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Oil Spill
Contingency Planning
National Status
A Report to the President
from
Samuel K. Skinner
Secretary, Department of Transportation
and
William K. Reilly
Administrator, Environmental Protection Agency
October 1990
Prepared By
The National Response Team
'/V- Printed on Recycled Paper
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Oil Spill Contingency Planning
National Status
A Report to the President
from
Samuel K. Skinner
Secretary, Department of Transportation
and
William K. Reilly
Administrator, Environmental Protection Agency
Prepared by
The National Response Team
October 1990
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CONTENTS
EXECUTIVE SUMMARY ES-1
PREFACE i
I. INTRODUCTION 1
I low This Report Was Developed 1
Fulfilling Mandate of Exxon Valctez Report .... 1
Information Submitted 1
Scope of Report 3
II. ENVIRONMENTAL AND HEALTH EFFECT'S 5
Fate and Effects of Spilled Oil 5
Human Health Risks 5
Worker Health and Safety 5
Food Chain Contamination 6
Threats to Aiiimul and Plant Life 6
Mitigative Strategies 7
Environmental Contingency Planning 7
III. STATE OF PREPAREDNESS 11
Prevention — The Best Protection 11
Nationwide Oil Pollution Response System 12
How the System Works 12
National and Regional Contingency Plans 13
OSC Plans 13
Other Federal Plans 14
Slate Plans 14
Local Community Plans 17
Industry Plans 17
Industry Cooperatives 18
Coordination of Contingency Plans 20
Interstate, Interagency, and
Federal-State Agreements 20
Coordination with Foreign Countries 21
Roles and Preparedness at the Regional,
State, and Local Levels 22
State Role in Oil Spill Response 22
Coast Guard Response Capabilities
for Routine Spills 23
Planning, Safety, and Prevention
at the Local Level 23
Minerals Management Service 25
Department of Defense 25
Maritime Administration 26
National Response Team: Lessons Learned
and Current Plans 26
Regional Contingency Plans 27
"Federalizing" an Oil Spill 28
Exercising Contingency Plans 30
Identifying the Worst-Case Oil Spill Scenario .... 31
Themes Arising From OSC Analyses
of Worst-Case Oil Spill Scenarios 33
Availability of Equipment 33
Personnel 36
Contractors and Cooperatives 37
Communications/Information 37
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Public Allans 38
Disposal 38
Chemical and Biological Countermeasurcs 38
Chemical Dispcrsanis 38
Viscoelastic and Plasiicising Agents 39
Biorcmediation 39
In-situ Burning 39
Funding 40
Storage Tank Spill Prevention 40
Organization of Response to
Catastrophic Oil Spill 41
Priority of Oil Spill Response Readiness 42
IV. CONCLUSIONS 43
Conclusions Regarding the National
Response System 43
Conclusions Regarding Response Shortfalls 44
Conclusions Regarding Contingency
Planning Efforts 45
J. RECOMMENDATIONS 51
Recommendations Regarding the National
Response System 5]
Recommendations Regarding Response
Shortfalls 52
Recommendations Regarding Contingency
Planning 52
APPENDICES
A. Summary of Regional Response Team
Contingency Plans 1
B. Examples of Hazards Analyses
and Worst-Case Scenarios 17
C. Summary of International Agreements 29
D. National Response Team Member Agencies 31
E. National Response Team Guidance 35
F. Acronym Glossary 57
FIGURES
1. Non-Vessel Spill Locations and
Vessel Spill Locations ii
2. Gallons of Oil Spilled in U.S./
Number of Oil Spills in U.S iii
3. Percent of Total Petroleum Products Carried iv
4. Sample of Environmental Areas of
Special Concern for Mobile, AL 9
5. Regional Response Team Boundaries 16
6. U.S. Coast Guard Districts 16
7. Ages of Above-Ground Storage Tanks 25
Contents-2
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EXECUTIVE SUMMARY
The Nation's oil spill response system routinely and
effectively responds to a wide range of minor, medium, and
major oil spills, but the country's response capabilities can be
overwhelmed by catastrophic events such as that which
occurred on March 24, 1989, when the Exxon Valdez ran
aground, spilling 11 million gallons of oil into Alaska's Prince
William Sound.
The nationwide response system is supported by a
multilayered network of Federal, regional, State, local, and
industry participants, each with its own planning mechanisms
and resources that can be activated in response to an oil
spill. The system is anchored by the Federal Government's
National Response System, which includes National and
Regional Response Teams and Contingency Plans, and is
represented at the regional and local levels by predesignated
Federal On-Scene Coordinators (OSCs). The majority of oil
spills, large and small, are cleaned up by the petroleum
industry and others that spill oil.
Although the system is basically sound, there are
shortcomings that undercut the Nation's ability to respond
to catastrophic oil spills. These shortcomings include
shortfalls in equipment, trained personnel, and other
resources; inadequate coordination among the Federal, State,
local, and industry participants; sometimes differing missions
at the Federal and State levels; and a fragmented approach
to training and exercises.
The Exxon Valdez disaster, along with other recent coastal
and inland incidents, has reminded the Nation that
catastrophic spills can and do occur. Public concern about
the environmental, economic, and health effects of oil spills
requires that oil spill preparedness and response have a
higher priority on the national agenda.
Prevention
Regardless of the effectiveness of the Nation's response
capabilities, prevention remains the best protection against
oil spills. The Coast Guard and EPA, along with other
Federal and State agencies with jurisdiction over oil
transportation, storage, or safety, as well as the petroleum
industry, have traditionally given prevention efforts the
highest priority. However, budget reductions in recent years
have placed constraints on prevention programs that make
it difficult to maintain maximum effectiveness. These budget
reductions have not been limited to the Federal Government.
Similar reductions have occurred in the industry and in many
States. Effective prevention programs, both in government
and industry, require substantial, long-term commitment of
resources. Prevention is an investment that pays valuable
dividends in protecting the environment and public health,
and in reducing the high costs of oil spill cleanups such as
that required by the Exxon Valdez incident.
Planning and Coordination
Simply requiring contingency planning is not sufficient to
address the practical aspects of oil spill preparedness and
response. A mechanism must be developed to ensure that
contingency plans are realistic and effective, and that they
are tested and updated through regular, rigorous exercises.
The broad network of Federal, State, local, and industry
organizations that participate in oil spill response is an
important strength of the National Response System, but
this network cannot operate at maximum effectiveness
without better coordination among the participants. While
reports from the regions offer examples of interagency
coordination, especially in local port areas, comprehensive
coordination appears to be more the exception than the rule.
This is particularly true of government and private sector
coordination. Federal agencies at the regional and local
levels with oil spill response authority have little information
about industiy resources and capabilities and no consistent
approach for verifying or assessing industiy plans, yet
industiy provides the first line of defense against oil spills.
Catastrophic Spills
It is clear from this review of contingency planning, as well
as the response to the Exxon Valdez, that some actions must
be taken by Federal, State, and local governments and
industry to increase the ability of the National Response
System to respond to a catastrophic oil spill. The Exxon
Valdez incident provided a graphic example of how time and
complacency have limited the system's ability to effectively
address such spills.
In order to gauge their abilities to respond to catastrophic
incidents, regional teams of agencies responsible for oil spills
were asked to develop realistic worst-case scenarios of oil
spills comparable to that which occurred with the Exxon
Valdez. The agencies developed worst-case scenarios,
analyzing their abilities to respond to these incidents, and
developing a list of shortfalls. In almost every case, the
agencies reported that local capabilities would be
overwhelmed by catastrophic events.
Any plan to address catastrophic spills must include the
ability to quickly move personnel, equipment, and other
resources from throughout the Nation to the oil spill site;
ensure effective management at the scene with a more
comprehensive, high-level coordination of national support;
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and must encompass all layers of the National Response
System-Federal, State, local, and industry.
Cumulative Effect of Responses
During a single week in June 1989, Federal, State, local, and
industry organizations and agencies responded effectively to
three demanding oil spills across the country, all at a time
when the Exxon Valdez response was underway. However,
those involved in the responses to these major coastal spills
have pointed out that these incidents pushed the system to
its limits. If the spills had occurred under less favorable
circumstances or if the response actions had gone on longer,
some parts of the system might not have had the backup
capability to perform a timely and adequate cleanup. Thus,
the cumulative effects of responding to a number of different
spills can also place a strain on response resources,
particularly when mounting sustained responses.
Improvements Needed
In keeping with these findings, improvements are needed to
ensure:
An adequate stockpile of state-of-the-art oil spill
response equipment.
Rapid mobilization of support personnel and equipment.
Consistent coordination among Federal, State, and local
agencies and industry with oil spill response capabilities.
Effective coordination of oil spill contingency plans.
Preplanned, regular, and coordinated training and
exercises.
Knowledge and verification of industry oil spill response
capabilities.
A more effective strategy for applying the principles of
the NCP to catastrophic oil spills.
Development of innovative cleanup technologies, such as
bioremediation and chemicals to enhance the
performance of oil recovery equipment.
Enhanced prevention efforts.
Strength Through Coordination
Just as the Federal, State, and local governments and
industry are partners in the oil spill response system, so the
task of improving the Nation's preparedness is a shared one.
Each partner has a role to play in making the system work
better.
Each participant in the system must make oil spill response
a higher priority and make a greater commitment to
improving response capabilities. The most important step in
improving the system is for the partners to work together.
Each partner by itself has important strengths and resources.
By harnessing these resources in a coordinated and
cooperative manner, the Nation can take a giant step in
protecting its citizens and its natural resources.
Ultimately, oil spills are cleaned up using equipment and
trained personnel. The National Response System, including
the response contractors who are hired by both industry and
government, does not have enough of either. Industry,
mainly the petroleum industry, has the primary responsibility
for investing in the equipment and providing the trained
personnel to improve the Nation's response capabilities.
Many of the findings and recommendations in this report
have been expressed in similar reports in past years.
Unfortunately, many of the shortcomings in the Nation's oil
response system that were identified more than a decade ago
have yet to be adequately addressed. Interest in oil spill
response tends to rise dramatically with an event such as the
Exxon Valdez but then drop off quickly as the incident fades
from memory. What is needed is a steady, long-term
commitment by all levels of government and industry to
provide the equipment, training, personnel, and financing
necessary to develop and maintain an effective oil spill
prevention and response system.
Although there is no way to totally keep oil spills from
occurring or to provide complete mitigation of catastrophic
spills like the Exxon Valdez, there is much that can be done
to reduce the number and size of spills and to protect our
natural resources when spills do take place. The United
States is among the world's leaders in oil spill prevention and
response. Throughout government and industry, there are
people with extensive experience in oil spill prevention and
response. But it is only through a sustained commitment by
each of those responsible for prevention and response that
the public mandate to preserve and protect the Nation's
health and environment can be fulfilled.
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PREFACE
The United States can boast the most diverse environment
of any nation on the globe-from the arctic wilderness of
Alaska to the tropical splendor of the Hawaiian Islands, from
the awesome majesty of her mountain chains to the white
sands of the Florida Keys. Despite the high regard in which
these areas are held, experience has shown that few are
exempt from the potential for disaster. We have been
reminded of this by the 1989 groundings of the Exxon Valdez
in Prince William Sound and the World Prodigy in
Narragansett Bay, by the 1988 collapse of the Ashland Oil
Company tank and spill into Pittsburgh's Monongahela
River, and by the 1979 offshore blowout on the IXTOCI in
Mexico's Bay of Campeche with the resultant oiling of Texas
beaches. (See Figure 1 for non-vessel and vessel spill
locations.)
