View the entire chapter in a PDF format. Please use the pdf for printing.

Requirements:
General (5.1)

The requirements for spill prevention, spill response, and spill reporting are listed below.

Prevention

Spill prevention relies on primary and secondary containment, proper work practices and housekeeping. For hazardous materials, these are covered in Chapter 40, "Hazardous Materials". Chapter 17, "Hazardous Waste", describes hazardous waste management. Best management practices for protecting the storm drain system from spills is provided in Chapter 26, "Stormwater". (See Spills: Spill Prevention Guidelines [pdf].)

Secondary Containment

Secondary containment must be provided for hazardous material and waste at SLAC in compliance with all applicable federal, state, and local regulations, and DOE orders. At the discretion of the responsible department and ES&H, secondary containment may also be provided in cases where it is not specifically called for by regulations, but will reduce health, safety, and environmental risks. Specific secondary containment requirements are provided in Chapter 40, "Hazardous Materials".

Planning

The planning requirement for this program is to maintain the SLAC Spill Prevention, Controls, and Countermeasures Plan [pdf], updated every three years.

In addition:

• Chapter 17, "Hazardous Waste", has spill management measures that are part of hazardous waste treatment requirements.
• Chapter 40, "Hazardous Materials", requires a consolidated chemical contingency plan for the site and the provision of easily accessible material safety data sheets (MSDS).
• Chapter 37, "Emergencies", requires buildings that have 10 or more occupants or house mission-critical equipment to maintain a facility emergency plan. This plan includes information on spill response capability for each listed facility.

Responding

Immediate spill response and cleanup are necessary for the protection of site personnel and the environment. However, unmitigated risks must never be taken. For example, spills of unknown materials must be treated as hazardous until confirmed otherwise. In the event of a spill, personnel must follow the plan-do-check process of five core functions of ISEMS by classifying the spill, identifying and mitigating the hazards and risks, then responding appropriately. Personnel must only respond to a spill if handling the spilled material is included in their routine or non-routine job hazard analysis and mitigation (JHAM) documentation and doing so will not result in an exposure risk to human health. If it is not in their JHAM, there is a risk, or they are uncertain of the risks, they must report the spill immediately, and not attempt to contain the spill (see Spills: Spill Response Flow Chart [pdf]).

Emergency Response

Spill response requirements are provided in 29 CFR 1910.120, which defines emergency response as an uncontrolled release of a hazardous substance, with the following two exceptions:

1. Incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area or by maintenance personnel
2. Responses to releases of hazardous substances where there is no potential safety or health hazard.

Spill response requirements provided in 29 CFR 1910.120 also list specific training requirements for emergency response. It does not provide any specific requirements for non-emergency responses as defined above. SLAC does not offer emergency response training, beyond first responder awareness level. When an emergency response is needed, SLAC-contracted emergency responders are used. First responder awareness level training is described in Section 5.3-Training.

Classifying

Spills are divided into three groups, non-emergency, emergency, and radioactive. Requirements for responding vary by group as follows:

1. Non-emergency spills are releases of non-hazardous material, or incidental spills of hazardous material where the spill can be controlled at the time of release and there is no potential safety or health hazard. Response to these spills can be performed by anyone provided they have the proper personal protective equipment (PPE) and any hazards associated with the response are mitigated as indicated in the responders JHAM. For example, response to a controllable spill of hazardous material will only be performed by someone who uses and handles that material on a regular basis and is therefore aware of the hazards and mitigations.
2. Emergency spills are uncontrollable spills of hazardous material or non-hazardous material which poses an imminent threat to the environment. Emergency spills fall into two subclasses, life threatening when the incident has resulted in serious injury or threat of serious injury and non-life threatening. Response to all emergency spills must be performed by outside contractors such as the Palo Alto Fire Department or the SLAC emergency response contractor.
3. Radioactive spills are releases in which the material is known or suspected to be radioactive. These spills may be non-emergency or emergency spills depending on the levels of radioactivity, if they also contain hazardous materials, and/or if they are controllable.

Containment and Cleanup

Responders to a spill must ensure it is, first, properly contained, then, second, properly cleaned up. Appropriate PPE and spill response equipment must be used. These will be determined based on the material spilled, using such means as MSDS. (See Chapter 40, "Hazardous Materials", and Chapter 17, "Hazardous Waste"; additional guidance on equipment can also be found in Spills: Spill Cleanup Equipment Guidelines [pdf].)

Reporting

Internal

All spills must be reported immediately to the Waste Management Group, even those contained and cleaned up by the person(s) who finds them. The Waste Management Group will prepare the spill report and contact the spills program manager.

Subcontractors must report spills immediately to their project manager/university technical representative, who will then contact the Waste Management Group to initiate reporting.

The spills program manager will notify immediately the chief operating officer and/or special assistant to the chief operating officer of all spills.

The spills program manager will record and track all spills and ensure they are entered in the Basic Incident Investigation (BII) Database.

External

Spills that exceed reportable quantities must be reported to external regulatory agencies. The spills program manager will make this determination, based on criteria provided by external agencies and regulations. If it does exceed the limits, the spills program manager will report it through the appropriate means within 24 hours of the spill. If the spill is radioactive, RP will submit notification to the appropriate regulators.

In addition, all externally reportable spills require the spills program manager to prepare a preliminary notification report (PNR) with the help of the Chemical and General Safety (CGS) Department and submit it to the Occurrence Reporting Processing System (ORPS) program manager. The ORPS program manager will determine whether the spill should be reported in ORPS. (See Chapter 28, "Incident Investigation", for details on incident reporting.)

Equipment

Spill response equipment, such as spill kits and PPE, must be readily available in areas where hazardous materials and waste are used or stored. The equipment kept in these areas and all equipment used for spill containment and cleanup must be compatible with the material they will be used on. Decontaminate or dispose of equipment after each use. Spill response equipment should be inventoried regularly and restocked as needed (see Spills: Spill Cleanup Equipment Guidelines [pdf]).

Personnel

Qualifications for spill response depend on spill type:

• Non-emergency spills may be addressed by any personnel if they have the appropriate PPE and spill response equipment, there is no exposure risk to human health, or risk of fire or explosion, and they feel that they can contain, clean, and dispose of the material safely. Personnel responding to non-emergency spills of hazardous materials may only do so if they have received training on proper handling and hazard awareness of hazardous materials (see Chapter 40, "Hazardous Materials", for training requirements of handling hazardous materials). If they are unsure of the hazards and/or do not have the proper training to handle the material, they should contact the Waste Management Group for assistance.
• Emergency spills, as defined by 29 CFR 1910.120, require emergency responders. These are spills of hazardous material that are uncontrollable and/or pose a potential health and safety hazard. Emergency response will be performed by the Palo Alto Fire Department or qualified subcontractors. Cleanup of such spills will be conducted by qualified subcontractors under the Waste Management Group.
• Radioactive spills that are not life-threatening may only be contained and cleaned by personnel who have Radiological Worker II Training (RWTII). All response to spills containing or suspected to contain radioactive material should be coordinated with the Radiation Protection Department.

continue to Requirements, Roles & Responsibilities (5.1.7)