NATIONAL PREPAREDNESSFORRESPONSE EXERCISE PROGRAM(PREP)GUIDELINESDEPARTMENT OF TRANSPORTATIONU.S. Coast GuardResearch and Special Programs AdministrationENVIRONMENTAL PROTECTION AGENCYDEPARTMENT OF THE INTERIORMinerals Management ServiceAugust 2002PREP GUIDELINESTable of ContentsIntroduction___________________________________________ 1-1Guiding Principles______________________________________ 2-1U.S. Coast Guard-Regulated Vesselsand Marine Transportation-RelatedFacilities _____________________________________________ 3-1EPA-Regulated Onshore and Certain Offshore _ Non TransportationRelated Facilities ______________________________________ 4-1Onshore Transportation-Related Pipelines __________________ 5-1Offshore Facilities______________________________________ 6-1Area Exercises ________________________________________ 7-1A. Internal Exercise Documentation Forms __________________A-1B. Response Plan Core Components_______________________B-1To the “Response Community”:This is the first revision since August 1994 to the Preparedness forResponse Exercise Program (PREP) when we set out together to design aneffective and coordinated exercise programunder the Oil Pollution Act of 1990.As before, the revisions are the result of an open dialogue and the incorporationof lessons learned over the past 8 years.We considered issues identified inpublic meetings and in written comments received to the Department ofTransportation regulatory docket (2000-7514). The PREP will evolve as thegovernment and industry continue to meet the challenge of protecting theenvironment, public health and welfare. Welook forward to working with allparties as we continue toimprove the PREP process.Captain David WesterholmChief, Office of ResponseU.S. Coast GuardMichael B. CookDirector, Office of Emergency andRemedial ResponseU.S. Environmental ProtectionAgencyStacey GerardAssociate Administrator forPipeline SafetyResearch and SpecialPrograms AdministrationElmer P. DanenbergerChief, Engineering and OperationsDivisionMinerals Management ServiceOperationsPREP GUIDELINESTable of Contents______________________________________________________________SECTIONS1. Introduction___________________________________________ 1-12. Guiding Principles _____________________________________ 2-13. U.S. Coast Guard-Regulated Vessels and MarineTransportation-Related Facilities_________________________ 3-14. EPA-Regulated Onshore and Certain OffshoreNon Transportation-Related Facilities _____________________ 4-15. Onshore Transportation-Related Pipelines _________________ 5-16. Offshore Facilities _____________________________________ 6-17. Area Exercises ________________________________________ 7-1APPENDICES...A. Internal Exercise Documentation Forms ____________________A-1B. Response Plan Core Components _________________________B-1SECTION 1: INTRODUCTIONPurposeThe National Preparedness for Response Exercise Program (PREP) wasdeveloped to establish a workable exercise program which meets theintent of section 4202(a) of the Oil Pollution Act of 1990 (OPA 90),amending section 311 (j) of the Federal Water Pollution Control Act(FWPCA), by adding a new subsection (6) and a new subsection (7) forspill response preparedness [33 U.S.C. 1321 (j)]. The PREP wasdeveloped to provide a mechanism for compliance with the exerciserequirements, while being economicallyfeasible for the government andoil industry to adopt and sustain. The PREP is a unified federal effort andsatisfies the exercise requirements of the Coast Guard, theEnvironmental Protection Agency(EPA), the Research and SpecialPrograms Administration (RSPA) Office of Pipeline Safety, and theMinerals Management Service (MMS). Completion of the PREPexercises will satisfy all OPA 90 mandated federal oil pollution responseexercise requirements.PREP addresses the exercise requirements for oil pollution response. Atthis time, Coast Guard is the onlyone of the four participating federalagencies considering regulationsrequiring HAZSUB response planningand exercises under the Federal Water Pollution Control Act and the OilPollution Act of 1990. Therefore,the HAZSUB exercise standardsdescribed in Section 3 of the Guidelines apply only to CG-regulatedvessels and facilities in accordance with 33 CFR 154/155. There areadditional industry planning and exerciserequirements contained in otherfederal statutes, which are notaddressed in these Guidelines.The PREP represents theminimumguidelines for ensuring adequateresponse preparedness. If personnel within an organization believeadditional exercises or an expansion ofthe scope of the PREP exercisesare warranted to ensure enhanced preparedness, they arehighlyencouragedto conduct these exercises.The PREP exercises should be viewed as an opportunity for continuousimprovement of the response plans and the response system.Planholders are responsible for addressing any issues that arise fromevaluation of the exercises and for making changes to the responseplans necessary to ensure the highest level of preparedness.1-1 August 2002Participation in PREPPlan holders are required to meet the pollution response exerciserequirements mandated by the federal agency with regulatory oversight for thespecific type of industry involved (e.g., vessels, marine transportation-relatedfacilities, onshore and certain offshorenon transportation-related facilities,pipelines, offshore facilities). ThePREP satisfies these requirements.ThePREP is a voluntary program. Plan holders are not required to follow thePREP guidelines and, if they choose notto, may develop their own exerciseprogram that complies with the regulatory exercise requirements.All plan holders, whether participating in the PREP or following theexercise mandates of relevant agencyregulations, will be subject togovernment -initiated unannounced exercises. Unannounced exercisesare mandated by OPA 90. These exercises are further described in theseguidelines.ApplicabilityThe PREP is applicable to all industry response plan holders who elect tofollow these guidelines. Area Contingency Plan holders are required to followthe PREP guidelines.Industry plan holders electing not to adoptthe PREP as their exercise programwill be responsible for developing and documenting an exercise program thatsatisfies the appropriate federal oversight agency.If an industry plan holder has developed one response plan that covers a fleetof vessels or regional operations of offshore platforms, this plan holder wouldonly be required to conduct one "set" of exercises for the plan, with theexception of the qualified individualnotification exercises and the emergencyprocedures exercises, which are required for allmanned vessels andunmanned barges (as specified in 33 CFR155.101 5).Effective DateTHE PREP GUIDELINESBECAME EFFECTIVE JANUARY 1,1994. THEPREP FOLLOWS THE CALENDARYEAR - THE EXERCISE YEAR ISJANUARY 1 TO DECEMBER 31.DefinitionsArea- That geographic area for which a separate and distinct AreaContingency Plan has been prepared, as described in the Oil Pollution Act of1990. For EPA Areas with sub - area plans or annexes tothe AreaContingency Plan, the EPA Regional Administrator shall decide which subarea plan is to be exercised within the triennial cycle.Area Committee-Area Committees are those committees comprisedof federal, state and local officials, formed in accordance with section 4202 ofthe Oil Pollution Act of 1990, whosetask is to prepare an Area ContingencyPlan for the area for response to a discharge of oil or hazardous substance.Area Spill Management Team-The Area Spill Management Team isthe group of individuals within the Coast Guard or EPA On-Scene Coordinatororganization with responsibility for spill response management within therespective area. The Area Spill Management Team should include state andlocal personnel whenever possible.Barge Custodian-A barge custodian is the individual that hascustody of an unmanned barge. The barge custodian may be affiliated withthe towing vessel, fleeting area or facility at which the barge may be moored.The custodian can be the towing vessel operator, the facility operator, the fleetoperator, or whoever may be in charge ofthe entity that has custody of thebarge.Certification-Certification is the act ofconfirming that an exercise(1) was completed; (2) was conducted in accordance with the PREPguidelines, meeting all objectives listed; and (3) was evaluated using amechanism that appraised the effectiveness of the response or contingencyplan.Complex-A complex is a facility regulated under section 311 (j) ofthe Federal Water Pollution Control Act[33 U.S.C. 1321 (j)] by two or morefederal agencies.Equipment deployment exercise-An equipment deploymentexercise is an exercise where response equipment is deployed to a specificsite and operated in its normal operating medium.Equipment activation-Equipment activation is the movement,staging, deployment or operation of response equipment, as determined by theplan holder in consultation with the exercise design team.Exercise Design Team-This team is comprised of federal, state andindustry representatives who haveresponsibility for designing an AreaExercise.1-2 August 20021-3 August 2002Hazardous Substance-For the purposes of PREP Section 3, thechemicals for which plan holders are required to prepare response plans bythe Coast Guard under 33 CFR 154, 155 .Hazardous Substance Response Organization (HSRO)-For thepurposes of PREP Section 3, HSRO refers to companies involved withhazardous substance response, removal,and remediation. This acronymdoes not suggest the same classification standards that are required byOSROs.Industry-For the purpose of these guidelines, industry means thevessels, marine transportation-related (MTR) facilities, onshore and certainoffshore non - transportation-related facilities, pipelines, and Outer ContinentalShelf platforms for which response plansfor oil spill response are required tobe submitted by owners or operators.The response plan requirements andregulations for these entities are administered by the Coast Guard, EPA,RSPA, and MMS.National Response System-Under 40 CFR part 300 (The NationalOil and Hazardous Substances Pollution Contingency Plan), the NationalResponse System (NRS) includes the National Response Team, RegionalResponse Teams, Area Committees, On-Scene Coordinators, and state andlocal government entities involved with response planning and coordination.The PREP, consistent with OPA 90 objectives, specifically involves the privatesector with the NRS in order toensure effective exercise development,delivery and coordination.Oil Spill Removal Organization (OSRO) -An oil spill removalorganization is an entity that provides response resources. An oil spill removalorganization includes, but is not limited to, any for-profit or not-for-profitcontractor, cooperative, or in-houseresponse resources established in ageographic area to provide required response resources.On-Scene Coordinator (OSC) -The On-Scene Coordinator is thefederal official predesignated by EPA or the USCG prior to an oil spill tocoordinate and direct federal responses under subpart D of the NationalContingency Plan, or the official designated by the lead agency to coordinateand direct removal actions under subpartE of the National Contingency Plan.Operating Environments-For the purposes of PREP, there arethree types of operating environments [33 CFR 154, 33 CFR 155, 40 CFR112]:♦River and canals♦Great Lakes/ Inland♦Ocean (nearshore, offshore, and open ocean)If an OSRO operates in all three environments, the OSRO is required toconduct an exercise of the minimumamount of equipment in each of theenvironments. If the OSRO only operatesin two of the environments, it mustconduct the exercises in the two environments.Plan Holder-The plan holder is the industry (e.g., vessels, MTRfacilities, onshore and certain offshorenon-transportation-related facilities,pipelines, or offshore facilities) for which a response plan is required by federalregulation to be submitted by a vesselor facility's owner or operator. If anowner or operator is authorized to prepare one plan for a fleet of vessels, thatowner or operator is considered to be the plan holder.Planning Volumes for Oil:1. Average Most Probable (USCG) / Small (EPA) Discharge: -Thisdefinition is agency-dependent, and the appropriate definitions are detailedas follows:♦For Coast Guard-regulated vessels, a discharge of 50barrels [2,100 gallons] of oil from the vessel during oiltransfer operations [33 CFR 155.1020].♦For Coast Guard-regulated facilities, a discharge of the lesserof 50 barrels [2,100 gallons] or 1 percent of the volume of theworst-case discharge [33 CFR 154.1020].♦For EPA regulated facilities, a small discharge is a volume of2,100 gallons [50 barrels]or less, provided this amount is lessthan the worst-case discharge [40 CFR 112.20].♦For RSPA - Not applicable♦For MMS - Not applicable2. Maximum Most Probable (USCG) / Medium (EPA) Discharge: -Thisdefinition is agency-dependent, and the appropriate definitions are detailedas follows:1-4 August 20021-5 August 2002♦For Coast Guard-regulated vessels, a discharge of 2,500 barrels[105,000 gallons] of oil for vessels with an oil cargo capacity equalto or greater than 25,000 barrels [1,050,000 gallons], or 10percent of the vessel's oil cargo capacity for vessels with acapacity of less than 25,000 barrels [1,050,000 gallons] [33 CFR155.1020].♦For Coast Guard-regulated facilities, a discharge of the lesser or1,200 barrels [50,400 gallons]or 10 percent of the volume of aworst-case discharge [33 CFR 154.1020].♦For EPA-regulated facilities,a discharge greater than 2,100gallons [50 barrels] and less than or equal to 36,000 gallons [858barrels] or 10 percent of the capacity of the largest tank at thefacility, whichever is less [40 CFR 112.20].♦For RSPA-Not applicable.♦For MMS-Not applicable.*Although this type of spill is not included as a spill to be used inany of the exercises, the definition is included to remind theprogram participants that this spill type is included in theplanning process and can be used when conducting the variousexercises.3. Worst Case Discharge-This definition is agency-dependent, and theappropriate definitions are detailed as follows:♦For Coast Guard-regulated vessels, a discharge in adverseweather conditions of a vessel's entire cargo as defined in 33 CFR155.1020.♦For Coast Guard-regulated facilities, the size of the discharge asdefined in 33 CFR 154.1020 (in the case of an onshore facility anddeepwater port, the largest foreseeable discharge in adverseweather conditions meetingthe requirements of 33 CFR154.1029).♦For EPA-regulated facilities, the sizeof the discharge described in40 CFR 112.20.♦For RSPA-regulated pipelines, the size of the discharge as definedin applicable regulations [49 CFR 194].♦For MMS-regulated offshore facilities,the size of the discharge asdefined in applicable regulations [30 CFR 254].♦For Areas, the size of the discharge as defined in the AreaContingency Plan.♦For complexes regulated by more than one federal agency, thelargest of the worst-case discharges calculated for the variousregulated components.♦Planning Volumes for HAZSUB – Applies to Section 3 only.4. Worst Case Discharge (vessel)- means a discharge of a vessel’s entirehazardous substance cargo during adverse weather conditions [33 CFR155. 3030].In addition, planning contingencies should also anticipatesituations where a vessel does notlose the entire cargo but theconsequences of the release present asignificant and substantial risk tohuman health or the environment. Furthermore, a company must beprepared to respond to any individual chemical it is authorized to carry.5. Worst Case Discharge (Coast Guard-regulated facility)– means adischarge of the entire volume of the largest hazardous substance cargoline (including the content of anyassociated breakout tanks) measuredfrom the transfer manifold on the dock to the first valve inside thesecondary containment of the facility.Personal Protective Equipment- equipment that meets therequirements contained in OSHA Hazardous Waste Regulations 29 CFR1910.120.Primary Oversight Agency-The primary oversight agency is theagency with regulatory authority over a particular industry. For the purposes ofthe PREP, the four primary oversightagencies and the industries they regulateare the U.S. Coast Guard (vessels,MTR facilities), the EnvironmentalProtection Agency (onshore and certain offshore non transportation-relatedfacilities), the Research and Special Programs Administration (pipelines), andthe Minerals Management Service (offshore facilities).Qualified Individual-A qualified individual is the person located inthe United States who meets the requirements identified in the respectivefederal regulations (USCG, EPA, RSPA, MMS), and who is authorized to do1-7 August 20021-6 August 2002the following: (1) activate and engage in contracting with oil spill removalorganizations; (2) act as a liaison with the On-Scene Coordinator; and (3)obligate funds required to effectuate response activities. The qualifiedindividual will be the individual or a designee identified in the response plan.Self-Certification-Self-certification is where the plan holder declareshe or she has met the following standards: (1) completion of the exercise; (2)conducting of the exercise in accordance with the PREP guidelines, meetingall objectives listed; and (3) evaluation ofthe exercise using a mechanism thatappraises the effectiveness of the response or contingency plan.Self-Evaluation-Self-evaluation means that the plan holder isresponsible for carefully examining the effectiveness of the plan for responseduring the exercise. The plan holder may choose the mechanism forconducting this appraisal, as long asit appropriately measures the planeffectiveness. The plan holder is responsible for addressing issues that arisein the exercise that would lead to improvements in the response plan or anyaspect of preparedness for spill response.The plan holder is responsible forincorporating necessary changes to the response plan as a result of theexercise.Spill Management Team-The spill management team is the group ofpersonnel identified to staff the appropriate organizational structure to managespill response implementation in accordance with the response plan.Tabletop Exercise-For the purpose of the PREP, a tabletop exerciseis an exercise of the response planand the spill management team's responseefforts without the actual deployment of response equipment.Timely-(as used in relation to CG and EPA government-initiatedunannounced exercise programs) means the times established in theappropriate response planning regulations issued by the EPA and USCG forproviding response resources to a small or average most probable spill.Unified Command-This entity is a command structure consisting ofthe On-Scene Coordinator, the State, the Responsible Party and other partiesas appropriate. The Unified Command isutilized during a spill response toachieve the coordination necessary tocarry out an effective and efficientresponse.Verification-Verification is the act of ensuring that an exercise wasproperly documented and certified. Verification would be conducted by theCoast Guard, EPA, RSPA, or MMS. Verification of the exercise records maybe conducted through normal operations ofthe regulatory agency, such asinspections, boarding, spot checks,or other systems developed to ensureexercises are being conducted and properly documented.Vessel-For the purpose of the oil spills, a "vessel" is any vesselrequired by 33 CFR 155.1015 to submit aresponse plan. For the purpose ofhazardous substance releases, a “vessel” is any vessel required by 33 CFR155. 