Discover what it takes to be at the forefront of environmental protection in Alaska's oil industry with the insights of Rosie Nethercott, biology expert and manager of the Plans and Permits Division at Integrity Environmental. Rosie decodes the nuances of the 485 Drill Program, an innovative approach to oil spill response that hinges on the practical and methodical Oil Spill Response Exercise Manual and Homeland Security's HSEEP methodology. We unravel how these strategies are reshaping compliance verification, elevating readiness, and nurturing a culture of innovation across Alaska's landscapes.
Our conversation with Rosie Nethercott doesn't just stop at unveiling the program's intricacies; we delve into the real-life applications of these drills. The focus is on the importance of thorough preparedness, where Rosie underscores the necessity for involvement across the board, from those on the ground to the C-suite executives. We also tackle the collaborative dance between companies and the Alaska Department of Environmental Conservation (ADEC) to pull off these drills successfully. The takeaway? It's not just about meeting requirements but about engraining those meticulous response strategies deep within the corporate culture, ensuring that companies can respond effectively to protect Alaska's pristine environment when called upon.
Whether you're looking for tailored training through Integrity Environmental and the Alaska Chadux Network or simply seeking guidance from ADEC, this episode of Tank Talk is your compass to navigating the complexities of exercise compliance and upholding the environmental integrity of The Last Frontier.
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. If you need professional regulatory advice, we would be happy to provide it as part of our consulting services.
Discover what it takes to be at the forefront of environmental protection in Alaska's oil industry with the insights of Rosie Nethercott, biology expert and manager of the Plans and Permits Division at Integrity Environmental. Rosie decodes the nuances of the 485 Drill Program, an innovative approach to oil spill response that hinges on the practical and methodical Oil Spill Response Exercise Manual and Homeland Security's HSEEP methodology. We unravel how these strategies are reshaping compliance verification, elevating readiness, and nurturing a culture of innovation across Alaska's landscapes.
Our conversation with Rosie Nethercott doesn't just stop at unveiling the program's intricacies; we delve into the real-life applications of these drills. The focus is on the importance of thorough preparedness, where Rosie underscores the necessity for involvement across the board, from those on the ground to the C-suite executives. We also tackle the collaborative dance between companies and the Alaska Department of Environmental Conservation (ADEC) to pull off these drills successfully. The takeaway? It's not just about meeting requirements but about engraining those meticulous response strategies deep within the corporate culture, ensuring that companies can respond effectively to protect Alaska's pristine environment when called upon.
Whether you're looking for tailored training through Integrity Environmental and the Alaska Chadux Network or simply seeking guidance from ADEC, this episode of Tank Talk is your compass to navigating the complexities of exercise compliance and upholding the environmental integrity of The Last Frontier.
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. If you need professional regulatory advice, we would be happy to provide it as part of our consulting services.
Good morning, welcome to Tank Talk. I have somebody from our staff today, somebody new to the podcast. I'd like to introduce Rosie Nethercott, our Senior Environmental Consultant and Manager of our Planning and Permitting Department. This spring, for a lot of our clients there's been a focus on a new program from the state of Alaska Department of Environmental Conservation Program from the State of Alaska Department of Environmental Conservation. Its nickname is the 485 Drill Program, but it is actually a combination of a regulation and exercise manual and I have invited Rosie on to the podcast to talk about it because we've been digging in deep and I think that there's a lot of value for our listeners who may also need to implement the 485 Drill Program in the coming years. So, rosie, welcome to the podcast and I was hoping you could maybe introduce yourself a little bit to our listeners, since you're new here, before we dig into the 485 Drill Program.
Rosie:
Yeah, thank you so much for having me on today. I have worked for Integrity now for eight years. My degree is in biology and I previously worked for the state of Alaska for the Division of Boiling Gas, where I helped with lease sales and writing best interest findings documents. Those are the documents that detail both environmental and economic impacts of boiling gas exploration in regions all across Alaska. During my time here at Integrity, I've grown from an environmental consultant into a senior consultant and now I'm managing the Plans and Permits Division.
