Environmental Audits for Grain Operations

by Teresa Acklin
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Environmental pollution has become a major issue around the world, and grain handling operations have attracted increasingly close scrutiny from environmental regulators in many countries. At the 1996 conference of the Grain Elevator and Processing Society, Loren Polak, environmental compliance officer for Bunge Corp., St. Louis, Missouri, U.S., explained how grain facility managers can protect themselves and their companies against future environmental headaches — and potentially massive expenses — by checking their facilities and taking corrective actions. This article is an excerpt from his presentation.

   What is an environmental audit? The U.S. regulatory definition of environmental auditing is “a systematic, documented, periodic and objective review by regulated entities of facility operations and practices related to meeting environmental requirements.” A second definition, probably more meaningful to grain facility managers and operators, is simply “an environmental evaluation process.”

   An environmental self-audit at a grain facility is an evaluation process that attempts to determine whether the facility is meeting environmental requirements and to identify and minimize environmental liabilities. The first objective of the environmental self-audit is to check facility operations to confirm that applicable environmental regulations and internal company procedures, policies and objectives are being met.

   The second objective is to identify and minimize the facility's long-term environmental liabilities, which are primarily actual or potential soil and ground water contamination. This effort is focused on determining whether soil and ground water contamination may have occurred in the past, is occurring in the present or could occur in the future.

Why Perform Environmental Self-Audits?

   In the United States, businesses annually spend hundreds of millions of dollars cleaning up soils and ground water that have been contaminated because of previous environmental practices. Additional hundreds of millions of dollars are spent in penalties for failing to comply with current environmental requirements. If developed properly, environmental auditing can be valuable in identifying areas where improvements are needed and can assist the company in operating at a higher level of compliance, with reduced liabilities and reduced long-term environmental costs.

   Environmental self-audits are performed by grain facility managers. The self-audit allows the manager to better identify environmental risks and noncompliance before those situations worsen or are scrutinized by environmental regulatory agencies.

   Self-audits can save money by quickly prompting action that helps minimize cleanups, fines, legal fees and other costs related to violations of environmental regulations or contamination of the soil and ground water. By learning just a few of the items that should be included in an environmental self-audit, a grain facility operator can meet many of the environmental auditing objectives.

   For example, the manager does not need an advanced degree in environmental engineering to realize that the grain dryer fuel oil storage tank has overfilled and many gallons of fuel oil have spilled on the ground around the tank. But he may not consider the possibility that the soil and ground water may become contaminated, requiring many thousands of dollars to clean up.

How Are Self-Audits Performed?

   Some of the items included in an environmental self-audit are often addressed in grain facility operational inspections. This is particularly true of environmental items that directly influence the operation of the facility.

   But several environmental items do not have a direct or immediate impact on facility operations and may be ignored. Let's explore some of the items that need to be included in the environmental self-audit.

   Air pollution control equipment includes cyclones, baghouses and enclosures to prevent the release of dust particulates into the air. This equipment needs to be included in any grain elevator environmental self-audit, and most grain facility managers are well aware of the environmental and safety reasons for regularly checking air pollution control equipment.

   The aspiration ducts and hoods should be checked to confirm they are not plugged and have adequate air flow, and fans and motors should be checked to determine whether any mechanical or electrical maintenance is needed. Fabric filter baghouses, cyclones and bag cleaning mechanisms should be checked to confirm they are operating within design specifications.

   Wastewater treatment equipment such as aeration lagoons, activated sludge systems or septic tanks need to be included in the environmental self-audit. The operational and maintenance components of the systems should be checked, including pumps and piping, aeration systems, settling tanks and sludge handling systems.

   Points of storm water runoff also should be examined. It is important to prevent storm water pollution by minimizing runoff of grain, grain dust, spilled oils and chemicals. A good housekeeping program is an effective method of minimizing storm water contamination.

   All present and past storage and piping systems for pesticides and fumigants should be included in the self-audit. It is especially important to review current and historical systems associated with grain fumigants that contained carbon tetrachloride, which was commonly used as a grain fumigant until approximately 1985. Carbon tetrachloride, along with other chlorinated hydrocarbon chemicals such as chloroform, trichloroethylene and perchloroethylene have proven to be major soil and ground water contaminants that are very difficult to clean up.

