Products and Processes for SPCC and VOC Regulation Compliance
Environmental protection has never been a higher priority for government agencies and industries throughout the United States. Businesses from coast to coast are altering their processes and upgrading their equipment to ensure compliance with governing bodies like the Environmental Protection Agency (EPA) on issues such as volatile organic compounds (VOCs) and spill prevention, control, and countermeasures (SPCCs). Both VOC regulations and SPCC regulations have seen enhanced enforcement in recent years, along with incentivization through state and federal regulations to help promote green practices.
Energy-saving, recycling, and VOC conservation programs are growing in prevalence. Read below to learn how different industries have acted on air and ground-water protection policies and have modified their processes using equipment specifically designed to reduce environmental contaminants.
VOC Containment Systems
The control of volatile organic compounds has been a concern in this country for decades and has been mandated for the past 20 years through VOC regulations. The Clean Air Act of 1990 created standards to protect public health by requiring sources to control emissions from hazardous air pollutants. EPA regulates these standards as charged in CFR 40 pan 63.
The release of VOCs must be controlled, even in small quantities. Following are examples of how organizations in the aerospace and furniture industries are complying with these regulations and developing their own volatile organic compound management plans to mitigate VOC exposure.
VOC Containment Processes in the Aerospace Industry
A major airline received multiple EPA citations for violations of the following sections of Subpart GG: National Emission Standards for Aerospace Manufacturing and Rework Facilities (NESAM).
- Section 63.741- Designation of Affected Sources: (1)(i) All hand wipe cleaning operations constitute an affected source.
- Section 63.742 - Definitions: Cleaning operation means collectively hand wipe, spray gun, and flush-cleaning operations. Hand wipe cleaning operation means the removal of contaminants such as dirt, grease, oil, and coatings from an aerospace vehicle or component by physically rubbing it with a material such as a rag, paper, or cotton swab that has been moistened with a cleaning solvent. Cleaning solvent means a liquid material used for hand wiping, a spray gun, or flush-cleaning. Aerospace facility means any facility that produces, reworks, or repairs in any amount any commercial, civil, or military aerospace vehicle or component.
- Section 63.744 - Cleaning Operations Standards: (a) Housekeeping measures.
- (1) Place solvent-laden cloth, paper, or any other absorbent applicators used for cleaning aerospace vehicles or components in bags or other closed containers immediately after use. Ensure that these bags and containers are kept closed at all times except when depositing or removing these materials from the container. Use bags and containers of such design to contain the vapors of the cleaning solvent.
- (2) Store fresh and spent cleaning solvents used in aerospace cleaning operations in closed containers.
In order to meet these VOC containment requirements, a portable, benchtop solvent can was modified to include a spring-loaded, gasketed, self-closing lid. Existing equipment was also modified to achieve protection against vapor emissions from drums containing solvent-soaked swabs or cloths. Standard drum covers were redesigned, eliminating the fusible link mechanism. New covers are gasketed and equipped with a latch and come in either manual or self-latching styles. The resulting equipment now contains VOCs to the standards set forth in VOC regulations.
VOC Containment Processes in the Furniture Industry
The furniture industry makes use of a wide variety of finishes, lacquers, and chemicals to produce the quality of furniture expected today and requires stringent VOC regulations to keep environmental contamination at a minimum. Furniture industry VOC regulations include: 40 CFR Parts 9 and 63 - Final Standards for Hazardous Air Pollutant Emissions from Wood Furniture Manufacturing Operations; Final Rule, Section 63.803 Work practice standards, (g) Storage requirements. Each owner or operator of an affected source shall use normally closed containers for storing finishing, gluing, cleaning, and wash off materials.
A special mixing can was developed to meet the VOC containment system regulations noted above. The new mixing can meets the EPA 40 CFR 63.803 (g) and EPA requirements for limiting VHAP (Volatile Hazardous Air Pollutants) emissions while providing the same safe-guards of the safety can for the Storage of Flammable and Combustible Liquids per OSHA 29 CPR 1910.106 to safely relieve internal pressure in the event of a fire.
