IIAR Ammonia Refrigeration Education and Training Program

IIAR Ammonia Refrigeration Education and Training Program

Ammonia SafetyModule 5 - Making the

First 30 Minutes of Emergency Response Count

Ammonia SafetyModule 5 - Making the

First 30 Minutes of Emergency Response Count

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© 2014 Copyright International Institute of Ammonia Refrigeration

Ammonia Safety

Module 5—Making the First 30 Minutes of Emergency Response Count

Terms and DefinitionsAEGL: The EPA recommends the use of Acute Exposure Guideline Levels (AEGLs) to describe the risk to humans resulting from once-in-a-lifetime, or rare, exposure to airborne chemicals. The National Advisory Committee for the Development of Acute Exposure Guideline Levels for Hazardous Substances provides these guidelines to help national and local authorities, as well as private companies, deal with emergencies involving spills or other catastrophic exposures. See http://www.epa.gov/oppt/aegl/pubs/process.htm for details.

ATSDR: The Agency for Toxic Substances and Disease Registry provides a toxicological profile that succinctly presents toxicologic and adverse health effects information for hazardous substances for the emergency response community. See http://www.atsdr.cdc.gov/substances/toxsubstance.asp?toxid=2 for details.

Buddy System: A system of organizing employees into work groups in which each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency. Paragraph 1910.120(q)(3)(v) of HAZWOPER requires that “operations in hazardous areas (emphasis added) shall be performed using the buddy system in groups of two or more.” In addition, paragraph 1910.120(q)(3)(vi) states that “back up personnel shall stand by with equipment ready to provide assistance or rescue.”

CAN Report: The Conditions, Actions, and Needs report is a size-up report delivered to the incoming public safety officer-in-charge, and for any other command team member that may be assuming command of the incident.

Command and Operations Zone: Also known as the Green Zone or the Cold Zone, it is the location of the Command Post and Operations as pictured on the 30-Minute Plan.

Command Team: Designed to engage during the first 30 minutes of an emergency and integrate with public safety responders to manage all four phases of emergency response.

Plant IC: In charge of coordinating and leading Plant response team operations, with emphasis on the creation and oversight of incident action plans used during Discover, Initial Response, and Sustained Response of the emergency.

Lead Responder: In charge of operations within the Red Zone (Exclusionary Zone) with the specific role of engaging life safety, rescue, decon and emergency shut-down.

Notification Unit Leader: In charge of handling notifications and incoming communications, documentation of the incident, scribe functions at the Command Post, and information and situation status reporting to the Plant IC and Command Team.

Evacuation Group Supervisor: In charge of moving all non-emergency responders to safe refuge; manages personnel accountability (location and status of all personnel), access control, and monitors on-site plume movement.

Plans Section Chief: Used during Sustained Response to create an accurate situation status report, hazard analysis, and future Incident Action Plan options for the Incident Commander.

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Contamination Reduction Zone: Also known as the Yellow Zone or Warm Zone. The corridor is where contaminated equipment is dropped, personnel are given proper decontamination (air for vapor and water for skin burns), and is located at least 100’ to 150’ between the Red and Green zones.

Danger Area: Relates to the conditions that an Operator (who may also be a responder) may be exposed to that is above the normal service and maintenance threats, such as chemical exposure, arc flash, or fire threat. Imminent danger exists when exposure limits threaten to exceed the limits of the Operator’s personal protective equipment and the Operator’s ability to assess the hazards, risks, and threats of the potential emergency event. The Operator must assure that those personnel who may be exposed to dangerous circumstances are moved to a safe area BEFORE considering incidental control and/or emergency shut-down while working in or near to the danger area.

Emergency Action Plan: Required by EPA for all facilities with 500 pounds or more of ammonia. At 10,000 pounds the facility is mandated to create Risk Management and Process Safety Plans that clearly define and mitigate on-site hazards, risks and threats, and identifies off-site receptors.

Emergency Response Plan: Required by EPA and OSHA when the Plant responders are expected to engage emergency operations within the danger Area.

Emergency Shut-Down: In accordance with 40 CFR 68.52 (b) (4) and 40 CFR 68.69 (a) (iv), facilities are required to prepare written emergency shutdown procedures for use by operators and emergency responders. The shutdown procedures should include the following: a manual of operating instructions, a system drawing showing the location of integral parts of the emergency shutdown procedure, the procedure to shut down the system for an extended periods of time, and subsequent startup procedures. A table of the ranges of safe operating parameters measured at crucial meter locations, safety procedures to be exercised at various locations, and locations for recharging the system, as well as the specifications of the charge materials should also be available to the Operator.

Exclusionary Zone: Also known as the Red Zone, Hot Zone, or Isolation Zone. The perimeter of the Isolation Zone is at the AEGL-2 level. The Protective Action Zone extends downwind of the Isolation Zone where conditions require protective action (between AEGL-1 and AEGL-2).

Four Phases of Response: Discovery, Initial Response, Sustained Response, Termination

Hazard Zones: Hazard Zones are used by emergency planners to define locations within the Plant where the effects of the operations could cause a high vulnerability of risk and threat to life safety, environment, and/or property; e.g., the engine room, cold room, roof-top condensers, chemical storage rooms, battery recharge areas, etc.

HRTs: Hazards, Risks, and Threats

Hazards: Chemical and physical characteristics associated with the chemical or specific conditions that may harm an employee while working in or near a dangerous area.

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Risks: When hazards are linked to the potential to injure or threaten life safety, environment, and/or property, risks can be mitigated to reduce the threat levels.

Threats: When hazards and risks present high vulnerability to harm responders, operators, and others working in or near a danger area. Threats include fire, explosion, structural collapse, electrical arc flash, and chemical release.

IDLH: Immediately Dangerous to Life and Health. OSHA regulation (1910.134(b)) defines the term as “an atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual’s ability to escape from a dangerous atmosphere.” IDLH values are based on the effects that might occur as a consequence of a 30-minute exposure.

Incident Command System (ICS): Is a system of command team operations that has been adopted by the fires service, OSHA, and the EPA as the method of command and control of emergency events. For more information see: http://training.fema.gov/is/courseoverview.aspx?code=IS-100.b

Integrated Command: Plant IC becomes a Plant Liaison to the Command Team overseen by the Public Safety IC. Cooperation and communications are closely aligned to a pre-arranged teaming agreement and an understanding of the Plant Emergency Plan objectives.

Unified Command: In the Incident Command System, a Unified Command is an authority structure in which the role of Incident Commander is shared by two or more individuals, each already having authority in a different responding agency.

Incident Action Plan (IAP): An IAP formally documents incident goals (known as control objectives in NIMS), operational period objectives, and the response strategy defined by Incident Command during response planning.

Safety Plan: The Incident Action Plan includes a Safety Plan, identifying the level of PPE, control zones, and safe movement to and from the Hot Zone. The ICS 215a form identifies safety hazards and ICS 208 details a site safety and control plan.

Incidental Response: Actions taken by trained operators to work in a non-dangerous manner to immediately control a hazardous circumstance that could become an emergency event.

Isolation Zone: Is located within a perimeter that is immediately dangerous to life and health (AEGL-2 level of exposure). Life safety concerns are high within the Isolation Zone and emergency responders should not be allowed to enter without proper PPE.

LANCE: An acronym that summarizes the actions taken during the Discovery Phase of an emergency event: Life safety, Alert the Command Team, Notify 9-1-1, Command and control, and Evacuate.

Levels of Concern: A quick method of categorizing an emergency: 1- controlled and contained (small), 2- controlled or contained (dangerous), 3- uncontrolled and uncontained (emergency, out-of-control).

One Plan: Integrated Contingency Plan created by a federally appointed committee to address the emergency response needs that incorporates all concerns into One Plan. For more details see http://www.epa.gov/oem/docs/chem/one-plan.pdf.

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30-Minute Plan: One-page (front and back) checklist of key emergency response concerns to be considered when managing the four phases of response. The goal of the 30-Minute Plan is to stop emergencies when they are small, during the first 30 minutes.

OSHA: Occupational Health and Safety Administration. Federal OSHA may delegate enforcement authority to a state based upon an agreement that the federal minimum levels of safety and health regulatory standards will be applied.

PPE: Personal Protective Equipment ensemble used to protect the employee from the hazards, risks, and threats of the circumstances associated with entry into the work environment and/or danger zone.

Playbooks: Details laid out in pictorial form showing how to accomplish Discovery (LANCE), Initial Response emergency shut-down (SIMPLE), and Sustained Response (advanced SIMPLE) ventilation, containment, and control.

PMP: Prevent (housekeeping), Mitigate (engineered controls), Prepare (for risks and threats).

Position Packets: Each command, operations, and support position appointed by the Incident Commander will have a packet of quick guides, response checklists, forms, and playbooks to improve readiness to play individual roles in sync with the response team.

