Your Solution for SMART Response Plans

The Facility Response Plan Assessment

Posted on Thu, Aug 07, 2014

As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, certain facilities that store and use oil are required to develop, maintain, and submit an approved Facility Response Plan (FRP). These plans should address the elements and responses associated with substantial threats and worst case discharges of oil. If the Oil Pollution Act regulations are applicable to a facility, the operating company must prioritize response plan compliance in order to minimize fines, negative public perceptions, and potential government mandated shutdown of operations.

Maintaining a FRP is an ongoing process. As company operations evolve, and equipment and employees change, adjustments need to be incorporated into the FRP to ensure accuracy, compliance, and effective response capabilities. Additionally, the plan submittal processes must be observed and applied in order to eliminate the potential for fines.

This FRP assessment is designed to recognize best practices. Following the set of questions, the scoring section can assist in identifying potential necessary actions that can reduce the risk of non-compliance and/or ineffective responses.

1. Have your personally reviewed your company’s FRP within the past 12 months?

Yes _____ No_____

2. Do your employees have a clear understanding the FRP and their designated responsibilities if a worst-case scenario were to occur?

Yes _____ No_____

3. Have your external responders participated in a comprehensive review of your emergency management system or a response exercise within the last 12 months?

Yes _____ No_____

4. Does your plan identify a Qualified Individual and alternate who has full authority to obligate funds required to carry out necessary response actions and act as liaison with Federal On-Scene Coordinator?

Yes _____ No_____

5. Does your FRP identify a public relations contact or information officer who has knowledge of public affairs policies identified in your company’s FRP?

Yes _____ No_____

6. Were representatives of external resources involved in developing and testing the company’s FRP?

Yes _____ No_____

7. Does your company have adequate documentation  procedures and capabilities to document plan l changes, training, and exercises?

Yes _____ No_____

8. Is your FRP consistent with the National Contingency Plan and any Area Contingency Plan?

Yes _____ No_____

9. Have you spent more than two hours during the past six months in face-to-face discussion with your incident management team about how to improve spill response management?

Yes _____ No_____

10. Are your response procedures brief and organized in a manner that enables your employees or response teams to effectively respond to a range of incidents?

Yes _____ No_____

11. Does your FRP clearly identify discharge detection procedures and equipment?

Yes _____ No_____

12. Are your current mutual aid agreements or external responder contracts current?

Yes _____ No_____

13. Is your incident response team equipped and trained to set up incident command center?

Yes _____ No_____

14. Does your FRP include detailed disposal procedures and contractors?

Yes _____ No_____

15. Does your FRP contain alternates for each Incident Management Team position in the event that the primary contacts are unavailable?

Yes _____ No_____

16.  Do key individuals have secured, immediate access to the most up-to-day FRP without potential “version confusion”?

Yes_____No_____

Self-Assessment Scoring

To assess your emergency management program, give yourself one point for each "yes" and zero points for each “no”. Total your score and grade your risk.

13–16 points: In general, your FRP is well managed. Look back at your "no" answers and decide what you can do to mitigate this area of exposure. Be sure to monitor regulatory requirements and any operational shifts that could alter the effectiveness of your FRP. For a comprehensive understanding of the status of your plan, perform a full FRP audit by qualified in-house experts or experienced consultants.

9-12 points: You are making good progress, but there are a number of actions required to reduce your risk of non-compliance or response inefficiency. You may wish to focus your attention on areas indicated by the "no" answers. Based on the results of reviews in these areas, you can decide what further steps are necessary. An expert evaluation of your current plan with response plan professionals can minimize potential fines and maximize response efficiencies.

5-8 points: Your company may be at risk, but you have taken the first step of mitigation: awareness. This score suggest your emergency management responsibilities are being partially met, but there is significant room for improvement. A response-planning consultant with FRP experience can assist planners with site evaluations, regulatory compliance criteria, mitigation efforts, and plan substantiation.

Fewer than 5 points: Your facility, employees, operations, and reputation are at risk! Prompt action is necessary to ensure a compliant emergency management program. You need to take immediate action for regulatory compliance and to improve the ability to respond effectively to an incident. A comprehensive review of your FRP and preparedness efforts is warranted to reduce your risk.