Rosie:
I manage a team of consultants that write and review environmental plans and permits. So we do SPCCs, FRPs, SWPPPs, and our specialty is Oil Discharge Prevention Contingency Plans or ODPCPs. We also offer consulting services for the gamut of environmental compliance issues that bulk fuel facilities, fish processors and utilities face across Alaska. I'm excited to talk to you today about ADEC's new exercise program that was adopted into regulation in February of 2023. The new regulations were partially implemented back then because there were quite a few changes, and they were fully implemented in August of 2023. We have worked with many clients over the past year to help them achieve credit for their 485 drill that Shannon mentioned earlier, and I'm looking forward just to sharing our experiences working with those clients and helping our listeners understand more about the new regs.
Shannon:
Rosie, thank you for that introduction. That gives us a real good idea of where you're coming from. I wanted to talk a little bit more about the 485 drill program and the accompanying exercise manual. I mean, the state of Alaska had drill requirements before February 5th of 2023. But after that date they significantly changed those requirements. So I was hoping you could potentially just give us sort of the big picture view of the 485 drill program.
Rosie:
The ADEC developed an oil spill response exercise manual in which they adopted the doctrine and methodology that was laid out in the Department of Homeland Security's exercise and evaluation program for the HSEEP. The methodology of the HSEEP is both flexible and scalable, allowing it to be adjusted to fit a specific facility. So, in consultation with ADEC, the exercise planning process can be scaled to meet the focus and size of any exercise. And, from our understanding, the Oil Spill Response Exercise Manual has been adopted into regulation to serve the wide range of regulated facilities all across Alaska.
Shannon:
Okay. So, if I'm understanding this right, the regulation that passed is what we're calling 485, and it's actually 18 AAC 75, 485. And in that section, under 485, the oil spill response exercise manual has been adopted by reference, and that manual is sort of a how to guide to how to do the drills. Is that correct? Yes, okay. And then, and then the scalable part, which was all the alphabet soup from Homeland Security that ends up being HSEEP or HSEEP. That is, a evaluation tool that allows the state to evaluate small drills or very complex drills, depending on all of the different factors. Yes, exactly, okay, okay, got it. So what are the end goals or outcomes?
Rosie:
Like when we look at the 485 drill program altogether. Has the state given us any sort of idea of what they want to come out of this program? And what they're wanting is to verify compliance with statutes and regulations relevant to an owner or operator's ability to adequately respond to a spill. They're wanting to improve current levels of response and readiness across the state. They're wanting to encourage innovation and improvement and then, of course, maintain consistency statewide with how they're evaluating all of the plan operators.
Shannon:
The main objective of every ADEC-recognized 485 exercise is to validate the ODPCP by ensuring it's adequate in content and that the ODPCP holder, the plan holder, can carry out it effectively. Okay, so I mean that doesn't differ too much from previous drill requirements. I think the biggest difference to me sounds like the consistency statewide and then the improving current levels of response readiness. Rosie, could you talk a little bit about the consistency piece, like how is the state looking to maintain consistency? I'm guessing that it goes two ways. Right, like the state needs to be consistent in how they respond to businesses subject to the ODPCP regulations. But what about the actual ODPCP holders, like what are they looking for for consistency there?
Rosie:
So it is critical that staff working in bulk fuels are kept up to date on how to safely and effectively respond to an oil spill, and the best way to accomplish this is through regular oil spill exercises.
Shannon:
That's consistent across state and federal right. Like that's universal best practice. So how does that oil spill response exercise manual talk about standardized stuff? What does it say?
Rosie:
The manual has established standardized procedures to ensure effective drills and consistent evaluations of the participants and per 1880, aac 75.485, c-plan holders are required to perform an oil spill response exercise in accordance with the manual at least once during their five-year renewal period of their C-Plan. The exercise has to be operations-based and it has to directly reflect an aspect of the C-Plan, so a part of a scenario or an entire scenario has to be incorporated into the exercise.
