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‘Plans Are Nothing, Planning Is Everything’

by Aug 19, 2019Engineering, Environmental, Magazine

Being proactive with spill contingency plans

Crowley’s tank farm in rural Aniak, outside of Bethel, was inspected by environmental consulting firm Shannon & Wilson engineers as part of an SPCC plan update.

Shannon & Wilson

According to the Environmental Protection Agency (EPA), just one gallon of spilled oil can contaminate more than 1 million gallons of water, so it’s critical for companies that deal with these products on a daily basis—whether in their primary trade or secondary to their primary business—to take steps to prevent a spill or discharge and mitigate the damage should one occur.

Enter environmental contingency plans. These documents provide companies with a blueprint that 1) helps implement safety and containment measures to prevent and mitigate the effects of accidental spills and discharges and 2) outlines response and clean-up procedures should catastrophe strike.

Regulated and Unregulated Entities

Environmental contingency plans can be both broadly and narrowly defined. From a regulatory standpoint, they are highly-specific documents required of a narrow set of companies that meet certain federal and state guidelines. In Alaska, that generally means large-scale companies that deal in high-volume oil storage, distribution, and production.

“Most of the time here in Alaska, when somebody says ‘contingency plan,’ they’re generally referring to oil spill/discharge contingency plans by the DEC [Alaska Department of Environmental Conservation],” explains Craig Wilson, principal with Stantec, a multidisciplinary design firm that offers environmental consulting services.

DEC regulations encompass most of Alaska’s large oil distribution, production, and storage facilities.

“The big thresholds that stand out to people are tank farms that are either 210,000 gallons of crude or 420,000 gallons of refined product. If you meet that threshold, you have to have a contingency plan,” says Graham Wood, program manager of the DEC’s Prevention, Preparedness, and Response Program, which is tasked with preventing and mitigating the effects of an oil spill or discharge and ensuring its cleanup. Oil production and exploration facilities, pipelines, tank vessels, and non-tank vessels are also subject to DEC regulations, he adds.

Facilities that don’t meet the DEC threshold likely fall under the EPA’s Spill, Prevention, Control, and Countermeasure (SPCC) plans, which Matt Hemry, PE, vice president of environmental consulting firm Shannon & Wilson, calls “a contingency plan lite.”

SPCC plans cover non-transportation facilities with either an aggregate above-ground oil storage capacity greater than 1,320 gallons or a completely buried oil storage capacity greater than 42,000 gallons, provided there is a reasonable expectation of discharge into or upon navigable waters of the United States or adjoining shorelines. The EPA also broadly defines oil to include petroleum products, vegetable oils, synthetic or mineral oils, and oil or grease derived from animals.

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“The umbrella of entities that are subject to SPCC regulations are much broader, and, as you can imagine, the facilities can vary greatly,” Hemry explains. Hospitals with emergency generator tanks, small oil and distribution generators, airports, and even small businesses with 2,000-gallon fuel tanks on premises used to heat a shop or power machinery all fall under the SPCC. Many of these entities, particularly small businesses off Alaska’s road system, are simply unaware that the regulations apply to them, Hemry says.

But while large or even mid-size oil storage, production, and distribution facilities are most commonly regulated, the deciding factor of whether or not to create a contingency plan shouldn’t hinge solely on whether a company’s particular industry is regulated.

“From a response standpoint, it doesn’t matter whether you’re a regulated entity or not; you can’t spill onto lands or waters of the state,” Wood says, adding that “a lot of the [spill] responses are from these smaller, unregulated facilities.”

Crowley’s tank farm in St. Mary’s was visited by Shannon & Wilson engineers as part of an SPCC plan update.

Shannon & Wilson

Risk Assessment and Prevention

Regulations aside, contingency planning is simply an exercise in risk analysis: identify potential harm, take steps to prevent that harm from happening, and have procedures in place to mitigate damage and deal with clean-up if preventative steps fail. It’s an analysis every company that stores or handles potentially harmful products or materials should undertake.

“The bottom line is, regardless of which set of regulations you’re talking about, if you have hazardous materials or things that are potential environmental pollutants at your facility, you need to be thinking about ways to avoid spills and ways to avoid unintentional release of those chemicals,” says John Jones, PE, branch manager for ATC Group Services.

Potential accidents fall into one of three categories, Wilson says. Routine incidents, like oil spilled from a bucket, happen regularly; they’re relatively easy to contain and are handled entirely in-house. Emergencies, like a tank truck rollover, release a larger quantity of contaminants and require the aid of special teams to assist with containment and clean-up. Disasters are the worst accidents and the ones that make national headlines, like the Exxon Valdez or Deepwater Horizon, Wilson explains; they are “defined by the fact that you are overwhelmed and outside help needs to run the show.”

