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The Team

Rick Smith

Owner

OWNER / SENIOR ENVIRONMENTAL CONSULTANT  Has been in the Safety, Health, and Environmental fields for over 25 years. Certified Steel Tank Inspector.

 rick@midwest-training.com

913-638-3455

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Chris Smith

Environmental Consultant

Christopher Smith is a environmental consultant for MTCS. Certified Steel Tank Inspector.

chris@midwest-training.com

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Steve Spencer

Sales and Marketing

20 plus years in Health, Safety and Environment Management.

steve@midwest-training.com

316-644-6102

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Marcia Hobbs

Environmental Consultant

15+ years experience environmental compliance for electric utility, OSHA certified SHEP (safety, health and environmental professional)
marcia@midwest-training.com

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Midwest Training and Consulting Services

Provide computer technology to provide an efficient and time saving measures related to organizational environmental compliance.
Provide on and off-site development and implementation to organizations with Environmental Compliance Regulatory Programs.
Provide organizations with a business resource in relation to Federal, State and local environmental regulatory requirements.

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Recent Accomplishments

MTCS has become the leading provider of Spill Prevention Countermeasure and Control Plans (SPCC) in the State of Kansas and in the last sixteen years we have completed over 1350 SPCC plans. Our clients have been federal, county and city organizations as well as many private and public companies. 
We have completed SPCC Plans in 33 states, including Kansas, Missouri, Nebraska and Iowa, Arkansas, and Oklahoma. 
Our staff has just completed the Steel Tank Institute (STI) SP-001 tank inspector course so that we can assist our clients with integrity testing requirements of the EPA. We have completed over 930 steel tank inspections. We have started assisting organizations with periodic steel tank inspections using the STI guidelines. 
Stormwater Pollution Prevention Plans (SWPPP) have a recent increase in government compliance attention, and we have recently completed many for ready mix, aggregate, manufacturing, and transportation activities. Between 2020 and 2021 we had an increase of 100 Stormwater Permit/Plans.
Emergency Planning and Community Right to Know (EPCRA) Tier II and Form R. We have completed over 45 Toxic Release Inventories and over 220 Tier II reports for reporting year 2021.
Pictured to the left is Rick Smith owner of MTCS taking tank testing and inspections to a higher level!

Environmental Activites and types of Organizations

As of April 2022


Local City and County Organizations: 78
Airport Operations: 41
Ready Mix and Aggregate Producers: 24 with 127 locations.
Power Plants and Electrical Cooperatives: 57
Petroleum Marketers Convenience Association Members and oil, fuel distributors: 89
Transportation Organizations: 27 with 125 locations
Truck and Equipment Activities: 94
Manufacturing Organizations: 31
Construction Organizations: 10
State Organizations:  6

Clients we served as of 2022: 288 organizations with over 727 locations in 38 states.

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New Service

Tracking System

Online tracking system with your permit documents

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New Service

Tablet

Environmental Inspections-available for you to use.

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New Service

Online training

Divided into monthly topics to ensure compliance

Environmental

Discover Our Expertise

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TIER II

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Storm Water Permits and Plans

Tank Management Systems

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Environmental Site Assessments

Integrity Testing Requiremnts

Our Clients Include:

Some pretty amazing folks

Midwest Training and Consulting Services offers the comprehensive capabilities and deep industry knowledge necessary to help you solve the most complex issues of your organization. Since opening our doors in 2000, we’re proud to say that each year we have a bigger list of returning and new clients.  Scroll down to see our clients,


Want to experience the expertise of Midwest Training and Consulting Services for yourself? Give us a call today and let’s discuss what we can do for you.

