In March 2015, Brent crude oil prices hovered around $50 per barrel, while West Texas Intermediate (WTI) crude fell to nearly $40 per barrel. The drastic price decline continues to pressure oil-related companies to re-evaluate operating expenses, administer headcount reductions, and rationalize budget cuts. The combination of pricing, demand, and production levels has inventory levels at their highest levels since May 1985 (US Energy Information Administration). With infrastructures at capacity and potential budget cuts aimed at stretching operating costs, EHS departments, safety managers, and response experts cannot afford to sacrifice oil spill contingency planning and preparedness elements that address a worst case spill scenario.
The benefits of oil spill contingency planning, preparedness, and response process optimization far outweigh the risks and costs associated with non-compliance or a worst case discharge. EHS departments must prioritize planning and response exercises, as they are necessary to satisfy applicable regulatory requirements, protect the environment, and ensure the best possible safety scenario for responders and employees.
Responding to a worst case spill is a dynamic scenario with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. Yet, all plans related to oil spills, regardless of the volume, have one common thread: to minimize impact. As profits margins are stressed, companies must ensure that risks and hazards remain mitigated through compliance, preparedness, and effective response planning.
Local, state and federal regulatory agencies often require varied site information depending on particular oil-related operations and locations. This information may be required in the form of a site-specific oil spill contingency plan. Contingency planning looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill. Contingency planning should provide procedural details, or a “game plan” that addresses various spill scenarios and situations.
Despite complexity and varied nature, a well-designed contingency plan should be easy to follow. Facilities must ensure that their spill contingency plan outlines the necessary procedures for before, during, and after an emergency. Although the plans can be vastly different, they typically have four major elements in common:
- Hazard identification
- Vulnerability analysis
- Risk assessment
- Response actions
Hazard Identification: Numerous varied criteria, such as location, climate, severe weather potential, operations, logistics, equipment, spill trajectory, or facility dynamics, can create situations that can affect the ability of response personnel to contain and clean up a spill. These hazards should be identified and processes put in place to counteract challenges caused by each specific situation. It may be possible for certain identified hazards to be mitigated, essentially eliminating the hazard altogether.
Vulnerability Analysis: It is critical to identify and provide detailed information regarding area social, natural, and economic resources that may be compromised or destroyed if a spill were to occur. This information regarding these non-facility related entities in the path of a spill or response, should guide response personnel to make reasonable, well-informed response actions to protect public health and the environment. Vulnerability analysis information should include the following:
- List of socio-economically sensitivities such as schools, nursing homes, hospitals, etc. and individual point of contact for each facility
- Lists of public safety agencies/officials in adjacent and nearby communities
- Lists of large gathering or recreational areas, such as campgrounds, parks, malls, etc.
- Calendar lists of special events and point of contact
- Identification of parts of the environment that are particularly susceptible to oil or water pollution such as water sources, beaches, farms
Risk Assessment: This assessment quantifies the hazards and the vulnerabilities to address the potential impact of a spill on its surroundings. The contingency plan should address best possible spill containment measures, how to prevent certain populations or environments from exposure to oil, and what can be done to repair the damage done by the spill.
Response Actions: Employees and responders should train for and exercise their assigned spill response actions in order to minimize the hazards to human health and the environment. Stakeholders and applicable levels of government and industry should be consulted and incorporated in spill response and contingency planning. Without the full participation of personnel, responders, contractors, and government entities, a plan may lack validity, credibility, and effectiveness.