2016 NATIONAL PREPAREDNESS

FOR

RESPONSE EXERCISE PROGRAM

(PREP)

GUIDELINES

DEPARTMENT OF HOMELAND SECURITY U.S. Coast Guard

ENVIRONMENTAL PROTECTION AGENCY

DEPARTMENT OF TRANSPORTATION Pipeline and Hazardous Materials Safety Administration

DEPARTMENT OF THE INTERIOR Bureau of Safety and Environmental Enforcement

- VERSION 2016.1 -

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To the “Response Community”:

This is the third revision since August 1994 to the Preparedness for Response Exercise Program (PREP), when we set out together to design an effective and coordinated exercise program under the Oil Pollution Act of 1990. As before, the revisions are the result of an open dialogue and the incorporation of lessons learned over the past two decades. We considered issues identified in written comments received by the Department of Homeland Security in response to regulatory docket IDs: USCG-2011-1178 and BSEE-2014-0003, which announced the upcoming revision. The PREP will evolve as government and industry continue to meet the challenges of protecting public health, welfare, and the environment. We look forward to working with all parties as we continue to improve the PREP process.

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Using the PREP Guidelines is voluntary; they are not regulations. Although agency regulations state that compliance with the PREP Guidelines will satisfy certain regulatory requirements, you are not required to use the PREP Guidelines to satisfy those requirements. You may choose an alternative approach if the approach satisfies the requirements of applicable statutes and regulations. Where provisions of the PREP Guidelines state that a plan holder is required to undertake a certain action, for instance the provisions that state a plan holder “must” undertake actions, those provisions presume that the plan holder is voluntarily using the PREP Guidelines to satisfy the existing regulatory requirements for oil spill response plan exercises specified within the relevant agency-specific Code of Federal Regulations.

Some of the regulatory requirements discussed in this document involve collections of information. An agency may not conduct or sponsor, and a person is not required to respond to, an information collection that does not display a currently valid Office of Management and Budget (OMB) control number. OMB control numbers for regulatory requirements can be found in each agency's regulations or Federal Register notices. For example:

Coast Guard vessel and facility response planning requirements, including exercise requirements, are covered by OMB control number 1625-0066.

Environmental Protection Agency requirements are covered by OMB control number 2050- 0135.

Pipeline and Hazardous Materials Safety Administration requirements are covered by OMB control number 2137-0589.

Bureau of Safety and Environmental Enforcement oil spill response requirements for facilities located seaward of the coastline are covered by OMB control number 1014-0007.

See www.reginfo.gov for the current approval status of each collection.

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RECORD OF CHANGES Affected Version Date Description of Changes Section

2016.1 N/A 7Jun17 Added Record of Changes section

Removed language referencing the annual, per vessel requirement for a remote assessment and 2016.1 1.2 7Jun17 consultation exercise.

2016.1 1.4 29May18 Added definition of “annual”

Changed language requiring annual remote assessment and consultation exercise per vessel to a triennial requirement on a per plan basis

Removed language referencing “per vessel per year.” 2016.1 2.3.2 7Jun17 Removed redundant language concerning the applicability to vessels operating outside of U.S. waters.

Removed language requiring one exercise per year be conducted during non-business hours. Modified language to be consistent with parent section 2.3.2. Annual exercise on a per vessel basis 2016.1 2.3.2.1 7Jun17 changed to triennial requirement on a per plan holder basis. Removed non-amplifying/redundant language. Removed confusing and unnecessary language regarding vessel response plans and barge 2016.1 2.3.2.2 7Jun17 custodians and inserted language emphasizing the exercise be conducted in accordance with the approved VRP. Removed language specifying annual remote assessment and consultation exercises for vessel or 2016.1 2.3.8.2 7Jun17 barge fleet. Now reads as triennial requirement. Language was removed from Section 2.3.7.2.3, which addresses Unannounced Exercises for Non- Transportation–Related Facilities Regulated by the EPA. Section 2.3.7.2.3 had indicated that alternative response times may be approved by the EPA Regional Administrator; however, there is 2016.1 2.3.7.2.3 1Nov17 no supporting regulatory language in 40 CFR part 112 that specifically provides for this allowance. This change removes the language regarding alternate response times being approved by the Regional Administrator and aligns the PREP Guidelines with the existing regulatory language in 40 CFR part 112.

