Oil Spill Response Drills and Exercises under the FRP new.pdf

Contents‣ Introduction: Why exercise? Authority for Conducting DrillsTroy Swackhammer, OSWER/OEM‣ PART I: Background: Facility Response Plan Regulation &Preparedness FrameworkTed Walden, Region 4‣ PART II: FRP Training and Exercise RequirementsArlene Anderson, Region 1‣ PART III: Implementing a GIUE and “The Good, the Bad,and the Ugly”Arlene and TedDrills and Exercises at FRP Facilities February 20103

Introduction: Authority forConducting Drills/Exercises‣ Oil Pollution Act of 1990• 311(j)(6)(A): Equipment Inspections• 311(j)(7): Tests of Facility Removal Capability‣ National Contingency Plan (NCP)• Area Contingency Plan (ACP)• Facility Response Plan (FRP) regulation requiresfacility response drills/exercises• Program must follow National Preparedness for ResponseExercise Program (PREP) (or alternative format approved bythe Regional Administrator) [112.21(c)]‣ National Response FrameworkDrills and Exercises at FRP Facilities February 20105

Introduction: Authority forConducting Drills/Exercises‣ National Preparedness for ResponseExercise Program (PREP)• Requires unannounced exercises by EPA,U.S. Coast Guard (USCG), MineralsManagement Services (MMS), and Pipelineand Hazardous Materials Safety Administration(PHMSA (listed as RSPA in PREP))Drills and Exercises at FRP Facilities February 20106

Introduction: Authority forConducting Drills‣ EPA Regulated Facilities (40 CFR part 112)• Non-TransportationTransportation-Related Onshore Facilities andCertain Offshore Facilities‣ USCG Regulated Facilities (33 CFR parts 154 and 155)• Vessels and Marine-TransportationTransportation-Related FacilitiesRSPA (now PHMSA)‣ RSPA• Pipelines(now PHMSA) Regulated Facilities (49 CFR part 194)‣ MMS Regulated Facilities (30 CFR part 254)• Offshore Facilities (i.e., located seaward of the coast line)‣ Complexes-Subject to Two or More Agencies• Agencies must coordinate efforts to avoid repeatingexercisesDrills and Exercises at FRP Facilities February 20107

PART IBackground: Facility ResponsePlan Regulation &Preparedness Framework8

Oil Pollution Act of 1990 andClean Water Act‣ Section 311(j)(5) of CWA, amended by OPA1990‣ A Facility Response Plan shall:• (i) be consistent with the requirements of the NationalContingency Plan and Area Contingency Plans;• (ii) identify the qualified individual having full authority toimplement removal actions, , and require immediatecommunications between that individual and theappropriate Federal official and the persons providingpersonnel and equipment pursuant to clause (iii);Drills and Exercises at FRP Facilities February 20109

Oil Pollution Act of 1990 andClean Water Act (cont’d)• (iii) identify, and ensure by contract or other meansapproved by the President the availability of, privatepersonnel and equipment necessary to remove to themaximum extent practicable a worst case discharge(including a discharge resulting from fire or explosion), andto mitigate or prevent a substantial threat of such adischarge;• (iv) describe the training, equipment testing, periodicunannounced drills, , and response actions of persons onthe vessel or at the facility, to be carried out under the planto ensure the safety of the vessel or facility and to mitigateor prevent the discharge, or the substantial threat of adischarge;• (v) be updated periodically; and• (vi) be resubmitted for approval of each significant change.Drills and Exercises at FRP Facilities February 201010

EPA’s s FRP Regulation‣ 40 CFR part 112, Sections 112.20 and 112.21,Appendices C - F‣ §112.20- Requirements to prepare plans to respond toworst-case discharge of oil• Substantial harm criteria include:• 42,000 gallons or more in oil storage capacity and transfers oil overwater to/from vessel• 1 million gallons or greater in oil storage capacity, and one or more ofthe following:• Inadequate sized secondary containment• Could impact fish and wildlife and sensitive environments• Could shut down a public drinking water intake• Had reportable discharge of 10,000 gallons or more in last 5 years• Other factors as determined by Regional Administrator• EPA must approve the plans for significant and substantial harmfacilities.Drills and Exercises at FRP Facilities February 201011

