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Spill Prevention, Control, and Countermeasures:
Hazardous Liquids
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Environmental Perspective
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Presentation Agenda
Reactive Measures
BTEX – Full Shift
Proactive Measures
Reactive
Measures
BTEX – Short Term Exposure
&
Real-time Monitoring
Two basic approaches used to deal with incidents
involving
the transportation
of hazardous
Other
chemicals
of interest…
liquids: proactive and reactive measures. This presentation discusses each.
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Presentation Goal – Provide 40,000 ft overview
This…
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Not This.
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Definition
Proactive Measures
“Creating or controlling a situation by causing
something to happen rather than responding to it
after it has happened.”
The steps you undertake before an incident occurs
which allows you to better mitigate its effects.
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Proactive Measures =
Spill Prevention and Control
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Spill Prevention and Control
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Spill Prevention and Control
49 CFR 195 – Transportation of Hazardous
Liquids by Pipeline
Testing
Maintenance
Procedures
Other
Training
Maps
Monitoring & Inspections
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Pro-Active Measures
Testing
Pressure Testing (or Risk-based alternative) of pipeline and all components
-4 continuous hrs at 125% of max. operating pressure plus:
-Visual inspection for leak or additional 4 hrs continuous testing at 110% of max
operating pressure
-Using H2O or inert gas (low stress pipe)
Cathodic Protection & External Corrosion Control
-Must be tested just prior to lowering the pipe into the ditch or submerging the pipe
Non-destructive Weld Tests
Recordkeeping
-Test records must be maintained the entire time that the tested facility is in use
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Pro-Active Measures
Standard Operating Procedures
Operations, Maintenance, and Emergencies
Manual of Written Procedures
-Normal Operations
-Abnormal Operations
-Emergencies
Reviewed once per calendar year
and at least every 15 months
Abnormal Operations
-Responding to, investigating, and correcting the cause of:
-Unintended closure of valves or shutdown
-Increase or decrease in pressure or flow
-Loss of communication
-Operation of any safety device
Emergencies
-Discovery, Notifications, Lists of Response Resources, Control/Minimize Hazards
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Pro-Active Measures
Training
Establish and Conduct Continuous Training Program
-Understand roles & responsibilities
-Know characteristics & hazards of commodities transported
-Recognize conditions likely to cause emergencies/predict consequences and take
appropriate actions
-Steps to minimize potential fire, explosion, toxicity or environmental damages
-Know characteristics and causes of fires and appropriate use of extinguishers
*Once per calendar year and at least every15 months
** Additional training required for “Qualified Personnel”
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Pro-Active Measures
Maps
Maps of Pipeline Systems
-Breakout tanks
-Scrapers and spheres
-Valves
-ROWs
-Safety devices
-Crossings (roads, railroads, rivers, pipelines, and utilities)
-Pressures
-Diameters, grade, type, and wall thickness
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Pro-Active Measures
Monitoring & Inspections
Right-of-Ways (ROWs)
-26 times/calendar year at interval not exceeding 3 weeks
-Surface conditions on and adjacent to ROWs (typically walking, driving, or flying)
Crossings under Navigable Waters
-Every 5 years for each crossing under navigable waterways
Gulf of Mexico
- If pipeline is >4 ½ inches (14mm) in diameter and located in water < 15 feet deep, must
rebury line to a depth of at least 3 feet below grade surface
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Pro-Active Measures
Other Pro-Active Measures
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Maintenance
Communication System
Line Markers
Signs
Security
Written Damage Prevention Program
Public Awareness
Leak Detection
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Pro-Active Measures
Special Considerations
High Consequence Areas
-Commercially navigable waterways
-Concentrated populations centers (>50,000 people as of last U.S. Census) and has a
population density of at least 1,000 people/mi2
-“Other” populated area, which means a place, as defined and delineated by the
Census Bureau, that contains a concentrated population, such as an incorporated or
unincorporated city, town, village, or other designated residential or commercial area
-“Unusually sensitive” areas (drinking water or ecological resource area that is
unusually sensitive to environmental damage from a hazardous liquid pipeline release)
-Drinking water intake;
-Source Water Protection Area (SWPA);
-Location containing imperiled, T&E, or depleted marine mammal species, or an
imperiled ecological community where the species or community is aquatic, aquatic
dependent, or terrestrial with a limited range
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Special Considerations
High Consequence Areas (HCA)
Requires Pipeline Integrity Management Program
- Elements of written program include:
- A process for identifying which pipeline segments could affect a HCA;
- A baseline assessment plan;
- An analysis that integrates all available information about the integrity of the entire
pipeline and the consequences of a failure;
- Criteria for remedial actions to address integrity issues raised by assessment &
analysis;
- A continual process of assessment and evaluation to maintain a pipeline's integrity
- Identification of preventive and mitigative measures to protect the HCA
- Methods to measure the program's effectiveness
- A process for review of integrity assessment results and information analysis by a
person qualified to evaluate the results and information
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Pro-Active Measures
40 CFR 112 – Oil Pollution Prevention
Differs from requirements found in 49 CFR 195 in that 40 CFR 112 deals
with bulk storage and internal handling of oil (i.e., facilities) not oil in
transportation (e.g., railcars, trucks, and pipelines).
