In lieu of reliable data or correlation (for leak-tracking), you might have to take auger samples at various depths and analyze the soil to determine the migration. You might also consider seeking help of outside contractors who specialize in soil sampling and remediation services.
Long term, we all realize that regulatory and productivity considerations dictate that focus be directed to minimizing spill frequencies and their magnitude and proper reporting/recording mechanisms.
G.C. Shah, environmental adviser/industrial hygienist
Total Petrochemicals, Bayport, Texas
Your lab can help with identification
Having worked in the laboratory at a number of oil and chemical companies, hearing about spills in the plant is somewhat common. However, all efforts to contain them are done first in the tank farm, such as having dikes or a containment system that runoff can safely go into and be pumped out later. This is proper engineering.
When a spill occurs in which a product is not readily known, your laboratory might be able to identify it. Monitoring your waste is also a way to identify system leaks. Once in the soil, it becomes harder and samples might have to be sent to an outside laboratory. You can also trace some chemicals with industrial safety and engineering controls equipment.
Myron Crum, quality control manager
Perkins Products, Bedford Park, Ill.
Gather as much information as possible
You should begin by gathering information. Start by finding out if the suspected spill might constitute a reportable quantity (RQ). If it does, immediately notify the state EPA and begin an emergency response.
If the material does not constitute an RQ, you have a little more time to plan your response. Identify the chemical and its physical properties from the Material Safety Data Sheet (MSDS). Follow the recommendations in the Emergency Response Guide (ERG) and the MSDS. Have the night supervisor prepare a written incident report to document as many details as possible. Obtain geology reports for the area <em dash>-- the response team will eventually need them. You can keep the material from leaching deeper into the soil if it is raining by spreading poly tarps or polyethylene sheeting. If practical, dike and divert runoff to impoundment for treatment and analysis.
Contact a company that specializes in spill response and remediation. In the long term, this is the best strategy to protect the community, the environment and the company’s assets. While the spill remediation company is mobilizing a response team, it would be prudent to cordon off the suspected area. You might consider notifying neighboring businesses and local police or the fire department, and provide copies of the MSDS to all responders. Discontinue the use of all spark-producing activities if you suspect a flammable liquid was spilled. For instance, do not operate forklifts, smoke or use cell phones and two-way radios that are not intrinsically safe.
If it is safe and prudent, you can have onsite personnel don the appropriate personal protective equipment (PPE) and start investigating where the material is before the spill-response team arrives. You might try one or more of the following:
• use gas-sampling tubes or a lower explosive limit (LEL) meter to sample the air trapped beneath the
tarps if the spilled material is volatile and/or flammable;
• watch for signs of unusual behavior, distress or death in local flora and fauna, such as brown patches in the grass or dead fish in impoundment ponds; and
• look for areas where bare soil is discolored or oily slicks are present on the surface of standing water.
The material might have characteristics that make it easily identifiable. Consider the following:
• UV fluorescence and analytical dyes;
• oily materials can be identified by the way they turn brown paper translucent <em dash>-- roll out a strip of brown wrapping paper in a suspected area and walk on it;
• alcohols and other chemicals can be identified by smell; and
• animals might be attracted by, or repelled from, the odor in the area.
By the time the spill-response team arrives, you should be able to provide a more accurate identification of the extent and location of the contaminated area than if you had done nothing. After the remediation, ensure that a disinterested third party performs soil and groundwater analyses and writes a closure report. Forward the closure report to the state EPA and follow their recommendations for drilling downstream sampling wells.
This will be expensive, so be sure you take full advantage of the opportunity to provide employees with relevant training based on a thorough After Action Review of the event.
James S. Bonnell, manager, environmental services
Barr Laboratories Inc., Cincinnati
We are having continuous problems getting an accurate level reading on the crude vacuum column boot at our refinery. A consulting firm has proposed using a clean, medium oil (HVGO) flush to keep the level taps clear. However, they have no idea how much flush oil is needed, and we need to know so we can size the restriction orifices. Is there a good way to determine how much flush oil is required to keep level taps open?