Helpful hints:

  1. Review FRP’s on a cyclical basis. If turnover is high or operations are rapidly evolving, FRPs should be reviewed quarterly, at a minimum.
  2. Ensure training, drills, and exercises are optimized. Each training event, drill, or exercise presents the opportunity to improve response process responsibility and site-specific response procedure awareness, rendering the potential for a more effective response.
  3. Despite the added strain of publicity during a crisis, engaging with the media should be incorporated into the planning process. Ensure the facility or company has a designated point of contact for media and site personnel. Consistent, accurate messages alleviate public anxiety and provide a level of credibility. The more information that is provided, the less the media will have room for interpretation.
  4. Documentation provides historical records, keeps management informed of site practices, serves as a legal instrument, if necessary, and supports time and maintenance costs.
  5. Consider utilizing a web-based, database driven planning system. A widely accessible emergency response plan can maximize efficiency and minimize impacts of an emergency on employees, the environment, and infrastructure. Incorporating TRP’s enterprise-wide emergency management system can maximize efforts, minimize maintenance costs, and allow for a streamlined and familiar response process.

For free download on facilitating effective oil spill exercises, click on the image below:

TRP Corp Emergency Response Planning Exercises 

 

Tags: Facility Response Plan, Response Plans, EPA, Oil Spill, Training and Exercises, Facility Management, Workplace Safety

Expert Tactical Response Plan Tips for Oil and Gas Companies

Posted on Thu, Jun 05, 2014

Maintaining accurate and effective response plans requires due diligence. In the oil and gas industry, response planning for a dynamic worst-case scenario with multiple moving parts and various potential trajectories is an ongoing, yet required challenge. However, utilizing web-based, database driven, standardized tactical plan template enables emergency managers to plan for numerous potential impact zones across vastly diverse terrains with multitudes response obstacles. The hazardous nature of the material spilled, the number of responders involved, and the probable impacts requires a pre-planned, coordinated, and swift response effort. A web-based template format allows secured access for various stakeholders, despite their location, maximizing the planning effort for an effective response.  

Tactical response plans contain numerous geographical fixed response actions for the various off-site tracts in the path of an oil spill. These planning tools assist in the implementation of an overall response strategy by minimizing the potential travel distance of a spill.  The tactical planning process identifies the “how” a downstream response will be implemented at a specific location. When spills migrate off site, it is essential to have plans in place that have been developed in cooperation with those in the potential path of a spill. Communication with downstream counterparts lessens spill response anxieties and promotes company/community partnerships.

Through the planning process, information necessary to achieve a successful response is gathered at each downstream response location. The primary objectives of tactical response plans are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • 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

Because a single oil spill can have a significant or catastrophic impact on downstream environments, it is imperative for emergency managers to cyclically evaluate response processes and maintain the most up-to-date plan possible. Off-site spill responses and containment efforts present unique challenges compared with those within the confines of a specific facility or secondary containment. Downstream spills require a higher level of coordination and communication in effort to minimize impending impacts. 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
  • Consequential costs associated with long-term cleanup activities
  • Extensive damage to marine and wildlife habitats, fishing, and/or tourism industries
  • Potential lawsuits

In the event of an emergency, updated paper plans are typically not available from all downstream locations. Web-based planning system software increases accessibility options while improving efficiency, functionality, and effectiveness. A standardized, enterprise-wide, yet customizable tactical plan template provides necessary data for each response site.  The systematic tactical response plan format should consist of customary response policies and procedures, as well as detailed, site-specific data necessary for an effective response.

Web-based tactical plans can provide a responder’s perspective of specific short-term actions and details that communicate best site access, assessment tools, and response measures. Tactical spill plans should include the following:

  • Various photographs of each segment (including ground and aerial views, if possible)
  • Maps
  • Latitude and Longitude
  • Land/property owner information
  • Driving directions to the site from main roads
  • Description of potential staging area(s)
  • Specific response tactics for the site location
  • Description of site and applicable waterways
  • Site access specifications
  • Necessary security requirements
  • Waterway flow rates and composition
  • Any critical response information that may be informative to responders
  • Recommended equipment and personnel to implement response strategy
  • Other site specific pertinent issues that may hinder a response

 

Challenged with managing preparedness amongst your various facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Emergency Preparedness, Response Plans, Oil Spill, Chemical Industry

Real Time Incident Management Systems Aid Emergency Responses

Posted on Mon, Apr 14, 2014

On March 22, 2014, a barge carrying nearly 900,000 gallons of marine fuel oil collided with a ship in the Houston Ship Channel. The collision led to the spill of an estimated 168,000 gallons of the heavy oil into the channel. The spill closed a critical area marine hub, impacted the local migrating wildlife, and spread nearly 12 miles into the Gulf of Mexico.