3030 to submit a response plan. A "vessel" includes unmanned barges.1-8 August 20021-9 August 2002SECTION2:GUIDINGPRINCIPLESInternal and External ExercisesÆInternal Exercises.Internal exercises are those that areconducted wholly within the plan holdersorganization. While the internal exercises include personnel such as thequalified individual and those affiliatedwith the plan holder’s spill managementteam, OSRO, the internal exercises usually do not involve othermembers of the response community. The internal exercises are designed toexamine the various components of theresponse plan to ensure the plan isadequate to meet the needs of the organization for spill response.TheInternalexercises include --♦Qualified individual notification exercises;♦Emergency procedures exercises for vessels and barges;♦Emergency procedures exercises for facilities (optional);♦Spill management team tabletop exercises; and♦Equipment deployment exercises.All internal exercises should beself-evaluatedandself-certified.ÆExternal Exercises.External exercises are exercises thatextend beyond the internal focus of theplan holder's organization, and involve other members of the responsecommunity. The external exercisesare designed to examine the responseplan and the plan holder's ability to coordinate with the response community toconduct an effective response to a pollution incident.Theexternalexercises include--♦Area exercises; and♦Government-initiated unannounced exercises.While the government-initiated unannounced exercises will not usuallyinvolve all members of the response community, the involvement of an agencyoutside of the plan holders’ organization places it in the category of an externalexercise.Qualified Individual Notification ExercisesThe purpose of the qualified individual notification exercise is to ensure thatthe qualified individual (or designee, asdesignated in the response plan) isable to be reached in a spill response emergency to carry out his or herrequired duties. Contact by telephone,radio, message-pager, or facsimilemust be made with the qualified individual, and confirmation must be receivedfrom him or her to satisfy the requirements of this exercise.The qualified individual notification exercise is not intended to verify phonenumbers, points of contact or the notification list contained in the plan. Theplan holder is expected to update the notification list periodically(recommended at least once every 6 months) as part of the normal course ofconducting business.At least once a year, the qualified individual notification exercise should beconducted during non-business hours.ÆVessels.For vessels, it is the responsibility ofthe plan holder to ensure that thequalified individual notification exerciseis conducted. If a plan holder has afleet of vessels covered by one response plan, the plan holder must ensurethat eachvessel in the fleet conducts this exercise.For vessels, a telex will be acceptable, but the baseline should be voicecommunication. If a telex is used forthis exercise, confirmation from thequalified individual must be received to properly satisfy the requirements of thisexercise.ÆUnmanned Barges.For unmanned barges, it is the responsibility of the plan holder to ensure thatthe qualified individual notification exercise is conducted. If a plan holder hasa fleet of unmanned barges covered by one response plan, during eachquarter the plan holder should randomly choose a barge in the fleet to conductthe qualified individual notification exercise.*The plan holder should have thebarge custodian of the chosen barge conduct the exercise. The plan holdershould choose the barges and the variouscustodians randomly. This method2-1 August 20022-2 August 2002will ensure that all barges and custodians are ultimately included in theexercises.*To require each unmanned barge in a fleet to conduct this exercisequarterly would be extremely difficult and unwieldy to manage.Emergency Procedures ExercisesThe purpose of the emergency proceduresexercises is to ensure thatpersonnel are capable of conducting the initial actions necessary to mitigatethe effects of a spill.ÆVessels.For vessels, it is the responsibility ofthe plan holder to ensure that theemergency procedures exerciseis conducted. If a plan holder has a fleet ofvessels covered by one response plan,the plan holder must ensure that eachvessel in the fleet conducts this exercise. Since vessels do not always sailwith the same crews, it is important that eachvessel conducts this exercisequarterly to ensure that the personnel on board are familiar with theprocedures for mitigating a spill occurring from that vessel.ÆUnmanned barges.For unmanned barges, it is the responsibility of the plan holder to ensure theemergency procedures exercise is conducted.*To require each unmanned barge in a fleet to conduct this exercisequarterly would be extremely difficult and unwieldy to manage.If a plan holder has a fleet of unmanned barges covered by one response plan,during each quarter the plan holder should randomly choose a barge in thefleet to conduct the emergency procedures exercise.The plan holder shouldhave the barge custodian of the chosenbarge conduct the exercise. The planholder should choose the barges and the various custodians randomly toensure that all barges and custodians will ultimately be included in theexercises.ÆFacilities (optional).Facilities have the option of conductingemergency procedures exercises. Forthe purpose of the PREP, emergencyprocedures for facilities are theprocedures established at the facility to mitigate or prevent any discharge or asubstantial threat of such discharge ofoil resulting from facility operationalactivities associated with cargo transfers . An emergency procedures exerciseconducted unannounced would satisfy the facility's requirement for the annualunannounced exercise.Spill Management Team Tabletop ExercisesThe response plan holder must identify a spill management team in theresponse plan. This spill management team shall conduct an annual tabletopexercise, in accordance with the PREP guidelines. The response plan mustbe utilized in the exercise to ensure the spill management team is familiar withthe plan and is able to use it effectively to conduct a spill response. At leastone spill management team tabletop exercisein a triennial cycle shall involve aworst-case discharge scenario.If a response plan lists different typesof spill management teams for varyingsizes of spills - for example a local spill management team for small spills, aregional team for larger spills, and a national team for major spills-each teamidentified would be required to conduct an annual spill management teamtabletop exercise.ÆExamples of Variations in Spill Management Team Organizations.If an organization has one national spill management team identified for allplans within the organization, thatspill management team would only have toconduct one spill management team tabletopexercise annually, as long as theTTX addresses individual responses tospill scenarios for all type of industryplan holders covered by the SMT, i.e. vessels, facilities, pipelines and offshorefacilities. For the annual spill managementteam tabletop exercise, the spillmanagement team may use core response management procedures thatwould cover all plan holders, but the SMT must ensure it is familiar with eachresponse plan for the vessels, facilities,pipelines and offshore facilities forwhich they are responsible, including the specific spill scenarios identified ineach of the plans as well as the specific operations of each of the vessels,facilities, pipelines and offshore facilities.All plan holders that cite this nationalteam in their response plans shouldtake credit for this exercise.Likewise, if regional spill management teams are set up within theorganization, each regional team would only have to conduct one spillmanagement team tabletop exercise annually, as long as the TTX addressesindividual responses to spill scenariosfor all types of industry plan holderscovered by the SMT, i.e. vessels, facilities, pipelines and offshore facilities.The spill management team may utilize core response managementprocedures that would cover all planholders, but the spill management teammust ensure it is familiar with eachresponse plan for which they are2-3 August 20022-4 August 2002responsible, including the specific spill scenarios identified in each of the plansas well as the specific operations andunique characteristics of each of thevessels, facilities, pipelines and offshore facilities. All plan holders that cite thisregional team in their response plansshould take credit for this exercise.If a plan holder uses a core spill management team to handle most spills andadds personnel to the team as the size ofthe spill increases, either locally orfrom regional locations, the entire expanded spill management team must beexercised annually.The spill management team tabletop exercises should take into account shiftchanges to ensure that all personnel serving as part of the spill managementteam during an actual spill have participated in an exercise.If a plan holder cites a spill management team that is not part of the planholder's organization, i.e. "SMT for hire", that spill management team wouldonly be required to conduct one spill management team tabletop exerciseannually, as long as the TTX addresses individual responses to spill scenariosfor all types of industry plan holders covered by the SMT, i.e. vessels, facilities,pipelines and offshore facilities. One ormore representatives from each planholder organization that the spillmanagement team represents mustparticipate in the exercise. During the spill management team tabletopexercise, the spill management teammust utilize each response plan toensure familiarity with the spill scenariosidentified in each of the plans as wellas the specific operations of each vessel,facility, pipeline, and offshore facilitythe spill management team represents.The spill management team must alsowork with each plan holder representative to ensure the spill managementteam is able to incorporate the response management operations into the planholder's organization during spill response. The spill management teamshould provide all plan holders with documentation upon completion of the spillmanagement team tabletop exercise, andeach plan holder should take creditfor the exercise.ÆVessels.For vessels, if a plan holder has one response plan for a fleet of vessels andcites the same spill management team for more than one or all of the plans,the spill management team would only have to conduct one spill managementteam tabletop exercise annually, as longas the core response plan is used inthe exercise and the spill management team demonstrates knowledge of thegeographic specific annexes of the vesselsduring the exercise. All vessel planholders in the fleet citing this spill management team should take credit for theannual exercise.ÆPipelines.For pipelines, the spill emergency response team is the spill managementteam.Equipment Deployment ExercisesThe equipment deployment exercise applies to all plan holders. It is theresponsibility of the plan holderto ensure that the Equipment DeploymentExercise requirement is met.The two primary requirements for theequipment deployment exercise are:1. The personnel that would normally operate or supervise theoperation of the response equipment must participate in the exercise.The personnel must demonstrate their ability to deploy and operate theequipment, while wearing appropriate personal protective equipment. Allpersonnel involved in equipmentdeployment and equipment operatorsmust be involved in a training program.2. The response equipment must be in good operating condition.The equipment must be appropriate for the intended-operatingenvironment. The equipment must operate during the exercise. Allresponse equipment must be included in a maintenance program.Although not required as part of the equipment deployment exercises, planholders are encouraged to use these exercises as an opportunity to validateresponse strategies detailed in response/contingency plans for the geographicarea where the exercise is being conducted.A plan holder is responsible for ensuringexercise of all equipment types citedin the plan whether plan holder owned or provided through an OSRO.The purpose of the equipment deploymentexercise is to validate that theequipment is appropriate for the operating environment in which it is intendedto be used and that operating personnel are trained and capable of itsdeployment and operation. Thus it is notnecessary to deploy every piece ofeach type of equipment as long as all equipment is included in a periodicinspection and maintenance program intended to ensure the equipmentremains in good working order. However, all operating personnel mustparticipate in exercises or responseson an annual basis in order to ensurethey remain trained and qualified tooperate equipment in the operatingenvironment.2-5 August 20022-6 August 2002Note that the CG applies the same standards to HSRO owned equipmentdeployment exercises as described below for OSROs.ÆOSRO Involvement in Equipment Deployment Exercises.The PREP guidelines identify the minimum amount of equipment that must bedeployed in an equipment deployment exercise. This amount is considered tobe a representative sample of the equipment. The rationale for this approachis that if the representative sample works, then the rest of the equipment couldbe expected to work since it wouldbe part of the company's maintenanceprogram. For the personnel, if a representative sample of the OSRO‘spersonnel are involved in the deployment exercise and handle theirresponsibilities effectively, the restof the personnel could be expected to beknowledgeable and effective since theywould be a part of the company'straining program.When selecting the equipment and personnel for theexercise, theOSROshould ensure that the same equipment and personnelare not used repeatedly for each exercise. The equipment should be selectedon a rotational basis, as with the personnel, with the ultimate goal of eventuallyexercising all of theOSRO’sequipment and personnel.If an OSRO has separate field response facilities located throughout thecountry in areas that do not lend themselves to regional consolidation, eachstaffed field response facility, for the purpose of the PREP, will be considereda separate OSRO and will be required to conduct an annual equipmentdeployment exercise of the minimum amount of equipment specified in the inthe PREP.In both cases, if the OSRO is classified to deploy equipment to more than onetype of operating environment, the OSROmust conduct a deployment exercisein each of the environments.A few of the larger OSROs have small field response facilities. A fieldresponse facility is defined as a location where personnel and equipment arestaged. Some of these OSROs have divided their operations into regionalresponse facilities. In some instances,a regional facility will be responsible forseveral small field response facilities or equipment stockpiles. For the purposeof the equipment deploymentexercises under the PREP,each regionalfacilitywill be considered a separate OSROand will be required to conduct anannual equipment deployment exercise ofthe minimum amount of equipmentspecified in the PREP. The OSRO regional facility would be responsible forcoordinating resources from all field facilities within the region for the exercise.In such instances, equipment may be drawn from one or more field facilities,but personnelfrom eachfield facility must participate in the equipmentdeployment exercise. If the OSRO operates using regional facilities, theOSRO will be responsible for defining its regional boundaries and providinginformation to its plan holders. Generally, however regions should bereasonable in geographic size. At a minimum, plan holders must ensure theirOSRO(s) conduct annual equipment deployment exercises in each operatingenvironment in which they expect to operate for each CG District or RegionalResponse Team Regions and EPA AreaContingency Planning area, or EPAsub-area (where identified), unless adjoining areas or sub-areas authorize analternative. For example, if an OSROis located in the First CG District, andprovides response assets to the FifthCG District as well those two mightmutually agree to allow the OSRO to conduct fewer exercises due to similarityof operating environments in those areas and opportunity to observe theexercises. The OSRO should request thisconsideration in writing from theappropriate Contingency Planning Area and sub-area.If the OSRO is cited in a response plan outside of its normal equipmentstaging and operating areas (i.e. as a Tier 2 responder), the plan holder citingthat OSRO must ensure that the OSROhas the local knowledge relevant to aneffective, efficient response in theplan holder's operating area. The planholder must describe arrangements for providing the OSRO with informationsuch as equipment launching locations,tides and currents of the local area,and any other logistical problems or information specific to the particular area.The OSRO should provide documentation of completion of the exerciserequirements to each plan holder covered by that OSRO. It is the planholder's responsibility to ensure thatthe OSRO has completed the equipmentdeployment exercise requirements and has obtained the necessarydocumentation. All plan holders identifying an OSRO in their response plansas providing response resources should take and document their credit forcompleting the equipment deploymentexercise requirements oncedocumentation is received from the OSRO. All plan holders must rememberthat merely citing an OSRO in their response plan is not sufficient to ensurecredit for the equipment deployment exercise.