Thursday, February 22, 2018

Most Common Problems With Secondary Containment

Common Problems With Secondary Containment

Missing Secondary Containment

Fuel Tank Without Containment Or Proper Support
Fuel Tank Without Containment Or Proper Support

Fuel Loading Area Without Drainage Control
Fuel Loading Area Without Secondary Containment

Leaking Used Oil Storage tank Observed During Phase I Facility Inspection
Leaking Used Oil Storage AST Observed During
Facility Inspection

Inadequate Volume Containment

Phase I Environmental Inspection Finds Leaking Tanks And Pumps In Refueling Area
Environmental Inspection Finds Leaking Tanks
And Pumps In Refueling Area

Wrong Material

Bulk Fuel Storage With Hay Bale Secondary Containment Observed During SPCC Audit
Bulk Fuel Storage With Hay Bale
Secondary Containment

Missing or Inadequate Maintenance

Broken Secondary Containment Wall Identified During SWPPP inspection
Cracked Secondary Containment Wall Identified
During SPCC Inspection


Damaged Oil Storage Containment

This photo shows an example of a Leaking Waste Solvent Hazardous Waste Tank identified during a hazardous waste inspection
Leaking Waste Solvent Hazardous Waste Tank


 

Caltha LLP | Your Stormwater Permit, 
SWPPP and Spill Plan Partner

Monday, February 19, 2018

Reducing Zinc In Stormwater Discharge Where Does Zinc Come From?

Zinc From Galvanized Metal And Dust

Many facilities required to monitor metal concentrations under their industrial stormwater permit have found high levels of zinc in their stormwater discharges. Work conducted by the State of Washington found the major sources of zinc were galvanized materials, particularly on roof surfaces, as well as motor oil and hydraulic fluid accumulated on parking areas, loading docks, and paved grounds. Tire dust in areas with high volumes of trucks and forklifts may also be an important source. Zinc concentrations in runoff from roofs with galvanized ductwork were about 10-fold greater than found from the roofs without galvanized materials.

Zinc From Oil and Hydraulic Fluid Leaks and Spills

Both motor oil and hydraulic fluid contain high concentrations of zinc, about 0.1% by weight. As an example, as little as ½ cup of motor oil spilled on a small paved parking lot could result in 250 µg/L of zinc in runoff during a small rain event.

Can Hydraulic System On Trash Compactor Leak?
Leaking Hydraulic System On Trash Compactor  


Contaminated Soil From Improper Used Oil Drum Storage identified during a facility environmental inspection
Contaminated Soil From Improper Used Oil Drum Storage

 Caltha LLP provides expert technical support to facilities that need to reduce pollutants in stormwater discharge. For further information go to Caltha Stormwater Compliance and Permitting Page.


    SWPPP and stormwater pollution prevention plans
Caltha LLP | Your Pollution Prevention Partner

Friday, February 16, 2018

Construction SWPPP And Contractor SWPPP Training, Spill Training

Caltha LLP Project Summary

Project: Construction Stormwater Permitting, SWPPP & Contractor Training 
Client: National Home Builder
Location(s): Minnesota

Key Elements: Stormwater permitting, SWPPP, Inspection training, Spill Control Plan

Overview: Caltha LLP was retained by a national home builder/developer to provide technical services required for a 8-ac single family home development. Caltha staff prepared the project stormwater pollution prevention plan (SWPPP), erosion control plan, spill control plan and then completed the permit application materials. Once permitted, Caltha staff provided SWPPP training to all site inspectors and subcontractors.


  SWPPP and Solid Waste Controls At Large Residential Construction Project
SWPPP and SWPPP Training For Residential Site Construction

For more information on Caltha LLP construction stormwater services, go to the Caltha Storm water Permitting and Compliance Page


   
Caltha LLP | Your Stormwater Permit, SWPPP 
and Spill Plan Partner

Friday, February 9, 2018

Contracting For SWPPP Inspections Stormwater Inspections

Caltha LLP provides SWPPP Inspection  and Annual Comprehensive Facility Inspection services to industrial facilities and construction sites regulated under State General Permits for stormwater discharge. Inspections are conducted by certified stormwater inspectorscertified hazardous material managers or certified environmental compliance auditors.

What Are Storm Water Inspection Requirements ?

The frequency of SWPPP inspections will vary from State to State, but for industrial sites inspections are generally conducted monthly or quarterly. In some cases, one or two inspections may have to be completed during a rainfall event. For construction sites, generally weekly inspections are required, and special inspections after significant rainfall events. In addition, most industrial permits will require an Annual Comprehensive Facility Compliance Inspection, which also reviews overall permit compliance records, such as training.


  This photo shows an example of Leaking Waste Solvent Drums contaminating soil and groundwater near the property line
Leaking Waste Solvent Drums
Along Property Line

Why Contract Your SWPPP Inspections?

Contracting to have inspections conducted by Caltha ensures that inspections will be conducted by certified professionals to meet the inspection requirements of your discharge permit. This also frees facility staff from the responsibility of making sure inspections are done on time and eliminates the need for specialized training of facility staff assigned to conduct inspections.

