Revised PREP Guideline Review: What You Should Know?

2017 ◽  
Vol 2017 (1) ◽  
pp. 156-172
Author(s):  
Daniel M. Sobieski ◽  
Kathryn L. Kelley
Keyword(s):  
Environmental Protection Agency ◽  
Oil Pollution ◽  
Exercise Program ◽  
Lessons Learned ◽  
Coast Guard ◽  
Vessel Response ◽  
Remote Assessment ◽  
Qualified Individual ◽  
Response Plan ◽  
New Guidelines

ABSTRACT No. 2017 – 296 On April 11, 2016 the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline and Hazardous Materials Safety Administration (PHMSA), and the Bureau of Safety and Environmental Enforcement (BSEE) released the 2016 National Preparedness for Response Exercise Program (PREP) Guidelines. The new guidelines became effective on June 10, 2016 and replaced the previous guidelines issued in 2002. Established under the Oil Pollution Act of 1990 (OPA 90), the PREP guidelines were developed to provide a mechanism for compliance with response plan drill and exercise requirements under the Act and implementing regulations. Use of the PREP Guidelines is voluntary, however, compliance with the PREP guidelines will satisfy these requirements. The 2016 PREP Guidelines apply to all OPA 90 response plan holders including USCG regulated vessels and marine transportation-related facilities, EPA non-transportation-related onshore and offshore facilities, PHMSA-regulated facilities and pipelines, BSEE-regulated offshore facilities and area on-scene coordinator (OSC) exercises. The guidelines specify that, within a three-year cycle, all elements of the Facility Response Plan (FRP) or Vessel Response Plan (VRP), including the 15 core components, should be exercised in a drill, or series of drills, involving the Owner/Operator, Qualified Individual (QI), Oil Spill Removal Organizations (OSRO) and Salvage and Marine Firefighting (SMFF) resource providers. This paper will provide an overview of the PREP requirements, including plan holder initiated exercises, the remote assessment and consultation exercises (RACE) for vessels, shore-based tabletop exercises, response equipment deployment exercises, and Government Initiated Unannounced Exercises (GUIEs). As the QI, O’Brien’s has designed, conducted, played, and or evaluated well over 1,000 PREP related activities. This paper will discuss the implementation of PREP from the QI’s perspective, and the identification of some lessons learned and best practices that may be applicable more broadly to support the regulated industry and response community with the implementation of PREP.

Integrated Vessel Response Plan Format

1999 ◽  
Vol 1999 (1) ◽  
pp. 635-638
Author(s):  
William C. Rogers ◽  
Jean R. Cameron
Keyword(s):  
Oil Spill ◽  
West Coast ◽  
Oil Pollution ◽  
Task Force ◽  
The United States ◽  
Coast Guard ◽  
Response Planning ◽  
Vessel Response ◽  
Response Plan ◽  
The U.S

ABSTRACT Oil shipping companies operating on the West Coast of the United States are subject to international, federal, and state oil spill prevention and response planning regulations. Many companies wrote separate plans for each jurisdiction with the result that tank vessels carried several different plans on board and parent companies faced an administrative burden in keeping plans current. In June 1996, oil shipping company representatives proposed that the States/British Columbia Oil Spill Task Force work with them to develop a format incorporating West Coast states' and U.S. Coast Guard contingency planning requirements. A workgroup comprised of representatives of the Task Force, industry, and the U.S. Coast Guard, working cooperatively, eventually proposed a voluntary integrated plan format based on the key elements of the U.S. Coast Guard Vessel Response Plan. This format allowed correlation with state planning requirements as well as with the Shipboard Oil Pollution Emergency Plan (SOPEP) required by international regulations. The U.S. Coast Guard, the Canadian Ministry of Transport, and all West Coast states have subsequently documented their agreement to accept vessel plans in this format, to coordinate review as needed, and to allow references to public documents such as Area Plans.