Shannon:
Okay. So the exercise manual is giving us a consistent way to perform these exercises, and then they also have requirements to perform at least one spill response exercise during each five-year renewal period. We know inside the exercise manual it discusses three different types of exercises that are acceptable and these drill types vary in complexity and how much time you have for a planning period. And then, within that planning period, we also have the amount of work a plan holder must do to prepare for that final drill. And I was hoping, Rosie, we could dig the amount of work a plan holder must do to prepare for that final drill.
Shannon:
And I was hoping, Rosie, we could dig into each one of those drill types independently, because this is the question I get the most from our clients is like which drill are we going to have to do? How much work is it going to be Like, what are the expectations? And you could read the exercise manual it is lengthy and not the most gripping tail manual. It is lengthy and not the most gripping tail. I thought maybe if you and I discussed it it might help our listeners get a good grip on the three basic types of drills. Sounds great, okay let's dig in.
Rosie:
What's the shorty? Yeah, so the shortest one of all of them is called a drill, and this type of exercise is the least involved of the three types. It has the shortest planning period and time frame to accomplish it. It is commonly used to test equipment, validate procedures or practice and maintain current skills. So some examples of this type of drill are skimmer and boom deployment and doing a specific tactic like containment boom, exclusion boom, diversion boom and deploying your skimmer. There's also land-based tactics that could happen creating a berm to divert or contains a spell and then also just practicing notification procedures as part of it.
Shannon:
It could be part of a drill so what kind of what kind of time frame is this looking like for something like for this level of drill?
Rosie:
So if you look at the manual, it's going to tell you two to four months, which sounds kind of scary. It sounds like a lot of time, but the actual time commitment that we're seeing our clients put into this is roughly five to seven days of their time, and this will involve doing one to three planning meetings with the state. Likely you would also have one to two internal planning meetings before you're meeting with the state of Alaska. Then you're going to have the drill itself, which is typically a half day to one full day. You'll have a lessons learned and evaluation meeting, final report preparation and then responding to any of ADEC's findings after they've issued their evaluation of the drill itself. Sometimes you will have to amend your C-Plan afterwards as well. So if something came up during the drill that wasn't able to be accomplished in the way it was described in the C-Plan, you might need to amend your C-Plan to make it more realistic. So the drill exercise described in the C plan you might need to amend your C plan to make it more realistic.
Shannon:
So the drill exercise described in the exercise manual is the shortest drill exercise and, just to summarize, two to four months, but the actual meeting load is more like five to seven days spread out all throughout those two to four months. I'm guessing they get harder, not easier, after this.
Rosie:
They do.
Shannon:
Okay.
Rosie:
Yeah, so the next level up from a drill is the functional exercise, and this one does have a longer time frame to complete. It's estimated at six to nine months when you look at the exercise manual. But as far as what time we estimate that you would be, or the plan holder would be, committing to it, it's closer to two to three weeks of their time.
Rosie:
The exercise is conducted in a realistic, real-time environment. However, the movement of personnel and equipment is usually stimulated in this type of exercise. It's similar to a tabletop drill, but it is more involved, and members of the incident command team are drilled on specifics in the C-Plan. There also might be a simulation cell or a sim cell which adds injects throughout the exercise that the players have to respond to.
Shannon:
This is not just a portion of a spill scenario. This is probably the whole spill scenario or significant portions of a spill scenario.
Rosie:
Yes, okay, it would involve more of the scenario. The timeline is longer on this exercise because there are more people involved and the exercise is larger, so it requires more planning to be successful. The planning phase for this exercise will typically include anywhere from three to five planning meetings. The scenario is developed, it's refined, injects may be determined if they are going to be included, and the final logistics are sorted out during that planning phase. The oil spill response exercise manual includes some really handy sections on each of these meetings and it lists the objectives that need to be achieved in each of those meetings. That's a really good reference for everybody to look at, and the exercise itself would likely be conducted over one to two days, so it would take longer when you're comparing it to the drill, and it, of course, would involve the evaluation by ADEC, which may require an amendment to the C-PLAN. So, yeah, overall, closer to two to three weeks of time commitment from the plan holder.