When determining how to mitigate each risk as part of the contingency plan, applicable regulations should serve as a starting point for the preventative steps to take, Wood says. And regardless of whether the DEC regulates a particular facility, the department is always available to answer questions from companies regarding the creation or implementation of contingency plans.

“From a prevention standpoint, even if you’re a smaller operation that’s not necessarily regulated, I would encourage you to pick up the phone and call us,” he says. “Technical assistance in creating a contingency plan from DEC is free; when you spill oil, it’s not.”

Basic common sense also comes into play when creating a contingency plan, whether the industry is regulated or not.

“A lot of times what you need to do may or may not be covered by the regulations,” Jones says. “You need to use a little bit of common sense.”

To start, businesses should examine their facility with a critical eye and identify every area that could possibly fail, the ramifications of that failure, and what can be done to prevent it.

“If something leaks, where’s it going to go? Is it going to go into the stormwater drain, is it going to go into the ditch, will it be contained, is it out of a double wall tank?” Jones lists as questions businesses should ask as they walk through the facility. “If we have a spill at this particular spot, where’s it going to go, and how are we going to stop it? If it’s going to be spraying out of a pipe, do you know where the shutoff valves are, and does your staff know how to shut them off?”

Checking that equipment is operating properly and in compliance with any regulations is also important.

“As you can imagine in Alaska, we’ve had facilities that have been around for decades or more, so the older tanks can be well out of compliance,” Hemry says.

And the duty to prevent and mitigate risk doesn’t end when the contingency plan is completed.

“There are inspection components where you have to go around and check; some are daily, some are weekly or monthly,” Jones says. “If something were at a high chance of a spill, inspections might be daily; fueling trucks, for example, every time you fill a truck you look at the ground for spills. It just kind of depends on the risk of the activity.”

Have and Use the Plan

Despite the known potential for harm if a spill occurs, Peter Beardsley, PE, principal-in-charge at Nortech, says it is sometimes difficult to convince companies of the necessity to plan for a hypothetical situation they hope never happens, particularly if regulations don’t require them to have a contingency plan on file.

“People just put their head in the sand and hope it doesn’t happen to them, or they rationalize it,” he explains. “There’s a human component to that. ‘Oh, it happens to other people, it doesn’t happen to me, so I don’t need a contingency plan.’”

The danger with that line of thinking, according to Jones, is that if a discharge does happen, it will be too late to come up with a clean-up plan.

“If you have a good plan and it’s in place, even if you have a small spill, nothing bad happens, because it’s contained or you’re able to clean it up quickly,” he says. “The really bad ones are where you didn’t have the right plan in place or the employees didn’t follow it.”

While some large companies may handle contingency planning in-house, the majority turn to environmental consulting and design firms that specialize in creating plans for their particular industry. Costs vary from thousands to tens of thousands of dollars, depending on the size and complexity of the facility, its location, and the type and amount of hazardous materials stored, Jones says, but it’s money well invested, both from an environmental and financial standpoint.

He remembers one incident where an employee filling an oil barrel forgot to turn off the hose before going home for the weekend. The result was a 2,500 gallon spill—an amount Jones calls “not gigantic”—that cost close to $1 million to clean up.

“As a guy who’s spent a good chunk of my career cleaning up spills, it’s way, way cheaper to spend money to prevent a spill than to clean one up,” Jones says. “People complain about the cost. One spill and you’d wish you’d bought that stuff.”

Creating the contingency plan is only half the battle. The other half is making sure that those responsible for implementing the plan understand how to respond to a spill before the plan ever has to be put into action.

“A contingency plan is only as useful as the fact that people know it’s there and know what to do in the event of an emergency,” Beardsley says. “We can write plans all day long, and if it just sits on a shelf and no one reads it, nobody is going to know what to do when the situation arises.”

On a shelf is exactly where Wilson once found a company contingency plan.

“I was doing one inspection of a facility and told the guy that he was required to have an oil spill discharge plan and asked to see it,” Wilson recalls. “The guy literally walked over to a large bookcase, stood on top of a chair, pulled a three-ring binder off the top of the bookcase, and blew the dust off.”

One practical way to ensure that employees understand the plan is to conduct tabletop exercises, which walk them step-by-step through the response procedures and can be an “eye-opening” experience, Wilson says.

If there’s one takeaway, he adds, it’s that every company needs to know its contingency plan.

“They need to open it up and read through it before something happens,” he says. ‘It’s the old saying, ‘Plans are nothing. Planning is everything.’ It’s the process, not the paper.”

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