The United States consumed 265.7 billion gallons of
petroleum products in 1988. Total domestic crude oil
production in 1988 was over 125 billion gallons, with offshore
production accounting for 18.3 billion gallons. Alaskan crude
oil production was 31 billion gallons, most of which was
shipped by tanker to ports in the lower 48 states. Imports of
crude oil and petroleum products into the United States in
1988 were 113.8 billion gallons. The major U.S. ports, based
on these imports, were Houston, New Orleans, Corpus
Christi, Philadelphia, Morgan City (Louisiana), New York,
and Newark. With petroleum distributed by water, rail,
highway, and pipeline, and stored in facilities across the
nation, the potential for a catastrophic oil spill is ever
present.1
During 1988, more than 46 million gallons of oil were spilled
into the navigable waters of the United States from 15,865
reported discharges. For 1989, oil spill data, detailed in
Figure 2, clearly shows that the majority of spills were minor
spills. The very few major spills, however, accounted for the
vast majority of oil spilled.2
Many factors will have a bearing on the number of future oil
spills. Government action, changes in the location and
intensity of domestic oil exploration and production,
quantities transported, changes in transportation routes and
modes, and the age of transportation and storage facilities
are among those factors.
Although every practical effort should be made toward
accident prevention, care must be taken to ensure that such
it
».*
U.S. Coast Guard photo
SUCCESSFUL RESPONSE
Rapid response by the Coast Guard averted large-scale
environmental damage when the Worid Prodigy ran aground
in Narragansett Bay off Rhode Island in June 1989. Tank
barges were able to remove most of the oil before it escaped
from the ship.
action extends beyond the relatively small U.S. shipping
industry. To be effective, any action taken that addresses
vessel design and operation would need to be directed to all
vessels entering U.S. waters, both foreign and domestic, since
1 Source: Department of Energy.
2 Source: DOT Transportation Systems Center.
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FIGURE 1
Non-Vessel Spill Locations 1973-1987
Over 50,000 Gallons
t
Vessel Spill Locations 1973-1987
Over 50,000 Gallons
Source: U.S. Coast Guard
ii
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FIGURE 2
Gallons of Oil Spilled in U. S.
(1989)
Caribbean
Oceana
Alaska
Region X
Region IX
Region VIII
Region VII
Region VI
Region V
Region IV
Region III
Region II
Region I
I 1
Minor Spills
Medium Spills
Major Spills
i—i—i—T
4 6 8 10 12
Millions of Gallons Spilled
Source: Coast Guard estimate based on data received from National Response Center
Caribbean
Alaska
Region X
Region IX
Number of Oil Spills in U.S.
(1989)
E
ra
I® Region VIII
35
Region VII
o Region VI
DC
Region V
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only an estimated 14 percent of the oil transported by ship
to and from U.S. ports is carried on vessels documented in
the United States.3 In any case, the effect of regulatory
action would be difficult to predict, since changes in
operating cost may ultimately result in changes in preferred
transportation modes, or levels of domestic (offshore)
production.
Shoreside variables also lead to uncertainties in predicting
the number of oil spills that we are likely to experience.
These variables include the age and state.of our rail systems
and pipelines; the increase in the quantities of product
carried by those systems; the condition of equipment used
to transport oil and oil products by highway; the increase in
traffic around major metropolitan areas, areas most often
located on or near waterways; and the age and location of
major oil storage facilities around the United States. (See
Figure 3.)
Public and government awareness of our society's effect on
the environment is increasing. As a result, new Federal,
State, and local laws are being considered. The intent of
these laws will be to make our lifestyles compatible with the
surrounding environment. However, even though accident
prevention is the best solution, it is no more likely that we
can design vehicles to transport or store oil without some
possibility of a release than it is to build an airliner that can
collide with a mountain and continue to fly.
Oil spill response is a complex matter, and no oil spill should
be taken lightly. The impact of a spill will depend on many
factors, including the type and quantity of oil spilled, area
population, area geology, area use, weather, ecological
sensitivity, availability of response equipment, and public
interest.
Consequently, both industry and government must develop
and maintain an aggressive response posture, through
comprehensive well-coordinated contingency plans, tested
and updated by periodic exercises, in order to minimize the
impact to the environment from oil spills.
FIGURE 3
Percent of Total Petroleum Products Carried
1987
1986
1985
Railroad
Motor Carrier
Pipeline
By Water
1984
1983
1982
1981
1980
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1 1 1 1 1 1
0 10 20 30 40 50 60
Source: Association of Oil Pipe Lines Press Release Dated July 18, 1989 — Washington, DC
3
Source: U.S. Coast Guard.
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I. INTRODUCTION
This Report which builds on the May 1989 Report to the President on the Exxon Valdez
Oil Spill, examines the Nation's oil spill preparedness and response system in the wake of
the Exxon Valdez disaster. This section describes how the report was developed; the diverse
Federal, Regional, State, and local agencies and organizations that contributed to the
report; and how the Federal system responded to the mandate of the earlier Report to the
President to assess the status of contingency planning, particularly in response to worst-
case incidents.
A. How This Report Was Developed
In response to the Exxon Valdez oil disaster, President Bush
directed the National Response Team (NRT) to take a fresh
look at America's readiness to respond to oil spills of
national significance in the countries' major ports and inland
waterways. At a press conference on April 7, 1989, the
President said, 'This situation has demonstrated the
inadequacy of existing contingency plans. And consequently,
I have directed a nationwide review of contingency plans of
this type to determine improvements that may be necessary."
This report was done in a compressed time frame to provide
a representative picture of oil spill planning and
preparedness across the country. The survey and selected
plan reviews were scheduled on a fast track to allow for
lessons already learned to be incorporated into response
planning and management as soon as possible. To
accomplish this task, the United States Coast Guard and the
United States Environmental Protection Agency (EPA)
provided a leadership role for the NRT which directed
Federal, regional, and local offices to evaluate the
effectiveness of their oil spill contingency plans.
This report represents the combined efforts of hundreds of
individuals, including predesignated Coast Guard and EPA
On-Scene Coordinators (OSCs), other regional Federal
agency representatives, State officials, private industry, and
members of port area marine communities. In total,
74 organizations submitted reports based on detailed NRT,
Coast Guard, and EPA guidelines.
1. Fulfilling Mandate of Exxon Valdez Report
The May 1989 Report to the President on the Exxon Valdez
Oil Spill concluded that "planning for and response to the
Exxon Valdez incident were unequal to the task." It
recommended that:
Contingency planning in the future needs to
incorporate realistic worst-case scenarios and to
include adequate equipment and personnel to
handle major spills. Adequate training in the
techniques and limitations of oil spill removal is
critical to the success of contingency planning.
Organizational responsibilities must be clear, and
personnel must be knowledgeable about their roles.
Realistic exercises that fully test the response system
must be undertaken regularly.
The May 1989 report went on to say that "the National
Response Team is conducting a study of the adequacy of oil
spill contingency plans throughout the country under the
leadership of the Coast Guard." This report is the result of
that study. It examines the ability of the Nation's oil spill
response system to address worst-case incidents on the order
of that which occurred with the Exxon Valdez. It reviews
the adequacy of equipment and personnel, assesses the
effectiveness of training and exercises throughout the
regions, and reports on the overall organizational
effectiveness of the National Response System.
The Exxon Valdez report emphasized the importance of
developing realistic worst-case scenarios. The contingency
plans in place scarcely contemplated a spill of the magnitude
that happened. We must expect the unexpected and plan for
it," the report said. This report pays particular attention to
the worst-case scenarios developed by the Coast Guard
OSCs and to the shortfalls in equipment, personnel, and
coordination that were identified.
2. Information Submitted
The National Response Team requested that each Regional
Response Team (RRT) report on the broad range of
contingency planning within its region-including Coast
Guard and EPA plans, State and local plans, interstate
agreements, and industry plans. The RRTs also assisted the
Coast Guard and EPA in gathering data for this report.
The Captain of the Port at each Coast Guard Marine Safety
Office (MSO), who serves as the OSC, and EPA OSCs
reviewed their local spill contingency plans and determined
the size and severity of spills for which they are currently
prepared to respond. In addition, the Coast Guard directed
its MSOs to assess their abilities to respond to potential
worst-case incidents and to develop a list of shortfalls
resulting from such incidents.
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U.S. Coast Guard photo
A DEMANDING RESPONSE
In order to determine their readiness in the face of worst-
case incidents, Coast Guard OSCs reevaluated hazards
analyses of potential spill sources; assessed personnel,
equipment, and other shortfalls; determined response times
to spills in all areas within their realms of responsibility;
assessed public affairs capabilities in the event of a spill of
national significance; and identified policies within their
regions regarding chemical dispersants, in-situ burning, and
disposal of oil and oily debris.
Many Coast Guard and EPA OSCs reported that they were
already reviewing and updating their oil spill contingency
plans. They emphasized that contingency plan review is an
ongoing process and the fact that the plans are being
updated should not be taken to mean that the plans have
been neglected in the past.
A number of other NRT member agencies provided
information about their oil spill contingency plans. Among
them were the Department of the Interior's Minerals
Management Service, the Department of Defense, the
Department of Energy, and the Department of
Transportation's Office of Pipeline Safety and United States
Maritime Administration.
The appendices include a summary of Regional Response
Teams' Contingency Plans and a summary of international
oil spill agreements. The original guidance documents and
an acronym glossary are also provided.
In addition to the 74 reports, a number of other published
documents were considered, including a U.S. Department of
Energy report on the Exxon Valdez oil spill, a General
Accounting Office report to Congress on the response to the
Exxon Valdez oil spill, Congressional testimony, and the
Canadian Minister of the Environment's report on its Public
Review Panel on Tanker Safety and Marine Spills Response
Capability.
The Exxon Valdez oil spill affected over 750 miles of shoreline in Prince William Sound. Thousands of people,
hundreds of boats, and tons of recovery equipment were needed in the response. The isolated locations of many beaches
required equipment and personnel to be brought in by boat and aircraft.
>2
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3. Scope of Report
This report casts a wide net both in the geographic areas it
covers and in the broad range of contingency plans discussed.
All 13 Regional Response Teams noted that to fully involve
all of their members and to address in depth all of the issues
raised by the NRT guidance would have required many more
months. However, the 74 reports which were submitted and
which form the foundation of this report represent a wealth
of information about the status of the Nation's oil spill
response capabilities. We believe that the information
available enables us to provide an accurate picture of the
Nation's readiness to respond to catastrophic oil spills such
as that which occurred on March 24, 1989, when the Exxon
Valdez ran aground in Alaska's Prince William Sound.
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II. ENVIRONMENTAL AND HEALTH EFFECTS
In order to develop effective oil spill contingency plans, the impact of oil spills on the
environment and human health must be considered. This chapter explains the chain of
events that occur when oil is spilled. It addresses key environmental and health concerns,
including the potential for contamination of the food chain, the emotional and social
stress that accompany significant spills, and strategies for mitigating these and other
hazards. It also addresses such issues as environmental contingency planning, worker
safety during response activities, and strategies for mitigating oil spill hazards.
