Marine safety Unit Savannah CDR Joseph Loring

National Preparedness for Response Exercise Program Guidelines (PREP) 2016 Summary: Reviewing major revisions to the PREP Guidelines Contributor: LT Jessica Wissmann, D9 DRAT Updated by DRAT: April 14, 2016

Table of Contents Terminology 2016 Additions Plan Holder Exercises Planning for Area FE/FSE Shared Credit for OSRO deployment exercises Updated by DRAT: April 14, 2016

Terminology PREP 2002 PREP 2016 National Scheduling Coordination Committee (NSCC) Oil Spill Removal Organization (OSRO) Spill Management Team (SMT) Renamed to: PREP Compliance, Coordination, and Consistency Committee (PREP 4C). OSRO Definition changed to better describe response resources and services Incident Management Team (IMT) PREP 4c: made changes to terminology to align with Homeland Security Exercise and Evaluation Program (HSEEP) - OSRO: includes source control, all spill countermeasures, and supporting services in order to adequately contain, secure, recover or mitigate a discharge of oil. Changed to be more inclusive to reflect that multiple response options are available and to ensure all the needs of involved parties regarding PREP are met. New: Oil Spill Removal Organization (OSRO). An OSRO is an entity that provides oil spill response resources to remove oil from the environment or mitigate associated impacts. OSROs include, but are not limited to, providers for source control, mechanical recovery, dispersants, bioremediation, in‐situ burning or other spill countermeasures, as well as any for‐profit or notfor‐ profit contractor, cooperative, or in‐house provider of oil spill removal resources established in a geographic area to provide oil spill removal resources required by regulation. Offshore Facility (33 U.S.C. § 1321(a)(11)). SMT -> IMT changed to reflect regulation terminology and align with Homeland Security Exercise and Evaluation Program (HSEEP). Example SMT-TTX is now IMT exercise Updated by DRAT: April 14, 2016

Salvage and Marine Firefighting (SMFF) 2016 Additions Salvage and Marine Firefighting (SMFF) The PREP Guidelines now include guidance for including SMFF providers and equipment into a plan holder's exercise program, in response to regulatory requirements at 33CFR155.4052. Non-tank Vessel (NTV) The PREP Guidelines now include guidance for exercises for NTV response plans, in response to regulatory requirements at 33 CFR 155.5060. Updated by DRAT: April 14, 2016

2016 Additions Use of Alternative WCD Scenarios during IMT Exercises: The draft Guidelines have been revised to allow for alternative WCD scenarios to be exercised. Some Facilities and Complex Facilities have more than one possible WCD, for example a storage tank and a pipeline section. Such plan holders are encouraged to consider adverse environmental impacts and to exercise more than just their largest volume WCD scenario. Updated by DRAT: April 14, 2016

2016 Additions The draft Guidelines have been updated to ensure consistency among agencies regarding the frequency of equipment deployment exercises. The frequency of deployment exercises for equipment that is owned by the facility, operated by Oil Spill Removal Organizations (OSROs), and listed in EPA-regulated plans has been changed from annually to semi-annually. This change will ensure the readiness of equipment that is not regularly used in actual spill response operations. Updated by DRAT: April 14, 2016

2016 Additions Oil Spill Surveillance and Tracking Systems USCG and BSEE regulations require plan holders to ensure available resources for oil spill surveillance and tracking. The Guidelines specifically identifies oil spill surveillance and tracking systems as a type of response equipment to be exercised during internal equipment deployment exercises. This will test the plan holders abilities to effectively support and direct other response activities and equipment, such as the use of dispersants, in-situ burning, mechanical recovery, shoreline protection, or wildlife recovery. Updated by DRAT: April 14, 2016

Plan Holder Exercises PREP 2002 PREP 2016 “Internal” exercises “External” exercises Renamed to “Plan Holder” exercises to evaluate industry specific oil spill response plans from regulated vessels, pipelines, railcars and facilities (Includes DOT/PHMSA & BSSE) “External” will no longer be used to describe an exercise in PREP Plan holder exercises may now involve both internal and external entities and may be initiated by either government or plan holder, but all are used as part of the plan holders tri-annual exercise cycle. NTVRP and SMFF IAW 33 CFR 153 update Updated by DRAT: April 14, 2016

Appendix B created to address confusion between internal vice external. Review Use handout Updated by DRAT: April 14, 2016

Area Level Exercises PREP 2002 PREP 2016 Single Functional Tests Functional or Full Scale Exercise (FE/FSE) Area exercise tri-annual Now referred to as “drills” FE/FSE quadrennial * NOTE REGARDING EXERCISE CYCLES* The exercise cycle for facility and vessel response plans is three years (codified in federal regulations). The Area exercise cycle is not addressed in regulations and by policy is set at four years. Single functional tests such as notification and equipment deployments Drills may be discussion based exercises to include TTX, workshops and seminars Triennial cycle includes, quarterly QI notification, annual remote assessment and consultation, quarterly emergency procedures, annual IMT (1 in 3 WCD), Annual shore based salvage exercises, annual plan holder initiated unannounced, semi annual plan holder announced SMFF, equipment deployment Updated by DRAT: April 14, 2016

Planning for Area FE/FSE PREP 2002 PREP 2016 Government Led or Industry Led Joint responsibility of all members of Area Committee and industry plan holders FE/FSE must be a minimum of ICS Type 3 Incident Joint exercises design team composed of all the exercise planning partners to develop scope, scenario and objectives Design team comprised of representatives from Federal, State, Local, industry plan holder and tribal entities Updated by DRAT: April 14, 2016

Shared Credit for OSRO deployment exercises PREP 2002 PREP 2016 Accepted practice for OSRO to deploy equipment for all their Industry Plan Holders Exercise credit can be shared between plan holders for the deployment of that specific equipment / personnel specific to location (COTP, RRT, EPA ACP or EPA subarea) Additional information in Guiding Principles Section Locations include COTP zone, Regional Response Team (RRT) region, EPA ACP or EPA subarea provided each plan holder has a contract for the use of the equipment and personnel exercised If all plan holders are taking credit for deployment it shall be done no less then annually! Updated by DRAT: April 14, 2016

QUESTIONS? Updated by DRAT: April 14, 2016