April 23, 2024 • 34 mins
In this episode, we dive into ADEC's 485 Drill Exercise Program, a vital initiative that ensures safety and preparedness in Alaska's fuel storage and transportation sectors. Join us as we explore the program's objectives and the rigorous training exercises involved in the significant impact of community and environmental protection. Hear firsthand accounts from experts who share their insights on the program's challenges and successes. Whether in the industry or curious about Alaska's proactive approach to fuel safety, this episode promises to be enlightening and engaging. Tune in to understand how the ADEC is making strides to safeguard Alaska's pristine environment through diligent preparedness.
Episode Transcription
ADDITIONAL RESOURCES:
ADEC SPAR Spill Response Exercise Program
18 AAC 75
Oil Spill Response Exercise Manual
ADEC SPAR Spill Response Exercise Schedule
ODPCP Regulation Implementation Tools and Resources 2023
Alaska Chadux Network
SEAPRO
CISPRI
Alaska Clean Seas
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. If you need professional regulatory advice, we would be happy to provide it as part of our consulting services.
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Episode Transcript
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Shannon (00:00):
Good morning, welcome to Tank Talk.
I have somebody from our stafftoday, somebody new to the
podcast.
I'd like to introduce RosieNethercott, our Senior
Environmental Consultant andManager of our Planning and
Permitting Department.
This spring, for a lot of ourclients there's been a focus on
a new program from the state ofAlaska Department of
(00:22):
Environmental ConservationProgram from the State of Alaska
Department of EnvironmentalConservation.
Its nickname is the 485 DrillProgram, but it is actually a
combination of a regulation andexercise manual and I have
invited Rosie on to the podcastto talk about it because we've
been digging in deep and I thinkthat there's a lot of value for
our listeners who may also needto implement the 485 Drill
(00:45):
Program in the coming years.
So, rosie, welcome to thepodcast and I was hoping you
could maybe introduce yourself alittle bit to our listeners,
since you're new here, before wedig into the 485 Drill Program.
Rosie (00:57):
Yeah, thank you so much for having me on today.
I have worked for Integrity nowfor eight years.
My degree is in biology and Ipreviously worked for the state
of Alaska for the Division ofBoiling Gas, where I helped with
lease sales and writing bestinterest findings documents.
Those are the documents thatdetail both environmental and
(01:18):
economic impacts of boiling gasexploration in regions all
across Alaska.
During my time here atIntegrity, I've grown from an
environmental consultant into asenior consultant and now I'm
managing the Plans and PermitsDivision.
I manage a team of consultantsthat write and review
environmental plans and permits.
So we do SPCCs, FRPs, SWPPPs,and our specialty is Oil
(01:44):
Discharge Prevention ContingencyPlans or ODPCPs.
We also offer consultingservices for the gamut of
environmental compliance issuesthat bulk fuel facilities, fish
processors and utilities faceacross Alaska.
I'm excited to talk to youtoday about ADEC's new exercise
program that was adopted intoregulation in February of 2023.
(02:08):
The new regulations werepartially implemented back then
because there were quite a fewchanges, and they were fully
implemented in August of 2023.
We have worked with manyclients over the past year to
help them achieve credit fortheir 485 drill that Shannon
mentioned earlier, and I'mlooking forward just to sharing
(02:30):
our experiences working withthose clients and helping our
listeners understand more aboutthe new regs.
Shannon (02:37):
Rosie, thank you for that introduction.
That gives us a real good ideaof where you're coming from.
I wanted to talk a little bitmore about the 485 drill program
and the accompanying exercisemanual.
I mean, the state of Alaska haddrill requirements before
February 5th of 2023.
But after that date theysignificantly changed those
(03:00):
requirements.
So I was hoping you couldpotentially just give us sort of
the big picture view of the 485drill program.
Rosie (03:08):
The ADEC developed an oil spill response exercise manual
in which they adopted thedoctrine and methodology that
was laid out in the Departmentof Homeland Security's exercise
and evaluation program for theHSEEP.
The methodology of the HSEEP isboth flexible and scalable,
(03:32):
allowing it to be adjusted tofit a specific facility.
So, in consultation with ADEC,the exercise planning process
can be scaled to meet the focusand size of any exercise.
And, from our understanding,the Oil Spill Response Exercise
Manual has been adopted intoregulation to serve the wide
(03:52):
range of regulated facilitiesall across Alaska.
Shannon (03:56):
Okay.
So, if I'm understanding thisright, the regulation that
passed is what we're calling 485, and it's actually 18 AAC 75,
485.
And in that section, under 485,the oil spill response exercise
manual has been adopted byreference, and that manual is
sort of a how to guide to how todo the drills.
Is that correct?
Yes, okay.
(04:17):
And then, and then the scalablepart, which was all the
alphabet soup from HomelandSecurity that ends up being
HSEEP or HSEEP.
That is, a evaluation tool thatallows the state to evaluate
small drills or very complexdrills, depending on all of the
different factors.
Yes, exactly, okay, okay, gotit.
(04:39):
So what are the end goals oroutcomes?
Rosie (04:49):
Like when we look at the 485 drill program altogether.
Has the state given us any sortof idea of what they want to
come out of this program?
And what they're wanting is toverify compliance with statutes
and regulations relevant to anowner or operator's ability to
adequately respond to a spill.
(05:10):
They're wanting to improvecurrent levels of response and
readiness across the state.
They're wanting to encourageinnovation and improvement and
then, of course, maintainconsistency statewide with how
they're evaluating all of theplan operators.
Shannon (05:42):
The main objective of every ADEC-recognized 485
exercise is to validate theODPCP by ensuring it's adequate
in content and that the ODPCPholder, the plan holder, can
carry out it effectively.
Okay, so I mean that doesn'tdiffer too much from previous
drill requirements.
I think the biggest differenceto me sounds like the
consistency statewide and thenthe improving current levels of
response readiness.
Rosie, could you talk a littlebit about the consistency piece,
like how is the state lookingto maintain consistency?
(06:06):
I'm guessing that it goes twoways.
Right, like the state needs tobe consistent in how they
respond to businesses subject tothe ODPCP regulations.
But what about the actual ODPCPholders, like what are they
looking for for consistencythere?
Rosie (06:21):
So it is critical that staff working in bulk fuels are
kept up to date on how to safelyand effectively respond to an
oil spill, and the best way toaccomplish this is through
regular oil spill exercises.
Shannon (06:34):
That's consistent across state and federal right.
Like that's universal bestpractice.
So how does that oil spillresponse exercise manual talk
about standardized stuff?
What does it say?
Rosie (06:47):
The manual has established standardized
procedures to ensure effectivedrills and consistent
evaluations of the participantsand per 1880, aac 75.485, c-plan
holders are required to performan oil spill response exercise
in accordance with the manual atleast once during their
(07:09):
five-year renewal period oftheir C-Plan.
The exercise has to beoperations-based and it has to
directly reflect an aspect ofthe C-Plan, so a part of a
scenario or an entire scenariohas to be incorporated into the
exercise.
Shannon (07:29):
Okay.
So the exercise manual isgiving us a consistent way to
perform these exercises, andthen they also have requirements
to perform at least one spillresponse exercise during each
five-year renewal period.