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Our Amazing Clients

1 Stop, Parker, Kansas – Environmental – SPCC Plan
4- Rivers Electric COOP Lebo KS SPCC Plan and Tank Inspections 
Allegiant Manufacturing, Kansas City Kansas – Environmental Compliance Assistance
Advanced Aviation, New Century, Kansas – Environmental (SPCC and Stormwater Plans)
Agenda Oil Company-Agenda Kansas, SPCC PLAN
Alhonna Resort MO.-SWP Plan
Allen County, Kansas – Public Works – Environmental (SPCC Plan) and Storm Water Plans
Amelia Earhart Airport-Atchison Kansas-SPCC PLAN
Andale Ready Mix – Wichita, Kansas – Environmental – SPCC Plan (3), TIER II and FORM R
Anderson Aerial – Russell, Kansas – SPCC Plan
Anderson County-Garnett, Kansas-SPCC Plan
A-Plus Trucking – Wichita, Kansas – Environmental – SPCC Plan, TIER II and SWP Plan
Ark Valley Electric COOP Hutchinson KS-SPCC Plan and Tank Inspection 
Arrow Forklift, Lenexa, Kansas – Environmental Services (EPCRA TIER II and FORM R)
Atchison County, Kansas – Public Works – Environmental (SPCC Plan and Five-Year Review)
B and B Trucking-SPCC/SWP Plans
Bayer Construction, Manhattan, Kansas – Integrity Testing of Tanks and 4- SPCC Plans
Beauty View Marina MO.-SWP/SPCC Plan
Beaver Lake Concrete- Rogers Arkansas-SWP PLAN Assistance
Bennett Rogers Pipe, Kansas City, Kansas – Safety and Environmental Assistance
Blish-Mize, Atchison, Kansas – Environmental (SPCC Plan and Five-Year Review)
Blue Stem Electric, Wamego – Community Right to Know (TIER II)
Bourbon County – Fort Scott, Kansas – SPCC Plan
Bluestem Electric COOP Wamego KS-SPCC Plan 
Boetcher Aerial – Beloit, KS – SPCC Plan
Bourbon County – Fort Scott, Ks – 2-SPCC Plans
Bringham Flying Service, Meade, Kansas-SPCC Plan
Brown Atchison ELECTRIC COOP Hiawatha KS-SPCC Plan and Tank Inspections 
Builders Choice – Topeka – TIER II, Stormwater, SPCC Plan and Tank Inspections
Bruder Tank – Sullivan, Ill – Stormwater Permit/Plan
Butler Electric COOP Eldorado KS-SPCC Plan 
Butterfly Aviation, Goodland, Kansas (SPCC Plan, SWP Plan, and Integrity Testing)
Capital City Oil, Topeka, Kansas – Integrity Testing for Four Locations
Capital Concrete, Topeka, Kansas – Stormwater Plan
CENEX – Blackwater – Centerview, Missouri – SPCC Plan
Central States Thermo King (CSTK) – SPCC Plans and environmental assistance (KS, MO, NJ, OK, and PA)
Central Valley AG, Beloit, Kansas – 16 SPCC Plans in locations in Kansas and Nebraska
Central Valley Cooperative, York, Nebraska – 8 location – SPCC Plans and Integrity Testing
Chandler Oil, Chanute (3 locations) and Fredonia, Kansas-SPCC Plans
Cherokee Public Works, Kansas– Environmental-SPCC Plan
Cheyenne County, Kansas Road and Bridge – two SPCC Plans and Integrity Testing
Chuck Henry Sales – Solomon, Kansas – SPCC Plan and Integrity Testing
City of Abilene – Kansas – Airport, Waste Water, Streets – SPCC Plans, SWP Plans, Tank Inspections
City of Ashland, Kansas – Airport and Power Plant – SPCC Plans
City of Atchison, Kansas Airport-SPCC Plan
City of Atwood Airport Kansas- SPCC/SWP PLANS
City of Augusta KS, (2)Power Plants-SPCC Plans 
City of Beloit KS, Power Plant and Airport – SPCC Plan
City of Belleville, Kansas – SPCC Plans for Power Plant and Airport
City of Burlington, Kansas – Power Plant, Environmental SPCC Plan
City of Butler MO, Power Plant and Airport-SPCC Plan and Tank Inspections
City of Chanute, Kansas-SPCC Plan 3 Power Plant and substations, Airport and Streets
City of Colby, Kansas- Airport, Streets and Power Plant – SPCC Plans
City of Council Bluffs, Iowa, - Airport – SPCC Plan, SWP Plan
City of Ellinwood, Kansas – Power Plant – SPCC Plan and Integrity Testing of tank
City of Emporia, Kansas – Streets, Airport – SPCC Plan
City of Erie, Kansas – Power Plants (2) – SPCC Plan and Integrity testing
City of Fort Scott, Kansas – Airport, Streets and Waste Water – SPCC Plan
City of Fredonia, Kansas – Power Plant and Streets – SPCC Plan
City of Garnett, Kansas – Power Plant and Airport – SPCC Plan
City of Girard, Kansas – Power Plant – SPCC Plan
City of Glasco, Kansas – Power Plant and Fuel Station – SPCC Plan
City of Higginsville, Kansas – Power Plant (2) and Airport – SPCC Plan
City of Holton, Kansas – Power Plant – SPCC Plan
City of Horton, Kansas – Power Plant – SPCC Plan
City of Hugoton, Kansas – Power Plant – SPCC Plan
City of Iola, Kansas – Power Plant (2) and Airport and Streets) – SPCC Plan
City of Jamestown, Kansas – Streets – SPCC Plan
City of Jetmore, Kansas – Power Plant – SPCC Plan
City of Kingman, Kansas – Power Plant – Integrity Testing
City of McPherson, Kansas – Power Plant – SPCC Plan
City of Minneapolis, Kansas – Power Plant – SPCC Plan
City of Mulvane, Kansas – Power Plant – SPCC Plan
City of Neodesha, Kansas – Power Plant and Airports – SPCC Plan
City of Nevada, Missouri – Airport – SPCC Plan
City of Oakley, Kansas – Airport – SPCC Plan
City of Oberlin, Kansas – Power Plant and Airport – SPCC Plan
City of Oswatomie, Kansas – Power Plant – SPCC Plan
City of Osborne, Kansas – Power Plant – SPCC Plan
City of Page, Arizona – Power Plant – SPCC Plan
City of Pittsburg, Kansas – Airport – Integrity Testing of Tanks
City of Poplar Bluff, Missouri – Airport – SPCC Plan
City of Pratt, Kansas – Power Plant – SPCC Plan
City of Russell, Kansas – Power Plant (2) – SPCC Plan
City of Sabetha, Kansas – Power Plant, Airport, and Streets, - SPCC Plan
City of Sharon Springs, Kansas – Power Plant – Integrity Testing 
City of Shelbina, Missouri – Power Plant – SPCC Plan
City of St Francis, Kansas – Power Plant and Integrity Testing – SPCC Plan
City of Sterling, Kansas – Power Plants and Integrity Testing – SPCC Plan
City of Stockton, Kansas – Power Plant – SPCC Plan
City of Winterset, Iowa – Airport – SWP Plan
City Wide Products – Ozark and Republic, TIER II, FORM R, SPCC Plan and Stormwater Plans
CK Enterprises, Lees Summit, MO – SPCC Plan and Stormwater Permit/Plan 
Clay Center, Kansas-SPCC Plan Power Plant and 5 Substations
Clay County Public Works, Kansas – SPCC Plan
CMS Electric COOP Meade KS-SPCC Plan 
Coffey County Airport – Environmental (SPCC Plan) and Stormwater Permit/Plan
Comanche County and airport KS-2 SPCC Plans
Concrete Enterprises – Kingman, Kansas – Form R Reporting
Concrete Industries – Garden City, Kansas – TIER II, Form R, SPCC Plan and SWP Program
Concrete Materials – Merriam, Kansas – EPCRA TIER II and FORM R Reporting
Concrete Supply of Topeka -Environmental Assistance – 9 Locations SPCC PLANS, SWP Plans
Copenhaver Aerial-Anthony Kansas-SPCC/ SWP Plans
Cox Machine – Wichita, Kansas – SPCC Plan and SWPP Plans (2 locations) FORM R
Coud County KS, Concordia KS -SPCC Plan 
Clemens Aviation-SPCC Plan
Clymore Trucking – Independence, Missouri – SPCC Plan
Crawford County KS-Shop-   SPCC Plan-2022
Croell Inc.-SPCC/SWP Plans for 10 facilities in Kansas
Crop Productions Services (Nutren)– Westboro, Missouri – SPCC Plan
Crop Services Center– Abilene, Kansas – SPCC Plan in two Locations
CS Carey, Kansas City, Kansas – SPCC Plan
Cutting Edge, Louisburg, Ks – SPCC Plan