The event highlights the importance of minimizing impacts through immediate, effective, and decisive communications and response actions. As the duration of an incident increases, it is likely that impacts will broaden. Real-time incident management is becoming more of an expected standard in today’s industrial settings. Current societal norms dictate the necessity for immediate access to crucial and timely information, especially during an emergency response.

A real-time incident management system (IMS) allows for real-time transmission of incident details, including location, severity, impact, and status.  Because of the instantaneous communication, decisions and coordinated efforts can be tailored to an event as it evolves. A real-time system can:

  • Reduce exponential impact of incidents through timely response
  • Increase effectiveness of response
  • Track status of the incident and all aspects of the response based on each organization/departments assignment(s) and operational levels
  • Clarify necessary deployment of resources in order to prevent duplication of efforts
  • Provides a means to aggregate data into a format that enables real-time analysis and decision making to ensure the most efficient and effective emergency response
  • Provide an instantaneous method of emergency situational awareness

However, response actions must not fall victim to exaggerated miscalculations, rumors, and inaccuracies. The incident commander must ensure rapid responses and decisive actions are relevant and best suited for the site-specific scenario. In order for a real-time IMS to be effective, specific situational checklists should be created.  Responders must understand applicable emergency procedures,  status updates that need to be communicated, and in what time frame communications need to be documented.  An incident should be managed through clearly identified and communicated objectives. These objectives should include:

  • Establishing specific 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

Just as timely communication methodology is important, commonly understood terminology is essential. A multi-agency incident response requires simple and parallel language. Rapidly communicating through unfamiliar company radio codes, agency specific codes, perplexing acronyms, unanticipated text messages, or specialized jargon will disconnect and confuse responders, and/or stakeholders, possibly prolonging a response.

Maintaining an accurate and up-to-date picture of resource utilization is a critical component of incident management and emergency response.  Each real-time status update should identify the following in order to clearly communicate to those in the Incident Command System:

  • 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

Companies that are required to maintain emergency response plans for regulatory purposes should consider the use of web-based response plans that integrate with a real-time IMS. Minimizing the consequences at the site, the environment, and the responders offsets the cost of implementing a new IMS.  Improving reactive decision management, timeliness of an ongoing response, and swift implementation of recovery strategies can limit resulting effects of any emergency situation.

Be prepared!  Download TRP's free guide by clicking the image below:

Preparedness and Emergency Management - TRP Corp

Tags: Emergency Response, Emergency Preparedness, Incident Management, Oil Spill, Communication Plan, Political Instability

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

Tanks

  • 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.

Equipment

  • 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
For a free white paper on "Best Practices for Designing a Crisis Management Program", click the image below:
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Tags: Oil Spill, Regulatory Compliance, Emergency Management Program, Flood Preparedness, Disaster Response

Business Continuity and Emergency Response Planning Acronyms

Posted on Mon, Oct 21, 2013

Acronyms are a shorthand communication method used within the emergency management industry. This list of common acronyms is often used in response plans and/or business continuity plans. Those utilizing these plans should be familiar with the language.