We know inside the exercisemanual it discusses three
different types of exercisesthat are acceptable and these
(07:53):
drill types vary in complexityand how much time you have for a
planning period.
And then, within that planningperiod, we also have the amount
of work a plan holder must do toprepare for that final drill.
And I was hoping, Rosie, wecould dig the amount of work a
plan holder must do to preparefor that final drill.
And I was hoping, Rosie, wecould dig into each one of those
drill types independently,because this is the question I
get the most from our clients islike which drill are we going
to have to do?
(08:13):
How much work is it going to beLike, what are the expectations
?
And you could read the exercisemanual it is lengthy and not
the most gripping tail manual.
It is lengthy and not the mostgripping tail.
I thought maybe if you and Idiscussed it it might help our
listeners get a good grip on thethree basic types of drills.
Sounds great, okay let's dig in.
Rosie (08:36):
What's the shorty?
Yeah, so the shortest one ofall of them is called a drill,
and this type of exercise is theleast involved of the three
types.
It has the shortest planningperiod and time frame to
accomplish it.
It is commonly used to testequipment, validate procedures
or practice and maintain currentskills.
So some examples of this typeof drill are skimmer and boom
(09:00):
deployment and doing a specifictactic like containment boom,
exclusion boom, diversion boomand deploying your skimmer.
There's also land-based tacticsthat could happen creating a
berm to divert or contains aspell and then also just
practicing notificationprocedures as part of it.
Shannon (09:19):
It could be part of a drill so what kind of what kind
of time frame is this lookinglike for something like for this
level of drill?
Rosie (09:27):
So if you look at the manual, it's going to tell you
two to four months, which soundskind of scary.
It sounds like a lot of time,but the actual time commitment
that we're seeing our clientsput into this is roughly five to
seven days of their time, andthis will involve doing one to
three planning meetings with thestate.
Likely you would also have oneto two internal planning
(09:50):
meetings before you're meetingwith the state of Alaska.
Then you're going to have thedrill itself, which is typically
a half day to one full day.
You'll have a lessons learnedand evaluation meeting, final
report preparation and thenresponding to any of ADEC's
findings after they've issuedtheir evaluation of the drill
itself.
Sometimes you will have toamend your C-Plan afterwards as
(10:14):
well.
So if something came up duringthe drill that wasn't able to be
accomplished in the way it wasdescribed in the C-Plan, you
might need to amend your C-Planto make it more realistic.
So the drill exercise describedin the C plan you might need to
amend your C plan to make itmore realistic.
Shannon (10:25):
So the drill exercise described in the exercise manual
is the shortest drill exerciseand, just to summarize, two to
four months, but the actualmeeting load is more like five
to seven days spread out allthroughout those two to four
months.
I'm guessing they get harder,not easier, after this.
Rosie (10:41):
They do.
Shannon (10:43):
Okay.
Rosie (10:44):
Yeah, so the next level up from a drill is the
functional exercise, and thisone does have a longer time
frame to complete.
It's estimated at six to ninemonths when you look at the
exercise manual.
But as far as what time weestimate that you would be, or
the plan holder would be,committing to it, it's closer to
two to three weeks of theirtime.
(11:06):
The exercise is conducted in arealistic, real-time environment
.
However, the movement ofpersonnel and equipment is
usually stimulated in this typeof exercise.
It's similar to a tabletopdrill, but it is more involved,
and members of the incidentcommand team are drilled on
specifics in the C-Plan.
(11:26):
There also might be asimulation cell or a sim cell
which adds injects throughoutthe exercise that the players
have to respond to.
Shannon (11:36):
This is not just a portion of a spill scenario.
This is probably the wholespill scenario or significant
portions of a spill scenario.
Rosie (11:45):
Yes, okay, it would involve more of the scenario.
The timeline is longer on thisexercise because there are more
people involved and the exerciseis larger, so it requires more
planning to be successful.
The planning phase for thisexercise will typically include
anywhere from three to fiveplanning meetings.
The scenario is developed, it'srefined, injects may be
(12:08):
determined if they are going tobe included, and the final
logistics are sorted out duringthat planning phase.
The oil spill response exercisemanual includes some really
handy sections on each of thesemeetings and it lists the
objectives that need to beachieved in each of those
meetings.
That's a really good referencefor everybody to look at, and
the exercise itself would likelybe conducted over one to two
(12:31):
days, so it would take longerwhen you're comparing it to the
drill, and it, of course, wouldinvolve the evaluation by ADEC,
which may require an amendmentto the C-PLAN.
So, yeah, overall, closer totwo to three weeks of time
commitment from the plan holder.
Shannon (12:49):
So we've covered the drill, we've covered the
functional exercise.
What do they have in theexercise manual to top the
functional exercise?
Rosie (12:59):
Yeah, the biggest one, it's the full scale IMT.
So it's not just a tabletop,it's not just an equipment
deployment, it's all of it.
It's the most comprehensive andcomplex exercise of the three
and it can take up to a year tocomplete.
So the manual says anywherefrom six to 12 months.
(13:20):
That we've estimated for theplan holder.
We're thinking closer to threeto four weeks of their time, so
it's longer, it's going to takemore planning and all of that.
This type of exercise combinesresources from both the IMT and
the field and it may involveadditional stakeholders,
regulatory agencies, both stateand federal, local interested
(13:44):
parties.
Really anyone that has aninterest in the spill response
capabilities can be involved inthis type of exercise and in a
full-scale exercise, events areprojected through an exercise
scenario with injects that driveactivity at the operational
level.
This type of exercise also willbe conducted in real time a
(14:08):
stressful environment and it'sreally intended to mirror a real
incident, so personnel andresources may be mobilized and
deployed to the scene whereactions are performed as if a
real incident has occurred, andthere are typically many players
in an exercise of this scaleand is performed over several
days.
Shannon (14:29):
That is a lot more complex than the first two.
Could you break down some ofthe pre-work that has to happen
for this level of exercise?
Rosie (14:39):
This type of exercise is going to involve a lot more
planning typically five planningmeetings with the state of
Alaska and with yourstakeholders, or whatever
stakeholders may be party to theexercise, and the plan holder
is likely going to need to holdmany internal planning meetings
as well just to prepare forthose agency meetings.
(15:02):
Lots of logistics have to beworked out.
The whole scenario needs to beplanned.
A lot more planning goes into alarger scale drill like that.
Shannon (15:12):
How long in real time would this drill be?
Rosie (15:17):
It could span anywhere from two to three days.
They can take a while to getthrough an entire exercise of
this scale.
Shannon (15:25):
So at the drill level, we've got one half to one full
day for an exercise and thefunctional exercise.
That may be one day, or one totwo days, and then this full
scale IMT.
We're expanding it all the wayup into two to three days and
you've got more players, morepieces and real functionality.
(15:47):
When I hear you describe all ofthis, rosie, it sounds like
those are sort of idealtimeframes and resource
estimates.
If everything's optimal and youand I live in reality, so do
the clients need to plan foradditional training or test runs
of any of these components ontop of that time commitment
mapped out by ADEC?
Rosie (16:09):
Yeah, absolutely.
I think we've seen some of ourclients show a little bit of
nervousness just that ADEC isgoing to be on site and
evaluating them.
So there is this desire to beprepared and to do that.
