Are Your Plans Smart Enough?

Company Fire Pre-Plans and Response Planning for Storage Tanks

Posted on Thu, May 28, 2015

An emergency can quickly escalate if a storage tank containing flammable material catches fire. Developing detailed response procedures and site-specific fire pre-plans as part of an overall emergency management program provides employees, emergency responders, and firefighters with valuable information that can facilitate a safe, timely, and effective response. By exercising and sharing response plans and fire pre-plans prior to an incident, the potential for catastrophic, chain-reaction consequences can be minimized.

When employees and responders are familiar with fire pre-plans, site-details, and respective responsibilities, they can quickly evaluate tank fires and initiate proven tactical responses with minimal delays. Pre-incident planning, preparedness and coordination of response strategies should be considered and made part of response plans, drills, and exercises

Identification of tank location in relation to facility entrances and fire-fighting equipment is critical in a timely response. This can be securely shared with responders through a web-based system with facility plot plans and detailed photographs. Other key fire pre-plan information should include individual tank specifications such as:
  • Tank roof type
  • Capacity
  • Tank surface area
  • Internal diameter
  • Tank height
  • Tank insulation
  • Total dike surface area
  • Dike capacity
  • Dike drain valve location
  • Exposures

Many established plans, including fire pre-plans, are inadequate for an effective response, out-of-date, or inaccessible to those that need the plans the most. These mistakes may stem from a failure to coordinate during the plan developmental process, inconsistent plan formats, or a lack of change management procedures. In order to be effective, site-specific tank and facility details must be incorporated any response plan. The following generic emergency management procedures should be considered when developing site-specific response plans for facilities with storage tanks. (NOTE: Specific characteristics of the tank, product, and available resources should be evaluated prior to implementing any response plan procedures.)

Initial Response Actions/Notifications/Warning:

  • Warn others in the immediate area through verbal communication and/or activate local alarms.
  • Take immediate personal protective measures (PPE, move to safe location, etc.).
  • Activate emergency services and other firefighting resources.
  • Implement local response actions if safe to do so, and consistent with level of training and area specific procedures (process shutdowns, activate fire protection systems, etc.).
Notifications and warnings:
  • Proceed with internal and external notifications.
  • Determine and communicate shelter-in-place and/or evacuation directives

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Site Control:
  • Account for all personnel at the site. Confirm with entry/exit log if applicable
  • Evacuate, as necessary, and monitor routes for safety
  • Establish secure perimeters, safety zones, and required security measures.
  • Minimize site entry to essential personnel and responders.
  • If appropriate, ground fires should be extinguished first. Exercise care after the ground fire is extinguished to avoid disrupting the foam blanket over the spilled materials.
  • Cease tank operations, such as filling or withdrawing product, as soon as possible to eliminate tank content turbulence.
Fire Fighting and Containment:
  • Trained company personnel, such as those on the internal fire brigade may extinguish the fire if it is within their training level parameters. It is imperative that responses are conducted in accordance with personnel training levels.
  • A response effort may be required by an internal fire brigade or external emergency personnel (ex. mutual aid groups, local fire departments, etc.)
  • The following concepts should be considered in the event of a crude tank fire when developing response procedures:
    1. A boil over covers approximately 7 times the tank area and extends into the air approximately 10 times the tank diameter. 
    2. Consumption rate of crude oil due to burning is approximately 12-18 inches per hour.
    3. The heat wave advances from the top of the liquid towards the bottom of the tank at approximately 24-36 inches per hour.
    4. A modified fog cooling stream may be periodically applied to the side of the tank to help determine the location of the heat wave in the tank.
    5. Evacuation of the area should be considered as the heat wave approaches the bottom few feet of the tank.
    6. Foam solution should only be applied through the tank foam chambers, if possible, to avoid the risk of static build-up
    7. During an atmospheric tank fire, while using cooling streams on the tank exterior, additional attention should be given to applying cooling streams on the foam chambers and foam supply lines as well as the process lines within the dike area.
    8. Cooling streams on adjacent tanks should be applied as needed only. A cooling stream should periodically be applied to the exposed tank. If stream is given off, the cooling stream application should be continued until steam is no longer apparent. This will help reduce the demands on the fire water delivery system, and will minimize the water handling and disposal concerns from the tank dike areas.
    9. Pumping out the product of the tank may worsen the fire if the sides have been distorted and the roof does not lower evenly.
    10. Mid-range gravity crude oils have the potential for a boil over during fires that last for extended periods.

