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'ff T 1117 Lone Palm Avenue,Suite 2016 <br /> NAk Modesto,CA 95351 <br /> Telephone 209-579-2221 <br /> Fax 209-579-2225 <br /> ENVIRONMENTAL • GEOTECHNICAL www.atcgroupservices.com <br /> BUILDING SCIENCES • MATERIALS TESTING <br /> KEYS TO SUCCESSFULLY IMPLEMENTING YOUR SPCC PLAN <br /> 1. Review Oil Transfer Procedures Familiarize yourself with the Oil Transfer <br /> Procedure in the appendices. These procedures should be copied and posted wherever <br /> oil is routinely transferred. <br /> 2. Review Spill Response Procedures and Notification Procedures <br /> Familiarize yourself Spill Response and Notification Procedures in the appendices so you know <br /> how to avoid spills, how to respond to spill spills, and who to notify after a spill. <br /> 3. Employee Training <br /> Train your employees how to avoid spills, how to recognize a spill when it occurs, how to respond <br /> to spills, and who to notify after a spill. Incorporate this training with established safety training or <br /> other regular training or call a special meeting to communicate this information. Document this <br /> training with the forms contained in the appendices and file them for easy reference when asked <br /> for by an inspector. Ensure to repeat this training at least once per year. Store records of <br /> completed training in a specific place and keep the records for at least three years. <br /> 4. Conduct the Required Periodic Inspections. Document these Inspections <br /> Make copies of the inspection forms contained in the appendices. There are items that need to <br /> be inspected monthly, quarterly, and annually. Store completed forms in a specific place and <br /> keep the records for at least three years. <br /> 5. When applicable, arrange Formal External Inspections (FEI) to be <br /> performed on ASTs 5,001 gallons or greater at least once every 20 years. <br /> This requirement is explained in more detail in the SPCC Section 13.5. Store completed forms in <br /> a specific place and keep the records for at least three years. <br /> 6. "Over-Report" Spills <br /> As unpractical as it seems, most regulatory agencies in California are requiring reporting of oil <br /> leaks and spills of ANY amount. However, you view this, the practical "between the lines" <br /> interpretation is that a company faces serious consequences for failure to report a spill; big <br /> consequences for not reporting big spills, and not so big for not so big spills. Our advice is that it <br /> is better to over-report than under-report. When in doubt...report! <br />