ECA

Who Are Oil-handling Personnel?



 

Background
As required by Federal Regulation 40CFR112 (aka the SPCC Rule), SPCC Plans must specify Engineering and Administrative controls and procedures that prevent or minimize oil/fuel releases, leaks and/or spills onto the ground and potentially into a nearby Navigable Water or drainage thereof. One key administrative control is the ANNUAL TRAINING of oil-handling personnel. 40CFR112.7(f) specifically requires that "At a minimum, train your oil-handling personnel ... discharge prevention protocols; applicable pollution control laws, rules and regulations ... and the contents of the facility SPCC Plan."

Who Are Oil-handling Personnel?
Oil-handling personnel are the salt of the Earth! They're the hard-working, behind-the-scenes employees at the leading-edge of a facility's operations that frequently involve the environmentally-sensitve transfer of oils and fuel, the ongoing handling and maintenance of oil / fuel storage containers and tanks, as well as being the initial onsite responders to facility leaks, releases and/or spills.

Improperly trained oil-handling personnel get hurt more often and inadvertently allow unnecessary leaks, releases and/or spills to occur at their facility. In my numerous facility inspections, I've found almost every oil-handling employee to genuinely care about the environmentally-safe operation of their facility, as they often take considerable personal pride in the critical function they have in properly running and maintaining the facility. As said above, oil-handling personnel are indeed the salt of the Earth!

This 8-hour workshop guides key oil-handling personnel through the otherwise confusing maze of regulatory text and helps them better understand their SPCC Plan, so that a future EPA inspection will only be a formality and NOT a bad dream (see http://e-c-associates.com/SPCC_news.html)! As stated in the regulatory citation (see Background), oil-handling personnel must get annual training that addresses the follow areas:

  • Proper operation / maintenance of oil/fuel-transfer equipment and oil/fuel-storage containers and tanks

  • Proper discharge prevention protocols

  • Refresher on applicable pollution control laws, rules and regs like 40CFR112

  • Refresher on the contents of their facility's SPCC Plan

In Closing ...
When the EPA Inspector visits your facility, s/he will probably talk with the facility's oil-handling staff, to determine just how well they understand the facility SPCC Plan. If such interviews reveal improperly trained oil-handling personnel, the EPA could cite the facility with a Training Violation (see http://e-c-associates.com/SPCC_news.html)!

Annual training by facility management or by designated well-trained oil-handling personnel orby third-party experts such as ECA, is critical, because it 1) eliminates regulatory violations and fines, 2) greatly enhances every employee's safety (we all want to go home every night!) and 3) significantly improves facility housekeeping and protects stored oil/fuel inventories!



Workshop Agenda

8:00 am to 8:30 am: REGISTRATION

8:30 am to 10:30 am: History and overview of the SPCC Rule and qualifying criteria that determine whether or not a facility needs an SPCC Plan (Plan). Demonstration of our proprietary algorithm that quickly / accurately makes "exempt / non-exempt" SPCC facility determinations. Often misunderstood Plan requirements such as the 5-year Review and the overall (non EPA) benefits to having and maintaining an effective Plan.

Facility inspection and preparation of your Plan, to meet the requirements of the SPCC Rule. Qualified Facilities and how they can self-certify without a Professional Engineer (PE). The five required PE attestations for Plans that can't self-certify and require preparation by a PE.

Definition of a Facility and a thorough discussion regarding the crucial Facility Diagram. Thorough discussion of sized and general secondary containment (SC). A discussion of environmentally-compliant SC solutions that can save tens of thousands of dollars in construction and operational costs - what IS "sufficiently impervious"?

10:30 am to 10:45 am: BREAK

10:45 am to 12:00 pm: Spill PREVENTION measures, with strong emphasis upon oil/fuel handling and loading - Unloading Area transfers. Environmental equivalence. Spill CONTROLS, spill response COUNTERMEASURES and spill reporting.

12:00 pm to 1:00 pm: LUNCH (on your own)

1:00 pm to 2:15 pm: Category 1, 2 and 3 Tank Integrity Inspections, using the Steel Tank Institute's latest (2018) SP001 Standard. Finding an ethical / qualified tank inpector, who will spare you unnecessary / costly formal inspections. The operational and maintenance advantages of achieving Category 1 status for all tanks. Facility security, with an emphasis upon economically deterring opportunistic vandals and disgruntled employees.

2:15 pm to 2:30 pm: BREAK

2:30 pm to 3:45 pm: An overview of the EPA Inspector's Checklist, a discussion of what to expect from an EPA inspection and the EPA's Top 12 SPCC violations. An informal discussion of weaknesses that attendees discover in their Plans and associated economical solutions and best management practices (BMPs).

3:45 pm to 4:00 pm: BREAK

4:00 pm to 5:00 pm: Q&A / Breakout Session to address loose ends from earlier in the day.

5:00 pm: End of Workshop

5:00 to 7:00 pm: As-needed OPTIONAL loose-ends discussion for interested attendees.

 

 


Environmental Compliance Associates, LLC


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