Depending on your facility’s operations, a company can be required to develop and remain in compliance with many different types of Spill Control and Contingency Plans.

Many of these plans identify similar characteristics which include:

• Routine inspections of chemical and waste storage areas
• Emergency response coordinators
• Emergency contacts in the event a spill of a hazardous substance were to occur
• Emergency response procedures
• Employee preparedness and prevention training
• Location and containment of chemical and waste storage areas

Many facilities actually fall under several contingency plan requirements which in the past have required multiple plans. The use of multiple plans has created redundancy and confusion for employees trying to maintain and utilize these plans.

To alleviate this burden, the Environmental Protection Agency (EPA) has created an Integrated Contingency Plan (ICP).

An Integrated Contingency Plan (ICP) is a compilation of contingency plans combined into a single user friendly plan. The ICP is designed to improve coordination between facility response personnel and local, state, and federal emergency response personnel. Overall, the ICP is a more efficient and cost effective means of complying with spill control and contingency planning requirements.

Each individual contingency plan can cost hundreds to thousands of dollars if your facility requires two or more different Contingency Plans. Envirologic can simplify all of your facility’s required contingency plans into an ICP and the savings can be substantial!

To obtain assistance with the State and Federal Contingency Plan requirements, please do not hesitate to contact Wendy Schlett of Envirologic Technologies, Inc. (Phone at 616-342-1100)

The applicability of each Contingency Plan is summarized below.

Spill Prevention, Control and Countermeasure Plans (SPCC)

An SPCC plan is required when:

• The facility is non-transportation related
• Aboveground storage capacity of a single container is in excess of 660 gallons or an aggregate aboveground storage capacity is greater than 1,320 gallons, or the total underground storage capacity is greater than 42,000 gallons
• The facility which, due to their location, could reasonably expect spilled oil to reach the waters of the United States or adjoining shorelines (e.g. storm water drains)

Storm Water Pollution Prevention (SWP³) Plans

Facilities with storm water discharges associated with industrial activity defined by either their Standard Industrial Classification (SIC) or the nature of activity at the site is required to comply with the federal standards. The following sites are regulated by storm water regulations.

• Facilities subject to 40 CFR Subchapter N
• Lumber, Wood, Paper, Chemical, Coal, Petroleum, Leather, Stone, Glass, Primary and Fabricated Metals & Transportation Industries
• Mining, Oil & Gas Operations
• Hazardous Waste TSDFs
• Landfills and Open Dumps
• Recycling Facilities
• Steam Generating Power Facilities
• Transportation Facilities
• Sewage Treatment Plants
• Construction Operations
• Certain Industrial Facilities with Materials Exposed to Storm Water

Pollution Incident Prevention Plans (PIPP background)

A facility is required to have a PIPP if the facility has the capability to store oil or other petroleum products, aboveground or underground storage tanks, in quantities greater than 40,000 gallons total capacity or store or use salt or any polluting material which is listed in the Critical Materials Register.

However, draft Rules have been proposed which would modify the qualifications. The newly proposed qualifications mimic the requirements of an SPCC plan. The MDEQ-SWQD anticipates that these draft rules will become effective beginning in the fourth quarter of 1998.

Hazardous Waste Preparedness and Prevention/Contingency Plans

A facility that has been identified as a:

• Large Quantity Generation
• Small Quantity Generator
• Transporter of Hazardous Wastes
• Transfer Facility
• TSDF

is are required to develop a contingency plan in the event of a:

• fire
• explosion
• release of hazardous waste

Risk Management Plans (RMPs)

Your facility would need an RMP if you store any of the 100+ regulated substances in quantities that meet certain thresholds, examples include:

A Tiered program has been designed which is based on off-site risks in the event of a chemical release. Compliance, which includes development and implementation, is required by June 21, 1999.