For the fullest understanding of the purpose and importance
of contingency planning, it is essential to know the potential
effects of petroleum products spilled into the environment.
There are a number of variables influencing the degree of
environmental harm resulting from oil spilled into marine or
inland waters, including the location of the spill, the time of
year, the weather, the type of oil involved, and the biological
productivity of the affected area-some of which can be
planned for, others of which cannot. Despite all planning
efforts, however, in the case of nearshore catastrophic spills,
the amount of oil involved can defeat all response efforts to
divert the moving slick from sensitive areas and may result
in substantial environmental harm.
A. Fats and Effects of Spilled Oil
Accepting the fact that oil spills occur and will continue to
do so, it is important to plan for spills of various types of oil
in a variety of locations. Freshly spilled crude, for example,
is more acutely toxic than oil that has been in the water
("weathered") for a number of days because of the
immediate presence of the more toxic volatile constituents of
crude, such as benzene and toluene, which quickly evaporate
or dissolve. Similarly, lighter refined products such as diesel
fuel and gasoline are more acutely toxic than crude, but they
also dissipate more rapidly. Weighing the immediate toxicity
levels of fuels with their capacity to dissipate, it becomes
clearly important to plan on keeping petroleum hydrocarbons
away from environmentally sensitive areas during the very
early stages of a spill.
The location of a spill is also of importance. When oil is
spilled into rivers, rapids, or dams that cannot be closed, oil
flows over them into the water column, making recovery and
protection of public drinking water intakes difficult. Bodies
of water with intense wave action will mix the oil and water,
forming an emulsion known as "mousse." Because mousse
can contain as much as 75 percent water, it complicates
mechanical removal by greatly increasing the volume of
material that must be removed. Chemical countermeasures
such as dispersants become less effective after mousse is
formed. Continuing wave action will break up the floating
mass of mousse into strands or ribbons. Evaporation and
dissolution of the lighter components thicken the remaining
oil into sticky tar formations which may move beneath the
water, making it difficult to track or recover.
In environments with little wave action (e.g., wetlands),
penetration of oil is limited to the upper few centimeters of
muddy sediments, but the stranded oil may persist for years.
Storms, high river stages, or high tides during a spill can
move oil far into wetlands and other sensitive areas,
increasing the harm done. In these areas, where mechanical
cleanup is both difficult and potentially harmful,
biodegradation assumes a more important role in the
removal of the oil.
Weather further complicates cleanup efforts. In cold
weather, heavy oils congeal quickly when spilled and may be
transported below the surface as large globs, a phenomena
which makes mechanical recovery difficult. In northern
latitudes, lower temperatures may slow the weathering and
biodegradation of the oil.
B. Human Health Risks
Protection of human health is a fundamental objective of oil
spill planning. Avoidance of exposure is an important means
of protecting the public, while training is a key element in
protecting worker health and safety. Human health risks
associated with oil spills include the threat of fire, hazards
encountered by workers during cleanup operations, exposure
to toxicants in crude oil through direct exposure or through
oil-tainted food or drinking water, and stress resulting from
economic and lifestyle losses.
1. Worker Health and Safety
Workers engaged in cleanup operations at oil spills have
inherently hazardous occupations. They must often work
long hours in hostile environments while being exposed to
toxic, possibly flammable, and/or explosive chemicals from
the oil as well as chemical countermeasures used to combat
the spill. Crude oil contains both acutely toxic and
carcinogenic substances. Most of the acutely toxic
substances are volatile, and exposures would be highest soon
after the spill. Given the large surface area created by a
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catastrophic oil spill, initial exposures to volatile substances
could be substantial, and a variety of acute health effects
may occur. These might include irritative, dermatologic,
respiratory, and/or neurologic effects. In addition, exposure
to carcinogens, such as benzene, could occur.
Weathered oil consists of paraffins and asphaltenes, but does
not contain many of the volatile aromatic hydrocarbons that
are present in the preweathered crude. With the possible
exception of ingestion, the health concerns attributable to
weathered crude relate to skin exposure. Prolonged or
repeated skin contact may result in dermatitis. Although
experimental studies involving occupational exposure to
cutting and lubricating oils have shown certain petroleum
components and products to be skin carcinogens, the
available data do not either support or refute the notion that
occupational exposure to weathered crude poses a substantial
risk of skin cancer.
Materials used for cleanup operations may include
dispersants and chemicals to promote microbial degradation
of oil. Geanup operations can also result in exposure to
motor fuels, motor exhaust, solvents, and other substances
used for shipboard and on-shore supporting activities, all of
which may cause a variety of health effects.
Site conditions pose additional risks to cleanup workers.
These range from heat stress to hypothermia. Walking
surfaces, which are often uneven, are made more slippery
and dangerous by the oil. The risk of inhalation of oil
aerosols and vapors is increased when hot water sprays used
in the cleanup create a misty, oil-laden atmosphere. The
effects of this type of exposure include irritation of the eyes,
nose, mouth, and throat; coughing; chest discomfort and
tightness; and shortness of breath. Traumatic injuries may
become more serious if the spill occurs in a remote area
where medical care is less accessible.
2. Food Chain Contamination
The potential long-term impact of an oil spill on food safety
is influenced by biodegradation and bioaccumulation. The
more complex hydrocarbon contaminants such as polynuclear
aromatic hydrocarbons (PAHs) pose the greatest long-term
health hazard to humans via the food supply. This is so
because of their inherent toxicity and environmental stability.
PAHs are well-known carcinogens and may produce adverse
human health effects at low levels over long durations of
exposure.
Bioaccumulation of petroleum contaminants like the PAHs
occurs to the greatest extent in shellfish. Shellfish
metabolize and excrete PAHs at a slower rate than fin fish.
Because of their immobility, they are unable to move away
from heavily polluted areas, resulting in direct contact with
sediments where components of petroleum are known to
accumulate.
To prevent the consumption of contaminated food,
governmental entities can issue warnings or close fishing
areas with visible oil contamination, and initiate appropriate
short-term and long-term screening/surveillance
methodologies for oil contaminants in seafood. The
techniques that can be used in the field, such as the sense of
smell, are sensitive enough to detect the most volatile
components in crude oil, which pose the most acute hazard.
C- Threats to Animal and Plant Life
Identifying and protecting sensitive ecosystems is an
important element of planning. Oil can kill animals and
plants through ingestion, dermal absorption, inhalation, or by
smothering. Various life stages of different species have
widely different tolerances and reactions to oil pollution.
Usually the eggs and larval stages are more vulnerable than
the adults. Because many species produce large numbers of
eggs and larvae to overcome natural losses, localized losses
caused by an oil spill may have little or no discernible effect
on future adult populations or on the predators that consume
the eggs and larvae. However, catastrophic spills may have
more than short-term localized effects on eggs and larvae
and the predators that eat them. This would be especially
true of spills occurring in biologically rich areas during
periods of peak productivity, usually the spring.
Whereas adults of some species can and do avoid oil slicks,
plants, shellfish, corals, and other immobile or slow-moving
shoreline or wetland animals cannot. Consequently, these
species may suffer high mortality rates from oil spills that
reach their habitats. Mangroves and submerged or
semisubmerged vegetation are especially vulnerable to oiling
of their root systems. Geanup operations which disturb the
sediments and increase the penetration of oil can add to the
harm caused by the oil itself. Recovery of these habitats and
the animals that depend on them for food and shelter can be
slow.
Birds and animals that swim or dive in water and depend on
their feathers or fur for thermal protection are especially
vulnerable to oil spills because oil quickly mats their feathers
or fur, destroying their thermal and waterproofing properties.
They may also be killed by ingesting oil as they seek to clean
themselves. Oil that birds carry back to their nests on their
feathers may kill embryos within their eggs or their chicks.
Scavenging birds and animals may be killed or injured by
eating oiled carcasses.
Even spills that occur on dry land (e.g., from pipelines or
storage facilities) and never reach surface waters can have
severe impacts on animals and vegetation caught in the path
6
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SAVING WILDLIFE
Response workers devote many hours to removing oil from birds and animals after an oil spill.
U.S. Coast Guard photo
of the oil, including important microfauna in the soil.
Cleanup of heavily oiled soil can be difficult and costly. If
the soils are porous enough to allow the spilled petroleum
hydrocarbons to seep down into aquifers, the cleanup can be
even more costly and the long-term human health risks more
significant.
D. Mitigative Strategies
Prevention is clearly the best defense against oil spills. Once
spills occur near shore, human ability to contain and remove
large amounts of oil from the water before it reaches the
shore is constrained by the vulnerability of mechanical and
chemical countermeasures to weather and other
environmental factors. More research is needed to improve
the ability of booms and skimmers to operate under high
wave and/or current conditions and to handle viscous,
debris-laden oil. The many questions remaining about the
effectiveness and environmental implications of dispersant
use also need to be resolved if these chemicals are to
become an effective response tool. But, even with these
improvements, large amounts of oil can still be expected to
reach environmentally sensitive shorelines after a
catastrophic spill occurs in protected, near-shore waters.
1. Environmental Contingency Planning
Incorporation of environmental concerns in contingency
planning has been shown to lessen the adverse effects from
oil spills. If planners can agree in advance on the best
cleanup techniques to use in different environments and the
priority of such areas, valuable time and limited resources
can be saved during an actual response, which can be critical
to the effectiveness of protective actions. Present technology
helps us to predict, through the use of computer models, the
movement of oil in water under a variety of weather,
currents, and/or tidal conditions. Additionally, the degree of
sensitivity of shorelines to oil spill impacts can be predicted
and shorelines can be ranked prior to a spill so that those
shorelines needing higher priority for protection are
considered in the decisions to deploy equipment. Booms and
other protective measures can be put in place to divert oil
from environmentally sensitive areas in the slick's predicted
path. This strategy' of combining trajectory models with
7
-------
maps of identified sensitive shorelines prior to an incident
was applied successfully in Alaska's Prince William Sound
following the grounding of the Exxon Valdez. Booms were
placed to divert oil from the bays where hundreds of millions
of hatchery salmon were being held prior to release into the
Sound. Booms were also used to protect the mouths of
streams to which adult salmon worth nearly $100 million
would return to spawn.
Prince William Sound was only one area for which
environmental contingency planning has been conducted.
Over the past 10 years, the National Oceanic and
Atmospheric Administration (NOAA), working with other
Federal and State agencies and private organizations, has
identified and mapped environmentally sensitive areas and
socioeconomic features such as public water intakes, fish
hatcheries, and recreational areas. Detailed maps showing
shoreline characteristics (e.g., wetlands, sandy beaches, or
rocky shorelines), as well as other environmental and
socioeconomic features, are now available for 90 percent of
the marine coastline of the United States and approximately
30 percent of the U.S. shoreline of the Great Lakes.
In addition to the environmental sensitivity index maps
(ESIs), NOAA has also been working with the Coast Guard
to help OSCs prepare for oil spill emergencies by analyzing
information from a port area to determine the most likely
scenarios for an oil spill or hazardous chemical release.
Development of this program has involved a systematic
inventory of port assets and environmentally sensitive areas.
Figure 4 summarizes ESI information for the Port of Mobile.
