Imagine this scenario...

Transcription

1 HOW TO KEEP YOUR EAP IN SHAPE WITH AN EXERCISE PROGRAM Rita Anderson, R.E.M. and Janis C. Murphy, P.E. Imagine this scenario... A call comes in the early morning hours; you are sound asleep but the dam for which you are responsible may be on the verge of failure. A deputy is on the phone telling you that he has reports of water across the road immediately downstream of the dam. You know the first thing you should do is call who? Then you remember it is all written down in the Emergency Action Plan the EAP. You remember putting it together when you first came on board. It is somewhere in that? Five years ago? Maybe eight years ago? Keeping Current If this reflects your knowledge level of your EAP, chances are that when you do find the plan, you will also find that little in there will be useful. What could have changed in five years? Have any of the people on your Notification Flow Chart changed in five years? Have there been elections in those years? Even if you have not looked at your EAP in the last year, it most likely is not current. And if you have not exercised the plan with key players in the past five years, you do not know if you are prepared to respond to any level of emergency. It is possible that some of the first responders in your area do not even know your dam exists. An organized exercise program keeps everyone with emergency responsibilities up-todate and fully informed. The full-scale exercise that is seen featured on newscasts are very dramatic but a simple orientation meeting followed by a table-top exercise can lay the foundation for increased communications, verify responsibilities outlined in the plan, identify resources and keep contact information current. Getting Started If you have not put together an EAP, there are guidelines on most state web sites as well as from the Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Natural Resources Conservation Commission (NRCS), Bureau of Reclamation (BuREC), and Association of State Dam Safety Officials (ASDSO) sources. There are classes you can attend and consultants you can hire. Part of an EAP is putting together a Notification Flow Chart or an Emergency Contact List. This is a list of people and numbers to contact during an emergency situation at the dam. Completing the Notification Flow Chart and updating it on a regular basis is the first step toward keeping your EAP in shape. Why Exercise Your Plan? There are many reasons to exercise your Emergency Action Plan. They include, but are not limited to: Meeting legal requirements Addressing liability issues Provide a venue for all involved with the plan to meet

2 Contacts and resources can be validated Provide an opportunity for overall plan improvement Legal Requirements State Requirements Most states require some form of an exercise program. 1 Often the requirement is not spelled out in the regulations but can be found in the guidelines or in the EAP examples provided by the state. States use a variety of language to describe an exercise program, sometimes referring to testing or verifying the EAP. Some states require specific sections of the EAP or emergency procedures to be tested over a period of time. Some states set a regular schedule for exercising while some set a rotational schedule. Some State regulations refer to FEMA 2 or FERC 3 regulations specifically as examples of an exercise program. FERC requires licenses to exercise EAPs and has a suggested time line for a series of exercises beginning with the simple orientation and progressing in complexity over a five year period. FEMA provides guidelines and training at the National and State levels; FEMA recommends an exercise schedule and sets out criteria for who should participate and provides documentation format. Addressing Negligence/Liability Issues Most EAP examples available on-line (from states or other sources) include a reference to exercises or testing the plan. Some states have a set schedule outlined in either regulations or guidelines. Whatever schedule you use, be careful to follow your plan. If your plan says you will exercise and you do not, federal requirements may not legally matter. If you are not complying with your own safety procedures, you leave yourself vulnerable to legal issues of non-compliance. Meet the Players An exercise gives you the opportunity to meet as fellow professionals and share information to meet a common goal preventing a dam failure and lessening the impacts should dam failure occur. Although you may know everyone in your emergency response network, often dam owners operate outside of that network. Sometimes the Emergency Management response network needed is miles from your area of operation. You may know a deputy or fireman; or maybe you have coffee with the sheriff. But knowing someone by name is not the same as knowing what they bring to the table during an emergency situation. Validate Your Contacts/Resource List The old saying The more things change, the more they stay the same really does not apply here. Things do change. Since you developed your EAP, your state may have changed how they respond to a disaster. Have they appointed Regional Coordinators? Many states have; but if your plan has you calling the State capital, precious time will be wasted while someone makes a second call to find the regional coordinator. In some states, the agency involved in a response may have changed their name in a state-wide reorganization since you developed your EAP. Your phone numbers and titles of who to contact could be inaccurate. With budget cuts, some responsibilities are being moved from one agency to another to reduce cost. Your plan may not reflect these recent changes.

