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/spill-compliance-news/)!
Part 1 Training – As required by 40CFR112.7(f)(1), 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.” In conversations with the EPA, Part 1 Training is NOT required every year, though your staff must stay current with the regulations and best industry practices.
Part 2 Training – However, 40CFR112.7(f)(3) does require ANNUAL discharge prevention briefings, even if no spills occurred during the year.
Option 1 – A Best Management Practice would be to retain an “expert trainer” to conduct the Part 1 Training along with the Part 2 Training, to ensure that oil-handling personnel are “refreshed” regarding the SPCC Plan and the latest regulatory changes. We recommend ONSITE TRAINING, to keep company-specific spill event information from public discussion and to minimize unnecessary travel expenses.
Option 2 – If a staff member has sufficient initial training by us or elsewhere to be credible to the EPA, then s/he may conduct the Part 1 Training along with the Part 2 Training, to ensure that oil-handling personnel are frequently “refreshed” regarding the SPCC Plan and the latest regulatory changes.
Option 3 – You may choose to focus ONLY UPON the annual Part 2 Training, while making sure that your oil-handling personnel stay current with the most current regulations (Part 1 Training). Your Part 1 Training staff can always opt to refresh themselves by retaining an “expert trainer”, on an as-needed basis.
Our 8-hour workshop (Part 1 Training) guides EHS Managers, Operations Supervisors, SPCC Plan-writing PEs and key oil-handling personnel through the confusing maze of regulatory text and helps them better understand and improve their SPCC Plan, so that a future EPA inspection will just be a formality and NOT a bad dream (see http://e-c-associates.com/spill-compliance-news/)!
