Facilities in certain manufacturing, mining, utilities and other sectors who have more than ten full time employees, and that manufacture greater than 25,000 pounds of a TRI-listed chemical or otherwise use greater than 10,000 pounds of a listed chemical in a given year are required to provide the EPA with an accounting of how those chemicals have been managed by July 1 of each year. [Thresholds are lower for Persistent, Bioaccumulative, Toxic chemicals (PBTs.]

TRI reporting is a requirement under Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) of 1986, and the Pollution Prevention Act (PPA) of 1990. A goal of TRI reporting is to ensure that citizens and communities have the information that they need about the chemicals being used, stored, managed and treated in their communities so that they can make informed decisions about preparedness and emergency response needs.

The TRI database currently contains information on over 650 chemicals that are used or managed by more than 23,000 industries. In addition to information about the chemicals themselves, information on the recycling, energy recovery or disposal of those chemicals is also available.

For more information on TRI reporting, or for help with filing, visit http://www.epa.gov/tri/index.htm

For facilities that ship or receive large shipments of oil or oil products, part of complying with SPCC regulations (40 CFR 112) is the requirement to be prepared for spills during bulk loading and off-loading and to have a Facility Response Plan (FRP).

Drainblocker® Stormwater Drain Covers are a simple tool that can be a form of active containment for Facility Response Plans, and used as an everyday good engineering practice for oil and fuel containment.

Certain facilities with large quantities of oil are required to have a Facility Response Plan as part of their SPCC Plan.    A Facility Response Plan is a document that details how a facility will respond to oil discharges.

If employees are trained to respond to spills as part of this Plan, a Drainblocker® Drain Cover is something that they can used as a fast response tool.   They are a form of active containment can be quickly deployed to cover and seal drains to prevent oil or fuels from entering the drain – which sometimes means the difference between “just a spill” and a reportable spill.

However, let’s step back and remember that SPCC planning is primarily about all of the proactive steps that will be taken to so that you don’t need to put your Facility Response Plan into action.    The EPA calls these steps “good engineering practices.”

Good engineering practices can take many forms.   They can include having spill kits available throughout the facility, teaching employees to keep containers closed when they are not in use, providing fuel containment, requiring oil suppliers to have documented safe transfer procedures… in short, they can be any type of practice, procedure or process that will help prevent oil from leaving the facility.

The EPA leaves it up the facility to determine what good engineering practices make sense for them.  For some people, preparing for spills during transfer might mean portable fuel containment pools.   For others, it might mean opening a valve that will allow a spill to channel to a holding tank.

Many facilities are using Drainblocker® Drain Covers as a good engineering practice, and we think that they are a great choice for a lot of applications – give us a call to see if they’ll be a good tool for your compliance shed.

A new campaign hopes to bring 12,000 rain gardens to the Puget Sound area by 2016. And, as of this morning, 615 have already been established!

Although this effort is primarily aimed at homeowners and residential areas that aren’t traditionally governed under EPA’s Stormwater Regulations in the same way that industry is regulated; the coordinators of this program say that if it is successful, it will help prevent about 160 million gallons of polluted stormwater runoff from entering storm drains each year. (Remember that sediment is a form of pollution, so residential rooftops, driveways and other hard surfaces can all be sources.)

For more information on this program, visit one of the websites shown below.

http://www.12000raingardens.org/

http://www.publicnewsservice.org/index.php?/content/article/19582-1

And, if you’re looking for creative solutions to help improve your facility’s Stormwater Pollution Prevention Plan, (SWPPP) visit our website or give us a call at 1-800-HOT-HOGS® (468-4647). We’ve got products to block drains, filter runoff and discharge, capture fluids for treatment and protect materials stored outdoors.

Secondary containment is at the heart of many SPCC requirements, and that makes sense, because when spill containment systems are in place, oil spills are less likely to leave a facility, triggering spill reporting requirements.

Providing fuel containment for tanks and drums that don’t really move too often is one thing – but providing secondary containment for things that are always on the go can be a bit more frustrating.

Many facilities have found portable containment pools to be a fast, affordable solution.    They can be set up just about anywhere spill containment is needed; stand up to repeated uses; and can be sized to meet nearly any secondary containment need.

One of the main applications that we see our Collapse-A-Tainer® Systems being used for these days is for providing fuel containment during offloading.   If a hose breaks, a coupling fails, or a tank bursts, everything is contained.    And, for faculties that may only receive bulk oil deliveries once a week or once a month, these secondary containment units can be folded up and stored out of the way until they’re needed again.

For facilities that need something a little more portable, pop-up-pools are another popular spill containment option.   Although they aren’t large enough to contain a catastrophic tank failure, pop-up pools are idea for “likely” failure scenarios, such as coupling failures or hose leaks.     If a receiving area already has secondary containment, these pools can help keep small spills contained so that clean up is faster and easier.

