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Key Facility Response Plan Tips for Spill Response Requirements

Posted on Thu, May 25, 2017

The environmental, health and safety landscape is riddled with stories of injuries, accidents, and emergencies. Some stories become headline news and others may be buried in the stacks of safety reports. Yet any incident, large or small, can impact your employees, your facilities, the surrounding environment, and your financial bottom line. While the intensity of events may vary, comprehensive, compliant, and functional response plans for each facility must be developed and maintained to address a broad scope of probable emergency and crisis situations.

Companies have an ethical and legal obligation to protect their employees while on the job. However, a response plan is only as effective as the accuracy of its information, potential emergency or crisis scenarios, and the level of responder comprehension. For facilities that store and/or utilize hazardous materials, the obligation to create a top-notch facility response plan is even greater.

The Facility Response Plan

A Facility Response Plan, which can serve as both a planning and response-guiding action document, should be easily accessible. Companies should confirm that regulatory compliance, inherent site-specific safety issues, response efforts, and human resource factors are addressed within each of their site plans. Depending on operations, a Facility Response Plan may consist of:

  • Facility information, including its name, type, location, owner, operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and analysis of potential spill hazards and previous spills
  • Discussion of small, medium, and worst-case discharge scenarios and response actions
  • Description of discharge detection procedures and equipment
  • Detailed implementation plan for response, containment, and disposal
  • Description and records of self-inspections, drills and exercises, and response training
  • Diagrams of facility site plan, drainage, and evacuation plan
  • Security (ex: fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)

As personnel responsibilities, facility or operational specifics change, response plans must change accordingly. At a minimum, cyclical plan maintenance is essential to capture multiple moving parts that impact an emergency management program. If a facility has a high-risk potential for a specific scenario or operations utilize hazardous materials, supplemental response plans, such as a fire pre-plan or business continuity plan, should be added to the overall emergency management program.

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Small, Medium and Worst-Case

It is essential that any company that transports, stores or handles hazardous materials ensure spills are properly cleaned up to minimize environmental impacts and  workers are not injured. The Environment Protection Agency (EPA) states that site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. Discharges are categorized as follows:

  • Small discharge: up to 2,100 gallons spilled
  • Medium: 2,100 to 36,000 gallons spilled, or 10% of the largest tank (whichever is less)
  • Worst Case Discharge: Volume of the largest tank over 36,000 gallons

The source of a small, medium, and worst-case discharge may stem from various facility operations and corresponding equipment components. If the worst-case discharge falls within one of the specified ranges for small or medium discharges, a smaller facility may only need to plan for that level of response. Potential discharge scenarios can be derived from human error, equipment malfunction, third party intervention, or severe weather. Typical site components relating to discharge scenarios include, but are not limited:

  • transfer hose failure
  • improper or faulty hose seals
  • valve failure
  • misaligned piping connection or seal failure
  • pump seal failure or overfill
  • tank overfill or leak
  • catastrophic failure of largest tank
Most spill scenarios are small and are unlikely to travel off site. These spills would likely be contained in specified areas or by specialized equipment. However, if the spill scenario could potentially result in oil traveling off site, its migration pattern, potential traveling distance, and specifically identified locations should be detailed.


Any spill response, despite the size of the spill, should incorporate the company defined preparedness structure and procedures. Despite the voluminous details and the nature of a spill, all employees and responders should demonstrate an understanding and application of company policies and agency requirements through an established training and exercise cycle.

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Tags: Facility Response Plan, Oil Spill

The Necessary Details for Pipeline Tactical Response Planning

Posted on Thu, Sep 03, 2015

Pipelines play a key role in the sustainability of our economy. Pipelines deliver millions of gallons of crude oil and petroleum products across every state so that communities can commute and travel, maintain homes and businesses, utilize modern communications systems, and manufacture thousands of products that are used in daily life.

