Do you know how much oil you store in aboveground containers at your facilities? If you have more than 1,320 gallons at a facility, you may need an SPCC Plan. SPCC stands for Spill Prevention, Control and Countermeasure, and it is a federal rule (40 CFR 112 in the Federal Register) designed to prevent oil-based products from entering navigable waterways of the United States. But it’s about more than just compliance. It’s an important tool to help you limit your liability.
As a utility leader, your focus is to deliver electricity to your customers; however, facilities covered under the SPCC Rule are subject to inspections and potential enforcement actions if your practices are out of compliance.
The 1,320-gallon threshold isn’t the only requirement for an SPCC Plan. The SPCC Rule only counts oil storage containers with a capacity of 55 gallons or more. Many electric utility facilities will meet the oil storage threshold, including substations, storage yards, power plants, and operations and maintenance facilities.
Another criterion is that a facility must reasonably be expected to discharge oil into navigable waters or adjoining shorelines of the U.S. The Environmental Protection Agency (USEPA) does not define what “reasonably be expected” means. Instead, the responsibility is on the facility owner or operator to determine the potential for discharge. In reality, it’s usually easy to think of a scenario where spilled oil could reach a waterway. Even if you think a spill would never reach the stream, what if there was a significant rain event that washed away spilled oil on the ground through a storm sewer? Often “reasonably be expected” is not challenged, and it’s best to err on the side of caution.
It’s time to prepare an SPCC Plan. The Plan summarizes your facility’s oil sources, identifies spill response coordinators, and outlines your spill prevention measures and spill response procedures. There are three options: 1) Prepare the Plan yourself; 2) Use a third-party provider to prepare your Plan; or 3) Have a licensed professional engineer (PE) prepare your Plan. The option you choose depends on how much oil you store at your facility and your working knowledge of the SPCC Rule.
If your facility has less than 10,000 gallons of oil and no single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you may prepare your own SPCC Plan, following the USEPA’s Tier I qualified facility template.
You can download the USEPA’s Tier I qualified facility template here: https://www.epa.gov/sites/production/files/2014-05/documents/tier1template.pdf. It is the cheapest way to comply with the SPCC Rule. You need to be familiar with the SPCC Rule’s requirements to complete a self-certified plan. You must also follow all of the requirements without deviation.
If your facility has less than 10,000 gallons of oil and a single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you qualify under the USEPA’s Tier II qualified facility category. The USEPA does not provide a plan template for a Tier II qualified facility. You can still prepare the Plan yourself, or you may hire a third party or PE to prepare the Plan for you. If you prepare the Plan yourself, you must still follow all of the requirements precisely without deviating from them.
If your facility has greater than 10,000 gallons of oil storage, you must have a licensed PE prepare and certify your facility’s SPCC Plan. The Rule allows PEs the flexibility to deviate from certain requirements, so you may decide you want a PE to prepare and certify your plan for your Tier I or Tier II qualified facility.
An SPCC Plan is about more than just compliance. An SPCC Plan contains important information that will be critical if you have an oil spill. The Plan contains inspection forms and protocols that help you maintain your oil sources and prevent a spill from happening in the first place. It identifies the single point of contact, an “SPCC Coordinator” for the facility. If there is a spill, the Plan contains steps to contain and control the spill initially, and the proper contacts to notify internally and externally.
The SPCC Rule requires oil-handling personnel to receive annual training to respond to spills in their work areas properly, and the SPCC Plan contains the material that must be covered in training. The SPCC Plan also contains forms for you to document training, plan reviews and updates, and spill notifications.
Work with your staff to determine if the SPCC Rule applies to you. An SPCC Plan is a required document for certain facilities to help you comply with the SPCC Rule and gain the benefits of having a plan in place. But more than that, it’s a practical document designed to assist with training and inspections while serving the function to help prevent spills from occurring. And if spills do occur, an SPCC Plan provides the guidance to help control the spill and limit your liability.
Read Part II – Are You Ready to Respond to an Industrial Spill?
