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 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/)!