Are Your Plans Smart Enough?

Corporate SPCC Plan Guidance: Oil Spills and Water Do Not Mix

Posted on Thu, Jul 02, 2015

Most analogies regarding oil and water convey an image of chaotic polarity. If oil comes in contact with water in an industrial setting, it can be destructive and costly. Oil spills that discharge into waterways have adversely affected environments and wildlife, caused substantial economic losses to communities, and inflicted financial penalties on companies.

If a company is subject to the Environmental Protection Agency’s Spill Prevention, Control, and Countermeasure (SPCC) rule, they must ensure plans are established, accurate, and compliant. The EPA estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the following rule:

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires these plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.

Since 1974, owners and operators of certain oil-handling facilities have been subject to the regulation. When referring to a recently plan delinquent and fined rail facility, the EPA stated that the failure to “maintain and fully implement an adequate SPCC plan leaves a facility unprepared to deal with an oil spill and to prevent a spill from having potentially serious consequences.”

Compliant "spill prevention" plans can prevent spills from occurring, as well as speed up necessary response and recovery actions. For EPA compliance, plans should provide site-specific details that allow responders to best access, assess, and quickly respond to off-site spills, limiting the effects of a spill on sensitive environments. The plans also relay site specific information related to the storage and management of oil. These plans require that facilities identify sufficient containment and/or other applicable countermeasures to reduce the potential for oil spills to reach navigable waters.

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Typical elements of an SPCC Plan include:

  • Professional Engineer Certification
  • Discussion of conformance with federal regulations
  • Facility description, plot plan, and contacts
  • Potential spill volume and flow rates
  • Inspections, tests and record keeping processes
  • Personnel training requirements
  • Loading/Unloading and transfer details
  • Discharge prevention measures
  • Security Measures
  • Recovered material drainage and disposal methods
  • Bulk Storage tanks details
  • Secondary containment locations and volumes
  • Discharge notification information and procedure
If a facility has more than 10,000 gallons of aggregate aboveground oil storage capacity, the plan must be inspected and certified by a professional engineer (PE). The certifying engineer must:
  • Be familiar with plan requirements
  • Visit applicable site and examine the facility
  • Certify that the plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards
  • Confirm that procedures for required inspections and testing have been established
  • Certify that the plan is adequate for the specific facility

Facilities that require these plans, yet have an aboveground oil storage capacity of less than 10,000 gallons, may self-certify these plans if they meet the following criteria;

The facility must not have had

  1. A single discharge of oil to navigable waters exceeding 1,000 U.S. gallons
  2. Two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any twelve-month period, in the three years prior to the SPCC Plan certification date, or since becoming subject to Title 40, Part 112 of the Code of Federal Regulations (CFR) if facility has been in operation for less than three years.

If a facility owner meets the above criteria, then the company may;

  • Prepare a self-certified plan
  • Meet tailored facility security and tank integrity inspection requirements without PE certification
  • Prepare a Plan which includes required PE certification for only the portions dealing with environmental equivalence and impracticability determinations. The remaining portions of the plan could be self-certified by the facility owner/operator.

TRP - SPCC and FRP

Tags: SPCC

Preparedness & Response Planning for Supply Chain Business Continuity

Posted on Thu, Jun 25, 2015

Weather, natural disasters, and other uncontrollable events can interrupt transportation flow and your supply chain – anytime, anywhere, and with little warning. - FedEx.com service alert

In January and February of 2015, blizzards, ice, and frigid cold temperatures targeted the eastern half of the United States. The deluge of extreme weather brought residents, cities, and supply chains to their knees. Meanwhile on the west coast, labor disputes between the International Longshore and Warehouse Union and the Pacific Maritime Association created the partial closure of 29 ports. The Port of Oakland experienced a 39% drop in cargo imports because of the circumstances (Wall Street Journal). The trucking and railroad industries lost valuable time and money, and customers experienced delayed delivery of tons of expected goods. The ripple effect of delayed shipments forced many customers to stockpile goods when available, and alter contracted shipping means when time sensitive goods were required.

Ensuring ample supplies in the midst of an incident can be challenging, especially when external forces create delays. Supply continuity and preparedness efforts are becoming more important as more companies depend on world-wide suppliers. These recent major supply disruptions, both on the east and west coasts, emphasize the need to develop business continuity plans (BCPs) that identify primary and secondary suppliers and alternate resources. By identifying and contracting with vendors and alternate suppliers prior to an incident, a company improves its ability to quickly and successfully respond to unforeseen disruptions.

