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Best Practices of Stormwater Pollution Prevention Planning and the SWPPP

Posted on Mon, Nov 25, 2013

The purpose of a Stormwater Pollution Prevention Plan (SWPPP) is to identify potential stormwater pollution sources and guide facilities to reduce the potential for pollutants reaching nearby waterways.  Establishing procedures and controls is necessary to accomplish the following SWPPP objectives:

  1. Identify pollutants that may come in contact with stormwater.
  2. Establish measures to prevent pollutants from interacting with stormwater
  3. Establish controls to reduce or eliminate the potential for contaminated storm water being released to the environment.

The Environmental Protection Agency (EPA) defines control measures as “any Best Management Practice (BMP) or other method used to prevent or reduce the discharge of pollutants.” The SWPPP requires that companies identify and document which BMPs will be installed at the facilities. BMPs may include:

  • Schedules of implementation activities
  • Prohibited practices
  • Other management practices
  • Treatment requirements
  • Operating procedures
  • Practices to control industrial stormwater runoff, spillage or leaks, sludge, waste disposal or drainage from raw material storage.

Facilities are not required to have structural best management practices implemented prior to a permit application for permit coverage.  According to the requirements, a facility has one year from the time of submitting a permit application to implement structural best practices. However, the EPA recommends installing structural best management practices as soon as possible.

There are 3 main categories of BMPs. These include:

  • Non-structural BMPs: examples include, but are not limited to:
    • Optimize maintenance practices
    • Control spills and leaks
    • Manage wastes
    • Employee training programs
    • Optimize procedures and operations
  • Simple structural BMPs: examples include, but are not limited to:
    • Move significant materials and activities under cover
    • Store materials in weatherproof containers, shelters, or dumpsters
    • Use temporary shelters, like tarps, on a short-term basis only until permanent structures can be installed
  • Complex structural BMPs: examples include, but are not limited to:
    • Cover materials or operations with canopy or awning type structures
    • Provide curb or slopes designed to prevent stormwater run-on or runoff
    • Create stormwater ponds, sedimentary or wetland treatment systems

The following questions can assist in the evaluation of potential BMPs and implementation:

  • Are the BMPs appropriate for my facility size/industrial activity/significant material?
  • Are the BMPs the most cost effective to install?
  • Is there another BMP that is simpler/more cost-effective that achieves SWPPP goals?
  • Does the BMP require maintenance and is there adequate staffing for required activities?
  • Can BMPs prevent precipitation from coming in contact with operations and/or significant material?
  • Does the facility meet the criteria for ”No Exposure Exclusion”?

The content of the SWPPP will vary depending on site-specific conditions. According to The State of Washington’s Department of Ecology, the following BMPs common in SWPPPs:

Covered Storage:  Chemicals stored outside should be covered so that rainfall does not become contaminated by contact with the chemical containers. The SWPPP should include this as a standard practice at the facility and a map should identify the covered storage areas.

Equipment Maintenance:  The SWPPP should identify equipment that can spill or leak contaminants, such as petroleum products. Provide an inspection and maintenance schedule for each piece of equipment that is identified.

Employee Training:  The first line of defense will often be an onsite employee. With proper training, facility personnel can properly manage stormwater and protect it from contamination.

Site Maintenance:  Grading the site to provide even infiltration of rain and eliminating site debris will minimize contamination of stormwater.

Infiltration:  Infiltration of all or part of the stormwater is preferred. A grassy swale, infiltration trench, or a constructed wetland may provide adequate infiltration for all or most stormwater events. However, when stormwater has become contaminated with pollutants such as oil and grease, treatment may be required before infiltration.

Detention Pond:  At sites that discharge stormwater to surface water, a detention pond will typically be required to control turbidity. Careful attention to pond dimensions and design is necessary to accommodate major storms and provide adequate settling.


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Tags: NPDES, EHS, Regulatory Compliance, Flood Preparedness, Chemical Industry

Proposed Changes to the NPDES General Permitting Requirements

Posted on Mon, Nov 04, 2013

On September 27, 2013, the U.S Environmental Protection Agency (EPA) requested public comments regarding proposed changes in the 2013 National Pollutant Discharge Elimination System (NPDES) general permit for storm water discharges from industrial activity.  Once finalized, the new permit will replace the 2008 document, which was issued for a five-year term on September 29, 2008.

