Training Agenda


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Brett D. Smith, PE

This 8-hour course includes as-needed group discussions and a Q&A / Breakout Session, to make sure attendees really understand the SPCC Rule and how it impacts their facility. Pertinent and useful handouts such as the EPA Inspector’s Checklist and the required periodic storage Tank Inspection Checklists (that many Plans lack) are provided, as well as a FREE 8 GB flash drive that contains additional useful information regarding the SPCC Rule.

This course addresses MAJOR SPCC Rule changes since 2002, with the latest regulatory information acquired by ECA through direct conversations with the SPCC Rule author at EPA headquarters in Washington D.C. and with the  Supervisor of Inspectors at the EPA Region 10 office in Portland, Oregon.

This course helps get your SPCC Plan compliant with the EPA and with your Pollution Liability Insurance provider. Though we follow the time-driven agenda shown below, we will focus on any “hot button” issues that arise within each time period. If time gets out-of-hand, we’ll table such loose-ends to the end-of-day, as needed.

During the day, there’ll be short BREAKS and refreshments and if you need to use the bathroom or grab a snack / beverage DURING the course, FEEL FREE because a structured, INFORMAL environment works best for everyone!

Post Workshop – Within a week after the workshop, we’ll email your Course Completion Certificate, as well as the  8 Professional Development Hour (PDH) credits for the PE attendees.


8:00 am to 8:30 am


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


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 inspector, 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.  We also address Tank Failure Forensics (TFF) – something that no other course offers.  This brief foray into TFF will make clear the CRITICAL IMPORTANCE of acquiring a properly-fabricated fuel storage tank!

2:15 pm to 2:30 pm


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


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.