D & S Convenience Stop – 2 locations Ellsworth, Kansas-SPCC PLAN and 5 year review
Double Check Company – Environmental (SPCC Plans – 5 clients – KTA, Twin Valley Electric and Tank Inspections Fort Riley, SYSCO)
Eakin Enterprises, Hays, Larned and Great Bend – SPCC Plans for locations
Earp Distribution, Kansas City, Kansas – SPCC PLAN and SWP Plan
Ebert Construction, Wamego, Kansas – SPCC Plan and Integrity Testing
DS & O Electric COOP Solomon KS-SPCC Plan and Tank Inspections 
Dailey AG – Oskaloosa, Kansas – SPCC Plan
DELSCO-Myton, Utah-Two SPCC Plans for two locations
Dieker Oil Company – Cottonwoods Falls, KS – Environmental (SPCC Plan)
Dodge City Concrete – Dodge City and Garden City – Environmental Assistance
Dodge City Waste Water (CH2M), Dodge City, Kansas – Environmental (SPCC Plan and TIER II)
Dodge City, Kansas-Waste Water Plant-SPCC Plan-Tier II
Domains General-Vassar, Kansas-SPCC Plan
Doniphan Electric COOP Troy KS-SPCC Plan 
Ellis County KS– Hays, KS – SPCC Plan and Integrity Testing
Emery Sapp and Sons-Bucyrus, Kansas-SPCC Plan
Emporia KS 3 SWPPP Landfill, Wastewater Plant and Public Works-SPCC Plan for airport, streets, & WWF
EnviroServe – 35 locations in 19 states – SWP and SPCC Plans
Evans Equipment – Concordia, MO, Environmental -SPCC Plan and CAA Permits, and Integrity Testing
Evans Oil – Lawson, MO – SPCC Plan
Farmway Union Cooperative (Hartington, NE) – SPCC Plan and Integrity Testing
Finney County – Garden City, Kansas – Integrity Testing and SPCC Plan
Fleet Fuels, Locations in KCMO, Coffeyville, El Dorado, Howard, Independence, Moline, Opie, Pittsburg-SPCC/SWP Plans and TIER II
Flint Hills Electric COOP Council Grove-SPCC Plan
Foley Equipment – Wichita, Ks – (KCMO and Topeka) – SPCC PLAN and Tank Inspections at 15 Locations
Free State Electric-Topeka and Mclouth, Kansas-SPCC Plan and Tank Inspections
Freeman Holdings-Million Air - Lake St Charles, Louisiana-SPCC Plan and Tank Inspections
Freeman Jet Center-SPCC/SWP Plans
GARMIN INTERNATIONAL – New Century, Kansas – Airport – SPCC PLAN
Geiger Ready-Mix Co Inc-KCKS-FORM R
Genysis Works – Blue Springs, Missouri – SPCC Plans
GFL Environmental-SPCC Plans for 12 in 7 States
Gove County, Kansas-SPCC Plan and Tank Inspections
Graham County – PW – Hill City, Kansas –SPCC Plan and Tank Inspections
Grand Central Station KS- SPCC Plan
Grant County, Kansas-Public Works-SPCC Plan and Integrity Testing
Gray County, Kansas-Public Works-Steel Tank Inspections for Shop and Sand Pit
Great Plains Spraying-Colby, Kansas-SPCC Plan
HAAG & Decker Oil – Environmental (SPCC Plan) and Integrity Testing– 4 locations
Hamilton County, Kansas-SPCC Plan, and Integrity Testing of Tanks
Hamm Quarries – Perry, Kansas – SPCC PLANS (4) – Integrity Testing of Steel Tanks
Hampel Oil KCK-Integrity Testing
Harbor Marina, MO-SWP Plan
Harper County KS-Public Works-SPCC Plan
Harshman Construction-Cedar Point Kansas – SPCC Plan for Rock Quarries (15 locations)
Hartford One Stop, Hartford, Kansas-SPCC Plan and Tank Integrity Testing
Healy Oil – Healy, Kansas – SPCC Plan
Heartland Aviation – SPCC Plan and Integrity Testing of Tanks
Heartland Rural Electric COOP – SPCC Plan, tank Integrity Testing for 6 locations
Hickory Marina, Lowell, Ark – SWP Plan
HIghway 50 Stop-Centerview, Missouri-SPCC Plan
Hirt Farm (DAVLAN) – Environmental (SPCC PLAN)
Hodgeman County-SPCC PLAN and Tank Integrity testing
Horseshoe Marina – Lowell, Ar – SWP Plan
Hoxie Sprayers – Hoxie, KS – TIER II Plan
HP Pelzer, Eudora, Kansas-SPCC/SWP Plans and Annual TIER II and FORM R Report
Hutto Grain – Galena, Kansas – SPCC Plan
Junction Store
Independence Ready Mix – SPCC Plan and Integrity Testing
IPL – (Plastic Enterprises) – Lees Summit, Missouri-SPCC Plan and TIER II Report
Iron Mountain – KCMO – SPCC PLAN AND AIR PERMITTING
Jackson County, Kansas – Road and Bridge – SPCC Plans and Integrity Testing
Jefferson – Leavenworth Electric Co. – Environmental (SPCC Plan) and Integrity Testing
Jefferson County, Kansas – Environmental (SPCC Plans) and integrity testing – 2 locations
JL Houston – Safety and Environmental Program Assistance and SPCC Plan
Johnson County Kansas Public Works, Olathe Kansas-SPCC Plan
Joplin Concrete, Joplin, Missouri – Air Permit, TIER II and Form R Reporting
Kansas Building – Wichita, Kansas – TIER II and FORM R
Kansas Electric Power Cooperative (17 Members) – SPCC Plans for Rurlal Electric Cooperatives
Kansas Jet Center-SPCC/SWP Plans
Kansas Sand and Concrete – Environmental (SPCC Plans and Five-Year Review)
Kansas City Aviation Center (JOCO Executive Airport & Spirit of St Louis) – Environmental and SPCC Plan
Kansas City MO-Water Works and Municipal Services-Steel Tank Inspections
Kansas Turnpike Authority-SPCC Plans for 5 locations
Kaw Valley Aviation, Topeka, Kansas – SPCC Plan and SWP Plan
King Construction, Oskaloosa, Kansas – Environmental Assistance (SPCC Plan)
Kay Concrete, Monett, Kansas – TIER II and Form R Preparation
Knotty Pine Oil Inc-Holton Kansas-SPCC Plan
Kramer Oil, Marysville, Kerkimer, Linn, Washington and Frankfort, Kansas – SPCC Plan and Tank Inspections
Labette County, Altamont, Kansas – SPCC Plan
Lake Perry Marina, Perry, Kansas – Integrity Testing
Lancaster Oil, Lancaster, Kansas – SPCC Plan (including Five Year Review) and Integrity Testing
Langley Recycling – Topeka, Kansas – Integrity Testing
Lawsons Quick Stop-SPCC Plan and Tank Integrity Testing
Leavenworth Asphalt-Leavenworth Kansas-Tank Integrity Testing
Leavenworth County, Kansas – Environmental (SPCC Plan) Public Works and Quarry and Integrity Testing
LeFebrve Trucking, Elk River, MN, Prairie City, IA and Shawnee, Kansas – SWP and SPCC Plans.
Leroy COOP-Leroy and Westphalia, Kansas Integrity Testing of Tanks
Lincoln Center, KS-Power Plant-SPCC Plan
Lincoln County KS – Lincoln, Kansas – SPCC Plan 
Little Blue Valley Sewer District, Independence, Missouri – Safety Assistance and SPCC Plan
Logan County KS R&B, Winona, Kansas – SPCC Plan and Integrity Testing
McAllister Transportation, Marion and West Memphis, Ark – Environmental (SPCC Plan and SWP Plan) and Wellington, Kansas-Steel Tank Inspections and Stormwater Programs
McGraw Fertilizer-Tonganoxie, Kansas-SPCC Plan and Tank Integrity Testing
MC Aviation – Colby, Kansas – SPCC Plan
Meade County Kansas-SPCC Plan
Mears Fertilizer, El Dorado, Kansas-SPCC Plans
Metropolitan Topeka Aviation Administration (MTAA), Topeka, Kansas – Environmental (SPCC Plan)
Miami County, Kansas – Road and Bridge and Airport, Environmental (SPCC Plans) and Integrity Testing
Midwest Concrete Materials Inc-SPCC Plans and FORM R
Mid-South Steel Products, Cape Girardeau, Missouri – Safety Program and Environmental Assistance
Midwest Energy Electric, Hays, KS & 4 POWER PLANTS-SPCC Plans 
Midwest Ready Mix – Hiawatha and Sabetha, TIER II and Form R and SWP Program
Mies and Sons Truck – Colwich and Garden City, TIER II, SWP and SPCC Plans
Million Air – Topeka Airport, Pueblo, Yuma, New Ibera, Moses Lake,  – SPCC Plan and Integrity Testing
