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Annual
Drills
The MMS GOM Unannounced Oil-Spill Drill Program tests
the ability of oil and gas and pipeline operators to properly respond to
an oil spill by using the procedures and resources in their MMS approved
Oil-Spill Response Plans. The drills monitor a particular company’s
readiness to deal with potential oil spills of all sizes. When initiated
in 1989, the unannounced drill program in the GOM was originally limited
to 5-6 drills per year. However, this program was expanded in the late
1990’s to 18-20 drills per year. There are presently plans in place to
increase the number of drills held each year beginning in 2006.
This program was designed to enable the agency to review
and assess the various stages of oil spill response actions on the part of
the oil and gas operators and their contracted responders. In order to
accomplish this goal, the region identified four types of drills for this
GOM program. These four drills include 1) unannounced drills with
equipment mobilization only, 2) unannounced drills with equipment
mobilization and deployment , 3) unannounced “Table Top” drills, and 4)
announced “Table Top” simulations of a large oil spill. The selection of an operator to participate in an
unannounced drill is based upon such factors as the number of oil
producing facilities, the volume of oil production, and proximity to
sensitive areas. During these exercises, an MMS monitoring team presents a
spill scenario involving one or more of the operator’s facilities to the
operator and then observes the operator’s designated Spill Management
Team’s simulated or actual response to the spill scenario. All of these
drills are evaluated using the National Preparedness for Response Exercise
Program guidelines. At the conclusion of a drill, the MMS monitoring team
discusses with the Spill Management Team the strong and weak areas of the
response. The MMS requires that a written report with the complete
documentation of the exercise be submitted to the Agency within 15 days.
The MMS then prepares a written evaluation of the exercise that may
include recOEMMendations/requirements for improvement. If changes in a
particular operator’s response strategy are deemed necessary during the
conduct of these drills, MMS can require that the operator’s proposed
response strategy and their Oil-Spill Response Plan be amended. An
Incident of Noncompliance may be issued for poor performance. The MMS-initiated unannounced exercises also provide an
opportunity for MMS to evaluate on a random basis, the response
preparedness of the oil and gas industry. Inferences can be drawn from the
results of these drills regarding the overall capability for the GOM
industry to respond to a spill. The adequacy of oil spill response
equipment and capabilities available through contract to GOM oil and gas
operators throughout the GOM can be verified through the conduct of these
drills. Tracking and verification of exercise requirements for
spill responders is an MMS function that ensures that all responders have
the required experience and expertise to respond to an offshore facility
spill. Operators are required to conduct annual Spill Management Team
“table top” exercises. These drills are required to test the Spill
Management Team’s organization, cOEMMunication, and decision-making in
managing a response. The operator is also required to conduct an annual
deployment exercise of the equipment staged at onshore locations
identified in their plan. Each type of equipment staged onshore must be
deployed and operated every 3 years. The operator is required to exercise
their entire response plan every 3 years. Another exercise that tests the
ability of the operator to cOEMMunicate information in a timely manner is
the required annual notification exercise required for every facility that
is manned on a 24-hour basis. The operator must notify MMS at least 30
days prior to these drills occurring. This notice provides an opportunity
for MMS to witness the exercise or to request changes in the frequency or
location of the exercise, equipment to be deployed and operated, or
deployment procedures or strategies. MMS can also evaluate the results of
these exercises and advise the owner/operator of any needed changes in
response equipment, procedures or strategies. Tracking and verification of training requirements for
personnel who operate spill response equipment or serve on the Spill
Response Management Team or as Qualified Individual for an operator is
also an MMS function, one that ensures that all responders have the
required knowledge to respond to an offshore spill. Operators are required
to train response team members in spill response methods. The Spill
Response Operating Team members who are responsible for operating response
equipment must attend hands on training classes at least annually. This
training must include the deployment and operation of the equipment that
they will use. Those responsible for supervising the team must be trained
annually in directing the deployment and use of the equipment. In
addition, the operator is required to provide annual training to the Spill
Response Management Team including the Spill Response Coordinators and the
operator’s designated Qualified Individual. The Qualified Individual is
the representative of the owner or operator of an OCS facility that has
been authorized by the owner/operator to obligate funds and authorize
spill removal actions. The required training includes instruction on all
responsibilities that the Spill Management Team or Qualified Individual
may need to perform their duties. This instruction covers the locations,
intended use, deployment strategies, and the operational and logistical
requirements of response equipment; spill response reporting procedures,
and prediction of spill movement.
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