May 20, 2024 • 28 mins
When you have an oil spill, it can be stressful, and the reporting process can be confusing. But, in this episode of Tank Talk, we break down the six critical steps to take immediately after a spill occurs, emphasizing the importance of rapid action and clear communication with authorities to minimize environmental impact. We also dive into the unique challenges terminal managers and operators face, from the stress of providing accurate spill volume data under the watchful eyes of state and federal agencies to the importance of candid communication during a crisis. Our conversation equips you with strategies to streamline spill notification procedures, enhance your understanding of the Incident Command System (ICS), and ensure you're ready to respond with poise and precision when spills happen.
Episode Transcription
Additional Resources
National Response Center (NRC)
Alaska Department of Environmental Conservation
FEMA ICS 100 Training
FEMA ICS 200 Training
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Episode Transcript
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Amanda (00:00):
Good morning Shannon.
What are you wanting to talkabout today?
Shannon (00:03):
Good morning Amanda.
Well, it's a really nice springday here in Anchorage, and
spring is when a lot ofcompanies we work with begin
preparing for summer fueldeliveries, and so I was
thinking we could talk aboutspill notifications today,
because spill notifications arepart of drill exercises that our
clients perform for manydifferent regulatory agencies,
(00:27):
and it's something, honestly,that a lot of people struggle
with, and so what do you thinkabout talking about that?
Amanda (00:33):
What makes spill notifications so complicated?
Shannon (00:37):
Well, there's three main reasons.
The first is that actual spillnotifications like when you're
really calling one in, they'realways done under stress, so
they're very stressful.
The second is that spillnotifications can feel a little
complicated because all thesedifferent regulatory agencies
and parent companies, they allhave different reporting
(00:58):
triggers.
And then lastly, if you'redoing it right, you don't have
spills regularly enough to sortof make reporting routine.
So all three of those feed intospill notifications being
difficult for many people.
Amanda (01:13):
It sounds pretty complex .
Where do spill notificationsfit into the bigger spill
response timeline?
Shannon (01:20):
That's a really good question because a lot of people
, amanda, think it has to happenfirst, like oh, there's a spill
, I have to call it in.
But I do want to point out thatnotifications are actually
after a few critical initialresponse steps.
Do you want me to go over those?
Oh, that would be great.
So there's six of them, so letme go through.
I've got them written downbecause I'm good, but I'm not
(01:42):
that good.
Number one determine what hasspilled and if the scene is safe
for you to enter.
What has spilled really impactshow you respond to it, for
example, the difference betweena response to a diesel spill,
which is a combustible material,and gasoline, which is
(02:04):
flammable and has a high vaporcontent.
Those two are going to be verydifferent spill response steps,
and so you need to know whatyou're working with there.
The second is to make sure thateverybody involved in this
spill has the right PPE personalprotective equipment on, and if
they don't go, get it on.
Three, shut off any ignitionsources pumps, machinery,
(02:28):
electrical.
Almost every spill has vapor ofsome kind as the spill
progresses, and so shutting offthose ignition sources will help
keep everyone safe and preventbigger problems from occurring.
Related to that.
Number four is to stop thesource of the spill.
If you can, shut off the valve,stop the pump, close the drain.
That step number four hasprevented major spills so many
(02:49):
times in my career.
Somebody was real quick,realized what was happening and
ran over and turned the valveoff at the secondary containment
.
Somebody realized what washappening and radioed the barge
and had the pump immediatelyshut down.
All of these stopping thesource of the spills can really
shrink the impact of the spillif they're performed right away
and not delayed.
(03:09):
And then the last two isolatethe area, and this is to
restrict access to other peopleso that you don't have a
spreading of the spill by peoplethat are not knowledgeable
about it.
So, for example, if you spillfuel across a roadway, you don't
want cars driving through itand dragging the fuel with them
on their tires.
Same thing in a small boatharbor.
(03:30):
If you've got fuel in the smallboat harbor, you don't want the
vessels going through that fueland taking it out of the boat
harbor.
Right.
And so it becomes reallyimportant to get that area
isolated and make sure peoplearen't traipsing through it.
Important to get that areaisolated and make sure people
aren't traipsing through it.
And then lastly and this isspecifically for someone who's
(03:52):
in charge of doing spillnotifications they need to
direct others to begin controland cleanup tactics, like, hey,
you guys go get the boat andsome boom and start circling the
dock so that they can work onthat while you're doing the
notifications.
Start circling the dock so thatthey can work on that while
you're doing the notifications.
Once you get those six initialresponse action steps done, now
(04:12):
it's time to make notifications.
There's three levels local,state and federal and we can go
into the details of what toreport later.
But I do get a lot of questionsabout how long to wait, like
how long can I take before Ineed to call the state if it's
not immediate?
And our firm generallyrecommends no more than half an
hour.
The reasons for that is, mostof these initial steps can be
(04:34):
accomplished within 30 minutes.
And then, if this is asignificant spill, like if
you've let thousands of gallonsof fuel enter a water body, some
of the bigger agencies, likethe US Coast Guard, have
resources that can be brought tobear to minimize the effects
sooner.
So you don't want to wait toolong because you may be cutting
(04:57):
off some of these agencies'abilities to help or to bring
resources that you don't have.
So no more than half an houryou can have other staff members
working on initial responseactions and containment and
control while you do thenotification.
And it's okay to not have allthe information when you call
and we'll go through that later.
Amanda (05:16):
You had mentioned earlier that agencies have
reporting triggers.
Would you share some of thosewith us?
Shannon (05:23):
Yeah, let's talk about what a trigger is, because that
is some of what makes spillreporting so challenging for
people.
So spills vary in size,material type, location, and
some spill situations are lesscritical than others.
I mean, imagine you're changingthe oil on your car and you
(05:46):
spill a gallon of oil to theconcrete floor of your garage.
That's going to be differentthan if you spill a gallon of
oil from your vessel's bilgepump right at the small boat
harbor.
It's going to be pumping out agallon of oil into places where
everybody's going to be trackingit and it's directly to water,
right, maybe more critical.
