Environmental Monitoring

Annual Drills

Unannounced Drills

The BOEMRE 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 BOEMRE 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 BOEMRE 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 BOEMRE monitoring team discusses with the Spill Management Team the strong and weak areas of the response. The BOEMRE requires that a written report with the complete documentation of the exercise be submitted to the Agency within 15 days. The BOEMRE then prepares a written evaluation of the exercise that may include recommendations/requirements for improvement. If changes in a particular operator’s response strategy are deemed necessary during the conduct of these drills, BOEMRE 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 BOEMRE-initiated unannounced exercises also provide an opportunity for BOEMRE 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.

Required Exercises

Tracking and verification of exercise requirements for spill responders is an BOEMRE 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, communication, 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 communicate 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 BOEMRE at least 30 days prior to these drills occurring. This notice provides an opportunity for BOEMRE 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. BOEMRE can also evaluate the results of these exercises and advise the owner/operator of any needed changes in response equipment, procedures or strategies.

Required Training

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 BOEMRE 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.