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Maintaining and Testing an EAP

After an Emergency Action Plan for a High-Hazard Potential dam has been developed, approved, and distributed, periodic reviews and updates must be performed. Without ongoing maintenance, the EAP will become outdated and ineffective. These reviews should be performed at least annually to evaluate the adequacy of the procedures and contact information. Some states that require EAPs for HHP dams also require these reviews, which may take the form of seminars and/or workshop. EAP forms typically include a section where the dates and findings of reviews can be recorded.

The review should involve the dam owner or manager, any engineers or consultants working with the dam owner, and the local emergency management director or coordinator. They will evaluate any changes in flood inundation areas, downstream developments, the reservoir, dam and emergency management personnel and contact information, or new emergency procedures. Any changes to the dam and/or inundation zone should be evaluated carefully because the changes may affect the inundation maps. The review should result in a determination of whether any revisions, including updates to inundation maps, are necessary. Once the EAP has been revised, the updated version (or only the affected pages in minor updates) should be promptly distributed to those on the distribution list. Maps should be changed as soon as practicable noted in the EAP and distributed as needed.

The EAP should be updated promptly with new information that results from reviews and verifications of personnel and contact information shown in the Notification Flowcharts and contact lists. Even if no revisions are necessary, the review should be documented as having been completed.

EAP planning meeting.

The next step up from a periodic review is an exercise of the EAP. Exercises are tests and practice sessions that additionally involve first responders, regional emergency management staff, and others who have a role in implementing an EAP. Exercises usually are held in cycles of two or more years since they involve more planning and people. If the EAP action items and procedures are not exercised periodically, those involved in its implementation may lose familiarity with their roles and responsibilities. A proposed exercise schedule and plans for an EAP exercise program should be included in the EAP.

Annual Review

The dam owner, operator, or representative is responsible for reviewing the EAP at least once annually and updating it as necessary. This review includes calling all contact information listed on the Emergency Response Information Sheets to verify that contact names, phone numbers, addresses and other information are current. One of the most important among these being the contacts listed in the Emergency Notification Flowcharts. Making updates to Locally Available Resources along with the other info sheets is also important so that accurate information is readily available during an emergency.

The EAP document held by the dam owner, operator, or representative is the master document. When revisions are made, the Record of EAP Revisions (usually an Appendix) must be updated and the revised version distributed to all EAP document holders. The document holders are responsible for replacing their outdated copy of the EAP when revisions are received. Outdated EAPs must be immediately discarded to avoid any confusion with the revisions. The EAP should identify which pages contain confidential information to ensure proper disposal of outdated pages (such as by shredding) upon receipt of updates. The dam owner, operator, or representative should consider numbering the EAP documents as "Copy __ of __" prior to initial distribution.

The Crucial Follow-Up Step: EAP Exercises

The dam owner, operator, or representative also is responsible for facilitating a periodic test, either tabletop or functional exercise, of the EAP. The frequency of testing, based on the hazard potential of the dam, may be determined by the dam owner or operator/representative, local emergency managers, and local first responders such as the county sheriff). State Dam Safety Program staff and emergency managers, with input from local emergency responders, can provide dam owners with guidelines and assistance in conducting exercises of their EAPs.

Exercises should be held in coordination with state, local and tribal emergency management authorities. Exercises promote prevention, preparedness, and response to incidents and emergencies and may also be extended to include recovery operations. Exercising also demonstrates the EAP’s effectiveness in an actual situation and demonstrates the readiness levels of key personnel. Periodic exercises result in an improved EAP as lessons learned are incorporated into the updated EAP document.

Exercises are conducted to test plans, procedures, equipment, facilities, and training. Exercises are evaluated to determine what went right and what needed improvement. Deficiencies noted during the exercise are documented and discussed in an After Action Review or report (AAR). A plan is developed to identify problems that need to be corrected and who is responsible for correcting them. The corrective action plan leads to changes in plans, procedures, equipment, facilities, and training, which are again tested during the next exercise.

Tabletop is the most common type of exercise for dams. Frequency may depend on the size of the dam and reservoir, the size of the inundation zone, and when there are changes in the key officials who would be involved in responding to a dam failure or severe emergency.

