July 17, 2003
Planning for an environmental emergency
By JOHN HILDENBRAND
Robinson & Noble
While these terms and issues are not new to those who have been involved in emergency response and hazardous materials issues, they are now discussed with an increased sense of urgency.
Businesses, industries and agencies are now saddled with new and renewed responsibilities requiring planning and coordination for the unthinkable. While many of the requirements are not new, the events of Sept. 11 reminded us that plans must be written to be used, not to merely satisfy a regulation.
The current state of the world has expanded emergency response beyond its traditional boundaries of life-safety and property protection to include protection of our environment as well. The possible scale of incidents has changed from square blocks and hundreds or thousands of people to square miles and tens of thousands of people.
Concurrently, a plethora of new services and equipment is now being marketed to nontraditional markets. Everything from gas masks to monitoring equipment is being sold to companies and individuals whose previous experience with such things has been confined to the news and the movies.
Emergency incidents, whether caused by natural events (earthquakes, floods, wind) or by man-made events (industrial accidents, terrorist activities), are handled in pre-emergency, emergency and post-emergency phases.
Acme Inc. is a diversified manufacturer of rocket skates, explosive devices, computer equipment and anvils. The company serves a niche market of animated antagonists, manufacturing products on a special-order basis only. It has a single manufacturing plant located on the banks of the Pure River.
The Pure River is a salmon-bearing stream that also serves as a water source for Roadrunnerville, located 15 miles downstream from Acme.
Acme stores about 3,000 gallons of hazardous liquids at the site and operates its own stormwater/wastewater treatment plant that does not discharge into the river. The Acme plant is only one year old so it conforms to all current regulations for construction and design, including seismic resistance.
When planning for an emergency, Acme needs to consider impacts to its facility, the surrounding area including the river and any potential impacted point downstream. Generally speaking, Acme needs to be concerned about releases to the river (either directly or through soil/groundwater), releases to the air, and releases to the soil/groundwater.
The next step in Acme’s planning is to evaluate how releases can occur. Based on Acme’s “vulnerability assessment,” the company’s leaders have concluded that their greatest risk of environmental impact is via sabotage or a direct, catastrophic event such as an explosion.
The major impacts are determined to be:
These impacts are above and beyond any and all risks to employees present on site.
The next step is to determine what preventative steps, procedures and facility modifications can be implemented to reduce the risks of impact once something occurs.
Acme developed and implemented several items, including an early warning sampling and analysis network in conjunction with Roadrunnerville Water Co., groundwater monitoring systems, a network of air monitoring equipment and alarms, and enhanced security systems such as access control, fencing, video monitoring and employee training.
Acme also established agreements with the local fire department’s hazardous materials team for mutual aid and even donated necessary environmental monitoring equipment. Additionally, Acme tripled the capacity of its wastewater treatment system to allow for the collection of firefighting water in the event of a catastrophic emergency by adding two concrete-lined emergency containment basins.
The planning and preparation paid off when a disgruntled employee drove a car packed with explosives (stolen from the plant) into the facility’s natural gas-fired boiler structure. The resulting explosion and fire destroyed the boiler room, two nearby 1,000-gallon reaction vessels (both in-use) and damaged one flammable-liquids storage building.
Acme immediately called 911, and activated its internal response systems. A recently installed automatic fire suppression system prevented impact to the flammable liquids storage building that was subjected to 800-degree flames. Although the water and suppression foam used in fighting the fire was contaminated with a variety of hazardous substances, it was contained within the concrete-lined emergency containment basins, preventing a release to the soil/groundwater system.
The existing air-monitoring network, as well as random monitoring by Acme and local fire department hazardous materials response personnel, showed that no significant airborne lease of hazardous materials occurred.
Within 15 minutes of the 911 call, a second call was placed to the Roadrunnerville Water Co.’s emergency duty officer to advise it of the situation. Roadrunnerville Water immediately alerted its monitoring personnel and began implementing plans to isolate its reservoirs if needed. Additional notifications were made to Sylvester County emergency management.
Within hours after the incident began, Acme conducted downstream water sampling of the Pure River to verify that contaminants were not released. Within a week of the incident, the company conducted groundwater monitoring of its existing well network to evaluate any potential impact in the event that undetected leaks were present in the emergency containment basins.
Acme also consulted with local health officials to determine any relationships between the incident and numerous emergency room visits by individuals complaining of breathing difficulties on the day of the incident.
The company evaluated the incident and modified its personnel screening policies, material access, and security procedures as a result.
Every plan unique
Admittedly, the above scenario was written to illustrate the benefits of prior planning, hazard mitigation and communication. There are thousands of possible scenarios that could be discussed that would be slightly different for every single facility, agency and company. It is this fact that requires plans to be unique. Canned programs and “cookie cutter” approaches do not work.
Obviously the ability to manage the environmental and public health consequences of major incidents, whether man-made or natural, can vary depending on many factors. Some environmental impacts, such as airborne releases, may be unavoidable, while others such as releases to soil and/or groundwater can be minimized and even prevented by good planning and facility construction.
The scenario presented herein would be much different if water and other materials used in firefighting had been allowed to enter storm drains that directly discharged to the river.
There is always a possibility of something so catastrophic that nothing preventative will work. This worst-case scenario should always be considered during planning since many of the steps that will control and/or prevent damage from lesser incidents will also help control and minimize (to some extent) impacts from the worst-case occurrence.
Communication is the underpinning of the entire process. When planning, those knowledgeable about a facility should be consulted. Engineers, maintenance personnel, managers and other employees familiar with a facility’s operation, design and construction should be involved in assessing risks as well as determining proactive and reactive efforts.
Sometimes this process can be accomplished in-house, while other times it requires the services of outside consultants (environmental experts, structural and mechanical engineers, security, computer).
Local, state and federal agencies should also be consulted. These can include police, fire, emergency management, public works, utilities (especially water and sewer), public health and environmental agencies.
Simply stated, the goal of the planning process is to clearly define what can happen, what is the probability of it happening, where and how could it happen, who or what is affected, how can it be prevented, how can it be controlled or contained, and if damage occurs anyway, how can it be repaired.
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