Whether you need a small pool to contain 30 gallons, or one large enough to contain 10,000 gallons, portable pools may be the answer!

Our nation recently marked the centennial of the tragic Triangle Waist Factory Fire that claimed the lives of 146 workers on March 25, 1911. Many of the victims, ranging in age from 14 to 48, were killed by the smoke and flames. Others jumped from the building to avoid being consumed by the fire.

Fortunately, this incident and others like it called many to action, and drew attention to the need to protect America’s workers. The American Society of Safety Engineers (ASSE) was formed on October 14, 1911 as a result of the incident. A handful of unions also used this tragedy to garner support for their organizations and push their plight for better working conditions.

Fire companies started looking at fire prevention opportunities in addition to fire fighting strategies. Building codes were revised, and new ones were developed. To this day, this tragedy is still studied by the fire service community and hard lessons are still learned from it.

In 1970, the Occupational Safety and Health Administration (OSHA) was created. With the newly created safety regulations came the tooth to enforce them. As we look at workplace safety conditions now that are world apart from the pictures painted 100 years ago, members of the safety community know that there is always room for improvement.

Violations to the hazard communication standard are always in “OSHA’s Top Five.”

Slips, trips and falls are still the number one cause of injury and lost work time.

Exit routes are still deemed to be insufficient or unsuitable.

The difference now is that we have the tools and the knowledge to make workplaces safer. We also have the tragedies of the past as vivid reminders of what can happen when we take shortcuts or ignore these duties.

Need help selecting safety products?    Give us a call.   Helping you keep your workplace cleaner and safer is our top priority.

When fuel containment is needed at your facility, concrete spill containment berms are probably one of the first things that come to mind – along with the time and expense to have them installed.

Often, containment berms are made of concrete or earthen materials, and are part of an engineered containment design for the fuel containment area.   While there’s nothing wrong with these systems, in fact, they are a nice solution; concrete spill berms don’t always allow full access to tanks or storage areas, they are usually expensive, and they are hard to remove if the facility design or containment needs change.

If your facility needs fuel containment solutions to satisfy the active secondary containment requirements of SPCC planning, flexible spill containment berms like our Build-A-Berm® Barrier are a solution worth considering.   They are more affordable than concrete berms, they allow easier access to fuel containment areas, and they can be easily moved if your needs change.

Our Build-A-Berm® spill berms are easy to install, and are available in 1.5”, 2”, 4” and 6” heights.  Just seal them to the ground with sealant, and connect the top sections and corners with vinyl cement and you can create a spill containment berm just about anywhere – and in far less time than it will take an engineering firm to give you the first draft of their design.

Because Build-A-Berm® containment berms have a foam core, they remain flexible, allowing carts, forklifts and delivery trucks to pass over them easily without the need for ramps, and without the big bump.

A heavy-duty version of the 2” Build-A-Berm® Barrier is also available for heavy traffic areas. We even offer a draining plug to facilitate draining of the fuel containment area (after you’ve sampled the collected rainwater or snowmelt, of course.)

For facilities that only need passive secondary containment, consider our polyurethane spill berms.    Our Spillblocker® Dikes can be put down proactively before routine fuel deliveries, or deployed quickly in the event of a spill.    These spill containment berms are super-flexible to channel and contain liquids just about anywhere.   They create an instantaneous firm seal on smooth surfaces to keep spills contained and out of sensitive areas like storm drains.

So whether you need active or passive containment berms, give us a call.  Chances are we have an affordable alternative to concrete.

If your facility is required to have a Facility Response Plan under SPCC regulations (40 CFR 112,) you’re probably familiar with the term “worst case scenario discharge.”

Chances are, you’ve already done a hazard evaluation and created lots of discharge scenarios, lists, and training modules   (if not – better get moving: the deadline is November 10^th… I’m sorry, but you aren’t eligible for the one-year extension.)

Because the main focus of Facility Response Plans is on “worst case” discharges, a topic that can sometimes get overlooked is the requirement to also plan for small to medium sized discharges.

According to the National Response Center, most discharges are less than 100 gallons, which makes preparing for small spills just as important as planning for “the big one.”

We’ve talked to a lot of customers who are creating, reviewing or modifying their response plans, and a common question is “how big of a spill kit do I need?”  We even recently had a call from a customer who had just gotten off the phone with EPA and was really frustrated because they wouldn’t tell her how many spill kits she needed or what products should be in them.

Could that be right?   Why couldn’t EPA tell her how many spill kits she needs?  After all, she did know her worst case scenario discharge.

Just like other portions of the SPCC rule, the EPA specifically created flexibility in this area to allow facilities to determine what will best meet their particular needs.  That’s why there was no hard, fast number of absorbent booms, bales of mat or any other “list” that the EPA could reference to answer this question.