Tabletop Exercise

The purpose of a tabletop exercise is to facilitate a learning environment where response agencies can come together, face to face, to understand and talk through an integrated response to a specific emergency situation. The tabletop exercise involves a meeting of the owner or a representative and local and state emergency management officials in a conference room. The exercise begins with a description of a simulated event and proceeds with discussions by the participants to evaluate the EAP and response procedures, and to resolve concerns regarding coordination and responsibilities. Any problems identified during an exercise should be included in revisions to the EAP.

During a tabletop exercise, emergency facilities are not activated and emergency response forces are not deployed. Tabletops provide an ideal environment for learning, discussing, and identifying issues that may not be as obvious when players are physically separated as they are during drills and other exercises. Tabletop exercises provide an excellent opportunity to compare what participants actually expect to do and how they plan to do it with what is written in the local emergency plan, highlighting changes that may need to be made in the plan. Tabletop exercises are frequently conducted as part of the preparation for a later functional or full-scale exercise. Tabletop exercises typically are recommended or required at least every three to five years.

EAP tabletop exercise session.

Functional Exercise

A functional exercise is designed to test and evaluate selected emergency functions and the interaction of various levels of government, response organizations, volunteer groups, and industry in a simulated emergency environment. This type of exercise usually involves key decision-makers, the local Emergency Operating Center, and representatives of response and support organizations. Field response units are not normally activated and deployed during a functional exercise. Emergency situations and events are simulated, along with field response activities, and some participants may represent external organizations pertinent to the exercise scenario that are not participating in the exercise, such as federal agencies.

Full-Scale Exercise

A full-scale exercise includes all the components of the functional exercise plus activation of an incident command post and actual deployment of response personnel and equipment to respond to a simulated emergency situation. Full-scale exercises may also involve participation by mutual aid resources from other jurisdictions and state and federal coordination and response elements. A full-scale exercise is intended to test and evaluate the operational capability of the overall emergency management organization to respond to a realistic scenario. Since full-scale exercises involve deployment and employment of actual response resources, they are often fairly costly to conduct. In a full-scale exercise, the EAP for a dam may be part of a more comprehensive situation involving multiple jurisdictions across several counties or states. For example, an earthquake, flood or hurricane exercise may include dam failure as one aspect of a much larger emergency scenario. Large-scale exercises may involve multiple dams, their owners and their EAPs.

USDA NRCS Watershed Dams

Watershed dams built with USDA funding participation are required to have period reviews and exercises. The NRCS EAP template notes that:

The Conservation District Manager will review and, if needed, update the EAP at least once each year. The EAP annual review will include the following:

• Calling all contacts on the three notification charts in the EAP to verify that the phone numbers and persons in the specified positions are current. The EAP will be revised if any of the contacts have changed.
• Contacting the local law enforcement agency to verify the phone numbers and persons in the specified positions. In addition, the Conservation District Manager will ask if the person contacted knows where the EAP is kept and if responsibilities described in the EAP are understood.
  
• Calling the locally available resources to verify that the phone numbers, addresses, and services are current.

Revisions

The Conservation District is responsible for updating the EAP document. The EAP document held by the Conservation District is the master document. When revisions occur, the Conservation District will provide the revised pages and a revised revision summary page to all the EAP document holders. The document holders are responsible for revising outdated copy of the respective document(s) whenever revisions are received. Outdated pages shall be immediately discarded to avoid any confusion with the revisions.

EAP periodic test

The Conservation District will host and facilitate a periodic test of the EAP at least once every 5 years. The periodic test will consist of a meeting, including a tabletop exercise, conducted at the County Conservation District office. Attendance should include the Conservation District Manager, key conservation district staff members, NRCS staff, at least one representative of the local law enforcement agency, and others with key responsibilities listed in the EAP. At the discretion of the Conservation District, other organizations that may be involved with an unusual or emergency event at the dam are encouraged to participate. Before the tabletop exercise begins, meeting participants will visit the dam during the periodic test to familiarize themselves with the dam site.

The tabletop exercise will begin with the facilitator presenting a scenario of an unusual or emergency event at the dam. The scenario will be developed prior to the exercise. Once the scenario has been presented, the participants will discuss the responses and actions that they would take to address and resolve the scenario. The narrator will control the discussion, ensuring realistic responses and developing the scenario throughout the exercise. The Conservation District Manager should complete an event log as they would during an actual event.

After the tabletop exercise, the five sections of the EAP will be reviewed and discussed. Mutual aid agreements and other emergency procedures can be discussed. The Conservation District will prepare a written summary of the periodic test and revise the EAP, as necessary.