Summer 1997

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

OPA 90
LESSONS LEARNED

Spotlight On Recent Area Exercise

A major component of DOT/OPS' participation in the National Preparedness for Response Exercise Program (PREP) is the area exercises. Each year, two of the twenty industry-led area exercises recommended by PREP involve a pipeline scenario. DOT/OPS participates in these two exercises specified in the PREP guidelines and assists the pipeline operator in hosting the exercise.

The primary purpose of these area exercises is to activate and observe the area response infrastructure and the response community's ability to conduct a spill response effectively. The focus is on the interaction between the responsible party and the federal, state and local government to validate both the Area Contingency Plan and the operator's FRP.

In May, DOT/OPS sponsored its most recent area exercise in Beaumont, Texas, with FINA Oil & Chemical Company leading the effort. The objectives were to exercise the Unified Command in accordance with appropriate plans (ACP, FRPs, etc.); to demonstrate the ability to set up and operate a Joint Information Center (JIC); and to demonstrate the ability to deploy equipment in accordance with PREP.

Overall, the response organizations participating in the exercise worked diligently and responded quickly and realistically to the scenario. Players were enthusiastic and provided positive input within their teams. The exercise proved to be a valuable learning experience for the players and validated the need for continuous improvement in handling and responding to emergencies.

"This exercise was an excellent learning experience for all involved, since it required a great deal of coordination between so many different FINA, federal, and state response and management teams," says Karen McDermott Jones, FINA's exercise coordinator. "Handoffs between different groups were done well and resulted in a true unified response."

The scenario involved a hypothetical leak from one of FINA's pipeline divisions that spilled 5,000 barrels of crude oil into a local waterway, heavily impacting wetlands and other environmentally sensitive areas. An on-duty Pipeline Control Center Operator identified the possible existence of a major pipeline leak.

Upon notification of the potential leak, the Incident Command System (ICS) immediately activated. The transition from ICS to Unified Command (UC) was accomplished in a timely manner. The UC functioned effectively and was able to mobilize adequate response resources. The resulting response required a concerted effort from all members of the area spill management team.

Some highlights of the exercise included the deployment of field equipment at four different sites and the establishment of a fully staffed Unified Command Center at the Holiday Inn's Holidome Center. The exercise involved close to 300 players and 58 exercise staff and provided for 23 hours of vigorous response play. This included a complete shift change, as Unified Command operations went throughout the night.

There was no doubt in the minds of the participants that the exercise provided the Unified Command organization with the training necessary to deal with a real oil spill quickly and effectively. FINA is to be commended on the tremendous effort they put into ensuring that the exercise was a success.

Frequently Asked Questions About Tabletop Exercises

In the process of developing the first and second quarter exercises, DOT/OPS received many questions from pipeline operators about the OPA exercising program. Here are some of the more commonly asked questions & answers:

Q: How was my company chosen?

A: Under the PREP Guidelines, DOT/OPS is able to conduct up to 20 tabletop exercises each fiscal year. Pipeline operators are randomly chosen from throughout the United States and its territories. Pipeline operators cannot be required to participate in a PHMSA-initiated unannounced exercise, if they have already participated in one within the past 36 months. Each operator, however, is required to conduct an internal spill management team tabletop exercise every year.

Q: What are the goals and objectives of these exercises?

A: The overall objectives of each tabletop exercise are to evaluate and validate the pipeline operator's FRP and emergency response procedures and to enhance the operator's knowledge of appropriate plans and procedures, including Area and State Contingency Plans. Worst-case discharge type scenarios are used to validate the operator's FRP.

Q: Do I get PREP credit for this?

A: The pipeline owner/operator may, under the PREP Guidelines, take credit for participating in these tabletop exercises if "...all objectives are met, the exercise is evaluated, and a proper record is generated."

Q: What is the exercise format?

A: The DOT/OPS tabletop exercise program is structured as a facilitated exchange conducted in a conference room setting, involving discussion of a scenario or series of scenarios by a response/management team(s). The facilitated discussion typically lasts about 6 hours. No phone calls are made, no equipment is mobilized, and no reports are prepared. There is no activation of the plan for the company involved, nor is the ACP activated.

Q: How much preparation time will this require of the operator?

A: Every effort is made to minimize the burden on the company. DOT/OPS works with a "Trusted Agent" to provide technical support for scenario development, supply the exercise facility, and also make arrangements for the spill management team to be available on the day of the exercise. A Trusted Agent is a company representative who provides technical information about the company's pipeline operations so it can be incorporated into the exercise scenario. (This person is required to keep details of the scenario confidential.) Planning and logistical arrangements usually take no more than 8-16 hours of the Trusted Agent's time.