Pre-Emergency Planning: A plan that meets the employer’s expectations for emergency management of Plant emergency events by employees, contractors, and public safety responders. The employer may choose to engage an Emergency Action Plan (employees working outside of the danger area) or an Emergency Response Plan (when employees are expected to work within the danger area). The level of personal protective equipment, training, and SOPs for proper engagement of emergency response must be documented in the plan.

Pre-Emergency Readiness Checklist: Steps taken to address life safety and emergency response readiness engaged during high-risk maintenance, service, repair, troubleshooting, and during an odor investigation.

Protective Action Zone (PAZ): The area where the public should take protective action, e.g., shelter-in-place or evacuate to a safe refuge; the ammonia ranges from 0.1 to 1.3 miles depending on day or night conditions, wind, weather, terrain, and moisture content of the surroundings.

SIMPLE: An acronym used during emergency shut-down that summarizes the following key concerns; Sources of ignition, Isolation of chemical flow, Management of pressure, Pressurized ventilation, Life safety of the responders, Emergency Action Plan.

Technician Emergency Responder: Title 29 CFR Part 1910.120 (q): Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of entering the danger area to contain and control the release. Hazardous materials technicians shall have received at least 24 hours of training that assures competency in the following areas (as certified by the employer):

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• Know how to implement the employer’s emergency response plan

• Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment.

• Be able to function within an assigned role in the Incident Command System.

• Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician.

• Understand hazard and risk assessment techniques.

• Be able to perform control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.

• Understand and implement decontamination procedures.

• Understand termination procedures.

• Understand basic chemical and toxicological terminology and behavior.

Termination Proclamation: The Incident Commander will proclaim that an emergency event is “all clear” once it is determined that conditions leading to the event have been alleviated, mitigated or contained, and unlikely to reoccur, and that all individuals are accounted for. The IC may establish special safety and security issues to be addressed by the plant management team.

To Review:l Understanding the terminology used to implement an Emergency Plan is

critical to the effective delivery of services.l The Command Team members and those involved with critical operational

engagement of the plant should commit these terms to muscle memory.

Lesson 1Pre-Emergency Planning

Introduction: Ammonia is valuable to the world’s population for its use in agriculture, cold storage, air and water treatment, and as a fuel source.

Ammonia is a natural refrigerant and is recommended by the Montreal Protocols as a “refrigerant of choice” because releasing ammonia to the environment will not harm the atmosphere and environment as much as other carbon based refrigerants. (Fig.1-1)

Question 1-1: Why is such a positive chemical like ammonia feared and regulated with such vigor?

Answer: The smell of ammonia scares humans who don’t have the knowledge and background on how to handle it. Workers, emergency responders, and the downwind receptors must be prepared to manage the hazards, risks, and threats of ammonia.

Those most at risk are the operators of ammonia systems who work on live-ammonia systems or are caught within 10 to 15 feet of a sudden ammonia release without proper personal protective equipment to escape.

It is the employer’s duty to decide the level of safety and depth of emergency response engagement of employees. The Plant’s Emergency Plan will provide a summary of the Plant response strategy and addresses the need for safe work practices and personal protective equipment to be used while engaging the Emergency Plan. (Fig.1-2)

Question 1-2: What is the minimum level of engagement an employer must plan for when dealing with an emergency event?

Answer: The EPA and OSHA have provided regulatory guidelines that define the minimum expectations for Plants that use 500 pounds or more of ammonia. At a minimum, the Emergency Plan MUST address evacuation and movement to safe refuge, rescue and medical care, and emergency shut-down procedures. (Fig.1-2a)

Pre-Emergency Readiness and Incidental Response (Fig.1-3): It is wise to increase preparedness measures when the risks and threats are higher than normal. Pre-emergency preparedness measures such as alerting the Command Team, wearing a higher level of PPE ensemble, and following a Safety Plan should be used when the Operations Team knows that the risks and threats are higher than normal.

Question 1-3: When is it best to engage pre-emergency readiness to address the risks and threats of the ammonia system?

Fig. 1-1 The Value of Ammonia

Fig. 1-2a Plant Team Readiness

Fig. 1-2 Emergency Planning

Fig. 1-3 Pre-Emergency Checklist

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Answer: A higher-than-normal level of risk and threat occurs during times when service or repair operations require the opening of the ammonia system. Risks are also higher when troubleshooting problems. Plant managers often require that early warning detection systems be installed so ammonia detectors give an alert when the odor is low. Pre-emergency readiness should be invoked when operators are investigating an ammonia alarm alert. (Fig. 1-3a)

Incidental Response and Emergency Shut-Down: An emergency event will often occur while working on the ammonia system. The sudden ammonia release will quickly exceed the regulatory limits set by OSHA (25 PPM for most States and 50 PPM federal OSHA), causing a need to escape.

Question 1-4: Can the Operator stay and fix the problem so there is no need to proclaim an emergency event?

Answer: The Operator must be trained and equipped to understand how to read the hazards, risks, and threats of working in a potentially dangerous environment. OSHA regulation gives consideration for employees prepared to engage incidental control as long as the conditions do not become “dangerous” for the employee and for those affected by the incident.

The employer may require Operators who are trained and PPE equipped to control a minor incidental release, while working near the “Danger Area” limit (see definition of Danger Area). Per 1910.38(a), these actions must be planned for in advance, and procedures must be developed and implemented.

The level of readiness for a refrigeration operator using an employer-adopted, Pre-Emergency Readiness standard of operation is much less dangerous than for an operator who is caught in a circumstance with no PPE or back-up support. (Fig. 1-3a and 1-4)

Question 1-5: What determines how long an Operator can stay and work on incidental control and engage emergency shut-down operations?

Answer: There are three key requirements (there will be more on this subject in the next Chapter):

1) The act of controlling the problem must be an obvious and easy to accomplish solution. An emergency response occurs when “a response effort by employees from outside the immediate release area or by other designated responders...to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance.” (Fig. 1-5)

2) Incident conditions must NOT be dangerous to the operator nor to anyone in the Isolation Zone.

3) Process operators must be trained at the Operations level and: (1) understand the Incident Command structure of the plant’s Emergency Plan; (2) wear adequate PPE; (3) have adequate training in the procedures to be performed; and (4) employ the buddy system; may take limited action in the danger area (e.g., turning a valve) before the emergency response team arrives. (Fig. 1-5a-d)

Fig. 1-3a Operator PPE Readiness

Fig. 1-5 PPE Readiness

Fig. 1-4 Team Engagement

Fig. 1-5a NO entry into IDLH

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Question 1-6: How does the use of Pre-Emergency Readiness improve the chances of accomplishing incidental control of a potentially dangerous emergency event?

Answer: The Command Team is ready to engage, having already been warned of the potential for an emergency event stemming from higher-than-normal plant operations. The repair team, including the contractors, is prepared to engage incidental control and emergency shut-down procedures if the situation turns into an emergency event.

Practicing incidental control, emergency shut-down, PPE readiness, decontamination readiness, and Command Team readiness improves the skills needed to engage an emergency event during the first 30 minutes of an incident. The opportunities to stop the emergency when it is small are significant if Pre-Emergency Readiness is used.

Value of Consistency in Emergency Planning: A consistently applied industry standard for how to engage the operational tools needed to deal with emergency events is valuable. The need for higher levels of skill, availability of resources, command structure, operational readiness, and technical information increases as the incident progresses through the four phases of emergency response.

Question 1-7: Why is consistency in emergency response SOPs a high priority?

Answer: Corporate, regulatory, and public safety responders are more likely to support Plant emergency plan playbook operations that are consistently recognized throughout the Nation. The SOPs must abide by the regulatory framework that guides emergency response (EPA) and responder safety (OSHA). The emergency response system is strengthened when all responders consistently follow response practices, such as the Incident Command System, Shelter-in-Place, hazard assessment, and rapid extrication rescue protocols.

A “nationally accepted standard” will support the ability of the local on-site and public safety response teams to support the “Teaming Agreement” expectations such as rapid-entry rescue, emergency shut-down, and safe areas for personnel within the building. (Fig. 1-6)

Final Note: The success of the Incident Command System is largely due to the National Incident Management System (NIMS) requirements that establish the forms, checklists, and command structure that EVERYONE (public and private responders) must use to engage an emergency response.

Fig. 1-6 Tripod Relationship

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Fig. 1-5b Fixing the problem

Fig. 1-5d Containment

Fig. 1-5c Sudden small release

To Review:l Discussion: Consider the value of consistently applied

emergency response operational engagement standards to corporate, public safety, and individual response team members. €l A corporation with multiple Plants located throughout the

country: the value of using nationally accepted standards of operation to engage incidental control, integration of public safety response, and use of nationally accepted checklists, quick guides, and playbooks that support the ability to quickly engage the local response capability on specific Plant challenges

l€ The response contractor and local public safety responders: the value of having a similar format and set of expectations for managing emergency events that occur in all similar Plant operations using ammonia refrigeration

€l The regulator’s ability to use accepted industry standards to judge the grey area concerns associated with emergency response

l Review the definition of “Danger Area” and then define the ability to engage incidental control and emergency shut-down operations.

l Review the definition of “Command Team” positions to be engaged during the first 30 minutes of an emergency; who in your organization could fulfill those positions?

