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Environmental Response & Prevention Plans

Environmental Compliance Plans:

Environmental Compliance PlansAn ERTS regulatory specialist can help with the preparing/updating of any emergency response plans or facility specific plans.

It is important to have a plan in place to deal with emergencies because the initial actions taken can be very critical. ERTS can conduct a risk assessment, determine resources and provide you with an Emergency Response Plan. Emergency Response Plans can be written for both specific chemicals traveling on dedicated routes, for facilities, or to fulfill the requirement that certain states have; mandating that the transporter provide a written transportation emergency response plan.

In addition to Emergency Response Plans ERTS can provide Prevention Plans for your facilities. ERTS can work with you via telephone or through site visits to determine what plans are necessary to keep you in regulatory compliance. Although other plans are available, please see additional information to determine if you are in need of an SPCC plan or a SWPP plan.

Spill Prevention Control and Countermeasures (SPCC)

Who is covered by the SPCC Rule?
A facility is covered by the SPCC rule if it has an aggregate aboveground oil storage capacity greater than 1,320 U.S. gallons or a completely buried storage capacity greater than 42,000 U.S. gallons and there is a reasonable expectation of an oil discharge into or upon navigable waters of the U.S. or adjoining shorelines.

What types of oil are covered?
Oil of any type and in any form is covered, including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including synthetic oils and mineral oils.

What kinds of facilities are covered?
A facility that stores, processes, refines uses or consumes oil and is potentially subject to the SPCC rule. Here are some examples of covered facilities and operations:

  • Industrial, commercial, agricultural, or public facilities using or storing oil;
  • Onshore and offshore oil well drilling facilities;
  • Onshore and offshore oil production facilities (including separators and storage facilities);
  • Oil refining or storage facilities;
  • Certain waste treatment facilities;
  • Loading racks, transfer hoses, loading arms, and other equipment;
  • Vehicles (e.g. tank trucks) and railroad cars used to transport oil exclusively within the confines of a facility.

How do I calculate oil storage capacity?
Use the shell capacity of the container (maximum volume) and not the actual amount of product stored in the container (operational volume) to determine whether the SPCC rule applies to you. Count only containers with storage capacity equal to or greater than 55 U.S. gallons. Simply add up the container oil storage capacities and compare your total facility capacity to the SPCC threshold:

  • A total aboveground oil storage capacity greater than 1,320 U.S. gallons; or
  • A completely buried oil storage capacity greater than 42,000 U.S. gallons.

Examples of oil storage containers at a facility that do count toward facility storage capacity:

Bulk storage containers: Aboveground storage tanks (either shop-built or field-erected tanks); certain completely buried tanks; partially buried tanks; tanks in vaults; bunkered tanks; and mobile or portable containers such as drums, totes, non-transportation-related tank trucks, and mobile refuelers.

Oil-filled equipment: May include electrical or operating equipment such as hydraulic systems, lubricating systems (e.g., those for pumps, compressors and other rotating equipment, including pump jack lubrication systems), gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, and electrical switches; or manufacturing equipment such as process vessels, or other equipment used in the alteration, processing or refining of crude oil and other non-petroleum oils, including animal fats and vegetable oils.

Storm Water Pollution Prevention Plan (SWPPP)

Who is covered by the SWPPP (Storm Water Pollution Prevention Plan) Rule?
Activities, such as material handling and storage, equipment maintenance and cleaning, industrial processing or other operations that occur at industrial facilities are often exposed to stormwater. The runoff from these areas may discharge pollutants directly into nearby waterbodies or indirectly via storm sewer systems, thereby degrading water quality.

In 1990, the U.S. Environmental Protection Agency (EPA) developed permitting regulations under the National Pollutant Discharge Elimination System (NPDES) to control stormwater discharges associated with eleven categories of industrial activity.

The Multi-Sector General Permit (MSGP) for Stormwater discharges associated with industrial activity regulates discharges of stormwater from 29 different industrial sectors. The sectors are based on the definition of "stormwater discharge associated with industrial activity" found at 40 CFR 122.26 (b)(14)(i)-(ix), (xi). Most sectors are based on a facility’s Standard Industrial Classification (SIC) code.

What kinds of facilities are covered?

  • Motor freight transportation facilities (SIC 4212-4231)
  • Passenger transportation facilities (SIC 4111-4173)
  • Petroleum bulk oil stations and terminals (SIC 5171)
  • Rail transportation facilities (SIC 4011, 4013)

What kinds of activities are covered?

  • Vehicle and equipment fluid changes
  • Mechanical repairs
  • Parts cleaning
  • Painting and/or fueling
  • Storage of vehicles and equipment waiting for repair or maintenance
  • Storage of the related materials and waste materials, such as oil, fuel, batteries, tires, or oil filters

What does an industrial stormwater permit require?
Common requirements for coverage under an industrial stormwater permit include development of a written stormwater pollution prevention plan (SWPPP), implementation of control measures, and submittal of a request for permit coverage, usually referred to as the Notice of Intent or NOI. The SWPPP is a written assessment of potential sources of pollutants in stormwater runoff and control measures that will be implemented at your facility to minimize the discharge of these pollutants in runoff from the site. These control measures include site-specific best management practices (BMPs), maintenance plans, inspections, employee training, and reporting. The procedures detailed in the SWPPP must be implemented by the facility and updated as necessary, with a copy of the SWPPP kept on-site. The industrial stormwater permit also requires collection of visual, analytical, and/or compliance monitoring data to determine the effectiveness of implemented BMPs

Please contact us to discuss any of the above plans in more detail, assistance determining if a plan is necessary, or a proposal for your needs.


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