Facility Response Plan or Spill Prevention, Control, & Countermeasure inspections can be announced or unannounced. Either way, it is critical to ensure your facility, personnel, and documentation are prepared and presentable to ensure a seamless and efficient inspection from EPA …with no surprises and no deficiencies.
Here are some tips to prepare for a successful FRP or SPCC inspection:
- Maintain a current copy of the plan on-site. For FRPs, this should include the “stand-alone” Emergency Response Action Plan” maintained in an accessible location.
- Confirm that your plan is certified, current, and accessible; with a designated Qualified Individual (FRP) or Individual Responsible for Spill Prevention (SPCC) who has a command of the plan and of all supporting compliance measures.
- Conduct and evaluate drills and exercises to confirm plan information, emergency contact lists, response equipment inventory, and spill prevention and response measures.
- Inspect and address any secondary containment issues.
- Ensure all truck/rail/barge transfer areas are well-maintained and easy to inspect, with readily available spill response equipment.
- Review your plan for updates, including reviews by operational staff. Ensure all signatures and dates are current and legible.
- For FRPs, ensure your plan is consistent with the National Contingency Plan.
- For Tier II SPCC plans, ensure the document has been certified by a Professional Engineer (PE) within 5 years and that the PE is registered in the same state.
While facility condition and plan quality will be the initial focus, the agency will also conduct a documentation review:
- Organize logs of inspections, training, and exercises/drills for the past three years (SPCC) or five years (FRP).
- Ensure the Qualified Individual (QI) and key employees are fully trained, aware of their responsibilities, and capable of demonstrating how they would respond to a routine spill and a worst-case discharge.
- Verify all emergency response equipment is available, organized, and functional.
- Check that secondary containment for oil storage is adequate, clean, and free of waste or debris; with functional but closed drain valves.
- Be prepared to explain how documented compliance measures have prepared the facility for a worst-case discharge response.
Preparation and EDGE support:
- Conduct self-inspections and drills prior to an EPA inspection to train staff and identify areas of concern.
- Prepare for the possibility of an unannounced inspection where the EPA will test your ability to activate the plan and respond to an actual incident.
- Schedule a visit from EDGE Engineering & Science to simulate an EPA inspection and to ensure facility compliance.
If you have any questions or to schedule a preparatory inspection and documentation review, please contact Evan Connolly, Sr. Project Manager, at erconnolly@edge-es.com for #FurtherInsight.