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Government Initiated Unannounced Exercises (Inland)

Government Initiated Unannounced Exercises (Inland). Craig Myers Federal 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

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Government Initiated Unannounced Exercises (Inland)

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  1. Government Initiated Unannounced Exercises (Inland) Craig Myers Federal On-Scene Coordinator

  2. 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

  3. 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

  4. 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

  5. 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

  6. Region 8 Giues since 2010

  7. Why do we do GUIEs? • It’s the law. • There’s no certification process for inland OSROs. • It’s easy to fake training logs.

  8. The Good. • Proper boom angle • Safe work practices CHS Missoula Terminal Tesoro Refinery, SLC

  9. The Bad • Poor Boom Angle • Smiley faces = • Use of sorbents – improper use • at that • Safety concerns Silver Eagle Refining, SLC “Now that you caught it, what are you going to do with it?” Flying J Refining, SLC

  10. Oh Boy…

  11. Questions? Craig Myers Myers.craig@epa.gov 303.312.7067

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