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Lesson 2Recommended Organizational Chart for Engaging the One Plan

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Transition to an Emergency Event

Awareness: The employer’s training program should comply with the Hazard Communication Standard (29 CFR 1910.1200) that requires all employees who work around ammonia to learn how to report an emergency and safely escape the dangers of an ammonia release. Employers are to communicate information concerning hazards and appropriate protective measures to employees, e.g., maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling containers of chemicals in the workplace, and preparing and distributing (or providing access to) safety data sheets to employees and downstream, downwind receptors.

The Employer must engage action to discover, report, and engage immediate life safety and emergency shutdown requirements, as established in an Emergency Action Plan (EAP) when the Plant has more than 500 pounds of ammonia. The EAP must be in writing, kept in the workplace, and available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees. (Fig 2-1)

Question 2-1: Does non-engagement with regard to emergency response mean that the response team has no emergency response duties?

Answer: Non-Engagement establishes the requirements for the response team to engage defensively for incidental control and emergency shut-down while working in non-dangerous locations. Responders must be trained to accomplish their assigned duties as per CFR 29 Section 1910.38 or the employer may choose to certify the Incident Commander and Lead Operator at the Operations level as per CFR 29 Section 1910.120(q) which requires an 8-hour class.

Question 2-2: What level of engagement is required to meet the rescue, medical, escape to safe refuge, and emergency shut-down procedures? (Fig. 2-2)

Answer: The EAP will describe how rescue, decon, and medical subjects are covered by on-site and incoming responders. Facilities relying on local contractor and public safety responders must determine if they have suitable equipment and training to accomplish the required level of engagement. If they do not, the facility may be required by the local authorities to take steps to insure that training and equipment needs to meet the minimum Action Plan requirements. A teaming agreement with the public safety and contract responders is helpful in defining the roles of the incoming responders.

Fig. 2-1 Emergency Planning

Fig. 2-2 Emergency Action Plan

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Minimum elements of an Emergency Action Plan:

Reporting a fire or other emergency;

Emergency evacuation, including type of evacuation and exit route assignments;

Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;

Account for all employees after evacuation; an employer must designate and train employees to assist in a safe and orderly evacuation of other employees.

Procedures to be followed by employees performing rescue or medical duties; and

The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.

Employee alarm system. An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in § 1910.165.

Review of Emergency Action Plan. An employer must review the Emergency Action Plan with each employee covered by the plan when the plan is developed or the employee is initially

assigned to a job. An employer must designate and train employees to assist in a safe and orderly evacuation of other employees. The Plan must also be reviewed when the employee’s responsibilities under the plan change and when the plan is changed. (Fig. 2-3)

Engaging the Emergency Action Plan - Operations Level: (Fig. 2-4) Employees trained at the Operations level may take limited action in the danger area (e.g., turning a valve) before the emergency response team arrives. The training must include: (1) being informed of the Incident Command structure of the plant’s Emergency Plan; (2) donning, doffing, and care of PPE; (3) training in the procedures they are to perform; and (4) how to employ the buddy system. The limited action taken by operators must be described in the Plant Emergency Plan.

Once the emergency response team arrives, these employees would be restricted to the actions that their training level allows. This limited action assumes that the emergency response team is on its way and that the action taken is necessary to prevent the incident from increasing in severity (i.e., to prevent a catastrophe). Employers must inform such employees during their training that they are to evacuate when they lack the capabilities to respond in a safe manner and in accordance with the standard operating procedures defined in the ERP.

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Fig. 2-3 Life and E-Shut-Down

Fig. 2-4 Operation E-Shut-Down

Question 2-3: What are three key issues that clarify the need for emergency response?

Answer: 1) the need to evacuate people from the Isolation Zone; 2) the need to enter IDLH conditions (above 300 PPM) to engage emergency shut-down and/or containment and control; 3) serious threat of fire, explosion, or toxic substance release that could endanger personnel.

Engaging an Emergency Response Plan: If the employer decides to mobilize employees to perform emergency response duties in the danger area the responders must be trained and equipped in accordance with CFR 29 Section 1910.120(q) requirements. The employer’s Emergency Response Plan must describe the level of engagement, PPE, and response equipment needed to accomplish the emergency response objectives. Employees who are expected to enter the danger area and/or create and implement action plans that require others to enter the danger area must be trained as Technician Commanders and/or responders. The Plant Emergency Planner should coordinate and conduct joint training with contractors and public safety responders who are expected to integrate into the Plant emergency response effort. (Fig. 2-5 a, b)

Question 2-4: Is the circumstance in Fig. 2-6 an emergency event? What are the Operator’s choices if he/she is first on scene? (Fig. 2-6)

Answer: The first size-up of the incident pictured in Fig. 2-6 would indicate that the incident is an emergency event. The trained operator must decide the appropriate action - incidental control or evacuate.

The Operator will evaluate the hazards, risks and threats of the ammonia release. If the Operator works in or enters a dangerous environment to engage emergency shut-down or containment and control operations he/she must do so under the guidance of a Technician-level Emergency Response Plan. Technicians require a higher level of training (24 hours) and PPE readiness as defined in 29 CFR 1910.120(q). The PPE requirements, especially respiratory equipment, are located in 29 CFR 1910.134.

YOUR life safety is always the first concern – protect yourself and escape harm so that you can alert the Response Team and then work as a team to effectively help others. (Fig. 2-7)

Acting decisively means that everyone on the team, especially the Command Team, is in sync and ready to act with regard to life safety and emergency shut-down.

All response team members must have the knowledge and ability to accomplish their personally assigned emergency response role. All Command Team members and responders must be able to recognize the hazards, risks, and their vulnerability to the threats. The responders and command team members must know the limitations of the personal protective equipment of those working in the danger area.

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Fig. 2-5a ERP

Fig. 2-6 Emergency Event?

Fig. 2-5b ERP

Fig. 2-7 Safety Motto

Question 2-5: What do you do if you encounter problems and aren’t sure what to do? (Fig. 2-8)

Answer: If there is uncertainty about the hazards, risks, and threats, or doubt about the containment and control measures, err on the side of safety and leave the Hazard Zone. Re-group with the Command Team and devise a better plan.

Question 2-6: How can we assure that services of fire, ambulance, law, and environmental responders are in sync with the Plant Emergency Plan expectations of service?

Answer: Integrate command with the fire department so that cooperation and coordination eliminate the need for snap judgments, over-reaction, or lack of support for pre-arranged methods of managing life safety and emergency shut-down. The communication between the first-in fire officer and the Plant IC should be in sync with expectations provided in the pre-emergency planning training and the teaming agreement. (Fig. 2-9)

Review the Lesson 2 video presentation by Chief Coleman, Captain Apodaca, Chief Johnson and Lee Pyle. Discuss the commonly held concerns with regard to the public safety responder’s expectations from the Plant response team. The following are key terms to listen for:

Chief Coleman: The understanding of the value of trust and confidence with regard to the response team’s ability to respond appropriately.

Captain Apodaca: Build relationship with staff; familiarity when we arrive; knowledge about Plant procedures for life safety and emergency shut-down.

Chief Johnson: The value of a walk-through; first-in officers concern about life safety (on and off site); transition of command between first-in officer and the Plant IC, and then with the incoming chief officer.

Lee Pyle explains how far a company should go with its emergency response capacity. There are two positions that are key to engaging the Action Plan: the Plant Incident

Commander and the Lead Responder. Lead Responders operate the system and “fix things.” The Plant IC coordinates the Response Plan with the responders, and integrates command with public safety.

Engaging The Technician-Level Responder should not occur until hazards, risks, and threats are understood by the Incident Command and the PPE ensemble, a buddy system, and the Safety Officer and/or Incident Commander are in position. The Incident Commander must approve entry into the Hot Zone and guide the response with an Incident Action Plan and Safety Plan. (Fig. 2-10)

The teaming agreement between the Plant and public safety should leave no surprise on the timing of response. If Technician (Hazmat Team) services are coming from public safety responders, the response and set-up time can easily exceed an hour. The Plant Emergency Planner will want to understand the

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Fig. 2-8 PPE with a Plan

Fig. 2-10 Emergency Planning

Fig. 2-9 Integrating Command

timing and level of engagement by first-in responders (during the first 30 minutes of the emergency) and assure that support is available to accomplish life safety and emergency shut-down requirements prior to arrival of the team of Technicians who can enter the danger area.

Technician Specialist: (Fig. 2-11) An employee who has special knowledge, skills, and abilities such as operation of systems located within a hazard zone is valuable to the Command Team. A Technician Specialist (24-hour trained) may participate outside the danger area as a member of the command team to provide critical information and support for the creation and implementation of an incident action plan.

