POLLUTION INCIDENT PLANNING GUIDELINES FOR PETROLEUM TERMINALS

Transcription

1 TECHNICAL GUIDANCE NOTES POLLUTION INCIDENT PLANNING GUIDELINES FOR PETROLEUM TERMINALS JUNE 2016 TGN 1.12

2 Contents 1. Introduction Disclaimer Pollution Incident Response Objective Scope Availability Legal Framework...14 Waste Management Water Quality Air Quality Pollutants Spills posing Environmental Risk Containment Systems...18 General Primary Containment Secondary Containment Remote Containment Systems Containment Lagoons Tanks Shut-off Valves and Penstocks Oil Water Separator Emergency Containment Systems Sacrificial Areas Bunding of Vehicle Parking and Other Hard Standings Pits and Trenches Page 2

3 Portable Tanks, Overdrums and Tankers Emergency Materials and Equipment...26 General Sand and Earth Proprietary Absorbents Sealing Devices and Substances for Damaged Containers Drain Seals Booms Waste Management Fire-fighting Strategies and Run-off Management Pollution Incident Response Plan...29 General Planning Cycle Prevention Preparedness Contents of PIRP...31 Purpose of the Plan Hazardous Material Inventory Terminal Layout Diagram Description of Potential Emergencies Risk Assessments Employee Safety Allocate Responsibility Communications Backup Resources Test Emergency Procedures Notification of Authorities Notification of Neighbours Page 3

4 Evacuation Incident Investigation Media Interest Response to Incidents or Emergencies...39 General Incident Impact Classification High Impact Incident Moderate Impact Incident Low Impact Incident Large Scale Incidents Small Scale Incidents Emergency Response Review Release Incident Response...43 General Short Term Actions Waste Environmental Action Plan Best Management Practices Pollution Prevention...47 Design and Construction Construction Quality Control Commissioning As Built Drawings and Plans Operations Groundwater Monitoring Wells Leak Detection and Maintenance Maintenance Unannounced Inspections Reporting Leaks, Spills and Serious Incidents Page 4

5 Decommissioning Terminal Records References Contacts...55 Page 5

6 Acronyms Acronym API AST DOSHS EMCA ERC GMW H2S KEBS KS NEMA OWS PIRP PPE PPG RP STW SUDs TGN Description American Petroleum Institute Aboveground Storage Tank Department of Occupational Safety and Health Services Environment Management and Coordination Act Energy Regulatory Commission Ground Monitoring Well Hydrogen Sulphide Kenya Bureau of Standards Kenya Standard National Environment Management Authority Oil Water Separator Pollution Incident Response Plan Personal Protective Equipment Technical Guidance Notes Recommended Practice Sewage Treatment Works Sustainable Drainage Systems Technical Guidance Notes Page 6

7 Terminology Terminology Bulk Storage Terminal Breathing Community Company Competent Person Compliance Containment Contractor Emission Facilities Foul drainage system Groundwater Hazard Description Premises consisting one or more tanks for storing petroleum or liquefied petroleum gas in transit or for sale Emissions from or intake of air into tank due to ambient temperature and/or pressure effects or due to vaporization/condensation of product Those residing near to an operating location/tank truck route to whom our activity is easily detectable either visually, aurally or by another means. It also encompasses key decision makers or those having a significant influence over local opinion for the locality. Company within the meaning of the Cap. 486 of Companies Act Means a person with enough practical and theoretical knowledge, training and actual experience to carry out a particular task safely and effectively. Meeting legal, regulatory or company requirements. Means to prevent loss of liquid product in the event of a leak or spill Any company or individual that is under contract to provide services. The episodic or ongoing release of materials to the environment (air, water or land). Physical equipment and/or plant, including large mobile equipment, involved in the performance of affiliate operations. The foul sewer is designed to carry contaminated wastewater to a sewage works for treatment Water that is below the surface of the ground in the saturation zone, i.e. below the water table. A potential source of serious harm to people, property or the environment. Page 7

8 Terminology Hazardous Area Incident Kenya Standard Loading Arms County Government Near Miss Occupational Health Operation Overfill Protection Pollution Incident Pollution Incident Description An area in which there exists or may exist an atmosphere containing flammable gas or vapor in a concentration capable of ignition A specific event or extended condition that has a significant unwanted and unintended impact on the safety or health of people, on property, on the environment, or on legal/regulatory compliance. Specification or Code of Practice declared by The Standards Council under section 9 of the Standards Act Equipment used for transferring product from the AST to the road tanker County Government is as defined in Constitution of Kenya 2010 An unintended or unwanted event or circumstance which under slightly different conditions would have resulted in an incident. Process encompassing all activities addressing workplace health hazards and employee health. It includes identification, evaluation, and control of health hazards; monitoring of worker exposures; communication of health hazards knowledge, determination of employees medical fitness to do their work and providing or arranging for medical services necessary for the treatment of occupational illnesses or injuries. Any activity involving the production, manufacture, use, storage or movement of material. Also, the utilization of resources by a unit to produce an output. Equipment that halts the transfer of product from a road tanker to an UST when the tank is full. A pollution incident is any unauthorized discharge to land, air or water that could cause environmental damage. Examples of pollution incidents at sites include: Fuel drips or spills during refueling vehicles Leaks or spills from fuel tanks Leaks or spills from chemical containers, e.g. cans of paint, cleaning chemicals, contaminated run-off entering a watercourse or drain, an oil or chemical spill Pollution Incident Response Plan is a short document that outlines the actions the site will take to minimize the Page 8