About the Author: Jared Omernik has 12 years of experience helping electric utilities comply with environmental regulations, including helping utility owners and operators build and review SPCC Plans and Storm Water Pollution Prevention Plans (SWPPPs).
For questions about the SPCC Rule or SPCC Plans, contact Jared at .
During this COVID-19 outbreak, many employers, property managers, and property owners are tirelessly working to maintain clean and safe environments for tenants and employees. Cleaning contractors and janitorial services are working overtime, expending considerable efforts trying to maintain clean and disinfected workspaces and buildings. While providing their services, they face continual challenges of not having enough information regarding COVID-19 behavior, and the dwindling supply of cleaning and disinfecting agents. Many have inquired about microbial sampling and analytical methodologies to evaluate the effectiveness of these cleaning measures.
Some of us have been here before. Twenty years ago, property managers and tenants faced similar challenges in the wake of anthrax contamination of mailrooms in several prominent buildings. The approach we took then—collecting wipe samples from areas of concern for analysis at a nationally-recognized specialty laboratory—can offer peace of mind and an empirical basis for the evaluation of cleaning/disinfection effectiveness.
While specific testing for viruses, including the novel coronavirus (SARS-CoV-2), is not generally available, it is possible to test environments and surfaces for the presence of surrogate clinical pathogens and bacteria—these should be absent if cleaning and disinfection are effective.
Every building, tenant space, and office work environment is unique, and therefore it is important to develop site-specific plans. Staff collecting the samples should be trained in hazardous incident response, including microbiological and chemical impacts on structures and the environment, and should have the proper personal protective equipment (somewhat scarce at present in many locations).
About SCS Engineers
SCS Engineers is a 50-year-old, employee-owned environmental consulting and contracting firm that designs and implements sustainable and innovative environmental solutions. With 70 offices nationwide and nearly 1,000 employees, we are a full-service provider in the solid waste, hazardous waste, and environmental engineering industries. We study challenges and design solutions; we remediate, build and operate environmental and energy projects and systems; and, we evaluate the public health risk of hazardous materials exposure scenarios. As technologies, industry, and public needs change and expand, SCS evolves to provide innovative solutions to our clients’ challenges.
Most states’ guidance considers SCS’s services as essential to protect public health.
Contact SCS today at 800-767-4727 or for additional information and consultation regarding the effectiveness of cleaning/disinfection at your properties and workspaces in your state. Further information about SCS is on our website at https://www.scsengineers.com/.
For International Women’s Day, SCS decided to interview one of our own, Nicole Kron, who is a Hydrogeologist in Madison, Wisconsin. Nicole joined SCS Engineers in December 2017, as a project professional in the Environmental Services practice. Nicole graduated with her Bachelors of Science in Geology from the University of Illinois and earned her Masters of Science in Hydrogeology from Illinois State University.
Early in her career, prior to working at SCS, she did a lot of fieldwork – characterizing sites, determining where there might be issues of contamination that would need to be cleaned up, drilling and installing wells, collecting groundwater and soil sampling and just getting an understanding of the geology of the site.
Nicole now focuses more on the evaluation and preparation for the fieldwork. Once the fieldwork is completed, Nicole conducts the evaluation of the lab data that comes back and a groundwater analysis if needed. Based on the data they receive, whether it’s groundwater data or soil data or any other medium, she performs evaluations for what that means for that site. She then develops reports that explain the geology and hydrogeology of the site, the extent of contamination, and what are the next steps, whether that be to close the site or needing to do more work to better define the issue. She assists in a lot of those different areas and helps with managing the reporting and analysis of the findings.
Prior to coming to SCS Engineers, I had worked with two other firms. They were good firms but did not always have the warmest culture. I had a friend who worked in the SCS Engineers’ Madison office and mentioned that he enjoyed working for SCS and encouraged me to apply. There’s always going to be challenges and difficult times wherever you work. What I appreciate about working at SCS Engineers is that when there are those challenges, or if I’m having a tough day, there is still an environment of support at SCS and a desire for everyone to achieve their goals. SCS Engineers has the best work culture I’ve ever worked in!
