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

drSSEE^

V Bureau of Safety and J
\ 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.

b —

Dana S. Tulis

Director

Incident Management & Preparedness Policy
U.S. Coast Guard

Reggie Cheatham

Director

Office of Emergency Management
U.S. Environmental Protection Agency

Jeffrey D. Wiese

Associate Administrator for
Pipeline Safety

Pipeline and Hazardous Materials Safety
Administration

David M. Moore

Chief - Oil Spill Preparedness Division
Bureau of Safety & Environmental
Enforcement

U.S. Department of the Interior

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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

Version

Affected
Section

Date

Description of Changes

2016.1

N/A

7Junl7

Added Record of Changes section

2016.1

1.2

7Junl7

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

2016.1

1.4

29Mayl8

Added definition of "annual"

2016.1

2.3.2

7Junl7

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."

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.

2016.1

2.3.2.1

7Junl7

Modified language to be consistent with parent section 2.3.2. Annual exercise on a per vessel basis
changed to triennial requirement on a per plan holder basis. Removed non-amplifying/redundant
language.

2016.1

2.3.2.2

7Junl7

Removed confusing and unnecessary language regarding vessel response plans and barge
custodians and inserted language emphasizing the exercise be conducted in accordance with the
approved VRP.

2016.1

2.3.8.2

7Junl7

Removed language specifying annual remote assessment and consultation exercises for vessel or
barge fleet. Now reads as triennial requirement.

2016.1

2.3.7.2.3

lNovl7

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
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

7Junl7

Removed language excepting fleet credit for SMFF remote assessment and consultation exercises

2016.1

2.3.9.5

7Junl7

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
exercise over the triennial cycle.

Language revised to clarify exercises required on a per plan basis over triennial cycle.

2016.1

3.4

7Junl7

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.

Language revised to specify that the Q.I and/ or the SMFF provider must be contacted is specified in
the plan (versus only the Ql).

Language revised to allow remote assessment and consultation drills be conducted concurrently
with Ql notification drills and/or shipboard emergency procedures exercise.

2016.1

3.5

7Junl7

Language revised to duplicate changes in Section 3.4

Language revised to require records be kept on board the barge AND with the VRP

2016.1

6.2

7Junl7

Added language to BSEE Incident Management Team (IMT) exercise. This includes clarifying IMT
roles and responsibilities in the "Participating Elements" section. Additionally, added note to first
paragraph of "Objectives" section to limit IMT involvement in exercise design.

2016.1

1.3

20ctl8

Effective date changed to 01 October to correspond with the date of publication in the Federal
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

IAP

ICS

IMT

ISB

ITB

JIC

MFF

MIDU

MMPD

MODU

MTR

NCP

NIMS

NRS

NRT

NSFCC

NTV

NTVRP

OCONUS

OCS

OMB

OPA90

OSC

OSPD

Homeland Security Exercise and Evaluation Program

Incident Action Plan

Incident Command System

Incident Management Team

In-Situ Burn

Integrated Tug/Barge Combination
Joint Information Center
Marine Firefighting
Mobile Inland Drilling Unit
Maximum Most Probable Discharge
Mobile Offshore Drilling Unit
Marine Transportation-Related

National Oil and Hazardous Substances Pollution Contingency Plan

National Incident Management System

National Response System

National Response Team

National Strike Force Coordination Center

Nontank Vessel

Nontank Vessel Response Plan

Outside the Continental United States

Outer Continental Shelf

Office of Management and Budget

Oil Pollution Act of 1990

On-Scene Coordinator

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

Ql	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

»

1.0

INTRODUCTION



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: Ql Notification - MTR Facility

3-2

3.2

DRILL: Ql Notification - Manned Vessel

3-3

3.3

DRILL: Ql 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: Ql 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: Ql 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: Ql 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,



i

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

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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 (Ql)
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 1st 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 discharge of oil or hazardous substance (as defined in the
Clean Water Act (CWA)).

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INTRODUCTION

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Area Incident Management Team (Area IMT). The Area IMT is the group of individuals within
the USCG or EPA Federal On-Scene Coordinator (FOSC) organization with responsibility for
incident response management within the respective Area. The Area IMT should include state
and local personnel whenever possible.

Average Most Probable Discharge (AMPD) (USCG)/Small Discharge (EPA). This definition is
agency-dependent, and the appropriate definitions are detailed as follows:

1.	For USCG-regulated vessels, a discharge of 50 barrels (2,100 gallons) of oil from the
vessel during oil transfer operations (33 CFR § 155.1020).

2.	For USCG-regulated facilities, a discharge of the lesser of 50 barrels (2,100 gallons) or
one percent of the volume of the worst-case discharge (WCD) (33 CFR § 154.1020).

3.	For EPA-regulated facilities, a small discharge is a volume of 2,100 gallons (50 barrels) or
less, provided this amount is less than the WCD (40 CFR § 112.20).

4.	For PHMSA: Not applicable.

5.	For BSEE: Not applicable.

6.	For complexes regulated by more than one federal agency, the largest of the AMPDs
calculated for the various regulated components.

Barge Custodian. A barge custodian is the individual who has custody of an unmanned barge.
The barge custodian may be affiliated with the 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 fleet operator, or whoever may be in charge of the entity that has custody of the
barge.

Certification. Documentation that certifies that an exercise was:

1.	Completed;

2.	Conducted in accordance with the PREP Guidelines and met all listed objectives; and

3.	Evaluated using a mechanism that appraised the effectiveness of the response or
contingency plan.

Complex Facility. A complex facility is one that is regulated under section 311 (j) of the CWA (33
U.S.C. § 1321 (j)) by two or more federal agencies.

Cooperative (Co-Op). A co-op is a classified or non-classified Oil Spill Removal Organization
(OSRO) that provides oil spill response coverage. Classified co-ops can provide AMPD, maximum
most probable discharge (MMPD), and WCD coverage while non-classified co-ops provide only
AMPD coverage.

Drill. A drill is an operations-based exercise employed to validate a specific function or
capability that is commonly used to provide training, validate procedures, or practice and
maintain current skills.

Discussion-Based Exercises. Discussion-based exercises include seminars, workshops, and
tabletop exercises (TTXs). These types of exercises can be used to familiarize participants with,

1.0

INTRODUCTION

Page 1-3


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or develop new, plans, policies, agreements, and procedures. Discussion-based exercises focus
on strategic, policy-oriented issues. Facilitators and/or presenters usually lead the discussion,
keeping participants on track towards meeting exercise objectives.

Equipment Deployment Exercise. An equipment deployment exercise is an exercise during
which response equipment is deployed to a specific site and operated in its normal operating
environment.

Equipment Activation. Equipment activation is the movement, staging, deployment, or
operation of response equipment, as determined by the plan holder in consultation with the
exercise design team.

Exercise Design Team. This team designs the exercise and may be comprised of federal, state,
and industry representatives who are stakeholders in the scenario.

Federal On-Scene Coordinator (FOSC). The FOSC is the federal official pre-designated by the
EPA or the USCG to coordinate and direct federal responses under the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), or the official designated by the lead
agency to coordinate and direct removal actions under subpart E of the NCP. The term FOSC is
synonymous with the term On-Scene Coordinator (OSC) as described in the NCP.

Functional Exercise (FE). FEs are designed to validate and evaluate capabilities, multiple
functions and/or sub-functions, or interdependent groups of functions. FEs are typically focused
on exercising plans, policies, procedures, and staff members involved in management,
direction, command, and control functions. In FEs, events are projected through an exercise
scenario with event updates that drive activity typically at the management level. An FE is
conducted in a realistic, real-time environment; however, movement of personnel and
equipment is usually simulated.

Full-Scale Exercise (FSE). FSEs are typically the most complex and resource-intensive type of
exercise. They involve multiple agencies, organizations, and jurisdictions, and validate many
facets of preparedness. FSEs often include many participants operating under cooperative
systems such as the Incident Command System (ICS) or Unified Command (UC). In an FSE,
events are projected through an exercise scenario with event updates that drive activity at the
operational level. FSEs are usually conducted in a real-time, stressful environment that is
intended to mirror a real incident. Personnel and resources may be mobilized and deployed to
the scene, where actions are performed as if a real incident had occurred. The FSE simulates
reality by presenting complex and realistic problems that require critical thinking, rapid
problem solving, and effective responses by trained personnel.

Government-Initiated Unannounced Exercise (GIUE). GIUEs are government-initiated
compliance monitoring activities that allow regulatory agencies the opportunity to evaluate
various aspects of a plan holder's preparedness, including their emergency procedures, and
their contracted OSROs' capabilities for proper and timely equipment deployment.

Group V Oils or oils that may exhibit similar qualities. Group V oils are oils with a specific gravity
greater than 1.0. Examples of these oils include, but are not limited to: diluted bitumen (dilbit),
asphalt, asphalt products, extra-heavy oil, and natural bitumen (oil sands).

1.0

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Incident Management Team (IMT). The IMT is the group of personnel identified to staff the
appropriate organizational structure to manage response implementation in accordance with
the response plan.

Industry. For the purpose of these Guidelines, industry refers to the regulated group of owners
or operators who are required to submit response plans for oil spills. The regulated group may
consist of vessels, marine transportation-related (MTR) facilities, onshore and certain offshore
non-transportation-related facilities, pipelines, or offshore facilities. The response plan
requirements and regulations for these entities are administered by the USCG, EPA, PHMSA,
and BSEE.

Marine Firefighting (MFF) Organization. For the purposes of these Guidelines, MFF organization
means the entity that provides resources—such as personnel, equipment, supplies, and other
capabilities necessary to perform marine firefighting services identified in the VRP—and which
has been arranged by contract or other approved means. MFF resource providers can include
public firefighting resources as long as they are able, in accordance with the requirements of 33
CFR § 155.4050(d), and willing to provide the required services. Refer to the definitions for
"resource provider" and "primary resource provider."

Marine Transportation-Related (MTR) Oil Facility. This facility type means any onshore facility
or segment of a complex regulated under Sec. 311(j) of the CWA by two or more federal
agencies, including piping and any structure used, or intended to be used, for transfer of oil to
or from a vessel, subject to regulation under 33 CFR § 154, or any deepwater port subject to
regulation under 33 CFR § 150. For a facility or segment of a complex regulated by two or more
federal agencies under Sec. 311 (j) of the CWA, the MTR portion of the complex extends from
the facility oil transfer system's connection with the vessel to the first valve inside the
secondary containment surrounding tanks in the non-transportation-related portion of the
facility or, in the absence of secondary containment, to the valve or manifold adjacent to the
tanks comprising the non-transportation-related portion of the facility, unless another location
has otherwise been agreed to by the Captain of the Port (COTP) and the appropriate federal
official.

Maximum Most Probable Discharge (MMPD) (USCG)/Medium Discharge (EPA). This definition is
agency-dependent, and the appropriate definitions are detailed as follows:

1.	For USCG-regulated vessels, a discharge of 2,500 barrels (105,000 gallons) of oil for
vessels with an oil cargo capacity equal to or greater than 25,000 barrels (1,050,000
gallons), or 10 percent of the vessel's oil cargo capacity for vessels with a capacity of less
than 25,000 barrels (1,050,000 gallons) (33 CFR § 155.1020).

2.	For USCG-regulated facilities, a discharge of the lesser of 1,200 barrels (50,400 gallons)
or 10 percent of the volume of a WCD (33 CFR § 154.1020).

3.	For EPA-regulated facilities, a discharge greater than 2,100 gallons (50 barrels) and less
than or equal to 36,000 gallons (858 barrels) or 10 percent of the capacity of the largest
tank at the facility, whichever is less (40 CFR § 112.20).

4.	For PHMSA: Not applicable.

5.	For BSEE: Not applicable.

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6. For complexes regulated by more than one federal agency, the largest of the MMPDs
calculated for the various regulated components.

Mobile Marine Transportation-Related Facility. Mobile MTR facility means any oil facility that
can readily change location, such as a tank truck or tank car, other than a vessel or public vessel
as defined by 33 CFR § 154.105.

National Response System (NRS). Under 40 CFR § 300 (NCP), the NRS includes the National
Response Team (NRT), Regional Response Teams (RRTs), Area Committees, OSCs, and state and
local government entities involved with response planning and coordination.

Nontank Vessel (NTV). An NTV is a vessel meeting the description provided in 33 CFR
§ 155.5015(a), which reads: (a) Except as provided in paragraph (d) of this section, this subpart
applies to each self-propelled vessel that—(1) Carries oil of any kind as fuel for main propulsion;
(2) Is not a tank vessel or is not certificated as a tank vessel; (3) Operates upon the navigable
waters of the United States, as defined in 46 U.S.C. § 2101(17a); and (4) Is 400 gross tons or
more as measured under the convention measurement system in 46 U.S.C. § 14302 or the
regulatory measurement system of 46 U.S.C. § 14502 for vessels not measured under 46 U.S.C.
§ 14302.

NOTE: Mobile Off Shore Drilling Units (MODUs) are considered NTVs. However, MODUs are also
subject to regulations covered in 30 CFR § 254 addressing Offshore Facility Response Plans
(FRPs).

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 not-
for-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)(ll)). The CWA defines an offshore facility as any facility of
any kind located in, on, or under any of the navigable waters of the United States, and any
facility of any kind that is subject to the jurisdiction of the United States and is located in, on, or
under any other waters, other than a vessel or a public vessel.

Onshore Facility (33 U.S.C. § 1321(a)(10)). The CWA defines an "onshore facility" as any facility
(including, but not limited to, motor vehicles and rolling stock) of any kind located in, on, or
under, any land within the United States other than submerged land.

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Operating Environments.

For the purposes of PREP and oil spill removal equipment requirements, there are three types
of operating environments (33 CFR § 154, 33 CFR § 155, 40 CFR § 112):

1.	River and canal;

2.	Great Lakes/Inland; and

3.	Ocean (nearshore, offshore, and open ocean).

For the purposes of PREP and SMFF requirements, there are three different types of operating
environments (33 CFR § 155.4030(b)):

1.	Pier;

2.	Nearshore; and

3.	Offshore.

Operations-Based Exercises. Operations-based exercises include drills, FEs, and FSEs. These
exercises can be used to validate plans, policies, agreements, and procedures; clarify roles and
responsibilities; and identify resource gaps. Operations-based exercises are characterized by
actual reaction to an exercise scenario, such as initiating communications or mobilizing
personnel and resources.

Persistent Oil. A persistent oil is a petroleum-based oil that does not meet the distillation
criteria for a non-persistent oil. Persistent oils are further classified based upon specific gravity
as follows:

1.	Group II—specific gravity of less than 0.85.

2.	Group III—specific gravity equal to or greater than 0.85 and less than 0.95.

3.	Group IV—specific gravity equal to or greater than 0.95 and less than or equal to 1.0.

4.	Group V—specific gravity greater than 1.0.

Plan Holder. The term "plan holder" is not defined in oil spill regulations. It is a term in common
usage and refers to the entity (company, organization, or agency) that owns or operates
vessels, facilities, and pipelines for which a response plan is required to be submitted by federal
regulation. If an owner or operator is authorized to prepare one plan for a fleet of vessels or
multiple facilities, that owner or operator is considered to be the plan holder.

Primary Oversight Agency. The primary oversight agency is the agency with regulatory authority
over a particular facility or vessel. For the purposes of PREP, the four primary oversight agencies
and the industries they regulate are the USCG (vessels, MTR facilities), EPA (onshore and certain
offshore facilities landward of the coastline), PHMSA (pipelines and certain transportation-
related facilities), and BSEE (offshore facilities seaward of the coastline).

Primary Resource Provider. A primary resource provider is listed in the VRP as the principal
entity contracted for providing specific SMFF services and resources, when multiple resource
providers are listed for that service, for each of the COTP Zones in which a vessel operates. The

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primary resource provider will be the point of contact for the plan holder, the FOSC, and the UC
in matters related to specific resources and services, as required in 33 CFR § 155.4030(a).

Qualified Individual (Ql). A Ql is the person located in the United States who meets the
requirements identified in the respective federal regulations (USCG, EPA, PHMSA, BSEE), and
who is authorized to do the following: (1) Activate and engage in contracting with OSRO; (2) act
as a liaison with the OSC; and (3) obligate funds of the plan holder required to effectuate
response activities. The Ql will be the individual or a designee identified in the response plan.

Remote Assessment and Consultation. Remote assessment and consultation means contacting
the SMFF resource providers identified in a VRP, by phone or other means of communications,
to discuss and assess an SMFF situation. The person contacted must be competent to consult
on a determination of the appropriate course of action and initiation of a response plan.

Resource Provider. The resource provider is an entity that provides personnel, equipment,
supplies, and other capabilities necessary to perform salvage and/or MFF services identified in
the response plan, and has been arranged by contract or other approved means.

Salvage Organization. For the purposes of these Guidelines, salvage organization means the
entity that provides resources such as personnel, equipment, supplies, and other capabilities
necessary to perform salvage services identified in the VRP, exclusive of MFF services, and
which have been arranged by contract or other approved means. Refer also to the definitions
for "resource provider" and "primary resource provider."

Salvage and Marine Firefighting (SMFF) Provider. SMFF Provider refers to a company providing
SMFF response services to applicable tank vessels and NTVs. Refer also to the definitions for
"resource provider" and "primary resource provider."

