Contingency Planning Including Emergency Procedures

INTRODUCTION

Operators shall evaluate existing and new operations in­volving hydrogen sulfide and sulfur dioxide to determine if contingency plans, special emergency procedures, and/or training are required. The evaluation process shall identify potential emergencies and their impact on operating person­nel and the general public. The contingency plan, if required, shall conform to all applicable local, state, and federal regu­lations regarding notifications, precautions, evacuations, and other requirements (refer to 40 Code of Federal Regulations Part 264, Subpart D; 29 Code of Federal Regulations Part 1910.120; and 29 Code of Federal Regulations Part 1910.38 for EPA and OSHA requirements, respectively, for contin­gency plans and emergency procedures).

SCOPE

The contingency plan should contain emergency response procedures that provide an organized immediate action plan for alerting and protecting operating personnel and the pub­lic. Contingency plans should be site specific for the facility operations and should consider the severity and extent of the anticipated atmospheric hydrogen sulfide and sulfur dioxide concentrations. Contingency plans should consider the dis­persion characteristics of hydrogen sulfide and sulfur dioxide (refer to Appendix С or other recognized dispersion mod­elling techniques). Contingency plans should contain provi­sions for all applicable items listed in this section. (Refer to Hazardous Materials Emergency Planning Guide, NRT-1, and Technical Guidance For Hazards Analysis. In addition to the contingency plan, Sections 302 and 303 of the Superfund Amendments and Reauthorization Act of 1986 (SARA Title III) can require a facility operator to name a facility emer-

gency coordinator to work with a local emergency planning committee (LEPC) in the development of an emergency re­sponse plan (refer to 40 Code of Federal Regulations Part 355).

AVAILABILITY OF PLAN

The contingency plan shall be available to all personnel responsible for implementation, regardless of their normal location assignment.

PLAN INFORMATION

Contingency plans should contain, but not be limited to, information on the following subjects, as appropriate:

a. Emergency Procedures:

1. Responsibilities of personnel (refer to Par. 7.5).

2. Immediate action plan (refer to Par. 7.6).

3. Telephone numbers and communication methods (re­
fer to Par. 7.7).

4. Locations of nearby residences, businesses, parks,
schools, churches, roads, medical facilities, etc.

5. Evacuation routes and road block locations.

6. Safety equipment and supplies available (e.g., number
and location of breathing equipment).

b. Characteristics of Hydrogen Sulfide and Sulfur Dioxide:

1. Refer to Appendix A for hydrogen sulfide characteris­
tics.

2. Refer to Appendix В for sulfur dioxide characteristics.

c. Facility Description, Maps, and Drawings:

1. Plants.

2. Water injection stations.

3. Wells, tank batteries, gas conditioning facilities, flow-
lines.

4. Compression facilities.

d. Training and Drills (refer to Par. 7.8):

1. Responsibilities and duties of essential personnel.

2. On-site or classroom (tabletop) drills.

3. Informing nearby residents on protective measures in
emergency situations, as appropriate.

4. Training and attendance documentation.

5. Briefing of public officials on issues such as evacua­
tion or shelter-in-place²⁰ plans.

RESPONSIBILITIES OF PERSONNEL

The contingency plan shall outline responsibilities and du­ties of all essential personnel. Visitors and other non-essen­tial personnel should be prohibited from remaining in or entering an area contaminated by hydrogen sulfide exceed­ing an atmospheric concentration of 10 ppm or a concentra-

tion of sulfur dioxide exceeding 2 ppm in the atmosphere (refer to Par. 4.1 and Appendices A and B).

IMMEDIATE ACTION PLAN

Each contingency plan should contain a condensed "Im­mediate Action Plan" to be followed by designated person­nel any time they receive notice of a potentially hazardous hydrogen sulfide or sulfur dioxide discharge. For the protec­tion of personnel (including the general public) and abate­ment of the discharge, this "Immediate Action Plan" should include, but not be limited to, the following provisions:

a. Alert and account for facility personnel.

