In thefirst partof our series, Living with an SPCC Plan, we cited four main activities fundamental to the SPCC plan:
- 在SPCC计划上培训相关设施工作人员
- Conducting inspections
- 回应发布
- Keeping records of inspections, releases, and changes
We spoke on the first two aspects: the importance of training relevant staff on the facility’s plan and best practices for conducting inspections. In this blog, we will discuss the two other necessary activities for maintaining compliance: release response and recordkeeping.
3. Responding to Releases
A crucial aspect of the SPCC Plan is how to respond to releases. Even if you have a contract with an emergency response contractor, there will be spills that you can handle in-house, as well as things that you may need to do while waiting for the emergency response contractor to arrive. Make sure that oil-handling staff know how to respond if there is a release, whether it is small (less than a few gallons) or large.
Unattended leaks can be perceived by an inspector as an indicator of larger problems. For example, a poorly managed facility could have hoses leaking for days (or even weeks) with no one stopping the release or notifying relevant parties about them.
Spills that occur outside of containment or in other areas that could contact stormwater, should be cleaned up immediately upon discovery. Spills captured in secondary containment should be cleaned up before there is a threat of release from the secondary containment or mixing with precipitation, resulting in a larger disposal volume.
For all spills, the following general steps should be taken:
- Eliminate potential spark sources near the release
- Determine the source of the release
- Act to stop the leak if safe to do so (e.g., plug hole, shut off valve, etc.)
- Contain the discharge with sorbents, berms, rags, drain covers, sandbags, soil, or other material to prevent it from going down drains or flowing into surface waters
- Contact the primary contact or the alternate for them to direct further actions
- 报告发布（如果适用）
Often, larger releases can create panic. It is important to remain calm and follow the steps laid out in the SPCC Plan. Even something as simple as covering indoor floor drains or outdoor stormwater drains to prevent the release from getting into the sewer or storm sewer can be instrumental in helping control and clean up the release.
4. Keeping records of inspections, releases, and changes
SPCC计划所需的最后一个主要项目是保留记录everything。这意味着:
- Your SPCC Plan
- Monthly Inspections
- Annual Inspections
- Other Inspections or testing required by the SPCC Plan
- Records of releases (check your SPCC Plan to see what size release triggers this)
- 向州或联邦机构报告的发布记录
- Documentation of periodic review of the SPCC plan
- Changes to your facility and/or your SPCC Plan (such as new containers or changing staff)
必须保留SPCC记录3年。计划在所有相关人员可访问的地方保持您的SPCC计划和您的记录。在我们的工作中，我们经常会看到记录在桌面上的堆中或后面的文件柜中，然后在最需要的时候增加所需的时间来定位它们。请记住，部分培训应该是提醒员工，其中SPCC计划的保存，所以可以在需要时引用。
Having an SPCC Plan prepared for your facility is just the first step to compliance with federal or state regulations. There are actions that must be conducted by facility staff and records that must be maintained. Once your SPCC Plan is complete, make sure that appropriate staff are trained on the requirements of the SPCC Plan and are conducting the actions as appropriate.
Braun Intertec can help with preparing, reviewing, or updating SPCC Plans, and conducting the annual training. Our trainers are experienced with preparing SPCC Plans and provided environmental assistance as required by the plans. Please feel free to reach out to our consultants with extensive knowledge on SPCC plans,Jill Mickelson, P.E., orJosh Kadrmas, P.E.
有关更多信息,请参见the EPA’s website spill prevention and preparedness regulations, including whether your facility needs a SPCC Plan.