Transcript Yellowstone Oil Spill Response Lessons Learned Final

October 2012
Y ELLOWSTONE O IL S PILL R ESPONSE
L ESSONS L EARNED
B ACKGROUND
2

Friday, July 1, 2011: 63,000 gallons crude oil
spilled into Yellowstone River from ExxonMobil’s
Silvertip Pipeline

Sunday, July 3, 2011: Governor Schweitzer
requests DEQ serve as state Incident Command
lead agency

Sunday, July 3, 2011: Tom Livers, DEQ Deputy
Director on scene

Following weeks: More than 100 DEQ employees
serve in spill response effort
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
3
S IGNIFICANT O VERALL S UCCESS

Timely and appropriate cleanup

Protection of human health

Protection of Montana’s environment

Protection of private and public lands

Long-term cleanup commitment

No significant injuries during cleanup
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
N EAR -M ISS S CENARIO
4


Favorable Factors

Timely EPA resources, expertise & leadership

Cooperative and capable RP

Large city access and logistics

Dedicated and capable employees
What will we have the next time???
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
L ESSONS L EARNED & C AUSE
A NALYSIS I NTRODUCTION
5
Purpose:
To review
and analyze
DEQ’s
incident
response
efforts

Identify what we did right

Identify where we can improve

Recommend improvements
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
L ESSONS L EARNED :
P ROCESS
6
Sponsored by
DEQ
Management

Organized by DEQ Quality Assurance Council

Lessons Learned team assembled

12 DEQ employees

Managers, supervisors, and staff
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L ESSONS L EARNED :
7
Solicited
comments
from
DEQ
incident
participants
PROCESS

More than 300 comments provided by 33
participants

Sorted and categorized comments into ICS
categories and subcategories

Reviewed comments

Verified facts

Performed follow-up interviews for clarification
and further fact finding
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8
I NCIDENT C OMMAND
S TRUCTURE (ICS)
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
C AUSE A NALYSIS :
M ETHODOLOGY
9
Customized
cause
mapping
analysis
method

Preferred method for analyzing processes, combining:

(Inverted) Ishikawa
diagram

5 Whys
Management Oversight
and Risk Tree (MORT)
root cause elements
 Cause mapping
technique

Ishikawa (fishbone) diagram
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
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C AUSE A NALYSIS :
P ROCESS
Identify goals
and impacts
to goals for
each ICS
category
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
C AUSE A NALYSIS :
P ROCESS
11
EPA had
Administrative
Order
indicating
authority
Legal
Integrity
Impacted
Unclear role in
response
EPA has
dedicated
programs to
ER, including
legal
DEQ did not
provide Exxon
legal
documentation
indicating
authority
Unclear legal
authority
Class action
lawsuit
impacted
DEQ position
and access
Multi environmental
media and
evolving
regulatory
focus
LTA guidance
on how to
interface NRD
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
C AUSE A NALYSIS :
P ROCESS
12
Possible Solution:
Address legal
authorities and issues
in DEQ Emergency
Incident Command
Management Plan
Legal
Integrity
Impacted
Unclear role in
response
Possible Solution:
Address preparation
of “boiler plate”
generic UAOs and
violation letters
EPA had
Administrative
Order
indicating
authority
EPA has
dedicated
programs to
ER, including
legal
DEQ did not
provide Exxon
legal
documentation
indicating
authority
Class action
lawsuit
impacted
position and
access
Unclear legal
authority
Evidence: Land
farming, solid waste,
open burning, haz
mat disposal, water
quality, etc.
Multi environmental
media and
evolving
regulatory focus
LTA guidance
on how to
interface NRD
Possible Solution: Address
relationship and
coordination between DEQ
and the NRD program
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L ESSONS L EARNED
T EAM AT W ORK
Big basket of candy
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
C AUSE A NALYSIS :
P ROCESS
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Possible Solution:
Address legal
authorities and
issues in DEQ
Emergency Incident
Command
Management Plan
EPA had
Administrative
Order
indicating
authority
EPA has
dedicated
programs to
ER, including
legal
Evidence: Land
farming, solid waste,
open burning, haz
mat disposal, water
quality, etc.
6d
Legal
Integrity
Impacted
Unclear role in
response
Possible Solution:
Address preparation
of “boiler plate”
generic UAOs and
violation letters
DEQ did not
provide Exxon
legal
documentation
indicating
authority
Class action
lawsuit
impacted
position and
access
4d
Unclear legal
authority
Multi environmental
media and
evolving
regulatory
focus
LTA guidance
on how to
interface NRD
Possible Solution: Address
relationship and
coordination between DEQ
and the NRD program
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
C AUSE A NALYSIS :
P ROCESS
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.
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
C AUSE A NALYSIS R ESULTS
Combined Cause Map
Incident Command
Finance
Logistics
Operations
Planning
Lessons Learned Report
MT DEQ YELLOWSTONE OIL SPILL
RESPONSE LESSONS LEARNED
OCTOBER 2012
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED 3/6/2012
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S UMMARY
17
OF
R ESULTS
Accomplishments
“BOTTOM LINE—DEQ employees did
an OUTSTANDING job of stepping up
to the plate, learning on a very fast
pace the basics of ICS, participating in
whatever activity needed to be done
and getting it done.”
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
S UMMARY
18
OF
R ESULTS
Accomplishments
 Successful completion of
first large-scale intra-agency
collaborative response
effort
 Networking with industry
specialists and other
government entities
 Adaptability of DEQ
employees
 Improved processes and
communication as response
progressed
 Flexibility
and willingness of
DEQ management to
commit resources
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
S UMMARY
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OF
R ESULTS
Accomplishments

