And last Tuesday at 2:17 a.m., the 110% berm around two 400-bbl tanks did its job so well the only release was my sigh of relief. Anyone else turn SPCC, NPDES, and Subpart W into late-night stand-up to keep the crew awake while we hit zero-discharge and sustainability commitments?
I keep a laminated SPCC/NPDES cheat sheet by the night-shift coffee pot and run a 90‑second “zero discharge” drill when alarms are quiet — keeps folks sharp and awake. Only catch is it can spook new hands, so I add a quick debrief. You tried rotating the lead so it doesn’t turn into one-person karaoke?
Quick example: we run a 2‑minute “SPCC walkdown” at shift change — one tags a valve, one checks the berm, and one reads the call‑down tree over radio. Keeps folks awake, but we cap it at once a week so it doesn’t drift into alarm fatigue, and the spill kit’s got better timing than my espresso. @MudMath, do you rotate the lead or tie it to specific permit triggers when weather flips?
At “2:17 a.m.” we do a quick “two truths and a lie” on SPCC/NPDES/Subpart W over the radio; loser restocks the spill kit and checks expiry dates so it’s not just bits… , it gets cheesy, so we cap it at 60 seconds and only run it when the board’s clean. Do you rotate who writes the prompts or keep one poor soul on joke duty?