According to the EPA, the NPDES general permit, also referred to as the Multi-Sector General Permit (MSGP), covers multiple facilities with common discharges within a specific geographic area. A general permit applies the same or similar conditions to all dischargers covered under the general permit. The EPA issues these permits for storm water discharges associated with industrial activity, under the NPDES program (as defined in 40 CFR 122.21 and 40 CFR 122.26).

Four states (Idaho, Massachusetts, New Hampshire and New Mexico), Indian lands, and several territories do not have their own federally approved storm water permitting programs.  Within these areas, entities that are subject to industrial storm water discharge regulations are required to apply to the EPA to obtain coverage under the MSGP. Due to the delay to allow for comments, the 2008 MSGP has been administratively continued in accordance with 40 CFR 122.6, and will remain in effect until the new draft permit is finalized. EPA estimates that the new MSGP will be reissued in the spring of 2014.

The MSGP covers 29 different industrial sectors with specific and varying compliance requirements. As written, the draft MSGP includes several new or modified requirements from the 2008 MSGP. The EPA proposes the following:

  • The EPA will perform Environmental Assessments (EA) for dischargers subject to any New Source Performance Standards (NSPS). The EA will consider the potential environmental impacts from the discharge of pollutants in storm water discharges from new sources associated with industrial facilities, where EPA is the permitting authority, to determine whether to prepare an Environmental Impact Statement (EIS).
  • The EPA will require electronic submission of numerous reporting documents including each notice of intent, notice of termination, discharge monitoring reports, annual reports, and all monitoring data, unless a waiver is granted. Waivers would be granted for a one-time use for single information submittal.
  • The EPA will prohibit the discharge of pavement wash waters directly to any surface water or storm drain inlet, unless the facility has implemented control measures or subjected the wastewater runoff to dry clean-up techniques prior to discharge.
  • The EPA will require that each permit holder make a copy of its Storm water Pollution Prevention Plan (SWPPP) publicly available, either by identifying a URL link on the notice of intent (“NOI”) that is filed with EPA to apply for the permit, and then posting the SWPPP on the internet, or by providing storm water management information in the NOI itself. The information required includes a detailed description of:
    • The onsite industrial activities exposed to storm water, including potential spill and leak areas
    • The pollutants associated with each industrial activity exposed to storm water and/or authorized non-storm water
    • The control measures employed to comply with the non-numeric technology-based effluent limits
    • Additional measures taken to comply with requirements in Part 2.2
    • The good housekeeping, maintenance, and inspections schedules
  • The proposed permit clarifies effluent limits to include a greater level of specificity in order to make the requirements more clearly articulated, transparent, and enforceable. These clarifications include requirements for minimizing exposure, good housekeeping, maintenance, spill prevention and response procedures, and employee training.
  • The proposed permit modifies specificity of corrective actions, including the necessary actions to be implemented prior to deadlines. The draft permit would require that corrective action steps be taken immediately (i.e., on the same day the condition was found) in order to ensure that pollutant discharges are minimized and that a permanent solution is implemented expeditiously. The draft MSGP also requires that subsequent action must be taken to install a new or modified control and make operational, or complete the repair, before the next storm event if possible, and within 14 calendar days from the discovery of the condition.
  • The EPA will require that all annual reports submitted under the new MSGP include a summary of the routine inspections and assessments conducted at the facility throughout the previous year.
  • The proposed permit clarifies that one is considered a discharger to impaired water if the discharge flows directly to the water, including if the discharge enters a storm water collection system that discharges to impaired water.
  • The EPA proposal clarifies language associated with the conduct of corrective actions. These actions are currently required under a limited set of circumstances.  The proposed permit expands the conditions under which corrective actions will be required and imposes specific deadlines for completing these actions, including immediate actions on the day of discovery to address conditions that require corrective action.

Those subject to the 2008 MSGP should carefully review the proposed requirements, as well as the sector-specific requirements that apply to their industry to ensure comprehension of the changes. Formal comments on the proposed draft will be accepted through November 26, 2013.

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Tags: NPDES, SWPPP, EPA, Regulatory Compliance, Facility Management, Flood Preparedness

Flood Disaster Management for Oil and Gas Facilities

Posted on Thu, Oct 31, 2013

From September 9 through September 13, 2013, a series of heavy storms settled over parts of Colorado, bringing flash floods and widespread destruction. Over the five-day period, parts of Boulder County received over 17 inches of rain, with an unprecedented 12 inches of rain occurring in one day. Rain totals in numerous Denver suburbs exceeded 20 inches, compounding the havoc from the storms. The catastrophic event created swollen rivers and flash flooding that cut off towns, destroyed homes, crumbled transportation infrastructures, ravaged sewer lines, and damaged oil and gas production facilities.

