Tank Talk - Alaska's Bulk Fuel Podcast
Tank Talk - Alaska's Bulk Fuel Podcast
Reporting an Oil Spill
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
intro/outro created with GarageBand
Good morning Shannon. What are you wanting to talk about today?
Shannon:Good morning Amanda. Well, it's a really nice spring day here in Anchorage, and spring is when a lot of companies we work with begin preparing for summer fuel deliveries, and so I was thinking we could talk about spill notifications today, because spill notifications are part of drill exercises that our clients perform for many different regulatory agencies, and it's something, honestly, that a lot of people struggle with, and so what do you think about talking about that?
Amanda:What makes spill notifications so complicated?
Shannon:Well, there's three main reasons. The first is that actual spill notifications like when you're really calling one in, they're always done under stress, so they're very stressful. The second is that spill notifications can feel a little complicated because all these different regulatory agencies and parent companies, they all have different reporting triggers. And then lastly, if you're doing it right, you don't have spills regularly enough to sort of make reporting routine. So all three of those feed into spill notifications being difficult for many people.
Amanda:It sounds pretty complex. Where do spill notifications fit into the bigger spill response timeline?
Shannon:That's a really good question because a lot of people, amanda, think it has to happen first, like oh, there's a spill, I have to call it in. But I do want to point out that notifications are actually after a few critical initial response steps. Do you want me to go over those? Oh, that would be great. So there's six of them, so let me go through. I've got them written down because I'm good, but I'm not that good.
Shannon:Number one determine what has spilled and if the scene is safe for you to enter. What has spilled really impacts how you respond to it, for example, the difference between a response to a diesel spill, which is a combustible material, and gasoline, which is flammable and has a high vapor content. Those two are going to be very different spill response steps, and so you need to know what you're working with there. The second is to make sure that everybody involved in this spill has the right PPE personal protective equipment on, and if they don't go, get it on. Three, shut off any ignition sources pumps, machinery, electrical. Almost every spill has vapor of some kind as the spill progresses, and so shutting off those ignition sources will help keep everyone safe and prevent bigger problems from occurring. Related to that. Number four is to stop the source of the spill. If you can, shut off the valve, stop the pump, close the drain. That step number four has prevented major spills so many times in my career. Somebody was real quick, realized what was happening and ran over and turned the valve off at the secondary containment. Somebody realized what was happening and radioed the barge and had the pump immediately shut down. All of these stopping the source of the spills can really shrink the impact of the spill if they're performed right away and not delayed.
Shannon:And then the last two isolate the area, and this is to restrict access to other people so that you don't have a spreading of the spill by people that are not knowledgeable about it. So, for example, if you spill fuel across a roadway, you don't want cars driving through it and dragging the fuel with them on their tires. Same thing in a small boat harbor. If you've got fuel in the small boat harbor, you don't want the vessels going through that fuel and taking it out of the boat harbor. Right. And so it becomes really important to get that area isolated and make sure people aren't traipsing through it. Important to get that area isolated and make sure people aren't traipsing through it. And then lastly and this is specifically for someone who's in charge of doing spill notifications they need to direct others to begin control and cleanup tactics, like, hey, you guys go get the boat and some boom and start circling the dock so that they can work on that while you're doing the notifications. Start circling the dock so that they can work on that while you're doing the notifications.
Shannon:Once you get those six initial response action steps done, now it's time to make notifications. There's three levels local, state and federal and we can go into the details of what to report later. But I do get a lot of questions about how long to wait, like how long can I take before I need to call the state if it's not immediate? And our firm generally recommends no more than half an hour. The reasons for that is, most of these initial steps can be accomplished within 30 minutes.
Shannon:And then, if this is a significant spill, like if you've let thousands of gallons of fuel enter a water body, some of the bigger agencies, like the US Coast Guard, have resources that can be brought to bear to minimize the effects sooner. So you don't want to wait too long because you may be cutting off some of these agencies' abilities to help or to bring resources that you don't have. So no more than half an hour you can have other staff members working on initial response actions and containment and control while you do the notification. And it's okay to not have all the information when you call and we'll go through that later.
