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/)!
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/)!