Transcript Qualified Individual Spill Management Team Training

Regulatory Lessons Learned
Drills, Plans, Training and
Response
Presented By
Trey Phillips
J. Connor Consulting, Inc.
www.jccteam.com
Beginnings
Rivers and Harbors Act
1899
Regulatory History
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Clean Water Act of 1972 – established a basic
system for the cleanup of oil spills
Required operators to own or have access to spill
response equipment
 CGA formed
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1978 Amendments to the Outer Continental
Shelf Lands Acts (OCSLA) established liability
for cleanup costs and damages
Regulatory History
Oil Pollution Act of 1990
(OPA 90)
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Catalyzed by the grounding of the Exxon Valdez, signed into
law by President Bush on August 18, 1990
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The most comprehensive oil spill liability and prevention
regime enacted by any country in the world
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Primary aspects:
 Prevention
 Planning
 Liability
 Response
Regulatory History
Prevention
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OPA 90 Requirement for double hulled vessels by 2015
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SKS Satilla
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Off Houston, 4 March, 09
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40,000,000 Gallons Crude
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Struck Ensco 74
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130 ft. Gash, Outer Hull
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No Spill
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It worked!!
Regulatory History
Prevention
DBL 152, The largest spill you’ve never heard of
Various “Experts” said, the 441 foot barge “Will not turn turtle!”
Oops!!
Spill recovery techniques!?
How much lost? 1.3 Million Gallons??
Where is it??
OPA Jurisdiction for
Prevention and Planning
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USCG for vessels & marine-transportation related
facilities
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EPA for onshore oil storage facilities
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DOT-PHMSA for oil transmission pipelines
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BSEE for offshore facilities
Concept of “Responsible Party”
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RP of offshore facility = the
lessee or permittee of the
area in which the facility is
located
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OPA imposes strict liability
for oils spills  liability
without fault
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Therefore, the RP is the
owner or operator of the
facility, regardless of who
was at fault for the spill
Preparedness
Oil Spill Response Plan
Requirements for the OCS
BSEE Plan Requirements
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30 CFR Part 254 requires operators of all oil
handling, storage, or transportation facilities
located “seaward of the coast line” to submit an
oil spill response plan to BSEE
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This includes all facilities in state waters that are
“outside of the barrier islands”
Plan Submission
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All facilities must be covered under an approved
response plan. Plans are approved for a period of two
years.
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Plans must be kept up-to-date; operations must be in
compliance with the Plan.
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Significant modifications must be submitted to BSEE
within 15 days:
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Reductions in response capability
Significant increase to any worst case discharge scenario
(NTL 2013-N02)
Changes to QI/Spill Management Team
NTL 2013-N02
Instead of comparing WCD volumes, BSEE is
now shifting the focus of a WCD comparison to
spill response equipment.
If proposed WCD requires more equipment, then
you must revise your OSRP and submit to BSEE
within 15 days.
 For drilling WCD, the 15 day deadline begins when
you submit an APD.
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OSRP Regulations - 30 CFR 254
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254.30 When must I revise my response plan?
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You must submit revision to your plan for approval
within 15 days whenever:
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A significant change occurs in the worst case discharge
scenario or in the type of oil being handled, stored, or
transported at the facility.
Implications
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The NTL was issued by BSEE and it affects Oil
Spill Response Plans.
The NTL has no bearing on BOEM or
EP/DOCD process.
BSEE and BOEM are still in discussions
regarding OSRP approval’s role in EP/DOCD
review/approval.
They have not yet come to an agreement.
BSEE Definition of a Qualified
Individual
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An English-speaking representative of an owner or
operator:
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located in the United States
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available on a 24-hour basis
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with full authority to:
 obligate
 carry
funds for surface and subsea operations
out removal actions
 communicate
with the appropriate Federal officials
and the spill response organization
Evolution
Training, Drills & BSEE
Unannounced Drill Program
Evolution of Exercises
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Exercises Mid 90’s
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Exercises in Y2k
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Operator filled most or all boxes on Organization chart
Training once a year left most unsure of how to perform their assigned duties
Started the transition to Contract Spill Management Teams
Operator moved to positions on the Organization chart that made sense to their
daily expertise
 Qualified Individual
 Source Control
 HR/PIO/Legal
Contract SMT’s found their way into most operators Spill Plans
Training was dwindling down to the QI for operators
Exercises Post-Deepwater Horizon
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Healthy combination of Responsible Party and contract SMT on Org. Chart
All personnel listed on the Org. Chart receive annual classroom training ,
covering components outlined by BSEE
Deepwater source control has outgrown the traditional organization
Training Requirements
Today and Beyond
Spill Management Team and QI must receive
annual classroom training
 SMT members should “Know Their Job”
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Source Control Section Chief should have Source
Control Training. (At this time, BSEE accepts
exercises as training)
 No other guidance given by BSEE regarding types
of training for specific team members.
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BSEE Oil Spill Program Initiatives
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Inspects oil spill response equipment under contract
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Conducts unannounced oil spill drills:
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Develops the spill scenario
Establishes an observation plan
Initiates exercise with Operator, contract SMT or offshore
facility
Facilitates and evaluates the exercise
Reviews drill documentation (to be submitted w/n 15
business days)
Prepares and disseminates a technical analysis of the drill and
determines success on a pass/fail basis
BSEE Unannounced Exercise Hints
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Be aggressive, notify responders early
Know how to activate your subsea contractor
Have an orderly sign-in system and formatted roster
Follow the BSEE instructions to the letter when preparing
documentation
All team members must keep a log of their major actions during the
event—recommend use of ICS 214 A
Put your name and SMT position at the top of each page
If you are named in the OSRP in any position, ensure you have had
SMT training in the last year
Most INCs are for documentation
Problems with past drills or district offices and bad safety record can
get you picked.
Recent Lessons from Exercises and Incidents
BSEE:
• Is extremely involved working blowout scenarios
• Research all possible avenues to solve a well control issue
• Be ready to provide detailed safety plans for every source
control and debris removal operation
Communications
• Ensure good communications between Source Control
and Unified Command
• Request USCG and BSEE liaison at your Source
Control Command Post
Recent Lessons from Exercises and Incidents
Documentation & Control
• Ensure contractors and company personnel turn in
documents
• An Incident Action Plan (IAP) will likely be requested
if extended well control operations are expected (2-3 days)
Recent Lessons from Exercises and Incidents
Training and Records:
• Initiate organization of training records of contractors and
company personnel
• Initiate organization of all BOP records from date of
manufacture through latest testing prior to deployment
Source Control Operations:
• Coordinate all Well Control actions with CG and BSEE
Incident Management
•Leave no doubt that you are in control and are working
cooperatively with the USCG and BSEE
•Get PIO help ASAP
QUESTIONS????