The industry standard SP001 is incorporated into many Spill Prevention, Control, and Countermeasure (SPCC) Plans is now updated. How does it affect your facility’s SPCC Plan?
The Steel Tank Institute (STI) recently released an updated version of SP001 – Standard for the Inspection of Aboveground Storage Tanks. This document is the industry standard used in most SPCC Plans for inspection guidelines and integrity testing for shop-fabricated aboveground storage tanks. In a typical SPCC Plan prepared by SCS Engineers, your monthly and annual inspection forms, and tank integrity testing frequency requirements are based on the criteria provided in SP001.
No. We recommend incorporating the updated inspection forms during your next SPCC Plan Amendment or 5-year renewal.
The inspection criteria have been simplified, and more flexibility is allowed with the revised inspection forms. This will help make your inspection process easier and of higher quality.
Need help sorting out the details of the revised standard, or have an SPCC Plan that needs amending or is due for a 5-year review? Contact , and we will help you stay on top of your SPCC needs with offices nationwide.
Coauthors: Denise Wessels and Amber Fidler.
SCS Engineers SPCC specialists in Pennsylvania.
It might feel like the July 1 deadline is far away, but it is time to start preparing to report your releases of toxic materials. The U.S. Environmental Protection Agency (USEPA) indicates that printing and related industries are subject to this report. It is an important part of your environmental compliance strategy if you have a facility with at least 10 full-time equivalent employees in a covered NAICS code that exceeded a reporting threshold in the previous calendar year. Reporting releases of toxic materials on an annual basis is one aspect of the Emergency Planning and Community Right-to-Know Act (EPCRA).
Read the article with steps to your report for printing and related industries.
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right To Know Act (EPCRA), Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) and Section 112(r) of the Clean Air Act
Modeling for a Worst Case Release and the Alternative Release Scenario – not so mysterious after all. Lee Pyle explains it to you in her recent article in the RETA Breeze. Lee is SCS Engineers National Expert on Industrial Risk Management Plans and Process Safety Management.
All of us with over 10,000 pounds of ammonia in our plant system are well aware of the EPA Risk Management Program Hazard Assessment requirements (40 CFR Part 68.20). When the EPA inspector shows up, we hand them the manual and cross our fingers that they understand what they are reading and pray they do not ask a question.
Do not fret; chances are that the inspector at your plant is probably not much more fluent in dispersion modeling than you are. Much debate occurs over how long it would take to stop a release, but you do not want to get into a debate with an EPA inspector.
Read, share, or print Unmasking the Mystery of the Worst Case Release and the Alternative Release Scenario here. Happy Modeling!
Secondary containment is a basic engineering control to prevent a chemical or oil spill. There are misconceptions, though, regarding secondary containment requirements. In terms of oil-based storage, these misconceptions can lead to not enough containment capacity, significantly more containment capacity than necessary, or simply not providing the right level of containment when containers are grouped.
Chris Jimieson of SCS Engineers explains the five most common misperceptions and advises you how to keep your facility in compliance.
Read the article by clicking here.
This article discusses global air quality and how the collaboration between policy-makers and the scientific community can have a continued positive impact on air quality in the U.S. This collaboration has been the primary cause for the improvements observed in air quality over the past few decades.
U.S. Environmental Protection Agency (EPA) programs, such as the New Source Performance Standards (NSPS), New Source Review, and Maximum Achievable Control Technology standards, have all had a significant impact on improving air quality by lowering the ambient concentrations of NOX, VOC, CO, SOX, and PM.
Some areas, such as southern California, have committed to working toward electrifying the transportation network, implementing more stringent standards on diesel fuel sulfur content, and encouraging heavier utilization of public transportation.
Author: SCS Engineers’ Ryan Christman, M.S., is an air quality engineer and environmental management information systems specialist with experience in the oil and gas industry and the solid waste industry. He is just one of SCS’s outstanding Young Professionals.
Vapor intrusion (sometimes known as soil gas intrusion or soil vapor intrusion) is a potential environmental risk that can occur at a wide variety of properties, from former industrial facilities, shopping malls, and even residential properties. Knowing how to assess the risk and mitigate potential harm from soil vapor intrusion is critical to reducing health impacts and mitigating financial and other liability from potential exposures.
What is Vapor Intrusion?
Developers and the public understand that soil and water contamination can pose a health hazard, but vapor intrusion is an environmental health risk that can be overlooked. It is a hazard that can result from both heavy industrial operations and small “mom-and-pop” businesses so that it can be an issue both at industrial properties, suburban strip malls, and even residential developments.
Vapor intrusion is the migration of soil or water contamination from below structures into businesses or homes as a vapor. Common vapor intrusion contaminants from small businesses include benzene from gasoline and perchloroethylene (perc) from dry-cleaners, while large industrial facilities may have a wide range of industrial chemical contaminants. Less common vapor intrusion hazards are mercury, polychlorinated biphenyls, and pesticides.
Determining Whether Vapor Intrusion is an Issue
Environmental due diligence is key to determining whether vapor intrusion is a likely issue. An environmental site assessment (ESA) is critical in assessing the potential for vapor intrusion issues and the current state of vapor intrusion based on past site history. A Phase I ESA will review the current and historical use of the property and surrounding properties to determine where and when potential sources of contamination were present. Leaky underground gasoline storage tanks and poor chemical handling practices at dry cleaners lead to chemical contamination that can create vapor intrusion issues, so the “corner” gas station or the strip mall dry cleaner can be the source of vapor intrusion hazards.