Using historical information on past spills, seasonal
climatologic data, and patterns of the movement of oil
transported through a port, likely accident sites can be
identified and resulting pollutant movement can be
estimated. Based on these scenarios, environmental and
socioeconomic features more likely to be impacted by a spill
can be defined, allowing for pre-spill decisions on the types
and quantities of response equipment needed to protect
those areas. Port studies have been completed for 20 of
47 port areas. These studies result in a series of maps and
data in hard copy form. In the last two years, port studies
have also been produced in a microcomputer format to allow
more rapid access to information, easier updating,
customization, and multiple scenario assessment.
The use of computers for rapid response has recently been
expanded beyond the USCG-NOAA Port Studies Program
to include hazardous materials databases, automatic spill
call-up capabilities, and an air plume model for hazardous
chemicals. An oil spill probability model and reference
information on environmental databases will be added.
Expansion into the hazardous materials field is based upon
the similarity of incident planning required for both oil and
hazardous materials, and takes advantage of an ongoing
effort by NOAA and the EPA to use computers for planning
and response to hazardous materials. Other expansions for
computerized planning for oil spills are anticipated based
upon current interagency discussions and appropriate
resources being made available.
8
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FIGURE 4
Chickasaw Creek
MOBILE
MOBILE BAY
Common
Along
Eastern
: Shore
Weeks Bay
Found Throughout Bav Area
fnfcracoastal
Waterway
.Dauphin
I Island
GULF OF MEXICO
10 5 0 10
Miles
Shoreline Type
High Sensitivity
— Medium Sensitivity
Biological Resources
d) Oysters
^J^Wading Birds
(j^ Shrimp
Diving Birds
© Crabs
Shorebirds
Dolphins
Waterfowl
Fish
Raptors
Seabirds
Nesting
Sand^
Island
Environmental Areas of Special Concern for Mobile, AL
Maps of port areas identifying regions of greater environmental sensitivity are used to plan cleanup and mitigation operations.
-------
111. STATE OF PREPAREDNESS
Assessing the Nation's ability to respond to oil spills requires a review of response
capabilities at many different levels. This chapter describes the nationwide oil spill
response system-including the Federal Government's National Response System; the status
of Federal, State, local, and industry contingency planning; the adequacy of exercises testing
oil spill plans; the effectiveness of oil spill contingency plans; and the development,
response, and shortfall assessment of worst-case scenarios.
A. Prevention - The Best Protection
As noted in the Report to the President on the Exxon Valdez
Oil Spill, the best way to protect the environment is to
prevent spills from occurring.
The Coast Guard, the Environmental Protection Agency, and
other government agencies involved with oil spill response
have always made oil spill prevention a high priority. The
Coast Guard regularly inspects vessels and facilities that
transport and store oil, enforces maritime personnel training
and licensing requirements, maintains ship construction
standards, provides a safe navigation infrastructure for U.S.
waters, and plays an active role in international forums for
promoting safe navigation and pollution prevention
worldwide.
EPA's primary prevention program, the Spill Prevention,
Control and Countermeasures Program (SPCC), regulates
nontransportation-related facilities such as above-ground
storage tanks and oil production facilities that have the
potential to spill oil in navigable U.S. waters. The program
establishes general site and construction standards for all
such facilities, and it maintains a limited inspection program.
The program has been successful in increasing overall
awareness within the oil facility community of the importance
of spill prevention.
The Department of Transportation's Office of Pipeline
Safety (OPS) also focuses its pipeline safety efforts on
preventing oil spills.
In addition to these long-term prevention measures, the
Coast Guard and EPA have taken additional measures to
improve prevention activities in response to the Exxon Valdez
oil spill and other oil spills during the last decade. The
Coast Guard has initiated activities in 20 areas that address'
prevention and response activities. These initiatives include:
A comprehensive review of alternative tanker designs
under the auspices of the National Academy of Sciences.
The project will review past and present tanker designs,
evaluate the double hull and double bottom on tank
vessels, and make recommendations for new tanker
design standards.
A study of the Coast Guard tank vessel inspection
program, which has been completed and is undergoing
agency review.
A review of pilotage requirements that addresses pilot
certification and training, Federal and State roles in pilot
oversight, and the requirements for pilots aboard various
types of vessels and coastal areas. The findings of this
report may be incorporated into future legislation
affecting the Coast Guard.
Proposals for strengthening licensing and documentation
of merchant marine personnel, including periodic review
of merchant marine documents and staff certificates,
withholding or denying document and license requests
based on applicant character and habits, extending
disciplinary authority to cover onshore alcohol-related
incidents, and review of automobile driving records for
driving-while-intoxicated convictions. These proposals
are included in pending legislation.
Development of the International Convention on
Standards Training, Certification, and Watchkeeping of
Seafarers, which, if ratified, would establish basic
qualifications for ships' crews around the world.
EPA reviewed its SPCC program following the Ashland Oil
Spill, a major inland oil spill in January 1988, and is
currently implementing recommendations to develop more
specific requirements in the areas of tank integrity testing
and facility-specific contingency planning.
Despite the long history of concern for prevention, both the
Coast Guard and EPA have experienced budget reductions
in recent years that have put strains on their prevention
programs. Yet the Exxon Valdez incident, the Ashland Oil
Company storage facility discharge, and other oil spills of the
past decade demonstrate the importance of maintaining
effective prevention programs as a vital element in protecting
public health and the Nation's natural resources.
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B. Nationwide Oil Pollution Response System
The Nation's system of responding to oil spills is a
multilayered partnership developed over many years, which
includes the Federal Government, States, local government,
and industry. The system comprises a network of individual
contingency plans that describe the roles, responsibilities,
requirements, and capabilities of different levels of
government and industry. With the exception of the
Regional Contingency Plans mandated by the National
Contingency Plan, coordination among these plans is mostly
voluntary.
The National Contingency Plan provides for, but cannot
mandate or detail the activities of other non-Federal levels
of government. Rather, the system relies upon every level of
government and industry taking the initiative to develop
effective contingency plans, coordinate with the other
response partners, and exchange information on a wide
range of oil spill response issues.
For oil spills, the national system operates under the Federal
Water Pollution Control Act as amended by the Clean Water
Act (CWA) of 1977. For hazardous substances, the authority
comes from the 1980 Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) as
amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986. This report deals
specifically with contingency planning for oil pollution
response.
At the heart of the Federal role in responding to oil spills is
the National Response System. The system refers to the
hierarchy of procedures set forth in the National
Contingency Plan (NCP), which was developed to ensure
that the resources and expertise of the Federal Government
would be immediately available for oil spills or releases of
hazardous substances that are beyond the capacity of the
organization responsible for the spill or of State or local
response capabilities. A basic premise is that the spiller is
responsible for taking appropriate action.
1. How the System Works
Under the current system, the first line of defense when an
oil spill occurs is the company responsible for the spill, the
company's oil spill response contractors, local fire and police
departments, and local government emergency managers.
If needed, a variety of State agencies stand ready to support,
assist, or take over. Most of these potential responders have
their own plans and standard operating procedures, which
govern their response actions and command structures.
Regardless of the State, local, and private response
capabilities, all oil releases which cause a sheen on the
navigable waters of the United States must, by law, be
reported immediately by the spiller to the National Response
Center (NRC), which is located at the United States Coast
Guard headquarters in Washington, D.C. However, not
every report triggers a full-scale Federal response action.
Once an oil spill is reported, the NRC immediately notifies
a predesignated Coast Guard or EPA On Scene Coordinator
(OSC)-the lead agency depends on the location of the spill.
The procedure for determining the lead agency is clearly
defined so that there is no confusion about who is in charge
during an oil spill response. The OSC determines the status
of the local response and monitors the situation to determine
if greater Federal involvement is necessary. It is the OSC's
job to ensure that the cleanup, whether accomplished by
industry or local, State, or Federal officials, is appropriate,
timely, and minimizes environmental damage.
The OSC may determine that the local action is sufficient
and that no additional Federal action is required. If a larger
volume of oil is involved or the situation is more complex,
the Federal OSC may remain on the scene to monitor the
response and advise on the deployment of equipment and
personnel.
However, if the spiller or OSC determines that the spill is
beyond the capacity of the company, industry, local, or State
responders to manage-because of scope or complexity of the
response, or lack of experience and/or equipment of the
local responders; or the spiller is unknown-the OSC takes
command of the response. The OSC may call in additional
contractor support, request the services of a NOAA or EPA
predesignated Scientific Support Coordinator, call in Coast
Guard Strike Teams or EPA's Environmental Response
Team, and convene the Regional Response Team (RRT) on
the scene or by phone for counsel, to access special
expertise, or for particular logistical support. The spiller
remains liable for all actual removal costs incurred by the
Federal Government in responding to the spill; however,
initial funding may be provided from Federal pollution
cleanup funds.
The National Response Team (NRT) stands ready to provide
backup support to the OSC and the RRT during a spill
response. However, the NRT is not an operational body-
it does not direct spill responses. The NRT's primary
responsibilities include setting and maintaining national
response policy, evaluating the effectiveness of the National
Response System (NRS), and making recommendations to
improve the system. The hierarchy of response support is
set forth in the National and Regional Contingency Plans-
including agency roles, responsibilities, and action options.
These plans delineate the players and the responsibilities for
making decisions-they do not indicate what the decisions
should be.
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Z National and Regional Contingency Plans
The framework for the National Response System is the
National Oil and Hazardous Substances Pollution
Contingency Plan, commonly called the National
Contingency Plan. National planning and coordination is
accomplished through the National Response Team (NRT),
an interagency group with representatives from 14 Federal
agencies with various kinds of expertise or jurisdiction over
oil spills and hazardous substance releases and their impact
on public health and welfare and the environment.
The NCP is the plan for Federal actions, which centers on
the On-Scene Coordinator (OSC) for response to oil spills.
The NCP provides a framework of Federal responsibilities;
it does not dictate specific actions for the OSCs or the
elements of their support system. The NRT supports the
Regional Response Teams (RRTs) in aid of the OSC,
though this level of support is usually only needed for
especially significant spills.
The NCP serves as a model for Regional Contingency Plans
(RCPs), which are developed and maintained by the
13 standing RRTs, whose members are drawn from the same
Federal agencies as the National Response Team, and from
State agencies in the region. The RCPs typically contain lists
of those to call in the event of a spill for RRT and other
types of assistance, location of equipment and expertise
within the region, criteria and protocols for notification and
the like. It is up to the OSC to determine the proper action
for a spill and to call in additional resources needed within
the NCP framework. RRTs support the OSC when notified
of a spill.
While individual Federal agencies have planning
requirements for specific industries and provide incentives to
local and State governments to develop oil spill contingency
plans, the Federal Government does not supervise State,
local, or industry planning processes. In practice,
coordination throughout the system is fostered by interaction
among members of the RRTs, who represent Federal
agencies and States, and by Federal OSCs, who work with
State, local, and private officials on a regular basis. Indeed,
one value of the contingency planning process is that officials
from agencies or companies with very different missions
come to know each other as they develop contingency plans
together. In preparing the plan, they establish patterns of
cooperation and coordination among their agencies which
serve them well when they must coordinate effective
responses to actual spills.