Amanda:You had mentioned earlier that agencies have reporting triggers. Would you share some of those with us?
Shannon:Yeah, let's talk about what a trigger is, because that is some of what makes spill reporting so challenging for people. So spills vary in size, material type, location, and some spill situations are less critical than others. I mean, imagine you're changing the oil on your car and you spill a gallon of oil to the concrete floor of your garage. That's going to be different than if you spill a gallon of oil from your vessel's bilge pump right at the small boat harbor. It's going to be pumping out a gallon of oil into places where everybody's going to be tracking it and it's directly to water, right, maybe more critical.
Shannon:So the state of Alaska and the EPA and the Coast Guard all have different levels of spill reporting that trigger certain notification requirements. So before you can do spill reporting, you sort of need to understand what needs to be reported within what timeframe, and those two pieces together is what the trigger is. Some of them are pretty straightforward and some are more nuanced, which increases complexity for people who don't report very frequently. What do you want me to start with? Federal or state?
Amanda:Start from maybe federal notifications.
Shannon:Oh good, I'm glad you chose that one.
Shannon:It's the easiest one For both EPA and the Coast Guard. You'll be making a report to something called the National Response Center, and that phone number is 1-800-424-8802. It's a one-stop shop for federal agencies. However, their one and only trigger is and I also have this written down because I did not have it memorized as soon as knowledgeable of an oil spill from a vessel or facility in or along US navigable waters comma on the outer continental shelf, in a deep water port or from a vessel transporting oil from the outer continental shelf, and the very plain English version of that is any spill of any amount to surface waters. These apply to all fuel products ultra low sulfur diesel gasoline, regular and lead and premium AvGas 100 low lead Jet A heating oil number one and number two kerosene any of these fractions of refined product. That's what we're talking about today. So these notifications are specific to fuel products. So I just want to make sure that's clear for anybody taking notes, so that they don't think these apply to other products, because the state has some very nuanced reporting triggers.
Amanda:So what are the specific triggers for Alaska?
Shannon:Yes, the State of Alaska spill reporting is a little more nuanced than the federal reporting. There are different time frames for reporting, based on the location of the fuel spilled and the quantity of the fuel spilled. Fortunately, the state has made a handy dandy placard that's available on their website and we will definitely include in the show notes, and that placard has really critical information for spill reporting, so I'm going to cover it here. One is the phone number to call. There are two: one is a toll-free number and one is the international number. The toll-free number is 1-800-478-9300. And then there's an international number and this is important especially for vessels that are entering Alaskan waters. They may not necessarily be land-based and that international number is 1-907-269-0667. And then this is a little bit newer within the last two or three years, but they have an online reporting system as well now, and that's reportspillsalaska. gov, and again, we'll include all the links to this. But you can go ahead and go online and report spills.
Shannon:I do want to remind people that the reporting of spills for the state of Alaska is required both by statute and regulation, and the posting of this placard is also required in areas that transfer fuel. In addition to the phone numbers, the oil spill reporting placard also has a breakdown of when to call the state and some of those volume and location triggers. So, first, any spill to water needs to be reported immediately and that is in alignment with the federal requirements. So any spill of fuel product to the water, you need to call it in as soon as you can within that one-half hour window If the amount of fuel spilled is over 10 gallons but under 55 gallons and this is to land, because if it was to water it would be immediate but if you spill 10 to 55 gallons on land, you'd need to report it within 48 hours.
Shannon:If you have a spill occur to land that's between 1 and 10 gallons, you need to report it on a monthly spill log, which we will also post on this episode, and note that this is to land, not to secondary containment. We'll get to secondary containment in a minute. And then, lastly, the state says if it's under one gallon to land, reporting is not required. But we are going to ask you to be a decent human being, keep Alaska great and clean it up anyways. Many companies choose to report all amounts, but the regulation does say specifically that spills under a gallon to land are not required to be reported.
Amanda:What about spills that occur into a secondary containment area?
