As a company that specializes in oil and hazardous material transfer operations, you pride yourself on safety and stewardship. It goes without saying that spill prevention, among other things, is the best solution to pollution. Even a company whose operations don’t involve oil or hazardous material transfers, if you store, handle, or maintain a supply of oil or hazardous material on site, you run the risk of causing a mishap. For the following, we will leave response procedures for another day and focus on prevention.
A spill is something that no company wants to have to deal with. Between the costs of cleanup, recovery, recuperation, and fines, the financial impact that stems from a spill or release can be staggering. Include this with the resulting publicity that your company will undoubtedly face, and you can see why spill and release prevention measures are things to take seriously.
The world we live in is something that is shared. When an unfortunate event like a spill or release occurs, those we share this world with will want it to be restored, recovered, or rectified in some way. In order to prevent spills and releases into the environment, it is imperative to develop a comprehensive plan that involves industry standards, regulatory requirements, and keen foresight to ensure that a spill or release doesn’t happen on your company’s watch. These following tips will help you and your company develop awareness and operations that will hopefully prevent spills and releases.
1.) Keep up with containment. Let’s face it: product can be a sneaky thing that can be discharged from a hose coupling from time to time. This is usually caused by residual product left behind in a hose before or after a transfer. This is where small discharge containment comes into play. This containment is meant to catch any drips and splashes that may come from the hose or the fixed piping that it was coupled to. Routinely check your discharge containment for cracks along welds, in corners, and anywhere else there may seem to be a weak spot. These should not be visual in nature alone–these checks should involve leak tests to ensure there aren’t any pinholes present that may not be readily found visually. This isn’t just for companies that merely store oil and hazardous materials, but for all companies whose operations involve one or both. These companies should develop a containment plan for any possible spills or releases that can happen with the materials on site. Remember that containment could mean the difference between a simple allowable drainage to a visit from enforcement agencies.
2.) Keep up with condition of hoses and pipelines: Hoses and pipelines are workhorses in the petrochemical world. They are constantly feeding consumers with necessary products they need. These hoses and pipelines need the attention they deserve. Granted, operating pressures may be well below the Maximum Allowable Working Pressure (MAWP), but there are various other factors involved that can lead to hose and pipeline failure. An example of pipeline failure can be seen in Santa Barbara, California, where approximately 123,000 gallons of crude oil spilled onto the beach and into the ocean. The Pipeline and Hazardous Materials Safety Administration determined that the direct cause of failure was external corrosion of the pipeline. Hoses and pipelines are exposed to various types of environments that can effect their structural integrity. Develop a plan to have your hoses and pipelines checked regularly. If what you have are removable non-metallic hoses, then ensure they are tested and inspected appropriately. If a fixed pipeline is involved, have monitoring devices installed and ensure that your employees heed their readings. Had the responsible party been doing this, it could have saved them legal headaches and millions of dollars in fines.
3.) Keep up with equipment: equipment can be just as important as hoses and pipelines. Your equipment needs to be functioning as it is intended at all times. Pumps, booms, and machinery all require maintenance to function properly. Be on top of maintenance as per the manufacturer’s instructions. Seals and gaskets can fail. Critical components require calibration. One should also not forget about equipment that isn’t directly used with product operations all of the time. Hydraulic systems, cooling lines, and more have materials that can discharge or release that will result in a reportable mishap. Maintain your equipment to ensure reliability, and don’t be afraid to dispose of any equipment that looks like it has any chance of letting you down. A $400 hose is a lot less expensive than fines and negative publicity.
4.) Keep up with your plan: whether or not you specialize in transferring oil or hazardous materials through hoses and pipelines, if your company’s operations cause you to run the risk of discharging any reportable quantity of materials that could lead to a visit from various levels of government agencies, then you should have at least two different plans: one for general operations and prevention, and another for response. For example, Title 33 Code of Federal Regulations Part 154 has requirements for the Operations Manual and Facility Response Plan for companies that fall within that Part’s applicability. Even if you’re not applicable, this doesn’t mean you can’t borrow from that Part. Develop a plan–in writing–that will outline exactly how you do your operations in a safe and responsible manner. Then, develop a second plan that will outline how you will respond to any release or discharge of oil or hazardous materials. If you already have plans for your company, when was the last time they were audited by an outside entity? How often do you or your managers review them for updates? While this may already be a requirement for certain companies out there, if it isn’t a requirement for you, there isn’t any reason not to make it company policy. There is no harm in going above and beyond what is required of your company.
5.) Keep up with diligence: This all brings me to our final point: people. People are undoubtedly what makes or breaks a company. You can write all the policies, manuals, and procedures you want, but if your people don’t have buy-in, then all of your administrative measures won’t mean much. One of the top reasons that oil spills and hazardous material releases occur involves human error. There is always that ever-so beloved “human element” in any operation that can be the cause of a spill or release. Be sure to stay abreast with the latest and greatest in regulations and industry practices. Be on top of any manufacturer’s updates. Ensure that your people care about what you care about. Be diligent with their training and professional development. Have your managers manage properly. And for the love of