EPA’s s FRP Regulation (cont’d)‣ §112.21- Requirements for training and program ofdrills/exercises• Training (§112.21(b))(• Train personnel involved in oil spill response activities• Recommendation that training program be based on USCG’sTraining Elements for Oil Spill Response• Alternative program may be acceptable, subject to approval by theRegional Administrator• Facility Response Drills/Exercises (§112.21(c))(• Develop a program of drills/exercises, including evaluationprocedures• Program either follows National Preparedness for ResponseExercise Program (PREP) will satisfy the requirement – commonor…• Alternative exercise program may be acceptable, subject toapproval by the Regional Administrator – not commonDrills and Exercises at FRP Facilities February 201012

Universe of FRP Facilities3811641844612583021362571,608499Current Count: approx. 4,250 FRP Plan holdersDrills and Exercises at FRP Facilities February 201013

FRP Facility CharacteristicsIndustry Sectors, by number of FRPFacilities*• Electric power generation, transmissionand distribution (30%)• Petroleum and petroleum productswholesalers (23%)• Petroleum and coal productsmanufacturing (7%)• National security and international affairs(6%)• Grain and oilseed milling (6%)• Warehousing and storage (4%)• Pipeline transportation (3%)• Other sectors (23%), including• Basic chemical manufacturing (2%)• Pulp/paper manufacturing (2%)• Support for air/rail/water transportation (2%)• Oil and gas extraction (1%)AverageFacility total storage capacity (gal)• Electric power generation, transmissionand distribution (10.4 M)• Petroleum and petroleum productswholesalers (11.2 M)• Petroleum and coal productsmanufacturing (23.5 M)• National security and international affairs(5.2 M)• Grain and oilseed milling (4.7 M)• Warehousing and storage (20.6 M)• Pipeline transportation (25.5 M)• Others sectors, including• Basic chemical manufacturing (1.9 M)• Pulp/paper manufacturing (2.4 M)• Support for air transportation (10.8 M)• Support for water transportation (4.5 M)• Support for rail transportation (1.4 M)• Oil and gas extraction (6.6 M)* Based on 1,872 facilities (of 4,143 facilities total) with available NAICS/SIC sector and storage capacity informationDrills and Exercises at FRP Facilities February 201014

NationalSpill Contingency PlanningFrameworkNational Contingency PlanNational Response Team16 Federal AgenciesRegionalArea Contingency PlansRegional Response TeamFederal agencies, State and Local governmentArea 1 Area 2 Area … Sub-AreasLocal / FacilityFacility Response PlansFacility owner/operatorSpill response contractorsFacility 1 Facility 2 Facility …Drills and Exercises at FRP Facilities February 201015

Spill Contingency PlanningDrills and ExercisesNational‣ Spill Of National Significance (SONS)ExerciseRegional‣ Area ExerciseLocal / Facility‣ Facility ExerciseDrills and Exercises at FRP Facilities February 201016

Area Exercise‣ Purpose: : Evaluate the entire pollution responsemechanism in a given geographic area toensure adequate response preparedness.‣ Involve government and industry responders.‣ Triennial schedule maintained by U.S. CoastGuard• Schedule published in the Federal Register• Based on calendar yearsDrills and Exercises at FRP Facilities February 201018

Facility Exercise‣ Purpose: : Demonstrate timely, properlyconducted response that follows the FRPwith adequate equipment for a smalldischarge.• Internal Exercise: : Initiated by facilityowner/operator• External Exercise: : Government-initiated (e.g.,GIUE)Drills and Exercises at FRP Facilities February 201019

FRP Content1. Emergency Response Action Plan (ERAP)2. Facility Information3. Information about Emergency Response4. Hazard Evaluation5. Response Planning Levels6. Discharge Detection Systems7. Plan Implementation8. Self-Inspection, Drills/Exercises, and ResponseTraining9. Diagrams10. Security Systems11. Response Plan Cover SheetDrills and Exercises at FRP Facilities February 201020

FRP Spill ResponsePlanning LevelsPlanningscenarioSmallMediumOil volume2,100 gallons or lessGreater than 2,100 gallons but less than or equal to 36,000 gallonsor 10 percent of largest tank at facility, whichever is lessWorst CaseCalculated based on type of facility, number of containers, whethersecondary containment is adequate, and capacity of largestaboveground storage tank (AST).Often the capacity of the largest AST.Drills and Exercises at FRP Facilities February 201021

