Spill Prevention Control and Emergency Response

As a midstream oil and gas company, spill prevention and control is fundamental to the success of our business, as well as to the preservation of the surrounding environment. We maintain emergency response plans tailored to our assets, and work closely with our employees, contractors, and local communities to prevent incidents and respond quickly and safely in the event of an emergency.

Approach

Oversight of emergency response and crisis planning begins with our Vice President of Environmental Safety & Regulatory (ESR), who reports to the Chief Executive Officer as the direct link to the executive committee. Our operational, pipeline compliance, and transportation safety personnel monitor and implement emergency response processes on the asset level, reporting up through our ESR department.

We have key systems in place to prevent spills and respond to any emergency our company may face. On the prevention side, our Asset Integrity process identifies potential hazards and implements appropriate controls. Our Crisis Communications Plan outlines our standard corporate processes for responding to and communicating about potential emergencies across our assets. Our site-specific Emergency Response Plans (ERPs), Risk Management Plans and/or Spill Prevention, Control, and Countermeasure (SPCC) plans outline scalable types of emergencies relevant to the site, corresponding response procedures, and key personnel responsible. Some of our sites also have location specific Contingency Plans, such as a hurricane contingency plan for a coastal asset. We review these plans annually and make updates as needed. Our emergency response policies and plans are on our company Intranet, available to all employees. In 2018, we improved our communications to share best practices across the company, increasing employee visibility of the actions they can take to monitor and reduce risks in the workplace.

Pipelines

We follow the U.S. Environmental Protection Agency’s (EPA) Spill Prevention, Control, and Countermeasure (SPCC) regulation for the prevention of, preparedness for and response to pipeline spills. Our SPCC plan includes clear monitoring and prevention responsibilities, and instructions for safely and quickly reducing the impact of a potential spill on the surrounding environment and ensuring the safety of our people and contractors.

As outlined in our Operational Maintenance Manual, our operations maintenance team monitors our crude oil pipelines every hour from our control centers, and periodically conducts physical inspections of our natural gas liquids pipelines, which are monitored by fail-safe pressure controls and alarms. Similar to our pipelines, we monitor our produced water lines to ensure they are operating within their designed pressures. We maintain capabilities to immediately shut down or block off a pipeline in the event of an emergency. Part of this is ensuring that our response equipment is appropriate for the area and hazards, and is properly maintained. We also maintain a hotline specifically for our workers to report any emergencies, suspicious activities, environmental or safety issues, spills, pipeline bursts, or other events. These reports are then escalated to the appropriate leadership level for proper handling.

Transportation

Our Safety Plan includes an Emergency Response Plan for transportation incidents that meets federal requirements and outlines safe practices for our drivers, especially in relation to hazardous materials (hazmat) transport. We file Crestwood’s transportation security plans and hazmat safety permits with the U.S. Department of Transportation, ensuring we uphold the safest processes for handling and transporting these materials. We also partner with TRANSCAER®, a national outreach effort focused on assisting communities in preparing for and responding to possible hazmat transportation incidents, to help train first responders in our communities. 

Emergency Response Training and Drills

We require all of our employees to complete annual training on their local emergency response plans, and participate in ongoing drills to keep our action plans current and to make sure everyone knows their role in the event of a spill. Furthermore, we participate with local emergency responders in tabletop and functional exercise drills where we communicate the resources available and processes for working together during an emergency event. We partner with organizations such as Boots and Coots, GHD Services Inc. to conduct these scenario drills. Crestwood facilitated 22 functional exercises with local emergency responders in 2018.

Crestwood also participates in industry associations that meet with first responders to provide education on the unique hazards for worksites and conduct facility drills. In 2018, we improved our outreach, exercises and functional drills across assets, working with and building relationships with first responders, and provided more training on incident command structure.

We have succeeded in reducing the number and severity of spills, as well as our response times in the event of a spill or other emergency.

2018 Spill Prevention Control and Emergency Response
Significant Spills Total Number: 6

Total Number
Hydrocarbons
2
Non-Hydrocarbons
4

2018 Spill Prevention Control and Emergency Response
Significant Spills Total Volume: 194 bbl

Total Volume
Hydrocarbons
34 bbl
Non-Hydrocarbons
160 bbl

2018 Spill Prevention Control and Emergency Response
Other Metrics

Data
Reportable Releases
6
Number of Drills
22

Case Studies

South Jersey Terminal Drill

South Jersey Terminal Drill

In June 2018, Crestwood conducted a functional drill with Upper Deerfield Emergency Services, Vineland HazMat, County 911, regional fire departments, Winchester & Western Railroad and Conrail. There were 31 participants, nine of whom were Crestwood employees. The exercise resembled a remote Emergency Operations Center or Command Post, and the incident was that a Winchester & Western Railroad train heading southbound in Bridgeton, NJ derailed, and subsequently a placarded tractor-trailer truck carrying diesel struck the side of the train.

The main objective of the drill was to establish command and control for the incident, which included establishing: a remote command post, an action plan, an incident command system, and communications among all necessary parties so all parties are informed of response and action plans. Participants also had to determine the physical and chemical characteristics of the drill, perform basic risk assessments to evaluate risk exposure to themselves and the public, create evacuations or shelters as needed, notify authorities, design a containment plan and establish a public information system.

During the drill, participants successfully conducted proper protocol for the emergency response and identified areas of improvement for communication between EMS and Crestwood employees.

TRANSCAER Training Trailers

TRANSCAER Training Trailers

Each year, Crestwood partners with TRANSCAER®, which stands for Transportation Community Awareness and Emergency Response. TRANSCAER is a national outreach effort focused on assisting communities in preparing for and responding to possible hazmat transportation incidents. In 2018, TRANSCAER worked with a Crestwood operation in West Virginia to help improve area first-responders’ awareness of the products we handle and the equipment we operate. This particular exercise illustrated how to properly respond to a liquefied petroleum gas (LPG) emergency involving semi-trailers.

Crestwood engages TRANSCAER to facilitate the use of training trailers to illustrate the internal workings of our equipment to reinforce classroom trainings for Crestwood personnel and first responders.

Looking Ahead

In 2019, we will continue to train on the incident command structure program across our assets and further enhance our crisis communications plan. We will also continue to share best practices across the company to further reduce the likelihood of spill occurrences, and improve our response rate.

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