Beyond the requirements found in the NCP for Coast Guard
contingency plans, there is no Federal requirement for State
and local oil spill contingency planning, and no uniform
Federal responsibility for knowing of the existence of such
plans or evaluating them. Title III of SARA, also known as
the Emergency Planning and Community Right-to-Know Act,
includes explicit provisions for comprehensive emergency
response planning. Although oil spills are not required to be
covered by Title III plans, the planning structure can address
oil spills. For example, all of the Local Emergency Planning
Committees (LEPCs) in New Hampshire have already
included provisions for oil spills in their plans. RRTs
coordinate plans known to them within the overall context of
their support to the OSC, but they are not specifically tasked
to identify or evaluate plans.
Origins of the National
Contingency Plan
In response to an accident involving the Torrey
Canyon tanker off the coast of England on
March 18, 1967, the first National Contingency
Plan was developed and published in 1968. More
than 37 million gallons of crude oil spilled into the
water, causing massive environmental damage.
Officials in this country decided that it was time to
develop a coordinated approach to cope with
potential spills in U.S. waters.
Congress has broadened the scope of the National
Contingency Plan over the years to cover releases
of hazardous substances, including hazardous
waste site releases requiring long-term remedial
actions as well as emergency removal actions.
The National Contingency Plan is being revised
again to implement provisions of the Superfund
Amendments and Reauthorization Act of 1986
(SARA) and to incorporate the knowledge gained
during the plan's first 21 years. The plan is a
Federal regulation administered by the EPA (40
CFR Part 300). The revised plan is expected to
be published in early 1990.
3. OSC Plans
Federal OSC plans govern Federal participation in oil spill
responses at the local level. Coast Guard OSCs are
designated for specific maritime port areas and are located
in those areas. EPA's inland OSCs are designated by region
and are generally stationed at EPA regional offices. (See
Figures 5 and 6 for Regional Response Team boundaries
and Coast Guard Districts.)
Predesignated OSCs make the initial determination of the
need for Federal spill oversight and response. EPA OSCs
often make this determination after speaking by phone to the
most knowledgeable people at the scene—usually local or
State officials or other Federal officials. Coast Guard OSCs
make some level of response to virtually every spill reported
-------
in their Captain of the Port zone of jurisdiction to make this
determination.
Coast Guard OSCs maintain individual contingency plans for
their jurisdictions. In most cases, EPA OSCs rely on their
Regional Contingency Plans rather than developing specific
OSC contingency plans.
The differences in the EPA and Coast Guard approaches to
OSC planning result from the nature of their missions.
Coast Guard stations are located in the areas they serve, and
their OSC plans are developed for a specific coastal zone or
port area. EPA's inland OSCs are responsible for an entire
region, and it is impractical for them to develop specific local
plans for all areas; there are many more communities for
them to cover, and most communities are less at risk from
oil spills than shoreline communities. Thus, most EPA
OSCs are able to respond in accordance with their basic
Regional Contingency Plans. They are also active in
providing technical assistance in local government
contingency planning upon request.
4. Other Federal Plans
Federal agencies with major landholdings and facilities, such
as the Departments of the Interior, Agriculture, Defense,
Energy, and the Saint Lawrence Seaway Development
Corporation have contingency plans for response to oil spills
within their jurisdictions. In addition, Federal agencies have
special contingency plans covering their responsibilities for
natural resources which may not be bound to a particular
location, such as endangered species, migratory birds, and
certain kinds of fishes in the event of an oil spill (for
example, Interior's Fish and Wildlife Service and NOAA's
National Marine Fisheries Service).
5. State Plans
State oil spill contingency plans are developed under
individual State authority. The Federal Government has no
authority over them. State plans are not required by the
National Contingency Plan (NCP), although they often
reference the NCP. The NCP is intended to serve as a
framework for a variety of Federal actions and levels of
involvement. Federal decisions depend on the nature of the
spill, discharge, or release, and whether the available
response to an incident is adequate and timely. The NCP
does not specifically delineate States' roles in response.
Rather, the NCP encourages States to conduct planning and
to coordinate plans through their membership in the RRTs.
The NCP similarly encourages Indian Tribal governments,
which are covered under the same terms as States by several
environmental laws, including the Clean Water Act.
State contingency plans vary widely in content and
comprehensiveness. Some State plans focus specifically on
oil spills, while others are broadet in scope, addressing oil
spills along with response planning for other types of natural
and man-made or technological hazards. Thirty-five States
have specific oil spill contingency plans, and eleven other
States have some other type of plan. In States with no
specific oil spill contingency plans, oil spill responses are
often guided by hazardous materials contingency plans. State
plans are often tied to Coastal Zone Management Plans or
to the program requirements of a particular State or Federal
agency. In several cases, State plans emphasize reporting
spills to the proper agency rather than describing response
procedures.
The following examples demonstrate the variety of State
plans:
Indiana. The State maintains a Standard Operating
Procedure that describes notification procedures and
response staff duties. The State does not have a formal oil
spill contingency plan.
New Hampshire. The State is covered by 14 contingency
plans, all updated in 1988 or 1989. They include three Coast
Guard OSC plans, seven LEPC plans (which address oil spill
response), the Seabrook Power Station Emergency Planning
Zone plan, the State Emergency Response Commission Plan,
the Portsmouth Harbor Marine Firefighting Contingency
Plan, and the New Hampshire Oil Prevention and Response
Plan.
California. The State's Oil Pollution Contingency Plan is
coordinated with Federal and local oil spill response
activities, and it is consistent with both the National
Contingency Plan and the Regional Contingency Plan
(Region IX). The State Interagency Oil Spill Committee
(the State equivalent of a Regional Response Team)
regularly invites Coast Guard and EPA officials to its
meetings.
New York/New Jersey. Both States have well defined
response plans that envision Federal assistance in the event
of a major spill. Each provides detailed guidelines on when
to notify the Federal Government of an oil spill. These
guidelines are also included in their State Implementation
Memoranda under EPA's Chemical Emergency
Preparedness Program.
Louisiana. The Louisiana State Police and the Louisiana
Department of Environmental Quality have regulations
covering discharges of hazardous materials. The State also
has an all-hazards contingency plan developed by the
Louisiana Office of Emergency Preparedness-which will be
updated to address oil spills.
Territories/Commonwealths. The Puerto Rico
Environmental Quality Board updated its Oil and Hazardous
14
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A Weekend to Remember
It's been said that bad
things come in threes, and
that is exactly what
happened one weekend in
June 1989. The Coast
Guard had committed more
than 1,000 active duty and
reserve personnel-along
with numerous cutters and
aircraft--to assist with the
cleanup of the 11 million
gallon Exxon Valdez spill,
when three additional spills
on June 23-24, 1989 posed
new threats to wildlife and
summer tourism on the
East and Gulf coasts.
Regional Response Teams
and numerous other
Federal and State agencies
were similarly involved in
the responses. The total oil
from these three spills was
close to one million gallons.
=3=3
I ll.l.l 1,1.1.1.1,1,1.1.l.l.l 11,11 III, I IM.IHI I III M.IIIII.IMI I Mil
— " .
I ll I III III III 11
Major Oil Spills
June 23-24, 1989
Rhode Island
World Prodigy.
289,000 gallons
light heating oil
Prince William Sound.
Exxon Valdez
11 million gallons
Alaskan crude
Houston Ship Channel,
252.000 gallons
heavy crude oil
Delaware River.
Presidente Rivera
300,000 gallons
#6 fuel oil
In Narragansett Bay, Rhode
Island, the Greek tanker
World Prodigy ran aground on Brenton Reef, spilling 293,000 gallons of light home heating oil. Ten miles south of
Philadelphia in the Delaware River, more than 300,000 gallons of heavy industrial fuel oil spilled after the Uruguayan
tanker Presidente Rivera ran aground. In Galveston Bay, near Baytown, Texas, more than 252,000 gallons of heavy
crude oil spilled after a barge and merchant ship collided in the Houston Ship Channel.
The Coast Guard's response to each spill was quick and effective. At the Wortd Prodigy spill, the cleanup effort at
20 different sites along Rhode Island's coastline was aided by the evaporation of 70 percent of the oil within the first
three days. By June 30th, almost all of the beaches and the shell fishing areas had been reopened.
Difficult river currents made the Presidente Rivera spill much more challenging to clean up. The oil spread
approximately 21 miles up and down the river banks. However, within the first week, all free-floating oil had been
removed, and by the 4th of July the initial cleanup of all of the affected river banks of Pennsylvania, Delaware, and
New Jersey had been completed.
Because of 2-4 foot seas, 15 knot winds, and scattered thunderstorms in the Houston Ship Channel, containment
booms could not be placed around the barge that was leaking heavy crude oil. Fortunately, prevailing winds, sea
conditions, and some well-placed deflection booms guided all of the oil into the Bayport Channel. Cleanup
operations were conducted on a 24-hour basis, and by June 29th, the Bayport Channel was reopened with only a
small percentage of oil remaining to be cleaned up in the turning basin.
As these examples show, oil spills can happen anywhere or anytime, even in the same weekend. Even though
cleanup operations continued in Alaska, quick action and hard work prevented these three spills from causing even
greater damage to the environment. In each instance, the existing Local, Regional and National Contingency Plans
were followed and were shown to be adequate in dealing with these three unrelated major spills.
-------
Region X
Seattle. WA
Region V
Chicago, IL
£ Region VIII
£§!;iw; Denver, CO
Region VII
Kansas City, KS
Region IX
San Francisco. CA
p Region IV
V Atlanta. GA
(2 Region VI
v Dallas, TX
ALASKA
OCEANIA
Hawaii
Guam
Northern Mariana Islands %
U.S. Pacific Island Territories
American Samoa ^
Regional Response Team Boundaries
13 Regions
Region 1
Boston, MA
Region II
New York, NY
Region III
Philadelphia, PA
CARIBBEAN
Puerto Rico
U S Virgin Mands
*
W'*
Coast Guard Districts
117th District
Uuneau
113th District
[Seattle
9th District
Cleveland
1st District
I Boston
Atlantic Area
New York
Pacific Area
San Francisco
fend District
St. Louis
pth District
Portsmouth
11th District
Long Beach
~^§li
14th District
Honolulu
8th District
New Orleans
|7th District
Miami
Guam |§
Northern Mariana Islands vr
Trust Territory ol tfta Paallc Islands
American Samoa
Puerto Rtco
us Vigin islands
16
-------
Michigan's Plan to Improve Spill Prevention Efforts
and Response Capabilities
On May 23,1989 the State of Michigan's Office of the Great Lakes, Department of Natural Resources, submitted
an interim report to Governor James J. Blanchard outlining a plan to improve Michigan's spill prevention efforts
and response capabilities. The Office of the Great Lakes worked with a number of Federal, State, and local agencies
to develop this report, entitled "Michigan's Great Lakes Preparedness for Oil and Other Hazardous Material Spills,"
As a result of this report, the Governor appointed a task force to implement the recommendations that were
contained within the report
The following examples are just a few of the recommendations that were offered in this report
1. Enact legislation to facilitate local implementation of new Federal requirements for
emergency planning and training.
2. Establish a permanent revolving fund for environmental cleanup of spills and for
state-of-the-art cleanup equipment.
3. Establish a unified, coordinated environmental emergency response system as part
of an overall State emergency system, complete with a central command post, a 24-
hour-per-day 800 number dispatch, and response teams with environmental expertise.
4. Establish a State training and certification program for hazardous materials response,
including spills into waters of the Great Lakes.
5. Prepare contingency plans for containment and cleanup where needed, compile
information about cleanup technologies appropriate to the Great Lakes, and
computerize relevant chemical information.