You've got to practice and sowe're seeing our clients want to
do a practice run ahead of thereal drill.
(16:33):
That really should be accountedfor when you're planning for
your time commitment.
So typically, if you're goingto do some practice runs, I'd
add in another day or two to getthrough that training with your
employees.
Shannon (16:46):
Correct me if I'm wrong , but I think we're seeing
practice runs both at theterminal or facility level, like
the guys on site.
But there's also incidentmanagement training for the
command level right People at acompany that would be on the
incident management team.
So CEOs, general managers, cfos, they're having to do practices
(17:08):
as well, correct?
Rosie (17:09):
Yes, yeah.
Anyone that's going to have arole or an ICS role in that
exercise should be prepared andthat would involve practicing
what their responsibilitieswould be.
Shannon (17:21):
In the last year that we've been doing this, Rosie,
how has ADEC been applying theseregulations in real life?
What has come out of this inthe first year of the 4E5 drill
program?
Rosie (17:31):
So what we have seen in our experience so far is ADEC is
starting where the clients areat right now and what they are
currently capable of.
So what I mean by that is forthe smaller facilities, so those
without a large year-roundstaff they're typically going to
start with a drill, which isthe smallest exercise that we
(17:52):
talked about, and then for thelarger facilities, the ones that
have a big staff to pull fromthey're there all year round.
They may be expected to do thefunctional exercise or even a
full-scale IMT.
Shannon (18:06):
How is the state scheduling these exercises?
Rosie (18:10):
Just pulling from our knowledge and what we've seen is
ADEC has initiated theconversation with our plan
holders about schedulingexercises.
I say that as what we've seen,but it's not what's in
regulation.
So it really is the planholder's responsibility to
initiate the planning phase ofthe drill and to engage with the
(18:31):
state of Alaska.
Shannon (18:33):
The state is reaching out to people right now, but the
way the regulation is written,the responsibility for
scheduling these drills restswith the C-Plan holder, not the
state of Alaska.
Exactly so the state's helpingout or trying to get things
going with some outreach, butthat's not necessarily part of
their obligation or requirement.
Rosie (18:53):
So, yeah, what we have seen over the past year is that
ADEC is giving plenty of leadtime when they contact the plan
holder to make sure that theyhave time to plan and prepare.
And in past drills ADEC hasshown an understanding that
running these exercises takestime away from the businesses
and they want to work with theplan holders to make sure
(19:14):
operations at the facility arenot significantly interrupted
but still, of course, ensuring asuccessful exercise is
accomplished.
Shannon (19:23):
I'm wondering like how strict are they being about the
DEC participation?
I mean, I'm wondering like, howstrict are they being about the
DEC participation?
I mean, how does that look inreality?
Rosie (19:30):
They are being pretty strict about that.
It's clearly stated in theregulation we have seen that
they're not allowing facilitiesexercises to qualify for a 485
drill if that plan holder didn'tcoordinate with ADEC during the
planning phase.
Coordinate with ADEC during theplanning phase.
(19:51):
Per the manual, ADEC must begiven the opportunity to
participate in the planningphase of the exercise for the
plan holder to receive 485 drillcredit.
This means that if you're readyto do a 485 drill, reach out to
ADEC as soon as you can to geta tentative schedule lined out
so they can participate from thebeginning and really ensure
that you're going to get thecredit for the exercise.
Shannon (20:12):
That is a great critical point and everybody
listening if you are responsiblefor the 485 drill program at
your company, you've got toreach out and get on the
schedule as soon as you know youare ready.
All right, so let's talk aboutthe evaluation framework for
these drills.
We've been through quite a fewnow and I want to talk about.
Dec has objectives, but thereare evaluation criteria as well.
(20:36):
So what does evaluation looklike under the exercise manual,
rosie?
Rosie (20:41):
Past drills.
We've observed we have seenADEC evaluates 485 drills to
determine whether the actionstaken during the exercise are
consistent with what is in the Cplan.
They also want to see a timelyresponse during the exercise and
without coaching from ADEC.
So the oil spill responseexercise manual.
Shannon (21:03):
There's a really good appendix in there, append b so
if they're evaluating what's themetric, are they giving out
gold stars?
A pluses five out of five?
Like what?
Where?
Where does the state fall onthe performance scale?
Rosie (21:20):
I'm gonna pull from what I've seen in the past year.
They're just issuing lettersacknowledging that the 485 drill
was run and that credit isbeing given to the plan holder.
The manual itself does have arating system.
So, like I said, the manual iskind of a guidance document so
(21:42):
it can be used for evaluations,and the four ratings that are
listed in the manual areperformed without challenge,
which is a letter P.
Performed with some challenges,s, performed with major
challenges, m and then unable tobe performed.
(22:02):
So those are the four differentratings that can be given based
on the ADEC evaluation.
Shannon (22:09):
So with these rating system and response letters to
actual drills?
How is ADEC coming in onfeedback and lessons learned?
Are they coming in hot withnotices of violation or are they
taking a different approach?
Rosie (22:29):
with notices of violation , or are they taking a different
approach?
So far, I've not seen anynotices of violation coming out
of these drills, and no fineshave been assessed due to
unsuccessful exercises, as faras we know.
Depending, though, on theseverity of the inadequacies,
adec may require another 485drill, so you might not achieve
the credit that you were goingfor.
You might have to do it again,or they may propose actions to
(22:50):
the plan that the plan holdercan take to ensure a successful
exercise next time.
There is a sense that ADECwants these exercises to make
the plan holder more preparedfor spill response instead of
being used as a way to issueNOVs and fines of being used as
(23:12):
a way to issue NOVs and fines.
Shannon (23:13):
Yeah, that sounds like a relief.
I think a lot of our clientswere really worried that there
was going to be quite a bit ofNOV and fees and I am not a
lawyer, neither is Rosie but Ido think that at this early
stage of the game, with thisprogram being new, the state of
Alaska is leaning more towardsassistance, towards compliance,
rather than correction throughissuance of notice of violation.
(23:35):
That is all really goodinformation to know for our
listeners that are responsiblefor 485 DRLs.
I do get this question a lot,rosie, and maybe we can debunk
it or clarify it here.
How does the 485 program differfrom NPRP, and can we just do
NPRP and meet the 485 drillguidance?
Rosie (23:56):
Biggest difference between NPRP or even a federal
government initiated unannouncedexercise or a GUI and the 485
drill is ADEC's involvement.
Adec has to be involved prettymuch as soon as the plan holder
knows that they're going to havea drill.
They will be part of theplanning meetings, they're going
to be present at the exerciseand they will provide a final
(24:19):
evaluation after the exercise iscomplete.
The second biggest differenceis that 485 drills must be based
on an aspect of the spillscenario in your C plan.
So it doesn't necessarily haveto be the largest spill scenario
, which is the ADEC responseplanning, standard volume or the
worst case discharge scenario.
(24:39):
It can be the medium or thesmall spill scenario.
But ADEC is just really wantingto see that what is written in
your C plan is not just fictionand that it can actually be put
into action.
Shannon (24:53):
Can any of the end prep exercises get credit for 485
drill?
Is there some mechanism forthat or do they have to be
separate?
Rosie (25:01):
No, they absolutely can be done concurrently and can
receive credit.
