A discussion of ICPs describes the benefits of an integrated contingency plan,

regulations this plan addresses, and ways to create a user friendly plan
By Adam H. Steinman and Nimrata K. Hunt, Ph.D., P.E.

Integrated Contingency Planning Promotes Efficient Emergency Response at Mills

The ICP approach offers pulp and paper mills the opportunity to consolidate their stand-alone emergency response and accident prevention plans, addressing all emergency response planning requirements that apply to mills under the various federal, state, and local laws. In most cases, a single, well-written ICP from a person with a thorough understanding of regulatory requirements and mill responses can cost less and provide better emergency response guidance. Also, mill personnel find it easier to be committed to one document instead of many.

If the ICP is written with the end user in mind, the mill gets a document that everyone can understand and use — and one that serves as a great tool for conducting training and drills. Involving personnel responsible for the final implementation of the ICP during the development of the plan increases their comfort level and sense of ownership. Most mills see an improvement in overall safety management and regulatory compliance because the personnel understand and endorse the plan.

The ICP approach is also the federally preferred method for facilities to meet their emergency response planning obligations. Moreover, if existing plans are outdated, inaccurate, or generally not providing effective assistance, drafting an ICP can provide mills with an excellent opportunity to cost effectively consolidate and update their emergency planning and accident prevention plans.

BENEFITS OF THE ICP APPROACH. An ICP consolidates all applicable emergency response and contingency plans into a single, easy to understand, and concise document. The goal of an ICP is to satisfy several complex requirements from different regulating agencies, while improving a mill’s ability to respond to a crisis. Addressing all emergency response plan requirements in one integrated plan can save a mill time and money, increase employee and community confidence in the mill’s ability to handle potential emergencies, and satisfy all overlapping state and federal emergency response planning requirements.

Mills that have already integrated their overlapping emergency response and prevention plans into one ICP, in most cases, have found that the streamlined plans: (1) are easier to use, (2) provide better response guidance, (3) are less expensive and easier to maintain, and (4) provide enhanced regulatory compliance over the multiple plans that had existed. In addition, mills that included personnel with significant plan implementation responsibilities in the ICP drafting process have found that those persons actually use and trust the ICP, as opposed to prior documents that were never opened unless the facility was subject to a compliance audit by a regulator or an internal auditor.

A common trend in several mills is that the environmental and safety departments view their response plans as mutually exclusive documents. However, most of the requirements of OSHA and EPA response plans are interrelated and overlap in several areas. In almost all cases, the ICP helped build a bridge between the two departments, and eliminated contradictory and outdated information. In addition, organizing the information into an ICP format made most other departments aware of their respective inspection, maintenance, and response duties.

REGULATIONS ADDRESSED IN AN ICP. All mills are required to adopt emergency response or accident prevention plans pursuant to at least two of the federal planning regulations listed in Table 1.

Facilities are required to have an Oil SPCC if the amount of oil stored in the facility exceeds EPA’s preset limits for aboveground or underground storage. Most pulp and paper mills are near rivers, so the chances of a spill getting to navigable waters are very high. Mills might have to include an oil response plan, pursuant to 40 C.F.R. Part 112, if it is established that the mill could cause substantial harm to the environment by discharging into navigable waters or adjoining shorelines.

The Risk Management Plan Rule applies to all paper mills that have stationary sources containing certain common paper industry chemicals (i.e., chlorine, chlorine dioxide, propane, and ammonia) above threshold quantities. OSHA gives facilities an option between providing an Emergency Action Plan, if they won’t respond to spills, and an emergency response plan, if they will respond to emergencies. Since most mills have their own Hazardous Material (HazMat) teams and fire brigades, they fall under the requirements of an Emergency Response Plan.

Among the requirements in the rules just cited and in Table 1, there is considerable overlap in the information that must be provided. For example, most plans must describe a facility’s internal and external notification procedures, emergency response procedures, employee training programs, evacuation routes, and a list of emergency response and personal protection equipment. In addition, many state laws require similar plans.

In addition, some mills that have devices containing radioactive substances such as Cesium 137 and Americium 241 have elected to include response and reporting procedures for radioactive substances in the ICP to satisfy the requirements of the U.S. Nuclear Regulatory Commission (NRC) and applicable state regulations.

