Chapter 9: RESPONSE TEAM TRAINING - DRILLS AND EXERCISES
9.1 Drills And Exercises
It is Navy policy to participate in the National Preparedness for Response
Exercise Program (PREP) to meet Oil Pollution Act of 1990 (OPA 90) drill and
exercise requirements. Each activity required to comply with OPA 90 must
participate in all phases of PREP. PREP consists of internal and external
exercises. Internal exercises are those that can be conducted with only Navy
personnel. External exercises are those that require participation by outside
organizations such as other federal agencies (e.g., U.S. Coast Guard [USCG],
the National Oceanic and Atmospheric Administration [NOAA], the Department of
Interior [DOI], and the U.S. Environmental Protection Agency [EPA]), state
agencies, and local government agencies. The following are internal exercises:
-
Qualified Individual Notification Exercises;
-
Emergency Procedures Exercises;
-
Spill Management Team Tabletop Exercises;
-
Equipment Deployment Exercises.
-
The following are external exercises:
-
Area Exercises;
-
Coast Guard/EPA/RSPA-Initiated Unannounced Exercises.
Each category of exercise is designed to test a particular aspect of spill
response and has distinct objectives that must be met. The particulars of each
exercise are detailed in the publication "National Preparedness for Response
Exercise Program (PREP) Guidelines", produced by the regulatory agencies
charged with overseeing OPA 90 compliance. Copies of this document are
available from COMXXXX. This chapter discusses sections of the PREP Guideline
that are specifically applicable to NOSC commands and Navy facilities. A
summary of these sections appears in matrix form in Table 9-1. Note that there
are differences between the requirements of the three regulatory agencies. For
example, USCG requires records maintenance for three years, while EPA requires
that the same records be retained for five years. It is Navy policy to meet the
most stringent requirement. The matrix shows that all records will be
maintained for five years.
A brief discussion of each type of exercise is included in this chapter.
Detailed explanations for each exercise requirement are contained in the PREP
Guidelines.
Table 9-1
OPA 90 (PREP) Drill and Exercise Requirements [top] |
|
Notification Drill |
Tabletop Drill |
Equipment Deployment Drill |
Unannounced Drill |
Area Exercise |
|---|
| Partici-pating Elements |
Facilities |
Spill Management Team (SMT) Facility SMT
|
Installations with organic response equipment Navy SUPSALV
|
Installations with Facility Response Plans |
Federal, State and Local Government and Industry |
| Initiating Authority |
NOSC Navy Facility |
NOSC Navy Facility |
Installation's Command Policy Navy SUPSALV |
Self-Intitiated |
USCG, EA and Industry (may include U.S. Navy)* |
| USCG/EPA- initiated |
| Frequency |
Quarterly |
Annually |
Semiannually for installations with organic response equipment |
Annually (not required to participate if participated in unannounced USCG or
EPA-initiated drill w/in last 36 months) Maximum of 4 per Area per year for
USCG/ EPA-initiated
|
Triennially for each Area (20 total exercises per year)
Total annual exercises to consist of:
5 Coastal, USCG lead
10 Coastal, Industry lead
4 Inland, EPA lead
1 Inland, EPA lead
|
| Scope and Objective |
Exercise communi-cations between the spiller and Facility QI.
Contact with and confirmation by the appropriate response command must be made
(ie., by telephone, radio, message, pager, or fax).
Revalidate notification list at least every 6 months.
Note: The FQI may also be referred to as the FIC.
|
Exericse SMT in a review of:
Knowledge of response plan
Proper notification
Communciations system
Abililty to accses the OSRO
Transition from a local facility team to a reagional NOSC team
Coordination of personnel with responsibility for spill response
Ability to coordinate effectively with NRS infrastructure
Ability to access information in the ACP for location of sensitive areas,
rsources available within area, unique conditions of area, etc.
Exercise SMT organization, communication and decision making
At least 1 SMT exercise in triennial cycle shall involve WCD scenario.
|
Navy SUPSALV
Deploy into intended operating areas, and operate response
equipment. (Only a representative sample of each type of equipment need to be
operated)
To receive credit, as a minimum, must deploy: 1) 1000' of each type of boom in
inventory (only 50' Bottom Seal boom) and 2) one of each type of skimming
equipment
Ensure response equipment is operational, and personnel are capable of deploying
and operating the equipment
Equipment not deployed must be included in a comprehensive training and
maintenance program. The maintenance program must ensure the equipment is
periodically inspected and maintained in good operating condition in accordance
with the manufacturer’s recommendation and best commercial practices. All
inspections and maintenance must be documented
OSROs that respond to and have equipment pre-staged in various geographic
locations are required to conduct exercises in EACH location.
