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Unannounced Drills
Ecology may require unannounced drills from oil spill contingency plan holders
(reference
Chapters 90.56 and
88.46 RCW and
Chapter 173-182 WAC). These drills are typically coordinated with the U.S
Coast Guard, Environmental Protection Agency and the Office of Pipeline Safety.
In Washington, plan holders include tank vessels & barges, larger cargo, fishing
and passenger vessels, oil refineries, oil distribution terminals, pipelines,
and other miscellaneous types of facilities.
Why are
unannounced drills called?
·
Specific problems with plans exist or are suspected, or are
·
Strategically selected to ensure adequate testing of personnel and equipment in
all operating environments of Washington State.
What gets
drilled?
Unannounced drills may involve testing any component of the plan including
notification procedures, response management, and deployment of personnel, boom,
recovery and storage equipment.
Unannounced notification
procedure drills use a spill scenario to test that a company:
·
Knows where the plan is.
·
Follows the plan and
·
Effectively initiates a response through timely and appropriate notifications.
Unannounced response
management team drills use a spill scenario to test that a company:
·
Assembles the spill management team.
·
Establishes a command post and
·
Utilizes an Incident Command System (ICS).
Unannounced deployment drills
use a spill scenario to test that a company:
·
Deploys boom for protection and recovery systems.
·
Deploys recovery systems including storage or
·
Deploys personnel for assessment and shoreline cleanup.
How and where are unannounced
drills called?
Typically an inspector arrives on scene, announces the drill, describes the
scope of the drill, and provides drill scenario inputs as needed. The drill is
started as soon as the company has read all of the material provided.
Plan holders may request to be excused for that day if conducting the drill
poses an unreasonable safety or environmental risk, or significant economic
hardship. If the plan holder is excused, Ecology will conduct an unannounced
drill at a future time.
An example of the unannounced drill protocol and checklist for vessels can be found here.