Working with my team! I also love that I have the opportunity to develop my own career path and can contribute to finding solutions to issues we encounter while working on projects. I always feel respected and not just a “cog in the wheel,” but a part of the team. I appreciate that my work is valued here.
This is hard to answer! I’m a part of such a great team and am able to do a lot of work for some of our bigger clients in the Midwest. I’ve also taken over as the local SCS Young Professionals Leader for the Upper Midwest, where I help arrange meetings and lead discussions. I work on ways to help the YP’s feel like a connected group, supported while learning new skills, and improving work environments.
We all have different personalities and strengths to our personalities. There are no personality types that are designed for one type of career. For example, I’m an extrovert and like to collaborate with other people. But, not everyone is an extrovert and may take on challenges differently than I do. On the DiSC chart of personalities, I am a solid “iD,” which means I like to be high-spirited and enthusiastic and am also strong-willed. It’s good to recognize everyone has different strengths and weaknesses, and learning what works and doesn’t work for your team.
Surprisingly, there were! It was fairly balanced. Many of the women that I attended school with have gone into a variety of fields since graduating – Oil and Gas, government and state agencies, and a few went into environmental consulting. I do see an increase in women joining the environmental field, which is exciting! Most are just starting off in their careers, but I think it’s great that hopefully there will continue to be more women in STEM fields!
The non-profit organization was started by a graduate student who wanted to ensure that science would continue beyond just the classroom and that students could see scientists as well-rounded people. Scientists are paired up with a classroom over a Skype video conference, and the students can ask questions about the scientist’s work and why they chose their career path. It’s a great opportunity for students to see what scientists are like and what they do. The founder of the program wanted to make sure students would see more of a scientist than the stereotype of a person with a lab coat and goggles on, mixing chemicals all day.
I’ve participated in two sessions – a 4th-grade class and a 10th-grade class. The 4th graders were from Canada, wanted to talk about volcanoes, and where they could find diamonds! The 10th-grade class happened to be an all-female class. They were excited to learn that I was a dancer and used to perform in plays and on the speech team in college. We also talked about how it is okay to fail sometimes and to recognize failure as part of the journey in your career and in life. Failure is part of being a scientist. If your experiment fails, you can’t just give up. You have to try something new! It was great to be able to remind your students that it’s okay to fail sometimes as long as you learn how to work through it.
Don’t discount opportunities to learn something that would be applicable to your field. When I was finishing my Masters, I had an opportunity to take a class that would give me the foundational understanding in this field, but I elected not to take it because I did not believe I would go into environmental consulting. Now I’m working in this field! Yes, it was one class and didn’t hinder my abilities to get a job or do my job today, but you never know what may be in store for you in the future. If you have an opportunity to learn something new, try it anyway! This should go beyond STEM as well. If you have a chance to learn, do it!
As a woman in the environmental field, sometimes you are the minority, but that’s not a bad thing. You are there to contribute and to be a part of a team. It shouldn’t matter the color of your skin, how old you are, or what gender you associate with.
Remember that your voice is just as important as everyone else’s! Be ready to listen and learn. Your voice has just as much power and meaning as any other person in the room.
I love to knit, go camping, and kayaking! I also really love to go dancing! I used to take ballroom dance classes when I was younger, so I take any opportunity I have to go dance!
Interview by Lindsay Evans, SCS Engineers Human Resources
SCS Engineers welcomes Ben Reynolds, to our Little Rock, Arkansas office. Mr. Reynolds joins the SCS environmental services team providing support to real estate developers, construction firms, and industrial clients in the region. These businesses need to manage air, water, and soil safely within federal and state policies as they operate.
Ben is a Professional Engineer in Arkansas, Oklahoma, and Tennessee. He comes to SCS Engineers from the Arkansas Division of Environmental Quality (DEQ), where he served as the technical branch manager for Assessment and Remediation and in the Hazardous Waste Division as a permit engineer. His expertise and working knowledge from the DEQ is valuable to clients who need support to obtain multiple permits and to complete successfully Brownfield and other voluntary remediation projects.