2016.1 2.3.9.1 7Jun17 Removed language excepting fleet credit for SMFF remote assessment and consultation exercises

Revised language to specify first time foreign vessel entry into U.S. must conduct a remote assessment and consultation exercise ONLY if VRP plan holder has not been subject to such and 2016.1 2.3.9.5 7Jun17 exercise over the triennial cycle.

Language revised to clarify exercises required on a per plan basis over triennial cycle. Remote Assessment and Consultation exercise frequency changed from annually per vessel to triennially per plan holder.

Language revised to require marine firefighting scenario be required in the triennial exercise. If marine firefighting and salvage capabilities are managed by different providers, separate exercises must be conducted for each provider. 2016.1 3.4 7Jun17 Language revised to specify that the QI and/ or the SMFF provider must be contacted is specified in the plan (versus only the QI).

Language revised to allow remote assessment and consultation drills be conducted concurrently with QI notification drills and/or shipboard emergency procedures exercise. Language revised to duplicate changes in Section 3.4 2016.1 3.5 7Jun17 Language revised to require records be kept on board the barge AND with the VRP Added language to BSEE Incident Management Team (IMT) exercise. This includes clarifying IMT 2016.1 6.2 7Jun17 roles and responsibilities in the “Participating Elements” section. Additionally, added note to first paragraph of “Objectives” section to limit IMT involvement in exercise design. Effective date changed to 01 October to correspond with the date of publication in the Federal 2016.1 1.3 2Oct18 Register.

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ACRONYMS

ACP Area Contingency Plan

AMPD Average Most Probable Discharge

API American Petroleum Institute

BSEE Bureau of Safety and Environmental Enforcement

CFR Code of Federal Regulations

Co-Op Cooperative (aka OSRO)

COTP Captain of the Port

CPS Contingency Preparedness System

CWA Clean Water Act

DHS U.S. Department of Homeland Security

DOI U.S. Department of the Interior

DOT U.S. Department of Transportation

EEZ Exclusive Economic Zone

EPA U.S. Environmental Protection Agency

FE Functional Exercise

FOSC Federal On-Scene Coordinator

FPSO Floating Production, Storage, and Offloading

FRP Facility Response Plan

FSE Full-Scale Exercise

FWPCA Federal Water Pollution Control Act

GIUE Government-Initiated Unannounced Exercise

GRP Geographic Response Plan

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HSEEP Homeland Security Exercise and Evaluation Program

IAP Incident Action Plan

ICS Incident Command System

IMT Incident Management Team

ISB In-Situ Burn

ITB Integrated Tug/Barge Combination

JIC Joint Information Center

MFF Marine Firefighting

MIDU Mobile Inland Drilling Unit

MMPD Maximum Most Probable Discharge

MODU Mobile Offshore Drilling Unit

MTR Marine Transportation-Related

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NIMS National Incident Management System

NRS National Response System

NRT National Response Team

NSFCC National Strike Force Coordination Center

NTV Nontank Vessel

NTVRP Nontank Vessel Response Plan

OCONUS Outside the Continental United States

OCS Outer Continental Shelf

OMB Office of Management and Budget

OPA 90 Oil Pollution Act of 1990

OSC On-Scene Coordinator

OSPD Oil Spill Preparedness Division (BSEE)

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OSRO Oil Spill Removal Organization

OSRP Oil Spill Response Plan (BSEE)

PHMSA Pipeline and Hazardous Materials Safety Administration

PREP Preparedness for Response Exercise Program

PREP 4C Preparedness for Response Exercise Program Compliance, Coordination and Consistency Committee