Scenario Description‣ For each scenario, address factors that affect responseefforts, including:• Spill volume• Material discharged• Location of discharged material• Direction of spill pathway• Proximity to wells, waterways, drinking water intakes, fish and wildlife,and sensitive environments• Weather or aquatic conditions• Likelihood that the discharge will travel offsite• Probability of a chain reaction of failures• Available remediation equipment• Circumstances and contributing factors (e.g. loading/unloading, facilitymaintenance, facility piping, pumping stations and pumps, bulk storage scontainers, vehicle refueling, age and condition of facility andcomponents)Drills and Exercises at FRP Facilities February 201022

Response Capability: General‣ Demonstrate availability of response personnel andequipment necessary to respond within the specified times‣ Resources may be ensured by “contract or other approvedmeans”• Written contractual agreement with Oil Spill Removal Organization(OSRO)• Written certification by the owner or operator that the necessarypersonnel and equipment are available to respond to a dischargewithin appropriate response times• Active membership in local or Regional cooperative• Other arrangement approved by the RA upon request by the owneror operator‣ Spill Response Planning Tiers are specified in Appendix Eto 40 CFR part 112Drills and Exercises at FRP Facilities February 201023

Response Capability: Small DischargeAppendix E, Section 3.3:The response resources shall, as appropriate, include:EquipmentCapacityTimelineCitationContainmentBoom*1,000 feet orTwice the length of the largestvessel that regularly conducts oiltransfers to or from the facilityMeans of deployingwithin 1 hour of thediscovery of an oildischargeAppendix E,Section 3.3.1(whichever is greater)Oil RecoveryDevicesEffective daily recovery capacityequal to the amount of oildischarged in a small dischargeor greaterAvailable at the facilitywithin 2 hours of thediscovery of an oildischargeAppendix E,Section 3.3.2Oil StorageCapacityDaily storage capacity equivalentto twice the effective dailyrecovery capacity, unless theowner/operator can show that alower capacity is adequateAvailable at the facilityAppendix E,Section 12.2* Other means of containment may be appropriate for inland facility (see next)Drills and Exercises at FRP Facilities February 201024

Containment Boom Alternatives‣ “As Appropriate”‣ For example:• Alternative strategy may be more appropriate forinland facilities, where spill pathway could be a drydrainage pathway or tributary• Alternatives include:• Underflow dams• Temporary containment dams (soil, etc.)• Inflatable diaphragmsDrills and Exercises at FRP Facilities February 201025

Alternative Methods‣ Open creek‣ Difficult access‣ Debris and vegetationuncontrolled‣ Requires differenttype of boomDrills and Exercises at FRP Facilities February 201026

Addressing alternative methods‣ Access anddeployment ability‣ Appropriateequipment for theenvironment andaccess pointDrills and Exercises at FRP Facilities February 201027

Alternative Methods‣ City re-routing routing thedrainage of creek‣ Effluent dischargeupgrade by the facility‣ Spill gate at dischargepoint‣ Access to deploymentarea improvedDrills and Exercises at FRP Facilities February 201028

PART IIFRP Training, Inspectionsand ExerciseRequirements29

Response Training‣ Must provide adequate training for QI, facility personnel,and spill management teams‣ Training scope examples:• QI and Facility Personnel training• Notification procedures, communication systems, internal responseorganizations• Procedures for mitigating a discharge or threat of a discharge,including site safety and security• Hazard recognition and evaluation and emergency and evacuationprocedures• Spill Management Teams• Procedures for use of facility response equipment• Information on oil containment, oil recovery methods and devices,equipment limitations and uses, use of dispersants, waste storage e anddisposal methods‣ Training is reinforced by drills/exercisesDrills and Exercises at FRP Facilities February 201030

‣ QI InterviewFRP-related InspectionActivities• Evaluate overall knowledge of the person(s) identifiedas QI or key personnel in the Plan and who would becharged with directing/performing response actions.‣ Field inspection• Verify the implementation of the preparednessmeasures described in the FRP.‣ Government-Initiated Unannounced Exercise• Verify that facility is able to activate its planand respond to a simulated discharge incident.Drills and Exercises at FRP Facilities February 201031

