The Risk Management Tool Box Blog

Well done to Santos

Graham Marshall - Friday, March 14, 2014

The Greenies reaction to the news of aquifer contamination - which actually occurred several years ago - at a location recently purchased by Santos in NSW shows how these people try to create a climate of fear around low-risk and low-impact events.

In response to the leak, NSW Labor put out a press release stating that: “The O’Farrell Government’s Memorandum of Understanding with Santos to fast track the approval process for Coal Seam Gas mining in the Pilliga forest should be torn up in light of revelations of contamination of the water aquifer.”

And the Greens exclaimed that this event meant it was "game over for coal seam gas”.

Which is, of course, their ultimate aim to achieve.

Many environmental groups have also leapt on the bandwagon to justify their opposition to Coal Seam Gas (CSG).

But what actually happened - and more importantly - what is the risk?

Several years ago a retaining dam was constructed in the Pilliga Forest, near Narrabri, to hold produced water extracted from wells drilled in the search for CSG.

The dam was not lined properly and it leaked.

The leaking water then entered an aquifer.

According to the NSW EPA, the contaminated aquifer - being inside the Pilliga forest - was not used for livestock, crop irrigation or human consumption.

But the leaking water contained NORM - Naturally-occurring Radioactive Materials - and other naturally-occurring minerals found in bedrock through which the drill-string passed (e.g., lead, arsenic and barium).

Fast forward to a couple of years ago - when Santos purchased the legacy asset from the original owners.

In looking over the asset as part of its due-diligence process (a good way to identify environmental issues so they can be managed properly), Santos themselves discovered the problem with the dam.

You'll recall that the dam was constructed by the prior owner of the operation before Santos acquired it.

Being a good corporate citizen, however, Santos then reported the leaking dam to the EPA.

For whatever legal reason, the NSW EPA fined Santos $1,500 because the dam leak (which occurred prior to Santos' ownership) had contaminated the aquifer.

Maybe fair enough I guess.

But the Greenies jumped on the story and the minor fine to beef-up the talk and transform the issue of NORM into "Uranium" poisoning in drinking water and lead, arsenic, and barium toxicity.

The Greenies know that "Uranium" holds a special place of fear in the human psyche due to its association atomic bombs.

So they'll stoop to any level of fear-mongering in their desperate attempt to convince the Australian population that Santos and the search for CSG is evil.

The reality, in this case, is that a small and relatively low consequence spill, with absolutely low-risk consequence to animal or public health should not be allowed to stand in the way of a billion-dollar industry that creates tens of thousands of jobs for Australians.

And Santos should be congratulated for its environmental practices; firstly discovering the leak, secondly reporting it to the EPA, and finally, in remediating it!

Well done Santos!

Hydrocarbon Releases in the North Sea for 2012

Graham Marshall - Tuesday, June 18, 2013

Hydrocarbon releases in the UK sector of the North Sea reached a record low last year according to new figures from the Health and Safety Executive (UK HSE).

There were 97 incidents reported to the UK HSE in 2012.

This is down from 133 reported incidents in 2011 and continuing a long-term downward trend.

The figures reveal a 48 per cent reduction in the number of hydrocarbon releases over the last three years – just short of the target the industry set itself in 2010 to halve releases.

The target was set following pressure from the UK HSE to improve performance.

In 2009 there were 187 hydrocarbon releases, of which 86 were classified as significant or major (84 significant and two major).

Greenies should be driving V8 Petrol Range Rovers

Graham Marshall - Tuesday, March 05, 2013

The eco-mentalist focus on global warming, or "climate change" as it is nowadays is beginning to have serious negative consequences on urban air quality and on the health of people who live it British cities.

This is because the toxic fumes produced by diesal-engined cars - promoted as a "green" alternative to petrol because of its reduced CO2 output - are significantly more damaging to health than those from petrol engines.

The research, published by the UK Department for Energy and Climate Change shows that diesal-related air pollution contributes to lung disease, heart attacks, asthma and other respiratory problems.

The findings are an embarrassment for successive governments, which have been conned by the climate-change agenda into encouraged a switch to diesel since 2001 by linking road and company car tax to CO2 emissions.

Diesel engines have long been promoted as "green" by car makers, governments and environmental groups because they produce less CO2 than petrol.

