According to the March 27th U.S. Energy Information Administration's weekly status report, the petroleum supply continued to rise in the first quarter of 2015. Bloomberg Energy suggested that oil inventory is approximately 25% above its 5-year average. Many petroleum storage facilities are handling near capacity volumes and should evaluate preparedness measures and oil spill response plans to ensure the hazards associated with increased oil storage volumes are accurately and effectively addressed.
Operators of oil storage facilities should review their oil spill response plans to ensure that response procedures are consistent with local topography, sensitivities, and other site-specific details. This is especially critical when tank volumes and potential spill impacts are increasing. If properly planned, exercised, and executed, plans can protect lives, communities, and the environment, and reduce the financial impact 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 spills
- 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
Through facility assessments, best practices, and responder input, effective plans should incorporate a variety of aspects and perspectives of a response. As inventories increase, it is imperative that risks and threats be re-evaluated. The following 30 questions can be used as planning discussion points to develop or review oil spill plans:
- Have high-risk activities been identified, assessed and, if possible, mitigated?
- Have sensitive areas been identified and potential consequences been assessed for the current tank volumes?
- How would a potential spill with current tank volumes affect external resources?
- Did previous risk assessments utilize realistic scenarios, current oil volumes, and potential release locations?
- Have trajectory estimates been completed for a variety of tank volumes, and do they include potential weather scenarios?
- Do trajectory maps mimic local observations and historical tendencies?
- Have trajectory-timing estimates and recovery location points been included in oil spill planning process?
- Have Safety Data Sheets been updated per OSHA regulations, and are hazardous material properties been included in the planning process?
- Have processes been established for updating planning information, tank volumes, and required response resources?
- Have plot plans and area mapping been integrated with GIS data and knowledge?
- Are sensitive sites prioritized for protection?
- Have response times and limitations been set?
- Have alternate strategies and response procedures been identified because of increased potential spill volumes?
- Is there an agreement over response strategies and priorities between personnel and responders?
- Does the planning process incorporate best practices ecological risk assessment principles?
- Have response equipment needs been re-evaluated and defined?
- Is appropriate external spill response support available and are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
- Are staff roles and responsibilities specified and communicated?
- Are personnel appropriately trained for allocated roles?
- Do plans include specific criteria for provisional tiered responses?
- Have the plans be thoroughly exercised with realistic scenarios?
- Is the response management team structure clear and able to be communicated?
- Is there an internal and external communication method established?
- Is exercise feedback incorporated into plan revisions?
- Are clear procedures in place to notify, assess, and initiate a response?
- Are communications backup systems available and described in the plan?
- How is information accessed during a response to determine size, shape, type, location, and movement of the oil?
- Are procedures in place for monitoring spill size, shape, type, location, movement, and impact
- Are waste management and demobilization processes in place and communicated?
- Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?