QI Interview‣ Verify that QI understands responsibilities and is the personresponsible for implementing the facility’s s FRP.‣ Discussion topics, regarding the handling of a worst-case discharge:• Discharge discovery and assessment• Notifications and mitigation measures• Temporary storage of recovered product and contaminatedmaterials• Treatment and disposal of contaminated materials• Roles and responsibilities of response team and other facility or ocontractor employees• Incident command and control• Training, exercise, and evaluationDrills and Exercises at FRP Facilities February 201032

Field Inspection‣ Hazard evaluation and vulnerability analysis• Are assumptions reasonable given facility conditions? Reviewdischarge history, areas where discharges could occur, anticipatedspill pathway (e.g., storm drains)• Are there vulnerable sites not considered in the plan (e.g., waterintakes, residential or recreational areas, wetlands)?‣ Worst-case discharge scenario and planned responseactions• Are assumptions regarding volume and failure mode reasonable?Confirm tankage and secondary containment• Have there been changes in the facility characteristics not reflectedectedin the current version of the Plan?Drills and Exercises at FRP Facilities February 201033

Field Inspection (cont’d)‣ Spill response equipment• Type and amount available at the facility? Adequate quantities?Readily accessible? In working condition?• Contract with Oil Spill Removal Organization? Is it current?‣ Discharge detection equipment and procedures• Review logs and records of equipment inspection, assessemployee knowledge of required procedures‣ Security measures• Implementation of emergency cut-offs, fencing, locking of valves,and lighting, as required under the SPCC rule.Drills and Exercises at FRP Facilities February 201034

Facility Drills and Exercises‣ Use the National Preparedness and Response ExerciseProgram (PREP) guidelines or equivalent• Combination of internal and external exercises• Range of exercises covering all aspects of the FRP over a 3-year 3cycle• Satisfies all OPA-mandated Federal Oil Pollution Response ExerciseRequirements• All alternative programs must be approved by the RegionalAdministrator prior to implementation‣ Facility receives credit for Area or Facility-specific exercisesfor actual response to a spill if:Plan was utilized for responsePREP objectives were metThe response was properly evaluated, documented, and self-certifiedDrills and Exercises at FRP Facilities February 201035

PREPPREP document is available electronically at: http://www.au.af.mil/au/awc/awcgate/uscg/prep_gid.pdf36Drills and Exercises at FRP Facilities February 2010

PREP Exercise ComponentsElementFrequency*InitiatingAuthorityNotesQI NotificationExercisesQuarterlyFacility owneror operatorEmergencyProceduresExercisesQuarterlyFacility owneror operatorOptional: can be used by facilities as anunannounced exercise.Spill ManagementTeam TabletopExerciseAnnuallyFacility owneror operatorAt least one exercise every 3 years mustinvolve a worst-case discharge scenario.EquipmentDeploymentExercisesSemiannuallyFacility owneror operatorIf OSRO-owned equipment is identified inthe Plan, the OSRO equipment must alsobe deployed and operated. OSRO mustprovide documentation to facility owner oroperator.Government-TrienniallyEPA, RSPA,If successfully completed, the facilityInitiatedUSCGcan only be subject to a GIUE onceUnannouncedevery 3 years.Exercises* At least one exercise per year must be unannounced.37Drills and Exercises at FRP Facilities February 2010

Coordination‣ Coordination with other agencies duringdrill/exercise‣ Regulatory jurisdiction vs. responsejurisdiction‣ Region 1 experience coordinating withU.S. Coast GuardDrills and Exercises at FRP Facilities February 201038

PART IIIImplementing a GIUE39

Preparing for a GIUE‣ Outreach to potential candidate FRP facilities• General Awareness outreach• Letters, mailings• Information sessions, seminars, webcasts• Emails• Attendance at conferences and trade shows• No advance notification of potential for a GIUEDrills and Exercises at FRP Facilities February 201040