And vehicles with poor fuel economy and high CO2 emissions are also penalized by higher fuel duty tax, while diesels are not subject to road tax or congestion charges.

As a result of all this focus on CO2, petrol car sales are now 15 per cent down since 2011.

But the new research estimates that diesel-related health problems cost the Country more than 10 times more than problems caused by petrol fumes.

And only last year, the UN WHO declared that diesel exhaust caused cancer and was comparable in its effects to secondary cigarette smoking.

No account is being taken of the health damage done by diesel fumes because CO2 emissions are seen as the sole benchmark for environmental responsibility.

And the Campaign for Clean Air, a London watchdog group accused the government of deliberately exacerbating health problems by in effect subsidizing diesel.

A 2011 test by government to measure emissions from vehicles in everyday use concluded that, while petrol emissions had improved by 96 per cent, emissions of nitrogen oxide from diesel cars and light goods vehicles have not decreased for the past 15-20 years.

And I'm glad to be doing my bit by continuing to drive a 4.5 litre V8 Petrol Range Rover Vogue.  And who'd have thought you could call me a greeny?


Diesel Particulate Risk in WA Mines

Graham Marshall - Wednesday, January 02, 2013

Diesel particulates - tiny carbon particles in diesel exhaust - that have the potential to penetrate deep into the lungs are now listed as carcinogenic by the World Health Organisation's cancer research branch.

And underground mine workers in Western Australia, and elsewhere, may be at higher risk than the rest of the population because the machines they use are diesel-powered.

If exhaust fumes cannot escape mine shafts or mining companies allow poor ventilation, then the risk increases.

In Western Australia, a "top priority" working group chaired by the WA Chamber of Minerals and Energy and including the Department of Mines and Petroleum was set up in June 2011, to finalise guidelines for the management of diesel particulates.

As far back as 2004, the Australian Institute of Occupational Hygienists warned that regulatory bodies in Australia were not treating the issue seriously.

Exhaust filters should be mandatory, better ventilation is a must and air testing should be rigerous.

The WA Mines Department says diesel particulates must not top 0.1 milligrams per cubic metre of submicron elemental carbon, all mines must submit their air quality results, and any that exceed the levels are shut down.

So far this year, inspectors shut down two mines in the WAGoldfields for air quality or ventilation breaches. "The department recognises that exposure to diesel engine emissions should be minimised, which is why the working group is currently developing a new guideline and why we inspect and audit sites," safety executive director Simon Ridge said.

Barrick Gold is one company which now requires underground workers to wear respirators where diesel levels are high.

Risk Assessment Methods for Flammable Liquids Storage Depots

Graham Marshall - Thursday, September 27, 2012

Enclosed here is a benchmark study into the outcomes of two risk assessment methods which are used by regulators in Holland and France to make risk-management decisions for land use planning in and around storage depots containing flammable liquids.

 The study will be of particular interest to any person with control over tank farms and such like.

The area where vulnerable objects are undesirable and where future vulnerable objects should be avoided is largely the same in the two risk assessments. The area where severe consequences from a potential accident have to be considered is comparable as well.


Cleaning-up a Broken Fluorescent Lamp Globe

Graham Marshall - Monday, September 03, 2012

Fluorescent lamp globes (e.g., strip lights) contains a small amount of mercury, which can present a hazard if the lamp is broken.

To prevent the mercury from harming people, the best option is to use "elimination" or "substitution" methods from the hierarchy of safety control. 

That means considering alternatives to fluorescent lamps in situations where they could easily be broken or in bedrooms or carpeted areas frequented by infants, small children, or pregnant women.

It is also worth considering putting a drop cloth on the floor so that any accidental breakage can be easily cleaned up the next time you do have to replace a fluorescent globe.

Also, consider not storing too many used/spent lamps before recycling as that may increase your chances of breakage.

So what should you do if a fluorescent lamp is broken (e.g., dropped on the floor and smashed)?