But, like I said earlier, theyjust need to make sure they're
getting ADEC involved from thestart and that the exercise is
based on a scenario in theirC-Plan.
Shannon (25:18):
Okay, well, you mentioned GUIs.
I have a feeling a GUI is alittle trickier, though, because
it's unannounced.
So how do you get the stateinvolved if it's unannounced?
Rosie (25:27):
trickier though, because it's unannounced.
So how do you get the stateinvolved if it's unannounced?
Yeah, so with it beingunannounced, you're not going to
be able to notify ADEC prior tothe drill.
But ADEC has actually answeredthis question on their FAQ page
and we will link that in theshow notes.
But basically, for a GUI tocount, the planning team will
also need to consist of atrusted agent from the plan
(25:49):
holder in addition to ADEC andthe federal agency.
Following the guidelines in themanual, a trusted agent could
be a third-party contractor orit could even be someone from a
federal agency, such as the USCoast Guard, that brings the
ADEC into the exercise planningphase and that would ensure that
(26:12):
it would meet 485 credit.
Shannon (26:14):
Okay, Got it.
So that trusted agent.
It can be many different people, but I think the idea is that
the unannounced part still staysunannounced to the client.
Okay.
I also do get quite a fewquestions about combining drills
for regional exercises andpotentially cost savings.
(26:36):
Like, hey, if the ADC is goingto come all the way out to this
remote Western location, do youthink we could do a drill
involving multiple seaplaneholders in the same community?
How has the state been reactingto those types of requests,
Rosie?
Rosie (26:52):
With this program still being in its infancy, what we
have seen is ADEC is leaningtowards keeping the exercises
focused on individual facilitiesat this time, and the main
reasoning is that it keeps thescope of the drills a little
more manageable from ADEC'sperspective, it ensures that one
(27:12):
facility meets the requirementsin their C-Plan, and that's
simpler than including multiplefacilities with all of their own
C-Plans and all of their ownscenarios.
With that all said, there hasbeen an indication that ADEC is
open to incorporating multipleplan holders in 485 drills in
the future future.
Shannon (27:38):
I have a feeling, rosie , that as the program develops
and skills are built, the statewill probably be more open to
that kind of combination stuff.
But I think right now for someof our communities and sea plan
holders the readiness level isnot.
They need to build and practicefirst.
And then I also I did want toclarify we've been talking
throughout about facilities andC-plans and I did want to just
(28:00):
make this note that we're usingthe term facility and C-plan
sort of interchangeably.
Some C-plans do have multiplefacilities in them and the state
is focused primarily on theC-plan, the way the 485
regulation is written.
So just in case you think you'reout there thinking you could be
really clever and just have adrill for one facility, even if
(28:20):
you have two under one OD PCP,it's really the OD PCP or the
C-Plan that is driving the drill, not a north terminal versus a
south terminal, for example.
It could be any component ofany part of a sea plan.
So if you've got two differentsea plan activities at two
different terminals all underthe same sea plan, it's all fair
(28:40):
game.
Rosie, thank you, that was avery in-depth dive and I think
that kind of answered some ofour frequently asked questions,
and it was a very good and clearoverview of the types of drills
and the evaluation criteria,and so I was wondering if you
could point our listeners toresources that we have
(29:01):
identified as useful to learnmore about the 485 Drill Program
and to guide their own 485Drill responsibilities.
Rosie (29:10):
Plan holders.
C-plan itself is really a greatdocument to refer to.
I would specifically be payingattention to the spill scenario
section, and your ODPCP isbasically a contract between you
and ADEC.
So you as a plan holder haveattested that your facility has
(29:30):
the capabilities lined out inthe plan.
So now is really a great timeto look through it and see if
any revisions are needed.
Your oil spill responseorganization or your OSRO, or
also can be referred to as theprimary response action
contractor, PRAC they havesometimes will have planning
tools and or oil spill responsemanuals that are really
(29:52):
excellent tools and resources tolook at to prep for an exercise
.
Some other useful websites thatwe're going to link in the show
notes include ADEC's SpellResponse Exercise Manual.
We've mentioned it many timeshere today and they have a
website set up for the manual.
(30:12):
They also have a website set upfor the Spell Response Exercise
Program website set up for themanual.
They also have a website set upfor the spill response exercise
program.
The regulation itself, ofcourse, is good to refer to 18
AAC, 75.
And then ADEC also has a spillresponse exercise scheduler.
It's a fancy calendar thatshows when all of the upcoming
(30:33):
exercises have been scheduled,and you can also schedule your
exercise through that website.
Shannon (30:41):
So that exercise scheduler, Rosie, that's to
ensure that you're notoverlapping drills with someone
else.
So you need to actuallyschedule like, you need to check
that when you're thinking abouta drill and making sure that if
you want to do it in June of2025, then you didn't have the
same idea as six other people inthe state of Alaska.
Yeah, exactly.
Rosie (31:01):
And just being cognizant of your region too, because SPAR
is broken up into differentregions so you can check the
calendar to see make sure you'renot overlapping with a drill
that's in your same region.
Okay, yeah, just a few othersthat are good the ODPCP
regulation, implementation toolsand resources.
That's a mouthful, but there'stons of links on that website
(31:24):
that are very helpful withC-Plan writing and planning for
exercises.
And then some of the OSROs andPRACs that we are familiar with
are the Alaska Shadot Network,CPRO, CISPRI and Alaska Clean
Seas.
Shannon (31:43):
And each of their websites has access to spill
response planning tools.
All right, Rosie, thank you forthat review of the resources.
Thank you for taking us throughthe regulation and the exercise
manual.
This is complex.
This is not necessarily theeasiest thing to do.
Where could our listeners gofor additional training or help
(32:03):
with any part of this process?
Rosie (32:06):
You can always come here to Integrity Environmental, Of
course.
Yes, yeah, here at Integrity wecan provide a lot of guidance
on how to set up the exercise.
We can help with training andprovide feedback during the
practice runs of it.
Shannon (32:24):
We also can facilitate the drill.
Rosie (32:27):
Yes, absolutely.
Another good resource fortraining would be the Alaska
Shadow Network.
They are a business partner ofours and they can provide
incident management teamtraining, which can happen in a
virtual setting or they can dothat in person as well.
Shannon (32:44):
And that is a valuable resource because a lot of the
incident management teamtraining that's out there is
free and available from FEMA andwe can also link that.
But a lot of people learnbetter in person when they can
ask questions and have it bespecifically directed to the
Alaska community that the drillis going to be in, and so that
(33:05):
in-person training or virtualtraining, but from somebody who
knows Alaska, can be really, Ithink, more effective in the
long run for people retainingthe knowledge and being able to
use it during a real spill,which is super stressful,
instead of this generic FEMAtraining about.
I mean, the FEMA training isgood, I will never knock it, but
it's not the same, as this iswhat you do for your specific
(33:28):
facility in your specificcommunity.
Rosie (33:30):
One more that I was going to plug is ADEC.
They are a really good resource.
When you have questions aboutthis, you can go straight to
your plan holder to ask specificquestions about drills.
If you have questions aboutregulations, they have set up an
email that you can sendspecific questions about regs
that they will respond to in atimely manner.