TRP Corp Fire Pre-Plans Pre Fire Plan

Severe Weather Planning TIPS for Company Emergency Response Plans

Posted on Thu, May 21, 2015

Despite best efforts of meteorologists, weather can still be unpredictable. Volatile spring weather with the potential for tornadoes, floods, and severe thunderstorms can affect some locations, while higher probabilities of drought-induced wildfires can affect others. Fortunately, historical seasonal data and likelihood levels of potential weather enables companies with multiple facilities in various locations to establish scenario-specific procedural responses and natural disaster preparedness in the event the unpredicted occurs.

Methodically formatted, web-based emergency plans injected with site-specific details can serve as a standard company model for the entire enterprise. Employees familiar with company preparedness efforts and trained in site-specific response processes are more likely to implement best practices in the event a weather phenomenon occurs. Despite the dynamic nature of weather-related incidents, responders with scenario-specific training will better comprehend their roles and responsibilities, and contend with emergency situations.

Below are a sample of natural disaster preparedness and emergency management planning concepts that companies can initiate for a variety of seasonal weather challenges.

Tornados
  1. Seconds count! Conduct tornado drills to ensure employees can locate and mobilize to designated shelter location(s).
  2. Be sure plans are communicated and revised as necessary.
  3. Examine architecture and facility construction to identify the safest location for sheltering. Large, open-spanning areas (such as a grand entryways, auditoriums, or gymnasiums) are not adequate shelters.
  4. Identify product release dangers and shutdown procedures.
  5. Be aware of the site-specific dangers posed by wind from equipment and buildings.
  6. Identify data backup and recovery procedures.
  7. Establish news and weather monitoring methods (Be sure to have battery backup available).
  8. Identify and procure potential alternate location options and necessities for conducting critical business processes off-site.
  9. Develop an emergency communication plan to relay specific expectations and responsibilities during the aftermath.
  10. Update employee contact lists with alternate contact information.

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Floods

  1. Assess the flood risk potential in your area. Be aware of stream, ditches, drainage areas, and other low-lying areas on the property.
  2. Map facility and identify multiple access and egress routes.
  3. Familiarize staff with the evacuation plan and alternate routes.
  4. Ensure important documents and server(s) are not stored in basement or ground level, and review backup procedures.
  5. Update employee contact lists with alternate contact information in the event evacuation is necessary.
  6. If evacuation is necessary, assign trained personnel to secure the premises and equipment (such as sandbagging and/or extending regulator vents and relief stacks above the level of anticipated flooding, as appropriate.).
  7. Perform continuous monitoring of the flood through various media outlets and weather tracking.
  8. Unplug all electrical devices.
  9. If flooding is probable, discuss shutting off high voltage power and natural gas lines with energy providers.
  10. Maintain hazards awareness regarding, but not limited to:
    • Structural damage
    • Downed power lines
    • Leaking natural gas, water, and sewer lines
    • Poisonous snakes and other wildlife sheltering in structures, vehicles, and furniture
    • Direct contact with flood water, mud, and animal carcasses
  11. Deploy personnel so that they will be in position to take emergency actions, such as shutdown, isolation, or containment in the event of an emergency.
  12. Identify, contract, and communicate with water damage specialist(s).
  13. Ensure clean-up equipment is available, adequate, and ample. If cleanup will be done by employees, Personal Protective Equipment (PPE) may be required. OSHA requires Personal Protective Equipment (PPE) for cleanup operations if water source is contaminated with sewage, chemicals, or other biological pollutants.
  14. Consider obtaining portable pumps and hoses from local suppliers.
  15. If applicable, determine if flooding can expose or undermine pipelines as a result of erosion or scouring.
  16. If applicable, coordinate with emergency and spill responders on pipeline location(s) and condition, and provide maps and other relevant information to them.
  17. If applicable, advise the State Pipeline Safety Office (for intrastate lines), or PHMSA's Regional Pipeline Safety Office (interstate lines) prior to returning pipelines to service, on increasing the operating pressure, or otherwise changing the operating status of the line.
  18. Conduct a post-incident review and identify mitigation opportunities to prevent future flooding impacts.

Wildfire

  1. Cut back brush or vegetation that may be impeding on structures or property.
  2. Remove dead wood and combustible litter from the site.
  3. If possible, enclose the underside of eaves and decking with fire-resistant materials to keep out flying embers.
  4. Cover exterior vents with fire retardant mesh screens to prevent embers from entering building.
  5. Develop, review, and share fire pre-plans with local fire departments
  6. Ensure employees are trained in fire prevention, evacuation procedures, and fire safety measures.
  7. Identify on-site and external equipment resources, procuring contracts if necessary (fire trucks, Backhoe/Front end loader for cutting fire breaks).
  8. Test functionality of sprinkler systems and fire extinguishers.
  9. Evaluate and maintain irrigation system
  10. If applicable, establish response team and train as necessary
  11. If a wildfire is present in the area, pay attention to local air quality reports to determine health impacts to employees. Even small amounts of smoke and toxic gases can make employees drowsy, disoriented, and short of breath.