Require facilities to prepare and implement site-specific plans* to address
three areas:
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Secondary containment and other engineered and procedural control measures
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Operating procedures, inspections and other administrative measures
•
Countermeasures and clean up measures
*Type and complexity of plans determined by overall storage capacity of the facility (e.g., Spill
Prevention Control and Countermeasures Plan versus Facility Response Plan)
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Pro-Active Measures
40 CFR 112 – Oil Pollution Prevention
Highlights of SPCC Rule:
Facilities must utilize secondary containment or environmental equivalent”
for all bulk oil storage containers which are defined as > to 55 gallons and
must account for containment of 100% of single largest container in dike
plus “adequate freeboard for precipitation”.
Security at facility must be sufficient to deter vandalism and acts of
terrorism (e.g., fences, lights, cameras, locks, 24-hour staffing, etc)
Inspections must be conducted routinely (typically monthly) and include all
tanks and appurtenances including , supports, pipes, dikes, handling areas,
etc.
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Pro-Active Measures
40 CFR 112 – Oil Pollution Prevention
Highlights of SPCC Rule Cont’d:
Training must be given annually to all “oil handling personnel”.
If facility oil storage capacity exceeds 1,000,000 gallons than Facility
Response Plan (FRP) must additionally be prepared which incorporates all
SPCC rules plus requires hazard analysis of worst case discharge and
triannual drills and exercises to demonstrate efficacy of the plan.
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Reactive Measures
When bad things happen despite pro-active measures
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Definition
Reactive Measures
“Actions done in response to a problem or situation.
Reacting to problems when they occur instead of
doing something to prevent them.”
The steps taken after a release has occurred to
minimize environmental exposure and liabilities.
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Reactive Measures
Responding to An Incident
Work the Plan
- You’ve spent time, money and resources engaging in pro-active measures.
You’ve previously planned the work, now work the plan.
- Internal notifications
- External agency notifications
- Corrective measures and stopping the source of the release
- Mobilization of contractors and resources
- Deployment of control and recovery assets
- Organization, structure, and location of incident command
- Coordination of response activities
- System restoration/business continuity
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Reactive Measures
Responding to An Incident
Response Priorities:
P-E-A-R
People
Environment
Assets
Reputation
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Response Priorities
People
Responsibility for
Community
st
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Responders, Employees & Contractors, and
- Constituent-specific OSHA established “Permissible Exposure Limit” (PEL) Time
Weighted Average (TWA) which is the permissible concentration in air of a substance
that shall not be exceeded in an 8-hour work shift or a 40-hour work week
- Constituent-specific ACGIH derived “Threshold Limit Values” (TLV) TWA which is the
concentration for a normal 8-hour workday and a 40-hour workweek, to which nearly all
workers may be repeatedly exposed, day after day, without adverse effect.
- Typically the primary concern when dealing with people is the route of exposure
through inhalation. Exacerbated by fires, blow-outs and activities like vacuum truck
recovery, transferring, lightering, etc which aerosolize particulates into the air.
- Other routes of exposure include: ingestion (drinking water, fish consumption) and
contact dermatitis (exposure to surface water, sediment, and/or soils).
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Response Priorities
People – Air Monitoring
Strategy
- Incident details – Location (i.e. urban versus remote), type and amount of product
released and/or on fire, SDSs, description of the environmental impacts (i.e. soil,
water), site air monitoring results.
- Receptors – Location in relation to unplanned release and/or fire (i.e. distance, downwind/stream, up wind/stream), type of receptors (i.e. intermediate, commercial,
industrial, farmland, residential, schools, daycares, hospitals, immune compromised
individuals).