Shannon (33:53):
Yeah, that's my experience with the state is,
every time I've called and asked, I've gotten an immediate
response from them and they arevery open to talking people
through this process.
All right, thank you so much,rosie.
I really appreciate you comingonto the podcast to share all of
this information with ourlisteners and I hope for
everyone out there listeningthat we made the 485 drill
(34:15):
process a little more clear andif you have any questions or if
you'd like to see us coveranything, you have suggestions
for future episodes, we'd liketo hear it.
So give us a shout out on emailand we will see you on the next
podcast.
Thanks so much, everybody.
Good morning, welcome to Tank Talk.
I have somebody from our stafftoday, somebody new to the
podcast.
I'd like to introduce RosieNethercott, our Senior
Environmental Consultant andManager of our Planning and
Permitting Department.
This spring, for a lot of ourclients there's been a focus on
a new program from the state ofAlaska Department of
(00:22):
Environmental ConservationProgram from the State of Alaska
Department of EnvironmentalConservation.
Its nickname is the 485 DrillProgram, but it is actually a
combination of a regulation andexercise manual and I have
invited Rosie on to the podcastto talk about it because we've
been digging in deep and I thinkthat there's a lot of value for
our listeners who may also needto implement the 485 Drill
(00:45):
Program in the coming years.
So, rosie, welcome to thepodcast and I was hoping you
could maybe introduce yourself alittle bit to our listeners,
since you're new here, before wedig into the 485 Drill Program.
Rosie (00:57):
Yeah, thank you so much for having me on today.
I have worked for Integrity nowfor eight years.
My degree is in biology and Ipreviously worked for the state
of Alaska for the Division ofBoiling Gas, where I helped with
lease sales and writing bestinterest findings documents.
Those are the documents thatdetail both environmental and
(01:18):
economic impacts of boiling gasexploration in regions all
across Alaska.
During my time here atIntegrity, I've grown from an
environmental consultant into asenior consultant and now I'm
managing the Plans and PermitsDivision.
I manage a team of consultantsthat write and review
environmental plans and permits.
So we do SPCCs, FRPs, SWPPPs,and our specialty is Oil
(01:44):
Discharge Prevention ContingencyPlans or ODPCPs.
We also offer consultingservices for the gamut of
environmental compliance issuesthat bulk fuel facilities, fish
processors and utilities faceacross Alaska.
I'm excited to talk to youtoday about ADEC's new exercise
program that was adopted intoregulation in February of 2023.
(02:08):
The new regulations werepartially implemented back then
because there were quite a fewchanges, and they were fully
implemented in August of 2023.
We have worked with manyclients over the past year to
help them achieve credit fortheir 485 drill that Shannon
mentioned earlier, and I'mlooking forward just to sharing
(02:30):
our experiences working withthose clients and helping our
listeners understand more aboutthe new regs.
Shannon (02:37):
Rosie, thank you for that introduction.
That gives us a real good ideaof where you're coming from.
I wanted to talk a little bitmore about the 485 drill program
and the accompanying exercisemanual.
I mean, the state of Alaska haddrill requirements before
February 5th of 2023.
But after that date theysignificantly changed those
(03:00):
requirements.
So I was hoping you couldpotentially just give us sort of
the big picture view of the 485drill program.
Rosie (03:08):
The ADEC developed an oil spill response exercise manual
in which they adopted thedoctrine and methodology that
was laid out in the Departmentof Homeland Security's exercise
and evaluation program for theHSEEP.
The methodology of the HSEEP isboth flexible and scalable,
(03:32):
allowing it to be adjusted tofit a specific facility.
So, in consultation with ADEC,the exercise planning process
can be scaled to meet the focusand size of any exercise.
And, from our understanding,the Oil Spill Response Exercise
Manual has been adopted intoregulation to serve the wide
(03:52):
range of regulated facilitiesall across Alaska.
Shannon (03:56):
Okay.
So, if I'm understanding thisright, the regulation that
passed is what we're calling 485, and it's actually 18 AAC 75,
485.
And in that section, under 485,the oil spill response exercise
manual has been adopted byreference, and that manual is
sort of a how to guide to how todo the drills.
Is that correct?
Yes, okay.
(04:17):
And then, and then the scalablepart, which was all the
alphabet soup from HomelandSecurity that ends up being
HSEEP or HSEEP.
That is, a evaluation tool thatallows the state to evaluate
small drills or very complexdrills, depending on all of the
different factors.
Yes, exactly, okay, okay, gotit.
(04:39):
So what are the end goals oroutcomes?
Rosie (04:49):
Like when we look at the 485 drill program altogether.
Has the state given us any sortof idea of what they want to
come out of this program?
And what they're wanting is toverify compliance with statutes
and regulations relevant to anowner or operator's ability to
adequately respond to a spill.
(05:10):
They're wanting to improvecurrent levels of response and
readiness across the state.
They're wanting to encourageinnovation and improvement and
then, of course, maintainconsistency statewide with how
they're evaluating all of theplan operators.
Shannon (05:42):
The main objective of every ADEC-recognized 485
exercise is to validate theODPCP by ensuring it's adequate
in content and that the ODPCPholder, the plan holder, can
carry out it effectively.
Okay, so I mean that doesn'tdiffer too much from previous
drill requirements.
I think the biggest differenceto me sounds like the
consistency statewide and thenthe improving current levels of
response readiness.
Rosie, could you talk a littlebit about the consistency piece,
like how is the state lookingto maintain consistency?
(06:06):
I'm guessing that it goes twoways.
Right, like the state needs tobe consistent in how they
respond to businesses subject tothe ODPCP regulations.
But what about the actual ODPCPholders, like what are they
looking for for consistencythere?
Rosie (06:21):
So it is critical that staff working in bulk fuels are
kept up to date on how to safelyand effectively respond to an
oil spill, and the best way toaccomplish this is through
regular oil spill exercises.
Shannon (06:34):
That's consistent across state and federal right.
Like that's universal bestpractice.
So how does that oil spillresponse exercise manual talk
about standardized stuff?
What does it say?
Rosie (06:47):
The manual has established standardized
procedures to ensure effectivedrills and consistent
evaluations of the participantsand per 1880, aac 75.485, c-plan
holders are required to performan oil spill response exercise
in accordance with the manual atleast once during their
(07:09):
five-year renewal period oftheir C-Plan.
The exercise has to beoperations-based and it has to
directly reflect an aspect ofthe C-Plan, so a part of a
scenario or an entire scenariohas to be incorporated into the
exercise.
Shannon (07:29):
Okay.
So the exercise manual isgiving us a consistent way to
perform these exercises, andthen they also have requirements
to perform at least one spillresponse exercise during each
five-year renewal period.
We know inside the exercisemanual it discusses three
different types of exercisesthat are acceptable and these
(07:53):
drill types vary in complexityand how much time you have for a
planning period.
And then, within that planningperiod, we also have the amount
of work a plan holder must do toprepare for that final drill.
And I was hoping, Rosie, wecould dig the amount of work a
plan holder must do to preparefor that final drill.
And I was hoping, Rosie, wecould dig into each one of those
drill types independently,because this is the question I
get the most from our clients islike which drill are we going
to have to do?
(08:13):
How much work is it going to beLike, what are the expectations
?