Well, the good news is that you can clean this up yourself if you do the following:

•  Immediately open any windows in the room where the breakage occurred, and then leave the area for 15 minutes. Mercury vapour levels will be lower by then;

•  Keep people and pets away from the breakage area;

•  Don't use a vacuum cleaner because this method of clean-up will spread the mercury vapour and contaminate the vacuum;

•  Start the clean-up by carefully removing the larger pieces of broken glass and place them in a secure closed container, preferably a glass container with a metal screw top lid and seal like a canning jar.  A glass jar with a good seal works best to contain any mercury vapors inside;

•  For maximum protection and if you have them, wear rubber gloves to protect your hands from the sharp glass;

•  Collect the smaller pieces and dust. Use stiff paper or card to scoop up the smaller pieces;
•  Pat the area with the sticky side of duct tape, packing tape or masking tape to pick up fine particles;

•  Wipe the area with a wet wipe or damp paper towel to pick up even finer particles;
•  Put all the broken glass and waste, including all material used in the cleanup that may have been contaminated with mercury into the container;

•  Remove the container with the breakage and cleanup materials from your home. This is particularly important if you do not have a glass container;
•  Continue ventilating the room for several hours;

•  Wash your hands and face;
•  Find out where your Local Authority has made arrangements for recycling of this type of waste, and take the container to that location;

•  When a break happens on carpeting, consider removing throw rugs or the area of carpet where the breakage occurred as a precaution, particularly if the rug or carpet is in an area frequented by infants, small children or pregnant women;
•  Finally, if the carpet is not removed, open the window to the room during the next several times you vacuum the carpet to provide good ventilation.

Don’t forget to properly recycle your used fluorescent bulbs so they don’t break and put mercury into our environment.

Emergency Response Guidebook 2012

Graham Marshall - Monday, August 27, 2012

The 2012 Emergency Response Guidebook has been recently released for use by fire fighters, police, and other emergency services personnel who may be the first to arrive at the scene of a transportation incident involving dangerous goods.

Developed jointly by Transport Canada, the U.S. Department of Transportation, the Secretariat of Transport and Communications of Mexico and with the collaboration of the Centro de Informaciòn Quìmica para Emergencias of Argentina, the guide assists first responders in quickly identifying the specific or generic hazards of the material(s) involved in the incident, and protecting themselves and the general public during the initial response phase of the incident.

This guidebook will assist responders in making initial decisions upon arriving at the scene of a dangerous goods incident.

The Guidebook is not a substitute for emergency response training, knowledge or sound judgment and it does not address all possible circumstances that may be associated with a dangerous goods incident.

It is primarily designed for use at a dangerous goods incident occurring on a highway or railroad.

It may also have some limited value in its application at fixed facility locations.

A copy of the 2012 Emergency Response Guidebook is available here (free).


Esperence Lead Contamination

Graham Marshall - Sunday, July 22, 2012

The clean-up  of one of Western Australia's worst environmental disasters, involving lead contamination in the town of Esperence is due to be completed in July 2012.

It has taken more than five years since the problems were first identified following the deaths of thousands of birds and the discovery of elevated lead levels in local children.

It was found that lead dust was escaping at the Esperence Port during ship-loading and during transportation from a Wiluna mine by train to the town.
Water tanks across Esperence were discovered to have lead levels exceeding the standard for safe drinking water.

Since establishing a clean-up program in 2008, the Government of WA has spent AUD $25 million testing properties in the town for lead contamination.

Lead mining company Magellan Metals has also contributed AUD $9 million towards the clean-up and $1 million to establish a community fund. The WA Minister for Transport (Troy Buswell) said the clean-up had cost $5.8 million more than expected.

Of the tested properties, 1,775 homes and commercial premises needed to be de-contaminated.

The WA Department of Health carried out a blood lead survey and identified 33 people, including many children with blood lead levels in excess of the internationally recognized health guideline of 10 micrograms per decilitre.

Blood lead levels in affected children have since reduced to below 5ug/dL, according to a government website.

An audit will now be carried out by an independent environmental consultant to ensure no lead contamination remains in the town.

Poor Safety Culture & Not Following Procedures Contributes to Pipeline Spill

Graham Marshall - Wednesday, July 18, 2012

A visitor to the Risk Tool Box safety blog has emailed to me the information reported below.  It makes interesting reading for any safety professional and shows how an inadequate safety culture and a lack of procedures being followed can contribute to disasters. 


Pervasive organizational failures by a pipeline operator along with weak federal regulations led to a pipeline rupture and subsequent oil spill in 2010, the National Transportation Safety Board said today.

