1. Presented to: RETA National Conference – Atlanta November 5, 2014 If you’d like to reach SCS Engineers, Tracer Environmental Division please contact us at: Service@scsengineers.com Emergency Action Planning It’s not just 9-1-1

2. 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? Regulatory Criteria - Emergency Planning & Response

3. Emergency Planning & Response - Compliance with PSM  OSHA – “Emergency Action Plan” Requirements:  Documented Plan  Procedures for reporting an emergency (ex: fire, NH 3 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. 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 Emergency Planning & Response - Compliance with PSM

5. “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 Emergency Planning & Response - Interpretations

6.  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).” Emergency Planning & Response - EPA Guidance

7. Emergency Action Plan elements:  Site maps indicate evacuation route assignments.  Hazard Communication (NH 3 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. Emergency Planning & Response - Checklist for Implementation

8. Emergency Action Plan elements (con’t):  Wind sock (or other wind direction indicator) visible from assembly area(s).  Test facility PA / alarm systems / radios at least annually. Emergency Planning & Response - Checklist for Implementation

11. Emergency Action Plan elements (con’t):  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. Emergency Planning & Response - Checklist for Implementation

12. 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 Emergency Planning & Response - Checklist for Implementation

14.  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 Emergency Planning & Response - Emergency Reporting

15. What is your facility’s 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. 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 don’t, 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. Regulatory Criteria - Emergency Planning & Response

17. Must Ensure the following:  Facility’s 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 Regulatory Criteria - Emergency Planning & Response

18. 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. immediately  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. Regulatory Criteria - Emergency Planning & Response This information should be spelled out in your EAP / ERP.