9 Terminology Response Plan Pollution Prevention Program Practice Recommendations Release Spill Response Plan Standard Standard Operating Procedures Sustainable Drainage Systems Vapor Recovery Description pollution caused by an incident. Pollution prevention describes activities that reduce the amount of pollution generated by a process. The pollution prevention approach seeks to increase the efficiency of a process, thereby reducing the amount of pollution generated at its source. Although there is wide agreement that source reduction is the preferred strategy, some professionals also use the term pollution prevention to include recycling or reuse. Approved method or means of accomplishing stated tasks. Potential solutions to findings or observations. Spilling, leaking, emitting, discharging, escaping, leaching or disposing from a storage tank into surface waters and groundwaters or soils or subsurface soils in an amount equal to or greater than the reportable released quantity A written plan developed by the operator to respond to any spills at Vehicle Cleaning, Washing and Servicing facility at a site. As a minimum the plan shall define roles and responsibilities for spill response, contact names and numbers for appropriate agencies and a checklist for all spill response equipment. A defined product or result. Includes requirements for quality, content, review and conformance with regulations. Standard Operating Procedures are documented series of steps to be carried out in a logical order for a defined operation or in a given situation. SUDS are a sequence of water management practices and facilities designed to drain surface water in a manner that will provide a more sustainable approach than what has been the conventional practice of routing run-off through a pipe to a watercourse. Vapor Recovery System is the process when vapor is collected and returned to a road tanker or AST during product handling. Page 9

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11 1. Introduction 1.1. These Technical Guidance Notes (TGNs), herein referred to as guidelines, provide information on good practices for the development, implementation and sustenance of a Pollution Incident Response Plan, herein referred to as PIRP, for a Petroleum Terminal, herein referred to as terminal and outlines the actions the terminal will take to respond to pollution incidents Each terminal and potential sources of pollution should be assessed individually and we advise operators to consult the National Environment Management Authority (NEMA), County Government and the Energy Regulatory Commission (ERC) for incident response guidance The TGNs have been produced by the ERC. Contact details can be found at the end of these guidelines. 2. Disclaimer 2.1. The information contained in the TGNs is not intended to be prescriptive, or to preclude the use of new developments, innovative solutions or alternative designs, materials, methods and procedures, so long as such alternatives provide a level of control over pollution appropriate to the risks identified The guidelines are provided for information and while every reasonable care has been taken to ensure the accuracy of its contents, the ERC cannot accept any responsibility for any action taken, or not taken, on the basis of this information. 3. Pollution Incident Response 3.1. Hydrocarbons and contaminated waste poses a risk to the environment and people if inappropriately stored, handled or discharged The use of a comprehensive PIRP can help lessen environmental impacts, minimize costs and aid terminals clean-up, reduce occupational health and safety incidents and enhance community attitudes Terminals have the potential to cause significant environmental harm and to threaten water supplies and public health. Spillages of oil are obvious threats and the environmental damage may be long term and persist for decades or even longer Major pollution incidents can be prevented, if pollution prevention measures are in place or immediately available. Contingency planning is Page 11

12 the key to success and carefully addresses strategic preventative measures and incident response procedures. Page 12

13 3.5. The TGNs provide guidance on issues of environmental concern, and offer potential solutions based on professional judgement and precedent for pollution incidents at terminals. The recommendations made do not override any statutory obligations or regulatory requirements Alternative practical environmental solutions suited to local conditions may be considered and should take into account the values of the surrounding environment, the safeguards in place, and the different potential precautionary and prevention approaches This guideline also gives good practices for the protection of the environment in the management of run-off generated in the event of fire (or fire water and storm water) and major spillages. It aims to help terminal operators consider what is appropriate for a specific terminal, taking into account the risks and terminal layout In the event of an incident reporting should be in line with the National Oil Spill Contingency Plan. The ERC must also be notified within 48 hrs. 4. Objective 4.1. Any substance, if released into the environment from terminals at above background concentrations, presents or has the potential to present a harmful risk to human health, disrupt ecological processes and affect and/or impact the water environment The TGNs provide requirements for the preparation, maintenance and implementation of an effective PIRP by operators of terminals to facilitate emergency response to pollution incidents. The TGNs set out BPs for producing a PIRP to deal with environmental incidents The PIRP will help terminal operators to prevent or reduce environmental damage if such an incident occurs. The guideline sets out: a. Why you need the PIRP? b. What information should be included? c. What supporting procedures are needed to implement the PIRP? d. What the PIRP should look like? 4.4. The TGNs focus on containment strategies, physical structures that can be used to contain firewater and spillages (so called secondary containment facilities) and equipment. Other approaches to protect the environment, such as operational and management controls are also considered The TGNs are intended principally for those with responsibility for new and existing, terminals and also apply to: Page 13