Vapor intrusion can also come from groundwater plumes that originate outside the property boundary, so it is important that any assessment looks for potential contamination issues from nearby properties as well as on-site.
When the potential for a vapor intrusion issue exists, a Phase II ESA should be conducted to determine whether there is contamination, the extent and magnitude of the contamination, and whether the contamination poses a significant health risk. In the Phase II ESA, samples of soil and groundwater are collected from the property and analyzed for evidence of contamination.
If contamination is present, results are compared to screening levels established by regulatory agencies or a health risk assessment (HRA) can be prepared. Either of these strategies can potentially be used to demonstrate that health risks are not significant for the property’s current or future use or to determine the level of remediation necessary.
Dealing with Significant Soil Vapor Contamination
If soil vapor intrusion poses a significant health risk, there are ways to mitigate that risk. Mitigation can include removal of the contamination, active mitigation of the contamination source, and protection against indoor air exposure. The approaches are not mutually exclusive, and multiple risk reduction strategies may be used.
The most effective way of reducing soil vapor risk is to remove or treat the soil or water that is the source. This remediation is the most cost-effective for small sources of contamination and when that contamination can be easily accessed. It is often not feasible to remove the source when contamination originates offsite and moves onto the property in a groundwater plume. It may also be more cost-effective to mitigate risk through other means when the source of the vapor intrusion is extensive or difficult to remove.
In active mitigation, soil vapor intrusion is mitigating by reducing contamination at the source. Active systems can include soil vapor extraction, in which vapor is collected and removed; in situ treatment, which uses chemical reagents to transform the contamination into less toxic chemicals; and containment of the contamination source by some form of barrier. Under ideal conditions, these methods have the potential to be highly effective in reducing contamination but monitor treatment for effectiveness and to determine that the resulting contamination levels are acceptable.
It is also possible to mitigate indoor air exposure to soil vapor intrusion. Underground vents, membranes, and seals beneath the foundation and slab depressurization can reduce the flow of soil vapor into a building. This type of passive mitigation leaves the contamination source in place, which may limit future uses for the contaminated property, but it may be more cost-effective than active mitigation, especially in cases where contamination originates off the property. Regulatory agencies typically require that properties mitigating the movement of soil vapor into buildings monitor the ongoing mitigation on a continuous basis with sensors and alarms or periodic resampling.
What You Need to Know
Soil vapor intrusion is a potential environmental liability, but it is manageable. Environmental due diligence can significantly reduce unforeseen costs of vapor intrusion by identifying the issue for proactive management before development, which is always easier and more cost-effective than trying to address a problem after development. It is possible to mitigate health risk from soil vapor intrusion on developed sites. Developers should work with qualified environmental consultants to address vapor intrusion through each stage of the process to adequately minimize risk.
A look at the confusion stemming from regulatory uncertainty of new rules limiting air emissions from municipal solid waste landfills by David Greene, P.E., SCS Engineers – Asheville, NC.
The landfill industry continues to work with EPA Administration to get a longer-term stay to work out needed NSPS/EG rule changes. At this time, industry representatives are hopeful both these related goals can be achieved.
While the new NSPS/EG rules became effective back in 2016, the concerns with the rules raised at the time still remain unresolved. Despite this, we can expect resolution though it may take some time to fix. The fog should be lifting, yielding changes that are expected to be more workable for both the landfill industry and state/local regulators. In the meantime, stay tuned and stay informed.
Read the full article with links to the NSPS/EG update in a recently published SCS Technical Bulletin.
Agri-business companies handling large quantities of chemicals and transporting them through all sorts of conditions to different facilities must be prepared for an accidental spill. Accidental spills create environmental problems that can cost your business. However, agri-businesses can control their response to spills and react in ways that limit the environmental impact and help save time and money should a spill occur.
Environmental consultant, Tony Kollasch first discusses, what businesses can do to minimize environmental impacts? He covers the importance of spill response preparedness and REACT; Respond, Evaluate, Alert, Contain, Take.
Read the full article published in Wisconsin Agri-Business News Quarterly.
SCS Engineers periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. Our most recent SCS Bulletin summarizes the new rules which took effect on October 28, 2016, with compliance obligations under the NSPS Subpart XXX rule beginning November 28, 2016. Originally, states and local air jurisdictions were to submit their proposed EG rules by May 30, 2017; however, there have been some delays in this process, which we condense and detail in this Bulletin. SCS will continually update coverage of this Rule on our website.
In a Motion filed on November 7, the U.S. Environmental Protection Agency (USEPA) requested remand of five provisions of the Coal Combustion Residuals (CCR) Rule (40 CFR Parts 257 and 261), which would allow the agency to reconsider the provisions. This SCS Engineers Technical Bulletin covers the five provisions and the basis for their reconsideration. Read the full text here.
Oral arguments on EPA’s motion took place on November 20, 2017. EPA had asked that oral arguments be postponed, and all other aspects of the litigation are suspended until it could rule, but the court did not agree. The current provisions in this Technical Bulletin remain in place unless and until USEPA revises or rescinds them in a future rulemaking.
SCS Engineers will continue to track these issues and keep you informed. Join our Technical Bulletin email list by clicking here, or follow SCS on LinkedIn, Facebook, or Twitter .
