Free EPA SPCC & FRP Course

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 (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

NISTM CO-LOCATED EVENT: EPA SPCC Short Course | April 12, 2022 | 8:00am – 12:00pm

8:00am – 12:00pm

The purpose of the Spill Prevention, Control, and Countermeasure (SPCC) rule is to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines. This rule is part of the U.S. Environmental Protection Agency’s oil spill prevention program and was published in 1974, under the authority of Section 311(j)(1)(C) of the Federal Water Pollution Control Act (Clean Water Act). The rule may be found at Title 40, Code of Federal Regulations, Part 112.

A facility is covered by the SPCC rule if it has an aggregate aboveground oil storage capacity greater than 1,320 U.S. gallons or a completely buried storage capacity greater than 42,000 U.S. gallons and there is a reasonable expectation of an oil discharge into or upon navigable waters of the U.S. or adjoining shorelines.

12:00pm – 1:00pm

PLANNED IN PERSON: Spill Prevention Control and Countermeasure (SPCC) Overview and review of the Guidance Document for Regional Inspectors Mark Howard, U.S. EPA, Office of Emergency Management (invited)

The short course is available for all SPCC stakeholders. This short course will provide an overview both the rule and the SPCC Guidance for Regional Inspectors. The session will be approximately four hours long, including time to address questions. This short course will describe the requirements for SPCC facility owner/operators and certifying professional engineers. The course will include an overview of the rule, the elements from the revised inspector guidance document and implementation issues encountered since the last course. This overview will include but is not limited to:

• Applicability • Jurisdiction • General plan elements • Oil Filled Equipment (OFE) • Testing requirements • Qualified facilities • Specific requirements for bulk facilities • New for 2022: Report out on SPCC FY 18/19 inspection findings. An abbreviated version of the full conference presentation on an EPA analysis on inspection finds will be presented. This will provide attendees with feedback from actual SPCC inspections on common violations and best practices.

The intended audience for this short course is stakeholders in the SPCC regulated community, which include, but are not limited to, Professional Engineers (PE), consultants, insurance professionals, and facility owners who maintain SPCC Plans or will be updating SPCC Plans. This presentation is similar to the presentation provided to EPA. You do not need a background in SPCC to attend.

Lunch Break

NISTM CO-LOCATED EVENT: FRP Short Course | April 12, 2022 | 1:00pm to 5:00pm

1:00pm – 5:00pm

In 1994, EPA finalized the Facility Response Plan regulation at 40 CFR Part 112.20 and 112.21. Promulgated under the authority of the Oil Pollution Act of 1990, the regulation requires certain facilities that pose the risk of substantial harm to the environment to prepare plans to respond to a worst-case discharge of oil. FRP-regulated facilities must prepare and submit a plan to their EPA Regional Administrator. EPA reviews and approves FRPs for certain facilities that have the potential to cause significant and substantial harm. There are about 3,800 FRP plan holders in the U.S.

PLANNED IN PERSON: Plan Requirements for Facilities Covered by EPA’s Facility Response Plan (FRP) Regulation Troy Swackhammer, U.S. EPA, Office of Emergency Management (invited)

This presentation describes the requirements and expectations for the FRP plan holders. This four-hour short course will cover:

This four hour short course will cover:

• Introduction and purpose of the FRP regulation and discussion about FRP applicability • Plan requirements under §112.20, Appendices E and F, and the PREP guidelines revisions, particularly for inland plan holders • Steps in implementing an FRP and preparing for an FRP inspection and a government initiated unannounced exercise (GIUE) • Common problems observed and recommendations for improvement of plans and exercises • New for 2022: Discuss new proposed CWA Hazardous Substances (HS) WCD Planning Regulation and existing requirements in the FRP rule related to CWA HS.