In 2013, 192,396 miles of pipelines transported nearly 15 billion barrels of crude oil and petroleum products. Controversies develop because these vast pipelines often share common acreage with waterways, residential neighborhoods, businesses, schools, and municipalities. Despite strict regulations, pipeline incidents do occur. Because these common geographic boundaries exist, it is imperative that tactical spill response plans contain site specific details that are unique to the location and landscape.

Pipelines present a distinct risk since it is not practical for them to utilize secondary containment. When a spill occurs, impacts can be costly to the environment, surrounding communities, and the pipeline company. If a worst-case discharge were to occur, the impacts can be devastating on multiple fronts. However, the faster the spill can be contained, the less impacts it creates.

Spill prevention should be the primary objective. However, by creating location-specific tactical response plans, pipeline companies and operators can identify and compensate for key geographical challenges that may delay responding to and managing a pipeline emergency. The planning process should involve a detailed site examination and anticipated response analysis, as well as an understanding of the characteristics of the pipeline contents.

The primary objectives of tactical response plans are to:

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

Tactical spill plans should include location-specific details that include, but are not limited to:

  1. Photographs of response locations
  2. Maps
  3. Latitude and Longitude
  4. Property owner information
  5. Driving directions to the site from main roads
  6. Description of potential staging area(s)
  7. Specific response tactics for the site location
  8. Description of site and applicable waterways
  9. Site access specifications
  10. Security requirements
  11. Waterway flow rates
  12. Any critical response information that may be informative to responders
  13. Recommended equipment and personnel to implement response strategy
  14. Sensitive environments

Pipeline spills within waterways increase the complexity of a response. They require a higher level of coordination and communication in effort to minimize impending impacts. As a result, companies must maintain optimal pipeline spill response standards to address challenges. Those challenges include, but are not limited to:

  • Response time must be minimal due to spill flow rate and travel distances
  • Potential substantial equipment deployment
  • Waterway access points
  • Coordination and cooperation efforts with private landowners
  • May require extensive geographic surveys
  • Associated increased costs of deployment
  • Consequential costs associated with long-term cleanup activities 
  • Extensive damage to marine and wildlife habitats, fishing, and/or tourism industries
  • Potential lawsuits

Analyzing possible spill trajectories through topographical features, wind speeds, and water flow rates allows planners to identify which areas are most likely to be impacted by a spill. Once these resources have been identified, proper response techniques and procedures specific to the sensitive areas must be incorporated into the response plan. Types of sensitive areas to evaluate during the planning phase include, but are not limited to:

Ecological: Examples of sensitive species include shore birds and other water fowl, marine life, commercially important wildlife, and species with limited distribution or populations. Sensitive habitats range from protected bays with marshes and tidal flats to open coast areas used as marine mammal or bird breeding sites.

Cultural: Areas of direct importance to humans including, but not limited to native lands, historical landmarks, waterfront parks, and recreational areas.

Economical: Populated areas that are highly valued because of their ability to generate income. Areas include tourist sites, real estate developments, urban developments, marinas, parks, and other locations.

Specific sensitive resources: Specific resources that are only available at that particular location, such as specialized suppliers, water sources, transportation systems, food sources.

  

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Tags: Tactical Response Planning, Pipeline, Oil Spill

FRP Compliance for Crude Oil Storage Facilities

Posted on Thu, Aug 27, 2015

According to an August 11th report by the U.S. Energy Information Administration, crude oil storage fell slightly from 1,150.4 million barrels on July 31, 2015 to 1,148.7 million barrels on August 7, 2015. Although crude levels continue to vary, facilities that are bound by the EPA Facility Response Plan (FRP) requirement must ensure compliance. This is especially true during mergers, acquisitions, and when new storage facilities come online. In response to the potential growth opportunities, numerous U.S. companies are expanding storage capabilities.