Hazard assessment, automatic early warning devices, pollution prevention inspections, pilotage of vessels by Great
Lakes experts, and a uniform spill notification system were also recommended. In all, 28 recommendations were
offered in this report.
Substances Contingency Plan in 1988. The U.S. Virgin
Islands Department of Planning and Natural Resources
maintains a comparable plan. EPA Region II staff provided
direct technical assistance in the development of both plans
to ensure the coordination and integration with Federal
response plans for the Caribbean.
6. Local Community Plans
The NCP provides specifics only for the Federal role in a
spill as it may be needed, rather than providing requirements
for specific levels of response from local communities.
Individual OSCs are a technical assistance and
communicating link between communities and the national
response system. In 1986, Title III of SARA initiated a
requirement for Local Emergency Planning Committees
(LEPCs) to be established, and to develop Local Emergency
Response Plans for chemical hazards in their areas.
Although mandated by Federal law, these are local plans and
generally apply to releases of hazardous substances.
LEPC plans may cover oil spills as well as releases of
hazardous substances although few plans have done so at this
point. Several RRTs reported that LEPC plans currently do
not contain specific provisions for responding to oil spills, but
that some State Emergency Response Commissions have
called for oil spill coverage in future revisions of the LEPC
plans.
7. Industry Plans
The National Contingency Plan does not require RRTs to
maintain information about industiy contingency plans.
Consequently, RRTs rarely have consistent detailed
information about local company spill response plans, except
as the information comes to them through spedfic program
requirements of individual Federal and State agencies.
However, industry spill response plans fall into eight basic
categories:
Worldwide/Regional plans are general management
plans with a global perspective for corporate use.
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National/Sub-continent plans are based on provisions of
national legislative and regulatory requirements.
Geographic plans, for example on Delaware Bay and
Puget Sound, maintain response strategies and
protective planning for specific areas, highlighting
sensitive environmental resources.
Facility/terminal plans cover particular transfer or
storage sites.
Vessel plans address specific vessels or classes of
vessels.
Individual response team plans are separate plans
describing emergency response, salvage,
communications, and "strike team" type activities.
Oil spill cooperatives are usually established for a
specific geographic area and include equipment listings
and notification procedures in the event of an oil spill.
Public relations plans are often developed in two parts,
one for crisis management at the corporate level for a
broad perspective, and the other operational, with
incident-specific procedures.
When a company is prepared and is capable of carrying out
a proper spill response, it has been Federal policy to allow
it to do so, with the Federal OSC monitoring the response
and providing technical assistance and oversight.
In addition to industry initiatives, there are Federal pollution
prevention regulations that require certain private companies
to develop oil pollution response plans. The degree of detail
required in each plan varies with the type of facility and its
operations. The Coast Guard requires a certain level of
planning for shoreline facilities, thus, their OSC plans are
likely to include information about waterfront oil transfer
facility plans and cleanup cooperatives, especially when these
facilities or activities are a significant feature within their
response zones.
Federal regulations also require other oil storage facilities
and nontransportation related terminal facilities to maintain
Spill Prevention Control and Countermeasures (SPCC)
Plans. However, RRTs have little information about specific
SPCC plans, and the adequacy of individual plans is not
always known to the regions, nor is information in such plans
coordinated consistently with surrounding jurisdictions.
The Interior Department's Minerals Management Service
(MMS) requires all Outer Continental Shelf oil and gas
operators to maintain oil spill contingency plans tailored to
each activity and site--and all potential conditions. The plans
must be approved by MMS and coordinated with other
Federal and State regulatory agencies with the Coast Guard
reviewing the response portions.
The Department of Transportation's Office of Pipeline
Safety regulates the safety of pipelines transporting oil and
petroleum products in interstate and some intrastate
commerce. In the context of oil spill contingency planning,
this regulatory scheme can be characterized as addressing
spill prevention through the oversight of pipeline design,
construction, testing, operations, and maintenance.
The regulations require pipeline operators to protect public
health and safety in the event of an oil spill. Often, the first
concern is to prevent or respond to fires or explosions. In
practice, however, pipeline operators are often involved in
efforts to protect the environment as part of their response
to hazardous liquid pipeline emergencies.
While pipeline operators are not required to develop specific
cleanup procedures, they often play an integral part in
cleanup operations. For example, in a recent pipeline
discharge outside of Philadelphia, the pipeline operator was
involved in the effort to keep the spilled product from
infiltrating the Philadelphia water system. In addition,
pipeline operators are required by Federal regulations to
keep fire, police, and other appropriate public officials
informed about the locations of pipelines and the types of
product that are transported. The operator is required to
inform public officials about its capabilities in the event of a
hazardous liquid pipeline emergency and to obtain
information about the responsibilities and resources of public
agencies in such an emergency. In addition, the operator
must establish procedures for communicating with public
officials in the event of a pipeline emergency.
Each pipeline operator is also required to develop and
maintain a manual that contains procedures to be followed
in pipeline emergencies. The procedures include guidance
for calling appropriate public agencies if a pipeline
emergency occurs and plans for coordination with public
agencies both in the preplanning stage and during actual
emergency responses.
8. Industry Cooperatives
In order to ensure readily available oil spill response
equipment and personnel, industry facilities rely heavily on
cooperative organizations, on other companies with similar
needs, and, sometimes, on commercial cleanup firms.
Furthermore, in variants of this "co-op" model, such groups
can include local governments, State and Federal agencies,
university experts, and environmental and other citizens
groups.
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The oil industry is also actively pursuing the issue of
enhancing existing cooperative response capabilities. The
American Petroleum Institute's recently created Committee
on Environment and Health will inventory existing
cooperatives and make recommendations for improvements
as well as the creation of new cooperatives.
Region VI reports many local co-ops have been established
for geographic areas where there is a continuing threat of
discharges by industry and transportation sources, such as
around Beaumont/Port Arthur, Houston Ship Channel,
Texas City, and Freeport (all in Texas). One co-op was
prominent in the response to the Phillips Chemical disaster
in Pasadena, Texas, in the fall of 1989. Coast Guard OSCs
participate with these organizations during drills and provide
expertise during responses. Several oil pipeline companies
are involved in these cooperatives. For example, there is the
Clean Channel Association in Houston and the Clean River
Association on the lower Mississippi River.
In Paducah, Kentucky, a local co-op organized primarily for
its members assists nonmember organizations on a case-by-
case basis. Alaska and California have a number of co-ops,
but problems with co-op response are often encountered if
spills involve nonmembers.
In the Los Angeles-Long Beach area, there are two large co-
ops that have agreed to help each other if called upon. The
co ops are well-equipped and have 4 response vessels that
are over 130 feet long.
In New York, the Clean Harbor Cooperative asserts that it
has sufficient equipment to deal with an estimated
1.7 million gallon oil spill. Equipment stocks include 9 miles
of containment boom, 6 work boats, 15 deployment boats,
7 self-propelled skimmer boats, dispersant spray equipment,
a high volume oil-transfer system, a mobile command post,
as well as other equipment. Its resources are available to
nonmembers, including the Coast Guard, on a rental basis.
¦ ¦
U.S. Coast Guard photo
OIL RECOVERY IN A RIVER
Booms assisted in removing oil spilled into the Monongahela River in Pittsburgh after an Ashland Oil Company storage
tank collapsed in January 1988, spilling a million gallons of diesel oil. Booms divert oil along a river until it can be
collected by mechanical recovery equipment.
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In Louisville, KY, 106 marine oil, chemical, and general
industry companies participate with local, State, and Federal
agencies in one of five pollution co-op groups. The Coast
Guard OSC recommends to all facility operators in the area
that they participate in such groups in order to satisfy
response readiness requirements.
In Memphis, Tennessee, the Coast Guard OSC spearheaded
a co-op that includes industry members as well as Federal,
State, and local government representatives, and the
academic community. The OSC feels that this is an
important first step in establishing essential liaison,
coordination, and support between concerned companies,
agencies, and organizations.
Most co-ops are formed as non-profit organizations and as
such receive a State permit for operation. The State may
add provisions as requirements of the permit that the
equipment not be removed from the State. If more States
make this a practice it could severely hinder future
responses.
In Alaska, State requirements have had an impact on an
OSC's ability to use equipment owned by the oil spill co-
ops that were formed in response to State requirements for
industry oil spill response capability. If equipment in support
of a State-approved plan is removed from a terminal area in
order to respond to a spill elsewhere, the State can shut
down the terminal until the response equipment is returned
or replaced. There is an understandable reluctance on the
part of these co-ops and the companies supporting them to
enter into any mutual aid or contract agreements with
government agencies or others if it could place their primary
operations in jeopardy.
9. Coordination of Contingency Plans
The NCP describes the interlocking nature of the National,
Regional, and OSC Contingency Plans, and emphasizes the
need to coordinate these Federal plans with existing non-
Federal plans (e.g., State plans, Indian Tribal government
plans, LEPC plans, and industry plans). There is wide
variation in the amount of coordination between Federal and
non-Federal contingency plans.
When planners are knowledgeable of the capabilities,
responsibilities, and authorities of the responders at all levels
of government and industry in the immediate neighborhood,
response actions will be more effective. For example, EPA
Region VIII has developed a local plan entitled the "North
Platte River Federal Local Oil and Hazardous Substances
Pollution Contingency Plan," (a similar plan exists for the
Colorado River). It covers U.S. waters and adjoining
shorelines of the North Platte River in Wyoming. The plan
is complementary to and supports the Wyoming Oil and
Hazardous Substances Pollution Contingency Plan, the
Wyoming Natural Disaster Plan, and the National and
Regional Contingency Plans, thus allowing for a well-
coordinated response in the event of a release.
Regional Response Teams routinely learn about planning
and response resources within their region through
interaction with agency representatives during RRT activities.
Many RRTs and Coast Guard OSCs reported that personnel
shortages-both in number of staff and in oil spill training
and experience-hamper the ability of member agencies to
coordinate their planning with that of other responders. As
a result, with few exceptions, RRTs cannot readily determine
the relationship of their plans with overlapping or adjacent
non-Federal plans.
The Coast Guard OSC in the Tampa-St. Petersburg, Florida,
area is involved in numerous spill response planning
initiatives. The list provides a graphic look at the range of
coordination possibilities. It includes the Hazardous
Materials Response Committee, the Local Emergency
Planning Council, the Tampa Bay Spillage Committee, the
Hillsborough County Emergency Operations Center, and the
Pinellas County Emergency Operations Center.
The amount of interregional cooperation varies among the
regions; some indicated considerable cooperation, others
alluded to none. Coordination is usually facilitated by EPA
and Coast Guard RRT Co-chairs and other Federal agency
representatives who serve on more than one RRT because
a single Coast Guard district or other agency's regional
boundary overlaps several Federal regions. Interregional
coordination can be particularly important for regions such
as the eight-State southeastern region which borders directly
on four other Federal regions and, across the water, on the
Caribbean Region. Virtually all of the members of the
Caribbean RRT are also members of other RRTs in
Regions II or IV. However, the geography of the Caribbean
region does not lend itself readily to interregional oil spill
response support arrangements.
10. Interstate, Interagency, and Federal- State
Agreements
Interstate commissions and cooperatives can play a
significant role in oil spill preparedness and prevention.