Installations with organic response equipment
Same scope & objectives as below
Required to deploy equipment up to amount necessary to respond to AMP
Dysfunctional equipment is to be repaired or replaced within 30 days
|
USCG/ EPA-Initiated
Will involve equipment deployment in each drill. Equipment deployment should
demonstrate:
Timeliness
Adequate Equipment for Scenario
Proper Deployment
Maximum of 4 hours in duration
Respond to AMP scenario
Conduct proper notifications to respond to AMP
See Note 1
Self-Initiated
May be any requiared drill except Notification Drill
Conduct proper notifications
Once every 3 years must involve equipment deployment
|
Exercise Area Contingency Plan along with selected industry response plans. Exercise
Unified Command System along with appropriate players participating
Exercise SMT
Ensure proper notifications are made
Ensure adequate response equipment is activated for response to the exercise
scenario
8-12 hours in duration
Players will be in actual spaces eg. The command post utilized for a real spill
Conducted in real time
Lessons learned may be shared nationwide
|
| Credit |
May take credit for this exercise in the course of conducting business or other
drills provided that the objectives of the drill are met and the drill is
properly recorded. Similarly, credit may be given for an actual spill response
when the objectives are met and properly recorded. |
May take credit for this exercise when conducted in conjunction with other
drills provided that the objectives of the drill are met and the drill is
properly recorded. Similarly, credit may be given for an actual spill response
when the objectives are met and properly recorded. |
May take credit for this exercise when conducted in conjunction with other
drills provided that the objectives of the drill are met and the drill is
properly recorded. Similarly, credit may be given for an actual spill response
when the objectives are met and properly recorded.
Credit will be given for deployment conducted during training.
|
Credit may be taken for an actual spill response when these
objectives are met and properly recorded. Plan holders participating in
Unannounced USCG/ EPA-initiated drills may take credit for Notification and
Equipment Deployment Exercises.
|
| Evaluation & Certification |
All internal drills are self-evaluating and self-certifying.
Unannounced drills initiated by an external agency will be evaluated and
certified by the initiating agency. Area exercises will be jointly evaluated by
federal, state and industry agencies. Area exercises are certified by the OSC,
in consultation with USCG, EPA, RSPA, or MMS. |
| Records |
Navy policy will be that documentation of drills/exercises must be
retained for 5 years following completion of the drill/exercise. |
| Note 1: |
Facilities have the possibility of conducting an optional Emergency
Procedures Exercise that would satisfy the requirement for the annual
Unannounced Exercise. For the purposes of PREP, emergency procedures for
facilities are those procedures established at the facility to mitigate or
prevent any discharge associated with cargo transfer. |
| Note 2: |
Area Drills are "external drills". Unannounced drills may be either
Navy-initiated or initiated by an external organization (eg. USCG/EPA) |
9.1.1 QI Notification Exercise [top]
A Qualified Individual (QI) Notification Exercise is required
to exercise the communications between facility personnel and the individual
(the QI) with the authority to mobilize whatever resources are required to
respond effectively to the spill. At the facility level, this communications
network normally is exercised on a routine basis for small spills, and with
proper documentation, these responses can satisfy the facility QI notification
requirement. For a spill response exceeding the capability of the facility, the
QI notification process includes the NOSC. The QI Notification Exercise is
designed to establish and exercise this component.
9.1.2 Emergency Procedures Exercise [top]
The Emergency Procedures Exercise ensures that personnel are
capable of conducting the initial actions necessary to mitigate the effects of
a spill resulting from operational activities associated with cargo transfers.
PREP designates this exercise as optional for facilities. However, this
exercise can be a good method for facilities to fulfill the annual unannounced
internal exercise requirement (see paragraph 9.1.6).
9.1.3 Spill Management Team Tabletop Exercise
[top]
The Spill Management Team Tabletop Exercise is probably the
most significant internal exercise conducted. This annual requirement exercises
the NOSC response organization and develops working relationships with other
organizations, including the facility response team, USCG, EPA, other federal
agencies, state officials, local governments, and other responsible parties.
