ACT CASE STUDY

Veterans Administration

ACT Safe, LLC provided Spill Prevention, Control & Countermeasure Plan and Hazardous Waste Contingency Plan for the Veterans Administration September 2016 – April 2017 at its Sioux Falls, South Dakota location.

Prevention is the best medicine.

PROJECT OVERVIEW:
  • Mobilized a Registered Professional Engineer / Environmental Scientist to project site.

  • Prepared a site sketch to show facility features including regulated oil storage, piping, buildings, secondary containments, fencing, lighting, and apparent drainage. Site sketches included hazardous waste storage locations, spill response equipment, and fire protection equipment.

  • Quantified oil storage in USTs/ASTs and other regulated oil storage (55 gallons and greater). Established appropriate standards for required UST/AST integrity testing and brittle fracture evaluation. Identified cathodic protection, inventory methods and frequency, type and location of piping/supports, etc.

  • Compared size of existing secondary containment and unloading/loading basins with SPCC required capacity, including allowances for precipitation.

  • Compared site to state UST/AST rules (i.e. registration, secondary containment, inventory, cathodic protection, overfill).

  • Reviewed previous oil spill history of the site, including state spills lists and federal Emergency Response Notification System database.

  • Reviewed facility drainage, and spill prediction to surface water, storm sewer lines, and sanitary sewer lines. Prepared a release notification plan with phone numbers and addresses of government agencies to contact in the event of a release. Developed a contingency plan for response to spills.

  • Compared existing security, lighting, fencing, signs, caps (on pipes), and locks (on valves or controls) to SPCC requirements. Identified record keeping requirements such as product inventory/reconciliation, facility inspections, water discharge, personnel training, and integrity testing. Established procedures for facility unloading and loading.

  • Prepared a written SPCC plan, including example forms (inspection, water discharge, inventory), and a certification of the applicability of the substantial harm criteria. The SPCC Plan incorporated hazardous waste management provisions that are sufficient to comply with the requirements of the Contingency Plan and Emergency Procedures.