(06:07):
So the state of Alaska and theEPA and the Coast Guard all have
different levels of spillreporting that trigger certain
notification requirements.
So before you can do spillreporting, you sort of need to
understand what needs to bereported within what timeframe,
and those two pieces together iswhat the trigger is.
Some of them are prettystraightforward and some are
(06:28):
more nuanced, which increasescomplexity for people who don't
report very frequently.
What do you want me to startwith?
Federal or state?
Amanda (06:36):
Start from maybe federal notifications.
Shannon (06:39):
Oh good, I'm glad you chose that one.
It's the easiest one For bothEPA and the Coast Guard.
You'll be making a report tosomething called the National
Response Center, and that phonenumber is 1-800-424-8802.
It's a one-stop shop forfederal agencies.
However, their one and onlytrigger is and I also have this
(07:02):
written down because I did nothave it memorized as soon as
knowledgeable of an oil spillfrom a vessel or facility in or
along US navigable waters commaon the outer continental shelf,
in a deep water port or from avessel transporting oil from the
outer continental shelf, andthe very plain English version
of that is any spill of anyamount to surface waters.
(07:23):
These apply to all fuelproducts ultra low sulfur diesel
gasoline, regular and lead andpremium AvGas 100 low lead Jet A
heating oil number one andnumber two kerosene any of these
fractions of refined product.
That's what we're talking abouttoday.
(07:44):
So these notifications arespecific to fuel products.
So I just want to make surethat's clear for anybody taking
notes, so that they don't thinkthese apply to other products,
because the state has some verynuanced reporting triggers.
Amanda (07:59):
So what are the specific triggers for Alaska?
Shannon (08:02):
Yes, the State of Alaska spill reporting is a
little more nuanced than thefederal reporting.
There are different time framesfor reporting, based on the
location of the fuel spilled andthe quantity of the fuel
spilled.
Fortunately, the state has madea handy dandy placard that's
available on their website andwe will definitely include in
the show notes, and that placardhas really critical information
(08:26):
for spill reporting, so I'mgoing to cover it here.
One is the phone number to call.
There are two (08:32):
one is a toll-free number and one is the
international number.
The toll-free number is1-800-478-9300.
And then there's aninternational number and this is
important especially forvessels that are entering
Alaskan waters.
They may not necessarily beland-based and that
international number is1-907-269-0667.
(08:57):
And then this is a little bitnewer within the last two or
three years, but they have anonline reporting system as well
now, and that'sreportspillsalaska.
gov, and again, we'll includeall the links to this.
But you can go ahead and goonline and report spills.
I do want to remind people thatthe reporting of spills for the
(09:18):
state of Alaska is required bothby statute and regulation, and
the posting of this placard isalso required in areas that
transfer fuel.
In addition to the phonenumbers, the oil spill reporting
placard also has a breakdown ofwhen to call the state and some
(09:40):
of those volume and locationtriggers.
So, first, any spill to waterneeds to be reported immediately
and that is in alignment withthe federal requirements.
So any spill of fuel product tothe water, you need to call it
in as soon as you can withinthat one-half hour window If the
amount of fuel spilled is over10 gallons but under 55 gallons
(10:04):
and this is to land, because ifit was to water it would be
immediate but if you spill 10 to55 gallons on land, you'd need
to report it within 48 hours.
If you have a spill occur toland that's between 1 and 10
gallons, you need to report iton a monthly spill log, which we
will also post on this episode,and note that this is to land,
(10:27):
not to secondary containment.
We'll get to secondarycontainment in a minute.
And then, lastly, the statesays if it's under one gallon to
land, reporting is not required.
But we are going to ask you tobe a decent human being, keep
Alaska great and clean it upanyways.
Many companies choose to reportall amounts, but the regulation
(10:48):
does say specifically thatspills under a gallon to land
are not required to be reported.
Amanda (10:53):
What about spills that occur into a secondary
containment area?
Shannon (10:58):
Well, the state has another regulation criteria for
reporting to containment, andthat is if the spill to
secondary containment exceeds 55gallons, you need to report
that within 48 hours.
And this one's a little harderfor people to wrap their heads
around because you're notactually spilling to land or to
(11:18):
water.
You're spilling it to animpermeable area.
So why would you need to reportit?
And the regulation does not saywhy, but in my experience doing
this for 20 years, I believethe reason that that regulation
was included was because ifsomething releases that amount
of fuel to the secondarycontainment area, there's
(11:39):
probably something in thefacility that is malfunctioning,
and that's a good way for thestate to determine if there's
something they need to look atat that tank farm, if
maintenance is required, andthey're not doing it and they're
having all these spills tosecondary containment.
That's my best guess.
I am not currently a regulator,nor did I write these
regulations.
(12:01):
The takeaway is that if you dohave a secondary containment
area spill that's bigger than 55gallons, you've got two days to
notify the state.
And then one more note on thisspill placard is that they do
require you to post theseanywhere you transfer fuel.
This includes fuel deliverytrucks at marinas.
It includes at bulk fuelstorage offices, and this is a
(12:24):
requirement of 18 AAC 75 325.
So it applies to all fuelstorage facilities, not just the
larger 10,000 barrel or 420,000gallon facilities.
If you do have a spill placardin your office or place of work,
I'd like you to look at itright now, and at the bottom
there's a revision date.
(12:45):
If that revision date is notOctober of 2022, which is the
most current version at the timewe're recording this podcast,
you need to update that spellplacard to be compliant with
that regulation.
Amanda (12:57):
And how do we know which agency to call first.
Shannon (13:01):
You know I do get asked that question a whole lot,
Amanda, I think it probablydoesn't matter, as long as you
call both right away, like oneright after the other.
However, I generally say, ifyou've got a spill to open water
, specifically like the ocean orthe shoreline, I generally
(13:22):
encourage people to call NRCfirst, because then you've got
the US Coast Guard aware of thefacility or, sorry, aware of the
situation and they can activateresources if needed.
If it's to land, then generallywe call the state first,
especially if it's to land andit's not to water.