Each year, the scenario can focus on a worst case discharge at a different
regulated facility within the COMXXXX Area of Responsibility (AOR). Observers
from other Navy facilities within the COMXXXX AOR can be invited to attend,
thereby gaining experience while also providing valuable input to the exercise.
Individual facilities are also required to conduct these
exercises annually. Every three years, each facility must conduct a worst case
discharge tabletop exercise. A combined facility/NOSC exercise receives credit
for both the facility and NOSC. Variations on the scenario can test the full
range of NOSC responsibility. For example, a scenario can involve a commercial
barge at a Navy facility, two "gray hulls" not at a facility, or a public
vessel and a commercial ship in a remote region of the COMXXXX AOR.
9.1.4 Equipment Deployment Exercises [top]
There are two categories of Equipment Deployment Exercises.
The first is for equipment owned and operated by the facility. These exercises
are conducted semi-annually. The second is for equipment required when a spill
exceeds the capabilities of a facility. This equipment deployment exercise (at
the NOSC level) involves SUPSALV equipment.
SUPSALV is the Navy's equivalent to an Oil Spill Removal
Organization (OSRO). SUPSALV implements the required equipment exercise
schedule for each geographic area as required by the PREP Guidelines.
Documentation for each completed exercise is sent to every NOSC to meet record
keeping requirements. To maximize the training benefits while minimizing the
costs of exercises, SUPSALV schedules their equipment deployment exercises to
coincide with area exercises, when possible.
9.1.5 Area Exercise [top]
The objectives of the Area Exercise include exercising the
Area Contingency Plan in conjunction with a Facility Response Plan (FRP);
exercising the area and facility spill management teams; exercising the unified
command including federal, state, and local agency participants; and deploying
adequate response equipment for the exercise scenario. Since an Area Exercise
is required in each area only once every three years, it is viewed as the
ultimate test as to whether an area is ready to respond to a major oil spill.
There are a total of 20 Area Exercises per year. Six are led by USCG or EPA and
14 are led by a facility, pipeline, or vessel owner/operator.
The organization that is assigned lead responsibilities for
an Area Exercise is responsible for much of the planning and execution of the
exercise and the associated expenses. Since an Organization gets the same
credit for participating in an exercise as they do for leading the exercise, it
is more cost effective to participate in an exercise lead by another
organization. In an area where no facility owner/operator volunteers to lead an
exercise, the USCG or EPA selects an organization that has not participated in
an Area Exercise to lead an upcoming exercise.
9.1.6 Unannounced Exercise [top]
There are two categories of Unannounced Exercises. The first
is an internal unannounced exercise; the second is a government-initiated
unannounced exercise. The internal unannounced exercise requirement is that one
of the following exercises be unannounced:
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Emergency procedures exercise;
-
Spill management team tabletop exercise; or
-
Equipment deployment exercise.
The government-initiated unannounced exercise is conducted by
the USCG/EPA. These regulatory agencies may conduct four exercises per area per
year. The exercises are limited to four hours in duration and involve equipment
deployment to respond to an average most probable spill scenario. If a facility
has been selected for one of these unannounced exercises, that facility will
not be required to participate in another for at least 36 months from the date
of the exercise.
9.1.7 Drill and Exercise Credit [top]
Credit can be taken for many of the exercises by accurately
documenting actual spill incidents. Refer to Table 9-1 for detailed information
on the type of information that must be documented. Figures 9.1, 9.2, 9.3, and
9.4, a series of forms extracted directly from the PREP Guidelines, are
included herein to illustrate the documentation requirements for exercise
events. At a minimum, the documentation must include the following:
-
Date and time of the exercise;
-
A description of the exercise;
-
The objectives met in the exercise;
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The components of the response plan exercised; and
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Lessons learned.
An important part of the exercise documentation is a listing
of components of the response plan that are exercised. Table 9-2, also
extracted from the PREP Guidelines, provides an explanation of the 15 core
components that must be exercised at least once in a three year period.
9.1.8 Schedule [top]
The drills and exercises schedule is driven by many
variables. One factor is the PREP schedule which is based on the calendar year.
