Presented to:

1
Emergency Action PlanningIts not just 9-1-1

• Presented to
• RETA National Conference Atlanta
• November 5, 2014
• If youd like to reach SCS Engineers, Tracer
  Environmental Division
• please contact us at
• Service_at_scsengineers.com

2
Regulatory Criteria - Emergency Planning
Response

• Regulations
• Process Safety Management (PSM)
• OSHA Code of Federal Regulations, Title 29,
  Section 1910.119(n). 29CFR 1910.119(n), 29CFR
  1910.38(a), 29CFR 1910.120(a), (p), and (q)
• Risk Management Program (RMP)
• EPA Code of Federal Regulations, Title 40, Part
  68.95 (40CFR 68.95)
• Is your facility going to response to an ammonia
  release or not?
• What are your responsibilities other than calling
  9-1-1 and waiting for the fire department to
  arrive?

3
Emergency Planning Response -Compliance with
PSM

• OSHA Emergency Action Plan Requirements
• Documented Plan
• Procedures for reporting an emergency (ex fire,
  NH3 leak)
• Evacuation route assignments
• Account for all employees after an evacuation
• Rescue medical duties (not required to be
  in-house)
• Names / job titles for people to contact for more
  information about the plan or their duties
• Must include procedures for handling small
  releases
• Alarm System must use a distinct signal for each
  purpose (ex fire, Ammonia leak)

4
Emergency Planning Response -Compliance with
PSM

• OSHA Emergency Action Plan Requirements
  (cont.)
• Sufficient number of employees to be trained to
  assist in a safe and orderly evacuation
• Special attention for disabled employees
  including temporary disabled employees
• Training / re-training must occur at the
  following times
• Initially when the plan is developed
• Whenever the responsibilities or duties change
• Whenever the action plan is changed
• What does this mean ? PRACTICE!
• Evacuation Drills at least annually
• All employees on all shifts to participate
• Evacuation maps posted near exits

5
Emergency Planning Response -Interpretations

• Response vs. Action
• If facility chooses to utilize employees for
  response activities, further pre-planning and
  training is required.
• Response requires a team of people trained in
  HAZWOPER and Incident Command System, use of
  proper PPE (SCBA positive air pressure,
  full-face cartridge respirators).
• Current interpretations include a minimum of 4
  people
• Buddy system with backups in full gear
• Joint Response Team
• Coordinate with local responders!
• Local Fire Department, Hazardous Materials
  Response Teams
• Recommendation
• Send a written invitation (certified mail or
  email) to your local responder, HAZMAT, and LEPC
  to come on-site and become familiar with your
  facility.
• Coordinate with private response company or
  neighboring facility

6
Emergency Planning Response -EPA Guidance

• From EPA Risk Management Plan Guidance, May 2000
• ...it would be inappropriate, and probably
  unsafe, for a facility with only two full-time
  employees to expect that a major fire could be
  handled without the help of the local fire
  department or other emergency responder. EPA
  does not intend to force such facilities to
  develop emergency response capabilities. At the
  same time, you are responsible for ensuring
  effective emergency response to any releases at
  your facility. If your local public responders
  are not capable of providing such response, you
  must take steps to ensure that effective response
  is available (e.g., by hiring response
  contractors).

7
Emergency Planning Response -Checklist for
Implementation

• Emergency Action Plan elements
• Site maps indicate evacuation route assignments.
• Hazard Communication (NH3 SDS available for
  review).
• Employees trained in evacuation duties
  (accounting for any disabled employees).
• Employees Contractors know how to report an
  emergency within the Plant.
• Designated On-Site Emergency Coordinator for all
  shifts.
• Procedures to account for all employees and
  visitors.
• Distinct signal to evacuate the workplace (PA,
  alarms, verbal warning, etc.).
• Who to contact for more information on the plan.

8
Emergency Planning Response -Checklist for
Implementation

• Emergency Action Plan elements (cont)
• Wind sock (or other wind direction indicator)
  visible from assembly area(s).
• Test facility PA / alarm systems / radios at
  least annually.

9
Emergency Planning Response -Checklist for
Implementation
10
Emergency Planning Response -Checklist for
Implementation
11
Emergency Planning Response -Checklist for
Implementation

• Emergency Action Plan elements (cont)
• Maintain all emergency response equipment
  properly
• Conduct emergency evacuation drills that include
  all employees. Maintain records.
• Emergency plan is coordinated with outside
  responders as appropriate.

12
Emergency Planning Response -Checklist for
Implementation

• DOT Isolation Zones / Coordination
• 100 feet for slow leak venting to atmosphere.
• 300 feet for relief valve venting to atmosphere.
• 500 feet for major incident on the liquid side.
• Sensitive Populations in the area.
• Fire Department Staging Locations / Options

13
Emergency Planning Response -Checklist for
Implementation
14
Emergency Planning Response -Emergency
Reporting

• Federal Reportable Quantity (Verbal only)
• 100 pounds or more - National Response Center
  (1-800-424-8802) requires immediate notification
  (within 15 minutes)
• State Local Reporting Quantities - Vary
• Example CA requires, Any Significant Release or
  Threatened Release Must be Reported
• Notify Your Local LEPC and SERC
• Which employee(s) are Designated to make Release
  Notifications

15
What is your facilitys plan?

• Emergency Action vs. Emergency Response
• Evacuation vs. HazMat Response Team
• Capabilities of Local Responders
• Maintain training records for
• Evacuation drills,
• PPE (respiratory fit tests, medical evals),
• HAZWOPER,
• Incident Command (IC) System, etc.

vs.
16
Regulatory Criteria - Emergency Planning
Response

• Summary
• You are responsible for ensuring effective
  emergency response to any releases at your
  facility.
• If you rely on local emergency responders for all
  of the response effort, you must determine that
  they have the equipment and training to handle an
  incident.
• If they dont, you should consider one of the
  following
• develop your own response capabilities
• develop mutual aid agreements with other
  facilities
• hire a response contractor or
• provide support to local responders so they can
  acquire the equipment training.

17
Regulatory Criteria - Emergency Planning
Response

• Must Ensure the following
• Facilitys Emergency Action Plan is accurate and
  up-to-date.
• Employees and Contractors are trained in the
  Emergency Action Plan.
• All emergency response equipment is maintained
  properly.
• Emergency evacuation drills are performed
  annually and documented (for all shifts).
• Coordinated with the local emergency responders.
• Certified mail or email invitation to come
  on-site for emergency pre-planning

18
Regulatory Criteria - Emergency Planning
Response

• Recent Citations
• EPA - Emergency Notification Requirements
• Update Emergency Response Program to include
  protocols for ensuring notification will be made
  within 15 minutes of releasing in excess of 100
  pounds of ammonia.
• Federal Requirement Facilities must immediately
  notify the LEPC and the SERC if there is a
  release into the environment of a hazardous
  substance that is equal to or exceeds the minimum
  reportable quantity set in the regulations (100
  pounds in 24 hours for ammonia).
• NOTE The reporting criteria (e.g., quantity, who
  to call, what to report, etc.) varies
  state-to-state.

This information should be spelled out in your
EAP / ERP.