Contributed by Matt Ebbert, Senior Geologist, PPM Consultants
Whether you manage environmental compliance for a steel factory, a chemical plant, the all-important widget factory, a retail petroleum station, or a commercial business, sometime during your career you will likely have a spill of a regulated substance or chemical under your watch. Do you know what needs to be done to get the spill cleaned up to protect your workers and the environment; what reporting requirements you have to federal, state, and local government entities; what to do to minimize your environmental liabilities for your organization; and to protect yourself with your company? If not, now is a good time to develop your strategies to respond to the possible release rather than to react after it occurs.
Many companies try to address the spills on their own or call the fire department. Fire departments are fantastic for putting out fires, but not all of the departments have the training to handle chemical spills and unfortunately can make the spill many times worse than calling in an expert. I cannot tell you how many times that I have seen fire departments use water to hose down a spill which then spreads the chemical or fuel across the land surface and into storm drains and surface water bodies. This alone has changed spill clean-ups from a one-day, less than $5,000 response into a multi-year assessment/remediation that costs hundreds of thousands of dollars.
To be ready for a spill, and the aftermath, it is wise to have an up-to-date spill plan, have spill response materials available and ready for use, know your regulatory requirements, and have your qualified response team identified and ready to respond. Spill plans are sometimes required by law dependent on the types and volumes of chemicals stored at your facility and they are typically called Spill Prevention Control and Countermeasure (SPCC) plans. Dependent once again on types and volumes of chemicals, these can be prepared by yourself or are required to be prepared and signed by a Professional Engineer. If your facility is not required to have a SPCC plan, it is still advisable to have a plan for your facility that identifies where chemicals are stored, how to address spills immediately, a contact list for your response team, reporting requirements, and disposal requirements for the recovered materials. PPM has extensive experience developing these plans with the owners/operators of facilities that store hundreds of chemicals to facilities that have one drum of solvents and we are ready to help you.
Reporting requirements to federal, state, and local government agencies are complex and vary significantly from one facility to another. For some agencies, there are not clearly identified reporting requirements and that is where quality environmental consultant can help you to avoid unnecessarily reporting a spill or to minimize the risk of fines if you do not report when required. Also, nine times out of ten, when something is spilled on the ground surface, the witnesses over estimate the volume spilled. Although this is a conservative way to proceed, your firm may be reporting spills to agencies that would not be required if an actual volume of material spilled was known. Once again, a qualified consultant can help you determine the actual volume spilled using various information from your facility and observations of the spill.
Time is of the essence on responding to spills to keep your facility operating, to minimize environmental impact, to minimize costs, and to protect your liabilities. Spills also tend to happen late at night, during holidays, or Friday afternoons. Therefore, you need to have a response team made up of your consultant and emergency response team that has a 24-hour call center or you know the cell phone numbers of your team. PPM has staff on call 24/7 to assist our clients with issues, when they arise. We also have a team of emergency response companies to assist if the spill involves more manpower and equipment.
Remember, proper planning can help you and your staff to respond rather than react if a spill occurs. Responding in an organized manner helps your business continue to do your business. Reacting is where costs and long-term liabilities increase and can cause disruption to your business. If you want to discuss a spill response strategy for your facility or your organization please feel free to reach out to me at matt.ebbert@ppmco.com.