Are you approaching the required five-year review/plan re-certification for your facility’s Spill Prevention, Control, and Countermeasure (SPCC) Plan? Even if you’ve been through several cycles of performing five-year tune-ups on your SPCC Plan, you can make your next review easier and prepare yourself for future SPCC Plan re-certifications if you follow these five tips.
Start Early
Late renewals are a consistent pain point for many companies. To avoid being late with your next re-certification, start your review six months before your SPCC Plan is due for its 5-year review. If you are conducting the review internally, start by identifying the person who will be doing the review. If you are using a third party, this approach will help you go through the proposal/contracting process, so you are ready to conduct the actual review and complete the re-certification before the Plan expires.
Simplify Data Collection
One of the keys to a compliant SPCC Plan is to collect accurate data in the field about your facility’s oil sources. Streamlined data collection is of particular importance if you have a large facility or your oil storage changes regularly. The key to simplifying data collection is to make sure your reviewer has organized information to evaluate the compliance aspects of each source. Accurate data collection can limit the follow-up required from plan preparers to verify information, as well as minimize the potential for discrepancies. Moreover, particularly useful if a third party is auditing your Plan or if it is in review during an EPA inspection.
Reduce Redundancy with a Summary Table
One way to simplify your Plan is to use an oil source summary table to cover as much information as possible. A table can include each oil source and the aspects of how the oil source is compliant with the SPCC Rule. There may be areas in the Plan where you need to provide additional text discussion regarding oil sources to explain a compliance matter. In general, try to avoid duplicating information within the Plan.
Watch Out for Commonly Overlooked Areas
While secondary containment and overfill protection are key elements to review at each oil source, some reviewers forget to measure the size of containment structures. Dimensions need to be carefully measured in the field to verify and show sufficient secondary containment capacity in your facility’s SPCC Plan.
Another commonly overlooked area is facility drainage; specifically the overland flow in the proximity of each oil source, which is key to determining the potential receptors where spilled product can travel. These receptors could be storm sewers, ditches, wetlands, or waterways. You can discuss the protection of these receptors during your facility’s annual SPCC training. Swift action and concise communication during a spill can help limit your liability.
Use Targeted Annual Training
Many companies struggle to comply with the annual training requirement. One of the tripping points is trying to train all employees who handle oil for example. To avoid this pitfall, implement a tiered training program so you can focus the training content based on an employee’s responsibility level.
Spill recognition and notification through proper internal channels to get a spill cleaned up is an essential message for employees that occasionally handle oil. These employees could also be trained to aid with the initial control and response to a spill. A second tier may include team members who manage the SPCC Plan; they have additional responsibilities such as inspections of oil sources and spill reporting.
By Chris Jimieson, SCS Engineers
Chris Jimieson has over 17 years of experience supporting industrial, commercial, military, federal, state, municipal, and solid waste companies with environmental compliance. He has extensive experience building and reviewing SPCC and Storm Water Pollution Prevention Plans (SWPPP) and manages compliance assignments, providing computer-based training modules to meet employer training needs. Contact Chris at or 608-216-7367.
The Long Beach Business Journal published an article in February about the role of engineers in infrastructure design and investment. With discussion of an immense $1 trillion outlay at the federal level in the news, the LBBJ took a look at the roles engineers play in every aspect of infrastructure development.
President and CEO, Jim Walsh discusses the purpose SCS Engineers plays as an environmental consultant and contractor on infrastructure projects ensuring they meet environmental needs, as well as economic ones.
On March 1, each year facilities that use hazardous chemicals in specific quantities must file an EPCRA Tier II report identifying the chemicals with the State Emergency Response Commission, the Local Emergency Planning Committee, and the local fire department.
Easy to avoid mistakes and omissions in Tier II filings may lead to civil penalties of as much as $54.8K per day. Most cited violations involve just a few common chemicals such as ammonia, sulfuric acid inside equipment, and an EHS that is a component of mixtures. These are often overlooked or thought to be exempt from reporting because the threshold for reporting may be low.
Rather than risk non-compliance, ask the professionals at SCS Engineers about common chemical thresholds, voluntary self-disclosure, and EPA’s audit policies.
Read our most recent EPCRA Technical Bulletin, or contact us at .
We hope you find this Waste360 article helpful.
http://www.waste360.com/fleets-technology/what-s-next-route-optimization
Other related articles of interest include financing and rate studies see Solid Waste Management Services at SCS Engineers.