To Review:l Discussion: A Plant Incident Commander does not need to be a Technician

IF they do not oversee or engage offensive Action Plan objectives associated with an Emergency Response Plan.

l Make a list of subject matter related to accomplishing the Plant Emergency Plan that requires teaming with contractors and public safety. Develop a training plan for conducting training that builds identity with response expectations.

l Understand what level of training (Awareness, Operations, and Technician/Specialist) is required for Plant employees and responders.

l Understand that an emergency must be proclaimed when any employee or downwind population is at risk.

l Assure that fire service and contract responders understand their roles in supporting the Plant’s emergency response plan expectations. Recognize the value of a written teaming agreement with off-site responders; the teaming expectations must be supported by a regular training plan.

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Fig. 2-11 Contractor Support

Lesson 3Hazard Analysis

In order to engage Pre-Emergency Readiness, Emergency Shut-Down, and the four phases of emergency response the Incident Commander and response team will need to assess the hazards, risks, and threat vulnerability.

The Incident Commander, Lead Responder, and Operators working in the danger area require a high level of reflex capability that is built through training and creating muscle memory to quickly assess the hazards before engaging the response team into dangerous conditions. The key muscle memory capabilities include the following:

Hazards: Chemical/physical characteristics of the chemicals

• Ability to identify the physical form and visual presentation of the four basic types of release: aerosol stream, dense gas cloud, invisible vapor, and liquid

•€ Ability to judge dense gas and invisible vapor movement (vapor density, water solubility, density)

•€ Understand flammability, boiling point, corrosiveness and the warning signs, safety data, and placards

Risks: To life, environment, and property

•€ Ability to escape ammonia and give escape and evacuation direction to those in the danger area

•€ Ability to set the Isolation Zone and Protective Action Zone for an emergency event

•€ Ability to assess life threat to those trapped (needing rescue), sheltered in place, and those responding to an ammonia release

•€ Ability to triage, decontaminate, and medically treat (as a first-responder) those who have been exposed to an ammonia release (and other hazards such as fire and other chemical exposure)

Threats: To responders (fire, explosion, and chemical release)

•€ Ability to judge flammability threat, overpressure, corrosiveness, and cold temperature threats

•€ Ability to judge the proper use of water and the threats of aqua ammonia

•€ Ability to determine the proper safety measures and PPE to protect against the hazards, risks, and threats

16 Module 5

Personal Protective Equipment

Four Levels of Personal Protective Equipment (PPE): EPA and OSHA establish general regulatory reference to Level A, B, C, or D PPE. Each level of PPE has a general application, e.g., Level A protects against the highest level of chemical and respiratory threat; Level B includes self-contained-breathing apparatus (SCBA) and chemical over-suit for protection against low level chemical vapor; Level C includes an air-purifying respirator and full-skin protection for working in less than IDLH (300 PPM) conditions; and Level D is the work uniform with protection for day-to-day work hazards. (Fig 3-1)

PPE Ensemble: Each Level of PPE should be designed by the employer and implemented by the Incident Commander as an “ensemble,” meaning that the Level of PPE must also have protection options added to address the specific hazards and threats of the circumstance. Developing a PPE ensemble that adds protection factors based upon the response risk and threat circumstances is referred to as performance-based compliance. (Fig. 3-2)

Question 3-1: Who determines the level of PPE worn in the work environment and on a chemical emergency response event?

Answer: The employer has the duty to define the type of PPE worn during the workday to protect against process hazards. The employer is also responsible to provide appropriate PPE to protect responders for the level of engagement that the employer’s Emergency Plan may require. The Incident Commander approves the level of PPE and safety required to achieve the Incident Action Plan objectives (Fig. 3-3). Employees must be trained, medically cleared, fit-tested, and be physically fit to wear the PPE.

A Level A and/or Level B ensemble including positive-pressure SCBA must be used as a baseline for responder protection while working in the danger area (Hot Zone). A positive pressure SCBA is required for entry into ammonia atmospheres at or above 300 PPM (IDLH). Refer to 29 CFR 1910.132 through 1910.138 for personal protective equipment requirements.

Level D - Daily routine operations may involve a clipboard check with NO valve turning or hands-on service or repair. The routine PPE ensemble would include eye and ear protection, safety boots, and an optional bump helmet. (Fig. 3-4a)

The employer would want to step-up the Level D ensemble if the Operator is likely to become exposed to an unexpected chemical release, arc flash, or problem that may occur while doing inspection or system operational adjustments. (Fig. 3-4b)

Module 5 17

Fig. 3-1 Levels of PPE

Fig. 3-3 Plant IC Engagng PPE Plan

Fig. 3-2 PPE Ensemble

Fig. 3-4a Level D PPE

18 Module 5

Level D Ensemble Options to be considered:

Eye Protection: safety glasses and/or chemical splash goggles – no use of contact lenses; a face shield may be worn over safety glasses

Skin and Glove Protection: Coveralls, chemical resistant apron, and gloves

Hearing Protection: Ear plugs or ear muffs

Foot Protection: Boots/shoes (chemical-resistant steel toe and shank)

Head Protection: bump hat or hard hat - Type I or Type II impact requirements. Type I helmets are intended to reduce the force of impact resulting from a blow only to the top of the head. Type II helmets are intended to reduce the force of impact resulting from a blow to the top or sides of the head.

Respiratory: Escape mask (may be stored for quick access or carried)

Responder Safety: Reflective orange or lime green vest that can carry a radio, ammonia detector, and a pocket-sized quick guide for engaging an emergency response

Non-Mandated PPE Ensemble Options: The video shows two examples of advanced (non-mandated) PPE options that the employer may consider for higher levels of protection for emergency responders. (Fig 3-5)

1. Nomex hoods (Nomex is a registered trademark for flame-resistant meta-aramid material developed in the early 1960s by DuPont and first marketed in 1967)

2. An air-purifying respirator that can be transferred to an SCBA regulator if the work environment develops into a higher level of respiratory threat while conducting incidental control, emergency shut-down, and/or emergency escape

Question 3-2: When would it be appropriate to use an escape hood?

Answer: The escape hood is helpful when the daily work area is close to ammonia release risks and threats, and for Command Team members who may unexpectedly be exposed to vapor while engaging their roles. The escape hood can be designed with a

cartridge (protecting to 1500 PPM) or a 10-minute air bottle. It is important to clarify that the escape hood is NOT for entry into a dangerous environment – ONLY escape. (Fig. 3-6)

Fig. 3-4b Level D Options

Fig. 3-5 Non-Mandated Options

Fig. 3-6 Escape Hood

Module 5 19

Level C Ensemble: The PPE ensemble will be upgraded to address the challenges associated with odor investigation, troubleshooting operational problems, and while performing maintenance, service, and repair operations. (Fig. 3-7a-b) In some cases, the risks and threats may be high enough for the Lead Operator to consider using Level A or B emergency response PPE (it’s also great training).

Eye Protection: Same choices as Level D

Skin and Glove Protection: Same choices as Level D with the addition of consideration for Nomex hood, hooded chemical-resistant overalls, two-piece chemical-splash suit, or disposable chemical-resistant overalls; inner and outer chemical resistant gloves

Hearing Protection: Same choices as Level D

Foot Protection: Same choices as Level D plus consideration for outer chemical-resistant boots (disposable)

Head Protection: Same choices as Level D

Respiratory: Same choices as Level D plus full-face or half-mask, air purifying respirators (NIOSH approved), or air purifying respirator with a back-up, self-contained-breathing apparatus to switch to during incidental control measures or during escape from a dangerous environment

Responder Safety: Same choices as for Level D except that an ammonia monitor, radio, and Emergency Plan should be a higher priority, especially when incidental control option is selected (Fig. 3-7c)

PPE for emergency response is an option that the employer must clearly define in the Emergency Response Plan. The Incident Commander and Entry Team Leader will determine a PPE ensemble (Level A and B ensemble) that protects against the hazards, risks, and threats associated with working in the dangerous environment (Hot Zone) before entering to engage an Incident Action Plan. A Situation Status and Pre-Entry Hazard Analysis is to be performed PRIOR to entry into the Hot Zone.

The Entry Team Leader and/or Hazmat Group Supervisor will develop a safety plan that includes: status of the emergency shut-down, rescue and decon readiness, emergency communications, use of the buddy system, PPE ensemble and pre-entry medical evaluation, tracking system for on-air time while working in the Exclusionary Zone, wind and weather conditions, and rehab readiness to evaluate responder fitness (hydrate and rest period prior to considering re-entry).

Fig. 3-7a Level C PPE

Fig. 3-7b Increased Options

Fig. 3-7c Plant IC Approval

Question 3-3: What is the purpose of using Level B PPE rather than Level A?

Level B Ensemble: Used to engage rapid entry rescue, emergency shut-down, emergency ventilation, containment, and control operations within atmosphere of VAPOR (not working in a dense gas cloud or aerosol) not exceeding 5,000 PPM.

The minimum staffing for engaging within the Hot Zone is to have an Incident Commander, who may also serve as the Safety Officer, and a buddy system (prepared for rescue). (Fig. 3-8 a-c)

A 2-in and 2-out buddy system should be used during high-risk operations in which the entry team must search within the Hot Zone while the release is out of control and increasing in intensity (risk and threat).

