Why Do I Need SPCC Training?

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Brett D. Smith, PE

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/)!

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 (regarding) … applicable pollution control laws, rules and regulations; general facility operations and the contents of the facility SPCC Plan.
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/spill-compliance-news/)!