ACP

Area Contingency Plan

API

American Petroleum Institute

BBL

Barrel

BCP

Business Continuity Plan

BLEVE

Boiling Liquid Expanding Vapor Explosion

BIA

Business Impact Analysis

BOP

Blowout Preventer

BPD

Barrels per Day

BSSE

Bureau of Safety and Environmental Enforcement

BST

Business Support Team

CAER

Community Awareness and Emergency Response

CFR

Code of Federal Regulations

CM

Crisis Manager

CMT

Crisis Management Team

COTP

Captain of the Port

CP

Command Post

CWA

Clean Water Act

DOM

Dock Operations Manual

DOT

Department of Transportation

DR

Disaster Recovery

DWT

Deadweight Tons

E&P

Exploration and Production

EAP

Emergency Action Plan

EMT

Emergency Management Team

EOC

Emergency Operations Center

EPA

Environmental Protection Agency

EPCRA

Emergency Planning and Community Right-to-Know Act

EPZ

Emergency Planning Zone

ERAP

Emergency Response Action Plan

ERP

Emergency Response Plan

ETA

Estimated Time of Arrival

FOG

Field Operations Guide

FOSC

Federal On-Scene Coordinator

FPP

Fire Pre-Plan

FRP

Facility Response Plan

FSC

Finance Section Chief

GOM

Gulf of Mexico

GPM

Gallons Per Minute

HAZMAT

Hazardous Materials

HAZWOPER

Hazardous Waste Operations and Emergency Response

HMIS

Hazardous Material Information System

H2S

Hydrogen Sulfide

IBRRC

International Bird Rescue Research Center

IAP

Incident Action Plan

IC

Incident Commander

ICP

Incident Command Post, Integrated Contingency Plan

ICS

Incident Command System

IDLH

Immediately Dangerous to Life and Health

IMO

International Marine Organization

IMT

Incident Management Team

IPIECA

International Petroleum Industry Environmental Conservation Association

JIC

Joint Information  Center

LEL

Lower Explosive Level

LEL

Lower Explosive Limit

LEPC

Local Emergency Planning Committee

LEPD

Local Emergency Planning District

LNG

Liquefied Natural Gas

LPG

Liquefied Petroleum Gas

LSC

Logistic Section Chief

MOU

Memorandum of Understanding

MSDS

Material Safety Data Sheet

NCP

National Contingency Plan

NGL

Natural Gas Liquid

NIMS

National Incident Management System

NIOSH

National Institute for Occupational Safety and Health

NM

Nautical Miles

NOAA

National Oceanic and Atmospheric Administration

NPDES

National Pollutant Discharge Elimination System

NRC

National Response Center

NRDA

National Resource Damage Assessment

NRS

National Response System

NRT

National Response Team

OPA 90

Oil Pollution Act of 1990

OSC

On-Scene Coordinator/Commander, Operations Section Chief

OSHA

Occupational Safety and Health Administration

OSRO

Oil Spill Removal Organization

OSRP

Oil Spill Response Plan

PE

Professional Engineer

PFD

Personal Flotation Device

PHMSA

Pipeline Hazardous Material Safety Administration

PIAT

Public Information Assistance Team

PIO

Public Information Officer

POB

Persons on Board

PPE

Personal Protective Equipment

PREP

Preparedness for Response Exercise Program

PRP

Pandemic Response Plan

PSC

Planning Section Chief

PSI

Pounds per Square Inch

QI

Qualified Individual

RCT

Regional Crisis Team

ROC

Record of Changes

RPO

Recovery Point Objective

RTO

Recovery Time Objective

RP

Responsible Party

RRC

Regional Response Centers

RRT

Regional Response Team (Federal)

RRI

Regional Resource Inventory

SAR

Search and Rescue

SARA

Superfund Amendments and Reauthorization Act

SCAT

Shoreline Cleanup Assessment Team

SCBA

Self-Contained Breathing Apparatus

SERC

State Emergency Response Commission

SITREP

Situation Report Message

SMT

Spill Management Team

SOLAS

Safety of Life at Sea

SONS

Spill of National Significance

SOPEP

Shipboard Oil Pollution Emergency Plan

SOSC

State On-Scene Coordinator

SOT

Standard Operating Procedure

SPCC

Spill Prevention, Control, and Countermeasures Plan

SSC

Scientific Support Coordinator

SSSP

Site Specific Safety & Health Plan

SWD

Saltwater Disposal

UCS

Unified Command System

USCG

United States Coast Guard

WCD

Worst Case Discharge

WHO

World Health Organization

TRP Corp - Emergency Response Planning Crisis Management

Tags: Emergency Management, Response Plans, Crisis Management, Oil Spill, Emergency Response Planning, Communication Plan, Business Continuity Plan, Disaster Response, National Preparedness

New Response Plan Requirements for Select Nontank Vessels

Posted on Thu, Oct 03, 2013

One September 30, 2013, the U.S. Coast Guard announced its final rule regarding nontank vessels carrying oil in U.S. waters.  This final rule specifies the content of nontank vessel response plans (NTVRP) and addresses the requirement to plan for responding to a worst-case discharge and a substantial threat of such a discharge.  Nontank vessel owners and operators must comply with the preparation and submission requirements of the Coast Guard and Maritime Transportation Acts of 2004 and 2006 and requires owners and operators to prepare and submit oil spill response plans.

