P 112024Z JAN 11 SUBJ: REGIONAL AND AREA CONTINGENCY PLAN PREPAREDNESS FOR A WORST CASE DISCHARGE A. THE FEDERAL WATER POLLUTION PREVENTION AND CONTROL ACT, 33 USC 1321, AS AMENDED BY THE OIL POLLUTION ACT OF 1990 (PUBLIC LAW 101-380) B. THE NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY PLAN (40 CFR PART 300) C. COMDTINST 16471.3, AREA CONTINGENCY PLAN ORGANIZATION, CONTENT, REVISION CYCLE AND DISTRIBUTION D. OIL-SPILL RESPONSE REQUIREMENTS FOR FACILITIES LOCATED SEAWARD OF THE COAST LINE (30 CFR PART 254) E. MEMORANDUM OF AGREEMENT BETWEEN THE MINERALS MANAGEMENT SERVICE (NOW THE BUREAU OF OCEAN ENERGY MANAGEMENT, REGULATION AND ENFORCEMENT) - U.S. DEPARTMENT OF THE INTERIOR AND THE U.S. COAST GUARD - U.S. DEPARTMENT OF HOMELAND SECURITY, MMS/USCG MOA: OCS-03, 23 MAY 2007 F. NOTICE TO LESSEES AND OPERATORS 2009 P-03: OIL SPILL RESPONSE PLANS, 28 OCTOBER 2009 G. NOTICE TO LESSEES AND OPERATORS 2006 G-21: REGIONAL AND SUBREGIONAL OIL SPILL RESPONSE PLANS, 26 OCTOBER 2006 H. NOTICE TO LESSEES AND OPERATORS 2010 N-10: STATEMENT OF COMPLIANCE WITH APPLICABLE REGULATIONS AND EVALUATION OF INFORMATION DEMONSTRATING ADEQUATE SPILL RESPONSE AND WELL CONTAINMENT RESOURCES, 08 NOVEMBER 2010 1. SITUATION. A. THE RESPONSE TO THE BP OIL SPILL IN THE GULF OF MEXICO EMPHASIZED THE IMPORTANCE OF REGIONAL CONTINGENCY PLANS ( RCP) AND AREA CONTINGENCY PLANS ( ACP). IT ALSO IDENTIFIED THE NEED TO REVISIT OUR PREPAREDNESS EFFORTS TO RESPOND TO A WORST CASE DISCHARGE (WCD) FROM AN OFFSHORE OIL EXPLORATION OR PRODUCTION FACILITY. PER REFS A, B, AND C, REGIONAL AND AREA CONTINGENCY PLANNING MUST CONSIDER ALL ACTIONS NECESSARY TO MITIGATE A WCD FROM ALL POTENTIAL SOURCES OF OIL DISCHARGES, INCLUDING OFFSHORE FACILTIES. REF E PROVIDES FOR CG REVIEW OF OFFSHORE FACILITY OIL SPILL RESPONSE PLANS (OSRP). IN SOME INSTANCES, THE CG HAS NOT REVIEWED THE PLANS. B. IAW REF D, EACH OWNER OR OPERATOR OF AN OIL EXPLORATION AND PRODUCTION FACILITY SEAWARD OF THE COAST LINE MUST SUBMIT AN OSRP TO THE BUREAU OF OCEAN ENERGY MANAGMENT, REGULATION AND ENFORCEMENT (BOEMRE) FOR APPROVAL. OSRPS MAY INCLUDE MULTIPLE WCD SCENARIOS, AS APPROPRIATE, INCLUDING PROCEDURES FOR RESPONDING TO, AND SUPPORTING OPERATIONS FOR, AN UNCONTROLLED WELL BLOWOUT LASTING 30 DAYS. BOEMRE HAS ALSO ISSUED ADDITIONAL REGIONAL SPECIFIC REQUIREMENTS FOR OSRPS AS