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As facilities and operations expand, owners and operators often find themselves regulated under many different laws, regulations, and agencies. This can result in diverse plans addressing a broad range of emergency response activities that, while often redundant, remain separate and disconnected. Not only is this a huge waste of resources for environmental management staff, it can also cause confusion during emergencies when response personnel are faced with sorting through multiple plans to determine appropriate response actions.
To help minimize this confusion, the NRT developed guidance to help facilities voluntarily prepare an ICP or “One Plan” that integrates all required emergency response plans into a single document for use during releases of “oil and nonradiological hazardous substances.” In the Guidance, the NRT cites many different regulations that require such plans, including those promulgated by the:
- Environmental Protection Agency (EPA),
- Occupational Safety and Health Administration (OSHA),
- Department of Interior (DOI) Bureau of Safety and Environmental Enforcement (BSEE),
- United States Coast Guard (USCG), and
- Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA).
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As a result, one ICP can conceivably cover response activities on- and offshore as well as from sources aboveground or belowground at a single facility. Not only will this help to expedite appropriate timely emergency response, it will also “improve economic efficiency for both the regulated and regulating communities.”
The key aspect of an ICP is that it is designed to be a “functional” emergency response plan. So although it is one plan, it must encompass all applicable regulatory requirements and ultimately combine them so that the end product is a valuable, easy-to-use plan for all responders in the event of an emergency. To further enhance the usefulness and success of an ICP , the “ICP concept” should also permit coordination of facility plans with plans that are maintained by local emergency planning committees (LEPCs) as required under the Emergency Planning and Community Right-to-Know Act, Area Committees designated by the Oil Pollution Act of 1990 (OPA), and other mutual-aid and cooperative organizations.
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Many states also have requirements and assistance programs for facilities and the NRT guidance also notes that in some cases, an ICP may actually be integrated with local, state, and federal plans, especially those for larger facilities with greater potential to impact “public health, worker safety, the environment, and property.”
Within the NRT guidance document is a suggested ICP format that, while not required, is designed to be flexible for facilities of all sizes and with both simple and complex regulatory responsibilities. The goal of this document format, according to the NRT, is “not to create new planning requirements, but to provide a mechanism to consolidate existing concepts into a single, functional structure.”
The format has three primary sections:
- Introduction,
- Core Plan, and
- Annexes (1to 3 containing Response Critical information and 4 to 8 containing noncritical information such as compliance and background planning information)
While the Introduction section contains general facility information, the Core Plan and Annex sections are based on the National Interagency Incident Management System (NIIMS) Incident Command System (ICS), which is the primary system in use by local, state, and national emergency response organizations. Facilities may choose to incorporate the NIIMS ICS by reference within their ICP that will “allow the plan to dovetail with established response management practices, thus facilitating its ease of use during an emergency.”
The NRT also notes that the flexibility of the format also allows smaller, less regulated facilities to “include most if not all of information within the core plan “consistent with the goal of keeping the size of the ICP as manageable as practicable …” keeping in mind that “a rule of thumb is that the core plan should fit in the glove box of a response vehicle” and should provide “information that is time critical in the earliest stages of a response and a framework to guide responders through key steps necessary to mount an effective response.”