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Identifying Sensitive Environments in the Path of an Oil Spill

Posted on Mon, Oct 17, 2011

While oil spills can effect the immediate area, migrating spills that extend beyond its containment measures can greatly affect the surrounding areas and possibly damage sensitive environments. A critical step in protecting sensitive resources is identifying the presence and types of resources that are in the likely path of an oil spill.

Analyzing possible spill trajectories through topographical features, wind speeds, and water flow rates allows planners to identify which areas are most likely to be impacted by a spill.  Once these resources have been identified, decisions need to be made as to the proper protection techniques for each locale and the priority for application of resources to each sensitive site.

Sensitive_Environments_TRP.jpgTypes of sensitive areas to evaluate include, but are not limited to:

  • Ecological: Examples of sensitive species include shore birds and other water fowl, seals and other marine mammals, shellfish, commercially important wildlife, and species with limited distribution or populations. Sensitive habitats range from protected bays with marshes and tidal flats to open coast areas used as marine mammal or bird breeding sites.
  • Cultural: Areas of direct importance to humans including, but not limited to native lands, historical land marks, waterfront parks, and recreational areas.
  • Economical: Populated areas that are highly valued because of their ability to generate income. Area’s include tourist sites, real estate developments, urban developments, marinas, parks and other locations.
  • Specific sensitive resources: Specific resources that are only available at that particular location, such as specialized suppliers, water sources, transportation systems, food sources.

Once the sensitive areas in the path of a potential oil spill are identified, tactical plans and processes should be developed to limit the duration of impact. Tactical planning provide site-specific focus to emergency response plans, and applies a response perspective with specific, short-term actions and responses. These plans provide details that allow responders to best access, assess, and quickly respond to off-site spills, limiting the effects of a spill on sensitive environments.

 

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Tags: USCG, Pipeline, OSHA HAZWOPER, Emergency Preparedness, SPCC, OPA 90, Oil Spill, Emergency Management Program, HAZWOPER

Storage Tank Fires - Emergency Planning Considerations

Posted on Mon, May 30, 2011

Emergency situations can quickly escalate if a storage tank containing flammable material catches fire. Employees need to act swiftly to limit consequences to personnel, the environment, and company assets.

The following general considerations should be taken into account when developing emergency response plan for fires involving storage tanks.  Specific characteristics of the tank, product, and available resources should be evaluated prior to implementing these procedures:

  • In the event of a fire, cease tank operations, such as filling or withdrawing product, as soon as possible to eliminate turbulence in the tank contents. These activities may be initiated at a later time as a part of the fire fighting strategy.
  • If a foam blanket is used as a precautionary measure on liquid, avoid plunging of the foam streams into the liquid. Industry experience and research indicates that a static charge can develop and cause ignition of the stored materials. Foam solution should only be applied through the tank foam chambers to avoid the risk of static build-up.
  • If appropriate, ground fires should be extinguished first. Exercise care after the ground fire is extinguished to avoid disrupting the foam blanket over the spilled materials.
  • During an atmospheric tank fire, while using cooling streams on the tank exterior, additional attention should be given to applying cooling streams on the foam chambers and foam supply lines as well as the process lines within the dike area.
  • Cooling streams on adjacent tanks should be applied as needed only. A cooling stream should periodically be applied to the exposed tank. If stream is given off, the cooling stream application should be continued until steam is no longer apparent. This will help reduce the demands on the fire water delivery system, and will minimize the water handling and disposal concerns from the tank dike areas.
  • Pumping out the product of the tank may worsen the fire if the sides have been distorted and the roof does not lower evenly.
  • Mid-range gravity crude oils, such as those processed at this refinery, have the potential for a boil over during fires that last for extended periods.

The following "rules of thumb" should be considered in the event of a crude tank fire:

  1. A boil over covers approximately 7 times the tank area and extends into the air approximately 10 times the tank diameter.
  2. Consumption rate of crude oil due to burning is approximately 12-18 inches per hour.
  3. The heat wave advances from the top of the liquid towards the bottom of the tank at approximately 24-36 inches per hour.
  4. A modified fog cooling stream may be periodically applied to the side of the tank to help determine the location of the heat wave in the tank.
  5. Evacuation of the area should be considered as the heat wave approaches the bottom few feet of the tank.

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

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Tags: Fire Pre Plans, Emergency Preparedness, OPA 90, Emergency Management Program, Chemical Industry

Hazardous Spill Containment Options and Recovery Methods

Posted on Fri, Mar 18, 2011

Hazardous spills that breach secondary containment can have disastrous results on the the surrounding population and environment. Understanding containment options and recovery methods is essential in limiting the effects of a spill.

Spills reaching water typically spread faster than those on land. They also have greater potential to contaminate water supplies, to affect wildlife and populated areas, and to impact man made structures and human activities. Responses which may impact waterways should focus on source control, containing the oil near its source, and protecting sensitive areas before they are impacted. The planned strategies and response efforts must be evaluated prior to implementation during an actual event to ensure that they are appropriate for the situation.

