Document 2098073

Supplemental Environmental Projects Plan
Silvertip Pipeline Incident Response – Yellowstone River, Montana
ATTACHMENTS – INDIVIDUAL SEP IMPLEMENTATION PLANS
Attachment 1
Yellowstone River sACP and Spill Response Equipment Staging SEP Plan
Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
Attachment 3
Huntley Dam Fish Passage Rehabilitation Construction Grant SEP Plan
Attachment 4
Yellowstone River Channel Migration Easement Program Grant SEP Plan
Attachment 5
Clean Diesel School Bus Program Grant SEP Plan
21
Attachment 1
Supplemental Environmental
Projects Implementation Plan
Yellowstone River Sub-Area
Contingency Plan and Spill
Response Equipment Staging
SEP Plan
January 18, 2013
Supplemental Environmental Projects Plan – Attachment 1
Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
TABLE OF CONTENTS
INTRODUCTION.................................................................................................................................................. 1 DESCRIPTION AND DETAILED SCOPE ................................................................................................................... 1 YELLOWSTONE RIVER SACP .............................................................................................................................................. 2 FIELD ASSESSMENT AND TACTICAL RESPONSE PLAN ............................................................................................................... 3 RESOURCE ASSESSMENT / EVALUATION .............................................................................................................................. 4 ADDITIONAL STAGING OF EQUIPMENT ................................................................................................................................ 5 TRAINING / EXERCISE PROGRAM ........................................................................................................................................ 5 ANNUAL MAINTENANCE .................................................................................................................................................. 6 BENEFITS ........................................................................................................................................................... 6 SPONSOR AND PARTICIPANTS ............................................................................................................................ 7 REQUIREMENTS AND RELATIONSHIP TO OTHER SEPS ......................................................................................... 9 SCHEDULE MILESTONES AND COMPLETION ........................................................................................................ 9 COST ESTIMATE ................................................................................................................................................ 11 TABLES 1‐1
1‐2
1‐3
SUB‐AREA CONTINGENCY PLAN CONTENTS TACTICAL RESPONSE PLAN CONTENTS PROJECT COST ESTIMATE FIGURES 1‐1
1‐2
1‐3 YELLOWSTONE RIVER WATERSHED SACP COVERAGE MAP FIELD ASSIGNMENT SHEETS SUMMARY OF MAJOR TASKS, DURATION, AND MILESTONES ii
Supplemental Environmental Projects Plan – Attachment 1
Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
INTRODUCTION
This Supplemental Environmental Project (SEP) includes numerous elements, all of which aim to
enhance emergency response in the region. There are three major components that will result from this
SEP: a Sub-Area Contingency Plan (sACP) for the region, a revised and expanded Tactical Response
Plan (TRP) for the region, and augmentation of existing spill response equipment and equipment staging.
The enhanced preparedness and capacity building accomplished through this SEP will directly benefit
natural resources and the environment along Montana’s middle and lower reaches of the Yellowstone
River in the event of future incidents in the area.
The sponsor for this SEP is U.S. Environmental Protection Agency (USEPA) Region VIII. Written plans
developed under this SEP will be provided to the sponsor for review and written approval, and inclusion in
the Region VIII Area Contingency Plan as an annex or a Geographic Response Plan (GRP) with the
intent that the augmented plan will be used by all public and private emergency response organizations in
the region. These organizations are expected to include Local Emergency Planning Committees (LEPCs),
Tribal Emergency Response Commissions (TERCs), State Hazardous Materials Incident Response
Teams (SHMIRTs), local Fire Departments, private industry, and other organizations that play a central
role in spill prevention, preparedness, and response.
DESCRIPTION AND DETAILED SCOPE
This SEP provides assessment, contingency planning, training, and equipment for a portion of the
Yellowstone River watershed within Big Horn, Yellowstone, Carbon, Stillwater, Sweet Grass, Park,
Gallatin, Treasure, Rosebud, and Custer counties of Montana, and through the stem of the Yellowstone
River downstream to the Missouri River confluence (Figure 1-1). Through a well-organized and
collaborative planning process, current capabilities of local emergency response providers will be
identified and enhanced to create greater opportunities for safe, coordinated, and effective incident
response.
Specific elements that will be developed and delivered for the defined coverage area under this SEP
include:

Yellowstone River sACP

TRP baseline desktop/office work (e.g., mapping and analysis)

Field assessment to develop a TRP for the sACP region

Additional spill response equipment and equipment staging

Training and exercises for local emergency responders, including boom deployment and handson use of other response equipment to foster familiarity with the sACP and TRP; additionally,
targeted grant funding may be provided to assist LEPCs in the region providing training (e.g.,
HAZWOPER) to local individuals

Guidance for proper handling and disposal of spill cleanup waste
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan

sACP and TRP annual maintenance for three years
These elements will focus on use, storage, transportation, and response to petroleum and petroleumrelated releases within a defined region of the Yellowstone River watershed. This SEP does not provide
full hazardous materials contingency planning, assessments, training, or equipment; instead, it focuses
on petroleum and related substances. The sACP and TRP will be included as an annex or addendum to
the Region VIII Area Contingency Plan and the sponsor will integrate participation by public emergency
response entities within the region. Private entities with significant petroleum use, transportation, or
storage within the region will also participate in the development process. The sponsor, in coordination
with EMPCo, will lead this effort through the Montana-Wyoming Oil Spill Control Cooperative (COOP).
Yellowstone River sACP
The sACP will be developed to facilitate a safe, coordinated, and effective response by private industry
and representatives of local, state, and federal agencies to petroleum discharges within the defined
region. The goal of this sACP development task is to enhance existing plans, improve response
readiness through well-defined response procedures, and familiarize responders with all aspects of
response requirements. The sACP document will include the following:
Table 1-1
Sub-Area Contingency Plan Contents
sACP Document Heading
Scope
Purpose
Coordinated emergency response
planning
Description of sub-regional area
Response operations and roles
Natural Resource Damage
Assessment (NRDA) Trustees
Hazard identification
Hazard analysis
Additional Clarification
Among federal, state, local, and tribal entities and private industry
Including a map of the coverage area
Includes identifying local authorities and contact information
List of NRDA Trustees
 Facilities with reportable quantities of hazardous material (with National
Institute for Occupational Safety & Health information)
 Hazardous waste (Resource Conservation and Recovery Act) and special
waste disposal facilities
 Hazardous and non-hazardous waste handling procedures
 Abandoned facilities (Comprehensive Environmental Response,
Compensation, and Liability Act [CERCLA] sites)
 Oil storage facilities
 Transportation hazards (highways, trains, chemicals carried)
 Hazardous spill events
 Natural hazards
 Identification of high density populations
 Sensitive human populations (very old, very young demographics)
 Identification of environmentally sensitive areas (waterways, wetlands,
fish, and wildlife species)
 Identification of other sensitive receptors (municipal water intakes,
irrigation channels)
Risk analysis
Credible worst case scenarios
Training, health, and safety
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
sACP Document Heading
Additional Clarification
Appendices
Tier II reporting facilities
Tier I and/or Tier II information consists of aggregate data on the amounts
and general location of hazardous materials stored at facilities subject to
Superfund Amendments and Reauthorization Act) SARA. This will include all
vulnerable zones for Tier II reporting facilities.
CERCLA sites
Highway identifications
Stream gauging information
Population data and demographics
Sensitive populations
Sensitive environments and species
Acronyms
Field Assessment and Tactical Response Plan
EMPCo maintains a TRP for its facilities in Montana (Silvertip Pipeline Tactical Response Plan, South
Central Montana). This TRP supports response to releases at EMPCo assets and within a reasonable
coverage area within proximity to each asset. This existing TRP will serve as a baseline to guide creation
of a regionally applicable, revised, and expanded TRP. The revised TRP will provide expanded coverage
of benefit to all facilities that use, store, or transport petroleum within the defined sub-area region and will
extend downstream through the major tributaries and middle and lower stem of the Yellowstone River to
its confluence with the Missouri River. The revised TRP will be a discrete plan developed in conjunction
with the sACP and will be available to public and private entities for use in support of spill response in the
region.
Segments of waterways that will be evaluated and supported by the revised TRP are highlighted in Figure
1-1.
Initially, a field assessment will be conducted to identify, inventory, and evaluate the information needed
to supplement the existing plan and to broaden the coverage area. This assessment includes
identification of sensitive environments and resources (e.g., water intakes, sensitive habitats) that would
be prioritized for protection in the event of a future spill. This information will also be used to identify
current and potential new locations for response deployment during protection, containment, and cleanup
activities. From that inventory, specific access points will be identified, evaluated, and selected, including
an assessment of the feasibility and resources needed to support response activities at/from those
locations. Staging areas will also be identified, evaluated, and selected based on factors that include
tactical strategy and proximity to access points and sensitive environments and resources.
In summary, the TRP developed under this SEP will include these specific elements:

Identification of sensitive environments and resources

Identification, evaluation, and selection of access points for response, protection, containment,
and cleanup activities
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
Identification, evaluation, and selection of response equipment and staging locations for response
equipment and supplies, including additional equipment and storage containers purchased
through the emergency response equipment SEP that is integrated with this SEP

Field assessment documentation of each access location’s details, including digital photographs

Driving directions to each location that is accessible by vehicles

Strategy maps (utilizing high resolution imagery) that include response tactics such as underflow
dams, earthen dams, containment, protection, and recovery

Field Assignment Sheets (ICS 204s; Figure 1-2) listing the types of response equipment and
quantity needed to implement response strategies identified within each area.
The revised and expanded TRP will include the specific elements listed in Table 1-2 below.
Table 1-2
Tactical Response Plan Contents
TRP Document Heading
Scope
Purpose
Plan distribution list
Emergency response
Additional Clarification
Physical contact information
Response division maps, river and tributary division maps (including response
sites)
Appendices
Staging area overview map
Incident command systems forms
Site safety plan and Material Safety
Data Sheets
Spill response methods
Aerial and base map
Introduction, inland shoreline cleanup methods, alternative response methods,
generic strategies
Resource Assessment / Evaluation
The incident response resource capacity for the region will be evaluated to identify what is needed to
enhance response capabilities. In addition to the information produced for development of the TRP, an
inventory of available response resources will be conducted. This inventory will identify the oil spillspecific and oil spill support equipment, material, and personnel available through public and private
sector entities and will be compiled by location. This information will be compared to the Field Assignment
Sheets developed for the TRP to identify resource needs for enhancing the region’s response capacity.
These identified needs will form the basis of recommendations made to Montana Department of
Environmental Quality (MDEQ) and USEPA for purchase (and recipients) of equipment to be acquired
and donated by EMPCo under this SEP. Equipment will include, at a minimum, personal protective
equipment, multi-meters, absorbent boom, etc.
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
Recommendations for purchase of additional response equipment, potential staging locations, and
selection of recipient organizations to maintain/manage the equipment will be included in the resource
assessment/evaluation for approval by USEPA and MDEQ prior to actual purchase and delivery for
staging. This will include the criteria, bases, and rationale upon which response equipment and staging
methods and locations recommendations are based.
Additional Staging of Equipment
The resource assessment/evaluation will provide detailed recommendations to the sponsor and MDEQ
for equipment needs in the region; these recommendations will include equipment identification and
quantity, staging and transport method and location, and identification of equipment recipients. Response
equipment will be stored at locations where they can be managed, maintained, and used by government
first responders. Upon approval by the sponsor and MDEQ, EMPCo will purchase and deliver equipment
to the recipient(s) and provide training on use of the equipment.
Training / Exercise Program
This SEP includes training and deployment exercises for agency and local response personnel within the
defined region, and grant funding to LEPCs to provide HAZWOPER training to local members of their
community (feasibility, selection criteria, and numbers of participants to be targeted are yet to be
determined). Training includes sessions to facilitate understanding of the sACP and TRP, plus fieldbased, hands-on deployment exercises using the revised TRP. Field training exercises include booming
techniques in fast water environments and field deployment of response equipment. The training and
deployment exercises will be open to all public and private sector participants (as identified in Sponsor
and Participants section below).
Based on input during MDEQ’s November 15, 2012 public meeting held in Billings, the feasibility and
utility of grant funding will be evaluated to consider whether LEPCs or possibly other local entities could
provide HAZWOPER or other spill response training for local members of the community (selection
criteria for participation will need to be developed). These potential additional training opportunities could
target volunteer fire department staff or other appropriate local resources. As to the potential funding and
timing of such training, the funds would most likely be provided at the completion of this SEP for use by
the LEPCs or other entities for events during the annual maintenance period. Any program or additional
funding must be within the overall SEP budget described below and must be determined by USEPA,
MDEQ, and EMPCo to be feasible, cost-effective, targeted, and administratively simple to implement,
document, and verify success and completion. For planning purposes, the budget for this SEP includes a
$20,000 line item for this potential additional training. This estimate may be adjusted based on further
evaluation and input from the sponsor and others, but this additional training funding is not to exceed the
overall budget allocated for completion of all primary elements of this SEP.
Three training sessions will be conducted throughout the region. Specific training locations will be
determined during the planning process; however, training is expected in the following general locations:

Upstream of Billings, along the Yellowstone River

Billings, along the Yellowstone River

Downstream of Billings, along the Yellowstone River
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
Training sessions will be scheduled through the late summer and possibly early fall months to facilitate
scheduling options for local responders. The TRP may not be fully complete prior to these events;
however, the plan will be sufficiently and substantively complete for the purposes of the training and
related exercises. The Billings COOP conducts its seasonal exercise in mid-summer in Billings, and to
maximize participation, the Billings training/exercise under this SEP may coincide with this COOP event.
Safety is of utmost importance during these training exercises, so the three sessions will only occur when
physical and weather conditions are safe and favorable. All three sessions are expected to be completed
within 2013, but if river or weather conditions are not favorable for some reason, any remaining training
sessions will be postponed until 2014. Dates, locations, and participants for each training session will be
coordinated by USEPA as the SEP sponsor, with concurrence and approval by EMPCo and MDEQ.
Annual Maintenance
The sACP and TRP will be maintained for a period of three years from the date those documents are
submitted to the sponsor. Specific maintenance tasks include:

Updating contact information

Incorporating supplemental information provided by the sponsor

Revising and/or upgrading lessons learned from training and exercises

Revising and/or upgrading lessons learned from drills and actual incidents, as provided by the
sponsor

Incorporating edits required by the sponsor
Plans will be updated annually and submitted to the sponsor in both hard copy and electronic PDF
formats.
BENEFITS
This SEP provides spill response planning, training, exercises, and equipment. These elements will
improve local organizations’ ability to meet regulatory obligations and improve their ability to safely and
effectively respond to future petroleum-related releases within the identified region.
Resource needs within the region will be evaluated and will serve to identify sensitive areas, potential
access locations, equipment needs, and equipment staging locations that may enhance or supplement
future response to petroleum releases. The sACP and TRP documents will improve local organizations’
ability to fulfill their obligations under the Emergency Planning and Community Right-to-Know Act to
collect information to assess facilities that manufacture, use, transport, or store petroleum products within
their jurisdiction; to develop emergency response plans; to train emergency response personnel; and to
safely, quickly, and effectively respond to petroleum spills. Similarly, information developed in these plans
will enable state and local communities to plan for and effectively respond to petroleum releases and
inform potentially affected citizens of the potential hazards posed by these incidents. It will also enhance
public and private ability to protect sensitive environments and resources potentially affected by incidents.
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
Training and exercises will help put the sACP and revised TRP into operation to further improve the
coordination and effectiveness of responders during an incident within this region.
These and other benefits resulting from this SEP will be measured by:

Development and delivery of the sACP, TRP, and other supporting documents to USEPA

Inventory, assessment, and augmentation of response equipment and staging

Development and delivery of training and field exercises in coordination with USEPA

Potential delivery of additional targeted local training opportunities (e.g., HAZWOPER)

