'Plans Are Nothing, Planning Is Everything': Being proactive with spill contingency plans.

• Author: Newman, Amy
• Position: ENVIRONMENTAL SPECIAL SECTION/CONTINGENCY PLANS

According to the Environmental Protection Agency (EPA), just one gallon of spilled oil can contaminate more than 1 million gallons of water, so it's critical for companies that deal with these products on a daily basis--whether in their primary trade or secondary to their primary business--to take steps to prevent a spill or discharge and mitigate the damage should one occur.

Enter environmental contingency plans. These documents provide companies with a blueprint that 1) helps implement safety and containment measures to prevent and mitigate the effects of accidental spills and discharges and 2) outlines response and clean-up procedures should catastrophe strike.

Regulated and Unregulated Entities

Environmental contingency plans can be both broadly and narrowly defined. From a regulatory standpoint, they are highly-specific documents required of a narrow set of companies that meet certain federal and state guidelines. In Alaska, that generally means large-scale companies that deal in high-volume oil storage, distribution, and production.

"Most of the time here in Alaska, when somebody says 'contingency plan,' they're generally referring to oil spill/discharge contingency plans by the DEC [Alaska Department of Environmental Conservation]," explains Craig Wilson, principal with Stantec, a multidisciplinary design firm that offers environmental consulting services.

DEC regulations encompass most of Alaska's large oil distribution, production, and storage facilities.

"The big thresholds that stand out to people are tank farms that are either 210,000 gallons of crude or 420,000 gallons of refined product. If you meet that threshold, you have to have a contingency plan," says Graham Wood, program manager of the DEC'S Prevention, Preparedness, and Response Program, which is tasked with preventing and mitigating the effects of an oil spill or discharge and ensuring its cleanup. Oil production and exploration facilities, pipelines, tank vessels, and non-tank vessels are also subject to DEC regulations, he adds.

Facilities that don't meet the DEC threshold likely fall under the EPA's Spill, Prevention, Control, and Countermeasure (SPCC) plans, which Matt Hemry, PE, vice president of environmental consulting firm Shannon & Wilson, calls "a contingency plan lite."

SPCC plans cover non-transportation facilities with either an aggregate above-ground oil storage capacity greater than 1,320 gallons or a completely buried oil storage capacity greater than...