EXISTING REGULATORY GUIDANCE. In 1996, the National Response Team (NRT) published guidance providing regulatory support and a flexible framework for facilities to consolidate their emergency response plans. The NRT is comprised of the EPA, Department of Transportation, Department of Labor, Department of the Interior, OSHA, U.S. Coast Guard, Minerals Management Service (MMS), and the Research and Special Programs Administration.

NRT’s guidance suggests organizing an ICP into three main sections: (1) plan introduction, (2) core plan, and (3) response annexes. The plan introduction should include the statement of purpose, areas covered by the plan, general facility information, facility contacts, and current revision date.

The guidance structure of the core plan and response annexes is based on the National Interagency Incident Management System (IMS) Incident Command System (ICS). This system is commonly used in emergency responses by federal, state, local, and private emergency response organizations. The core plan is intended to contain a facility’s basic emergency response procedures and, depending on the size of a facility and the number of potential hazards, frequent references to response annexes. The annexes would include, in part, emergency response procedures for potential emergencies at a specific facility. For example, a mill that receives oil by water could describe general response procedures in the core plan and specific responses for oil spills occurring during oil delivery in a response annex.

As more and more mills start going with the ICP approach, they have found that strict adherence to the guidance results in duplication of efforts, defeating the purpose of an ICP. For example, the guidance encourages the core plan and response annexes to be complimentary, address the same issues—albeit to different levels of detail—and include frequent cross references between its sections and other plans that may be incorporated by reference. Inclusion of the same information in two or more places in one plan will require responders to flip back and forth, and citations to an entirely separate document may result in more wasted time.

During an emergency, lost time can lead to the loss of lives, property, and increased damage to the environment. Accordingly, mills should analyze whether it is better to provide general information on a subject in a core-plan, supplemented by more detailed information on the same topic in a response annex or separate incorporated document, as opposed to devoting one plan section to a subject and including different levels of detail within that section.

The main objective of an ICP is to provide emergency responders with all relevant information in the quickest and most efficient way possible. Consequently, over the past few years, several ICP formats have emerged that deviate considerably from the NRT guidance. Several pulp and paper mills in Maine, New York, Ohio, and Michigan have developed ICPs that are organized in a more chronological order, which significantly reduces duplication.

Irrespective of what format a mill decides to adopt, the ICP must independently satisfy all applicable regulations. The rest of this article provides suggestions and ideas for drafting an ICP that will provide effective guidance to a third-shift paper mill operator discovering a spill at midnight, as well as an incident commander directing response activities during an emergency, while meeting all applicable plan requirements.

DRAFTING A USER-FRIENDLY PLAN. The first step in drafting an integrated plan is to define the scope. This entails identifying the applicable state and federal requirements that the mill will address in the plan. The NRT guidance is helpful in identifying potentially applicable federal laws. However, some of these laws will not apply to all mills and the guidance does not address applicable state laws. Producing a table identifying applicable requirements in columns with overlapping requirements listed on the same row typically helps delineate the topics that must be addressed (Table 2).

Once the scope is defined, the plan’s outline should be determined. While a mill may choose to follow the format used in the NRT guidance, it does not have to. In addition, a mill may need to incorporate applicable state requirements. Many mills have found adherence to the NRT format problematic and have elected to organize the plan chronologically to follow the way they address emergency response planning, with facility information and pre-emergency planning sections first, followed by emergency response procedures, and then post-emergency follow-up.

Facility information. This ICP section provides a brief description of the mill operations, identifies the laws that are applicable to the mill, lists the internal and external plan recipients, and has the Management Approval/Promulga-tion Statement. Since most mills have ancillary operations such as steam generation, water treatment, and wastewater treatment, this section also identifies other areas covered by the ICP.

Pre-emergency planning. The pre-emergency planning portion of the ICP describes the systems and procedures in place to (1) prevent emergencies, and (2) equip the mill response employees to handle likely mill emergencies.

For example, a mill can list all the regulated bulk chemical and petroleum storage tanks and the secondary containment and other spill prevention measures for each tank. This list helps determine if any of the tanks have inadequate secondary containment and if any additional measures must be implemented to prevent or control a tank spill.

Other areas covered under pre-emergency planning can include: the mill’s inspection and preventive maintenance procedures, spill detection equipment, alarms, communication systems, emergency response equipment, personnel protection equipment, employee training programs, duties of emergency response personnel, and key phone numbers.