This NTVRP final rule expands response plan requirements from only tank vessels, for which regulations were initially issued in 1993, to include nontank vessels. This expansion recognizes the significant increase in the quantity of petroleum and petroleum products carried as bunker for fuel and the potentially catastrophic consequences should a mishap result in tank breach. The Coast Guard states that a significant number of today's large nontank vessels carry more oil than many of the tank vessels did as cargo when the original tank vessel response plan requirements were initiated.  These statutorily mandated requirements fill this regulatory gap and enhance the national oil response infrastructure.

According to the U.S. Coast Guard, the NTVRP rule will improve the nation's pollution response planning and preparedness posture, and help limit the environmental damage resulting from nontank vessel marine casualties.

The Federal Water Pollution Control Act defines a nontank vessel as a self-propelled vessel of 400 gross tons or greater that operates on U.S. navigable waters while carrying oil of any kind as fuel for main propulsion and is not a tank vessel.  The response services a nontank vessel owner or operator must plan for are scaled to the risk (i.e., oil capacity) of the vessel. Doing so allows the Coast Guard to minimize burden in carrying out the statutory mandate and focus on those vessels which present the greatest risk to the environment should a breach occur. The Coast Guard revisions include provisions to allow nontank owners or operators to submit their VRP electronically.

Per 33 U.S.C. 1321(j)(5)(D)(i-iv), a response plan must:

  • Be consistent with the requirements of the National Contingency Plan and Area Contingency Plans.
  • Identify the qualified individual having full authority to implement removal actions, and require immediate communications between that individual and the appropriate Federal official and the persons providing personnel and equipment.
  • Identify, and ensure by contract or other approved means the availability of, private personnel and equipment necessary to remove to the maximum extent practicable a worst case discharge (including a discharge resulting from fire or explosion), and to mitigate or prevent a substantial threat of such a discharge.
  • Describe the training, equipment testing, periodic unannounced drills, and response actions of persons on the vessel or at the facility, to be carried out under the plan to ensure the safety of the vessel or facility and to mitigate or prevent the discharge, or the substantial threat of a discharge.

This final rule supports the Coast Guard's strategic goals of protection of natural resources and maritime mobility. This pre-planning will create vital linkages between the shipping industry and oil spill response service providers (such as oil spill removal organizations (OSROs), salvage companies, and marine firefighting companies), ensuring that mechanisms are in place to immediately respond to an emergency.

This final rule goes into effect October 30, 2013.

For a free download of a Response Procedures Flowchart, click the image below:

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Tags: USCG, Oil Spill, Regulatory Compliance, National Preparedness

USCG Oil Spill Planning and the Facility Response Plan

Posted on Thu, Sep 26, 2013

Oil Pollution Act of 1990 (OPA 90) created comprehensive prevention, response, liability, and compensation policies for vessel and facilities that could cause oil pollution to U.S. navigable waters. For facilities adjacent or nearby shorelines, OPA 90 highlights the need for site-specific Facility Response Plans (FRP).

Responding to an oil spill is a dynamic scenario with multiple moving parts and trajectories, both in regards to the material spilled and the responders involved. As a result, a FRP must provide guidelines to quickly, safely, and effectively respond to a spill.

OPA 90 greatly increased federal oversight of oil related vessels and facilities in attempt to provide greater environmental safeguards. OPA 90 implemented the following key points:

  • Set new requirements for vessel construction, crew licensing, and manning
  • Mandated contingency planning
  • Enhanced federal response capability
  • Broadened enforcement authority
  • Increased penalties
  • Created new research and development programs
  • Increased potential liabilities
  • Significantly broadened financial responsibility requirements.

Facilities can enhance oil spill response efforts and incorporate regulatory compliance by preparing site-specific FRPs.  A FRP must provide responders with processes and procedures to quickly, safely, and effectively respond to a spill to prevent further damaging effects. The following are US Coast Guard OPA 90 Facility Response Plan components (33 CFR 154.1035):

Prioritized notification procedures

  1. List of facility response personnel.
  2. List of Federal, State or local agencies, as required
  • Spill response notification forms to Federal, State, local agencies. Form must state that initial notification must not be delayed by collection of data.
  • Notification of the National Response Center.