   Carbon tetrachloride has been found in ground water at numerous U.S. grain elevators. Facilities where the fumigant was stored in tanks are especially prone to environmental contamination.

   If a grain elevator facility has old storage tanks or piping that may still contain carbon tetrachloride, it is important to have them emptied and thoroughly cleaned out. If the grain elevator facility has previously stored carbon tetrachloride in tanks and has on-site drinking water wells, it also is prudent to have the water checked to confirm that the water is safe to drink.

   Storage and use locations of all other pesticides, such as malathion and methyl bromide, also should included in the self-audit. All storage locations should be kept dry, locked and clearly labeled.

   Aluminum phosphide is currently a commonly used grain fumigant that does not present as great a potential for environmental contamination as some other pesticides. Nevertheless, environmental protection measures should be taken, such as returning empty flasks or other containers to the supplier or thoroughly cleaning the used containers before disposal. Also, storage locations should be clearly labeled.

   The environmental self-audit needs to include electrical transformers and capacitors to confirm that they do not contain PCB dielectric or PCB contaminated dielectric.

   In the U.S., regulations require the removal of all PCB transformers that have the potential of exposure to food or grain. PCB contaminated transformers should also be removed if they have a potential of contaminating grain or feed. For example, if a PCB contaminated transformer or capacitor could contaminate the grain either directly or indirectly, such as on truck tires that enter a grain unloading area, it should be eliminated.

   If a transformer does not contain a label that identifies it as a non-PCB transformer, it must be assumed that it is a PCB contaminated transformer. Electrical transformers are classified into the following PCB concentration categories:

   • PCB transformer: greater than 500 parts per million PCB

   • PCB contaminated transformer: 50 to 500 ppm PCB

   • Non-PCB transformer: less than 50 ppm PCB.

   If there is any doubt as to the concentration of PCBs in transformers or capacitors, it is prudent to confirm they are non-PCB. If a transformer is owned by an electrical utility company, the first step is to contact the utility to determine the PCB status of the transformer.

Oil and Chemicals

   Gasoline and fuel oil storage tanks should be included in the environmental self-audit, as petroleum contains several toxic chemicals that are well known as soil and ground water contaminants.

   If the storage tanks are above ground, leaks or overfilled tanks should be obvious. If leakage or spillage is apparent, it should be cleaned up, and petroleum-contaminated soil should be removed and disposed of properly.

   Do not ignore leaks and spills. Over time, they can result in environmental contamination that can be very expensive to clean up. Leaking pipe fittings, hoses and other components need to be quickly repaired.

   If you have spill containment structures around tanks and piping, make sure containment drain valves are securely closed, plugged or locked. Do not allow rain water to accumulate in the spill containment structures. If your above ground tank has been provided with an integral “tank within a tank” arrangement, it is important to check the interstitial space to confirm that leakage from the inner tank has not occurred.

   If you have underground fuel oil or gasoline storage tanks and piping, it is more difficult — but also more important — to confirm that they are not leaking. Some tanks systems include corrosion protection, spill and overflow prevention devices, monitoring and leak detection.

   Other tanks require measures to prevent spills and leaks. A systemic inventory or tank measuring system can be used to help detect a leak, and tanks suspected of leaking can be pressure tested.

   In addition to storage tanks, efforts should be taken to prevent oil spills and leaks in other areas. Some common areas at a grain elevator facility that should be checked for petroleum oil leaks or spills include the truck dump hydraulic systems, maintenance shops and areas where oil is stored.

   Efforts to prevent spills and leaks could include improving maintenance programs to repair leaky hoses or pipes, developing greater precautionary measures to prevent spills or providing spill containment such as drip pans. Whenever petroleum oil spills or leaks have occurred on soil, surface water or ground water, it is important to remove and dispose of the contaminated element as quickly as possible.

   Used oil collection and storage areas also should be included in the environmental self-audit. Used oil must never be dumped on the ground or into storm water drains.

   Tanks, drums and other containers that receive and store used oil need to be marked “Used Oil.” No former markings or labels should be visible. Containers should be in good condition, and drum lids should be in place to prevent spills and leaks.

   Areas where chemical products and wastes are used, handled or stored should be included in the environmental self-audit. These products include paints and paint solvents, maintenance cleaning solvents, caustic cleaners, lubricants and lead-acid batteries.