TRP Corp Hurricane Checklist

Business Continuity Planning Until Infrastructure Resilience Secured

Posted on Wed, May 13, 2015

For the power, oil, and natural gas industries, a growing array of physical and electronic threats, coupled with decaying infrastructures and strained budgets is a recipe for disaster. Over the past few years, countless broadcasts of threats, risks, and actual incidents have been reported. From computer system hackings to gas pipeline failures, the energy industry is under continuous pressure to preserve and upgrade the resiliency of our critical infrastructures. However, until resilience is secured and infrastructures have been upgraded, companies must continue to prioritize safety and preparedness best practices.

Reliable operations are crucial to the economic stability of companies, communities, and commerce. There has been a surge by public and private stakeholders to identify steps to improve the cyber resilience of computer-based systems that manage operational processes in the power, oil, and natural gas industries. These industries are also keenly aware of the inherited deteriorating infrastructures that support their operations.

Until effective, sustainable policies, regulatory compliance initiatives, and corporate budgets embrace widespread modernization and effectively mitigate for infrastructure resilience, companies should ensure emergency management programs and business continuity plans are current and effective. In an effort to maximize preparedness and minimize inherent risks, an emergency management program should provide:

  • A system for assessing and prioritizing incidents
  • Streamlined and standardized response methods
  • Communication and notification procedures
  • Roles and responsibilities for corporate and incident level response teams
  • Optimized training, drills and exercises
  • A demonstrated commitment to safety

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According to experts, the maze of infrastructure that support the energy industries and end users requires extensive upgrades to effectively meet the nation’s energy demands. Ensuring the resilience, reliability, safety, and security of energy transmission, storage, and distribution (TS&D) infrastructure is vital.

According to the Quadrennial Energy Review (QER), the TS&D, “includes approximately 2.6 million miles of interstate and intrastate pipelines; 414 natural gas storage facilities; 330 ports handling crude petroleum and refined petroleum products; and more than 140,000 miles of railways that handle crude petroleum, refined petroleum products, LNG and coal.”

The QER was developed to identify the threats, risks, and opportunities for U.S. energy and climate security. The goal of the review is to enable the federal government to translate policy goals into a set of integrated actions. In April 2015, the QER recommended the following actions:

  • Establish a competitive program to accelerate pipeline replacement and enhance maintenance programs for natural gas distribution systems. The Department of Energy should establish a program to provide financial assistance to:
    • Incentivize cost-effective improvements in the safety and environmental performance of natural gas distribution systems
    • Enhance direct inspection and maintenance programs
  • Update and expand state energy assurance plans. The Department of Energy should establish a program to provide financial assistance to:
    • Improve the capacity of states and localities to identify potential energy disruptions, quantify their impacts, share information, and develop and exercise comprehensive plans that respond to those disruptions and reduce the threat of future disruptions.
    • Establish a competitive grant program to promote innovative solutions to enhance energy infrastructure resilience, reliability, and security.

Facility and supply chain management should be a crucial aspect of business continuity planning. At a minimum, the following planning considerations should be taken into account in order to safeguard critical operations:

  • Establish preventive inspection and maintenance schedules for all systems and equipment. 
  • Ensure that key safety and maintenance personnel are thoroughly familiar with all building systems, such as alarms, utility shutoffs, elevators, etc.
  • Establish company-wide computer security, download, and backup practices in order to secure technologies and communications networks.
  • Determine the impact of service disruptions and mitigate if possible (generators, fuel, relocating inventory, back up suppliers etc.) 
  • Establish procedures for restoring systems. 

NOTE: The April 2015 QAR can be read in its entirety here.

Preparedness and Emergency Management - TRP Corp

Tags: Business Continuity, Resiliency, Emergency Management Program

Enterprise-Wide Contingency Planning & Regulatory Compliance

Posted on Thu, May 07, 2015

Emergency Operations Plans (EOPs), or Emergency Response Plans, are often the centerpiece of a comprehensive emergency management program. EOPs should be flexible enough to be effective in a variety of emergency scenarios. However, many company emergency management programs, as well as specialized industrial facilities utilize an integrated contingency plan (ICP) to consolidate a variety of required site and response information.

An ICP is a comprehensive plan that documents necessary response actions, identifies the resources required to effectively manage potential hazards, and can fulfill compliance mandates for a variety of regulatory agencies.  ICPs enable facilities to comply with multiple federal planning requirements by consolidating them into one functional response plan.  Elements of an ICP will reflect the complexity of operations, response components, and required documentation. Depending upon the EOP’s structure and required content, hazard-specific information may be either included within an ICP or created as a separate stand-alone plan that can be distributed exclusively.