Shannon:
So we've covered the drill, we've covered the functional exercise. What do they have in the exercise manual to top the functional exercise?
Rosie:
Yeah, the biggest one, it's the full scale IMT. So it's not just a tabletop, it's not just an equipment deployment, it's all of it. It's the most comprehensive and complex exercise of the three and it can take up to a year to complete. So the manual says anywhere from six to 12 months. That we've estimated for the plan holder. We're thinking closer to three to four weeks of their time, so it's longer, it's going to take more planning and all of that. This type of exercise combines resources from both the IMT and the field and it may involve additional stakeholders, regulatory agencies, both state and federal, local interested parties.
Rosie:
Really anyone that has an interest in the spill response capabilities can be involved in this type of exercise and in a full-scale exercise, events are projected through an exercise scenario with injects that drive activity at the operational level. This type of exercise also will be conducted in real time a stressful environment and it's really intended to mirror a real incident, so personnel and resources may be mobilized and deployed to the scene where actions are performed as if a real incident has occurred, and there are typically many players in an exercise of this scale and is performed over several days.
Shannon:
That is a lot more complex than the first two. Could you break down some of the pre-work that has to happen for this level of exercise?
Rosie:
This type of exercise is going to involve a lot more planning typically five planning meetings with the state of Alaska and with your stakeholders, or whatever stakeholders may be party to the exercise, and the plan holder is likely going to need to hold many internal planning meetings as well just to prepare for those agency meetings. Lots of logistics have to be worked out. The whole scenario needs to be planned. A lot more planning goes into a larger scale drill like that.
Shannon:
How long in real time would this drill be?
Rosie:
It could span anywhere from two to three days. They can take a while to get through an entire exercise of this scale.
Shannon:
So at the drill level, we've got one half to one full day for an exercise and the functional exercise. That may be one day, or one to two days, and then this full scale IMT. We're expanding it all the way up into two to three days and you've got more players, more pieces and real functionality. When I hear you describe all of this, rosie, it sounds like those are sort of ideal timeframes and resource estimates. If everything's optimal and you and I live in reality, so do the clients need to plan for additional training or test runs of any of these components on top of that time commitment mapped out by ADEC?
Rosie:
Yeah, absolutely. I think we've seen some of our clients show a little bit of nervousness just that ADEC is going to be on site and evaluating them. So there is this desire to be prepared and to do that. You've got to practice and so we're seeing our clients want to do a practice run ahead of the real drill. That really should be accounted for when you're planning for your time commitment. So typically, if you're going to do some practice runs, I'd add in another day or two to get through that training with your employees.
Shannon:
Correct me if I'm wrong, but I think we're seeing practice runs both at the terminal or facility level, like the guys on site. But there's also incident management training for the command level right People at a company that would be on the incident management team. So CEOs, general managers, cfos, they're having to do practices as well, correct?
Rosie:
Yes, yeah. Anyone that's going to have a role or an ICS role in that exercise should be prepared and that would involve practicing what their responsibilities would be.
Shannon:
In the last year that we've been doing this, Rosie, how has ADEC been applying these regulations in real life? What has come out of this in the first year of the 4E5 drill program?
Rosie:
So what we have seen in our experience so far is ADEC is starting where the clients are at right now and what they are currently capable of. So what I mean by that is for the smaller facilities, so those without a large year-round staff they're typically going to start with a drill, which is the smallest exercise that we talked about, and then for the larger facilities, the ones that have a big staff to pull from they're there all year round. They may be expected to do the functional exercise or even a full-scale IMT.
Shannon:
How is the state scheduling these exercises?
