Oil spill response planning and contingency planning are necessary to satisfy applicable regulatory requirements, protect the environment, and ensure the best possible safety scenario for responders and employees. Local, state and federal regulatory agencies may require varied site information depending on particular oil-related operations and locations. Yet, all emergency response plans for oil spills have one common thread: to minimize the impact of the spill.
The primary objectives of spill response plans, regardless of whether a facility is a production, storage, or a transport facility, are to:
- Allow response personnel to prepare for and safely respond to spill incidents
- Ensure an effective and efficient response that highlight and account for geographical challenges
- Identify potential equipment, manpower, and other resources necessary to implement a spill response
- Outline response procedures and techniques for combating the spill at a specific location
- Improve regulatory compliance efforts
According to the Environmental Protection Agency (EPA), an oil spill contingency plan should be a set of instructions that outlines necessary procedures for before, during, and after an emergency. “A contingency plan looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill.”
Oil spill contingency planning should provide site-specific procedural details that address various spill scenarios and situations. Despite complexity and varied nature, a well-designed oil spill containment plan should be easy to follow. Although the plans can be vastly different, they typically have four major elements in common:
- Hazard identification
- Vulnerability analysis
- Risk assessment
- Response actions
1. Hazard Identification
Numerous varied criteria, such as location, climate, severe weather potential, operations, logistics, equipment, spill trajectory, or facility dynamics, can create situations that can affect the ability of response personnel to contain and clean up an oil spill. These hazards should be identified and oil spill response procedures put in place to counteract challenges caused by each specific situation. It may be possible for certain identified hazards to be mitigated, essentially eliminating the hazard altogether.
According to the EPA, the following information is usually collected as part of the hazard identification:
- Types of oils frequently produced at, stored in, or transported through that area
- Locations where oil is stored in large quantities
- Mode of transportation used to move the oil, such as pipelines, trucks, railroads, or tankers
- Possible extreme weather conditions
- The location of response equipment and trained response personnel
2. Vulnerability Analysis
It is critical when developing an oil spill contingency plan to identify and provide detailed information regarding area social, natural, and economic resources that may be compromised or destroyed if a spill were to occur. This information regarding these non-facility related entities in the path of a spill or response, should guide response personnel to make reasonable, well-informed response actions to protect public health and the environment. Vulnerability analysis information in your oil spill response plan should include the following:
- List of sensitive facilities such as schools, nursing homes, hospitals, etc., and individual point of contact for each facility
- Lists of public safety agencies/officials in adjacent and nearby communities
- Lists of large gathering or recreational areas, such as campgrounds, parks, malls, etc.
- Calendar lists of special events and point of contact
- Identification of parts of the environment that are particularly susceptible to oil or water pollution such as water sources, beaches, farms
3. Risk Assessment
A risk assessment quantifies the hazards and the vulnerabilities to address the potential impact of a spill on its surroundings. The oil spill contingency plan should address best possible spill containment measures, how to prevent certain populations or environments from exposure to oil, and what can be done to repair the damage done by the spill.
4. Response Actions
Employees and responders should train for and exercise their assigned oil spill response procedures in order to minimize the hazards to human health and the environment. Stakeholders and applicable levels of government and industry should be consulted and incorporated in oil spill response and contingency planning. Without the full participation of personnel, responders, contractors, and government entities, an oil spill containment plan may lack validity, credibility, and effectiveness.
Oil and gas facility response planning frequently requires multiple types of plans with interrelated information that needs to stay current, such as Facility and Emergency Response Plans, Spill Prevention Control and Countermeasure, and Fire Pre Plans. Our SMARTPLAN team’s expertise and technology-enabled approach has offered a proven solution for oil and gas facility response plan development and management for over 25 years.