Preparing for a GIUE (cont’d)‣ Selection of target facility• EPA already has a list of FRP planholders• Significant and substantial harm facilities• Substantial harm facilities• Candidate facilities:• New facilities that have never been drilled/exercised• Facilities that have failed an earlier drill/exercise• Facilities that have not performed a drill/exercise in the last 3 years‣ PREP limits the number of GIUEs to 10 percent of FRPplanholders per Region per year.• Coordinate with other regulating agencies regarding complexfacilities that may participate in upcoming Area Exercises (e.g.,PREP schedule).Drills and Exercises at FRP Facilities February 201041

Planning a GIUE‣ Identify and invite GIUE observers/evaluators• Other EPA inspectors• State environmental agency representative• USCG, or other regulatory agencies, if facility is a “complex”• USCG FRP Rule (33 CFR 154) – Applies to deepwater ports andmarine transportation-related on-shore facilities that are capable oftransferring to/from vessel with 250 barrels (10,500 gallons) or more ofoil storage capacity• DOT (49 CFR 130) – Applies to transportation of oil by motor vehiclesand rolling stock• RSPA (49 CFR 194) – Applies to onshore oil pipelines• MMS (30 CFR 254) – Applies to offshore facilities (located seaward ofthe coast line)• Superfund Technical Assistance and Response Team (START)contractor or other regional contractor support‣ EPA remains the lead evaluator if it initiated theexerciseDrills and Exercises at FRP Facilities February 201042

Planning a GIUE (cont’d)‣ Develop drill/exercise scenario• Review plan and identify circumstances of smalldischarge• Review map, location of sensitive environments, drinkingwater intakes, areas to be protected• Review Emergency Response Action Plan (ERAP), pre-designated deployment locations, pre-deployedequipment• Determine timing of exercise (review tidal charts toassess current direction)• Be prepared for shift changes at the facilityDrills and Exercises at FRP Facilities February 201043

Spill Scenario‣ Typically taken from the Plan‣ Use “small discharge” of 2,100 gallons or less• Discharge incident may involve a larger total volume on-site, ofwhich 2,100 gallons escapes to water.‣ Specify• Tank• Type of product• Volume discharged and volume in water• Weather conditions, if assuming different from conditions at timeof the exercise‣ Identify• Impacted areas based on NOAA maps• Chain reactions information• Flow pattern based on site topography• Ingress and egress to the facility for evacuation and responseDrills and Exercises at FRP Facilities February 201044

Safety Considerations‣ Follow facility safety procedures• Visitor sign in procedures• Mandatory safety video on process hazards and facilityevacuation plan• Proper attire (footwear, helmet, safety glasses, personal flotationdevice, NOMEX clothing if required by the facility, etc.)• Inspector should bring own safety equipment‣ Crucial that drill/exercise be conducted in a safe manner• EPA representative can terminate drill at any time• Hazardous conditions may include severe adverse weather oremergency situation at the facility or neighboring area• Should be addressed in FRP• If you determine that the drill/exercise is causing hazardousconditions, you should call a time out and confer with the facilityityowner/operatorDrills and Exercises at FRP Facilities February 201045

EPA Equipment List‣ Two-way way radios or cell phones‣ Hard hat, safety boots, safety glasses‣ Agency credentials‣ Camera/video recorder‣ Binoculars‣ Checklist/logbook‣ Copies of relevant sections of FRP (e.g., map showinglocation of tanks, sensitive areas and drinking waterintakes, direction of water flow, etc.)• Need to compare copy at EPA with most current version atfacility‣ GIUE drill letter with description of scenario to beexercised‣ Some facilities (such as refineries) require NOMEX(flame-resistant clothing) be wornDrills and Exercises at FRP Facilities February 201046

GIUE Scheduling/Costs‣ Exercise is meant to be unannounced• Exercise must proceed even if the QI happens to beon vacation (an alternate QI is often identified in theplan)• However, , exercise may be cancelled if existingconditions present a safety concern‣ Facility is responsible for costs of performing thedrill/exercise, including:• Internal costs of facility employees and equipmentinvolved in the response• External costs associated with contractor-suppliedequipment and resources (OSRO)Drills and Exercises at FRP Facilities February 201047

Initiate the GIUE‣ Inform the QI that you are at the facility toconduct an unannounced exercise‣ Provide GIUE Drill Letter, if used• Certain regions send letters in advance to all regionalfacilities, some do not provide letters‣ Go over exercise guidelines with QI‣ Start the exercise clock• Discharge has just been discovered• Oil has already reached water‣ Overall exercise duration is up to 4 hoursDrills and Exercises at FRP Facilities February 201048