Q: How much will this cost the company?

A: DOT/OPS provides support services for planning and conducting the exercise with your company. The costs to the company involve labor and support items, such as a conference room.

Q: How is the company evaluated?

A: DOT/OPS prepares a report outlining specific observations and lessons learned from the exercise. We provide pipeline owners/operators with an advance copy of this report about two weeks after conduct of the exercise. The operator then has the opportunity to review and provide comments directly to DOT/OPS before we distribute the report to exercise participants.

DOT/OPS hopes this information has answered most of your questions. Are there any other general exercise questions you'd like to see answered in future publications? If so, please send them to the attention of Ms. Toni Hundley at the U.S. Department of Transportation, PHMSA/OPS (DPS-3), 400 Seventh Street, S.W., Suite 2110, Washington, D.C. 20510.

A Look At Lessons Learned

By the close of the second quarter of 1996, DOT/OPS will have exercised the spill management teams (SMT) of over a dozen pipeline operators, using the guidelines established for the PREP exercise program.

The overall tabletop exercise program objectives are to validate and enhance the facility response plans (FRP) and response procedures of both the involved operators and the spill response personnel of local, state and federal agencies.

Within these overall objectives are eight core objectives that exercise evaluators use when assessing the SMT's performance. These objectives are: to enhance the SMT's operational capabilities; to increase their knowledge of emergency management issues; to demonstrate their knowledge of the notification process; to improve decision-making among members; to demonstrate their knowledge in protecting environmentally and economically sensitive areas; to increase their knowledge of oil spill response operations; to enhance their communication among the various groups; and to confirm the role of the Qualified Individual (QI).

"A less formal program objective is to bring together local responders and industry to exchange information and problem-solve," says Robert Bradshaw, tabletop exercise facilitator.

The following is a sample of some of the common observations culled from these exercises:

Lesson Learned:

Revise FRP to include information about establishing a Joint Information Center in concert with local, state, and federal public information officers.

During the first few hours after an oil spill, reporters will not only contact the operator for comments, but they'll also call the many local, state, and federal agencies who are involved in the response effort for information.

Establishing a Joint Information Center (JIC) would help to successfully coordinate all media efforts in conjunction with public information officers from all of the involved regulatory agencies. Since a JIC is one of the normal functions of the Unified Command System, its implementation procedures should also be outlined in the operator's FRP.

Lesson Learned:

Revise notification procedures in the FRP to prioritize calls and assign responsibilities.

DOT regulations require that pipeline operators include a description of their notification process in their response plans. Unfortunately, in some plans this may amount to no more than a list of names and numbers. It's important that the operator, prior to an incident, determine the priority of these calls and assign specific personnel to be responsible for placing the calls. Some operators divide this responsibility in two different parts: one person alerts the operator's SMT and oil spill contractors, while the other notifies external agencies, local government officials, and neighboring facilities.

Lesson Learned:

Identify water supply systems and pre-plan their protection strategies.

Water quality issues are critically important to local communities whose drinking water supplies could be threatened by oil spills. Some Area Contingency Plans do not list or address all important water intakes or municipal water supplies and not all local communities have an established mechanism for prompt, systematic notification of all managers of water intakes and other water supply systems. FRPs might be able to better address these water quality issues by highlighting the locations where an oil spill could cause a major disruption to a community's water system, and by including any practical response measures designed to protect the water resource.

These are just a few of the many common lessons learned this year at DOT/OPS-sponsored tabletop exercises. Stay tuned for information about other tabletop exercise findings in upcoming editions.

Through The Eyes Of An Operator

Conoco Inc.'s Rocky Mountain Pipeline System recently participated in a DOT/OPS tabletop exercise held in Denver, Colorado. One of the key lessons we learned was that information-sharing is a powerful learning tool. The exercise fostered interaction with local, state and federal agencies and emphasized the need to integrate our exercising in order to effectively respond to actual emergencies.

Although Conoco conducts numerous drills, this tabletop exercise was unique in that it allowed us to see what the responding agencies could supply during the response effort. It also gave us the opportunity to show them that we're prepared to respond to an incident.

Randy Beggs

Director, Regulatory Compliance

Conoco, Inc.

Calendar of Upcoming Exercises

** = tentative dates