Spills are rarely predictable, which means that there’s very little way of knowing when tomorrow won’t be just another day at the office. The better prepared a facility is to handle spill scenarios, the less likely it will be for a release to enter the environment.
Chances are, right now, somewhere in America, a facility is experiencing the inconvenience and potential chaos caused by a spill. Not all of those spills are reportable, and few make the local or national news. In fact, most are less than 10 gallons in volume, and many are incidental — small in nature and pose no immediate threat to the environment or to the people who will implement cleanup.
Despite this, the National Response Center (NRC) fields nearly 11,000 calls a year from fixed facilities representatives who report the release of a hazardous chemical from their facility. That averages out to more than one call per hour.
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Spills and Releases
Many spills are simply an inconvenience. A 5-gallon pail of floor cleaner that falls off the shelf creates a spill that needs to be cleaned up, but it probably won’t cause irrevocable damage. Releases that reach the air, soil and especially water, however, cause harm that can sometimes take decades to remediate.
Even when a spill is released, all things are not equal. Oil spills are a good example of this because a release to water is far more detrimental than a spill to land.
No matter what their cause, at a minimum, spills waste useful product and interrupt normal facility operations. At their worst, they force evacuations of communities, damage infrastructure and pollute the air, land and water. Stopping spills before they are released to the water, land or air minimizes the risk of harm to humans and the environment. It also saves time and money.
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Facilities that use, store or handle hazardous materials are required by the EPA to identify and mitigate spill hazards. Facilities must also have a contingency plan that outlines the processes, procedures and equipment that will be used to counteract those hazards. Taking a proactive approach to eliminate hazards before they can cause spills helps to minimize the need for reactive spill response measures. However, because even the best plans and procedures can fail, facilities are also required to be prepared for spills and have resources available to contain and control them quickly and effectively.
In addition to contingency plans, facilities that could release hazardous materials directly into water are required to have a National Pollutant Discharge Elimination System (NPDES) Permit and a Stormwater Pollution Prevention Plan (SWPPP). Facilities that use, store or handle threshold quantities of oil and oil products that could reach water are also subject to Spill Prevention Control and Countermeasures (SPCC) regulations.
Best Management Practices
At the heart of these regulations are best management practices (BMPs). In the Clean Water Act, the EPA defines BMPs as:
“Schedules of activities, prohibitions of practices, maintenance procedures and other management practices to prevent or reduce the pollution of waters of the United States…BMPs also include treatment requirements, operating procedures and practices to control plant site runoff, spillage or leaks, sludge or waste disposal or drainage from raw material storage.”
Plans outline and describe the BMPs that a facility will proactively use to prevent hazards from polluting the environment. Because each facility is unique, the BMPs will vary. But many BMPs, such as good housekeeping measures and Standard Operating Procedures (SOPs) that facilities use daily, make operations run smoothly and help prevent pollution.
In addition to good housekeeping practices and SOPs, facilities can take additional steps to stop spills at or near their source. One of the most common pollution prevention measures that a variety of industries use is secondary containment systems for containers, tanks and processes that could leak or spill and cause a release to the environment. Secondary containment systems provide a permanent barrier that prevents spills from reaching drains or other sensitive areas. They also keep spills in a confined area so that they can be cleaned up more easily.
Secondary containment takes many forms, including temporary or permanent berms that surround several tanks and their piping, a portable pallet or deck under drums or a collapsible pool or pad. Whatever the system, the purpose of secondary containment is the same: to provide a temporary holding area for loose liquids.
A facility’s design is sometimes enough for secondary containment and there is no need for fabricated structures. For example, if tanks or containers are located in an area with an impervious floor that is sloped, spills will automatically be collected at the lowest point of that area. This also happens in most parking lots and loading docks.
A problem with these designs is that the low point is typically fitted with a drain. Drains are great for removing rain, snowmelt and other water from the area, but they are also a fast escape route for spilled liquids.
Drain covers quickly seal drains, prevent spills from being released and, in some cases provide secondary containment. Drain covers can be deployed before bulk fluids are delivered or after a spill has been discovered.
Spills aren’t always the cause of water pollution. Debris such as dirt and litter that are carried into storm drains from parking lots, other outdoor paved areas and construction projects also cause water quality problems.
Sediment is one of the most common and persistent forms of stormwater pollution. Stopping it before it reaches waterways helps to preserve water quality and prevent the accumulation of harmful chemicals that often bond to free-floating sediment particles in water. Keeping sediment from stormwater also helps prevent algae and other chemical and biological blooms that rob the water of oxygen that is necessary for fish and other aquatic life to survive.
Drain inserts and stormwater filtration devices capture sediment and litter before they reach water. These items need to be maintained periodically to be effective and prevent drain backups.
In an ideal world, BMPs, SOPs and environmental protection plans would all work together to prevent the chance of a spill, which would in turn prevent releases to the environment. But, this isn’t an ideal world. Equipment and machines unexpectedly fail. People forget to turn something on or off. Natural disasters occur all over the world. Whatever the cause, spills still happen.
Like BMPs, there is no absolute list of spill response tools and supplies that works for every facility. Regulations simply say that the facility needs to have a plan and be prepared for spills. For some facilities, that means containing spills and vacuuming them up for reuse. For others, that means absorbing the spill, neutralizing or flushing liquids to an onsite water treatment facility.
All of these solutions, as well as many others, are acceptable. To effectively prevent a release to the environment, facilities must have a spill response plan and appropriate materials in readily accessible locations.
Some of the best BMPs are common sense measures. Others can be a bit more complex. No matter what combination of practices are chosen, to be effective, employees need to understand how the plans, procedures and products chosen will work together to prevent releases. They also need to know how to perform any expected functions to either prevent a release or respond to one when it happens.
Training isn’t solely for production and maintenance personnel. Everyone needs to understand their role in pollution prevention – even if their only responsibility is to pull an alarm or evacuate. For many, this education can be part of hazard communication or other safety trainings.
Having a plan to prevent spills from being released is not only a requirement. It just makes sense. Facilities that use proactive BMPs to prevent unanticipated spills are less likely to experience unnecessary associated downtime and costs. They are also better prepared to quickly and effectively respond to spills and prevent releases that harm the environment and compromise safety.