Yet you may not need toactually notify NRC (National
(13:44):
Response Center) until you getto water.
Although in the spills we'veparticipated in the past, if the
spill is larger than a fewgallons, I generally call NRC
just to let them know that it'sthere and the volume or that it
has not made it to water yet.
And the reason for that isbecause people, when they know a
spill is going on in acommunity, often call the Coast
(14:06):
Guard to find out what they'redoing about it.
And so if they haven't heardabout it and don't know about it
, they're going to call you tofind out more anyways.
So it makes sense to just sortof notify everybody, even if it
doesn't necessarily meet thenotification requirements.
They're still going to becurious about it and probably
hear about it from a communitymember.
One of the other things that Iwant to make sure to really
focus on for this because thisgets missed on spill
(14:28):
notification training all thetime is that you have to call
both.
If it's to water, so you've gotto call the state, you've got
to call the NRC.
The NRC will report to both theEPA and the Coast Guard, and
even some other federal agencieswill maybe be made aware of it,
like marine mammal groups andstuff like that.
But you can't just call onelike the NRC.
(14:50):
They won't notify the state,and if you call the state, they
won't necessarily notify theCoast Guard and the EPA.
So you have to call both andthat will cover your bases.
So, again, this is why peoplestruggle with this, because
there's all these small piecesthat you have to keep in mind.
Amanda (15:10):
Is there a guideline for information of what needs to be
reported?
Shannon (15:17):
So the way the regulations are written.
The regulations require thesetwo agencies to be notified if
there's a spill to water.
But if you have a spill planthat was written to meet other
regulations like 40 CFR, 112 and18 AAC 75, also known as SPCCs
or an OD PCP, you will also havenotifications to make to local
(15:42):
stakeholders and potentiallyother stakeholders, depending on
the spill.
Often the harborbormaster orthe fire department and the
public safety department arenotified because they'll need to
help with response or trafficmanagement.
If the spill is in a criticalhabitat area or a historic
preservation area, then certainfederal or state agencies must
(16:03):
be notified to assist withendangered species.
Marine mammals, culturalresources are all good examples.
And then another common one wesee all the time is that if the
spill happens near a seafoodprocessor, that processor needs
to be made aware of the spill sothey can shut down the
saltwater intake so they're notsucking up fuel into their food
(16:25):
processing facility.
Amanda (16:28):
So what information are we needing to report?
Yeah, that's.
Shannon (16:35):
That's the kicker question.
So there's a lot of informationthat's needed when there's a
spill and when we drill this.
It's very easy to have all ofthe information available from
the spill plan.
You can like read ahead and youknow all the things right, and
so it's very easy to fill it outand be like oh yes, these are
all the things, and I can fillthis whole form out and call the
(16:58):
state and EPA within 30 minutes.
However, in a real spill,that's never what happens and
you only have part of theinformation and maybe not all of
the information you really need.
So what we typically recommenddoing is the state of Alaska has
a reporting form available forfree on their website that we
will include in the show notes,and that reporting form has a
(17:20):
little space for pretty muchevery single piece of
information that the state wouldwant to have in the event of a
spill, and it's a really goodtraining aid.
So if you're going to do spilldrill trainings, start with this
sheet and what the state andthe NRC are both looking for.
You know, essentially it's likea 911 dispatch.
They have a series of questionsthey're going to ask you when
(17:42):
you call and they're trying tounderstand how big the spill,
what the potential impacts are.
If there's any public safetyissues, you know they're,
they're looking at it from thestate and federal level, and so
there's there's this checklistof information that they're
going to want to have.
Amanda (17:59):
So we get that form completed, we write everything
down and then we call it in Wellyes and no.
Shannon (18:07):
So, uh, you are going to want to use that form to
collect the data that you can.
Uh, but most of the times whenyou have a spill in real life
you do not have all of theinformation.
So you'll have some of it, butyou should not delay reporting
to collect more information, andI think it actually says it
right on that form.
So some of the criticalinformation you should have when
(18:30):
you make that first call is thespill location and its
potential to travel.
So this includes location whereyou think, like where it is
right now and where you thinkit'll end up in the near future,
like in the next two to fourhours, based on tide, wind and
weather.
It's important to report theactual location of the spill,
which may be different from thefacility location.
(18:50):
We were involved in a spillonce, Amanda, where the general
manager reported the facilityGPS coordinates, because that's
what was written on the cover ofthe plan, but the facility
itself was a mile inland fromwhere the spill occurred, at the
marine header, and that causeda lot of confusion for the Coast
Guard because it was reportedto them as a spill to water, but
the GPS coordinates were a mileinland.
(19:12):
So make sure that if it's notat your facility to get updated
or correct GPS information forthe actual spill location, I
wanted to talk about informationthat you don't know.
We have a lot of terminalmanagers and operators that,
because of the stress you knowthey're having this big spill,
(19:33):
they feel very responsiblebecause every terminal manager I
have ever met takes fullresponsibility for their
terminal Right, and so they're.
They're feeling a lot ofpressure, they're really upset
because something bad happenedand they're feeling super
responsible.
And so there's this like urgeto kind of fill in the blanks,
because there's a lot ofpressure from the state agency
and federal agencies Like howmuch did you spill?
(19:54):
What's this?
How is it going?
What was the root cause?
Because they do need thatinformation.
But I want to reassure anyonelistening to this that you don't
.
It's okay to say I don't knowyet or I don't have good
information to give you for that.
And when you start a spillreporting process, there's going
to be lots of follow-up phonecalls as they develop an
(20:15):
incident command system and amanagement team.
There's all these things thatfollow after.
That will give you a chance togive that information when you
have a better idea of what it isand where this really sticks
for most people is the volume ofthe spill.
And I'll just say this bluntlyDetermining the volume of a
(20:36):
spill by eyeballing it is verydifficult, especially if you
don't respond to spills on adaily basis.
Once it hits water, it spreadsout really thin, Amanda, and it
can look like a lot of fuel, butit can actually be a very small
amount.
