LSC EHS Consulting Services, LLC

Environmental & Safety Blog Page

An ongoing series of informational entries

Stormwater Management

28 September 2019 

Over the years, we have heard about companies having issues with stormwater pollution and how many cities and states are implementing higher fines. However, most people don't see or understand the consequences of stormwater pollution.

More than ever, I hear what stormwater pollution is? What are some of the potential sources for this environmental hazard? What are the benefits of an effective stormwater runoff management plan?

What is stormwater pollution?

Stormwater pollution is a consequence of stormwater runoff. Generally, we get our most prominent contribution to stormwater runoff from rain and snowmelt. During these events, the water flows overland and impervious surfaces and doesn't have adequate time to soak into the ground. As stormwater runoff passes over these surfaces, it picks up trash, chemical residue, oils, and sediment and channels them to rivers, streams, lakes, wetlands, and coastal waters.

What are some potential sources for stormwater pollution?

The most common causes of stormwater pollution are municipal separate storm sewer systems (MS4), construction activities, and industrial activities. Since these are the most common methods, states require companies and organizations to obtain an NPDES (National Pollutant Discharge Elimination System) permit before any discharges. In hindsight, the NPDES program addresses water pollution by regulating point source discharges to any WOS (Waters of the State).

What are the benefits of an effective stormwater runoff management plan?

As we continue to see population growth and even economic development, we will continue to see changes in hydrology and the modification of water quality, leading to habitat loss and alteration. A good stormwater runoff management plan will assist in the protection of vital aquatic ecosystems. Furthermore, this will improve the upstream and downstream quality for any receiving waterbody, improve on necessary water conservation, protect the health and well fair of the public, and reduce chances for flood control impacts.

Excavation & Trenching: Basic Information

4 April 2020

In the construction industry, it never fails that we must conduct trenching and excavation work. However, we know that trenching and excavation work is one of the most severe hazards that our workers are involved in doing. In hindsight, one cubic yard of soil can equal to the weight of a car (approx. 3000-5000 lbs). Employers have to have a system in place that will ensure that their workers entering a trench has adequate protections that will address cave-in hazards. Furthermore, there is a potential for hazardous atmospheres and mobile equipment.

What are excavations and trenches?

If we look at this from a military aspect, excavation is a human-made cut: while a trench is a depression in the ground that is formed by the removal of earth. However, in layman’s terms, an evacuation is nothing more than excavation that is deeper than it is wide. Furthermore, home foundation or basements are exempt from 29 CFR 1926 Subpart P unless the following items do not exist:

· No water, tension cracks, or other environmental conditions are noted that may reduce the overall stability of the excavation.

· Horizontal width at the base of the excavation is as wide as practical yet not less than 2 feet.

· The presents of heavy equipment is voided that could cause vibration to the excavation during employee presents

· The foundation/basement has a depth lower 7.5 or is benched to a minimum of 2 ft horizontal at every 5 ft or less of vertical height.

· Surcharge (soil, equipment, and material) must not be closer than 2 ft.

What is a Competent Person

To comply with the specifications of being a competent person per OSHA, the employee must be someone who is capable of recognizing actual and certain hazards in the surroundings or working conditions which are unsanitary, unsafe, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them. This person has vital inspection oversight when it comes to excavations. Additional duties are:

· Clear and open communication with all personnel responsible for the excavation operations;

· Determination of the appropriate protective systems based on the conditions at the excavation site, including trench depth and width, soil conditions, etc.;

· Monitoring of all employees entering the excavation to ensure proper training in hazards and recognition, work practices, protective measures, and emergency response;

· Ongoing inspections of the excavation and adjacent areas;

· Atmosphere testing for potential oxygen deficiency or build-up of hazardous gases;

· Classifying soil and rock deposits, by visual analysis and testing, to determine appropriate protection; re-classifying, if necessary, based on changing conditions;

· Authorizing immediate removal of employees from hazardous areas where evidence of possible cave-in, failure of protective systems, hazardous atmospheres, or other hazardous conditions exists, until proper safety precautions are taken.

Understanding Soil Types and Complications

With many construction projects that deal with excavation and trenching: we have to understand that soil conditions vary from site to site. In part, we have a total of six soil groups and they are clay, sand, silty, peat, chalk, and loam. All of these have variations in properties thus it is important for the competent person to know these specifications.

Clay soil will have a lumpy feel to it and sticky when it's wet. However, when the clay is dry its rock hard and is very poor when it comes to draining due to lack of air space. Sandy soil is very gritty and allows water to drain fast and easily. Silty soil has a soft and soapy feel to it, and it holds moisture and highly rich in nutrients. Furthermore, silty soil provides the best means for drainage and is easy to manage. Peaty soils are dark soil that more-than-often feels damp and spongy due to high levels of peat (decomposed vegetable matter) and it is a very acidic soil type.

