spill response plans why are they developed n.
Download
Skip this Video
Loading SlideShow in 5 Seconds..
Spill Response Plans – Why Are They Developed? PowerPoint Presentation
Download Presentation
Spill Response Plans – Why Are They Developed?

Loading in 2 Seconds...

play fullscreen
1 / 17

Spill Response Plans – Why Are They Developed? - PowerPoint PPT Presentation


  • 121 Views
  • Uploaded on

Spill Response Plans – Why Are They Developed?. Alan K. Mayberry Deputy Associate Administrator for Pipeline Safety. Plans required by PHMSA Regulations. Operations, Maintenance and Emergency Manuals Natural Gas Regulations 49 CFR 192.605 &192.615

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about 'Spill Response Plans – Why Are They Developed?' - lindley


An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
spill response plans why are they developed

Spill Response Plans – Why Are They Developed?

Alan K. Mayberry

Deputy Associate Administrator

for Pipeline Safety

plans required by phmsa regulations
Plans required by PHMSA Regulations
  • Operations, Maintenance and Emergency Manuals
    • Natural Gas Regulations 49 CFR 192.605 &192.615
    • Hazardous Liquid Regulations 49 CFR 195.402
    • Liquefied Natural Gas Facilities 49 CFR 193.2503 & 193.2509
  • Response Plans for Onshore Oil Pipelines

49 CFR 194.101

phmsa information sharing requirements
PHMSA Information Sharing Requirements
  • Pipeline operators must provide information to the public:
    • Landowners and Rights of Way residents
      • Public Awareness;
      • Indications of leaks;
      • Emergency reporting procedures
    • Excavators
      • Damage Prevention and One-Call Information
phmsa information sharing requirements1
PHMSA Information Sharing Requirements
  • Pipeline operators must provide information to the public:
    • Public assemblies, municipalities, school districts, businesses and residents of pipeline facility locations
    • Emergency officials
      • Emergency Plans, Briefings, and Continuing Liaison
phmsa information sharing requirements2
PHMSA Information Sharing Requirements
  • Certain procedures in Emergency manuals may be “Business Confidential or Proprietary.”
  • Could disclose or illustrate sensitive business processes or practices the operator has developed as a competitive advantage
  • Business Confidential ≠ Best Practice
what s in emergency plans
What’s in “Emergency Plans?”
  • Each operator shall establish and maintain liaison with appropriate fire, police, and other public officials to:
    • Learn the responsibility and resources of each governmental organization that may respond to a gas pipeline emergency
    • Acquaint the officials with the operator’s ability in responding to a gas pipeline emergency

49CFR.192.615(c) (1),(2)

what s in emergency plans1
What’s in “Emergency Plans?”
  • Each operator shall establish and maintain liaison with appropriate fire, police, and other public officials to:
    • Identify the types of gas pipeline emergencies of which the operator notifies the officials; and
    • Plan how the operator and officials can engage in mutual assistance to minimize hazards to life or property

49CFR.192.615(c) (3), (4)

phmsa enforces plan sharing
PHMSA Enforces Plan Sharing
  • In a 2008 case, PHMSA proposed a civil penalty, PHMSA fined a pipeline operator $310,000 for violation of 49 C.F.R. § 195.402(c)(12).
  • The operator failed to maintain liaison with fire, police, and other appropriate public officials to learn the responsibility and resources of each government organization that might respond to a hazardous liquid pipeline emergency and to acquaint local officials with the operator’s ability in responding to a hazardous liquid pipeline emergency and its means of communication.
phmsa enforces plan sharing1
PHMSA Enforces Plan Sharing
  • Our final order states,
  • “Failure to maintain effective liaison can result in misunderstandings, erroneous expectations, and delayed communications and responses on the part of both the responding local officials and the pipeline operator.”
phmsa advisory bulletin
PHMSA Advisory Bulletin
  • Published Nov. 3, 2010
  • “PHMSA reminds operators of gas and hazardous liquid pipeline facilities that they must make their pipeline emergency response plans available to local emergency response officials.”
  • “PHMSA recommends that operators provide their emergency response plans to officials through their required liaison and public awareness activities.”
  • “PHMSA intends to evaluate the extent to which operators have provided their emergency plans to local emergency officials when PHMSA performs future inspections…”
onshore oil pipeline facility response plans frps
Onshore Oil Pipeline Facility Response Plans (FRPs)
  • Required by the Clean Water Act, as amended by the Oil Pollution Act of 1990
  • Need to address response organization and resources required to respond to a worst case discharge to the maximum extent practicable.
  • Submitted to PHMSA for review and approval
  • States may require submission of plans under their own regulations – OPA did not preempt State oil spill laws
    • State approval process is independent of PHMSA review
facility response plans
Facility Response Plans
  • Used during spill incidents to guide response, recovery, and removal actions
  • Can direct operator to share with Federal On-Scene Coordinators
  • Almost all content is publicly available through Freedom of Information Act requests
facility response plans1
Facility Response Plans
  • FRP must include:
    • Corporate information and Qualified Individual
    • Immediate notification procedures
    • System description or diagrams
    • Computed worst case discharge on pipeline or at tank facilities
    • Spill response resources owned by operator or available through contract Oil Spill Response Organization (OSRO)
facility response plans2
Facility Response Plans
  • PHMSA reviews and approves FPRs for 5-year period
    • Must be updated when significant changes occur
    • Deepwater Horizon response caused PHMSA to publish an Advisory Bulletin in June 2010
      • Most operators’ OSROs were not affected.
comparison of phmsa required plans
Comparison of PHMSA-Required Plans

Emergency Plans

Facility Response Plans

Required for Onshore Oil Pipeline Operators

Operators submit to PHMSA for review and approval

Library of FRPs maintained by PHMSA

Shared, when requested Federal On Scene Coordinators

Publicly available* through FOIA

  • Required for all pipeline operators
  • PHMSA reviews at operator facility during inspections
  • Not collected or maintained by PHMSA
  • Operator must share with local emergency officials
  • Not publicly available through FOIA

*Portions may be redacted

facility response plans3
Facility Response Plans
  • Certain FRP information could provide information to an adversary.
    • Reveal system vulnerabilities and aid target selection
    • Reveal choke points or non-redundant systems
    • Maximize damage and interfere / interdict response activities
    • Some content considered sensitive
thank you
Thank you

Alan K. Mayberry

alan.mayberry@dot.gov

202-366-5124