Pre-emptive identification and mitigation efforts are crucial to preventing supply chain interruptions and costly consequences. Factors to consider in the identification of critical suppliers are complex and extend well beyond first glance analyses. While suppliers of material goods and business-specific products may be critical to business practices, suppliers may also include those that provide the following services, utilities, or infrastructures:

  • Sole source services
  • Electrical power
  • Water
  • Fuel
  • Telecommunications
  • Transportation
  • Staffing
  • Waste Management
  • Facilities

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Companies should utilize BCPs to prepare for incidents that could impair or impede the ability to operate as a result of a temporary or permanent loss of required supplies, equipment, critical staff, data, and necessary infrastructure. A BCP can help minimize or counteract many of the potential impacts of a supply interruption or set procedures in motion that limit the effects on operations.

Identification of risks and business impact analyses (BIA) should be performed for critical supply chains as part of the development of BCPs. For common disruptions, inept supplier performance, required resources forecasting errors, and transportation and delivery breakdowns, companies can typically utilize historical data to quantify the level of risk and necessary response effort. However, when extraordinary events impact the supply chain, such as the east and west coast incidents, companies may encounter atypical and domino effect impacts. Continuity plans with supply chain response measure must be in place to mitigate the disruption, sustain operations, and restore “business as usual”.  The following supply chain related questions, while not all-inclusive, can be used as response planning discussion points to identify necessary supply-related business continuity and response elements:

  • How would a potential critical material supply disruption affect both internal and external resources?
  • Have critical supplies, interdependencies, and potential bottleneck scenarios been identified?
  • Have critical materials and response equipment needs, minimum levels, and recovery time limits been evaluated and defined?
  • Are processes in place to monitor internal and external supply chains that identify potential delivery disruption?
  • Have back up suppliers been identified and communicated with?
  • Are memorandum of understandings (MOUs) for services, and equipment or supply contracts been established and/or up-to-date?
  • Do business continuity initiation procedures encompass verified primary and secondary supply chain contacts?
  • Is there historical data that indicates potential impacts and durations that can be used for planning?
  • Are “Best Practices” supply chain continuity procedures available from like-companies and industry experts?
  • Do critical suppliers have alternate processes and delivery methods in case an event affects their operations?
  • Have supply disruption scenarios been included in emergency response and business continuity exercises?
  • Are employees trained in the event of supply disruption?
  • Have mitigation measures been examined and implemented based on BIAs?

TRP Corp - Emergency Response Planning Crisis Management

Tags: BCM Standards, Business Continuity key points, Business Continuity Plan, Business Disruption, Mitigation

6 Goals of Effective Corporate Emergency Management Communication

Posted on Thu, Jun 18, 2015

When the Memorial Day torrential rains hit southeast Texas, smartphones equipped with Wireless Emergency Alerts (WEA) services were buzzing! WEAs of flash flood alert warnings were sent out by the National Weather Service to thousands of individuals in the affected areas through their smartphones. The idea of instantaneous communication for emergency management alerts is now a reality. However, in order to be effective for companies, corporate emergency management communications must lead to heightened awareness and/or action at the employee or responder level.

“Modern technology has brought us the greatest level of warning dissemination in our lifetime, but even with all that said there’s always going to be that situation where people may not be aware of what’s going on around them,” says Walt Zaleski, the warning coordinator at the National Weather Service’s southern region headquarters in Fort Worth, Texas.

While WEA technology adds another layer of resiliency to the suite of communication tools, companies must establish and train employees on their specific workplace emergency communications protocols. When employees are aware of corporate communication procedures and the roles that they play in each scenario, necessary responses can be effectively played out. If a widespread incident were to occur in your area, do you have effective communication procedures in place to communicate with employees and/or initiate a response?

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If and when an emergency occurs, clear communication is crucial to establish response expectations, which can protect lives, the environment, and the surrounding community. Effective corporate emergency communications should:

  1. Result from accurate data collection
  2. Be timely and current
  3. Remain concise to accurately define the “next step” or necessary tasks
  4. Clarify initial emergency response initiatives, if applicable
  5. Include time parameters and follow up procedures
  6. Be strategic in how tasks should be accomplished

An effective emergency communications strategy must be developed with a commitment from corporate leadership. In the event of an emergency scenario or incident, consistently accurate messages by company representatives alleviate potential anxiety, safeguard employees, and provide a level of credibility. This commitment must include, but is not limited to:

  • Utilizing advanced contact verification procedures: Contact lists should be verified on a regular basis to ensure all information is accurate. If maintaining accurate contact information is challenging, consider opting for notification verification system with email or text message capability that enables the contact to verify their own information through hyperlinks.
  • Establishing a communications strategic framework: Verify necessary checklists and response criteria that will guide the communications decision-making process for a variety of emergency scenarios and incidents.
  • Optimizing notification procedures: Establish a proven communications methods that will relay information to both internal and external individuals and/or organizations.
  • Testing emergency communications: Ensure communication among site managers and all business units is effective and initiates the required responses.