Working as an environmental engineer, Ben gained experience helping clients with Phase I and Phase II environmental site assessments, Spill Prevention, Control, and Countermeasures (SPCC) Plan, and Storm Water Pollution Prevention Planning (SWPPP). These assessments and plans keep businesses compliant with environmental federal and state regulatory policies. Ben approaches each project analytically, mitigating the financial risk and future liability through careful evaluation, analysis, and planning that protects clients and the environment during all phases of redevelopment or production.
Ben also has experience with real-time telemetry for directional drilling, assisting with well completions, and the production of oil and natural gas. Telemetry is useful in many industries for collecting measurements and other data at remote or inaccessible points. These systems complement SCS’s technologies, SCSeTools® and SCS RMC®, to help streamline monitoring, auditing, and record-keeping, which reduce the cost of operations and of maintaining environmental records. His experience complements and enhances SCS’s Oil & Gas and SCS’s Energy practices too.
Ben earned his Bachelor of Science in Mechanical Engineering at the University of Arkansas. His supplemental professional education includes Establishing Energy Metrics, Closure Cost and Financial Assurance, Resource Conservation and Recovery Act (RCRA), RCRA Sampling Techniques, and Stack Sampling. He is certified as an STI/SPFA SP001 Aboveground Tank Inspector; with OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) 40-Hour Certified.
“Ben’s a valuable resource for our clients,” stated Dan McCullough. “We’re happy to welcome another SCS member with strong analytical skills and the expertise to resolve complex environmental challenges.” The SCS Engineers Little Rock office supports the growing demand for environmental scientists, engineers, and consultants. SCS professional staff specializes in meeting federal, state, and local clean air, water, and soil goals, and the restoration of property once thought impractical to revitalize.
SCS has completed numerous mold surveys for a variety of facilities, such as schools, offices, warehouses, industrial, and commercial buildings. We do not recommend a mold survey if you observe mold — if you can see it, you have a mold issue. Mold is ubiquitous and requires water and food to grow, so if you observe mold growth, the first step is to stop the source of water.
Exposure
There are no promulgated governmental exposure limits for mold, as every individual responds differently to the presence of mold. Mold surveys are typically performed after the water leak has been repaired, and the water damaged building materials have been replaced. This post-remediation survey lets you know if the cleanup has been successful and the area is safe to occupy.
If tenants are complaining of moldy or musty odors, a survey can tell you if you have a mold problem even if there is no visible growth. Mold can be present inside walls, air ducts, and false ceilings, behind cabinets, beneath flooring, for example. Successful survey results will show lower levels of mold spores inside the building compared to the outside sample results, with low to absent levels of concern.
Survey Process
SCS performs indoor air quality or IAQ, mold surveys using the newest battery-powered Zefon Bio-Pump® Plus, which collects an air sample for mold analysis in as little as 5 to 10 minutes, with an auto-shutoff feature once the sample is collected. Typically, a minimum of six samples are recommended, three inside and three outside, with the total number of samples dependent on the size and complexity of the affected area.
We transport the sample cassettes to a certified laboratory under the chain-of-custody protocol for mold spore analysis, with results typically available within 2 to 5 days. Rush analysis is available for an additional cost (same day service is dependent on the time of sample delivery to laboratory). Laboratory analytical reports may include spore counts for approximately 20 types of mold, total count comparisons; background count comparisons; explanation of results with descriptions of the individual spore types; references, and informational links.
Costs
Typical costs for a mold survey range from $2,500 to $10,000, depending on the location, size, and complexity of the survey area. As soon as the review of the laboratory report is complete, SCS provides verbal results, with a technical report typically issued within 10 business days of receipt of laboratory data. Most mold inspection firms utilize technician level workers. Having oversight by a certified industrial hygienist, SCS ensures the most complete and comprehensive survey appropriate to the needs of landlords and owners of commercial buildings and multi-residential dwellings.