sACP and TRP maintenance support provided to USEPA for a period of three years

Written approval by USEPA of the sACP, TRP, and equipment staging
SPONSOR AND PARTICIPANTS
The sACP and TRP documents, and equipment staging inventory and locations, will be developed and
submitted to the sponsor, USEPA Region VIII for written approval. Upon acceptance, plans will become
the sponsor’s property. While EMPCo will provide basic editorial support to USEPA in maintaining the
new sACP and revised TRP for a period of three years, these plans will remain the property and
responsibility of USEPA throughout this period. It is EMPCo’s understanding that the USEPA, as the
sponsor, will solicit participation by and will distribute the plans to the participants identified below. In
addition, EMPCo can assist USEPA in soliciting and pursuing participation of private industry through the
COOP.
The Response Group, Inc. (TRG) is a provider of software and services related to emergency response
planning and support. TRG will develop the sACP and the TRP, and will conduct the field assessment,
training, and exercises on EMPCo’s behalf.
ARCADIS, a national engineering and science consultancy with offices in Montana and personnel in
Billings, will provide technical services on behalf of EMPCo to facilitate progress and successful
completion of this SEP. These services include, but are not limited to, working with TRG and the sponsor
to develop the plans and resource assessment/evaluation report, identify and coordinate equipment
staging recipients and locations, compliance reporting to the sponsor and MDEQ, and facilitate the timely
and cost-effective completion of this project as specified in this SEP Plan.
Although ARCADIS and TRG are not headquartered in Montana, this SEP involves considerable
expenditure within Montana and the target region for supplies, travel accommodations, local services and
labor, and ultimately investment of time, money, and resources in preparation and implementation of
regional/local spill response plans, training, and equipment staging.
EMPCo and MDEQ expect full cooperation by all parties involved in this SEP to require and retain all
project-related documentation, correspondence, expense receipts, itemized invoices, and all other forms
of documentation needed to develop and support the quarterly SEP Progress Reports and final SEP
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
Completion Report. Such documentation will be provided by all participants in a timely manner so as not
to cause delay in schedule, increase in scope or cost of the SEP, or interfere with full compliance with all
implementation and reporting requirements specified in this SEP Plan, the AOC, and the SEP Policy.
Primary contacts for this SEP are:
USEPA (SEP Sponsor):
Steven B. Merritt
Federal On-Scene Coordinator
Emergency Response Unit
1595 Wynkoop Street
8EPR-ER/SA
Denver, CO 80202-1129
(303) 312-6146 office
(303) 775-7226 cell
[email protected]
EMPCo:
Brian T. Magruder
Environmental Supervisor
ExxonMobil Pipeline Company
800 Bell Street
Houston, TX 77002
(713) 656-2190 office
(713) 898-5736 cell
[email protected]
The Response Group:
Jeff Berg
13939 Telge Road
Cypress, TX 77429
(281) 880-5000 office
(832) 493-5142 cell
[email protected]
ARCADIS:
Debbie J. Vreeland
Vice President / Oil & Gas Market Sector Manager
ARCADIS U.S., Inc.
70 Stringari Lane
Belfry, MT 59008
(406) 664-3377 office
(406) 839-6023 cell
[email protected]
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
REQUIREMENTS AND RELATIONSHIP TO OTHER SEPS
This SEP includes assessment, plan development, and training that will be provided on a time and
materials basis by TRG. This SEP also provides equipment to be acquired, staged at appropriate
locations, and donated to local agencies by EMPCo. Total costs for implementation and completion of this
SEP are not to exceed the budgeted amount described later in this plan, although some reasonable
redistribution of funds among the line item tasks of this SEP can be expected as more detailed project
planning is completed. Any changes in budget, use, or reallocation of funds within or outside this SEP are
at the discretion of EMPCo, with concurrence and prior written approval by MDEQ. Should actual costs of
this SEP be less than estimated here, remaining funds will be transferred to another MDEQ-approved
SEP.
SCHEDULE MILESTONES AND COMPLETION
After MDEQ approval of the SEP Plan, the planning process under this SEP will begin within 30 days.
Initially, a kickoff meeting or conference call will be held with the sponsor and other key agency and
industry participants to determine in more detail the development process and schedule milestones for
delivery of the plan documents, training/exercises, and equipment purchase/staging.
The sACP will require approximately six months to develop and submit to the sponsor. The plan will be
submitted in hard copy and electronically in PDF format.
Development of the TRP will be completed in three segments: Billings and upstream and downstream of
Billings. Field assessment for the upstream segment will initiate during the sACP preparation, and will
include development of the segment’s TRP; training and exercises will immediately follow the assessment
and plan development, and will include three training and exercise sessions conducted within each of the
TRP segment areas. Training and exercises may be conducted prior to full and final TRP development to
allow the training and exercises to be completed safely during the low water season in 2013. The TRP will
be developed to substantial completion prior to the low water season; otherwise training and exercise
sessions will require scheduling in the summer of 2014. This process will allow the training and exercise
events to occur during lower water flow seasons, creating conditions for safe field exercise events. The
three segment TRPs will be combined, and lessons learned from the exercises will be incorporated into a
final master TRP. The final TRP development will be completed approximately eleven months after
MDEQ approval of the SEP Plan. The TRP will be submitted in both hard copy and electronic PDF
formats.
During this TRP development process, a recommendation for equipment purchase and staging locations
will be prepared and submitted to USEPA and MDEQ. Upon approval by USEPA and concurrence by
MDEQ and EMPCo, the equipment will be purchased and delivered to the appropriate staging areas.
Depending upon availability and vendor, delivery of the equipment is believed to be possible within
approximately 90 days after approval of the equipment plan by USEPA and concurrence by MDEQ and
EMPCo. Note that if actual costs for plan development and training exceed the estimated budget needed,
funding will be reallocated from the equipment budget or possibly other approved SEP budgets, with prior
written approval of MDEQ.
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
After delivery of the sACP and TRP to USEPA, EMPCo will execute a retainer agreement with TRG to
provide plan maintenance for a three year period. Upon execution of this agreement, all implementation
activities required under this SEP will be complete. Plans will be updated annually and submitted to the
sponsor in both hard copy and electronic PDF formats.
These major tasks, milestones, and approximate duration are shown on Figure 1-3 below. A more
detailed schedule will be developed with the project team during the sACP SEP development/kickoff
