Fall 1997

U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration

OPA 90
LESSONS LEARNED

New Integrated Contingency Plan Simplifies Emergency Planning

If you are involved in facility response planning, then you have probably heard about the Integrated Contingency Plan (ICP) concept at some point over the last several months. In 1995, Federal, state and local officials, in cooperation with industry representatives, began developing guidelines to simplify emergency planning requirements. As a result, the "National Response Team's ICP Guidance" was published in the Federal Register on June 5, 1996.

DOT/OPS, in cooperation with the Environmental Protection Agency (EPA), U.S. Coast Guard (USCG), Occupational Safety & Health Administration (OSHA), and the Minerals Management Service (MMS), designed this ICP guidance to help facilities prepare emergency response plans in the event of an emergency, such as oil and hazardous substance releases. The objective is to take the many facility plans that have been developed to fulfill the various regulatory requirements and consolidate them into one single plan. In recognition of the ICP's contribution to reinventing government, the project has been awarded the National Performance Review's "Hammer" Award.

We have an excellent working relationship with our regulated community, says Rich Felder, Associate Administrator for Pipeline Safety. They have told us that developing and maintaining multiple plans was costly and burdensome. We have responded by working with them to be able to offer the ICP option. Some of the larger operators have said that the ability to consolidate into one plan could save them a considerable amount of money, while maintaining or even improving the plan's quality.

DOT/OPS' experience in reviewing and approving pipeline industry facility response plans (FRP) over the last three years has made them keenly aware of the various agencies' overlapping requirements. Complex facilities which are regulated by more than one Federal or state agency were developing plans for each set of regulations that applied. This created confusion and concern about what plans would really be implemented during an emergency. In some cases, the plans that were submitted weren't necessarily the ones that were being used. In a real incident, the response plans actually being used were the ones tucked away in the responders' desks!

Pipeline operators can continue maintaining multiple plans to demonstrate federal regulatory compliance; however, PHMSA believes that an integrated plan prepared in accordance with the new guidance is a preferable alternative.

The ICP's format is organized into three sections -- an introductory section, the core plan and supporting annexes. The guidance contains a detailed description of each section's content, as well as a plan outline and tables providing regulatory cross references.

The introductory section identifies basic information about the plan and the entity it covers. This section has a statement of purpose and scope, general facility information, and key contacts.

The core plan section identifies the essential response steps necessary to initiate, conduct and terminate response to an emergency. Incident detection, notification and implementation of response strategies should all be addressed within the core plan.

The annexes provide key supporting information for implementation of the provisions of the core plan. They are not meant to duplicate the core plan information, but to augment it. The ICP guidance lists eight recommended annexes, as follows:

• Facility Information
• Notification
• Response Management System
• Incident Documentation
• Training and Exercises
• Response Critique and Plan Review and Modification
• Prevention
• Regulatory Compliance and Cross Reference Matrices

OPS, EPA, USCG, and MMS are now revising its plan review protocols and checklists to accommodate plans submitted in the ICP format.

OPS is looking forward to seeing how the new format will work for the pipeline industry. Some operators are now revising their FRPs to fit the new ICP format and OPS expects to see the results within the next several months.

More Lessons Learned

During the first three quarters of 1996, DOT/OPS exercised eighteen spill management teams (SMTs), with each team providing positive feedback on the many different lessons they have learned from the exercises.

All participants, however, have shared that the greatest benefit they receive from the exercises is the opportunity to come face-to-face with other people who make up their area SMTs. Tabletop exercise attendees not only include facility- and headquarters-level personnel of the pipeline operator, but also representatives of the various local, state, and Federal agencies who would assist the operator in an oil spill response effort. In fact, for some pipeline operators, these tabletop exercises are the first time they have had the opportunity to meet face-to-face with government agencies they would normally interface with during an actual incident.

What are some other lessons learned from these tabletop exercises? We consider the following lessons to be common among many of our participating organizations:

Lessons Learned:

Identify adequate numbers of qualified personnel to staff a long-term oil spill response.

Many participating pipeline operators are small companies that would have difficulty staffing a SMT for a long-term, round-the-clock, worst-case spill situation. While such a scenario is unlikely, due to the excellent safety record of most pipeline operators, it is nevertheless prudent for operators to plan for such an event. Operators should evaluate the number of responders available to them for extended emergency operations to determine if there is a need to contract trained personnel for support. Operators should also consider the number of relief shifts, the alternative personnel resources needed to staff these shifts, and the effect that this personnel drain would have on normal business operations.

Identify and take advantage of resources available via agencies and other pipeline operators in the area.