1. Move away from the hydrogen sulfide or sulfur diox­
ide source and get out of the affected area.

2. Don proper personal breathing equipment.

3. Alert other affected personnel.

4. Assist personnel in distress.

5. Proceed to the designated emergency assembly area.

6. Account for on-site personnel.

b. Take immediate measures to control the present or poten­
tial hydrogen sulfide or sulfur dioxide discharge and to elim­
inate possible ignition sources. Emergency shutdown
procedures should be initiated as deemed necessary to cor­
rect or control the specific situation. When the required ac­
tion cannot be accomplished in time to prevent exposing
operating personnel or the public to hazardous concentra­
tions of hydrogen sulfide or sulfur dioxide, proceed to the
following steps, as appropriate for the site specific condi­
tions.

c. Alert the public (directly or through appropriate govern­
ment agencies) that may be subjected to an atmosphere ex­
posure exceeding 30 ppm²¹ of hydrogen sulfide or 10²¹ ppm
of sulfur dioxide.

d. Initiate evacuation operations.

e. Contact the first available designated supervisor on the
call list (refer to Par. 7.4.a). Notify the supervisor of circum­
stances and whether or not immediate assistance is needed.
The supervisor should notify (or arrange for notification of)
other supervisors and other appropriate personnel (including
public officials) on the call list.

f. Make recommendations to public officials regarding
blocking unauthorized access to the unsafe area and assist as
appropriate.

g. Make recommendations to public officials regarding
evacuating the public and assist as appropriate.

h. Notify, as required, state and local officials and the Na­tional Response Center to comply with release reporting re-

Emergency Response Planning Guide Level 2 (ERPG-2), refer to Refer­ence 27. ERPG-2 is defined as the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair an individual's ability to take protective action.

quirements (i.e., 40 Code of Federal Regulations Parts 302 and 355) (refer to Par. 4.4).

i. Monitor the ambient air in the area of exposure (after fol­lowing abatement measures) to determine when it is safe for re-entry.

Note: This sequence (Par. 7.6) should be altered to fit the prevailing situa­tion. Certain actions, especially those dealing with the public, should be co­ordinated with public officials.

EMERGENCY TELEPHONE LISTS

A list of emergency telephone numbers should be pre­pared and maintained as a part of the contingency plan, con­sidering the need to contact any of the following:

a. Emergency Services

1. Ambulances

2. Hospitals

3. Medical personnel (e.g., doctors)

4. Helicopter services

5. Veterinarians

b. Government Agencies and Contacts

1. Local Emergency Planning Committee

2. National Response Center

3. State Emergency Response Commission

4. State and Local Law Enforcement Agencies

5. Civil Defense

6. Fire Departments

7. Other applicable government agencies,
с Operator and Contractors

1. Operator personnel

2. Contractor personnel

3. Applicable service companies
d. Public

 TRAINING AND DRILLS

The value of training and drills in emergency response procedures for oil and gas operations involving hydrogen sulfide or sulfur dioxide cannot be over emphasized. All per­sonnel identified in the plan shall have appropriate training. It is important that the training conveys a full appreciation of the importance of each role and the effect that each person has on implementing an effective emergency response.

Exercises or drills that simulate an emergency in which personnel perform or demonstrate their duties are important tools that can convey the importance of contingency plans and result in their being kept current. The exercise can be a tabktop or classroom discussion; or can be a realistic drill in which equipment is deployed, communication equipment is tested, and "victims" are sent to hospital facilities with sim­ulated injuries. Public officials should be informed of (and preferably involved in) these exercises. After a plan is tested, it should be revised and retested until those responsible for the plan are confident the plan is operational. Refer to NRT-1: Hazardous Materials Emergency Planning Guide.

UPDATING PROVISIONS

A contingency plan shall be periodically reviewed and up­dated any time its provisions or coverage change (refer to Par. 9.24).