In 2009 Con Edison initiated an assessment to proactively identify and schedule corrective actions and administrative procedures needed to enhance water discharge control and operation. The cross-organizational Water Vulnerability Assessment (WVA) team worked first to develop a water discharge standard of operation focused on establishing the company’s expectations for water discharge systems. This standard was then used throughout 2010 to perform a gap analysis throughout the company.
At the conclusion of the WVA team’s efforts, 155 projects were identified for completion. The final projects from this effort were finished in 2012. Project deliverables included the development of alarm response procedures, flow diagrams, and updated spill pollution, control, and containment plans. Physical changes to locations were made as well, including the installation of oil containment systems at a number of facilities.
The company is committed to understanding and acting upon knowledge of where its existing programs and processes are vulnerable. Correcting these vulnerabilities will be a clear manifestation of our commitment to protecting the environment, and will be an ongoing theme in future reports.
As an outcome of the Water Vulnerability Assessment initiated in 2009, Con Edison established a Spill Management Team (SMT). The SMT’s mission is to mitigate, prepare for, respond to and recover from spills to navigable waterways from the substation and transmission systems, continuously striving for excellence in spill management response. Where operating organizations were once charged with handling both the operational and cleanup aspects of a spill response, the establishment of this team allows organizations to focus solely on their operational responsibilities while the SMT handles cleanup efforts. This means customers who lost service are restored faster and spills are addressed by specialized, trained responders.
The team developed more than 280 oil spill contingency plans in 2011, including maps created in partnership with local municipal agencies identifying sewage system pathways by which released oil could travel from Con Edison facilities to a waterway discharge point. The maps also identify areas to prioritize clean-up efforts in the event of an oil spill. Cleaning up these areas first will reduce the risk of oil contamination in the nearby waterways. In the event of a spill, these maps allow for a timelier, more geographically-focused response.
Along with the development of the oil spill contingency plans, the team worked extensively to develop a comprehensive training program. The team partnered with the Clean Harbors Cooperative to complete two days of oil spill training in 2011. Topics included oil identification, booming strategies, basic water flow properties, and a review of the Incident Command System. The team also assumed incident command during the company’s annual oil spill response drill, developing a clean-up response plan to a theoretical release of oil to the Hudson River.
The Spill Management Team continued its training and response efforts throughout 2012, and engaged the New York Fire Department and New York City Department of Environmental Protection in an Oil Spill Multi-Year Exercise Program for response training purposes. The response training exercise was conducted at a Con Edison of New York substation, simulating actions based on previous oil spill incidents, and is a model that can be tailored for exercises at other substations.
“Having been through these events, and with an understanding of the mindset of the regulator, I believe I am able to offer insight that will help the company as we move forward with the Spill Management Team.”Patrick Hanley Pat is a member of the EH&S Response Team and Spill Management Team, and is a lieutenant in the U.S. Coast Guard Reserve. Pat was a first responder during the 2010 BP Deepwater Horizon oil spill.