February 2020, Vol. 247, No. 2


New OPA90 PREP Guidelines Bring Flexibility to WCD Response Testing

Oil transfer and storage businesses (onshore), which fall under the Oil Pollution Act of 1990 (OPA90), are familiar with the 2016 National Preparedness for Response Exercise Program (PREP) Guidelines.  PREP Guidelines require downstream and midstream operators to stress-test incident responses for worst-case discharges (WCDs) at complex facilities. These facilities fall under one or more governmental jurisdictions that are part of OPA90, such as the Environmental Protection Agency (EPA), the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the U.S. Coast Guard (USCG). The original PREP Guidelines require incident management teams (IMTs) to conduct an annual exercise (as

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