ÆCooperatives (Co-ops).For co-ops that are comprised of severalOSROs,each separate OSROthatmakes up the co-op would be required to conduct an annualequipmentdeployment exercise of the minimum amount of equipmentlisted below.For co-ops that are comprised of facility equipment and personnel pooledtogether,for the purposed of the PREP, this type of co-op is consideredan OSROand would be required to conduct the equipment deploymentexercise as outlined in the OSRO section.This co-op, which is formed by a2-7 August 20022-8 August 2002number of facilities pooling their response equipment and personnel together,would be required to conduct an equipment deployment exercise of theminimum amount of equipmentlisted below annually. Each facility and thepersonnel will not have to conduct the exercise individually. The co-op as awhole would conduct oneequipment deployment exercise per year.Representatives from all of the facilities comprising this co-op must participatein this exercise.Co-op personnel that are responsiblefor deploying the response equipmentmust be involved in a training program,which prepares them for operating theresponse equipment. Likewise, the Co-op must have a maintenance programfor all of the response equipment.ÆVessel and Facility Plan Holder Owned and Operated Equipment.Plan holder owned and operated equipment isthat equipment owned by a planholder and operated either by the plan holder’s own personnel or otherpersonnel hired by the plan holderto operate this equipment. Whoeveroperates this equipment must be involved in the equipment deploymentexercises.Plan holders that have plan holderowned and operated equipment, and havethis equipment identified in their response plan for spill response, would berequired to deploy this equipment twice a year (semiannually). The planholder would be required to deploy the minimum amount of equipment fordeployment specified below or the total amount of equipment that plan holderhas available for response, whichever is less. The requirement for semiannualequipment deployment is based on the factthat this equipment is not deployedroutinely and that the personnel operatingit do not do this as a part of thevessel’s or facility's normal operations. The semiannual requirement isnecessary to ensure adequate preparedness for spill response.The plan holder’s personnel responsible for deploying the response equipmentmust be involved in a training program which prepares them for operating theresponse equipment. Likewise, the vessel/facility plan holder must have amaintenance program for all of the response equipment.ÆPlan Holders Using a Combination of OSRO Equipment and PlanHolder Owned and Operated EquipmentPlan holders citing bothOSRO equipment and their own equipment in theirresponse plans would be required to exercise both types of equipment at theabove described intervals.ÆMinimum Amount of Equipment to beDeployed in Internal EquipmentDeployment Exercises.I. Hazardous Substance Incident Assessment Equipment used in the initialassessment and response to hazardous substance releases. Note that thistype of equipment is not required by regulation for oil spill response.a) Monitoring- Air, surface and subsurface plume monitoring equipment.b) Personal Protective Equipment-Protective clothing, protectivebreathing apparatus appropriate toprotecting responders in theenvironments to which they might be exposed in responding to areleasec) Technical Equipment - Used for trajectory analysis.ÆOil and Hazardous Substance Response Systems.A) Mechanical - Skimming/Recovery Systems - One of each type ofSkimming System as listed in the plan. A Skimming System includescontainment boom, hoses, piping, pumps,prime movers, support vessels, etc.necessary for the effectiveoperation of that system.Types of Skimming/Recovery Systems include:•Oleophilic - Brush•Oleophilic - DiscOleophilic - Paddle Belt•Oleophilic - Rope Mop•Oleophilic - Sorbent Lifting Belt•Oleophilic - Submersion Belt•Oleophilic - Submersion Plane•Suction ( including vacuum trucks)•Weir•Advancing Weir2-9 August 20022-10 August 2002•Special Purpose skimmers (e.g. fast water)B) In-Situ Burn Systems – Each ISB package listed in the plan andrelied on by the plan holder in meeting response equipment capabilityrequirements - including boom, method of ignition, support vessels andsmoke plume monitoring equipment. Deployment or use of in situburning should not occur during theexercise unless directed by theFederal On-Scene Coordinator.C) Dispersant Systems – Each dispersant package listed in the planandrelied on by the plan holder in meeting response equipmentcapability requirements , includingdispersant delivery vehicles,application equipment, and dispersed oil plume monitoring equipment.Deployment or use of the actual dispersant should not occur during theexercise unless directed by the Federal On-Scene Coordinator.II.Booming Systems (includes protective and containment boom notexercised as part of a skimming orin-situ burning system describedabove) 1,000 feet (or total amount ofboom listed in plan, whichever isless) of each protective or containment boom system listed in the planandrelied on by the plan holder in meeting response equipmentcapability requirements. Protectiveboom systems (boom and means ofdeploying and anchoring) include the following types:•Fence Boom•Curtain Boom: internal foam; external foam, self-inflatable andpressure inflatable.•External Tension Boom•Tidal Seal Boom(Only 50 feet of this type of boom need bedeployed.)•Special Purpose•-Ice Booms*Fast Water Booms (Equipment and/or techniques intended to improvespill containment, control in fast water situations).ÆArea Equipment Deployment. (Oil only).The area equipment deployment exerciseinvolves Coast Guard and EPA "firstaid" response equipment and the CoastGuard's prepositioned equipment. Allof the "first aid" equipment or that which is necessary to respond to an averagemost probable discharge in the area, whichever is less, would be deployedannually.Internal Unannounced ExercisesTHIS IS NOT A SEPARATE EXERCISE. THIS SECTION OUTLINES THEREQUIREMENT THAT ONE OFTHE PREP EXERCISES USED BELOWMUST BE CONDUCTED UNANNOUNCED.Annually, each plan holder should ensure that one of the following exercises isconducted unannounced:♦Emergency procedures exercise for vessels and barges;♦Emergency procedures exercisefor facilities (optional);♦Spill management team tabletop exercise; or♦Equipment deployment exercise.An unannounced exercise is where the exercise participants do not have priorknowledge of the exercise, as would be the situation in an actual spill incident.To ensure that the nation maintains an adequate posture for responsepreparedness, and to satisfy the OPA 90 requirement for unannouncedexercises, it is necessary to have an exercise program, which is comprised ofboth announced and unannounced exercises.The requirement for the annualunannounced exercise is necessary to maintain the level of preparednessnecessary to effectively respond to a spill.Response to an actual spill shouldbe taken as credit for the unannouncedexercise requirement, ifthe response was evaluated.The emergency procedures exercise is being offered as an option for facilities,to provide an additional exercise that may be conducted unannounced.2-12 August 20022-11 August 2002Government-Initiated Unannounced ExercisesThe government-initiated unannounced exercises are designed to give theagency with primary regulatory oversight over a particular industry theopportunity to evaluate, on a random basis, the response preparedness of thatindustry. The PREP has attempted to make this requirement as reasonable aspossible. The frequency of these drillsfor the noted Agencies are as follows:♦For Coast Guard regulated vessels and facilities, the government -initiated unannounced exercises are limited to four per area per year.♦For EPA-regulated facilities,the government-initiated unannouncedexercises are limited to 10% of the plan holders per EPA region peryear.♦For RSPA-regulated pipelines,the government-initiated unannouncedexercises are limited to 20annually across the nation.♦For MMS-regulated offshore facilities, the number of governmentinitiated unannounced exercises are determined by the RegionalSupervisor and may exceed 50 per yearnationally. A facility will notface an MMS unannounced exercise more than once per year, unlessthe results of previous exercisesindicate that follow-up drills arewarranted due to poor performance during a drill.A plan holder directed to participate in a government-initiated unannouncedexercise is required to participate asdirected unless specific conditions existthat may result in safety hazards.The cost of the unannounced exercise willbe borne by the response plan holder.For complex facilities that are regulatedby two or more agencies, it is theresponsibility of the exercising agency tonotify and invite the participation ofthe other agency and the responsible On-Scene Coordinator in advance, so asto minimize the possibility of the facility being exercised multiple times during acompressed time period.A plan holder that has successfullycompleted a government-initiatedunannounced exercise would not be required to participate in another Federalgovernment - initiated unannounced exercisefor at least 36 months from thetime of the last exercise providedthat the drill protocols and method ofevaluation are equivalent. The plan holder must maintain documentation ofthis participation.Guidelines for determining successful completion of an exercise and fordetermining enforcement actions (including but not limited to civil penalties) foran unsuccessful exercise are the responsibility of the individual oversightagencies, based on application of their individual agency regulations.ÆSuccessful Completion of Government-Initiated UnannouncedExercises.A government-initiated unannounced exercisemust be successfully completedas determined by the initiating authority.Failure to successfully complete anexercise indicates that either the plan holder could not properly implement itsresponse plan, that the response resources were not available or not inoperating condition, or that responsepersonnel were not adequately trained inimplementing the response plan. Theseare all causes for corrective actionthat may include but is not limited to additional unannounced exercises andrevisions to the submitted response plan.For an exercise to be successful it isintuitive that it must meet the Scope andObjectives of the exercise element. Itis the responsibility of the agency withoversight of the regulated entity todevelop specific guidelines for determining the successful completion of anexercise and for determining appropriateenforcement actions (including butnot limited to civil penalties) for an unsuccessful exercise.One of the objectives for successful completion of an exercise is the conceptof demonstrating that the response can be conducted in a timely manner.Note that the connotation of timely remains a planning rather than aperformance standard. Timely isdefinedin Section 1 of these guidelines andis further discussed in specific portionsof the Guiding Principles and in thosesections of the Guidelines which address specific exercise elements forvessels and facilities.Marine Transportation-Related Facilities and Vessels Regulated by theU.S. Coast Guard.Coast Guard personnel conducting USCG-initiated unannounced exercises willbe guided by the following concepts whendetermining success of an exercise.Keeping in mind that response time frames in the regulations are planningstandards and not performance standards,and that the government initiatedunannounced exercise program focuses on average most probabledischarges, successful completion cannotbe determined by a stopwatch, butby subjective evaluation of avariety of factors including:1. Response resources located within 17-mile radius of transfer site(boom - 1 hour response time over the road given half hour formobilization) and 52-mile radius oftransfer site (recovery equipment -2-13 August 20022-14 August 20022 hour response time over the road given half hour for mobilization) ifresponse personnel are standing bywith the equipment during anyplan holder transfer operation.2.For lightering, bunkering etc, on water, Response resources locatedwithin 2.5 nautical mile radius oftransfer site (boom - 1 hour responsetime over the road given half hour for mobilization) and 7.5 nauticalmile radius of transfer site (recovery equipment - 2 hour response timeover the road given half hour for mobilization) if response personnelare standing by with the equipment during any plan holder transferoperation.3. Personnel to operate the equipmentneed not be co-located with theequipment, as long as those personnel are located within the sameresponse radii and personnel neededto mobilize and transport theequipment are co-located with the equipment.4. If plan holder notifies and orders OSRO equipment quickly and theOSRO demonstrates it’s capability to mobilize the equipmentimmediately then the precise time the equipment arrives on scene isnot important. USCG exercise personnel may opt to send a team tothe OSRO site to observe mobilization as part of the exercise. (E.g.,Boom is 7 miles away from transfer site - at 35 miles per hour thatboom can be on scene in 12 minutes, so if notification and mobilizationcan be completed in 45 minutes, it is reasonable to assume that theboom will be on scene in less than one hour. If boom is 17 miles awaynotification and mobilization must becompleted in 30 minutes. If it is28 miles away, mobilization must be complete in 15 minutes, and soon.).5.Under the above circumstances isdoes not matter how soon theequipment and personnel arrive on scene because any delay canreasonably be presumed to have been caused by the instantconditions rather than the average conditions on which the planningtravel times are based.6. Once the equipment is delivered on scene, personnel should be ableto deploy and operate the equipmentwithout significant difficulty(people should generally be aware of locations of equipment launchsites, anchoring points and deployment strategies.) However,because specific conditions vary atevery site, deployments are notlikely to be entirely seamless and deployment personnel may need tomake adjustments that will delay completion of deployment. In fact,the ability to adjust to these differing environmental conditions may bean indicator of the competence of response personnel.7. While it is intended that equipment be in the water and operationalbefore the end of 4-hour exerciseperiod, there are circumstances,particularly related to safety and non-interference with actualoperations that may delay completion of deployment beyond that time.In such a case, exercise should continue until equipment is deployedand operated satisfactorily.