Your Solution for SMART Response Plans

Utilizing Technology to Improve Regulatory Compliance and Preparedness

Posted on Thu, May 12, 2016

Workforce Reductions and Petroleum Inventories

Industry volatility associated with plunging commodity pricing is pressing many energy companies to operate at minimal staffing levels, challenging them to “do more with less” while sustaining current enterprise-wide preparedness capabilities and regulatory compliance.

Workforce reductions in the energy sector have resulted in a loss of nearly 118,000 jobs in the U.S. since the beginning of 20151, and more than 320,000 positions globally since the downturn began2. Even with reduced staffing, safety expectations, environmental protection standards, and regulatory compliance requirements remain constant - providing justification for utilizing tools that increase efficiencies and further reduce labor costs.

In conjunction with enormous staff reductions, petroleum inventories have increased to record levels. As of April 29, 2016, the U.S. Energy Information Agency listed the inventory of crude oil and petroleum stocks at 2,065,928 (thousand barrels), the highest amount in history3. Although facilities and response plans are designed for a worst case discharge, there is now less margin for error for a large spill, given that many facilities are operating at higher capacities.

Complex Compliance Requirements

Oil storage operations are heavily regulated. Overlapping response plan requirements from multiple agencies are applicable to many facilities. Federal agencies that may require response plans include EPA, U.S. Coast Guard, PHMSA, and OSHA. As many as three different federal agencies regulate OPA 90 for some facilities, and certain states add more requirements. In addition to the complexities of developing and maintaining Facility Response Plans, many facilities are subject to planning requirements for Spill Prevention, Control, and Countermeasures, Dock Operations, Security, Risk Management, Process Safety Management, Emergency Response, and Fire Pre-Plans. Many of these regulations require similar site-specific details, further exemplifying the need for tools that are specifically designed to leverage and manage this content.

In order to maintain company-wide compliance and preparedness, every response plan must contain accurate site-specific details consistent with operations, personnel, topography, sensitivities, weather, and other factors. Maintaining this level of detail across multiple plan types for a large number of facilities is a challenge, especially when less personnel are available. TransMontaigne Partners and DCP Midstream, among others, have embraced cloud-based, database-driven systems specifically designed to improve flexibility, accessibility, efficiency, and consistency of their response plans. Intuitive response planning systems that streamline formats, and utilize database technology to leverage and manage information offer tremendous benefits in improving compliance and preparedness.

SMARTPLAN™ Response Planning Tools

For companies with multiple facilities and locations, cloud-based planning systems, such as Technical Response Planning’s (TRP) SMARTPLAN™ Software, provide a platform for site-specific response plans that integrate seamlessly with company-wide operations, procedures, and policies. DCP Midstream, which has been utilizing TRP’s technology for their Emergency Response Plans since 2001, operates 63 gas processing plants and over 64,000 miles of pipelines across 17 states. “With a footprint that large, we need to leverage technology to improve efficiencies,” says Brian McGuire, Director of Health, Safety and Security for DCP Midstream. TRP’s system enabled DCP Midstream to optimize plan maintenance processes, plan formats, and regulatory compliance at every location.

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In 2013, TRP demonstrated their new SMARTPLAN™ Software to DCP. “I quickly recognized the power of the new platform and improvements that would enable us to easily manage all of our plan types, including SPCC Plans, Business Continuity Plans, and Risk Management Plans, in addition to the Emergency Response and Crisis Management Plans that TRP had been managing since 2001,” says McGuire. “When integration of our current plans into the SMARTPLAN™ platform was completed in 2014, it was an easy decision to also add our NGL Pipeline County Emergency Response Plans and our more than 700 SPCC Plans. TRP’s quick turnaround in transitioning these additional plans exceeded our expectations.”

TransMontaigne Partners, which operates more than 50 refined product bulk storage terminals and pipeline systems, also saw the enterprise-wide benefits of the new system. “TRP recently upgraded our account to their new SMARTPLAN™ platform, which provides even more functionality, flexibility, and tools to help us manage regulatory requirements and plan maintenance for our large operation,” says Dudley Tarlton, Vice President of Environmental, Safety and Occupational Health with TransMontaigne Partners. “Their software allows TransMontaigne Partners to manage our plans much more effectively and with less manpower than could be done with traditional methods.” 

TRP’s SMARTPLAN™ software system and unique approach has been widely adopted by companies like DCP Midstream and TransMontaigne Partners. SMARTPLAN™ accomplishes these improvements in efficiency by providing the following:

Instant Accessibility: Ensures each approved stakeholder has access to the latest version of every response plan. Accessibility options include being able to access live from the Internet, download a static electronic version, or print paper copies. The electronic format also provides the ability for plans to be shared for regulator or auditor review. In addition, hyperlinks, reference libraries, simplified interfaces, and reporting tools improve functionality and further leverage available data for plan users.

Plan Management Tools: Database allows for information to be mapped to multiple locations in all plan types, across an entire company. By reducing time requirements, plan updates are more likely to be performed, thereby improving accuracy and compliance.

Instantaneous Revisions: Plan updates are immediately available to all stakeholders. This eliminates “version confusion” for plan users, which improves response plan accuracy. This functionality also provides the ability to quickly and cost effectively apply lessons learned, regulatory changes, and company reorganization issues across all response plans.

Plan Consistency: Promotes the use of a consistent plan format across entire companies, yet it is still customized to account for company-specific processes and philosophies. This allows for improved familiarization with response plans for all company personnel.

Plan Types: Provides all types of response plans, including Facility Response Plans, Emergency Response Plans, SPCC Plans, Fire Pre-Plans, Business Continuity Plans, and others.

“TRP’s system has always done an amazing job of standardizing our many plans, and helping us manage all of our plan contacts,” says McGuire. “In addition, the new dike volume calculation tools in SMARTPLAN™ have greatly improved the accuracy and documentation of our SPCC plans and have significantly reduced time required to perform manual calculations.”

  1. http://www.houstonchronicle.com/business/energy/article/Fed-U-S-oil-job-cuts-reach-about-118-000-7237605.php
  2. http://fuelfix.com/blog/2016/04/07/chevron-cutting-655-houston-jobs-amid-oil-bust/#31744101=0
  3. https://www.eia.gov/dnav/pet/PET_STOC_WSTK_DCU_NUS_W.htm

TRP Corp - Emergency Response Planning Crisis Management

Tags: Emergency Preparedness, Regulatory Compliance, corporate preparedness