3 If there has been an election since you developed your plan, your plan is probably no longer current. Even if every elected official on your contact list was re-elected, it is likely that some of the people they appointed have left or moved to a different position. Over a period of years, people leave for all kinds of reasons: relocations, job changes, retirements, business closings. They even die. No one wants to be on the phone with the widow of a heavy equipment supplier at 2 a.m. asking who else might have excavators available. An Opportunity to Improve Your Plan Although you may think you have written a perfect plan, we have already seen how perfection can be a fleeting condition due to ever changing situations. Your plan may include radio call signals but newer responders may use cell phones instead. A small change may be the most important change the contact number. There have been numerous changes to area codes in the last few years so the main number may be the same but the area code may be different than the one in your plan. Agencies may want information ed to them after an initial phone call so you might want to add addresses to your Notification Flowchart. Duties may have been reassigned to another department so everything you have assumed in your plan could be wrong. Often during an exercise it is revealed that roles and responsibilities have shifted even within the dam owner s organization yet the EAP does not reflect these changes. It is very common to find that a layer of management has been added or deleted since the plan was developed. It is not uncommon to find an employee was at the dam and was an emergency contact but has moved to another position within the organization yet this is not reflected in the plan. An exercise also presents the opportunity for new response methods to be discovered or new problems to be revealed. Some areas use the reverse 911 system; detailed messages to smart phones may be the new required method of notification. Most agencies have GIS capabilities and can share shape file information for use in both planning and response. Types of Exercises Five Types Several terms are used to describe an exercise. FEMA and FERC both offer detailed explanations and examples of the five types of exercises listed below. The five types are: Orientation Seminar/Workshop Table-top Exercises Drills Functional Exercises Full-Scale Exercises Orientation Seminars/Workshops FERC recommends using this format for updating your Notification Flowchart on an annual basis. This step can be eliminated during years when you have a table-top or higher level exercise but it should not be skipped if you have not exercised the plan in several years. This informative meeting can serve as an introduction to the more intensive exercise; however, the two events should be separated by several weeks. FERC inspectors will check for evidence that the licensee has collaborated with local emergency managers; such collaboration is considered as an ingredient of a minimally

4 acceptable dam program 4. An orientation workshop and annual review of the EAP with local and state emergency management meets that criterion. The purpose of this type of exercise is to make your staff and key emergency responders familiar with duties and responsibilities described in the EAP. At a minimum, they should know where the EAP is kept. Some jurisdictions require the Notification Flowchart to be posted for quick access; this location should be widely known by staff. FERC, FEMA, NRCS and most state EAP examples provide forms to document staff review of the EAP. Table-top Exercises A table-top exercise involves getting responsible people into a conference room environment where solutions to emergency situations can be found through discussion. Some states require that the state and local Office of Emergency Management (OEM) representatives are included in table-top exercises and, even if it is not required, it is a very good idea. The table-top is usually informal with minimum stress involved. The presentation is a description of a simulated event and participants discuss and evaluate the EAP and response procedures. Issues are resolved on a consensus basis. Table-top exercises are a great way to meet face-to-face and to discuss response procedures and resolve concerns regarding coordination and responsibilities. Drills Drills test, develop or maintain skills regarding a single procedure. Typically a drill is performed in-house and will not involve other groups. It is often used to make sure changes have been implemented or to check retention of recent training. For instance, a dam owner might choose to test response time during an emergency soon after a key staffer has moved to new housing or response time for personnel during major road construction that could impact staff travel time over a lengthy period. Other examples include testing emergency shut-down procedures, executing the weekend emergency notification procedures or testing remote equipment operation. Functional Exercises A functional exercise involves a wide range of individuals including state and local emergency management personnel and key responders. A Functional Exercise is considered Comprehensive and should test all areas of the EAP. The goal would be to make it as real life as possible without field deployment. Participants should feel stressed and results and actions should be time sensitive. This is not the first exercise you should have it should follow a progression of orientation, drills and table-top exercises. Functional Exercises can test inter-agency coordination, policy issues and operational response. Typically participants would be in separate rooms to delineate the physical separation between an Emergency Operation Center and the site of the incident. Full-Scale Exercises Full-scale exercises are the most complex and comprehensive. They are the events that get news coverage. Although typically a full-scale exercise will test the entire EAP, emphasis can be placed on certain sections such as coordination with evacuation officials or area-wide communications systems. Full-scale exercises mobilize personnel and resources. Interagency coordination and deployment of seldom used resources are key activities in a fullscale event. These are complex events and require coordination with multiple agencies. It is a good idea to work with other s who are required to have full-scale exercises. Some states

