HomeMy WebLinkAbout3.09 Incident Response Plan
INCIDENT RESPONSE PLAN
Page 1 of 50 Original Document Date: 07.12.2011
Last Reviewed Date: 10.11.2021
Document #: EHS-016 Approved By:
This is a controlled document only valid for the date printed and should not be copied.
Date last printed: 10/11/2021 11:26:00 AM
Table of Contents
1.0 INTRODUCTION ............................................................................................................ 3
1.1 PURPOSE .................................................................................................................. 3
1.2 SCOPE ....................................................................................................................... 3
1.3 TYPES OF INCIDENTS COVERED ............................................................................ 4
2.0 ROLES AND RESPONSIBILITIES .................................................................................. 5
2.1 MANAGEMENT ROLES AND RESPONSIBILITIES ..................................................... 5
2.2 ON-CALL RESPONDER ROLES AND RESPONSIBILITIES ....................................... 6
3.0 ACTIVATION OF THE INCIDENT COMMAND SYSTEM AND EMERGENCY
MANAGEMENT TEAM .............................................................................................................. 6
3.1 THE INCIDENT COMMAND SYSTEM ............................................................................ 6
3.2 EMERGENCY MANAGEMENT TEAM............................................................................ 7
4.0 DEFINITIONS ................................................................................................................. 8
5.0 INCIDENT RESPONSE PROCEDURES ........................................................................ 9
5.1 BLOWOUTS/LOSS OF WELL CONTROL ................................................................... 9
5.2 FIRE AND EXPLOSION RESPONSE PROCEDURES .............................................. 10
5.2.1 SMALL FIRES ........................................................................................................... 10
5.2.2 LARGE FIRES .......................................................................................................... 10
5.3 INJURY/MEDICAL EMERGENCY RESPONSE PROCEDURES .............................. 11
5.4 MOTOR VEHICLE ACCIDENTS ............................................................................... 12
5.5 NATURAL DISASTERS ............................................................................................ 12
5.6 PIPELINE RUPTURES AND NATURAL GAS LEAKS ............................................... 13
5.7 SPILL RESPONSE PROCEDURES .......................................................................... 14
5.8 THEFTS AND ECO-TERRORISM ............................................................................. 16
5.9 WORKPLACE VIOLENCE/ACTIVE SHOOTER ........................................................ 17
6.0 INCIDENT DOCUMENTATION, DEBRIEFING AND FOLLOW-UP ............................... 18
6.1 DEBRIEFING ............................................................................................................ 19
6.2 FOLLOW UP ............................................................................................................. 19
INCIDENT RESPONSE PLAN
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Last Reviewed Date: 10.11.2021
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7.0 TRAINING .................................................................................................................... 20
7.1 REQUIREMENTS FOR STAFF .................................................................................... 20
7.1.1 GENERAL TRAINING REQUIREMENTS ..................................................................... 20
7.1.2 HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (HAZWOPER)
TRAINING ............................................................................................................................... 21
7.2 THIRD-PARTY CONTRACTOR TRAINING REQUIREMENTS ..................................... 22
7.3 INCIDENT RESPONSE DRILLS ................................................................................... 22
7.4 TRAINING RECORDS .................................................................................................. 23
8.0 MEDIA COMMUNICATIONS ........................................................................................ 23
9.0 DOCUMENT CONTROL LOG ...................................................................................... 24
ON-CALL RESPONSE FORM APPENDIX A
RECORDING AND REPORTING OCCUPATION INJURIES AND ILLNESS APPENDIX B
COLORADO REPORTING REQUIREMENTS APPENDIX C
UTAH REPORTING REQUIREMENTS APPENDIX D
INCIDENT RESPONSE PLAN
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Last Reviewed Date: 10.11.2021
Document #: EHS-016 Approved By:
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Date last printed: 10/11/2021 11:26:00 AM
1.0 INTRODUCTION
1.1 PURPOSE
This Incident Response Plan (“IRP”) has been prepared for the use by Caerus Operating LLC
(“Caerus”) to address response procedures for all reasonably anticipated incidents at Caerus
facilities. This plan covers the expectations, protocols, roles, and responsibilities to support a site-
specific incident response. Use of the guidelines contained in this plan will help to ensure the
safety of the public, company personnel, the environment, and timely notification of management
and appropriate governmental agencies if an incident occurs in the oil field. The crisis
management and emergency response framework adopted by Caerus utilizes a graduated
response based on the significance of the incident, the risks involved and potential for escalation.
The significance, complexity and magnitude of the emergency situation will determine the type of
response that is activated. Effective communication and timely notifications are essential
requirements for conducting an effective emergency response.
This IRP also addresses best practices in preparing for potential litigation by or against Caerus
from the moment an incident occurs and, as such, this document is privileged and confidential
and should not be shared without express authorization of Caerus in-house legal counsel. As
explained further below, ensuring the health and safety of Caerus employees, contractors, and
the general public is the first and foremost task when an incident occurs. Once the scene and
surrounding area and people are safe and has been secured, it is imperative that Caerus
employees abide by the below recommendations and check lists to ensure proper compliance
with regulatory requirements, State and Federal laws, and the collection and preservation of
evidence for possible litigation.
This IRP with the resources and equipment listed herein, is a planning document to demonstrate
the potential response capability available to respond to an incident. It is not a guarantee of what
will occur or the equipment/deployment sequencing that will be used in an actual event. Nothing
in this plan is intended to limit the discretion of Caerus company employees and/or contractors
to select any sequence of actions or to take whatever time they deem necessary to maximize the
effectiveness of their responses consistent with safe practices.
1.2 SCOPE
This IRP is intended to comply with OSHA CFR 1910.38 and 1910.120, and addresses the
following:
INCIDENT RESPONSE PLAN
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• Incident types and personnel roles and responsibilities;
• Incident response procedures;
• Training;
• Media communications;
• Incident response documentation;
• State-specific and federal reporting procedures; and
• Preparing for potential claims and lawsuits
This Plan applies to all Caerus employees (consultant, agency, contract, and subcontract -
casual, full and part-time) who work at any Caerus site or facility in Colorado or Utah and are
required to comply with the IRP. Any Contractors (including their subcontractors) working on, in,
or around Caerus locations, facilities and equipment are expected to be in compliance with this
plan and their Master Service Agreement.
1.3 TYPES OF INCIDENTS COVERED
The Caerus IRP should be activated when a significant incident that adversely affects, or has the
potential to adversely affect, the health and safety of employees, contractors, the general public,
or the environment (including significant property damage) occurs at a company location.
The following situations should be considered significant incidents:
• Blowouts and loss of well control;
• Fires and Explosions;
• Injury or medical emergency;
• Pipeline ruptures or other uncontrolled natural gas leaks;
• Motor vehicle accidents;
• Natural disasters, including avalanches, tornadoes, rockslides or other weather-
related disasters;
• Spills or releases of reportable quantities;
• Thefts, eco-terrorism events and bomb threats;
• Workplace Violence/Active Shooter; and
• Other potentially hazardous situations
Each Caerus manned facility will have a site-specific, Emergency Evacuation Plan defining
management’s expectations for evacuation/shelter in place procedures. In addition, operations
will determine a plan for evacuation and emergency response for each jobsite based on scope of
INCIDENT RESPONSE PLAN
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job prior to starting work; typically, this information would be discussed and documented using a
JSA form.
2.0 ROLES AND RESPONSIBILITIES
Employees and contractors should take the opportunity to become familiar with these procedures
and where the exit routes, fire extinguishers, and pull alarms are located before conducting any
work in and near Caerus operations.
Depending on the severity and potential impact of an incident, response personnel will consist
of Caerus management and field supervisors, oil-field contractors, Caerus Legal Counsel, EHS,
outside legal counsel, expert witness investigators, the local fire department, law enforcement,
or emergency response team.
2.1 MANAGEMENT ROLES AND RESPONSIBILITIES
The Management Team, including Caerus’ legal counsel and EHS, will provide corporate level
expertise and direction for incident-response operations. Management responsibilities include:
• Assessing the incident, directing efforts to lessen the impacts, and ensuring that on-scene
priorities are being handled;
• Ensuring resources have been allocated to meet any on-site emergencies;
• Calling for technical, operational and special services as needed (i.e., well control, H2S
gas, or company specialists);
• Assessing the magnitude and impact of the incident across the value areas of the
corporation (i.e., people, environment, financial, and public image);
• Developing procedures to communicate information to the general public, to neighboring
property owners, and to Caerus employees;
• Notifying first responders as necessary;
• Notifying appropriate regulatory agencies; and
• Communicating with outside legal team and consultants to ensure evidence is secured,
pertinent documents preserved, the site is controlled, and that protocols are in place to
ensure that only authorized personnel can access the site and remove materials or
evidence from the site.
