Terrorists hijack a ship on Lake Erie and under cover of darkness head for the Maumee River – their target the city of Toledo. The Coast Guard responds, but without an assault vessel immediately available, they are unable to stop the ship until it rams into oil dock of a refinery, causing a major oil spill. In a coordinated attack, another group of terrorists wreck a tank truck of fuming sulfuric acid. There are injuries. A massive response ensues. Fortunately, responders are prepared.

The above incident occurred in August, but the 'terrorists' were actually a red team of employees of BP Toledo, a refinery located in Oregon, OH, near Toledo. Their actions were part of a full full-scale deployment exercise nicknamed "Mayhem on the Maumee" intended to test the ability of BP and other local government and public safety organizations to respond to a terrorist incident and/or massive oil spill. Participating in the exercise with BP Toledo were representatives of the FBI, Department of Homeland Security, U.S. Coast Guard, FEMA, the Environmental Protection Agency, Oregon (Ohio) SWAT Team, and many other groups. These are the agencies with whom BP Toledo would partner in the event of an actual terrorist attack or major oil spill.

Preparedness post 9/11
Chris Herman, Emergency Response Specialist with BP Oil Co's Toledo, OH refinery, has been organizing preparedness exercises for 25 years. Chris heads BP Toledo’s Industrial Response Team, which comprises 65 response technicians and a 40-person incident management team. "We have always had plans for oil spills and for bomb threats. The hazards we are facing are the same, but the risks have changed. The threat of terrorism has increased obviously, and so has our intensity for preparedness. 9/11 galvanized our resolve to prepare."

According to Herman, "Planning for this type of exercise begins a full year ahead of the actual event. We put together a Design Team of 10-15 people, all members of groups in the area that are interested in participating in a training exercise." The motivation for a public or private agency to participate in an exercise usually boils down to compliance, the need to test internal systems and interoperability with other response agencies before the 'Real Deal.' Each group will probably have a different training need. For example:

• BP’s training seeks to meet the on-going requirements of OPA ’90, OSHA 1910.120, and the Process Safety Standard.
• Local public response agencies such as police and fire seek to meet certain government requirements, such as NIMS, communication interoperability, hospital interface, and response tactics.
• Environmental groups may be finding out how certain endangered species might be impacted and/or protected.
• The U.S. Coast Guard & the Environmental Protection Agency are training to contain and clean up oil spills.
• Fire departments are training to deal with injuries and to contain hazardous material spills.
• Response contractors need to maintain their certification status with Coast Guard and with local industry.

Committing to preparedness
For the past several years, TOPOFF (Top Officials) preparedness exercises have been conducted by the U.S. Department of Homeland Security in cooperation with other federal and state agencies. This series of challenging, role-playing scenarios takes place approximately annually, in various regions of the country, and has involved all levels of government officials directing crisis management and consequence management response to simulated WMD attacks. The Coast Guard has implemented PortSTEP (Port Security Exercise Training Programs) over the past few years to develop port security exercise and evaluation services and solutions for maritime and affiliated industries.

While preparedness has been stepped up in recent years at the federal and local levels primarily due to the increased threat of terrorism, industry has been conducting preparedness exercises for years in response to the federal government’s ever-increasing compliance requirements. In 1986, Congress passed the Superfund Amendments and Reauthorization Act (SARA) as a response to the chemical accident in Bhopal, India in which a toxic gas escaped from an industrial plant and killed or injured more than 1,000 people. Title III of SARA, also known as the Emergency Planning and Community Right to Know Act, requires industries to release information about the hazardous materials that are used or stored at their locations, and to make arrangements to prepare for the mitigation of possible emergencies and disasters involving those hazardous materials. Other laws which require preparedness include the Oil Pollution Act of 1990 (OPA’90), which seeks to improve the country’s ability to prevent and respond to oil spills; the Process Safety Standard, 29 CFR 1910.119, which contains requirements for the management of hazards associated with processes using highly hazardous chemicals; and the Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120, also known as Hazwoper), which outlines specific training requirements for workers who may be exposed to safety or health hazards while performing work at a hazardous waste site.

Full-scale deployment exercises are critical for building effective response teams. Designed to test personnel and equipment performance and improve preparedness during major incidents, exercises point out the deficiencies of procedures and improve interaction among the key players, paving the way for improved performance during an actual incident. A full-scale exercise requires a commitment of resources, personnel and time. To be effective, it will involve multiple agencies and multiple jurisdictions operating under ICS or Unified Command. Operating in real time in a stressful environment intended to mirror an actual event, a full-scale exercise should be designed to test the many facets of emergency response and recovery while implementing and analyzing current plans, policies and procedures. Most importantly, there must be a mechanism for analyzing the strengths and weaknesses of existing plans and procedures based on the exercise, and for implementing change.