Since credit can be taken for actual events that are properly documented,
actual spills allow facilities to maximize the efficient use of their resources
by satisfying exercise requirements without actually holding a drill. To avoid
the tendency to wait until the end of the requirement period to schedule and
hold many drills (assuming that an actual spill will occur), exercises should
be scheduled on a routine basis and canceled only when an actual spill
supersedes the requirement.
In general, the planning cycle for drills and exercises for
each calendar year commences in July when the National Schedule for PREP Area
Exercises is published in the Federal Register for the upcoming year. SUPSALV
develops tentative schedules based on the Areas that have been selected,
whether the Navy has been selected to lead an Area Exercise, and whether the
Navy will be a participant in any exercises. One schedule addresses SUPSALV
Equipment Deployment Exercises and another identifies dates and locations for
the NOSC Contingency Planning Course. These schedules are available in late
fall of each year.
Notification Exercise
***Currently being developed.****
Figure 9.1: INTERNAL EXERCISE DOCUMENTATION FORM
Emergency Procedures Exercise
***Currently being developed.***
Figure 9.2: INTERNAL EXERCISE DOCUMENTATION FORM
Spill Management Team Tabletop Exercise
****Currently being developed.***
Figure 9.3: INTERNAL EXERCISE DOCUMENTATION FORM
Equipment Deployment Exercise
***Currently being developed.***
Figure 9.4: INTERNAL EXERCISE DOCUMENTATION FORM
****Currently being developed.***
9.2 Response Plan Core Components
This section describes the core components which must be exercised at least once
in a three year period. The following description and Table 9-2 are directly
extracted from the PREP guidelines.
"During each triennial cycle, all components of a plan holder's response plan
must be exercised at least once. The purpose of this requirement is to ensure
that all plan components function adequately for response to an oil spill.
The 15 core components listed below are the types of components that must be
exercised. However, these components may not be contained in each response
plan. As such, the plan holder shall identify those that are applicable from
this list, adding or deleting as appropriate."
Table 9-2
RESPONSE PLAN CORE COMPONENTS* [top]
|
-
Notifications: Test the notifications procedures identified in the Area
Contingency Plan and the associated Responsible Party Response Plan.
-
Staff Mobilization: Demonstrate the ability to assemble the spill
response organization identified in the Area Contingency Plan and associated
Responsible Party Response Plan.
-
Ability to Operate Within the Response Management System Described in the Plan:
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Unified Command: Demonstrate the ability of the spill response organization to
work within a Unified Command.
-
Federal Representation: Demonstrate the ability to consolidate the
concerns and interests of the other members of the Unified Command into a
unified strategic plan with tactical operations.
-
State Representation: Demonstrate the ability to function within the
Unified Command structure.
-
Local Representation: Demonstrate the ability to function within the
Unified Command structure.
-
Responsible Party Representation: Demonstrate the ability to function
within the Unified Command structure.
-
Response Management System: Demonstrate the ability of the response organization
to operate within the framework of the response management system identified in
their respective plans.
-
Operations: Demonstrate the ability to coordinate or direct operations
related to the implementation of action plans contained in the respective
response and contingency plans developed by the Unified Command.
-
Planning: Demonstrate the ability to consolidate the various concerns of
the members of the Unified Command into joint planning recommendations and
specific long-range strategic plans. Demonstrate the ability to develop
short-range tactical plans for the operations division.
-
Logistics: Demonstrate the ability to provide the necessary support of
both the short-term and long-term action plans.
-
Finance: Demonstrate the ability to document the daily expenditures of
the organization and provide cost estimates for continuing operations.
-
Public Affairs: Demonstrate the ability to form a joint information
center and provide the necessary interface between the unified command and the
media.
-
Safety Affairs: Demonstrate the ability to monitor all field operations
and ensure compliance with safety standards.
-
Legal Affairs: Demonstrate the ability to provide the unified command
with suitable legal advice and assistance.
-
Discharge Control: Demonstrate the ability of the spill response
organization to control and stop the discharge at the source.
-
Assessment: Demonstrate the ability of the spill response organization to
provide an initial assessment of the discharge and provide continuing
assessments of the effectiveness of the tactical operations.
-
Containment: Demonstrate the ability of the spill response organization
to contain the discharge at the source or in various locations for recovery
operations.
-
Recovery: Demonstrate the ability of the spill response organization to
recover the discharged product.
