Summary of HAZMAT Contingency Plans, Spill Plans,
and Emergency Response Plans

August 1996 - TI#10092
Introduction
Spill Prevention Control and Counter-measures Plan (SPCC)
Facility Response Plan (FRP)
Hazardous Waste Contingency Plan
Occupational Safety and Health Administration (OSHA) Emergency Plans
OSHA Laboratory Chemical Hygiene Plan
PCB Spill Response Plan
Other Plans
Integrated Contingency or HAZMAT Plan
For More Information
References

Introduction
There are a number of separate and distinct laws which govern the handling, storage, use and manufacture of oil and other hazardous materials (HAZMAT). These laws were promulgated to regulate specific materials or specific types of facilities and form a patchwork of requirements. Some of these laws require contingency or emergency response plans of one form or another, and each of these plans apply to only a limited array of circumstances.

In order for Air Force installations to effectively comply with all applicable laws and implement the appropriate plans when needed, the Air Force issued Air Force Instruction (AFI) 32-4002, Hazardous Material Emergency Planning and Response Compliance, 9 May 1994. AFI 32-4002 provides an outline of an overall plan which meets the requirements of each applicable law. By placing all the individual plans under one larger plan, installation personnel have one reference to consult when responding to any HAZMAT emergency. Additionally, on 6 June 1996, the National Response Team (NRT), chaired by the Environmental Protection Agency (EPA), announced the availability of the NRT's Integrated Contingency Plan Guidance.

This fact sheet provides a summary of the major individual plans likely required for many installations as part of the overall emergency response plan. Refer to the table below for HAZMAT categories common to Air Force installations and corresponding plans required for those categories.

HAZMAT CATEGORYPOTENTIALLY REQUIRED PLAN
OilSpill Prevention, Control, and Countermeasures (SPCC) Plan; Facility Response Plan (FRP)
Hazardous WasteContingency Plan
OSHA Hazardous MaterialEmergency Plans
Laboratory ChemicalsChemical Hygiene Plan
PCBSpill Response Plan

Spill Prevention Control and Countermeasures Plan (SPCC)
Title 40 Code of Federal Regulations (CFR) 112.1

The SPCC Plan is required under the Clean Water Act (CWA) for "facilities that store, transport, or handle oil and could reasonably be expected to discharge oil in harmful quantities to navigable waters." Specifically, an SPCC Plan is required if the facility stores more than 42,000 gallons of oil in underground tanks, or 1,320 gallons of oil in aboveground tanks, or 660 gallons of oil in a single container. For purposes of this regulation, "oil" means oil of any kind or in any form, including, but not limited to petroleum, fuel oil, sludge, oil refuse, and oil mixed with waste other than dredged spoil. SPCC Plans must be updated every three years, or within one year of a change in design, construction, operation, or maintenance, and are kept on file at the facility. An SPCC Plan has the following six required elements described in 40 CFR 112.7:

  • a written description of any spills and corrective actions within the previous 12 months, and plans for prevention of future spills;
  • predictions of direction, flow rate, and quantity of discharge for each major type of failure where reasonable potential for equipment failure exists (e.g., overflow, rupture, leakage);
  • details of appropriate containment or diversionary structures used to prevent oil from reaching navigable waters;
  • if installation of containment or diversionary structures is not practicable, a strong contingency plan and a written commitment to the expeditious control of oil discharges is required;
  • documentation that the facility design, construction, operation, and maintenance conforms with the requirements of 40 CFR 112.7 (e); and
  • certification by a Professional Engineer (PE) and appropriate management approvals.
An SPCC Plan generally does not include detailed emergency response plans for dealing with releases after they occur.

Facility Response Plan (FRP)
40 CFR 112.20
The FRP is required under the Oil Pollution Act (OPA) of 1990 for facilities which transfer oil over water to or from vessels and have a total oil storage capacity greater than or equal to 42,000 gallons, or for facilities that have a total oil storage capacity greater than or equal to one million gallons and if one of the following is true:
  • The facility does not have secondary containment for each aboveground storage area sufficiently large to contain the capacity of the largest above-ground oil storage tank within each storage area plus sufficient freeboard to allow for precipitation;
  • The facility is located at a distance (as calculated using the appropriate formula in Appendix C to this part or a comparable formula) such that a discharge from the facility could cause injury to fish, wildlife, and sensitive environments;
  • The facility is located at a distance (as calculated using the appropriate formula in Appendix C to this part or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake; or
  • The facility has had a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last five years.
FRPs are extensions of SPCC Plans designed to cover detailed response actions in the event of a release. FRPs are submitted to the EPA and to other agencies, such as the U.S. Coast Guard, which may have jurisdiction. An FRP has a number of basic elements described in 40 CFR 112.20 (h) and in Appendix F to 40 CFR 112 which include:
  • an overview of the facility and a description of past activities at the facility;
  • responsibilities of qualified individual coordinating emergency response actions;
  • emergency notification phone list;
  • spill response notification form;
  • response equipment list and location;
  • response equipment testing and deployment information;
  • facility response team description, including training programs;
  • evacuation plan;
  • a description of immediate actions in the event of a discharge;
  • diagrams that include a detailed facility layout, drainage plan, and evacuation diagrams; and
  • a response plan cover sheet.