Setting objectives
At the first meeting of the Design Team, the overall objectives of the deployment exercise are established. For this particular exercise, the overall objective was to test the ability to respond to a terrorist threat and massive oil spill. A third party contractor who specializes in exercise planning is hired to help organize and facilitate the exercise. This contractor has no ties to any of the participating agencies: their primary purpose is to help facilitate the design meetings and the actual exercise.

Next, each participating group meets independently to define their sub-objectives and to write a scenario to address their own particular training needs. For example, the local Police Department and FBI branch were seeking to get field experience in an industrial environment during incidents involving security breaches. The full-scale deployment exercise weaves together all of these scenarios into a storyboard, which forms the screenplay for the exercise. Next, the budget must be addressed. This is still many months ahead of the exercise. The cost of the exercise is borne by all the players who, in effect, must 'pay to play.' According to Herman, a full deployment exercise involving 100-250 participants can easily cost from $15,000 - $150,000, or even more, depending on the scope. The exercise in Toledo cost about $50,000. One of the reasons for early planning is to give local agencies time to seek approval for and to appropriate the funds needed for participation.

In preparation for the exercise, Herman says that BP conducts training and holds drills. "Training … drill … training … drill … training … drill …Exercise," said Herman. "We want to have our processes in place by the time of the exercise so that we know that we’re testing our best possible procedures." Drills are repetitive, while the exercise will be held in real time.

Only the contractor and a few select members of the Design Group know the specific details of the scenario, including exactly when it will take place and what will happen. Participating groups only know the general timeframe and overall objectives for the exercise. As the date gets closer, the exercise is hyped during training, but the exact timing remains secret.

The exercise
On the appointed day and time, the event begins according to the script, with a message to the designated 'First Input' about reports of an 'unscheduled activity.' The response takes off from that point according to procedures. Exercise evaluators are on the scene right from the start to record the response as early as First Input.

As the 'incident' unfolds, the 'Truth Room' operates behind the scenes, staffed by the contractor/facilitator and members of the Design Team "in the know" about the full details of the scenario. All input and decisions made by the various response team players must be cleared through the Truth Room to ensure that there are no conflicts. Facilitators make sure the response teams stay on track, which sometimes requires a gentle prodding towards a 'better response direction,' or sometimes requires the ad lib interjection of 'events' should the action begin to stall. Some members of the Design Team are assigned to be evaluators to critique the action. According to Herman, the exercise is never designed to fail, just to expose weaknesses. It is important for all planners and participants to maintain a positive attitude throughout.

In this exercise, a ship on Lake Erie was hijacked by terrorists and was making its way down the Maumee River to the Port of Toledo. Said Herman, "We hired a couple of employees who had been former Marines to play the roles of the hijackers." The Coast Guard in the area had no assault ships and was unable to stop the 'unfriendly' vessel, which was crashed into the dock causing a massive oil spill. While this was taking place, another group of 'terrorists' hijacked a train servicing the refinery and crashed into a tank truck carrying oleum (fuming sulfuric acid). Response systems were stretched to the limit as BP, mutual aid and response contractors responded to the oil spill; law enforcement and the FBI responded to the security breach at BP; and the Oregon Fire Department responded to the train wreck and resulting hazmat leak. Unified Command was established, with the BP Plant Manager, the Chief of the Oregon Fire Department and the Commander of the Port of Toledo heading up Command.

Lessons Learned
Herman was very pleased with his Team's interactive capabilities. However, the exercise highlighted a few areas requiring improvement. "We learned that we need to continue to upgrade our interoperability systems and infrastructure to meet the needs of Emergency Management of larger L2 [regional] and L3 [global] incidents. We plan to continue with our plans for updating site security to an even greater degree."

Although the BP Toledo has been fortunate that no major disasters, manmade or natural, have occurred in their area, their training exercises have helped them respond in support of offsite industrial complexes. BP is a member of the Northwestern Ohio and Michigan Mutual Aid District (NOMMAD) industrial support team, which supports local public agencies as well as each other. Other members of NOMMAD include Sunoco, the Davis Bessie nuclear power plant, CSX Railroad, BP Pipeline, several trucking companies, five area chemical plants and several clean-up contractors. On an ongoing basis NOMMAD participates in containing oil spills on the Maumee River and adjacent waterways, and recently they responded to fires at a local grain elevator and at a large tire dump.

Herman’s philosophy about training exercises is simple: "We approach exercises in a positive light and make every opportunity for participation by regulators and government agencies to participate and observe."

Chris Herman is a Emergency Response Specialist with BP Oil Co's Toledo, OH refinery. He is core lead instructor for BP's worldwide fire and emergency training programs and has been a fire service instructor for over 25 years. He is a member of the International Association of Fire Chiefs (IAFC) and chairman of the Northwestern Ohio and Michigan Mutual Aid District (NOMMAD). He has served as a technical committee member for several EFG programs. Chris received a commendation from the Captain of the Port of Toledo for his work in organizing the Mayhem on the Maumee exercise.