Spills and leaks, together, are the largest source of industrial stormwater pollution. For this reason, your stormwater pollution prevention plan (SWPPP) must identify control measures that are used at your site to minimize the potential for spills, leaks, and other releases that may come into contact with stormwater.

Among the practices that should be in place at your site are plans for effective response to spills if or when they occur. If your facility has more than 1,320 gallons of oil storage capacity in aboveground tanks you may also be required to develop a Spill Prevention, Control and Countermeasure (SPCC) Plan in accordance with the Environmental Protection Agency’s (EPA) Oil Pollution Prevention regulation found in 40 CFR 112. In addition, state programs may require more stringent plans (e.g., New Jersey requires a DPCC/DCR Plan)

Spill Notification

Employees must be aware of notification procedures in the event of a spill or leak, including when to contact appropriate facility personnel, emergency response agencies, and regulatory agencies. State or local requirements may necessitate reporting of spills or other prohibited discharges to local emergency response, public health, or drinking water supply agencies.

Contact information must be posted in locations that are readily accessible and available to employees. Where a leak, spill, or other release containing a hazardous substance or oil in an amount equal to or in excess of a reportable quantity established under either 40 CFR Part 110, 40 CFR Part 117, or 40 CFR Part 302, occurs during a 24-hour period, you must notify the National Response Center (NRC) at (800) 424-8802 or, in the Washington, DC, metropolitan area, call (202) 267-2675 in accordance with the requirements of 40 CFR Part 110, 40 CFR Part 117, and 40 CFR Part 302 as soon as you have knowledge of the discharge.

What to Include in Your SWPPP

Describe any structural controls or procedures you are putting in place to minimize the potential for leaks, spills, and other releases. At a minimum, your SWPPP should include:

  • The location(s) of spill response plans for significant materials;
  • A schedule for training employees in spill response procedures;
  • Procedures for plainly labeling containers (e.g., used oil, spent solvents, fertilizers and pesticides, etc.) that could be susceptible to spillage or leakage to encourage proper handling and facilitate rapid response if spills or leaks occur;
  • Preventive measures such as barriers between material storage and traffic areas, secondary containment provisions, and procedures for material storage and handling;
  • The individual or position responsible for making sure the spill kits are complete and ready for use;
  • Procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and other releases; and
  • Procedures for notification of appropriate facility personnel, emergency response agencies, and regulatory agencies.

For assistance with your environmental or safety regulatory compliance, contact Ralph Carito at Total Environmental & safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599.