5 require working with the county OEM s exercise schedule FEMA funded OEMs have an exercise requirement to meet for continued funding. Other groups who have exercise requirements and could work with you include hospitals and other dam owners (upstream or downstream of your facility). As with all levels of exercises, the goal is to identify areas wherein the EAP that can be improved. If actions do not match the plan, changes to either the plan or the actions should be made. Often, making the identified changes that are needed may take longer to complete when they involve multi-agency groups and procedures. Who should participate in an Exercise and how long should an Exercise last? Many states dictate the participation of state and local OEM coordinators at all levels of exercises, including the orientation. Some states require more involvement including exercises at the dam being incorporated into the county s schedule of exercises, as mentioned above. There are no regulations regarding the specific length of any of the exercises however, typical lengths are noted below as well as who should be invited. Orientation Seminar/Workshop Participants In addition to anyone required by regulation to attend, orientation seminars are often attended primarily by staff and the engineer familiar with the dam. This may include security personnel as well. If the function of the dam is water supply, primary customers may also attend as they may have insight into the Notification process or have additional resources to provide in an emergency. Local responders may also be invited. This is particularly important when no exercises have been held and responders are unfamiliar with the facility and the staff. Time-line An orientation workshop should take one to two hours depending on the number present who are unfamiliar with the EAP and the facility. An orientation is often included in new employee training or added to annual awareness training or other annual required training. When primarily staff attends, the issues of location and amenities are not as much an issue as when responders and OEM personnel are included. An early breakfast meeting or meeting over lunch can assure a good turn-out when this group is included in the orientation. Drills Participants As discussed earlier, drills are often tests of specific, single emergency procedures and therefore may involve only internal staff. The consulting engineer may be on-call to answer questions by telephone or may be on-site. If the test is calling the Notification Flowchart contacts to verify numbers, a scripted greeting should assure those answering the phone that this is a drill and not an actual emergency.

6 Time-line With limited involvement of outside parties, a drill should take two to four hours, depending on the procedure being tested. This would include time for feedback. As with the orientation workshop, a drill can be incorporated into other training. Unlike other exercises, the limited involvement of outside parties also requires less notification and coordination for scheduling the event. The EAP coordinator can respond quickly to a perceived problem or recent change with a drill to ensure key personnel remain prepared for potential emergencies at the dam site. Table-top Exercises Participants A wide-range of participants should be included in a table-top exercise. This should include those in command level positions with response agencies as well as the field supervisors for response agencies. The dam owner should include individuals from many multiple functional areas at the dam including those who observe the dam on a regular basis, security personnel, and the engineer for the dam. State and local emergency management personnel should also be present. Time-line Participants involved in a table-top exercise should have adequate time to resolve the scenario as well as discuss alternatives. Table-top exercises are to be low-stress and well documented so a minimum of two hours should be allowed for a simple scenario. Table-tops may take as long as four or more hours, depending on the number of participants, the level of familiarity with the EAP, and their knowledge of the response procedures of other agencies. Invitations should be sent at least six weeks prior to the event. If breakfast or lunch can be incorporated into the event, it is likely you will have more participants. For example, an informal review can occur over lunch or groups can continue to resolve issues during the meal, depending on the meeting time selected. Functional Exercises Participants Functional exercises will include most of the same individuals attending a table-top exercise with additional representatives from other coordination agencies such as Department of Transportation, Parks and Wildlife, Emergency Management Services, hospitals and other entities that could be impacted from failure of a dam. It is helpful to have objective observers to function as evaluators 5 and someone to keep track of timed responses. Some agencies may need to receive calendar request far in advance; discuss potential dates and notification requirements with all agencies you hope to involve prior to choosing a date. Time-line Organizers should plan for a functional exercise to take at least four hours for the exercise plus time for comments and a critique or review. The more complex the scenario and the more participants, the longer the exercise may take to complete. However, if sticking to a schedule is of primary importance, the exercise can be stopped at a set time and consequences of actions taken or delayed, can be discussed and analyzed. The potential for