meeting.
This SEP will be considered complete and successful upon delivery to and subsequent approval of the
sACP and TRP by the sponsor, completion of three training and exercise sessions, contracting and
funding a retainer agreement to TRG for the three year maintenance program, and delivery and sponsor
approval of purchased equipment to identified recipients and staging locations. The Completion Report
for this SEP will then be submitted to MDEQ within 90 days.
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
COST ESTIMATE
This SEP will be implemented by EMPCo, contracting directly with TRG and ARCADIS. On behalf of
EMPCo, ARCADIS will manage this SEP while TRG provides the plan preparation, training, exercise, and
maintenance functions. ARCADIS will assist with development of the plans, and will develop the resource
assessment/evaluation. The TRG contract will be a time and materials based contract for all elements
with the exception of the maintenance program, which will be procured through a pre-purchased retainer
with TRG.
Allowable costs within this SEP to be accounted as creditable against the SEP budget and AOC
requirement will include consulting costs incurred by TRG and ARCADIS, plus direct expenses (e.g.,
travel) related to implementation of this project. No internal EMPCo labor expense will be charged. Other
expenses may include additional consultant or contractor fees to facilitate training and exercises, direct
purchase and delivery cost of equipment donated, and potential additional grant funding to LEPCs or
other organizations for HAZWOPER or related local/community training programs. Final cost reporting in
the SEP Completion Report will include only actual and documented expenses incurred by TRG,
ARCADIS, other outside vendors as needed, or for direct expenses. Supporting backup documentation
will include itemized invoices detailing the time and material charges, with copies of all expenses
included.
Table 1-3 provides a summary of tasks and estimated costs for this SEP.
Table 1-3
Project Cost Estimate
Activity
Estimated Cost
Development of the sACP
$75,000
Development of the TRP
$330,000
Conduct Training and Exercises
$110,000
Conduct Targeted Local HAZWOPER Training
$20,000
Annual Plan Maintenance for three (3) years
$18,000
Total Cost for sACP, TRP, Training/Exercise
Additional Staging of Spill Response Equipment
Total Estimated Cost to Implement this SEP
$553,000
$250,000
$803,000
As noted previously and with MDEQ concurrence and written approval, if any of the above plan
development or training activities cost less than estimated here, those remaining funds will be reallocated
to purchase of additional response equipment or transferred to another MDEQ-approved SEP. Similarly, if
actual need and cost of equipment is determined to be less than estimated above, those remaining funds
will be reallocated as needed within this SEP or transferred to another MDEQ-approved SEP.
Conversely, if actual costs for plan development and training activities cost more than estimated here, the
needed funding will be reallocated from the response equipment line item budget. In no case or
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circumstance will the equipment purchase and staging line item budget exceed the estimated $250,000
specified here unless excess funds are available for transfer from another MDEQ-approved SEP without
causing harm or limitation to the donor SEP(s).
Consistent with this approach, in no case or circumstance will the total cost of this SEP exceed the
estimated $803,000 specified here unless excess funds are available for transfer from another MDEQapproved SEP without causing harm or limitation to the donor SEP(s). Any changes in budget, allocation
of funds across the above budget line items, or transfer of budget or funds with other SEPs will be at the
discretion of EMPCo, and in concurrence and with written approval by MDEQ. Further, any such changes
will be documented in the applicable SEP Completion Report.
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Yellowstone River Sub-Area Contingency Plan and Spill Response Equipment Staging SEP Plan
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Attachment 2
Supplemental Environmental
Projects Implementation Plan
Gas Leak Detection
Infrared Camera and
Operator Training SEP Plan
January 18, 2013
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
TABLE OF CONTENTS
INTRODUCTION.................................................................................................................................................. 1 DESCRIPTION AND DETAILED SCOPE ................................................................................................................... 1 BENEFITS ........................................................................................................................................................... 2 SPONSOR AND PARTICIPANTS ............................................................................................................................ 2 REQUIREMENTS AND RELATIONSHIP TO OTHER SEPS ......................................................................................... 3 SCHEDULE MILESTONES AND COMPLETION ........................................................................................................ 3 COST ESTIMATE ................................................................................................................................................. 4 TABLE 2‐1 PROJECT COST ESTIMATE FIGURES MANUFACTURER’S SPECIFICATIONS MANUFACTURER’S QUOTE ii
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
INTRODUCTION
Infrared (IR) imagery is a safe and efficient method for detecting hydrocarbon vapor leaks to the
atmosphere in pipeline operations, petroleum terminal facilities and tank trucks, oil and gas production
operations, and process equipment in the refining or petrochemical industries. IR cameras are portable,
and allow rapid and remote detection of fugitive air emissions from above ground components without
disassembly of components or other intrusive means.
IR cameras are used by industry personnel for inspection and maintenance activities, and by regulators
for compliance monitoring and assessment. This Supplemental Environmental Project (SEP) will provide
to the sponsor, Montana Department of Environmental Quality (MDEQ), one FLIR Commercial Systems,
Inc. GF300-24° IR camera, with accessories and 1-year service contract, and on-site Optical Gas Imaging
Training for up to 12 MDEQ operators.
DESCRIPTION AND DETAILED SCOPE
According to the supplier’s website, the FLIR GF300-24° IR camera offers a preventative maintenance
solution to spot vapor leaks in above ground piping, flanges, and connections in petrochemical
operations. The camera can rapidly scan large areas and pinpoint leaks in real time. Thousands of
components can be scanned per shift without the need to interrupt facility operations. It reduces repair
downtime and is proven to be exceptionally safe, allowing potentially dangerous leaks to be monitored
from several meters away.
As an auditing, compliance, and pollution prevention tool, the FLIR GF300-24° is expected to improve
work safety, environmental/regulatory compliance, and help find vapor leaks. The camera also embeds
GPS data into the image allowing workers to pinpoint the location of a leak.
As specified by MDEQ, the following items will be purchased and donated to MDEQ:

FLIR GF300-24o IR camera (quantity = 1)

IR lens, 14.5o with case (quantity = 1)

IR lens, 6o with case (quantity = 1)

Extra battery (quantity = 1)

Battery charger, including power supply with multi-plugs (quantity = 1)

Platinum Premier Service Contract (quantity = 1 year)

Customer On-Site Optical Gas Imaging training for up to 12 students (including instructor travel
expenses)

Shipping of the camera and accessories

See attached additional specifications from FLIR for more details
One single on-site training course (in-state location and time to be determined by MDEQ), Optical Gas
Imaging Training, will be led by a professional trainer from the manufacturer’s Infrared Training Center.
1
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
According to the supplier, students will learn how to set up and operate the FLIR GF300-24°, adjust the
camera for varying conditions, identify different vapors and leak size limitations, and understand basic
inspection procedures. Students will also learn basic IR theory and heat transfer concepts. Lab and field
practice in finding leaks is also a mandatory portion of the training. Students will observe videos of leaks
and learn what to look for including thermal contrast, vapor plume motion, and distance limitations. Each
student must complete a related field assignment as part of the training. At the end of the course,
students will be provided with a student manual and a CD with presentation files.
Students earn Optical Gas Imaging Thermographer Certification when they complete the following:
1. Attend each day of the three day course (8:00 a.m. – 5:00 p.m.)
2. Perform lab activities as instructed
3. Pass a three page written exam
4. Submit a course evaluation
5. Complete an acceptable field assignment
BENEFITS
The FLIR GF300-24° IR camera is expected to improve MDEQ’s ability to conduct inspections and audits
of above ground refinery, pipeline, and other infrastructure where vapor leaks or other operations and
performance parameters are detectable via IR technology (even if not apparent to the unaided eye). The
device adds value in emergency preparedness and response, plus it will be a useful tool during MDEQ
assessment, audit, and inspection activities. The tool is expected to be used in the region and statewide.
Benefits of this SEP are measurable in several ways. The device uses state of the art technology that is
highly sensitive and effective for detecting vapor emissions. The technology can be used to detect many
hydrocarbons in the alkane, alkene, and aromatic groups at leak rates below 5 grams per hour (g/hr), and
reportedly benzene detections at 3.5 g/hr. The instrument allows remote inspection of systems without
need for shutdown of those systems, and the technology will reduce labor hours and costs associated
with physical or intrusive testing.
Remote sensing with the device increases operator and facility health and safety by allowing the operator
to stand a safe distance from target equipment, and to the extent the device detects leaks it will directly
prevent or reduce emissions of volatile organic compounds into the atmosphere.
The training component brings additional benefit through the training and certification of up to 12 MDEQ
operators, thus increasing the number of personnel capable of properly using the tool and applying its IR
technology.
SPONSOR AND PARTICIPANTS
MDEQ is the sponsor for this SEP, and will receive the products and training purchased by EMPCo. The
equipment and training will be provided by FLIR Commercial Systems, Inc.
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Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
Primary contacts for this SEP are:
MDEQ (SEP Sponsor):
Dave Aguirre
Montana Department of Environmental Quality
49 North Main, Suite B
Butte, MT 59701
(406) 782-2689
[email protected]
EMPCo:
Brian T. Magruder
Environmental Supervisor
ExxonMobil Pipeline Company
800 Bell Street
Houston, TX 77002(713) 656-2190 office
(713) 898-5736 cell
[email protected]
ARCADIS:
Debbie J. Vreeland
Vice President / Oil & Gas Market Sector Manager
ARCADIS U.S., Inc.
70 Stringari Lane
Belfry, MT 59008
(406) 664-3377 office
(406) 839-6023 cell
[email protected]
REQUIREMENTS AND RELATIONSHIP TO OTHER SEPS
MDEQ will designate training participants, coordinate the training directly with FLIR, and report to EMPCo
the training date, time, and participants. MDEQ will be responsible for all participant scheduling, labor,
travel, lodging, meals, and other costs that may be necessary to attend the training.
This SEP is not directly related to other SEPs. Costs are based upon a current fixed-price quote from
FLIR; should costs vary from the current quote, funds will be either transferred from or transferred to other
SEPs to supplement as appropriate, with prior written approval by MDEQ.
SCHEDULE MILESTONES AND COMPLETION
As shown in the simplified schedule below, this project will initiate within 30 days of the final SEP Plan
approval by MDEQ and is anticipated to conclude within approximately 120 days thereafter. The camera
and associated equipment will be delivered to MDEQ as noted above within 90 days of order receipt.
MDEQ will coordinate onsite training directly with FLIR (according to FLIR, the single onsite training
session typically requires eight weeks advance booking).
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Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
This SEP will be considered complete and successful upon EMPCo’s delivery of the IR Camera
equipment and accessories to MDEQ, and payment for training MDEQ personnel. The SEP Completion
Report will be prepared and submitted to MDEQ within 90 days of equipment/training purchase.
Maintenance/utilization of the service contract and completion of the training is funded and expected
under this SEP but such completion is the responsibility of MDEQ and will not affect the fact that this SEP
is considered complete upon purchase and delivery of the IR camera, accessories, and training package.
COST ESTIMATE
EMPCo will process all payments directly with FLIR Commercial Systems, Inc., and with the associated
Infrared Training Center. Table 2-1 provides a summary of estimated costs for this SEP.
Table 2-1
Project Cost Estimate
Activity
FLIR GF300-24° IR camera, accessories, 1-year service
Onsite training of up to 12 personnel
Total Estimated Cost to Implement this SEP
Estimated Cost
$116,000
$17,000
$133,000
Notes:
Estimate above is based on a November 2012 quote (attached) received from the manufacturer and
according to FLIR is valid through February 2013.
 EMPCo to purchase the camera, accessories, service contract, and training; MDEQ is responsible for
coordinating and completing the training.
 FLIR quote and this cost estimate do not include sales taxes that may be applicable.