When we look at chalky soils you will notice that they have large grains and are generally stonier than other soil types. This soil is perfect for overlaying limestone bedrock and is very alkaline. Lastly, loamy soil is composed of sand, silt, and clay. This soil type has a fine texture and sometimes damp to the touch.

Out of all these soil types, we will still see various complications when it comes to excavation and trenches. These complications are unexpected settlement, soil sliding, and cave-ins. Through proper planning and adequate supervision, we can avoid these complications while working in excavations or trenches.

What Are Some Protection Measures

All trenches and excavations have their inherited hazards: whether it be restricted space, oxygen depletion, toxic fumes, or water accumulation. Moreover, it is important that protective systems are in place while employees are present. These measures can be achieved through sloping, shoring, or shielding.

· Sloping – when using this method at the general specification for A-type soil the slope must be ¾ to 1 for a 20’ max excavation. Yet, if a short term for A-type soil (less than 24 hrs) it must be ½ to 1 for a 12’ max excavation. When we deal with B type soil the slope must be 1 to 1 for a 20’ max for a simple slope. Finally, when we have a C type soil the simple slope is 1 ½ to 1 for 20’ max.

· Shoring – is the method of installing boards or other bracing against an excavation wall. These can be completed through the installation of a post, screw jack, or hydraulic cylinder.

· Shielding – In this method the use of trench boxes to prevent soil from caving-in.

· Benching – this method prevents excavations from caving-in and this method cannot be used in Type C soils.

Hazardous Waste: Humble Beginnings

12 January 2020

Hazardous waste was pretty foreign when I started in this field. I was a young Private First Class (E-3) in the U.S. Army: when I became aware of this subject matter at first. We had just finished up a live fire mission at Rodriguez Live Fire Range in South Korea, and we returned to the unit motor pool with a 55-gallon drum of waste JP8 (Jet Propellant 8/jet fuel) and some used HEM-239 HEMTT Fuel Filters.

I went to the supply sergeant and asked what the method for disposal was, and he sent me to the U.S. Army Garrison Humphreys Environmental Divison to discuss the handoff process for our hazardous waste. I can say I was nervous because I didn’t know what to expect at the time: however, I got there, and the personnel was very open to sharing the requirements and any additional information that I had questions on the subject matter.

It was at that point that I wanted to pursue the matter further. I stayed up late reading countless hours of Hazardous Waste regulations for training requirements, response requirements, transportation requirements, and disposal requirements ( I know: Oh my GOSH, you are a nerd.)

What Is Hazardous Waste

The first definition of Hazardous waste that I ever read was in Army Regulation 200-1. The regulation stated that hazardous waste was a waste that is dangerous or potentially harmful to our health or the environment; furthermore, hazardous wastes can be liquids, solids, gases, or sludges.

Low and behold, when I looked at the definition from the Environmental Protection Agency, had the same explanation: yet the Department of Transportation was significantly different. The DOT defined hazardous waste products or articles or substances that are capable of posing a significant risk to health, safety, or property when transported by air, rail, ground, or sea. (See 49 CFR 171.8)

Who Governs It and the Requirements

I started to dig into the governing bodies that have a hand in regulating hazardous waste. Simply because you would think that it was only one organization; yet, that was wrong.

The first organization is the Environmental Protection Agency. The EPA governs hazardous waste through the Resource Conservation and Recovery Act: which became an act in 1976. This Act governed how we handled hazardous waste, non-hazardous waste, and other RCRA matters (i.e., underground storage tanks, management of used oil, etc.)

Secondly, when it comes to training, the Department of Labor: Occupational Safety and Health Administration showed us how to train individuals in 1910.120. In this regulation, OSHA tells us that if a company has a spill at its site, personnel must be prepared to at least the 40-hour or 24-hour level to respond to the spill. The 40-hour training is for workers handling “hazardous substance deportation or other activities which disclose or potentially disclose workers to health peril. The 24-hour training is for employees who are unlikely to be disclosed to concentrations above permissible exposure limits and published exposure limits (” in the NIOSH hand guide.

Now that we know the regulation and training requirements, how do we transport these items? Interesting to say, the Hazardous Materials Transportation Act of 1975 and the Hazardous Materials Regulation regulates the transportation of hazardous materials; however, the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) helps to regulate the tenacious movement of hazardous waste to ensure that it diminishes perils to life, property, and the environment due to relatable dangerous waste incidents.