FACILITY-SPECIFIC CONTINGENCY PLANNING UNDER THE OIL SPCC REGULATIONS

Abstract

ABSTRACT Under the U.S. Environmental Protection Agency's (EPA) Oil Spill Prevention, Control, and Countermeasures (SPCC) program, facilities must complete an oil spill prevention and control plan. If a facility is unable to complete a control plan, a contingency plan must be completed in accordance with the SPCC regulations. A recent EPA SPCC Program Task Force found these regulations to be inadequate in several areas, including mandatory facility-specific contingency planning. Contingency planning should be conducted in a three-phase approach: completing risk assessment of the specific facility, determining the manner in which identified risks will be managed, and preparing for the execution of contingency plans during a spill emergency. A risk assessment of a facility subject to the SPCC regulations consists of hazard identification, vulnerability and exposure analysis, and event and fault tree analysis. Risk management consists of various components, including the identification of personnel, equipment, emergency procedures, and waste disposal options. The execution of a contingency plan depends upon accessibility of the appropriate equipment, which may include trucks, boats, communication systems, booms, and dispersants. Contingency plans for facilities covered under the SPCC regulations should provide specific information related to notification procedures, spill response, and mitigation.