Self-Certification. Self-certification is a declaration made by a plan holder that their exercise has
met the following standards:

1.	Completed the exercise;

2.	Conducted the exercise in accordance with the PREP Guidelines;

3.	Met all objectives listed; and

4.	Evaluated the exercise using a mechanism that appraises the effectiveness of the
response or contingency plan.

Self-Evaluation. Self-evaluation means that the plan holder is responsible for carefully
examining the effectiveness of the plan for response during the exercise. The plan holder may
choose the mechanism for conducting this appraisal, as long as it appropriately measures the
plan's effectiveness. The plan holder is responsible for addressing issues that arise in the
exercise that would lead to improvements in the response plan or any aspect of preparedness
for response. The plan holder is responsible for incorporating necessary changes to the
response plan as a result of the exercise.

Seminars. Seminars generally orient participants to, or provide an overview of, authorities,
strategies, plans, policies, procedures, protocols, resources, concepts, and ideas. As a

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discussion-based exercise, seminars can be valuable for entities that are developing or making
major changes to existing plans or procedures. Seminars can be similarly helpful when
attempting to assess or gain awareness of the capabilities of interagency or interjurisdictional
operations.

SMFF Response Services. SMFF response services means the 19 services listed below and
defined by regulations requiring their inclusion in applicable VRPs. SMFF response services are
not classified by the USCG.

SALVAGE

Assessment & Survey

1.	Remote assessment and consultation;

2.	Begin assessment of structural stability;

3.	On-site salvage assessment;

4.	Assessment of structural stability; and

5.	Hull and bottom survey.

Stabilization

6.	Emergency towing;

7.	Salvage plan;

8.	External emergency transfer operations;

9.	Emergency lightering;

10.	Other refloating methods;

11.	Making temporary repairs; and

12.	Diving services support.

Specialized Salvage Operations

13.	Special salvage operations plan;

14.	Subsurface product removal; and

15.	Heavy lift.

MARINE FIREFIGHTING
Assessment & Planning

16.	Remote assessment and consultation; and

17.	On-site fire assessment.

Fire Suppression

18.	External firefighting teams; and

19.	External vessel firefighting systems.

Spill Response Operating Team (SROT). A SROT comprises the trained persons who respond to
spills through deployment and operation of oil spill response equipment (30 CFR § 254.6).

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Tabletop Exercises (TTX). ATTX is intended to generate discussion of various issues regarding a
hypothetical, simulated emergency. TTXs can be used to enhance general awareness, validate
plans and procedures, rehearse concepts, and/or assess the types of systems needed to guide
the prevention of, protection from, mitigation of, response to, and recovery from a defined
incident. Generally, TTXs are aimed at facilitating conceptual understanding, identifying
strengths and areas for improvement, and/or achieving changes in perceptions. During a TTX,
participants are encouraged to discuss issues in depth, collaboratively examining areas of
concern and solving problems. The effectiveness of a TTX is derived from the energetic
involvement of participants and their assessment of recommended revisions to current policies,
procedures, and plans.

Timely. As used in relation to GIUE programs, this means the times established in the
appropriate response planning regulations for providing response resources to a spill or
significant threat of such a spill.

Unified Command (UC). This entity is a command structure consisting of the FOSC,
representatives from the state, the responsible party (RP), and other parties that have authority
or functional responsibility for an area that may be affected by an incident and coordinate or
manage a major aspect of the response. The UC is used during a response to achieve the
coordination necessary to carry out an effective and efficient response.

Verification. Verification is the act of ensuring that an exercise was properly documented and
certified. Verification would be conducted by the USCG, EPA, PHMSA, or BSEE. Verification of
the exercise records may be conducted through normal operations of the regulatory agency,
such as inspections, boarding, spot checks, or other systems developed to ensure that exercises
are being conducted and properly documented.

Vessel. For the purpose of the PREP Guidelines, a vessel is any vessel required by 33 CFR § 155
to submit a response plan.

Worst Case Discharge (WCD). This definition is agency-dependent, and the appropriate
definitions are detailed as follows:

1.	For USCG-regulated vessels, a discharge in adverse weather conditions of a vessel's
entire cargo as defined in 33 CFR § 155.1020.

2.	For USCG-regulated facilities, the size of the discharge as defined in 33 CFR § 154.1020
(in the case of an onshore facility and deepwater port, the largest foreseeable discharge
in adverse weather conditions meeting the requirements of 33 CFR § 154.1029).

3.	For EPA-regulated facilities, the size of the discharge described in 40 CFR § 112.20.

4.	For PHMSA-regulated facilities or pipelines, the size of the discharge as defined in
applicable regulations (49 CFR § 130 or § 194).

5.	For BSEE-regulated offshore facilities, the size of the discharge as defined in applicable
regulations (30 CFR § 254).

6.	For Areas, the size of the discharge as specified in the ACP. NOTE: WCD is defined in the
NCP at 40 CFR §300.5.

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For complexes regulated by more than one federal agency, any of the WCDs calculated
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2.0 GUIDING PRINCIPLES

2.1	Safety

Safety during an exercise or an actual response is paramount; the plan holder and responders
carry the primary responsibility for safety. The response plan should comply with all regulatory
requirements while considering safety factors. Plan holders and responders are never expected
to operate in an unsafe manner during an exercise or actual response. It is the plan holder's
responsibility to confirm that the resources identified in the response plan can mount an
effective response while operating safely within all applicable laws and regulations. In short,
there is no expectation or justification for placing people at risk during an exercise or response.
Safety violations will be considered a failure to follow response plans and likely lead to an
unsatisfactory exercise.

2.2	Core Components for Exercising Response Plans

Appendix A of these Guidelines outlines 15 core components that should be exercised for each
response plan during the exercise cycle. These core components may be exercised through a
combination of exercise types that are described in the following Guiding Principles and agency-
specific sections (Sections 3, 4, 5 and 6).

2.3	Plan Holder Exercises

Plan holder exercises are planned and implemented within the plan holder's organization. This
type of exercise may include personnel that are employed or contracted by the plan holder
such as the Ql, cooperatives, OSROs, associated supporting contractors, consultants, and others
affiliated with the plan holder's IMT. Plan holders should consider the appropriate level of
involvement of external participants. The plan holder exercises are designed to examine
specific components of their response plan, and cumulatively to ensure that the whole plan is
ready to be implemented.

Plan holder exercise types include:

1.	Ql notification exercises;

2.	Remote assessment and consultation exercises for vessels;

3.	Emergency procedures exercises for vessels;

4.	Emergency procedures exercises for facilities (optional);

5.	IMT exercises;

6.	Shore-based salvage and shore-based MFF management team exercises for vessels;

7.	Equipment deployment exercises; and

8.	GIUEs.

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All plan holder-initiated exercises should be self-evaluated and self-certified by the owner or
operator.

2.3.1	Qualified Individual Notification Exercises

The purpose of the Ql notification exercise is to ensure that the Ql (or designee) listed in the
response plan will respond as expected and carry out his or her required duties in a spill
response emergency or significant threat of a spill. Contact by telephone or radio must be made
with the Ql, and confirmation must be received from him or her to satisfy the requirements of
this exercise. Electronic messaging is an acceptable alternative if voice contact is not possible.

The Ql notification exercise is not intended to verify phone numbers, points of contact, or the
notification list contained in the plan. The plan holder is expected to verify this information
when updating the notification list periodically (recommended at least once every six months)
as part of the normal course of conducting business.

At least once per year, the Ql notification exercise should be conducted during non-business
hours.

2.3.1.1	Vessels

For vessels, it is the responsibility of the plan holder to ensure that the Ql notification exercise
is conducted. If a plan holder has a fleet of vessels covered by one response plan, the plan
holder must ensure that each vessel in the fleet conducts this exercise.

For vessels, electronic messaging will be acceptable, but the baseline should be voice
communication. If electronic messaging is used for this exercise, confirmation from the Ql must
be received to properly satisfy the requirements of this exercise.

2.3.1.2	Unmanned Tank Barges

For unmanned tank barges, it is the responsibility of the plan holder to ensure that the Ql
notification exercise is conducted. If a plan holder has a fleet of unmanned tank barges
covered by one response plan, during each quarter the plan holder should randomly choose a
barge in the fleet to conduct the Ql notification exercise. The plan holder should have the
barge custodian of the chosen barge conduct the exercise. This method will ensure that all
barges and custodians are ultimately included in the exercises.

2.3.2	Remote Assessment and Consultation Exercise for Vessels

Early incident notification and activation of VRPs may prevent potential spills from turning into
spills, and prevent actual spills from escalating in size, beginning with the early initiation of a
situational assessment by a competent salvage professional. The purpose of the remote
assessment and consultation exercise is to ensure that personnel are able to initiate remote
assessment and consultation when a situation presents a discharge or substantial threat of a
discharge. Substantial threats of a discharge may exist during, but are not limited to, grounding,
stranding, collision, hull damage, fire, explosion, loss of propulsion, flooding, and equipment
failure, where taking preventive action may prevent spillage.

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The remote assessment and consultation exercise requires following VRP notification and
activation procedures. The remote SMFF assessor contacted during the PREP exercise must be
competent to consult on a determination of the appropriate course of action and initiation of a
response plan. This initial course of action may be as simple as identifying appropriate key
measurements aboard the vessel and establishing a reporting timetable for status updates to
the remote assessor, in order to facilitate damage assessment using a computerized program.

The remote assessment and consultation exercise must be conducted triennially by each plan
holder when the vessel is operating in U.S. waters, including the exclusive economic zone (EEZ).

2.3.2.1	Tank and Nontank Vessels Carrying Oil as Cargo or Fuel

For manned tank vessels and NTVs, it is the responsibility of the plan holder to ensure that the
remote assessment and consultation exercise is conducted.

2.3.2.2	Tank Barges

For tank barges, it is the responsibility of the plan holder to ensure that the remote assessment
and consultation exercise is conducted.

If a plan holder has a fleet of tank barges covered by one response plan, the plan holder
should randomly choose a barge in the fleet to conduct remote assessment and consultation
exercise. The plan holder should have the barge custodian of the chosen barge conduct the
PREP exercise in accordance with the approved VRP.

2.3.3 Emergency Procedures Exercises

The purpose of the emergency procedures exercises is to ensure that personnel are capable of
conducting the initial actions necessary to mitigate the effects of a spill.

2.3.3.1	Tank and Nontank Vessels Carrying Oil as Cargo or Fuel

For vessels, it is the responsibility of the plan holder to ensure that the emergency procedures
exercise is conducted. If a plan holder has a fleet of vessels covered by one response plan, the
plan holder must ensure that each vessel in the fleet conducts this PREP emergency procedures
exercise. Since vessels do not always sail with the same crews, it is important that each vessel
conducts this exercise quarterly to ensure that the personnel on board are familiar with the
procedures for mitigating a spill or potential spill, as well as an SMFF incident, occurring from
that vessel.

2.3.3.2	Unmanned Tank Barges

For unmanned tank barges, it is the responsibility of the plan holder to ensure that the
emergency procedures exercise is conducted.

If a plan holder has a fleet of unmanned tank barges covered by one response plan, during
each quarter the plan holder should randomly choose a barge in the fleet to conduct the
emergency procedures exercise. The plan holder should have the barge custodian of the
chosen barge conduct the exercise. The plan holder should choose the barges and the various

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custodians randomly to ensure that all barges and custodians will ultimately be included in the
exercises.

2.3.3.3 USCG and EPA Marine Transportation-Related Facilities (optional)

Facilities have the option of conducting emergency procedures exercises. For the purpose of
the PREP, emergency procedures for facilities are the procedures established at the facility to
mitigate or prevent any discharge or a substantial threat of such discharge of oil resulting from
facility operational activities associated with cargo transfers. An emergency procedures exercise
conducted unannounced by the facility would satisfy the facility's requirement for the annual
plan holder-initiated unannounced exercise.

2.3.4	Incident Management Team Exercises

For USCG, EPA, PHMSA, and BSEE-regulated plan holders, the owner or operator identifies an
IMT in the response plan. The IMT conducts an annual exercise, in accordance with the PREP
Guidelines. The response plan is used in the exercise to ensure that the IMT is familiar with the
plan and is able to use it effectively to conduct a response, including all response
countermeasures described in the plan. For any chemical or biological countermeasure or in-
situ burning cited in the response plan, the IMT must demonstrate the ability to prepare and
submit a request, usage, and monitoring plan. Each specific countermeasure listed in the plan
will be exercised during the triennial cycle. At least one IMT exercise in a triennial cycle must
involve a WCD scenario. The exercise design team may use alternative WCD scenarios that are
representative of a worst-case scenario (e.g., exercise of a pipeline line segment WCD) for
environmental impact purposes. One or more plan holder representatives must participate in
each exercise.

If a response plan lists different types of IMTs for varying sizes of incidents (for example, a local
IMT for small incidents, a regional team for larger incidents, and a national team for major
incidents), each team identified is required to participate in an annual IMT exercise.

It is recommended that the IMT actions and documentation include, at a minimum:

1.	ICS forms 201, 204, and 207;

2.	Incident Action Plan (IAP); and

3.	Health and Site Safety.

2.3.5	Shore-Based Salvage and Shore-Based Marine Firefighting Management Team
Exercises for Vessels

The VRP holder who must follow 33 CFR § 155, Subpart I, SMFF, must conduct shore-based
salvage and shore-based MFF management team exercises annually. NTVs with oil capacity less
than 250 barrels are exempt from MFF exercise requirements. This requirement for an annual
exercise will be satisfied if conducted in accordance with the PREP Guidelines. The response
plan, and associated pre-fire plan when applicable, must be used in the exercise to ensure that
the management teams are familiar with the plans and are able to use them effectively to
conduct an SMFF response.

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These annual exercises may be conducted in conjunction with the annual IMT exercise, or
separately. Annual SMFF PREP exercises may be combined when the criteria for claiming credit
found in the exercise description (Section 3) are met.

2.3.6 Equipment Deployment Exercises

The purpose of PREP equipment deployment exercises is to ensure that response equipment is
appropriate for the operating environment in which it is intended to be used and that operating
personnel are trained in its deployment and operation. The equipment deployment exercise
guidelines apply to all plan holders and their contracted equipment operators. It is the
responsibility of the plan holder to ensure that its respective equipment deployment exercise
requirements are met.

A plan holder's equipment deployment exercise program should include the following
components:

1.	Personnel who would normally operate or supervise the operation of the response
equipment must participate in the exercise.

2.	Personnel must demonstrate the ability to deploy and operate the equipment, while
wearing appropriate personal protective equipment.

3.	A training program must be provided for the personnel involved in equipment
deployment and for equipment operators. The operating personnel should participate
in exercises or responses on an annual basis in order to ensure that they remain
trained and qualified to operate equipment in the operating environment.

4.	Response equipment must be in good operating condition.

5.	Equipment must be appropriate for the intended operating environment.

6.	Equipment must be operated during the exercise.

7.	There must be a maintenance program for all response equipment.

Plan holders are responsible for ensuring that all equipment types cited in their respective plans
are exercised, whether the equipment is plan holder owned and operated, or supplied through
an OSRO/SMFF provider. It is not necessary to deploy every piece of each type of equipment, as
long as all equipment is included in a periodic inspection and maintenance program intended to
ensure that the equipment remains in good working order. Although not required as part of
this section, plan holders are encouraged to use these exercises as an opportunity to validate
response strategies detailed in ACPs.

2.3.6.1 OSRO Involvement in Equipment Deployment Exercises

PREP exercises strive to deploy a representative sample of each type of equipment. The
rationale for this approach is that if the representative sample is in proper operating condition,
then the rest of the equipment could be expected to be in the same working order since it
would be part of the company's maintenance program. Similarly, if a representative sample of
the OSRO's personnel are involved in the deployment exercise and handle their responsibilities
effectively, the rest of the personnel could be expected to be knowledgeable and effective,
since they would be a part of the company's training program. When selecting the equipment

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and personnel for the exercise, the OSRO should ensure that the same equipment and
personnel are not used repeatedly for each exercise. The equipment and personnel should be
selected on a rotational basis, with the ultimate goal of eventually exercising all of the
OSRO's equipment and personnel.

If an OSRO has separate field response facilities located throughout the country in areas that do
not lend themselves to regional consolidation, each staffed field response facility, for the
purpose of the PREP, will be considered a separate OSRO and will be required to conduct an
annual equipment deployment exercise.

In both cases, if the OSRO is classified to deploy equipment to more than one type of operating
environment, the OSRO must conduct a deployment exercise in each of the environments.

Some OSROs have small field response facilities. A field response facility is defined as a location
where personnel and equipment are staged. Some of these OSROs have divided their
operations into regional response facilities. In some instances, a regional facility will be
responsible for several small field response facilities or equipment stockpiles. For the purpose
of the equipment deployment exercises under the PREP, each regional facility will be
considered a separate OSRO and will be required to conduct an annual equipment deployment
exercise of the minimum amount of equipment specified in the PREP. The OSRO regional facility
would be responsible for coordinating 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
personnel from each field facility must participate in the equipment deployment exercise. If the
OSRO operates using regional facilities, that OSRO will be responsible for defining its regional
boundaries and providing information to its plan holders. Generally, however, regions should
be reasonable in geographic size. At a minimum, plan holders must ensure that their OSRO(s)
conduct annual equipment deployment exercises in each operating environment in which they
expect to operate for each USCG district and EPA ACP Area, or EPA Subarea (where identified),
unless adjoining Areas or Subareas authorize an alternative. For example, if an OSRO is located
in the First USCG District, and provides response assets to the Fifth USCG District as well, those
two districts might mutually agree to allow the OSRO to conduct fewer exercises due to
similarity of operating environments in those Areas. The OSRO should request this
consideration in writing to the appropriate Area Committees and/or EPA Subarea.