Special PPE ensemble protection (Level A) is recommended while attempting mitigation efforts when an aerosol dense gas cloud is building in size and intensity.

Eye Protection: MUST wear a self-contained breathing apparatus (SCBA) which will be fit tested to protect the eyes, face, and respiratory system from exposure to dangerous vapor

Skin and Glove Protection: Nomex hood, hooded chemical-resistant overalls, two-piece chemical-splash suit, or disposable chemical-resistant overalls; inner and outer chemical resistant gloves with thermal and chemical resistance when operating free-flowing, leaking or open valves. The vapor protection may be improved by taping the over-suit where arms meet the outer gloves; where the legs meet the boots; and at the throat area where the chemical over-suit meets the SCBA mask.

Hearing Protection: Same choices as Level C

Foot Protection: Same choices as Level C plus consideration for outer chemical-resistant boots (disposable); also thermal protection required if liquid ammonia is located within the Hot Zone

Head Protection: Same choices as Level C

Respiratory: SCBA located inside the chemical suit when higher levels of protection against the thermal threat is needed.

Responder Safety: (Fig. 3-9) The response team must have a pre-entry readiness evaluation by the Safety Officer or Entry Team Leader, and work with a clearly identified Incident Action Plan and Safety Plan. An ammonia monitor is mandatory while working within the Hot Zone. A radio and/or tag line communications and hand signals for escape must be established prior to entry. the on-air entry time must be monitored and warning given for low air movement out of the Hot Zone. The responders must drink water to improve hydration before entry.

20 Module 5

Fig. 3-8a Level B PPE

Fig. 3-8c Maximum level of entry

Fig. 3-8b Taping Level B PPE

Fig. 3-9 Plant IC and PPE Safety

Module 5 21

Question 3-4: What level of safety readiness is required for all entry team members, regardless of their PPE ensemble?

Answer: All responders must be medically evaluated and approved to wear the PPE required of them in the Plant Emergency Response Plan. The employees must be annually fit-tested with their respirators and skill tested to assure they have knowledge and skill for donning, doffing and selection/care of the respirators and PPE equipment. The pre-and-post medical/physical readiness (as per employer policy) and safety plan must be reviewed with the entry team prior to entry into the Hot Zone. The Safety Officer (or Plant IC) will assure that on-air-time is monitored while working in the Hot Zone.

Level A Ensemble: Used to engage as indicated for Level B except that the entry team may engage in higher levels of vapor, and may also have ensembles that can withstand the thermal and flash fire protection associated with aerosol and dense gas releases. Staffing levels may be increased to assure 2-in and 2-out with an Incident Commander and Safety Officer and an optional Entry Team Leader overseeing the entry. (Fig. 3-10a-c)

Eye Protection: Same as Level B

Skin and Glove Protection: Nomex hood, hooded chemical-resistant overalls, two-piece chemical-splash suit, or disposable chemical-resistant overalls; inner and outer chemical-resistant gloves with thermal and chemical resistance when operating free-flowing, leaking or open valves. The vapor protection may be improved by taping the over-suit where arms meet the outer gloves; where the legs meet the boots; and at the throat area where the chemical over-suit meets the SCBA mask.

Hearing Protection: Same choices as Level B

Foot Protection: Outer chemical-resistant boots that are thermal protected to at least -60°F

Head Protection: Same choices as Level B

Respiratory: SCBA must be inside the over-suit

Responder Safety: An ammonia monitor reading the level of ammonia as compared to the protection factor of the entry suit. The Incident Action Plan, Safety Plan, methods of communication, on-air tracking, pre-entry readiness check, and post-entry rehab identified for Level B applies to Level A.

Fig. 3-10a Level A PPE

Fig. 3-10c Working in the Hot Zone

Fig. 3-10b Entry Team

22 Module 5

To Review:l Review OSHA’s PSM Standard - A Plan for Keeping the Ammonia in

the Pipes https://www.osha.gov/dte/grant_materials/fy09/sh-19489-09/mod2task2-trainernotes.pdf

l Evaluate your PPE policy and consider how each Level of PPE ensemble may be enhanced.

l Develop a clear policy on the staffing requirements for engaging action in the Hot Zone. Consider staffing needs for emergency shut-down when risks and threats are building but are not high risk or a threat to the response team versus an entry into an unknown circumstance with a dense gas aerosol present.

l Develop an employee and management company focus on how to match the hazards, risks, and threats within the work environment to the most appropriate PPE ensemble. The PPE ensemble options may be INCREASED to a level of protection deemed necessary for the specific event, e.g., performance-based standard.

l Assure that the public safety responders and OSHA regulators support your PPE policy and level of engagement while working in Level C and D ensembles. The same scrutiny must be applied to Level A and/or B ensembles.

l Evaluate the effectiveness of your radio communications system. Consider utilizing multi-frequency radios (a minimum of one channel for command/operations and another for evacuation and support functions). ASTI recommends that ear microphones be used to enhance the ability to send and receive radio communications.

Module 5 23

Lesson 4Discovery and Initial Response

The readiness to engage the Emergency Plan is dependent on the level of training and the quality of the operational response PPE and tools (e.g., ammonia monitor, radio, valve wrench, containment tarp) provided to those who discover and then respond to the incident.

The Command Team must be ready to address life safety and emergency shut-down within the Discovery and Initial Response phases to stop the problem when it is small. These phases of response are commonly referred to as the “first 30 minutes.” (Fig. 4-1)

The Discovery Phase starts with the first recognition of an incident that is or will soon will be an emergency event. (Fig. 4-2) The first to recognize the problem should be prepared to engage incidental control and/or immediately engage LANCE (Life safety, Alert the Command Team, Notify responders, Contain and control, and Escape/Evacuate the danger zone).

The Discovery Phase will be engaged using a defensive strategy that can be overseen by the Operations-trained Plant Incident Commander and Lead Responder. The Plant IC may depend on the public safety IC or a Technician-trained Incident Commander to take charge when an offensive Action Plan is implemented. This is especially important when a rapid entry rescue is required. (Fig. 4-3)

The employer should consider providing a Technician-level responder with PPE and training to perform rapid entry rescue. The Plant response team must be prepared to do decontamination, and medical treatment in conjunction with the public safety responder support.

ASTI recommends that industrial refrigeration operators be trained to the Technician level (CFR 29 1910.120(q)) with ammonia-specific requirements as a priority. The course should be directly related to the Plant emergency plan and Plant response team members trained on Plant specific hazards, risks, and threats.

The Command Team includes a Notification Unit Leader and Evacuation Group Supervisor. There is tremendous value in having notification, documentation, and evacuation duties handled by specialists who are trained to Awareness or Operations level plus have the skills and confidence to accomplish assigned checklist duties.

The goal of the response effort is to reduce reaction time and increase the effectiveness of the response, especially during the first 30 minutes. (Fig. 4-4)

Fig. 4-1 Discovery and Initial Response

Fig. 4-3 Rapid Entry Rescue

Fig. 4-2 First Report

Fig. 4-4 The Response Goal

24 Module 5

Question 4-1: During Discovery, who will most likely be the First IC?

The discovery process requires that the first supervisor to discover the emergency event must take charge. The supervisor must be trained and ready to take command and establish the life safety Isolation Zone and begin the alerting process (engage LANCE). (Fig. 4-5)

First Supervisor: The employer should set the benchmark time for the first supervisor to initiate life safety and simultaneously engage the Alert system giving the notification lead and/or Plant IC the first details: Who? What? Where?

Question 4-2: How will the supervisor know what the Isolation Zone will be?

Answer: The range of Isolation Concern for ammonia is 100’ for a small release and 500’ for a large release. A catastrophic event such as an explosion of an ammonia vessel or threat of flash fire would require 1,000’. These details should be located in the Plant Emergency Plan. ASTI recommends a Blue (Discovery) Playbook that provides pictures and a response checklist for life safety concerns. (Fig. 4-6)

The best first move to escape ammonia vapor is to travel laterally and upwind to a safe refuge. If the release is contained, the timeframe for movement is less urgent.

Question 4-3: How far would the supervisor be able to engage rescue, decon, and/or medical?

Answer: All supervisors should be trained to give direction and help those immediately in harm’s way to move to safety. The Supervisor must also begin the notification alert as soon as possible. The Command Team and responders (Fig. 4-7) notified through the Alert process immediately begin working with the Supervisor to assure that life threats and emergency shut-down procedures are addressed. Radio notification is easier/faster in engaging the Alert than using a telephone.

The first alert is received by one of the Command Team members: Plant Incident Commander, Lead Responder, Notification Leader, or Evacuation Group Supervisor. The Command Team members must engage the Plant IC and initiate response based upon their checklist responsibilities. (Fig. 4-8a)

The Plant Incident Commander may use the Alert form, 30-Minute Plan Discovery checklist, and the command packet checklists as guidance and muscle memory reminders on how to initiate the first Incident Action Plan.

