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.