It's just widely spread out onvery calm water, on very calm
(20:58):
water.
It also can look much smallerthan it is if it's in choppy
water and the water surface isdisrupted and it just doesn't
look like it's sheening, butthere's more fuel than you think
on the water.
And so what we recommend formost people that are going to be
responding initially to thespill, which FEMA and wildland
firefighting calls the on-scenecoordinator for most on-scene
coordinators, it's going to bebetter to get your volume number
(21:19):
from looking at inventorynumbers or backwards engineering
what's missing.
So if you have a spill from atank and you know that yesterday
it had 100,000 gallons, there'sa spill that happened, and you
go and you dip the tank and it'sat 93,400 or something you know
, that estimate is better thantrying to look at your secondary
containment or look at thegravel pad that it spilled to
(21:45):
and trying to determine how muchfuel is there.
Determining fuel to soil is alsovery difficult because it can
soak into the soil and just gostraight down, and so you can
actually have a very smallsquare footage at the surface,
but it goes straight down for 28feet, you know.
So those are.
Those are some things that makeit difficult.
So we tell most people, ifyou're going to do a volume of a
(22:07):
spill at in real life, um, doit from inventory backwards,
engineer it.
And this is something that'sdifficult when you practice
spill drill notifications,because typically the spill
drill tells you you have spilled4,000 gallons of fuel to the
secondary containment.
The secondary containment has acrack and it's slowly leaking
(22:29):
and you fill it out.
You say it's 4,000 gallons,right, and you know with great
certainty because that's whatthe tabletop exercise holds you.
But in a real spill no one'sgoing to tell you how much it is
.
You got to go figure it out onyour own.
So all of that to say you don'twant to delay the reporting
Remember we talked aboutdelaying too long can result in
(22:51):
a fine and you do need to notifystate and local agencies and
federal agencies so that theycan bring resources to bear to
help or to limit the destructionor the impacts of this spill.
And so if you don't have allthe information, you definitely
shouldn't wait.
You should definitely give themwhat you got and it's okay to
say I don't know for some ofthose things and fill in those
(23:11):
blanks later, when you've gottime to go track them down or do
the gauging or do the measuringyou've got time to go track
them down or do the gauging ordo the measuring.
What advice do you have forsomeone responsible for
performing spill notifications?
First, practice, train anddevelop your team ahead of time
(23:34):
and make sure you have a backupperson for each position.
I would say if you and a backupperson are training twice a
year on spill notifications, youwill probably be prepared to do
it correctly when you have anactual spill or an unannounced
drill.
And that backup person isreally important because
vacations, right Like people goon vacations, they have medical
procedures they need to be outfor, and so if only one person
(23:55):
has that knowledge, there'sgoing to be times where you have
gaps in coverage.
I also would like to make a.
I would like to make a case forincreasing your incident
command system knowledge.
FEMA and wildland firefightingboth use the ICS system, which
is incident command system, andthere are ICS 100 and 200 level
(24:18):
courses that are free from FEMAand what they really do is they
get you used to the incidentcommand system format and
terminology.
And my pro tip to everybodylistening is if you do not know
what a 201 form is and how tofill it out, that is where you
need to focus on, because mostof the communication during
small and medium-sized spillsand even into larger spills
(24:41):
occurs on that 201 form, and so,once you get over the initial
reaction steps, you're going tobe feeding information not into
a notification form but intothis 201 form and it's
documenting the progress of thespill and the spill response.
One form and it's documentingthe progress of the spill and
the spill response.
So, practice, have a backup,make sure you have knowledge
(25:03):
about the ICS system.
There's free courses from FEMA.
And then my last little bit ofadvice is to make sure you
understand the division of laborat your company.
We always recommend having avery candid conversation at all
levels of your company about whocontacts stakeholders.
A lot of our clients have asplit where the terminal manager
(25:23):
is responsible for notifyinglocal stakeholders because they
live and work in that community,and then they also send
information to their supervisoror an environmental manager at
their company, and in thisscenario, someone at the
environmental manager level orhigher is going to be the one
reporting to the state andfederal groups.
Remember what I said aboutbackups at the beginning.
You need to have a backup heretoo.
(25:44):
We had a client where thatsystem was in place.
The terminal manager made localnotifications and then they
were supposed to report to apresident for the state and
federal notifications.
But at the time of the spillthe old president had retired,
they had not hired a newpresident and there was no
interim and they ended updelaying notification by almost
(26:06):
three hours trying to figure outwho was going to make the
notifications for the company,and that ended up in a fine for
that company.
So backups at every level.
If you have somebody who'sresponsible for doing those
spill notifications, they needto have somebody as an alternate
in place and that needs to becommunicated to everybody when
(26:26):
things change.
Amanda (26:28):
All right, it sounds like we have a lot of little
nuggets of resources scatteredthroughout this podcast episode.
Would you mind reviewing someof those resources that you've
recommended?
Shannon (26:38):
Yeah.
Yeah, that's the nice thingabout spill notifications is
there are a lot of resources outthere, but I do think this
curated list will help somebodyreally focus on.
You know, if they want toimprove their spill notification
training, uh, this will be verybeneficial.
So we have the EPA's NRCwebsite.
It talks a lot about the NRC.
(26:59):
It has a guideline you candownload.
There's also the state ofAlaska Department of
Environmental Conservation has aspill notification website.
Same thing lots of exampleforms.
They have what to do if youneed to report a spill.
It's written in plain English.
It's very interactive andhelpful.
And then some of the forms thatI mentioned is the ADEC
(27:24):
reporting placard Remember thatone that I said had to be dated
October of 2022 or newer.
And then there's the State ofAlaska monthly spill log and the
spill reporting form.
And then, lastly, we'll includea link to FEMA's ICS training
website where you can sign upfor and take those ICS 100 and
200 classes for free if youwould like.
Amanda (27:47):
Wonderful.
Well, I'm really excited todive deeper into spill drills in
this upcoming series, and I'mglad that we started with
reporting.
I think it's something that weget a lot of questions about.
Shannon (28:00):
Yeah, not a problem.
