Question: I recently had an EPA inspection and was told we need a spill response plan because we have drums of oil- and water-based liquids. What do I need to do?
Answer: The Environmental Protection Agency (EPA) wants to make sure your drums of water- and oil-based liquids won’t leak and release to the environment. Spills and releases can have adverse effects on the environment and the community around your facility, which is why you need a spill response plan.
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Your plan should outline the processes, containers, tanks and equipment that could leak or spill, as well as the plans and procedures you have in place to prevent spills and respond to them. The processes, procedures and equipment are known as best management practices (BMPs). Here are a common set of BMPs to consider as you start your plan:
Stop spills at the source and create a temporary holding area for loose liquids with secondary containment. Secondary containment can take a variety of forms, such as temporary or permanent berms around the containers or pallets and decks under drums.
If your storage tanks or containers are located near drains, the chance of a spill releasing to the environment is greater than if there were no drains around. Keep drain covers on hand to quickly seal drains and prevent releases when there’s a spill.
You might have all the measures in place to prevent spills, but you still need to be prepared with spill response supplies in case one happens. Because you have water- and oil-based liquids, you can use PIG Universal Absorbents to clean up leaks or spills. You can also get PIG Oil-Only Absorbents if you need to respond to outdoor oil spills on land or water. You can keep a universal or oil-only spill kit near your containers to show you’re prepared to quickly respond to spills.
It’s important that employees working near these containers and with these liquids know how to properly respond to spills. Make sure your workers know where to find spill response items, like absorbents and drain covers, and how to respond to spills through regular training.
This is just a preliminary set of BMPs to consider for your spill response plan. You should also factor in any regulations you might need to comply with, like stormwater or SPCC.
When you have the first draft of your plan with the BMPs you have in place at your facility to prevent and respond to spills, run it by your local emergency management office or other local authority having jurisdiction (AHJ) in your area. These groups are usually eager to work with facility owners and managers to make sure they’re prepared for the unexpected and often provide support services at no cost.