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While NPS certainly does provide many more services other than emergency response and clean-up, the regulations that require response plans typically state that the plan should/must list the contractors that provide these specific services.



Do you have the capacity to store, process, refine, use or consume oil in excess of the following thresholds:

  • 1,320 gallons of total above ground storage capacity in any container (e.g., drums, totes) or tank of 55-gallon capacity or greater, or

  • 42,000 gallon total underground storage capacity.


Remember, these thresholds are based on storage capacity, not the actual amount you have in storage.  Also, the definition of oil is quite broad, and includes (but is not necessarily limited to) petroleum-based oils and greases, petroleum-based fuels (e.g., gasoline, diesel fuel, heating oils, etc.) and  plant or animal-based oils (e.g., vegetable oils).


If you do, chances are you are regulated under the Spill Prevention, Control and Countermeasure or SPCC regulations.  These federal regulations require you to develop, maintain and implement an SPCC Plan that details not only exactly what your facility will do to prevent releases, but also how you will respond. The SPCC regulations specifically require you to provide a Contact List in your Plan with the names and phone numbers of "clean-up contractors with whom you have an agreement for response".


Spill & Slug
Control Plans

Your local water reclamation district that operates the wastewater treatment plant(s) that treats your discharges to the sanitary sewer will have adopted ordinances that regulate these discharges.  These ordinances will vary from district to district but have common elements that are derived from federal regulations. If you are a categorical discharger (based upon the type of operation(s) that you conduct, there may be federal and local discharge limitations that apply to you),  are otherwise classified as a significant industrial user (SIU) based on the total volume of your discharge, or have otherwise been identified by the District as needing one, you will have to generate a Plan to address spills or slugs that could cause interference or damage to the downstream treatment plant or otherwise “pass-through” the treatment plant.  Again, the requirements for such plans will vary from District to District but may contain a specific requirement to identify a spill response contractor in your plan (For example, the Slug Plans required by the Water Reclamation District of Greater Chicago contain such a specific requirement.)

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Contingency Plans

If you generate hazardous waste in any given calendar month in excess of any of the following thresholds, you are classified as a large quantity hazardous waste generator , or LQG:

  • 1,000 kilograms (2,200 pounds) of non-acutely hazardous waste, OR

  • 1 kilogram (2.2 pounds) of acutely hazardous waste, OR

  • 100 kilograms (220 pounds) of residues generated from the cleanup of the spill of an acutely hazardous waste.


If you are a LQG, the hazardous waste regulations (often referred to as  the RCRA regulations, after the federal law that established them, the Resource Conservation and Recovery Act) require you generate a Contingency Plan detailing how you will respond to a release of hazardous waste at your facility. These regulations also require that your Plan describe arrangements agreed to with (among others), any emergency response contractors that will provide response and/or cleanup services for addressing a release of hazardous waste.



Many commercial and industrial facilities are required to obtain an industrial stormwater discharge permit.  Most states have received authorization from the USEPA to administer this permit program.  In addition, regardless of who issues the permit (USEPA or your state), most covered facilities opt for coverage under a “general” permit (as opposed to a site specific permit).  Either way, if your facility is covered, you will have to generate a Stormwater Pollution Prevention Plan or SWPPP. 


While these permits typically do not require you to specifically identify a spill response contractor in the SWPPP, the Plan must describe spill response procedures, and identifying a contractor within the SWPPP that will provide response assistance or services is commonplace.

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