Hazardous Waste Contingency Plan
40 CFR 262.34 (a) and 264.50 - 56
A hazardous waste contingency plan is required by the Resource Conservation and Recovery Act (RCRA) for facilities that generate, store, treat, or dispose of hazardous waste. Contingency plans may be amendments to SPCC Plans, but must be submitted to police and fire departments, hospitals, and state and local emergency response teams. A Hazardous Waste Contingency Plan has the following five required elements described in 40 CFR 264.52:
  • description of actions to be taken in response to fires, explosions, or any unplanned release of hazardous waste;
  • descriptions of arrangements agreed to by local police and fire departments, hospitals, contractors, and emergency response teams to coordinate emergency response services;
  • an up-to-date list of names, addresses, and telephone numbers of primary and alternate emergency coordinators;
  • a list of emergency and decontamination equipment, location, description, and outline of capabilities; and
  • an evacuation plan for facility personnel, including procedures and routes.

Occupational Safety and Health Administration (OSHA) Emergency Plans
29 CFR 1910.38 (a) and 1910.120 (l)(2)
OSHA provides for two levels of emergency planning for facilities that manufacture, handle, use, or store hazardous materials. Both types of plans must be available to employees under the Hazard Communication Standard of 29 CFR 1910.1200. For facilities which fall under a particular OSHA standard (e.g. asbestos or vinyl chloride), and which will evacuate all employees in the event of an emergency, and will not permit any employees to assist in emergency response, a basic emergency action plan meeting the requirements of the appropriate standard and 29 CFR 1910.38(a) is required.

For facilities that plan to respond to emergencies and assist in the control and mitigation of a release, an Emergency Response Plan is required. This plan is also required for responses to past hazardous materials releases. The Emergency Response plan must contain at a minimum, the following 11 elements (29 CFR 1910.120 (l)(2)):

  • pre-emergency planning;
  • personnel roles, lines of authority, and communication;
  • emergency recognition and prevention;
  • safe distances and places of refuge;
  • site security and control;
  • evacuation routes and procedures;
  • decontamination procedures;
  • emergency medical treatment and first aid;
  • emergency alerting and response procedures;
  • critique of response and follow-up; and
  • personal protective equipment and emergency equipment specifications.

OSHA Laboratory Chemical Hygiene Plan
29 CFR 1910.1450(e)
Laboratory operations are also covered by OSHA standards. OSHA requires each laboratory handling hazardous chemicals to develop and make available a Chemical Hygiene Plan. The Chemical Hygiene Plan is intended to document procedures designed to protect the employees from hazards associated with chemical exposure. The Chemical Hygiene Plan must include a number of elements that cover day to day operations and standard operating procedures. The Chemical Hygiene Plan should also include a plan for responding to spills in the laboratory setting.

PCB Spill Response Plan
40 CFR 761.125
EPA regulations do not specifically require a written plan for response to spills of polychlorinated biphenyls (PCBs). However, the activities required after such a spill are extensive and unique to PCBs. For this reason, a plan for the event of a PCB spill is recommended. The PCB Spill Response Plan should include the following elements:
  • reporting requirements, with names and telephone numbers of appropriate agencies;

  • immediate response procedures;

  • information on containers, labeling, and disposal requirements for cleanup debris;

  • methods for determining spill boundaries;

  • separate discussions of the cleanup requirements for different categories of spills (i.e., low-concentration spills with less than 1 pound of PCBs, or high concentration spills and low-concentration spills with more than 1 pound of PCBs);

  • decontamination procedures for different PCB use areas;

  • required records; and

  • post-cleanup sampling requirements.