However, enterprise response planning with a variety of information into an ICP often becomes challenging when:

  • A company has multiple facilities utilizing multiple formats
  • The comprehensive plan format does not allow for the facility-specific information required for regulatory compliance
  • Plan updates result in “version confusion” or lack of data consistency
  • Known quantities of hazardous materials vary depending on operational status

An enterprise-wide template should serve as an outline for compliance required information, but should be populated with site-specific details. Utilizing a customizable, secure, web-based template with a database of common company planning information allows each site to provide facility-specific compliance data, as well as the precise information required to assist responders in determining the best response for the specific scenario.

hazardousliquidandGastransimssionpipelinemap2010

With effective web-based formats and comprehensive, yet site-specific capability, emergency managers can;

  • Reduce the need for multiple plans
  • Minimize administrative costs
  • Simplify plan reviews
  • Minimize discrepancies across various plans
  • Streamline response effort directives from one source
  • Simplify required distribution in a secured manner

ICPs do not exempt facilities from applicable regulatory planning requirements pertinent to releases of hazardous and non-hazardous substances. Companies must evaluate each site for applicable regulatory requirements. . Fortunately, multiple federal agencies endorse the use of an ICP as a means to incorporate response planning regulations, and simplify the complex planning process. An ICP may be used to incorporate one or more of the following applicable federal regulations:

EPA
  • Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR part 112.7(d) and 112.20-.21
  •  RCRA (Resource Conservation and Recovery Act) Contingency Planning Requirements, 40 CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
  • RMP (Risk Management Programs), 40 CFR part 68
Department of Transportation/Pipeline and Hazardous Materials Safety Administration
  • RSPA Pipeline Response Plan Regulation, 49 CFR part 194
  • US Coast Guard, Facility Response Plan Regulation, 33 CFR part 154, Subpart F
Occupation Safety and Health Administration (OSHA)
  • Emergency Action Plan Regulation, 29 CFR 1910.38(a)
  • OSHA's Process Safety Standard, 29 CFR 1910.119
  • OSHA's HAZWOPER Regulation, 29 CFR 1910.120

While ICPs may simplify the planning process, many companies still choose to maintain separate plans. Stand-alone plans typically contain site-specific, unique response details that apply to a single hazard, such as pandemic, hurricane, fire, or hazardous spill. Procedural, tactical, and/or incident-specific action plans tend to be location-based and often highlight operational hazards, inherent threats, or response needs. These stand-alone plans are often shared with specialized local responders and/or regulatory agencies to address specific regulatory requirements, such as the EPA’s SPCC plans (spill prevention, control, and countermeasure). Other stand-alone plans may be developed for crisis management situations, security-related incidents, and/or business continuity scenarios.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

Tags: Pipeline, Facility Response Plan, Response Plans, Regulatory Compliance, Emergency Response Planning

Enterprise-Wide Incident Response Planning for Hospital Systems

Posted on Thu, Apr 30, 2015

The Joint Commission on the Accreditation of Healthcare Organizations (JCAHO) sets standards for healthcare organizations and issues accreditation to those organizations that meet those standards. Despite the emphasis on standardization among hospital industry practices, there can be a lack of enterprise-wide incident response planning standardization among a company’s multiple facilities.

Hospital systems’ incident response plans, also commonly referred to as emergency operations manuals or disaster plans, establish process and procedures that strengthen capabilities to minimize service disruptions, support local community responses to a variety of scenarios, and promote ongoing financial and organizational well-being. A web-based, enterprise-wide response planning system can unify standard company response processes and procedures, simplify compliance and accreditation efforts, ensure best practices, and provide up-to-date preparedness arrangements for hospital systems.

Hospitals systems, like a variety of other companies, are embracing advanced communications methods and applying web-based technology to response planning. Increasingly available and more reliable technology has allowed multiple industries to transition from archaic binder-based plans to an all-inclusive web-based preparedness program. An enterprise-wide incident response planning system for hospital systems should:

● Support the ability to execute company approved response strategies
● Easily incorporate company growth and facility acquisitions
● Enable site-specific details while not compromising company directives
● Be easily updated with minimal dedicated staff
● Become a shared tool for internal and external responders
● Allow for streamlined compliance audits

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While including unique site-specific hazards and response capabilities for each facility, overall response guidelines and visual layout should be standardized to allow for a comprehensive understanding of the parent company’s best practices and proven emergency procedures. Strategic response plan knowledge and familiarity improves the ability of individuals to respond as part of a cohesive system. Standardized incident response plan formats and guidelines should include, but are not limited to:

