Lessons Learned and Corrective Actions from BSEE Initiated Unannounced Source Control Exercises In 2018–2019

Abstract

Government initiated unannounced exercises (GIUEs) conducted by the Bureau of Safety and Environmental Enforcement (BSEE) provide operators a challenging but fair opportunity to demonstrate their response capabilities. When a source control GIUE is initiated, personnel from both industry and government are expected to perform their response roles in real time as they would in an actual incident. Source control GIUEs are also used to objectively assess spill preparedness and identify any deficiencies and vulnerabilities. The intent of this report is to share appropriately redacted lessons learned and corrective actions that transpired from BSEE source control GIUEs for the benefit of regulators, operators, and other responders seeking to improve upon their existing capabilities. During the 2018 and 2019 fiscal years, the BSEE Oil Spill Preparedness Division (OSPD) conducted 29 GIUEs. Of those 29 GIUEs, 17 were functional exercises and 12 were full-scale exercises involving the deployment of response equipment. The Source Control GIUEs, which comprised 7 of the 29 exercises, intended to assess a broader scope of readiness as compared to the more familiar capping stack soft shut-in scenarios from past years. OSPD coordinated with numerous stakeholders to ensure the appropriate experts were involved in the GIUE planning process. These interdisciplinary planning teams collaborated to develop previously unexplored but relevant scenarios involving surface blowouts, relief wells, and subsea well interventions. BSEE's intention is to maintain this coordinated effort to produce new and challenging scenarios for the purpose of ensuring maximal preparedness for all potential and plausible response conditions. Increasing the source control GIUE program's scope and scale in this directed manner resulted in significant lessons learned and corrective actions relevant to both the regulated community and the regulators. OSPD has compiled and summarized these results for distribution. Lessons learned were classified utilizing the following 6 categories adapted from the Homeland Security Exercise and Evaluation Program (HSEEP) Guidance: Communications, Leadership and Management Processes, Organizational Structures, Plans or Procedures, Resources, and Training. With regards to corrective actions, OSPD issued these directives with the intent of providing operators an opportunity to resolve deficiencies identified during the source control GIUEs to ensure adequate preparedness and are not to be considered punitive. This paper will present a redacted summary of these lessons learned and corrective actions identified during the 2018 and 2019 GIUE years for the benefit of everyone involved in spill response preparedness.