Braun Intertec environmental consultants prepared Spill Prevention, Control, and Countermeasure (SPCC) plans in compliance with Title 40 of the Code of Federal Regulations Part 112 (40 CFR 112) for three facilities owned and operated by an aggregate and construction materials business in North Dakota. One of the facilities was located in a gravel pit and included an aggregate wash plant, an asphalt plant and a ready mix plant. Another facility was a mobile asphalt plant that traveled with construction projects. The third facility was a concrete plant that is occasionally occupied by the mobile asphalt plant
The SPCC plans were written to be complementary to existing SWPPP plans under National Pollutant Discharge Elimination System (NPDES) permit coverage for each respective facility. The existing SWPPP for the facilities included an inventory of potential pollutants, contaminant flow paths, inspections and annual training. The SPCC additions included sections to describe the facilities’ storage tanks and containment systems; spill response and reporting requirements; oil transfer procedures; potential spill volumes and site security.
As both the SPCC and NPDES regulations include requirements for training, runoff control and regular inspections to prevent pollution of adjacent surface water, nesting these requirements together helps protect adjacent resources while reducing the burden of compliance. Our consultants also included resources such as inspection forms, monthly inspection records and annual facility checklists to be completed by the appropriate personnel.
As the mobile plant was frequently relocated to new sites across the state, Braun Intertec environmental consultants generated a standard equipment layout of the plant with material storage and tank list, emergency contacts and contacts for spill reporting outlining responsibilities and guidance for incorporating site-specific conditions into a stand-alone SPCC plan or in conjunction with an associated SWPPP. This minimized the need for revisions to elements of the plan each time they would move within the state. These elements include the type and volume of oils maintained onsite, the nature of their storage containers, the means of secondary containment and spill response.