Rogoff will be leading a panel at this year’s WasteExpo in New Orleans. The session on Route Optimization Management will take place on Monday 8 at 9:00 AM. See more presentations and topics at Waste Expo 2017.
Chad Milligan, P.G. of SCS Engineers is presenting a holistic approach to water quality treatment at mines.
About the Presentation:
Disposal of produced fluids from industrial processes is becoming more challenging with time. Options such as surface discharge through NPDES or trucking can be cost prohibitive, requiring an evaluation of alternative methods such as disposal via deep will injection.
Such problems have arisen for three coal mines in Illinois. Two of the mines generate high chloride native groundwater that infiltrates the mine and is then pumped to surface retention ponds prior to treatment and disposal. The third mine generates fluids from multiple sources including a coal fire power generating plant and a coal combustion residual landfill. These fluids will be also stored in surface retention ponds prior to treatment and disposal.
An evaluation was performed of the treatment and disposal of native groundwater infiltrating the mines using a holistic approach. The approach includes an evaluation of the water quality by assessing the chemical and physical characteristics of water, water quantities, water treatment system, geochemistry, and applicable disposal well characteristics. Current evaluations have identified specific minerals that may be precipitating within the disposal well diminishing well capacity and biological fouling originating within the mine itself that has substantially increased pretreatment filtering costs.
The treatment and disposal of produced powered generating fluids has introduced a new level of review by not only including the general physical and chemical characteristics of water treatment, but also the review and evaluation of the plant-wide water budget identifying the source of fluids within the plant, and also a thorough characterization and review of solid waste regulations such as the Resource Conservation and Recovery Act.
This presentation will compare the source and treatment options of the produced waters from these three coal mines.
About Chad Milligan
Chad Milligan is a licensed professional geologist in the states of Kansas, Louisiana, and Illinois. He has a Bachelors degree in Environmental Chemistry from Emporia State University and a Master’s degree in Environmental Science from Wichita State University. Chad is responsible for the permitting and regulatory compliance of Class I and Class II disposal wells, Class III salt solution mining wells, LPG storage caverns, and Class V cavern stabilization wells.
SCS periodically prepares technical bulletins to highlight items of interest to our clients and friends. These are published on our website. This SCS Technical Bulletin addresses the Emergency Planning and Community Right-to-Know Act (EPCRA). The purpose of specific sections are consolidated and explained by SCS professionals; specifically:
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At the upcoming USWAG CCR Workshop Feb 22-23 in Arlington, VA, Steve Lamb and Floyd Cotter of SCS Engineers will present a session about the advantages and disadvantages of emerging alternative capping options, and how different regulatory agencies are viewing these options.
About this Session: Traditional final cover and capping design for coal combustion residual (CCR) surface impoundments and landfills have included compacted soil liner, geomembrane liner, drainage layer, and a vegetative soil cover. But coal-fired plants oftentimes don’t have the large volumes of soil that it takes to implement these options.
Alternative capping options have recently emerged in the industry such as exposed geomembrane liners or synthetic turf/geomembrane liner systems. Some of these alternative capping options have many advantages over their traditional counterparts. These advantages include faster installation times, minimal need for soil, improved storm water quality, and reduced maintenance and post-closure costs. For surface impoundments, alternative capping designs can also greatly reduce the amount of disturbance of the existing CCR material within the impoundment.
About Steve Lamb: Steve Lamb, PE provides SCS with over 27 years of experience in solid and hazardous waste management, environmental engineering, civil engineering, hydrology and hydraulics, landfill engineering, remedial design, and regulatory compliance. Mr. Lamb is a Vice President and director of SCS’s Charlotte, NC office.
About Floyd Cotter: Floyd Cotter specializes in solid waste management projects. His project work involves all areas of solid waste management including planning, permitting, transportation, landfill design, construction, and monitoring. Mr. Cotter is also experienced in general civil engineering, construction oversight, environmental site assessments, closure and post-closure plans, and permit and contract document preparation.
“Dave Hostetter sets the example of how an honorable, dynamic, and experienced engineer acts at SCS,” said Paul Mandeville, Senior Vice President and Director of SCS’s offices on the east coast. “Dave serves as a model of what young professionals and students should strive to become in their professional careers; we are very proud of him.”
Dave Hostetter, a recent graduate of the SAME DC Post’s 2015 Leadership Lab was honored to receive the Society of American Military Engineers Honorable Mention for Outstanding Contributions by Young Civilian Member. Dave is a registered professional engineer, a LEED Accredited Professional (LEED AP) through the U.S. Green Building Council, and a Certified Energy Manager (CEM) at SCS Engineers.