14 a. Spills, leaks and releases at terminals that may pose a threat to air, soil or water environment and which affect human health, amenity, environmental or economic values. b. Pollution prevention plans for the life cycle of terminals from establishment, through operation to closure. 5. Scope 5.1. The TGNs will assist terminal operators/owners develop and implement a PIRP that will mitigate or eliminate the potential pollution hazards due to environmental incidents resultant from the receipt, storage, handling and/or delivery of hydrocarbons. 6. Availability 6.1. The TGNs are published by the ERC and are now available. 7. Legal Framework Waste Management 7.1. Waste management facilities (keeping, treating and disposing of waste) are regulated by NEMA to protect the health and well-being of the environment and the community Businesses that produce waste are also compelled to comply with the EMCA (Waste Management) Regulations Waste from a business represents the loss of valuable resources and presents a risk to the environment if it is not treated carefully. Water Quality 7.4. Groundwater is stored naturally in porous rocks and soils called aquifers and are also important for maintaining river flows and wetlands Pollutants and effluents disposed of onto land and, by seeping through the soil, cause land contamination and groundwater pollution, which makes the water unusable without costly treatment All effluent discharge to the environment must comply to the standards set out in the EMCA (Water Quality) Regulations. Page 14

15 Air Quality 7.7. Emissions to the air can affect people s health, cause odor nuisance and damage the natural and built environment All emissions to the environment must comply with the standards set out in the EMCA and OSHA. 8. Pollutants 8.1. Potential causes of environmental incidents at the terminal include: a. Overfilling ASTs b. Equipment failure c. Containment failure d. Wrong connections of sewers and pipes e. Uncontrolled releases f. Discharge of partially-treated or raw effluent g. Vandalism h. Flooding of part or all of the terminal 8.2. Any of these incidents could affect: a. Drainage systems, surface waters, aquatic ecosystems, groundwater and soil b. Air quality by producing toxic fumes and airborne pollutants which may damage human health, wild and domestic animals and ecosystems 8.3. The impacts may be immediate and long lasting; the terminal operator will be responsible for the costs of cleanup, which can be expensive particularly if groundwater is contaminated There may be additional costs too associated with incident response and/or fines or costs through the criminal and/or civil courts The terminal s reputation may suffer Pollutants may escape from the terminal into the environment by a number of pathways. These include: a. Terminal s surface water drainage system, either directly or via off-site surface water sewers. b. Direct run-off into nearby watercourses or onto ground, with potential risk to ground waters. Page 15

16 c. Via the foul drainage system, with pollutants either passing unaltered through a sewage treatment works or affecting the performance of the works, resulting in further environmental damage. d. Through atmospheric deposition, such as vapor plumes Physical, operational and managerial measures are key elements of the PIRP to reduce the impact of any unplanned event that does occur. Page 16

17 9. Spills posing Environmental Risk 9.1. Terminals are considered an essential Petroleum Products Supply Chain Component and facilitate the distribution and marketing of petroleum products and can pose pollution risks to air, soil and the water environment through: a. Leakage of products from ASTs, pipelines and their ancillaries b. Spillage of products at Loading and Offloading Facilities c. Inappropriate containment or disposal of wastes including wastewaters from terminal operations 9.2. The risk that contaminants pose to air, soil and water resources varies based on factors including: a. Nature of the contaminant (i) Toxicity to living things (ii) Mobility of the contaminant (including solubility, viscosity, adsorption to soil particles, and the influence of rainfall) (iii) Whether the pollutants will react with substances present in the environment and the subsequent outcome b. Contaminant s persistence in the environment whether it will evaporate, be filtered out in soils, degrade on contact with soil microorganisms or move under the influence of gravity or rainfall to cause harm c. Spill volume d. Timeliness and effectiveness of spill management measures e. Location of spills relative to sensitive receptors in the environment f. Risk of downstream harm to living things from exposure to pollutant residue (i.e. the degree of toxicity ranging from mild discomfort through to death). Page 17

18 10. Containment Systems General On any terminal there may be one or more levels of containment. In deciding the appropriate level of containment a risk assessment will be helpful The operator should consider the hazardous materials at the terminal, the risks posed by accidents, fire, flooding and vandalism, likely failure mode of the primary containment, the sensitivity of the receiving environment and the importance of preventing any resultant discharge to it. Page 18