Successful corporate emergency communications are those that are taken seriously and responded to in a timely and effective manner. Communication procedure training should be included as part of the corporate and site emergency response plans. It may be necessary to cross-train response team members in order to provide extended knowledge in case primary team members are not available. Each team member should have a clear understanding of the procedures for receiving and disseminating information. In case of communication disruption, companies should provide employees training in primary and established secondary communication methods.

Because traditional and social media outlets can disseminate information quickly, public relations personnel should be included in emergency planning and associated exercises. Establishing and committing to communications and public relations efforts define lines of communications with employees and all partners, enables leaders to communicate response efforts and requirements, and ensures that public affairs staff has the training and the tools to be successful to maintain company reputation and client relationships.


TRP Corp Emergency Response Planning Exercises

Tags: Communication Plan

Oil Prices, Facility Response Plan Compliance, and Corporate Shuffling

Posted on Thu, Jun 11, 2015

Historically, low oil prices have triggered energy sector consolidations, reorganizations, and liquidations. As the industry responds to plunging company profits, a wave of mergers and potential acquisitions may be on the horizon. Once again, the dynamic nature of the oil industry will require corporate emergency managers to re-evaluate their approach to emergency management and regulatory compliance.

When companies merge and facilities are acquired, a company-wide emergency management program must consolidate and verify the regulatory compliance and the accuracy of facility response plans. Companies undergoing corporate structural changes should perform gap analyses or audits to identify procedural, policy, or regulatory compliance deficiencies.

Integrating plans under one centralized format consolidates preparedness and response objectives. In company merger circumstances, this process requires clear, concise, and frequent communication among multiple parties. A cohesive team, in cooperation with facility managers, should manage the consolidation of emergency management practices. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion. Responsible parties must verify and apply data, site assessments, and personnel information into cohesive, compliant, and effective plans for the new enterprise.

The following fundamental preparedness and response questions may assist companies in unifying facilities into a compliant emergency management program. Determining site-specific information, possible mitigation efforts, and response capabilities can mobilize stakeholders to develop necessary and required response planning objectives. (Note: The questions below are meant to initialize conversations and should not be considered a thorough checklist for preparedness and response planning)

Who is assigned to an emergency response?
  • Identify Incident Commander for each location
  • Create or update Emergency Management Team organizational chart
  • Identify and verify Emergency Management Team activation measures
  • Create or update Emergency Management Team roles and responsibilities checklists

Does the facility have a compliant response plan?

  • Update necessary personnel, contact information, and notifications procedure
  • Perform a gap analysis of the current plan(s) against new operations, equipment, company policies, industry best practices, and applicable local and state regulations
  • Review agency approval and electronic submittal processes, and comply as necessary

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What threats affect the facility or employees?

  • Perform a detailed hazard and risk analysis
  • Prioritize and carry out necessary mitigation measures
  • Verify or create response procedures for each identified threat
  • Identify the new process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and/or necessary equipment necessary for response
  • Establish training and scenario-specific exercises to ensure process are responses are effective for identified threats/hazards

What regulatory requirements apply to each facility?

  • Evaluate all applicable regulations based on:
    • location
    • industry
    • operations
    • hazards
    • response specifics
  • Identify required training and implement compliant program
  • Review submitted response plan information
  • Confirm training and planning documentation
  • Perform plan(s) compliance audits

What is required for an effective and timely response?

  • Identify response capabilities and determine if additional resources are necessary
  • Initiate a Memorandum of Understanding or contract specific response needs
  • Confirm contact information, availability, and response times
How will an emergency be reported and response initiated?
  • Create site-specific notification procedures. (Emergency notifications may include 911, National Response Center, internal or external response team, emergency services, and others)
  • Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in alarm procedures and immediate response actions per roles and responsibilities
  • Implement company approved emergency classification levels to associated response procedures with emergency conditions to prevent the incident from escalating
  • Create multiple evacuation routes
  • Identify the muster point(s) and head count procedures

How are response actions sustained?