Mineral Right-Phillipsburg, Kansas-Steel Tank Inspections
Missouri Western University (State)-SPCC Plan and Tan Inspections
MO’s Stop and Shop – Linn, Kansas – Environmental (SPCC Plan)
Montgomery County, Kansas (Road and Bridge) – SPCC Plan and Five-Year Review
Mission Plastics, Nashville, Arkansas-SPCC/SWP Plans
Missouri Western State University, St Joseph, Missouri – SPCC Plan and Integrity Testing
Monarch Cement of Iowa, Des Moines, Iowa-TIER II Reporting
Monarch Cement, Humbolt, Kansas-SPCC Plan
Moyer Aviation, Ulysses, Kansas – SPCC Plan
MRI Global-Kansas City, Missouri-SPCC Plan
Mueller Construction, Coffeyville, Kansas – SPCC Plan, Integrity Testing, and TIER II Report
Mutton Creek Marina – Stockton Lake, Missouri – SPCC Plan
Myers Farms, Colby, Kansas – SPCC Plan
National Weather Forecast, Wichita, Kansas – Indoor Air Quality
Nebraska Machinery Corporation (including NMC, RAKA, Vancer, CERES) 28 facilities in eight states Testing and Other Environmental Assistance
Nemaha Marshall Electric COOP Axtel KS SPCC Plan 
Neosho County, Kansas – Public Works – SPCC Plan
Ness County KS-Integrity Testing of Tanks
Nevada MO-Airport-Environmental Services
Ninnescah Electric COOP Pratt KS- SPCC Plan
Norfolk Iron and Metal – Norfolk, Nebraska, Emporia, Kansas, Greeley, Colorado and Durant, Iowa – SPCC Plan and Integrity Testing, Stormwater Permit and Plans, and Community Right to Know Reporting
North Star Aviation, Ulysses, Kansas-SPCC Plan and Tank Integrity Testing
North Arkansas Electric – Salem, Kansas – SPCC Plan
Norton County R&B and Airport, Norton, Kansas – SPCC Plan
Norton Fuel Service, Norton, Kansas – SPCC Plan
Novation IQ – Lenexa, Kansas, Environmental Reporting (TIER II and Stormwater Permit and Plan)
One Stop, Parker Kansas-SPCC Plan
O’Riley Oil Company, Hopkin, Missouri – Environmental (SPCC Plan) and Integrity Testing
Orleans Marina – Stockton, Missouri– SPCC Plan
Osage KS-Power Plant-Integrity Testing of tanks
Osborn County, Kansas-SPCC Plan
Ottawa County-SPCC Plan
Ottawa KS-Two SPCC Plans-City Utilities and Power Plant
Pawnee County-Larned Kansas-SPCC Plan
Peterson Manufacturing – Grandview, Missouri and Nashville, Arkansas- Environmental (SPCC Plans)
Pete’s Corporation-Tank Inspections
Penny’s Concrete – Environmental for 27 locations including (15- SPCC Plans), SWPP Plans and EPCRA Reports
Pottawatomie Retail, Holton, Kansas-SPCC Plan and Tank Integrity Testing
Power Flame, Parsons, Kansas – SPCC Plan and Integrity testing and SWP Plan
Prairie Land Electric COOPERATIVE Norton KS SPCC Plan and Tank Inspections 
Pratt County – Pratt, Kansas – SPCC Plan and Integrity Testing
Prairie Land Electric, Norton, Kansas – Integrity Testing SPCC Plan
Ramsey Oil – Hutchinson, Kansas – 5 Locations – SPCC Plans – Kansas and Oklahoma
Rawlins County, Atwood, Kansas – SPCC PLANS (3)
Progress Rail, Atchison, Kansas – Integrity Testing of Steel Tanks
Republic County, Kansas – Highway Dept – SPCC Plan
REVV aviation – Council Bluffs – IA – SWP Plan
Rickets South Plaza – Nevada, MO – SPCC Plan
Riley County Public Works, Kansas-SPCC Plan, TIER I Report and Integrity Test
Rimpull Corporation, Olathe, Kansas – Safety and Environmental Assistance
Roadbuilders Machinery, Kansas City, Kansas – (SPCC PLAN – five locations – KS, MO and NEB) and EPCRA TIER II reports
Robbie Manufacturing, Lenexa, KS – OSHA Programs and Industrial Hygiene (Noise and Air Sampling)
Robson Oil – Abilene, Kansas – SPCC Plan and Integrity Testing
ROM Corporation – Belton, Missouri – Safety and Environmental Assistance
Rooks County Airport and R&B Shop, SPCC Plans
Roots Sprayer – Dighton and Harper, Kansas – SPCC Plans
Rush County-LaCrosse, Kansas-SPCC Plan
Rolling Hills Electric COOP Beloit KS- SPCC Plan 
Russell County KS R&B Shop-Integrity Testing of Tanks
Saline County, KS Highway Dept, Salina, Ks – SPCC Plan and Integrity Testing
Savage Services – Environmental (SPCC Plans in AR, CA-2, CO, IN, KS-2, LA, MD-2, MI, NV-1, PA-3, TX-3, UT-5, WV and Integrity Testing, Stormwater Plans and TIER II Reporting
Schock Transfer – Kansas City, Kansas – SPCC Plan and Five Year Review
Schnoover Oil Company – Mound City, Missouri – Environmental (SPCC Plans)
Scott County Road Dept-SPCC PLAN and Integrity Testing
Scotts Precision AG, Oberlin, Kansas – SPCC Plan
SEK Corporation, Yates Center, Kansas – SPCC Plan
Sherman County, Kansas Public Works, Goodland, Kansas – (SPCC Plans)
Skymark – Kansas City, Kansas and Findlay, Ohio- Environmental Assistance (Air Permit), SPCC Plans for KC and Findlay, Ohio, and Safety Assistance
Southwest Butler Quarry – Augusta, Kansas – SPCC Plan and TIER II
Springfield Ready Mix – Springfield, Missouri – Community Right to Know, TIER II
Spring Hill Oil – Spring Hill, Kansas – SPCC Plan and Integrity Testing
Stafford County, Kansas – Public Works – SPCC and Integrity Testing
Sedgwick County Electic COOP Cheney KS – SPCC Plan 
Sharpe Generating Station Waverly KS Five Year Review and Integrity Testing 
Stop and Go-Popular, Bluff, Missouri-SPCC PLAN
Sumner Cowley COOP Wellington KS– SPCC Plan 
Sunbelt Solomon KS-Tank Inspections
SUTECO – Kansas City, SPCC Plan and SWP Plan
Taney County Airport, Hollister, Missouri-Tank Inspections
TC Capri-Clinton, Missouri-2 Locations-Industrial Hygiene (Noise Survey)
Theis Dozier and Hi Plans Aggregate, Spivey and Arkansas City, Kansas – SPCC Plan
Topeka, Kansas-Metropolitan Airport-MTAA-SPCC Plan and Tank Integrity Testing
Fill Rite Corporation, Lenexa, Kansas-Air Permit, Hazardous Waste/Solid Waste and TIER II
Twin Creek, Inc., Kingston, Missouri (SPCC PLAN and 5-year review and Integrity Testing
Ultra Tech, Kansas City Kansas-SWP Plan and Annual reporting TIER II and FORM R reporting
VERTEX Plastics – Kearney, Missouri – Safety and Environmental Assistance
Victory Electric COOP– Dodge City, Kansas, Environmental Assistance (SPCC Plan and Five-Year Review)
Victory Fuels, Norfolk, Nebraska-SPCC Plan
VP Racing – Manhattan, Kansas – SPCC Plan
Wakeeney Ready Mix-SWP Plan
Wanklyn Oil – Frankfort, Kansas – Integrity Testing and SPCC Plan
Washington County Kansas Public Works – SPCC Plan and Integrity Testing
Waubanesse County Kansas Public Works – SPCC Plan
Washington County Kansas Public Works-SPCC Plan and Tank Inspections
We Mac Manufacturing-Atchison Kansas– Safety and Environmental Assistance (Air Permit, Form R and Tier II, SWPPP and SPCC Plan)
Wes Recycling, Centerville and Prescott – SPCC Plans and Stormwater Plans.
Western Chemical – Olathe, Kansas – Industrial Hygiene and Environmental Assistance
Western Forms, KCMO – Environmental Assistance, SPCC, SWP, Annual Reporting TIER II and Form R
Wichita State University-Tank Integrity testing-SPCC Plan
Wilkerson Crane – Shawnee, Kansas – SPCC Plan
WIESE USA – St Louis – EPCRA TIER II – 28 locations in seven states
Wilson County R&B – SPCC Plan
Winterset Airport – Winterset, IA – SWP Plan
Zollicker Oil – Clinton and Warsaw – SPCC Plans
Z W Tech, Kansas City, Kansas – SPCC Plan and Storm Water Plans

