best practices for leak & spill control

Best Practices for Leak and Spill Control

New Pig Corporation

Bermuda Triangle of Regulations and Codes

OSHA Fire Codes

EPA

LiquidsLiquids

EPA

National Pollutant Discharge Elimination System (NPDES)– Limits water pollution through permits

– Defines oil pollution as a “sheen” on the water

– Regulates “stormwater” discharges from manufacturing facilities

– 40 CFR 122

Spill Prevention, Control, and Countermeasure (SPCC) – Monitors plans to prevent oil spills

– Defines a reportable spill as one that reaches “navigable waters”

– Regulates containers 55 gallons or larger

– 40 CFR 112

EPA Continued

Resource Conservation & Recovery Act (RCRA)

– Restricts hazardous waste collection and storage

– Defines “characteristic” and “listed” hazardous wastes

– Regulates waste oil through “ignitability” characteristic

– 40 CFR 260-265 (generator standards)

OSHA

Occupational Safety & Health Administration (OSHA)

– Inspects working conditions

– Defines safe and healthful standards

– Regulates floor conditions, storage cabinets, hazardous waste operations and emergency response

– 29 CFR 1910 (general industry standards)

Fire Codes

National Fire Protection Association (NFPA)

– An international, nonprofit membership organization

– Merged with Uniform Fire Code (UFC) in 2006

– NFPA'S 300 codes and standards influence every building, process, service, design and installation in the U.S.

– Regulated through state and local fire marshals

– NFPA 30: Flammable and Combustible Liquids Code

– UFC, Articles 74, 79, and 80

Outside Leaks & Spills

Drain Covers

Storm drains are a major entry point into US waters, which can trigger multiple violations.

Tip: Cover drains during bulk transfer as a precaution.

NPDES 40 CFR 122.26SPCC 40 CFR 112.7

Drain Filters

Sediment and oil are the twolargest stormwater pollutants fromthe industrial sector.

Remember, it only takes a sheenfor a spill to be reportable.

Tip: Install an insert below thegrate that collects both oil andsediment.

NPDES 40 CFR 122.26

Covered Storage

Weather-tight buildings expandstorage and prevent rainwater from mixing with chemicals.

Tip: Use a ramp for safe loading and unloading.

RCRA 40 CFR 264.175RCRA 40 CFR 262.34 (c) (1)NPDES 40 CFR 122.26SPCC 40 CFR 112.7

Collapsible Storage

Lightweight and transportable containment can be used for vehicles and drums.

Tip: Attaching an oil-selective filter to the discharge port keeps the sump free of rainwater accumulation.

RCRA 40 CFR 264.175SPCC 40 CFR 112.7NPDES 40 CFR 122.26

Spill RemovalSurround spill with boomsto prevent spreading.

Tip: Oil-only adsorbents will notpick up water, which reducesdisposal costs.

NPDES 40 CFR 122.26SPCC 40 CFR 112.7 (c) (1) (vii)

Inside Leaks and Spills

Loading Docks

Kits contain a variety of absorbents to address the type and quantity of spill.

Tip: Keep kit locations well marked and conduct regular inspection of contents.

OSHA 29 CFR 1910.120SPCC 40 CFR 112.7 (c) (1) (vii)

Battery Storage

Designate a specific area and provide secondary containment.

Tip: Store acid neutralizing spill kits and proper PPE nearby. Eyewash stations are required.

OSHA 29 CFR 1910.178

Leaks & Drips

Good housekeeping practices prevent slips and falls.

Tip: Non-slip footwear should have a large area of contact with a softtread and diverting channels.

Tip: Socks quickly surround and absorb.

Tip: Berms can be designed for drive over traffic.

OSHA 29 CFR 1910.22(a)

Fluid Maintenance

Effective fluid change outprocedures prevent spills.

Tip: Use flexible funnels to controlhard to reach plugs and filters.

OSHA 29 CFR 1910.22(a)NPDES 40 CFR 122.26

Fluid Dispensing

Fluid dispensing is a high risk area for both hazardous and non-hazardous spills.

Tip: Flammables should be bonded and grounded duringdispensing. Vents and faucets should be FM-approved.

OSHA 29 CFR 1910.106NFPA 30

Fluid Dispensing

Good housekeeping encouragesthe capture of leaks and drips at dispensing stations.

Tip: Make sure that the pumpseals and housing are compatiblewith the liquid being dispensed.

SPCC 40 CFR 112.7 (c)NPDES 40 CFR 122.26

Waste Collection – Solid

Reduce air pollutant emissionsfrom storage containers with continuous gasket.

Tip: Latching lids provide easyaccess for frequently opened and closed containers.

EPA 40 CFR 264.1086RCRA 40 CFR 262.34 (c) (1)NFPA 30

Waste Collection – LiquidHazardous waste can be collected in satellite accumulation drums in quantities of 55 gallons or less.

Tip: Use a funnel with integralventing and overflow preventionto reduce spills.

OSHA 29 CFR 264.1086RCRA 40 CFR 262.34 (c) (1)RCRA 40 CFR 264.173

Containment

Sump capacity should contain 10% of the volume of containersor the total volume of the largest container, whichever is greater.

Tip: Fluorinated polyethylenepallets provide greater chemical resistance.

RCRA 40 CFR 264.175SPCC 40 CFR 112.7 (c)NFPA 30

Bermuda Triangle

OSHA Fire Codes

EPA

LiquidsLiquids

Pyramid of Control

InspectionGoodHousekeeping

Products

ComplianceCompliance