Government Initiated Unannounced Exercises (GIUEs): Developing Response Best Practices to Improve Marine Environmental Response Preparedness

2017 ◽  
Vol 2017 (1) ◽  
pp. 2879-2894
Author(s):  
Christopher Klarmann ◽  
LCDR Johna Rossetti
Keyword(s):  
Best Practices ◽  
Oil Spill ◽  
Oil Pollution ◽  
Coast Guard ◽  
Regulatory Agencies ◽  
Environmental Response ◽  
Vessel Response ◽  
Oil Spill Response ◽  
Response Plan ◽  
Marine Environmental

ABSTRACT ID: 2017-101 – GIUEs: Developing Best Practices to Improve Marine Environmental Response Preparedness The U.S. Coast Guard (USCG) is authorized by the Oil Pollution Act (OPA) of 1990 to conduct Government Initiated Unannounced Exercises (GIUE), a cornerstone of the oil spill exercise cycle. These exercises are instrumental for USCG Captains of the Port (COTP) to evaluate industry preparedness for oil spill response by specifically testing a facility or vessel on notification procedures, response time, and deployment of facility-owned or Oil Spill Removal Organization (OSRO) equipment. Facility Response Plan holders and Vessel Response Plan holders are subject to these exercises under federal regulations 33 C.F.R. § 154 and § 155. In 2013, the USCG restructured their GIUE policy to provide better guidance for employees. This updated policy detailed how to properly plan and conduct a GIUE as well as established expectations following both satisfactory and unsatisfactory exercises. In this paper we will examine the changes that the USCG has made regarding its policy on planning and conducting GIUEs, describe how USCG field units are implementing the new policy, including how unsatisfactory GIUEs are addressed, and examine what commonalities, are being seen in GIUE unsatisfactory results. Finally, we will discuss how plan holders, OSROs, and regulatory agencies can work together to better prepare for responding to an environmental emergency when it occurs.

LESSONS LEARNED FROM THE NATIONAL PREPAREDNESS FOR RESPONSE EXERCISE PROGRAM1

1995 ◽  
Vol 1995 (1) ◽  
pp. 543-546 ◽  
Author(s):  
W. Michael Kurgan ◽  
Karen Laney
Keyword(s):  
Environmental Protection Agency ◽  
Oil Pollution ◽  
Community Response ◽  
Lessons Learned ◽  
Coast Guard ◽  
Management Service ◽  
Incident Command ◽  
Unified Command ◽  
National Preparedness ◽  
Response Exercise

ABSTRACT The National Preparedness for Response Exercise Program (PREP) was developed to meet the intent of the Oil Pollution Act of 1990 (OPA 90). PREP is a unified federal effort and incorporates the exercise requirements of the Coast Guard; Environmental Protection Agency (EPA); Research and Special Programs Administration (RSPA), Office of Pipeline Safety; and the Minerals Management Service. (MMS). Each year 20 PREP area exercises are held: six led by the federal government and 14 led by the industry. Five of the six government-led exercises are conducted in coastal areas where the Coast Guard is designated as the federal on-scene coordinator (FOSC). One is held in an inland region where the EPA is the FOSC. Each government-led pollution simulation typically involves more than 40 agencies and more than 400 participants. The PREP simulations focus on a geographical community response to a pollution incident with a unified command structure. The unified command is supported by the four basic elements of an incident command system: planning, operations, logistics, and finance. Area PREP exercises create realistic situations focusing on specific objectives. Emphasis is placed on the realism and decision-making process throughout the entire 30 weeks it takes to prepare an exercise. The National Strike Force Coordination Center collects data from critiques and other aspects of the exercise to help create and develop a standard for exercise evaluation. Data collected and lessons learned at each exercise are disseminated throughout the oil spill industry.

HARMONIZING REQUIREMENTS FOR OILS, NOXIOUS LIQUID SUBSTANCES, AND HAZARDOUS SUBSTANCES IN SPILL PREPAREDNESS REGULATIONS1

2005 ◽  
Vol 2005 (1) ◽  
pp. 101-106
Author(s):  
Gary Yoshioka ◽  
Ellinor Coder ◽  
Isabelle Morin ◽  
Mark Landry ◽  
Barbara Davis ◽  
...  
Keyword(s):  
Environmental Protection Agency ◽  
Coast Guard ◽  
Maritime Transportation ◽  
Hazardous Substances ◽  
Environmental Response ◽  
International Convention ◽  
Vessel Response ◽  
Require Response ◽  
Response Plan ◽  
The U.S