Contact Us

401 S Clairborne, Suite 205, Olathe, KS. 66602

913-712-8077

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Tier II

“Facilities covered by The Emergency Planning and Community Right-to-Know Act (EPCRA) must submit an emergency and hazardous chemical inventory form (Tier II Report) to the LEPC, the SERC and the local fire department annually.” This report is due March 1st of each year. 
The EPA currently lists over 300 Extremely Hazardous Chemicals. If you use, store or manufacture any of the listed chemicals at or above their Threshold Planning Quantity (TPQ), those chemicals must be reported in a Tier II Report. Please note – if a chemical does not meet its TPQ, but you manufacture, use or store over 500 pounds in weight at your facility, it also must be disclosed in a Tier II Report. In addition, ALL other chemicals have a TPQ of 10,000 pounds, and if you use, store or manufacture these chemicals in quantities greater than 10,000 pounds at your facility, they must also be reported. 
If a chemical meets its TPQ, an Emergency Planning Document must also be prepared. 
It is important to note the standard of measurement for these chemicals is pounds, not gallons. Items easily overlooked are Compressed Gases (propane, nitrogen, oxygen) which may weigh over 10 pounds per gallon; Forklift Batteries contain battery acid and approximately 18% of the total weight of a battery, in some cases one battery could reach the 500 pound threshold. 
You may already have the necessary documents by another name. If you have a Spill Prevention Plan certified by a professional engineer it would meet the requirement for over 10,000 pounds (1,320 gallons) of petroleum products. An RCRA Contingency Plan, developed for hazardous waste, may meet the requirement if modified. 
We do an on-site inspection, prepare all necessary cover letters and documentation, including a chemical list and site diagram. If needed, we also prepare an Emergency Planning Document for your facility. 
For the 2015 annual reporting we completed over 125 reports.

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Tank Management Systems

Owners Responsibilities relating to Tank Management.

  • The owner is responsible for compliance with the Steel Tank Institute SP-001, fire codes, ordinances, and other rules and regulations.

  • The owner shall verify that persons working on ASTs understand and address all hazards association with the contents of the ASTs, as well as safe entry and hot work procedures with those ASTs.

  • The owner inspections are responsible for performing the periodic AST inspections and documentation the results.

  • The owner is responsible for assuring that the tank is appropriately designed, constructed, repaired (if necessary) and maintained to operate safety in the intercede service conditions.

  • The owner has the responsibility to address corrective actions identified in inspection reports.

The management program we propose to assist you with is:
First, we categorize your Above Ground Storage Tank to determine what your inspection and full integrity testing requirements must be completed.

The EPA requires an Annual Tank Inspection. Steel Tank Institute which is one of the standards the EPA states should be completed. This would include an initial External Inspection by STI Inspector and document event.