Containment and recovery techniques that can be employed to contain and recover terrestrial and aquatic spills include, but are not limited to the following:

Containment/Diversion Berming

  • Construct berms ahead of leading edge of spill to divert spill to a containment area.
  • May cause disturbance of soils and increased soil penetration.

Blocking/Flow-Through Dams

  • Construct dam in drainage course/stream bed to block and contain flow of spill. Cover with plastic sheeting. If water is flowing, install inclined pipes during dam construction to pass water underneath dam.
  • May increase soil penetration.

Culvert Blocking

  • Prevent oil from entering culverts by blocking with plywood, sandbags, or sediments.

Interception Trench

  • Excavate ahead of advancing surface spill to contain spill and prevent further advancement; cover bottom and gradients with plastic.
  • May cause disturbance of soils and increased soil penetration

Containment Booming

  • Deploy boom to contain free oil.

Diversion Booming

  • Deploy boom at an angle to the approaching oil to divert to a less sensitive area or area better suited for collection.
  • Diverted oil may cause heavy oil contamination to the shoreline downwind and down current.
  • Anchor points may cause minor disturbance to the environment.

Exclusion Booming

  • Deploy boom to limit contamination of sensitive areas, inlets, a river mouths, creeks, water intakes, bays, or other sensitive areas.
  • Anchor points may cause minor disturbance to the environment.

Sorbent Booming

  • Used only on quiet water with minor oil contamination.
    Boom is anchored along a shoreline or used in a manner described above.
  • May utilize sorbent material as boom or pack sorbent material between multiple booms placed parallel to each other.

Other cleanup methods include natural recovery, manual removal/scraping, low-pressure flushing, warm water washing, and burning. Berms and dams are also used to protect shallow waterways.

Appropriate cleanup methods are provided in NOAA's "Shoreline Assessment Manual," and NOAA's "Options for Minimizing Environmental Impacts of Freshwater Spill Response". Regional site-specific methods should be reviewed in the appropriate Area Contingency Plan (ACP).

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

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Tags: Pipeline, Emergency Preparedness, Crisis Management, OPA 90, Oil Spill, Training and Exercises, HAZWOPER, Chemical Industry

Regulatory Compliance Management

Posted on Fri, Feb 11, 2011

Managing regulations for industrial facilities can be a daunting task.  Industrial facilities must operate profitably, yet comply with a complex array of federal, state and local regulations. 

To ensure regulatory compliance, companies must establish an effective method of tracking and documenting actions items required for compliance.

Companies are always searching to reduce the costs and efforts required to manage compliance, so they can focus budgets within their core business.  However, lack of compliance can result in additional financial burdens resulting from fines, negative public perception, and possibly government mandated shutdown of operations.

Technology can be a useful, and relatively inexpensive tool for companies to monitor continually evolving regulatory requirements. The use of Excel spreadsheets is a common way to manage these requirements and may be effective for small operations. However, as companies grow and numbers of facilities increase, spreadsheets can become overwhelming, ineffective, and time consuming. Larger operations should consider utilizing database technology to ensure that compliance can be effectively managed on an enterprise-wide level.

Key concepts for managing regulatory compliance from a corporate perspective include, but are not limited to:

  • Use of Database Technology - This allows association of each regulatory requirement to applicable facilities. Updating evolving regulatory information can be effectively managed across multiple facilities with the use of a database.
  • Available Expertise - Identify corporate resources or outsource compliance expertise, and leverage that knowledge enterprise-wide.
  • Identify Facility-Specific Regulations -  Highlight mandatory submission requirements and tasks for each facility associated with each regulatory requirements.
  • Tasking -  Assign compliance tasks, frequencies, due dates, persons responsible, and document completion actions.
  • Identify Best Practices -  Apply best practices related to compliance with specific regulatory requirements, when practical to do so.
  • Organize Compliance Information - Utilize a database to limit duplication of tasks generated when multiple agencies have regulations that are related to the same subject matter.
  • Search Functionality - Create the ability to search database for key words and phrases associated with regulations.

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

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Tags: USCG, DOT, CFATS, Emergency Preparedness, EPA, OPA 90, Regulatory Compliance, OSHA HAZWOPER standard training

EPA Regions Press On with Underground Storage Tank Inspections

Posted on Tue, Aug 24, 2010

The EPA has requested $34.4 million of its total budget to be allocated to continue to focus on issues included in the Energy Policy Act of 2005. The Energy Policy Act of 2005 P.L. 109-58 (EPAct) imposed several responsibilities and regulatory requirements on the individual states. Section 1523 of the Act imposed one of the most significant new requirements: States must inspect all regulated underground storage tanks (USTs) every three years. States had to complete the first three-year inspection cycle by August 2010.