If the OSRO is cited in a response plan outside of its normal equipment staging and operating
areas (e.g., as a Tier 2 responder), the plan holder citing that OSRO must ensure that the OSRO
has the local knowledge relevant to an effective, efficient response in the plan holder's
operating area. The plan holder must describe arrangements for providing the OSRO with
information such as equipment launching locations, tides and currents of the local area, and
any other logistical problems or information specific to the particular area. Plan holders are
encouraged to conduct familiarization training with each OSRO cited in the response plan to
provide information such as equipment launching locations, tides and currents of the local area,
and any other logistical problems or information specific to the particular area. This
familiarization training may include a walk-through or actual equipment deployment as
appropriate, such that each OSRO can be made aware of any logistical problems related to
equipment deployment.

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It is the plan holder's responsibility to ensure that the OSRO has completed the equipment
deployment exercise requirements and has prepared the necessary documentation. All plan
holders must remember that merely citing an OSRO in their response plan is not sufficient to
ensure credit for the equipment deployment exercise.

2.3.6.2	Cooperatives

For the purposes of the PREP Guidelines, co-ops must meet the same annual exercise
requirements as all other OSROs. Each facility and personnel will not have to conduct the
exercise individually. The co-op as a whole would conduct one equipment deployment exercise
per year. All entities that provide response resources to a co-op should participate in this
exercise. For co-ops that are comprised of several different OSROs, each unique OSRO would
be required to conduct an annual equipment deployment exercise.

Co-op personnel who are responsible for deploying the response equipment must be involved
in a training program that prepares them for operating the response equipment. Likewise, the
co-op must have a maintenance program for all of the response equipment.

2.3.6.3	Vessel and Facility Plan Holder Owned and Operated Oil Spill Removal
Equipment

Plan holder owned and operated oil spill removal equipment is defined as equipment owned by
a plan holder and operated either by the plan holder's own personnel or other personnel hired
by the plan holder to operate this equipment. Whoever operates this equipment must be
involved in the equipment deployment exercises. This equipment is separate from SMFF
equipment.

If plan holder owned and operated oil spill removal equipment is identified for use in a spill
response plan, the plan holder is required to deploy this equipment twice per year
(semiannually). The plan holder would be required to deploy the minimum amount of
equipment for deployment specified in this section or the total amount of equipment that the
plan holder has available for response, whichever is less. The requirement for semiannual
equipment deployment is based on the fact that this equipment is not deployed routinely and
that the personnel operating it do not do this as a part of the vessel's or facility's normal
operations. The semiannual requirement is necessary to ensure adequate preparedness for spill
response.

The plan holder's personnel responsible for deploying the response equipment must be
involved in a training program that prepares them for operating the response equipment. The
plan holder should ensure that equipment and personnel are rotated and not used repeatedly
for each exercise. Likewise, the vessel/facility plan holder must have a maintenance program
for all of the response equipment.

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2.3.6.4	Plan Holders Using a Combination of OSRO Equipment and Plan Holder Owned
and Operated Equipment

Plan holders citing both OSRO equipment and their own oil spill removal equipment in their
response plans would be required to exercise both types of equipment at the above described
intervals.

2.3.6.5	Shared Credit for OSRO Equipment Deployment Exercises

Due to the large number of plan holders participating in PREP and the burden it would put on
OSROs to conduct separate equipment deployment exercises on behalf of each plan holder
they provide services for, it is an accepted practice for OSROs to conduct equipment
deployment exercises on behalf of all their plan holders. In such circumstances, exercise credit
can be extended to and shared amongst all the plan holders for the deployment of that specific
OSRO equipment and personnel in a specific location (USCG COTP zone, RRT region, EPA ACP
Area, or EPA Subarea), provided that each plan holder has contracted for the use of both the
equipment and personnel that were exercised. Where exercise credit is extended to all the plan
holders who are clients for an OSRO's equipment deployment exercise, each type of response
equipment being deployed in this manner should be exercised on an annual basis (as opposed
to once during the triennial cycle).

2.3.6.6	Types of Equipment to Be Deployed in Plan Holder Equipment Deployment
Exercises

2.3.6.6.1 Oil Response Systems

1.	Mechanical Skimming/Recovery Systems. One of each type of skimming system as listed
in the plan should be deployed. A skimming system includes containment boom, hoses,
piping, pumps, prime movers, support vessels, etc., necessary for the effective
operation of that system.

Types of skimming/recovery systems may include, but are not limited to:

a.	Oleophilic - Brush;

b.	Oleophilic - Disc;

c.	Oleophilic - Paddle belt;

d.	Oleophilic - Rope mop;

e.	Oleophilic - Sorbent lifting belt;

f.	Oleophilic - Submersion belt;

g.	Oleophilic - Submersion plane;

h.	Suction (including vacuum trucks);

i.	Weir;

j. Advancing weir; and

k. Special-purpose skimmers (e.g., fast water).

2.	In-Situ Burn (ISB) Systems. Each type of ISB system listed in the plan and relied on by the
plan holder in meeting response equipment capability requirements should be

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deployed, including boom, method of ignition, support vessels, and smoke plume
monitoring equipment. Use of ISB to actually burn oil is not allowed during an exercise.

3.	Aerial/Vessel Dispersant Systems. Each type of dispersant package listed in the plan and
relied on by the plan holder in meeting response equipment capability requirements
should be deployed, including dispersant delivery vehicles, application equipment, and
dispersed oil plume monitoring equipment. Use of actual dispersants is not allowed
during an exercise. Deployment exercises for dispersant equipment should include the
following:

a.	Dispersant spray aircraft should conduct actual spraying operations using water
during deployment exercises.

b.	Dispersant deployment exercises should use spotter aircraft to direct spray
operations, and spotting personnel should demonstrate familiarity with best
management practices for protecting wildlife.

c.	Aerial dispersant deployment exercises should be conducted offshore and far
enough out of sight of land to simulate expected flight conditions during actual
offshore spraying operations.

d.	Dispersant spray documentation systems, flight tracking and flight recording
systems, key communications equipment, and flow control and reporting
systems should be tested.

4.	Booming Systems. Booming systems include protective and containment boom not
exercised as part of a skimming or ISB system described above; 1,000 feet (or total
amount of boom listed in plan, whichever is less, particularly for inland plan holders
located near small water bodies) of each protective or containment boom system or
alternative system listed in the plan and relied on by the plan holder in meeting
response equipment capability requirements should be deployed. Protective boom
systems (boom and means of deploying and anchoring) include the following types:

a.	Fence boom;

b.	Curtain boom: Internal foam, external foam, self-inflatable, and pressure
inflatable;

c.	External tension boom;

d.	Tidal seal boom (only 50 feet of this type of boom need be deployed.);

e.	Special purpose;

f.	Ice booms;

g.	Fast-water booms (equipment and/or techniques intended to improve spill
containment/control in fast-water situations); and

h.	Alternative systems, particularly for inland plan holders, may include the
following:

i.	Temporary dams;

ii.	Underflow dams;

iii.	Weirs; and

iv.	Inflatable diaphragms for drainage culverts.

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These alternative systems may be used by the plan holder in the initial response
to an oil discharge in conjunction with booming systems, which may be used
further downstream in the planning distance.

5.	Oil Spill Surveillance and Tracking Systems. These systems include the use of remote
sensing and platforms used to conduct surveillance and track spilled oil, and to direct
the mechanical recovery, dispersant, and ISB operations for spilled oil.

6.	Source Control, subsea containment, and subsea dispersant injection equipment (SSDI).
See Section 6.5 on BSEE-Regulated Offshore Facilities for more information.

2.3.6.6.2 Salvage and Marine Firefighting Equipment Deployment Exercises

The owner or operator of vessels that have SMFF requirements should ensure that the SMFF
provider identified in the response plan exercises a representative sample of the SMFF
equipment described in 33 CFR §§ 155.4025 and 155.4030 for the following categories of SMFF
services, as applicable:

1.	Salvage assessment and survey;

2.	Stabilization;

3.	Specialized salvage operations;

4.	MFF assessment and planning; and

5.	Marine fire suppression.

The SMFF provider must be identified by contract or other approved means, with a funding
agreement, and the equipment deployment exercises must be documented according to PREP
Guidelines.

The SMFF provider should ensure that the same equipment and personnel are not used
repeatedly for each exercise. Documenting actual equipment deployment may be used to
satisfy this requirement. The ultimate goal is to exercise each type of equipment and personnel.
SMFF equipment should be deployed in each applicable operating area within the three-year
exercise cycle. Documentation of the use of equipment, such as heavy lift equipment deployed
on non-response operations, may be used to satisfy this requirement.

It is the vessel plan holder's responsibility to ensure that the contracted SMFF provider has
completed PREP equipment deployment exercise requirements. All vessel plan holders
identifying a contracted SMFF provider in their response plans should be able to document
completion of their equipment deployment requirements following receipt of exercise
information from the SMFF provider. Documentation of actual deployments may be accepted
to satisfy this requirement.

2.3.7 Unannounced Exercises

Unannounced exercises are one of the cornerstones of oil spill exercise requirements. They
provide plan holders and regulatory agencies with the opportunity to evaluate vessel and
facility response plan procedures for notifications, OSRO response time to the incident location,
and deployment of facility-owned or OSRO equipment.

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To maintain an adequate level of oil spill preparedness in the local area, it is highly important to
continually evaluate the readiness of OSROs to deploy their equipment during a realistic
scenario and fulfill obligations to their plan holders.

2.3.7.1	Plan Holder-Initiated Unannounced Exercises

Annually, plan holders (excluding plan holders regulated by BSEE) should ensure that one of the
following is conducted as an internally-initiated unannounced exercise:

1.	Emergency spill procedures exercise for vessels;

2.	Emergency procedures exercise for facilities (optional);

3.	IMT exercise; and

4.	Equipment deployment exercise.

Additionally, each vessel plan holder with SMFF requirements should ensure that one of the
following is conducted as an unannounced exercise:

1.	Emergency SMFF procedures exercise for vessels; and

2.	SMFF equipment deployment exercise for vessels.

An unannounced exercise is one in which the exercise participants do not have prior knowledge
of the exercise, as would be the situation in an actual spill and/or SMFF incident.

To satisfy OPA 90 requirements for unannounced drills and maintain an adequate posture for
response preparedness, it is necessary to have an exercise program comprised of both
announced and unannounced exercises. The annual unannounced exercise requirement is
necessary to maintain the level of preparedness to respond to a spill effectively.

A response to an actual spill may be considered for plan holder-initiated unannounced exercise
requirement credit, if the response was self-evaluated and required exercise objectives were
met and documented by the plan holder.

The emergency procedures exercise is being offered as an option for facilities, to provide an
additional exercise that may be conducted unannounced.

2.3.7.2	Government-Initiated Unannounced Exercises

GIUEs are compliance activities that allow regulatory agencies the opportunity to evaluate
various aspects of a plan holder's preparedness, including their emergency procedures and
their contracted OSROs' capabilities for proper and timely equipment deployment. The
frequency of these drills for the noted agencies is as follows:

1.	For USCG-regulated vessels and facilities, GIUEs are limited to a maximum of four
total per COTP zone per year.

2.	For EPA-regulated facilities, GIUEs are limited to 10 percent of the plan holders per
EPA region per year.

3.	For PHMSA-regulated facilities or pipelines, the number of GIUEs is determined by
DOT. DOT reserves the authority to conduct and require an operator to participate in

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a GIUE. A facility will not be required to participate in a GIUE more than once every 36
months, unless the results of previous exercises indicate that follow-up drills are
warranted due to inadequate performance during a drill.

4. For BSEE-regulated offshore facilities, the number of GIUEs is determined by the Oil
Spill Preparedness Division (OSPD) Chief. A facility will not participate in a BSEE-
initiated unannounced exercise more than once every 36 months, unless the results
of previous exercises indicate that follow-up drills are warranted due to inadequate
performance during a drill.

A plan holder directed to participate in a GIUE is required to do so unless specific conditions
exist that may result in safety hazards. The cost of the unannounced exercise will be borne by
the response plan holder.

Federal agencies are encouraged to engage other regulatory partners in conducting local joint
GIUEs to leverage scarce resources in order to more readily assess plan holder and OSRO
capabilities within the local area. Joint USCG and EPA GIUEs should include an AMPD scenario
for either the USCG-regulated or EPA-regulated portion of the facility. USCG units also have the
opportunity to participate in BSEE-led GIUEs. Members of the Area Committee are encouraged
to review and discuss the GIUE results to assess their overall preparedness.

For complex facilities that are regulated by two or more agencies, the exercising agency should
notify and invite the participation of the other agency(ies) and the responsible OSC in advance,
so as to minimize the possibility of the facility being exercised multiple times during a
compressed time period.

2.3.7.2.1 Successful Completion of Government-Initiated Unannounced Exercises

A facility that has successfully completed a GIUE will not be required to participate in another
GIUE for at least 36 months from the time of the last exercise. The facility must maintain
documentation of this participation.

A vessel that has successfully completed a GIUE will not be required to participate in another
GIUE in any USCG COTP zone for at least 36 months. The vessel must maintain documentation
of this participation. All other vessels covered by the same VRP will not be subject to a GIUE in
that COTP zone for 36 months, but may be subject to a GIUE in another USCG COTP zone.

Guidelines for determining successful completion of an exercise and for determining
enforcement actions (including, but not limited to, assessment of civil penalties) for an
unsuccessful exercise are the responsibility of the individual oversight agencies, based on
application of their individual agency regulations.

Each industry GIUE participant may follow the appropriate steps to document the exercise and
take credit, as prescribed in these Guidelines, for successful completion of the exercised portion
of their respective response plans.

For an exercise to be successful, it must meet the scope and objectives established for each
particular GIUE. For EPA- or USCG-led GIUEs, proper notifications and equipment deployment in
response to spill scenarios (vessel and facility) are the two primary objectives evaluated by the

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initiating authority. Failure to complete an exercise successfully indicates one or more of the
following:

1.	The plan holder could not properly implement its response plan.

2.	Response resources were not available or not in operating condition.

3.	Response personnel were not adequately trained in implementing the response plan.

Enforcement actions that may be necessary include, but are not limited to, successful
completion of an additional unannounced exercise, revisions to the approved response plan, or
administrative action by the initiating authority. It is the responsibility of the agency with
oversight of the regulated entity to develop specific guidelines for determining the successful
completion of an exercise and for determining appropriate enforcement actions for an
unsuccessful exercise.

One of the objectives for successful completion of an exercise is to demonstrate that the
response can be conducted in a timely manner. Note that the term "timely" is associated with a
planning rather than a performance standard. Timely is defined in Section 1 of these Guidelines
and is further discussed in specific portions of the Guiding Principles and in those sections of
these Guidelines that address specific exercise elements for vessels and facilities.

2.3.7.2.2 Marine Transportation-Related Facilities and Vessels Regulated by the
USCG

GIUEs test the ability of FRP and VRP holders to execute their plans in response to an AMPD.
GIUEs strengthen interagency and industry partnerships, and improve the COTP's awareness of
the plan holder's emergency procedures and local OSRO capabilities. A broad goal for all GIUEs
is that they result in a safe, timely, and effective response. Further discussion on GIUE scope
and objectives is detailed in Sections 3.14 and 3.15 of these Guidelines.

It is important to keep in mind that response timeframes in the regulations are planning
standards and not performance standards, and that the GIUE program focuses on AMPD. A
successful GIUE cannot be determined solely by a stopwatch, but rather through the subjective
evaluation of a variety of factors. Response time criteria are detailed in 33 CFR § 154.1045(c)
for facilities and 33 CFR § 155.1050 (d) for vessels. A general summary table of the response
times for Groups l-IV oils is provided:

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AMPD Planning Criteria: Response Times (From Spill Detection)

Vessel Response Plans

Facility Response Plans

Spill Site Location

On-scene deployment
of boom

On-scene deployment
of oil recovery and
storage equipment

On-scene deployment
of boom

On-scene deployment
of oil recovery and
storage equipment

Location of MTR
facility or 0-12 miles
from the nearest
shoreline

0-1 hour

0-2 hours

0-1 hour

0-2 hours

12-200 miles from the
nearest shoreline

1 hour + transit time
(assumes on-water
speed of 5 knots)

1 hour + transit time
(assumes on-water
speed of 5 knots)

N/A

N/A

Once the equipment is delivered on scene, personnel should be able to deploy and operate the
equipment without significant difficulty (e.g., people should generally be aware of locations of
equipment launch sites, anchoring points and deployment strategies). However, because
specific conditions vary at every site, deployments are not likely to be entirely seamless and
personnel may need to make adjustments that will delay completion of the deployment. In fact,
the ability to adjust to these differing environmental conditions may be an indicator of the
competence of response personnel.