This inspection will include: Documenting the inspection from US EPA and Steel Tank Institute – Annual Inspection Requirements for Above Ground Storage Tanks and Components of the Tank.

We already have an automated tracking system for environmental and tank inspection requirements. We can assist you with the input of your locations and will assist you in suspensing the inspection requirements of your bulk tanks. Tracking will include all tank maintenance, Fire Codes, state and local Ordinances and other rules and regulations.

An initial external inspection and evaluation of the tank program. Includes identifying a baseline integrity of the steel tank. If the tank does not have an Underwriters Laboratory label or engineering drawings, then a baseline must be established. If records of the tank are not available, ultra sound measurements may be taken. If additional inspection such as integrity testing of some tanks, we can do that also. Documentation for each tank will completed.

Initial and Periodic Tank Inspection – 
Initial inspection includes checking for presence of water inside a tank and including the interstice if a double wall AST.

Management of fuel tanks systems.

  • Corrosion Management and evaluation

  • Ensure water management program is conducted.

  • Verify compliance with employee monthly inspections.

  • Verify regulatory inspections of equipment such as overfill protection is completed, tested, and issues are corrected.

  • Vents are proper and working

  • Check electrical wiring, including grounding

  • Settlement issues

  • Inspect and verify operation of ancillary equipment to include:

  • Piping and piping connections

  • Stairways, handrails and platforms

  • Monitoring of correction of deficiencies.

  • Documentation of Water Releases from Containment.

Conduct Annual Employee Training for Above Ground Storage Tanks (how to conduct inspections) and management of SPCC Plans.

We can also provide Quarterly information (provided through email) on up to date Environmental and Tank programs.

We can also assist with evaluation of additional mandatory external inspection requirements for initial installation, episodic (Severe Weather and Extreme Icing), change of product and repairs to tank.

If we can answer any questions, please contact us. We expect most of the assistance after the initial visit, can be by phone, email and other electronic means.

Richard Smith, MTCS, Phone Number is 913-638-3455. Email rick@midwest-training.com, Company Website: Midwest-training.com

Storm Water Permits

General: Facilities with a stormwater discharge associated with industrial activity subject must request authorization for and obtain coverage under an NDPES permit. Coverage may be obtained under this general permit, or by meeting the requirements for permit exemption or exclusion. This program does not relieve a facility with other Clean Water Act requirements relating to direct discharges, wetlands and special aquatic restrictions, and community requirements.

Stormwater Associated with Industrial Activity means the discharge from any conveyance that is used for collecting and conveying stormwater and which is directly related to manufacturing, process or raw materials storage areas at an industrial plant.

If your facility has “no exposure” (all industrial materials and activities are protected by storm resistant shelter to prevent exposure to precipitation, snowmelt, surface runoff or drainage) then a certification that there is “no exposure” must be submitted.

There are 11 categories some of the more common are listed below.

Category (i) Facilities subject to stormwater effluent limitation guidelines, new source performance standards, or toxic pollutant effluent standards under 40 CFR Subchapter N (numerous activities and processes). There are already 57 specific industry requirements relating to water run-off of facilities. Category (ii) Certain specific industries Series 24, 26, 28, 29, 311, 32, 33, 34, 373. Category (iii) Mineral Industries, Category (iv) Hazardous Waste Activities, Category (viii) Transportation Activities. Category (xi) Light Industry activities

The EPA program documents includes material handling equipment (including earth moving).

Obtaining Authorization – Notice of Intent
Submission of a Notice of Intent must be submitted, even if already submitted. There is a change of form that requires certain information be provided. In addition, there is a state fee required at the submission.

For new facilities requiring authorization to discharge stormwater runoff, must submit an NOI at least 60 days prior to commencement of the covered industrial activity.

Stormwater Pollution Prevention (SWP2) plans and Best Management Practices (BMP).
The permittee must develop a stormwater pollution prevention (SWP2) plan that is specific to the industrial activity and site characteristics occurring at the permitted location described in the NOI. The permittee must fully implement and periodically review, and update as necessary, the provisions of their SWP2 plan.

The SWP2 Plan is to be retained on site and made available to State EPA, or MS4 upon request.

The plan requirements are outlined in the EPA/State document. This includes general facility information, description of potential pollutant sources, measures and controls, monitoring and recordkeeping requirements, spill and release requirements and reporting.

Implementation Requirements

• Review facility for versus requirements of the procedure.
• Ensure Notice of Intent (NOI) and Annual review (fees) are submitted.
• Develop documentation a Stormwater (P2) Plan for facility.
• Designate person to administer the Stormwater (P2) plan program.
• Provide local training of site personnel.
• Conduct Inspections required by Site specific Stormwater (P2) Plan
• Maintain inventory of equipment and containment to reduce or eliminate stormwater contamination from facility.
• A log to document a description of incidents and items that need follow-up must be maintained. 
• Visually inspect stormwater quality periodically.

Phase One Environmental Site Assessments

WHO NEEDS An Environmental Site Assessment: Phase I

Owner/Operators that intend to apply liability defenses must complete the Phase I or Due Diligence is completed to satisfy one of the requirements to qualify for the liability defense:

1) Innocent Landowners (Owner/Operator)

2) Contiguous Property Owner

3) Bona Fide Prospectus Purchaser

4) Application for EPA Brownfield's Grants

PURPOSE OF PHASE I

The Phase I uses requirements of ASTM E1527-05 and 40 CFR 312 is required to find:

A. Recognized environmental conditions means presence or likely presence of any hazardous substances and/or petroleum products.

B. All appropriate inquiry for other state, local laws and federal laws.

C. Brownfield’s grants, you must also look for controlled substances that could be at the property.

WHAT WILL YOU GET WITH THE PHASE I

Four Components that must be included:

A. Records Review, historical sources and records from federal, state, and local government records, UST records, and Hazardous Waste handling, treatment, storage, disposal and spill records.

B. Site Reconnaissance, visual inspection of the facility and adjoining property.  Includes geological concerns, general description of property, storage tanks, pools of liquids.

C. Interviews, past and present owners, operators, and occupants of facility.

D. Report

E. If Brownfield’s Grants, then research on history of controlled substances must be reviewed.

F. No bulk sampling of materials, this could be recommended for the Phase II.

WHY YOU MIGHT WANT TO HAVE A PHASE I

This is something you want before your purchase the property. Financing companies will want this before approving the financial agreement.

