By Joe Lorenz and George Biemel, P.E.
It is often said you should plan for the worst and hope for the best. That’s especially true when it comes to protecting your operation from a costly cleanup or an EPA violation. In fact, keeping an engineer and a qualified environmental contractor involved from the beginning is an important first step in creating your Spill Prevention, Control and Countermeasure Plan.
Your professional engineer
It’s no secret that engineers like to build things and that’s why they play a key role in building an efficient, thorough and comprehensive plan. Partnering with your professional engineer can ensure the proper systems and procedures are in place to limit your company’s overall liability and risk of sustaining hazardous and costly mishaps.
As many are already aware the EPA requires your SPCC Plan to be certified by a licensed professional engineer, but this is more than just a formal sign-off. When a P.E. grants your certification, he or she is specifying that five conditions have been met, stating that:
- He or she is familiar with the requirements of 40 CFR Part 112.
- He or she (or the P.E.’s agent) has visited and examined the facility.
- The plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards and the requirements of 40 CFR Part 112.
- Procedures for required inspections and testing have been established.
- The plan is adequate for the facility.
It sounds simple enough, but the challenge lies in getting to the point of certification. Engineering firm Burgess & Niple has worked with a variety of companies at various stages of the compliance process and many of them could have benefited from engineering advice earlier in the planning stage.
One example is a manufacturer based in the Midwest. The hydraulic reservoir on facility’s trash-compacting system blew a hose, leaking a significant amount of fluid into its storm-water system and into a ditch.
In this case, the engineer and environmental contractor, PRO-TERRA Environmental Contracting, acted after the incident. PRO-TERRA responded to the spill and Burgess & Niple designed a measure to prevent a future occurrence or at least limit the severity of a future incident. The course of action involved designing an oil-water separator to be installed in the drainage system. The P.E., the environmental contractor and the company all worked together to make sure the incident didn’t happen again, and even if it did, to make sure the proper measures were in place to limit the scope of damage and the cost of containing and cleaning up afterwards.
Best management practices
When it comes to protecting your operation and the environment from a spill, your operation should create and follow the path of best management practices. Your engineer can help show you the way.
BMPs are defined as structural, nonstructural and managerial methods that are recognized to be the most effective means to reduce surface water and groundwater contamination while still allowing the productive use of resources.
Your engineer can help you establish BMPs, but again the key is to have the measures in place before you need them.
A common BMP was put in place by another Midwestern manufacturer, which operated a large aboveground fuel oil container on its property. A substantial pipeline connected the tank to the main plant, which was located about a quarter-mile away. Planning for the worst – and working to achieve the best – the company proactively created a BMP to protect any accidental leakage from escaping the property via storm-water runoff. Since the pipeline crossed a drainage ditch, the company worked with Burgess & Niple and PRO-TERRA to build a storm-water control structure to capture any potential releases.
In this case, the system’s valve remains closed and run-off water is contained until it can be visually inspected. An operator checks the water for an oily sheen. If the water is clean, it is discharged; if an accidental oil release is detected, the company calls the spill response contractor.
Aside from the obvious designing of prevention measures, the engineer’s most important role with the company is knowing the regulations that apply to each unique circumstance and staying up-to-date with the regulations.
One of the most recent changes in SPCC rules includes integrity-testing requirements for aboveground containers. The testing is now directed to take place on a regularly scheduled basis and to be combined with visual inspection and an additional testing technique. Your contracted P.E. will determine the appropriate test and testing intervals as part of your SPCC plan.
|Required elements of an SPCC plan
The EPA’s Oil Pollution Prevention Regulation requires that your SPCC Plan be prepared in accordance with good engineering practices and be approved by a person with the authority to commit the resources necessary to implement the SPCC plan. The SPCC plan should clearly address the following three areas:
• Operating procedures that prevent oil spills
• Control measures installed to prevent a spill from reaching navigable waters
• Countermeasures to contain, clean up and mitigate the effects of an oil spill that reaches navigable waters.
Each SPCC plan must be unique to the facility. Development of a unique SPCC plan requires detailed knowledge of the facility and the potential effects of any oil spill. Each SPCC plan, while unique to the facility it covers, must include certain standard elements to ensure compliance with the regulations. These elements include:
• A description of the physical layout and a facility diagram.
• Contact list and phone numbers for the facility-response coordinator, National Response Center, cleanup contractors, and all appropriate federal, state and local agencies who must be contacted in case of a discharge.
• A prediction of the direction, rate of flow and total quantity of oil that could be discharged where experience indicates a potential for equipment failure.