While it is intended that equipment be in the water and operational before the end of a 4-hour
exercise period, there are circumstances, particularly related to safety and noninterference
with actual operations, that may delay completion of deployment beyond that time. In such a
case, exercises should continue until equipment is deployed and operated satisfactorily.

2.3.7.2.3 Non-Transportation-Related Facilities Regulated by the EPA

The measure of an effective GIUE will be the overall ability of the responders identified in the
FRP to rapidly and effectively control a small discharge, with particular attention to those
actions that afford the best chances to control a spill and minimize its impact in the first few
hours of the incident. While recognizing that an effective response to an oil discharge entails
the rapid deployment of proper equipment, it is not the intention of the EPA to use timeliness
as the sole factor when evaluating the response to a GIUE for a small discharge. EPA personnel
will evaluate whether the response equipment in the FRP arrives on time. These times are listed
in the FRP and are based on the response planning requirements in 40 CFR § 112. Whether the
containment boom and recovery devices specified in the FRP arrive precisely at the specified
times is less relevant than the overall conduct of the exercise and the successful achievement of
the exercise objective described in PREP. The objective of a GIUE for a small discharge includes
the following sub-objectives:

1.	Conducting proper notifications.

2.	Arrival of containment boom and/or alternative systems as specified in the FRP within
one hour of detection of the discharge and subsequent successful deployment. For
alternative systems using temporary dams or underflow dams, simulated installation of
these systems according to the FRP is expected to be performed for a successful GIUE.
For plans using both containment boom and alternative systems, successful boom

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deployment and simulated installation of the alternative systems is expected for a
successful GIUE.

3.	Arrival of oil recovery devices as specified in the approved FRP within two hours of
detection of the discharge and the subsequent successful operation/simulated recovery.

4.	Demonstrating the availability of adequate storage capacity for recovered oil.

5.	Properly conducting the exercise considering the size of a small discharge, including the
skill and competency of responders and material readiness of response equipment.

The failure to achieve any one sub-objective should not automatically indicate that an exercise
is a failure. EPA personnel evaluating the exercise should assess:

1.	The plan holder's ability to conduct proper notifications.

2.	Material readiness of response equipment.

3.	The overall ability of responding personnel to mobilize, arrive on scene in a timely
manner, properly deploy the containment boom, simulate recovery of oil, and
demonstrate skill and competency during the 4-hour exercise window.

The EPA exercise evaluator will have a subjective role in determining the success of the exercise
based on the achievement of the exercise objectives within the specified time. These
evaluations will be dependent on spill site and circumstances. EPA personnel may request to
review records of previous FRP exercises when there is a concern that the response time is
excessive. As the result of an unsuccessful exercise, the EPA may require the plan holder to
participate in additional GIUEs, revise the existing FRP, or both. Unsuccessful GIUEs may also
result in enforcement action against the plan holder.

2.3.8 Plan Holder Triennial Exercise Cycle

All components of a response plan must be exercised during the triennial exercise cycle.

Rather than requiring each plan holder to conduct an all-encompassing major exercise every
three years, the PREP cycle is designed for the various individual components to be exercised in
portions through a series of required exercises.

SPECIAL 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.

2.3.8.1 Exercise Plan Components

The Core Components that must be exercised during the triennial cycle are listed in Appendix A
of these Guidelines. Since not all of the components in Appendix A are necessarily applicable to
each and every plan, the plan holder should review the list of components in the appendix, and
identify those that are applicable to their specific plan, as appropriate. The plan holder would
then be responsible for ensuring that all of those components identified are exercised within
each triennial exercise cycle.

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These plan components may be exercised in segments over a period of three years, as long as
each component of the plan is exercised at least once within the three-year period.

The plan holder is responsible for documenting the components completed in each exercise.

2.3.8.2 Plan Holder Exercise Cycle

In the triennial cycle, at a minimum, the following exercises must be conducted:

1.	Quarterly Ql notification exercises. Vessels are required to conduct one each quarter
while in U.S. waters.

2.	One remote assessment and consultation exercise per plan holder.

3.	Quarterly emergency procedure exercises. For vessels, half (6) should address SMFF
scenarios. Emergency procedures exercises are optional for all facilities.

4.	Annual IMT exercise; one exercise per triennial cycle must involve a WCD scenario.

5.	Annual shore-based salvage exercises per plan and annual shore-based MFF
management team exercises per plan. Note that MFF exercises do not apply to NTVs
with oil capacities of less than 250 barrels.

6.	Annual plan holder-initiated unannounced exercises, which may be emergency spill
procedures, IMT exercises, or OSRO equipment deployment exercises. BSEE plan holders
are excluded. Note that plan holder-initiated unannounced exercises are not required
for BSEE-regulated facilities.

7.	Semiannual additional plan holder-initiated unannounced exercises for plans with
vessels having SMFF requirements, of which three are emergency SMFF procedure
exercises and three are SMFF equipment deployment exercises.

8.	Equipment Deployment Exercises:

a.	For vessel/facility owned and operated equipment: Semiannual plan holder
owned and operated equipment deployment exercises (for plan holders with
vessel/facility owned and operated equipment identified in their response plan).

b.	For vessels and facilities with OSROs identified for response equipment: Annual
OSRO equipment deployment exercises.

c.	For plan holders of vessels that have SMFF requirements: Annual SMFF
equipment deployment exercises.

d.	For PHMSA-regulated facilities or pipelines: Annual facility or pipeline equipment
deployment exercises, using either OSRO and/or operator owned equipment.

e.	For BSEE-regulated offshore facilities: Annual equipment deployment exercises
for equipment staged onshore. Semiannual equipment deployment exercises for
equipment staged offshore.

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2.3.9 Special Considerations

2.3.9.1	Fleet Plans

If an industry plan holder has developed one response plan that covers a fleet of vessels or
regional offshore platform operations, this plan holder would only be required to conduct one
"set" of exercises for the plan, with the exception of the Ql notification exercises (required for
all vessels and facilities) and the emergency procedures exercises (required for all manned
vessels and unmanned tank barges).

2.3.9.2	Complexes

Complexes are facilities that must meet the requirements of more than one federal agency. For
example, a facility that has oil storage tanks, a pipeline, and a waterfront oil transfer dock is
considered to be a complex since it must meet the requirements of EPA, PHMSA, and the USCG.

Complexes would only be required to conduct one exercise to meet all agency requirements for
that particular type of exercise. For example, if a quarterly notification exercise is required by
all three agencies regulating the complex, one notification exercise per quarter would satisfy
the requirements for all three regulatory agencies.

2.3.9.3	Vessels Serving as Secondary Carriers of Oil

Vessels serving as secondary carriers of oil should comply with the exercise requirements in 33
CFR§ 155.1045(g).

2.3.9.4	Trans-Alaska Pipeline Authorization Act Vessels and Facilities

Trans-Alaska Pipeline Authorization Act (TAPAA) vessels and facilities, in addition to complying
with the primary exercise requirements, must comply with the additional exercise
requirements identified in the VRP and FRP regulations at 33 CFR §§ 155.1125(a)(2) and
154.1125(a)(2), respectively.

2.3.9.5	Foreign Vessels Calling Only Occasionally at U.S. Ports

If a vessel plan holder has a VRP prepared with the intent that the vessel would occasionally call
on U.S. ports, the vessel plan holder must have an exercise program. If the plan holder is
following the PREP Guidelines, all exercises must be conducted at the frequency listed in the
PREP Guidelines. The only exceptions to this requirement are the Ql notification exercise and
remote assessment and consultation exercise, which are only required to be conducted while
operating in U.S. waters, otherwise upon entry into U.S. waters.

If a vessel enters U.S. waters for the first time but intends to continue trading, it must conduct
the Ql notification immediately, and then begin its exercise program. The vessel must conduct
a remote assessment and consultation exercise ONLY if the plan holder has NOT been subject
to such an exercise over the triennial cycle. Since PREP follows the calendar year, the triennial
cycle should begin as soon as the vessel enters U.S. waters. The vessel should remain on the
calendar year schedule (e.g., the next January 1 would begin Year 2 of the vessel's triennial
cycle). For the first year, the plan holder must complete one Ql notification and one emergency
procedures exercise each quarter during that year. Remote assessment and consultation

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exercises are only required on a per plan holder basis over a triennial exercise cycle. IMT and
equipment deployment exercises are recommended as soon as possible, but can be held up to
11 months after the date of the first entry into U.S. waters.

If the vessel only intends to make one voyage into U.S. waters, the vessel must conduct the Ql
notification immediately upon entry. The vessel must conduct a remote assessment and
consultation exercise ONLY if the plan holder has NOT been subject to such an exercise over the
triennial cycle. If the vessel intends to reenter U.S. waters at any time, it must comply with all
exercise requirements.

2.3.9.6	Railroad Tank Cars and Motor Vehicle Tank Trucks

Section 5 of these Guidelines (DOT/PHMSA-Regulated Facilities and Pipelines) is suitable for
certain transportation-related facilities located landward of the coastline. For additional
information on response planning requirements for railroad tank cars and motor vehicle tank
trucks transporting oil, see 49 CFR § 130. A railroad tank car or a tank truck that transfers oil to
or from certain vessels may be considered to be a mobile MTR facility and may be subject to
the response planning requirements in 33 CFR § 154. The loading and offloading of railroad
tank cars and tank trucks at certain non-transportation-related facilities may be covered by
response plans prepared by a facility owner or operator subject to the requirements contained
in 40 CFR § 112.

2.3.9.7	Group V Oils or Oils That May Exhibit Similar Qualities When Discharged into
the Environment

Due to the rapid expansion of Group V oils within the U.S. energy market, transportation of
Group V oils or oils that may exhibit similar qualities has increased. Therefore, plan holders
carrying Group V oils or oils that may exhibit similar qualities are highly encouraged to carry out
emergency procedure exercises, equipment deployment exercises, and IMT exercises focused
on scenarios involving Group V oil or oils that may exhibit similar qualities.

2.3.9.8	Vessels Serving as Facilities

MODUs, Mobile Inland Drilling Units (MIDUs) and floating production, storage, and offloading
(FPSO) vessels may be properly characterized as both facilities and vessels. They may be
regulated by more than one agency with respect to different functions or systems, and each
agency will have its own authority concerning these functions and systems. As such, it is up to
each agency to provide guidance regarding the applicability of the PREP Guidelines. When
MODUs and FPSO vessels are attached to the seabed for the purpose of exploring for,
developing, or producing oil and gas, the offshore facility PREP Guidelines administered by BSEE
apply to the systems and operations pertaining to these purposes. For vessel-oriented systems
that may cause oil spills on MODUs and FPSO, the vessel PREP Guidelines administered by USCG
apply. BSEE and the USCG will work closely together to ensure a coordinated approach to PREP
guidance and oversight with respect to these vessels whenever possible. For the purposes of
PREP, MIDUs are regulated by EPA.

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2.4 Area-level Exercises

2.4.1	Equipment Deployment Drills

Equipment deployment drills at the Area level historically involved USCG and EPA "first aid"
response equipment trailers and the USCG's prepositioned Vessel of Opportunity Skimming
Systems (VOSS) and shipboard Spilled Oil Recovery Systems (SORS) equipment. While SORS and
VOSS deployment drills for National Strike Force and Outside the Contiguous United States
(OCONUS)-located units will continue, deployments of VOSS systems as well as "first aid"
equipment in pre-positioned response trailers located throughout the contiguous United States
will no longer be required as part of the quadrennial Area exercise cycle.

2.4.2	IMT Discussion-Based Exercises

Area-level IMT discussion-based exercises should be conducted annually to test the
preparedness of the members of the Area Committee who will participate in an IMT and
oversee the implementation of the ACP during an incident. An IMT discussion-based exercise
does not need to be conducted the same year that the Area Committee conducts its
quadrennial operations-based FE/FSE.

2.4.3	Operations-Based, Functional or Full-Scale Exercises (FE/FSEs)

Area FE/FSEs, which exercise and test the overall preparedness of the Area Contingency Plans,
are conducted on a quadrennial schedule. The purpose of the Area FE/FSE is to exercise the
ACP and the response community in a particular Area. The response community is comprised of
the federal, state, and local government, industry, and tribal invitees. The Area FE/FSEs are also
designed to exercise the government and industry interface for spill response or response to a
significant threat of a spill.

The goal of the PREP is to conduct an Area FE/FSE for each ACP during each quadrennial cycle.
The design and execution of such exercises is a collaborative process involving the FOSC, the
Area Committee, and industry. Division of labor and level of effort among all government and
industry stakeholders is exercise-specific. The lead exercise planning role may be filled by either
USCG or EPA, industry, or a combination thereof. However, it is important that the design team
composition includes all appropriate stakeholders. A joint exercise design team should be
comprised of representatives from the federal, state, and local government agencies, the local
response community, and an industry plan holder. If applicable, tribal entities will be invited to
participate. The lead planning element, if one is designated, will coordinate the overall
execution of the Area FE/FSE; however, it remains the ultimate responsibility of the Area
Committee under the direction of the FOSC. The lead planning partner and the Area Committee
Chair will share the final decision-making authority for the design of the exercise, including the
scope and scenario.

A suggested mix of participants for industry plan holder participation in Area FE/FSEs would
include vessels, MTR facilities, onshore and certain offshore non-transportation-related
facilities, pipelines, and offshore facilities. Any industry participants should claim PREP credit
toward their triennial cycle requirements for participation in an Area FE/FSE.

The Area FE/FSEs do not have to be a WCD scenario. The primary purpose of the Area FE/FSE is
to activate and observe the response infrastructure in the Area and the ability of the response

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community to respond effectively to a spill or a significant threat of a spill. The focus should be
on the interaction between the industry plan holder as the RP and the federal, state, and local
government to exercise the ACP consistent with the NCP and in coordination with the RP's
response plan.

The following are recommendations for the Area FE/FSEs:

1.	Each exercise should be approximately 8-12 hours in duration and may be longer if
agreed to by the exercise design team.

2.	The Area's response mechanisms would be evaluated in each Area FE/FSE, including the
implementation of a UC capable of responding to a complex National Incident
Management System (NIMS) Type 3 incident scenario.

a. In a complex Type 3 incident:

i.	Multiple operational periods are expected.

ii.	Response resources may be required from out of the Area, including
regional and/or national resources.

iii.	Most or all of the command and general staff positions are filled.

iv.	A written IAP is required for each operational period.

v.	At least one WCD capability must be tested.

3. The exercise scenario may involve some amount of equipment deployment, which
should be determined by the lead planning partner after consulting with the exercise
design team.

It is recommended that equipment deployments during an Area FE/FSE should test various
response strategies contained in the ACP and relevant geographic response strategies (this
includes existing Geographic Response Plans (GRPs)). Equipment deployments can include, but
are not limited to:

1.	Protective booming for shoreline, fish, wildlife, and sensitive environmental areas;

2.	Fast-water, open-water, or shallow-water containment and collection; or

3.	Dispersant or ISB operations.

Equipment deployment drills do not need to be conducted simultaneously with an IMT-
focused, discussion-based portion of the exercise. They may be done several weeks or even
months before or after the IMT portion to allow more efficient allocation of exercise planning
and resources.

An industry plan holder that participates in an Area FE/FSE should not be required to
participate in another Area FE/FSE for a minimum of six years.

Each exercise partner is responsible for funding their own participation in Area FE/FSE.

An After Action Report should be completed no later than 60 days after the completion of the
Area FE/FSE. The After Action Report is completed by a joint evaluation team. The results of

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Area FE/FSEs within the coastal zone will be entered in the Coast Guard's lessons learned
database for exercises (Contingency Preparedness System (CPS)).

2.4.4	Area Exercise Scheduling

Scheduling of Area FE/FSEs will be done under a nationally coordinated system that involves
the federal, state, and local governments and industry plan holders, and that recognizes the
unique needs of specific geographic regions of the country.

For EPA Areas with Subarea plans or annexes to the ACP, the EPA Regional Administrator
shall decide which Subarea plan is to be exercised.

2.4.5	PREP Compliance, Coordination and Consistency Committee (PREP 4C)

The PREP 4C is responsible for scheduling Area FE/FSEs. The PREP 4C is comprised of personnel
representing the four federal regulating agencies:

1.	USCG;

2.	EPA;

3.	PHMSA; and

4.	BSEE.

2.4.6	Scheduling Process

The PREP 4C is charged with developing and publishing a proposed Area FE/FSE schedule for
each quadrennial exercise cycle. This proposed schedule will be posted and announced on the
PREP 4C Website. Area FE/FSEs are scheduled in advance to allow both Area Committees and
industry plan holders to allocate sufficient funds and personnel resources to plan and conduct
the exercises. The PREP 4C will solicit comments on the proposed schedule and industry plan
holders to lead and participate in the Area FE/FSEs. It is important to note that the PREP 4C only
proposes which ACPs will be exercised during the given exercise cycle. It is incumbent on the
Area Committees with jurisdiction over an Area to validate the proposed timeframe and to
identify the industry plan holder who will participate in the exercise. Each Area Committee
should work with the local industry to identify industry plan holders in advance of the
scheduled exercise. Industry plan holders may also provide input into the scheduling process
through the Area Committees.

2.4.7	Other Credit Considerations
2.4.7.1 Credit for Response

2.4.7.1.1 Credit for Plan Holder Response

Plan holders may take credit for responses to actual spills or releases, or to significant threats of
a spill, instead of conducting exercises. The response must be evaluated. The plan holder must
determine which exercise requirements were met during the response. This determination
should be based on whether the response effort would meet the objectives of the exercise
requirements as listed in the PREP Guidelines.