Disposing of spent aerosol cans can be hazardous in any industry. Residual gas or product creates a pressure that must be relieved without VOC emission to the atmosphere. Designation for aerosols requires businesses to recycle or properly dispose of them as hazardous waste. A system is available to change spent aerosols from solid hazardous waste to a non-hazardous waste state. The Aerosolv360® Aerosol Can Recycling System safely punctures and empties aerosol cans of their contents into a separate container, leaving the owner with ready to recycle scrap metal.
Spill Prevention, Control, and Countermeasures
The SPCC rule requires owners or operators of onshore and offshore facilities to prepare and implement a plan for the prevention of oil spills. Spill containment plans and secondary containment regulations are of the utmost importance; A spill of only one gallon of oil can contaminate one million gallons of water. Oil spills include both petroleum oils and non-petroleum oils.
Under the authority of the Federal Water Pollution Control Act and the Clean Water Act, the rule requires the demonstration of consideration for secondary containment solutions for containers 55 gallons and larger. Each secondary containment unit must:
- Hold the entire capacity of the largest container.
- Have sufficient freeboard to hold precipitation.
- Freeboard: the vertical distance to the lowest point of overflow.
- Adequate freeboard needs to be determined by the owner, operator, or engineer as outlined in their plan.
- Pallets that are sheltered do not require a freeboard to hold precipitation. This would be implied under "good engineering practices."
In February of 2009, the EPA fined an Oklahoma oil company for violating this SPCC regulation. Among the irregularities cited was inadequate secondary containment of storage areas. Mobile or portable storage containers were not positioned to prevent discharged oil from reaching waterways. Secondary containment equipment is available to help companies in this industry meet these environmental objectives, including spill pallets and accumulation platforms that comply with secondary containment requirements.
Products for Reduced Environmental Contamination
Another way many companies are reducing their environmental footprint is by purchasing eco-friendly products. Manufacturers are stepping up their green efforts by offering products made of recycled materials or eliminating from products materials that are harmful to the environment. Consider this: one ton of this recycled material saves 163 barrels of oil (that's 685 gallons), 5,774 kWh of electricity, and 30 cubic yards of landfill space.
Organizations such as UL Environment are available to validate green claims covering a variety of products. An independent validation provides customers with greater confidence in this claim than when only endorsed by the manufacturer.
Plan for a Greener Future
Whether your business is primarily considered with VOC emissions or SPCC compliance, there are steps you can take toward reduced environmental contamination. Audit your existing exposures. Record where exposures exist and analyze each problem situation. Search for solutions - check the Internet, libraries, and vendors' literature. Justrite can also serve as an excellent resource for environmental contaminant containment products, offering a line of products that can be applied in a diverse array of industries. To find products that your team can utilize to mitigate VOC exposure and meet SPCC requirements, you can browse the Justrite website or contact our experts.
Fitting, Fabrication, and Welding Areas
Fabrication and welding are integral parts of the construction process, but they are potentially dangerous without proper safety equipment. When transporting gas cylinders on site, it is important to utilize a gas cylinder cart to avoid injury or damage to the cylinder itself. For storage when not in use, we recommend either a gas cylinder cabinet or pallet dedicated to their safe storage.
Active Construction Area
Active construction areas are the single most dangerous setting in the construction industry and can require numerous different safety materials throughout construction to mitigate the risk of injury or death. Whenever small quantities of fuel are being transported or used on-site, it is vital to utilize an appropriate safety can. For greater ease of use and accuracy when pouring, we recommend the Type II safety can.
When storing fuel or other potentially dangerous liquids on site, it is crucial to have the appropriate safety cabinet available for safe storage when not in use. In addition to safety cans and cabinets, it can also be beneficial to be equipped with a form of secondary containment. The ideal form of secondary containment will vary depending on the setting and circumstances, but Justrite provides spill containment pallets, berms, and absorbents for the safe containment of spills on site.
While specific needs will vary depending on the job site and the scope of work undertaken, you might also find that your site requires waste disposal containers, gas cylinder lockers, aerosol can disposal systems, and many others to ensure smooth operations and regulatory compliance.
The Right Safety Equipment for Your Construction Company
Justrite has been recognized as an industry leader in safety equipment for more than 100 years, and we supply construction companies and job sites all over the world with the products they need to keep crews and contractors safe. Justrite carries numerous products that would be of benefit in many different construction settings. No matter what you need, we are confident that we will be able to help.