INCIDENT RESPONSE PLAN
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2.2 ON-CALL RESPONDER ROLES AND RESPONSIBILITIES
One person from the EHS team is designated to be on-call at all times, and one person from
Operations is designated to be on-call on days off (weekends, holidays, etc.). The on-call persons
will adhere to the following requirements:
1. In cellular service, or able to respond by phone within one hour
2. On-call includes days away from work (i.e. weekends, public holidays and flex-days).
3. Fit for duty on arrival at the Emergency Operations Center (EOC).
4. Able to arrive at the EOC or Incident Command Post (ICP) within a reasonable amount
of time (generally, within a few hours).
Caerus’ OCC has a copy of the on-call calendar and will contact the appropriate on-call person
in the event of any incident. OCC will also initiate the Incident Command System by ensuring
relevant people are notified.
3.0 ACTIVATION OF INCIDENT COMMAND SYSTEM & EMERGENCY MANAGEMENT TEAM
3.1 THE INCIDENT COMMAND SYSTEM
The Incident Command System (ICS) is a standardized approach to command, control, and
coordinate emergency response by providing a common hierarchy within which responders from
multiple agencies can be effective. During an emergency, the most senior available field
employee (or Site Supervisor) will act as the Incident Commander. The Incident Commander’s
primary responsibility is to assume immediate command during incidents, and is responsible
for the following:
• Safety, protection, health and welfare of employees, contractors, and the general public;
• Protection of the environment and wildlife;
• Controlling property damage and securing the facility;
• Notification of management, EHS, legal team, and/or first responders of the incident;
• Following directions from management, EHS, the legal team, and/or first responders; and
• Providing input regarding the need for additional personnel, technical services, company
specialists, expert witnesses etc.
During emergency incidents, key stakeholders, including regulatory agencies, other operating
companies, and community members will likely need to be contacted and subsequently
communicated with. It is imperative that a consistent message is conveyed in these
INCIDENT RESPONSE PLAN
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communications. The Incident Commander has the overall responsibility for managing
information flow relating to the incident to and from stakeholders.
Caerus has designated emergency levels and the internal Caerus staff that need contacted at
each level of emergency in the Emergency Level Chart (Table 1A or Table 1B). Emergency
levels range from 1 to 3, where Level 1 emergencies are the least severe, and Level 3
emergencies are the most severe. All level 3 emergencies are to be reported to the people listed
under Level 1 and Level 2 emergencies, plus the executives listed on the Emergency Notification
Chart in (Table 1A or Table 1B). Level 3 emergencies are classified as an incident that results
or is anticipated to result in:
• Life-threatening conditions
• Jeopardizes public health or safety
• Has extensive media attention
• Causes irreversible or long-term environmental damage
Since almost all government agencies use the incident command system in their training, they
are very familiar with the requirements. Thus, it will be very easy to coordin ate with the local
emergency response agencies. Each county has an agency (typically the local sheriff) that will
assume incident command in a situation, and that person will have authority over the situation
once that person arrives at the scene. Company personnel will have their own ICS, but the
Company incident commander may actually report to the county incident commander depending
on the incident type and severity. This type of combined company ICS and agency ICS is
sometimes referred to as a “Unified Command System”. In addition to being able to coordinate
with government agencies, some other advantages of the ICS are:
1 The response can be suited to the size of the incident
2 The response to an emergency involves only necessary functions (such as operations,
logistics, finance, planning and public relations)
3 The response can grow if the incident worsens
4 One person takes charge of the incident for the company, and this person can determine
the size of the response required
3.2 EMERGENCY MANAGEMENT TEAM
The Emergency Management Team (EMT) is an organized support team that functions within
the ICS. Each member has a crucial role to play in managing property, landowners, operations,
and legal. The EMT should conduct periodic drills to ensure members of the team understand
INCIDENT RESPONSE PLAN
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Last Reviewed Date: 10.11.2021
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their role(s) in the event of an emergency and are familiar with the structure and process of the
ICS, as well as to identify any gaps that need to be addressed prior to an actual incident.
The response for any serious incident shall use the EMT in an Incident Command System. While
most incidents are small enough that only limited incident command will be required, larger
incidents may require a full-scale ICS and EMT.
Activation of the EMT will be decided by OCC if it is determined that additional support is needed
for Level 1 and 2 incidents, and for all level 3 incidents. Once the decision is made to activate
the EMT, the EMT Leader will:
1. Notify the EMT members via phone call (refer to the tables on the following pages)
2. Contact the Incident Commander to inform them of the EMT activation (refer to contact
information under the IMT section)
3. Agree with the Incident Commander frequency and timing of communications (i.e. every
hour, 3 hours etc.).
4. Conduct a “kick-off” meeting of the EMT. Some of the members of the EMT are located
in Denver, CO, Parachute, CO and Vernal, UT. Therefore, the meeting will likely take
place in Denver with a call into Parachute and Vernal.
5. A suggested EMT “kick-off” meeting agenda is:
a. Roll call
b. Review of the incident facts and current status
c. Discussion of the Incident Commander and agreed EMT/Incident Commander
communication plan
d. Identify any additional resources that will be needed for the EMT
e. Agree to frequency and timing of subsequent EMT meetings
f. Identify any issues that need to be resolved and agree actions to address
6. Contact the Incident Commander to make any adjustments to the previously agreed
communication plan post the EMT “kick-off” meeting
7. The Chief Operating Officer (COO) will make the decision, in consultation with the EMT
Leader when it is appropriate to stand down the EMT.
Notification and response to emergencies is defined on the Caerus Emergency Notification Chart
using a color-coded system defining the emergency level based on the potential or actual impact
to people, the environment, company assets, reputation, and business/finances.
Caerus crisis and emergency management process mandates timely notification and
communications both internally and externally during incidents. Internally, emergency and crisis
related communication routes through the asset organizational line. Timely and continuous
INCIDENT RESPONSE PLAN
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external communication may be required with key stakeholders and to meet regulatory
compliance. Any person who observes or becomes aware of an emergency situation shall report
the incident to the person in charge and their supervisor.
(Table 1A or Table 1B) provides an example of the Caerus Emergency Notification Chart required
to be posted at each Caerus manned facility.
Table 2 is the Emergency Level Chart that defines the level of emergency based on a color-
coded system:
• YELLOW = Level 1 Emergency having limited severity potential and a relatively minor
impact being anticipated
• ORANGE = Level 2 Emergency having significant severity potential and moderate impact
being anticipated
• RED = Level 3 Emergency having catastrophic severity potential and severe impact being
anticipated based on the defined criteria and examples provided.
Notification and involvement of personnel and management members depends on the level of
the emergency, and it is the responsibility of the Incident Commander to assure suitable
notification and involvement is provided based on the criteria for each incident.
INCIDENT RESPONSE PLAN
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TABLE 1 - A: CAERUS PICEANCE EMERGENCY NOTIFICATION CHART
INCIDENT RESPONSE PLAN
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TABLE 1 - B: CAERUS Greater Natural Buttes EMERGENCY NOTIFICATION CHART
INCIDENT RESPONSE PLAN
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TABLE 2: CAERUS EMERGENCY LEVEL CHART
INCIDENT RESPONSE PLAN
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4.0 DEFINITIONS
All Clear The term used to communicate that an emergency has been
terminated. It does not represent a Release to Normal Operations.
Emergency A serious situation or occurrence that happens unexpectedly,
poses an immediate risk to life, health, property, or environment,
and demands immediate action.
Emergency
Declaration
An announcement that communicates an emergency condition
exists. Once a declaration is made, the Incident Response Plan is
formally activated.
Emergency
Management Team
Group that coordinates emergency and non-emergency incident
response at Caerus by product line; a matrix organization
coordinated through the Incident Commander (IC).
Emergency Manager
(EM)
Management member by product line responsible for coordination
of emergency and non-emergency incident response at Caerus; a
matrix organization coordinated through the Incident Commander
(IC).
Emergency Plan Course of action developed to mitigate the damage of potential
events that could endanger an organization's ability to function.
Such a plan should include measures that provide for the safety of
personnel and, if possible, property and facilities.
Emergency Response
Team (ERT)
The core of Caerus Emergency Management Group; this team
provides multiple response capability but specializes in emergency
management.
HAZWOPER An acronym which stands for Hazardous Waste Operations and
Emergency Response. HAZWOPER training is covered under
OSHA standard 29 CFR Part 1910.120.
Incident Commander
(IC)
Most senior person at a particular worksite or building who is
responsible for notifying appropriate parties, lead or managing the
response to an emergency situation, evacuation or shelter in place,
and for accounting for all persons in that space.
Incident Response
Plan (IRP)
Document establishing the general emergency response
procedures for Caerus.