QI Qualified Individual

RCP Regional Contingency Plan

RP Responsible Party

RRT Regional Response Team

SMFF Salvage and Marine Firefighting

SORS Spilled Oil Recovery Systems

SROT Spill Response Operating Team

SSDI Subsea Dispersant Injection

TAPAA Trans-Alaska Pipeline Authorization Act

TTX Tabletop Exercise

UC Unified Command

U.S. United States

USC U.S. Code

USCG United States Coast Guard

VOSS Vessel of Opportunity Skimming System

VRP Vessel Response Plan

WCD Worst Case Discharge

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PREP GUIDELINES

Table of Contents

Acronyms v 1.0 INTRODUCTION 1-1 1.1 Purpose 1-1 1.2 Applicability and Participation in PREP 1-1 1.3 Effective Date 1-2 1.4 Definitions 1-2 2.0 GUIDING PRINCIPLES 2-1 2.1 Safety 2-1 2.2 Core Components for Exercising Response Plans 2-1 2.3 Plan Holder Exercises 2-1 2.3.1 Qualified Individual Notification Exercises 2-2 2.3.1.1 Vessels 2-2 2.3.1.2 Unmanned Tank Barges 2-2 2.3.2 Remote Assessment and Consultation Exercise for Vessels 2-2 2.3.2.1 Tank and Nontank Vessels Carrying Oil as Cargo or Fuel 2-3 2.3.2.2 Tank Barges 2-3 2.3.3 Emergency Procedures Exercises 2-3 2.3.3.1 Tank and Nontank Vessels Carrying Oil as Cargo or Fuel 2-3 2.3.3.2 Unmanned Tank Barges 2-4 2.3.3.3 USCG and EPA Marine Transportation-Related Facilities (optional) 2-4 2.3.4 Incident Management Team Exercises 2-4 Shore-Based Salvage and Shore-Based Marine Firefighting Management Team 2.3.5 Exercises for Vessels 2-5 2.3.6 Equipment Deployment Exercises 2-5 2.3.6.1 OSRO Involvement in Equipment Deployment Exercises 2-6 2.3.6.2 Cooperatives 2-7 2.3.6.3 Vessel and Facility Plan Holder Owned and Operated Oil Spill Removal Equipment 2-7 Plan Holders Using a Combination of OSRO Equipment and Plan Holder Owned and 2.3.6.4 Operated Equipment 2-8 2.3.6.5 Shared Credit for OSRO Equipment Deployment Exercises 2-8 2.3.6.6 Types of Equipment to Be Deployed in Plan Holder Equipment Deployment Exercises 2-8 2.3.6.6.1 Oil Response Systems 2-8 2.3.6.6.2 Salvage and Marine Firefighting Equipment Deployment Exercises 2-10 2.3.7 Unannounced Exercises 2-10 2.3.7.1 Plan Holder-Initiated Unannounced Exercises 2-11 2.3.7.2 Government-Initiated Unannounced Exercises 2-11 2.3.7.2.1 Successful Completion of Government-Initiated Unannounced Exercises 2-12 2.3.7.2.2 Marine Transportation-Related Facilities and Vessels Regulated by the USCG 2-13

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2.3.7.2.3 Non-Transportation–Related Facilities Regulated by the EPA 2-14 2.3.8 Plan Holder Triennial Exercise Cycle 2-15 2.3.8.1 Exercise Plan Components 2-15 2.3.8.2 Plan Holder Exercise Cycle 2-16 2.3.9 Special Considerations 2-17 2.3.9.1 Fleet Plans 2-17 2.3.9.2 Complexes 2-17 2.3.9.3 Vessels Serving as Secondary Carriers of Oil 2-17 2.3.9.4 Trans-Alaska Pipeline Authorization Act Vessels and Facilities 2-17 2.3.9.5 Foreign Vessels Calling Only Occasionally at U.S. Ports 2-17 2.3.9.6 Railroad Tank Cars and Motor Vehicle Tank Trucks 2-18 Group V Oils or Oils that may Exhibit Similar Qualities When Discharged into the 2.3.9.7 Environment 2-18 2.3.9.8 Vessels Serving as Facilities 2-18 2.4 Area-level Exercises 2-19 2.4.1 Equipment Deployment Drills 2-19 2.4.2 IMT Discussion-Based Exercises 2-19 2.4.3 Operations-Based, Functional or Full Scale Exercises (FE/FSEs) 2-19 2.4.4 Area Exercise Scheduling 2-21 2.4.5 PREP Compliance, Coordination and Consistency Committee (PREP 4C) 2-21 2.4.6 Scheduling Process 2-21 2.4.7 Other Credit Considerations 2-21 2.4.7.1 Credit for Response 2-21 2.4.7.1.1 Credit for Plan Holder Response 2-21 2.4.7.1.2 Area FE/FSE Credit for Response 2-22 2.4.7.2 Proper Documentation for Self-Certification of Plan Holder Exercises 2-22 3.0 USCG -REGULATED VESSELS AND MARINE TRANSPORTATION-RELATED FACILITIES 3-1 3.1 DRILL: QI Notification – MTR Facility 3-2 3.2 DRILL: QI Notification – Manned Vessel 3-3 3.3 DRILL: QI Notification – Unmanned Tank Barge 3-4 3.4 DRILL: Remote Assessment and Consultation – Manned Vessel 3-5 3.5 DRILL: Remote Assessment and Consultation – Unmanned Tank Barge 3-6 3.6 DRILL: On Board Emergency Procedures – Manned Vessels 3-7 3.7 DRILL: Emergency Procedures – Tank Barges 3-8 3.8 DRILL: Emergency Procedures – MTR Facilities (optional) 3-9 3.9 TTX: Incident Management Team Exercise – MTR Facilities 3-10 3.10 TTX: Incident Management Team Exercise – Tank and Certain NTVs 3-11 3.11 TTX: Shore-based Salvage Exercise 3-12 3.12 TTX: Shore-based Marine Firefighting Exercise 3-14 3.13 DRILL: Equipment Deployment – MTR Facilities (Facility-owned equipment) 3-15 3.14 DRILL: Equipment Deployment – MTR Facilities (OSRO-owned equipment) 3-16 3.15 DRILL: Equipment Deployment – Vessels (OSRO and SMFF Equipment) 3-17 3.16 FE+DRILL: Government-Initiated Unannounced Exercise – MTR Facilities 3-18 3.17 FE+DRILL: Government-Initiated Unannounced Exercise – Vessels 3-19