● Overall plan structure
● Notification procedures
● Response Team organization
● Response Tactics (Initial, intermediate, and long-term)
● Roles and Responsibilities
● Layout and content of Fire Pre plans (if applicable)
● Plot plan key
● Demobilization procedures
● Mandated company and Incident Command System (ICS) forms lists

The purpose of the plan is to ensure effective response procedures dictate appropriate behaviors in the event a crisis situation arises. Whether potential emergency situations occur within the hospital setting or the surrounding communities, effective plans should account for various potential scenarios, ensuring staff readiness and timely responses. Hospital systems’ response plans should reflect potential scenarios that would significantly impact the demand for services or interfere with the ability to provide those services.

Potential operational impacting scenarios can include a sudden and abrupt event or a sustained episode over a longer period of time. Database driven, enterprise-wide planning systems provide hospitals with a tool to standardize best practices while incorporating relevant site-specific details. Hospital response scenarios may include process and procedures related to the following:

● Severe weather
● Natural disaster (ex. earthquake, tsunami)
● Utility failure
● Evacuation and Shelter-in-Place
● Explosion
● Chemical Release
● Radiation exposures
● Active shooter
● Hostage or barricade incident
● Pandemic or local infectious disease episode
● Information technology failure or hacking
● Mass casualty
● Missing person(s)
● Staff shortage
● Fire

Within each of these scenarios, response processes and procedures must be established, trained for, and exercised. However, common duplicate information is often relevant to a variety of scenarios among multiple plan types. Web-based, database driven systems utilize one database to manage information. This function allows users to effectively duplicate common plan content and revision efforts to all plans and locations that utilize the similar data. This feature minimizes administrative time and ultimately costs associated for managing response plans.

Until web-based preparedness programs became available, plan formats often varied from one facility to another, making it difficult to manage training, compliance efforts, and consistency of basic response procedures. Incorporating a definitive enterprise-wide incident response planning system across a hospital system can maximize efforts, allowing for a streamlined and familiar response process.

Web based response planning - TRP CORP

Tags: Incident Action Plan, Incident Management, Disaster Recovery

TRP Releases SMARTPLAN™ and Upgraded Incident Management System

Posted on Thu, Apr 23, 2015

Concurrent with its 20th Anniversary, Technical Response Planning Corporation (TRP) has released SMARTPLAN™, its newest, most innovative response planning / emergency management system. This robust tool demonstrates TRP’s long term vision of improving corporate preparedness and the planning process, and reinforces their commitment to the needs of current and future clients.

SMARTPLAN™’s integrated database-driven platform provides unmatched plan revision capabilities, incorporates an array of customized templates and plans, and allows for leveraged functionality upgrades for all users.

“Since 1995, it has been our mission to provide innovative solutions to the challenges associated with preparedness, response planning, and regulatory compliance.” says Steve Bassine, TRP President. “SMARTPLAN™ is the result of a two-year design initiative to create the most user-friendly, yet robust response planning / emergency management system on the market.”

earth13-resized-600Included in SMARTPLAN are major improvements to system navigation, document printing, contacts management, plan maintenance, support tools, and browser compatibility. The company has also completed major upgrades to its real-time Incident Management System, now a SMARTPLAN™ module, with meeting tools, resource tracking capabilities, time zone management, stakeholder and contacts tracking, and many improvements to system interface and forms.

Since the development of its first “electronic plan” more than ten years ago, TRP has introduced evolutionary technological improvements, upgrades, and state-of-the-art response planning modules, resulting in robust, highly functional systems that improve clients’ usability and regulatory compliance.

TRP continues to provide quality emergency planning, training, and exercise consulting services, while steadily gaining industry recognition for its innovative approach to improving the functionality of emergency response, business continuity, and related plans. SMARTPLAN™, and the upgraded Incident Management System module, positions the company among the world leaders in emergency planning technology.

To experience the power of SMARTPLAN™ or to consult with TRP exercise management experts, call (281) 955-9600 or contact us through our website.

Response Planning For Large Organizations with Multi-Facility Operations DOWNLOAD

TRP: 20 Years of Improving Response Planning & Preparedness Technology

Posted on Mon, Apr 20, 2015

For 20 years, Technical Response Planning Corporation (TRP) has designed, implemented, and managed response plans for some of the largest, most complex operations in the world, enabling companies to standardize their preparedness programs and seamlessly deliver response planning “best practice” initiatives.

