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30 Questions Oil Spill Response Plans Should Reveal

Posted on Thu, Oct 18, 2012

Oil spill response planning should provide site-specific details to enhance oil spill response plans and incorporate a response perspective with specific short-term and long term actions and procedures. If properly planned, exercised, and executed in a timely and effective manner, oil spill response plans can protect lives, communities, and the environment and limit the financial burdens associated with an oil spill. 

The primary objectives of oil spill response plans are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for combating the spill at a specific location
  • Improve regulatory compliance efforts

While oil spill response plans are necessary to satisfy applicable regulatory requirements, different regulatory agency require specific plans depending the facility’s operations (oil producing, storage, or transport) and location. The Bureau of Safety and Environmental Enforcement (BSEE) is responsible for oil spill planning, preparedness, and other select response activities for facilities located seaward of the coastline.  Oil Spill Response Plans” (OSRP) are necessary to satisfy BSEE regulatory requirements for facilities in this geographic area.

“Facility Response Plans” are required by the Environmental Protection Agency (EPA) for certain oil storage facilities that store and use oil that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on navigable waters. EPA regulated facilities must submit plans that reveal details of policies and procedures to respond to a substantial threat of a discharge and a worst-case discharge. The EPA may also require ‘Spill Prevention, Control, and Countermeasure” (SPCC) plans and “Contingency Plans” depending on site location and quantity of oil at the site.

According to the EPA, a regional administrator may consider additional factors to determine if facility response plans are required. Those factors include, but are not limited to:

  • Type of transfer operations
  • Oil storage capacity
  • Lack of secondary containment
  • Proximity to fish, wildlife, and sensitive environments or drinking-water intakes
  • Spill history

Through facility assessments, best practices, and responder input, effective oil spill response plans should incorporate a variety aspects and perspectives of a response. The following 30 questions can be used as planning discussion points to develop or assess oil spill response plans:

  1. Have high-risk activities been identified, assessed and, if possible, mitigated?
  2. Have high sensitive areas been identified and potential consequences been assessed?
  3. How would a potential spill affect both internal and external resources?
  4. Did risk assessment utilize realistic scenarios to define oil volumes and release locations?
  5. Have trajectory estimates been completed and do they include potential weather scenarios?
  6. Do trajectory maps mimic local observations and historical tendencies?
  7. Have trajectory-timing estimates and recovery location points been included in oil spill planning process?
  8. Have material safety data sheets (MSDS) been updated and properties included in the planning process?
  9. Have processes been established for updating planning information prior to an emergency and during a response?
  10. Have plot plans and area mapping been integrated with GIS data and knowledge?
  11. Are sensitive sites prioritized for protection?
  12. Have response times and limitations been set?
  13. Have alternate strategies and response procedures been identified?
  14. Is there an agreement over response strategies and priorities between personnel and responders?
  15. Does the planning process incorporate best practices ecological risk assessment principles?
  16. Have response equipment needs been evaluated and defined?
  17. Is external spill response support available and are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
  18. Are staff roles and responsibilities specified and communicated?
  19. Are personnel appropriately trained for allocated roles?
  20. Do plans include specific criteria for provisional tiered responses?
  21. Have the plans be thoroughly exercised with realistic scenarios?
  22. Is the response management team structure clear and able to be communicated?
  23. Is there an internal and external communication method established?
  24. Is feedback from exercises incorporated into plan revisions?
  25. Are clear procedures in place to notify, assess and initiate a response?
  26. Are communications backup systems available and described in the plan?
  27. How is information accessed during a response to determine size, shape, type, location, and movement of the oil?
  28. Are procedures in place for monitoring spill size, shape, type, location, movement, and impact?
  29. Are waste management and demobilization processes communicated?
  30. Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?

Oil Spill response plans are an effective collaborative response tool that should be shared with contracted response groups and local authorities.  Collaborative efforts in developing and exercising the plan provides opportunities for the response community to work together as a team and develop the interpersonal relationships that can effectively promote smooth functioning during a response.

For information about SPCC Plans, download TRP Corp's free SPCC and FRP Inspections guide.

TRP - SPCC

Tags: Emergency Preparedness, SPCC, EPA, Oil Spill, Regulatory Compliance