SPCC & FRP FY18 & 19 Inspection Findings, Common Problems and Innovative Practices, Mark Howard and Troy Swackhammer, EPA Office of Emergency Management (OEM), Oil Branch (Invited) Come see EPA’s Headquarters National Oil Program Implementation Managers present information on SPCC and FRP inspection findings from FY 18 and FY 19, explain/clarify some of the rules’ confusing requirements and provide materials to assist with SPCC and FRP compliance. The Environmental Protection Agency (EPA) conducted an internal quality and consistency review of a sample of Spill Prevention, Control, and Countermeasure (SPCC) Plans and Facility Response Plans (FRPs) required under 40 CFR part 112. The review was to inform the Agency’s continued outreach to provide regulatory clarity and improve SPCC and FRP compliance. EPA surveyed regional offices for data related to SPCC Plans and FRPs reviewed during routine compliance monitoring activities for Fiscal Years 2018 and 2019. Facilities with identified Plan deficiencies were reviewed in order to assess Plan inconsistencies with the applicable rule requirements, and EPA subsequently developed a fact sheet showing the most frequent deficiencies found. This presentation will provide details and examples of the most common SPCC and FRP Plan deficiencies with the aim of clarifying SPCC and FRP requirements and improving compliance at regulated facilities. The presentation is targeted to tank owners and operator, tank inspectors, environmental compliance staff, facility owners and operators, and professionals want to learn more about the SPCC and FRP rule (40 CFR part 112). Mark Howard: Mark Howard is an Environmental Scientist with the Headquarters Office of the United States Environmental Protection Agency’s Office of Emergency Management (OEM), Regulation Implementation Division (RID) in Washington D.C. He is the Spill Prevention Control and Countermeasure (SPCC) National Technical Expert. He also serves as the SPCC Team Leader, national project manager for the Inspector’s Training Program, the Oil Program representative/instructor for the OSC academy, and the lead for the Oil Program Technical Workgroup. He is also the lead technical member of the SPCC rulemaking workgroup and is one of the authors of the SPCC rule (40 CFR part 112). Mr. Howard served as the OEM lead for reviewing the Keystone Pipeline Environmental Impact Statement
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(EIS) and Agency Hydraulic Fracturing Study. Mr. Howard was consulted by the National Academy of Sciences on their diluted bitumen paper. Mr. Howard is an active voting member of the STI SP001 committee. Mark also is the EPA executive Committee representative for the International Oil Spill Conference. EPA has awarded Mr. Howard with a 2018 National Notable Achievement Award for inspector training, a silver medal and several bronze medals. Prior to his Federal service he worked ten years as a State oil/ Haz-Mat responder and AST inspector with the Commonwealth of Virginia’s Department of Environmental Quality. Mr. Howard holds a Master of Science Degree in Biology (Specializing in Environmental Science and Policy) from George Mason University. He holds Virginia Emergency Services certifications as a Hazardous Materials Specialist and Incident Manager. He is most proud of his relationship with his wife Christine and daughter Hope. Troy Swackhammer: Academics: B.S. Chemical Engineering, University of Virginia, 1988 M.S., Civil-Environmental Engineering, Virginia Tech, 1994 Work Experience:• Versar, Inc. and SAIC, Virginia offices, 1988-1992: Environmental consulting engineering work in the areas of insurance and property acquisition audits, UST compliance and site remediation. • Metropolitan Washington Airports Authority, 1992-1996: Environmental engineering work for DCA and IAD, with focus on AST and UST compliance under the Phase 1 Capital Development Program. • U.S. EPA, 1997-present: Member of Oil Branch in Office of Emergency Management working on oil spill prevention and preparedness policies and regulations under 40 CFR 112, which includes the Spill Prevention, Control and Countermeasure (SPCC) and the Facility Response Plan (FRP) regulations. Currently serve as national lead on FRP regulation and policy coordination and member of PREP4C