Rosie:
Just pulling from our knowledge and what we've seen is ADEC has initiated the conversation with our plan holders about scheduling exercises. I say that as what we've seen, but it's not what's in regulation. So it really is the plan holder's responsibility to initiate the planning phase of the drill and to engage with the state of Alaska.
Shannon:
The state is reaching out to people right now, but the way the regulation is written, the responsibility for scheduling these drills rests with the C-Plan holder, not the state of Alaska. Exactly so the state's helping out or trying to get things going with some outreach, but that's not necessarily part of their obligation or requirement.
Rosie:
So, yeah, what we have seen over the past year is that ADEC is giving plenty of lead time when they contact the plan holder to make sure that they have time to plan and prepare. And in past drills ADEC has shown an understanding that running these exercises takes time away from the businesses and they want to work with the plan holders to make sure operations at the facility are not significantly interrupted but still, of course, ensuring a successful exercise is accomplished.
Shannon:
I'm wondering like how strict are they being about the DEC participation? I mean, I'm wondering like, how strict are they being about the DEC participation? I mean, how does that look in reality?
Rosie:
They are being pretty strict about that. It's clearly stated in the regulation we have seen that they're not allowing facilities exercises to qualify for a 485 drill if that plan holder didn't coordinate with ADEC during the planning phase. Coordinate with ADEC during the planning phase. Per the manual, ADEC must be given the opportunity to participate in the planning phase of the exercise for the plan holder to receive 485 drill credit. This means that if you're ready to do a 485 drill, reach out to ADEC as soon as you can to get a tentative schedule lined out so they can participate from the beginning and really ensure that you're going to get the credit for the exercise.
Shannon:
That is a great critical point and everybody listening if you are responsible for the 485 drill program at your company, you've got to reach out and get on the schedule as soon as you know you are ready. All right, so let's talk about the evaluation framework for these drills. We've been through quite a few now and I want to talk about. Dec has objectives, but there are evaluation criteria as well. So what does evaluation look like under the exercise manual, rosie?
Rosie:
Past drills. We've observed we have seen ADEC evaluates 485 drills to determine whether the actions taken during the exercise are consistent with what is in the C plan. They also want to see a timely response during the exercise and without coaching from ADEC. So the oil spill response exercise manual.
Shannon:
There's a really good appendix in there, append b so if they're evaluating what's the metric, are they giving out gold stars? A pluses five out of five? Like what? Where? Where does the state fall on the performance scale?
Rosie:
I'm gonna pull from what I've seen in the past year. They're just issuing letters acknowledging that the 485 drill was run and that credit is being given to the plan holder. The manual itself does have a rating system. So, like I said, the manual is kind of a guidance document so it can be used for evaluations, and the four ratings that are listed in the manual are performed without challenge, which is a letter P. Performed with some challenges, s, performed with major challenges, m and then unable to be performed. So those are the four different ratings that can be given based on the ADEC evaluation.
Shannon:
So with these rating system and response letters to actual drills? How is ADEC coming in on feedback and lessons learned? Are they coming in hot with notices of violation or are they taking a different approach?
Rosie:
with notices of violation, or are they taking a different approach? So far, I've not seen any notices of violation coming out of these drills, and no fines have been assessed due to unsuccessful exercises, as far as we know. Depending, though, on the severity of the inadequacies, adec may require another 485 drill, so you might not achieve the credit that you were going for. You might have to do it again, or they may propose actions to the plan that the plan holder can take to ensure a successful exercise next time. There is a sense that ADEC wants these exercises to make the plan holder more prepared for spill response instead of being used as a way to issue NOVs and fines of being used as a way to issue NOVs and fines.
Shannon:
Yeah, that sounds like a relief. I think a lot of our clients were really worried that there was going to be quite a bit of NOV and fees and I am not a lawyer, neither is Rosie but I do think that at this early stage of the game, with this program being new, the state of Alaska is leaning more towards assistance, towards compliance, rather than correction through issuance of notice of violation. That is all really good information to know for our listeners that are responsible for 485 DRLs. I do get this question a lot, rosie, and maybe we can debunk it or clarify it here. How does the 485 program differ from NPRP, and can we just do NPRP and meet the 485 drill guidance?
