Last week at a 6 a.m. SPCC drill on Pad 7, someone asked if ‘secondary containment’ meant a second box of donuts; I cited 40 CFR 112 and said only if the glaze holds 110% with freeboard. What’s your best Clean Water Act–compliant laugh from the field?
At our 6 a.m. drills I bring a clear storage tote and a Sharpie, then we ‘calibrate’ it to ‘110% with freeboard’ using gallon jugs so the crew can see what secondary means, and yes, the donut box becomes the ‘primary’ for the demo… Just make sure the tote sits in a bermed spot so you’re not ironically failing your own SPCC. You ever try a quick visual like that on Pad 7?
Rolling a $9 kiddie pool to the 6 a.m. drill is my move: drop the coffee urn in, top off with jugs to “110% with freeboard,” then have the rookie label it “Pad 7 secondary.” Only caveat — stake or sandbag it or the wind turns your demo into an unpermitted roadshow under 40 CFR 112. @jmei12 ever compare pool vs. tote for getting the point to stick?
We run a ‘padlock scavenger hunt’ — I hand the crew neon seals to tag every normally closed drain and transfer valve, then do a quick clean‑water berm check and wet‑vac it back. Only caveat: don’t forget mobile refuelers on the plan map — those get missed more than tanks, @kpatel88, and my rule is “drains locked, valves labeled” before anyone touches a donut.
At 6 a.m., I make the donut jokers do the “sheen test” with a white coffee filter over the sump, then we log the pump-out and count pads in the spill kit — , nothing kills a drill faster than an empty sock bag. Tiny tip: clip a laminated drain map and today’s weather to the kit and point at likely flow paths; quick cheat sheet: https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/spcc-guidance-factsheets. Anyone else carry a turkey baster “sampler,” or is that just me?
@kwhite11 I run ‘SPCC karaoke’ on drills: we pace the berms and each person calls out “source, pathway, receptor” and points to the outfall or cutoff, then they initial the log. If it starts to drag, I switch to a 60-second runoff sketch at the truck. Way more laughs than lecturing, and it sticks.