As a result of the flooding, the local oil and gas industry was forced into flood disaster management mode. Many oil and gas wells and facilities were shut-in to reduce potential impact to the environment, however the force of the flooding caused thousands of gallons of oil to be spilled. According to The Colorado Department of Natural Resources’ October 8th report, the agency was tracking 13 notable releases caused by the extensive flood waters, with oil releases totaling 43,134 gallons or 1,072 barrels.

Experts believe the release totals are likely to rise, as state oil and gas commission inspectors evaluate additional areas affected by flooding. The agency developed “flood impact zone” mapping which expanded its initial flood assessment area. The report states, “This is not due to an increase in impacted locations, but is an exercise designed to use an excess of caution in ensuring any location potentially affected receives an assessment and evaluation by Colorado Oil and Gas Conservation Commission (COGCC) personnel.”

The flood impact presents an opportunity for governments agencies, LEPC’s, and companies to review response plans, assess response procedures, and identify what lessons can be learned from the disaster. Alan Gilbert, a director at the Colorado Department of Natural Resources, stated that regulators were examining their response to the disasters. "We are going to have a formal review. We'll look at what worked and what didn't work."

However, the extent of the flooding has highlighted effective mitigation measures. Doug Hock, spokesman for Encana, a North American energy producer, identified a lessons’ learned concept from their Front Range operations.  Hock told The Daily Sentinel that fences are typically installed on well pads when operations are located in densely populated areas. While Encana did sustain damage from the flooding, the damage was limited at the Front Range facility because the fences kept out floating debris. “It was kind of an ah-ha, light-bulb moment to say, going forward we should do this because it helped protect those pads,” Hock said.

On October 4, 2013, the COGCC released a notice stating that Level 1 and Level 2 facilities in the flood impact zone shall be subject to a Compliance Plan. The Compliance Plan includes start-up procedures, certification that the procedures have been completed, and submission of a Notice of Start-up.

The following COGCC recommended start-up procedures could be utilized as a guide for restoring operations after a flooding incident has occurred.  (Note: Site-specific operations may dictate specialized start-up procedures and applicable regulatory compliance requirements).

Fluid Inventory

  • A status report shall include fluid inventory assessment to compare pre-flood volumes to post-flood volumes.
  • Inventory list shall include review of tank gauging records and or remote monitoring data.
  • The inventory assessment shall occur before facility is restarted or before tanks are moved from the location and reported on a status report.
  • Inconsistent volumes may trigger spill reporting.

 Flowlines and Pipelines

  • Pressure test and document the integrity of flowlines. Submit pressure test results of any segment that fails integrity test and include plans for repair or replacement.
  • Pressure test all pipeline segments and onsite production equipment.
  • Pressure test flow lines to the maximum anticipated operating pressure


  • Stabilize tanks
  • Check all valves and piping on the drain, and all inlet and tank load valves
  • Pressure test oil dump line(s) to tanks to the maximum anticipated operating pressure.
  • Each oilfield tank must be inspected to ensure integrity. If damage is known or suspected (the tank, flanges and/or any other fitting), additional integrity testing such as Magnetic/Flux Leakage (MFL), ultrasonic thickness, or weld inspections may be required or replace tanks as necessary.
  • All oilfield tanks shall be labeled with the following:
    • Name of operator
    • Operator’s emergency contact telephone number
    • Tank capacity
    • Tank contents
    • National Fire Protection Association (NFPA) Label
    • Information shall be on tanks and legible from 100 feet
  • All equipment including buried vessels and sumps shall be anchored
  • Each buried or partially buried sump, vault, vessel shall be tested to ensure integrity using static level test methods.

Secondary containment

  • Shall be installed at tanks, sumps, and partially buried vessels.
  • Where secondary containment has been damaged and will be replaced/repaired, the containment shall be constructed of metal, concrete or other armored material such as compacted earth with gravel protective covering. Material must be sufficiently impervious to contain released fluids and resist damage from floodwaters.
  • Tanks shall be anchored using an engineered design.
  • Submit Form 4 with GPS coordinates for all tank batteries taken from southeast corner of battery. Include listing of all wells producing to the battery.
  • Storm water management BMPs shall be installed.