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2.4.7.1.2 Area FE/FSE Credit for Response

Authorized PREP 4C agency representatives may grant credit for responses to actual spills or
releases in lieu of conducting Area FE/FSEs based on the recommendations of the FOSC. Area
FE/FSE credit may be given for participation in an actual response to a discharge of oil or
release of a hazardous substance, pollutant, or contaminant if the following circumstances
exist:

1.	The ACP was used in the response.

2.	The response involved the appropriate members of the response community in a UC
structure.

3.	The objectives of an Area FE/FSE were met as outlined in the PREP Guidelines.

4.	The response was evaluated.

5.	The response was properly documented, including detailed information on how each of
the major objectives listed in the report were met.

6.	The names of all OSROs and SMFF providers activated, a listing of the equipment
deployed, and the following information included:

a.	A copy of the initial Incident Action Plan (IAP), Incident Command System (ICS)
Form 202; and

b.	A discussion of the spill response procedures that were used.

Requests for credit should be routed through the appropriate agency (EPA or USCG) for
submission to the PREP 4C. The PREP 4C convenes quarterly.

2.4.7.2 Proper Documentation for Self-Certification of Plan Holder Exercises

Proper documentation for self-certification of an exercise should include, at a minimum, the
following information:

1.	Type;

2.	Date and time;

3.	Description;

4.	Objectives met;

5.	Core components (from Appendix A) exercised; and

6.	Lessons learned.

This documentation must be in writing and signed by an authorized representative of the plan
holder organization.

Sample documentation may be available online at the USCG National Strike Force Coordination
Center (NSFCC) website.

As a general rule, exercise documentation should be completed within 60 days of the exercise,
although this may vary depending upon exercise complexity.

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PREP Guidelines do not create binding legal requirements.

While the PREP Guidelines have been developed with the regulated community, they are not legally binding
substantive rules. Plan holders can accept the PREP Guidelines to fulfill the exercise requirements of OPA 90.
An alternative program can also be acceptable, subject to approval by the USCG Office of Marine
Environmental Response (CG-MER) in accordance with the applicable response plan exercise regulations:

•	Facility Response Plans (33 CFR § 154.1055)

•	Tank Vessel Response Plans (33 CFR § 1060)

•	Salvage and Marine Firefighting (33 CFR § 155.4052)

•	Nontank Vessel Response Plans (33 CFR §§ 155.5060 and 155.5061)

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Facility.



Quarterly.



Facility owner or operator.



Facility personnel and Ql.



Exercise communications between facility personnel and Ql.



Voice contact and confirmation must be made with a Ql as detailed in the plan. Electronic messaging
may be used only if communication by voice is not possible.



Self-certification.



USCG COTP/FOSC.



Three years.



Records to be kept at the facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Manned tank vessels and NTVs carrying oils as cargo or fuel.



Quarterly while operating in U.S. waters, including the EEZ; otherwise, upon entry into U.S. waters, not
to exceed four times per year. The Ql notification exercise is not required for ships outside U.S. waters.



Master or designee according to the procedure established in the VRP.



Vessel personnel, plan-designated shore-side personnel, including a vessel's Ql.



Exercise communication between vessel personnel and Ql.



Contact by telephone or radio and confirmation must be made with a Ql as detailed in the plan.
Electronic messaging may be used only if communication by voice is not possible.



Self-certification.



USCG COTP/FOSC.



Three years.



On board the vessel.

These exercises may be documented in the vessel log or may be kept in a separate exercise log.



Self-evaluation.

Owner or operator should conduct review to determine if objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Unmanned tank barge.



Quarterly while operating in U.S. waters, including the EEZ; otherwise, upon entry into U.S. waters, not
to exceed four times per year. The Ql notification exercise is not required for tank barges outside U.S.
waters.



Tank barge owner or operator or designee, according to the procedure established in the VRP.



Tank barge custodian, plan-designated shore-side personnel, and Ql.



Exercise communication between tank barge custodian and Ql.



A.	Contact by telephone or radio and confirmation must be made with a Ql as detailed in the plan.
Electronic messaging may be used only if communication by voice is not possible.

B.	Exercises should be conducted randomly to ensure that all tank barge custodians have an equal
chance to participate in the notification exercises.



Self-certification.



USCG COTP/FOSC.



Three years.



Records to be kept on board the barge or with the VRP for the barge.



Self-evaluation.

Owner or operator should conduct a review to determine if objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Manned tank vessels and NTVs carrying oils as cargo or fuel.



Note: NTVs with a capacity of less than 250 barrels of oil are not required to plan SMFF resources for
fire scenarios, and their exercises should be designed accordingly.



Triennially per plan holder while operating in U.S. waters, including the EEZ; otherwise, upon entry into
U.S. waters. The remote assessment and consultation exercise is not required for vessels operating
outside U.S. waters.



Vessel owner or operator, vessel master, or designee, according to the procedure established in the
VRP.



VRP-designated vessel and shore-side personnel for activation of and provision of remote assessment
and consultation services.



Contact the Ql and/or the SMFF remote assessor as specified in the approved VRP by telephone, radio,
or other means of communications to discuss a shipboard response scenario as detailed in the VRP.
Electronic messaging may be used for the initial contact only if communication by voice is not possible.



A. Following VRP notification/activation procedures, the information communicated from the vessel
to the remote assessor identifies a general scenario type from the VRP's shipboard emergency
procedures section (e.g., collision, excessive list, fire). Confirm that remote assessor has the VRP
shipboard emergency procedures section of the VRP.



B. Remote assessment and consultation for a fire scenario must be exercised triennially, except for
NTVs with oil capacity less than 250 barrels, which are exempt from planning for fire response. The
remote assessor listed in the VRP (identified by contract and funding agreement) advises the
vessel what on-scene situational information would facilitate his or her preliminary assessment of
the vessel's status, given the type of scenario.



C. Vessel and assessor establish a communication process that would support completion of the
vessel's stability and structural integrity assessment through use of a salvage software program.



D. For all applicable VRPs where there are different remote assessment resources contracted for
salvage and for MFF, separate exercises involving the salvage remote assessor and the MFF
remote assessor must be conducted.



Self-certification.



USCG COTP/FOSC.



Three years.



Onboard the vessel.



Records must also be maintained at the U.S. location of the Ql, the vessel owner or operator, the IMT,
or the SMFF provider, as designated in the VRP.



Self-evaluation.

Owner or operator should conduct a review to determine if objectives have been met.



NOTE: These exercises may be conducted concurrently with the quarterly Ql notification exercises or
shipboard emergency procedures exercise.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Vessel custodian for unmanned tank barges carrying oil as cargo or fuel.



Triennially per plan holder while operating in U.S. waters including the EEZ. The remote assessment
and consultation exercise is not required for vessels operating outside U.S. waters.



Tank barge owner or operator, or designee, according to the procedure established in the VRP.



Vessel custodian and a vessel's VRP-designated shore-side personnel for activation of remote
assessment and consultation services.



Contact the Ql and/or the SMFF remote assessor as specified in the approved VRP, by telephone, radio,
or other means of communications to discuss a barge response scenario as detailed in the VRP.
Electronic messaging may be used for the initial contact only if communication by voice is not possible.



A.	Following VRP notification/activation procedures, the information communicated from the vessel
custodian to the remote assessor identifies a general scenario type from the VRP's shipboard
emergency procedures section (e.g., collision, excessive list, fire).

B.	Remote assessment and consultation for a fire scenario must be exercised triennially.

C.	The remote assessor listed in the VRP (identified by contract and funding agreement) advises the
vessel custodian what on-scene situational information would facilitate his or her preliminary
assessment of the vessel's status, given the type of scenario.

D.	Vessel and assessor establish a communication process that would support completion of the
vessel's stability and structural integrity assessment through the use a salvage software program.

E.	For all applicable vessels and where there are different remote assessment resources contracted
for salvage and for MFF separate exercises involving the salvage remote assessor and the MFF
remote assessor must be conducted..



Self-certification.



USCG COTP/FOSC.



Three years.



Records to be kept on board the barge and with the VRP for the barge.



Self-evaluation.

Owner or operator should conduct review to determine whether or not objectives have been met.



NOTE: These exercises may be conducted concurrently with the quarterly Ql notification exercises or
shipboard emergency procedures exercise.

Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Manned tank vessels and NTVs carrying oil as cargo or fuel.



Quarterly.



Master or designee, according to the procedure established in the VRP.



Vessel personnel.



Exercise the emergency procedures for the vessel crew to mitigate or prevent any discharge or a
substantial threat of such discharge of oil as described in the shipboard spill mitigation procedures
section of the VRP.



A.	Conduct an exercise of the vessel's emergency procedures to ensure crew knowledge of actions to
be taken to mitigate a spill. This exercise may consist of a walk-through of the crew's actions.

B.	Exercise should involve one or more of the emergency scenarios/procedures described in the
shipboard spill mitigation section of the VRP.

C.	Annually ensure that spill mitigation procedures for contingencies identified in the VRP have been
exercised and, for vessels with SMFF requirements, half of the exercises address emergency
procedures with an SMFF component.



Self-certification.



USCG COTP/FOSC.



Three years.



Logbook entry.

These exercises may be documented in the vessel log or may be kept in a separate exercise log.



Self-evaluation.

Owner or operator should conduct review to determine whether or not objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Tank barge(s).



Quarterly.



Tank Barge owner or operator, or designee, according to the procedure established in the VRP.



Tankerman or designee, as established in the VRP.



Exercise the emergency procedures to mitigate or prevent any discharge or a substantial threat of such
discharge of oil as described in the shipboard spill mitigation procedures section of the VRP.



A.	Conduct a walk-through of the emergency procedures.

B.	Ensure tank barge custodians know proper actions to take in the event of an oil discharge or
substantial threat of such discharge, including incidents requiring SMFF response.



Self-certification.



USCG COTP/FOSC.



Three years.



These exercises may be documented in the vessel log or may be kept in a separate exercise log.
Records to be kept on board the tank barge or with the VRP for the tank barge



Self-evaluation.

Owner or operator should conduct review to determine whether or not objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Facility.



Quarterly.



Facility owner or operator.



Facility personnel.



Exercise the emergency procedures for the facility to mitigate or prevent any discharge, or a
substantial threat of such discharge, of oil resulting from facility operational activities associated with
oil transfers.



A.	Conduct an exercise of the facility's emergency procedures to ensure personnel knowledge of
actions to be taken to mitigate a spill. This exercise may consist of a walk-through of the
emergency procedures.

B.	Exercise should involve one or more of the sections of the emergency procedures for spill
mitigation. For example, the exercise should involve a simulation of a response to an oil spill.

C.	The facility should ensure that spill mitigation procedures for all contingencies at the facility are
addressed at some time.



Self-certification.



USCG COTP/FOSC.



Three years.



At each facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

*This section describes an optional exercise to provide facilities with an exercise that may be conducted unannounced to fulfill the
requirement for a plan holder-initiated unannounced exercise.

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Facility IMT.



Annually.



Facility owner or operator.



IMT as established in the response plan.



Exercise the IMT's organization, communication, and decision-making in managing a spill response.



Exercise the IMT in a review of:

A.	Knowledge of the response plan;

B.	Proper notifications;

C.	Communications system;

D.	Ability to access an OSRO;

E.	Coordination of internal organization personnel with responsibility for spill response;

F.	Annual review of the transition from a local team to a regional, national, and international team as
appropriate;

G.	Ability to effectively coordinate spill response activity with the NRS infrastructure (If personnel
from the NRS are not participating in the exercise, the IMT should demonstrate knowledge of
response coordination with the NRS);

H.	Ability to access information in the ACP for location of sensitive areas, resources available within
the area, unique conditions of area, etc.; and

I.	Minimum of one IMT exercise in a triennial cycle must involve simulation of a WCD scenario.



Self-certification.



USCG COTP/FOSC.



Three years.



At each facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may be
claimed for an actual response when these objectives are met, the response is evaluated, and a proper
record is generated.

Plan holders are responsible for ensuring that IMTs are familiar with Area Committees/RRTs and ACPs
in every Area in which the plan holder operates. While it is not practicable to require an IMT to exercise
in every Area/region in which they offer coverage each year, each IMT is expected to review ACPs
annually and the makeup of Area Committees/RRTs in all Areas in which they offer coverage. Self-
certification for exercise credit should include IMT certification that the IMT has completed an annual
review and is familiar with the ACPs and Area Committees/RRTs in all Areas in which the plan holder
operates.

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Tank vessels and NTVs carrying oil as cargo or fuel.



Annually.



Company policy.



IMT as established in the VRP.



Exercise the IMT's organization, communication, and decision-making in managing a response.



Exercise the IMT in a review of:

A.	Knowledge of the response plan;

B.	Proper notifications;

C.	Communications system;

D.	Ability to access resource providers;

E.	Coordination of internal organization personnel with responsibility for response;

F.	Annual review of the transition from a local team to a regional, national, and international team as
appropriate;

G.	Ability to effectively coordinate response activity with the NRS infrastructure (If personnel from
the NRS are not participating in the exercise, the IMT should demonstrate knowledge of response
coordination with the NRS);

H.	Ability to access information in the ACP for location of sensitive areas, resources available within
the area, unique conditions of area, etc.;

I.	Minimum of one IMT TTX in a triennial cycle must involve simulation of a WCD scenario;

J. For any chemical or biological countermeasures or in-situ burning cited in the VRP, the ability to
prepare and submit a request and usage plan to the FOSC/RRT. Each such countermeasure listed in
the plan will be exercised during the triennial cycle; and

K. When applicable to submit a request for aerial/vessel applied dispersants, American Petroleum
Institute (API) Technical Report 1148 contains an example of a Daily Aerial/Vessel Dispersant
Application Plan that may be appropriate for use in this situation.



Self-certification.



USCG COTP/FOSC.



Three years.



At the U.S. location of the Ql, IMT, vessel owner/operator, resource provider, as established in the VRP.



Self-evaluation.

Owner or operator should conduct review to determine whether or not objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.



Plan holders are responsible for ensuring that IMTs are familiar with Area Committees/RRTs and ACPs
in every Area in which the plan holder operates.

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Tank vessels and NTVs carrying oil as cargo or fuel.



One salvage exercise per year.



Company policy.



Salvage management team as established in the response plan.



Exercise the management team's organization, communication, and decision-making in managing a
salvage response.



Exercise the salvage management team in a review of:

A.	Knowledge of the response plan;

B.	Proper notifications;

C.	Communications system;

D.	Ability to access an salvage provider;

E.	Coordination of internal organization personnel with responsibility for spill prevention and
salvage:

1.	Remote assessment and consultation;

2.	Begin assessment of structural stability;

3.	On-site salvage assessment;

4.	Assessment of structural stability;

5.	Hull and bottom survey;

6.	Emergency towing;

7.	Salvage plan;

8.	External emergency transfer operations;

9.	Emergency lightering (not required for NTVs under 250 barrel oil capacity);

10.	Other refloating methods;

11.	Making temporary repairs;

12.	Diving services support;

13.	Special salvage operations plan;

14.	Subsurface product removal; and

15.	Heavy lift.

F.	Annual review of the transition from a local team to a commercial, regional, national, and
international team as appropriate;

G.	Ability to coordinate response activity effectively with the IMT and NRS infrastructure (if personnel
from the IMT or NRS are not participating in the exercise, the response team should demonstrate
knowledge of response coordination with the IMT or NRS); and

H.	Ability to access information in the ACP for resources available within the area, unique conditions
of the area, etc.



Self-certification.



USCG COTP/FOSC.



Three years.



At the U.S. location of the Ql, IMT, the vessel owner or operator, or primary salvage provider, as
indicated in the VRP.

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Self-evaluation.

Owner or operator should conduct review to determine whether or not objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

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Tank vessels and NTVs carrying oil as cargo or fuel. (Not required for NTVs with an oil capacity of less
than 250 barrels.)



One MFF exercise per year.



Company policy.



MFF management team as established in the response plan.



Exercise the management team's organization, communication, and decision-making in managing an
MFF response.



Exercise MFF management team in a review of:

A.	Knowledge of the response plan and when exercising the MFF team, the pre-fire plan;

B.	Proper notifications;

C.	Communications system;

D.	Ability to access a MFF provider;

E.	Coordination of internal organization personnel with responsibility for spill prevention and MFF;

F.	Remote assessment and consultation;

G.	On-site fire assessment;

H.	External firefighting teams;

I.	External vessel firefighting systems.

J. Annual review of the transition from a local team to a commercial, regional, national, and
international team as appropriate;

K. Ability to coordinate response activity effectively with the IMT and NRS infrastructure (if personnel
from the IMT or NRS are not participating in the exercise, the response team should demonstrate
knowledge of response coordination with the IMT or NRS); and

L. Ability to access information in the ACP for resources available within the area, unique conditions
of the area, etc.



Self-certification.



USCG COTP/FOSC.



Three years.



At the U.S. location of the Ql, IMT, the vessel owner or operator, or primary MFF provider, as indicated
in the VRP.



Self-evaluation.