Release to Normal
Operations
An order issued releasing an area involved in an emergency back
to normal operations. An “All Clear” terminates the official
emergency, while the “Release to Normal Operations” authorizes
the restart of work.
INCIDENT RESPONSE PLAN
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5.0 INCIDENT RESPONSE PROCEDURES
Upon the discovering of an incident or potential problem, employees must immediately notify their
supervisor and Operational Command Center (OCC). The OCC will then make additional
notifications based on the severity of the incident per the Caerus Emergency Notification Chart
(Table 1A or Table 1B).
During an emergency, immediate action must be taken to protect human life (the top priority in
any emergency), the environment and wildlife, control the incident source (if possible), and to
secure the area. The most senior on-site Caerus personnel, or representative at the scene or
that arrives on the scene first, will be considered the on-site Incident Commander until they are
relieved by someone with more experience and training. If there is any doubt as to which Caerus
personnel or representative is the on-site Incident Commander, personnel should immediately
contact the Emergency Manager or a member of the Emergency Management Team. The first
and most immediate task is to call 911 as needed to ensure that any injuries are addressed
quickly. Thereafter, the Emergency Manager / Emergency Management Team should be
immediately notified, and operations in the immediate surrounding area will cease.
If the incident area poses a risk to human health, personnel will be immediately cleared from the
area surrounding the incident. Printed maps and KMZ files depicting well pads, facilities, and
pipelines, as well as nearest water bodies and access roads are available at the front desk; these
tools can be used to find locations and may be provided to emergency responders if needed. If
safe to do so, Caerus personnel will try to control the situation with available equipment until
emergency response personnel arrive, or until all attempts have been exhausted without placing
themselves in unnecessary risk of harm or injury. Either the Incident Coordinator or a designee
should keep detailed notes during the incident; incident documentation, debriefing and follow-up
guidance are provided in Section 6. Life safety is of the upmost importance during any
emergency.
The following sections outline specific procedures to follow by incident type:
5.1 BLOWOUTS/LOSS OF WELL CONTROL
In the event of a large well blowout or complete loss of well control, a third party will be used to
ultimately gain control of the well. Contact information for Caerus’ contracted well control
company is listed in Table 1. While Employees and local contractors will likely not be responsible
for stopping the blowout, they may take steps to limit damage and protect safety, the environment
and property. The following steps may be implemented by employees and contractors in the
INCIDENT RESPONSE PLAN
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event of this type of an emergency:
1. Stop. Think. Are you safe?
2. Notify your supervisor and call the OCC. The OCC will then notify relevant members
of the Emergency Management Team per the Caerus Emergency Notification
Chart (Table 1).
3. Eliminate potential ignition sources (remember that the potential for fire and
explosion DO exist).
4. Consult the Well Control Action Plan for additional information related to well control.
5. Follow additional procedures below for spill response and injury/medical emergency
to address associated spills and injuries.
6. Document your account of the incident (witness statement), providing time, date,
location, a description of what happened, and any other relevant details, and provide
it to the on-call person from the EHS group as soon as possible.
5.2 FIRE AND EXPLOSION RESPONSE PROCEDURES
5.2.1 SMALL FIRES
1. If the fire is small, i.e., the size of a waste basket, a trained employee may attempt to shut
off the fuel source and extinguish the flames, only if it can be done safely.
2. If you are unable to extinguish the fire, or do not think it is safe to do so, evacuate and call
911 and OCC.
3. Document your account of the incident (witness statement), providing time, date, location,
a description of what happened, and any other relevant details, and provide it to the on-
call person from the EHS group as soon as possible.
5.2.2 LARGE FIRES
1. First evacuate the site and call 911 and OCC. OCC will then notify relevant members of
the Emergency Management Team per the Caerus Emergency Notification Chart (Table
1). The flowcharts provided in the state-specific appendices provide the procedures to follow
for regulatory notifications for non-spill incidents. All reports should be coordinated with
Caerus legal team and EHS.
2. If danger of the fire approaching a neighboring property exists, Surface Land in coordination
with Caerus’ legal team and the On-Site Coordinator should notify the neighboring
landowner (or law enforcement if the affected neighbor cannot be reached) in the event it
INCIDENT RESPONSE PLAN
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is possible to mitigate damage to neighboring properties.
3. Within the proper reporting timelines, as explained in Appendices D and E, the necessary
regulatory agencies should be contacted and alerted of the fire. All reports to any regulatory
agency should be coordinated with the Caerus legal team.
4. Document your account of the incident (witness statement), providing time, date, location,
a description of what happened, and any other relevant details, and provide it to the on-call
person from the EHS group as soon as possible.
5.3 INJURY/MEDICAL EMERGENCY RESPONSE PROCEDURES
1. If the injury or medical emergency is critical, call 911 or OCC from a safe location. Notify
your supervisor and OCC. OCC will then notify relevant members listed in the Caerus
Emergency Notification Chart (Table 1).
2. Take immediate steps to control bleeding or stabilize the victim if it is safe to do so within
the training and qualification limits. Be sure to use PPE – Your safety is the number one
priority.
3. If it is safe to do so, administer additional first aid/CPR and use an AED if available within
training and qualification limits.
4. Assign someone to meet the ambulance at a designated location to escort them to the
scene. In some cases, due to the remoteness of facilities, you will need to meet the air
ambulance helicopter at the nearest entrance or emergency access point and direct them
to the victim(s). You may also have to meet the emergency responders at the nearest
highway turn off. If so, keep somebody stationed there or mark the turn off in some fashion.
In remote areas with no medical services available, transport the injured person to a hospital
or call the air ambulance helicopter if the injury is serious.
5. Control access to the scene. Consider suspending activities and shutting down operations
to maintain safety and preserve evidence.
6. EHS should complete an On-Call Response Form located in APPENDIX A for each incident
and near-miss incident.
7. OSHA must be notified of a work-related fatality within 8 hours. Caerus Legal Counsel and
EHS will make the notification.
8. OSHA must be notified of all work-related inpatient hospitalizations, amputations, and eye
loss within 24 hours. OSHA requirements for recording and reporting occupational injuries
and illness are provided in APPENDIX B. All reporting to OSHA will be conducted by Caerus
Legal Counsel in cooperation with Caerus EHS and/or the EHS Department.
9. Document your account of the incident (witness statement), providing time, date, location,
a description of what happened, and any other relevant details, and provide it to the on-call
person from the EHS group as soon as possible.
INCIDENT RESPONSE PLAN
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5.4 MOTOR VEHICLE ACCIDENTS
This pertains to incidents or accidents under the operation of company-owned or leased vehicles,
whether the vehicle is being driven on organizational business or for personal use, and the
operation of rental or driver-owned vehicles used for business purposes. All incidents will be
reported to management, investigated, documented, and reviewed by the Operations Manager.
1. Pull over to a safe location. Call 911 if emergency medical attention and/or police assistance
is warranted. Ask a motorist or passerby to notify the police if you are unable to do so
yourself.
2. Remain at the scene. Do not move the vehicle unless it presents a safety hazard to others
or appropriate authorities tell you to.
3. Put on your hazard lights, if available, to protect yourself and your vehicle, as well as to
warn other traffic to prevent any additional injury and/or damage.
4. If necessary, get help for injured persons, and refer to the steps in Section 4.4
(Injury/Medical Emergency) of this plan.
5. Record information for preserving the scene, documenting & preserving evidence (i.e.
pictures).
6. Obtain necessary information at the accident scene from other driver(s) and any witnesses
by completing the appropriate forms, and as soon as practical, but at least within 24 hours,
report all accidents to your manager and/or supervisor and the Fleet Manager.
7. Do not discuss fault or blame at the scene of the accident (except to the appropriate
authorities) and sign no papers for anyone except police. If the driver of the other vehicle
leaves the scene or is uncooperative, you must, at a minimum, obtain the vehicle license
plate number and a description of the vehicle, driver, and any passengers.
8. Document your account of the incident (witness statement), providing time, date, location,
a description of what happened, and any other relevant details, and provide it to the on-call
person from the EHS group as soon as possible.
5.5 NATURAL DISASTERS
For tornados, hurricanes, earthquakes, lightning, floods, landslides and other natural disasters,
tune to local radio and/or TV stations for information. Wherever possible, preparations should be
made in advance to secure property and safeguard personnel from the effects of such weather
events. Under no circumstances should work be conducted where employees are exposed to the
potential harm or risk from extreme weather. Avoid fallen power lines. If conditions are favorable
for the formation of tornadoes or a hurricane, a Tornado/Hurricane Watch will be issued by local
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authorities. In the event a Severe Weather or Tornado/Hurricane Warning has been issued, heed
guidance from the National Weather Service, public emergency announcements and/or NOAA
and follow the suggested guidelines below:
Stay calm. Warn persons in your immediate vicinity of the threat. If outdoors during a tornado,
take shelter in low-lying areas, provided that they are free from heavier-than-air gases, or in your
field truck and remain there until the threat is over. If indoors, move to designated shelters/muster
points and/or stay away from glass windows and shelter in an interior room. Bathrooms are a
good choice because of the strength provided by the piping.