Rosie:
Biggest difference between NPRP or even a federal government initiated unannounced exercise or a GUI and the 485 drill is ADEC's involvement. Adec has to be involved pretty much as soon as the plan holder knows that they're going to have a drill. They will be part of the planning meetings, they're going to be present at the exercise and they will provide a final evaluation after the exercise is complete. The second biggest difference is that 485 drills must be based on an aspect of the spill scenario in your C plan. So it doesn't necessarily have to be the largest spill scenario, which is the ADEC response planning, standard volume or the worst case discharge scenario. It can be the medium or the small spill scenario. But ADEC is just really wanting to see that what is written in your C plan is not just fiction and that it can actually be put into action.
Shannon:
Can any of the end prep exercises get credit for 485 drill? Is there some mechanism for that or do they have to be separate?
Rosie:
No, they absolutely can be done concurrently and can receive credit. But, like I said earlier, they just need to make sure they're getting ADEC involved from the start and that the exercise is based on a scenario in their C-Plan.
Shannon:
Okay, well, you mentioned GUIs. I have a feeling a GUI is a little trickier, though, because it's unannounced. So how do you get the state involved if it's unannounced?
Rosie:
trickier though, because it's unannounced. So how do you get the state involved if it's unannounced? Yeah, so with it being unannounced, you're not going to be able to notify ADEC prior to the drill. But ADEC has actually answered this question on their FAQ page and we will link that in the show notes. But basically, for a GUI to count, the planning team will also need to consist of a trusted agent from the plan holder in addition to ADEC and the federal agency. Following the guidelines in the manual, a trusted agent could be a third-party contractor or it could even be someone from a federal agency, such as the US Coast Guard, that brings the ADEC into the exercise planning phase and that would ensure that it would meet 485 credit.
Shannon:
Okay, Got it. So that trusted agent. It can be many different people, but I think the idea is that the unannounced part still stays unannounced to the client. Okay. I also do get quite a few questions about combining drills for regional exercises and potentially cost savings. Like, hey, if the ADC is going to come all the way out to this remote Western location, do you think we could do a drill involving multiple seaplane holders in the same community? How has the state been reacting to those types of requests, Rosie?
Rosie:
With this program still being in its infancy, what we have seen is ADEC is leaning towards keeping the exercises focused on individual facilities at this time, and the main reasoning is that it keeps the scope of the drills a little more manageable from ADEC's perspective, it ensures that one facility meets the requirements in their C-Plan, and that's simpler than including multiple facilities with all of their own C-Plans and all of their own scenarios. With that all said, there has been an indication that ADEC is open to incorporating multiple plan holders in 485 drills in the future future.
Shannon:
I have a feeling, rosie, that as the program develops and skills are built, the state will probably be more open to that kind of combination stuff. But I think right now for some of our communities and sea plan holders the readiness level is not. They need to build and practice first. And then I also I did want to clarify we've been talking throughout about facilities and C-plans and I did want to just make this note that we're using the term facility and C-plan sort of interchangeably. Some C-plans do have multiple facilities in them and the state is focused primarily on the C-plan, the way the 485 regulation is written.
Shannon:
So just in case you think you're out there thinking you could be really clever and just have a drill for one facility, even if you have two under one OD PCP, it's really the OD PCP or the C-Plan that is driving the drill, not a north terminal versus a south terminal, for example. It could be any component of any part of a sea plan. So if you've got two different sea plan activities at two different terminals all under the same sea plan, it's all fair game. Rosie, thank you, that was a very in-depth dive and I think that kind of answered some of our frequently asked questions, and it was a very good and clear overview of the types of drills and the evaluation criteria, and so I was wondering if you could point our listeners to resources that we have identified as useful to learn more about the 485 Drill Program and to guide their own 485 Drill responsibilities.
