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PT Notes

EPA RFI - Emergency Drills

PT Notes is a series of topical technical notes provided periodically by Primatech for your benefit. Please feel free to provide feedback.

On July 24, 2014, the U.S. Environmental Protection Agency (EPA) announced a Request for Information (RFI) seeking comments on potential revisions to its Risk Management Program (RMP) regulations and related programs to modernize its regulations. Multiple issues were addressed in the RFI.

One of the issues addresses emergency drills to test a source's emergency response program or plan. RMP-covered facilities are required to address emergency response requirements but the requirements do not include emergency drills. EPA believes that exercising response plans is critical to ensure that response personnel understand their roles, local emergency responders are familiar with the hazards at the facility, and the emergency response plan is appropriate and up to date. Also, exercises and drills ensure that personnel are properly trained and they can be used to identify future training needs.

In order to improve coordination with community responders and ensure that facility personnel have practice responding to accidental releases, EPA is considering requiring RMP-regulated facilities to perform exercises or drills as an element of the emergency response program identified in the RMP rule.

Questions posed by EPA on this issue include:

  1. Are RMP-regulated facilities currently conducting exercises with their emergency response plans? If so, are they doing these exercises to comply with other federal, state or local regulatory requirements? What references or guidelines were used to develop the exercise program?
     
  2. What should be the scope of an exercise/drill program? Should the exercise/drill program include internal elements (emergency response, notifications, and evacuation) and external elements (involving community and federal and state responders, as appropriate)? What elements should be exercised as part of the exercise/drill program? For example, should the program include communications, coordination, logistics, and evacuations/accounting for personnel, etc? What response scenarios should be considered for the exercise/drill program?
     
  3. How frequently should exercises/drills be performed?
     
  4. Who should be involved in the exercise program? How should the management team be engaged as part of the exercises/drills? How should contractors be included in the exercise/drill planning and when conducting exercises/drills? Who should be the designated official responsible for coordinating the exercises and drills conducted at the RMP facility? How should other federal, state and local agencies be included in the exercise/drill program? Should all RMP facilities be required to participate in some type of exercise/drill program or only those that are required to develop an emergency response program? Should Program 1 facilities, and Program 2/Program 3 facilities that do not respond to accidental releases with their own employees, be required to conduct external exercises with community responders and test notification procedures? Should Program 2 and Program 3 facilities whose employees respond to accidental releases conduct both internal and external exercises?
     
  5. How should lessons learned and recommendations be documented and addressed? What timeframe should be considered for completing such records? How long should records of exercises/drills be maintained?
     
  6. Should stationary source operators be required to document and address lessons learned and recommendations when they respond to an actual accidental release?
     
  7. Should information such as the date of the most recent exercise involving the emergency response plan be required to be reported to EPA in the facility's RMP?
     
  8. What would be the economic impacts and paperwork burden of requiring an exercise/drill program for all or a subset of RMP facilities? Would such a requirement substantially improve preparedness for dealing with emergency situations? Are there any special circumstances involving small entities that EPA should consider with respect to an exercise/drill program?

Further details on this issue are provided in EPA's RFI which can be accessed by clicking here.

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