19 Primary Containment This is the AST in which product is stored It is the first line of defense and must be fit for the purpose Temporary ASTs should not be used for long term storage. Secondary Containment Depending on the way they provide protection, secondary containment systems may be categorized as local, remote or combined (both) Local containment is a bund. Remote Containment Systems In many cases, primary and local containment (bunding) will prevent an incident from causing pollution. However, where local containment is not provided, or risk assessment indicates that additional security is required, for example to contain firewater run-off, which may amount to thousands of cubic metres, then remote containment systems may be employed Remote containment may be used in isolation, or in combination with local containment, for anything from a small area, covering part of a terminal, to a number of large individual installations. They may be required to protect both surface and foul water drainage systems Considerations for remote containment include: a. Primary capacity, which is 100% of primary capacity, considers the possible failure modes and where appropriate, includes the capacity of all primary ASTs in multi-ast installations. b. Rainfall - subject to operational procedures, in order to calculate the volume to be contained, allow for a 10 year return, 8 days rainfall prior to the incident, and a 10 year return, 24 hour rainfall, plus an allowance for rain falling directly on to remote containment and areas of the terminal into it, immediately after the incident. c. Fire fighting and cooling water - Allowance for extinguishing and cooling water delivered through fixed and non-fixed installations with adjustments in the light of particular circumstances. Consultation with the regulators and the fire service essential. d. Foam - Allow a freeboard of not less than 100 mm. e. Dynamic effects - this is to allow for the initial surge of liquid and for wind-blown waves. Page 19

20 f. In the absence of detailed analysis, allow 250mm (750 mm for earth walled bunds). Containment Lagoons Where the terminal topography and the ground and soil conditions are suitable, earth banked containment basins (or lagoons) can provide cost effective, remote secondary containment systems, particularly for the retention of firewater Lagoons may be constructed either above or below the surrounding ground level and formation level is often determined by the economic advantage of balancing cut and fill To protect groundwater, the lagoon should be substantially impermeable. In some situations this will require the use of an impermeable membrane or other suitable liner to ensure that it does not leak in the event of an incident occurring. In situations where a membrane is not required, it is recommended that a minimum of 1 metre of engineered clay, with a maximum permeability of 1x10-9 m/sec, is used to line the lagoon Lagoons should be constructed so that they can be isolated in an emergency from the main drainage system. Flood defense installations, such as a balancing lagoon or shared, off-site flood storage facilities may be used to contain fire-fighting run-off, providing that they incorporate shut-off devices If pumped storage or transfer facilities are in use, a back-up power supply should be considered. Tanks Purpose-built tanks may be used for the containment of fire-fighting runoff or spillages. Although most tanks are not designed specifically for the containment of spillages or firewater, they are suitable for use as secondary containment and may be more expensive to construct than lagoons The actual type, size, design standards and protective finishes of the tank will be influenced by the terminal s risk rating, the retention time, the quantity and the nature of the materials stored. Where available, an economical option might be to make use of an adequate redundant or spare tank Tanks can be constructed both above and below ground out of using materials stated in the Kenya standards The tank will need to be protected from corrosion and aggressive conditions. This may be provided by a range of coatings, including Page 20

21 bitumastic paints, epoxy coatings and rubber and glass linings. These will be determined by the substance to be contained, as well as other corrosive influences In all cases, it is recommended that a minimum freeboard of 300 mm is provided as a buffer capacity. No overflows should be permitted within the freeboard depth. Tanks that are open to rainwater will require regular monitoring and emptying to maintain the necessary containment capacity The most onerous loading conditions should be considered for design purposes. The overall depth of the tank including freeboard should be taken as the minimum design depth when assessing the static head of contained liquids In some emergency situations it may be possible to use storm tanks on the sewerage system, at a STW or at other effluent treatment facilities. This will require consultation with the sewerage undertaker and should only be used as a last resort and should not be relied upon, as the tanks may be full in the event of a storm The effects of the discharge on the STW should also be considered, as damage to the treatment process may result in greater environmental harm, due to the discharge of raw or partially treated sewage, as well as the contaminated run-off. Alternative means of disposal may need to be considered if the contained material is unsuitable for treatment at the STW. Shut-off Valves and Penstocks Shut-off valves or penstocks which can isolate part or the whole of a terminal facilitate the retention of spillages or fire-fighting run-off at the terminal. Their effectiveness depends on the capacity of the drainage system. They may be operated manually or triggered by means of automatic sensors Automatic sensors and closure devices may be used to ensure a rapid response on terminal where an incident might not be immediately noticed. It is vital that such devices are properly maintained and regularly tested. In the event of an incident, it is essential to verify that they have functioned properly as soon as possible, either by inspection or the use of telemetry Consideration should be given to the consequences of overflows from gullies and other entry points to the drainage system. Oil Water Separator Oil separators are devised to contain spillages of hydrocarbons and other, lighter than water, immiscible liquids. They will not contain soluble Page 21