Facility’s spill mitigation procedures

  1. Description of volume and oil groups that would be involved in the following:
    • Average, maximum and worse discharge from the MTR facility. And, where applicable, the worst case discharge from the non-transportation-related facility.
  2. Prioritized list of procedures and facility personnel (identified by job title).  Procedures must address actions to be taken in the event of a discharge, potential discharge or emergency involving equipment and scenarios.
  3. Listing of equipment and the responsibilities of facility personnel to mitigate an average most probable discharge.

Facility's response activities: Responsibilities of facility personnel to initiate a response and supervise response resources pending arrival of qualified individuals.

  1. Responsibilities and authority of the qualified individual and alternate as required in § 154.1026.
  2. Application of the following organizational structure to manage response actions:
    • Command and control
    • Public information
    • Safety
    • Liaison with government agencies
    • Spill operations
    • Planning
    • Logistics support
    • Finance
  3. Identification oil spill removal organizations and the spill management teams to be capable of providing the following response resources:
  • Equipment and supplies to meet § 154.1045, 154.1047, as appropriate
  • Trained personnel for response to be on hand for the first 7 days of the response
  • Job descriptions for each spill management team member within the organizational structure in a response action.
  • For mobile facilities in more than one COTP zone, oil spill removal organizations and the spill management teams must be identified from paragraph (3)(iv) and included in each COTP zone.

Sensitive Environments

  1. Identification of areas of economic importance and environmental sensitivities which are potentially impacted by a worst case discharge
  2. Development of plans to contain detailed information as to how they will respond to small, medium, and worst-case spills. Identification of  appropriate equipment and personnel as described in § 154.1028 to protect sensitive elements by one of the following calculations:
    • Persistent oils and non-petroleum oils discharged into non-tidal waters, the distance from the facility reached in 48 hours at maximum current.
    • Persistent and non-petroleum oils discharged into tidal waters, 15 miles from the facility down current during ebb tide and to the point of maximum tidal influence or 15 miles, whichever is less, during flood tide.
    • Non-persistent oils discharged into non-tidal waters, the distance from the facility reached in 24 hours at maximum current.
    • Non-persistent oils discharged into tidal waters, 5 miles from the facility down current during ebb tide and to the point of maximum tidal influence or 5 miles, whichever is less, during flood tide.
    • Spill trajectory or model may be substituted if acceptable to Captain of the Port.
    • Procedures contained in the Environmental Protection Agency’s regulations on oil pollution prevention may be substituted for non-tidal and tidal waters.
    • Captain of the Port may require additional sensitive elements to be protected depending on trajectory.
  3. Disposal Plan

Training and Exercises

  1. Training and drill procedures facility owner or operator must fulfill
  2. Plan reviews and update procedures

Site Specifications

  1. List of contacts must include primary and alternate personnel, response contractors and Federal, state and local officials.
  2. Equipment list and records
  3. Communications plan
  4. Site-specific safety and health plan

The above is a summary of the USCG regulation. For more specific information regarding requirements for facilities that could reasonably be expected to cause significant and substantial harm to the environment, please see  33 CFR 154.1035.

Understanding the required elements of the SPCC and FRP, and associated inspections may minimize potential regulatory penalties and fines and curtail operational downtime. For a free download on the SPCC and FRP nspections, click the image below:

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Tags: USCG, Facility Response Plan, OPA 90, Oil Spill, Facility Management, Communication Plan

The SPCC Plan Hybrid Inspection Program

Posted on Thu, Sep 12, 2013

The Environmental Protection Agency (EPA) estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule:

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

The SPCC inspection program is designed to detect oil leaks, spills, or other potential integrity or structural issues before a  spill occurs.  The type of inspection program, scope, and frequency will depend on site-specific conditions, spill history, and type of facility. Typically, inspection programs are in accordance with industry standards. However, companies can decide to deviate from industry standards when another approach would be more appropriate or cost effective, based on site-specific factors. The result may be a Hybrid Inspection Program.