Request a Quote For SWPPP Inspection Services

Caltha provides routine weekly, monthly or quarterly SWPPP inspection services and Annual Comprehensive Facility Compliance Inspection.

To request a quote, go to the Caltha Contact Page.


    
Caltha LLP | Your Stormwater Permit, SWPPP 
and Spill Plan Partner

Contract SPCC Inspections, Tank Inspections

Caltha LLP provides SPCC Inspection services to facilities regulated under the Federal SPCC Rule (40 CFR 112). Inspections are conducted by certified hazardous material managers or certified environmental compliance auditors.

What Are Facility Inspection Requirements Under SPCC Rule?

The SPCC Rule requires that at a minimum monthly inspections be conducted and documented. Various provisions of the SPCC rule relate to the inspection, evaluation, and testing of containers, associated piping, and other oil-containing equipment. Different requirements apply to different types of equipment, oil, and facilities. The requirements are generally aimed at preventing discharges of oil caused by leaks, corrosion, brittle fracture, overfill, or other forms of container or equipment failure by ensuring that containers used to store oil have the necessary physical integrity for continued oil storage. The requirements are also aimed at detecting container and equipment failures (such as pinhole leaks) before they can become significant and result in a discharge as described in §112.1(b). For certain above ground tanks, these monthly inspections can be used in lieu of more extensive tank inspections and integrity testing by a certified tank inspector.



Cracked Secondary Containment
Dike Around Oil Tank


Why Contract Your SPCC Inspections?

Contacting to have inspections conducted by Caltha ensures that inspections will be conducted by certified professionals to meet the SPCC Rule. This also frees facility staff from the responsibility of making sure inspections are done on time and eliminates the need for specialized training of facility staff assigned to conduct inspections.

Request a Quote For SPCC Inspection Services

To request a quote, go to the Caltha Contact Page.


  
Caltha LLP | Your SPCC Compliance, 
Auditing and EMS/SMS Partner

Wednesday, January 31, 2018

Do Electric Transformers Need To Be In SWPPP and SPCC Plan?

Electric transformers are found at almost every larger commercial, institutional and industrial facility. Sometimes this equipment is owned by the facility owner and sometimes by the power company. For some facilities, it is not always clearly understood who owns and is responsible for transformers.

Can Electric Transformers Leak Oil?

Yes, electric transformers can leak oil, but only if they actually contain oil.

How Can I Tell If Electric Transformer Contains Oil?

For newer transformers, the quantity of oil in the unit is usually found on the label. For older equipment, this information may not be on the label, or the label may have been removed or is illegible. In this case, a visual inspection of the equipment by a knowledgeable person can usually determine if it contains oil or not.     Not sure?   Send Caltha a photo and we may be able to determine this - send to info@calthacompany.com

Who Is Responsible To Clean Up Leaks From Transformers?

This will depend on State laws. In general, the Owner of the equipment is responsible. However, for a property owner whose property has been impacted by a leaking transformer, the issue could affect the value of the property and they may voluntarily elect to clean up leaks.

What Are The Environmental Risks For Electric Transformers?

A risk for oil spills exists for any oil-filled transformer. Older transformers commonly contained PCB oils. Use of PCB oils has been phased out and newer equipment is often labeled "No PBC"; however older electric transformers could still contain PCBs which makes clean up more involved.

Leaks can occur over long periods and accumulate slowly. The other risk is an emergency spill caused by a fire or the transformer being damaged by vehicles, etc. These risks are minimized by ensuring equipment is included in pollution prevention plans and spill plans (such as SWPPP, SPCC Plan or other spill plans) and is regularly inspected and maintained.

Typical Leaking Electric Transformer

Sunday, January 28, 2018

Action On Waters of US At Supreme Court

On January 22, 2018, the Supreme Court unanimously decided a procedural issue determining the court in which challenges to the meaning of the term “Waters of the United States” (WOTUS) may be brought. The choice of court is significant because it affects the resources needed to litigate the merits of challenges, sets the statute of limitations for filing lawsuits and helps determine whether actions can be challenged in subsequent civil or criminal proceedings.

Immediate Impact of Waters of US Decision

The decision requires that any challenge to the current meaning of WOTUS must be brought in the federal district court rather than in the federal court of appeals and allowed pending litigation in the district courts to continue. Lifting the stay puts the Obama-era WOTUS definition back into effect and forces any future litigation to occur throughout the United States wherever there is a challenge to the WOTUS definition, unless it is able to get a stay in the pending litigation.

Why is Waters of the US Definition Important?

WOTUS is a key term impacting the scope of Clean Water Act. The EPA and Corps of Engineers issued the definition in May 2015. The rule was widely criticized, with many, such as farmers, home builders, and developers, claiming that the rule impermissibly allowed EPA to regulate private land. Others felt the rule narrowed federal jurisdiction. In the Supreme Court, the current Administration argued that any challenges to the meaning of WOTUS must be brought in a court of appeals; this argument was rejected in the court decision.

Under the Clean Water Act, the uncertainty as to the scope of the WOTUS rule affects whether a Federal discharge permit (NPDES permit) is required and the scope of permits needed to discharge wastewater and storm water. It also impacts whether real estate contains federally-regulated wetlands.