  • Establish command post location
  • Identify internal and external response resources and equipment for necessary sustained response actions
  • Share plans with appropriate responders/stakeholders
  • Develop a communications plan and identify sustainable communications equipment
  • Identify hazard control applicability and methods
  • Detail external communications and public relations policies

What is done after the incident is secured?

  • Create checklist to demobilize the response
  • Identify post incident review and debriefing objectives
  • Generate a means to apply “lessons learned”
  • Update plan accordingly and amend necessary training

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, Regulatory Compliance, Facility Management

FRP and SPCC Compliance within the Proposed 2016 EPA Budget

Posted on Thu, Jun 04, 2015

As part of the proposed $8.6 billion Environmental Protection Agency (EPA) 2016 budget, the agency is allocating $18.5 million for the Oil Spill Prevention, Preparedness and Response program. The program aims to protect U.S. environment by effectively preventing, preparing for, responding to, and monitoring oil spills.

According to the EPA’s Budget in Brief, the agency “will perform inspections of regulated high-risk oil facilities to better implement prevention approaches and to bring 60 percent of Spill Prevention, Control, and Countermeasure (SPCC) and Facility Response Plan (FRP) inspected facilities found to be non-compliant during the FY 2010 through FY 2015 inspection cycle into compliance.”

Oil spills can threaten human health, cause severe environmental damage, and create financial loss to businesses and the public. According to the EPA, there are currently over 600,000 SPCC-regulated facilities under the EPA’s jurisdiction, including a subset of roughly 4,300 facilities subject to FRP requirements. Rather than be susceptible to fines, penalties, and negative publicity, companies that are required to comply with SPCC and FRP regulations should ensure response plans are up-to-date and effective. Evaluating company operations and each facility’s site-specific information will determine necessary elements for regulatory compliance and response plan requirements.

Compliance monitoring is comprised of all activities that determine whether regulated entities are in compliance with applicable laws, regulations, permit conditions, and settlement agreements. In coordination with these governances, the EPA’s Compliance Monitoring program’s goal is to determine whether conditions exist that may present imminent and substantial threat to public health or welfare of the United States.

The 2016 proposed budget enables the EPA to have a greater emphasis on emergency preparedness, particularly through the use of unannounced drills and exercises. It is imperative that facilities and responders can effectively implement established response plans according to regulations. In FY 2014, the EPA was able to bring 79% of FRP and 72% of SPCC facilities into compliance due to the development of improved guidance and procedures. The compliance program will continue to focus resources on bringing non-compliant facilities into compliance.

EPA_OIl_Facility_ComplianceSource: EPA (Chart presents data as of end of FY2014. Data represent the percentage of facilities found initially compliant in a particular year and facilities previously found to not be in compliance that were brought into compliance out of the respective sets of facilities inspected. Therefore, the numbers do not total to 100 percent.)

Compliance monitoring activities include data collection, analysis, data quality review, on-site compliance inspections/evaluations, investigations, and reviews of facility records and reports.
The EPA ensures that the management and oversight of the compliance monitoring program is enhanced by the exchange of information from the FRP and SPCC data systems to the EPA’s Integrated Compliance Information System (ICIS). This exchange provides the EPA the opportunity to focus compliance monitoring resources on areas of highest risk, and increase transparency to the public of this enforcement, and compliance data. In addition, submitting information into ICIS electronically improves data coverage and quality.

The ability to streamline the regulatory submission process is advantageous for both industry and regulatory agencies. As opposed to paper plans, web-based planning is extremely beneficial for organizations that are subject to multiple applicable regulatory requirements. A web-based planning system with a regulatory tracking element can eliminate redundancies across converging compliance requirements, which maximizes informational consistency and administrative productivity. Many companies have embraced the benefits of streamlined web-based preparedness programs because of cost efficiency, information accessibility, and the ability to verify compliance. By advancing submission practices and raising industry standards, the EPA embraces a higher level of accuracy, availability, and consistency.

As part of the 2016 budget, the EPA states it will finalize the development and begin implementation of the National Oil Database including identifying requirements for electronic submission of Facility Response Plans (FRP) in order to create reporting efficiencies for the agency, states, local government and industry. The ICIS and database will support a more comprehensive analysis and better management of the FRP and SPCC compliance programs.

Note: FRP facilities are currently required to submit their plans to the EPA Regional Offices, while SPCC facilities maintain their plans onsite.

Regulatory Compliance with TRP Corp

Tags: Facility Response Plan, SPCC, EPA

Company Fire Pre-Plans and Response Planning for Storage Tank Facilities

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.

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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