SSCI Environmental

Founded in 1986, SSCI specializes in enhancing the environment through its sound solutions approach. “Getting the job done is priority number one, not prolonging our participation,” says Helen I. Hodges, President and CEO.

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Protect yourself with a certified SPCC

If your company maintains a total aboveground oil storage capacity of greater than 1,320 gallons, or a total underground oil storage capacity of greater than 42,000 gallons located where there is a “reasonable potential” for a discharge to reach navigable waters, your company is subject to Spill Prevention Control and Countermeasure (SPCC) regulations. The U.S. Environmental Protection Agency (EPA) requires SPCC plans in an attempt to prevent oil from entering navigable waters and adjourning shorelines, which can have a costly impact on the environment and your financial bottom line.

Of note: Aboveground storage containers with a capacity of 55-gallons or more are included in the aboveground capacity threshold calculation. Underground storage tanks regulated under 40 CFR 280 and 281 are not subject to the SPCC regulations. Neither are operations that exist to move oil from one location to another.

Oil of any type and in any form is covered, including petroleum, fuel oil, sludge, oil refuse, oil mixed with wastes other than dredged spoil, fats, oils or greases of animal, fish, or marine mammal origin, vegetable oils and other oils and greases such as synthetic and mineral oils.

The trick can be determining whether or not your storage containers possess the “reasonable potential” for a discharge to reach navigable waters.” When determining that, consider:

  • The geography and location of your facility relative to nearby navigable waters such as streams, creeks and other waterways
  • Whether ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams
  • The estimated volume of oil that could be spilled in an incident and how that oil might drain or flow from your facility and the soil conditions or geographic features that might affect the flow toward waterways
  • Whether precipitation runoff could transport oil into navigable waters or adjoining shorelines

You should not take into account manmade features such as dikes, equipment, or other structures that might prevent, contain, hinder, or restrain the flow of oil. Assume those features are not present when making your determination.

If you consider the factors described above and determine a spill can reasonably flow to a waterway, then you must comply with the SPCC rule by developing and implementing an SPCC plan.

Prepare and implement an SPCC plan that describes oil handling operations, spill prevention practices, discharge or drainage controls, and the personnel, equipment and resources used at the facility to prevent oil spills from reaching navigable waters or adjoining shorelines. Each company’s SPCC plan needs to be unique and specific to that company. But, some elements must be describe in every plan:

  • Operating procedures at the facility to prevent oil spills
  • Control measures (such as secondary containment) installed to prevent oil spills from entering navigable waters or adjoining shorelines
  • Countermeasures to contain, cleanup, and mitigate the effects of an oil spill that has impacted navigable waters or adjoining shorelines

Every SPCC plan must be prepared in accordance with good engineering practices. Preparation of the SPCC plan is the responsibility of the facility owner or operator. Unless you meet certain criteria that allows for self-certification, your SPCC plan must be certified by a licensed professional engineer. The engineer will confirm the plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards, and with the requirements of the rule; procedures for required inspections and testing have been established; and the SPCC plan is adequate for the facility.

No matter who certifies your SPCC Plan, remember that ultimately the owner or operator is responsible for complying with the rule. A copy of the rule is available at www.epa.gov/oilspill.

If your company needs assistance with creating, updating or implementing its SPCC plan, SSCI can help. We’ve written or updated SPCC plans for a variety of client types, including more than 320 plans for the Texas Department of Transportation facilities.

Spill-prevention tips

A significant part of your SPCC plan will be focused on oil spill prevention. Here are some tips on how to do that:

  • Use containers suitable for the oil stored
  • Provide overfill prevention for your oil storage containers. You could use a high-level alarm or audible vent
  • Provide sized secondary containment for bulk storage containers, such as a dike or a remote impoundment. The containment needs to hold the full capacity of the container, plus possible rainfall. The dike may be constructed of earth or concrete. A double-walled tank may also suffice
  • Provide general secondary containment to catch the most likely oil spill where you transfer oil to and from containers and for mobile re-fuelers and tanker trucks
  • Periodically inspect and test pipes and containers. You need to visually inspect aboveground pipes and oil containers according to industry standards. Buried pipes need to be leak tested when they are installed or repaired. Include a written record of inspections in the plan

Have a plan in case of hazards

The federal government requires all companies that have hazards in the workplace – and who doesn’t? – have a proper Health & Safety Plan (HASP). Every company that has more than 10 employees is required to have at minimum a written Emergency Action Plan and Fire Prevention Plan. For more hazardous activities, OSHA requires companies to have their own individual hazard plan. For example, if employees are working more than six feet above the ground for any reason or any duration, your company must have Fall Protection.

HASPs set a standard for employees to follow and work by and allow for discipline and enforcement if employees aren’t adhering to the practices. More than that, a HASP shows your employees that you’re committed to their safety.