  • Visually inspect all equipment.
  • Check for separator stabilization on pad.
  • Check regulators; connections on separator inlet and outlet to meter; and high/low valves to ensure that they are functioning correctly.
  • Check flame arrestors and fire tubes for debris.
  • Integrity testing to the maximum anticipated operating pressure shall be conducted for the following equipment:
    • Separator equipment
    • Heater treaters
  • Integrity testing shall be conducted according to industry standards and documented in final compliance certification.
  • All separator equipment shall have general secondary containment. It shall consist of metal, concrete, or earthen material that is sufficiently impervious to contain released fluids and to resist damage from wind and water erosion.
  • All separators shall have NFPA Hazard Diamond label.
  • Check stability of emission control device. Inspect pilot light(s), ignition control equipment and flame arrestor. As necessary, disassemble and clean affected parts. Clear line from production tanks to emission control device
  • Check stability of Vapor Recovery Unit and that the unit is operating safely and efficiently.
  • Check suction and discharge lines.
  • Safely remove debris from all equipment in order to provide unrestricted access.
  • Repair damaged fencing around equipment as needed
  • Ensure onsite gathering equipment has integrity
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Tags: Oil Spill, Regulatory Compliance, Emergency Management Program, Flood Preparedness, Disaster Response

Emergency Response Planning for Severe Weather

Posted on Thu, Jul 11, 2013

The topic of severe weather and its devastating impacts continues to dominate the news headlines. Prior to forecasts and potential destructive weather patterns, companies should evaluate scenario-specific response plans in order to be prepared for naturally occurring threats. Severe weather, including derechos (powerful and extended straight line wind storms), flash-flooding, hail, tornadoes, and tropical storms can be destructive for typical business operations. Scenario-specific response plans, in conjunction with a business continuity plan, can ensure the safety of employees and company viability in the aftermath of severe storms.

When assessing risk and activation of a plan, the facility supervisor must be informed of the type of severe weather, forecasted possibilities, and potential timing of impact. If ample time is allotted, implementation of a plan may begin with activation phases. This allows for basic facility preparations to occur prior to being susceptible to weather hazard(s). Facilities should not institute exterior preparations once severe weather is imminent. If thunder is heard or lightning is seen, outdoor activities should be terminated and employees moved to safety immediately. According to The National Weather Service the following terminology is used to describe the potential forecast and/or timeline:

  • Special Weather Statement:  Designed to provide critical short-term hazardous weather information. The time frame of this information is six hours or less.
  • Watch: Significant weather is possible within 48 hours, but not imminent.
  • Advisory: Significant weather event is likely to occur in a specified area, or imminent. An advisory may be the time frame between a watch and a warning.
  • Warnings: Significant weather is occurring, imminent, or likely, and is a potential threat to life and property.

Both large and small businesses can benefit from instituting mitigation measures and training efforts prior to the high-risk months. Possible planning and mitigation efforts include, but are not limited to:

  • Pertinent site-specific policies and procedures should be reviewed for applicability and effectiveness.
  • Obtain materials to secure windows and brace doors, if necessary. (If lumber is necessary, pre-cut wood to size, mark each panel/piece to identify location).
  • Prune tree limbs from hanging over rooftops and clear gutters/downpipes
  • Verify employee contact information, alternate contact information, and list potential evacuation locations.
  • Develop methods for employees to receive pertinent corporate information if evacuation is conducted.
  • Establish recovery contracts with suppliers.
  • Routinely verify contact information and equipment availability with response resources.
  • Assign and train employees on severe storm related preparedness, response, and recovery tasks.

A simple checklist can be incorporated into severe weather plans that minimize the impacts of these events.

  • Monitor news and weather reports on smart phone, television, or battery operated radio
  • Alert employees or others on-site that severe weather is approaching and communicate expectations (i.e. shelter in place, evacuate, facility closure)
  • Review shutdown procedures and evacuation routes
  • Identify structural integrity of building(s) to withstand forecasted winds
  • Be aware of the dangers posed by airborne debris, equipment, and facility structures. Mitigate and secure, if possible
  • Be aware of potential for product release posed by containment failures (I.e. tanks, piping, pipelines, process equipment)
  • Contract tree removal services or obtain the necessary equipment to remove potential debris
  • Ensure that vehicles have a full tank of gas and are functioning properly
  • Obtain emergency equipment, such as generators, battery-operated radios, flashlights, lighting and additional batteries. Be prepared to acquire additional fuel if necessary, and time permits.
  • Monitor tanks, buildings, or other equipment for potential damage or failure
  • Obtain generators, if necessary to re-power facilities
  • Establish and maintain communication with personnel in remote areas
  • Communicate potential severe weather to facility personnel
  • Identify secure shelter location(s) within the facility (i.e. underground shelters, interior room without windows)
  • Conduct drills to ensure employees can locate and mobilize to designated shelter location(s)
  • Consider limiting vehicle traffic
  • Notify supervisors if facility(s) looses power, experiences storm related damage, any injuries, or if operations must be terminated
  • Develop an emergency communication plan to relay specific expectations and responsibilities during the aftermath
  • Identify product release dangers and shutdown procedures
  • Identify data backup procedures
  • Identify essential business records, backup procedures, and recover plans
  • If evacuating the facility, locate and pack critical documentation (e.g. insurance, financial, legal and identification documents) in a portable waterproof container
  • Identify and procure potential alternate location options and necessities for conducting critical business processes off-site.