Throughout his career he has focused on three things: using his engineering skills to make a difference in the world, serving his clients wholeheartedly, and mentoring others. These guiding principles have led him through many fields of engineering from HVAC and plumbing engineering to energy engineering to landfill gas engineering to controls system engineering.
From 2012 to 2013 Dave was the site project manager for a large retro-commissioning project of two hospitals in the Veterans Integrated Service Network (VISN) 3. More than 1,500,000 square feet of building space were retro-commissioned. Throughout this project, he worked diligently to identify hundreds of issues with the building HVAC systems and create recommendations for each one. His recommendations were projected to save the VA approximately $200,000 / year and have an average payback period of approximately 0.2 years.
In 2016 Dave engineered and installed a unique environmental monitoring system for a client at a port in New Jersey. The client had an air monitoring program which required them to monitor the air quality at six different points around the port on a daily basis. Their original process was time-consuming and was, therefore expensive. Dave engineered and installed a system of wireless sensors which communicate air monitoring data back to an online database. This online database allows the client to view current and historical data, it automatically generates a daily summary report, and it sends out alarms when one of the measured parameters exceeds its alarm setpoint. This new system has reduced the client’s expenditure on labor, saved costs and resources, and increased their ability to understand and respond to the results from their environmental monitoring system.
Dave mentors other young professionals at SCS by involving them in real life hands-on engineering projects. These projects include some sort of equipment installation or troubleshooting work which allows the young engineers to actually see how things are installed, ask good questions on how things work, get face-to-face time with a senior level engineer, and learn valuable lessons on risk and safety management in specific situations.
Dave’s expertise was developed as the result of SCS professionals taking the time to mentor him in the same manner, and his goal is to pass the learning technique and knowledge on to others.
Dave lives the SCS Engineers mission statement to:
Clients trust him for his honest and comprehensive approach to their challenges. Dave takes ownership of his work and puts in the time and effort to deliver excellent results and maintain a great relationship with his clients.
Congratulations, Dave!
The Society of American Military Engineers recognized SCS Engineers for their 15 years of service and volunteer support at the District of Columbia post this month. The award was presented by Commander Craig Clutts of the US Navy, the Outgoing DC Post President.
On hand to receive the award for SCS was John Tabella, PG, LEED AP®, National Expert for Environmental Due Diligence and for Federal Services; Heather Blake (pictured), Federal Marketing Coordinator, and Dave Hostetter, PE, LEED AP®, and CEM at SCS Engineers.
SCS Engineers has a very long track record of solving environmental and energy management, solid waste, hazardous waste, water, and air compliance challenges. Approaches we pioneered include risk-based cleanups, voluntary cleanups, accelerated investigations, presumptive and sustainable remedies, environmental management systems, energy systems, and waste minimization. These approaches are at the forefront of local and Federal environmental and energy programs today.
SCS provides professional engineering and scientific services with a focus on environmental protection and conservation of resources. Our clients come back because we find practical approaches to even the most complex environmental challenges.
SCS’s environmental services supporting COMM22, a mixed-use, mixed-income redevelopment project in San Diego will be recognized at Environmental Industry Summit XV
When the Environmental Business Journal (EBJ) presents its 19th annual Business Achievement awards this March, SCS Engineers will receive an award of Project Merit: Redevelopment, for its investigation and design program for COMM22, a multi-family residential development by BRIDGE Housing.
COMM22 is a mixed-use, mixed-income, transit-oriented development built on a former bus maintenance facility. SCS addressed several issues including underground storage tanks and the testing of fill soils. The firm’s pre-construction characterization and three-dimensional data analysis resulted in time and budget savings.
“Our remediation effort on this property ensured that human health and the environment were protected as cost-effectively as possible,” said Dan Johnson, vice president of SCS. “Affordable housing is important to San Diego communities and we applaud the work of BRIDGE Housing and the collaboration it takes to create urban projects like this.”
BRIDGE Housing Corporation, a leading nonprofit developer of affordable housing, creates and manages a range of high-quality, affordable homes for working families and seniors. Since it was founded in 1983, BRIDGE has participated in the development of over 16,000 homes in California and the Pacific Northwest.
More award-winning redevelopment projects of interest:
Petco Park and East Redevelopment – San Diego
Emerald Ridge Homes – East Alton
NFL Stadium Site – Los Angeles
Commercial Real Estate Transactions blog
