I recently visited with industry peers in the U.K. and assessed a wastewater treatment facility who wanted help understanding their spill risks and preparedness.
Part of my goal going into this trip was to get some understanding of what the situation looked like “on the ground” when it comes to the general level of preparedness in the U.K.
It was quite interesting, mostly because it wasn’t interesting.
We used the Spill Preparedness Report to audit the spill risk for nine areas and look for ways the wastewater treatment facility can be better prepared for spills and releases.
What we found when auditing this facility was directly in line with a facility in the U.S.
Spill Kits Too Small
The perennial risk we see in facilities in the US was over there, as well. We’re not talking “a little bit” too small; we’re looking at spill kits that are 90 percent undersized.
Spill Kits Too Far Away
Having a spill kit that is 400 feet away is not going to cut it in an emergency, nor is having it locked away in a separate building. These are also common problems in the U.S. and U.K. Similarly, these aren’t a couple percentage points off; we’re looking at distances in the hundreds of feet in many cases.
No Drain-Blocking Provisions
This is also a problem in both the U.S. and U.K., and is a yes/no, pass/fail question. If there is an at-risk drain nearby, you need some means to block the flow or seal it. Whatever means is up to you and your facility preference (e.g. dike, sock, berm, drain cover), but you should have some means of preventing the spill from reaching the nearest drain.
Low Consideration of Liquid Transfers
This is a little trickier, but the facility had a pretty major liquid transfer and pumping operation. There were very few considerations as to placing the appropriate supplies in these transfer locations.
This problem tends to happen in a variety of different forms, but this facility had droves of oil-only absorbents because they were an outdoor facility using lubricants. That’s great. The issue comes from the 5,000-gallon holding tank filled with a water-based, hazardous precipitant. If they tried to absorb a spill of that hazardous liquid with the available absorbents, it would have shed like water off a duck’s back!
Overall, the recommendations we made for this facility were straightforward, not especially elaborate or obscure. The problems weren’t complex – it’s that they didn’t realize they had a problem in the first place.
Some of the specific recommendations we made were:
- Add spill kits or supplement the spill kits already in place to bring capacity into acceptable ranges. In most cases, this usually entailed adding around 20 gallons of absorbency to each location.
- Move or add spill kits to within appropriate range of each spill area, defined specifically for each area and the size of its largest container.
- Add drain-blocking measures where drains are present and at-risk. In many cases, these were either drain covers or drain plugs, depending on the area and its needs.
- Add spill kits to outdoor areas where pumping and liquid transfers frequently happen.
- Make sure that each area has absorbents appropriate to the type of liquids in that area.
All in all, we find that when we understand the spill risks in a way based on the actual spill potential (and not vague rules of thumb), we can take the right steps to prepare. While this facility needed some additional supplies, in many cases we find facilities are over-complying in some areas and under-complying in others.
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