22 substances such as soluble oils and their action is adversely affected if degreasing agents or detergents, such as those used in some fire fighting foams, are present If separators are to be used to contain large spillages, bypass type separators should not be used Separators may also be fitted with a penstock valves at both inlet and outlet to provide flexibility in handling spillages OWS shall have adequate controls to ensure that only authorised discharge passes through the outlet (Also see Page 22

23 TGN 1.2 Design of Oil Separators in Surface Drainage Systems). Emergency Containment Systems Although permanent containment facilities should be provided at many terminals, there may be circumstances where a spillage cannot be dealt with by such facilities, for example if it occurs outside a bunded area In other cases, particularly at smaller sites, firewater containment facilities may be impracticable because of cost and space considerations. In such cases, temporary containment systems or pollution control materials should be considered If reliance is placed on these secondary measures, consideration of some other form of local containment may be necessary to provide sufficient time to prepare them. Their use and location must be clearly marked in the PIRP and indicated on terminal with durable signs explaining their use Emergency containment measures include: Sacrificial Areas This method relies on the conveyance of firewater to a remote, designated sacrificial area, designed to allow infiltration and to prevent run-off The contaminant is contained within a layer of permeable soil or porous media and should be prevented from dispersing into other strata or groundwater by an impermeable lining system which should be capable of containing both vertical and horizontal flow The storm water drainage serving the area must be capable of being shut off quickly and effectively during an incident, until the contamination is dealt with After use, if the area has been contaminated, the permeable material should be excavated and removed for disposal Area could also be used for controlling storm water run-off from the terminal, which helps in the management of flooding and pollution from surface run-off. Bunding of Vehicle Parking and Other Hard Standings Impermeable yards, roads and parking areas can be converted to temporary lagoons using sandbags, suitably excavated soil or sand from emergency stockpiles to form perimeter bunds Permanently installed bunding, in the form of either a low kerb or rollover bunds around suitable impermeable areas, the entire terminal, or just the sensitive area, is a better option. Page 23

24 In the event of an incident, all drain inlets, such as gullies, within the area, must be sealed to prevent the escape of the pollutant. Page 24

25 Pits and Trenches Pits or trenches may be used where other methods have failed or no other method is available. Their use should be considered carefully due to the risk of groundwater contamination If possible, a liner should be employed, particularly in areas of high groundwater vulnerability, although the effect of the substances being contained on the liner will need to be considered If no liner is used, the contaminated ground will need to be removed promptly to a disposal site Pits and trenches may also be used to add reagents for neutralizing harmful substances. Portable Tanks, Overdrums and Tankers Portable storage tanks made from synthetic rubber, polymers and other materials come in a wide variety of sizes The portability of the tanks allows them to be moved rapidly to the fire or spillage location, or to where any run-off has been contained If a portable tank is to be used during an incident, the following measures need to be considered: As part of the PIRP, suitable points in the drainage systems must be preselected at which the drainage pipe can be blocked and a man-hole chamber used as a pump sump to transfer contaminated waters to the tank. A suitable pump, which may need to be flame-proof, will also be required Locations for the erection of portable tanks must be pre-selected (areas such as car parks are most suitable), ensuring that there is both sufficient space and an adequate foundation Larger sizes become increasingly unwieldy and will need to be supported by a frame Consideration may also be given in the PIRP to the re-use of the collected water to tackle the fire. This should take into account the materials present on the terminal and the risks to equipment, through contamination, and to the safety of fire crews Overdrums, which are designed primarily to safely store leaking or damaged drums, can also be used as a temporary store for a small quantity of a spilt liquid Re-usable liners are available for overdrums and portable tanks. These must be resistant to attack by the stored substances. Page 25

26 Vacuum or similar mobile tankers may also be used for collecting and containing small spills 11. Emergency Materials and Equipment General A wide variety of products are available to deal with spillages or to contain spills in emergency containment area Any materials or equipment used must be well maintained and strategically placed at accessible locations which are clearly marked with durable notices explaining their use The PIRP should identify pollution prevention equipment and materials and their location. Sand and Earth These are versatile containment materials which may be used to soak up spillages of oil and chemicals and used in sand bags to block off drains or to direct flows to a predetermined collection point Sand should be kept dry and a shovel should be available Contaminated material must be properly disposed of and must not be washed into the drainage system. Proprietary Absorbents These serve a similar purpose to sand. They are available as granules, sheets, pillows or a loose powder Although most absorbents are designed for hydrocarbon spills, products are available for chemical spills. Sealing Devices and Substances for Damaged Containers These devices and materials are designed for use when a tank, storage drum, valve or pipe has been punctured or damaged Leak sealing devices may take the form of a pad or clamp which is put over the damaged area like a plaster, or they may be pre-shaped, inserted into the damaged area and then inflated. Page 26