1. Obtaining a new commercial or industrial property

2. Expanding your current facility by obtaining adjoining property.

3. Expanding your current operations by leasing additional property.

4. Leasing your facility property to another industrial/commercial enterprise.

5. Refinancing your operations budget.

6. A government agency may condemn property for local government buildings.

7. Recovering a property for delinquent obligations (back taxes).

8. Obtaining a Brownfield’s grants for assistance in a hazardous substance clean-up.

ADDITIONAL ITEMS ON PHASE I that may be requested:

            Asbestos                                        Lead in Paint and Drinking Water

            Radon                                            PCB’s

            Wetlands                                        Endangered Species

            Regulatory Compliance status      Mold and other Indoor Air Quality Issues

SPCC's

Midwest Training and Consulting Services (MTCS) started in April 1996 as an independent safety, health and environmental consulting services. WE ARE THE PREMIER PROVIDER OF THE EPA’s SPILL PREVENTION PLANS (SPCC) in the four state areas of Kansas, Missouri, Iowa and Nebraska. We completed over 74 last year and nearly 800 plans in the total.

DO YOU NEED SPCC PLAN? Companies meet the threshold of the SPCC Plan (40 CFR 112.7) requirement (1,320 gallons of oil products (fuels, fluids, and lubricants). This includes all containers 55 gallons or greater – drums, totes, tanks, electrical equipment and equipment reservoirs new or used. Once the threshold is met you will need to have a Spill Prevention Control and Countermeasure Plan. This law has been in place since 1973 and has had many changes since that date. You should complete these documents as soon as possible, so you will know what changes to your facility and operations the Professional Engineer will require meeting the EPA rules.

I recently reviewed of all EPA Inspections of locations where SPCC Plan’s were the reason for the inspection. The following information is based on inspections where no fuel or oil was released. 85% of all SPCC Plans inspected had deficiencies including no SPCC Plans completed with fines assessed. Technical Amendments: Technical changes to your facility operations and bulk storage containers must be approved by a Professional Engineer. You have 6 months to make these amendments to your facility once the change has been made. Every Year: Your management official should review the document for any changes and if technical amendments are noted. A review of your facility, training and recordkeeping should also be checked. Five Year Review: EPA requires a management official to review the SPCC Plan every five years. This has two important requirements bring your SPCC Plan update with changes the EPA has made in past five years and changes to your facility in the past five years.

Other inspections violations include 45% of the locations had deficiencies related to inspections and 50% of the locations had not completed required training. 95% of the locations had not completed the integrity testing of the bulk storage containers. We can assist your organization with our training and inspection workbooks and we can complete the tank inspections for steel – shop built tanks.  For more information about when to update your plan see below!

INTEGRITY TESTING OF ABOVE GROUND STORAGE TANKS (AST)

If you have a SPCC Plan then you know you must complete integrity testing for your tanks. The EPA has spelled this out since the 2002 changes to these regulations. The allowed some grace period to get it completed by November 2011.

If you have above ground storage tanks the professional engineer should have designated a period of time to complete your inspections including the integrity testing of bulk containers larger than a drum. You should make sure your tank has a UL 142 stamped label on the tank. If you do you should be able to have the tank in service for 10 years without integrity testing. If you do not have a UL label or you do not know how long the tank has been in service, you should arrange for this testing immediately. If you know the manufacturer of the tanks you may contact them to verify the date of service or the standard which was used to construct the tank.

The EPA regulation 40 CFR 112.8 states a qualified inspector with either Steel Tank Institute (STI) or American Petroleum Institute (API) complete the inspection. There will be a visual inspection to verify the tank system is complete and one form of nondestructive testing. Since technology exists with the ultrasound device, many companies including ours uses this type of device.

The key to not completing an internal inspection is the tank cannot be in contact with soil. The ultrasound measurement device allows us to do this inspection at a reduced rate.

Some basic questions you should be asking your staff.

  1. Do we have an integrity testing program?

  2. Do we have all inspection and maintenance items in our SPCC Plan.

  3. Do we have any plastic totes that we are reusing in service over 5 years.

  4. Do we have any bulk containers greater than 55 gallons that we have had in service over 10 years need integrity testing by a qualified inspector.

  5. Have we completed all items of concern from maintenance items and inspectors requirements.

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Quarterly updates per groups

Quarterly Updates

Midwest Training and Consulting Services would like to offer you this service for free!  A quarterly update you can follow for your operations!

Environmental Calendar for First Quarter

January

Review Topics for your facility

          Air Permitting Requirements – Review visible Air Emissions for the facility. Air Emissions can be a distortion like a vapor from a solvent or a fuel, visible particulate like abrasive blasting media, overspray or oil colling mist, welding fume.

Is there a formal evaluation of total air emissions calculations to compare state air permitting requirements?

Review of recordkeeping and documentation, monthly air emissions for VOC and HAPs, training and inspections.

Stationary motors such as a generator

Review of Facility for applicable Maximum Achievable Control Technology (MACT) programs.

          MACT 6X annual report must be received by EPA and State Agencies by Jan 31

          MACT 6H – Painter three-year training, good time to review for employees that must be renewed.


February

Review Topics for your facility

          EPCRA – TIER II Reporting:  Applicable to organizations that are required to comply with OSHA.

Emergency Planning Review

Chemical Inventory Review

Safety Data Sheet Inventory

Preparation and Submission of TIER II Report for Extremely Hazardous Substances (there are over 400 substances) and items that are over 10,000 pounds. That were on site one day of the year.

Report must be submitted to Fire Department, County Emergency Management (LEPC) and State Emergency Response Commission (SERC)


March

Review Topics for your facility

          Hazardous Waste (RCRA) Program.  Hazardous waste is either on the lists of F, K, P, U or it has certain characteristics of Ignitability, Corrosive, Reactive or fail the Toxic Characteristics Leaching Properties.

Review your hazardous substances that are wastes.

Review your recordkeeping for shipments (manifests)

Review your weekly and monthly inspections documentation

Ensure employees are obtaining annual training.

Review disposal records and evaluate hazardous waste transporters and disposal facilities

Some states like Kansas require annual reporting to be submitted.

Changes in your category should have a new EPA 8700 notification submitted.