Rosie:
Plan holders. C-plan itself is really a great document to refer to. I would specifically be paying attention to the spill scenario section, and your ODPCP is basically a contract between you and ADEC. So you as a plan holder have attested that your facility has the capabilities lined out in the plan. So now is really a great time to look through it and see if any revisions are needed.
Rosie:
Your oil spill response organization or your OSRO, or also can be referred to as the primary response action contractor, PRAC they have sometimes will have planning tools and or oil spill response manuals that are really excellent tools and resources to look at to prep for an exercise. Some other useful websites that we're going to link in the show notes include ADEC's Spell Response Exercise Manual. We've mentioned it many times here today and they have a website set up for the manual. They also have a website set up for the Spell Response Exercise Program website set up for the manual. They also have a website set up for the spill response exercise program. The regulation itself, of course, is good to refer to 18 AAC, 75. And then ADEC also has a spill response exercise scheduler. It's a fancy calendar that shows when all of the upcoming exercises have been scheduled, and you can also schedule your exercise through that website.
Shannon:
So that exercise scheduler, Rosie, that's to ensure that you're not overlapping drills with someone else. So you need to actually schedule like, you need to check that when you're thinking about a drill and making sure that if you want to do it in June of 2025, then you didn't have the same idea as six other people in the state of Alaska. Yeah, exactly.
Rosie:
And just being cognizant of your region too, because SPAR is broken up into different regions so you can check the calendar to see make sure you're not overlapping with a drill that's in your same region. Okay, yeah, just a few others that are good the ODPCP regulation, implementation tools and resources. That's a mouthful, but there's tons of links on that website that are very helpful with C-Plan writing and planning for exercises. And then some of the OSROs and PRACs that we are familiar with are the Alaska Shadot Network, CPRO, CISPRI and Alaska Clean Seas.
Shannon:
And each of their websites has access to spill response planning tools. All right, Rosie, thank you for that review of the resources. Thank you for taking us through the regulation and the exercise manual. This is complex. This is not necessarily the easiest thing to do. Where could our listeners go for additional training or help with any part of this process?
Rosie:
You can always come here to Integrity Environmental, Of course. Yes, yeah, here at Integrity we can provide a lot of guidance on how to set up the exercise. We can help with training and provide feedback during the practice runs of it.
Shannon:
We also can facilitate the drill.
Rosie:
Yes, absolutely. Another good resource for training would be the Alaska Shadow Network. They are a business partner of ours and they can provide incident management team training, which can happen in a virtual setting or they can do that in person as well.
Shannon:
And that is a valuable resource because a lot of the incident management team training that's out there is free and available from FEMA and we can also link that. But a lot of people learn better in person when they can ask questions and have it be specifically directed to the Alaska community that the drill is going to be in, and so that in-person training or virtual training, but from somebody who knows Alaska, can be really, I think, more effective in the long run for people retaining the knowledge and being able to use it during a real spill, which is super stressful, instead of this generic FEMA training about. I mean, the FEMA training is good, I will never knock it, but it's not the same, as this is what you do for your specific facility in your specific community.
Rosie:
One more that I was going to plug is ADEC. They are a really good resource. When you have questions about this, you can go straight to your plan holder to ask specific questions about drills. If you have questions about regulations, they have set up an email that you can send specific questions about regs that they will respond to in a timely manner.
Shannon:
Yeah, that's my experience with the state is, every time I've called and asked, I've gotten an immediate response from them and they are very open to talking people through this process. All right, thank you so much, rosie. I really appreciate you coming onto the podcast to share all of this information with our listeners and I hope for everyone out there listening that we made the 485 drill process a little more clear and if you have any questions or if you'd like to see us cover anything, you have suggestions for future episodes, we'd like to hear it. So give us a shout out on email and we will see you on the next podcast. Thanks so much, everybody.