During lightning storms, immediately move to shelter in a structure or your vehicle, avoid being
the tallest object in the area, and avoid tall structures such as trees and drill rig masts. If you feel
your skin tingle or your hair stands on end, a lightning strike is imminent. Immediately crouch
down, keeping your weight on only your heels to minimize your surface area in contact with the
ground. Do not lie flat on the ground.
Seek high ground in the event of a flash flood.
If conditions require evacuation, the site-specific Emergency Evacuation Plan or Emergency
Response plan should be followed. a trained employee should immediately shut down all ignition
sources if it is safe to do so and then evacuate the site. Once the natural disaster has passed,
Caerus sites should be assessed by the Incident Commander for damage.
5.6 PIPELINE RUPTURES AND NATURAL GAS LEAKS
Stop. Think. Are YOU safe? If you believe the situation is unsafe, back off. If the situation is safe
proceed with the following steps:
1. Call 911 and OCC. OCC will then notify relevant members of the Emergency Management
Team per the Caerus Emergency Notification Chart (Table 1).
2. Evacuate all non-essential personnel from the site and downwind areas.
3. Immediately shut down all ignition sources and close blow-out preventers (BOPs) and/or
blind rams, if it is safe to do so. Be sure to use appropriate PPE.
4. Stop the source of the leak by isolating the leak area, staying upwind of the leak. Avoid
going into the vapor cloud. Company employees can only respond defensively (shut valves,
build dams, etc.) to spills or releases unless they have extensive HAZWOPER training.
Company employees will operate company owned equipment, since only company
employees know the proper valves to open and shut-in case of an emergency. Contractors
must be qualified and authorized to operate any company valves or other equipment by
Caerus.
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5. If the leak ignites or is likely to ignite, evacuate the site.
6. Do not use water on a natural gas fire.
7. The flowcharts provided in the state-specific appendices provide the procedures to follow
for regulatory notifications for non-spill incidents. All reports should be coordinated with
Caerus Legal Counsel.
8. Secure the Site: The site must be secured by both law enforcement and private security or
Caerus employees. A representative of Caerus must document all persons entering and
leaving the scene, and that representative must document any evidence leaving the scene
or moved within the scene. Caerus must maintain a chain of custody log for all evidence at
the scene describing the removed evidence and identifying the custodian, date, and time.
The scene must be secured by a perimeter, such as a fence, caution tape or other
appropriate mechanism. Consider whether, depending on the severity of the event and
likelihood of spoliation, 24-7 video surveillance is needed at the accident site. If any
mechanism malfunctioned or appears likely to have malfunctioned, that piece of evidence
must be photographed, secured immediately and not alerted, changed, or tampered with.
9. Document your account of the incident (witness statement), providing time, date, location,
a description of what happened, and any other relevant details, and provide it to the on-call
person from the EHS group as soon as possible.
5.7 SPILL RESPONSE PROCEDURES
In the event of, or upon the discovery of, an accidental release of hazardous materials,
fuel, oil, or produced water, the following procedures will be implemented:
1. Stop. Think. Are you safe?
2. Notify your supervisor and call the OCC. The OCC will then notify relevant members of
the Emergency Management Team per the Caerus Emergency Notification Chart
(Table 1).
3. Eliminate potential ignition sources (remember that the potential for fire and explosion DO
exist).
4. Check the Safety Data Sheet (SDS) for the spilled substance(s) and remember that some
spilled materials can generate hazardous gasses. Always approach the spilled material
from an uphill or upwind direction, if possible. Wear proper personal protective equipment
(PPE) as directed in the (SDS) for the spilled chemical.
5. Never touch, smell or taste any spilled material.
6. Note any other materials within the vicinity of the release, as other products may adversely
react with the spilled material.
7. If safe to do so, stop the source of the spill.
8. Assess the spill and attempt to mitigate possible environmental damage by using spill kit
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supplies, oil booms, dry sweep, absorbent materials, or build temporary berms to prevent
the materials on land from spreading, if it is safe to do so.
9. Immediately upon observance of a spill that enters or threatens to enter a nearby water
body, field personnel, in coordination with EHS, should initiate containment, recovery, and
cleanup actions to mitigate potential pollution of Waters of the United States, using, as
applicable:
a. An “Intercept Point”, w h i c h is a point along a potentially affected
waterway with good road access where response contractors could install
temporary barriers or booms, and pump affected water from the drainage into
vacuum trucks.
b. The use of booms and barriers, which is typically limited to the containment
and recovery of materials that will readily separate from and float on water.
The type and size of a boom will depend on the specific location and the
conditions within which the boom will be used.
c. Trenches, which can be used to intercept and hold fluids. Note: An emergency
one-call is needed prior to digging.
10. Caerus personnel or contractors should be dispatched as appropriate to oversee clean-
up of released materials.
11. Proceed with remediation/cleanup activities following instruction from Caerus EHS in
consultation with an environmental consultant or regulatory agency, as applicable.
12. EHS should document the release information using the On-Call Response Form
provided in APPENDIX A. The flowcharts provided in the state-specific appendices (i.e.,
APPENDIX C and APPENDIX D) provide the procedures to follow for regulatory
notifications for spills. All reports to regulatory agencies must be coordinated with the EHS
team under the authority of the legal team.
13. Notify Caerus’ legal team of the spill as soon as possible.
14. If danger of the spill approaching a neighboring property exists, Surface Land in
coordination with Caerus’ legal team and the Incident Coordinator should notify the
neighboring landowner (or law enforcement if the affected neighbor cannot be reached)
in the event it is possible to mitigate damage to neighboring properties.
15. Within the proper reporting timelines, as explained in APPENDIX C and APPENDIX D,
the necessary regulatory agencies should be contacted and alerted of the spill. All reports
to any regulatory agency should be coordinated with Caerus’ legal team.
16. Document your account of the incident (witness statement), providing time, date, location,
a description of what happened, and any other relevant details, and provide it to the on-
call person from the EHS group as soon as possible.
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5.8 THEFTS AND ECO-TERRORISM
Contractors, vendors and visitors to the field, field offices and lay down yards should not enter
onto Caerus properties without the knowledge and permission of Operations Management. It is
not uncommon for “pedestrians” or vehicles to make their way through our operating area,
especially during hunting season. If a suspicious vehicle or activity is observed at any of our
facilities or on the lease roads, do not approach or attempt to confront the person or persons.
Move to a safe area and contact the local law enforcement as soon as possible. Avoid
confrontational contact. Provide a description of the vehicle(s) and any people observed, time of
day, location and any other details considered important. Use extreme caution when traveling to
remote areas after dark. When responding to alarm callouts, make a cursory inspection around
the area and do not leave your vehicle if you do not feel it is safe to do so. Park in a manner that
will enable a quick exit from the location, and if necessary, wait until daylight to address the
equipment problem.
1. In the event of a theft or eco-terrorism event occurring on a Caerus property, call
your supervisor, and OCC. OCC will then notify relevant members of the Emergency
Management Team per the Caerus Emergency Notification Chart (Table 1). Once the
situation is evaluated by management, the appropriate individual will contact local law
enforcement, and the insurance provider for Caerus. If the situation is an emergency
or a potential emergency, call 911 immediately.
2. The flowcharts provided in the state-specific appendices provide the procedures to
follow for regulatory notifications for non-spill incidents. All reports should be coordinated
with Caerus Legal Counsel. In addition, follow the below steps:
a) In the event of an eco-terrorism incident that threatens the environment,
shut down the scene or well, turn off all pipes, and immediately stop all
production or other work in the area. Immediately employ all other
available mitigation measures, including the drilling of monitoring wells.
b) Secure the Site: Follow the procedures in Section 4.5 above.
3. After the scene is completely secure, and danger and other concerns have been
addressed, work with law enforcement to collect all information from persons present.
This will include law enforcement and the in-house and outside legal teams conducting
interviews, review of any video or audio footage, and discussions or interviews with any
first responders who have relevant information.
4. Document your account of the incident (witness statement), providing time, date,
location, a description of what happened, and any other relevant details, and provide it
to the on-call person from the EHS group as soon as possible.
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5.9 WORKPLACE VIOLENCE/ACTIVE SHOOTER
There are four categories of workplace violence that may lead to an active shooter event:
1. Violence in connection with criminal acts (robbery, gangs, etc.)
2. Violence related to a customer or client.
3. Violence among co-workers (pre-dominant threat).
4. Domestic violence spillover into the workplace.
Employees at Caerus should feel empowered to report suspicious activity. If you see something,
say something.