  • Magellan Midstream Partners and LBC Tank Terminals have a $95 million crude oil storage and transportation project along Houston’s Gulf Coast. The two companies said they will build about 700,000 barrels of new crude oil storage and distribution infrastructure near Seabrook, Texas, about 30 miles southeast of Houston. The new storage will be connected into the area’s existing oil transportation infrastructure by a planned 18-inch diameter pipeline.
  • The Louisiana Offshore Oil Port is adding three new above-ground oil tanks and 1.1 million barrels of storage capacity to its Clovelly Hub, one of the nation's largest oil trading and distribution centers. It is expected to be completed by late summer 2016.
  • Florida Fuel Connection is investing $75 million to build a petroleum terminal and rail transportation facility near the Mississippi River.

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Because a single oil spill can have a significant or catastrophic impact, it is imperative for emergency managers to evaluate response processes for best practices and maintain the most current FRP possible. Storage facilities that meet EPA capacity thresholds and could reasonably cause "substantial harm" to the environment by discharging oil into or on navigable waters, must prepare and submit FRPs. Facilities that could cause "significant and substantial harm" are required to have their plans approved by an EPA Regional Administrator (RA).

Substantial Harm
According to the FRP rule, a facility may pose "substantial harm" if:

  1. The site has a total oil storage capacity greater than or equal to 42,000 gallons and it transfers oil over water to/from vessels; or
  2. The site has a total oil storage capacity greater than or equal to 1 million gallons and meets one of the following conditions:
  • Does not have sufficient secondary containment for each aboveground storage area.
  • Is located at a distance such that a discharge from the facility could cause "injury" to fish, wildlife, and sensitive environments.
  • Is located at a distance such that a discharge from the facility would shut down a public drinking water intake.
  • Has had a reportable discharge greater than or equal to 10,000 gallons within the past five years.

If the facility meets the criteria, an FRP is required to be prepared and submitted to the regional EPA office. Once the FRP is submitted to the EPA, the regional administrator (RA) will review and determine if the facility should be classified as a significant and substantial harm facility. If the regional administrator determines that the facility could cause significant and substantial harm, the FRP requires approval by the RA.

Significant and Substantial Harm
An RA determines if a facility could cause significant and substantial harm to the environment by discharging oil into or on the navigable waters and adjoining shorelines. This is determined by factors similar to the substantial harm criteria, as well as:

  • The age of tanks;
  • Type of transfer operations;
  • Oil storage capacity;
  • Lack of secondary containment;
  • Proximity to fish, wildlife, and sensitive environments or drinking-water intakes;
  • Spill history and frequency of past discharges; or
  • Other information, including local impacts on public health.

The landscape of growth opportunities may be changing as the Department of Commerce recently announced a partial lift to the 1975 Energy Policy and Conservation Act ban allowing U.S. companies to export domestically produced crude oil to Mexico. However, despite the change or volatility of the oil industry, companies must ensure regulatory compliance remains across their enterprise.

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Tags: Facility Response Plan, Oil Spill

High Petroleum Supplies Advocate Oil Spill Response Plan Reviews

Posted on Thu, Apr 16, 2015

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

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

The primary objectives of oil spill response plans are to:

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

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

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

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Tags: Response Plans, Oil Spill, Disaster Response

Oil Spill and Contingency Planning in an Industry Downturn

Posted on Thu, Apr 09, 2015

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

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

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

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

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

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

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

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

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

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

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

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

Enterprise-Wide OPA 90 Plans: Standardize and Comply

Posted on Thu, Feb 12, 2015

Amidst the challenges of sustaining profitable operations, oil and gas companies must ensure that employees and work conditions are compliant with various regulations in order to manage innate risks, operational hazards, and minimize potential detrimental impacts. As a result, regulatory agencies require response plans and response exercises that adequately reflect the current operations and emergency response capabilities.

In the wake of the Exxon Valdez oil spill, emergency preparedness requirements were reassessed and the Oil Pollution Act of 1990 (OPA 90) was created to instill comprehensive prevention, response, liability, and compensation policies for vessel and facilities that could cause oil pollution to U.S. navigable waters. The law requires that regulated facilities and vessels develop and submit oil spill plans for approval. For facilities adjacent or nearby shorelines, OPA 90 requires compliant site-specific Facility Response Plans (FRP).

