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exercises should demonstrate the ability of personnel to of the 2016 PREP Guidelines on our clients’ operations. deploy and operate response equipment, and ensure the Additionally, we are working with our 24/7 Emergency equipment is in working order. Operations and Command Center staff to further stream-

Plan Holder-Initiated Unannounced Exercise: The USCG line the exercise process and documentation procedures, requires plan holders to annually conduct either an emer- and revise vessel response plans to align with and satisfy gency procedures exercise with an SMFF component, or these new exercise requirements. We understand the added the SMFF equipment deployment as an unannounced ex- burden new requirements like this place on industry and ercise. This is in addition to the current requirement to are committed to identifying solutions with minimal cost annually conduct either the emergency procedures, IMT and disruption to current operations. To this end, we re-

TTX, or equipment deployment as an unannounced exer- main in regular contact with the USCG Of? ce of Marine cise. O’Brien’s recommends that plan holders conduct two Environmental Response, which oversees these guidelines, of their emergency procedures exercises as unannounced, to communicate the impact the 2016 PREP Guidelines including one oil spill scenario and one SMFF scenario, to will have on industry before they come into force.

satisfy this requirement.

Government-Initiated Unannounced Exercise (GIUE):

While GIUEs are not new to PREP, the USCG recently renewed their emphasis on this program. According to the

USCG, the current intent of a GIUE is to test an Aver- age Most Probable Discharge (AMPD) scenario including response equipment deployment for tank vessel operators and facilities. These will be limited to a maximum of four per Captain of the Port Zone (COTP) per year. While the guidance on GIUE implantation originates from USCG

Headquarters, each of the 42 COTP’s maintain responsi- bility for implementing GIUEs in their respective zones.

Kate Kelley is the Vessel Services Compliance Manager for

As a result, confusion remains regarding whether the

O’Brien’s Response Management (ORM), a Witt O’Brien’s

USCG intends to focus GUIEs on tank vessels conducting company. Prior to joining ORM, Ms. Kelley worked for the cargo transfers at facilities or designated lightering areas.

Environmental Protection Agency (EPA) as a program lead for the development and implementation of the EPA’s Vessel

O’B ’ A

RIEN S PPROACH

General Permit (VGP). Ms. Kelley holds and M.S. in Applied

As the QI and vessel compliance consultants for a large

Economics from Johns Hopkins University, and a B.A. in number of domestic and international shipping compa-

Environmental Policy from the University of Michigan.

nies, we are actively engaged in meetings with OSROs and

SMFF providers to identify ways to minimize the impact 23 www.marinelink.com MN

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