Pollution Engineering - September 2008 - (Page 41)

SPCC N DO By MERRILL E. BISHOP president, , Trans Environmental Systems Tra ans or many corporate directors and top management, July 1, 2009, is still a long ways away. But for their environmental staff, that date looms with an immediacy that, frustratingly, top management may not yet perceive as being significant. However, when that day arrives, the impact of the anticipated re-enforcement of the often delayed Spill Prevention, Containment and Countermeasures (SPCC) regulations could mean a lot more for those who waited. Though corporations operating prior to August 2002 are supposedly operating under a current SPCC plan, very little enforcement is evident to the industries who are involved with transporting, or the shipping and receiving of commodities that are listed as “oil or oil products” as defined by the Department of Transportation (DOT). A recent rewriting, in 2004, of the SPCC directive excused some industries, while others are currently negotiating or have filed suit to get exempt or special treatment. EPA staff have asked for comments on items that seem confusing to the industries from the 40 CFR 112 directive. They have received many comments. One of TA AI TW ’ the unpublished items of discussion is the apparent turf battle with the DOT over who controls what, and when does the jurisdiction over prevention and control of spills become the EPA’s responsibility. The demarcation line gets fuzzy when a railroad locomotive unhooks a tank car on one of their own spur tracks, and a new company now attaches a hose to unload it, but not into a fixed, nearby tank farm facility. Too often, it appears that petro-chemical and oil shippers are preoccupied with what the EPA might do to them while ignoring or turning a blind eye to the impact that prior and future accidental releases might have on the total company’s financial future. But if there’s one lesson that previous environmental controls have taught this industry, it’s that eventually, “out of sight and out of mind” almost never flies. Many companies have ignored earlier releases that were slowly migrating downgradient in the groundwater. As more public or private sampling occurs, sooner or later, such pollution streams are often detected. Each year, thousands of environmental managers say “we have no accidental releases here,” and each year, thousands of incidents of chemical and oil pollution of the groundwater are reported or discovered. With each SEE ND While the federal SPCC regulations aren’t scheduled to take effect until next July, the deadline for industries to seriously be thinking about controlling spills is long past. F These specially designed collection pans will contain any materials falling from the bottom of the vehicles. passing year, the cost of cleanup increases. Why control before it’s regulated? Even though these SPCC regulations have been withdrawn for rewriting many times, most enterprises already understand that any 41 SEPTEMBER2008 www.pollutionengineering.com http://www.pollutionengineering.com

Table of Contents Feed for the Digital Edition of Pollution Engineering - September 2008

Pollution Engineering - September 2008 Contents The Editor’s Desk Reader Comments EnviroNews PE Events Legal Lookout Environmental Management The Green Files Guest Dialog 500-Year Storm Control How Do You Clean Up 100 Years of Pollution? SPCC: Don’t Wait and See The Next Wave in Air Purification An Invitation to the Windy City Flood Control Infrastructure Saves ‘Green’ Puts a New Spin on Pest Control Instrumentation Products Material Safety and Storage Equipment PE Products Classified Marketplace Advertisers Index State Rules

Pollution Engineering - September 2008

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