2nd Quarter Environmental Requirements, what you need to know by groups and Counties



The EPA and State Solid/Hazardous Waste Requirements are such that every organization must decide by following certain guidelines about materials that they are disposing of.  The State has specific forms and processes to determine which items are Hazardous Waste, Oils, Universal Waste and Special Waste.  There are also other products that have specific disposal requirements such as FIFRA and PCB materials. 
We can assist your organization with determining what materials are in which category and documenting your solid waste program.
Ready Mix/Asphalt
The EPA requires all companies with certain industry codes and activities to prepare Toxic Release Inventory (TRI or FORM R).  Both Ready Mix and Asphalt operations have materials that must be reported that are as small as 100 pounds and one material is just 10 pounds to reach its threshold.
We can do some simple calculations to let you know if you must do the report and if you require assistance, we can assist you.
This is the quarter that all ready-mix facilities must complete their annual stormwater comprehensive evaluation for forwarding next quarter.  We currently assist 50 organizations in Kansas and Missouri.
If we provide the assistance, we will complete an electronic checklist that will be mailed as well as the state inspectors checklist and the other state forms that must be mailed in.
Airports
This second quarter airports review their Spill Prevention Control and Countermeasure (SPCC) Plan.  Most airports have at least 1,320 gallons of oil products (Fuels, Fluids and Lubricants).  You must have a current SPCC Plan (Prepared and reviewed every five years) that is specific to your location and details your compliance with the Federal Requirements and organization policies.  Those locations that have over 10,000 gallons total oil products including portable containers like refuelers and transports must be signed by a Professional Engineer.
Annual Inspections should include a review of the plan, ensuring all employees that may see a release have had annual training related to spills and the portion of your SPCC Plan that covers releases.
Verify your monthly inspection documentation
Verify your secondary containment discharge records.
Power Plants/Electric
This 2nd Quarter is a great opportunity to review your tank inspection program.  Your SPCC Plan must detail this program including scheduling of the Integrity Testing of the tanks and methods to be used.  If the Tank does not have a UL Label, then it must be inspected immediately to establish a baseline.  If it has a label and is within secondary containment (including double wall tanks) then the general guidelines are:
Every tank must have a periodic inspection by a qualified inspector
Vertical Tanks should have an external inspection within a 10-year service schedule.
Horizontal Tanks (raised) should have an external inspection within a 20-year service schedule.
In addition, annually the tank should be inspected for visual issues such as leaking valves, hoses and to ensure overfill protection is accurate and in working order.  
Fuel Providers
This second quarter you should review your Spill Prevention and Control and Countermeasure (SPCC) Plan.  The basic threshold is at least 1,320 gallons of oil products (Fuels, Fluids and Lubricants).  You must have a current SPCC Plan (Prepared and reviewed every five years) that is specific to your location and details your compliance with the Federal Requirements and organization policies.  Those locations that have over 10,000 gallons total oil products including portable containers like refuelers and transports) must be signed by a Professional Engineer.
Annual Inspections should include a review of the plan, ensuring all employees that may see a release have had annual training related to spills and the portion of your SPCC Plan that covers releases.
Verify your monthly inspection documentation.  Verify your secondary containment discharge records.

When is it time to update your Spill Prevention Control and Countermeasure Plan.

As you are aware there are three categories of SPCC Plans
TIER I – 1,320 total oil capacity up to 10,000 gallons no tanks greater than 5,000 gallons
TIER II – 1,320 total oil capacity up to 10,000 gallons a tank greater than, 5,000 gallons
Professional Engineer – Total oil capacity over 10,000 gallons
In addition, TIER I and II must have Professional Engineer sign off on all exceptions to regulatory requirements. Such as an exception to visual observation of secondary containment releases due to a technology improvement such as an oil shut off device of a pumping system.

The Management Responsible Official is responsible for complying with 40 CFR 112.5.
Pursuant to 112.5(a), the facility must periodically review and evaluate the SPCC Plan for any change in facility design, construction, operation, or maintenance that materially affects the facility’s potential for an oil discharge, including, but not limited to:
•    commissioning of containers.
•    reconstruction, replacement, or installation of piping systems.
•    construction or demolition that might alter secondary containment structures; or,
•    changes of product or service, revisions to standard operation, modification of test/inspection procedures, and use of new or modified industry standards or maintenance procedures.
 
Amendments to the plan made to address changes of this nature are referred to technical amendments and must be certified by a PE. Non-technical amendments can be done, and must be documented in this section, by the facility owner and/or operator. 

Non-technical amendments include the following:
•    Change in the name or contact information, i.e., telephone numbers, of individuals responsible for the implementation of this plan; or,
•    Change in the name or contact information of spill response or cleanup contractors.
 
Facility must make the needed revisions to the plan as soon as possible, but no later than six months after the change occurs. The plan must be implemented as soon as possible following any technical amendment, but no later than six months from the date of the amendment.

Remember this statement is including, but not limited to. My experience with EPA inspections is they will find the changes. In addition, to the changes to plan descriptions, every document in the plan is reviewed with the noted changes to the facility operation and site diagram. Your site diagram will also be cited if the description and the diagram do not match. 
This is important to keep this plan updated and when the technical amendments are made.  
The mandatory five year would only require changes if your operation has implemented more effective prevention and control technology.
The Five-year (40 CFR 112.3 and 112.5) review includes designating a person as responsible for imitating and coordinating revisions to the plan. This is a good time to catch your current plan up with all the technical and non technical changes since the last prepared SPCC Plan.
Notwithstanding compliance with paragraph (a) of this section, complete a review and evaluation of the SPCC Plan at least once every five years from the date your facility becomes subject to this part; five years from the date your last review was required under this part. As a result of this review and evaluation, you must amend your SPCC Plan within six months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge as described in § 112.1(b) from the facility. You must implement any amendment as soon as possible, but not later than six months following preparation of any amendment. You must document your completion of the review and evaluation and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan. The following words will suffice, “I have completed review and evaluation of the SPCC Plan for (name of facility) on (date) and will (will not) amend the Plan as a result.”
NOTE:  During your review for technical changes, compare your SPCC Plan for Portable containers and tanks.  Transports and Refuelers and similar petroleum carrying transportation equipment is commonly missed during the SPCC Plan reviews.  Any portable tanks that have fluids in above the release valve must be considered in your plan.
The Review Process
You should make a complete review of the current plan, especially noting the date of the plan’s preparation.
Review the current regulatory requirements, referenced materials and EPA interpretations and guidelines.
Review your organizations operations and facility with the current plan.
After you note all changes – identify which ones are technical (PE Required) and nontechnical.
Identify the process of updating your SPCC Plan.
Bulk Containers and Inspections. (Latest change is January 2018)
I have also attached a fact sheet on Integrity Testing published by the EPA.
The STI SP-001 indicates all tanks with secondary containment that are 5,000 gallons or above must have a form of integrity testing.  Although the PE is responsible for identifying in the SPCC Plan tank inspection schedules, as general rule.
Vertical Tanks require External Inspections after 10 years of service or since the past (passing) external inspection.
Horizontal Tanks require External Inspections after 20 years of service or since the past (passing) external inspection.
Tanks without a UL Plate or technical design diagrams must have a baseline evaluation regardless of orientation and if secondary containment is provided or not.  This will serve as the baseline and generally five years another inspection is made to determine if the container is losing integrity.

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