OUTLINED IN REFS F, G, AND H. ALL OSRPS ARE SUJECT TO BIENNIAL UPDATES, REVISIONS, AND AMENDMENTS. C. THE GULF OUTER CONTINENTAL SHELF (OCS) REGION HAS 170 ACTIVE OSRPS ON FILE THAT COVER FACILITIES IN STATE OFFSHORE WATERS, FEDERAL OFFSHORE WATERS OR BOTH. DUE TO INFORMATION SECURITY RESTRICTIONS, THESE OSRPS ARE ONLY AVAILABLE AT THE BOEMRE REGIONAL OFFICE LISTED IN PARA 4.B. D. THE PACIFIC OCS REGION HAS 10 OSRPS ON FILE. ELECTRONIC COPIES (ON CD) OF THE 6 OCS PLANS ARE AVAILABLE AT SECTOR LA/LB AND MARINE SAFETY DETACHMENT SANTA BARBARA. COPIES OF THE 4 OSRPS FOR FACILITIES IN CALIFORNIA STATE WATERS ARE AVAILABLE EITHER AT THE BOEMRE REGIONAL OFFICE IN CAMARILLO OR THE CALIFORNIA DEPARTMENT OF FISH AND GAME, OFFICE OF SPILL PREVENTION AND RESPONSE IN LOS ALAMITOS. E. THE ALASKA OCS REGION HAS 2 (INACTIVE) OSRPS FOR FACILITIES IN FEDERAL OFFSHORE WATERS. THERE ARE 11 OSRPS FOR FACILITIES IN THE COOK INLET AND BEAUFORT SEA, WHICH ARE IN STATE WATERS. PLANS ARE REVIEWED BY BOEMRE AND THE STATE OF ALASKA. THESE OSRPS ARE AVAILABLE AT THE BOEMRE REGIONAL OFFICE LISTED IN PARA 4.B. 2. ACTION. A. IAW REF B, ENSURE THAT AREA AND REGIONAL CONTINGENCY PLANS ADDRESS WCD SCENARIOS FROM EXISTING OFFSHORE OIL EXPLORATION AND PRODUCTION FACILITIES. B. PROVIDE AN INTERIM REPORT ON WCD CONTINGENCY PLAN GAPS NLT 15APR2011. C. COMPLETE WCD CONTINGENCY PLANS ANALYSIS NLT 30JUN2011. INCLUDE SIGNIFICANT PLANNING AND RESOURCE GAPS AND RECOMMENDED CORRECTIVE ACTIONS AND COMPLETION DATES TO CG-53. D. AFTER COMPLETING AND REPORTING ON THE GAP ANALYSIS, AREA AND REGIONAL CONTINGENCY PLANS SHALL BE REVISED AS APPROPRIATE NLT 30DEC2011 TO DOCUMENT WHOLE OF COMMUNITY PREPAREDNESS TO RESPOND, AND IDENTIFY AND RESPONSE PLANNING GAPS AND SHORTFALLS (I.E. SUBSEA CONTAINMENT STRATEGIES, PROTECTION OF SENSITIVE AREAS, WASTE DISPOSAL PLANNING, DISPERSANT OPTIONS, RESPONSE EQUIPMENT AND PERSONNEL CAPACITY, ETC). DEVELOP GUIDANCE TO THE APPROPRIATE AREA COMMITTEES TO BE CHAIRED BY BOEMRE TO LEAD DELIBERATE PLANNING EFFORTS TO IMPROVE PREPAREDNESS ESTABLISH DEEPWATER RESPONSE SUBCOMMITTEES TO IMPROVE PREPAREDNESS. 