Alert Form: The Notification Leader and/or Plant IC will use the Alert form to start the system of notification, evacuation, and Command Team engagement. Review the Alert form and assure that it is appropriate for use at your facility. Discuss the following:

(Fig. 4-8b)

Fig. 4-5 First IC

Fig. 4-7 Command Team

Fig. 4-6 Isolation Zones

Fig. 4-8a Position Packets

Module 5 25

Level of Concern: Assure that the levels of concern line-up with the Plant response policy. The level of concern will initiate pre-authorized action (Fig. 4-8c) by the Notification Unit Leader and the Evacuation Group Supervisor.

Hazard Zone locations: Engine room, rooftop condensers, cold room (evaporators), chemical storage rooms, fork lift battery charge area, refrigerated loading docks, etc. The Alert form list of Hazard Zones must reflect Plant policy.

Isolation Zone: Each Hazard Zone will have the downwind threats associated with ammonia vapor diagrammed or well understood (located in the Blue Discovery Playbook). The levels of concern link to the Isolation Zone distances: Level 1 requiring 100’ to 300’, Level 2 is 300’ to 500’, and Level 3 is 500’ to 1,000’ (catastrophic).

Location of the Incident Command Post: The Notification Leader will use the Alert form to guide the call to 9-1-1. The Notification Unit Leader should notify 9-1-1 even though others may have made the call. The details provided by the Notification Leader give responders critical information such as access route and situation-status details. The information provided by the Notification Leader will be relayed by the 9-1-1 dispatcher to the 9-1-1 responders.

Command and Control: The Plant IC must establish command and then communicate the Incident Action Plan to the Command Team. The Command and Control portion of the 30-Minute Plan (Phase #1 Blue Discovery box) outlines the key information needed to engage an Action Plan. The response effort is supported by the following playbook and quick guide checklists.

Blue and Green Playbooks: The details associated with wind direction, location of Isolation Zone, Protective Action Zone, Command Post locations, safe refuge locations, location of hazard zones, sides of the building, rooftop access, and other critical details regarding life safety are provided in the Blue Playbook. (Fig. 4-9)

Hazard Analysis Quick Guide: This guide is used to focus the Plant IC and Command Team on the high priority concerns regarding life safety hazards, risks, and threats. The use of the AEGLs (Acute Exposure Guideline Levels recommended by EPA for emergency response decision making) will provide the Command Team with the information needed to judge life safety challenges such as rescue, evacuation (shelter-in-place and safe refuge). AEGL 1, 2, and 3 can support the judging of the three levels of triage for medical treatment. The reminders about wind movement, escape planning, and personal protective equipment sets the stage for a safe response effort. Detailed safety and hazard analysis worksheets are available in the Plant IC’s command packet (used during Sustained Response to prepare the entry team to enter the Hot Zone).. (Fig. 4-10a)

Fig. 4-8b Alert Form

Fig. 4-9 Blue and Green Playbooks

Fig. 4-8c Pre-Authorized Call-Out

Fig. 4-10a Hazard Guide

26 Module 5

Plant IC’s Size-up Checklist (Fig. 4-10b): This form helps to prepare the Plant IC for what the rest of the Command Team is seeing with regard to the emergency event. The key communication is between the Lead Responder and the Plant IC. Once the confirmation on the location, depth, and degree of the emergency (Hazard Zone and Level of Concern) is affirmed, the Plant IC can set the Isolation Zone distance and establish the Command Post location.

Plant IC’s Command Checklist: This form helps guide the Plant IC when he/she is announcing command on the radio. The Plant IC’s command announcement will trigger the pre-authorized actions accomplished by the Notification Unit Leader and the Evacuation Group Supervisor. (Fig. 4-8c)

C-A-N Report: The Plant IC packet includes the size-up form called a CAN report: Conditions – Actions - Needs size-up report. The CAN report is also used as a size-up summary for when the first arriving public safety responders, e.g., the first-in fire officer, will want a report on Conditions (hazards, risks, threats), Actions taken so far (life safety and emergency shut-down), and Needs (rescue, decon, medical, etc.).

The employer should set benchmark times for completing the notifications, engaging the Command Team, and evacuating non-emergency personnel. This process should take no longer than 15 minutes to complete.

Initial Response Phase: The Discovery and Initial Response phases coincide smoothly as the Command Team accomplishes the first action checklists as pre-assigned and documented on their individually assigned command packet. During the Discovery Phase the majority of the life safety and Command Team set-up challenges should have been accomplished. The challenge now centers on responder safety, emergency shut-down, and integration with public safety first responders.

The Lead Responder focuses on dealing with the life safety issues located in the Hot Zone (Isolation Zone) AND the engagement of the Emergency Shut-Down plan. The Notification Unit Leader will document the high points of the incident and serve as the scribe and Information Officer at the Command Post. The Evacuation Group Supervisor continues to control access away from the Isolation Zone and look after those in safe refuge.

Incident Action Plan (IAP): There is an ICS 201 form located on the back of the 30-Minute Plan. (Fig. 4-11)

The Plant IC develops and oversees the IAP and assures that the incoming contractor and public safety responders are properly briefed before engaging action.

The Initial Response Green Box Checklist identifies the key concerns of assuring the Hazard Zone and Control Zones are properly secured and that the eye-level wind indicators and downwind receptors are identified for management of life safety and environmental receptors within the Protective Action Zone (0.1 to 1.3 miles).

Fig. 4-10b Size-up and Checklist

Fig. 4-11 Incident Action Plan

Fig. 4-10c Size-Up – CAN Report

Module 5 27

The acronym “SIMPLE” is used to describe the high points of the emergency shut-down procedure. SIMPLE is also used to create on-going Incident Action Plan objectives while ventilating, containing, and controlling the emergency during the Sustained Response phase.

The “SIMP” of SIMPLE summarizes the first concerns while initiating emergency shut-down (Fig. 4-12a). The Green Playbook gives a pictorial description of the emergency shut-down procedures for each Hazard Zone.

The LE of SIMPLE (Fig. 4-12b) are checklist reminders that assure the safety of the responders while working in the Red Exclusion Zone, the Yellow Contamination Reduction Zone (Decon Corridor) and the Green Cold Zone as diagrammed in the 30-Minute Plan.

Incident Command System (ICS): The National Incident Management System (NIMS) identifies concepts and principles of ICS to manage emergencies, regardless of their cause, size, location or complexity. NIMS provides a consistent, nationwide approach and vocabulary for multiple agencies or jurisdictions to work together to build, sustain, and deliver the core capabilities to achieve a secure and resilient nation.

The Incident Command System organizational chart is made up of positions assigned the Incident Command Team and four Branches that are staffed by Branch Chiefs for Operations, Plans, Logistics, and Finance. (Fig. 4-13a)

Consistent implementation of NIMS provides a solid foundation across jurisdictions and disciplines to ensure effective and integrated Command Team operations. NIMS empowers the components of the National Preparedness System, a requirement of Presidential Policy Directive (PPD)-8, to guide activities within the public and private sector and describes the planning, organizing, equipping, training and exercising needed to build and sustain the core capabilities in support of the National Preparedness Goal.

ICS is based upon management by objectives and a team-based hierarchy in which each position plays an integral part in achieving the operational Action Plan in a safe and timely manner.

Fig. 4-12a the SIMP of SIMPLE

Fig. 4-12B the LE of SIMPLE

Fig. 4-13a ICS Organizational Chart

28 Module 5

Question 4-4: Chief Coleman mentions that ICS is not based on the powers of the IC; ICS gets its power from the Command Team. What does this mean?

Answer: Coaches of sports teams, military officers, and public safety leaders ALL agree that the power of a team comes from its ability to work together to achieve the mission. The following is a summary of the key issues required for effective ICS Command Team operations. (Fig. 4-13b,c)

Question 4-5: What one position is required for ALL emergency events?

Answer: Plant IC

Question 4-6: Who assigns the Command Team positions and which of the Command Team positions would be the first to be assigned by the Plant IC?

Answer: The Plant IC assigns Command Team members. The first and most important position is the Lead Responder because that position manages life safety and emergency shut down within the Isolation Zone. (Fig. 4-14a)

Question 4-7: During night shifts there may be no staff members available to cover the Lead Responder role. How should the Plant IC cover this need?

Answer: The Plant IC would appoint or carry out the duties of the Notification Unit Leader because the emergency calls would summon the needed resources while the evacuation movement would be handled by the shift supervisor. The critical notifications would be to the Plant refrigeration contractor and off-duty operators. (Fig. 4-14b)

Plant Manager Juan Gonzalez mentioned that he has used existing staff members to cover the Notification and Evacuation roles, while the facilities services manager and plant management team handle the Lead Responder and Plant IC roles. (Fig. 4-14c)

Lee Pyle mentions that the support team takes the pressure off of the Plant IC and Lead Responder so they can more effectively do their primary jobs of commanding the Action Plan and conducting emergency shut-down. (Fig. 4-14d)

Question 4-8: How does the IC appointment of the Notification Unit Leader and Evacuation Group reduce the reaction time, thus increasing the odds of stopping the emergency when it is small?

