Spill & Emergency Response Plans
An oil storage facility that has Spill & Emergency Response Plans

Spill Countermeasure and Control Plans (SPCC) and SPCC Training (40 CFR 112)

Facilities with more than twenty-four 55- gallon drums (1,320 gallons) of petroleum or animal fats and oils on site that are near navigable waters must have an SPCC Plan. Any combination of operating equipment and storage containers that have oil volume > 55 gallons are to be counted toward the 1,320-gallon limit. This includes transformers, machines using oil-based coolants, tank farms, and 55-gallon drums. There are special conditions for facilities that have less than 5,000 gallons on site (Tier 1) and 10,000 gallons on site (Tier 2). It is recommended to get a professional’s opinion on the exact requirements for your plant. Annual training on the SPCC Contents, changes to the SPCC Plan and any failure of the plan is required. Click here for Title 40 Code of Federal Regulations.

Tier I and II plans may be self-certified by the owners. Other SPCC Plans must be certified by a licensed PE when they are first deployed, when construction of spill controls and when equipment of greater than 55 gallons volume of oil are added. Every 5 years, the SPCC Plan must undergo a review for possible use of field proven technology that will reduce the probability of spills.

Stormwater Pollution Prevention Plans (SWPPP) and Training

Certain Standard Industrial Classifications (SIC) Codes require a storm water permit if equipment, waste containers, vehicles, product, raw materials and other are stored outside and are exposed to rainwater. The most common permits are General Permit No. 1 for Industries or commercial entities and Genera; Permit No. 2 for construction activities that disturb more than one acre of soil. These are federally mandated. Most states have a variety of general permits for other storm water conditions such as asphalt plants, concrete batch plants, rock crushing, non-contact cooling water, and sand and gravel facilities. Some states may have 10 or more types of general water permits. A SWPPP must describe potential storm water contamination areas, potential storm water controls, inspections for those areas, annual training for designated personnel, and a written annual inspection. States vary in what is required for reporting. These plans will describe Best Management Practices for storm water management.

Toxic Organic Management Plans (TOMP)

Facilities that do metal finishing (coating, phosphating, electroplating, etching and other processes) as defined at 40 CFR 433. are required to do semi-annual monitoring for Total Toxic Organics (TTO), a suite of over 100 volatile, semi volatile and other organic parameters. This monitoring can be quite expensive depending on the number of monitoring locations, e. g. each pre-paint treatment system. A TOMP may be prepared in lieu of monitoring, The TOMP must describe where the TTO’s are located, spill protection measures, and requires periodic inspections of the locations. Typically, it must be approved by the City that controls the industrial discharges to the sewer system.

Hazardous Waste Contingency Plans

Large Quantity Generators (LQG) of Hazardous Waste are required to have a written Contingency Plan that covers response to fires, explosions, and any unplanned sudden or non-sudden releases of hazardous waste to air, soil, or surface water. The Plan must be shared with the local fire and police depts. and hospitals. Small Quantity Generators (SQG) are only required to have a basic contingency plan (40 CFR 262.16(b)(8) & (9). Annual training on the Contingency plan is required including any changes to the plan or what happened if the Plan needed to be implemented.

Emergency Response Plans

29 CFR 1910, Subpart E requires a facility to have an emergency and fire prevention plan in place. Emergency exits and routes must be documented. Training on plan implementation is needed. Plans can include tornados, chemical spills, serious injuries or fatalities, workplace violence, electricity failure, and many other scenarios.

Remediation Closure and Post Closure Care Plans

Contaminated sites that have undergone cleanup are often regulated at the state level. States require a Site Closure Plan to demonstrate that all activity at the site has stopped and appropriate controls are in place to keep any contamination on site. A post closure care plan is also required. Annual or bi-annual cost estimates of post closure care of the site are required by the state. Ongoing monitoring of groundwater or soil may be required. When monitoring data looks favorable, a site can file an affidavit for certifying completion of post closure care with the regulatory agency. This usually results in some negotiation with the agency and answering final questions. The affidavit requires a summary of groundwater monitoring and maintenance and other activities during the post closure care period.  All these documents require a PE review and signature, as well as the site owners.

Chemical Facility Anti-Terrorism Plans

The Department of Homeland Security regulates the Chemical Facility Anti-Terrorism Standards (CFATS). If a facility exceeds the quantity and concentration of a chemical of interest (COI), the facility must submit a Top Screen using an online tool called “Chemical Security Assessment Tool” which is located at https://www.cisa.gov/cfats-process. This standard is to ensure that COI’s are protected from potential terrorist threats. Once the Top Screen is submitted, DHS will evaluate the data and decide what if any further action is required.

Slug Control Plan

Larger municipalities are required to have a pretreatment program. The City issues discharge permits to industries discharging to the sanitary sewer system. Cities often require a Slug Discharge Control Plan – a plan that ensures that a toxic chemical is not spilled into a sanitary drain or that a large slug of solids or organic material does not enter the sewer system. Slug loads can disrupt the operation of the POTW (Publicly Owned Treatment Works), possibly causing them to violate their permit discharge standards. These are usually required with sanitary sewer discharge permit applications.