In the event of an active shooter in your workplace, there are three basic survival strategies: RUN.
HIDE. FIGHT. Remember the goal is to keep yourself and others, if you can, safe until the police
arrive. Most active shooter incidents last five to seven minutes, so your goal is to create time,
barriers, and distance between you and the shooter. Employees should refer to their local area
office’s emergency exit routes and safe areas where they can escape to.
Discovering Party:
• If safe to do so, call 911 and supply as many details as you can about the shooter(s),
including number of shooters, physical descriptions of shooters, location of shooters,
types of weapons, number of injured people, and any other details you have.
• If safe to do so, notify company supervisor/executive.
Run:
• React quickly and escape using a known escape route from the building or location.
• Leave your belongings behind but take your cellular phone if you can.
• Help others escape if you can but run regardless of whether others agree to follow.
• Do not attempt to move the wounded.
• Keep others from entering an area where you believe there may be active shooters.
• Call 911 when you are safe and provide as much detail to the operator as you can.
• Stay in the evacuation area safe location to be available to law enforcement for questions.
• Do not leave until instructed to do so.
Hide:
• If you cannot escape, hide in an area that provides both protection from bullets and is out
of the shooter’s view.
• Lock doors, turn off lights, close blinds, and block entry to the hiding place.
• Silence cell phones and remain quiet.
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• If others are with you, span out around the room to make smaller targets in case the
shooter enters the space.
Fight:
• Fight as a last resort and only when you are in immediate danger.
• Act with as much physical aggression as possible.
• Improvise weapons, make noise, and throw items at the shooter to get the shooter off
balance.
• Commit to your actions, subdue, and neutralize the shooter as much as you can.
When Law Enforcement Arrives:
• Remain calm and follow instructions.
• Keep hands visible and raised, avoid quick movements towards officers and don’t ask
questions – their first job is to neutralize the threat.
• Wait for the rescue teams who will follow their responders to attend to the injured and
help you.
6.0 INCIDENT DOCUMENTATION, DEBRIEFING AND FOLLOW-UP
The Incident Commander , and the legal team, in conjunction with EHS, should document all
aspects of the incident and associated response. Be sure to:
1. Specify incident type, location, personnel involved, quantity of spill, etc.;
2. Identify Names and companies (or agencies) of everyone involved in the response;
3. Collect all information from persons present about the incident. This will include interviews,
review of any video or audio footage, and discussions or interviews with any witnesses or
first responders who have relevant information. All interviews should be conducted by legal
counsel if possible.
4. Document the scene. This includes taking photographs, taking any soil or other samples
that may be necessary and analyzing the area for any environmental impacts or other
potential personal injuries. Consultants and experts should be involved in this process as
early as possible.
5. Collect any relevant manuals and operating procedures for the task being performed, and
any equipment involved in the incident. These manuals should be saved for use in any
potential litigation, and include equipment manuals, company policies, training records,
work-shift schedules, previous complaints, etc.
6. Document appropriate chain of custody for any physical evidence;
7. Sign and date all documents and keep a copy for the local office records
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8. Once the incident no longer poses a threat to anyone’s health and safety, Caerus should
begin its “root cause analysis,” to determine what caused the emergency event. This will be
done by knowledgeable Caerus personnel, any necessary consultants and should be
monitored by external legal counsel to ensure that the investigation and resulting work
product is attorney-client privileged.
9. Following the root cause analysis, Caerus should implement the appropriate corrective
actions based on the hierarchy of controls including engineering improvements, procedural
changes, training or etc. to prevent similar events from occurring again.
10. Caerus legal department should issue a “litigation hold letter” to all Caerus employees who
may have knowledge, information, or documents about the emergency event so as to
preserve relevant information in the event litigation ensues.
In coordination with Caerus Legal Counsel whenever possible and as soon as possible after a
significant incident occurs, documentation of incident response actions is critical for conducting
follow-up investigations of incidents, including coordination with state, federal, and local
agencies. All documentation should be signed and dated. Always make a copy in case the
original is lost and save an electronic copy to Caerus’s document share system (S: drive). Do not
destroy the paper and electronic copies.
6.1 DEBRIEFING
The Incident Commander is responsible for ensuring that personnel have been debriefed
following an incident. The following steps should be taken:
11. Complete and/or collect all forms and other documentation before releasing employees
from the scene;
12. Inquire whether employees have additional information to share; and
13. Complete follow-up paperwork and evidence preservation as necessary.
6.2 FOLLOW UP
An investigation, coordinated by Caerus legal counsel, should be performed following any
incident-related response. The attorney-client privileged, and attorney work product protected
investigation should include a review of all documentation, a review of the IRP, root cause
analysis of the incident, and follow-up reports to internal and external parties as appropriate.
Include:
14. What went wrong;
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15. What was handled well;
16. Items that should be handled differently and lessons learned;
17. Areas of new training (if necessary); and
18. Employee feedback on the incident and response.
7.0 TRAINING
7.1 REQUIREMENTS FOR STAFF
7.1.1 GENERAL TRAINING REQUIREMENTS
Experienced, well-trained people are essential for successfully implementing this IRP.
Completing routine drills and training are critical components to ensuring operational
personnel are properly prepared to perform their response duties in the event of an emergency.
Caerus personnel who work in the field or in critical roles for emergency response, such as OCC
or direct supervisors to personnel in the field, have the potential to be involved in emergency
response to varying degrees. To ensure competency and safety in the event of an emergency
situation, all applicable Caerus personnel who have the potential to be involved in emergency
response will be instructed in the following:
• Appropriate PPE
• Site-specific Emergency Procedures;
• Applicable regulations and programs;
• Hazard communication;
• Caerus personnel roles and incident response duties;
• Types of incidents;
• Company incident notification procedures;
• Steps on how to control and handle incidents;
• Basic first aid;
• Protection of sensitive areas; and
• Awareness of material recovery and disposal.
All Caerus employees and in-house contractors will be trained initially at hire and at least
annually on the requirements of this program and the site-specific emergency plan including
drills to evaluate program effectiveness. The IRP will be reviewed periodically to evaluate
program effectiveness and employees training needs.
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7.1.2 HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE
(HAZWOPER) TRAINING
The HAZWOPER requirements are based on levels of response recognized by the hazardous
materials response industry. The training criteria for Caerus incident response personnel and
other company personnel, who may be otherwise involved in an incident, are based on the
duties and functions that the personnel may be expected to perform.
Since it is anticipated that Caerus will outsource any large-scale spill response activities, there
are only three levels of HAZWOPER training that potentially apply to Caerus staff: The 8-hour,
24-hour and 40-hour level trainings. Further details about each level of HAZWOPER training that
may apply to a Caerus employee or in-house contractor are as follows:
• The 8-Hour HAZWOPER Operational Level training may be completed Caerus personnel
who will respond to releases or potential releases of hazardous substances as part of the
initial response to the site for the purpose of protecting nearby persons, property, or the
environment from the effects of the release. They are trained to respond in a defensive
fashion without trying to stop the release. Their function is to contain the release from a
safe distance, keep it from spreading, and prevent exposures.
• The 24-Hour HAZWOPER Technician Level training may be completed for the Caerus
personnel who respond to releases or potential releases for the purpose of stopping the
release. They assume a more aggressive role than a first responder at the operations
level in that they will approach the point of release in order to plug, patch or otherwise
stop the release of a hazardous substance. In addition to the 24-Hour HAZWOPER
course, the technician level responder must also know how to implement the employer's
emergency response plan; be able to classify, identify and verify known and unknown
materials by using field survey instruments and equipment; and be able to function within
an assigned role in the Incident Command System.
• 24-Hour HAZWOPER Incident Commander Level
• The 40-Hour HAZWOPER Technician Level training (clean-up work) is required for any
Caerus personnel who will be engaged in hazardous substance removal or other activities
which expose or potentially expose workers to hazardous substances and health hazards.
Additionally, a minimum of three days actual field experience under the direct supervision
of a trained experienced supervisor is required.
Caerus staff will be trained to the appropriate level of HAWOPER based on their job duties.
TABLE 3 provides a description of job duties and their corresponding required HAZWOPER level,
which has been assigned by Caerus as a conservative estimate of the worst-case scenario.
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Caerus Incident Response personnel who complete 8 -Hour, 24-Hour or 40-Hour
HAZWOPER training requirements must attend an 8-Hour OSHA Refresher training annually.
Response personnel, including non-Caerus personnel whose skills are needed temporarily to
perform immediate incident support work (i.e., dirt truck drivers and crane operators) may not be
required to meet the HAZWOPER training requirements discussed previously. However, these
personnel must be briefed concerning the potential hazards and their duties at the site prior to
participating in response operations. They should receive instruction in the use of any safety
and PPE needed and be provided with all other appropriate safety and health precautions.