ABSTRACT The U.S. Coast Guard (USCG) enforces regulations for vessel response plans and marine transportation-related facility response plans for oil. The U.S. Environmental Protection Agency (EPA) enforces similar regulations for response plans for non-transportation-related facilities. Proposed USCG rules would require response plans for hazardous substances designated under the authority of the Clean Water Act (CWA). Other USCG regulations implement provisions of the International Convention for the Prevention of Pollution from Ships, known as MARPOL 73/78. Annex I of MARPOL 73/78 addresses petroleum pollution, while Annex II identifies and addresses Noxious Liquid Substances (NLSs). The Coast Guard and Maritime Transportation Act of 2004 gives the USCG authority to require response plans for NLSs under the CWA. There is some overlap, however, in the substances that are listed as NLSs and those that are categorized as oils or designated as CWA hazardous substances. Adding NLSs to the list of substances requiring a response plan has several implications for spill prevention, preparedness, and response programs. Some facilities currently have response plans for oils and may have response plans for CWA hazardous substances in the future. Some NLSs may be hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and response plans for those NLSs must be consistent with spill notification and response requirements under CERCLA. EPA and USCG On-Scene Coordinators must consider these overlapping listings when deciding on the appropriate removal actions for discharges. Facility owners and operators will need to consider their existing response plans when preparing response plans for NLSs. Under the CWA all response plans must be consistent with the National Contingency Plan and Area Contingency Plans.

U.S. Environmental Protection Agency/U.S. Coast Guard Peer Exchange Program1

1999 ◽  
Vol 1999 (1) ◽  
pp. 1137-1139
Author(s):  
Jeffrey C. Babb ◽  
Glenn Cekus
Keyword(s):  
Environmental Protection ◽  
Environmental Protection Agency ◽  
Oil Pollution ◽  
Coast Guard ◽  
Leadership Roles ◽  
Environmental Response ◽  
Protection Agency ◽  
Response Planning ◽  
Response Team ◽  
The U.S

ABSTRACT Nationwide, the U.S. Coast Guard (CG) and the U.S. Environmental Protection Agency (EPA) are both tasked with the implementation of several environmental and safety statutes (Comprehensive Environmental Response, Compensation, and Liabilities Act [CERCLA], Oil Pollution Act of 1990 [OPA 90], Clean Water Act [CWA], international Convention for the Prevention of Pollution from Ships [MARPOL], etc.). They share important leadership roles on the National Response Team (NRT), Regional Response Team (RRT) and several other response planning bodies. Often EPA On-Scene Coordinators (OSCs) and CG OSC representatives work together in oil and chemical response operations and on various planning and exercise committees. However, the joint efforts of both organizations are often impacted by a mutual lack of understanding of each other's authorities, policies, procedures, internal structures, and leadership roles. Even the response zones for CG and EPA are often based on factors other than geography and often may not be well understood. USCG Marine Safety Office (MSO) Chicago and EPA Region V are bridging this gap in understanding by sponsoring a Peer Exchange Program. Representatives from each agency are spending up to a week with the other agency for hands-on training and education. The program was initiated in April 1996 and has produced excellent results. As a result, joint CGIEPA responses run more smoothly, mutual understanding and accessibility are enhanced, and overall public health and welfare and the environment are better protected.

Unannounced Drill Program: Testing Spill Management Team Capability through Vessel & Facility Oil Spill Contingency Plans

2017 ◽  
Vol 2017 (1) ◽  
pp. 2017425
Author(s):  
Cassidee Shinn ◽  
Joe Stewart ◽  
Yvonne Addassi
Keyword(s):  
Oil Spill ◽  
Environmental Protection Agency ◽  
Initial Response ◽  
Lessons Learned ◽  
Coast Guard ◽  
Incident Command ◽  
Contingency Plan ◽  
Program Testing ◽  
Continued Education ◽  
Contingency Plans

California has approximately >10,000 vessels calling its ports each year, and 200–300 facilities state wide, many of which are required to have a California Oil Spill Contingency Plan (Contingency Plan) on file with Office of Spill Prevention and Response (OSPR). Spill Management Teams (SMT), either staffed by Contingency Plan holders' employees or contracted out, and the use of the Incident Command System (ICS) structure must be described in these plans. OSPR introduced an unannounced SMT drill program (Program) in 2012 to ensure that Contingency Plan holders can successfully complete the proper initial notifications, activate their SMT, and use ICS in accordance with their approved Contingency Plan and California Code 820.01, Drills and Exercises. There are multiple goals of this Program, including the enhanced capability of SMTs, OSPR, and other partners. This Program provides continued education and training for Contingency Plan holders and SMTs in an effort to bolster the initial response phase of an actual incident. Through these drills, SMTs must demonstrate that they could make proper notifications and decisions during an actual incident and be staffed with trained personnel in ICS to fill positions before State and Federal representatives respond. Additionally, SMTs should deploy resources listed in their approved Contingency Plans and ensure those resources are up to date, available, and sufficient. Furthermore, drills provide an opportunity for OSPR and SMTs to build relationships through testing these procedures, which should make the initial response more efficient and effective. Lastly, the drills are often conducted with representatives from United States Coast Guard and Environmental Protection Agency, both of which have their own drill programs. Working in conjunction with federal partners ensures continuity and fewer required drills of SMTs. Since the beginning of the Program, SMTs continue to improve their response capabilities, validated by more successfully completed unannounced drills. OSPR has conducted 30 unannounced drills, all of which were on SMTs for marine facilities and vessels. With the expanded authority of OSPR to regulate facilities statewide in 2015, this Program will continue to grow. Ultimately, a more comprehensive Program should lead to enhanced SMT capability statewide, and therefore better protection of the State's natural resources overall. The goal of this poster will be to describe: 1) the history and purpose of this Program; 2) the lessons learned and improvements of SMTs and Contingency Plans; and 3) the expansion of the Program from marine to statewide.