On Sunday, July 25, 2010, at about 5:58 p.m., a 30 inch-diameter pipeline (Line 6B) owned and operated by Enbridge Incorporated ruptured and spilled crude oil into an ecologically sensitive area near the Kalamazoo River in Marshall, Mich., for 17 hours.

A local utility worker discovered the oil and contacted Enbridge to report the rupture.

The NTSB found that the material failure of the pipeline was the result of multiple small corrosion-fatigue cracks that over time grew in size and linked together, creating a gaping breach in the pipe measuring over 80 inches long.

"This investigation identified a complete breakdown of safety at Enbridge. Their employees performed like Keystone Kops and failed to recognize their pipeline had ruptured and continued to pump crude into the environment," said NTSB Chairman Deborah A.P. Hersman.

“Despite multiple alarms and a loss of pressure in the pipeline, for more than 17 hours and through three shifts they failed to follow their own shutdown procedures.”

Clean up costs are estimated by Enbridge and the EPA at $800 million and counting, making the Marshall rupture the single most expensive on-shore spill in US history.

Over 840,000 gallons of crude oil – enough to fill 120 tanker trucks – spilled into hundreds of acres of Michigan wetlands, fouling a creek and a river.

A Michigan Department of Community Health study concluded that over 300 individuals suffered adverse health effects related to benzene exposure, a toxic component of crude oil.
Line 6B had been scheduled for a routine shutdown at the time of the rupture to accommodate changing delivery schedules.

Following the shutdown, operators in the Enbridge control room in Edmonton, Alberta, received multiple alarms indicating a problem with low pressure in the pipeline, which were dismissed as being caused by factors other than a rupture.

"Inadequate training of control center personnel" was cited as contributing to the accident.

The investigation found that Enbridge failed to accurately assess the structural integrity of the pipeline, including correctly analyzing cracks that required repair.

The NTSB characterized Enbridge's control room operations, leak detection, and environmental response as deficient, and described the event as an "organizational accident."

Following the first alarm, Enbridge controllers restarted Line 6B twice, pumping an additional 683,000 gallons of crude oil, or 81 percent of the total amount spilled, through the ruptured pipeline.

The NTSB determined that if Enbridge's own procedures had been followed during the initial phases of the accident, the magnitude of the spill would have been significantly reduced.

Further, the NTSB attributed systemic flaws in operational decision-making to a "culture of deviance," which concluded that personnel had a developed an operating culture in which not adhering to approved procedures and protocols was normalized.

The NTSB also cited the Pipeline and Hazardous Materials Safety Administration's weak regulations regarding pipeline assessment and repair criteria as well as a cursory review of Enbridge's oil spill response plan as contributing to the magnitude of the accident.

The investigation revealed that the cracks in Line 6B that ultimately ruptured were detected by Enbridge in 2005 but were not repaired.

A further examination of records revealed that Enbridge's crack assessment process was inadequate, increasing the risk of a rupture.

"This accident is a wake-up call to the industry, the regulator, and the public.

Enbridge knew for years that this section of the pipeline was vulnerable yet they didn't act on that information," said Chairman Hersman.

"Likewise, for the regulator to delegate too much authority to the regulated to assess their own system risks and correct them is tantamount to the fox guarding the hen house.

Regulators need regulations and practices with teeth, and the resources to enable them to take corrective action before a spill. Not just after."

As a result of the investigation, the NTSB reiterated one recommendation to PHMSA and issued 17 new safety recommendations to the Department of the Transportation, PHMSA, Enbridge Incorporated, the American Petroleum Institute, the International Association of Fire Chiefs, and the National Emergency Number Association.



Oil Spill Shore-line Clean Up

Graham Marshall - Tuesday, July 17, 2012

The majority of marine oil spills occur close to the coast and the techniques used for shoreline clean-up are relatively straightforward. 

Clean up operations on shorelines can be considered under three stages.  These are:

1. Emergency phase involving the collection of floating oil close to shore;

2. Project phase involving the removal of stranded oil and oiled shoreline materials; and

3. Polishing phase involving the final clean up of light contamination and removal of oil stains.

Enclosed here is an excellent technical information paper from the International Tanker Owners Federation dealing with techniques for clean-up of oil from shorelines across the three-phases of action.

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