Yet, because of the rapid decline in the price of oil, emergency managers are, once again, being asked to “do more with less”. Reduced staffing levels and heightened personnel responsibilities due to budget constraints create various enterprise-wide challenges for environment, health and safety professionals. The mandate of managing and maintaining multiple emergency response plans and ensuring regulatory compliance and site specific accuracy can be a continual uphill battle.

Oil spill responses can be challenging dynamic scenarios with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. FRPs must provide procedures to quickly, safely, and effectively respond to these potential spills to prevent further damaging effects. This is challenging for a company that has multiple facilities that fall under the OPA 90 compliance requirements.

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FRPs require site-specific information and response details including, but not limited to:

  • Emergency Response Action Plans, which serves as both a planning and action document
  • Facility information, including  name, type, location, owner, and operator information
  • Emergency notification, equipment, personnel, and evacuation information
  • Identification and analysis of potential spill hazards and spill history
  • Discussion of small, medium, and worst-case discharge scenarios and response actions
  • Description of discharge detection procedures and equipment
  • Detailed implementation plan for response, containment, and disposal
  • Description and records of self-inspections, drills and exercises, and response training
  • Diagrams of facility site plan, drainage, and evacuation plan
  • Security (e.g., fences, lighting, alarms, guards, emergency cut-off valves and locks, etc.)
  • Response plan cover sheet

An enterprise-wide response planning system can remove the uncertainties and challenges associated with managing multiple, regulation-driven response plans. A single web-based system can streamline the update process and simplify plan reviews, ensuring a consistent path toward compliance.  For companies with various facilities, advanced systems offer budget-friendly, advantageous response plan management opportunities, improve the overall planning system framework, and provide greater  accuracy of site-specific emergency response plans.

In addition to simplifying the administrative duties of managing multiple response plans, an enterprise-wide response planning system should:

  • Support the ability to execute company approved response strategies across multiple locations/facilities
  • Easily incorporate company growth and facility acquisitions
  • Enable site-specific details while not compromising company directives
  • Facilitate the ability to update corporate planning elements across many locations,  without compromising site-specific details and response challenges
  • Be easily updated with minimal dedicated staff
  • Become an easily accessible, yet secured, shared tool for internal and external responders
  • Allow for streamlined regulatory compliance audits
  • Automate and optimize response planning, training, and exercise activities
  • Reduce non-compliance issues on a company-wide scale
  • Automate regulatory governance with electronic submissions

An enterprise-wide response planning system enables EHS departments to augment dwindling budgets, spend more time on preparedness planning, and maximize response efforts. The result is a more streamlined company emergency management program that reduces administrative efforts, non-compliance fines, and ineffective responses.

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Tags: Facility Response Plan, Emergency Preparedness, OPA 90, Oil Spill

Make 2015 "The Year of Response Planning and Preparedness"!

Posted on Thu, Jan 08, 2015

While it is more cost efficient and less complicated to learn from other's response experiences and emergency management mistakes, every emergency scenario, exercise, or training endeavor can be used to improve the outcome of the next response. As we begin 2015, facility and emergency managers should draw from personal experiences, staff knowledge, and industry-wide lessons learned to improve their preparedness and response program.

The following discussion points, while not all-inclusive, can be used to spur emergency management program improvements and response planning reformations for 2015:

Compliance

  • What agencies and new or impending regulations apply to my location(s)?
  • Have budgets been allocated for necessary compliance mitigation resolutions?
  • If applicable, have Globally Harmonized System (GHS) Safety Data Sheets (SDS) been updated and have their properties been included in the planning process?
  • Has an inspection taken place, and if so, have non-compliant issues been mitigated?
  • Will an internal compliance audit(s) be conducted?
  • Is personnel training up-to-date and compliant with site-specific requirements?
  • Are required exercises scheduled?