• A description of containment and/or diversionary structures or equipment to prevent discharged oil from reaching navigable waters. (For on-shore facilities, one of the following must be used at a minimum: dikes, berms or retaining walls; curbing; culverting, gutters or other drainage systems; weirs, booms or other barriers; spill-diversion ponds; retention ponds; sorbent materials.)
• Where appropriate, a demonstration that containment and/or diversionary structures or equipment are not practical; periodic integrity and leak testing of bulk containers and associated valves and piping; oil -pill contingency plan; and a written commitment of manpower, equipment and materials to quickly control and remove spilled oil.
• A complete discussion of the spill prevention and control measures applicable to the facility and/or its operations.
• The SPCC Plan must include a demonstration of management’s approval and must be certified by a licensed professional engineer.
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Your environmental contractor
Specialization is key in any industry and that is especially true in environmental contracting and spill response. Ideally, your contractor should offer comprehensive service, from construction and installation capabilities to emergency spill response, cleanup and remediation services. The contractor should also serve as a valuable consultant for all environmental issues related to your operation.
Establishing a partnership with a qualified contractor as part of your SPCC plan allows your operation to take full advantage of the contractor’s knowledge and experience before an accident takes place.
Since government regulations change frequently and are often very complex, a qualified contractor will stay up-to-date on all current EPA rules and compliance issues. The environmental contractor maintains communication with your P.E. to make recommendations and ensure your facility meets all requirements.
If your SPCC plan determines a need for preventive measures or designing/building a BMP, your environmental contractor will make sure the equipment and procedures are put in place correctly and according to regulation.
A Columbus, Ohio-based manufacturer asked PRO-TERRA Environmental Contracting to assist it with testing its emergency response plan. They constructed a spill-control drill involving the plant’s 85 employees, PRO-TERRA’s emergency response team, the Columbus Fire Department and the fire department’s HAZMAT team.
The company, which stored a number of flammable and toxic chemicals, already had a comprehensive SPCC plan in place, but chose to put it to the test and simulate a real disaster.
The drill began with a simulated accident that forced the employees to evacuate the facility. The company’s in-house response team and PRO-TERRA’s emergency response unit donned protective equipment and rescued an “injured” employee. The fire department then arrived to take over incident command. Together, the fire department, the company’s team and PRO-TERRA’s responders made sure the building was safe. They suited up and took air measurements inside the building before allowing workers to re-enter.
The drill was a valuable tool for helping plant managers determine how their internal responders would coordinate spill control with an outside contractor and the fire department. It was also helpful in establishing working relationships and enhancing communication with the external teams.
In conjunction with the drill, the company gave tours to about 60 firefighters who would be the first responders to a blaze at the plant. The tours familiarized firefighters with the plant’s layout and fire-suppression systems.
As the facility in the above example learned, another big advantage of partnering with a spill response contractor is that the company works as an extension of your in-house spill response team. When a spill takes place, the in-house team can respond to the incident right away, while the spill response contractor is en route. When the contractor arrives, the in-house team can return to other assignments. Also, since an outside spill-response contractor is responsible for maintaining appropriate equipment, tools and materials to address larger spills, companies can keep the response equipment used by the in-house team to an efficient minimum.
Closing the loop
Overall, the arrangement is a three-sided relationship created by your company, your environmental contractor and your professional engineer, and the focus should be on your SPCC plan. Remember, when you work with your P.E. in the planning process, you receive important recommendations in time to get a contractor into your facility to construct appropriate containment.
You should have an established contract with an environmental contractor in place before you have an incident. This agreement ensures that a qualified responder is on standby if or when you need them. Bringing your contractor in during the planning stage ensures the company is aware of all potential risks and the various nuances of your operation, saving time and expense in the event they have to respond to an emergency.
Finally, facilities may want to follow the lead of a large auto-parts manufacturer based near Columbus, Ohio. Each year, the company invites its P.E., its environmental contractor, local police, fire and emergency responders, as well as area medical staff, and holds a group walk-through of all appropriate facility operations.
The thought behind this practice, of course, is to help responders become familiar with the facility before an accident and respond more efficiently if, or when, an emergency arises. l FON
Joe Lorenz is president of PRO-TERRA Environmental Contracting. The Columbus, Ohio-based company develops practical, long-lasting solutions to environmental concerns. Its specialties include the cleanup and disposal of hazardous and non-hazardous wastes; landfill containment, capping and expansion; brownfield site remediation; and 24-hour emergency response to chemical and petroleum spills. PRO-TERRA also works closely with engineering firms and regulatory agencies in creating construction plans. For more information, call 8-PR0TERRA-4 or visit www.proterra-ec.com.