Pollution Engineering - The Consequential Cost of Carelessness

The Consequential Cost of CarelessnessBy GLEN CARTER

Properly handling liquid hazardous wastes may not be rewarding but it can save a ton of money.

In December 2010, the EPA announced that in the 2010 fiscal year they "took enforcement actions that require polluter to pay more than $110 million in civil penalties." 1n that time the agency' criminal enforcement program opened 346 new environmental crime cases. The cases led to 289 defendants charged for allegedly committing environmental crime, the highest number in five years. One-hundred ninety-eight criminal were convicted and $41 million was assessed in fines and restitution.

The federal government can make it expensive to ignore regulations. However these costs may only be the tip of the iceberg. Any spill requires some cleanup time depending on the volume and Iocation of the occurrence. Time spent on cleanup operations is non-productive, resulting in reduced output and lower profits. When injuries occur costs quickly escalate.

Slips and falls are common when spills create slippery floors. A typical minor slip or fall accident requiring medical attention averages about 5,000 on the low side. Add to that another $2,800 for lost time and perhaps six to eight week of medical care and treatment, along with a Worker's Compensation settlement of $7,000, and it is easy to see how a simple slip quickly adds up to nearly $15,000. For more severe cases, lost time accidents can average $40,000.

Many hazardous liquid are flammable. Flammable liquids, and the release or spill of flammable vapors create a significant danger of fire. The costs from industrial and commercial fire are staggering. Indeed, government regulation are only one area on to treat hazardous liquids with respect.

Containment the key

A drum, tank or intermediate bulk container (IBC) used to store a free liquid that is considered to be hazardous must be inspected for its integrity on a regular basis. Such inspection must be properly documented as well. When found to be leaking the contents should immediately be transferred to another container. Again, make certain to document the transfer. To prevent the spread of a leaking liquid, every drum, tank or IBC must rest on a properly engineered form of containment system as required by EPA regulation 40 CFR 264.175.

A spill-containment pallet can be used to store 55-gallon drums containing hazardous liquids. This type of pallet is designed with a leak-proof sump to capture leaks from a damaged drum or a pill that might occur when filling or pumping from the drum. The pallet features a removable grate that allows easy access to the sump area to visually check if any leak has occurred and subsequent cleanup as needed. Containment pallets are available in two, three or four drum capacities. Square or space-saving linear styles are available. The containment standard is a minimum sump capacity of 66 gallons.

When specifying spill containment pallets for their facilities users also should be aware of the Spill Prevention Control and Countermeasure (SPCC) rule, which applies to facilities with 1,320 gallons or more of above ground storage or 42,000 gallons of buried storage of petroleum oils, non-petroleum oils, animal fats, oils and grease and fish oils, marine mammal oils, and vegetable oils (including oils from seeds, nuts, fruits or kernels). An owner or operator must demonstrate in their PC plans all considerations for secondary containment solutions for containers 55 gallons and larger.

Each secondary containment area shall be as follows: (1) to hold the entire capacity of the largest container and (2) to have sufficient "freeboard" to hold precipitation. Freeboard refers to the vertical distance to the lowest point of overflow. Adequate freeboard needs to be determined by the owner, the operator or their engineer as outlined in their plan. Pallets that are sheltered do not require freeboard to hold precipitation. This would be implied under good engineering practices.

Additional Green Objectives

Store acids or bases with confidence in Justrite's sturdy, completely metal-free poly cabinets

Saving oil, electricity and landfill space are additional objectives to be considered. By specifying spill control pallet constructed of recycled polyethylene, it is possible to achieve a double good impact for the environment. Not only do containment pallet protect against ground water contamination; but their material of construction conserves resources and saves landfill space. Well engineered spill control products made of recycled resin have undergone an extensive review process and some suppliers have recycled content validation by a recognized third-party auditor, such as UL Environment. This independent validation assures customers that a product claiming to be green, really is; and therefore assures a positive impact on the environment.

Why the use of recycled resin? Consider this: one ton of recycled plastic saves:

  • 6.3 barrels of oil
  • 5,774 kwh of electricity
  • 30 cubic yards of landfill space

Considering these types of savings, it is no wonder the federal government, under Executive Order 13514 as signed by President Obama last October, is required to establish an integrated strategy toward sustainability. EO 13514 requires agencies to ensure that 95 percent of federal purchases, amongst other initiatives, contain recycled content.

Glen Carter chief technology officer, Justrite Manufacturing Co., is a recognized authority on flammable liquids storage and handling. He Is currently o member of the NFPA 30 Technical Committee and sits on three UL Standards Committees.

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From Pollution Engineering
June 2011