Mills that are large quantity hazardous waste generators and/or use personnel to respond to emergencies must have mutual aid agreements with any public outside entity that may be called on to provide response during an emergency (fire department, police department, ambulance, and hospitals). The pre-emergency planning sections require extensive data gathering and the person preparing the ICP may want to start by making check-lists of all the information required.

Emergency procedures. This portion of the plan describes the procedures followed by the mill from the time when an employee discovers a spill until an emergency no longer exists. Topics covered include: procedures for notifying internal emergency response personnel of a potential emergency; guidelines for recognizing and characterizing an emergency; internal notification and warning of employees; notification of outside emergency responders; emergency response procedures; evacuation procedures; site security and control; and decontamination procedures.

This is the most critical part of the plan and should be very clear and easy to read. All the relevant information should be readily available to the emergency response personnel in the form of checklists, tables, and flow charts.

Post emergency. The ICP should describe how an emergency incident is terminated at the mill. Procedures for notifying federal, state, and local officials during an emergency should be outlined, and all relevant phone numbers should be listed. Any forms that might have to be filled out as a result of the incident should be included along with the procedures. Several mills have found it very helpful to include checklists of the information that each notified agency will require. An incident critique meeting should follow every emergency at a mill and the lessons learned should be incorporated in the ICP, keeping it a current, working document.

Miscellaneous sections. Since all mills have employees potentially exposed to hazardous chemicals, OSHA requires a mill Hazard Communication Plan. This plan typically is a stand-alone document. However, many mills are electing to include it as a chapter in their ICP. This plan can be included either in the body of the ICP or as an appendix to keep it separate from the emergency response information.

Mills store and use hundreds of hazardous chemicals in various quantities. Usually, most smaller spills occur in the operation areas and might never come to the attention of the environmental department. Because of this, mill operators should be provided with, and trained on, tools that can help them in determining if the spill has exceeded a reportable quantity (RQ) and should be reported to regulatory agencies.

To help operators, include a quick and easy reference in the ICP that consists of a table that lists federal and state RQs of hazardous substances used at the mill, such as chlorine, chlorine dioxide, hydrogen peroxide, phosphoric acid, and black liquor. The RQ for a substance should be based on the conservative value calculated from the highest possible percentage of each hazardous substance in a mixture, and the lowest applicable individual RQ for all of the hazardous constituents contained in the mixture. RQs should be listed in pounds and gallons (for liquids).

Other helpful hints. The easiest way to draft an ICP is to begin by compiling all existing information on each subject. If a mill will rely on existing plans, it is imperative that the information in the existing plans is accurate and current. Many mills have provided outside plan writers their existing plans and received draft integrated plans that were legally compliant, but ones that contained outdated information that did not correspond to the current operations. This scenario has lead to mills incurring unnecessary costs and frustration on the part of mill personnel, as well as the outside writer. Consequently, mills should confirm that their existing plans contain current and accurate information and should replace outdated information where necessary.

To keep the ICP lean and to avoid duplication, all information pertaining to a particular subject should be kept together. Further, the information should be made easily accessible with a thorough table of contents and section tab dividers with identifying text. This facilitates the quick location of specific information during an emergency, as well as during a general review of the plan.

To make updating the plan easy, tabulate the information that changes frequently, such as names and telephone numbers. Some mills add figures and tables at the end of each section, while others choose to include them with the text.

Always place oversized maps at the end of the document to prevent the plan from getting unmanageable. Mills usually have numerous evacuation maps and including them all in the ICP may make the plan too bulky. Therefore, a mill might choose to either select a few critical evacuation routes to include in the plan or add another volume for appendices that include all maps. It is important that the evacuation maps are displayed in appropriate areas in the mill and employees are made aware of them.

Since most regulations have different terminology for similar things, the mill should decide which terms to use and add a footnote to cite other terminology. For example, EPA, USCG, and DOT/RSPA oil response plan rules identify persons charged with coordinating oil spill responses as “qualified individuals.” EPA hazardous waste rules identify persons charged with overall response activities as “emergency coordinators,” and OSHA emergency response plan rules identify persons charged with directing emergency response as “incident commanders.” A mill may decide to use the term “emergency coordinator” and then add a footnote stating that this person would have the same roles and responsibilities as a “qualified individual” or an “incident commander.”