Spill kits are just one of many tools that can be used to comply with the requirement to have “emergency response equipment” as part of your Facility Response Plan.

So, how many spill kits do you need, and where should you put them?

The first question we usually ask customers is how big of spill they can have at their facility (or in EPA terms, what is the “worst case scenario.”)  But, that doesn’t tell the whole story.

Barring natural and man-made disasters, discharges most commonly happen when oil is being transferred, and spills are usually less than “worst case” levels.   Data from the National Response Center helps to confirm this: most spills are less than 100 gallons.

Knowing this, it makes sense to put spill kits in areas where oil is transferred, and in areas where spills are likely to happen.  Receiving docks, waste collection areas, processing areas, areas where oil is pumped from drums or totes, outdoor storage areas, and fleet maintenance areas are all good areas to consider for spill kits.

Next, consider the size needed in each area.   Instead of looking at the overall “worst case” scenario, consider what is likely to happen in a given area.   For example, if you’re pumping oil from a 55-gallon drum that is stored on a containment pallet into a five gallon bucket, you could create a “worst case” scenario for that area that would involve a full-drum failure that somehow missed the containment pallet.

However, it is far more likely that a spill in this area would involve someone tipping the five gallon bucket – so a spill kit that absorbs five gallons may be an appropriate choice for that particular area (especially if other kits can be accessed and brought to the area quickly to address “worst case” issues.)

For loading docks, consider the types of containers that commonly arrive: are they five gallon pails? Drums? Totes? If the biggest container is a 55-gallon drum, it’s reasonable to plan for a 55-gallon spill on the dock.  You can follow this logic throughout a facility to address “small” spill needs.

So, back to “the big one.” If you have a 10,000 gallon, outdoor, above-ground storage tank – which spill kit should you choose?

We’ve found our large and extra large response carts to be a good fit for these scenarios, when they are coupled with other response equipment like our Drainblocker® Drain Covers, absorbent booms, vacuum trucks and other recovery equipment.    They help get the spill under control while other equipment is being readied.

Still not sure?  Give us a call.  We’d be glad to walk you through possible solutions.

Providing drum spill containment to meet SPCC’s secondary containment requirements can sometimes be frustrating because traditional spill pallets aren’t always the best solution when drums are stored outdoors.

Fortunately, your drum containment choices aren’t limited to the same old, super-tall spill pallets covered by a big, blue tarp that someone purchased a decade ago to meet another regulatory requirement.

Now, there are a lot of different options for storing drums outdoors that are more user-friendly  – and they still help you comply with a host of regulations, including SPCC (40 CFR 112)!

It’s all about controlling oil

The goal behind SPCC’s secondary containment requirement is the same as the overall goal of SPCC planning: to prevent oil from leaving your facility (or preventing a “discharge to navigable waters” as the regulation states it.)

Secondary containment for large tanks gets a lot of attention – but let’s not forget that 55 gallon drums are subject to this requirement as well; and considering that it only takes a single drop of oil hitting navigable waters for a spill to be reportable, drum spill containment isn’t something that can’t be put aside to deal with another day.

Spill pallets are an affordable, versatile way to provide drum containment and capture everything from an incidental leak to a catastrophic failure.

How to beat the freeboard

Keeping leaks and spills from drums in check when the containers are stored indoors is challenging enough, but when those same containers are stored outdoors, new challenges to drum containment issues are introduced.  Secondary containment must be sufficient to hold the spilled drum contents, plus freeboard (rain or melted snow).

If you put regular, uncovered spill pallets outdoors, they can quickly become useless in the event of a spill if rainwater has accumulated in the sump.

Roll-top pallets are the easy solution! We’ve got roll-top units available for one drum containment to a hundred.

Okay, in all fairness, I do have to admit that although it can be done, I’ve never actually seen 25 of our four-drum roll-top pallets linked together to hold a hundred drums. That would be neat!  If anyone has done that, shoot me the picture, I’d love to see it!   The most I’ve seen is five linked into a row, which still rocks, in my opinion.

Flammables or combustibles outdoors? Yep

We also have a wide selection of steel outdoor storage units for anyone who needs to store flammable or combustible petroleum products outdoors.  The units can be grounded and designed to meet a variety of fire codes and other regulations, in addition to meeting SPCC secondary containment requirements.

A leading benefit of roll-top pallets and steel outdoor storage units is that the sump is completely covered, which helps prevent water from accumulating in the sump.   Keeping drums in a covered spill pallet also keeps the container clean and helps prevent rust if the container is steel, or UV degradation if the container is poly.

These options can be a bit of an investment if you store a lot of drums outdoors, but they are a huge time saver if you’re the one who has to go test the accumulated rainwater and discharge it from each sump. They also provide more versatility than creating a permanent outdoor storage area with traditional moat-style concrete containment walls around the drum spill containment area.