Risk Assessment

  • What are the new high-risk, medium-risk, and low risk-activities or circumstances, and are how will these scenarios relate to planning?
  • Can high-risk tasks or conditions be mitigated with the current budget? (The higher the probability and severity of risk, the higher the emphasis should be on corrective actions)
  • Are there additional environmentally sensitive areas that need to be addressed in the response plan?
  • Does the risk assessment utilize realistic scenarios to define potential spill volumes and downstream locations?
  • How will employees be made aware of hazards associated with specific workplace process, materials, or location(s)?

Supply Chain

  • When will response equipment needs be re-evaluated and defined?
  • Are there new technologies or equipment that will better suit your program's equipment needs?
  • Will current vendors have predefined supplies or equipment available in the event of an operational disruption or emergency scenario, or do new suppliers need to be evaluated?
  • Are processes in place to monitor internal and external supply chains and their response time?
  • Is additional or alternate external spill response support necessary and available?
  • How would a spill affect both internal and external resources?
  • Are back up suppliers identified, and when will their availability be confirmed?

Training

  • Are current personnel appropriately trained for their allocated roles?
  • Are new employees being trained effectively?
  • Do new training measures need to be implemented?
  • Will training comprehension be tested with realistic exercise scenarios?
  • Is the response management team structure clear and able to be communicated?
  • Will external responders included in plan preparations and exercises receive a copy of the current plan?
  • Have post exercise review mitigation measures been applied to current training and preparedness measures? If not, when will these tasks be completed?
  • Should training include any new resource tracking documentation methods, software, or amended response communication actions?

Response Elements

  • If an incident were to occur today, would your response plan minimize impacts and be a guide for an effective and coordinated response effort?
  • Is a process established for individual responders to verify their contact information to allow for timely responses? If not, can verification process improvements be made to ensure accuracy?
  • Are clear initial response action procedures in place to notify, assess, and initiate a response?
  • Can approved stakeholders easily access response plans? Have you researched innovative technology that allows for improved plan access?
  • Have response times and limitations been confirmed? Have they changed from the previous plan revision?
  • Does the current response plan address necessary updates, such as site construction, personnel changes, and supply chain changes?
  • Have internal and external communication methods been upgraded? If so, have these changes been addressed in the plan.
  • Are new or additional communications backup systems available and described in the plan?
  • Are there new staff roles, personnel, or modified internal or external responsibilities that need to be specified in the plan, and communicated to responders?
  • Are there alternate strategies and response procedures that need to be included in the plan?
  • Are updated processes and procedures identified in the plans to assess and monitor size, shape, type, location, and movement of a spill or release?
  • If applicable, have tactical response details been included in the planning process for incidents that expand beyond the confines of the facility? Are there any changes that need to be incorporated?
  • Do trajectory maps and estimates mimic local observations and historical tendencies?
  • Are sensitive sites prioritized for protection?
  • Do plans include specific criteria for provisional tiered responses?
  • Are waste management and demobilization processes communicated?

Documentation

  • Are sufficient processes established for updating planning information prior to an emergency and during a response?
  • Have plot plans and area mapping been integrated with the latest GIS data and knowledge?
  • Are appropriate agreement documentation, such as contracts and memorandums of understanding (MOUs), updated and in place? Are there new MOUs or contracts that need to be established or finalized?
  • Do stakeholders have a copy of your most up-to-date plans?
  • Are training and exercise records, and applicable regulatory required documentation up-to-date and accessible to auditors?
  • Are necessary Incident Command (ICS) and company-specific forms readily available for documentation?

By analyzing the past, monitoring the present, and evaluating the “potentials” of 2015, companies can reinforce their commitment to emergency management while establishing a culture of preparedness. Executing plan enhancements and reinforcing preparedness across an enterprise strengthens a company’s resolve, ultimately creating a more resilient organization.

