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Questions and Answers About Temporary Changes to the Drill Program
 

Introduction

These “Questions and Answers” are intended to help you understand these temporary changes to the drill program. In making these tough decisions, we tried to stay true to the following principles:

• Place a top priority on threats to human health and safety, particularly spill response.
• Protect our environment, economy, and cultural resources by continuing to pursue the legislatively-directed “Zero Spills” goal.
• Maintain a highly skilled and dedicated work force.
• Support the Puget Sound Partnership’s aggressive Action Agenda to restore the health of Puget Sound by 2020.
• Work to sustain a level regulatory “playing field” to help our ports remain competitive.

Due to our staff cuts, we will be dramatically reducing our presence at certain types of drills. This means:

• Worst case drills: we will not design, participate or evaluate these drills. For the time being, industry will self-certify this drill.
• Annual tabletop drills: we will not design, participate or evaluate these drills. For the time being, industry will self-certify this drill.
• Deployment drills: We will continue our full participation in the scheduling, design, staffing and evaluation of this type of drill.
• Unannounced vessel notification drills: We are reducing our emphasis on conducting unannounced vessel notification drills.

This will hold true with very few exceptions. You may see us occasionally drop by during drills, but it will be a limited opportunity.

• Question 1: How many drills should I plan for this year?
• Question 2: Do I still need to schedule my drills on the RRT Area Exercise Calendar?
• Question 3: What about other agencies participating in my worst case drills?
• Question 4: Does this mean that there will be no Ecology staffing (SOSC, Liaison, EUL) at tabletop drills?
• Question 5: Do I still need to involve Ecology in the design of tabletop and deployment drills?
• Question 6: What does it mean to self-certify my tabletop drills?
• Question 7: Should I keep using the drill evaluation checklist?
• Question 8: How many days do I have to send you the documents after my drill?
• Question 9: What if I already have a drill planned and have started drill design meetings?
• Question 10: Can companies still do joint tabletops?
• Question 11: Can companies get credit for out-of-state-drills?
• Question 12: How long will this last?
• Question 13: Will Ecology provide staff for the EU and PIO functions during an actual spill? 

“Questions and Answers”

Question 1: How many drills should I plan for this year?
The number of drills you need to conduct is not changing. Please work hard to stay on your schedule for drills. We are counting on your continued commitment to oil spill preparedness. The regulatory requirements to conduct drills that test your plan within the State of Washington have not been changed. Each plan holder should continue to plan for and conduct a table top drill and two deployment drills each year (and one worst case table top drill must be conducted every three years).

Question 2: Do I still need to schedule my drills on the RRT Area Exercise Calendar?
Yes. Ecology’s inability to participate in table top drills is temporary and maintaining the drill calendar will help us transition quickly back into active planning and participation in these drills when this situation changes. The drill calendar is found at
http://www.ecy.wa.gov/programs/spills/preparedness/Drills/drill_calendar0809.html

Question 3: What about other agencies participating in my worst case drills?
Drills offer opportunities to build stronger relationships, and improve trust among industry, contractors, federal, state, tribal and local agencies, and local communities. Ecology’s reduced level of participation in worst case drills does not reflect the position of our partner agencies. We are asking our federal partners to step up their level of participation at this time. Please continue aggressively seeking participation from other agencies, local government and tribal representatives at your drills.

Question 4: Does this mean that there will be no Ecology staffing (SOSC, Liaison, EUL) at tabletop drills?
Yes, unfortunately so, and with very few exceptions.

Question 5: Do I still need to involve Ecology in the design of tabletop and deployment drills?
For now, table top drills will not be planned or designed with Ecology. Due to our budget constrains we have chosen to focus on deployment drills and other activities that can improve the initial response such as geographic response plan development. However, we will continue to work with you to develop, design, staff and evaluate deployment drills that will help test and improve your contingency plan.

Question 6: What does it mean to self-certify my tabletop drills?
According to the National Preparedness for Response Exercise Program Guidelines, certification is the act of confirming that an exercise (1) was completed; (2) was conducted in accordance with the PREP guidelines, meeting all objectives listed; and (3) was evaluated using a mechanism that appraised the effectiveness of the response or contingency plan. Until we notify you otherwise, you should send your Ecology point of contact a copy of the documentation developed at the drill with an explanation of the credit you expect to receive. These documents will then be used to determine what credit will be given to each plan holder. The credit will then be transferred to the drill tracking matrix and sent back to you.

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Question 7: Should I keep using the drill evaluation checklist?
Please do so. The checklist follows the 15 federal NPREP core components required to be tested. The drill evaluation checklist was developed as a tool to help with drill design and evaluation. The checklist is not a mandatory document though we encourage you to continue to use if it is helpful to you.  http://www.ecy.wa.gov/programs/spills/preparedness/Drills/DRILL_CHECKLIST_Final.pdf

Question 8: How many days do I have to send you the documents after my drill?
Plan holders should submit documentation, and a summary of the credit they expect to receive, to their plan manager within 30 days of the drill.

Question 9: What if I already have a drill planned and have started drill design meetings?
Each plan holder will be contacted individually to discuss the status of any drills currently in the planning phase. We will figure out together how to make this a smooth transition.

Question 10: Can companies still do joint tabletops?
Companies can continue to conduct joint table top drills. However, it is important that each company carefully delineate what credit they are expecting to receive based on the roles, tasks, and activities conducted by each team. Each company will need to submit documentation to their plan manager and schedule the drill on the calendar with the appropriate lead time.

Questions 11: Can companies get credit for out-of-state-drills?
This request typically comes from vessel companies that operate in many states, rather than a fixed facility located in Washington. This news about our cuts and adjustments does not impact the ability for a vessel company under limited circumstances to seek out of state drill credit. Some vessel plan holders can receive credit for drills out of state – as long as the company has a contingency plan on file with Ecology that is the same as the plan to be tested out of state. Requests for out-of-state credit for drills must be submitted to Ecology at least 90 days in advance and scheduled on the RRT Area Exercise Calendar.

While some general plan components can be exercised for credit, there are certain plan components that are local in their nature or applications and simply not appropriate for out-of-state drill credit. Plan holders should be aware of the policies in the Northwest Area Contingency Plan, which is specific to Washington, Oregon, and Idaho, EPA Region 10, and the U.S. Coast Guard, Sector Seattle and Sector Portland. It will be difficult to receive credit from Ecology for an out-of-state drill that evaluates geographic response plans or other Northwest Area Contingency Plan policies.

If Ecology approves the plan holder request for out of state drill credit you must provide self-certification documentation to Ecology within 30 days of the drill.

Question 12: How long will this last?
Our ability to participate and help plan table top drills will be re-evaluated on a regular basis. We will let you know if our decision on these priorities changes.

Question 13: Will Ecology provide staff for the EU and PIO functions during an actual spill? 
Ecology will continue to provide trained staff for agency designated positions such as State On Scene Coordinator, Environmental Unit, Liaison Officer and Public Information Officer in the event of an actual spill. 

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