Need help narrowing your choices?  Give us a call at 1-800-HOT-HOGS®. We’d be glad to help you find the perfect match!

Even if your facility already has an SPCC plan in place, it doesn’t hurt to take it of the shelf and sneak a peek at it a little more often than the required 5-year interval spelled out in 40 CFR 112 to see if those good engineering practices that were listed so long ago are still relevant and viable.

When you think about all of the different technologies that have been developed over the past five or six years, it makes sense that EPA requires periodic plan reviews. It is very likely that there’s a new tool, form of spill containment, new types of spill berms, or some other gadget that wasn’t available ten years ago, and that might end up being a really good fit in your facility response plans.

What’s new in Countermeasures?

Let’s reflect for a moment on the last “C” in SPCC. It stands for “Countermeasures.” The elements in facility response plans document those countermeasures, listing what workers at the facility will use to contain, clean up and mitigate any oil spill that actually does reach navigable waters. Even if your facility doesn’t meet the criteria to be required to have a facility response plan, there still are some other spill containment and planning elements that need to be considered and documented with your SPCC plan.

Being able to provide spill containment is an essential plan element, and it goes a long way toward minimizing the effects of a discharge.  Even if some oil does reach a drain and enter navigable waters, having portable spill berms, dikes or other devices to minimize the overall volume entering the water is still going to be a benefit to the overall clean-up effort.

In a guidance document on 40 CFR 112 issued to EPA Regional Inspectors, one of the elements that an inspector is tasked with looking for in a facility’s plan is whether or not they feel that the planning elements and control devices are adequate to control or mitigate an oil discharge.

Specifically, what’s new in Spill Berms?

Spill berms are a control device that gives facilities a lot of liberty for containment and diverting liquids. Years ago, spill berms were most often highly engineered products—most often made of concrete—that required several months and hundreds of drawings before installation. Now, there are other options—both active and passive—that can alleviate a lot of the headaches associated with stopping spills, without being an obstacle.

One example is our PIG® Build-A-Berm® Barrier. It comes in two, four and six-inch heights and is simple to install indoors or outdoors to provide active secondary spill containment around tanks, processing areas, storage bays or anything else that could leak.  I actually had a call from a customer last week who has had one in place in a tank farm in Texas since 2004—and it’s still going strong; he just needed some new sealant because it was starting to crack in a few places and he wanted to renew the seal.

One of the neatest features of this product is that unlike hard, concrete berms, the foam core allows the product to be walked on or driven over, so you never lose or limit access to the area being contained.

If low-clearance vehicles are in use—here’s what else is new!

If traditional spill berms just won’t work—which is sometimes the case if tow motors or other vehicles with low clearance are common at your facility, our PIG® SPILLBLOCKER® Dikes are a great form of passive spill containment.  The flexible polyurethane hugs flat surfaces, creating a seal that keeps liquids in check and out of sensitive areas.  Like the PIG® Build-A-Berm® Barrier, it is also available in multiple heights to meet a variety of containment needs.  It can be deployed proactively prior to fluid transfers, or reactively in response to a release that has just happened, making a versatile spill response tool.

Depending on the type of secondary containment needed, 40 CFR 112 does offer a lot of flexibility when choosing products or designs to fit your facility’s needs.  With innovative products, you may no longer have to settle for concrete moats that don’t allow access.  If you facility is expanding or changing processes, it might be time to consider new ways of containing them, too.

News item: Clorox to stop using chlorine to make bleach

Okay, time out.

So Clorox is going to stop using chlorine gas which is transported by rail—the safest form of transportation—in double-walled, insulated tanker cars with reinforced ends and all of the valves and gateways guarded. (Thank you FEMA AW 147 rail car incident class that I took two weeks ago!!)

Greenpeace applauds, the news release says, but that questioning voice you hear above the clapping is mine.

Let’s all put on our properly fit-tested SCBAs so we’re not overcome by the green cloud and consider what this means.

Now Clorox will be transporting bulk quantities of liquid sodium hypochlorite, which can be shipped in a “general service” single-wall rail tank car with no reinforced ends and no protection on the valves and gateways.

In the event of a derailment, guess which of these two types of rail car is more likely to breech???

With chlorine gas, you can evacuate the area and let the cloud dissipate. With a sodium hypochlorite spill, you’ll be digging up soil for months—and guess what:  That soil’s offgassing the pollutants the entire time. 

And guess what else—just because Clorox is going to stop using chlorine doesn’t necessarily translate to less chlorine on the rails or on the road.  

Guess how you make sodium hypochlorite: You react dilute a caustic soda solution with liquid or gaseous chlorine.   So chlorine is still going to be transported.  Most likely by rail.

This is a good thing??  What am I missing?

Yes, it will be safer for Clorox employees— and kudos to Clorox for that—but I just don’t see the environmental triumph. 

Image © Beth Van Trees – Fotolia.com