If you’d like more information or have questions, please contact Jed Douglas, CIH, CSP, PG, Senior Project Advisor at SCS Engineers, or contact SCS at for an Occupational Health and Safety professional nearest you.
Mr. Douglas is a Senior Project Advisor specializing in Occupational Health and Safety Programs. He is a Certified Industrial Hygienist (CIH), a Certified Safety Professional (CSP), a licensed Professional Geologist in California, Oregon, Washington, and Arizona, and a U.S. Green Building Council LEED Accredited Professional. He has over 25 years of experience as a health and safety specialist and senior project manager, and has managed numerous environmental projects involving safety; soil and groundwater investigations and remediation of hazardous constituents; and, indoor air quality (IAQ) assessments for physical, chemical, and biological contaminants.
SCS Engineers has expanded into Green Bay to increase our municipal solid waste and electric utility customer support in the Green Bay/Fox Cities area.
Jared Omernik, SCS senior project manager, and civil engineer is now in Green Bay and available to provide support for local projects. Jared has worked with many of SCS Engineers’ clients from the Madison office over the past five years. Mr. Omernik has experience as an engineer on a wide variety of civil and environmental engineering projects. He has worked on development, permitting, design, construction, documentation, and compliance for a number of projects in several states.
Contact Jared via email at or call 608-216-7348. Thank you for your continued trust in SCS Engineers. We look forward to meeting your engineering and environmental compliance needs.
Joseph Dinan heads the SCS Engineers new office at 101 Arch Street, Boston, MA 02110,
Tel: 857-444-6302
SCS Engineers opened a new office in Boston’s Downtown Crossing district. The new location is more convenient for clients and enhances support to the firm’s growing client base in New England.
Joseph Dinan, an accomplished project manager and senior scientist heads Boston’s SCS team. Dinan has an excellent record meeting regulatory compliance and accountability for his clients to efficiently permit projects, keep them on budget and maintain the redevelopment schedule while meeting all environmental guidance. His background includes applied sciences including chemistry, microbiology, and environmental and soil sciences. Dinan has successfully managed hundreds of environmental assessment and remediation projects, both domestically and internationally.
Dinan’s Boston team resolves complex environmental challenges through the application of comprehensive analytical skills and technologies. Approaching each project with decades of expertise, mitigating the financial risk through careful assessment, analysis, and planning protects clients and the environment during all phases of redevelopment.
The Boston location supports the growing demand for environmental scientists, engineers, and consultants. SCS professional staff specializes in meeting federal, state, and local clean air, water, and soil goals, and the restoration of property once thought impractical to revitalize. The firm also provides vapor intrusion systems for protecting existing properties and a range of comprehensive environmental services for public and private entities.
As with most established urban environments, many properties may have previously been industrial or mass transportation sites, which often means that extra care is taken during redevelopment. Commercial real estate transactions must take environmental issues into consideration. Complex laws can impose significant environmental liabilities on purchasers, sellers, and lenders, whether or not they caused the problem, and whether or not they still own the property.
Important rules published by the U.S. Environmental Protection Agency – USEPA and in Massachusetts and other states offer defenses against environmental liabilities provided that the defendant conducted “all appropriate inquiries” regarding the property at the time of the acquisition, and then took reasonable steps to mitigate the effects of hazardous substances found on the property.
For more information, case studies, events, and articles visit these pages:
The Department of Toxic Substances Control (DTSC), State Water Resources Control Board, and San Francisco Bay Regional Water Quality Control Board have developed supplemental vapor intrusion guidance for conducting vapor intrusion evaluations in California. The Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion is available for review and public comment until 12:00 noon, April 30, 2020. Click here for available public meetings and comments.