This is so critical.
I hope it helps people to bemore prepared for spill
notifications in the future,because this is the kind of
thing where, if you do itcorrectly, you can really reduce
the amount of damage a spillcan uh inflict.
So I felt it was an importanttopic to think of and discuss
more about on this podcast.
So I appreciate the time.
Amanda (28:21):
Thanks, Amanda, thank you.
See you next time.
Bye-bye.
Good morning Shannon.
What are you wanting to talkabout today?
Shannon (00:03):
Good morning Amanda.
Well, it's a really nice springday here in Anchorage, and
spring is when a lot ofcompanies we work with begin
preparing for summer fueldeliveries, and so I was
thinking we could talk aboutspill notifications today,
because spill notifications arepart of drill exercises that our
clients perform for manydifferent regulatory agencies,
(00:27):
and it's something, honestly,that a lot of people struggle
with, and so what do you thinkabout talking about that?
Amanda (00:33):
What makes spill notifications so complicated?
Shannon (00:37):
Well, there's three main reasons.
The first is that actual spillnotifications like when you're
really calling one in, they'realways done under stress, so
they're very stressful.
The second is that spillnotifications can feel a little
complicated because all thesedifferent regulatory agencies
and parent companies, they allhave different reporting
(00:58):
triggers.
And then lastly, if you'redoing it right, you don't have
spills regularly enough to sortof make reporting routine.
So all three of those feed intospill notifications being
difficult for many people.
Amanda (01:13):
It sounds pretty complex .
Where do spill notificationsfit into the bigger spill
response timeline?
Shannon (01:20):
That's a really good question because a lot of people
, amanda, think it has to happenfirst, like oh, there's a spill
, I have to call it in.
But I do want to point out thatnotifications are actually
after a few critical initialresponse steps.
Do you want me to go over those?
Oh, that would be great.
So there's six of them, so letme go through.
I've got them written downbecause I'm good, but I'm not
(01:42):
that good.
Number one determine what hasspilled and if the scene is safe
for you to enter.
What has spilled really impactshow you respond to it, for
example, the difference betweena response to a diesel spill,
which is a combustible material,and gasoline, which is
(02:04):
flammable and has a high vaporcontent.
Those two are going to be verydifferent spill response steps,
and so you need to know whatyou're working with there.
The second is to make sure thateverybody involved in this
spill has the right PPE personalprotective equipment on, and if
they don't go, get it on.
Three, shut off any ignitionsources pumps, machinery,
(02:28):
electrical.
Almost every spill has vapor ofsome kind as the spill
progresses, and so shutting offthose ignition sources will help
keep everyone safe and preventbigger problems from occurring.
Related to that.
Number four is to stop thesource of the spill.
If you can, shut off the valve,stop the pump, close the drain.
That step number four hasprevented major spills so many
(02:49):
times in my career.
Somebody was real quick,realized what was happening and
ran over and turned the valveoff at the secondary containment
.
Somebody realized what washappening and radioed the barge
and had the pump immediatelyshut down.
All of these stopping thesource of the spills can really
shrink the impact of the spillif they're performed right away
and not delayed.
(03:09):
And then the last two isolatethe area, and this is to
restrict access to other peopleso that you don't have a
spreading of the spill by peoplethat are not knowledgeable
about it.
So, for example, if you spillfuel across a roadway, you don't
want cars driving through itand dragging the fuel with them
on their tires.
Same thing in a small boatharbor.
(03:30):
If you've got fuel in the smallboat harbor, you don't want the
vessels going through that fueland taking it out of the boat
harbor.
Right.
And so it becomes reallyimportant to get that area
isolated and make sure peoplearen't traipsing through it.
Important to get that areaisolated and make sure people
aren't traipsing through it.
And then lastly and this isspecifically for someone who's
(03:52):
in charge of doing spillnotifications they need to
direct others to begin controland cleanup tactics, like, hey,
you guys go get the boat andsome boom and start circling the
dock so that they can work onthat while you're doing the
notifications.
Start circling the dock so thatthey can work on that while
you're doing the notifications.
Once you get those six initialresponse action steps done, now
(04:12):
it's time to make notifications.
There's three levels local,state and federal and we can go
into the details of what toreport later.
But I do get a lot of questionsabout how long to wait, like
how long can I take before Ineed to call the state if it's
not immediate?
And our firm generallyrecommends no more than half an
hour.
The reasons for that is, mostof these initial steps can be
(04:34):
accomplished within 30 minutes.
And then, if this is asignificant spill, like if
you've let thousands of gallonsof fuel enter a water body, some
of the bigger agencies, likethe US Coast Guard, have
resources that can be brought tobear to minimize the effects
sooner.
So you don't want to wait toolong because you may be cutting
(04:57):
off some of these agencies'abilities to help or to bring
resources that you don't have.
So no more than half an houryou can have other staff members
working on initial responseactions and containment and
control while you do thenotification.
And it's okay to not have allthe information when you call
and we'll go through that later.
Amanda (05:16):
You had mentioned earlier that agencies have
reporting triggers.
Would you share some of thosewith us?
Shannon (05:23):
Yeah, let's talk about what a trigger is, because that
is some of what makes spillreporting so challenging for
people.
So spills vary in size,material type, location, and
some spill situations are lesscritical than others.
I mean, imagine you're changingthe oil on your car and you
(05:46):
spill a gallon of oil to theconcrete floor of your garage.
That's going to be differentthan if you spill a gallon of
oil from your vessel's bilgepump right at the small boat
harbor.
It's going to be pumping out agallon of oil into places where
everybody's going to be trackingit and it's directly to water,
right, maybe more critical.
(06:07):
So the state of Alaska and theEPA and the Coast Guard all have
different levels of spillreporting that trigger certain
notification requirements.
So before you can do spillreporting, you sort of need to
understand what needs to bereported within what timeframe,
and those two pieces together iswhat the trigger is.
Some of them are prettystraightforward and some are
(06:28):
more nuanced, which increasescomplexity for people who don't
report very frequently.