It’s essential to keep your HASP updated to address today’s hazards. After all, you don’t want to be cited by OSHA because that plan you worked so hard on is out of date.

But creating a plan that meets OSHA standards can be complex. That’s where SSCI can come in.

We’ve written HASPs for government entities, small firms and companies with 500 employees. SSCI employees don’t just sit in the office and write about safety theories; we work onsite with construction companies. Because of that, we’re uniquely qualified to create and implement HASPs.

SSCI has also provided consulting services for companies with OSHA violations and aided in the abatement of those violations. That’s experience that can really help you out of a tough situation – or help you avoid one altogether.

SSCI offers several levels of HASP services:

  • We can do a safety audit of your workplace, which includes a review of your HASP and recommendations on how to strengthen it.
  • Since most plans require at least an annual update, we can review and update your plan.
  • We can create a brand new, from-scratch plan unique to your company. This starts with a meeting to determine which written plans are mandatory.
  • We can train your employees in the new plan. Or we can help you do it in-house, saving you the expense of a full day of training.
  • After writing your plan, we can do a six-month (or sooner) quality-assurance/quality-control check-up to ensure implementation is going smoothly.

If you need a HASP, or your HASP needs updated, we can give you a FREE consultation.

Who you hire to do your environmental site assessments matters

Since the passage of the Superfund Cleanup Acceleration Act of 1998, anyone interested in selling, buying or financing a commercial property is encouraged or required to have an environmental site assessment (ESA) performed to uncover evidence of environmental site contamination. To obtain Innocent Landowner status, the buyer must assure that the Phase I ESA meets the specific requirements  of ASTM E1527-13: Standard Practice for Environmental Assessments: Phase I Environmental Site Assessment Process. If there’s indication of contamination, a Phase II environmental investigation is used to determine the presence, or absence of, petroleum products or hazardous waste in the subsurface of the site.

Doing an assessment is a good idea, besides:  cleaning up a site can be costly, and site contamination is a possible liability for all parties — the buyers, sellers and lenders. The assessment lets a buyer know what he’s getting into.

And, who you hire to do the assessment is important.

For example, when a small city bought two tracts of land for construction of a new amateur athletic complex, the tracts were environmentally clean — supposedly. A Phase I ESA hadn’t cited any need to conduct subsurface investigations or further inquiry.  The property was purchased and development begun.

But when construction started, it became clear that the previous ESA had overlooked obvious past uses and contaminants. The construction crew found piping, appurtenances and evidence of stained soil.

The City turned to SSCI to help it re-assess the site and properly document the condition of the site. SSCI had already worked with other cities, as well as counties, municipal facilities, universities and schools, TxDOT, TxDPS and other agencies and companies.

SSCI did a visual site inspection, reviewed records, interviewed past owners and neighbors and took soil samples. SSCI’s Phase II ESA projects must be performed to comply with ASTM E1903-11 Standard Guide for Environmental Site Assessments: Phase II Environmental Site Assessment Process standard, in addition to each client’s specific needs.

SSCI found extensive evidence of historical oilfield activity. Sample results revealed significant concentrations of hydrocarbon-contaminated soils. Near-surface hydrocarbon contamination was found to be associated with former oil-field-related aboveground tank batteries and underground pipes.

Because SSCI was able to properly classify the waste as oilfield waste subject to Railroad Commission (RRC) of Texas rules that allow higher closure levels, the City was able to close the site to RRC requirements, saving tax payers time and money.

The City used the findings to develop a plan for remediation. Following TCEQ and RRC review and approval, the City accepted SSCI’s proposal for closure.

Contaminated soil was excavated and removed. Old pipelines associated with the prior oilfield development were also excavated and removed. A NORM (Naturally Occurring Radioactive Materials) survey was performed to ensure that all underground pipes and surface soils were free of regulated quantities of NORM. The athletic complex was constructed as planned.

Unfortunately in this case, the City incurred unexpected expenses and delays because pre-purchase investigations lacked thoroughness. Innocent landowner status and smooth-moving projects start out with a proper ESA that will discover and gauge the extent of contamination, if any. For developers as well as government entities, that first step is essential to protecting their commercial investment, never mind their legal requirements.

Scope of Phase I ESA
  • General Site Inspection
  • Review of Site Records and Activities
  • Regulatory Records Research
  • Title and Historical Records Search
  • Facility / Site Inspection
  • Knowledgeable Individual Interviews
  • Geologic evaluation
Scope of Phase II ESA
  • Asbestos and Lead-Based Paint Surveys
  • Extended Records Review
  • Detailed Land Use Evaluation
  • On-Site Sampling and Analysis of Soil and Groundwater
  • Water and Building Materials Sampling
  • Operations Review

 

“Isolated wetlands” as we know them might be changing

Isolated Wetlands

Last year, the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers jointly proposed expanding the interpretation of “isolated wetlands.” The proposed rule is designed to clarify issues raised in Supreme Court decisions that created uncertainty over the definition of jurisdictional waters under the Clear Water Act (CWA). The proposed changes would expand the range of waters that fall under federal jurisdiction.

