Storage Terminals Face Strong Need For Updated Emergency Response Plans

Oct. 1, 1998
Storage terminals that handle hazardous materials are coming under increasing public scrutiny. It is more important than ever that these facilities have

Storage terminals that handle hazardous materials are coming under increasing public scrutiny. It is more important than ever that these facilities have up-to-date emergency response plans.

Spill response planning and remediation were addressed by several speakers at the 18th Annual International Operating Conference in Houston, Texas. Held in June by the International Liquid Terminals Association, the meeting focused on issues of concern for bulk liquid transfer and aboveground storage tank terminals.

Gordon A Robilliard, vice-president of Entrix Inc, discussed the potential impact of the National Resource Damage Assessment (NRDA) and why storage terminal operators should be concerned. In short, this program has the potential to significantly increase cleanup costs.

"Storage facilities often are in environmentally sensitive areas," he said. "They handle oil and other hazardous substances, and there is always potential for spills. NRDA makes cleanup a much more challenging project."

Under NRDA, a board of trustees reviews any spill that damages natural resources. Natural resources are defined as anything but people. Government agencies make up the board of trustees, and they are charged with collecting money for damages from responsible and potentially responsible parties.

Cleanup costs include two components: actual restoration cost and compensation for interim loss of services and resources. Trustees assign costs that are reasonable and not punitive. However, they are given a wide latitude, Robilliard said.

"On average, NRDA involvement in a spill boosts response costs by 25%," he said. "The financial impact can approach $15 to $20 per gallon, and that's in addition to fines and the actual remediation cost. NRDA-related cleanup costs can easily exceed annual revenues or profits."

Robilliard encouraged storage terminal operators to take a proactive stand. They need to evaluate natural resources that are at risk and assemble a history of oil spills at the terminal and in the area. What have NRDA trustees in the area done in the past?

Preplanning includes operating a terminal in a manner that prevents spills. An NRDA immediate-response plan should be developed, and a manager and team should be chosen. Consultants and subcontractors should be identified in the plan.

It is crucial to meet with the NRDA trustees in the area where the terminal is located. Applicable laws, regulations, and guidelines should be identified. Sampling kits should be assembled, and spill drills should be conducted.

If a spill occurs, the terminal's NRDA team should be mobilized immediately and begin collecting samples in the area affected by the spill. The NRDA trustees must be contacted, and terminal managers must make it clear that they will cooperate in whatever way they can.

"Lastly, you should prepare for an extended cleanup process," Robilliard said.

Storage terminal operators also will be increasingly affected by risk-based corrective action (RBCA), a new ASTM (American Society for Testing and Materials) remediation standard. The standard focuses on damage that is likely when a spill occurs.

"RBCA is a framework that enables managers to make cost-effective risk management decisions," said Michael Kinkley, director of environmental remediation at GATX Terminals Corporation. "It has the potential to save billions of dollars across various industries.

"It is a defensible technical process that protects human health and the environment. It links actions to site-specific exposures and risks, and it achieves closure of the remediation effort.

"ASTM is ideally suited for this type of program because the organization has a standards-development infrastructure in place. Decisions are made through a voting approval process, and all negative votes must be resolved. ASTM is not tied to any specific industry."

An RBCA petroleum standard has been completed, and a provisional standard for chemicals has been published. States are beginning to adopt the standards.

Industry has provided much of the driving force behind the RBCA standards, and the objective is to remediate a site as quickly as possible for the lowest possible cost. A key value of the standard is that it clarifies risks for management.

The process starts with a site assessment during which managers look at all potential release phases and outline the potential impacts. It's important to analyze where a release will go, how it will change, and who will be affected.

The next step in the process is to classify the site. Under RBCA, there are four classifications, with Class 1 being an immediate threat and Class 4 standing for no perceived threat.

The amount of data needed to accurately assess corrective action under the standard is determined by a three-tier approach. Tier 1 is the lowest cost option and requires essential site data.

Tier 2 imposes a moderate cost and calls for more site data, along with some modeling. Tier 3 brings the highest cost and includes site-specific modeling.

William S Wilson, training director for Robert J Meyers & Associates Inc, described the latest developments in modeling software that can be used to study the way a spill is likely to perform. He specifically addressed geographic information systems (GIS).

"This is a relatively new tool for personal computers," he said. "The software has powerful mapping capabilities and can run on desktop or laptop units. Terminal locations can be analyzed in detail, and potential spill sites can be isolated based on a customized set of criteria.

"Information management is the key to a good spill response plan. GIS helps a company to decide when and where to allocate emergency resources. Most importantly, the maps used in GIS can be easily updated.

"GIS helps emergency responders avoid the information overload that can result when they are trying to keep maps up to date. It also helps prevent the extreme clutter that can occur when hard copies of maps are repeatedly updated."

The software tracks where a spill is going and what personnel, equipment, and resources are available to fight the problem. It helps identify environmentally sensitive areas very quickly. Some of the software on the market even includes digital photographs of plants and animals.

Schematics of the spill location can be created on the computer, and step-by-step spill response plans can be organized. The software can even provide lists of hotels, motels, and other facilities that might be needed.

The mapping capabilities are very flexible. Map scales can be adjusted as needed, and distances can be calculated using any scale. Any type of map can be used, including aerial and satellite photographs.