4
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
5
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
6
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
7
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
8
Supplemental Environmental Projects Plan – Attachment 2
Gas Leak Detection Infrared Camera and Operator Training SEP Plan
9
Attachment 5
Supplemental Environmental
Projects Implementation Plan
Clean Diesel School Bus
Program Grant SEP Plan
January 18, 2013
Supplemental Environmental Projects Plan – Attachment 5
Clean Diesel School Bus Program Grant SEP Plan
TABLE OF CONTENTS
INTRODUCTION.................................................................................................................................................. 1 DESCRIPTION AND DETAILED SCOPE ................................................................................................................... 1 BENEFITS ........................................................................................................................................................... 2 SPONSOR AND PARTICIPANTS ............................................................................................................................ 2 REQUIREMENTS AND RELATIONSHIP TO OTHER SEPS ......................................................................................... 3 SCHEDULE MILESTONES AND COMPLETION ........................................................................................................ 3 COST ESTIMATE ................................................................................................................................................. 4 FIGURE 5‐1 MONTANA CLEAN DIESEL SCHOOL BUS PROGRAM APPLICATION ii
Supplemental Environmental Projects Plan – Attachment 5
Clean Diesel School Bus Program Grant SEP Plan
INTRODUCTION
More than half of today’s school buses have been in service for over a decade. These older buses lack
today's emissions control and safety features, and can have nearly twice the amount of emissions per
mile as a semi-truck. Montana Department of Environmental Quality (MDEQ) administers the Montana
Clean Diesel School Bus Program (CDSB Program), which is designed to reduce human exposures to air
emissions from motor vehicle diesel exhaust by replacing older school buses with those that meet at least
the 2010 emissions standards. The program provides matching funds to school districts for replacing
buses that meet the program criteria.
This program accepts grant funds in varying amounts that can be earmarked for specific school districts,
in this case within Yellowstone or downstream counties affected by the incident. Based on public input
received during MDEQ’s November 15, 2012 public meeting in Billings, this approved Supplemental
Environmental Project (SEP) will remain unfunded until completion of all other SEPs. If at that time
surplus funds remain from other SEPs and MDEQ provides its prior written approval, those funds will be
transferred to this SEP and granted to the CDSB Program.
DESCRIPTION AND DETAILED SCOPE
The U.S. Diesel Emissions Reduction Act (DERA) was part of the Energy Policy Act of 2005. DERA
provided new diesel emissions reduction grant authority to the U.S. Environmental Protection Agency
(USEPA). Through this authority, USEPA’s state grant assisted MDEQ in developing the CDSB Program.
The CDSB Program focuses on reducing diesel emission exposure to susceptible populations and in
designated air quality areas identified in Montana’s air quality State Implementation Plan (SIP).
The CDSB Program provides funds to school districts for the purpose of replacing older buses. MDEQ
manages the program and awards funding to districts for replacement buses that meet specific criteria.
School districts apply for replacement of specific buses; the applications (Figure 5-1) are point scored for
consideration, prioritization, and award. Upon approval, the districts are required to produce matching
funding in order to purchase a replacement bus or buses.
Older buses that are removed from service under the CDSB Program must be shredded and recycled to
prevent them from being reused for another purpose and thus not achieve a net reduction in air
emissions. In addition to meeting at least 2010 emissions standards, new replacement buses must be
equipped with engine block heaters to reduce/eliminate the need for idling (and emissions) during engine
warm up.
Under this SEP and if surplus funds are available from the other SEPs, MDEQ will direct ExxonMobil
Pipeline Company’s (EMPCo’s) grant to school districts in Yellowstone, Treasure, Rosebud, and Custer
Counties (specifically requested by several participants at MDEQ’s November 15, 2012 public meeting in
Billings). Upon funding availability, MDEQ will solicit applications from districts within these counties, and
apply the CDSB Program criteria and ranking to determine specific awards.
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Supplemental Environmental Projects Plan – Attachment 5
Clean Diesel School Bus Program Grant SEP Plan
BENEFITS
According to the program website and MDEQ’s program spokesperson, there are approximately 2,500
diesel-powered buses in Montana transporting 70,000 children to public schools traveling over 18 million
miles annually. Replacement of pre-2004 model buses with new emissions technology reduces tailpipe
and in-cabin criteria emissions by over 85 percent. Long-term public health benefits result from reducing
this emissions exposure to school age children and others.
School buses built to meet USEPA’s 2010 standards release 95 percent less air emissions than pre-2007
vehicles and are 60 times cleaner than pre-1991 buses. Older, higher emitting school buses can lead to
significant health risks for students who typically ride these buses for one-half to two hours a day.
Children are more susceptible to air emissions than healthy adults because their respiratory systems are
still developing and they have a faster breathing rate. Asthma, which affects 6.3 million American school
children, is the most common long-term childhood disease in America, making newer, cleaner buses an
urgent priority. Older buses are excellent candidates for replacement with newer, cleaner vehicles.
Replacing the oldest buses will greatly reduce children’s exposure to diesel exhaust and provide
considerable safety improvements. Replacing older buses also reduces air emissions that can contribute
to ozone formation, haze, acid rain, and global climate change.
Montana’s CDSB Program and its predecessor program have replaced 90 school buses and provided
emissions retrofits to another 16. Replacement of these buses has a lifetime emissions reduction of over