 

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Tags: Emergency Management, Response Plans, Oil Spill, Event Preparedness

Maintaining Regulatory Compliance in an Oil Industry Acquisition

Posted on Thu, Oct 30, 2014

Oil companies are not stagnant entities.  Every year, the industry experiences acquisitions, mergers, and systemic transformations. The dynamic nature of the energy sector requires environmental, health, and safety departments, as well as facility managers, to periodically review and adjust their approach to emergency management and regulatory compliance.

Whether a facility is located in the U.S. or abroad, ensuring compliance, employee safety, and an effective response requires a streamlined, coordinated, and exercised response plan. All response plans, including SPCC's and facility response plans, within the corporate enterprise should address site-specific facility details, applicable and tested response processes, and standardized company-wide best practices while maintaining location-specific regulatory compliance. A customizable response plan template can enable the development of a streamlined, site-specific preparedness program that consistently delivers company-standard guidelines and practices while providing a medium for rapid assimilation of merging or acquired facilities.

Industrial operations are required by law to institute site-specific emergency response plans, and train employees according to their response roles and pertinent response methods. Acquiring one or more new facilities typically presents challenges that generic or static response plan templates do not account for. Failure to incorporate site-specific details may result in incomplete, ineffective, and costly non-compliant plans.  Companies with multi-facility operations should utilize a customizable template with the ability to inject distinct facility information and hazards for each operation, pre-approved company best practices, as well as applicable local, state, and federal requirements.

Integrating response plans under one centralized format enables consolidated preparedness and response objectives. Acquired facilities must be absorbed into the company-wide emergency management program. If response plans exist, companies should perform a gap analysis or audit to identify any procedural, company policy, or compliance deficiencies that may be applicable to the new facilities. It is critical to define preparedness objectives, response roles, and responsibilities in order to eliminate ambiguity and confusion.  Responsible parties must apply new data, site assessments, and validated information into cohesive, compliant, and effective response plans for the new enterprise.

New or outlying facilities may present preparedness and response challenges. Cultural differences, infrastructure challenges, response equipment availability, minimal response knowledge and training, and security priorities may require heighten preparedness priorities and planning efforts. As a result, new locations may be particularly vulnerable to crisis or emergency response situations.

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The following fundamental preparedness and response questions may assist companies in absorbing facilities into an established 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 will be in charge of the response and how will it be organized?

  • Identify Incident Commander
  • Create Emergency Management Team organizational chart
  • Identify Emergency Management Team activation measures
  • Create Emergency Management Team roles and responsibilities checklists

Does the facility have a current response plan to draw from?

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

What threats affect the new facility and its employees?

  • Perform a detailed hazard and risk analysis
  • Verify or create response procedures for each identified threat
  • Identify process for incident documentation
  • Utilize appropriate ICS Forms
  • Identify current and necessary equipment necessary for response

What regulatory requirements apply to this facility?

  • Evaluate operations for compliance
  • Identify required training and confirm documentation
  • Review submitted response plan information
  • Perform a compliance audit

If necessary, what organization will conduct additional response duties?

  • 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 the emergency be reported and response initiated?

  • Create site-specific notification procedures
  • Identify site-specific alarms that signal employee evacuation or shelter in place.
  • Test alarms to confirm they are in proper working condition
  • Ensure employees are trained in alarm procedures and immediate response actions per designated roles and responsibilities
  • Implement company approved emergency classification levels to associated response procedures with emergency conditions to prevent the incident from escalating

What incidents or classification level require evacuation/shelter in place

  • Establish multiple evacuation routes.
  • Does the evacuation go beyond facility borders?
  • 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 a sustained response
  • Share response plan with appropriate responders/stakeholders
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Tags: Facility Response Plan, SPCC, Oil Spill, Emergency Management Program

Crude by Rail: Cooperative Preparedness Planning and Training

Posted on Thu, Oct 23, 2014

CSX, a North American leading supplier of rail-based freight transportation, recently hosted a crude-by-rail (CBR) incident response training session at the Security and Emergency Response Training Center (SERTC) in Pueblo, Colorado. The training consisted of 40 first responders representing 12 states.  According to CSX, “The three-day training session focused on preparation for and emergency response to railroad incidents involving crude oil, and included an overview of the history of crude oil extraction, chemical and physical properties of different types of crude oil currently being transported, incident site and damage assessment, and tank car design and construction. Participants also practiced specialized response techniques and incident command scenarios during mock derailments.”