“Since 1995, it has been our mission to provide innovative solutions to the challenges associated with preparedness, response planning, and regulatory compliance.” says Steve Bassine, TRP President. “We are proud that our accomplishments have simplified planning and preparedness management for companies with large, complex, and geographically diverse operations, and we look forward to future challenges and expanded relationships with companies in energy, manufacturing, transportation, utilities, automotive, and other industries.”

TRP was founded in 1995 to provide the energy industry with quality emergency planning, training, and exercise consulting services. In 1997, TRP pioneered the first "electronic plan”, as well as graphical one-page response plans for fire pre-plans, oil spill tactical plans, and spill prevention plans.

As Internet accessibility became more widespread, TRP developed the industry's first web-based system for delivering response plans, offering value-added services, increased efficiency, and customized tools for clients to manage their own response programs. This achievement and overwhelming industry acceptance significantly changed TRP's business methods, project models, and growth potential.

TRP_20th_Anniversary_seal-1

TRP continues to introduce evolutionary technological improvements, upgrades, and state-of-the-art response planning modules, resulting in robust, highly functional systems that improve clients’ usability and regulatory compliance. Concurrent with its 20th Anniversary, TRP has released SMARTPLAN™, its newest, most innovative emergency management / response planning system. This robust tool demonstrates TRP’s long term vision of improving corporate preparedness and the planning process, and reinforces their commitment to the needs of current and future clients.

TRP’s industry-proven technology has resulted in many large-scale enterprise-wide implementations across highly regulated industries. The TRP platform has enabled these companies to transition from static mismatched formats and non-functional binder-based response plans to an all-inclusive, user-friendly, web-based preparedness program.

TRP develops web-based, enterprise-wide emergency management / response planning systems that accommodate various plan types, as well as response planning and exercise consulting services. TRP plan types include Emergency Response Plans, as well as Business Continuity Plans, Oil Spill Response Plans, OPA 90/Facility Response Plans, Oil Spill Tactical Plans, Crisis Management Plans, SPCC Plans, Fire Pre-Plans, Office/Building Emergency Action Plans, School Emergency Operation Plans, Hurricane Plans, and other plan types.

To experience the power of SMARTPLAN™ or to consult with TRP exercise management experts, call (281) 955-9600 or contact us through our website.

Simplifying the Complexity of Response Plans:  The TRP Approach

High Petroleum Supplies Advocate Oil Spill Response Plan Reviews

Posted on Thu, Apr 16, 2015

According to the March 27th U.S. Energy Information Administration's weekly status report, the petroleum supply continued to rise in the first quarter of 2015. Bloomberg Energy suggested that oil inventory is approximately 25% above its 5-year average. Many petroleum storage facilities are handling near capacity volumes and should evaluate preparedness measures and oil spill response plans to ensure the hazards associated with increased oil storage volumes are accurately and effectively addressed.

Operators of oil storage facilities should review their oil spill response plans to ensure that response procedures are consistent with local topography, sensitivities, and other site-specific details. This is especially critical when tank volumes and potential spill impacts are increasing. If properly planned, exercised, and executed, plans can protect lives, communities, and the environment, and reduce the financial impact associated with an oil spill.

The primary objectives of oil spill response plans are to:

  • Allow response personnel to prepare for and safely respond to spills
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for combating the spill at a specific location
  • Improve regulatory compliance efforts

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Through facility assessments, best practices, and responder input, effective plans should incorporate a variety of aspects and perspectives of a response. As inventories increase, it is imperative that risks and threats be re-evaluated. The following 30 questions can be used as planning discussion points to develop or review oil spill plans:

  1. Have high-risk activities been identified, assessed and, if possible, mitigated?
  2. Have sensitive areas been identified and potential consequences been assessed for the current tank volumes?
  3. How would a potential spill with current tank volumes affect external resources?
  4. Did previous risk assessments utilize realistic scenarios, current oil volumes, and potential release locations?
  5. Have trajectory estimates been completed for a variety of tank volumes, and do they include potential weather scenarios?
  6. Do trajectory maps mimic local observations and historical tendencies?
  7. Have trajectory-timing estimates and recovery location points been included in oil spill planning process?
  8. Have Safety Data Sheets been updated per OSHA regulations, and are hazardous material properties been included in the planning process?
  9. Have processes been established for updating planning information, tank volumes, and required response resources?
  10. Have plot plans and area mapping been integrated with GIS data and knowledge?
  11. Are sensitive sites prioritized for protection?
  12. Have response times and limitations been set?
  13. Have alternate strategies and response procedures been identified because of increased potential spill volumes?
  14. Is there an agreement over response strategies and priorities between personnel and responders?
  15. Does the planning process incorporate best practices ecological risk assessment principles?
  16. Have response equipment needs been re-evaluated and defined?
  17. Is appropriate external spill response support available and are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), in place?
  18. Are staff roles and responsibilities specified and communicated?
  19. Are personnel appropriately trained for allocated roles?
  20. Do plans include specific criteria for provisional tiered responses?
  21. Have the plans be thoroughly exercised with realistic scenarios?
  22. Is the response management team structure clear and able to be communicated?
  23. Is there an internal and external communication method established?
  24. Is exercise feedback incorporated into plan revisions?
  25. Are clear procedures in place to notify, assess, and initiate a response?
  26. Are communications backup systems available and described in the plan?
  27. How is information accessed during a response to determine size, shape, type, location, and movement of the oil?
  28. Are procedures in place for monitoring spill size, shape, type, location, movement, and impact
  29. Are waste management and demobilization processes in place and communicated?
  30. Are external responders included in plan preparations, exercises, and distribution of the plans prior to an emergency?
As oil storage volumes fluctuate, companies must utilize collaborative efforts in developing, evaluating, and exercising oil spill response plans. Worst case discharge collaborative planning among companies, responders, and the community provides opportunities for all entities to develop the teamwork and interpersonal relationships that can result in an effective, functional, and timely oil spill response.

TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: Response Plans, Oil Spill, Disaster Response

Oil Spill and Contingency Planning in an Industry Downturn

Posted on Thu, Apr 09, 2015

In March 2015, Brent crude oil prices hovered around $50 per barrel, while West Texas Intermediate (WTI) crude fell to nearly $40 per barrel. The drastic price decline continues to pressure oil-related companies to re-evaluate operating expenses, administer headcount reductions, and rationalize budget cuts. The combination of pricing, demand, and production levels has inventory levels at their highest levels since May 1985 (US Energy Information Administration). With infrastructures at capacity and potential budget cuts aimed at stretching operating costs, EHS departments, safety managers, and response experts cannot afford to sacrifice oil spill contingency planning and preparedness elements that address a worst case spill scenario.

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The benefits of oil spill contingency planning, preparedness, and response process optimization far outweigh the risks and costs associated with non-compliance or a worst case discharge. EHS departments must prioritize planning and response exercises, as they are necessary to satisfy applicable regulatory requirements, protect the environment, and ensure the best possible safety scenario for responders and employees.

Responding to a worst case spill is a dynamic scenario with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. Yet, all plans related to oil spills, regardless of the volume, have one common thread: to minimize impact. As profits margins are stressed, companies must ensure that risks and hazards remain mitigated through compliance, preparedness, and effective response planning.

Local, state and federal regulatory agencies often require varied site information depending on particular oil-related operations and locations. This information may be required in the form of a site-specific oil spill contingency plan. Contingency planning looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill. Contingency planning should provide procedural details, or a “game plan” that addresses various spill scenarios and situations.

Despite complexity and varied nature, a well-designed contingency plan should be easy to follow. Facilities must ensure that their spill contingency plan outlines the necessary procedures for before, during, and after an emergency. Although the plans can be vastly different, they typically have four major elements in common:

  1. Hazard identification
  2. Vulnerability analysis
  3. Risk assessment
  4. Response actions

Hazard Identification: Numerous varied criteria, such as location, climate, severe weather potential, operations, logistics, equipment, spill trajectory, or facility dynamics, can create situations that can affect the ability of response personnel to contain and clean up a spill. These hazards should be identified and processes put in place to counteract challenges caused by each specific situation.  It may be possible for certain identified hazards to be mitigated, essentially eliminating the hazard altogether.

Vulnerability Analysis: It is critical to identify and provide detailed information regarding area social, natural, and economic resources that may be compromised or destroyed if a spill were to occur.  This information regarding these non-facility related entities in the path of a spill or response, should guide response personnel to make reasonable, well-informed response actions to protect public health and the environment. Vulnerability analysis information should include the following:

  • List of socio-economically sensitivities such as schools, nursing homes, hospitals, etc. and individual point of contact for each facility
  • Lists of public safety agencies/officials in adjacent and nearby communities
  • Lists of large gathering or recreational areas, such as campgrounds, parks, malls, etc.
  • Calendar lists of special events and point of contact
  • Identification of parts of the environment that are particularly susceptible to oil or water pollution such as water sources, beaches, farms

Risk Assessment: This assessment quantifies the hazards and the vulnerabilities to address the potential impact of a spill on its surroundings. The contingency plan should address best possible spill containment measures, how to prevent certain populations or environments from exposure to oil, and what can be done to repair the damage done by the spill.

Response Actions: Employees and responders should train for and exercise their assigned spill response actions in order to minimize the hazards to human health and the environment. Stakeholders and applicable levels of government and industry should be consulted and incorporated in spill response and contingency planning. Without the full participation of personnel, responders, contractors, and government entities, a plan may lack validity, credibility, and effectiveness.