27 Leak sealing putties are also available, readymade or supplied in a dry powder form for mixing with water. These are applied over the damaged area to form a temporary seal A more permanent method may be required before moving the damaged vessel. Drain Seals There are several types of drain seal, including those which can be used to seal a drainage grid by covering or blocking the drain and those which fit in a pipe The use of a pipe seal may enable the drains to be used as a retention system, which may provide a significant volume of containment Drain seals should be kept in a readily accessible location close to where they would be used Care should be taken in their installation to avoid exposure to hazardous conditions and to ensure the contained liquid does not overflow from gullies or elsewhere on the drainage system. Booms Booms designed for use on watercourses may also be used to isolate drains or divert or contain spillages Absorbent booms are filled with absorbent material which can be suitable for hydrocarbons, aqueous chemicals or both Plastic physical barrier booms can be inflated with air or water. 12. Waste Management Measures should be in place to dispose of as per EMCA(Waste Management) Regulations Where re-use is possible, the spilled material should be returned to storage at the terminal If off-site disposal is required, a licensed waste transporter in accordance to EMCA(Waste Management) Regulations should be used, although if a foul sewer is available it may be possible to discharge to it with the approval of the local sewerage undertaker It may be possible to treat hydrocarbon contaminated water using oil separators, but the presence of foam can adversely affect their efficiency. Page 27

28 12.5. The movement of the waste will need to be documented with a transfer note. The terminal operator will need to keep these notes for a minimum period of three years. Page 28

29 13. Fire-fighting Strategies and Run-off Management The PIRP may consider fire fighting strategies and possible methods of reducing the amount of firewater run-off generated, for example by the use of sprays rather than jets, controlled burn and the possible re-cycling of fire-fighting water, where it is safe and practicable to do so. 14. Pollution Incident Response Plan General A comprehensive Pollution Incident Response Plan (PIRP) should be prepared, maintained and used by personnel working at terminal It should be easy to read, logically formatted and provide sufficient detail The PIRP should establish necessary links between terminal emergency response protocols and the National and County Government emergency management structures Operational plans should ensure that the user is able to quickly and effectively respond in the event of accidental discharges, releases or other serious emergencies The effectiveness of an emergency response system depends on the documentation of the response process, the availability of adequate resources and training of those responsible for its implementation. The plan should support the concepts of Emergency Response Element s of Prevention, Preparedness, Response and Recovery The PIRP should be periodically reviewed (at least every two years) or after a major modification to ensure it remains up to date and effective The most important concern after making the terminal safe should be to contain then recover as much of the released product as practical prior to any escape of residues into the environment. Planning Cycle The planning cycle is the continuous process of assessing the risk of the site and preparing for incidents. Page 29

30 14.9. The process is supported by procedures that make sure the PIRP works (validation), that the terminal operator/owner reviews and revises it regularly and that staff and contractors are prepared and trained The key elements of the planning cycle are: a. Preparing the PIRP b. Activating and responding c. PIRP testing/training d. Reviewing and training The elements of the planning cycle ensure that the plan is updated, remains effective and communicated to staff and contractors, who should understand it. Prevention The terminal operator should aim to eliminate or reduce the probability of an unplanned release of contaminants and reduce the degree of damage that could occur to the environment In situations where spill risk exists, the following management measures should be arranged: a. Store hazardous materials in leak proof containers, on hardstand flooring on safe racks and weatherproof areas. b. Place spill risk facilities away from sensitive environments with a sufficient buffer to allow for effective intervention prior to pollution occurring. c. Use secondary spill control facilities such as bunded containment compounds. d. Avoid risk related activities at times when weather conditions may magnify any harm caused by a spill e.g. outdoor unloading during rainfall. e. Where practical, ensure all drainage structures can be sealed to halt the passage of spilt fluids. f. Ensure all employees and contractors are trained on safe procedures and good environmental practice. Preparedness An effective PIRP means being well prepared for accidents and emergencies and should include: a. An assessment of risk scenarios leading to accidental releases, leaks and spills and the probable impacts Page 30

31 b. Terminal incident response manuals, including the provision and maintenance of relevant Material Safety Data Sheets (MSDS) in locations accessible to staff. c. Staff training in incident response protocols. d. Continuous availability of suitable equipment to protect workers and mitigate the effects of pollution emergencies. e. Installation and maintenance of warning and emergency contacts signage. f. Plans for containment and disposal of contaminated fluids if there is a large spill or fire. g. Plans should be available for terminal drainage systems and where they discharge should be defined. h. Carrying out drills 15. Contents of PIRP The following details should be included in the PIRP: Purpose of the Plan State the aim, objectives, application and extent of the plan: a. Details of the site: name, full postal address, physical location and contact details b. Summary of the main business activities carried out on site c. Date the plan was signed off, by whom and the version number d. Person who s responsible for its review, distribution and implementation e. Distribution list of staff and external organizations that hold copies. f. The external contacts list should contain 24-hour contact details for all those organizations or companies that may need to be involved during or after an incident: i. ERC ii. DOSHS iii. Emergency Services iv. NEMA v. County Government County Government vi. Local Water Company Page 31