According to the Association of American Railroads’ October 4, 2014 Weekly Report, petroleum and petroleum products shipped by rail was up 12.8% from the same time frame in 2013 (1). As CBR shipments continue to increase, companies must prioritize response and safety training, as well as coordinated planning and preparedness efforts. Because a single incident can have a significant or catastrophic impact, it is imperative that pre-planning and training be incorporated with coordinated response efforts.

In May 2014, the Department of Transportation (DOT) mandated initial coordination by instituting an emergency order for railroads to communicate specific information to each State Emergency Response Commission (SERC). The notifications must provide information regarding the estimated volumes and frequencies of train traffic implicated. Rail companies that transport 1,000,000 gallons or more of Bakken crude oil must adhere to the emergency order.

Specifically, the emergency order dictated that the notifications must: 

  1. Provide a reasonable estimate of the number of trains expected to travel, per week, through each county within the state
  2. Identify and describe the petroleum crude oil expected to be transported in accordance with 49 CFR part 172, subpart C
  3. Provide all applicable emergency response information required by 49 CFR part 172, subpart G
  4. Identify the routes over which the material will be transported.

Communication and cooperative pre-incident planning provides a tool for railroad companies and response agencies to begin the collaborative process of preparedness. This endeavor should be a coordination of overall response strategies that are made part of CBR response plans, training, drills, and exercises. A derailment that includes crude may require mutual aid efforts and a clear, yet robust Incident Management System.

In order for an incident management system to be effective, specific situational checklists should be created.  Rail employees, and local incident responders must be trained in applicable emergency procedures, communications cycles, and documentation requirements.  Rail incidents should be managed through clearly identified and communicated objectives. These objectives may include, but are not limited to:

  • Establishing specific and step-by-step incident objectives
  • Developing strategies based on incident objectives
  • Developing and issuing assignments, plans, procedures, and protocols
  • Establishing specific, measurable tactics or tasks for various incident management functional activities, and directing efforts to accomplish them, in support of defined strategies
  • Documenting results to measure performance and facilitate corrective actions

Maintaining an accurate and up-to-date picture of resource utilization is a critical component of incident management and emergency response. This may be especially challenging on select high or low density rail routes.  Each real-time incident management status update should include the following information in order to clarify response status:

  • Time of update (timestamp)
  • Incident or event name
  • Elapsed time of incident from initiation
  • Name/position of responder making status updates
  • Current planning phase and/or specific status update
  • Tasks assigned, both internally and externally, and resources used or required
  • Emergency Operations Center location and contact information

Improving rail car emergency response training, reactive decision management, timeliness of an ongoing response, and swift implementation of recovery strategies can limit resulting effects of any CBR emergency situation. As the shipments of CBRl continue to increase, it is imperative that companies, in conjunction with local responders prioritize well-coordinated preparedness initiatives.

NOTE: SERTC was established in 1985 to train railroad officials to safely handle accidents involving tank cars carrying hazardous materials. Because the initial endeavors were so successful, hands-on training courses were extended to serves the public sector emergency response community, the chemical industry, government agencies, and emergency response contractors from all over the world.  

(1)   Association of American Rail Traffic Weekly Rail Traffic Report, Oct. 9, 2014.

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Tags: Response Plans, Oil Spill, Training and Exercises, Safety, Crude by Rail

Oil Spill Response Planning, Drones, and Spill Surveillance

Posted on Thu, Sep 04, 2014

Oil spill response planning and preparedness are necessary to satisfy applicable regulatory requirements, protect the environment, and ensure safety for responders and employees. Yet, all plans related to oil spills have one common thread: minimize the impacts!

