Government Initiated Unannounced Exercises (Inland)

GOVERNMENT INITIATED UNANNOUNCED EXERCISES (INLAND)Craig MyersFederal On-Scene Coordinator

WHAT IS A GIUE? Functional Full Scale Exercise Evaluates the ability of the facility to

Implement their response plan Effectively mobilize trained personnel and oil

containment equipment Effectively obtain and mobilize oil recovery

equipment Based on a small discharge (2,100 gallons) to

water. note the discrepancy in small discharge volume

for NCP and FRP purposes 1,000 gallons and 2,100 gallons, respectively

WHO IS SUBJECT? Non-transportation related (i.e. non-pipeline): 42,000 gallons of total oil storage with over

water transfers, and/or: 1 Million gallons of total oil storage, and:

Lack of adequate secondary containment for one or more tanks

Potential for a discharge to injure fish, wildlife and sensitive environments

Potential for a discharge to shut down a public drinking water intake

Has had a reportable discharge of <10,000 gallons in the last 5 years

WHAT “PASSING” MEANS Sufficient containment boom available at the

facility in one hour Recovery equipment available at the facility

in two hours On water containment achieved in less than

4 hours.

Will occasionally award a “conditional” pass Full containment not achieved Staff are knowledgeable and trained Requires a scheduled exercise w/ locals to pass

HOW DO WE DECIDE WHERE TO DO A GIUE? New facilities / never had a GIUE Recent discharges Persistent and/or major problems with their

Plan

REGION 8 GIUES SINCE 2010

WHY DO WE DO GUIES? It’s the law. There’s no

certification process for inland OSROs.

It’s easy to fake training logs.

THE GOOD.

• Proper boom angle• Safe work practices

CHS Missoula Terminal

Tesoro Refinery, SLC

THE BAD• Poor Boom Angle

Smiley faces = • Use of sorbents – improper useat that• Safety concerns

“Now that you caught it, what are you going to do with it?”

Silver Eagle Refining, SLC

Flying J Refining, SLC

OH BOY…

QUESTIONS?Craig [email protected]