Shannon:Well, the state has another regulation criteria for reporting to containment, and that is if the spill to secondary containment exceeds 55 gallons, you need to report that within 48 hours. And this one's a little harder for people to wrap their heads around because you're not actually spilling to land or to water. You're spilling it to an impermeable area. So why would you need to report it? And the regulation does not say why, but in my experience doing this for 20 years, I believe the reason that that regulation was included was because if something releases that amount of fuel to the secondary containment area, there's probably something in the facility that is malfunctioning, and that's a good way for the state to determine if there's something they need to look at at that tank farm, if maintenance is required, and they're not doing it and they're having all these spills to secondary containment. That's my best guess. I am not currently a regulator, nor did I write these regulations.
Shannon:The takeaway is that if you do have a secondary containment area spill that's bigger than 55 gallons, you've got two days to notify the state. And then one more note on this spill placard is that they do require you to post these anywhere you transfer fuel. This includes fuel delivery trucks at marinas. It includes at bulk fuel storage offices, and this is a requirement of 18 AAC 75 325. So it applies to all fuel storage facilities, not just the larger 10,000 barrel or 420,000 gallon facilities. If you do have a spill placard in your office or place of work, I'd like you to look at it right now, and at the bottom there's a revision date. If that revision date is not October of 2022, which is the most current version at the time we're recording this podcast, you need to update that spell placard to be compliant with that regulation.
Amanda:And how do we know which agency to call first.
Shannon:You know I do get asked that question a whole lot, Amanda, I think it probably doesn't matter, as long as you call both right away, like one right after the other. However, I generally say, if you've got a spill to open water, specifically like the ocean or the shoreline, I generally encourage people to call NRC first, because then you've got the US Coast Guard aware of the facility or, sorry, aware of the situation and they can activate resources if needed. If it's to land, then generally we call the state first, especially if it's to land and it's not to water. Yet you may not need to actually notify NRC (National Response Center) until you get to water. Although in the spills we've participated in the past, if the spill is larger than a few gallons, I generally call NRC just to let them know that it's there and the volume or that it has not made it to water yet. And the reason for that is because people, when they know a spill is going on in a community, often call the Coast Guard to find out what they're doing about it. And so if they haven't heard about it and don't know about it, they're going to call you to find out more anyways. So it makes sense to just sort of notify everybody, even if it doesn't necessarily meet the notification requirements. They're still going to be curious about it and probably hear about it from a community member.
Shannon:One of the other things that I want to make sure to really focus on for this because this gets missed on spill notification training all the time is that you have to call both. If it's to water, so you've got to call the state, you've got to call the NRC. The NRC will report to both the EPA and the Coast Guard, and even some other federal agencies will maybe be made aware of it, like marine mammal groups and stuff like that. But you can't just call one like the NRC. They won't notify the state, and if you call the state, they won't necessarily notify the Coast Guard and the EPA. So you have to call both and that will cover your bases. So, again, this is why people struggle with this, because there's all these small pieces that you have to keep in mind.
Amanda:Is there a guideline for information of what needs to be reported?
Shannon:So the way the regulations are written. The regulations require these two agencies to be notified if there's a spill to water. But if you have a spill plan that was written to meet other regulations like 40 CFR, 112 and 18 AAC 75, also known as SPCCs or an OD PCP, you will also have notifications to make to local stakeholders and potentially other stakeholders, depending on the spill. Often the harborbormaster or the fire department and the public safety department are notified because they'll need to help with response or traffic management. If the spill is in a critical habitat area or a historic preservation area, then certain federal or state agencies must be notified to assist with endangered species. Marine mammals, cultural resources are all good examples. And then another common one we see all the time is that if the spill happens near a seafood processor, that processor needs to be made aware of the spill so they can shut down the saltwater intake so they're not sucking up fuel into their food processing facility.
Amanda:So what information are we needing to report? Yeah, that's.
Shannon:That's the kicker question. So there's a lot of information that's needed when there's a spill and when we drill this. It's very easy to have all of the information available from the spill plan. You can like read ahead and you know all the things right, and so it's very easy to fill it out and be like oh yes, these are all the things, and I can fill this whole form out and call the state and EPA within 30 minutes. However, in a real spill, that's never what happens and you only have part of the information and maybe not all of the information you really need.