Answer: The Plant IC’s announcement of the Hazard Zone and Level of Concern automatically engages pre-authorized actions by the Notification Unit Leader and the Evacuation Group Supervisor (Fig. 4-14c)

Fig. 4-13b The Plant Command Team

Fig. 4-14a Integrated Command

Fig. 4-13c Football Team Analogy

Fig. 4-14b Notification Unit Leader

Module 5 29

As the challenges of the emergency increase, so does the capacity of the IC appointed response team. The Access Control Officer helps the Evacuation Supervisor by controlling entry into the Plant by outside vehicles and facilitates the movement of the public safety responders to the Command Post (or staging area). The Production Control Officer is assigned to the Lead Responder to coordinate shut-down of utilities, which is critical when production systems such as boilers, air movement systems and other processing equipment are involved.

Muscle Memory, checklist, response guides and playbooks: The One Plan operational system depends on the Command Team’s ability to engage appropriately during the four phases of response.

Question 4-9: What muscle memory skills should be in place for each of the four initial Command Team members (Plant IC, Lead Responder, Notification Unit Leader, and Evacuation Group Supervisor)? (Fig. 15a-b)

Answer: All command positions should be ready to:

ۥ Identify the Isolation Zone distances without delay

ۥ Understand the location of Hazard Zones

ۥ Understand the purpose and location of the Red, Yellow, and Green control zones

ۥ Read eye-level wind conditions and weather conditions (temperature/humidity) and predict vapor movement through buildings and into the environment

ۥ Be ready to escape ammonia vapor (laterally, upwind, and/or shelter-in-place, or seek PPE)

ۥ Understand the roles of each of the four Command Team members

ۥ Understand the basic hazards, risks, and threats (HRTs) of ammonia

ۥ Know how to preform emergency decontamination and basic medical care of an ammonia injury

ۥ Wear appropriate PPE while working around ammonia systems

ۥ Master the checklist responsibilities that are specifically assigned assigned to the command team member.

Fig. 4-14c Assigning Command Team

Fig. 4-15a Muscle Memory

Fig. 4-14d Value of Support Team

Fig. 4-15b Lead Responder

30 Module 5

To Review:l For more information check the FEMA website: http://www.fema.gov/

national-incident-management-system.l Assure that all Command Team members are familiar with the following:

l All command positions receive their assignments from the Incident Commander

l ICS structure: Command, Operations, Plans, Logistics, Finance/administration

l Unity of command: orderly line of authority, e.g., report to one supervisor

l Span of control: one supervisor oversees a maximum of 5 to 7 reportsl Transfer of command: senior IC may assume command after a size-up

briefingl Accountability: check-in, personnel tracking, and personnel and

resource assignmentl Employee can refuse an assignment if not properly trained or equippedl Unified and Integrated Command: Company Liaison is a part of

Integrated Commandl Incident Action Plan priorities: life, incident stabilization, environment

and property. Doable tasks: Doing what? Who is responsible? How communicated? Safety?

l Incident Command Post (ICP): upwind (see “Control Zone Layout” on 30-Minute Plan)

l Incident scene orientation: four sides – A, B, C, and D; floors (1, 2, 3…)

l Conduct a Hazard Analysis before engaging ANY Incident Action Plan l Radio Communications: use “to-from” call out, keep messages short

and to the point, repeat key points to critical messages to assure communication connection

l Evaluate your Command Team organizational structure and determine how to cross-reference the position assignments to accomplish the checklist concerns for Discovery and Initial Response.

Module 5 31

Lesson 5Sustained Response

The Plant IC and first arriving fire officer will set the stage for the entire response during the first 30 minutes of the emergency event. The transition to Sustained Response is enhanced when the initial CAN size-up accurately assesses the conditions, actions, and needs, and the Incident Commander orders the appropriate level of personnel and resources needed to prevent the emergency event from escalating into a catastrophic life safety, environmental, and property damage threat. (Fig. 5-1)

Question 5-1: How do the steps taken during the Discovery and Initial Response Phases of response help reduce the time to engage the Incident Action Plans developed during the Sustained Response?

Answer: Discuss the benefits of accomplishing the following actions during Discovery and Initial Response within the 30-minute benchmark time. (Fig. 5-2a-c)

•€ The first-in fire officer receives a Conditions – Actions –Needs report from the Plant IC.

•€ The fire officer takes charge as IC and supports the Plant IC’s need to complete life safety challenges (rescue, decon, medical) and emergency shut-down operations.

• Control the Isolation Zone with personnel accountability for all personnel in safe refuge and those engaged in emergency response.

•€ Access controls are in place and vapor plume movement is clearly mapped with public safety control of the life safety concerns in the Protective Action Zone.

•€ All mandatory notifications are documented and accomplished within the regulatory guideline; all key issues and situation status details properly documented.

•€ Pre-defined emergency shut-down procedures are complete and the status of the emergency is stabilized and improving.

•€ Safety measures are in place with controlled movement between the Green, Yellow, and Red Zones clearly marked with eye-level wind indicators.

•€ Incident Command management system is organized, coordinated, and communicating well with the Plant Incident Commander now acting as the Liaison to an Integrated Command with public safety Command Team.

Life Safety Challenges: One of the most challenging decisions required of the first-in fire officer is to decide if a rescue is within the capacity of the firefighters to accomplish. The life safety issues extend to off-site receptors, especially those located in the Isolation Zone. Downwind receptors will be notified by the Public Safety IC to evacuate or shelter-in-place. The downwind vapor in the Protective Action Zone (PAZ) is less of a life safety

Fig. 5-1 Sustained Response

Fig. 5-2b Actions

Fig. 5-2a Conditions

Fig. 5-2c Needs

32 Module 5

threat but is very noxious and can be especially challenging for those who are very young, senior citizens, and those with medical ailments (especially respiratory). The Plant IC should be prepared to identify high risk life threats within the PAZ.

Discussion: Review Captain Apodaca’s comments about the choice to risk a lot to save a lot, or to wait for a hazmat team with a higher level of chemical PPE and training. Identify the key information available to increase the level of risk assessment needed to weigh the hazards and threats against the likeliness of survival of the victim. (Fig. 5-3a-e)

Remember, it may take an hour to wait for a hazmat team to arrive and suit-up for entry.

Review the following response concerns to aid in the decision to engage rapid entry rescue.

•€ Quick Guide Hazard Analysis: What is the status of the ammonia release? Vapor or aerosol cloud?

•€ Timeframe of exposure to the estimated level of vapor? Reference the AEGL timeline exposure table. Has the person been exposed to more than 5,000 PPM for over 10 minutes?

•€ Is the location of the victim in clear sight and access to and from the victim safe for entry team members?

•€ Has emergency shut-down been accomplished and the condition of the release improving as ventilation and pressure management and isolation of ammonia flow reduces the risks and threats?

•€ Is the team ready to engage decontamination, medical treatment, and transport?

•€ What are the threats associated with moving into an environment of ammonia vapor under 5,000 PPM? Unprotected skin irritation starts at 10,000 PPM and can cause skin damage at 30,000 PPM. The SCBA provides eye, face, and respiratory protection. Responders should be prepared for a sudden high exposure if inside conditions worsen. The firefighter will sense skin irritation (a cold-irritating feeling, especially in areas where moisture gathers) much earlier than actual skin damage occurs. Taping or securing pant legs and the coat arm to the gloves will significantly reduce the threat of ammonia vapor entering the fire turnout clothing.

Sustained Response must be guided by a written Incident Action Plan and Safety Plan created and overseen by the Incident Commander. The ICS 215a Hazard Assessment and the ICS 208 Site Safety and Refuge forms are used to assure a safe and methodical Incident Action Plan (IAP) for a given response time period, e.g., an IAP objectives and tasks will be based upon a 10-minute entry time. The SCBA on-air time will be monitored by the Entry Team Leader and Assistant Safety Officer to assure the entry team’s safe exit from the Hot Zone. Decontamination will be performed with a fan (high speed air) for vapor exposure and with water spray for liquid ammonia exposure.

Fig. 5-3a Operator Down

Fig. 5-3e Medical Treatment

Fig. 5-3c Rescue Carry

Fig. 5-3b Rapid Entry Rescue

Fig. 5-3d Full Decon

Module 5 33

Preparing for Entry: The Hazmat Entry team must have a pre-entry briefing before engaging the Incident Action Plan objectives. The Entry Team Leader and Safety Officer will assure that the Entry team is properly prepared to engage the IPA tasks. The briefing will include the following: (Fig. 5-4a-e)

•€ Hazmat team members will be medically evaluated and appropriately hydrated (drink water) prior to entry.

•€ Safety briefing – hazards of ammonia, entry team communications, hand signal reminders, and escape plan

•€ Clarity on the incident objective and task assignments. This should be supported with P&ID valve locations and pictures showing the location and operation of the task assignments (e.g., valve closure).