Coast Guard and Epa: One Area Contingency Plan

1999 ◽  
Vol 1999 (1) ◽  
pp. 967-969
Author(s):  
David Westerholm ◽  
David Anderson ◽  
James Augustyn ◽  
Thomas Rayburn
Keyword(s):  
Environmental Protection Agency ◽  
Oil Pollution ◽  
Pilot Project ◽  
Coast Guard ◽  
Contingency Planning ◽  
Physical Size ◽  
Western Lake ◽  
Federal Response ◽  
The One ◽  
Western Lake Erie

ABSTRACT The U.S. Coast Guard (USCG) and U.S. Environmental Protection Agency (EPA) have developed a pilot project to address federal Oil Pollution Act of 1990 (OPA) requirements for Area Contingency planning in the Captain of the Port (COTP) Zone and the corresponding U.S. EPA inland area in a portion of the Western Lake Erie Basin. The project, known as the “One County In” approach, encompasses contingency planning for the entire county, not just the COTP Zone. Local and state planners and responders as well as industry representatives fully support the effort. The one plan eliminates the multi-plan issues associated with divided federal response jurisdictions. While the geographic scope of the Plan expanded, the physical size of the document decreased significantly due to a detailed review by the Area Committee. Initiated in fall 1997, the combined Plan was completed in September 1998.

VESSEL RESPONSE PLANS: FORGING BETTER PLANS THROUGH INDUSTRY/GOVERNMENT COOPERATION

1997 ◽  
Vol 1997 (1) ◽  
pp. 443-446
Author(s):  
Charles Corbett ◽  
Svein Ringbakken
Keyword(s):  
Coast Guard ◽  
Final Rule ◽  
Vessel Response ◽  
Response Plan

ABSTRACT The vessel response plan process of review and the substance of the existing requirements are in need of review and refinement. Both vessel operators and, we believe, the Coast Guard are overwhelmed with a paperwork burden that should be relieved, and can be relieved. Additionally, there are a number of issues that require attention to ensure that all interested parties are reacting to the provisions of the final rule (as amended, we suggest) in a constructive manner. This paper proposes a joint industry/government forum in which dialogue can occur, and it offers examples of why that dialogue is needed.

USING EXERCISES AS A SOURCE OF OIL POLLUTION RESEARCH IDEAS

2014 ◽  
Vol 2014 (1) ◽  
pp. 1400-1407
Author(s):  
William T. Vocke
Keyword(s):  
Homeland Security ◽  
Oil Pollution ◽  
Evaluation Criteria ◽  
Exercise Program ◽  
Pollution Prevention ◽  
Lessons Learned ◽  
Limiting Factors ◽  
Research Needs ◽  
Wide Range ◽  
New Research

ABSTRACT Advancing the state of the art in oil pollution prevention and response requires the identification of missing elements and developing research to fill in the gaps in information. Researchers rely on a wide range of methods to identify new areas for study. Previous research frequently identifies new questions that could not be addressed at the time, or were outside the scope of the study. Lessons learned during response to real events also provide valuable insights. However, Preparedness for Response Exercise Program (PREP) and Homeland Security Exercise Evaluation Program (HSEEP) exercises are often overlooked as a source of new ideas for research. Exercises are widely used to identify emergency response capabilities, to test equipment, practice response protocols, and to train personnel in their duties. This paper presents a review of selected After Action Reports (AARs) from PREP and HSEEP oil spill exercises to determine the extent that new research ideas could be gleaned from the information and the extent that research opportunities were identified. This paper also addresses factors that limit the utility of exercises for identifying research needs. These limiting factors include the exercise purpose, exercise design, evaluation criteria, and after action reporting protocols. Practical suggestions on approaches to considering research needs during the exercises are provided.

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