Spring 1997

U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration

OPA 90
LESSONS LEARNED

Exercise Program Validates Operators' SMT Capabilities

The Department of Transportation, Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety (DOT/OPS) has designed a new exercise program to meet agency requirements under the Oil Pollution Act of 1990 (OPA). The DOT/OPS exercise program is designed to exercise and validate pipeline operators' spill management team (SMT) capabilities. Thus far a diverse group of pipeline operators across the country are participating in the new program.

The DOT/OPS exercise program uses the pipeline guidelines of the National Preparedness for Response Exercise Program (PREP) for both area exercises and strategic tabletop exercises. PREP offers a guidance mechanism for compliance with OPA 90's exercise requirements, while being economically feasible for the government and oil industry to adopt and sustain. PREP provides guidelines for satisfying the exercise requirements of the Coast Guard, the Environmental Protection Agency (EPA), and the Minerals Management Service (MMS), in addition to DOT/OPS.

Under OPA 90, DOT/OPS is tasked with reviewing and approving facility response plans (FRP) for oil pipelines. FRPs must describe the operator's drill and exercise program. DOT/OPS assists pipeline operators by providing technical assistance in exercise design, conduct and evaluation.

DOT/OPS believes that their new exercise program is a cost-effective way to monitor and enhance industry preparedness, in addition to establishing some consistency across the industry in the operators' approach to exercising. The program also encourages cooperation and coordination among pipeline operators and the local, state and federal responders with whom they may work in a major oil spill.

According to Toni Hundley, Response Plans Officer at DOT/OPS, "One of the most beneficial aspects of our new program is bringing the pipeline industry and governmental regulatory agency responders face-to-face to share information regarding emergency preparedness and response capabilities. In this way, responders can assess response plans and procedures, determine readiness, clarify roles and responsibilities, and prepare for real spill events prior to an incident."

In October 1995, DOT/OPS sponsored its most recent area exercise, with Williams Pipe Line Company, exercising the entire response community in the Kansas City, Missouri, area. In 1996, DOT/OPS and its contractor, The Corporate Response Group Inc. (CRG), are designing, developing, conducting and evaluating strategic SMT tabletop exercises for approximately 20 pipeline operators, and are assisting in one pipeline industry-led area exercise. In the first quarter of 1996, six pipeline companies participated in this new DOT/OPS tabletop exercise program. These operators were Colonial Pipeline Company, EOTT Energy Corporation, Houston Lighting & Power Company, Chevron Production Company, Defense Fuels Supply Point (Port Tampa), and Conoco Pipe Line Company.

DOT/OPS has already chosen pipeline operators to participate in the remaining 1996 tabletop and area exercises of the program (see Upcoming Exercises). OPS selected operators randomly from a variety of both large and small companies across the United States. While CRG has primary responsibility for tabletop exercise design, development, conduct, and evaluation, operators are asked to provide technical support to ensure scenario accuracy, in addition to supplying a location for the exercise conduct.

The six operators who have participated in the tabletop exercises have been pleased with the results. "While Chevron conducts numerous drills, this tabletop exercise allowed us to see and hear how the state and federal agencies interact in coordinating a government response," said Clinton Terry, environmental engineer at Chevron. "Likewise, Chevron was able to demonstrate its personnel and plan competency during the course of this one-day event. This insight can improve the integration of a coordinated response among Chevron and government agencies."

DOT/OPS contributes significant resources to the development and conduct of both tabletop and area exercises as part of their commitment to assist pipeline operators in enhancing their emergency preparedness and response capabilities.

Boxed quote: "Bringing industry and agency responders face-to-face is a benefit of the program."

Recent Tabletop Exercises Yield New Lessons Learned

The first six DOT/OPS-sponsored SMT tabletop exercises were highly productive and well received by participants. Pipeline operators agreed that they yielded some important lessons that will help enhance existing response capabilities. Although some of the lessons learned were unique to a particular exercise, DOT/OPS discovered some common observations that could possibly be applied to a diverse range of operators.

• Increase Your Opportunities for Agency Interface

The participation of other agency officials in the DOT/OPS exercise program is optional. Since many pipeline operators conduct only internal exercises, it is hardly surprising that several of the exercises provided the first opportunity for external agencies to meet with the operator's SMT. Moreover, most exercise participants said that the opportunity to meet face-to-face with agency officials was the greatest single benefit of this exercise program.

According to Glenn Epler, tabletop exercise facilitator for CRG, "Perhaps the most significant contribution that these tabletop exercises make is simply in getting the federal, state and local governmental responders around the same table with industry, to discuss mutual concerns and issues surrounding a potential "worst case" oil spill. This coordination and cooperation is critical to ensuring success in any oil spill response operation."

Without such interaction, it is difficult to understand the concepts behind Unified Command. Operators might consider scheduling and conducting SMT exercises in a way that facilitates attendance by external agencies. Agency response officials might also consider placing a higher priority on attending industry exercises within their area of jurisdiction.