ÆNon-transportation-Related Facilities Regulated by the EnvironmentalProtection Agency.The measure of an effective unannouncedgovernment-initiated exercise willbe the overall ability of the responders identified in the facility response plan torapidly and effectively control a small discharge with particular attention tothose actions that afford the best chances to control a spill and minimize itsimpact in the first few hours of the incident. While recognizing that an effectiveresponse to an oil discharge entails the rapid deployment of proper equipment,it is not the intention of the EPA touse timeliness as the sole factor whenevaluating the response to a government-initiated unannounced exercise for asmall discharge. EPA personnel will evaluate whether the responseequipment specified in the response plan arrives at the specified times. Thesetimes are listed in the response plan and are based on the response planningrequirements in 40 CFR 112 or alternative response times when approved bythe Regional Administrator. Whetherthe containment boom and recoverydevices specified in the response plan arrive precisely at the specified times isless relevant than the overall conductof the exercise and the successfulachievement of the exercise objectivedescribed in PREP. The objective of agovernment-initiated unannounced exercisefor a small discharge includes thefollowing sub-objectives:♦Conducting proper notifications;♦Arrival of containment boomas specified in the approvedresponse plan within one hour of detection of the discharge andthe subsequent successful deployment;♦Arrival of oil recovery devicesas specified in the approvedresponse plan within two hours of detection of the discharge andthe subsequent successful operation/simulated recovery;2-15 August 20022-16 August 2002♦Demonstrating the availability of adequate storage capacity forrecovered oil; and♦Properly conducting the exercise considering the size of a smalldischarge including skill and competency of responders andmaterial readiness of response equipment.The failure to achieve any one sub-objective should not automatically indicatethat an exercise is a failure. EPA personnel evaluating the exercise shouldassess: the plan holders ability to conduct proper notifications; materialreadiness of response equipment; and the overall ability of respondingpersonnel to mobilize, arrive on scene ina timely manner, properly deploy thecontainment boom, simulate recovery of oil, and demonstrate skill andcompetency during the 4 hour exercise window.The EPA exercise evaluator will have a subjective role in determining thesuccess of the exercise based on the achievement of the exercise objectiveswithin the specific time. Theseevaluations will be dependent on spill site andcircumstances. EPA personnel may requestto review records of previousfacility response plan exercises when thereis a concern that the response timeis excessive. As the result of an unsuccessful exercise the EPA may requirethe plan holder to participate in additional unannounced exercises, revise theexisting response plan, or both.Unsuccessful unannounced exercises mayalso result in enforcement action against the plan holder.ÆSafety During Exercises and Responses.The responsibility for safely conductingan exercise or an actual responseremains with the plan holder and responding personnel. The response planshould comply with all the regulatoryrequirements while considering safetyfactors. Plan holders and responders are never expected to operate in anunsafe or illegal manner during an exercise or actual response. The planholder is responsible to confirm thatthe resources identified in the responseplan can mount an effective response while operating within all applicable lawsand regulations. In short, there is no expectation or justification for placingpeople at risk during an exercise or response. Conducting the exercise in anunsafe manner is likely to contribute to an unsatisfactory exercise.Triennial Exercise of the Entire Response Plan.Every 3 years all components of the entire response plan must be exercised.Rather than requiring each plan holderto conduct a major-exercise every 3years, the PREP allows for the individual components to be exercised inportions through the required exercises.The following are the basic types ofplan components that must be exercisedat least once every 3 years:Organizational Design(1) Notifications(2) Staff mobilization(3) Ability to operate within theresponse management system describedin the planOperational Response(4) Discharge control(5) Assessment of discharge(6) Containment of discharge(7) Recovery of spilled material(8) Protection of sensitive areas(9) Disposal of recovered material and contaminated debrisResponse Support(10) Communications(11) Transportation(12) Personnel support(13) Equipment maintenance and support(14) Procurement(15) DocumentationWhile not all of these componentswould necessarily be contained ineach plan, the plan holder should identify those that are applicable fromthe list above, and add or delete other components as appropriate. Theplan holder would then be responsiblefor ensuring that all components ofthe plan are exercised withineach 3-year exercise cycle.To satisfy the requirement of the triennial exercise of the entire responseplan, it is not necessary to exercisethe entire plan all at one time. Theplan may be exercised in segments overa period of 3 years, as long aseach component of the plan is exercised at least once within the 3-yearperiod. The required exercises should be developed to ensure that eachcomponent is addressed and exercised inthe triennial cycle. Appendix A2-18 August 20022-17 August 2002includes a template for use by plan holders tacking exercise completionover the 3-year PREP cycle.The plan holder is responsible for documenting the componentscompleted in the exercises.ÆTriennial Cycle.In the triennial cycle, the followinginternal exercises must be conducted12 qualified individual notification exercises;12 emergency procedures exercises--manned vessels andunmanned barges (optional for facilities);3 spill management team tabletop exercises--one must involve aworst case discharge scenario;3 unannounced exercises--any of the exercises,with the exceptionof the qualified individual notification exercise, if conductedunannounced, would satisfy this requirement;Equipment deployment exercises as described below:♦For vessel/facility owned and operated equipmento 6 plan holder owned and operated equipment deploymentexercises (for plan holders with vessel/facility owned andoperated equipment identified in their response plan)♦For vessels and facilities with OSROs identified for responseequipmento 3 OSROs equipment deployment exercises♦For pipelines -o 3 pipeline equipment deploymentexercises (using eitherOSRO and/or operator owned equipment♦For offshore facilitieso 3 equipment deployment exercises (for equipment stagedonshore)o 6 equipment deployment exercises (for equipment stagedoffshore); andTriennial Exercise of Entire Response Plan -Each component of theresponse plan must be exercised at least once in the triennial cycle.Area ExercisesThe purpose of the area exercise is toexercise the entire response communityin a particular area. An area is defined as that geographic area for which aseparate and distinct Area Contingency Plan has been prepared, as describedin OPA 90. The response community includes the federal, state and localgovernment and industry. The area exercises are designed to exercise thegovernment and industry interface for spill response.The goal of the PREP is to conduct 20 area exercises per year nationwide, 60within a triennial cycle. This method should ensure that all areas of thecountry are exercised triennially. Six of the 20 annual area exercises would beled by the government, that is the Area Committee, with a single industry planholder as exercise partner. Industryplan holders would lead the other 14 withthe Area Committee as exercise partner.An exercise design team will developall of the area exercises. The exercise design team is comprised ofrepresentatives from the federal, state, and local government agencies, thelocal response community and the industry plan holder. A lead plan holderwould lead each area exercise. The lead plan holder is the organization(government or industry) that is responsible for the primary plan that isexercised in the area exercise. The lead plan holder would have the final wordon designing the scope and scenario of the exercise. The U.S. Coast Guardor the EPA, as Area Committee chair, would be the lead plan holder for the 6government led exercises, with RSPA and MMS participating as appropriate.Asuggestedmix of participants for the industry led area exercises wouldinclude:♦Vessels (6 exercises);♦Marine transportation-related (MTR) facilities (2 exercises);♦Onshore and certain offshore non-transportation-related facilities(2 exercises)♦Pipelines (2 exercises); and2-20 August 20022-19 August 2002♦Offshore facilities (2 exercises).The area exercises do not necessarily have to be large-scale productions.The scenario does not always have toinvolve a worst-case discharge.However at a minimum, the scenario mustinvolve exercise of Tier I WorstCase discharge capability. The primarypurpose of the area exercise is toactivate and observe the response infrastructure in the area, and the ability ofthe entire response community to effectively conduct a spill response. Thefocus should be on the interaction between the responsible party and thefederal, state and local government toexercise both the Area ContingencyPlan and the responsible party's response plan. The following arerecommendations for the area exercises:♦Each exercise should be approximately 8-12 hours in duration.The exercises may be longer, if agreed to by the exercise designteam.♦The area response mechanism would be evaluated in each areaexercise. The unified command would be exercised.♦The lead plan holder will have the primary voice and final decisionauthority in the exercise design.However, exercise design shouldbe conducted as a cooperative effortof the entire exercise designteam.♦The exercise scenario willinvolve some amount of equipmentdeployment. The extent ofequipment deployment should bedetermined by the lead plan holder after consulting with theexercise design team.Area exercise equipment deploymentshould include testing adequacy ofvarious response strategies contained inthe plan, including but not limited to:protective booming for shoreline, fish,wildlife, and sensitive environment; fastwater, open-water, or shallow water containment and collection; or dispersantor in-situ burn operations. If the exercise spill scenario involves a maximummost probable or larger spill, a minimum of tier 1 equipment deploymentshould be conducted.Equipment deployment need not be conducted simultaneously with thetabletop portion of the exercise. It may be done several weeks or even monthsprior to or after the tabletop to allow more efficient allocation of exerciseplanning and execution resources.An Industry plan holder that participates in an Area Exercise would not berequired to participate in another area exercise for a minimum of 6 years.Plan holders are responsible for funding their participation in the areaexercises.An evaluation report should be completed not later than 60 days aftercompletion of the area exercise. The evaluation report is completed by the jointevaluation team. For USCG Area Exercises, results of these joint evaluationswill be entered in CGSAILS.Area Exercise SchedulingScheduling of area exercises will be done under a nationally coordinatedsystem that involves the federal,state and local governments and industryplan holders, and that recognizes the unique needs of specific geographicregions of the country.ÆNSCC.A National Schedule Coordination Committee (NSCC) has been establishedfor scheduling the area exercises. The NSCC is comprised of personnelrepresenting the four federal regulating agencies - the Coast Guard, EPA,RSPA, and MMS.ÆScheduling Process.The NSCC is charged with developing and publishing a proposed areaexercise schedule for each upcoming triennial period. This proposed schedulewill be published in the Federal Registerannually. The reason the exercisesare scheduled three years in advance is to allow both area committees andindustry plan holders to allocate sufficient funds and personnel. The NSCCwill solicit comments on the proposed schedule and industry plan holders tolead and participate in the Area Exercises.It is important to note that theNSCC only proposes which area plans willbe exercised over the three-yearperiod. It is incumbent on the Regional Response Teams and AreaCommittees with jurisdiction over an area, to validate the proposed timeframeand to identify the industry plan holder who will participate in the exercise.Each Regional Response Team and Area Committee should work with thelocal industry to identify industry planholders three years in advance of thescheduled exercise. Industry plan holders may also provide input to thescheduling process through the Area Committees.2-22 August 20022-21 August 2002Other Credit IssuesÆCredit for Spill Response.Plan holders may take credit for internal exercises conducted in response toactual spills. The spill response must be evaluated. The plan holder mustdetermine which exercises were completed in the spill response. Thisdetermination should be based on whether the response effort would meet theobjectives of the exercise as listedin the PREP guidelines. The plan holdermust document the exercises completed.The NSCC is responsible for authorizing credit for area exercises, based onthe recommendations of the On-Scene Coordinator. Credit should be given toa plan holder for participation in an area exercise if the following circumstancesexist (1) the response plan was utilizedin an actual spill response; (2) theresponse involved the entire response community; (3) the objectives of thearea exercise were met as outlined inthe PREP guidelines; (4) the responsewas evaluated; and (5) the spill response was properly documented andcertified. Note that actual spills must involve, at minimum, deployment ofworst-case discharge tier 1 capabilities to be eligible for this credit.ÆProper Documentation for Self-Certification.Proper documentation for self-certification should include, as a minimum, thefollowing information:♦The type of exercise.♦Date and time of the exercise.♦A description of the exercise.♦The objectives met in the exercise.♦The components of the response plan exercised.♦Lessons learned.This documentation must be in writing and signed by an individual empoweredby the plan holder organization.Sample documentation forms are attached as Appendix A to the PREPGuidelines.As a general rule, exercise records should be completed within 30-60 days ofthe exercise, although this may vary depending on exercise complexity.Special IssuesÆComplexes.Complexes are facilities that must meet the requirements of more than onefederal agency. For example, a facilitythat has oil storage tanks, a pipelineand a waterfront oil transfer dock is considered a complex since it must meetthe requirements of EPA, RSPA and the Coast Guard.Complexes would only be required to conduct oneexercise to meet all agencyrequirements for that particular type ofexercise. For example, if a quarterlynotification exercise is required by all three agencies regulating the complex,one notification exercise per quarter would satisfy the requirements for allthree regulatory agencies.ÆVessels Serving as Secondary Carriers of Oil.Vessels serving as secondary carriers ofoil should comply with the exerciserequirements in 33 CFR 155.1045(h).ÆTAPAA Vessels and Facilities.Trans-Alaska Pipeline Authorization Act (TAPAA) vessels and facilities, inaddition to complying with the primaryexercise requirements, must complywith the additional exercise requirements identified in the vessel and facilityresponse plan regulations at 33 CFR 155.1125(a)(2) and 33 CFR154.1125(a)(2), respectively.ÆLEPC Drill Credit.Local Emergency Planning Committees(LEPCs) are required to conducthazardous substance exercises periodically. Industry plan holders shouldcoordinate their exercises with theLEPCs, whenever possible, and shouldtake credit, as long as the PREP exercise objectives are met.ÆForeign Vessels Calling Only Occasionally at U.S. Ports.If a vessel plan holder has a response plan,prepared with the intent that thevessel would be calling at U.S. ports, even if only occasionally, the vessel plan2-23 August 20022-24 August 2002holder must have an exercise programin place and be conducting the requiredexercises. If the plan holder is following the PREP guidelines, all exercisesmust be conducted at the frequency listed in the PREP guidelines. The onlyexception to this requirement is thequalified individual notification exercise,which is only required to be conducted quarterly while operating in U.S.waters, otherwise upon entry into U.S. waters.If a vessel comes into U.S. waters forthe first time, but intends to continuetrading, it must conduct the qualified individual notification exerciseimmediately, and then begin its exerciseprogram. Since the PREP follows thecalendar year, the triennial cycle should begin as soon as the vessel entersU.S. waters. The vessel should remain on the calendar year schedule, with thefollowing January 1 beginning the next year ofthe vessel's triennial cycle. Insuch cases, the plan holder will only be expected to complete 2 full years ofinternal exercises during the first triennial cycle. For the first year, the planholder must complete one QI notification and one emergency proceduresexercise each quarter during that year. Spill management team andequipment deployment exercises are recommended as soon as possible, butcan be held up to 11 months after the dateof the first entry into U.S. Waters.If the vessel only intends to make one voyage into U.S. waters, the vesselmust conduct the qualified individual notification exercise immediately uponentry. If the vessel intends to reenter theU.S. at any time, it must comply withall exercise requirements.