Yellowstone Oil Spill Response Lessons Learned Final
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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 MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012 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 MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012 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 10 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 MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012 13 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 14 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 15 . 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 16 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 19 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 20 Cause elements allowed analysis on three levels Organizational Programmatic ICS Structure MT DEQ YELLOWSTONE OIL SPILL RESPONSE LESSONS LEARNED OCTOBER 2012 O PPORTUNITIES FOR I MPROVEMENT 21 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 22 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 23 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 24 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 25 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 26 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 27 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 28 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 29 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 30 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 31 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 32 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 33 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 34 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