-
On-Water Recovery: Demonstrate the ability to assemble and deploy the
on-water recovery resources identified in the response plans.
-
Shore-Based Recovery: Demonstrate the ability to assemble and deploy the
shoreside cleanup resources identified in the response plans.
-
Protection: Demonstrate the ability of the spill response organization to
protect the environmentally and economically sensitive areas identified in the
Area Contingency Plan and the respective industry response plan.
-
Protective Booming: Demonstrate the ability to assemble and deploy
sufficient resources to implement the protection strategies contained in the
Area Contingency Plan and the respective industry response plan.
-
Dispersant Use: Demonstrate the ability to quickly evaluate the
applicability of dispersant use for this incident and implement the protection
strategies contained in the Area Contingency Plan and the respective industry
response plan.
-
In-Situ Burning: Demonstrate the ability to quickly evaluate the
applicability of in-situ burning for this incident and implement a pre-approved
plan from the Area Contingency Plan or develop a plan for use.
-
Water Intake Protection: Demonstrate the ability to quickly identify
water intakes and implement the proper protection procedures from the Area
Contingency Plan or develop a plan for use.
-
Wildlife Recovery and Rehabilitation: Demonstrate the ability to quickly
identify these resources at risk and implement the proper protection procedures
from the Area Contingency Plan to develop a plan for use.
-
Population Protection: Demonstrate the ability to quickly identify health
hazards associated with the discharged product and the population at risk from
these hazards, and to implement the proper protection procedures from the Area
Contingency Plan or develop a plan for use.
-
Bioremediation: Demonstrate the ability to quickly evaluate the
applicability of bioremediation use for this incident, and implement a plan
from the Area Contingency Plan or develop a plan for use.
-
Disposal: Demonstrate the ability of the spill response organization to
dispose of the recovered material and contaminated debris.
-
Communications: Demonstrate the ability to establish an effective
communications system for the spill response organization.
-
Internal Communications: Demonstrate the ability to establish an
intra-organization communications system. This encompasses communications
within both the administrative elements and the field units.
-
External Communications: Demonstrate the ability to establish
communications within both the administrative elements and the field units.
-
Transportation: Demonstrate the ability to provide effective multi-mode
transportation both for execution of the discharge and support functions.
-
Land Transportation: Demonstrate the ability to provide effective land
transportation for all elements of the response.
-
Waterborne Transportation: Demonstrate the ability to provide effective
waterborne transportation for all elements of the response.
-
Airborne Transportation: Demonstrate the ability to provide the necessary
support of all personnel associated with the response.
- Personnel Support: Demonstrate the ability to provide the necessary
support of all personnel associated with the response.
-
Management: Demonstrate the ability to provide administrative management
of all personnel involved in the response. This requirement includes the
ability to move personnel into or out of the response organization with
established procedures.
-
Berthing: Demonstrate the ability to provide overnight accommodations on
a continuing basis for a sustained response.
-
Messing: Demonstrate the ability to provide suitable feeding arrangements
for personnel involved with the management of the response.
-
Operational and Administrative Spaces: Demonstrate the ability to provide
suitable operational and administrative spaces for personnel involved with the
management of the response.
-
Emergency Procedures: Demonstrate the ability to provide emergency
services for personnel involved in the response.
-
Equipment Maintenance and Support: Demonstrate the ability to maintain
and support all equipment associated with the response.
-
Response Equipment: Demonstrate the ability to provide effective
maintenance and support for all response equipment.
-
Support Equipment: Demonstrate the ability to provide effective
maintenance and support for all equipment that supports the response. This
requirement includes communications equipment, transportation equipment,
administrative equipment, etc.
-
Procurement: Demonstrate the ability to establish an effective
procurement system.
-
Personnel: Demonstrate the ability to procure sufficient personnel to
mount and sustain an organized response. This requirement includes insuring
that all personnel have qualifications and training required for their position
within the response organization.
-
Response Equipment: Demonstrate the ability to procure sufficient
response equipment to mount and sustain an organized response.
-
Support Equipment: Demonstrate the ability to procure sufficient support
equipment to support and sustain an organized response.
-
Documentation: Demonstrate the ability of the spill response organization
to document all operational and support aspects of the response and provide
detailed records of decisions and actions taken.
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| *NOTE: The components listed are taken directly from the PREP Guidelines. |
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