TABLE 3: HAZWOPER LEVEL NEEDED BY JOB TYPE
Job Type Type of Training Hours of Training
Production Engineers, Completions
Supervisor, Drilling Supervisor, and
Automation
First Responder
Operations Level
8
Lease Operators, Facility Operators,
and Construction
Hazardous Materials
Technician
24
Foreman and Operations Leads On scene incident
commander (24-Hour)
24, plus additional
experience
EHS, Special Groups (H2S Team,
etc.)
The 40-Hour HAZWOPER
Technician Level
40, plus additional
experience
7.2 THIRD-PARTY CONTRACTOR TRAINING REQUIREMENTS
However, it is necessary for Caerus to confirm that any outside contractors have complied with
all applicable regulations regarding training requirements. Caerus should acquire copies of
training certificates from the outside contractors they plan to use for incident response. Training
certificates should be kept on file at the Caerus Office.
7.3 INCIDENT RESPONSE DRILLS
Incident response procedures should be practiced and tested annually. Practice drills should
include the following:
• Notification of medical services and law enforcement;
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• Identification of individual(s) who will assume command and control of various situations;
• Review of safety requirements and Personal Protective Equipment (PPE);
• Site evacuation;
• Spill containment methods and equipment;
• Notification of Caerus Management and inside and outside legal counsel;
• Internal communication procedures and practices including in anticipation of lawsuits; and
• Documentation and protection of evidence requirements.
On-site coordinators must document the drill date and participants and identify areas for
improvement in detailed reports. The reports should be maintained at the Caerus Office for a
period of three years. Any records of the participation of local spill response agencies
should also be kept at the Caerus Office for a period of three years.
7.4 TRAINING RECORDS
Training documents should be retained for the following length of time:
RECORD CUSTODIAN RETENTION
Training Records Caerus Office 5 years
OSHA Reporting Program Caerus Office 12 months after revised,
superseded or obsolete
8.0 MEDIA COMMUNICATIONS
During most incidents, control of the incident will be quickly restored, losses will be modest, and
the public will not be in danger. In such situations, it is Caerus’ policy not to involve the media
or the public. However, depending upon the size, nature, location and time of an incident,
the public may quickly become aware of the incident or safety considerations may dictate
that the company needs to alert the public. In such instances, it is imperative the public be
informed of the incident quickly, effectively, and appropriately. The manner in which the
company communicates can make the difference between a forgiving public and an angry
community.
When interacting with the media, always be professional and courteous. Site supervisors,
pumpers, and other site personnel should politely say that you are not the media spokesperson,
refrain from making any comments, but state that he or she will be available soon. Inform the
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media who the spokesperson is and give them an estimated time of arrival. This is important
so the media will know that Caerus will be providing them with information about the
incident. Also, ask for the names and phone numbers/business cards of media representatives
so the spokesperson can contact them in case they do not remain on the scene. It is important
to have the information so the company can reach the reporters with updated information
later. Nothing is ever “off the record”. Assume everything you say will be quoted. If in doubt,
leave it out
Refer to the Caerus Emergency Notification Chart for the name and contact information for the
Media Relations & Corporate Communications representative.
Don’t:
1. Give incident details if you are not the Media Relations & Corp Communications designee;
2. Go off the record;
3. Estimate damages; (this will be determined in the investigation)
4. Use the phrase “no comment;”
5. Lie or bluff;
6. Place blame, responsibility or anything that might imply company fault, liability or negligence
(it’s under investigation);
7. Speculate;
8. Purposefully minimize the event or its impacts;
9. Be afraid to admit that you don’t know the answer to specific questions;
10. Repeat a negative phrase;
11. Wait for reporters to ask you the right questions;
12. Use industry-specific jargon;
13. Speak for other parties;
14. Allow reporters or “sightseers” to wander around;
15. Discuss confidential information within earshot of persons you don’t know; or
16. Curse or lose your temper.
REMEMBER: DO NOT VOLUNTEER INFORMATION OR SPECULATE AS TO THE CAUSE
OF THE INCIDENT. ONLY THE MEDIA RELATIONS & CORP COMMUNICATIONS SHOULD
PROVIDE INCIDENT DETAILS TO THE MEDIA.
9.0 DOCUMENT CONTROL LOG
The Caerus Operating LLC July 2011 Incident Response Plan has been amended as shown in
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the Amendment Summary TABLE 4.
Table 4: Amendment Summary
Amendment
Date Purpose and Description of Amendment
11/29/2011 Edits provided by Caerus management were incorporated.
12/06/2012 State reporting flowcharts and Oklahoma appendix were added.
03/04/2013 Emergency contact information was revised.
05/01/2013 Emergency contact information was revised.
04/18/2014 State reporting flowcharts revised and updated.
05/15/2015 Emergency contact information was revised.
10/19/2016 Emergency contact information was revised. Corporate address was
updated.
02/01/2017 Assets in NE Colorado & Kansas were divested, and Plan was revised
accordingly.
12/11/2017 Legal input added by Wheeler Trigg O’Donnell LLP and other
organizational changes made.
08/04/2019 Technical and other organizational changes made by Lockton
Companies.
11/07/2019 Revised plan by Caerus staff; approved by Caerus management
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APPENDIX A: ON-CALL RESPONSE FORM
INCIDENT RESPONSE PLAN
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INCIDENT RESPONSE PLAN
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INCIDENT RESPONSE PLAN
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APPENDIX B: GUIDE TO OSHA REPORTABLE/ RECORDABLE INJURIES AND
ILLNESSES
1.0 OSHA Reporting Requirements
The Occupational Safety and Health Administration (OSHA) has procedures for recording and
reporting occupational injuries and illnesses. These procedures are contained in Recording
and Reporting Occupational Injuries and Illnesses, 29 CFR Part 1904. Caerus employees
should be trained regarding OSHA requirements for reporting workplace injuries and illnesses.
Federal law prohibits employers from discriminating against an employee for reporting a work-
related fatality, injury, or illness.
1.1 Roles and Responsibilities
1.1.1 Employee Responsibilities
• Being aware that workplace injuries and illnesses are regulated by OSHA;
• Notifying their supervisor in writing of any workplace injuries and/or illnesses prior to
the end of the work shift that the incident occurred.
1.1.2 Supervisors Responsibilities
• Ensuring that workplace injuries and/or illnesses are properly documented by
reporting the incident to OCC/EHS. EHS will then document the incident by
completing On-Call Response Form (APPENDIX A) within 24 hours of the
incident occurrence.
• Ensuring that employees are not discriminated against for reporting a workplace
injury or illness.
1.1.3 Management Responsibilities:
• Ensuring that all employees are trained to report, in writing, any workplace injuries
and/or illnesses before the end of the work shift that the incident occurred;
• Ensuring that Supervisors complete the On-Call Response Form (APPENDIX A) as
soon as possible after the incident occurrence;
• Ensuring that employees are not discriminated against or retaliated against for
reporting a workplace injury or illness;
• Report all work-related fatalities within 8 hours and all work-related inpatient
hospitalizations, all amputations and all losses of an eye within 24 hours to OSHA;
• Maintaining, reviewing, and, when necessary, modifying the program as required.
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1.2 Reporting OSHA-Reportable Incidents
• For any fatality that occurs within 30 days of a work-related incident, the legal
department, in conjunction with EHS, must report the event within 8 hours of finding
out about it.
• For any in-patient hospitalization, amputation, or eye loss that occurs within 24
hours of a work-related incident, the legal department, in conjunction with EHS, must
report the event within 24 hours of learning about it.
• If an employee work related fatality, hospitalization, amputation, or loss of eye
occurred as a result of a motor vehicle accident and the motor vehicle accident
occurred in a construction work zone, then the legal department, in conjunction with
EHS, must report the fatality, in-patient hospitalization, amputation, or loss of an eye
to OSHA. If the motor vehicle accident occurred on a public street or highway, but
not in a construction work zone, then the fatality, in-patient hospitalization,
amputation, or loss of an eye does not need to be reported to OSHA. However, the
event must be recorded on the OSHA injury and illness records if the employer is
required to keep OSHA injury and illness records.
There are three options for reporting an event to OSHA:
1. By telephone to the OSHA Area Office nearest to the site of the work-related incident.
2. By telephone to the 24-hour OSHA hotline (1-800-321-OSHA or 1-800-321-6742).
3. Electronically, using the event reporting application that will be located on OSHA's public
website.
2.0 Providing Records to Government Representatives
When an authorized government representative asks for the Occupational Injuries and Illnesses
records, Caerus must provide copies of the records within four business hours. Authorized
government representatives include representatives of the Secretary of Labor conducting an
inspection or investigation under the OSHA Act or representatives of the Secretary of Health
and Human Services (including the National Institute for Occupational Safety and Health --
NIOSH) conducting an investigation under the OSHA Act.