 Establishing strategies to help cope with natural disasters, such as severe storms, can limit harm, financial losses, maintain business continuity, and enable a timely recovery.

TRP Corp Hurricane Checklist

Tags: Business Risk, Training and Exercises, Business Continuity Plan, Flood Preparedness, Disaster Recovery, Disaster Response, Tornado Preparedness

Incident Specific Response Planning

Posted on Thu, May 30, 2013

No two crisis situations or responses are identical. As a result, Emergency Managers and Environmental Health and Safety (EHS) Managers responsible for developing and managing comprehensive, compliant, and functional response plans should create a broad scope of planned responses for potential emergency and crisis situations. In many circumstances, response efforts to various incidents may be similar. However, supplemental response procedures for specific hazards or threats can be added to the overall emergency management program to address these scenarios.

Focused supplemental response procedures or plans, for specific events such as pandemic flu and hurricanes can encompass a full range of hazards and potential threats and unique response details that apply to that single hazard. Depending upon response plan structure and volume of content, hazard-specific information may be included within an all-hazards response plan, or created as a stand-alone plan.

Hazard or incident-specific plans should include the same level of detail as the basic response plan, including, but not limited to:

  • Specific location(s)
  • Contact information for internal and external responders
  • Evacuation routes
  • Plot Plans
  • Specific provisions and protocols for warning employees, the public, and disseminating emergency information
  • Personal protective equipment and detection devices
  • Policies and processes for each specific hazard response
  • Identification of additional potential hazards
  • Response team roles and responsibilities
  • Recovery and restoration processes

Just as in the primary response plan, a planning team may use supporting documents as necessary to clarify the contents of the incident specific plan. These supporting documents can include hazard specific aerial photographs, facility maps, checklists, resource inventories, and summaries of critical information. Supplemental response plans may include, but are not limited to:

  • Assessment and control of the hazard information
  • Identification of unique prevention and preparedness of critical infrastructure/key resources
  • Initial protective actions
  • Communications procedures and warning systems
  • Implementation of protective actions
  • Identification of short-term stabilization actions
  • Implementation of recovery actions

Below are examples of potential supplemental response plans. Theses plans should be aligned with site-specific company facilities and personnel details.

  • Hurricane Plans:  Identifies response procedures and specific pre and post hurricane responsibilities according to landfall prediction timeline. May require providing evacuation route maps or shelter in place areas. Evacuation routes and scope of evacuation may change depending on the location of the facility, potential threats, or forecast.
  • Fire Pre Plans: Addresses specific information necessary to effectively fight a fire and limit exposures. Chemical and hazardous details in regards to particular buildings, tanks, and process units, and foam and water requirements should be included in fire pre plans.
  • Pandemic Plans: Documents procedures and methods necessary to maintain and restore operations of critical business processes in the event of a pandemic outbreak among the local population and workforce.
  • Additional Natural Disasters: Natural hazards tend to occur repeatedly in the same geographical locations because they are related to weather patterns or physical characteristics of an area. Depending on your specific risks, supplemental plans may be developed for one or more of the following:
    • Floods
    • Tornadoes
    • Thunderstorms and Lightning
    • Winter Storms and Extreme Cold
    • Extreme Heat
    • Earthquakes
    • Volcanoes
    • Landslide and Debris Flow (Mudslide)
    • Tsunamis
    • Wildfires

The planning development stage must include the identification of potential site specific hazards, and the critical responses necessary to respond to those hazards. To ensure consistency, it is a best practice for hazard-specific plans to follow the same layout and organizational format as the main response plan. This allows for familiarity and continuity, which enables the information to be identified and disseminated in a timely manner. Best practices also dictate that plans be developed during normal operational conditions, prior to any threatened outbreak. Training on the specific response plans allows for a complete understanding of assigned responsibilities and processes if an actual incident were to occur.