Other Plans
In addition to these major plans, some facilities may be required to prepare additional plans. These are briefly described below:
  • Clean Air Act Risk Management Plan for Chemical Accident Prevention (40 CFR 68). The specific requirements of these plans have not yet been promulgated in the regulations.
  • Pesticide fire fighting plans may be required for facilities that store pesticides bearing the "warning" or higher toxicity symbols (40 CFR 165.10 (g), and state/local regulations).
  • The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) provides for the development of a National Contingency Plan and Area Contingency Plans. Facilities may be required to provide information to assist the responsible agencies in preparing and updating the Area Contingency Plans (40 CFR 300).
  • The Emergency Planning and Community Right-to-Know Act (EPCRA) requires Local Emergency Planning Committees (LEPCs) to gather chemical storage and release information from facilities to assist in emergency response planning (40 CFR 302, 355 and 372).
  • Specific types of oil handling and transportation facilities, such as on-shore pipelines require additional emergency response plans under the OPA and other regulations (49 CFR 194).

Integrated Contingency or HAZMAT Plan
A single plan addressing all the different plans will minimize duplication in the preparation and use of emergency response plans saving time and money. The HAZMAT plan should allow coordination with plans that are maintained by local emergency planning committees under EPCRA and Area Committees under the OPA. The following is the Air Force HAZMAT Plan Format as outlined in AFI 32-4002.
  1. Introduction
    1. Emergency Action Plan
    2. Telephone Roster
    3. Mission Statement
    4. Legal Authority and Responsibility for Responding
    5. Abbreviations and Definitions
    6. Assumptions/Environmental Settings
    7. Concept of Operations
      1. Governing Principles
      2. Organizational Roles and Responsibilities
      3. Relationship to Other Plans
    8. Instructions on Plan Use
      1. Purpose
      2. Plan Distribution
    9. Record of Amendments
  2. Hazards Analysis
    1. Hazards Identification
    2. Vulnerability Analysis
    3. Risk Analysis
  3. Capability Assessment
    1. Base Resources
    2. Off-base Resources
  4. Response Functions
    1. Initial Notification of Response Agencies
    2. Direction and Control
    3. Communication (among responders)
    4. Warning Systems and Emergency Public Notification
    5. Public Information/Community Relations
    6. Resource Management (including training)
    7. Medical Support
    8. Environmental Management
    9. Decontamination Procedures
    10. Personal Protection of Citizens
      1. Indoor Protection
      2. Evacuation Procedures
      3. Other Public Protection Strategies
    11. Fire and Rescue Support
    12. Security Police Support
    13. Civil Engineering Support
    14. Other Support Services
  5. Containment and Cleanup
  6. Documentation and Investigative Follow-up
  7. Procedures for Testing and Updating the Plan
  8. References

For More Information
For a copy of AFI 32-4002, or more information about any of the plans discussed in this fact sheet, please contact PRO-ACT at DSN 240-4214 or (800) 233-4356. Examples of comprehensive plans developed by Brooks AFB and others are available for reference in developing installation-specific plans.

References
  1. AFI 32-4002, Hazardous Material Emergency Planning and Response Compliance, 9 May 1994
  2. 29 CFR 1910.38, Occupational Safety and Health Standards, Emergency Action Plans and Fire Prevention Plans
  3. 29 CFR 1910.120, Occupational Safety and Health Standards, Hazardous Waste Operations and Emergency Response
  4. 29 CFR 1910.1450, Occupational Safety and Health Standards, Occupational Exposure to Hazardous Chemicals in the Laboratory
  5. 40 CFR 68, Clean Air Act, EPA Provisions for Chemical Accident Prevention
  6. 40 CFR 112, Oil Pollution Prevention
  7. 40 CFR 165, Pesticide Storage Requirements
  8. 40 CFR 194, Response Plans for Onshore Oil Pipelines
  9. 40 CFR 262, Standards Applicable to Generators of Hazardous Waste
  10. 40 CFR 264, Standards for Owners and Operators of Hazardous Waste Treatment, Storage and Disposal Facilities
  11. 40 CFR 300, Oil and Hazardous Substance Pollution Contingency Plan
  12. 40 CFR 302, Designation, Reportable Quantities, and Notification Requirements for Hazardous Substances Under CERCLA
  13. 40 CFR 355, Emergency Planning and Notification Under CERCLA
  14. 40 CFR 761, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, and Distribution in Commerce and Use Prohibitions
  15. "National Response Team's Integrated Contingency Plan Guidance," Federal Register, Volume 61, Number 109, June 5, 1996
  16. "National Response Team's Integrated Contingency Plan Guidance," Federal Register, Volume 61, Number 119, June 19, 1996