The EPA classifies a Hybrid Inspection Program as a customized, site-specific inspection program based on relevant industry standards (in whole or in part) and other good engineering principles. According to the EPA, the components of a Hybrid Inspection Program would likely include frequent visual inspections by the operator, as well as periodic inspections (plus testing as appropriate) by an EPA certified inspector. A company must document environmentally equivalent inspection and testing alternatives, the reason for the deviation, and describe the alternative method in detail, including how it is environmentally equivalent in the SPCC Plan.

It is recommended that formal container test records or reports be retained for the life of a container under the Hybrid Inspection Program. When implementing a Hybrid Inspection Program, the EPA recommends the following elements:

Inspection elements for shop-built tanks:

  • Visually inspect exterior of tank
  • Evaluate external pitting
  • Evaluate “hoop stress and longitudinal stress risks” where corrosion of the shell is present
  • Evaluate condition and operation of appurtenances
  • Evaluate welds
  • Establish corrosion rates and determine the inspection interval and suitability for continued service
  • Evaluate tank bottom where it is in contact with ground and no cathodic protection is provided
  • Evaluate the structural integrity of the foundation
  • Evaluate anchor bolts in areas where required
  • Evaluate the tank to determine it is hydraulically sound and not leaking

Inspection elements for field-erected tanks:

  • Evaluate foundation
  • Evaluate settlement
  • Determine safe product fill height
  • Determine shell corrosion rate and remaining life
  • Determine bottom corrosion rate and remaining life
  • Determine the inspection interval and suitability for continued service
  • Evaluate welds
  • Evaluate coatings and linings
  • Evaluate repairs for risk of brittle fracture
  • Evaluate the tank to determine it is hydraulically sound and not leaking.

When industry standards do not apply to a container or the container is outside the scope of the standard, a PE does not need to provide and certify an environmental equivalence justification. However, specific inspection protocols must be described in the SPCC Plan, and records of inspections and tests must be maintained for three years. Containers included outside the scope of industry standard can include, but are not limited to:

  • Containers storing oils that have a specific gravity greater than 1.0
  • Oil containers operated at elevated temperatures
  • Animal fat or vegetable oils (AFVOs) containers

Regional EPA representative(s) conduct both announced and unannounced inspections at facilities. A copy of the facility’s SPCC Plan with site-specific inspection procedures should be available for inspector(s) to review at all times. Additional documentation,  including operating procedures, spill prevention measures, personnel training, drainage discharges, and spills should be provided to inspector(s), as well as site plans for tankage, diversionary structures, and drainage patterns.

For a free download on Tips on Conducting an Effective Eercise, click the image below:

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Tags: SPCC, Oil Spill, Training and Exercises, Regulatory Compliance, Chemical Industry

Objectives and Details of Oil Spill Tactical Plans

Posted on Mon, Aug 12, 2013

Pipeline companies often have numerous potential impact zones across vastly diverse terrains with multitudes of emergency response obstacles. Because a single oil spill can have a significant or catastrophic impact on downstream environments, it is imperative to create a pre-planned, coordinated response effort.

Throughout the duration of a spill response, responders may be required to employ various downstream tactics applicable to the various response site. Oil spill tactical response plans provide the position specific information to assist responders along the spill route.

Off-site spill responses and containment efforts present unique challenges compared with spills occurring within the confines of a facility or secondary containment. Offsite spills require a higher level of coordination and communication in effort to minimize impending impacts. 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
  • 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
  • Exercises must include outside entities

Tactical response plans contain numerous geographical fixed response actions for the various off-site tracts in the path of an oil spill. These planning tools assist in the implementation of an overall response strategy by minimizing the potential travel distance of a spill.  When spills migrate off site, it is essential to have plans in place that have been developed in cooperation with those in the potential path of a spill. Communication with downstream counterparts lessens spill response anxieties and promotes company/community partnerships.

Objectives of Tactical Response Plans

Through the planning process, information is gathered to identify the course of action that is necessary to achieve a successful response at the specific downstream location. The primary objectives of tactical response plans are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • 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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Details of the Tactical Response Plan

The tactical planning process identifies the “how” a downstream response will be implemented at a specific location. Tactical planning provides site-specific focus to the comprehensive emergency response plan. They apply a response perspective with specific short-term actions and details that allow responders to best access, assess, and quickly respond to offsite spills. Tactical response exercises will better prepare responders for the potential conditions and actions required at the site.

