The importance of SPCC, FRP and SWPPP Documents
A key part of hurricane preparations involves fortifying structures and systems in the hopes of withstanding the storm’s force. But another dimension is anticipating what must be done if those defenses fail—and in that regard, some of your strongest preparations for hurricanes should already be in The Cloud.
Because if you’re a business owner, it’s essential for you to have thorough, comprehensive plans for dealing with storms and stormwater.
The SPCC and FRP Documents
Government regulations exist to prevent discharge of petroleum products into any waterways, whether directly into shorelines, creeks and wetlands, or indirectly via drainage features such as swales, culverts, or catch basins.
You’re probably already aware that the EPA requires you to have a current Spill Prevention, Control and Countermeasure (SPCC) plan if you:
- are a non-transportation facility;
- have total onsite petroleum storage capacity of 1,320 gallons;
- OR have buried storage capacity of 42,000 gallons or more.
However, it’s important to note that those criteria are based on capacity—whether you’re actually utilizing all of that capacity or not—and this also includes the total capacity of any individual storage containers of 55 gallons or greater. Also keep in mind that the regulations apply to ALL oils & petroleum products, with just a very few exceptions.
Consequently, the SPCC requirements could pertain to operations ranging from light manufacturing and heavy industry, to C-stores and drycleaners.
Those same enterprises would need to develop and maintain a Facility Response Plan (FRP) that lays out in detail the procedures that would be followed when a spill occurs.
The SWPPP Document
Stormwater management comes into play whether your business is pelted by a full-fledged hurricane, a nasty tropical storm, or seasonal rainfall. Your Stormwater Pollution Prevention Plan (SWPPP) requires you to be certain that any stormwater that leaves your property is not carrying pollutants with it.
Part of that effort involves determining not only what contaminants on your site might actually be swept away by stormwater, but also whether there are any materials that could contribute pollutants simply by being rained on.
Professional evaluation can help you prepare situations ranging from minor inconveniences to worst-case scenarios.
Be sure you have an expert who can evaluate your systems, processes & procedures not only for preventing spills and stormwater-based discharges, but also controlling them when they occur—and who can make sure that you’re conducting appropriate training that relates to all these situations.
Many of you reading this may already have basic plans in place, but it’s definitely worth making sure that those documents are suitably comprehensive.
Because the penalties for permit violations might be more devastating than the hurricane itself…