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

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Tags: Fire Pre Plans, Event Preparedness, Extreme Weather, Hurricane Preparedness, Flood Preparedness, Emergency Action Plan

Top Flood Emergency Response Plan Tips

Posted on Mon, Apr 01, 2013

Spring brings warmer weather and longer days, but it also brings a variety of weather conditions that can result in heavy rains and flooding. Floods are one of the most common hazards across the United States. They can develop slowly over a few hours or days, leaving ample time to prepare and implement established flood procedures. However, flash floods can develop within minutes from intense rainfall, tropical storms and their remnants, or dam failures several miles upstream from a facility. Facilities must have an established and exercised flood emergency response plan in order to minimize the potential impact on life, the environment, and business operations.

The National Weather Service offers real time river observations data across the United States. Monitoring water levels allows companies to determine the likelihood of flooding resulting from local conditions, and enables prompt and accurate response decisions. In addition, offers a variety of assessment tools, including a free hypothetical flood risk scenarios guide that can assist companies to better protect against financial losses due to flooding. Developing a flood emergency plan can prepare employees and facilities before, during, and after a flood to minimize health and safety impacts.

The following flood planning tips can be implemented to minimize risks to your business or industrial facility:

Flood Fatalities - TRP Corp

  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 on 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.
         Flash flood watch:  flooding is possible
         Flash flood warning: flooding is occurring or is imminent
  8. If flooding is probable, request that gas and electric services are turned off.
  9. Communicate imminent flood status updates to supervisory personnel.
  10. Deploy personnel so that they will be in position to take emergency actions, such as shutdown, isolation, or containment in the event of emergency.
  11. Implement developed data backup procedures.
  12. If applicable, identify, contract, and communicate with water damage specialist(s).
  13. Ensure clean-up equipment is available, adequate, and ample. If clean up 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. Evaluate the accessibility of necessary equipment (such as valves, storage sheds, regulators, relief sets, etc.). Mitigate accessibility, if possible.
  15. Consider obtaining portable pumps and hoses from local suppliers.
  16. Unplug all electrical devices.
  17. If applicable, determine if flooding can expose or undermine pipelines as a result of erosion or scouring.
  18. If applicable, coordinate with emergency and spill responders on pipeline location(s) and condition, and provide maps and other relevant information to them.
  19. If applicable, advise the State Pipeline Safety Office (for intrastate lines), or RSPA'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.
  20. Conduct a post-incident review and identify mitigation opportunities to prevent future flooding impacts.

Download this free 9-Step sample Emergency Response Procedures Flow Chart.

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Tags: NOAA, Business Continuity, Flood Preparedness, Workplace Safety, Business Disruption

Geographical Risks and Business Continuity

Posted on Thu, Dec 06, 2012

Despite a company’s location, natural hazards are a risk to business continuity. Natural hazards have a tendency to be location specific. However, images of the devastation left behind by these events are widespread. Unfortunately, many companies and their employees believe such disasters will not happen to them and fail to plan for plausible business disruption. 

The CMI 2012 Business Continuity Management Survey detailing Business Continuity efforts stated that 54% of companies surveyed that don’t have  business continuity plans stated their reasoning that they experience disruptions. This statistic is not uncommon. However, every year, rivers overflow their banks, high winds break treetops and tear away roofs, and power outages leave entire areas in the dark.

Despite the likelihood of a business disrupting natural disaster, many companies do not implement a Business Continuity Plan. Earthquakes and hurricanes are persistent and ingrained in location-specific cultures. Changing weather patterns, unprecedented seismic activity, strong winds and tropical rainfall impact many communities. Yet, 50% of all companies do not practice continuity planning.

Threats from extreme weather, wildfires, and flooding can affect any business in any location.  The below graphic from the Institute for Business and Home Safety demonstrates the potential risks of naturally occurring events across the United States.

These natural events can result in the loss or temporary disruption of key business resources including:

  • Facilities or Workspace
  • Infrastructure or IT Applications/Systems
  • People
  • Supply Chain

While natural weather events are not avoidable, companies may limit damage, loss, or prolonged interruption to key business resources with mitigation measures and business continuity planning. A detailed company identification and evaluation of critical business processes should be performed as an integral part of a business continuity plan.

