Emergency management centers on risk assessment and preparation. The events of September 11, 2001 increased the regulatory oversite. Risk management plans are industry specific. Our broad range of experience qualifies our engineers & consultants to assist with plan preparation in several areas.
Oil Spill Prevention, Control & Countermeasure Plan
Any facility holding more than 1320 gallons of any type of oil (mineral, plant or animal) must prepare an oil spill prevention control and countermeasure (SPCC) plan. All SPCC plans must be completed/revised and fully implemented by November 10, 2011.
However, off-shore facilities, or large storage facilities that meet the criteria for "Substantial Harm" must meet a compliance deadline of November 10, 2010.
The following are exempt from the SPCC rule:
Completely buried storage tanks subject to all the technical requirements of the underground storage tank regulations
Containers with a storage capacity less than 55 gallons of oil
Wastewater treatment facilities
Permanently closed containers
Motive power containers (e.g., automotive or truck fuel tanks)
The EPA proposed in the August 3, 2010 Federal Register a one year extension for updating existing or preparation of new facility SPCC plans until November 10, 2011. Facilities not covered by the proposed extension are off-shore facilities, and facilities which could cause "significant harm" i.e. facilities which load/unload oils over water with capacities at or above 42,000 gallons OR facilities with more than 1 million gallons of capacity and which pose a risk to sensative environmental areas or water supplies (i.e. facilities required to prepare and implement facility response plans). This proposed extension is expected to be approved.
Our staff has prepared and/or certified plans for a wide assortment of facilities including machine fabrication, petroleum oil bulk storage plants, drum storage facilities, oil well sites, food processing plants, airport operators, power substations and drill and workover rigs. We are confident we can contribute to a cost effective solution, such as multi-facility SPCC plans, for your situation.
EPA Facility Response Plan (FRP)
For oil handling facilities with capacities at or above 1 million gallons and located in specific locations such as environmentally sensitive areas or upstream of community drinking water intakes, a second level of preparedness is required. A Facility Response Plan (FRC) is required to be prepared and submitted to the EPA for review and approval. The facility FRC must be consistant with the response plans prepared by community emergency response organizations. Annual field drills, equipment and supply pre-placement and extensive training are all required for these operators. Our staff engineers have past practical experience as field supervisors for major international oil companies, including actual "incident commander experience." Don't under estimate what "real-world" experience brings to the process.
Chemical Preparedness & Prevention Plans
Facilities handling one or more of the 140 “regulated substances” above threshold quantities were required to develop and submit a Risk Management Plan (RMP) to the EPA by June 1999.
Plans must be updated and resubmitted every five years. Most plans will require resubmission by June 21, 2004 or the five year anniversary of its last submittal.
Note: US Department of Homeland Security (DHS) regulations have updated resubmission requirements for RMPs.
Our chemical engineers and certified hazardous material managers are available to prepare, revise and or submit Risk Management plans for anhydrous ammonia, chlorine, LPG/propane, hydrogen sulfide or any other material subject to this regulations consistant with the recent revisions and comply with EPA's resubmission requirements. Our goal is to assist you in implementation of an effective accidental release prevention program.
HazMat Transportation Security Plan
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Most hazardous materials shippers and carriers to develop written security plan based on a self-conducted formal risk assessment. The plan, to be implemented by September 23, 2003, required attention to threats posed by employees, unauthorized personnel on the site, and while materials are en route. Site specific training must also be provided.
Sites must now develop and implement a security plan based on a site specific risk assessment if it offers for transportation or carry any of the following:
��Any quantity of a Division 1.1, 1.2, or 1.3 Explosive Material ��A quantity of a Division 1.4, 1.5, or 1.6 Explosive Material requiring placarding in accordance with 49 CFR 172.504(c) ��A large bulk quantity of Division 2.1 Compressed Flammable Gas ��A large bulk quantity of Division 2.2 material with a subsidiary hazard of 5.1 ��Any quantity of a material poisonous by inhalation, as defined in 49 CFR 171.8 ��A large bulk quantity of a Class 3 material meeting the criteria for Packing Group I or II ��A quantity of a desensitized explosives meeting the definition of a Division 4.1 or Class 3 material requiring placarding in accordance with 49 CFR 172.504(c) ��A large bulk quantity of a Division 4.2 material meeting the criteria for Packing Group I or II ��Any quantity of a Division 4.3 material ��A large bulk quantity of a Division 5.1 material in Packing Groups I and II ��Perchlorates; or ammonium nitrate, ammonium nitrate fertilizers, or ammonium nitrate emulsions, suspensions, or gels ��Any quantity of organic peroxide, Type B, liquid or solid, temperature controlled �� A large bulk quantity of Division 6.1 material �� A select agent or toxin regulated by Centers for Disease Control and Prevention under 42 CFR 73 or the United States Department of Agriculture under 9 CFR 121 �� A quantity of uranium hexafluoride requiring placarding under 49 CFR 172.505(b) �� International Atomic Energy Agency (IAEA) Code of Conduct Category 1 and 2 materials including Highway Route Controlled quantities as defined in 49 CFR 173.403 or known as radionuclides in forms listed as RAM-QC by the Nuclear Regulatory Commission �� A large bulk quantity of Class 8 material meeting the criteria for Packing Group I.
In addition to the original plan components, the following additional information must now be added to the security plan:
�� Identification of the job title of the senior management official responsible for overall development and implementation of the plan �� Security duties for each position or department that is responsible for implementing the plan or a portion thereof and the process of notifying employees when specific elements of the security plan must be implemented; and �� A plan for training hazmat employees.
The plan must be reviewed annually and updated or revised as necessary. The most recent version of the plan must be made available to employees consistent with their need to know and security clearance.
Changes to the rule in December 2005 have exempted small farm operations which can meet the following criteria:
Transportation activities of a farmer, who generates less than $500,000 annually in gross receipts from the sale of agricultural commodities or products, if activities are:
(1) Conducted by highway or rail
(2) In support of their farming operations
(3) Conducted within a 150-mile radius.
Our staff conducted risk assessments and prepared plans for a wide range of clients. We assisted several trade associations in providing compliance options for their members, including training and tools for clients to develop their own plans and serve only as an advisor.
DOT Oil Spill Prevention and Response Plan
Since 1994, transportation vehicles and rolling stock (i.e. rail cars) containing petroleum, vegetable or animal derived oils with a transport capacity of at least 3500 gallons must prepare and implement an oil spill prevention and response plan per DOT regulations 49 CFR 130. Additional requirements exist for vehicles transporting at least 42,000 gallon loads.
While not as robust as the comparable EPA regulations, the challenge for transportation companies is providing for emergency response anywhere in their service area. Our professionals have worked with multiple clients in the truck and rail industries and have successfully addressed compliance in a cost effective manner.
Emergency Restoration Plan (ERP)
Electric power systems have been identified in Presidential Decision Directive (PDD-63) as one of the critical infrastructures of the United States.The Rural Utilities Service proposed in early 2004 a requirement for electric distribution, communication, generation, and transmission borrowers to expand their currently established Emergency Restoration Plan (ERP), or create a plan if one does not exist.The ERP is to be comprised of both a Crisis Management Plan and a Business Continuity Plan.
Our staff is educated and experienced in the areas of business, management, & engineering including industry-specific utility experience. We have risk and emergency management experience in electrical distribution, electric transmission, information technology, hazardous material transportation, and pipeline systems. We would welcome the opportunity to share our knowledge and best practices experience as a business consultant for you.
Contact Keitu via e-mail or by phone at 701-667-1800 for assistance in these or other areas of emergency response preparation.