•€ The Entry Team leader and Assistant Safety Officer will assure that the on-air time is recorded and that the team is pulled out of the Hot Zone with time to engage decontamination and movement to rehab.

To Review:l Consider Chief Coleman’s comments about the need to avoid

response chaos by being ready to engage your operational plan effectively in the first 30 minutes.

l Consider Chief Johnson’s and Captain Apodaca’s comments about recognizing the value of the lead fire officer’s confidence and understanding of the pre-arranged readiness implemented by a Plant Command Team; and the benefit of having an established game plan that is jointly understood and implemented by the plant and public safety responders.

l Develop an Incident Action Plan (IAP) objective and tasks needed for an entry team to isolate a compressor leaking at the thermo-syphon solenoid valve. Review the safety measures that would be communicated to the entry team.

Fig. 5-4a The Release

Fig. 5-4e Engaging Action

Fig. 5-4c Pre-Entry Briefing

Fig. 5-4b The IAP

Fig. 5-4d Pre-Entry Medical Evaluation

34 Module 5

Lesson 6Termination of the Emergency Event

The Incident Commander will decide when the emergency operations are completed and the emergency response can be de-activated. The IC will proclaim that an emergency event is “all clear” once it is determined that conditions leading to the event are alleviated, mitigated or contained, and unlikely to reoccur, and that all individuals are accounted for. (Fig. 6-1a, b)

Question 6-1: Why is it important to proclaim that the emergency incident is terminated?

Answer: The IC must alert all Command Team members, emergency refuge leaders, and those sheltered-in-place in the downwind that the emergency event is over. Special instructions and safety measures may also be announced prior to giving an “all-clear” to return to normal operations.

The Termination Proclamation should be written, signed, and dated. The signed Termination Proclamation clears the way for the Plant IC to begin recovery and restart action plans. The pre-emergency readiness standards of operation used for maintenance, service, and repair will apply to the restart and recovery action plan.

The IC may establish special safety and security issues to be addressed by the plant management team, such as a fire guard, structural engineer assessment of damage infrastructure, or other special concerns involving the safety of the building and surrounding environment.

Discussion: The recovery effort associated with a major fire or structural damage will require a command team and operational plan similar to the IAP and ICS team engagement used during the emergency. The recover plan will identify the repair, and restart challenges that the Command Team must prepare for to engage: challenges that the Command Team must prepare to engage:

•€ Command Team: Plant IC, Lead Responder, Notification Unit Leader, Evacuation Group Supervisor, and Plans Section Chief, Safety, Access Control, and Logistics (Fig. 6-2)

•€ Special consideration for: business recovery, customer relations, insurance and regulatory coordination, debris removal and disposal, engineering and construction contractors, restart readiness (more concerns may be added to the list).

Incident Debriefing: The cause and origin of the incident and a review of the response actions must be reviewed with all of the responders. The objective of the debriefing is NOT to place blame for the problems that may have occurred…that should be done privately. The objective is to determine the lessons learned that can prevent, mitigate, and prepare the response team for any future events. This is also the time to confirm the teaming agreement with the public safety responders so that an even stronger future response can be developed. (Fig. 6-3)

Fig. 6-1a Hazard Assessment

Fig. 6-2 Announcing All-Clear

Fig. 6-1b Termination Proclamation

Fig. 6-3 Debriefing

Module 5 35

To Review:l Review the forms and official notifications needed to provide mandated

regulatory, insurance, and OSHA serious injury reporting.l Evaluate the ability of your team to recover from a major event. Do you

have a Crisis Management Plan, marketing strategy, ability to engage structural engineers and repair contractors without delay, and ability to establish a repair team that can act in time to save the cold storage warehouse product? What about a movement plan for transferring product that is being threatened by loss of cold storage or fire spread?

l Does your disaster plan address setting up for self-sufficiency, information services, computer back-up, and transition of business leadership due to injury or displacement of key business leaders?

l Does your insurance policy have exclusions for the high cost of debris removal and environmental damage?

l Is your team able to coordinate accurate crisis information together with the public safety Joint Information Committee (JIC)?

l How do you handle your debriefings? Are people fearful of talking; are they anticipating embarrassment, or is the focus constructively built around joint understanding of the need to engage higher levels of prevention, mitigation, and preparedness?

36 Module 5

Lesson 7Summary High Points

Review the highpoints associated with each of the directional signs on the roadway to One Plan readiness to engage emergency response. (Fig. 7-1)

•€ Discovery: Life safety (LANCE) - Blue box on the 30-Minute Plan and the Blue Life Safety Playbook

•€ Initial Response: Responder readiness and emergency shut-down (SIMPLE) – Green box on the 30-Minute Plan and the Green Emergency Shut-Down playbook

•€ Sustained Response: Ventilation, containment, and control with an Incident Action Plan and safety plan (advanced SIMPLE) – Red box on the 30-Minute Plan and Red Playbook

• Control Zone Layout, ICS 201 Incident Action Plan and the ICS 203 Organizational Chart located on the 30-Minute Plan

•€ Termination: An official act on the part of the IC to end the emergency and turn repair, restart, and recovery operations back to the plant management; also a debriefing is planned – Orange box on the 30-Minute Plan

Chief Coleman: One of two outcomes develop from an emergency event: 1) WE control the emergency, or 2) the emergency controls US. (Fig. 7-2)

Juan Gonzalez: Accidents are going to happen, we need to be prepared to prevent injury or damage; be on top of the circumstance BEFORE and during the event; safety and emergency preparedness are keys to success for all of us. (Fig. 7-3)

Sonny Basaldua: We don’t need heroes or double rescues – we need to live our plan every day. (Fig. 7-4)

Captain Apodaca: Have our firefighters understand and support life safety and emergency shut-down procedures developed by the Plant leadership; work together for a joint success. When we roll-up we have to be ready; this requires annual training. (Fig. 7-5)

Chief Johnson: Be proactive, not reactive. Train on the plan and know the plan so upon arrival everything is going to move quicker: you won’t have a sustained incident, the incident will be mitigated in 30 minutes or less! (Fig. 7-6)

Our Goal: To prevent or stop emergencies when they are small, to preserve life safety, property, and the environment. (Fig. 7-7)

Fig. 7-1 Emergency Response Map

Fig. 7-3 Plant Manager Gonzalez

Fig. 7-2 Chief Coleman

Fig. 7-4 Facilities Services Manager Sonny Basaldua

Module 5 37

To Review: Ending Discussion: Review the following list of things that individuals and the plant management team can do to address the emergency response readiness challenges:

1. Define the primary and secondary Incident Command Post locations (IAP). The Plant Incident Commander must take command and stay positioned at the Incident Command Post for incoming responders (on-site, off-site, and the Public Safety IC).

2. Develop Command Team checklist readiness, especially for the first 30 minutes: Plant IC, Lead Responder, Evacuation Group Supervisor, and Notification Unit Leader

3. Develop an SOP for PPE (personal protective equipment) and training to perform: incidental, discovery, and initial response operations - the 30-Minute Plan. Acknowledge what the term “Danger Area” means to know the limits of performing incidental control and emergency shut-down.

4. Develop effective radio communications to support the planned engagement of Command and Operations responders; consider bone or air induction ear-mics.

5. Prepare the Support positions assigned to the Command Team for production control, safety management, access control, air monitoring, logistics, advanced planning, decontamination, medical, etc.

6. Develop Command and Support team training to create muscle memory understanding of the Plant Hazard Zones, Levels of Concern, Isolation Zone distances, and recognition of basic hazards, risks, and threats (HRT’s). Develop the ability to take appropriate actions to move away from HRT’s and safely escape harm.

7. Develop Command team checklists for operational readiness reminders; quick guides for hazard, risk, and threat assessment; incident action and safety plans; and, situation status and hazard analysis reports.

8. Develop Task Book training for emergency response team members to improve the self-sustaining capabilities using Plant-specific emergency readiness training:• Muscle memory readiness for first 30 minutes

assignments• Operational experience working as a Plant Command Team exercised

during pre-emergency events, simulations, and non-emergency event planning/operations

• Knowledge of how to use checklists, quick guides, and command forms• Situation awareness of the hazards, risks, and threats during an

emergency event within hazard zones• Operational connection between the Emergency Plan and the findings

and recommendations of RMP, PSM, and PHA

For more information contact the Ammonia Safety & Training Institute at (831)-761-2935 or visit the website at http://ammonia-safety.com/

Fig. 7-5 Sacramento Fire Captain Jerry Apodca

Fig. 7-7 Our Goal

Fig. 7-6 Watsonville Fire Division Chief Chris Johnson

Text here.

IIAR1001 North Fairfax Street, Suite 503

Alexandria, VA 22314Phone: 703/312-4200

Fax: 703/312-0065

Module 5

Making the First 30 Minutes of Emergency Response Count

Module 5

Making the First 30 Minutes of Emergency Response Count