What do you want me to startwith?
Federal or state?
Amanda (06:36):
Start from maybe federal notifications.
Shannon (06:39):
Oh good, I'm glad you chose that one.
It's the easiest one For bothEPA and the Coast Guard.
You'll be making a report tosomething called the National
Response Center, and that phonenumber is 1-800-424-8802.
It's a one-stop shop forfederal agencies.
However, their one and onlytrigger is and I also have this
(07:02):
written down because I did nothave it memorized as soon as
knowledgeable of an oil spillfrom a vessel or facility in or
along US navigable waters commaon the outer continental shelf,
in a deep water port or from avessel transporting oil from the
outer continental shelf, andthe very plain English version
of that is any spill of anyamount to surface waters.
(07:23):
These apply to all fuelproducts ultra low sulfur diesel
gasoline, regular and lead andpremium AvGas 100 low lead Jet A
heating oil number one andnumber two kerosene any of these
fractions of refined product.
That's what we're talking abouttoday.
(07:44):
So these notifications arespecific to fuel products.
So I just want to make surethat's clear for anybody taking
notes, so that they don't thinkthese apply to other products,
because the state has some verynuanced reporting triggers.
Amanda (07:59):
So what are the specific triggers for Alaska?
Shannon (08:02):
Yes, the State of Alaska spill reporting is a
little more nuanced than thefederal reporting.
There are different time framesfor reporting, based on the
location of the fuel spilled andthe quantity of the fuel
spilled.
Fortunately, the state has madea handy dandy placard that's
available on their website andwe will definitely include in
the show notes, and that placardhas really critical information
(08:26):
for spill reporting, so I'mgoing to cover it here.
One is the phone number to call.
There are two (08:32):
one is a toll-free number and one is the
international number.
The toll-free number is1-800-478-9300.
And then there's aninternational number and this is
important especially forvessels that are entering
Alaskan waters.
They may not necessarily beland-based and that
international number is1-907-269-0667.
(08:57):
And then this is a little bitnewer within the last two or
three years, but they have anonline reporting system as well
now, and that'sreportspillsalaska.
gov, and again, we'll includeall the links to this.
But you can go ahead and goonline and report spills.
I do want to remind people thatthe reporting of spills for the
(09:18):
state of Alaska is required bothby statute and regulation, and
the posting of this placard isalso required in areas that
transfer fuel.
In addition to the phonenumbers, the oil spill reporting
placard also has a breakdown ofwhen to call the state and some
(09:40):
of those volume and locationtriggers.
So, first, any spill to waterneeds to be reported immediately
and that is in alignment withthe federal requirements.
So any spill of fuel product tothe water, you need to call it
in as soon as you can withinthat one-half hour window If the
amount of fuel spilled is over10 gallons but under 55 gallons
(10:04):
and this is to land, because ifit was to water it would be
immediate but if you spill 10 to55 gallons on land, you'd need
to report it within 48 hours.
If you have a spill occur toland that's between 1 and 10
gallons, you need to report iton a monthly spill log, which we
will also post on this episode,and note that this is to land,
(10:27):
not to secondary containment.
We'll get to secondarycontainment in a minute.
And then, lastly, the statesays if it's under one gallon to
land, reporting is not required.
But we are going to ask you tobe a decent human being, keep
Alaska great and clean it upanyways.
Many companies choose to reportall amounts, but the regulation
(10:48):
does say specifically thatspills under a gallon to land
are not required to be reported.
Amanda (10:53):
What about spills that occur into a secondary
containment area?
Shannon (10:58):
Well, the state has another regulation criteria for
reporting to containment, andthat is if the spill to
secondary containment exceeds 55gallons, you need to report
that within 48 hours.
And this one's a little harderfor people to wrap their heads
around because you're notactually spilling to land or to
(11:18):
water.
You're spilling it to animpermeable area.
So why would you need to reportit?
And the regulation does not saywhy, but in my experience doing
this for 20 years, I believethe reason that that regulation
was included was because ifsomething releases that amount
of fuel to the secondarycontainment area, there's
(11:39):
probably something in thefacility that is malfunctioning,
and that's a good way for thestate to determine if there's
something they need to look atat that tank farm, if
maintenance is required, andthey're not doing it and they're
having all these spills tosecondary containment.
That's my best guess.
I am not currently a regulator,nor did I write these
regulations.
(12:01):
The takeaway is that if you dohave a secondary containment
area spill that's bigger than 55gallons, you've got two days to
notify the state.
And then one more note on thisspill placard is that they do
require you to post theseanywhere you transfer fuel.
This includes fuel deliverytrucks at marinas.
It includes at bulk fuelstorage offices, and this is a
(12:24):
requirement of 18 AAC 75 325.
So it applies to all fuelstorage facilities, not just the
larger 10,000 barrel or 420,000gallon facilities.
If you do have a spill placardin your office or place of work,
I'd like you to look at itright now, and at the bottom
there's a revision date.
(12:45):
If that revision date is notOctober of 2022, which is the
most current version at the timewe're recording this podcast,
you need to update that spellplacard to be compliant with
that regulation.
Amanda (12:57):
And how do we know which agency to call first.
Shannon (13:01):
You know I do get asked that question a whole lot,
Amanda, I think it probablydoesn't matter, as long as you
call both right away, like oneright after the other.
However, I generally say, ifyou've got a spill to open water
, specifically like the ocean orthe shoreline, I generally
(13:22):
encourage people to call NRCfirst, because then you've got
the US Coast Guard aware of thefacility or, sorry, aware of the
situation and they can activateresources if needed.
If it's to land, then generallywe call the state first,
especially if it's to land andit's not to water.
Yet you may not need toactually notify NRC (National
(13:44):
Response Center) until you getto water.
Although in the spills we'veparticipated in the past, if the
spill is larger than a fewgallons, I generally call NRC
just to let them know that it'sthere and the volume or that it
has not made it to water yet.
And the reason for that isbecause people, when they know a
spill is going on in acommunity, often call the Coast
(14:06):
Guard to find out what they'redoing about it.