3.0 Accident Investigation
Supervisors should complete the On-Call Response Form (APPENDIX A) for each accident
and near-miss Incident which fulfills the OSHA requirement for completing the OSHA 301. The
investigation should be completed within 24 hours of the incident occurrence to assure timely,
accurate information is obtained, prompt action is taken to minimize the potential for
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reoccurrence of similar incidents and to assure important evidence is preserved if needed. The
form will document corrective actions to be taken to ensure that the root causes of the
accident/Incident have been identified, addressed, and corrected.
The goal of an investigation is an objective and thorough analysis of the incident that accurately
describes the event and its causes and suggests ways to prevent the future occurrence of similar
incidents. We then use the investigation information in a constructive way to improve our
environment, health, and safety processes and to share lessons learned with others who may
be faced with similar work situations.
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APPENDIX C: COLORADO REPORTING REQUIREMENTS
1.0 COLORADO INCIDENT REPORTING CONTACTS
Contact information for Colorado incident reporting is provided in TABLE 1 below.
TABLE 1. COLORADO INCIDENT REPORTING CONTACTS
1Contact the EPA only if the NRC cannot be reached.
2.0 REPORTABLE QUANTITIES FOR CHEMICAL SPILLS
FIGURE 1 and FIGURE 2 are decision trees that provide additional guidance on what spill/release
incidents need reported and which agencies need to be notified. Reportable quantities vary by the type
of chemical spilled. Hazardous chemicals are regulated by the EPA, and the Reportable Quantities are
National Response Center
(NRC) http://www.nrc.uscg.mil/index.html 800.424.8802 (24 hour)
Environmental Protection
Agency Region VIII (EPA) 1
http://www.epa.gov/region8/
303.312.6312
800.227.8917
Colorado Oil and Gas
Conservation Commission
(COGCC)
http://oil-gas.state.co.us/
303.894.2100
Colorado Department of Public
Health and Environment
(CDPHE)
http://www.cdphe.state.co.us/
877.518.5608 (24 hour)
Division of Oil & Public Safety
http://oil.cdle.state.co.us/
303.318.8547
Colorado Public Utilities
Commission Pipeline Safety
Group
http://www.dora.state.co.us/puc/
303.894.2000
OSHA Denver Office
http://osha.gov/oshdir/co.html
720.264.6550
Colorado Utility Notification
Center (One-Call System) http://www.co811.org 811
800.922.1987
Colorado State Patrol
Headquarters http://www.csp.state.co.us 303.239.4500 (24 hour)
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listed in the table in 40 CFR 302.4. Examples of the large differences in reportable amounts of
hazardous chemicals are listed in TABLE 2 below. For example, 1 lb. of spilled mercury must be
reported, but a spill of ethylene glycol is not reportable under 5,000 lbs. (539 gallons). It is important to
always comply with the most stringent reporting requirements.
TABLE 2. EXAMPLES OF REPORTABLE QUANTITIES FOR SPILLED CHEMICALS UNDER 40
CFR 302.
SUBSTANCE REPORTABLE QUANTITY
Diethylamine 100 lbs. (17 gallons)
Ethylene glycol 5000 lbs. (539 gallons)
Methanol (Methyl alcohol) 5000 lbs. (762 gallons)
Mercury 1.0 lb. (0.009 gallon)
Other chemicals See the MSDS for amount
Oil is considered a non-hazardous chemical and is not listed in the table in 40 CFR 302.4. However,
each state has developed its own reporting requirements for oil spills.
Resources are available online to determine if the released substances are considered hazardous and
require reporting. The following links provide a “list of lists” that summarize reportable quantities for
hazardous substances:
• http://www.epa.gov/emergencies/docs/chem/list_of_lists_7_26_2011.xls
• http://www.epa.gov/emergencies/docs/chem/list_of_lists_revised_7_26_2011.pdf
In summary, this list shows Threshold Planning Quantities (TPQ) and Reportable Quantities (RQ),
which are the minimum reporting amounts (pounds or curies) for each hazardous substance. Lead, for
example, is 10, meaning that a release of 10 or more pounds of lead is reportable under the CERCLA
RQ.
3.0 LOCAL EMERGENCY PLANNING COMMITTEES
Chemical spills greater than the EPCRA Section 302 and 313 thresholds should be reported to
NDDES and the appropriate LEPC. Phone the local fire department or other Local Emergency
Planning Committees (LEPC) contact listed in TABLE 3 to report:
• The chemical name
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• An indication of whether the substance is extremely hazardous
• An estimate of the quantity released into the environment
• The time and duration of the release
• Whether the release occurred into air, water, and/or land
• Any known or anticipated acute or chronic health risks associated with the emergency
• Advice regarding medical attention for exposed individuals where necessary
• Proper precautions, such as evacuation or sheltering in place
• Name and telephone number of contact person
Written follow-up notice is required as soon as practicable. Written notice should include updates to
the information listed above and descriptions of the response actions taken.
TABLE 3. COLORADO LOCAL EMERGENCY PLANNING COMMITTEES (LEPC)
Agency Name Contact Information
GARFIELD COUNTY 970.945.0453; (24 HOUR) 970.625.8095
MESA COUNTY 970.244.1763; (24 HOUR) 970.242.6707
RIO BLANCO COUNTY 970.878.9623; (24 HOUR) 970.878.9620
WELD COUNTY 970.356.4015 X3990; (24 HOUR) 970.304.4015 X2700
4.0 AGENCY REPORTING REQUIREMENTS
4.1 COLORADO OIL & GAS CONSERVATION COMMISSION RULES
The Colorado Oil & Gas Conservation Commission (COGCC) requires reporting of spills under section
906 - Spills and Releases as follows:
• Spills of 1 barrel must be verbally reported within 24 hours, and by written report using
COGCC Form 19, Spill/Release Report, within 10 days of discovery.
• Spills of any size spill that enters or threatens to enter a water body, must be verbally
reported with 24 hours to the COGCC Director.
• The operator is required to notify the affected surface owner or the surface owner’s
appointed tenant of reportable spills as soon as practicable, but not more than 24 hours,
after discovery.
4.2 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT SPILL
REPORTING
Releases that must be reported to the Colorado Department of Public Health and Environment
(CDPHE) may be reported to the Colorado Environmental Release and Incident Reporting Line.
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Hazardous Substances: Under CERCLA, reportable quantities were established for hazardous
substances listed or designated under other environmental statutes. CERCLA-reportable releases
must be reported immediately to the National Response Center (NRC). These include:
1) All hazardous air pollutants (HAPs) listed under Section 112(b) of the Clean Air Act.
2) All toxic pollutants designated under Section 307(a) or Section 311(b)(2)(A) of the Clean
Water Act.
3) All Resource Conservation and Recovery Act (RCRA) characteristic and listed hazardous
wastes.
4) Any element, compound, or substance designated under Section 102 of CERCLA.
5) Emergency Planning and Community Right-to-Know Act (EPCRA)-reportable releases must
be reported immediately to the National Response Center, the State Emergency
Response Commission (SERC) and the affected Local Emergency Planning Committee
(LEPC).
6) In the case of a release of hazardous waste stored in tanks, RCRA-permitted facilities and
large quantity generators must also notify CDPHE within 24 hours of release to the
environment that is greater than one (1) pound.
Radiation Control: Each licensee or registrant must report to the Radiation Incident Reporting Line
in the event of lost, stolen or missing licensed or registered radioactive materials or radiation machines,
releases of radioactive materials, contamination events, and fires or explosions involving radioactive
materials. Releases of radionuclides are reportable under CERCLA.
Clean Water Act: The Clean Water Act also requires that facilities with a National Pollutant Discharge
Elimination System (NPDES) permit report to the National Response Center within 24 hours of
becoming aware of any unanticipated bypasses or upsets that cause an exceedance of the effluent
limits in their permit and any violations of their maximum daily discharge limits for pollutants listed in
their permit.
Clean Air Act: Hazardous air pollutants (HAPs) are designated as hazardous substances under
CERCLA. If a facility has an air permit but the permit does not allow for or a substance, or if the
facility does not have an air permit, then all releases in excess of the CERCLA / EPCRA reportable
quantity for that substance must be reported to the National Response Center and CDPHE. Upset air
emissions resulting from failure of air pollution control equipment needs to be reported by 10:00 am
the following day to the CDPHE.
Regulated Storage Tanks: Regulated storage tank Owners and operators of systems must report a
release or suspected release to the Division of Oil and of regulated substances to Public Safety at the
Colorado Department of Labor and Employment within 24 hours. Under this program, the reportable
quantity for petroleum releases is 25 gallons or more, or any amount that causes sheen on nearby
surface water. Spills of less than 25 gallons of petroleum must be immediately contained and cleaned
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up. If cleanup cannot be accomplished within 24 hours, the Division must be contacted immediately.