A “bare bones” evaluation should list the minimum criteria necessary to keep a business in operation. Subsequent continuity plans should include procedures for the prevention of loss or restoration of operations.  Necessary resources for business continuity may include:

  • Alternate workplace location(s)
  • Necessary equipment
  • Critical software
  • Client records
  • Off-site storage
  • Key vendors lists
  • Inventory and supplier requirements
  • Notification procedures for key stakeholders
  • Predefined personnel roles and responsibilities with current and alternate contact information
  • Business Continuity Team notification and activation procedures
  • Staff relocation requirements, including name, department, title, function code, home address, type of PC (PC or Laptop), number of adults and children in immediate family, pets /other, relocation priority, recovery location or facility, relocation seat number/room assignment, alternate employees, and special needs

A business continuity effort for an impending or existing natural event should incorporate the following four phases into the plan:

  1. Initial Response: This phase covers initial response to an active or potential business interruption and immediate efforts to minimize downtime.
  2. Relocation:  Mobilization of resources and relocation of equipment and personnel to alternate facilities or redundant sites may become necessary if forecasted or current conditions dictate. The relocation phase ensures that the recovery phase can be fully implemented to sustain minimum service levels defined for each critical process. This stage may include “Work from Home” and “Alternate Facility” relocation strategies.
  3. Recovery:  The time after personnel and equipment have been relocated to an alternate site to before primary facilities have been restored or permanent alternate facilities have been secured. This phase incorporates the processes and procedures necessary to recover lost or interrupted resources.
  4. Restoration:  Personnel are able to return to restored facilities, or permanent alternate facilities, and critical resources are in full operational status.

A business continuity natural disaster event may be initiated from a single contained incident that affects one facility, or a large-scale incident that affects an entire region. Regardless of the incident, business restoration can be accelerated if communication processes and continuity of operations plans have been developed, tested, and properly implemented.

For a sample Emergency Response Checklist, download our helpful and informative guide.

Tags: Climate Change, Fire Preparedness, Extreme Weather, Business Continuity Plan, Hurricane Preparedness, Flood Preparedness, Business Disruption, Tornado Preparedness, BCM

Disaster Response Planning Guidelines in Emergency Management

Posted on Thu, Oct 04, 2012

Disasters, whether natural or man made, can result in a serious disruption to company operations. They typically involve widespread human, material, economic, or environmental impacts, which can exceed response capabilities for company facilities and offices. Planned response actions that incorporate qualified and trained internal and external responders are key to ensuring that both short-term and longer-term needs are addressed.

Although specific vulnerabilities to disasters vary, no company or facility is immune to the effects of a disaster. There are four main types of disasters:

  • Natural disasters: These include, but are not limited to, floods, hurricanes, tornadoes, earthquakes, tsunamis and volcanic eruptions that have immediate impacts on communities and local companies.
  • Environmental emergencies:  These include technological or industrial accidents, usually involving hazardous materials, and occur where these materials are produced, used or transported. Large forest fires are generally included in this definition because they tend to be caused by humans.
  • Facility emergencies: These involve an authoritarian collapse and/or attacks on an installation. Complex emergencies include conflict situations, terrorism, and/or war.
  • Pandemic emergencies:  These involve a sudden onset of a contagious disease that affects public health, but can escalate to disrupt services and business operations. Effects may include economic and social costs.


Disaster Response Staging Area

A disaster scenario typically requires external resources beyond the scope of a company’s capabilities. In a major response, establishing a staging area (or areas) may be required to support an increase in activity and ongoing response operations.

In selecting a suitable staging area, the following criteria should be considered:

  • Accessibility to impacted areas
  • Location safety
  • Proximity to secure parking, airports, docks, pier, or boat launches
  • Accessibility to large trucks and trailers that may be used to transfer equipment
  • Accessibility to basic needs
  • Accessibility to necessary utilities

disaster_response_planning.jpgIn addition, the staging area should:

  • Be in a large open area in order to provide potential equipment storage and increased responder population
  • Not interfere with equipment loading and offloading operations
  • Have a dock/pier on site for deploying equipment if emergency is near shore or offshore
  • Have moorage available for vessels to aid the loading/offloading of personnel, as necessary


Disaster Plan Considerations

Other key considerations to be included in a disaster management plan include:

  • Communication Plan: Should identify telephone numbers and radio frequencies used by responders. This may also involve activation of multiple types of communications equipment and coordination among multiple responding agencies and contractors.
  • Public Affairs Plan: Contains guidelines for dealing with the media during an emergency. The Incident Commander will play a key role in providing the initial public assessment and taking the first steps to provide situational understanding.
  • Site Security Measures:  The potential for increased public attention created towards a disaster site may require additional security measures to be implemented. Several measures should be planned in advance to prepare security personnel for possible security events that may occur.
  • Waste Management Procedures:  Disposal plans should be in place to manage increased waste from the initial disaster, as well as from the increased activity surrounding the disaster. Waste management needs may be overlooked in the emergency phase of a response, which could result in delays and interruption of cleanup operations.
  • Demobilization Plan: These guidelines provide an organized set of procedures to help facilitate and expedite a return to normal operating conditions, and help to minimize costs by standing down response resources in a timely manner.