7 lack of responses and the timing of responses are key aspects of the functional exercise. If responses cannot be completed in the time set-aside, the actual time required should be noted and planned for in the future. Changes may need to be made to the EAP; this may require follow-up meetings. Full-Scale Exercises Participants Typically you would not want to include downstream residents but in addition to all those who would attend a functional exercise, the full-scale exercise needs victims for realism. This is particularly true if you are working with the hospital and helping them meet a regulatory requirement. Victims can be provided from 4-H Clubs, drama groups, or other similar organizations that would have no role in the response to a dam failure emergency. Observers will be needed for each location of activity including the Emergency Operation Center (EOC). Media may also be involved which gives the dam owner the opportunity to test Public Information Officer procedures. These exercises typically involve at least two and sometimes more locations. Observers will be required for each field location and the EOC. Time-line Depending on the complexity of the scenario and the number of participants and locations involved, a full-scale exercise should last most of the day and may last up to three days. Who should facilitate the Exercise? The Orientation Seminar/Workshop can be facilitated by the EAP coordinator for the dam. For most types of drills, the EAP coordinator should be able to facilitate the drill. However, table-tops, functional and full-scale exercises are best realized when they are facilitated by an outside source. This allows the EAP coordinator to be tested as well. Many exercises have begun with a lot of complaining about why it is a waste of time; everyone knows what to do, etc. Often, there is only one person who knows what to do sometimes that is the EAP Coordinator. If the coordinator facilitates the exercise, it becomes very easy to feed the answers to the participants without realizing this. This practice does not test the coordinator and does not always educate the other participants. There are many options for an outsider facilitator. Many consultants design and implement emergency exercises for a living. Make sure that your in-house or consulting engineer does not facilitate they need to be tested as well. Others may be able to provide facilitation assistance include your local city or county Emergency Manager or a trainer from the police or fire department. Your state s dam safety program may have a trainer or be able to recommend someone. Other agencies conduct training and may be able to do site specific training. These include FERC, BuREC, and FEMA. For those who decide to facilitate the exercise, FEMA has an independent study available which includes checklists, evaluation forms and potential boiler-plate scenarios. 6 Scenarios

8 Orientation Seminar/Workshop An Orientation Seminar/Workshop does not require an in-depth scenario. It is designed to acquaint individuals with the EAP and the Notification Flowchart. Drills As mentioned earlier, the drill is testing a specific emergency procedure. Some examples are testing new communication equipment, timing how long it takes to make required notifications, testing knowledge of the Notification Flow Chart, testing specific procedures such as emergency shut-down or start-up procedures. A scenario might test response time for on-call staff or the time it takes to move equipment from the maintenance facility to the dam site. Table-top Exercises Table-top exercises should be based on real events at a similar site or something that could realistically happen at the site. Scenarios do not have to be a dam failure but could include an upstream event, historical rainfall event, storm debris damaging gates with high water levels, rapid development of a significant crack or heavy seepage with movement of material. It can be useful to review inspection reports to find problem areas to expand on for a scenario. Functional Exercise Scenarios should be realistic and based on a real scenario. The problem may include an issue away from the dam that will impact other agencies and organizations ability to respond. Using real time to determine actions is important for a functional exercise so participants need realistic estimates for material movement, travel time of flood waves and response time of assistance. Although field deployment is not included in functional exercises, actual phone calls can be made to verify numbers, radio frequencies, availability of resources, etc. Actual responses can be used to direct the flow of the exercise how long will it take to get more riprap (too long what next?); no riprap available (what now!?). Full-scale Exercises Although you might want to test for a flooding event, it is usually best to use existing weather conditions so responders do not get confused about wind, rain or other issues. They also need to dress for the existing weather conditions. A full-scale exercise gives responders time to set-up seldom used equipment. You can include several small issues that result into one major scenario continuous rainfall upstream while work at your dam site involves equipment failure or an injury which results in a delay in the planned response. It is easy to make up outlandish situations that test a multitude of things (a terrorist poisons the lake and then blows up the dam) but remember that while the outlandish does not usually happen, more than one thing can go wrong. Do not be afraid to have more than one problem. You do not want people standing around with nothing to respond to nor do you want them to finish the job in 15 minutes. If you are working with another agency, make sure the scenario provides everyone the training needed. For instance, hospitals need injured people to exercise their triage system and Emergency Room operations. You will be working with groups of well-trained individuals so use their trainers for ideas on what types of scenarios will challenge them. You want them to enjoy your event, learn from your event, and come back for your next exercise.