32 vii. Local Health Care Providers viii. Specialist Clean-up Contractor The internal contacts list will reflect the organizational structure of the terminal and the response procedures in place. Hazardous Material Inventory This details the types and quantities of products and/or hazardous materials stored or handled at the terminal. A MSDS for each material should be available. Terminal Layout Diagram This should be a clear diagram of the terminal showing layout and access details, along with a schematic representation of the terminal drainage arrangements. Page 32

33 15.6. Features on the Terminal Layout Diagram that should be included: a. Layout of buildings b. Access routes and meeting points for emergency services c. Location of terminal facilities for treatment of effluent or domestic sewage d. Areas or facilities used to store products and wastes (include details of ASTs sizes and products stored) e. Bunded areas, with details of products stored and estimated retention capacity f. Location of fireboxes and pollution prevention equipment and materials g. Any watercourse, spring, borehole or well located within or near the terminal h. Terminal drainage foul, surface and effluent drainage systems including features such as: i. Inspection points to detect pollution ii. Separators iii. Firewater/spillage containment systems iv. Pollution control devices (shut-off valves/penstocks fitted in drains) v. Other areas suitable for portable storage tanks, for blocking drains and temporary storage of firewater PIRP should provide a brief description of how all facilities operate. They should be clearly labeled above ground Use API RPs features of drainage plans to make them easier for other organizations to use and for staff to understand: a. Red for foul sewers. b. Blue for surface water sewers, watercourses and soakaways c. Blue for drain covers and grips Number drain covers to help identify them Mark the location, depth and construction details of soakaways or depth for boreholes and wells Indicate the direction of flow for all sewers Identify the sewage treatment works/sewage pumping station to which the terminal connects Identify all surface water outfalls from the terminal. Page 33

34 Description of Potential Emergencies Determine what incidents are likely to occur and the associated possible impacts both on and off the terminal Pollution pathways to environmental receptors should be determined Define the actions that may aggravate or limit the environmental impacts Develop action plans for each scenario. Action plans should include both on-site and off-site mitigation measures such as working with Government agencies to block stormwater drains Develop supporting emergency procedures to check the plan works if there s an incident Ensure all relevant staff and contractors are aware of these procedures and the plan including: a. Procedures for alerting key staff b. Standby/Rota Systems c. Clearly defined roles and responsibilities d. Names of staff and contractors trained in incident response e. Types and location of emergency response equipment available and appropriate personal protective equipment (PPE) to be worn f. System of response coordination g. Off-site support Clearly define the circumstances when the plan should be activated. This will depend on the nature of the terminal and the type of the incident Ensure all relevant staff know how and when to contact other emergency responders: emergency services, County Government and other organizations identified in the PIRP Consider the impact that an incident on the terminal could have on the environment outside the boundary: a. Nearby properties b. Contact procedures with them if possible. c. Put in place staff evacuation procedures d. Identify special methods to deal with substances posing particular health or environmental risk. e. Staff should be trained in the use of spill kits, drain blockers and other pollution control equipment and the operation of pollution control devices. f. Identify procedures for recovering spilled product and the safe handling and legal disposal of any waste associated with the incident. Page 34

35 g. Ensure staff are available who are trained to deal with media enquiries. Page 35

36 Risk Assessments These should be prepared by defining incident triggers, the probable frequency of occurrence (e.g. once a year), the probable scale of incidents and the impact thresholds i.e. the concentration that may cause pollution Factors such as dilution, soil filtration and storm water impact should be considered and applied in a conservative manner. Employee Safety Adequately trained and equipped staff should respond immediately to contaminant spills All other staff, in response to an alarm, should evacuate the terminal to a designated safe zone, as directed by terminal management or as directed by the agency that will take charge of the emergency response such as the Fire Brigade, Police or Specialist Contractor. Allocate Responsibility Terminal management should assign responsibility to a designated member of staff for implementation of the PIRP The roles and responsibilities of key support staff should be defined Ensure all staff are effectively trained to carry out their assigned function A 24-hour roster should be available so trained staff can respond at any time. Communications An effective round-the-clock communications system is essential Individual action cards should be prepared for personnel with roles and responsibilities under the PIRP. Backup Resources Trained staff and equipment should always be available to deal with emergencies Record the equipment and materials on the terminal to deal with pollution incident: Page 36

