The environmental, health and safety landscape is riddled with stories of injuries, accidents, and emergencies. Some stories become headline news and others may be buried in the stacks of safety reports. Yet any incident, large or small, can impact your employees, your facilities, the surrounding environment, and your financial bottom line. While the intensity of events may vary, comprehensive, compliant, and functional response plans for each facility must be developed and maintained to address a broad scope of probable emergency and crisis situations.
Companies have an ethical and legal obligation to protect their employees while on the job. However, a response plan is only as effective as the accuracy of its information, potential emergency or crisis scenarios, and the level of responder comprehension. For facilities that store and/or utilize hazardous materials, the obligation to create a top-notch facility response plan is even greater.
The Facility Response Plan
A Facility Response Plan, which can serve as both a planning and response-guiding action document, should be easily accessible. Companies should confirm that regulatory compliance, inherent site-specific safety issues, response efforts, and human resource factors are addressed within each of their site plans. Depending on operations, a Facility Response Plan may consist of:
- Facility information, including its name, type, location, owner, operator information
- Emergency notification, equipment, personnel, and evacuation information
- Identification and analysis of potential spill hazards and previous spills
- Discussion of small, medium, and worst-case discharge scenarios and response actions
- Description of discharge detection procedures and equipment
- Detailed implementation plan for response, containment, and disposal
- Description and records of self-inspections, drills and exercises, and response training
- Diagrams of facility site plan, drainage, and evacuation plan
- Security (ex: fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)
As personnel responsibilities, facility or operational specifics change, response plans must change accordingly. At a minimum, cyclical plan maintenance is essential to capture multiple moving parts that impact an emergency management program. If a facility has a high-risk potential for a specific scenario or operations utilize hazardous materials, supplemental response plans, such as a fire pre-plan or business continuity plan, should be added to the overall emergency management program.
Small, Medium and Worst-Case
It is essential that any company that transports, stores or handles hazardous materials ensure spills are properly cleaned up to minimize environmental impacts and workers are not injured. The Environment Protection Agency (EPA) states that site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. Discharges are categorized as follows:
- Small discharge: up to 2,100 gallons spilled
- Medium: 2,100 to 36,000 gallons spilled, or 10% of the largest tank (whichever is less)
- Worst Case Discharge: Volume of the largest tank over 36,000 gallons
The source of a small, medium, and worst-case discharge may stem from various facility operations and corresponding equipment components. If the worst-case discharge falls within one of the specified ranges for small or medium discharges, a smaller facility may only need to plan for that level of response. Potential discharge scenarios can be derived from human error, equipment malfunction, third party intervention, or severe weather. Typical site components relating to discharge scenarios include, but are not limited:
- transfer hose failure
- improper or faulty hose seals
- valve failure
- misaligned piping connection or seal failure
- pump seal failure or overfill
- tank overfill or leak
- catastrophic failure of largest tank
Any spill response, despite the size of the spill, should incorporate the company defined preparedness structure and procedures. Despite the voluminous details and the nature of a spill, all employees and responders should demonstrate an understanding and application of company policies and agency requirements through an established training and exercise cycle.