According to the published Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion Executive Summary
Background
Toxic vapors can move from contaminated groundwater and soil to indoor air. This process is called vapor intrusion. Vapors inside buildings can threaten human health. The science behind vapor intrusion has been evolving quickly. To protect the health of Californians, the DTSC and the California Water Boards drafted a supplement to the existing vapor intrusion guidance. This is important information to collect for environmental protection. This document is called the “Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion” (Draft Guidance). This Draft Guidance contains recommended improvements for vapor intrusion investigations and promotes consistency throughout the state. It also offers suggestions on the following topics:
The Draft Guidance is intended to be used with existing State guidance – DTSC 2011 Vapor Intrusion Guidance and San Francisco Bay Regional Water Board 2014 Interim Framework 1 – when there is a spill or disposal of vapor-forming chemicals. This guidance does not apply to any leaking petroleum underground storage tanks (USTs) since they are governed under the State Water Resources Control Board’s Low-Threat UST Case Closure Policy.
Four Steps to Evaluate Vapor Intrusion
The Draft Guidance describes four recommended steps to decide if there is vapor intrusion that could pose a risk to the health of people inside buildings. These actions are meant to protect public health and should be carried out under the oversight of the lead regulatory agency.
Step 1 – Decide which buildings should be tested first and how.
When there are several buildings, start with those that are occupied and closest to the contamination. If a building is directly above or very close to the spill, or if it is likely that the sewer could bring toxic vapors inside, skip Step 2 and go directly to Step 3.
Step 2 – Screen buildings from outside.
Measure vapor-forming chemicals underground at these locations:
Step 3 – Test indoor air.
Measure vapor-forming chemicals in indoor air, beneath the building’s foundation, and outdoor air at the same time:
Step 4 – Act to protect public health.
Toxic Vapors Can Travel Through Sewer Pipes
Vapor-forming chemicals can enter sewer pipes that run through contaminated soil or groundwater. Once inside a sewer, vapors can move through the pipes and escape through cracks or openings, under or inside a building. Some of the traditional ways to test for vapor intrusion could potentially miss vapor-forming chemicals moving through sewer pipes. This Draft Guidance recommends evaluating whether the sewer could bring toxic vapors inside.
Vapor Intrusion Attenuation Factors
Attenuation factors are used to estimate how much of the vapors underground or in groundwater end up in the indoor air. This Draft Guidance uses attenuation factors recommended by the U.S. Environmental Protection Agency. These were calculated from a large study of buildings at contaminated sites around the nation, including California.
California Vapor Intrusion Database
Data from sites evaluated using the process described in the Draft Guidance will be entered into a database that will be publicly available. The State Water Resources Control Board (State Water Board) added capabilities to the GeoTracker database including building-specific information for a cleanup case and the ability to differentiate Field Points for collecting samples. The State will analyze the information in the database and learn how to better protect the people of California from vapor intrusion.
Where to Find the Draft Guidance
The environmental reporting season is just around the corner. Every year Ann O’Brien publishes a table to help you determine your reporting obligations. The table summarizes the most common types of environmental reports due to environmental regulatory agencies in Illinois, Indiana, and Wisconsin, along with respective due dates.
Table: environmental regulatory agencies in Illinois, Indiana, and Wisconsin
The professional engineers and consultants at SCS Engineers can help you navigate the local, state, and federal reporting obligations and permitting for your business, in your region, and in your industry. Contact us at or find a professional like Ann, nearest you.
Ann O’Brien is a Project Manager with SCS Engineers with more than 30 years of experience in the printing industry. Ann’s experience includes air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, employee EHS training, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Thanks, Ann!
Recently, Waste360 published “Organics Diversion Drives Changes in Landfill Operators’ Roles,” an article examining the evolving role of landfill operators in organics waste diversion. Five industry leaders provide insight into how landfill operators and the solid waste industry are adapting to accommodate the evolution and the cost of organics management.
Waste360 interviewed:
The article provides best practices, strategies, technology, and systems that could support or supplement landfill operators’ response plans to the changing policies and contract requirements in more economically sustainable ways. Waste360 rounds up answers to the most common challenges operators and public works departments face including how to reduce permitting time, cost, and environmental impact.