   Inspection should include all areas where these items may be stored or handled as products or wastes, such as maintenance shop buildings, repair areas, scrap dumps and loading and unloading locations. It is important to check for leakage, spillage, handling practices and proximity to wells, drainage ditches, storm sewers and adjacent property. Look for evidence of prior spills and discharges.

   Many waste paints, paint solvents, maintenance cleaning solvents and chemica1 product wastes are classified as hazardous wastes and need to be disposed as hazardous wastes. Usually, spent maintenance cleaning solvents can be shipped to a solvent recycling facility.

   Empty drums and containers are another audit point. It is important to completely empty drums and containers because they will often contain small quantities of their original contents.

   The best procedure is to manage empty containers as if they were full. Residual drum contents should not be spilled on the ground, and lids should remain in place so that rain water does not enter. The addition of rain water creates a wastewater mixture in an empty container that can be difficult and costly to dispose of properly.

   Empty drums should not be dumped in the back corner of the property to rust away. It is best to make arrangements to return empty drums to the supplier or to send them to a reputable scrap dealer or drum reconditioner.

On-Site Areas

   Historically, grain elevators often had on-site dump pits, burn pits and other disposal areas. These areas could be a source of environmental contamination, and it is important to include them in the self-audit.

   The types and approximate quantities of wastes that were disposed need to be determined as accurately as possible. If the self-audit reveals that substantial quantities of hazardous substances were disposed on-site, it is prudent to determine whether the ground water is contaminated.

   Today, the disposal of solid waste is highly regulated in many countries, and most wastes are not allowed to be disposed of on-site. It is important to check with environmental agencies before burying or burning any solid wastes.

   Existing on-site water wells should be included in the self-audit, especially if the wells are used to supply water for human consumption or other domestic uses. The quality of the well water needs to be determined and tested periodically to confirm that it meets relevant drinking water standards. If the self-audit identifies the potential for hazardous substance contamination, the well water should be tested to confirm that the concentrations of those hazardous substances do not exceed drinking water standards.

   If the facility has abandoned water wells, it is important to confirm that they have been closed and plugged in accordance with requirements.

   The environmental self-auditor needs to be critically observant of several other environmental identifiers. For example, bare or discolored ground surface areas may indicate the presence of buried wastes or other underground contamination. A vertical pipe protruding a short distance above the ground surface may indicate the presence of an underground tank or piping system.

   The source of fill dirt that has been brought from an off-site location should be determined to confirm it did not come from an environmentally contaminated site. The past uses of the grain facility property also should be reviewed to identify any previous activities that could have involved the use of chemicals or the disposal of wastes. A check of possible asbestos-containing materials also should be included in the self-audit, especially where vessel, pipe and building insulation is located.

   Environmental contamination does not respect property lines, so the possible environmental influence of surrounding properties also needs to be considered when performing the self-audit.

   Do neighboring activities include the use and storage of petroleum or chemical products? Have surrounding properties been used as disposal sites? Do the neighbors have underground tanks, and if underground tanks were removed, were any contaminants present? Have nearby properties been the subject of environmental cleanup efforts?

   The last aspect of the environmental self-audit is paperwork. It is important to determine the status of facility environmental permits and all records that are required by the environmental permits.

   Waste disposal and waste recycling shipment records also must be kept, especially for hazardous wastes, used oils, spent solvents, etc. Records documenting the proper removal and closure of underground storage tanks also need to be maintained.

   These and any other environmental records should be reviewed periodically by the grain elevator manager to ensure that they are current and are readily available for future reference.

   Any type of environmental audit program is not free from risk. A grain company's decision to initiate environmental self-auditing should not be handled with a cavalier attitude and should be reviewed with the company's legal counsel.

   An environmental self-audit can lead to the discovery of violations of which the company had no knowledge. The audit may also discover discharges of hazardous substances or wastes that may trigger an obligation to notify environmental agencies, which could lead to mandated investigations and cleanups.

   Although environmental audits have some potential risks, overall, the advantages outweigh the disadvantages. Even if an audit reveals contamination or compliance deficiencies, it is far better to identify the problems early rather than have them mushroom into bigger problems later that may be far more serious to a grain company's bottom line.