-up, or in any other manner processed or handled with the ultimate goal of making the site safer for people or the environment.”

The following waste management information should be considered in an spill response plan:

  • Proper PPE and waste handling procedures
  • Disposal plan in accordance with any federal, state, and/or local regulations
  • Facility-specific disposal locations for different types of materials
  • Continuous tracking of oil disposition to better estimate amount of waste generated
  • Methods and procedures for waste collection, segregation, storage, transportation, and proper disposal
  • Regulatory review of applicable laws to ensure compliance and appropriate permitting
  • Documentation of all waste handling and disposal activities

Waste_Management_Planning_TRP.jpg

The backbone of hazardous waste management planning should include the “Reduce, Reuse, and Recycle” initiative implemented by the EPA:

  • Reusing materials when possible
  • Recycling or reclaiming waste
  • Treating waste to reduce hazards or reducing amount of waste generated

Emergency planning for waste management must incorporate personnel safety and minimize environment impacts.  Through proper planning and disposal procedures, hazardous waste management planning can limit environmental liability, and as an effect, minimize additional immediate and long-term financial burdens.

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

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Tags: Emergency Preparedness, Crisis Management, SPCC, Oil Spill, Emergency Management Program

The Problem with Paper-based Emergency Response Plans

Posted on Fri, Oct 08, 2010

Electronic documents, online textbooks, smart phones, VoIP, and GPS are some of the advances that are slowly becoming standard in today’s society. Increasingly available and more reliable technology has allowed better access to information and a higher level of functionality. Is this also true with emergency planning?  

Below are some common pitfalls with traditional paper plans that are still in use in large numbers:

1. Inefficiency of updating repeating information, especially in multiple plans - there are often duplicate or overlapping information requirements from one plan type to another, and for multiple facilities. Example: corporate emergency manager's contact information may reside in many plans. If/when that person's contact information changes, it has to be physically changed in each plan.

2. Difficulty in knowing when company personnel contact information has changed and time spent finding current information.

3. Limited Access to plans - Paper plans are not typically available to access from other locations. Most plan users will have a paper copy and will not carry it wherever they go. Some companies will post electronic plans to their intranet and possibly can be accessed remotely, however, the process of updating these plans is time-consuming and inefficient.

4. Lack of consistency - Plan formats usually vary from one facility to another, making it difficult to manage training and compliance efforts.

5. Limited functionality - Web-based plans can provide hyperlinks, forms libraries, simplified interfaces, and other tools designed to improve functionality for plan users.

6. Understanding which source files are the most current - use of Microsoft Word creates a multitude of files, which may be copied. This facilitates having multiple version of files and confusion as to which are the most current.

7. Assessing compliance level of the program - Since paper plans are typically not accessible, it is usually difficult for a program manager to know when plans were last updated, or approved by regulatory agencies.

8. Lack of ability to use data in plans for other purposes - Some plan types have data for contacts, equipment, chemicals, and other information which is utilized by other personnel or departments. There is not an efficient method to manage and share this data in Microsoft Word.

Will paper-based plans become obsolete in the near future? Have you tried to find a working pay phone lately? If you needed one in an emergency, would you be able to find one? Maybe its time to rethink the concept of paper-based emergency response plans also.

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

Tags: Corporate Hurricane Preparedness, Fire Pre Plans, Emergency Preparedness, SPCC, School Emergency Planning