And you could read the exercisemanual it is lengthy and not
the most gripping tail manual.
It is lengthy and not the mostgripping tail.
I thought maybe if you and Idiscussed it it might help our
listeners get a good grip on thethree basic types of drills.
Sounds great, okay let's dig in.
Rosie (08:36):
What's the shorty?
Yeah, so the shortest one ofall of them is called a drill,
and this type of exercise is theleast involved of the three
types.
It has the shortest planningperiod and time frame to
accomplish it.
It is commonly used to testequipment, validate procedures
or practice and maintain currentskills.
So some examples of this typeof drill are skimmer and boom
(09:00):
deployment and doing a specifictactic like containment boom,
exclusion boom, diversion boomand deploying your skimmer.
There's also land-based tacticsthat could happen creating a
berm to divert or contains aspell and then also just
practicing notificationprocedures as part of it.
Shannon (09:19):
It could be part of a drill so what kind of what kind
of time frame is this lookinglike for something like for this
level of drill?
Rosie (09:27):
So if you look at the manual, it's going to tell you
two to four months, which soundskind of scary.
It sounds like a lot of time,but the actual time commitment
that we're seeing our clientsput into this is roughly five to
seven days of their time, andthis will involve doing one to
three planning meetings with thestate.
Likely you would also have oneto two internal planning
(09:50):
meetings before you're meetingwith the state of Alaska.
Then you're going to have thedrill itself, which is typically
a half day to one full day.
You'll have a lessons learnedand evaluation meeting, final
report preparation and thenresponding to any of ADEC's
findings after they've issuedtheir evaluation of the drill
itself.
Sometimes you will have toamend your C-Plan afterwards as
(10:14):
well.
So if something came up duringthe drill that wasn't able to be
accomplished in the way it wasdescribed in the C-Plan, you
might need to amend your C-Planto make it more realistic.
So the drill exercise describedin the C plan you might need to
amend your C plan to make itmore realistic.
Shannon (10:25):
So the drill exercise described in the exercise manual
is the shortest drill exerciseand, just to summarize, two to
four months, but the actualmeeting load is more like five
to seven days spread out allthroughout those two to four
months.
I'm guessing they get harder,not easier, after this.
Rosie (10:41):
They do.
Shannon (10:43):
Okay.
Rosie (10:44):
Yeah, so the next level up from a drill is the
functional exercise, and thisone does have a longer time
frame to complete.
It's estimated at six to ninemonths when you look at the
exercise manual.
But as far as what time weestimate that you would be, or
the plan holder would be,committing to it, it's closer to
two to three weeks of theirtime.
(11:06):
The exercise is conducted in arealistic, real-time environment
.
However, the movement ofpersonnel and equipment is
usually stimulated in this typeof exercise.
It's similar to a tabletopdrill, but it is more involved,
and members of the incidentcommand team are drilled on
specifics in the C-Plan.
(11:26):
There also might be asimulation cell or a sim cell
which adds injects throughoutthe exercise that the players
have to respond to.
Shannon (11:36):
This is not just a portion of a spill scenario.
This is probably the wholespill scenario or significant
portions of a spill scenario.
Rosie (11:45):
Yes, okay, it would involve more of the scenario.
The timeline is longer on thisexercise because there are more
people involved and the exerciseis larger, so it requires more
planning to be successful.
The planning phase for thisexercise will typically include
anywhere from three to fiveplanning meetings.
The scenario is developed, it'srefined, injects may be
(12:08):
determined if they are going tobe included, and the final
logistics are sorted out duringthat planning phase.
The oil spill response exercisemanual includes some really
handy sections on each of thesemeetings and it lists the
objectives that need to beachieved in each of those
meetings.
That's a really good referencefor everybody to look at, and
the exercise itself would likelybe conducted over one to two
(12:31):
days, so it would take longerwhen you're comparing it to the
drill, and it, of course, wouldinvolve the evaluation by ADEC,
which may require an amendmentto the C-PLAN.
So, yeah, overall, closer totwo to three weeks of time
commitment from the plan holder.
Shannon (12:49):
So we've covered the drill, we've covered the
functional exercise.
What do they have in theexercise manual to top the
functional exercise?
Rosie (12:59):
Yeah, the biggest one, it's the full scale IMT.
So it's not just a tabletop,it's not just an equipment
deployment, it's all of it.
It's the most comprehensive andcomplex exercise of the three
and it can take up to a year tocomplete.
So the manual says anywherefrom six to 12 months.
(13:20):
That we've estimated for theplan holder.
We're thinking closer to threeto four weeks of their time, so
it's longer, it's going to takemore planning and all of that.
This type of exercise combinesresources from both the IMT and
the field and it may involveadditional stakeholders,
regulatory agencies, both stateand federal, local interested
(13:44):
parties.
Really anyone that has aninterest in the spill response
capabilities can be involved inthis type of exercise and in a
full-scale exercise, events areprojected through an exercise
scenario with injects that driveactivity at the operational
level.
This type of exercise also willbe conducted in real time a
(14:08):
stressful environment and it'sreally intended to mirror a real
incident, so personnel andresources may be mobilized and
deployed to the scene whereactions are performed as if a
real incident has occurred, andthere are typically many players
in an exercise of this scaleand is performed over several
days.
Shannon (14:29):
That is a lot more complex than the first two.
Could you break down some ofthe pre-work that has to happen
for this level of exercise?
Rosie (14:39):
This type of exercise is going to involve a lot more
planning typically five planningmeetings with the state of
Alaska and with yourstakeholders, or whatever
stakeholders may be party to theexercise, and the plan holder
is likely going to need to holdmany internal planning meetings
as well just to prepare forthose agency meetings.
(15:02):
Lots of logistics have to beworked out.
The whole scenario needs to beplanned.
A lot more planning goes into alarger scale drill like that.
Shannon (15:12):
How long in real time would this drill be?
Rosie (15:17):
It could span anywhere from two to three days.
They can take a while to getthrough an entire exercise of
this scale.
Shannon (15:25):
So at the drill level, we've got one half to one full
day for an exercise and thefunctional exercise.
That may be one day, or one totwo days, and then this full
scale IMT.
We're expanding it all the wayup into two to three days and
you've got more players, morepieces and real functionality.
(15:47):
When I hear you describe all ofthis, rosie, it sounds like
those are sort of idealtimeframes and resource
estimates.
If everything's optimal and youand I live in reality, so do
the clients need to plan foradditional training or test runs
of any of these components ontop of that time commitment
mapped out by ADEC?
Rosie (16:09):
Yeah, absolutely.
I think we've seen some of ourclients show a little bit of
nervousness just that ADEC isgoing to be on site and
evaluating them.
So there is this desire to beprepared and to do that.
You've got to practice and sowe're seeing our clients want to
do a practice run ahead of thereal drill.
(16:33):
That really should be accountedfor when you're planning for
your time commitment.
So typically, if you're goingto do some practice runs, I'd
add in another day or two to getthrough that training with your
employees.
Shannon (16:46):
Correct me if I'm wrong , but I think we're seeing
practice runs both at theterminal or facility level, like
the guys on site.
But there's also incidentmanagement training for the
command level right People at acompany that would be on the
incident management team.
