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.

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.

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.

Intervention of spills and leaks I’ve had a spill or

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

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.

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.

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.”

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

Responsibility once a release of a hazardous substance occursPart 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.

What does this mean to me? In layperson’s 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.

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.

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.

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.

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).

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.

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.