In addition to the personnel requirements we reviewed yesterday, Part 109 also defines how facilities that do not have a Facility Response Plan (FRP) in place and that have made the determination that required secondary containment is impracticable, should both have and be prepared to obtain necessary spill response equipment. In general, according to the Part 109 rule, facilities should “assure that full resource capability is known and can be committed during an oil discharge situation…”
Specifically, facilities must:
- Conduct “identification and inventory” of response-related materials, equipment, and supplies available locally or regionally,
- Estimate quantities based on a worst-case scenario (maximum possible oil discharge), and
- Develop “agreements and arrangements” for obtaining these predefined materials, supplies and equipment from suppliers, in the event of an oil discharge.
In its SPCC Guidance for Regional Inspectors, EPA notes that while small discharges may be handled by qualified personnel using on-site equipment materials or supplies such as absorbent socks, and pads etc., the potential for larger spills requiring off-site materials should be addressed differently. For example when creating arrangements with contractors and suppliers, consider how long it will take to get the necessary resources to the site upon a verbal request by the RC. Another recommendation is to have a backup supplier for critical equipment and materials and to meet with all contractors and suppliers at least annually to discuss facility needs, operational changes and new processes that may require additional response resources.
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Another equipment-related requirement of Part 109 is that of communications and control. Part 109.5 requires that facilities predetermine all required communications equipment needs and have that equipment available on-site for use by the response coordinator designated staff on the response team.
This equipment may include:
- Cell phones in all vehicles and held by the RC (with 24/7 availability);
- Two-way portable radios maintained with the response equipment and supplies and with the radio frequency to be used during and incident provided to local first responder; and
- Additional communications equipment available from a prearranged supplier should it be required.
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Again, EPA recommends ongoing training in the use of all oil discharge response process, equipment and supplies to ensure designated personnel have the level of knowledge and skill necessary to address spills appropriately. In addition, although Part 109 does not contain any requirements for recordkeeping, it is always a good policy to keep meticulous records of everything you do to comply with both Part 109 and the SPCC rule. This is especially true of any training that takes place because even though both regulations require training, neither one defines the type or level of training except to infer that it must be adequate for the responsibilities of the personnel. Thus, facilities that undertake a comprehensive, qualified training agenda and keep records that include names, dates, scores, and evaluation results have one less thing to worry about in the event of an oil discharge or an EPA inspection.