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EPA-REGULATED NON-TRANSPORTATION-RELATED ONSHORE AND OFFSHORE 4.0 FACILITIES LOCATED LANDWARD OF THE COASTLINE 4-1 4.1 DRILL: QI Notification – Inland Facility 4-2 4.2 DRILL: Emergency Procedures – Inland Facilities (optional) 4-3 4.3 TTX: Incident Management Team Exercise – Inland Facilities 4-4 4.4 DRILL: Equipment Deployment – Inland Facilities (Company-owned equipment) 4-5 4.5 DRILL: Equipment Deployment – Inland Facilities (OSRO-owned equipment) 4-6 4.6 FE+DRILL: Government-Initiated Unannounced Exercise – Inland Facilities 4-7 5.0 DOT/PHMSA-REGULATED FACILTIES AND PIPELINES 5-1 5.1 DRILL: QI Notification 5-2 5.2 TTX: Incident Management Team Exercise 5-3 5.3 DRILL: Equipment Deployment 5-4 5.4 FE+DRILL: Government-Initiated Unannounced Exercise 5-5 6.0 BSEE-REGULATED OFFSHORE FACILITIES 6-1 6.1 DRILL: QI Notification – Offshore Facility 6-2 6.2 FE: Incident Management Team Exercise – Offshore Facilities 6-3 6.3 DRILL: Equipment Deployment – Offshore Facility (Equipment staged offshore) 6-5 6.4 DRILL: Equipment Deployment – Offshore Facility (Equipment staged onshore) 6-6 DRILL: Equipment Deployment – Offshore Facility (Source control, subsea containment, 6.5 and SSDI equipment) 6-7 6.6 Government-Initiated Unannounced Exercise – Offshore Facilities 6-8 7.0 AREA/OSC EXERCISES 7-1 7.1 DRILL: Quarterly Area Notification 7-2 7.2 TTX: Incident Management Team Exercise – Area IMT 7-3 7.3 DRILL: Equipment Deployment-Area Committee 7-4 7.4 FSE: Quadrennial Area Exercise 7-5 Appendix A CORE COMPONENTS FOR EXERCISING RESPONSE PLANS A-1 Appendix B EXERCISE REFERENCE MATRIX B-1

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1.0 INTRODUCTION

1.1 Purpose

The National Preparedness for Response Exercise Program (PREP) was developed to establish a workable exercise program that meets the intent 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 subsection (6) and subsection (7) for spill response preparedness (33 United States Code (U.S.C.) § 1321 (j)). PREP was developed to provide a mechanism for compliance with the exercise requirements, while being economically feasible for the U.S. Government and oil industry to adopt and sustain. PREP is a unified federal effort and satisfies the exercise requirements of the U.S. Coast Guard (USCG), the Environmental Protection Agency (EPA), the Pipeline and Hazardous Materials Safety Administration (PHMSA), and the Bureau of Safety and Environmental Enforcement (BSEE). Completion of the exercises described in the PREP Guidelines is one option for maintaining compliance with OPA 90-mandated federal oil pollution response exercise requirements.