Leaks, or releases, from underground storage tanks (UST) continue to pose a serious threat to the environment and to public health. "Out of sight does not mean out of mind when it comes to underground storage tanks, which is why it is critical that facilities monitor their tanks and make sure they are not leaking," said EPA Region 2 Administrator, Judith Enck. 

The EPA’s 2011 “Budget in Brief” explains that individual states will continue to use the UST categorical grant funding to implement their leak prevention and detection programs. Through these UST categorical grants, states can continue to fund such activities as:

  • Seeking state program approval to operate the UST program in lieu of the Federal program.
  • Approving specific technologies to detect leaks from tanks.
  • Ensuring that tank owners and operators are complying with notification and other requirements.
  • Ensuring equipment compatibility.
  • Conducting inspections.
  • Implementing operator training.
  • Prohibiting delivery for non-complying facilities
  • Requiring secondary containment or financial responsibility for tank manufacturers and installers.

Routine EPA inspections of P.J. Hyde & Son, Inc.’s gas stations and hotel in N.Y revealed that from 2007 to 2009, the company failed to properly test the leak detection equipment of underground petroleum storage tank systems for leaks at five gas stations in Saranac Lake, Tupper Lake and Indian Lake, and a hotel in Lake Clear. The company was fined $16,000 under the agreement. As a result, P.J. Hyde & Son, Inc is spending $60,000 to improve its leak detection system.

According to the EPA’s semi-annual report of UST Performance Measures Mid fiscal year 2010, 491,572 releases have been reported since the beginning of the monitoring program in 1984. UST partners have completed more than 395,433 cleanups or about 80 percent. Between October 2009 and March 2010, 48,235 on-site inspections have been conducted. The 2011 allocated budget will continue to allow the EPA to monitor underground storage tanks. Facilities must be aware of their responsibilities and regulatory requirements.

Be prepared for a leak or release. For tips and best practices on conducting an effective oil spill exercise, download our Free Best Practices Guide

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Tags: Emergency Preparedness, SPCC, OPA 90

Oil Spill Liability Trust Fund and OPA 90

Posted on Fri, Jul 16, 2010

Twenty years ago, the Congress implemented The Oil Pollution Act of 1990 (OPA 90), which placed the primary burden of clean up costs on the responsible party.

However, the Oil Spill Liability Trust Fund (OSLTF), which currently is financed by a 8-cent-per-barrel oil tax, was created to offset clean up costs when the responsible party is incapable or unwilling to do so. Congress created the Fund in 1986, but did not pass the legislation to authorize the use of the money or the collection of revenue necessary for its maintenance until the passage of OPA 90 regulation four years later.

OPA 90 consolidated the liability and compensation requirement of certain prior federal oil pollution laws and their supporting funds.

Funds can be used for the following:

  • Removal costs incurred by the Coast Guard and EPA
  • State access for removal activities
  • Payments to federal, state, and Indian tribe trustees to conduct natural resource damage assessments and restorations;
  • Payment of claims for uncompensated removal costs and damages;
  • Research and development; and
  • Other specific appropriations.

Larger corporations may have sufficient resources to pay for cleanup costs resulting from large spills, however smaller companies may need to utilize the OSLTF for cleanup expenses. 

However, the best defensive measure against financing an oil spill clean up is prevention and thorough planning.

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Tags: OPA 90

OPA 90 and the Emergency Response Plan

Posted on Fri, Jul 02, 2010

Twenty years ago, Congress enacted The Oil Pollution Act of 1990 (OPA 90) as a direct result of the Exxon Valdez oil spill in Prince William Sound, off the coast of Alaska.

As a result of this law, marine vessels and certain land-based facilities that store oil are required to have response plans. In addition, OPA 90 requires that these regulated facilities and vessels to submit these oil spill plans to various Federal agencies for approval. These emergency response plans are required to contain detailed information as to how they will respond to small, medium, and worst-case spills.  Congress delegated responsibility for development of detailed regulations and oversight of regulated facilities to four agencies:

  • Environmental Protection Agency for certain non-transportation related onshore facilities
  • U.S. Coast Guard for certain land-based facilities that trasnport oil across the water (for loading and offloading vessels)
  • Pipeline Hazardous Materials Safety Administrtation for certain oil transportation pipelines
  • Minerals Management Service for Offshore pipelines and platforms that store and transport oil

oilspill.jpg

There are many cases where overlap exists between these agencies in which different agencies regulate a portion of the same facility. As an example, most refineries are regulated by three of the four agencies.   

Facilities regulated by OPA 90 include, but are not limited to:

  • Offshore production facilities and pipelines
  • Onshore oil pipelines
  • Bulk storage terminals, refineries, and other facilities that store 1,000,000 gallons or more of oil
  • Facilities that store 1,000 gallons or more of oil and transfer oil to barges and ships.

The regulation also requires the development of Area Contingency Plans, which describe federal, state, and local response and coordination to spills in each region. 

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Tags: Emergency Preparedness, OPA 90