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Spill Prevention, Control, and Countermeasures Plan and Installation Spill Contingency Plan
Section 6 - Personnel Training
6.1 - Training Program [40 CFR 112.7(e)(10)(i)]
Personnel training is provided for all CSSA employees involved in activities that may expose them to hazardous substances or health and safety hazards. The training program includes initial training and site-specific training, including on-the-job training. Personnel that deal with POL/hazardous materials receive training and periodic briefing on the SPCCP and their responsibilities in the event of a release. Selected members of CSSA staff have also received Emergency Response training and Hazard Communication training.
The following is a brief description of different types of personnel training programs in place at CSSA based on the job duties and responsibilities of the worker.
A 40-hour introductory HAZWOPER training is given to all CSSA employees who work or oversee hazardous waste facility operations and to all employees who are involved with the handling of hazardous waste. Continuing training consisting of 8 hours of classroom training has been conducted by the Environmental Management Department of the School of Logistics Science, U.S. Army Logistics Management College. Future training will be conducted by the U.S. Army or by other certified training program(s).
The purpose of the introductory and continuing training program is to educate the employees at all levels who are responsible for hazardous waste handling activities and facilities. The training programs are designed to reduce the potential for occurrence of situations which may threaten human health or the environment and to thoroughly familiarize personnel with their duties and responsibilities. The program will make known to the employees the following:
Safety and emergency response actions and procedures. Procedures delineated in the ISCP are in effect at CSSA and include information on key contact personnel, after hours point of contact, evacuation routes, and location of equipment and absorbents for containment/cleanup of spills.
Rationale why certain tasks must be performed in a prescribed manner.
Hazards of wastes generated, treated, or stored at CSSA.
State, federal, and Army regulations for hazardous waste activities.
Emergency and monitoring equipment (use, inspection, repair, and replacement).
Automatic cut off systems (key parameters).
Communication/alarm systems.
Fire or explosion response.
Procedures for shut down of operations.
Groundwater contamination response.
Response to release of hazardous waste to the environment.
In addition to formal training, on-the-job training is an ongoing process in all operational areas where employees are involved in the management of oil and hazardous substances. This training includes familiarizing personnel with emergency procedures, emergency equipment inspection, location evacuation routes, response to emergencies, and their job duties and responsibilities.
All employees who received initial training also receive annual refresher training as long as they continue to perform hazardous substance related functions. The refresher training will focus on maintaining proficiency, learning new techniques and procedures, and reinforcing safety and quality consciousness. This training also includes any changes or updates in the regulatory requirements. Any critique of incidents that have occurred in the past year that can serve as training examples and other related topics may also be included in refresher training.
Training records are maintained for each employee by the Post Personnel Officer. These records include the name of each employee, the job description of all positions held by the employee, the dates of employment for each position, and a description of the type and amount of training received by each employee.
All personnel who have received and successfully completed the training at CSSA are given a certification of completion by their instructor, head instructor, or trained supervisor. Formal training received by installation employees is annotated on the employee's permanent record. Training records on current personnel are kept on file by the Post Personnel Officer until closure of the facility. Training records on former employees will be maintained for 3 years after the employee last worked at the facility. The records include information such as the dates, type, and amount of introductory and continuing training; training technique; and schedule to be followed by the instructor. After each training session, the training received is annotated on the employee's personnel file.
6.2 - Designated Person for Spill Prevention [40 CFR 112.7(e)(10)(ii)]
The CSSA Commander has appointed the Camp Bullis Fire Department as the designated response team for spills at CSSA. The Camp Bullis Fire Department is under the direction of the Camp Bullis Fire Chief who will report to CSSA management per 40 CFR 112.7 (e)(10)(ii).
Training for the Camp Bullis Fire Department is discussed in the Oil and Hazardous Substances Emergency Contingency Plan, Camp Bullis, Fort Sam Houston, TX, October 1998.
6.3 - Spill Prevention Briefings [40 CFR 112.7(e)(10)(iii)]
As required by 40 CFR 112.7(e)(10)(iii), periodic spill prevention briefings are conducted for all personnel involved in activities that may expose them to oil, hazardous substances or health and safety hazards. Annual spill response exercises are also conducted, as required by AR 200-1, Chapter 3.