The consequences of a water pollution event can be dire - environmentally and economically. Alan Stubbs offers some prevention and planning advice.

The penalties for water pollution can be severe - Milford Haven Port Authority was awarded £750,000 following the Sea Empress incident. Although this incident was large, far larger than any organisation should have to deal with, the reality is that any polluter these days will face prosecution. Such a prosecution can mean large fines, time and money spent on defending the case, remedial action and loss of reputation. It is estimated that for every £1 of a fine there are £11 of other costs incurred as a result of an incident. Apart from being a good neighbour environmentally, the potential for fiscal loss should be a spur to ensuring that water pollution can be prevented.

Preventing water pollution through spills is a combination of many different things. Every company should know what its spill potential is, know the environmental and safety hazards of liquids and processes used, have clear packaging and storage policies, have clear waste disposal procedures for spills, and above all, a clear effective plan for managing a spill.

SPILL CONTINGENCY PLANS
Current environmental policies require documentation and flowcharts, which clearly show that due diligence with regard to the environment is recognised by the company and acted upon. There must be an effective contingency plan that clearly defines and documents the organisation's on-site response that is appropriate to the products and processes used in its activities. Furthermore, it should also cover the off-site response, should it be required, and its suitability for the organisation's activities. The plan should define the reporting procedures for a specific spill response, and the onsite response times to spill incidents. In addition to this, there must be a policy and guidance as to when to call the emergency services and how long they would take to arrive, when to use an emergency clean up company and their response times.

The spill contingency plans must show a competent spill management structure, and cover 365 days a year. Many companies have excellent plans, operated by knowledgeable managers, but if a spill were to occur on a bank holiday or at a weekend, the appropriate people might not be around to deal with it. Contingency plans should be in a known location and easy to get at. It might sound obvious, but it is no use waiting for a spill to happen to find that the plans are locked away. Regular training and personnel familiarisation of the role they have to play during an incident are crucial, as time is a precious commodity and it cannot be wasted when a spill occurs. Clear contingency plans, regular training and exercising with knowledgeable, effective staff are a good indicator to the Environment Agency (EA) that a company takes its environmental duties seriously.

Contingency plans should contain a constructive practical plan of action that covers every type of possible spill and gives clear instructions as to how to deal with them, including:

• immediate response;
• personal action plans;
• traffic movements;
• location of spill kits;
• method statements;
• storage of raw materials including hazard data sheets;
• exercise and training programme;
• reference section of contact details, telephone numbers and support facilities; and
• fire fighting water containment and disposal arrangements.

In addition to details on how to contain pollutants and any spilt products used in a company's day-to-day activity, new legislation is coming into operation making organisations responsible for the containment of water used in fighting fires, so disposal of fire fighting water must be included in the plan.

Spill kits are an essential part of spill contingency plans. If a spill does occur, how is it to be contained and cleaned up? Spill kits with the required equipment for the spill should be kept near the areas where spills are most likely. Containment booms and absorbent pads should all be within easy reach. But it is not enough to have them close by areas where spills could occur, there needs to be clear documentation - preferably a spill kit policy - showing the content of spill kits and their location. It should also demonstrate that the spill kits could contain 100 per cent of a company's spill potential, with full documentation on usage, disposal and replenishments.

DRAINAGE
On a practical note, if a company had a spill, where would the contamination go? In many cases down the drains, just where it shouldn't be going. All industrial and commercial sites should have a comprehensive drainage plan showing the layout and flow clearly marked. As with the contingency plan, this drainage plan should be a prominent place. Clear plans, with the flow clearly marked, make it straightforward to anticipate where to control a spill, by using drain plugs and absorbents to prevent a pollutant running through the drains. It may be that interceptors will need to be built to contain spills, backed up by a regular inspection and cleaning schedule. There are also systems being developed that can rapidly and effectively block drains to ensure that polluting substances to do not enter them. Some of these use an emergency carry system for chemicals or oil, which can stay in place for an indefinite period.

Another important area is that of bunds. A bund should hold at least 125 per cent of the fluid volume of the tank it surrounds, but having a bund is not enough: it has to be maintained. Bunds are, by their very nature, prone to fill with water, which, if it fills too much, means that the bund would not hold the volume of the tank. Bunds should be regularly inspected and de-watered to ensure that overspill cannot happen. Interceptors and bunds are regularly targeted by the EA, as their maintenance is a good way for the EA to assess the general housekeeping of a company and its level of vigilance towards spills.

WASTE MANAGEMENT
Waste management plays a crucial role in reducing spill risks. One of the biggest contributing factors to spills are standing skips. We find that many skips that are delivered to sites are not suitable for containing special waste because of damage to the lower floor area, so allowing product to escape.

Contractors should inspect skips and companies can go a long way towards helping to prevent spills in this way by ensuring that both contractors and on-site personnel know about their responsibilities. Our recommendation to companies is to insist that contractors bringing products onto site should provide safety data sheets and the appropriate absorbent materials to cope with their machinery and plant. All skips to be used should be of the closed top type and prior to putting any contaminated waste inside the skip, the skip should be lined with a plastic sheet such as a dpc membrane from the locals builders merchant or silage sheet from the local farmers co-operative.

TRAINING
In an organisation which regularly handles and moves pollutants, including oil, there should be a culture of environmental awareness among staff. It is not enough just to have spill plans and kits, but staff should be thinking about minimising risk to the environment in their day-to-day activities. This is where training can play an important part.

First, training should cover the immediate response of personnel to a spill, and practised regularly. In the event of a large spill, some staff may be drafted in to respond in areas with which they are unfamiliar - so regular training should be undertaken so that they know where to go and what to do. Similarly, office staff play a role in spill response, particularly during a large spill when there will be telephones to be manned, off-site response teams to be called in and staff moving around the site, parts of which may be cordoned off. They need to know their role to ensure that the administrative back up in the event of an incident is faultless. Second, regular training will not only ensure a swift response but also inculcates the priority that the organisation places on environmental concerns, and reinforces a culture of environmental awareness.

COMMON PROBLEM AREAS
DV Howells carries out consultancy, audits and inspections for organisations that want to know their current spill status, where (if any) problems will lie and remedial action to be taken. The company also provides the spill response to the Maritime and Coastguard Agency. It has worked closely with the statutory bodies, such as the HSE, EA and local authorities. As a result, it finds that there are some areas where companies frequently come unstuck in their planning and response. They are:

• comprehensive risk assessments, but not linked to an environmental policy;
• no overall environment policy;
• lack of monitoring of interceptors;
• no regular bund maintenance or dewatering plans;
• inadequate spill kits;
• poor or little labelling of waste;
• little environmental awareness among staff; and
• good plans but no training/exercising of them.

Organisations do not have to cope alone however, as there are some very good guides easily available from statutory authorities. Companies can acquire information and recommendations, including guidelines by the EA, on its web site (www.environment-agency.gov.uk/business/ppg) or from local offices via a publication referred to as PPG (Pollution prevention guidelines). PPG 18 (Managing fire, water and major spillages) and PPG 21 (Pollution incident response planning) are two such guidelines produced by the EA.

Planning for, and effective response to spill response is essential for any company or organisation which has substances with the potential to pollute. Good planning and effective training, coupled with using prevention pollution guides, or even retaining a consultancy to pin-point errors, will help to prevent a spill or ensure that if it happens, it is dealt with effectively and safely.

Alan Stubbs, Inland Response Manager, DV Howells Limited, The MPSC, Milford Haven, Pembrokeshire, SA72 6TF.