During the tabletop exercises, participants frequently offer to lend their expertise and equipment resources to one another in the event of an emergency. For example, a government agency may offer their equipment to a pipeline operator, followed by a reciprocal offer by the operator to lend their own resources to this agency.

This dynamic exchange of resources can be extremely important during an oil spill. If there is little interaction between industry and government responders until an incident actually occurs, various response groups may remain unaware of existing resources that would otherwise help them in their response effort.

Other pipeline operators in the area of a spill may also be able to provide assistance, particularly in the early hours after an incident. Some companies may have pre-positioned equipment that can be deployed more quickly than the responsible party's equipment. Agency responders often have access to advanced technologies, such as spill mapping, that could readily be shared with the responsible party.

Prioritize the environmentally and economically sensitive areas for protection prior to a spill.

Pipeline operators are required to list zones of economic and environmental value in their emergency plans and procedures. Possible damage and extensive clean-up costs could be minimized or even avoided if these areas are identified prior to a spill, prioritized for protection and included in the operator's FRP.

Plan for wildlife rescue and rehabilitation.

While wildlife rescue and rehabilitation can be a crucial element in reducing the impacts of an oil spill, some operators don't have environmental remediation experts on their SMTs, nor have they identified contractors to direct wildlife rescue and rehabilitation. Adequate planning in this area would pave the way for a smoother recovery for the affected facility, the local community, and certainly, the wildlife itself.

More suggestions on ways to improve your oil spill response plans will be included in upcoming issues of this newsletter.

Oil Pollution Act Public Workshop

DOT/Pipeline and Hazardous Materials Safety Administration (PHMSA) invites industry, government agencies and the public to come together for a workshop on response plans for onshore oil pipelines. The purpose of the workshop is to solicit comments about how the current regulations on response plans for onshore oil pipelines could be improved. DOT/PHMSA may issue a final rule based on the comments received.

WHEN:

• January 29, 1997; 8:30 am to 4:00 pm

WHERE:

• New Orleans Hilton Riverside
  New Orleans, Louisiana
  (504) 561-0500

Items of discussion will include, but not be limited to, the following topics:

• Whether the definition of significant/substantial harm as defined in 49 CFR 194.103 should be   changed.
• Whether a requirement for pipeline operators to have secondary communications systems for emergency response activities should be included in the final rule (Appendix A, Section 2 of 49 CFR 194).
• Whether operators should be able to take a 50% credit for the secondary containment around breakout tanks in calculating their worst-case discharge volumes per 49 CFR 194.105(b)(3).
• Whether the plan review cycle should be modified from the current three-year cycle (49 CFR 194.121(a)) to a five-year cycle, as with the U.S. Coast Guard (USCG) and EPA requirements.
• Whether a regulatory definition of "oil" for purposes of response planning should be adopted. If so, how should "oil" be defined -- the list published by the USCG (G-MRO) on February 24, 1995, the definition found in 49 CFR 194.5, or a different definition?
• Whether facility response plan requirements for pipelines transporting hazardous substances are needed.
• Whether PHMSA's "Guidelines for Developing and Evaluating an Oil Spill Response Exercise" should be more widely available.
• Whether greater emphasis should be placed on requiring operators to plan for "a substantial threat of a discharge," i.e. including procedures for shutting down the line prior to an actual release of oil.

 If you are interested in making a presentation or need further information, contact Jim Taylor, Response Plans Officer, at (202) 366-8860 (or e-mail to OPATEAM@RSPA.DOT.)

Call for Volunteers

DOT/OPS is currently seeking pipeline operators wishing to volunteer for upcoming area and tabletop exercises. In conjunction with EPA, we plan to conduct pipeline exercises in EPA Regions IV and X in FY '97 and in Regions I and V in FY '98.

If you operate in one of these designated EPA Regions and would like to participate in an upcoming area exercise, or if you want to participate in a tabletop exercise in any region, please contact Toni Hundley at 202/366-4397.

Coast Guard Reorganization May Give You A Wrong Number

In case you haven't heard, the Coast Guard is streamlining its operations.

What does this mean to pipeline operators? It could mean that the Coast Guard numbers in the FRP may be incorrect.

Operators...take a moment to make sure that the Coast Guard phone numbers in your plan are up-to-date -- so you won't get a disconnected number when you really need them.

Calendar of Upcoming Pipeline Exercises

• 1996
  • NOV 13: Tabletop Exercise, Consolidated Edison, New York, NY
• 1997
  • JAN 14: Tabletop Exercise, Howell Corp., AL
  • JAN 14*: Tabletop Exercise, Navajo, NM
  • FEB 13: Tabletop Exercise, All-American, AZ
  • FEB 26*: Tabletop Exercise, Shell, TN

*= tentative dates