If the broadening of the definition happens, developers will see increased regulation of properties with isolated wetlands. Some previously “exempt” properties will require permits and more acres of mitigation might be required for full development. On the other hand, if wetlands are left as is (avoiding a permit), less land will be available for development.

Whatever the outcome, it’s important that developers be proactive in meeting CWA requirements, including Section 401 (water quality certification), Section 402 (storm water compliance) and Section 404 permit requirements. Being proactive means hiring competent professionals and actively engaging with the environmental regulatory community in a dialogue from the beginning. Careful planning and patience during development of initial project concepts and/or proposed site selection will prevent many permitting surprises.

Some background: The basic premise of Section 404 of the Clean Water Act stipulates that “isolated wetlands” are subject to U.S. Army Corps of Engineers permitting requirements. If the development activity could affect offsite waters, the act of filling isolated wetlands may still be under the Corps’ jurisdiction because the activity may establish a significant commerce nexus and/or connect the isolated wetlands to nearby offsite navigable waters. The key is to determine if wetlands and/or waters are truly isolated.

Examples of the most common items used to establish a hydrologic connection are presented below. This list is by no means exhaustive, as caveats and special conditions exist for each site.

  1. Are the wetlands located within the 100-year flood plain? If yes, the wetlands are usually jurisdictional.
  2. Do the wetlands lie adjacent to, or are they connected to a river, stream, or intermittent stream? If yes, the wetlands are jurisdictional.
  3. Are the wetlands connected to one of the other types of waters listed in the above items? If yes, the wetlands are jurisdictional.
  4. Are the wetlands part of a “surface tributary system,” a continuum of wetlands or what appears to be a manmade drainage ditch that is hydrologically connected to a downstream navigable water? If yes, the wetlands may be jurisdictional.

Condition number four catches many developers off guard. “How can wetlands be considered jurisdictional solely because they are connected to a manmade drainage system?” they often ask.

Because many of the man-made drainage systems are rerouted/rechannelized historic waters of the United States, they remain within CWA jurisdiction. The water flows from the wetland into a drainage ditch and eventually into navigable waters. Hydrologic connection has been established, meaning the wetlands are likely jurisdictional.

Some history before we march into the future

On June 30, 1989, SSCI specialized in closing nonhazardous oilfield waste pits in Louisiana, a business model that took advantage of a government mandate that those pits be dealt with. The next day, Helen Hodges took over and expanded our services to include consulting and a range of environmental remediation activities.

That kicked off a thriving 25 years for SSCI.

Helen, who’d run small businesses enterprises since she was in grade school, brought both technical and business expertise. She had earned her bachelor’s degree in physical sciences from San Jose University, a master’s degree in chemistry from the University of Idaho and an MBA from the University of Chicago. Then she’d worked for a national laboratory and an energy consulting company before she and her family bought SSCI.

Helen insisted SSCI focus on the client, seeing it as the company’s job to look out for the customer. SSCI wouldn’t worry about the next job or where that job will come from – great work and a stellar reputation would take care of that – which means SSCI isn’t looking for ancillary services to sell to clients. “Getting the job done is priority number one, not prolonging our participation,” Helen said.

The blend of environmental consulting and remediation work has kept us busy and growing, even when one side of the business slowed down. Over time, our project management services offerings have grown.

Because we’re constantly watching what’s happening in the environmental services industry and bringing new, thoroughly tested innovations to environmental site and risk assessments, underground storage tank management, soil and groundwater remediation design and implementation, hazardous and nonhazardous waste disposal, asbestos and lead surveys, spill response plan design, and wetlands delineation and training, we bring the latest best practices to bear on each project.

That, combined with personnel who believe in a strong team focus, quality work and innovation, has led to steady success as SSCI has become one of the most honored women-owned companies in Texas.

But that’s our history. At SSCI, we don’t rest on our laurels. We’re constantly looking forward.

Today marks another significant milestone in SSCI’s existence: the installation of a blog and social media updates to keep you informed of new developments not just within SSCI, but also with environmental remediation initiatives and environmental issues.

Come back each month – we’ve got plenty of stories to tell. And connect with us on LinkedIn, follow us on Twitter or like us on Facebook to get regular semi-weekly updates and to engage us in lively debates.

We look forward to having a dialogue, and a long-term relationship, with you.