So CEOs, general managers, cfos, they're having to do practices
(17:08):
as well, correct?
Rosie (17:09):
Yes, yeah.
Anyone that's going to have arole or an ICS role in that
exercise should be prepared andthat would involve practicing
what their responsibilitieswould be.
Shannon (17:21):
In the last year that we've been doing this, Rosie,
how has ADEC been applying theseregulations in real life?
What has come out of this inthe first year of the 4E5 drill
program?
Rosie (17:31):
So what we have seen in our experience so far is ADEC is
starting where the clients areat right now and what they are
currently capable of.
So what I mean by that is forthe smaller facilities, so those
without a large year-roundstaff they're typically going to
start with a drill, which isthe smallest exercise that we
(17:52):
talked about, and then for thelarger facilities, the ones that
have a big staff to pull fromthey're there all year round.
They may be expected to do thefunctional exercise or even a
full-scale IMT.
Shannon (18:06):
How is the state scheduling these exercises?
Rosie (18:10):
Just pulling from our knowledge and what we've seen is
ADEC has initiated theconversation with our plan
holders about schedulingexercises.
I say that as what we've seen,but it's not what's in
regulation.
So it really is the planholder's responsibility to
initiate the planning phase ofthe drill and to engage with the
(18:31):
state of Alaska.
Shannon (18:33):
The state is reaching out to people right now, but the
way the regulation is written,the responsibility for
scheduling these drills restswith the C-Plan holder, not the
state of Alaska.
Exactly so the state's helpingout or trying to get things
going with some outreach, butthat's not necessarily part of
their obligation or requirement.
Rosie (18:53):
So, yeah, what we have seen over the past year is that
ADEC is giving plenty of leadtime when they contact the plan
holder to make sure that theyhave time to plan and prepare.
And in past drills ADEC hasshown an understanding that
running these exercises takestime away from the businesses
and they want to work with theplan holders to make sure
(19:14):
operations at the facility arenot significantly interrupted
but still, of course, ensuring asuccessful exercise is
accomplished.
Shannon (19:23):
I'm wondering like how strict are they being about the
DEC participation?
I mean, I'm wondering like, howstrict are they being about the
DEC participation?
I mean, how does that look inreality?
Rosie (19:30):
They are being pretty strict about that.
It's clearly stated in theregulation we have seen that
they're not allowing facilitiesexercises to qualify for a 485
drill if that plan holder didn'tcoordinate with ADEC during the
planning phase.
Coordinate with ADEC during theplanning phase.
(19:51):
Per the manual, ADEC must begiven the opportunity to
participate in the planningphase of the exercise for the
plan holder to receive 485 drillcredit.
This means that if you're readyto do a 485 drill, reach out to
ADEC as soon as you can to geta tentative schedule lined out
so they can participate from thebeginning and really ensure
that you're going to get thecredit for the exercise.
Shannon (20:12):
That is a great critical point and everybody
listening if you are responsiblefor the 485 drill program at
your company, you've got toreach out and get on the
schedule as soon as you know youare ready.
All right, so let's talk aboutthe evaluation framework for
these drills.
We've been through quite a fewnow and I want to talk about.
Dec has objectives, but thereare evaluation criteria as well.
(20:36):
So what does evaluation looklike under the exercise manual,
rosie?
Rosie (20:41):
Past drills.
We've observed we have seenADEC evaluates 485 drills to
determine whether the actionstaken during the exercise are
consistent with what is in the Cplan.
They also want to see a timelyresponse during the exercise and
without coaching from ADEC.
So the oil spill responseexercise manual.
Shannon (21:03):
There's a really good appendix in there, append b so
if they're evaluating what's themetric, are they giving out
gold stars?
A pluses five out of five?
Like what?
Where?
Where does the state fall onthe performance scale?
Rosie (21:20):
I'm gonna pull from what I've seen in the past year.
They're just issuing lettersacknowledging that the 485 drill
was run and that credit isbeing given to the plan holder.
The manual itself does have arating system.
So, like I said, the manual iskind of a guidance document so
(21:42):
it can be used for evaluations,and the four ratings that are
listed in the manual areperformed without challenge,
which is a letter P.
Performed with some challenges,s, performed with major
challenges, m and then unable tobe performed.
(22:02):
So those are the four differentratings that can be given based
on the ADEC evaluation.
Shannon (22:09):
So with these rating system and response letters to
actual drills?
How is ADEC coming in onfeedback and lessons learned?
Are they coming in hot withnotices of violation or are they
taking a different approach?
Rosie (22:29):
with notices of violation , or are they taking a different
approach?
So far, I've not seen anynotices of violation coming out
of these drills, and no fineshave been assessed due to
unsuccessful exercises, as faras we know.
Depending, though, on theseverity of the inadequacies,
adec may require another 485drill, so you might not achieve
the credit that you were goingfor.
You might have to do it again,or they may propose actions to
(22:50):
the plan that the plan holdercan take to ensure a successful
exercise next time.
There is a sense that ADECwants these exercises to make
the plan holder more preparedfor spill response instead of
being used as a way to issueNOVs and fines of being used as
(23:12):
a way to issue NOVs and fines.
Shannon (23:13):
Yeah, that sounds like a relief.
I think a lot of our clientswere really worried that there
was going to be quite a bit ofNOV and fees and I am not a
lawyer, neither is Rosie but Ido think that at this early
stage of the game, with thisprogram being new, the state of
Alaska is leaning more towardsassistance, towards compliance,
rather than correction throughissuance of notice of violation.
(23:35):
That is all really goodinformation to know for our
listeners that are responsiblefor 485 DRLs.
I do get this question a lot,rosie, and maybe we can debunk
it or clarify it here.
How does the 485 program differfrom NPRP, and can we just do
NPRP and meet the 485 drillguidance?
Rosie (23:56):
Biggest difference between NPRP or even a federal
government initiated unannouncedexercise or a GUI and the 485
drill is ADEC's involvement.
Adec has to be involved prettymuch as soon as the plan holder
knows that they're going to havea drill.
They will be part of theplanning meetings, they're going
to be present at the exerciseand they will provide a final
(24:19):
evaluation after the exercise iscomplete.
The second biggest differenceis that 485 drills must be based
on an aspect of the spillscenario in your C plan.
So it doesn't necessarily haveto be the largest spill scenario
, which is the ADEC responseplanning, standard volume or the
worst case discharge scenario.
(24:39):
It can be the medium or thesmall spill scenario.
But ADEC is just really wantingto see that what is written in
your C plan is not just fictionand that it can actually be put
into action.
Shannon (24:53):
Can any of the end prep exercises get credit for 485
drill?
Is there some mechanism forthat or do they have to be
separate?
Rosie (25:01):
No, they absolutely can be done concurrently and can
receive credit.
But, like I said earlier, theyjust need to make sure they're
getting ADEC involved from thestart and that the exercise is
based on a scenario in theirC-Plan.
Shannon (25:18):
Okay, well, you mentioned GUIs.
I have a feeling a GUI is alittle trickier, though, because
it's unannounced.
So how do you get the stateinvolved if it's unannounced?
Rosie (25:27):
trickier though, because it's unannounced.
So how do you get the stateinvolved if it's unannounced?
Yeah, so with it beingunannounced, you're not going to
be able to notify ADEC prior tothe drill.