Shannon:So what we typically recommend doing is the state of Alaska has a reporting form available for free on their website that we will include in the show notes, and that reporting form has a little space for pretty much every single piece of information that the state would want to have in the event of a spill, and it's a really good training aid. So if you're going to do spill drill trainings, start with this sheet and what the state and the NRC are both looking for. You know, essentially it's like a 911 dispatch. They have a series of questions they're going to ask you when you call and they're trying to understand how big the spill, what the potential impacts are. If there's any public safety issues, you know they're, they're looking at it from the state and federal level, and so there's there's this checklist of information that they're going to want to have.
Amanda:So we get that form completed, we write everything down and then we call it in Well yes and no.
Shannon:So, uh, you are going to want to use that form to collect the data that you can. Uh, but most of the times when you have a spill in real life you do not have all of the information. So you'll have some of it, but you should not delay reporting to collect more information, and I think it actually says it right on that form. So some of the critical information you should have when you make that first call is the spill location and its potential to travel. So this includes location where you think, like where it is right now and where you think it'll end up in the near future, like in the next two to four hours, based on tide, wind and weather. It's important to report the actual location of the spill, which may be different from the facility location. We were involved in a spill once, Amanda, where the general manager reported the facility GPS coordinates, because that's what was written on the cover of the plan, but the facility itself was a mile inland from where the spill occurred, at the marine header, and that caused a lot of confusion for the Coast Guard because it was reported to them as a spill to water, but the GPS coordinates were a mile inland. So make sure that if it's not at your facility to get updated or correct GPS information for the actual spill location, I wanted to talk about information that you don't know. We have a lot of terminal managers and operators that, because of the stress you know they're having this big spill, they feel very responsible because every terminal manager I have ever met takes full responsibility for their terminal Right, and so they're. They're feeling a lot of pressure, they're really upset because something bad happened and they're feeling super responsible. And so there's this like urge to kind of fill in the blanks, because there's a lot of pressure from the state agency and federal agencies Like how much did you spill? What's this? How is it going? What was the root cause? Because they do need that information. But I want to reassure anyone listening to this that you don't. It's okay to say I don't know yet or I don't have good information to give you for that. And when you start a spill reporting process, there's going to be lots of follow-up phone calls as they develop an incident command system and a management team. There's all these things that follow after. That will give you a chance to give that information when you have a better idea of what it is and where this really sticks for most people is the volume of the spill. And I'll just say this bluntly Determining the volume of a spill by eyeballing it is very difficult, especially if you don't respond to spills on a daily basis.
Shannon:Once it hits water, it spreads out really thin, Amanda, and it can look like a lot of fuel, but it can actually be a very small amount. It's just widely spread out on very calm water, on very calm water. It also can look much smaller than it is if it's in choppy water and the water surface is disrupted and it just doesn't look like it's sheening, but there's more fuel than you think on the water. And so what we recommend for most people that are going to be responding initially to the spill, which FEMA and wildland firefighting calls the on-scene coordinator for most on-scene coordinators, it's going to be better to get your volume number from looking at inventory numbers or backwards engineering what's missing. So if you have a spill from a tank and you know that yesterday it had 100,000 gallons, there's a spill that happened, and you go and you dip the tank and it's at 93,400 or something you know, that estimate is better than trying to look at your secondary containment or look at the gravel pad that it spilled to and trying to determine how much fuel is there.
Shannon:Determining fuel to soil is also very difficult because it can soak into the soil and just go straight down, and so you can actually have a very small square footage at the surface, but it goes straight down for 28 feet, you know. So those are. Those are some things that make it difficult. So we tell most people, if you're going to do a volume of a spill at in real life, um, do it from inventory backwards, engineer it. And this is something that's difficult when you practice spill drill notifications, because typically the spill drill tells you you have spilled 4,000 gallons of fuel to the secondary containment. The secondary containment has a crack and it's slowly leaking and you fill it out.