A regulatory requirement cross reference table should be included in the ICP because it is extremely helpful to compliance inspectors and the mill’s employed or hired auditors. Compliance inspectors typically perform inspections with an issue checklist and would rather read a well organized regulatory matrix and table of contents than read a plan cover-to-cover, hunting for text that satisfies a legal requirement.

Facilities that draft integrated plans internally should consider having a person with expertise on the regulatory requirements perform a compliance review prior to submission to regulators. It may also be helpful to seek comment from public and private emergency responders who may be asked to provide emergency services. At a minimum, the local fire department and other responders should be familiar with potential hazards at a facility and the emergency response system employed by the facility.

To help retrieve emergency response information during an emergency incident, it is helpful to consolidate all the important information in a five to eight page quick reference guide. This guide should have all the relevant phone numbers for internal and external emergency responders, flow-charts for emergency response procedures, immediate reporting requirements, and any other information that might be useful during emergency response. Some mills prefer to use color-laminated sheets to make the quick reference guide stand out from the rest of the plan. The quick reference guide should be able to serve as stand-alone document during an emergency and provide all the relevant response related information.

After a first draft is complete, input should be sought from all personnel with significant implementation responsibilities. This phase tends to lead to frustration—particularly for the person responsible for coordinating the mill’s effort—because everyone who reviews the draft is likely to have valid comments that should be addressed. The frustration is typically worth it, because this process ultimately will lead to an integrated plan that mill personnel believe in and are comfortable with—in part because their concerns are reflected.

Finally, the plan writer should incorporate the various comments, resolve internal conflicts, confirm regulatory compliance, and provide the review team with a second draft for review. There are almost always additional comments on the second draft, but typically far less than the first.

SUCCESSFUL ICP IMPLEMENTATION. Even the best-written ICP will gather dust on the shelves if it is not successfully implemented. If the plant personnel charged with the implementation of the ICP (for example, environmental department, safety department, operations supervisors, and emergency responders) are actively involved during the various developmental stages of the plan, they will feel comfortable and confident in it. They will trust the final plan more because their issues and concerns are addressed. A fully compliant plan drafted by a consultant without significant input from mill personnel will never be embraced them or be widely used during an emergency. Most mills see a marked improvement in overall safety management and regulatory compliance when personnel understand and endorse the final contingency plan.

A plan is successful if everyone buys into it and sees it as a helpful and useful document. The following recommendations will help successfully implement an ICP:

• Mill management should be committed to the ICP and should be willing to devote the necessary resources for its implementation.

• Once the ICP has been finalized, there should be an implementation meeting and a training session to make the appropriate mill personnel familiar with the various elements of the plan.

• As described earlier, a quick reference guide that the emergency responders can pull out during an emergency should be provided in a separate pocket at the beginning of the plan and should contain all crucial information for responding to the emergency. The HazMat team and other emergency response personnel should familiarize themselves with the information in the guide. This can save precious minutes during an emergency. This guide should also be used during drills to ensure that all relevant information has been included.

• A detailed table of contents helps internal and external plan users and auditors locate important information quickly.

• Besides being present in key locations in the mill, the ICP should be easily accessible to mill employees. Several mills now have online safety training. The ICP can be kept in the vicinity of the computer terminal and the training can be used to guide someone through the key aspects of the plan.

• There should be a designated person responsible for updating the plan. This person is the champion of the plan, and can have a team that meets on a regular basis to address any deficiencies that need to be addressed. This person will be responsible for keeping the plan updated and issuing amendments to all recipients of the original plan.

• Send a copy of the ICP to the local fire department and the hazardous incident response teams. This will make them familiar with the plan and make them aware of potential hot spots at the mill. Mills might choose to invite representatives from the local fire department and their HazMat response teams to participate in plan training.

• To keep things simple and minimize confusion, provide all plan recipients with complete copies of the plan. Send out amendments to all plan recipients with a memo asking them to replace their existing pages with the new pages in order to keep their personal copies current and updated.

Adam H. Steinman is the vice president of regulatory compliance and Nimrata K. Hunt, Ph.D., P.E., is a project engineer at Woodard & Curran Inc., Portland, Maine.

Note: This story has been revised from the printed edition.