But ADEC has actually answeredthis question on their FAQ page
and we will link that in theshow notes.
But basically, for a GUI tocount, the planning team will
also need to consist of atrusted agent from the plan
(25:49):
holder in addition to ADEC andthe federal agency.
Following the guidelines in themanual, a trusted agent could
be a third-party contractor orit could even be someone from a
federal agency, such as the USCoast Guard, that brings the
ADEC into the exercise planningphase and that would ensure that
(26:12):
it would meet 485 credit.
Shannon (26:14):
Okay, Got it.
So that trusted agent.
It can be many different people, but I think the idea is that
the unannounced part still staysunannounced to the client.
Okay.
I also do get quite a fewquestions about combining drills
for regional exercises andpotentially cost savings.
(26:36):
Like, hey, if the ADC is goingto come all the way out to this
remote Western location, do youthink we could do a drill
involving multiple seaplaneholders in the same community?
How has the state been reactingto those types of requests,
Rosie?
Rosie (26:52):
With this program still being in its infancy, what we
have seen is ADEC is leaningtowards keeping the exercises
focused on individual facilitiesat this time, and the main
reasoning is that it keeps thescope of the drills a little
more manageable from ADEC'sperspective, it ensures that one
(27:12):
facility meets the requirementsin their C-Plan, and that's
simpler than including multiplefacilities with all of their own
C-Plans and all of their ownscenarios.
With that all said, there hasbeen an indication that ADEC is
open to incorporating multipleplan holders in 485 drills in
the future future.
Shannon (27:38):
I have a feeling, rosie , that as the program develops
and skills are built, the statewill probably be more open to
that kind of combination stuff.
But I think right now for someof our communities and sea plan
holders the readiness level isnot.
They need to build and practicefirst.
And then I also I did want toclarify we've been talking
throughout about facilities andC-plans and I did want to just
(28:00):
make this note that we're usingthe term facility and C-plan
sort of interchangeably.
Some C-plans do have multiplefacilities in them and the state
is focused primarily on theC-plan, the way the 485
regulation is written.
So just in case you think you'reout there thinking you could be
really clever and just have adrill for one facility, even if
(28:20):
you have two under one OD PCP,it's really the OD PCP or the
C-Plan that is driving the drill, not a north terminal versus a
south terminal, for example.
It could be any component ofany part of a sea plan.
So if you've got two differentsea plan activities at two
different terminals all underthe same sea plan, it's all fair
(28:40):
game.
Rosie, thank you, that was avery in-depth dive and I think
that kind of answered some ofour frequently asked questions,
and it was a very good and clearoverview of the types of drills
and the evaluation criteria,and so I was wondering if you
could point our listeners toresources that we have
(29:01):
identified as useful to learnmore about the 485 Drill Program
and to guide their own 485Drill responsibilities.
Rosie (29:10):
Plan holders.
C-plan itself is really a greatdocument to refer to.
I would specifically be payingattention to the spill scenario
section, and your ODPCP isbasically a contract between you
and ADEC.
So you as a plan holder haveattested that your facility has
(29:30):
the capabilities lined out inthe plan.
So now is really a great timeto look through it and see if
any revisions are needed.
Your oil spill responseorganization or your OSRO, or
also can be referred to as theprimary response action
contractor, PRAC they havesometimes will have planning
tools and or oil spill responsemanuals that are really
(29:52):
excellent tools and resources tolook at to prep for an exercise
.
Some other useful websites thatwe're going to link in the show
notes include ADEC's SpellResponse Exercise Manual.
We've mentioned it many timeshere today and they have a
website set up for the manual.
(30:12):
They also have a website set upfor the Spell Response Exercise
Program website set up for themanual.
They also have a website set upfor the spill response exercise
program.
The regulation itself, ofcourse, is good to refer to 18
AAC, 75.
And then ADEC also has a spillresponse exercise scheduler.
It's a fancy calendar thatshows when all of the upcoming
(30:33):
exercises have been scheduled,and you can also schedule your
exercise through that website.
Shannon (30:41):
So that exercise scheduler, Rosie, that's to
ensure that you're notoverlapping drills with someone
else.
So you need to actuallyschedule like, you need to check
that when you're thinking abouta drill and making sure that if
you want to do it in June of2025, then you didn't have the
same idea as six other people inthe state of Alaska.
Yeah, exactly.
Rosie (31:01):
And just being cognizant of your region too, because SPAR
is broken up into differentregions so you can check the
calendar to see make sure you'renot overlapping with a drill
that's in your same region.
Okay, yeah, just a few othersthat are good the ODPCP
regulation, implementation toolsand resources.
That's a mouthful, but there'stons of links on that website
(31:24):
that are very helpful withC-Plan writing and planning for
exercises.
And then some of the OSROs andPRACs that we are familiar with
are the Alaska Shadot Network,CPRO, CISPRI and Alaska Clean
Seas.
Shannon (31:43):
And each of their websites has access to spill
response planning tools.
All right, Rosie, thank you forthat review of the resources.
Thank you for taking us throughthe regulation and the exercise
manual.
This is complex.
This is not necessarily theeasiest thing to do.
Where could our listeners gofor additional training or help
(32:03):
with any part of this process?
Rosie (32:06):
You can always come here to Integrity Environmental, Of
course.
Yes, yeah, here at Integrity wecan provide a lot of guidance
on how to set up the exercise.
We can help with training andprovide feedback during the
practice runs of it.
Shannon (32:24):
We also can facilitate the drill.
Rosie (32:27):
Yes, absolutely.
Another good resource fortraining would be the Alaska
Shadow Network.
They are a business partner ofours and they can provide
incident management teamtraining, which can happen in a
virtual setting or they can dothat in person as well.
Shannon (32:44):
And that is a valuable resource because a lot of the
incident management teamtraining that's out there is
free and available from FEMA andwe can also link that.
But a lot of people learnbetter in person when they can
ask questions and have it bespecifically directed to the
Alaska community that the drillis going to be in, and so that
(33:05):
in-person training or virtualtraining, but from somebody who
knows Alaska, can be really, Ithink, more effective in the
long run for people retainingthe knowledge and being able to
use it during a real spill,which is super stressful,
instead of this generic FEMAtraining about.
I mean, the FEMA training isgood, I will never knock it, but
it's not the same, as this iswhat you do for your specific
(33:28):
facility in your specificcommunity.
Rosie (33:30):
One more that I was going to plug is ADEC.
They are a really good resource.
When you have questions aboutthis, you can go straight to
your plan holder to ask specificquestions about drills.
If you have questions aboutregulations, they have set up an
email that you can sendspecific questions about regs
that they will respond to in atimely manner.
Shannon (33:53):
Yeah, that's my experience with the state is,
every time I've called and asked, I've gotten an immediate
response from them and they arevery open to talking people
through this process.
All right, thank you so much,rosie.
I really appreciate you comingonto the podcast to share all of
this information with ourlisteners and I hope for
everyone out there listeningthat we made the 485 drill
(34:15):
process a little more clear andif you have any questions or if
you'd like to see us coveranything, you have suggestions
for future episodes, we'd liketo hear it.
So give us a shout out on emailand we will see you on the next
podcast.
Thanks so much, everybody.
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