• Don't Overlook Your Local Fire Department and HAZMAT Teams in Your ICS

Many facility response plans (FRP) do not appear to fully address the role of the local fire department and/or HAZMAT response team when discussing ICS/UCS implementation. To a greater degree than with vessels or facilities, pipeline operators are likely to experience spills in locations where the fire department arrives on scene before operator personnel.

 In many instances, fire department personnel may be unaware of the existence or location of the pipeline and of the response capabilities of the pipeline operator. This may lead to initial confusion over who is in charge, and may result in delays in accessing the spill location for response purposes.

As a preparedness measure, pipeline operators with lines that cross multiple and/or distant jurisdictions are encouraged to meet periodically with local response officials to educate them on the characteristics of pipelines and the response capabilities of the pipeline operators and their contractors. This would include inviting these officials to the operator's exercises and training programs whenever practicable.

• Verify and Update Your Plan's Key Notification Numbers Frequently

Many sectors of industry and government are undergoing frequent and substantial changes in response capabilities, mainly due to budgetary and regulatory pressures. The local response community is no exception. Although multi-state operators are particularly affected, changes can also impact regional operators. In light of these changes, operators should continue to verify key notification numbers quarterly, as well as update the notification section of the FRP as often as necessary. Tabletop exercises highlighted the need to add notification of all local jurisdictions potentially impacted by the spill "downstream" and not just those traversed by the pipeline.

• Qualified Individuals Don't Need To Be Senior Managers

Qualified Individual (QI) responsibilities are often assigned to personnel at the highest levels of a company. This practice, however, may not always provide the best candidate for the QI role, as travel schedules of senior managers may interfere with their availability. What's more, the primary responsibilities assigned to the most senior managers can often preclude them from obtaining and maintaining in-depth knowledge of the FRP. These key factors --availability and overall knowledge of the FRP-- should be considered in determining the primary QI.

The QI may also be the pipeline operator's incident manager for the operation, although being incident manager requires a greater depth of knowledge for response operations than is generally required of the QI. The incident manager can also assume responsibility for all QI functions after arriving on scene and taking control of the spill.

• Calendar of Upcoming Pipeline Exercises

Pipeline operators are using these lessons learned to improve their FRPs and their overall response effort. At the end of each tabletop exercise, participants have the opportunity to share their observations and discuss the lessons learned they can take home for immediate action. Input from this "action planning session" is also used in the development of a formal post-exercise report prepared by DOT/OPS. The report is then shared with the pipeline operator and all exercise attendees to further maximize the value of the lessons learned.

Boxed excerpt: "Coordination and cooperation among industry and agency responders is critical to ensuring success in any oil spill response operation."

Message from... Rich Felder

We at DOT/OPS are very enthused about our new exercise program. We are also very impressed with the overwhelming participation from the pipeline industry and federal, state and local entities. Our goal is to provide the pipeline industry the resources and expertise to conduct effective exercises tailored to the conditions of each pipeline operator, and to provide usable "lessons learned".

Exercise Resources

DOT/PHMSA/OPS is committed to helping pipeline operators meet their 49 CFR Part 194 (facility response plans) requirements and to making the National Preparedness for Exercise Program work for the pipeline industry. Upcoming issues of this newsletter will therefore carry descriptions of exercise resources such as the U.S. Coast Guard's Lessons Learned Database, along with other resources available through the EPA and FEMA.

Operators with questions or needing assistance may contact Toni Hundley or Jim Taylor, Response Plans Officers at the Office of Pipeline Safety, or Glenn Epler of The Corporate Response Group Inc. (CRG). Questions may include any aspect of the exercise process (design, development, conduct, evaluation), the tabletop and area exercise program, or PREP requirements.

If you are interested in participating in this program, or would like more information on the services available through DOT/OPS, please contact Toni Hundley by phone at 202/366-4397, fax 202/366-4566, or by mail at DOT/PHMSA/OPS (DPS-3), 400 Seventh Street S.W., Room 2335, Washington, D.C. 20590-0001.

INDUSTRY CALENDAR OF EVENTS

• April
  • 4/25: Tabletop Exercise, Atlas Processing Company, Shreveport, LA
  • 4/30: Tabletop Exercise, Wickland Oil, Martinez, CA
• May
  • 5/2: Tabletop Exercise, Defense Fuel Supply Point, San Pedro, CA
  • 5/7-8: Area Exercise, Fina Oil and Chemical Company, Port Arthur/Beaumont, TX
  • 5/23: Tabletop Exercise, Quaker State Corporation, Magnolia, OH
  • 5/30: Tabletop Exercise, Cetex Pipeline, Inc., Mt. Pleasant, TX
• June
  • 6/11: Tabletop Exercise, Department of Navy, Cecil Field, FL
  • 6/27: Tabletop Exercise, Texaco Trading & Transport, Inc., El Dorado, KS
• July
  • 7/18: Tabletop Exercise, Kiantone Pipeline Corporation, Warren, PA
  • 7/18: Tabletop Exercise, Chemoil, Signal Hill, CA