OSC 2007 Evaluation Report

2007 OSC Readiness Training Program Evaluation Report
New and Improved . . . the 2006 SPCC Rule Amendments
Instructors: Patricia Fleming, EPA OEM
Mark Howard, EPA OEM
This course was geared to personnel conducting SPCC inspections or providing outreach related to the
SPCC rule. The SPCC rule (40 Code of Federal Regulations [CFR] Part 112) has been a controversial
regulation, the focus of significant public comment, and the subject of major litigation. EPA has recently
amended the SPCC requirements in several areas; these amendments will dramatically alter both the type
and content of plans developed in accordance with 40 CFR Part 112 and what OSCs will see in the field
during SPCC inspections. By taking this course, participants achieved the following objectives:
• Obtained a brief introduction to the SPCC rule, including a tour of its 30-plus year history,
leading up to the fall 2006 amendments.
• Learned what provisions were modified or added to the SPCC rule in the 2006 final rule
amendments, and why.
• Enhanced understanding of how these changes may affect the regulated community.
• Better understand the complex implications of compliance date extensions on enforcement.
• Learned what outreach materials are being made available for the regulated community, including
a plan template for qualified facilities.
• Obtained a “sneak preview” of the issues that EPA is considering to address in a future SPCC
rule revision.
The course was taught by technical staff from EPA’s OEM who drafted the final rule action. The
instructional methodology for this course included lecture and case scenarios for group analysis. The
target audience for this course was OSCs, SPCC inspectors, and other staff who need to understand the
fall 2006 SPCC rule amendments and how they relate to implementation.
Number of Participants Who
Pre-registered
Participation and Average Grade
Number of Participants Who
Signed Course Roster
Number of Evaluation
Forms Submitted
Average
Grade
29 23 18 4*
* The grade displayed is the average of the grades provided on the evaluation forms, where
1 = Poor, 2 = Fair, 3 = Good, 4 = Very Good, and 5 = Excellent.
C-80 Comments about Individual Training Courses