The National Preparedness for Response Exercise Program (PREP) is the framework utilized by government and industry for testing contingency plans of the National Response System (NRS). Established as a workable exercise program to meets the intent of section 4202(a) of the Oil Pollution Act of 1990 (OPA 90), PREP was developed to provide a mechanism for compliance with the exercise requirements, while being economically feasible for the government and oil industry to adopt and sustain. PREP represents the minimum guidelines for ensuring adequate response preparedness and addresses the exercise requirements for oil pollution response. PREP helps to clarify objectives and evaluation processes for compliance with Federal regulations. There are many processes that plan holders can use to design exercises to meet the objectives. One option is the Homeland Security Exercise and Evaluation Program (HSEEP). This program serves as a recognized and standardized planning process to assist in the design of exercises.
While industry use of PREP is voluntary, completion of the PREP exercises will satisfy all OPA 90 mandated federal oil pollution response exercise requirements. The PREP Guidelines describe the minimum expectations for ensuring adequate response preparedness. PREP exercises should be viewed as an opportunity for continuous improvement of the response plans and the response system. If Government, industry, or plan holders desire to expand their exercise programs beyond the PREP Guidelines, they are highly encouraged to do so.
Under PREP, plans are regularly tested through notification, tabletop (TTX), equipment deployment, and government-initiated unannounced or no notice exercises (NNX).
EMSI can assist your organization with Internal and External PREP exercises, including:
- Response Plan Triennial Exercise Cycle
- Emergency Procedures exercises
- Incident Management Team (IMT) Tabletop exercises
- Equipment Deployment exercises (Facility and OSRO/HSRO)
- Area exercises
Response Plan Triennial Exercise Cycle
Every three years, all components of the entire response plan must be exercised. Rather than requiring each plan holder to conduct a major exercise every three years, PREP is designed for the individual components to be exercised in portions through required exercises.
To satisfy the requirement of the triennial exercise of the entire response plan, it is not necessary to exercise the entire plan all at one time. EMSI can help exercise your plan in segments over a period of three years, if desired, and ensure that the required exercises are conducted to ensure that each component is addressed and exercised within the triennial cycle.
Emergency Procedures Exercise
The purpose of the emergency procedures exercises is to ensure that personnel are capable of conducting the initial actions necessary to mitigate or prevent any discharge or substantial threat of discharge of oil.
Incident Management Team (IMT) Exercise (Formerly referred to as Spill Management Team (SMT) Exercise)
For USCG, EPA, and BSEE–regulated plan holders, the owner or operator should identify an Incident Management Team (IMT) in the response plan. An annual IMT exercise is required under PREP guidelines and should test the incident management team’s organization, communication, and decision-making in managing a spill response. The response plan should be utilized in the exercise to ensure that the IMT is familiar with the plan and able to use it effectively to conduct a response, including response options described in the plan. At least one IMT TTX in a triennial cycle should involve a Worst Case Discharge (WCD) scenario.
Equipment Deployment Exercises (Facility and OSRO/HSRO)
The purpose of an Equipment Deployment exercise is to deploy and operate facility owned and operated response equipment identified in the response plan. All of the facility personnel involved in equipment deployment operations must be included in a comprehensive training program. Similarly, all facility equipment must be included in a comprehensive maintenance program. Equipment Deployment exercises can help organizations’ ensure that their personnel are properly trained and equipment in proper order in preparation for an incident.
For OSRO/HSRO Equipment Deployment exercises, all OSRO/HSRO personnel and operated equipment that are identified in the plan are held to the same standard as above.
The purpose of the area exercise is to exercise the entire response community in a particular area. An area is defined as that geographic area for which a separate and distinct Area Contingency Plan has been prepared, as described in OPA 90. The response community is comprised of the Federal, State, and local Government and industry, including inviting tribal entities to participate. The area exercises are designed to exercise the Government and industry interface for spill response.