ÆRailroad Tank Cars and Motor Vehicle Tank TrucksThere are few individual railroad tank cars or motor vehicle tank truckstransporting sufficient volumes of oilto be subject to the response planningrequirements of OPA 90. For additional information on response planningrequirements for individual railroad tankcars and motor vehicle tank truckstransporting oil, including training, equipment testing, and drills, see 49 CFR130. A railroad tank car or a tank truckwhich transfers oil to or from certainvessels may be considered to be a mobilemarine transportation-related facilityand may be subject to the response planning requirements in 33 CFR 154.Loading and offloading of railroad tank cars and tank trucks at certain nontransportation related facilities may becovered by response plans prepared bya facility owner or operatorsubject to the requirements contained in 40 CFR112.2-25 August 20022-26 August 2002Section 3:U.S. Coast Guard – RegulatedVessels andMarine Transportation-Related FacilitiesQI Notification ExerciseCoast Guard Marine Transportation-Related (MTR) FacilitiesApplicability:Facility.Frequency:Quarterly.InitiatingAuthority:Company policy.Particip.Elements:Facility personnel, qualified individual.Scope:Exercise communications between facilitypersonnel and qualified individual.Objectives:Contact must be made with a qualified individualor designee, as designated in the response plan.Certification:Self-certification.Verification:U.S. Coast Guard.Records:Retention:3 years.Location:Records to be kept at the facility.Evaluation:Self-Evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises,as long as all objectives are met, the exercise isevaluated and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.For plan holders handling both oil andhazardous substances, a single QI notification will3-2 August 20023-1 August 2002satisfy exercise requirement for both plans, if bothplans rely on the same QI. If the plan holder usestwo different QIs, the plan holder is required toexercise each separately,QI Notification ExerciseManned VesselsApplicability:Manned vessels.Frequency:Quarterly while operating in U.S. waters,including the exclusive economic zone (EEZ);otherwise upon entry into U.S. waters, not to exceedfour times per year. The qualified individualnotification exercise would not be required for shipsoutside U.S. waters.InitiatingAuthority:Master or designee according to plan.Particip.Elements:Vessel personnel, plan designated shore sidepersonnel, and a vessel's qualified individual.Scope:Exercise communication between vesselpersonnel and qualified individual.Objectives:Contact by telephone, radio, message-pager orfacsimile a confirmation must be made with aqualified individual or designee as designated in theplan. A telex may be used only if the other meansare not availableCertification:Self-certification.Verification:U.S. Coast Guard.Records:Retention:3 years.Location:Logbook entry indicating time of qualifiedindividual notification as provided at 33 CFR155.1060(e)(1).Evaluation:Owner or operator should conduct review todetermine if objectives have been met.3-4 August 20023-3 August 2002Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises,as long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluatedand a proper record is generated.For plan holders handling both oil andhazardous substances, a single QI notification willsatisfy exercise requirement for both plans, if bothplans rely on the same QI. If the plan holder usestwo different QIs, the plan holder is required toexercise each separately,QI Notification ExerciseUnmanned BargesApplicability:Unmanned barge.Frequency:Quarterly while operating in U.S. waters,including the exclusive economic zone; otherwiseupon entry into U.S. waters, not required to exceedfour times per year. The qualified individualnotification exercise would not be required for bargesoutside U.S. waters.InitiatingAuthority:Barge owner or operator or towing vesselcaptain.Particip..Elements:Barge custodian and qualified individual.Scope:Exercise communication between bargecustodian and qualified individual.Objectives:Contact-by telephone, radio, message-pager, orfacsimile and confirmation must be made with thequalified individual or designee, as designated in theresponse plan.Exercises should be conducted randomly toensure that all barge custodians have an equalchance for participation in the notification exercises.Certification:Self-certification.Verification:U.S. Coast Guard.Records:Retention:3 years.Location:Records to be kept on board the barge or withthe response plan for the barge.Evaluation:Self-evaluation.3-6 August 20023-5 August 2002Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises,as long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.For plan holders handling both oil andhazardous substances, a single QI notification willsatisfy exercise requirement for both plans, if bothplans rely on the same QI. If the plan holder usestwo different QIs, the plan holder is required toexercise each separately,On Board Emergency Procedures ExerciseManned VesselsApplicability:Manned vessels.Frequency:Quarterly.InitiatingAuthority:Master or designee according to plan.Particip.Elements:Vessel personnel.Scope:Exercise the emergency procedures for thevessel crew to mitigate or prevent any discharge or asubstantial threat of suchdischarge of oil/HAZSUBresulting from shipboard operational activitiesassociated with internal or external cargo transfers.Objectives:Conduct an exercise of the vessel's emergencyprocedures to ensure crewknowledge of actions to betaken to mitigate a spill. This exercise may be a walkthrough of the crews' actions.Exercise should involve one or more of thesections of the emergency procedures for spillmitigation. For example-> Simulation of response to a collision.> Simulation of response to an oil spill on the deckof the vessel.> Simulation of response to a vessel fire.Annually ensure that spill mitigation proceduresfor all contingencies identified in the response planhave been exercised.Certification:Self-certification.Verification:U.S. Coast Guard.3-7 August 20023-8 August 2002Records:Retention:3 years.Location:Logbook entry as provided at 33 CFR155.1060(e)(1).Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises,as long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.On vessels covered by both oil and hazardoussubstance plans, separate oil and hazardoussubstance exercises are notrequired. However, theshipboard personnel should alternate oil andhazardous substance scenarios each quarter.Emergency Procedures ExercisesUnmanned BargesApplicability:Unmanned barge(s).Frequency:Quarterly.InitiatingAuthority:Barge owner or operator.Particip.Elements:Barge custodian.Scope:Exercise the emergency procedures to be takenfor an oil/HAZSUB discharge orsubstantial threat ofsuch discharge. Such procedures are outlined at33CFR 155.1040 (a).Objectives:Conduct a walk-through of the emergencyprocedures.Ensure barge custodians know proper actions totake in the event of an oil discharge or substantialthreat of such discharge.Certification:Self-certification.Verification:U.S. Coast Guard.Records:Retention:3 years.Location:Records to be kept on board the barge or withthe response plan for the barge.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Credit3-10 August 20023-9 August 2002should be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.On vessels covered by both oil and hazardoussubstance plans, separate oil and hazardoussubstance exercises are notrequired. However, theshipboard personnel should alternate oil andhazardous substance scenarios each quarter.Emergency Procedures ExercisesFacilities (Optional)*Applicability:Facility.Frequency:Quarterly.InitiatingAuthority:Facility owner or operator.Particip.Elements:Facility personnel.Scope:Exercise the emergency procedures for thefacility to mitigate or prevent any discharge or asubstantial threat of suchdischarge of oil/HAZSUBresulting from facility operational activities associatedwith oil transfers.Objectives:Conduct an exercise of the facility's emergencyprocedures to ensure personnel knowledge ofactions to be taken to mitigate a spill. This exercisemay be a walk-through of the emergencyprocedures.Exercise should involve one or more of thesections of the emergency procedures for spillmitigation. For example,the exercise should involvea simulation of a response to an oil spill.The facility should ensure that spill mitigationprocedures for all contingencies at the facility areaddressed at some time.Certification:Self-certification.Verification:U.S. Coast Guard.Records:Retention:3 years.3-11 August 20023-12 August 2002Location:At each facility.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises,as long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.*This section describes an optional exercise to provide facilities with anexercise that may be conducted unannouncedto fulfill the internalunannounced exercise requirement.At facilities covered by both oil andhazardous substance plans, separate oiland hazardous substance exercises are not required. However, theshipboard personnel should alternate oil and hazardous substancescenarios each quarter.Spill Management Team Tabletop ExerciseU.S. Coast Guard MTR FacilitiesApplicability:Facility spill management teamFrequency:Annually.InitiatingAuthority:Company policy.Particip.Elements:Spill management team as established in theresponse plan.Scope:Exercise the spill management team'sorganization, communication, and decision-making inmanaging a spill response.Objectives:Exercise the spill management team in a review of-> Knowledge of the response plan;> Proper notifications;> Communications system;> Ability to access an OSRO/HSRO;> Coordination of internal organization personnelwith responsibility for spill response;> An annual review of the transition from a localteam to a regional, national, and internationalteam, as appropriate;> Ability to effectively coordinate spill responseactivity with the National Response System (NRS)infrastructure. (If personnel from the NRS are notparticipating in the exercise, the spill managementteam should demonstrate knowledge of responsecoordination with the NRS);3-13 August 20023-14 August 2002> Ability to access information in the AreaContingency Plan for location of sensitive areas,resources available within the area, uniqueconditions of area, etc> At least one spill management team tabletopexercise in a triennial cycle would involvesimulation of a worst-case dischargescenario.Certification:Self-certification.Verification:U.S. Coast Guard.Records:Retention:3 years.Location:At each facility.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.Plan holders are responsible for ensuring thatSMTs are familiar with Area Committees/RegionalResponse Teams (*RRTs) and Area ContingencyPlans in every area in which the plan holder operates.While it is not practicable to require an SMT toexercise in every area/region in which they offer covereach year, each SMT is expected to review ACPsannually and the make-up of Area Committees/RRTsin all areas in which they offer coverage. Selfcertification for exercise credit should include SMTcertification that the SMT has completed annualreview and is familiar with the ACPs and Area3-16 August 20023-15 August 2002Spill Management Team Tabletop ExerciseVesselsApplicability:Vessel spill management team.Frequency:Annually.InitiatingAuthority:Company policy.Particle.Elements:Spill management team as established in theresponse plan.Scope:Exercise the spill management team'sorganization, communication, and decision-making inmanaging a spill response.Objectives:Exercise the spill management team in a review of -> Knowledge of the response plan;> Proper notifications;> Communications system> Ability to access an OSRO/HSRO;> Coordination of internal organization personnelwith responsibility for spill response;> An annual review of the transition from a localteam to a regional, national, and internationalteam, as appropriate;> Ability to effectively coordinate spill responseactivity with the National Response System (NRS)infrastructure. (If personnel from the NRS are notparticipating in the exercise, the spill managementteam should demonstrate knowledge of responsecoordination with the NRS.); and> Ability to access information in the AreaContingency Plan for location of sensitive areas,resources available within the Area, uniqueconditions of Area, etc.At least one Spill Management Team TabletopExercise in a triennial cycle would involve simulationof a worst-case dischargescenario.Certification:Self-certification.Verification:U.S. Coast Guard.Records:Retention:3 years.Location:In accordance with 33 CFR 155.1060(e) (2).Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.Plan holders are responsible for ensuring thatSMTs are familiar with Area Committees and AreaContingency Plans in every area in which the planholder operates. While it isnot practicable to requirean SMT to exercise in every area in which they offercover each year, each SMT is expected to reviewACPs annually and the make-up of Area Committeesin all areas in which they offer coverage. Selfcertification for exercise credit should include SMTcertification that the SMT has completed annualreview and is familiar with the ACPs and AreaCommittees in all areas in which the plan holderoperates.3-17 August 20023-18 August 2002For plan holders who handle both oil andhazardous substances, if the same spillmanagement team handles all oil andhazardous substance incidents, only one SMTexercise is required annually. In such cases, atleast 1 of the exercises should focus on oil and1 on hazardous substancesevery three years.Over the course of six years, at least one worstcase hazardous substance and one worst-caseoil scenario should be exercised.For plan holders who handle both oil andhazardous substances, if the spill managementteams are not the same, separate spillmanagement team exercises are required.Equipment Deployment ExercisesU.S. Coast Guard MTR FacilitiesApplicability:Facilities with facility owned and operatedresponse equipment.Frequency:Semiannually.InitiatingAuthority:Company policy.Particip.Elements:Facility personnel.Scope:Deploy and operate facility owned and operatedresponse equipment identified in the response plan.The equipment to be deployed would be either (1) theminimum amount of equipment for deployment asdescribed in "Guiding Principles", or (2) the equipmentnecessary to respond to an average most probabledischarge at the facility, whichever is less.All of the facility's personnel involved inequipment deployment operations must be included ina comprehensive training program. All of the facility'sequipment must be included in a comprehensivemaintenance program. Credit should be taken fordeployment conducted during training. Themaintenance program must ensure that the equipmentis periodically inspected and maintained in goodoperating condition in accordance with themanufacturer's recommendations and bestcommercial practices. All inspection and maintenancemust be documented by the owner.Objectives:Demonstrate ability of facility personnel to deployand operate equipment.Ensure equipment is in proper working order.deployment should also include testing ACPcontainment, protection and diversion strategies.Certification:Self-certification.3-20 August 20023-19 August 2002Verification:U.S. Coast Guard.Records:Retention:3 years.Location: Records to be kept at facility.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.Note: If a facility with facility owned and operated equipment alsoidentifies OSRO equipment in its response plan, the OSROequipment must also be deployed and operated in accordancewith the equipment deployment requirements for OSRO ownedequipment.Equipment Deployment ExercisesU.S. Coast Guard MTR FacilitiesApplicability:Facilities with OSRO/HSRO response equipmentcited in their response plan.Frequency:Annually.InitiatingAuthority:Company policy.Particip.Elements:Facility owner or operator and OSRO/HSRO.Scope:Deploy and operate response equipmentidentified in the response plan. The equipment to bedeployed would be the minimum amount of equipmentas described in "Guiding Principles.All of the OSRO/HSRO personnel involved inequipment deployment operations must be included ina comprehensive training program. All of theOSRO/HSRO equipment must be Included in acomprehensive maintenance program. Credit shouldbe taken for equipment deployment conducted duringtraining. The maintenance program must ensure thatthe equipment is periodically inspected andmaintained in good operating condition in accordancewith the manufacturers recommendations and bestcommercial practices. Thefacility owner or operatormust ensure that inspection and maintenance by theOSRO/HSRO is documented. The OSRO/HSROmust provide inspection and maintenance informationto the owner or operator.Plan holders must ensure that when a regionalOSRO/HSRO is identified in the response plan, theOSRO/HSRO conducts annual equipment deploymentexercises in each operating environment for each CGContingency Planning Area.Objectives:Demonstrate the ability of the personnel to3-22 August 20023-21 August 2002deploy and operate equipment.Ensure the response equipment is in properworking order.Whenever feasible, equipment deploymentshould also include testing ACP containment,protection and diversion strategies.Certification:The facility owner or operator should ensure thatthe OSRO/HSRO identified in the response planprovides adequate documentation that therequirements for this exercise have been met.Verification:U.S. Coast Guard.Records:Retention:3 years.Records to be kept at the facility.Evaluation:Self-evaluation.Credits:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response when theobjectives are met, the response is evaluated, and aproper record is generated.Equipment Deployment ExercisesVesselsApplicability:Vessels.Frequency:Annually.InitiatingAuthority:Company policy.Particip.Elements:Vessel owner or operator, and OSRO/HSRO.Scope:Deploy and operate response equipmentidentified in the response plan. The equipment to bedeployed would be the minimum amount of equipmentfor deployment as described in "Guiding Principles."All of the OSRO personnel involved in equipmentdeployment operations must be included in acomprehensive training program. All of theOSRO/HSRO equipment must be included in acomprehensive maintenance program. Credit shouldbe taken for equipment deployment conducted duringtraining. The maintenance program must ensure thatthe equipment is periodically inspected and maintainedin good operating condition in accordance with themanufacturer's recommendations and best commercialpractices. The vessel owner or operator must ensurethat inspection and maintenance by the OSRO/HSROis documented. The OSRO/HSRO must provideinspection and maintenance information to the vesselowner or operator.Plan holders must ensure that when a regionalOSRO is identified in the response plan, the OSROconducts annual equipment deployment exercises ineach operating environment for each CG ContingencyPlanning Area.Objective:Demonstrate the ability of the personnel to deployand operate response equipment.3-23 August 20023-24 August 2002Ensure the response equipment is in properworking order.Whenever feasible, equipment deploymentshould also include testing ACP containment,protection and diversion strategies.Certification:The vessel owner or operator should ensure thatthe OSRO/HSRO identified in the response planprovides adequate documentation that therequirements for this exercise have been met.Verification:U.S. Coast Guard.Records:Retention:3 years (see 33 CFR 155.1060 (e)(2)).Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises aslong as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response when theobjectives are met, the response is evaluated, and aproper record is generated.Government-Initiated Unannounced ExercisesVessels and MTR Facility Response Plan HoldersApplicability:Vessel and MTR facility response plan holderswithin the area.Frequency:Triennially, if successfully completed. A facilitydeemed by the CG/EPA not to have successfullycompleted the exercise may be required to participatein another government initiated unannounced exerciseat the discretion of theexercising agency. (Planholders who have successfully completed a PREPgovernment-initiated unannounced exercise will notbe required to participate in another one for at least 36months from the date of the exercise.)InitiatingAuthority:U.S. Coast Guard.Particip.Elements:Vessel and MTR facility response plan holders.Scope:Unannounced exercises are limited to amaximum of four exercises per area per year.Exercises are limited to approximately 4 hours induration.Exercises must involve response to an averagemost probable discharge scenario.RSPA and MMS would cover unannouncedexercises for pipelines and offshore facilities not a partof a complexin their exercise programs.Objectives:Conduct proper notifications to respond tounannounced scenario of an average most probabledischarge.Demonstrate response is -> Timely- As a general rule, the regulatory planningstandard is containment equipment (e.g., booms)3-25 August 20023-26 August 2002on scene within one hour of notification andrecovery equipment (skimmers and temporarystorage) on scene within two hours. Therefore inan government initiated unannounced exercise,plan holder should be able to initiate simulatedclean up within approximately two hours ofexercise commencement.> Conducted with adequate amount of equipmentfor scenario; and> Properly conducted.Whenever feasible, equipment deploymentshould also include testing ACP containment,protection and diversion strategies.Certification:U.S. Coast Guard.Verification:U.S. Coast Guard.Records:Retention3 years.For facilities, at the facility.For vessels, in accordance with 33 CFR155.1060(e)(2).Evaluation:Evaluation to be conducted by initiating agency.Credit:Credit may be granted by the initiating authorityfor an actual spill response when the PREP objectivesare met, the response is evaluated by the initiatingauthority and a proper record is generated. Planholders participating in this exercise may take creditfor notification and equipmentdeployment exercises,if criteria for those exercises are met, the response isevaluated by the plan holder and a proper record isgenerated.Section 4EPA-Regulated Onshore And Certain Offshore NonTransportation-Related FacilitiesPREP Guidelines do not create binding legal requirements.While the PREP Guidelines have been developed with theregulated community, they cannot be considered to be legallybinding substantive rules. Plan holders can accept the PREPGuidelines to fulfill the exercise requirements of the OilPollution Act of 1990.An alternative program can also beacceptable subject to approval by the RegionalAdministrator. (See 40 CFR 112.21) Either the PREPGuidelines or the EPA-approved exercise program developedby the plan holder become binding when referenced in thesubmitted response plan.3-27 August 20024-1 August 2002QI Notification ExercisesEPA-Regulated FacilitiesApplicability:Facility.Frequency:Quarterly.InitiatingAuthority:Company policy.Particip.Elements:Facility personnel and qualified individual.Scope:Exercise communications between facilitypersonnel and qualified individual.Objectives:Contact must be made with a qualified individualor designee, as designated in the response plan.Certification:Self-certification.Verification:Environmental Protection Agency (EPA)Records:Retention:5 years.Location:Records to be kept at the facility.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.Emergency Procedures ExercisesFacilities (Optional)*Applicability:Facility.Frequency:Quarterly.InitiatingAuthority:Facility owner or operator.Partlcip.Elements:Facility personnel.Scope:Exercise the emergency procedures for thefacility to mitigate or prevent any discharge or asubstantial threat of such discharge of oil resultingfrom facility operational activities associated with oiltransfers.Objectives:Conduct an exercise of the facility's emergencyprocedures to ensure personnel knowledge of actionsto be taken to mitigate a spill. This exercise may be awalk-through of the emergency procedures.Exercise should involve one or more of thesections of the emergency procedures for, spillmitigation. For example, the exercise may involve asimulation of a response to an oil spill.The facility should ensure that spill mitigationprocedures for all contingencies at the facility areaddressed at some time.Certification:Self-certification.Verification:EPA.Records:Retention:5 years.Location:At each facility.4-3 August 20024-2 August 2002Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises,as long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.*This is offered as an optional exercise to provide facilities with anexercise that may be conducted unannouncedto fulfill the internalunannounced exercise requirement.Spill Management Team Tabletop ExerciseEPA-Regulated FacilitiesApplicability:Facility spill management team.Frequency:Annually.InitiatingAuthority:Company policy.Particip.Elements:Spill management team as established in theresponse plan.Scope:Exercise the spill management team'sorganization, communication, and decision- making inmanaging a spill response.Objectives:Exercise the spill management team in a reviewof-> Knowledge of the response plan;> Proper notifications;> Communications system;> Ability to access an OSRO;> Coordination of internal organization personnelwith responsibility for spill response;> An annual review of the transition from a localteam to a regional, national, and internationalteam, as appropriate;> Ability to effectively coordinate spill responseactivity with the National Response System (NRS)infrastructure. (If personnelfrom the NRS are notparticipating in the exercise, the spill managementteam should demonstrate knowledge of responsecoordination with the NRS.)> Ability to access information in Area Contingency4-4 August 20024-5 August 2002Plan for location of sensitive areas, resourcesavailable within the area, unique conditions ofarea, etc.At least one spill management team tabletopexercise in a triennial cycle would involve simulationof a worst-case dischargescenario.Certification:Self-certification.Verification:EPA.Records:Retention:5 years.Location:At each facility.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.Equipment Deployment ExercisesEPA-Regulated FacilitiesApplicability:Facilities with facility owned and operatedresponse equipment.Frequency:Semiannually.InitiatingAuthority:Company policy.Particip.Elements:Facility personnel.Scope:Deploy and operate facility owned and operatedresponse equipment identified in the response plan.The equipment to be deployed would be either (1) theminimum amount of equipment for deployment asdescribed in "Guiding Principles", or (2) the equipmentnecessary to respond to a small discharge at thefacility, whichever is less.All of the facility personnel involved in equipmentdeployment operations must be included in acomprehensive training program. All of the facilityequipment must be included in a comprehensivemaintenance program. Credit should be taken fordeployment conducted during training. Themaintenance program must ensure that the equipmentis periodically inspected and maintained in goodoperating condition in accordance with themanufacturers recommendations and bestcommercial practices. All inspection and maintenancemust be documented by the owner.Objectives:Demonstrate ability of facility personnel to deployand operate equipment.Ensure equipment is in proper working order.Certification:Self-certification.Verification:EPA.4-6 August 20024-7 August 2002Records:Retention:5 years.Location:Records to be kept at the facility.EvaluationSelf–Evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.Note: If a facility with facility owned and operated equipment alsoidentifies OSRO equipment in its response plan, the OSROequipment must also be deployed and operated in accordancewith the equipment deployment requirements for OSRO ownedequipment.Equipment Deployment ExercisesEPA-Regulated FacilitiesApplicability:Facilities with OSRO response equipment citedin their response plan.Frequency:Annually.InitiatingAuthority:Company policy.Particip.Elements:Facility owner or operator and OSRO.Scope:Deploy and operate response equipmentidentified in the response plan. The equipment tobe deployed would be the minimum amount ofequipment for deployment as described in "GuidingPrinciples."All of the OSRO personnel involved inequipment deployment operations must be includedin a comprehensive training program. All of theOSRO equipment must be included in acomprehensive maintenance program. Creditshould be taken for equipment deploymentconducted during training. The maintenanceprogram must ensure that the equipment isperiodically inspected and maintained in goodoperating condition in accordance with themanufacturer's recommendations and bestcommercial practices. Thefacility owner or operatormust ensure that inspection and maintenance by theOSRO is documented. The OSRO must provideinspection and maintenance information to theowner or operator.Plan holders must ensure that when a regionalOSRO is identified in the response plan, the OSROconducts annual equipment deployment exercisesin each operating environment for each CG or EPAContingency Planning Area, or EPA sub-area4-8 August 20024-9 August 2002(where identified).Objectives:Demonstrate the ability of the personnel todeploy and operate response equipment.Ensure the response equipment is in properworking order.Certification:The facility owner or operator should ensurethat the OSRO identified in the response planprovides adequate documentation that therequirements for this exercise have been met.Verification:EPA.Records:Retention5 years, kept at the facility.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthe objectives are met, the response is evaluated,and a proper record is generated.Government-Initiated Unannounced ExercisesEPA—Regulated Facility Response Plan HoldersApplicability:EPA-regulated facility response plan holderswithin the region.Frequency:Triennially, if successfully completed. A facilitydeemed by the CG/EPA not to havesuccessfully completed the exercise may berequired to participate in another governmentinitiated unannounced exercise at the discretionof the exercising agency. (Plan holders whohave successfully completed a PREPgovernment-initiated unannounced exercise willnot be required to participate in another one forat least 36 months from the date of theexercise).InitiatingAuthority:EPA.Partlcip.Elements:EPA-regulated facility response plan holders.Scope:Unannounced exercises are limited to amaximum of 10% of response plan holders perEPA Region per year.Exercises are limited to approximately 4 hoursin duration.Exercises should involve response to a smalldischarge scenario (assume 2,100 gallonsoutside secondary containment and dischargedinto or on navigable waters and adjoiningshorelines).Exercise would involve deployment ofresponse equipment identified in the facilityresponse plan to respond to spill scenario.RSPA and MMS will cover unannouncedexercises for pipelines and offshore facilities not4-10 August 20024-11 August 2002a part of a complexin their exercise programs.Objectives:Conduct proper notifications to respond tounannounced scenario of a small discharge.Demonstrate that the response is -> Timely as defined in section 1 of these Guidelines;> Conducted with adequate amount of equipmentfor scenario; and> Properly conducted.Certification:EPA.Verification:EPA.Records:Retention:5 years, kept at the facility.Evaluation:Evaluation to be conducted by initiating agency.Credit:Credit may be granted by the initiating authorityfor an actual spill response when the PREP objectivesare met, the response is evaluated by the initiatingauthority and a proper record is generated. Planholders participating in this exercise may take creditfor notification and equipmentdeployment exercises,if criteria for those exercises are met, the response isevaluated by the plan holder and a proper record isgenerated.Section 5Onshore Transportation-Related Pipelines5-1 August 20024-12 August 2002Owner or Operator Internal Notification ExercisesOnshore Transportation-Related PipelinesApplicability:Pipeline owner or operator.Frequency:As indicated by the response plan and, at aminimum, consistent with the triennial cycle(quarterly).PartyInitiatingExercise:As indicated in response plan.Participants:Facility response personnel and the facility'squalified individual.Scope:Exercise notification process between key facilitypersonnel and the qualified individual to demonstratethe accessibility of the qualified individual.Objectives:Contact by telephone, radio, message-pager, orfacsimile and confirmation established as indicated inresponse plan.Format:As indicated in response plan.Certification:Self-certification as indicated in response plan.Each plan should have a written description of thecompany's certification process.Verification:Verification conducted by Research and SpecialPrograms Administration (RSPA) during regularinspections* or RSPA tabletop exercises.* Verification will not be done by inspections in the near term.Records:Retention:3 years.Location:Owner or operator shall retain records asindicated in response plan.RSPA to retain verification records.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.5-2 August 20025-3 August 2002Internal Tabletop ExercisesOnshore Transportation-Related PipelinesApplicability:Pipeline owner or operator.Frequency:As indicated by the response plan and, at aminimum consistent with the triennial cycle (annually).PartyInitiatingExercise:As indicated in response plan.Participants:Designated spill emergency response teammembers.Scope:Demonstration of the response team's ability toorganize, communicate, and make strategic decisionsregarding population and environmental protectionduring a spill event.Objectives:Designated emergency response team membersshould demonstrate -> Knowledge of facility response plan;> Ability to organize team members to effectivelyinterface with a unified command;> Communication capability; and> Coordination for response capability as outlined inresponse plan.Format:Internal tabletop exercise as outlined in responseplan.Certification:Self-certification as indicated in response plan oras defined in the "Guiding Principles" section of thisdocument, whichever is more stringent. Each planshould have a written description of the company'scertification process.Verification:Verification conducted by RSPA during regularinspections* or RSPA tabletop exercises.* Verification will not be done by inspections in the near term.Records:Retention:3 years.Location:Owner or operator shall retain records asindicated in response plan.RSPA to retain verification records.Credits:Plan holders should take credit for this exercisewhen conducted in conjunction with other exercises aslong as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.5-4 August 20025-5 August 2002Owner/Operator Equipment Deployment ExercisesOnshore Transportation-Related PipelinesApplicability:Pipeline owner or operator.Frequency:As indicated by the response plan and, at aminimum, as consistent with the triennial cycle(annually).*The number of equipment deployment exercises should be suchthat equipment and personnel assigned to each responsezone are exercised at least once per year. If the samepersonnel and equipment respond to multiple zones, theyneed only exercise once per year. If different personnel andequipment respond to various response zones, each mustparticipate in an annual equipment deployment exercise.Party InitiatingExercises:As indicated in response plan.Participants:Designated spill emergency response teammembers.Scope:Demonstrate ability to deploy spill responseequipment* Identified in the FRP.*May consist entirely of operator owned equipment, or acombination of OSRO and operator equipment.Objectives:Designated emergency response personnelshould demonstrate---> (1) Ability to organize; and> (2) Ability to deploy and operate representativetypes of key response equipment as described inresponse plan.Format:Announced deployment exercise indicated inresponse plan.Certification:Self-certification as indicated in response plan.Each plan should have a written description of thecompany's certification process.Verification:Verification conducted by RSPA during regularinspections* or RSPA tabletop exercises.