Owner or operator should conduct review to determine whether or not objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

USCG PREP EXERCISES | PAGE 3-14


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Facilities with facility-owned and operated response equipment.



Semiannually.



Facility owner or operator.



Facility personnel.



A.	Deploy and operate facility-owned and operated response equipment identified in the response
plan. The equipment to be deployed would be the equipment necessary to respond to an AMPD at
the facility.

B.	All of the facility's personnel involved in equipment deployment operations must be included in a
comprehensive training program and a comprehensive maintenance program. Credit should be
taken for deployment conducted during training. The maintenance program must ensure that the
equipment is periodically inspected and maintained in good operating condition in accordance
with the manufacturer's recommendations and best commercial practices. All inspection and
maintenance must be documented by the owner.



A.	Demonstrate ability of facility personnel to deploy and operate equipment.

B.	At least annually, conduct deployment of dispersant application resources, if applicable.

C.	Ensure equipment is in proper working order.



Self-certification.



USCG COTP/FOSC.



Three years.



Records to be kept at facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

Note: If a facility with facility-owned and operated equipment also identifies OSRO equipment in its response plan, the OSRO
equipment must also be deployed and operated in accordance with the equipment deployment requirements for OSRO-owned
equipment.

USCG PREP EXERCISES | PAGE 3-15


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Facilities with OSRO response equipment cited in their response plan.



Annually.



Facility owner or operator.



Facility owner or operator and OSRO.



A.	Deploy and operate response equipment identified in the response plan for an AMPD response.

B.	All OSRO personnel involved in equipment deployment operations must be included in a
comprehensive training program and a maintenance program. Credit should be taken for
equipment deployment conducted during training. The maintenance program must ensure that
the equipment is periodically inspected and maintained in good operating condition in accordance
with the manufacturers' recommendations and best commercial practices. The OSRO must provide
inspection and maintenance information to the owner or operator.

C.	Plan holders must ensure that when a regional OSRO is identified in the response plan, the OSRO
conducts annual equipment deployment exercises in each operating environment for each USCG
Contingency Planning Area.



A.	Demonstrate the ability of the personnel to deploy and operate equipment.

B.	At least annually, conduct deployment of dispersant application resources, if applicable.

C.	Ensure the response equipment is in proper working order.



The facility owner or operator should ensure that the OSRO identified in the response plan provides
adequate documentation that the requirements for this exercise have been met.



USCG COTP/FOSC.



Three years.



Records to be kept at the facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

USCG PREP EXERCISES | PAGE 3-16


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Vessels with OSRO and SMFF equipment cited in their plans.



Annual OSRO exercise and Annual SMFF exercise.



Company policy.



Vessel owner or operator and OSRO, or vessel owner or operator and SMFF provider.



A.	Deploy and operate OSRO or SMFF response equipment identified in the response plan for an
AMPD response. There is no minimum amount of equipment prescribed for SMFF exercises.

B.	All OSRO personnel involved in equipment deployment operations must be included in a
comprehensive training program and a comprehensive maintenance program. Credit should be
taken for equipment deployment conducted during training. The maintenance program must
ensure that the equipment is periodically inspected and maintained in good operating condition in
accordance with the manufacturer's recommendations and best commercial practices. The vessel
owner or operator must ensure that equipment inspection and maintenance is documented.
OSROs must provide inspection and maintenance information to the vessel owner or operator.

C.	SMFF providers are encouraged to develop and implement a comprehensive training program for
their personnel, and implement a comprehensive maintenance program for their equipment,
which should be made available to vessel owners and operators.

D.	Plan holders must ensure that when a regional OSRO or SMFF provider is identified in the response
plan, the OSRO or SMFF provider conducts annual equipment deployment exercises in each
operating environment for each USCG Contingency Planning Area.



A.	Demonstrate the ability of the personnel to deploy and operate response equipment.

B.	At least annually, conduct deployment of dispersant application resources, if applicable.

C.	Ensure the response equipment is in proper working order.



The vessel owner or operator should ensure that the OSRO and SMFF resource providers identified in
the response plan provide adequate documentation that the requirements for this exercise have been
met.



USCG COTP/FOSC.



Three years.



At the U.S. location of the Ql, IMT, vessel owner or operator, OSRO, or SMFF provider, as indicated in
the VRP.



Self-evaluation.

Owner or operator should conduct review to determine whether or not objectives have been met.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

SMFF providers may document operational deployment of their equipment for credit when these
objectives are met, the deployment is evaluated, and a proper record is generated.

USCG PREP EXERCISES | PAGE 3-17


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MTR FRP holders within the Area.



As selected; plan holders who have successfully completed a GIUE will not be required to participate in
another one for at least 36 months from the date of the exercise.



USCG.



MTR, and Mobile MTR FRP holders.



A.	Unannounced exercises are limited to a maximum of four exercises per Area per year.

B.	Exercises are limited to approximately four hours in duration.

C.	Exercises must involve response to an AMPD scenario.



Conduct proper notifications and equipment deployment to respond to an unannounced scenario of an
AMPD. Demonstrate that the response is:

1.	Timely: As a general rule, the regulatory planning standard is containment equipment (e.g.,
booms) on scene within one hour of notification and recovery equipment (e.g., skimmers and
temporary storage) on scene within two hours. Therefore, in a GIUE, a plan holder should be
able to initiate a simulated cleanup or SMFF response within approximately two hours of
exercise commencement;

2.	Conducted with adequate amount of equipment deployed for the given scenario; and

3.	Properly conducted.



USCG COTP/FOSC.



USCG COTP/FOSC.



Three years.



At the facility.



Evaluation to be conducted by initiating agency.



Plan holder may receive credit for other required exercises (a Ql notification, equipment deployment
exercise, and unannounced exercise) if the GIUE is successfully completed, objectives of the other
exercise(s) are met, and a proper record is generated.

USCG PREP EXERCISES | PAGE 3-18


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Vessel response plan holders within the Area.



As selected; plan holders who have successfully completed a GIUE will not be required to participate in
another one for at least 36 months from the date of the exercise.



USCG does not routinely require SMFF providers to participate in unannounced exercises. USCG has
and reserves the authority to conduct and require a plan holder's SMFF provider to participate in a
USCG GIUE.



USCG.



Vessel.



A.	Unannounced exercises are limited to a maximum of four exercises per Area per year.

B.	Exercises are limited to approximately four hours in duration.

C.	Exercises must involve response to an AMPD scenario.

D.	SMFF scenarios are applicable only to tank vessels and NTVs and to unmanned tank barges
carrying oil.



A.	Conduct proper notifications and equipment deployment to respond to an unannounced scenario
of an AMPD. Demonstrate that the response is:

1.	Timely: As a general rule, the regulatory planning standard is containment equipment (e.g.,
booms) on scene within one hour of notification and recovery equipment (e.g., skimmers and
temporary storage) on scene within two hours. Therefore, in a GIUE, a plan holder should be
able to initiate a simulated cleanup or SMFF response within approximately two hours of
exercise commencement;

2.	Conducted with adequate amount of equipment deployed for the given scenario;

3.	Properly conducted.

B.	SMFF scenarios should include mobilization of remote and on-site salvage assessment personnel,
and initiation of the assessment processes. For firefighting scenarios, this includes making the
applicable vessel pre-fire plan accessible to firefighting personnel.



USCG COTP/FOSC.



USCG COTP/FOSC.



Three years.



In accordance with 33 CFR § 155.1060(e)(2).



Evaluation to be conducted by initiating agency.



Plan holder may receive credit for other required exercises (a Ql notification, equipment deployment
exercise, and unannounced exercise) if the GIUE is successfully completed, objectives of the other
exercise(s) are met, and a proper record is generated.

USCG PREP EXERCISES | PAGE 3-19


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USCG PREP EXERCISES | PAGE 3-20


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PREP Guidelines do not create binding legal requirements.

While the PREP Guidelines have been developed with the regulated community, they cannot be considered to
be legally binding substantive rules. Plan holders can accept the PREP Guidelines to fulfill the exercise
requirements of OPA 90. An alternative program can also be acceptable, subject to approval by the EPA
Regional Administrator (see 40 CFR § 112.21). Either the PREP Guidelines or the EPA-approved exercise
program developed by the plan holder become binding when referenced in the submitted response plan.

Note: For purposes of the PREP guidelines, the use of "inland" in the header for the following exercises
includes non-transportation-related onshore and offshore facilities located landward of the coastline.

EPA PREP EXERCISES | PAGE 4-1


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Facility.



Quarterly.



Facility owner or operator.



Facility personnel and Ql.



Exercise communications between facility personnel and Ql.



Voice contact and confirmation must be made with a Ql as detailed in the plan. Electronic messaging
may be used only if communication by voice is not possible.



Self-certification.



EPA.



Five years.



Records to be kept at the facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

EPA PREP EXERCISES | PAGE 4-2


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Facility.



Quarterly.



Facility owner or operator.



Facility personnel.



Exercise the emergency procedures for the facility to mitigate or prevent any discharge or a substantial
threat of such discharge of oil resulting from facility operational activities associated with oil transfers.



A.	Conduct an exercise of the facility's emergency procedures to ensure personnel knowledge of
actions to be taken to mitigate a spill. This exercise may consist of a walk-through of the
emergency procedures.

B.	Exercise should involve one or more of the sections of the emergency procedures for spill
mitigation; e.g., the exercise may involve a simulation of a response to an oil spill.

C.	Facility should ensure that spill mitigation procedures for all contingencies at the facility are
addressed at some time.



Self-certification.



EPA.



Five years.



At each facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

*This is offered as an optional exercise to provide facilities with an exercise that may be conducted unannounced to fulfill the
requirement for plan holder-initiated unannounced exercises.

EPA PREP EXERCISES | PAGE 4-3


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Facility IMT.



Annually.



Facility owner or operator.



IMT as established in the response plan.



Exercise the IMT's organization, communication, and decision-making in managing a response.



Exercise the IMT in a review of:

A.	Knowledge of the response plan;

B.	Proper notifications;

C.	Communications system;

D.	Ability to access an OSRO;

E.	Coordination of internal organization personnel with responsibility for response;

F.	Annual review of the transition from a local team to a regional, national, and international team as
appropriate;

G.	Ability to effectively coordinate response activity with the NRS infrastructure (If personnel from
the NRS are not participating in the exercise, the IMT should demonstrate knowledge of response
coordination with the NRS);

H.	Ability to access information in ACP for location of sensitive areas, resources available within the
area, unique conditions of area, etc.; and

I.	Minimum of one IMT exercise in a triennial cycle would involve simulation of a WCD scenario.



Self-certification.



EPA.



Five years.



At each facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

EPA PREP EXERCISES | PAGE 4-4


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Facilities with company-owned and operated response equipment and facilities with company-owned
response equipment, but operated by the OSRO.



Semiannually.



Facility owner or operator.



Facility personnel.



A.	Deploy and operate facility-owned and operated response equipment identified in the response
plan. The equipment to be deployed would be the equipment necessary to respond to a small
discharge at the facility.

B.	All of the facility personnel involved in equipment deployment operations must be included in a
comprehensive training program and a comprehensive maintenance program. Credit should be
taken for deployment conducted during training. The maintenance program must ensure that the
equipment is periodically inspected and maintained in good operating condition in accordance
with the manufacturer's recommendations and best commercial practices. All inspection and
maintenance must be documented by the owner.



A.	Demonstrate ability of facility personnel to deploy and operate equipment.

B.	Ensure equipment is in proper working order.



Self-certification.



EPA.



Five years.



Records to be kept at the facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

Note: If a facility with facility owned and operated equipment also identifies OSRO equipment in its response plan, the OSRO
equipment must also be deployed and operated in accordance with the equipment deployment requirements for OSRO-owned
equipment.

EPA PREP EXERCISES | PAGE 4-5


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Facilities with OSRO response equipment cited in their response plan.



Annual.



Facility owner or operator.



Facility owner or operator and OSRO.



A.	Deploy and operate response equipment identified in the response plan. The equipment to be
deployed would be the equipment necessary to respond to a small discharge at the facility.

B.	All of the OSRO personnel involved in equipment deployment operations must be included in a
comprehensive training program and a comprehensive maintenance program. Credit should be
taken for equipment deployment conducted during training. The maintenance program must
ensure that the equipment is periodically inspected and maintained in good operating condition in
accordance with the manufacturer's recommendations and best commercial practices. The OSRO
must provide inspection and maintenance information to the owner or operator.

C.	Plan holders must ensure that when a regional OSRO is identified in the response plan, the OSRO
conducts annual equipment deployment exercises in each operating environment for each USCG
or EPA Contingency Planning Area, or EPA Subarea (where identified).



A.	Demonstrate the ability of the personnel to deploy and operate response equipment.

B.	Ensure the response equipment is in proper working order.



The facility owner or operator should ensure that the OSRO identified in the response plan provides
adequate documentation that the requirements for this exercise have been met.



EPA.



Five years.



Kept at the facility.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

EPA PREP EXERCISES | PAGE 4-6


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EPA-regulated FRP holders within the region.



As selected; plan holders who have successfully completed a PREP GIUE will not be required to
participate in another one for at least 36 months from the date of the exercise.



EPA.



EPA-regulated FRP holders.



A.	Unannounced exercises are limited to a maximum of 10 percent of response plan holders per EPA
region per year.

B.	Exercises are limited to approximately four hours in duration.

C.	Exercises should involve response to a small discharge scenario (assume 2,100 gallons outside
secondary containment and discharged into or on navigable waters and adjoining shorelines).

D.	Exercises should involve deployment of response equipment identified in the FRP to respond to
the spill scenario.



A.	Conduct proper notifications to respond to unannounced scenario of a small discharge.

B.	Demonstrate that the response is:

1.	Timely, as defined in Section 2 of these Guidelines;

2.	Conducted with adequate amount of equipment for the scenario; and

3.	Properly conducted.



EPA.



EPA.



Five years.



Kept at the facility.



Evaluation to be conducted by initiating agency.



Plan holder may receive credit for other required exercises (a Ql notification, equipment deployment
exercise, and unannounced exercise) if the GIUE is successfully completed, objectives of the other
exercise(s) are met, and a proper record is generated.

EPA PREP EXERCISES | PAGE 4-7


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EPA PREP EXERCISES | PAGE 4-8


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SECTION 5.0

DOT/PHMSA-REGULATED FACILITIES AND PIPELINES

PREP Guidelines do not create binding legal requirements.

While the PREP Guidelines have been developed with the regulated community, they cannot be considered to
be legally binding substantive rules. Plan holders can accept the PREP Guidelines to fulfill the exercise
requirements of OPA 90. An alternative program can also be acceptable as described in the applicable
regulation (for pipelines see 49 CFR § 194.107(c)(l)(ix); for other regulated facilities see 49 CFR § 130). Either
the PREP Guidelines or the approved exercise program developed by the plan holder become binding when
referenced in the submitted response plan.

DOT/PHMSA PREP EXERCISES | PAGE 5-1


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Plan holder.



As indicated by the response plan and, at a minimum, consistent with the triennial cycle (quarterly).



Plan holder.



NOTE: DOT/PHMSA may have the operator conduct a Ql notification exercise as part of a regulatory
inspection of the facility.



Facility response personnel and the facility's Ql.



Exercise the notification process between key facility personnel and the Ql to demonstrate notification
processes and the accessibility of the Ql.



Voice contact and confirmation must be made with a Ql as detailed in the plan. Electronic messaging
may be used only if communication by voice is not possible.



Self-certification as indicated in response plan. Each plan should have a written description of the
company's certification process.



Verification by DOT/PHMSA; records must be available upon request.



Three years.



Plan holder shall retain records as indicated in response plan.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

DOT/PHMSA PREP EXERCISES | PAGE 5-2


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Plan holder IMT.



As indicated by the response plan and, at a minimum, consistent with the triennial cycle (annually).



Plan holder.



IMT as established in the response plan.



Plan holders are encouraged to notify their DOT/PHMSA regional office at least one month in advance
of conducting their PREP exercises. When possible, DOT/PHMSA will participate and evaluate their
exercise.



Exercise the IMT's organization, communication, and decision-making in managing a response.



Exercise the IMT in a review of:

A.	Knowledge of the response plan;

B.	Proper notifications;

C.	Communication system;

D.	Ability to access an OSRO;

E.	Coordination of internal organization personnel with responsibility for response;

F.	Annual review of the transition from a local team to a regional, national, and international team as
appropriate;

G.	Ability to effectively coordinate response activity with the NRS infrastructure (If personnel from
the NRS are not participating in the exercise, the IMT should demonstrate knowledge of response
coordination with the NRS);

H.	Ability to access information in ACP for location of sensitive areas, resources available within the
area, unique conditions of area, etc.; and

I.	Minimum of one IMT exercise in a triennial cycle would involve simulation of a WCD scenario.



Self-certification as indicated in response plan or as defined in the "Guiding Principles" section of this
document, whichever is more stringent. Each plan should have a written description of the company's
certification process.



Verification by DOT/PHMSA; records must be available upon request.



Three years.



Plan holder shall retain records as indicated in response plan.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

DOT/PHMSA PREP EXERCISES | PAGE 5-3


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Plan holder.



As indicated by the response plan and, at a minimum, consistent with the triennial cycle (annually).



Plan holder.



Designated response personnel.