During the GIUE‣ Evaluate command post and response activities‣ Intervene only for issues of health or safety• Examples: personal flotation devices, imminent harm topersonnel or third party‣ Only QI should modify scenario exercised when siteconditions are inconsistent with scenario described in theplan• Example: new construction which changes path of a waterway• QI should identify a probable scenario and exercise that specificscenarioDrills and Exercises at FRP Facilities February 201049

Evaluating GIUE Performance‣ PREP Evaluation Factors:Conducting proper notificationsArrival of containment boom as specified in the FRP withinone hour of detection of the discharge and subsequentsuccessful deployment (“boom(in the water”);Arrival of oil recovery devices as specified in the approvedresponse plan within two hours of detection of the dischargeand the subsequent successful operation/simulated recovery;Demonstrating the availability of adequate storage capacityfor recovered oil; andProperly conducting the exercise considering the size of asmall discharge including skill and competency of respondersand material readiness of response equipment.Drills and Exercises at FRP Facilities February 201050

‣ Command Post• Incident controlGIUE Evaluation• Are proper notifications conducted in a timely fashion?• Notification to NRC, state, facility management, etc. as outlinedin the FRP and ERAP• Has the spill response team and/or OSRO been activated?• When was response team/OSRO activated? When did theyarrive? Can they deploy equipment?• Are communications with response personnel and otherfacility personnel effective?• Are the ERAP and/or FRP being used?Drills and Exercises at FRP Facilities February 201051

Incident ControlDrills and Exercises at FRP Facilities February 201052

Boom Deployment‣ GIUE performanceevaluation criteria (PREP):• Sufficient containment boomand means for deploying itwithin one hour of discoveryof the spill.• 1,000 feet of boom or twice thelength of vesselsloading/unloading at the facility.• Must be containment boom, notmade of absorbent materials.• At inland facilities, boom maybe deployed in dry ditches.Drills and Exercises at FRP Facilities February 201053

Boom Deployment (cont’d)‣ Boom elements• Above-water freeboard• Flotation device• Below-waterwater “skirt”• Longitudinal support‣ Selection considerations• River flowrate, current, and tidal information todetermine if appropriate boom can hold the pressureand not fail• Length of deployment/goal of booming operation• Contain, deflect, protect• Anchoring method• Boat safety operations and capabilitiesDrills and Exercises at FRP Facilities February 201054

Boom Deployment (cont’d)‣ Commercial boom types• Fence boom• Curtain boom• External tension memberboom (uncommon)‣ A sorbent boom is not acontainment boom• Can be used for finalpolishing, to remove smalltrace of oil or sheen, or asbackup to containmentboomDrills and Exercises at FRP Facilities February 201055

Boom Deployment (cont’d)‣ Boom Functions• Protect (shorelines, creeks, wetlands, water intakes,etc.)• Deflect (move oil to collection point)• Contain (hold oil within collection location)‣ Booming Strategies• Containment booming (contain)• Exclusionary booming (protect)• Diversionary booming (deflect)• Shore seal booming (protect)‣ Other Strategies• Berms, underflow dams (contain)Drills and Exercises at FRP Facilities February 201056

Containment BoomingDrills and Exercises at FRP Facilities February 201057

Exclusionary BoomingDrills and Exercises at FRP Facilities February 201058

Inland “Small Stream” Containment‣ Containment dams‣ Underflow dams‣ Inflatable diaphragms‣ Spill gatesDrills and Exercises at FRP Facilities February 201059

Berms, Underflow DamsDrills and Exercises at FRP Facilities February 201060

Spill GatesDrills and Exercises at FRP Facilities February 201061

Boom Deployment Problems‣ Can facility personnel and/or OSROdeploy the boom?• Do they have the requiredequipment?• Do they have access to boomdeployment sites and anchor points?‣ Is the boom properly deployed?• Proper anchoring, proper flotation,proper tension• No twists or gaps‣ Is the boom properly rated for thestream flow rate?‣ Is the boom maintained in a way toallow for rapid deployment?‣ Does the facility have the appropriatehardware needed to link boomsections and stake the boom?Drills and Exercises at FRP Facilities February 201062