And so if they haven't heardabout it and don't know about it
, they're going to call you tofind out more anyways.
So it makes sense to just sortof notify everybody, even if it
doesn't necessarily meet thenotification requirements.
They're still going to becurious about it and probably
hear about it from a communitymember.
One of the other things that Iwant to make sure to really
focus on for this because thisgets missed on spill
(14:28):
notification training all thetime is that you have to call
both.
If it's to water, so you've gotto call the state, you've got
to call the NRC.
The NRC will report to both theEPA and the Coast Guard, and
even some other federal agencieswill maybe be made aware of it,
like marine mammal groups andstuff like that.
But you can't just call onelike the NRC.
(14:50):
They won't notify the state,and if you call the state, they
won't necessarily notify theCoast Guard and the EPA.
So you have to call both andthat will cover your bases.
So, again, this is why peoplestruggle with this, because
there's all these small piecesthat you have to keep in mind.
Amanda (15:10):
Is there a guideline for information of what needs to be
reported?
Shannon (15:17):
So the way the regulations are written.
The regulations require thesetwo agencies to be notified if
there's a spill to water.
But if you have a spill planthat was written to meet other
regulations like 40 CFR, 112 and18 AAC 75, also known as SPCCs
or an OD PCP, you will also havenotifications to make to local
(15:42):
stakeholders and potentiallyother stakeholders, depending on
the spill.
Often the harborbormaster orthe fire department and the
public safety department arenotified because they'll need to
help with response or trafficmanagement.
If the spill is in a criticalhabitat area or a historic
preservation area, then certainfederal or state agencies must
(16:03):
be notified to assist withendangered species.
Marine mammals, culturalresources are all good examples.
And then another common one wesee all the time is that if the
spill happens near a seafoodprocessor, that processor needs
to be made aware of the spill sothey can shut down the
saltwater intake so they're notsucking up fuel into their food
(16:25):
processing facility.
Amanda (16:28):
So what information are we needing to report?
Yeah, that's.
Shannon (16:35):
That's the kicker question.
So there's a lot of informationthat's needed when there's a
spill and when we drill this.
It's very easy to have all ofthe information available from
the spill plan.
You can like read ahead and youknow all the things right, and
so it's very easy to fill it outand be like oh yes, these are
all the things, and I can fillthis whole form out and call the
(16:58):
state and EPA within 30 minutes.
However, in a real spill,that's never what happens and
you only have part of theinformation and maybe not all of
the information you really need.
So what we typically recommenddoing is the state of Alaska has
a reporting form available forfree on their website that we
will include in the show notes,and that reporting form has a
(17:20):
little space for pretty muchevery single piece of
information that the state wouldwant to have in the event of a
spill, and it's a really goodtraining aid.
So if you're going to do spilldrill trainings, start with this
sheet and what the state andthe NRC are both looking for.
You know, essentially it's likea 911 dispatch.
They have a series of questionsthey're going to ask you when
(17:42):
you call and they're trying tounderstand how big the spill,
what the potential impacts are.
If there's any public safetyissues, you know they're,
they're looking at it from thestate and federal level, and so
there's there's this checklistof information that they're
going to want to have.
Amanda (17:59):
So we get that form completed, we write everything
down and then we call it in Wellyes and no.
Shannon (18:07):
So, uh, you are going to want to use that form to
collect the data that you can.
Uh, but most of the times whenyou have a spill in real life
you do not have all of theinformation.
So you'll have some of it, butyou should not delay reporting
to collect more information, andI think it actually says it
right on that form.
So some of the criticalinformation you should have when
(18:30):
you make that first call is thespill location and its
potential to travel.
So this includes location whereyou think, like where it is
right now and where you thinkit'll end up in the near future,
like in the next two to fourhours, based on tide, wind and
weather.
It's important to report theactual location of the spill,
which may be different from thefacility location.
(18:50):
We were involved in a spillonce, Amanda, where the general
manager reported the facilityGPS coordinates, because that's
what was written on the cover ofthe plan, but the facility
itself was a mile inland fromwhere the spill occurred, at the
marine header, and that causeda lot of confusion for the Coast
Guard because it was reportedto them as a spill to water, but
the GPS coordinates were a mileinland.
(19:12):
So make sure that if it's notat your facility to get updated
or correct GPS information forthe actual spill location, I
wanted to talk about informationthat you don't know.
We have a lot of terminalmanagers and operators that,
because of the stress you knowthey're having this big spill,
(19:33):
they feel very responsiblebecause every terminal manager I
have ever met takes fullresponsibility for their
terminal Right, and so they're.
They're feeling a lot ofpressure, they're really upset
because something bad happenedand they're feeling super
responsible.
And so there's this like urgeto kind of fill in the blanks,
because there's a lot ofpressure from the state agency
and federal agencies Like howmuch did you spill?
(19:54):
What's this?
How is it going?
What was the root cause?
Because they do need thatinformation.
But I want to reassure anyonelistening to this that you don't
.
It's okay to say I don't knowyet or I don't have good
information to give you for that.
And when you start a spillreporting process, there's going
to be lots of follow-up phonecalls as they develop an
(20:15):
incident command system and amanagement team.
There's all these things thatfollow after.
That will give you a chance togive that information when you
have a better idea of what it isand where this really sticks
for most people is the volume ofthe spill.
And I'll just say this bluntlyDetermining the volume of a
(20:36):
spill by eyeballing it is verydifficult, especially if you
don't respond to spills on adaily basis.
Once it hits water, it spreadsout really thin, Amanda, and it
can look like a lot of fuel, butit can actually be a very small
amount.
It's just widely spread out onvery calm water, on very calm
(20:58):
water.
It also can look much smallerthan it is if it's in choppy
water and the water surface isdisrupted and it just doesn't
look like it's sheening, butthere's more fuel than you think
on the water.
And so what we recommend formost people that are going to be
responding initially to thespill, which FEMA and wildland
firefighting calls the on-scenecoordinator for most on-scene
coordinators, it's going to bebetter to get your volume number
(21:19):
from looking at inventorynumbers or backwards engineering
what's missing.