Shannon:You say it's 4,000 gallons, right, and you know with great certainty because that's what the tabletop exercise holds you. But in a real spill no one's going to tell you how much it is. You got to go figure it out on your own. So all of that to say you don't want to delay the reporting Remember we talked about delaying too long can result in a fine and you do need to notify state and local agencies and federal agencies so that they can bring resources to bear to help or to limit the destruction or the impacts of this spill. And so if you don't have all the information, you definitely shouldn't wait. You should definitely give them what you got and it's okay to say I don't know for some of those things and fill in those blanks later, when you've got time to go track them down or do the gauging or do the measuring you've got time to go track them down or do the gauging or do the measuring.
Shannon:What advice do you have for someone responsible for performing spill notifications? First, practice, train and develop your team ahead of time and make sure you have a backup person for each position. I would say if you and a backup person are training twice a year on spill notifications, you will probably be prepared to do it correctly when you have an actual spill or an unannounced drill. And that backup person is really important because vacations, right Like people go on vacations, they have medical procedures they need to be out for, and so if only one person has that knowledge, there's going to be times where you have gaps in coverage. I also would like to make a. I would like to make a case for increasing your incident command system knowledge. FEMA and wildland firefighting both use the ICS system, which is incident command system, and there are ICS 100 and 200 level courses that are free from FEMA and what they really do is they get you used to the incident command system format and terminology. And my pro tip to everybody listening is if you do not know what a 201 form is and how to fill it out, that is where you need to focus on, because most of the communication during small and medium-sized spills and even into larger spills occurs on that 201 form, and so, once you get over the initial reaction steps, you're going to be feeding information not into a notification form but into this 201 form and it's documenting the progress of the spill and the spill response. One form and it's documenting the progress of the spill and the spill response. So, practice, have a backup, make sure you have knowledge about the ICS system. There's free courses from FEMA. And then my last little bit of advice is to make sure you understand the division of labor at your company.
Shannon:We always recommend having a very candid conversation at all levels of your company about who contacts stakeholders.
Shannon:A lot of our clients have a split where the terminal manager is responsible for notifying local stakeholders because they live and work in that community, and then they also send information to their supervisor or an environmental manager at their company, and in this scenario, someone at the environmental manager level or higher is going to be the one reporting to the state and federal groups.
Shannon:Remember what I said about backups at the beginning. You need to have a backup here too. We had a client where that system was in place. The terminal manager made local notifications and then they were supposed to report to a president for the state and federal notifications. But at the time of the spill the old president had retired, they had not hired a new president and there was no interim and they ended up delaying notification by almost three hours trying to figure out who 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's responsible for doing those spill notifications, they need to have somebody as an alternate in place and that needs to be communicated to everybody when things change.
Amanda:All right, it sounds like we have a lot of little nuggets of resources scattered throughout this podcast episode. Would you mind reviewing some of those resources that you've recommended?
Shannon:Yeah. Yeah, that's the nice thing about spill notifications is there are a lot of resources out there, but I do think this curated list will help somebody really focus on. You know, if they want to improve their spill notification training, uh, this will be very beneficial. So we have the EPA's NRC website. It talks a lot about the NRC. It has a guideline you can download. There's also the state of Alaska Department of Environmental Conservation has a spill notification website. Same thing lots of example forms. They have what to do if you need to report a spill. It's written in plain English. It's very interactive and helpful. And then some of the forms that I mentioned is the ADEC reporting placard Remember that one that I said had to be dated October of 2022 or newer. And then there's the State of Alaska monthly spill log and the spill reporting form. And then, lastly, we'll include a link to FEMA's ICS training website where you can sign up for and take those ICS 100 and 200 classes for free if you would like.
Amanda:Wonderful. Well, I'm really excited to dive deeper into spill drills in this upcoming series, and I'm glad that we started with reporting. I think it's something that we get a lot of questions about.
Shannon:Yeah, not a problem. This is so critical. I hope it helps people to be more prepared for spill notifications in the future, because this is the kind of thing where, if you do it correctly, you can really reduce the amount of damage a spill can uh inflict. So I felt it was an important topic to think of and discuss more about on this podcast. So I appreciate the time.
Amanda:Thanks, Amanda, thank you. See you next time. Bye-bye.