Existing interstate compacts may provide pollution response
coordination along with other compact purposes. The Upper
Mississippi River Basin Association (UMRBA) and the Ohio
River Sanitary Commission (ORSANCO) provide two
significant examples. Other interstate cooperatives include
the Great Lakes Commission, the Montana-Wyoming Oil
Coordinating Committee, and the Four Corners Cooperative
in the Southwest.
These groups can develop and maintain oil spill contingency
plans and offer guidance, technical assistance, and
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information exchange among their members. ORSANCO,
which has been in existence since the 1940s, was recently
involved in the response and follow-up to the Ashland Oil
Company spill. ORSANCO has since been strengthening its
planning efforts with its multistate membership. It has
developed a resource manual which provides information on
locks, dams, and water intakes. It also has a plan for the
notification of States and water users in the event of a spill.
The next version of the plan will include a catalogue of
private sector response resources. UMRBA's plan includes
notification procedures and assignments of tasks to State
agencies. Its resource manual includes river maps,
identification of potential spill sources, information on locks
and dams, lists of response equipment maintained by
waterfront facilities, and details on sensitive environmental
areas.
The New York Harbor area offers an example of effective
communications systems between agencies. Oil spill
response agencies and organizations have joined together in
a Multi-Agency Local Response Team (MALRT) that has
proved effective in coordinating response efforts. Team
members include the Marine Floatable Debris Work Group,
the New York Harbor Traffic Management Advisory
Committee, the New York Harbor Operations Committee,
the Clean Harbors Cooperative, the Hazardous Materials
Advisory Council, and the New York Shipping Association.
Another example is the Philadelphia COTP MALRT, which
has been very active in the Delaware River and Bay.
11. Coordination with Foreign Countries
The United States has a number of bilateral and multilateral
agreements and joint contingency plans with neighboring
countries to address notification of and response to oil spills.
In fact, every region except Regions IV and VII shares a
border with a foreign country. (A fuller description of these
plans and agreements is in Appendix C.)
The Canada/U.S. Joint Marine Pollution Contingency Plan
covers emergency response activities in a basic plan, with five
specific annexes addressing the Great Lakes, Atlantic Coast,
Pacific Coast, Beaufort Sea, and Dixon Entrance of the
Pacific Coast. (An inland plan is under development.)
Additionally, Washington, Alaska, and Oregon approved an
oil spill Memorandum of Cooperation with British Columbia
in August 1989.
The Agreement of Cooperation Between the United States
of America and the United Mexican States Regarding
Pollution of the Marine Environment by Discharges of
Hydrocarbons and other Hazardous Substances provides for
the establishment of joint U.S.-Mexico contingency plans.
Two of these are now in draft form, the Gulf of Mexico and
the Pacific Ocean. The latest cooperative effort between the
countries was a joint exercise in the Gulf of Mexico hosted
by Mexico in November 1989. The United States and
Mexico have also approved a joint agreement on cooperation
for the protection and improvement of the environment in
the border area. A joint U.S.-United Mexican States
Contingency Plan for Accidental Releases of Hazardous
Substances Along the Border is also in effect for oil and
other pollutants spilled along both countries' inland borders.
There have been meetings and exercises held on the Joint
Response Team level, including a yearly OSC/JRT major
simulation involving response personnel of both countries.
The U.S./USSR Joint Contingency Plan Against Pollution in
the Bering and Chukchi Seas, signed on October 17, 1989,
grew out of a project begun under the current U.S./USSR
environmental agreement. Efforts now continue by regional
working levels at Juneau, Alaska, and Vladivostok to develop
an operations annex containing the contingency planning
elements common to other joint contingency plans.
The United States has an agreement with Bermuda instituted
in 1976 as a result of several tank ship groundings and other
pollution incidents there. The United Kingdom is
considering a similar arrangement for pollution response in
the British dependent territories of the Caribbean.
The United States and France have been partners in the
Marine Pollution Control Project. This is a technical
information program rather than a response agreement. The
project addresses all aspects of marine pollution prevention
as well as response and contingency planning.
In the Caribbean there are multilateral agreements involving
the United States in three separate but related efforts:
By convention, the United States has agreed to
cooperate with and assist nations in the region on
marine pollution issues.
By protocol, the United States participates in a
subregional oil spill contingency plan to provide
protection for the U.S. Virgin Islands and Puerto Rico.
The Coast Guard provides an officer to the International
Maritime Organization, who serves as a regional
consultant on marine pollution, port safety, and security
for the wider Caribbean.
In the South Pacific, the United States is signatory to the
Convention for the Protection of the Natural Resources and
Environment of the South Pacific Region. Although the
Convention is currently not in force, the U.S. is in the
process of ratification and the Coast Guard has been
providing response protection to U.S. interests in the region.
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Internationally there is support to develop, under the
auspices of the United Nation's International Maritime
Organization, a new convention on preparedness and
response to oil spill emergencies from ships. This effort is
a direct result of the Presidential Initiative at the 1989
Economic Summit. The Coast Guard is leading the effort to
complete the Convention by the end of 1990.
The Navy has worked with foreign nations to address their
potential for oil spills, and has prepared regional contingency
plans which cover all Navy shipping operations in U.S.,
international, and foreign waters. The Navy has also
enhanced its own response capabilities by prestaging
response equipment strategically across the globe.
C. Roles and Preparedness at the Regional, State,
and Local Levels
Regardless of how careful the planning, the true test of oil
spill preparedness is how well an actual response is carried
out.
Under the NCP, the Coast Guard has primary responsibility
for the coastal zone, which refers to all U.S. waters subject
to tidal influence, the navigable waters of the Great Lakes,
and other specified navigable waters. As such, the term
coastal zone also includes certain inland waters. The
Environmental Protection Agency has primary responsibility
for all other inland areas. Precise boundaries are
determined by EPA/USCG agreements and are identified in
Regional Contingency Plans.
As noted earlier, the Coast Guard and EPA approach local
contingency planning differently because of the nature of
their missions. Coast Guard OSCs are located in port areas
and consequently develop OSC plans for their particular
areas. By contrast, the jurisdiction of EPA OSCs extends
over entire regions. Thus, EPA OSCs typically utilize
Regional Contingency Plans to provide a framework for oil
spill response in their regions, rather than developing OSC
plans. Their primary task is to work with States and local
communities to ensure that Federal resources are
incorporated in local oil spill response planning.
1. State Role in Oil Spill Response
The Federal oil spill response program established by
Section 311 of the Clean Water Act is the primary focus of
this report, but State oil spill response programs also have an
important place in the overall coordinated response
framework—along with those of private industry. Each State
has a vital interest in protecting the health of its citizens and
its natural resources. Some States benefit directly from oil
production, transportation, and storage, and all rely on oil to
fuel their industries and for many other purposes. Thus,
each has a role in ensuring that adequate resources are
Federal Response Capabilities
Stretched to the Limit
The Exxon Valdez spill of 11 million gallons of
crude oil in Prince William Sound was the largest
spill in U.S. history. The magnitude of this spill
severely overloaded the Federal, State, and
industry response capabilities.
NOAA's Scientific Support Coordinator (SSC)
network was one particular program that was
stressed to its limits. Because NOAA was
maintaining 20-25 people in Alaska to support the
Federal On-Scene Coordinator (OSC) throughout
the summer, they, like other agencies, rotated
their people on Alaskan assignments. This
approach, however, left the rest of the coastal
areas with limited SSC support, which became
apparent during June when three major spills
occurred within one week.
One SSC had just returned from Alaska to the
East coast when she was called to report to Rhode
Island. Before she could board the plane in
Washington, D.C., she was re-directed to
Philadelphia where another major spill, the
Presidente Rivera, had just occurred. Another
SSC had just returned from Alaska and was
similarly tracked down from vacation in order to
assist on the Rhode Island spill. This assignment
was again changed to Philadelphia after the
amount of support required for the Rhode Island
spill was re-evaluated. These people were asked
to continue 18-hour days and 7-day weeks after
having previously worked at this same level for
several weeks in Alaska.
The two Coast Guard Strike Teams were similarly
spread thin because of multiple spills. The Pacific
Area Strike Team had 10 personnel in Valdez and
the Atlantic Area had eight. When the three spills
occurred in June, 12 Atlantic Area Strike Team
members were sent to Rhode Island and sue went
to Philadelphia. As a result, the Atlantic Area
Strike Team only had six of 36 members or 17
percent of their personnel available to respond if
they had been needed at another spill.
available to address spills within their borders and each
shares in the responsibility for preventing and mitigating the
effects of oil spills. While there is no Federal mandate for
States to develop oil spill contingency plans, most States now
have their own plans. Coordination between State and
Federal plans varies widely.
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2. Coast Guard Response Capabilities for Routine
Spills
Coast Guard OSCs report that they can handle most small,
medium, and major oil spills in their port areas. However,
all Coast Guard OSCs said they would face shortfalls in
responding to their worst-case scenarios.
A number of OSCs noted that they face equipment and
personnel shortfalls as a result of medium or even minor
spills if their staffs are involved in other pressing port area
activities or if the spill is particularly difficult to clean up.
Under the Coast Guard's multimission approach, Marine
Safety Offices handle a wide range of responsibilities.
Stations and individuals have specific tasks such as spill
response, port security/safety, search and rescue, inspection,
and licensing. If an oil spill occurs, personnel may have to
be reassigned from other duties. In these cases, the
multimission responsibilities of Coast Guard OSCs can
impact spill response. For example, the Captain of the Port
(COTP) in Grand Haven, Michigan reported:
There is only one dedicated COTP staff member
[to oil spills], and he is sometimes borrowed by
operations to stand in as Search and Rescue (SAR)
controller. The COTP relies on the group's
outlying SAR stations to provide first response [to
spills]. With the current manning levels of the
stations, if the boat is underway, there are not
enough personnel remaining to respond to a
pollution incident. COTP Grand Haven also has
only one vehicle capable of pulling their pollution
response trailer, and this vehicle is shared with
other users at the unit.
Another example involves a series of four spills from one
tank ship in Portland, Oregon, during a three-week period in
late November and early December 1988. The largest of the
spills was only classed as a medium discharge, and the other
spills were much smaller. However, the fact that the spills
occurred so close together, complicated by the lack of
cooperation from tank ship personnel, severely strained the
MSO's pollution response personnel, as well as the unit's
marine inspection, investigation, and boat operations
activities.
The Coast Guard OSCs on inland waters such as the Great
Lakes and the Mississippi River system generally experience
shortfalls in any spill above a medium size (on inland waters
a medium oil spill is 1,000 to 10,000 gallons; a spill of more
than 10,000 gallons is classified as a major spill). The
contingency plan report summary prepared by the Ninth
Coast Guard District units stated this succinctly:
The staffing levels at Ninth District Marine Safety
units are such that a medium pollution incident
would quickly overwhelm them after just a few
days.... While it may be unrealistic to attempt to
staff each of these offices at the optimum level, this
does illustrate that should a significant incident
occur, sufficient response resources do not exist
within the district and response units would have to
be augmented quickly.
Private contractors that specialize in oil spill response often
have limited resources as well. The Grand Haven COTP
report noted that no local contractors have the capabilities
to respond to "anything more than a small spill."