Positive Employee Feedback

Increased pride in DEQ mission

Energizing experience working as a team on a common goal

Opportunity to experience impact that DEQ mission has on
Montana's public and environmental health

Developed cross-program relationships

Willingness of management to do things differently

Opportunity to use expertise in a unique way

Management trusted staff to apply their expertise & judgment
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Cause
elements
allowed
analysis
on
three
levels

Organizational

Programmatic

ICS Structure
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O PPORTUNITIES FOR
I MPROVEMENT
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Level 1: Organizational

Assess and clarify DEQ's mission,
obligations, authorities, roles,
responsibilities, and primacy on and for
future emergency response incidents.
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 1: Organizational

Develop a DEQ Emergency Response
Management Plan for each section of Incident
Command System





Incident Command
Logistics
Planning
Finance
Operations
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 1: Organizational
Extremely Good News

Templates for Emergency Response
Management Plan available

Customize for DEQ
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 1: Organizational

In preparation for future incident
response, ensure

Clear goals and objectives

ICS training and OJT

Intra-agency communication strategy

Work processes established
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 2: Programmatic
Safety

Define the emergency response roles,
responsibilities and authorities of the DEQ Safety
Officer.

Develop an Emergency Health and Safety Plan that
can be tailored as needed to incident and site
conditions.
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 2: Programmatic
Financial Services

Request the Legislature provide for emergency
incident response authorization and funding
through the Executive Planning Process.

Develop Finance section of ERMP
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 2: Programmatic
Records & Document Management

Create a centralized location for all programs to track
employee training

Include Records and Document Management processes in
ERMP: Planning section
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 2: Programmatic
Environmental Data Management

Include Data Management processes in ERMP: Planning
section

Data elements, standards & metadata

Data repository(ies) (databases)

Identification of laboratories that provide data in required
format

Data import/export

Data accessibility
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 3: ICS Specific

Incident Command Section of ERMP

Develop a DEQ Communications Plan

Roles and responsibilities for command section
staff

Legal authorities

Coordination of private parties; and federal, state
and local governments

Incident response staff scaling thresholds
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 3: ICS Specific

Planning Section of ERMP

Planning roles, responsibilities and assignments

Daily reporting format and standard content and
record-keeping

Meeting management, i.e., agenda, recording
format, and coordination with on-scene
personnel

Standardized, centralized assignment status and
tracking lists
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 3: ICS Specific

Operations Section of ERMP

Staff tours and rotations

Escalation of staffing deployments

Home-office duties of deployed staff

Inventory of staff’s core competencies

List of DEQ staff that have specific emergency
response training

Qualifications for emergency response staff
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 3: ICS Specific

Logistics Section of ERMP

Centralization of Logistics role

Coordination of on-scene logistics with home-office
support to handle travel, housing, and equipment and
supplies

Centralized tracking and inventory system for response
assets

IT involvement and support at incidents and remote
computing policy
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
O PPORTUNITIES FOR
I MPROVEMENT
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Level 3: ICS Specific

Finance Section of ERMP

Potential funding sources

Cost recovery procedures

Emergency response procurement

Staff expense reimbursement

Exempt comp time payout

Coordination and communication with other
responding entities
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
N EXT S TEPS
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
Read the report

Determine DEQ future role in incident
response

Plan

Do

Check

Act
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012
P ROGESS
35
Accomplishments so far:

DEQ has agreed to a primary role in 2 ESFs

New Montana MERF assigns ESFs to DEQ

Draft of ESF 12 and Draft of ESF 10 has begun

Active participation in SERC and RRT

ICS training plan for DEQ staff/have started

In-house plan underway
MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS
LEARNED OCTOBER 2012