*Verification will not be done by inspection in the near term.Records:Retention:3 years.Location:Owner or Operator shall retain records asindicated in response plan.RSPA to retain verification records.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises aslong as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.5-7 August 20025-6 August 2002Unannounced ExercisesOnshore Transportation-Related PipelinesApplicability:Pipeline owner/operator.Frequency:Maximum of 20 unannounced RSPA exercisesconducted annually for the pipeline industry as awhole. A single owner or operator will not be requiredto participate in a RSPA- initiated unannouncedexercise, if they havealready participated in onewithin the previous 36 months.PartyInitiatingExercise:RSPA.Participants:Designated spill emergency response teammembers.Operations staff.On-Scene Coordinator (optional).State and local government (optional).Scope:Demonstrate ability to respond to a worst-casedischarge spill event.Objectives:Designated emergency response team membersshould demonstrate adequate knowledge of theirfacility response plan and the ability to organize,communicate, coordinate, and respond in accordancewith that plan.Format:Unannounced tabletop exercise to discussstrategic issues.Operations will provide the owner or operator thefollowing information at least 10 working days inadvance (1) date, time, and location of exercise; (2)expected exercise duration; and (3) response zone tobe exercised.On the day of the exercise, the pipeline owner oroperator will be provided the scenario and post-spillevents. This information will be used to explore anddiscuss strategic issuesthat will help operatorsevaluate their response plans.Certification:Certification can be effectuated by RSPApersonnel conducting the exercise. RSPA will providewritten certification of theexercise date, participants,and response zone exercised.Verification:Verification can be made by RSPA personnelconducting the exercise.Records:RetentionTime:3 years.Location:Owner or Operator shall retain records asindicated in response plan.RSPA to retain verification records.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.5-8 August 20025-9 August 2002Section 6Offshore Facilities6-1 August 20025-10 August 2002Notification ExercisesOffshore FacilitiesApplicability:Offshore facilities.Frequency:Annual.InitiatingAuthority:Owner or operator.ParticipatingElements:Facility personnel and qualified individual.Scope:Exercise and test communications betweenpersonnel on each facility manned on a 24-hour basisand qualified individual; information to be provided inthe event of a spill must be simulated during thisexercise.Objectives:Voice contact must be made with the qualifiedindividual.Certification:Self-certification.Verification:Verification by MMS inspection personnel duringsite visits.Records:Retention:3 years.Location:Records to be maintained at the facility or at acorporate location designated in the spill responseplan.Evaluation:Self-evaluation.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.6-2 August 20026-3 August 2002UNANNOUNCED EXERCISESOffshore FacilitiesApplicability:Offshore Facilities.Frequency:Frequency will be determined by the RegionalSupervisor. A facility will not face an agencyunannounced exercise more than once per year,unless the results of previous exercises warrant morefrequency.InitiatingAuthority:MMS.ParticipatingElements:Facility personnel, qualified individual, spillmanagement team, oil spill removal organization(OSRO), state and local government and other federalagencies (optional).Scope:Exercise will require that the owner or operatorrespond to a spill scenario posed by the MMSRegional Supervisor.Objectives:Conduct proper notifications to respond tounannounced scenario.Demonstrate ability to mobilize adequateequipment to respond to scenario.Demonstrate ability to conduct timely deploymentof equipment.Demonstrate ability to conduct properdeployment to respond to scenario.Certification:MMS.Verification:Verification by MMS personnel.Records:Retention:3 years.Location:MMS will maintain records at the MMS RegionalOffice. The owner or operator will maintain records ata corporate location identified in the approved spillresponse plan.Evaluation:Evaluation to be conducted by MMS.CreditsPlan holder may receive credit for other requiredexercises if the unannounced exercise is successfullycompleted, objectives of the other exercise(s) are met,and a proper record is generated.6-4 August 20026-5 August 2002Spill Management Team Tabletop ExerciseOffshore FacilitiesApplicability:Spill management team.Frequency:Annually.InitiatingAuthority:Owner or operator.ParticipatingElements:Spill management team as established inresponse plan.Scope:Exercise the spill management team annually.Objectives:Exercise the spill management team'sorganization, communication, and decision-making inmanaging a spill response to an unannouncedscenario.Exercise the spill management team in a review of-> Knowledge of response plan;> Proper notifications;> Communications system;> Ability to access an OSRO;> Coordination of OSRO containment andrecovery activity;> Coordination of organization or agencypersonnel with responsibility for spillresponse;> Ability to effectively coordinate spill responseactivity with National Response Systeminfrastructure; and> Ability to access information in AreaContingency Plan for location of sensitiveareas, resources available within the area,unique conditions of area, etc.Certification:Self-certification.Verification:Verification by MMS personnel.Records:Retention:3 years.Location:Records to be maintained at a corporate locationdesignated in the spill response plan.Evaluation:Self-evaluation. The MMS may evaluate if theexercise is witnessed.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.6-6 August 20026-7 August 2002Equipment Deployment ExercisesOffshore Facilities-Equipment Staged OffshoreApplicability:OSRO or owner or operator response equipmentrequired to be staged offshore.Frequency:Semiannually.InitiatingAuthority:OSRO, or owner or operator.ParticipatingElements:Facility or OSRO personnel.Scope:Deploy and operate response equipment that isrequired to be staged offshore and identified in theresponse plan. Each typeof this equipment is to bedeployed annually. Each type need not be deployedat each exercise. Credit will be given for anygovernment-initiated deployment exercise orexercises initiated by OSRO member companies.*Objectives:Demonstrate ability of spill response personnel todeploy and operate equipment.Evaluate deployment strategies under variousspill scenarios.Certification:Self-certification (OSRO for OSRO equipmentand owner or operator for owner or operatorequipment).Verification:Verification by MMS inspection personnel.Records:Retention:3 years.Location:Records to be kept at the OSRO or at the facilityor a corporate location designated in approvedresponse plan for owner or operator equipment.Evaluation:Self-evaluation. The MMS may evaluate if theexercise is witnessed.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.*For exploratory wells being drilled from Mobile Offshore DrillingUnits (MODUs), at least one deployment exercise will beconducted during drilling of each well, as directed by theRegional Supervisor, if staged response equipment is requiredby the Regional Supervisor.6-8 August 20026-9 August 2002Equipment Deployment ExercisesOffshore Facilities – Equipment Staged OnshoreApplicability:OSRO, or owner or operator responseequipment stored at an onshore location.Frequency:Annually.InitiatingAuthority:OSRO, or owner or operator.ParticipatingElements:OSRO, or owner or operator personnel.Scope:Deploy and operate response equipment that isstored onshore and identified in the response plan.Each type of equipment must be exercised duringeach triennial period. It is not necessary to deployeach piece of equipment.Objectives:Demonstrate ability of spill response personnel todeploy and operate equipment.Evaluate deployment strategies under variousspill scenarios.Certification:Self-certification (OSRO for OSRO equipmentand owner or operator for owner or operatorequipment).Verification:Verification by MMS inspection personnel.Records:Retention:3 years.Location:Records to be kept at the OSRO or at the facilityor a corporate location designated in approvedresponse plan for owner or operator equipment.Evaluation:Self-evaluation. The MMS may evaluate if theexercise is witnessed.Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.6-11 August 20026-10 August 2002Section 7Area ExercisesNotification ExerciseAreaApplicability:Area.Frequency:Quarterly.InitiatingAuthority:On-Scene Coordinator.ParticipatingElements:Key Elements of the unified command(appropriate federal, state and local governmentagencies).Scope:Exercise and test communication between OnScene Coordinator and key elements of the unifiedcommand.Objectives:Ensure that the key elements of the unifiedcommand know whom to call in the event of adischarge within the area.Ensure contact by telephone, radio, messagepager, or facsimile and confirmation is made betweenthe On-Scene Coordinator and key elements of theunified command.Certification:Self-certification.Verification:Verification to be conducted by the District orRegion.Records:Retention:3 years (USCG).5 years (EPA).Location:With the On-Scene Coordinator.Evaluation:By Area Committee.7-1 August 20027-2 August 2002Credit:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercises,as long as all exercise objectives are met, theexercise is evaluated, and a proper record isgenerated. Credit should be taken for an actual spillresponse when these objectives are met, theresponse is evaluated, and a proper record isgenerated.Spill management Team Tabletop ExerciseAreaApplicability:Area spill management team.Frequency:Annually.InitiatingAuthority:U.S. Coast Guard District (m) or EPA Region.ParticipatingElements:Spill management team for the area (U.S. CoastGuard or EPA and respective response team) andstate(s).Scope:Exercise the spill management team'sorganization, communication, and decision-making inmanaging a spill response.Objectives:Exercise the spill management team in a review of> Knowledge of the Area Contingency Plan;> Proper notifications;> Communications system> Ability to access response equipment> Coordination of organization or agency personnelwith responsibility for spill response;> Ability to effectively coordinate spill responseactivity with National Response Systeminfrastructure;> Ability to access information in Area ContingencyPlan for location of sensitive areas, resourcesavailable within the area, unique conditions of thearea, etc.; andExercise the response management systemidentified in the ACP and to the extent possible theunified command.7-4 August 20027-3 August 2002At least one spill management team tabletopexercise in a triennial cycle would involvesimulation of a worst-case dischargescenario.Certification:Self- Certification.Verification:Verification to be conducted by District orRegion.RecordsRetention3 years (USCG).5 years (EPA).Location:With On-Scene Coordinator.Evaluation:Self-evaluation.Credit:Credit should be taken for this exercise whenconducted in conjunction with other exercises as longas all objectives are met, the exercise is evaluated,and a proper record is generated. Credit should betaken for an actual spill response when theseobjectives are met, the response is evaluated, and aproper record is generated.Equipment Deployment ExercisesAreaApplicability:Area Committee.Frequency:Annually.InitiatingAuthority:On-Scene Coordinator.ParticipatingElements:Local area response community (appropriatefederal, state and local response agencies).Scope:Deploy and operate Coast Guard and EPA "firstaid" response equipment and the Coast Guard'sprepositioned equipment. All of the "first aid"equipment or that which is necessary to respond to anaverage most probable discharge in the Area,whichever is less, should be deployed annually.All response personnel must be included in acomprehensive training program, and all responseequipment in a comprehensive maintenance program.Credit should be taken for deployment of equipmentduring training. The maintenance program mustensure that the equipment is periodically inspectedand maintained in good operating condition inaccordance with the manufacturer's recommendationsand best commercial practices.Objectives:Demonstrate the ability of the responsepersonnel to deploy and operate the equipment.Ensure that the response equipment is in properworking order.Certification:Self-certification.Verification:District or Region.Records:7-6 August 20027-5 August 2002Retention:3 years (USCG).5 years (EPA).With On-Scene Coordinator.Evaluation:Self-evaluation.Credits:Plan holder should take credit for this exercisewhen conducted in conjunction with other exercisesas long as all objectives are met, the exercise isevaluated, and a proper record is generated. Creditshould be taken for an actual spill response whenthese objectives are met, the response is evaluated,and a proper record is generated.Area ExercisesAreaApplicability:Area Response community.Frequency:Triennially for each area.InitiatingAuthority:U.S. Coast Guard, EPA and Industry.ParticipatingElements:Appropriate Federal, state, and localgovernment, and industry and other members of theresponse community.Scope:Area exercises will exercise the Area ResponseCommunity.Objectives:Exercise the Area Contingency Plan, along withselected industry response plans.Exercise the response management systemidentified in the ACP and, tothe extent possible, theunified command with the appropriate participants.Exercise the area and industry spill managementteams.Deploy adequate response equipment for theexercise scenario. At a minimum, the scenario mustinvolve exercise of Tier I Worst Case dischargecapability.Format:Total annual exercises would consist of thefollowing-> 6 government-led exercises; and> 14 industry-led.____________________________Total = 20 Area Exercises Per Year.Area exercises should beapproximately8 - 127-7 August 20027-8 August 2002hours in duration.Exercise scenario to be developed by theexercise design team.To simulate realism, the exercise should beconducted in the command post that would be utilizedfor a spill response, whenever possible.Exercise may be in real or limited compressedtime, and may start at any point during an incident, asdetermined by the Exercise Design Team. Flexibilityshould be allowed, to ensure the exercise objectivesare met.Lessons learned from the exercise should beincorporated into the PREP Lessons Learned System(e.g., CGSAILS), whenever possible.Certification:The On-Scene Coordinator will certify completionof the area exercise. In certifying the area exercise,the On-Scene Coordinator willconsider the following-> The area exercise was conducted.> The area exercise met the objectivesoutlined in the PREP guidelines.> The area response community wasexercised for spill response preparedness.Industry plan holders should take credit for all ofthe exercises completed during the area exercise.These exercises shall be self-certified by the planholder.Verification:Verification to be done by the NationalScheduling Coordinating Committee.RecordsRetention:3 years (USCG).5 years (EPA).Location:On Scene Coordinator.Evaluation:Joint evaluation team to be comprised of thefederal government (U.S.Coast Guard, EPA, RSPAor MMS) state and industry.Scheduling:Scheduling of area exercises will be done by theNSCC, utilizing input fromthe On-Scene Coordinator,Area Committee and Regional Response Team, inconsultation with the industry. A 3-year schedule ofPREP Area exercises will be published in the federalregister as a public forum for government and industryinput to the scheduling process.7-9 August 20027-10 August 2002Appendix A: Internal Exercise Documentation Forms______________________________________________________________The following sampledocumentation forms are provided to give planholders an idea of how to document the internal PREP exercises. Thesesample forms, are provided only as guidance. Plan holders do nothaveto include all of the informationpresented on these forms nor do theyhave to use these exact forms. Plan holders may choose to developtheir own forms. Documentation should be completed within 60 days ofexercise completion. Documentation should include, as a minimum, thefollowing information:♦The type of exercise;♦Date and time of the exercise;♦A description of the exercise;♦The objectives met in the exercise;♦The components of the response plan exercised; and♦Lessons learned along with procedures and schedulesfor implementing lessons learned.Internal Exercise Documentation FormNotification Exercise1. Date performed:____________________________________2. Exercise or actual response?__________________________3. Vessel/Facility/Pipeline/Offshore Facility initiatingexercise: ____________________________________________4. Name of person notified______________________________Is this person identified in yourresponse plan as qualified individualOr designee?