9 After the Exercise Conduct a Review Your state emergency management organization or FEMA can provide you with the format and details for preparing a review. FEMA makes forms and guidelines available online. 7 When working with a FEMA funded emergency management organization, a specific form to document the exercise may be required. FEMA calls this an After Action Review which is documented in an After Action Report. Both may be referred to as an AAR. Even if no review is formally required for funding, everyone will benefit from a critique of the exercise. This activity allows you to identify issues of concern, answer questions, and identify possible editing points within the EAP or your Standard Operating Procedures (SOPs). An informal review can involve just discussing the exercise. The AAR review format provided by FEMA can give some structure to an informal discussion. Depending on the size of the group and the complexity of the exercise, the review may consist of going around the room and giving each individual the opportunity to ask questions, address issues of concern or recognize areas of success. A larger group may break up into groups by function (communications group, fire department, evacuations group, security etc.) and report back to the group at large. There are AAR guidelines for a formal written report. When a forma report is required, group discussion should include someone to document conversations. In some instances, groups may be asked to submit a written memo to be incorporated into a final report. Follow-up Even at the Orientation Seminar/Workshop level, it is possible that an issue will be raised that will require a change to the EAP or to existing procedures. Some issues may require additional meeting of a smaller group to resolve. If a problem area is identified during the exercise, it might be resolved with additional training or drills concentrating on a specific procedure or set of procedures. FEMA funding may require the development of an Improvement Plan. FEMA s online plan matrix can be used as a guide to determine the level of editing your EAP requires. Any changes should be submitted to the state dam safety officer before the revisions are distributed to the plan holders. Keep in Shape! Keeping in shape does not end with the completion of an exercise. The cycle consists of developing or changing the EAP. Annually, the EAP is reviewed and new employees are introduced to the EAP. Employees participate in drills for specific procedures and table-tops are held, depending on requirements, every 3 to 5 years. Functional and Full-scale exercises are required in some jurisdictions. After each review and exercise, the EAP should be edited as necessary and those impacted are notified of any changes. Then, the process begins again. 8

10 References 1. Association of State Dam Safety Officers Dam Safety in the States; (with links to most state dam safety programs) 2. FEMA Federal Guidelines for Dam Safety Emergency Action Planning for Dam Owners, Interagency Committee on Dam Safety, US Department of Homeland Security, Federal Emergency Management Agency, October 1998 and April 2004, Washington, D.C. 3. Federal Energy Regulatory Commission Engineering Guidelines for the Evaluation of Hydropower Projects Chapter 6: Emergency Action Plans; 4. Owner s Dam Safety Program What Will FERC Be Looking For During Inspections? FERC Division of Dam and Safety Inspections Revision 2, June 3, HSEEP Evaluator Template form 1257-HSEEP; Planning/Operations Based Exercises/Evaluation 6. Exercise Design IS139, FEMA, Washing DC, March 2003 available at 7. After Action Review/Improvement Plan HSEEP template form 1015-HSEEP; Planning/OperationsBasedExercises/ImprovementPlanning 8. Training and Exercise Plan Workshop User s Handbook, Department of Homeland Security, 2006.