Tactical spill plans should include the following:

  • Various photographs of each segment (including ground and aerial views, if possible)
  • Maps
  • Latitude and Longitude
  • Land/property owner information
  • Driving directions to the site from main roads
  • Description of potential staging area(s)
  • Specific response tactics for the site location
  • Description of site and applicable waterways
  • Site access specifications
  • Necessary security requirements
  • Waterway flow rates and composition
  • Any critical response information that may be informative to responders
  • Recommended equipment and personnel to implement response strategy
  • Other site specific pertinent issues that may hinder a response
 
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TRP Corp Emergency Response Planning Exercises

Tags: Tactical Response Planning, Oil Spill

Energy Infrastructure Earns D+ : Preparedness Planning is Essential

Posted on Mon, Jun 24, 2013

Businesses rely on infrastructure for operational productivity and economic stability. Every 4 years, the American Society of Civil Engineers (ASCE) releases a “Report Card for America’s Infrastructure” that depicts the condition and performance of the United State’s infrastructure. Each type of infrastructure is assigned a letter grade, similar to a school report card. According to the 2013 report, the Energy sector infrastructure received a D+.

The aging electrical grid, some of which originated in the 1880s, and pipeline distribution systems are becoming more susceptible to failure. The report stated, “Ongoing permitting issues, weather events, and limited maintenance have contributed to an increasing number of failures and power interruptions”. Over the next five years, nearly 17,000 miles of new high-voltage transmission lines, as well as additional oil and gas pipelines are scheduled for construction. Despite plans, new construction is slow and expensive, leaving established infrastructure vulnerable until mitigation efforts are complete.

For companies, this potential for infrastructure failure highlights the importance of securing supply chains and assessing response plans. When extended power failures occur, companies operations can endure significant challenges and potential financial losses. “If the electricity goes out, businesses will shut down for the day,” said Gregory E DiLoreto, P.E.,President of ASCE.  “They will send their workers home. Goods and products don’t get made (and) profits are lost.”

Identifying critical utility and technology related operations is the first step in mitigating the potential threat of an extended power outage. Possible critical utility and technology involved in business operations include, but are not limited to:

  • Utilities including electric power, gas, water, hydraulics, compressed air, municipal and internal sewer systems, wastewater treatment services
  • Security and alarm systems, elevators, lighting, life support systems, heating, ventilation and air conditioning systems, electrical distribution system.
  • Manufacturing equipment, pollution control equipment
  • Communication systems, both data and voice computer networks
  • Transportation systems including air, highway, railroad and waterway

Once utility and technology related operations are identified, the following planning considerations should be taken into account in order to safeguard critical systems and develop an effective business continuity plan:

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

But energy infrastructure is not limited to power sources. Both the input and output supply chain associated with energy transmission must be secured. Despite corporate and regulatory inspection efforts and equipment evaluations and retrofits, oil and gas pipeline companies must be prepared for potential structural failures that inhibit overall energy operations and potentially affect the environment. Utilizing facility response plans and tactical response plans can address emergency response obstacles associated with pipeline failure.

Facility response plans are required by regulatory agencies for facilities that could potentially cause substantial harm to the environment by discharging oil into or on navigable waters. These plans present processes and procedures for mitigating additional harm to personnel, the facility, and the environment in the event of an incident. Tactical plans are beneficial in responding to pipeline incidents that can occur across various impact zones. It is typically not practical for Pipelines to utilize secondary containment, which eliminates a factor of safety often utilized for tanks and other equipment. Tactical plans deliver location-applicable response information across multiple pipeline zones. This short-term, site-specific information informs responders how to best access, assess, and respond to offsite spills.  At a minimum tactical response plans should:

  • Allow response personnel to prepare for and safely respond to spill incidents at sensitive locations  
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response at the location
  • Outline response procedures and techniques for responding to a spill at a specific location
  • Improve regulatory compliance efforts through a more complete response plan

While companies continue to mitigate and rectify aging infrastructure issues that can cause disruptions and potential destruction, response planning and preparedness must be prioritized in order to sustain operations, potential profitability, and overall economic growth.

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Tags: Emergency Preparedness, Crisis Management, OPA 90, Oil Spill, Emergency Management Program