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Tags: Facility Management, Emergency Management Program, Event Preparedness, Hurricane Preparedness, Flood Preparedness, Disaster Recovery, Disaster Response, Workplace Safety

Multiple Agency Coordination in Emergency Response

Posted on Mon, Jun 25, 2012

Response planning coordination between private and public entities improves emergency management capabilities. When establishing, updating, exercising, and implementing response plans, partnering with associated response participants will result in a more successful and streamlined implementation of emergency plans.

In a 2010 press release, FEMA Administrator Craig Fugate stated, "There's no way government can solve the challenges of a disaster with a government-centric approach. It takes the whole team. And the private sector provides the bulk of the services every day in the community.”

When a disaster strikes at a company facility, a response typically involves outside response groups and corresponding government agencies. Through collaborative planning, the following multifaceted concepts can be incorporated in a coordinated emergency management program:

  • Proven and successful response models and best practices
  • Effective tools and equipment from a variety of sources
  • Training and exercises

The goal of multi-agency coordination is to prioritize and organize the need for critical resources, thereby assisting the coordination of the response operations. A coordinated effort should consist of a combination of agreed upon elements including:

  • Personnel
  • Procedures
  • Protocols
  • Business practices
  • Communications systems and methods

The most commonly used elements in a coordinated response are Emergency Operation Centers (EOCs) and Multiagency Coordination Systems (MACS). An EOC is a central command facility, activated to support response operations in the event of an incident.

According to FEMA, MAC Groups are typically comprised of administrators/executives, or their appointed representatives. MAC Groups may also be known as multi-agency committees or emergency management committees.  There are seven common functions that MACS will generally perform during an incident:

  1. Assessment
  2. Prioritization
  3. Acquisition and allocation of critical resources
  4. Supporting relevant incident management policies and interagency activities
  5. Coordination with other MACS
  6. Coordination with elected and appointed officials
  7. Coordination of information

 For a sample Emergency Response Checklist, download our helpful and informative guide.

Tags: Emergency Response, Emergency Preparedness, Crisis Management, Training and Exercises, Regulatory Compliance, Hurricane Preparedness, Flood Preparedness, Disaster Response

Crisis Management Plan Reviews Identify Deficiencies

Posted on Mon, Mar 19, 2012

An emergency plan review can reveal shortcomings in preparation, response coordination, resources capabilities, and pinpoint inept response equipment. New York Governor Andrew M. Cuomo recently unveiled numerous disaster and emergency response initiatives stemming from a review of the handling of 2011’s Hurricane Irene and Tropical Storm Lee. The Governor-ordered review identified both strengths and weaknesses in the state's emergency response capabilities. As a result, the state initiatives include:

  1. Establishing five Regional Disaster Logistics Centers to serve as staging areas and store emergency equipment
  2. Launching a state agency emergency network to coordinate disaster response equipment
  3. Establishing Regional Rapid Response and Incident Management Teams to expedite deployment and coordinate with local governments
  4. Creating a statewide network of emergency responders
  5. Hosting a statewide Emergency Preparedness conference
  6. Selling unnecessary and outdated equipment

A thorough review of internal plans and policies can identify deficiencies and initiate the counteractions to correct these deficiencies. Some areas to include in a planning hazard analysis and/or procedural review include:

• Evacuation plan
• Fire protection plan
• Safety and health program
• Environmental policies
• Security procedures
• Insurance programs
• Finance and emergency purchasing procedures
• Plant closing policy
• Employee manuals regarding emergency policies
• Hazardous materials plan
• Process safety assessment
• Risk management plan
• Capital improvement program
• Mutual aid agreements

For a sample Emergency Response Checklist, download our helpful and informative guide.

Tags: Emergency Response, Emergency Preparedness, Crisis Management, Training and Exercises, Emergency Management Program, Flood Preparedness