Clean Water of New York, Inc. Oil Spill Contingency, Response and Security Plans
Posted on July 31, 2015
Client: Clean Water of New York, Inc.
Project Type: Oil Spill Contingency, Response and Security Plans
- Integrated Contingency Plan
- Mobile Facility Response Plans/Operations Manuals
- Vessel Response Plan
- Facility Operations Manual
- Facility/Vessel Security Plans
D&B Engineers and Architects, P.C. (D&B) has provided a variety of environmental engineering/technical consulting services for Clean Water of New York (Clean Water) for over 25 years. Clean Water is located on Newark Bay at 3249 Richmond Terrace,Staten Island, New York. The facility conducts barge and petroleum tank cleaning services, recycles oil, processes oily water and provides land transportation and disposal services for waste petroleum and related byproducts. Oily water processing is conducted using equipment installed both on-shore and on the facility’s vessels. The facility operates under a New York State Department of Environmental Conservation (NYSDEC) Part 360 and State Pollutant Discharge Elimination System (SPDES) permits. The facility is also regulated under United States Coast Guard (USCG) requirements for oil handling vessels and facilities. D&B has provided technical support for Clean Water to prepare and update a number of contingency, response and security plans for the facility and the facility’s barges and truck fleet, as described in the sections below.
Integrated Contingency Plan – 40 CFR Part 112, 6 NYCRR Part 360; 33 CFR Parts
154 and 1065
As specified by Parts 360-1.9(h) and 360-14.3(k), a contingency plan is required for owners and operators of facilities which manage used oil. The contingency plan must describe the actions to be followed in the event of an emergency situation. In addition, a Facility Response Plan is required for substantial harm facilities pursuant to United States Environmental Protection Agency (USEPA) regulations (40 CFR 112 Oil Pollution Prevention) and United States Coast Guard (USCG) regulations (33 CFR 154 Subpart F – Response Plans for Oil Facilities). In order to comply with the provisions of these requirements, D&B prepared an Integrated Contingency Plan for the facility which provides one functional emergency response plan that will be utilized to respond to emergency situations at the on-shore facility in a comprehensive and coordinated matter.
Mobile Facility Response Plans and Operations Manuals – 33 CFR Part 154
D&B has prepared Mobile Facility Response Plans and Operations Manuals that describes the oil spill response and operational procedures applicable to mobile facility operations conducted by Clean Water. The mobile facility currently consists of ten tanker trucks used for the receipt and transfer of used oil and waste material. The purpose of the response plan is to ensure that adequate response resources have been designated in the event of an oil spill involving one of the tanker trucks when operating outside of the facility. The operations manual provides comprehensive procedural guidelines detailing the duties and responsibilities of personnel conducting product transfer operations between tanker trucks operated by Clean Water and the vessels or facility receiving or discharging the product. D&B has prepared separate response plans and operations manuals for the various geographic areas that are serviced by Clean Water tanker trucks.
Vessel Response Plan – 33 CFR Part 155; Subpart D Tank Vessel Response Plans for Oil
D&B has updated the Clean Water Vessel Response Plan to detail response procedures and identify resources available to Clean Water to respond to various oil spill scenarios associated with the vessels currently operated by the facility. The plan identifies procedures to be used in the event of a number of potential emergency situations, such as grounding or stranding, collision, fire or hull failure. It includes notification requirements; procedures for shipboard mitigation and shore-based response actions; geographic-specific information on available response resources, including oil spill removal organizations; the organizational structure to be used to manage the response action; and training requirements.
Facility Operations Manual – 33 CFR Part 154
D&B has prepared a Facility Operations Manual for Clean Water to meet the requirements of 33 CFR 154.310. As required by
these regulations, the manual addresses a broad range of topics that include general information, such as the location, hours of operation, the type and number of vessels that can transfer oil at one time, products handled at the facility and the hazards involved; procedures to be followed in the case of a release; actions to be taken in case of fire; notification requirements; a description of personnel duties during transfer operations and inspection requirements.
Facility/Vessel Security Plans – 33 CFR Parts 104 and 105
D&B has prepared Security Plans for the Clean Water vessels and for the on-shore facility in accordance with 33 CFR Parts 104 and 105, respectively. The purpose of these requirements is to reduce the risk of an incident occurring in maritime areas and include designation of a Vessel/ Facility Security Officer; conducting security assessments and development of a security plan that must be submitted to the USCG for review and approval. Each plan includes detailed security measures required for each MARSEC Level; procedures for communication and notifications; training and inspection requirements; and procedures for security measures for handling cargo, delivery of vessel stores and providing access control.
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