Effective oil spill response plans can minimize the impacts associated with an oil spill. The objectives of these plans, regardless of type of facility, are to:

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

History has proven that a single oil spill can have significant impacts to the environment and the responsible party. Off-site spill responses and containment efforts present unique challenges compared with spills occurring within the confines of the facility or secondary containment. These migrating spills require a higher level of coordination, communication, and surveillance in an effort to minimize downstream impacts.

It is critical to identify and provide detailed information regarding area socio-economic and natural resources and vulnerabilities that may be damaged if a spill were to occur. This information should guide response personnel to make reasonable, well-informed response actions to protect public health and the environment. Detailed information of downstream vulnerabilities and applicable response procedures should be included in an oil spill or tactical response plan.

Spill surveillance should begin as soon as possible following the discovery of a release to determine the appropriate response tactics. One future option for surveillance is the use of commercial unmanned aircraft systems (UAS), or more commonly known as drones. The push for commercial use of drones is gaining momentum as affordable devices are increasing in popularity.  Currently, commercial use of drones are limited by the Federal Aviation Administration (FAA) authorization and require the operator to have certified aircraft and pilots, as well as FAA operating approval.

The FAA is responsible for establishing a plan for “safe integration” of UAS by September 30, 2015. However, some reports have indicated that the integration plan deadline will be delayed due to privacy debates and various industry specific regulations. “The FAA is still developing regulations, policies, and standards that will cover a wide variety of UAS users, and expects to publish a proposed rule for small UAS (under 55 pounds) later this year.”

A few companies have been granted the FAA’s Certificate of Waiver or Authorization for UAS allowing for the limited use of commercial drones. In July 2014, San Diego Gas & Electric (SDG&E) joined the likes of ConocoPhillips and BP with limited permission to use drones.

Until regulations, best practice protocols, and authorizations are established for the commercial use of drones, standardize surveillance guidelines and best practices can continue to enable response personnel to assess spill size, movement, and potential impact locations.  These guidelines should be outlined in an oil spill response plan.

Below are guidelines that are routinely included in spill surveillance procedures:

  • Dispatch observers to crossings downstream or down gradient to determine the spill’s maximum reach potential.
  • During surveillance, travel beyond known impacted areas to check for additional oil spill sites.
  • Clearly describe the locations where oil is observed and the areas where no oil has been seen.
  • Educate personnel that clouds, shadows, sediment, floating organic matter, submerged sandbanks, or wind-induced patterns on the water may resemble an oil slick if viewed from a distance.
  • Use surface vessels to confirm the presence of any suspected oil slicks (if safe to do so); consider directing the vessels and photographing the vessels from the air, the latter to show their position and size relative to the slick. It may be difficult to adequately observe oil on the water surface from a boat, dock, or shoreline.
  • Spill surveillance is best accomplished through the use of helicopters or small planes; helicopters are preferred due to their superior visibility and maneuverability.
  • If fixed-wing planes are to be used, high-wing types provide better visibility than low-wing types.
  • All observations should be documented in writing and with photographs and/or videotapes; include the name and phone number of the person making the observations.
  • Describe the approximate dimensions of the oil slick based on available reference points (i.e. vessel, shoreline features, facilities); use the aircraft or vessel to traverse the length and width of the slick while timing each pass; calculate the approximate size and area of the slick by multiplying speed and time.
  • Record aerial observations on detailed maps, such as topographic maps.
  • In the event of reduced visibility, such as dense fog or cloud cover, boats may have to be used to patrol the area and document the location and movements of the spill; however, this method may not be safe if the spill involves a highly flammable product.
  • Surveillance is also required during spill response operations to gauge the effectiveness of response operations; to assist in locating skimmers; and assess the spill's size, movement, and impact.
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Tags: Tactical Response Planning, Crisis Mapping, Emergency Management, Crisis Management, Oil Spill