b. When storing transporting, issuing, or using petroleum products, you should always consider spills.
To minimize the likelihood of spills, be aware of the causes of spills.
(1) Natural (earthquakes, hurricanes, tornadoes, floods) - consider location, special structural devices.
(a) Mechanical (leaking valve, broken pipe, damaged storage tank) - PMCS.
(b) Human error (carelessness, lack of training, mistakes) - props training and updates, SOP.
(c) Trigger event (one of these occurs causing another to take place) - all of the above.
c. The best way to combat a spill is to prevent it!
(1) Identify petroleum storage areas and prioritize those areas based on type of fuel, quantity of fuel,
frequency of transfer, proximity to high impact areas (for example, waterways, human habitation, protected
(2) Establish an effective SOP -- one that is clear and enforced.
(3) Insist on PMCS.
(4) Understand the procedures to follow should a spill occur - Know your spill response plan!
(5) Train employees and continue to update that training.
The following federal laws impact on petroleum and water operations.
a. Clean Water Act.
(1) Requires an NPDES permit for discharge into waters from a point source.
(2) Requires preparation of an NCP, which provides for a response plan to catastrophic spills.
b. OPA of 1990.
(1) "Harmful quantity" considers public health or welfare or the environment of the United States.