PREP addresses the exercise requirements for oil pollution response plans. In this edition, the new Nontank Vessel Response Plan (NTVRP) and Salvage and Marine Firefighting (SMFF) exercise requirements described in Section 3 of these Guidelines apply only to USCG-regulated vessels in accordance with recent changes to Title 33 of the Code of Federal Regulations (CFR), Part 155. There are additional industry planning and exercise requirements contained in other federal statutes that are not addressed in these Guidelines.

PREP helps to clarify OPA 90 exercise objectives and provides a methodology for evaluating compliance with federal regulations. PREP does not mandate a given exercise design process. Plan holders are free to design exercises that meet the PREP objectives as well as their own internal ones. Some plan holders have adopted Homeland Security Exercise and Evaluation Program (HSEEP) exercise design guidance for OPA 90 exercises. The use of HSEEP planning process is acceptable, but not required, for planning PREP exercises.

The PREP Guidelines describe the minimum expectations for ensuring adequate response preparedness. If government, industry, or plan holders desire to expand their exercise programs beyond the PREP Guidelines, they are highly encouraged to do so.

The PREP exercises should be viewed as an opportunity to improve response plans and the response system. Plan holders are responsible for addressing any issues that arise from evaluation of exercises and making changes to their respective response plans to ensure the highest level of preparedness.

1.2 Applicability and Participation in PREP

Plan holders are required to meet pollution response exercise requirements. One option to satisfy regulatory exercise requirements is to follow these PREP Guidelines for developing your exercise program. Using the PREP Guidelines is voluntary. Plan holders are not required to follow the PREP Guidelines and, if they choose not to, may develop their own exercise program

1.0 INTRODUCTION Page 1-1

that complies with the regulatory exercise requirements of the appropriate federal oversight agency. Plan holders may take credit for exercise requirements that are met by activities conducted in conjunction with other exercises, or during response to an actual incident, as long as the PREP exercise objectives are met, the response was evaluated, and the proper records are maintained.

The USCG and the EPA follow the PREP Guidelines in the planning and execution of their Area-level pollution response exercise programs.

If an industry plan holder has developed one response plan that covers a fleet of vessels, multiple offshore facilities (as defined in 33 CFR § 154.105), or multiple offshore leases or facilities (as described in 30 CFR § 254.3), this plan holder would only be required to conduct one "set" of exercises for the plan, with the exception of the qualified individual (QI) notification exercises and the emergency procedures exercises, which are required for all applicable vessels. Vessel Response Plan (VRP) regulations apply to tank vessels, tank barges, and nontank vessels (NTVs); but exclude nontank barges except when a nontank barge is part of an integrated tug/barge combination (ITB).

Appendix B of these Guidelines provides a Quick Reference Guide to PREP Exercises.

1.3 Effective Date

The 2016.1 PREP Guidelines are effective on October 1 st of 2018. The PREP Guidelines follow the calendar year (January 1–December 31).

1.4 Definitions

The definitions in this document are intended only to provide information within the context of the PREP Guidelines. Where the language in any of these definitions differs from language contained within any applicable statutes and regulations, the definitions in the statutes and regulations take precedence.

Alternative Training and Exercise Program. An alternative training and exercise program is an exercise program submitted to and approved by the USCG (as specified in 33 CFR § 155.5061) by owners or operators of NTVs with an oil capacity of less than 250 barrels in order to meet their exercise requirements, in lieu of the training and exercise requirements that apply to other NTVs.

Annual. Annual exercises must be conducted at least once each calendar year, with no more than 18 months between exercises.

Area. An Area is that geographic area for which a separate and distinct Area Contingency Plan (ACP) has been prepared, as described in OPA 90.

Area Committee. Area Committees are those committees comprised of federal, state, and local officials, formed in accordance with section 4202 of OPA 90, whose task includes preparing an ACP for the Area for response to a