37 a. Absorbents or sand b. Drain mats/covers c. Pipe blocker d. Pumps e. Drums. f. Personal protective gear g. Monitoring equipment h. Fire-fighting equipment i. Waste containment skips If any equipment requires special training to use it, include the contact details of staff members who are trained in its use and are expected to fulfill the emergency response role. Test Emergency Procedures Test the PIRP regularly by exercising. Exercises are vital to: a. Validate the whole plan does it work? b. Develop staff s and contractors competencies in emergency response c. Test standard procedures Exercises can be discussion based, table top or live to test the whole plan or critical elements within it such as: a. Contacts lists b. Activation process c. Equipment d. Information management Where resources permit, include external partners/responders as this helps validate the PIRP The frequency of testing and exercising should be related to the environmental risk the terminal poses, staff turnover and conclusions from previous exercises or incidents The effectiveness of the PIRP will depend on staff training. Ensure that all staff and contractors working on-site are aware of the plan All staff should know their role and responsibilities and the relevant procedures if an incident occurs Maintain and regularly review records of all staff training, which should include: Page 37

38 a. Awareness of the potential for harm to people and the environment from the materials held on-site b. Information on the sensitivity of the environment surrounding the terminal c. Environmental responsibilities of the terminal d. Use of the correct personal protective equipment and/or necessary health and safety training e. Reporting procedures if is risk of surface water, groundwater or land contamination f. Reporting to the local water/sewerage undertaker if a discharge to the foul or combined sewer is involved g. Safe and correct use of all spill clean-up equipment or pollution prevention structures and/or devices on site h. Safe handling and legal disposal of contaminated materials and wastes resulting from an incident, including arrangements for using specialist contractors and services Notification of Authorities Procedures for contacting emergency services, and regulatory agencies in the event of significant emergencies should be defined including who will contact the emergency services, under what conditions and the relevant all hours phone numbers Examples of those to be contacted include: a. Fire Brigade b. DOSHS c. ERC d. NEMA e. Ambulance f. Oil Marketing Company g. Disaster Management Committees h. Red Cross i. County Government Notification of Neighbours A contact list of neighbors and the circumstances under which they need to be notified should be maintained. Page 38

39 A cooperative approach that promotes mutual aid assistance can assist in an emergency response situation. Evacuation In situations where people s health or well-being may be at risk, a procedure should be prepared describing who, when, where, and how people will be evacuated and accounted for and how the evacuation protocol applies Periodic evacuation drills are recommended. Incident Investigation Staff should report both actual incidents and near misses to the designated staff member responsible for the PIRP An incident review should follow to assess and correct any procedural defects discovered during the emergency Media Interest Effective media communication (press, radio, television and Internet) can be a key element both in implementing the PIRP for major incidents and dealing with community interest during and after the incident Adequate attention should be given to this issue prior to an incident occurring so the site operator is seen to be an honest, competent, caring and valued member of the community. 16. Response to Incidents or Emergencies General PIRP should contain a variety of procedures for dealing with potential pollution incidents identified as typical for the terminal The plan should also include for the disposal of wastes (including liquids) which may arise from a pollution incident and the subsequent containment and clean up Copies of the PIRP should be kept not only on the terminal, but also at convenient off-site locations which allow rapid access. It might also be Page 39

40 useful to provide copies to the Fire Brigade, NEMA and other regulatory authorities Facilities which employ specialist contractors to deal with incidents should consider lodging copies with these contractors A list of all persons/organizations holding the PIRP should be held and kept up-to-date. If there are any changes in the retained contractors the PIRP should be issued again The type of response will depend on the nature and amount of substances discharged, the environmental values present in the surrounding area and the risk of transmittal of the hazard to a receptor. Page 40

41 Incident Impact Classification Emergency response can be managed using a three-tier Impact Classification System based on a risk assessment of the potential severity of environmental impact The three-tier Impact Classification (high, moderate and low) is aimed at indicating the severity of the incident, so that appropriate resources can be deployed in response to the emergency. High Impact Incident In the case of a large scale incident involving considerable loss of product, the PIRP might only be able to ensure that environmental impact is minimized, and not achieve a full clean-up of lost product. In such cases, a longer term remediation strategy will be required This applies to any one or more of the following situations: a. There is a significant and immediate threat to human life or property. b. Could result in significant or immediate harm to native fauna and flora. c. Observable harm has occurred to environmental receptors d. Located within water catchments that have recognized conservation or scientific values. e. The incident has the potential to persistently contaminate soil or water resources. Moderate Impact Incident This applies to any one or more of the following situations: a. There is a significant (but not immediate) threat to human life, amenity or property. b. Located within close proximity to private water supply sources. c. Chronic or long-term harm to native fauna and flora may result. d. Long-term (but not immediate) observable impact may occur to environmental receptors. Low Impact Incident This applies to any one or more of the following situations: a. No perceived threat to human life or property. Page 41