Boom FailuresDrills and Exercises at FRP Facilities February 201063

Boom Failures (cont’d)????Drills and Exercises at FRP Facilities February 201064

Oil Recovery Devices‣ GIUE performance evaluation criteria:• Oil recovery devices available within 2 hours of discovery of the spill• Must have effective daily recovery capability equal to amount of oilreleased in a small discharge (i.e., 2,100 gallons)• Deployed and ready to start oil recovery• Actual pumping of water is not requiredDrills and Exercises at FRP Facilities February 201065

Oil Recovery Devices:Skimmers‣ Suction‣ Weir• Best in calm water• Low recovery oil/water ratio• Low to medium viscosity oilDrills and Exercises at FRP Facilities February 201066

Oil Recovery Devices:‣ Rope mopSkimmers (cont‣ Disc(cont’d)• Low to medium viscosity oil• Good in debris and ice conditions• Shallow water• Medium viscosity oils• Higher oil/water ratio• Calm and shallow watersDrills and Exercises at FRP Facilities February 201067

Oil Recovery Devices:Skimmers (cont’d)‣ Drum‣ Belt Type Skimmer(e.g., Chain Brush)• Medium viscosity oils• Good debris handling capability• Calm and shallow waters• Medium to heavy oils• Excellent debris handling• Fast deploymentDrills and Exercises at FRP Facilities February 201068

Oil Recovery Devices: Others‣ Vacuum TruckDrills and Exercises at FRP Facilities February 201069

Provisions for Storage ofRecovered Oil‣ GIUE performance evaluation criteria:• Oil storage capacity for recovered oilymaterial equivalent to twice the effective dailyrecovery capacity required on-scene, or 4,200gallons per day.Drills and Exercises at FRP Facilities February 201070

Other Response Actions‣ Preventing further contaminationDrills and Exercises at FRP Facilities February 201071

Evaluating GIUE Performance‣ “Measure of an effective unannouncedGIUE is the overall ability of theresponders identified in the FRP to rapidlyand effectively control a small dischargewith particular attention to those actionsthat afford the best chances to control aspill and minimize its impact in the first fewhours of the incident.” - PREP Guidelines, August2002.Drills and Exercises at FRP Facilities February 201072

Evaluating GIUE Performance (cont’d)‣ “EPA personnel will evaluate whether theresponse equipment specified in the Planarrives at the specified times… Whetherthe containment boom and recoverydevices arrive precisely at the specifiedtimes is less relevant than the overallconduct of the exercise and the successfulachievement of the exercise’s s objectivesdescribed in PREP” - PREP Guidelines, August2002.Drills and Exercises at FRP Facilities February 201073

GIUE Evaluation‣ Debrief with QI/facility personnel and OSROs.‣ Consequences of pass/fail• A facility that successfully completes a GIUE cannot be subjectto another GIUE for 3 years• Failure of a GIUE may require the planholder to participate inadditional unannounced exercises, revise the existing responseplan, or both.• In the event of GIUE failure, the Region may choose to performfurther inspection of the facility.• In certain instances, EPA may revoke approval of FRP on thebasis of GIUE performance until changes are made.• Based on failure of a GIUE, the FRP coordinator mayrecommend to upgrade the facility to a significant and substantialalharm facility.‣ Follow-up• Verify implementation of recommended improvements.Drills and Exercises at FRP Facilities February 201074

Case Discussion: GIUE Failure‣ Reminder:• Goal is to observe how a facility implements their FRP; we areevaluating their performance against their FRP.‣ Field Observations:• Contractor identified in the Plan did not arrive at the facilityduring the duration of the exercise.• Facility personnel or OSRO were unable to deploy acontainment boom due to access issues, inappropriateequipment, lack of training with equipment.• Copy of the FRP was not available at the facility, so personnelcould not implement the Plan.• Facility lacked communications equipment identified in the FRP• Site selected for boat and boom placement was not consistentwith the FRP.• The Plan contained incorrect telephone numbers for spillnotifications (state agency, NRC, local responders). Facility wasunable to notify appropriate entities.Drills and Exercises at FRP Facilities February 201075

VideoExamplesThe Good, theBad and theUgly…76

Questions?Drills and Exercises at FRP Facilities February 201077