Plan holders are encouraged to notify their DOT/PHMSA regional office at least one month in advance
of conducting their PREP exercises. When possible, DOT/PHMSA will participate and evaluate their
exercise.



Demonstrate the ability to deploy response equipment* identified in the FRP.



Designated emergency response personnel should demonstrate the ability to:

A.	Organize; and

B.	Deploy and operate representative types of key response equipment as described in the response
plan.



Self-certification.



Verification by DOT/PHMSA; records must be available upon request.



Three years.



Plan holder shall retain records as indicated in response plan.



Self-evaluation.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

*May consist entirely of operator-owned equipment, or a combination ofOSRO and operator equipment.

DOT/PHMSA PREP EXERCISES | PAGE 5-4


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Plan holder.



PREP Guidelines require that operators conduct at least one of their exercises unannounced annually
(see Section 2).

DOT/PHMSA has and reserves the authority to conduct and require an operator to participate in a
GIUE. (Plan holders who have successfully completed a GIUE will not be required to participate in
another one for at least 36 months from the date of the exercise.)



DOT/PHMSA.



A.	Operator-designated spill emergency response team members.

B.	Operations staff.

C.	On-Scene Coordinator (optional).

D.	Federal, state, and other government agencies (optional).



A.	Demonstrate the ability to respond to a WCD spill event.

B.	Unannounced exercise to discuss strategic issues.

C.	On the day of the exercise, the plan holder will be provided the scenario and post-spill events. This
information will be used to explore and discuss strategic issues that will help operators evaluate
their response plans.



Designated emergency response team members should demonstrate adequate knowledge and
understanding of their FRP and the ability to organize, communicate, coordinate, and respond in
accordance with that plan. Initiate and demonstrate use of a UC, consistent with NIMS.



DOT/PHMSA will evaluate the conduct and achievement of objectives for the exercises and provide
certification of the exercise to the owner/operator.



DOT/PHMSA.



Three years.



Plan holder shall retain records as indicated in response plan.



DOT/PHMSA.



Plan holder may receive credit for other required exercises (a Ql notification, equipment deployment
exercise, and unannounced exercise) if the GIUE is successfully completed, objectives of the other
exercise(s) are met, and a proper record is generated.

DOT/PHMSA PREP EXERCISES | PAGE 5-5


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SECTION 6.0
BSEE-REGULATED OFFSHORE FACILITIES

While the PREP Guidelines have been developed with multiple iterations of public review and comment
occurring through the Federal Register, the PREP Guidelines are not, by themselves, legally binding rules. Plan
holders may adopt the implementing guidance contained within the PREP Guidelines to fulfill their exercise
requirements under OPA 90, or they may propose an alternative program subject to the approval of BSEE
OSPD. Either the PREP Guidelines or the BSEE OSPD-approved exercise program developed by the plan holder
become binding when referenced in the submitted oil spill response plan (OSRP).

BSEE PREP EXERCISES | PAGE 6-1


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24-hour manned offshore facilities.



On an annual basis and within two weeks after initiating production operations on a 24-hour manned
offshore facility. For MODUs (such as drill ship, jack-up rigs, etc.) that will be engaged in drilling or
down hole operations, within two weeks after movement on location and annually thereafter while at
this location, as applicable.



Owner or operator.



Facility personnel and Ql.



Exercise and test communications between personnel on each offshore facility manned on a 24-hour
basis and Ql; information to be provided in the event of a spill must be simulated during this
exercise/drill.



Voice contact and confirmation must be made with a Ql as detailed in the OSRP. Electronic messaging

may be used only if communication by voice is not possible.

All pertinent information must be communicated in a timely manner as outlined within the approved

OSRP and should include as many of the following elements of information as possible that are known

at the time of the notification call:

A.	Incident location: Indicate county, state, and latitude and longitude of release;

B.	Released material: Indicate name of material released, quantity released, and quantity in the
water;

C.	Brief description of incident;

D.	Incident details: Include platform rig name or platform or pipeline number, MODU name, location
area ID, block number, Outer Continental Shelf (OCS) lease number or state lease number;

E.	Sheen information: Include color, direction traveling, size, leading edge;

F.	Impact: Indicate if fire is involved and, if so, whether it is extinguished; document injuries or
fatalities and if evacuation(s) occurred;

G.	Remedial action: Indicate if source is secure and whether steps have been taken for source control
or spill response;

H.	Weather: Describe weather conditions, wind speed, wave conditions, speed and direction of
currents;

I.	Agency notifications: Indicate any local/state/federal agencies that have been notified;

J. Additional Information: Describe threats to personnel, biological resources, or the environment
and any other pertinent information not previously covered; and

K. Identify corrections and incorporate them into your OSRP to address any problems encountered
while conducting the notification exercise.



Self-certification.



Verification by BSEE; records must be available upon request.



Three years.



Records are to be maintained at the offshore facility or at a corporate location designated in the OSRP.



Self-evaluation of objectives.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

BSEE PREP EXERCISES | PAGE 6-2


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IMT.



Annually.



Owner or operator.



IMT and plan holder company officials as established in the spill response plan. At a minimum, IMT
roles and responsibilities that must be exercised in each IMT exercise include the incident commander,
in addition to any members of the command and general staffs that are necessary in order to exercise
the objectives that are being tested. If source control objectives are a significant element of the
scenario, then the source control branch should also be exercised, and the exercise design team should
consult BSEE regarding their availability to provide a Source Control Support Coordinator.



Exercise the IMT's organization, communication, and decision-making in managing a response.



Exercise a select combination of the Core Components as outlined within Appendix A of the PREP
Guidelines. During each triennial cycle, all of the applicable Core Components in Appendix A need to be
exercised at least once. (Note: A limited number of members of the Incident Management Team may
be involved with the exercise design team for the selection of objectives, plan components, and issues
to be tested during an exercise; however, none of the IMT members that are participating players in
the exercise should have knowledge of the exercise scenario script or the master scenario event list
(MSEL) prior to start of the exercise.)

In addition, effective demonstration of any of the following components may be included in the
scenario for the exercise:

A.	Ability to detect, assess, project, track and monitor the spill, properly map the spill information
necessary to respond, direct response resources appropriately, and share that information with
others as indicated in the response plan.

B.	Knowledge of OSRP, any referenced OSRO Inventories, tactics manuals, and well containment
plans.

C.	Ability to access information in the appropriate Regional Contingency Plans (RCPs) and ACPs for
the location of sensitive areas, protective best management practices, resources available within
the area, unique conditions of area, recommended response strategies, etc.

D.	For any chemical or biological countermeasures or in-situ burning cited in the OSRP, the ability to
prepare and submit a request and usage plan to the FOSC. The preparation of a usage and
monitoring plan/request for each such countermeasure listed in the plan must be exercised during
the triennial cycle.

1.	Ability to select and propose the use of an optimal mix of response countermeasures to the
FOSC, based on an assessment of the operational feasibility, expected effectiveness, and
projected environmental tradeoffs associated with using each countermeasure.

2.	In the case of a request for aerial/vessel applied dispersants, API Technical Report 1148
("Aerial and Vessel Dispersant Preparedness and Operations Guide") contains an example of a
Daily Aerial/Vessel Dispersant Application Plan that may be appropriate for use in this
situation.

3.	For OSRPs that also list SSDI as a response capability; the IMT should complete an application
request and usage and monitoring plan for SSDI, as well as a management plan for
coordinating the allocation of dispersant stockpiles between surface-application and SSDI
operations, as appropriate.

4.	Ability to implement and coordinate the use of multiple response countermeasures, as
approved by the FOSC, in accordance with the offshore response Concept of Operations
outlined in the OSRP.

E.	Demonstrate the effective and coordinated integration of source control and subsea containment
operations with other incident management activities, including oil spill response operations.

BSEE PREP EXERCISES | PAGE 6-3


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F. Identification of corrections necessary to address any noncompliance or preparedness issues
encountered while conducting the exercise and the incorporation of these corrections into the
OSRP.



Self-certification.



Verification by BSEE; records must be available upon request.



Three years.



Records are to be maintained at a corporate location designated in the spill response plan.



Self-evaluation.

BSEE may evaluate if the exercise is witnessed.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

BSEE PREP EXERCISES | PAGE 6-4


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OSRO or owner or operator response equipment required to be or voluntarily staged offshore.



On a semiannual basis and within 30 days after initial equipment placement. Notification of date
equipment will be staged offshore must be made to the BSEE Chief, OSPD, or designee prior to
equipment placement.

For wells being drilled from MODUs, at least once while the MODU is on each location and within 30
days of beginning operations if staged response equipment is required by the BSEE Chief, OSPD, or
voluntarily placed by the owner operator.



OSRO, or owner or operator.



Facility or SROT identified within the OSRP.



Deploy and operate response equipment that is staged offshore and identified in the OSRP. Each type
of this equipment is to be deployed annually. Each type need not be deployed at each exercise.



A.	Demonstrate ability of spill response personnel to conduct timely and proper mobilization,
deployment, and operation of equipment in a safe manner.

B.	Evaluate the effective operation of the deployed equipment; i.e., the operating condition and the
ability to demonstrate and achieve the equipment's defined operating specifications during the
exercise.

C.	Evaluate deployment strategies under various spill scenarios.

D.	Identify corrections necessary to address any noncompliance or preparedness issues encountered
while conducting the exercise and the incorporation of these corrections into the OSRP.



Self-certification



Verification by BSEE; records must be available upon request.



Three years



Records are to be kept at the OSRO or at the facility or a corporate location designated in approved
OSRP for owner or operator equipment.



Self-evaluation of objectives; BSEE may evaluate if the exercise is witnessed.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

BSEE PREP EXERCISES | PAGE 6-5


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OSRO or owner or operator response equipment stored at an onshore location that is cited in an OSRP
submitted to BSEE for review and approval.



Deployment exercises/drills must be conducted at a minimum on an annual basis and within 30 days
after initial placement per type of equipment. Each type of equipment being staged onshore must be
deployed at least once during a plan holder's triennial exercise cycle. Where exercise credit is extended
to all clients for a contracted OSRO's deployment exercise, each type of response equipment being
deployed in this manner should be deployed and exercised on an annual basis.



OSRO, or owner or operator.



OSRO, SROT, and/or owner or operator personnel.



Deploy and operate response equipment that is stored onshore and identified in the OSRP. It is not
necessary to deploy each piece of equipment.



A.	Demonstrate ability of spill response personnel to conduct timely and proper mobilization,
deployment, and operation of equipment in a safe manner as outlined in the Guiding Principles for
Equipment Deployment Exercises (Section 2).

B.	Evaluate the effective operation of the deployed equipment; i.e., the operating condition and the
ability to demonstrate and achieve the equipment's defined operating specifications during the
exercise.

C.	Evaluate deployment strategies under various spill scenarios.

D.	Identify corrections necessary to address any noncompliance or preparedness issues encountered
while conducting the exercise and the incorporation of these corrections into the OSRP.



Self-certification: OSRO for OSRO equipment and owner or operator for owner or operator equipment.



Verification by BSEE; records must be available upon request.



Three years.



Records are to be kept at the OSRO or at the offshore facility or a corporate location designated in
approved OSRP for owner or operator equipment.



Self-evaluation of objectives; BSEE may evaluate if the exercise is witnessed.



Plan holder may claim credit for this exercise when conducted in conjunction with other exercises, as
long as all objectives are met, the exercise is evaluated, and a proper record is generated. Credit may
be claimed for an actual response when these objectives are met, the response is evaluated, and a
proper record is generated.

BSEE PREP EXERCISES | PAGE 6-6


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Contractor or owner or operator equipment for source control, subsea containment, SSDI, and all
supporting equipment as necessary to implement actions to control and secure the source, or mitigate
the discharge as cited within a BSEE-regulated OSRP. The use of SSDI is considered a means to mitigate
the discharge, and is not considered a means of source control.



As deemed necessary by the BSEE Chief, OSPD, to test spill response preparedness. If the exercise is
voluntarily conducted by a source control, subsea containment, and SSDI equipment provider, the BSEE
Chief, OSPD, should be provided 60 days' notice prior to the date of the planned exercise.



BSEE Chief, OSPD; source control, subsea containment, or SSDI equipment provider; or owner or
operator.



Source control, subsea containment, SSDI, and supporting equipment providers, contractors, facility
personnel, Qls, state and local government, other federal agencies, and/or owner or operator
personnel.



Deploy, operate, and evaluate source control, subsea containment, SSDI equipment that is identified in
the OSRP as requested by the BSEE Chief, OSPD, in order to test spill response preparedness, or as
deemed necessary by an owner/operator or the source control, subsea containment, or SSDI
equipment provider. If the exercise is initiated by the BSEE Chief, OSPD, the parameters (e.g., location,
onshore or offshore, water depth, types of equipment to be exercised, drill protocols) for the exercise
will be provided to the source control, subsea containment, or SSDI equipment providers by the BSEE
Chief, OSPD. Due to the potentially extensive nature and complexity of exercising this type of
equipment, BSEE will consult whenever possible with industry regarding the planning for any BSEE-
initiated deployment exercises that will involve source control, subsea containment, or SSDI
equipment.



A.	Demonstrate ability of source control, subsea containment, or SSDI personnel to conduct timely
and proper mobilization, deployment, and operation of equipment in a safe manner.

B.	Evaluate the ability to procure in a timely manner all of the support equipment and services
necessary to ensure an effective source control, subsea containment, or SSDI response.

C.	Evaluate the operating condition and the ability to achieve the equipment's defined operating
specifications during the exercise.

D.	Evaluate deployment strategies under various spill release scenarios.

E.	Identify of any corrections necessary to address any noncompliance or preparedness issues
encountered while conducting the exercise and the incorporation of these corrections into the
OSRP.



BSEE.



BSEE.



Indefinite.



BSEE will maintain records at the BSEE OSPD Section Office that executed any BSEE-initiated
deployment exercise, or as directed by records management protocols. The owner or operator and/or
source control and subsea containment equipment provider will also maintain records at a corporate
location identified in the approved OSRP for any deployment exercises conducted as per this section.



Evaluation of objectives to be conducted by BSEE.



Credit may be requested for an actual response when these objectives are met, the response is
evaluated, and a proper record is generated.

BSEE PREP EXERCISES | PAGE 6-7


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Offshore facilities.



An offshore facility will not undergo a BSEE-initiated unannounced exercise more than once every 36
months, unless the BSEE Chief, OSPD, determines that the results of an exercise or response to real
time incidents warrant a more frequent evaluation, or an emerging concern arises necessitating that
BSEE test the preparedness and viability of the contents of a newly submitted or existing OSRP.



BSEE.



Facility personnel, Ql, IMT, OSROs, SROT, source control, and subsea containment, or SSDI equipment
and service providers, state and local government and other federal agencies (optional).



Exercise will require that the owner or operator respond to a spill scenario posed by the BSEE Chief,
OSPD, or designee. These unannounced exercises may consist of either (1) an IMT exercise, (2) a
deployment exercise/drill using equipment staged onshore, or (3) an IMT exercise combined with the
deployment of equipment staged onshore and/or offshore.



A.	IMT Exercise

The owner or operator will be requested by BSEE to demonstrate a select combination of the Core

Components outlined within Appendix A of the PREP Guidelines. Each drill will use an

unannounced scenario that will be designed to test these selected Core Components.

In addition, effective demonstration of any of the following components may be included in the

unannounced scenario for the exercise:

1.	Demonstrate the ability to detect, track and monitor the spill, and determine the size or flow
rate of a discharge;

2.	Demonstrate knowledge of the OSRP and any referenced OSRO inventories, tactics manuals,
and well containment plans;

3.	Demonstrate the ability to access information in the appropriate RCPs and ACPs for the
location of sensitive areas, protective best management practices, response resources
available within the area, unique conditions of area, recommended response strategies, etc.;

4.	Demonstrate the ability, through the appropriate procurement of resources and planning, to
use the equipment and techniques necessary to secure and mitigate the threat of a discharge
of oil and protect potentially impacted resources; and

5.	Demonstrate the effective and coordinated integration of source control and subsea
containment operations with other incident management activities, including oil spill response
operations.

B.	Deployment exercise/drill using equipment staged onshore and/or offshore

The deployment exercise is intended to:

1.	Demonstrate ability of response personnel to conduct timely and proper mobilization,
deployment and operation of selected spill response and source control equipment in a safe
manner, including any and all supporting logistical platforms, systems, and services;

2.	Demonstrate the ability of spill response personnel to employ response techniques and
methodologies that would enhance spill response capability and/or serve to protect
environmentally sensitive or economic resources;

3.	Evaluate the operating condition and the ability to achieve the deployed equipment's defined
operating specifications during the exercise;

4.	Evaluate deployment strategies under the unannounced spill scenario; and

5.	Effectively direct oil removal, protection, or mitigation operations using oil spill surveillance
and tracking resources.

C.	IMT exercise combined with deployment of equipment staged onshore and/or offshore

1. The objectives as outlined in numbers 1 and 2 of this section.



BSEE.

BSEE PREP EXERCISES | PAGE 6-8


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BSEE.



Three years.



BSEE will maintain records at the BSEE OSPD Section Office that conducted the exercise. The owner or
operator will maintain records at the corporate locations identified in the approved OSRP.



Evaluation of objectives to be conducted by BSEE.



