Combining SPCC Plan with OPA 90

TRP can either develop your SPCC plan as a stand-alone document, or we can integrate it with your OPA 90 Plan. Since there are portions of both of these plans that contain identical regulatory elements, the SPCC plan can be developed as an appendix to your OPA 90 Plan, thereby eliminating duplication of information.

Response actions and notifications, for example, are more applicable and better described in OPA 90 Plans, and tank lists are more applicable and better described in the SPCC. Regulatory cross-references must be used for both regulatory requirements to document that the regulatory issues are covered in the combined plan.

Related Article: Fire Prevention Plan

OPA 90 Plans

Alternatively, TRP's Web-based system utilizes templates for each plan type with an integrated database for site-specific information. This approach allows for the development of stand-alone OPA 90 plans and SPCC plans without duplication of information, since all site specific information is included in the database as unique elements and is not duplicated. For example, when tank information is updated, and it displayed is both the SPCC Plan and OPA 90 Plan, it is updated in one location in the database and is automatically replaced everywhere it appears in all plans.

The Oil Pollution Act of 1990 (OPA 90) was a direct result of the Exxon Valdez oil spill in Prince William Sound, off the coast of Alaska. As a result of this law, vessels are required to have response plans. In addition, offshore production facilities and pipelines, and onshore oil pipelines, bulk storage terminals and refineries which store 1,000,000 gallons or more of oil, and facilities which store 1,000 gallons or more of oil and transfer oil to barges and ships.

For more information on these and other response plans, or for information on integrating several plans, please contact TRP.

More information:
Spill Prevention Plan
Oil Spill Response Plans
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