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: