ECA

Why Do I Need SPCC Training?



 

Background
Facilities that store as little at 1,320 gallons aggregate of oil and/or fuel, tallied over all containers 55-gallons capacity and larger, need a Spill Prevention, Control and Countermeasure (SPCC) Plan. There are a few rare cases when such facilities do not need an SPCC Plan, but they must be located so far from a drainage (that leads to what our Federal government calls a Navigable Water) for a spill to plausibly NEVER reach it. Again, this situation is very uncommon.

Regulatory Reality
As required by the Oil Pollution Prevention portion of the Clean Water Act, SPCC Plans help oil/fuel storage facilities stay in compliance with Federal Regulation 40CFR112, aka the SPCC Rule. These Plans 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.

When an SPCC-regulated facility lacks an SPCC Plan, they're subject to large economic risk when their facility has a release, leak and/or spill and the United States Environmental Protection Agency (EPA) and/or their pollution liability insurer gets involved (see
http://e-c-associates.com/SPCC_news.html)!

Why the Annual Training?
As required by 40CFR112.7(f), which is addressed in any well-written SPCC Plan, key oil-handling personnel working at oil/fuel storage facilities must
“At a minimum, train your oil-handling personnel (regarding) … applicable pollution control laws, rules and regulations; general facility operations and the contents of the facility SPCC Plan.”

This 8-hour workshop guides EHS Managers, Operations Supervisors, PEs (who write the Plans) and key oil-handling personnel through the otherwise confusing maze of regulatory text and helps them confirm or improve 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/SP001news.html)!



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


WASHINGTON OFFICE
719 Jadwin Avenue, Richland, WA 99352
Voice: (509) 628-9959

IDAHO OFFICE
372 South Eagle Road, Suite 146, Eagle, ID 83616
Voice: (208) 968-9705

ecabrett@cableone.net
Cell: (208) 501-9984