87 tons, and a reduction of over 454,000 diesel gallon equivalents based on the reduction of carbon
dioxide. Based on fine particulate reductions, the first-year health benefits savings using the USEPA
diesel emissions quantifier model was estimated at $702,639. The retrofitted school buses reduced
emissions by another 290 tons as estimated using the USEPA diesel emissions quantifier. Another 14
buses were recently added for replacement, and have not yet had emissions reductions estimated.
Finally, the program yields additional tangible benefits to recipient school districts, communities, and
taxpayers. For example, the new buses have cleaner burning, more efficient engines that not only reduce
emissions but improve fuel efficiency and reduce fuel costs. As new buses are added to a district’s fleet
the upgraded equipment improves the average age of the fleet and therefore the safety of the fleet; the
new buses are equipped with improved safety features/standards relative to older buses.
SPONSOR AND PARTICIPANTS
MDEQ administers the CDSB Program and is the sponsor for this SEP. School districts in Yellowstone,
Treasure, Rosebud, and Custer Counties will be eligible for grant funding via the program if this SEP is
funded. The sole and final decisions for grant allocation will be made by MDEQ.
Primary contacts for this SEP are:
MDEQ (SEP Sponsor):
Brian Spangler
Program Manager
P.O. Box 200901
Helena, MT 59620-0901
(406) 841-5250 office
[email protected]
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Supplemental Environmental Projects Plan – Attachment 5
Clean Diesel School Bus Program Grant SEP Plan
EMPCo:
Brian T. Magruder
Environmental Supervisor
ExxonMobil Pipeline Company
800 Bell Street
Houston, TX 77002
(713) 656-2190 office
(713) 898-5736 cell
[email protected]
ARCADIS:
Debbie J. Vreeland
Vice President / Oil & Gas Market Sector Manager
ARCADIS U.S., Inc.
70 Stringari Lane
Belfry, MT 59008
(406) 664-3377 office
(406) 839-6023 cell
[email protected]
REQUIREMENTS AND RELATIONSHIP TO OTHER SEPS
Based on public input at the SEP Public Meeting in Billings on November 15, 2012, the Clean Diesel
School Bus SEP is a lower priority among the preliminarily approved SEPs in this SEP Plan. All other
SEPs will require completion prior to determination of funding availability for this SEP. Upon completion of
all other SEPs, and the approval of all completion reports and agreement between EMPCo and MDEQ of
the allowable and applicable SEP costs relative to the overall $1.3 million requirement, the availability of
remaining funds will be determined. It is the intent of this SEP to grant all available and remaining funds
to this CDSB Program SEP after completion and MDEQ acceptance of all other SEPs.
SCHEDULE MILESTONES AND COMPLETION
It is anticipated that completion of all other SEPs will require approximately 18 months after MDEQ
approval of the SEP Plan. If surplus funding remains from other SEPs, this SEP will initiate at that time.
As shown in the simplified schedule below, MDEQ will require 60 days to distribute program applications
to the school districts within the defined region, and an additional 60 days to receive and evaluate
applications from interested districts. While buses typically require 9 months to procure and receive,
funding of this program will be made upon identification of approved districts. When grant funds, if
available, are distributed to the CDSB Program this SEP will be considered complete and successful, and
a SEP Completion Report will be submitted to MDEQ within 90 days. If the SEP is not funded, no
Completion Report will be required.
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Supplemental Environmental Projects Plan – Attachment 5
Clean Diesel School Bus Program Grant SEP Plan
COST ESTIMATE
This SEP is initially unfunded. All other SEPs within this SEP Plan will require completion prior to
determination of funding availability. Upon completion of all other SEPs, and the approval of all
completion reports and agreement between EMPCo and MDEQ of the allowable and applicable SEP
costs, availability of funds will be determined. As stated previously, it is the intent of this SEP to grant all
available and remaining funds to this CDSB Program SEP after completion and MDEQ acceptance of all
other SEPs. Therefore, funding levels could range from zero to several thousand dollars to tens of
thousands of dollars, which would in turn provide funding support for one or potentially several new clean
diesel school buses for the benefit of school districts and communities within the target counties.
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Supplemental Environmental Projects Plan – Attachment 5
Clean Diesel School Bus Program Grant SEP Plan
FIGURE 5-1 – MONTANA CLEAN DIESEL SCHOOL BUS PROGRAM APPLICATION
PROCESS FOR SELECTION: DEQ will release a Request for Application, 30 days for schools to
respond, 30 days for selection by a DEQ selection committee and implement contract. It can take 9
months to arrive.
MONTANA CLEAN DIESEL SCHOOL BUS SCORE SHEET
Application No.
Applicant/Organization: __________
School Bus make, model, year: VIN:
Total Application Points (Factors 1+2+3+4=30 points max)
Total Points ______
FACTOR 1: Poor Air Quality Areas (bus routes in): References: school bus route maps and route
numbers compared with map/designations Air Quality Considerations sheet.
Location
PM2.5/10, Non-attainment, Maintenance areas
Poor AQ/High Population and Class 1 Areas
High Risk Topography
Points
8
4
2
APPLICATION POINTS_____
FACTOR 2: Student Rider Service Levels (riders-VMT/bus/school year):
Existing Bus:
___ students/yr; Route Description Miles/day (or year): ___ miles; Pupil miles/yr: ____, bus capacity __
New Bus Miles/Yr: _____ Pupils/Daily Route: _____ = _____ rider-VMT/yr or
Daily miles ___ X days/year ______ X eligible students _____ = _______rider VMT/ year
Pupil-VMT per Bus
> 700,000 pupil-VMT
> 400,000 – 700,000
> 100,000 – 400,000
Points
6
4
2
APPLICATION POINTS_____
FACTOR 3: Existing Diesel Bus Emission Rates (engine model year):
Reference: (location/source of information-engine plate preferred)
Bus model year or bus engine model year of production: 19__ or 200_
Engine Manufacturer, Engine serial no:
Model Year Range
Pre-1992
1993-1997
1998-2003
Points
10
6
4
APPLICATION POINTS_____
FACTOR 4: Remaining Useable Life: Reference: Bus model year, manufacturer, or engine miles
(odometer) Fuel consumption, old bus xxxx gallons per year; Fuel economy __________ mpg.
Accumulated Mileage
Points
APPLICATION POINTS_____
< 100,000 miles
6
100,000 - < 150,000
4
150,000 - < 200,000
2
200,000 - < 225,000
1
Total Chassis Miles: _________
Total Current Diesel Engine Miles: ___________
NOTE: Copy of title to old bus will be included as will a copy of the route map.
5