1 center for toxicology and environmental health, llc hazardous liquids spill prevention, control,...
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Center for Toxicology and Environmental Health, LLC
Hazardous LiquidsSpill Prevention, Control, and Countermeasures:
Environmental Perspective
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Center for Toxicology and Environmental Health, LLC
Reactive Measures
BTEX – Full Shift
BTEX – Short Term Exposure
Real-time Monitoring
Presentation Agenda
Other chemicals of interest…
Proactive Measures Reactive Measures
&
Two basic approaches used to deal with incidents involving the transportation of hazardous liquids: proactive and reactive measures. This presentation discusses each.
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Presentation Goal – Provide 40,000 ft overview
This… 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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49 CFR 195 – Transportation of Hazardous Liquids by Pipeline
Spill Prevention and Control
MaintenanceTesting
Procedures
Training
Maps
Monitoring & Inspections
Other
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TestingPro-Active Measures
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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Standard Operating ProceduresPro-Active Measures
Manual of Written Procedures-Normal Operations-Abnormal Operations-Emergencies
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
Reviewed once per calendar year and at least every 15 months
Operations, Maintenance, and Emergencies
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TrainingPro-Active Measures
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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MapsPro-Active Measures
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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Monitoring & InspectionsPro-Active Measures
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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Other Pro-Active MeasuresPro-Active Measures
• Maintenance• Communication System• Line Markers• Signs• Security• Written Damage Prevention Program• Public Awareness• Leak Detection
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Special ConsiderationsPro-Active Measures
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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High Consequence Areas (HCA)Special Considerations
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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40 CFR 112 – Oil Pollution PreventionPro-Active Measures
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:
• Secondary containment and other engineered and procedural control measures
• 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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40 CFR 112 – Oil Pollution PreventionPro-Active Measures
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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40 CFR 112 – Oil Pollution PreventionPro-Active Measures
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 MeasuresWhen 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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Responding to An IncidentReactive Measures
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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Responding to An IncidentReactive Measures
Response Priorities:
P-E-A-R
People
Environment
Assets
Reputation
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PeopleResponse Priorities
Responsibility for 1st Responders, Employees & Contractors, and Community
- 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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People – Air MonitoringResponse Priorities
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, down-wind/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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People – Air MonitoringResponse Priorities
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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Environment Response Priorities
Monitoring & Sampling
Shoreline Assessment
Resources At Risk (RAR)
Wildlife
Natural Resource Damage Assessment
Waste Coordination
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Monitoring & SamplingEnvironment
Purpose is to produce rapid, reproducible, actionable, and defensible data.
Examples include:- 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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Shoreline AssessmentEnvironment
Shoreline Cleanup Assessment Technique (SCAT)- 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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Resources At Risk (RAR)Environment
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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WildlifeResponse Priorities
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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Natural Resource Damage AssessmentResponse Priorities
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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Waste CoordinationResponse Priorities
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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AssetResponse Priorities
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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ReputationResponse Priorities
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?
DECREASED PUBLIC TRUST
Increased Regulatory Oversight
Increased negative media coverage
Decreased Stock Price
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The “True” Cost of a ResponseThe “True” Cost of a Response…
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The Emergency Is Over…..Now what?
Did you do enough to address potential lingering issues?
• Health Effects of Chemicals• Safety of Food• Indoor Air Quality• Water/soil Quality• Medical Surveillance• Water wells, supply• Property• Claims• Litigation
Are my pets safe?
Is my water safe to drink?
Is my home safe to re-occupy?
Is this chemical
toxic?
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ConclusionsWrap Up
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 [email protected]