TRP Corp Emergency Response Planning Exercises

Tags: Tactical Response Planning, Response Plans, Oil Spill, Regulatory Compliance

MITIGATION: The Ever-Present Emergency Management Tool

Posted on Thu, Apr 02, 2015

Effective mitigation can often prevent emergencies or minimize their impacts. Mitigation requires a thorough understanding of the potential risks, procedures, regulatory compliance, lessons learned, and operational goals. It is often difficult to quantify and financially justify preparedness mitigation initiatives, however, taking action in the present can often reduce human, environments, and financial consequences in the future.

It is often impractical for companies to spend relentlessly on emergency management mitigation efforts. Operations must remain profitable and margins maintained for corporate viability. Despite that a disaster can strike at any time, potential human, environmental, and financial impacts are often difficult to predict. For optimal financial benefit, mitigation efforts should meet certain key operational and response objectives. Ideally, mitigation efforts should eliminate or lessen the strategic cost of an incident, and reduce the tactical effort of regulatory compliance. Mitigation efforts should, at a minimum:

  • Reduce the likelihood of incidents
  • Improve the ability to respond to incidents
  • Improve the casualty and harm conditions through faster rescues and accident avoidance
  • Strengthen infrastructure against failure
  • Improve corporate reputation through intent and safety investment
  • Reduce projected downtime
  • Improve asset utilization
  • Solidify supply chain availability

Disaster preparedness mitigation measures should also be integrated into corporate and site-specific response planning and corporate preparedness initiatives.  Incorporating upgraded communication methods, technologies, response procedures, and lessons learned can improve the overall functionality of response plans. Response planning mitigation measures may include, but are not limited to:

  • Automating response planning through tracking, updating, and management
  • Facilitating the ability to update plans across locations, sites, rigs, geographies through updated technology
  • Automating regulatory compliance components and response planning activities
  • Reducing the compliance and safety resource consumption
  • Enabling HSE departments, emergency managers, and compliance specialists to spend less time on administrative duties, maintaining plans, reviewing compliance, and reporting
  • Automating governance and controls
  • Optimizing and coordinating drills, testing, and actual emergency responses

toolboxIdentifying and prioritizing mitigation efforts can be challenging. Below are a series of discussion provoking questions that can assist in mitigation assessments. Although not industry specific, these points may identify which areas of preparedness should be mitigated in order to ensure best emergency management practices are in place (NOTE: These suggested discussion points do not address all mandated planning requirements. Please refer to your operations-specific requirements to ensure regulatory compliance.)

Risk Assessment

  • What are the current high-risk activities at the location?
  • Can high-risk tasks or conditions be mitigated? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Have sensitive areas been identified and potential consequences been assessed?
  • Did risk assessment utilize realistic scenarios to define spill and release volumes and locations?
  • Are employees made aware of hazards associated with specific workplace process, materials, or location(s)?

Compliance

  • What agencies and specific regulations apply to my location(s)?
  • If applicable, have safety data sheets (SDSs) been updated per operations and properties included in the planning process?
  • Have inspections taken place or regulatory audits been performed? If so, have non-compliant issues been mitigated?
  • When will an internal compliance audit(s) be conducted and how will findings be prioritized for mitigation?
  • Is personnel training up-to-date and compliant with site-specific requirements?

Response Elements

  • Are clear procedures in place to notify, assess, and initiate a response?
  • Are individual responders and their contact information verified for accuracy?
  • Can approved stakeholders easily access response plans?
  • Have response times and limitations been identified?
  • Do response elements address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been identified in the plan, and are they accurate?
  • Are communications backup systems available and described in the plan?
  • Are staff roles and responsibilities current, specific, and communicated?
  • Have “best practice” strategies and response procedures been identified and implemented?
  • Are processes and procedures identified in the plan to assess and monitor size, shape, type, location, and movement of a spill or release?
  • If applicable, have tactical response details been included and verified for incidents that expand beyond the confines of the facility?
  • If applicable, do spill trajectory estimates and maps mimic current local observations, potential weather scenarios, and historical tendencies?
  • Have sensitive areas been identified and prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes accurate and communicated?

Documentation

  • Have processes been established for updating planning information?
  • Have updated plot plans and area mapping been integrated with accurate GIS data?
  • Are contracts, memorandums of understanding (MOUs), and other appropriate agreements and documentation in place?
  • Has exercise feedback/lessons learned been incorporated into plan revisions?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible?
  • Are necessary Incident Command (ICS) forms and company paperwork readily available for response documentation?

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Management, Emergency Management Program, Mitigation