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.
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
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 Training?
Part 1 Training - As required by
40CFR112.7(f)(1), 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
applicable pollution control
laws, rules and regulations; general facility
operations and the contents of the facility SPCC
In conversations with the EPA, it's
clear that Part 1 Training is required only once,
though staying current is expected, in accordance
with best industry practices.
Part 2 Training - However,
40CFR112.7(f)(3) does require ANNUAL discharge
prevention briefings, even if no serious spills
(discharges) occurred over the past 12 months!
Option 1 -
A Best Management Practice would be to hire an
"expert trainer" to conduct the Part 1
Training concurrently with the required Part 3
Training, to ensure that your oil-handling
personnel are frequently "refreshed"
regarding your SPCC Plan and the latest
regulatory changes. The "expert
trainer" invariably has useful input
regarding the facility-specific Part 2 Training.
We recommend employing Option 1 at your
facility, to keep embarrassing spill event
information from public discussion and to also
minimize unnecessary travel expenses.
Option 2 -
If you feel that your Ops Manager (or equivalent
staff member) has had sufficient initial training
by us or by way of a convincing (to the EPA)
self-educational effort, then s/he may conduct ONSITE Part 1 Training
concurrently with the required Part 2 Training,
to ensure that your oil-handling personnel are
frequently "refreshed" regarding your
SPCC Plan and the latest regulatory changes.
Option 3 -
Once your oil-handling personnel have been
trained formally by us or informally by a
designated formally / informally-trained staff
member, you may choose to focus strictly upon the
annual Part 2 Training, while making sure that
your oil-handling personnel stay current with the
elements (ie, know the regs and the Plan) of the
Part 1 Training.
Because we offer
less-expensive ONSITE Part 1 Training and
real-time WEBINARS that occur
alongside live training workshops, you might want
to select Option 1, where you get the benefit of
our experience for the Part 1 and Part 2
Training at a manageable additional increase to
your operations budget.
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)!
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