Management of Spills

1
Management of Spills Leaks

• Two areas of focus
• Prevention Taking steps to minimize the
  potential for a spill and properly maintaining
  equipment to eliminate leaks.
• Intervention Reporting and responding properly
  to a spill once it occurs.

2
Prevention of Spills and Leaks

• Inspection and replacement of hydraulic hoses and
  fittings on a regular basis.
• Maintenance of equipment at the shop before
  heading to the job site.
• Development and documentation of a maintenance
  program for each piece of equipment.
• Proper management and design of staging or
  fueling areas.

3
Prevention (cont.)

• Maintaining a readily available spill kit at the
  job site or with each piece of equipment.
• Regular training of equipment operators and other
  personnel as necessary as to proper response
  actions when a spill occurs.These last two are
  included because they will help to limit or
  control a spill.

4
Intervention of spills and leaks

• Ive had a spill or leak of a polluting material
  such as hydraulic fluid, diesel fuel, or motor
  oil. Now what?

5
TIME OUT!

• Before we look at how to respond to a spill we
  need to define what they are and what Michigan
  law says about them.

6
NREPA

• The Natural Resources and Environmental
  Protection Act, PA 451 of 1994 provides the
  statutory requirements for addressing a spill.
  
• A spill as we know it according to Part 201 of
  NREPA is defined as a RELEASE.

7
Definition of a Release.

• any spilling, leaking, pumping, pouring,
  emitting, emptying, discharging, injecting,
  escaping, leaching, dumping, or disposing of a
  hazardous substance into the environment, or the
  abandonment or discarding of barrels, containers,
  and or other closed receptacles containing a
  hazardous substance.

8
What is a Hazardous Substance?

• Hazardous substance as defined under
  Comprehensive Environmental Response,
  Compensation, and Liability Act (CERCLA)
• Hazardous waste as defined under Part 111
  (Hazardous Waste Mgt.)
• Petroleum as described in Part 213
• Any other substances the DEQ demonstrates pose a
  threat to human health or the environment

9
Responsibility once a release of a hazardous
substance occurs

• Part 201 of NREPA says in part
• (c) Immediately stop or prevent the release at
  the source.
• (d) Immediately implement source control or
  removal measures to remove or contain hazardous
  substances that are released after the effective
  date of the 1995 amendments to this section if
  those measures are technically practical, cost
  effective, and provide protection to the
  environment. At a facility where hazardous
  substances are released after the effective date
  of the 1995 amendments to this section, and those
  hazardous substances have not affected
  groundwater but are likely to, groundwater
  contamination shall be prevented if it can be
  prevented by measures that are technically
  practical, cost effective, and provide protection
  to the environment.
• (e) Immediately identify and eliminate any threat
  of fire or explosion or any direct contact
  hazards.
• (f) Immediately initiate removal of a hazardous
  substance that is in a liquid phase, that is not
  dissolved in water, and that has been released.

10
What does this mean to me?

• In laypersons terms it means if you have a spill
  (release) of a hazardous substance (petroleum
  product such as hydraulic fluid, diesel, motor
  oil, grease, gasoline, etc.) you are responsible
  to stop it and then clean it up.
• Most spills from logging operations are minor
  in nature. Minor spills do not mean that you do
  not have to respond.
• There is not a set quantity which requires no
  further action.

11
Response Actions to Address a Release

• These can vary based on situation at hand and
  severity or sensitivity of release.
• Example Ten gallons of hydraulic fluid spraying
  all over tree limbs and bark on an upland site
  vs. the same amount flowing into a sensitive
  wetland area.

12
Response Actions (cont.)

• Appropriate response actions include
• Utilization of a spill kit to contain, absorb,
  control a release.
• Shoveling up stained soils and placing them in a
  container for disposal at a licensed Type II
  landfill.
• Placing absorbents pads on a pond or stream that
  is contaminated with petroleum.

13
Response Actions (cont.)

• Placing drips pans under equipment with leaks
  that are waiting for repairs or replacement
  parts.
• Notifying the DNR forester who is responsible for
  you job of the release.
• Notifying the DEQ when the release can not be
  easily contained and cleaned up.

14
Response Actions (cont.)

• Inappropriate response actions include
• Pushing soil over top of a release with the blade
  of the equipment.
• Pulling tree tops onto an area where a release
  occurred.
• Ignoring that the release occurred.
• Ignoring equipment that is causing an ongoing
  release (defective equipment).

15
Some No Brainers

• Do not drain used motor oil directly onto the
  ground. This is a misdemeanor under Part 167 of
  NREPA.
• Do not discard oil containers or other trash into
  the woods.
• Do not perform routine maintenance or fueling in
  sensitive environmental areas or buffer strips.

16
How to Contact the

• If a release is large enough or involves
  sensitive environmental areas you should contact
  the DEQ.
• Pollution Emergency Alerting System (PEAS) for
  after hours and weekends. 1-800-292-4706
• Local DEQ office during normal working hours.