Plan holder may receive credit for other required exercises (a Ql notification, equipment deployment
exercise, and unannounced exercise) if the GIUE is successfully completed, objectives of the other
exercise(s) are met, and a proper record is generated.

*GIUEs conducted by BSEE may be a IMT FE, an equipment deployment drill, or a combination of a IMT FE and an equipment
deployment drill.

BSEE PREP EXERCISES | PAGE 6-9


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BSEE PREP EXERCISES | PAGE 6-10


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SECTION 7.0
AREA/OSC EXERCISES

AREA/OSC EXERCISES | PAGE 7-1


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Area.



Quarterly.



FOSC.



Key elements of the UC (appropriate federal, state and local government agencies).



Exercise and test communication between the OSC and key elements of the UC.



A.	Ensure that the key elements of the UC know who to call in the event of a discharge, including
discharges and significant threats of discharges with SMFF implications, within the Area.

B.	Ensure contact by telephone or electronic messaging and that confirmation is made between the
OSC and key elements of the UC.



FOSC.



FOSC.



Four years (USCG).
Five years (EPA).



With FOSC.



By Area Committee.



Credit may be requested for an actual response when these objectives are met, the response is
evaluated, and a proper record is generated (see Section 2.13.1.2 of these Guidelines).

AREA/OSC EXERCISES | PAGE 7-2


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Area IMT.



Annually.



FOSC.



IMT for the Area (USCG or EPA and respective response team) and state(s).



Exercise the IMT's organization, communication, and decision-making in managing a spill and/or SMFF
response in a discussion-based exercise.



Exercise the IMT in a review of:

A.	Knowledge of the ACP;

B.	Proper notifications;

C.	Communications system;

D.	Ability to access response equipment;

E.	Coordination of organization or agency personnel with responsibility for response;

F.	Ability to effectively coordinate spill and/or SMFF response activity with NRS infrastructure;

G.	Ability to access information in ACP for location of sensitive areas, resources available within the
area, unique conditions of the area, etc.;

H.	Exercise the response management system identified in the ACP and, to the extent possible, the
UC;

I.	For any chemical and biological countermeasures or in-situ burning cited in the ACP, the ability to
prepare requests for and make recommendations to the FOSC regarding the use of these
countermeasures. Each such countermeasure identified in the ACP should be exercised during the
quadrennial cycle; and

J. Minimum of one IMT exercise in a quadrennial cycle would involve simulation of a WCD scenario.



FOSC.



FOSC.



Four years (USCG).
Five years (EPA).



With FOSC.



By Area Committee.



Credit may be requested for an actual response when these objectives are met, the response is
evaluated, and a proper record is generated.

AREA/OSC EXERCISES | PAGE 7-3


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Area Committee.



Annually.



FOSC.



Local Area response community (appropriate federal, state, and local response agencies).



A.	SORS and VOSS deployment drills for USCG National Strike Force and OCONUS-located units will
continue; deployments of VOSS systems as well as "first aid" equipment in pre-positioned
response trailers located throughout the continental U.S. will no longer be required as part of the
quadrennial Area exercise cycle.

B.	All response personnel must be included in a comprehensive training program, and all response
equipment in a comprehensive maintenance program. The intent is to ensure maximum
preparedness of both response personnel and equipment via the most efficient means. Credit
should be taken for deployment of equipment during training. The maintenance program must
ensure that the equipment is periodically inspected and maintained in good operating condition in
accordance with the manufacturer's recommendations and best commercial practices.



A.	Demonstrate the ability of the response personnel to deploy and operate the equipment.

B.	Ensure that the response equipment is in proper working order.



FOSC.



FOSC



Four years (USCG).
Five years (EPA).



With FOSC.



By Area Committee.



Credit may be requested for an actual response when these objectives are met, the response is
evaluated, and a proper record is generated.

AREA/OSC EXERCISES | PAGE 7-4


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Area response community.



Quadrennial (for each Area).

Scheduling of Area FE/FSEs will be done by the PREP 4C, using input from the FOSCs, Area Committees,
and RRTs, in consultation with the industry. A national, multi-year PREP schedule comprised of FE/FSEs
will be published on the NSFCC website. This will be updated on a regular basis (no less than
semiannually).



FOSC.



Appropriate federal, state, and local government, industry, and other members of the response
community.



A.	Operations-based FE/FSEs will exercise all aspects of the Area response community, including the
Area IMT, the ACP, equipment deployments, and the testing of relevant geographic response
strategies.

B.	Area exercises should be approximately 8-12 hours in duration.

C.	Exercise scenario is to be developed by the exercise design team.

D.	To simulate realism, the exercise should be conducted in the command post that would be used
for a response, whenever possible.

E.	Exercise may be in real or limited, compressed time and may start at any point during an incident,
as determined by the exercise design team. Flexibility should be allowed to ensure that the
exercise objectives are met.

F.	Lessons learned from the exercise shall be incorporated into each agency's PREP Lessons Learned
System (e.g., CGSAILS), whenever possible.



A.	Exercise the ACP, along with selected industry response plans.

B.	Exercise the response management system identified in the ACP and, to the extent possible, the
UC with the appropriate participants.

C.	Exercise the Area and industry IMTs.

D.	Deploy adequate response equipment for the exercise scenario. At a minimum, the scenario must
involve responding to a complex ICS Type 3 incident scenario or greater (Type 2 or 1) with
equipment deployment.



A.	The FOSC will certify completion of the Area FE/FSE. In certifying the Area exercise, the FOSC will
consider the following:

1.	Area FE/FSE was conducted;

2.	Area FE/FSE met the objectives outlined in the PREP Guidelines; and

3.	Area response community was exercised for response preparedness.

B.	Participating industry plan holders should take credit for all of the applicable exercise activities
that were completed during the Area FE/FSE. These exercises shall be self-certified by the plan
holder.



FOSC.



Four years (USCG).
Five years (EPA).



With FOSC.



By Area Committee.



Credit may be requested for an actual response when these objectives are met, the response is
evaluated, and a proper record is generated. Credit may be granted for hazardous substance (as
defined in Clean Water Act) scenarios, provided relevant ACP sections were tested.

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APPENDIX A: CORE COMPONENTS FOR EXERCISING RESPONSE PLANS

During each triennial (quadrennial for ACPs) cycle, the following 15 core components must be
exercised at least once for a response plan. All of 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.

A.l Notifications: Test the notifications procedures identified in the response plan being
exercised.

A.2 Staff Mobilization: Demonstrate the ability to assemble the response organization
identified in the response plan being exercised.

A.3 Ability To Operate Within the Response Management System Described in the Plan:

1.	Unified Command: Demonstrate the ability of the response organization to work

within a UC.

a.	Federal Representation: Demonstrate the ability to consolidate the concerns
and interests of the other members of the UC into a unified strategic plan with
tactical operations.

b.	State Representation: Demonstrate the ability to function within the UC
structure.

c.	Local Representation: Demonstrate the ability to function within the UC
structure.

d.	Responsible Party Representation: Demonstrate the ability to function within
the UC structure.

2.	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.

a.	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 UC.

b.	Planning: Demonstrate the ability to consolidate the various concerns of the
members of the UC into joint planning recommendations and specific long-
range strategic plans. Demonstrate the ability to develop short-range tactical
plans for the Operations Section.

c.	Logistics: Demonstrate the ability to provide the necessary support of both the
short-term and long-term action plans.

APPENDIX A

Page A-l


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d. Finance: Demonstrate the ability to document the daily expenditures of the
organization and provide cost estimates for continuing operations.

e.	Public Affairs: Demonstrate the ability to form a Joint Information Center (JIC)
and provide the necessary interface between the UC and the media.

f.	Safety Affairs: Demonstrate the ability to monitor all field operations and
ensure compliance with safety standards.

g.	Legal Affairs: Demonstrate the ability to provide the UC with suitable legal
advice and assistance.

A.4 Source Control: Demonstrate the ability of the response organization to control and
stop the discharge at the source, and to effectively coordinate source control activities within
the response management system used for the overall incident. Source control actions may
involve specialized operations including, as applicable:

1.	Salvage: Demonstrate the ability to assemble and deploy salvage resources
identified in the VRP for the following salvage services:

a.	Hull and bottom survey;

b.	Emergency towing;

c.	External emergency transfer operations;

d.	Emergency lightering;

e.	Other refloating methods;

f.	Making temporary repairs;

g.	Diving services support;

h.	Subsurface product removal; and

i.	Heavy lift.

2.	Marine Firefighting (vessels): Demonstrate the ability to assemble and deploy the
firefighting resources identified in the VRP for fire suppression.

a.	External firefighting teams; and

b.	External vessel firefighting systems.

3.	Lightering: Demonstrate the ability to assemble and deploy the lightering resources
identified in the response plan.

a. Emergency lightering (not applicable to NTVs under 250 barrel capacity).

APPENDIX A	Page A-2


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4.	Other Salvage Equipment and Devices: Demonstrate the ability to assemble and
deploy the other salvage devices identified in the response plan.

a.	Specialized salvage operations;

b.	Special salvage operations plan;

c.	Subsurface product removal; and

d.	Heavy lift.

5.	Well Control: Where applicable, demonstrate the ability to regain well control and
secure the source of a discharge.

A.5 Assessment: Demonstrate the ability of the response organization to provide an initial
assessment of the discharge or potential discharge and provide continuing assessments of the
effectiveness of the tactical planning.

1.	Salvage (vessels): Demonstrate the ability to assemble and deploy salvage
assessment and consultation resources identified in the VRP for the following
salvage services:

a.	Remote salvage assessment and consultation;

b.	On-site salvage assessment;

c.	Assessment of structural stability;

d.	Salvage plan; and

e.	Special salvage operations plan.

2.	Marine firefighting (vessels): Demonstrate the ability to assemble and deploy the
firefighting assessment and planning resources identified in the VRP for the fire
assessment and planning.

a.	Remote fire assessment and consultation; and

b.	On-site fire assessment.

A.6 Containment: Demonstrate the ability of the response organization to contain the
discharge at the source or in various locations for recovery operations.

A.7 Mitigation (formerly Recovery): Demonstrate the ability of the response organization to
mitigate the discharged product through the use of oil spill countermeasures, including, but not
limited to, dispersants, in-situ burning, and bioremediation, in addition to mechanical oil
recovery.

APPENDIX A

Page A-3


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A.8 Protection: Demonstrate the ability of the response organization to protect the
environmentally and economically sensitive areas identified in the ACP and the respective
industry response plan.

1.	Protective Booming: Demonstrate the ability to assemble and deploy sufficient
resources to implement the protection strategies contained in the ACP and the
respective industry response plan.

2.	Water Intake Protection: Demonstrate the ability to quickly identify water intakes
and implement the proper protection procedures from the ACP or develop a plan for
use.

3.	Wildlife Recovery and Rehabilitation: Demonstrate the ability to quickly identify
these resources at risk and implement the proper protection procedures from the
ACP to develop a plan for use.

4.	Population Protection (Protect Public Health and Safety): 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 ACP to develop a plan for use.

A.9 Disposal: Demonstrate the ability of the response organization to dispose of the
recovered material and contaminated debris.

A.10 Communications: Demonstrate the ability to establish an effective communications
system for the response organization.

1.	Internal Communications: Demonstrate the ability to establish an intra-organization
communications system. This encompasses communications at the command post
and between the command post and deployed resources.

2.	External Communications: Demonstrate the ability to establish communications
both within the response organization and other entities; e.g., RRT, claimants,
media, regional or headquarters agency offices, and nongovernmental
organizations.

A.ll Transportation: Demonstrate the ability to provide effective multimode transportation,
both for execution of the discharge and support functions.

1.	Land Transportation: Demonstrate the ability to provide effective land
transportation for all elements of the response.

2.	Waterborne Transportation: Demonstrate the ability to provide effective
waterborne transportation for all elements of the response.

3.	Airborne Transportation: Demonstrate the ability to provide effective airborne
transportation for all elements of the response.

APPENDIX A

Page A-4


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A.12 Personnel Support: Demonstrate the ability to provide the necessary support of all
personnel associated with the response.

1.	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.

2.	Berthing: Demonstrate the ability to provide overnight accommodations on a
continuing basis for a sustained response.

3.	Messing: Demonstrate the ability to provide suitable feeding arrangements for
personnel involved with the management of the response.

4.	Operational and Administrative Spaces: Demonstrate the ability to provide suitable
operational and administrative spaces for personnel involved with the management
of the response.

5.	Emergency Procedures: Demonstrate the ability to provide emergency services for
personnel involved in the response.

A.13 Equipment Maintenance and Support: Demonstrate the ability to maintain and support
all equipment associated with the response.

1.	Response Equipment: Demonstrate the ability to provide effective maintenance and
support for all response equipment.

2.	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.

A.14 Procurement: Demonstrate the ability to establish an effective procurement system.

1.	Personnel: Demonstrate the ability to procure sufficient personnel to mount and
sustain an organized response. This requirement includes ensuring that all personnel
have qualifications and training required for their position within the response
organization.

2.	Response Equipment: Demonstrate the ability to procure sufficient response
equipment to mount and sustain an organized response.

3.	Support Equipment: Demonstrate the ability to procure sufficient support
equipment to support and sustain an organized response.

A.15 Documentation: Demonstrate the ability of the response organization to document all
operational and support aspects of the response and provide detailed records of decisions and
actions taken.

APPENDIX A

Page A-5


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APPENDIX A	Page A-6


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APPENDIX B TO PREP GUIDELINES: EXERCISE REFERENCE MATRIX

OIL SPILL RESPONSE PLAN AS REQUIRED BY CWA:

Vessel Response
Plans

Coastal Zone
Facility Response
Plans

Inland Facility
Response Plans

Onshore Pipeline
Response Plans

Offshore Facility
Response Plans

Area Contingency
Plans

USCG

USCG

EPA

DOT-PHMSA

DOI-BSEE

USCG and EPA

33 CFR Part 155

33 CFR Part 154

40 CFR Part 112

49 CFR Part 194,
Part 130

30 CFR Part 254

40 CFR Part 300

PREP EXERCISES (ORGANIZED BY HSEEP* EXERCISE TYPE)

Applicable Exercise Guidance Sections (specific guidance found on page number referenced)

DISCUSSION BASED EXERCISES (Type | Name)

TTX

Incident Management Team Exercise -MTR Facilities



3-10









TTX

Incident Management Team Exercise -Tankand Certain NTVs

3-11











TTX

Shore-based Salvage Exercise

3-12











TTX

Shore-based Marine Fire fighting Exercise

3-14











TTX

Incident Management Team Exercise - Inland Facilties





4-4







TTX

Incident Management Team Exercise







5-3





TTX

Incident Management Team Exercise - Area IMT











7-3

OPERATIONS BASED EXERCISES (Type | Name)

DRILL

Ql Notification-MTR Facility



3-2









DRILL

Ql Notification-Manned Vessel

3-3











DRILL

Ql Notification - Unma nned Tank Barge

3-4











DRILL

Ql Notification-Inland Facility





4-2







DRILL

Ql Notification







5-2





DRILL

Ql Notification-Offshore Facility









6-2



DRILL

Quarterly Area Notification











7-2

DRILL

Remote Assessment and Consultation-Manned Vessel

3-5











DRILL

Remote Assessment and Consultation-Unmanned Tank Barge

3-6











DRILL

On Board Emergency Procedures - Ma nned Vessels

3-7











DRILL

Emergency Procedures -Tank Barges

3-8











DRILL

Emergency Procedures - MTR Facilities (optional)



3-9









DRILL

Emergency Procedures-Inland Facilities (optional)





4-3







DRILL

Equipment Deployment-MTR Facilities (Facility-owned equipment)



3-15









DRILL

Equipment Deployment-MTR Facilities (OSRO-owned equipment)



3-16









DRILL

Equipment Deployment-Inland Facilities (Company-owned equipment)





4-5







DRILL

Equipment Deployment-Inland Facilities (OSRO-owned equipment)





4-6







DRILL

Equipment Deployment-Vessels (OSROand SMFF Equipment)

3-17











DRILL

Equipment Deployment







5-4





DRILL

Equipment Deployment-Offshore Facility (Equipment staged offshore)









6-6



DRILL

Equipment Deployment-Offshore Facility (Equipment staged onshore)









6-7



DRILL

Equipment Deployment-Offshore Facility (Source control, subsea containment, and SSDI equipment)







6-8



DRILL

Equipment Deployment-Area Committee











7-4

FE

Incident Management Team Exercise -Offshore Facility









6-4



FE+DRILL

Government-Initiated Unannounced Exercise-MTR Facilities



3-18









FE+DRILL

Government-Initiated Unannounced Exercise-Vessels

3-19











FE+DRILL

Government-Initiated Unannounced Exercise -Inland Facilities





4-7







FE+DRILL

Government-Initiated Unannounced Exercise







5-5





FE and/or DRILL

Government-Initiated Unannounced Exercise-Offshore Facilities









6-9**



FSE

Quadrennial Area Exercise











7-5

KEY NOTES

TTX = TableTop Exercise * HSEEP refers to the Homeland Security Exercise and Evaluation Program as defined by FEMA
FE = Functional Exercise **GIUEs conducted by BSEE may be a IMTFunctional Exercise, an Equipment Deployment Drill,
FSE = Full Scale Exercise or a combination of a IMTFunctional Exercise and an Equipment Deployment Drill

APPENDIX B

Page B-l


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