Oil and Public Safety must be notified of Spills of hazardous substances from tanks in excess of the
CERCLA or EPCRA reportable quantity must be reported immediately to the National Response
Center, CDPHE and the local fire authority, and to the Division of Oil and Public Safety within 24 hours.
Transportation and Pipelines: The person in physical possession of a hazardous material must
notify the National Response Center as soon as practical, but not to exceed 12 hours after the incident,
if as a dire material, a person is killed or injured, there is an evacuation of the general public lasting
more than an hour, a major transportation artery is shut down for an hour or more, the flight pattern
of an aircraft is altered, there is fire, spillage or suspected contamination. Natural gas releases from
interstate pipelines that result in injury or death must be reported to the Colorado Public Utilities
Commission Pipeline Safety Group in addition to the National Response Center and appropriate
LEPC.
4.3 NRC AND EPA REPORTING REQUIREMENTS
Releases greater than the RCRA and CERCLA thresholds should be reported to the NRC. Incidents
that must be reported to Federal agencies include spills that enter or threaten Waters of the U.S., any
release of hazardous substances, and natural gas releases from interstate pipelines that result in
injury or death. For all of these Incidents, the National Response Center must be called within 24
hours. If the NRC cannot be reached, call the local EPA 24-Hour Spill Response number or office.
4.4 OSHA REPORTING REQUIREMENTS
See APPENDIX B for information on reporting requirements for the Occupational Safety and Health
Administration (OSHA). Figure 3 is a decision tree that provides additional guidance on what safety
incidents need reported and which agencies need to be notified.
INCIDENT RESPONSE PLAN
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Figure 1: COLORADO SPILL REPORTING DECISION TREE
INCIDENT RESPONSE PLAN
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Figure 2: Colorado BLM Notification Decision Tree
INCIDENT RESPONSE PLAN
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Figure 3: Colorado Safety Notification Decision Tree
INCIDENT RESPONSE PLAN
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Last Reviewed Date: 10.11.2021
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APPENDIX D: UTAH INCIDENT REPORTING REQUIREMENTS
1.0 REPORTABLE QUANTITIES FOR CHEMICAL SPILLS
Reportable quantities vary by the type of chemical spilled. Hazardous chemicals are regulated
by the EPA, and the Reportable Quantities are listed in the table in 40 CFR 302.4. Examples of
the large differences in reportable amounts of hazardous chemicals are listed in TABLE 2 below.
For example, 1 lb. of spilled mercury must be reported, but a spill of ethylene glycol is not
reportable under 5,000 lbs. (539 gallons). It is important to always comply with the most stringent
reporting requirements. Refer to the table in 40 CFR 302.4 and MSDSs for specific chemicals
not contained in TABLE 2 below.
TABLE 1: EXAMPLES OF REPORTABLE QUANTITIES FOR SPILLED CHEMICALS UNDER 40 CFR 302.
SUBSTANCE REPORTABLE QUANTITY
Diethylamine 100 lbs. (17 gallons)
Ethylene glycol 5000 lbs. (539 gallons)
Methanol (Methyl alcohol) 5000 lbs. (762 gallons)
Mercury 1.0 lb. (0.009 gallon)
Other chemicals See the MSDS for amount
Oil is considered a non-hazardous chemical and is not listed in the table in 40 CFR 302.4.
However, each state has developed its own reporting requirements for oil spills.
Resources are available online to determine if the released substances are considered
hazardous and require reporting. The following links provide a “list of lists” that summarize
reportable quantities for hazardous substances:
• http://www.epa.gov/emergencies/docs/chem/list_of_lists_7_26_2011.xls
• http://www.epa.gov/emergencies/docs/chem/list_of_lists_revised_7_26_2011.pdf
In summary, this list shows Threshold Planning Quantities (TPQ) and Reportable Quantities
(RQ), which are the minimum reporting amounts (pounds or curies) for each hazardous
substance. Lead, for example, is 10, meaning that a release of 10 or more pounds of lead is
reportable under the CERCLA RQ.
INCIDENT RESPONSE PLAN
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2.0 LOCAL EMERGENCY PLANNING COMMITTEES
Chemical spills greater than the EPCRA Section 302 and 313 thresholds should be reported to
NDDES and the appropriate LEPC. Phone the local fire department or other Local Emergency
Planning Committees (LEPC) contact listed in TABLE 3 to report:
• The chemical name
• An indication of whether the substance is extremely hazardous
• An estimate of the quantity released into the environment
• The time and duration of the release
• Whether the release occurred into air, water, and/or land
• Any known or anticipated acute or chronic health risks associated with the emergency
• Advice regarding medical attention for exposed individuals where necessary
• Proper precautions, such as evacuation or sheltering in place
• Name and telephone number of contact person
Written follow-up notice is required as soon as practicable. Written notice should include updates
to the information listed above and descriptions of the response actions taken.
TABLE 2. UTAH LOCAL EMERGENCY PLANNING COMMITTEES (LEPC)
Agency Name Contact Information
UINTAH COUNTY 435.781.6755
DUCHESNE COUNTY 435.738.1226
2.1 UTAH OFFICE OF HOMELAND SECURITY
All emergencies should be reported to the Utah Department of Homeland Security. Dispatchers
are available 24 hours a day to assist in emergency response.
2.2 UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY (UDEQ)
Emergency Response - Section 114 of Chapter 5 of the Utah Water Quality Act (UWQA)
regulates the containment, cleanup and disposal of oil or hazardous substances released to
waters of the state, or which threaten to enter waters of the state. Pursuant to Section 114 of
Chapter 5 of the WQA, the following spills/releases are reportable to the UDEQ:
• Releases of "oil" and "hazardous substances" which enter waters of the state.
• Releases that are determined to be a threat to enter waters of the state and are: a)
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considered a "hazardous substance", or b) any amount greater than 25 gallons of
crude oil/petroleum, condensate/produced water, or refined crude oil products that have
traveled off site.
• Releases from underground storage tanks are regulated by UDEQ rule R311-202-1
incorporating 40 CFR 280.53.
• Incidents at exploration and production facilities are regulated by Utah Division of Oil,
Gas, and Mining (UDOGM) Rule R649-3-32.
• Please note that non-reportable spill events are still required to be addressed
immediately by containing, removing, and UDEQ disposing of the released product
according to UDEQ regulations.
Procedures following a spill:
• Immediately notify the division of the type, quantity, and location of the release, if the
spill traveled offsite, and of the response, containment and cleanup actions which have
been taken or are proposed to be taken.
• Immediately proceed to correct the cause of the release.
• Within five (5) days following a release, submit a complete written report to the division
describing the reportable release and steps taken to prevent a reoccurrence.
• See Figures 4 and 5 for release reporting notification criteria.
UDEQ Emergency Response Coordinator
If you are unsure about whether the substance that has been released is reportable or would be
considered a hazardous substance, you should contact the UDEQ Emergency Response
Coordinator.
Contact information for Utah incident reporting is provided in TABLE 3 below.
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TABLE 3: UTAH INCIDENT REPORTING CONTACTS
Agency Name Web Address Contact Information
National Response Center
(NRC)1
http://www.nrc.uscg.mil/index.html 1.800.424.8802 (24 Hour)
Environmental Protection Agency
Region VIII (EPA)
http://www.epa.gov/region8/ 303.312.6312
800.227.8917
UDEQ Emergency Response
Coordinator
https://deq.utah.gov/division-
environmental-response-remediation
801.536.4123 - 24-hour number
801.536.0200
State of Utah Division of Oil, Gas
& Mining (UDOGM)
https://oilgas.ogm.utah.gov/oilgasweb/ 801.538.5296
801.386.3902 – After Hours
Local Emergency Planning
Commission (LEPC)
N/A See Table 2 for non-
emergency phone numbers.
Bureau of Land Management
Green River District Vernal Utah
Field Office (BLM)
https://www.blm.gov/office/vernal-field-
office
435.781.4400
3.0 NATIONAL REPORTING REQUIREMENTS
Releases greater than the RCRA and CERCLA thresholds should be reported to the NRC.
Incidents that must be reported to Federal agencies include spills that enter or threaten Waters
of the U.S., any release of hazardous substances, and natural gas releases from interstate
pipelines that result in injury or death. For all of these Incidents, the National Response Center
must be called within 24 hours. If the NRC cannot be reached, call the local EPA 24-Hour Spill
Response number or office.
See APPENDIX B for information on reporting requirements for the Occupational Safety and
Health Administration (OSHA)
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Figure 4: Utah Spill Reporting Decision Tree
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Figure 5: Utah BLM Notification Decision Tree