Compliance Plans

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A Spill Prevention, Control, and Countermeasure (SPCC) Plan is must meet the requirements of Title 40 of the Code of Federal Regulations,  Part 112 (40 CFR 112).

In addition to fulfilling requirements of  40 CFR 112, the SPCC Plan is used as a reference for oil storage  information and testing records, as a tool to communicate practices on  preventing and responding to accidental oil discharges with employees,  as a guide to facility inspections, and as a resource during emergency  response.

The purpose of the SPCC Plan is to describe measures  implemented by an industrial facility, to prevent accidental oil  discharges from occurring and to prepare them to respond in a safe,  effective, and timely manner to mitigate the impacts of an accidental  oil discharge.

SPCC is applicable (40 CFR 112) to Non-transportation related facilities that:

• due  to their location, could reasonably be expected to discharge oil into  or upon the navigable waters of the U.S. or adjoining shorelines; and
• have a total underground storage capacity >42,000 gallons, or
• have a total above ground storage capacity >1,320 gallons, in containers of 55 gallons or greater.

A Stormwater Pollution Prevention Plans (SWPPP) is required for compliance with the National Pollution  Discharge Elimination System (NPDES) General Permit and by State/Federal  Regulations. The Multi Sector Permit covers the industrial activities  exposed to rain water and runoff.

A SWPPP plan contains;

• Annual comprehensive site compliance evaluations
• Signatures on designated worksheets in accordance with the attached signatory requirements
• Quarterly site inspections of the facility
• Quarterly visual monitoring of stormwater discharges
• Analytical monitoring of stormwater discharges
• Maintenance of a rain gauge with corresponding event log on site
• Remedy by SWPPP team of all benchmark exceedances within 90 days of notification

Material Handling Plans (MHPs) are typically required when dealing with construction or redevelopment at a contaminated site. MHPs include policies and procedures to handle, store, move, sample, and dispose of contaminated materials,

More and more construction projects require a site specific Health  and Safety Plan (HASP) regardless of the nature of the work performed.   This includes both government and private construction projects not just  highway projects, building demolitions, excavations and of course where  hazardous waste may be present.

In the past, generally only construction projects that dealt with  known or suspected Hazardous Waste (HAZWOPER) activities require a HASP.  The OSHA Regulation 29 CFR 1926.65 requires a written HASP for such  activities and requires personnel to be trained and qualified under the  HAZWOPER Training Requirements in 29 CFR 1910.120 (either a 24 hr or 40 hr  training course).

Many government entities now require a site-specific HASP regardless  of the activities, for example, the Port Authority of NY and NJ  (PANYNJ). Most projects for the Department of Energy (DOE) and  the U.S. Army Corps of Engineers (USACE) also now require a  site-specific HASP.  Many private organizations also require a HASP to protect them in the event of illness, injury, destruction of property or  if contamination occurs.

Templates for such written programs are available through OSHA.  These can sometimes be difficult to use not because of the software but  due to the complexity of the problems and solutions to activities in  the project. Often the expertise of a PE, a Certified Industrial  Hygienist (CIH) or Certified Safety Professional (CSP) is needed to  prepare a site specific HASP.