3. RECOMMENDED PRACTICES AND PLANNING TOOLS: A. AREAS ESTABLISH A TIGER TEAM TO ENSURE STANDARDIZATION AND IMPLEMENTATION OF PLAN ANALYSIS PROCEDURES. B. BEGIN THE REVIEW PROCESS BY FIRST REVIEWING OSRPS CONTAINING THE LARGEST WCD VOLUMES. A SINGLE OSRP MAY BE APPLICABLE TO SEVERAL COTP/FOSC ZONES. IN THAT CASE, IT SHOULD BE REVIEWED BY EACH APPROPRIATE COTP/FOSC. IF A WCD CAN AFFECT MULITPLE COTP/FOSC ZONES, THEN PLAN COORDINATION SHOULD BE MANAGED BY THE APPROPRIATE DISTRICT. IF A WCD CAN AFFECT MULTIPLE DISTRICT AORS, THEN PLAN COORDINATION SHOULD BE MANAGED BY THE APPROPRIATE AREA. C. THE FOLLOWING MISLE ENTRY SHOULD BE EMPLOYED TO DOCUMENT OSRP ANALYSIS: (1) SELECT ACTIVITY TYPE: PLATFORM INSPECTION. (2) SELECT UNIQUE ID: EITHER FIN OR VIN. (3) ADD INSPECTION TYPE: FRP/VRP REVIEW. (4) ACTIVITY TITLE: OSRP REVIEW - INSERT NAME OF VESSEL OR FACILITY (THE USE OF 'OSRP WCD REVIEW' AT THE BEGINNING OF THE ACTIVITY TITLE IS CRITICAL AS IT WILL ALLOW MISLE SEARCH RESULTS TO BE FILTERED). (5) NARRATIVE: INCLUDE DATE REVIEWED, NAMES/AGENCY OF THOSE WHO PARTICIPATED IN THE REVIEW, FINDINGS OR GAPS, RECOMMENDATIONS AND FOLLOW UP ACTION REQUIRED, IF NECESSARY REGARDING ACPS AND/OR OSRPS. D. REVIEW THE RESULTS OF THE LATEST PREPAREDNESS ASSESSMENT VISITS (PAV) CONDUCTED BY THE NATIONAL STRIKE FORCE COORDINATION CENTER. THE REPORTS ARE AVAILABLE AT HTTP://CGWEB.ARSC.USCG.MIL/NSF/NSFCC/AAREPORTS.CFM. ENSURE PLAN UPDATES REFLECT PAV INFORMATION. E. THE RESPONSE RESOURCE INVENTORY ( RRI) IN MISLE CAN BE USED TO REVIEW THE CURRENT LISTING OF CLASSIFIED OSRO EQUIPMENT WITHIN EACH COTP ZONE. F. ANNUAL RESPONSE EQUIPMENT INSPECTION REPORTS FROM BOEMRE ARE AVAILABLE AT THE REGIONAL OFFICES LISTED IN PARA 4.B. 4. POINTS OF CONTACT: A. COAST GUARD HEADQUARTERS AND NATIONAL STRIKE FORCE COORDINATION CENTER ( NSFCC) INFORMATION: (1) MR. JOE BONN, CG-5332, JOSEPH.D.BONN(AT)USCG.MIL, 202-372-2250. (2) LCDR KEVIN LYNN, CG-5442, KEVIN.P.LYNN(AT)USCG.MIL, 202-372-1130. (3) LCDR TEDD HUTLEY, NSFCC, TEDD.B.HUTLEY(AT)USCG.MIL, 252-331-6000, EXT. 3005. B. BOEMRE OIL SPILL PROGRAM INFORMATION: (1) NATIONAL COORDINATOR, MR. DAVID M. MOORE, BOEMRE DAVID.MOORE(AT)BOEMRE.GOV, 703-787-1637. (2) GULF OF MEXICO OCS REGION, NEW ORLEANS, LOUISIANA, MR. RUSTY WRIGHT, 504-736-2529. (3) PACIFIC OCS REGION, CAMARILLO, CALIFORNIA, MR. CRAIG OGAWA, 805-389-7569. (4) ALASKA OCS REGION, ANCHORAGE, ALASKA, MS. CHRISTY BOHL, 907-334-5309. 5. RADM K. S. COOK, DIRECTOR OF PREVENTION POLICY AND RDML C. B. THOMAS, DIRECTOR OF RESPONSE POLICY, SENDS. 6. INTERNET RELEASE AUTHORIZED.