- Location Details – Urban versus remote, accessibility, weather conditions, flooding,
run-off, inversions, exclusion zone boundary, private versus public land, aerial maps.
- Sample Methodologies – Equipment/Sample Media capability (i.e. range, resolution,
specificity), availability, chemical interferences, previous results, data extrapolation,
laboratory capabilities.
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Response Priorities
People – Air Monitoring
Sampling & Monitoring
- Real-time instrumentation vs. analytical
- Rapidity vs. quality
- If not done and documented properly can yield results quickly but not provide you
with the level of detail needed to support subsequent litigation.
Public Health Unit
- Review data: issue advisories for beach closures, fish consumption, evacuations, etc.
Typically work with Federal, State, County Health Departments.
- Not stood up in every incident; depends on UC/IC whether it is warranted.
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Response Priorities
Environment
Monitoring & Sampling
Shoreline Assessment
Resources At Risk (RAR)
Wildlife
Natural Resource Damage Assessment
Waste Coordination
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Environment
Monitoring & Sampling
Purpose is to produce rapid, reproducible, actionable, and defensible data.
Examples include:
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Work Zone Exposure Monitoring
Community Exposure Monitoring
Drinking Water Intake Sampling
Source Oil Sampling for Comparative Fingerprinting
Background Sampling of River, Material and Waste Staging Areas
Ephemeral Environmental Sampling (surface water, water column, sediment, soil,
biota)
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Environment
Shoreline Assessment
Shoreline Cleanup Assessment Technique (SCAT)
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Evaluates oiling conditions;
Factors in shoreline types ;
Identifies sensitive resources;
Determines need for cleanup;
Recommends cleanup methods and endpoints; and,
Places constraints on cleanup if necessary, due to ecological, economic, or cultural
concerns
Rapid Assessment Technique (RAT)
- Rapidly documents gross delineation of shoreline impacts and documents unimpacted
shorelines
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Environment
Resources At Risk (RAR)
Evaluate impacts to threatened & endangered plants and animals; culturally
sensitive areas such Native-American artifacts, shipwrecks, etc); and/or,
historically sensitive areas such as parks, monuments, and cemeteries.
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Response Priorities
Wildlife
Hotline Number Set-up
- Report & Documentation of sightings
- Advise Operations Section
Establish Animal Recovery and Rehabilitation Center(s)
- Requires permits
- Knowledge of Proper Chain of Custody Records
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Response Priorities
Natural Resource Damage Assessment
Separate Activity from “Response”
Purpose is to compensate the public for injured natural resources
Natural Resources Have Value
The Government Holds Natural Resources in Trust for the Public- Trustees
Focus is on restoration of natural resources
Not punitive
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Response Priorities
Waste Coordination
Properly manage waste generation, handling, transportation, final
disposition (e.g., recycling, disposal, beneficial re-use, etc)
Provide necessary documentation for “mass-balance” accounting
- Penalties and fines are determined in part by the amount of material released into the
environment. Accounting for the amount of material recovered as part of the waste
stream can potentially save you millions in fines.
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Response Priorities
Asset
System Restoration and Business Continuity; resumption of “normal”
operations
- Typically slowed by causation and/or criminal investigations (e.g., CSB, PHMSA, FRA)
- Know your rotation schedule and personnel. If you are working on the response, who
is running the business and doing your “day job”?
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Response Priorities
Reputation
How credible is your response to the incident?
How effectively are you communicating?
Did you take responsibility for the incident or pass blame onto others?
What do your public statements say about your organization?
Increased Regulatory Oversight
DECREASED PUBLIC TRUST
Increased negative media coverage
Decreased Stock Price
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The
The “True”
“True” Cost
Cost of
of aa Response
Response…
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Now what?
The Emergency Is Over…..
Did you do enough to address potential lingering issues?
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Health Effects of Chemicals
Safety of Food
Indoor Air Quality
Water/soil Quality
Medical Surveillance
Water wells, supply
Property
Claims
Litigation
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Is this
chemical
toxic?
Is my water
safe to drink?
Is my home
safe to reoccupy?
Are my pets
safe?
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Wrap Up
Conclusions
Proactive measures are generally better than reactive
measures –demonstrates to regulators, employees, and
shareholders: we are ahead of this, our approach is solid,
and we know how to move forward.
Reactive measures involve protecting people, the
environment, and assets, but also protecting your liabilities!
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Questions?
April Steger, B.S.
CTEH, L.L.C.
Manager, Gulf Coast Operations
asteger@cteh.com
501-960-5723
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