_______________________________________5. Time initiated: ______________________________________Time in which qualified individual or designeeresponded _________________________________________6. Method used to contact:____Telephone____Pager____Radio____Other _________________________________________7. Description of notification procedure:_____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________8. Identify which of the 15 corecomponents of your response planwere exercised during this particular exercise:____________________________________________________________________________________________________________________________________________________________________________________________________________________________________Certifying SignatureA-2 August 2002A-1 August 2002Retain this form for a minimum of 3 years (for USCG/RSPA/MMS) or 5years (for EPA).For vessel qualified individual notification, ensure log entry is alsomade and retained for a minimum of 3 years.Internal Exercise Documentation FormEmergency Procedures Exercise1. Date performed: ____________________________________2. Exercise or actual response ? __________________________If an exercise, announced or unannounced? ______________3. Location: __________________________________________4. Vessel/Barge/Facility name: ___________________________5. Time started: _______________________________________Time completed: ____________________________________6. Sections of Vessel/Barge/Facility emergency procedures exercised(i.e., response to collision, response to oil spill on deck, response tovessel fire, etc.)? _______________________________________________________________________________________________________________________________________________________________________7. Description of exercise:______________________________________________________________________________________________________________________________________________________________________8. Identify which of the 15 corecomponents of your response planwere exercised during this particular exercise: ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________A-4 August 2002A-3 August 2002Emergency Procedures Exercise (continued)9. Attach a description of lesson(s) learned, procedures and schedule forimplementation, and person(s) responsible for follow up of correctivemeasures.________________________________Certifying SignatureRetain this form for a minimum of 3 years (for USCG/RSPA/MMS) and 5years (for EPA).For manned vessels, ensure log entry is made and retained for 3 years.Internal Exercise Documentation FormSpill Management Team Tabletop Exercise1. Date(s) performed: ___________________________________2. Exercise or actual response? __________________________If an exercise, announced or unannounced? _________________3. Location of tabletop: _________________________________4. Time started: _______________________________________Time completed: ____________________________________5. Response plan scenario used (check one):_______________________Average most probable discharge_____________________ Maximum most probable discharge________________________________ Worst case discharge_______________________ Size of (simulated) spill-bbls/gals6. Describe how the following objectives were exercised:a) Spill management team's knowledge of oil-spill response plan:______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________b) Proper notifications:______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________A-5 August 2002A-6 August 2002Spill Management Team Tabletop Exercise (continued)c) Communications system:__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________d) Spill management team's ability to access contracted oil spillremoval organizations:________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________e) Spill management team's ability tocoordinate spill response withOn-Scene Coordinator, state and applicable agencies:________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________f) Spill management team's ability to access sensitive site andresource information in the Area Contingency Plan:____________________________________________________________________________________________________________________________________________________________________________________________________Spill Management Team Tabletop Exercise (continued)__________________________________________________________________________________________________7.Identify which of the 15 corecomponents of your response planwere exercised during this particular exercise:___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________8. Attach a description of lesson(s) learned, procedures and schedulefor implementation, and person(s) responsible for follow up ofcorrective measures.________________________________Certifying SignatureRetain this form for a minimum of 3 years (for USCG/RSPA/MMS) or 5years (for EPA).A-7 August 2002A-8 August 2002Internal Exercise Documentation FormEquipment Deployment Exercise1. Date(s) performed: __________________________________2. Exercise or actual response? __________________________If an exercise, announced or unannounced? ____________3. Deployment location(s):_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________4. Time started: _______________________________________Time OSRO/HSRO called________________________Time on-scene_________________________________Time boom deployed____________________________Time recovery equipment arrives on-scene___________Time completed: ____________________________________5. Equipment deployed was:_____Facility-owned_____OSRO/HSRO-owned if so, whichOSRO/HSRO?__________________BothEquipment Deployment Exercise (continued)6. List type and amount of all equipment (e.g., boom and skimmers)deployed and number of support personnel employed:______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________7. Describe goals of the equipment deployment and list any AreaContingency Plan strategies tested.(Attach a sketch of equipmentdeployments and booming strategies):_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________8. For deployment of facility-owned equipment, was the amount ofequipment deployed at least the amount necessary to respond toyour facility's average most probable spill?__________________________________________________________________________________________________Was the equipment deployedin its intended operatingenvironment?_____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________A-10 August 2002A-9 August 2002Equipment Deployment Exercise (continued)9. For deployment of OSRO/HSRO-owned equipment, was arepresentative sample (at least1000 feet of each boom type and atleast one of each skimmer type) deployed?____________________________________________________________________________________________________________________________________________________________________________________________________Was the equipment deployedin its intended operatingenvironment?___________________________________________________________________________________________________________________________________________________10. Are all facility personnel that are responsible for responseoperations involved in a comprehensive training program, and allpollution response equipment involved in a comprehensivemaintenance program? __________________________________________________________________________________________________________________________________________________________________________________If so, describe the program:________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________Date of last equipment inspection: ______________________11. Was the equipment deployed bypersonnel responsible for itsdeployment in the event of an actual spill? ________________12. Was all deployed equipment operational? If not, why not?____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________13. Identify which of the 15 corecomponents of your response planwere exercised during this particular exercise: ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________14. Attach a description oflesson(s) learned, procedures andschedule for implementation, and person(s) responsible for followup of corrective measures.________________________________Certifying SignatureRetain this form and other documentation related to this exercise onfile for a minimum of 3 years (for USCG/RSPA/MMS) or for aminimum of 5 years (for EPA).A-12 August 2002A-11 August 2002Core ComponentsYearCYCYCYQuartersQuartersQuarters123456789101112 Notification Staff Mobilization Operate in RMS Discharge Contained Assessment Containment Recovery Protection Disposal Communications Transportation Personnel Support Equipment Maint. Procurement DocumentationQI NotificationEmergencyProceduresSMT TabletopEquipmentDeploymentOSRO/HSROEquipmentDeploymentGov’t-initiatedUnnannouncedArea ExerciseFor each quarter in which an exercise was completed, mark that with an“X” then mark each core component tested during an exercise.Triennial CYLCLE DocumentationFORMA-13 August 2002A-14 August 2002______________________________________________________________During each triennial cycle, all components of a plan holder's responseplan must be exercised at least once.The purpose of this requirementis to ensure that all plan components function adequately for responseto an oil spill.The 15 core components listed beloware the types of componentsthat must be exercised. However, these components may not becontained in each response plan.As such, the plan holder shallidentify those that are applicable from this list, adding or deleting asappropriate.1. Notifications:Test the notificationsprocedures identified in theArea Contingency Plan and the associated Responsible PartyResponse Plan.2. Staff Mobilization:Demonstrate the ability to assemble the spillresponse organization identified in the Area Contingency Plan andassociated Responsible Party Response Plan.3. Ability to Operate Within the Response Management SystemDescribed in the Plan:3.1Unified Command:Demonstrate the ability of the spillresponse organization to work within a unified command3.1.1 Federal Representation:Demonstrate the ability toconsolidate the concerns and interests of the other members of theunified command into a unified strategic plan with tacticaloperations.3.1.2 State Representation:Demonstrate the ability to functionwithin the unified command structure.3.1.3 Local Representation:Demonstrate the ability to within theunified command structure.3.1.4 Responsible Party Representation:Demonstrated( tofunction within the unified command structureRESPONSEPLANCORECOMPONENTS(continued)3.2.Response Management System:Demonstrate the ability ofthe response organization to operate within the framework of theresponse management system identified in their respective plans.3.2.1 Operations:Demonstrate the ability to coordinate or directoperations related to the implementation of action plans containedin the respective response andcontingency plans developed by theunified command.3.2.2 Planning:Demonstrate the ability to consolidate the variousconcerns of the members of the unified command into jointplanning recommendations and specific long-range strategic plans.Demonstrate the ability to develop short-range tactical plans for theoperations division.3.2.3 Logistics:Demonstrate the ability to provide the necessarysupport of both the short-termand long-term action plans.3.2.4 Finance:Demonstrate the ability to document the dailyexpenditures of the organization andprovide cost estimates forcontinuing operations.3.2.5 Public Affairs:Demonstrate the ability to form a jointinformation center and provide the necessary interface between theunified command and the media.3.2.6 Safety Affairs:Demonstrate the ability to monitor all fieldoperations and ensure compliance with safety standards.3.2.7 Legal Affairs:Demonstrate the ability to provide the unifiedcommand with suitable legal advice and assistance.4.Source Control:Demonstrate the ability of the spill responseorganization to control and stop the discharge at the source.4.1 Salvage:Demonstrate the ability to assemble and deploysalvage resources identified in the response plan.4.2 Firefighting:Demonstrate the ability to assemble and deploythe firefighting resources identified in the response plan.APPENDIXB:RESPONSEPLANCORECOMPONENTSB-1 August 2002B-2 August 2002RESPONSE PLAN CORE COMPONENTS (continued)4.3 Lightering:Demonstrate the ability to assemble and deploythe lightering resources identified in the response plan.4.4 Other salvage equipment and devices:(electrical and manualcontrols and barriers to control the source) Demonstrate the abilityto assemble and deploy the othersalvage devices identified in theresponse plan5.Assessment:Demonstrate the ability of the spill responseorganization to provide an initial assessment of the discharge andprovide continuing assessments of the effectiveness of the tacticaloperations.6.Containment:Demonstrate the ability of the spill responseorganization to contain the dischargeat the source or In variouslocations for recovery operations.7.Recovery:Demonstrate the ability of the spill responseorganization to recover, mitigate, and remove the dischargedproduct. Includes mitigation and removal activities, e.g. dispersantuse, ISB use, and bioremediation use.7.1 On-Water Recovery: Demonstrate the ability to assemble anddeploy the on-water response resources identified In the responseplans.7.2 Shore-Based Recovery: Demonstrate the ability to assembleand deploy the shoreside responseresources identified in theresponse plans.8.Protection:Demonstrate the ability of the spill responseorganization to protect the environmentally and economicallysensitive areas identified inthe Area Contingency Plan and therespective industry response plan.8.1 Protective Booming:Demonstrate the ability to assemble anddeploy sufficient resources to implement the protection strategiescontained in the Area ContingencyPlan and the respective industryresponse plan.RESPONSE PLAN CORE COMPONENTS (continued)8.2 Water Intake Protection:Demonstrate the ability to quicklyidentify water intakes and implement the proper protectionprocedures from the Area Contingency Plan or develop a plan foruse.8.3 Wildlife Recovery and Rehabilitation:Demonstrate the abilityto quickly identify these resources at risk and implement the properprotection procedures from theArea Contingency Plan to develop aplan for use.8.4 Population Protection (Protect Public Health and Safety):Demonstrate the ability to quickly identify health hazardsassociated with the dischargedproduct and the population at riskfrom these hazards, and to implement the proper protectionprocedures from the Area Contingency Plan or develop a plan foruse.9.Disposal:Demonstrate the ability of the spill responseorganization to dispose of the recovered material and contaminateddebris.10.Communications:Demonstrate the ability to establish aneffective communications system for the spill responseorganization.10.1 Internal Communications:Demonstrate the ability toestablish an intra-organization communications system. Thisencompasses communications at the command post and betweenthe command post and deployed resources.10.2 External Communications:Demonstrate the ability toestablish communications both within the response organizationand other entities (e.g., RRT, claimants, media, regional or HQagency offices, non-governmental organizations, etc.).11.Transportation:Demonstrate the ability to provide effectivemulti-mode transportation both forexecution of the discharge andsupport functions.11.1 Land Transportation:Demonstrate the ability to provideeffective land transportation for all elements of the response.B-4 August 2002B-3 August 2002RESPONSE PLAN CORE COMPONENTS (continued)11.2 Waterborne Transportation:Demonstrate the ability toprovide effective waterborne transportation for all elements of theresponse.11.3 Airborne Transportation:Demonstrate the ability to providethe necessary support of all personnel associated with theresponse.12.Personnel Support:Demonstrate the ability to provide thenecessary support of all personnel associated with the response.12.1 Management:Demonstrate the ability to provideadministrative management of all personnel involved in theresponse. This requirement includes the ability to move personnelinto or out of the response organization with establishedprocedures.12.2 Berthing:Demonstrate the ability to provide overnightaccommodations on a continuing basis for a sustained response.12.3 Messing:Demonstrate the ability to provide suitable feedingarrangements for personnel involved with the management of theresponse.12.4 Operational and Administrative Spaces:Demonstrate theability to provide suitable operational and administrative spaces forpersonnel involved with the management of the response.12.5 Emergency Procedures:Demonstrate the ability to provideemergency services for personnelinvolved in the response.13.Equipment Maintenance and Support:Demonstrate the abilityto maintain and support all equipment associated with theresponse.13.1 Response Equipment:Demonstrate the ability to provideeffective maintenance and support for all response equipment.RESPONSE PLAN CORE COMPONENTS (continued)13.2 Response Equipment:Demonstrate the ability to provideeffective maintenance and support for all equipment that supportsthe response. This requirement includes communicationsequipment, transportation equipment, administrative equipment,etc.14.Procurement:Demonstrate the ability to establish an effectiveprocurement system.14.1 Personnel:Demonstrate the ability to procure sufficientpersonnel to mount and sustain an organized response. Thisrequirement includes insuring thatall personnel have qualificationsand training required for their position within the responseorganization.14.2 Response Equipment:Demonstrate the ability to procuresufficient response equipment to mount and sustain an organizedresponse.14.3 Support Equipment:Demonstrate the ability to procuresufficient support equipment to support and sustain an organizedresponse.15.Documentation:Demonstrate the ability of the spill responseorganization to document all operational and support aspects of theresponse and provide detailed records of decisions and actionstakenB-5 August 2002B-6 August 2002