I was recently undergoing some continuing education training at Rutgers University, when a comment the instructor made in passing caught my attention.
He’s an old pro, a veteran of a public utility. He said that contamination and releases are “lazy.” The rest of the group kind of looked at him strangely. But I caught on right away.
You might think this is good news… that lazy releases mean you don’t have anything to worry about. However, it’s the opposite.Here’s what he meant:
When a contaminant is released by accident, it looks for the path of least resistance. It does the least amount of “work” possible to do the greatest amount of damage to your facility. Say there’s a chemical spill – that liquid is headed straight to the nearest floor drain… and you better know where that drain discharges.
This is an issue that should keep you up night, because you probably have some lazy contamination just waiting to happen; especially if there are hazardous materials stored, handled, offloaded and/or loaded in your facility that have the potential to be spilled.
Of course, no facility is really immune; almost all have the potential for lazy contamination, as you’ll see in a moment.
The good news is these issues are generally easy to solve. To reduce, or eliminate, the potential for lazy contamination, all you have to do is identify and eliminate the paths of least resistance. And, if you take action now and put preventive measures in place, you’ll be able to avoid a potentially expensive cleanup situation.
We’ve visited many sites that feature a containment area for their storage tanks. The idea is to capture any released material from malfunctioning line connections. But too many people don’t realize these containment areas are just for emergencies in case of a release. That released material, although captured in the containment area, still needs to be removed relatively quickly.
A typical containment area is made of concrete, which is porous, if it is not properly sealed. If the released material is left sitting long enough… it follows the path of least resistance, passing right through the unsealed, porous concrete to impact the soil and potentially the groundwater underneath.
That’s just the start of potential problem areas.
Unsealed floor cracks, unsealed floor-wall joints, floor drains, and scuppers are some features we see at typical manufacturing and hazardous material storage sites. All are places where spilled contaminants could potentially leak through to soil, groundwater and/or surface water.
If there’s a spill, the material will head straight to these unprotected areas– it’s just gravity at work.
Floor cracks, floor seams and joints should all be properly sealed. As for floor drains – do you know where they discharge? Is it the sewer system… or is it really somewhere else, like an on-site pond or a septic system you are not aware of?
I would also advise you to look closely at any floor trenches or sumps at your site that are meant to capture or contain released materials. Many facilities never think to look for cracks in these trenches and sumps. Yes, it’s unpleasant. You have to clean out and inspect them routinely to find and eliminate cracks. Those are the paths of least resistance that could allow any material in that trench or sump to impact your site.
One problem area that often escapes notice can commonly be found at multifamily residential buildings, office buildings, and more; the bottom of an elevator shaft. These areas are very seldom inspected. Whenever we look at these areas for clients, we often see oily materials and water sitting in the bottom of the elevator shaft. That water quite often is groundwater making its way into the structure. So if groundwater is making its way into the bottom of your elevator shaft, the other materials found there, like the oil sludge and hydraulic oil, can make their way out of the elevator shaft and impact the soil and groundwater below your building! Again, you need routine inspections. And seal those cracks!
Another one that escapes notice but is all too common on all sorts of non-manufacturing sites: backup generators, which have become very popular in the wake of active hurricane seasons, at gas stations, grocery stores, and more.
We visited one office complex with a generator that runs on diesel fuel, which was stored in an aboveground tank next to it. Also next to the generator: a storm drain that discharges to a small stream on the property. When the vendor comes around with the fuel truck to fill up the diesel tank, guess what happens if there’s a spill if the hose is not connected properly to the tank or if the driver is not paying attention and the tank is overfilled?
It’s that lazy contamination… always finding a way to make you do the hard work.
These last two examples are a great reminder that you don’t have to be a an industrial facility to worry about these issues.
Offloading and loading areas are a major cause of concern.
A lot of times facilities will have a tanker that comes to offload material or load wastes via a remote hose transfer connection at the facility. We’ve seen too many times where material is released at this remote hose transfer connection, where the transfer hose from the tanker hooks up to the facility, maybe near an aboveground storage tank. Without proper protection and prevention measures at this connection point, you could have a big problem.
That remote hose transfer connection location should be protected from weather events with an overhang, and the area around the connection location should be bermed, creating a containment area to capture any released materials.
The simplest thing you could do right now if you’re worried about any releases during such transfer operations is to buy a couple of five-gallon buckets from Home Depot and hang one at the area where the transfer hose connects to the tanker, and hang the other bucket where the transfer hose connects to your facility. It’s a $10 investment that could save you thousands if a release occurs.
I’m willing to guarantee you have paths of least resistance at your facility where lazy contamination can cause you major problems. Your first step is to find them.
In these areas, you can do a simple exercise. Simply spill water and see where it flows because that's where any released liquid will go.
Then seal floor drains – or make sure you know where they discharge. Seal floor cracks, seams and joints. Put berms across doorway thresholds. Have your spill kits handy (and fully stocked), where they will be needed. Stop letting material find the easy way out of your facility into the environment. A small investment in this now will save you big time by preventing costly cleanup efforts.
The trick is that most of these problem areas are hard to see. They are hard for you and your crew to spot because you’re so familiar with your facility.
It takes an outside trained eye to spot these paths of least resistance, which we also call Invisible Environmental Gorillas.
We’ve worked with so many facilities at Envision Environmental, Inc., we know exactly what to look for. Call me now at (609) 208-1885 or email me at markroman@envisionenvironmental.com to schedule a phone consultation so I can tell you more about our Gorilla Evaluation Services.