So if you have a spill from atank and you know that yesterday
it had 100,000 gallons, there'sa spill that happened, and you
go and you dip the tank and it'sat 93,400 or something you know
, that estimate is better thantrying to look at your secondary
containment or look at thegravel pad that it spilled to
(21:45):
and trying to determine how muchfuel is there.
Determining fuel to soil is alsovery difficult because it can
soak into the soil and just gostraight down, and so you can
actually have a very smallsquare footage at the surface,
but it goes straight down for 28feet, you know.
So those are.
Those are some things that makeit difficult.
So we tell most people, ifyou're going to do a volume of a
(22:07):
spill at in real life, um, doit from inventory backwards,
engineer it.
And this is something that'sdifficult when you practice
spill drill notifications,because typically the spill
drill tells you you have spilled4,000 gallons of fuel to the
secondary containment.
The secondary containment has acrack and it's slowly leaking
(22:29):
and you fill it out.
You say it's 4,000 gallons,right, and you know with great
certainty because that's whatthe tabletop exercise holds you.
But in a real spill no one'sgoing to tell you how much it is
.
You got to go figure it out onyour own.
So all of that to say you don'twant to delay the reporting
Remember we talked aboutdelaying too long can result in
(22:51):
a fine and you do need to notifystate and local agencies and
federal agencies so that theycan bring resources to bear to
help or to limit the destructionor the impacts of this spill.
And so if you don't have allthe information, you definitely
shouldn't wait.
You should definitely give themwhat you got and it's okay to
say I don't know for some ofthose things and fill in those
(23:11):
blanks later, when you've gottime to go track them down or do
the gauging or do the measuringyou've got time to go track
them down or do the gauging ordo the measuring.
What advice do you have forsomeone responsible for
performing spill notifications?
First, practice, train anddevelop your team ahead of time
(23:34):
and make sure you have a backupperson for each position.
I would say if you and a backupperson are training twice a
year on spill notifications, youwill probably be prepared to do
it correctly when you have anactual spill or an unannounced
drill.
And that backup person isreally important because
vacations, right Like people goon vacations, they have medical
procedures they need to be outfor, and so if only one person
(23:55):
has that knowledge, there'sgoing to be times where you have
gaps in coverage.
I also would like to make a.
I would like to make a case forincreasing your incident
command system knowledge.
FEMA and wildland firefightingboth use the ICS system, which
is incident command system, andthere are ICS 100 and 200 level
(24:18):
courses that are free from FEMAand what they really do is they
get you used to the incidentcommand system format and
terminology.
And my pro tip to everybodylistening is if you do not know
what a 201 form is and how tofill it out, that is where you
need to focus on, because mostof the communication during
small and medium-sized spillsand even into larger spills
(24:41):
occurs on that 201 form, and so,once you get over the initial
reaction steps, you're going tobe feeding information not into
a notification form but intothis 201 form and it's
documenting the progress of thespill and the spill response.
One form and it's documentingthe progress of the spill and
the spill response.
So, practice, have a backup,make sure you have knowledge
(25:03):
about the ICS system.
There's free courses from FEMA.
And then my last little bit ofadvice is to make sure you
understand the division of laborat your company.
We always recommend having avery candid conversation at all
levels of your company about whocontacts stakeholders.
A lot of our clients have asplit where the terminal manager
(25:23):
is responsible for notifyinglocal stakeholders because they
live and work in that community,and then they also send
information to their supervisoror an environmental manager at
their company, and in thisscenario, someone at the
environmental manager level orhigher is going to be the one
reporting to the state andfederal groups.
Remember what I said aboutbackups at the beginning.
You need to have a backup heretoo.
(25:44):
We had a client where thatsystem was in place.
The terminal manager made localnotifications and then they
were supposed to report to apresident for the state and
federal notifications.
But at the time of the spillthe old president had retired,
they had not hired a newpresident and there was no
interim and they ended updelaying notification by almost
(26:06):
three hours trying to figure outwho was going to make the
notifications for the company,and that ended up in a fine for
that company.
So backups at every level.
If you have somebody who'sresponsible for doing those
spill notifications, they needto have somebody as an alternate
in place and that needs to becommunicated to everybody when
(26:26):
things change.
Amanda (26:28):
All right, it sounds like we have a lot of little
nuggets of resources scatteredthroughout this podcast episode.
Would you mind reviewing someof those resources that you've
recommended?
Shannon (26:38):
Yeah.
Yeah, that's the nice thingabout spill notifications is
there are a lot of resources outthere, but I do think this
curated list will help somebodyreally focus on.
You know, if they want toimprove their spill notification
training, uh, this will be verybeneficial.
So we have the EPA's NRCwebsite.
It talks a lot about the NRC.
(26:59):
It has a guideline you candownload.
There's also the state ofAlaska Department of
Environmental Conservation has aspill notification website.
Same thing lots of exampleforms.
They have what to do if youneed to report a spill.
It's written in plain English.
It's very interactive andhelpful.
And then some of the forms thatI mentioned is the ADEC
(27:24):
reporting placard Remember thatone that I said had to be dated
October of 2022 or newer.
And then there's the State ofAlaska monthly spill log and the
spill reporting form.
And then, lastly, we'll includea link to FEMA's ICS training
website where you can sign upfor and take those ICS 100 and
200 classes for free if youwould like.
Amanda (27:47):
Wonderful.
Well, I'm really excited todive deeper into spill drills in
this upcoming series, and I'mglad that we started with
reporting.
I think it's something that weget a lot of questions about.
Shannon (28:00):
Yeah, not a problem.
This is so critical.
I hope it helps people to bemore prepared for spill
notifications in the future,because this is the kind of
thing where, if you do itcorrectly, you can really reduce
the amount of damage a spillcan uh inflict.
So I felt it was an importanttopic to think of and discuss
more about on this podcast.
So I appreciate the time.
Amanda (28:21):
Thanks, Amanda, thank you.
See you next time.
Bye-bye.
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