OSCs located in the larger coastal area ports, where there
are large Coast Guard MSO/COTP offices, can often
respond to major spills (over 100,000 gallons in coastal
areas). MSO Corpus Christi, Texas, reported: "The average
spill and the largest or most complex spill within the zone in
the last ten years have been determined to be within the
capabilities of the Zone." In fact, the MSO was able to
respond to a 600,000 gallon crude oil spill from the Nord
Pacific in July 1988.
However, in a worst-case spill, the Corpus Christi MSO
reported that it would experience shortfalls in personnel,
public affairs capabilities, equipment response time, and
other areas. The MSO noted that the Nord Pacific spill took
place in an accessible location for cleanup and under
favorable weather conditions. It is important to point out
that the same spill in a different location was one of the
MSO's worst-case scenarios.
3. Planning, Safety, and Prevention at the Local Level
Some local port authorities and oil transportation companies
have oil spill contingency plans. The quality of the plans
usually depends on the size of the port or company and its
resources. These plans may or may not be coordinated with
other government agencies.
Oil spills into the inland waters frequently pose serious
problems because of the potential for contamination of
public drinking water intakes for large communities, along
with contamination of aquatic organisms, oiled water fowl,
and toxicity to wildlife populations exposed to the oil.
Although a large number of inland oil spills are associated
with river transportation, a major concern for future oil spills
in the inland areas is from pipelines and above-ground
storage tanks.
The remote locations of many pipelines make detection,
discovery of rupture, and physical response difficult.
Pipeline operators are required to notify the National
Response Center of any unauthorized discharge of oil into
U.S. waters, and to remove the discharged oil under the
Federal Water Pollution Control Act. However, these
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regulations are directed toward the prevention and control
of oil pollution, and do not include requirements for pipeline
operators to prepare specific oil spill contingency plans.
Safety regulations issued by the Department of
Transportation (DOT) Research and Special Programs
Administration under the Hazardous Liquid Pipeline Safety
Act of 1979 include provisions for interstate pipelines
transporting oil, onshore or offshore. These regulations do
not require pipeline operators to prepare oil spill
contingency plans. However, the operators are required to
follow federally prescribed procedures for recognizing and
responding to pipeline emergencies and to conduct training.
All of these requirements apply to approximately 208
operators, covering about 155,000 miles of pipeline.
Regulations issued by DOT enable States to assume
responsibility for implementing safety regulations for oil
transportation pipelines. In 1988, six States—Arizona,
California, Minnesota, Oklahoma, Texas, and West
Virginia-assumed responsibility for exercise, inspection, and
enforcement authority over intrastate oil pipelines. Alabama,
Louisiana, and Mississippi perform only pipeline inspections
and request that the Federal Government take enforcement
actions. The State of California has also been certified to
assume inspection over interstate oil pipelines. The
regulations established by these States are at least as
stringent as Federal regulations.
Prevention is an integral part of the Coast Guard's marine
safety mission and is woven into every aspect of the
commercial vessel and port safety programs. Safety and
prevention are incorporated into regulations addressing
vessel design, licensing, and testing of vessel officers,
navigation aids and vessel traffic systems, and cargo transfer
operations. There are also specific regulations addressing oil
spill prevention.
U.S. Coast Guard photo
NATURAL DISASTERS CAN CAUSE OIL SPILLS
Hurricane Hugo ripped through storage tanks at the Hess Oil Virgin Islands complex in September 1989, releasing 420,000 gallons
of diesel oil.
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FIGURE 7
Ages of Above-Ground Storage Tanks
7%
¦ 0-10 Years
^ 11-20 Years
H 21-30 Years
^ 31-40 Years
~ 41+Years
¦ Unknown
Another major concern is the potential for major releases
from above-ground storage tanks. Significant numbers of
these tanks are more than forty years old. (See Figure 7.)
EPA regulations (40 CFR 112) require that owners and
operators of non-transportation related facilities, including
facilities with above-ground storage tanks, that may be
reasonably expected to cause a reportable oil spill to the
navigable waters of the United States prepare and implement
a Spill Prevention, Control and Countermeasures (SPCC)
Plan. The SPCC Program currently focuses on preventing
oil spills to the navigable waters, and, when fully supported,
has been viewed by a broad spectrum of government and
industry representatives as one of the most effective
prevention programs that the government has established.
However, the commitment to monitoring for compliance
with the requirements of the program has declined
dramatically. Following the Ashland Oil spill, an interagency
government task force recommended that the Federal
Government restore its commitment to this program and
expand it to include requirements for facility-specific oil spill
contingency planning.
4. Minerals Management Service
The Outer Continental Shelf (OCS) is the location of
numerous oil and gas production platforms and drilling rigs.
The highest density of these platforms and drilling rigs is in
the Gulf of Mexico and off the coast of California. OCS
spills are different from tanker spills in that tanker spills can
occur on any navigable waters, usually during a short period
of time. OCS spills, on the other hand, are confined to fixed
locations where oil characteristics, currents, and wind
patterns are known. Also, the rate of flow from an OCS site
is much slower than from a typical tanker spill, with the
average flow from wells being approximately 7,560 gallons
per day. Only seven OCS platforms produce more than
126,000 gallons per day. A major blowout of 210,000 gallons
per day would require over 50 days to release the amount of
oil released from Exxon Valdez in a few hours. Therefore,
the worst-case OCS spill would generally occur at a much
slower rate than a typical tanker spill, and would offer the
potential for recovery of greater amounts of the spilled oil.
A task force of MMS experts from headquarters and
regional offices evaluated oil spill contingency planning,
training, drill and inspection requirements and procedures
for each OCS Region (Alaska, Pacific, Gulf, and Atlantic),
and identified possible modifications or alternative practices.
The task force concluded that current MMS regulations
provide a sound basis and framework for preventing and
reporting oil spills, and training and planning for oil spill
response. Areas in which the task force made
recommendations include: improving spill response
equipment performance, reviewing collision avoidance
systems in high-density shipping areas, making new
equipment requirements as appropriate, reviewing all OCS
oil spill plans to ensure an appropriate response to the
largest possible oil spill, further studying the effectiveness of
instrumentation for rapid detection of pipeline spills,
developing more extensive oil spill drill programs, and
pursuing a more effective strategy for imposing civil
penalties.
5. Department of Defense
The Department of Defense (DOD) is the Nation's single
largest petroleum user. The Department relies on domestic
petroleum production and transportation systems to supply
and deliver more than 14.7 million gallons of product per
day. This includes jet fuels, distillates, automotive gasolines,
and residuals. In a typical year, the Department experiences
about 6 major spills, 30 medium, and 500 minor spills.
The Department retains cleanup responsibility for all spills
from its facilities. It has had an extensive oil spill prevention
and contingency program since 1972. DOD policy is to
reduce the likelihood of oil discharges, to respond rapidly to
minimize the damage caused by discharges, and to assist
other Federal response efforts consistent with DOD
operational requirements. About 1,100 DOD installations
are required to have spill prevention control and
countermeasures (SPCC) plans and spill contingency plans.
Spill contingency plans must be compatible with EPA or
Coast Guard contingency plans. While the DOD
components review their plans periodically and report in the
annual Defense Environmental Status Report on the number
that are incomplete, there has been no Department-wide
evaluation of their planning effectiveness. Experience has
shown, however, that each facility can effectively respond to
most of its spills. In addition, more resources are available
within the Department of Defense to supplement its
response capability, if necessary.
The Department can provide spill response resources to civil
authorities through the Department of the Army's Director
Source: Entropy Limited Technical Report RN-623
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of Military Support (DOMS). A DOMS Joint Task Force
provided support to the Coast Guard during the Exxon
Valdez oil spill under direction from the President and the
Secretary of Defense. The Department can provide support
to other Federal agencies through interagency agreements,
such as the existing agreement between the U.S. Navy and
the U.S. Coast Guard for cooperation in oil spill cleanup
operations and salvage operations. The Navy Supervisor of
Salvage (SUPSALV) maintains approximately $100 million
of oil spill response and salvage equipment. The Navy has
successfully deployed equipment to nearly eveiy major spill
in the last 15 years. On June 19, 1989, SUPSALV sent a
letter to all concerned agencies describing its equipment and
how to access it.
Other examples of available support include: Army
transportation and communications assets; Corps of
Engineers dredges, water monitoring network, and contract
management capabilities; and Air Force world-wide heavy
airlift capabilities. In addition, the Army Corps of Engineers
has both responsibilities and expertise in dealing with spills
reaching locks and dams, rivers, or reservoirs. Governors
can direct State National Guard units to assist in large spill
responses.
6. Maritime Administration
The United States Maritime Administration (MARAD)
oversees the operation of the National Defense Reserve
Fleet. This is an inactive reserve fleet of 312 vessels which
could be activated to meet shipping requirements (such as
movement of troops or military equipment and supplies)
during national emergencies. While these vessels are not
normally operating, let alone engaged in trade or the
carriage of oil cargo, the residual fuel and lube oils aboard
each vessel do offer the potential for oil spills. The
estimated amount of these oils is approximately 80,000
gallons per vessel. The principal locations for MARAD
vessels are: Beaumont, TX, Fort Eustis, VA, and Benicia,
CA, with approximately 50 other vessels located at various
other U.S. ports and in Yokohama, Japan.
MARAD is revising its Emergency Response Plan for Oil
Spills/Hazardous Substance Spills. The plan was reviewed
by the Coast Guard's Marine Environmental Response
Division in October 1989, and proposals arising from the
review are being incorporated into the plan. Coast Guard
OSCs and State and local officials have also been asked to
review the plan. The review was expected to be completed
by December 31, 1989.
The plan requires each of the designated MARAD Local
Action Coordinators to maintain and update area-specific
Emergency Response Plans, which prescribe immediate
actions for MARAD personnel in response to a spill from a
MARAD vessel until the Coast Guard assumes the
responsibility for spill response. MARAD headquarters
intends to review each of the Local Emergency Response
Plans annually.
7. National Response Team: Lessons Learned and
Current Plans
The roles and responsibilities of the NRT are described in
the National Contingency Plan along with the other elements
of the system designed to center on the needs of the OSCs.
The NCP makes provision for coordination, involvement, or
interface with all levels of government and the private sector.
The NRT's primary responsibility is to oversee the system so
that lessons learned in an incident are transmitted
throughout the system, including recommendations for
improvements in policy and operations. The NRT was
functioning in this capacity in its preparation of the May
1989 Report to the President (the "30-day Report"). This
report on Oil Spill Contingency Planning further implements
its charge under the NCP.
The Exxon Valdez incident provided the NRT with a ready-
made worst-case scenario in that it taxed the system beyond
any previous spill in its jurisdiction. Paradoxically, however,
while the system was sorely stretched, and many lessons were
learned, some of the system's strengths also became
apparent.
The media reported perceptions that the information
available from the Federal Government was confusing or
contradictory, with the inference being that the Federal
Government was somehow lacking in timely and strong
response to the incident.
In fact, the NRT did convene frequently, receiving up-to-
the-minute briefings on the status of the response effort,
exchanging information on individual agency efforts and
concerns, compiling lessons learned and developing
recommendations for the Report to the President, and
planning implementation of those recommendations.
However, Federal agencies did not always operate effectively
through the NRT as provided for in the NOP. Federal
member agencies also operate under their individual
authorities for incident response. NRT members and staff
relied heavily upon the well-established network of
knowledgeable colleagues. A central information center was
established to provide a clearinghouse for information
developed through many agencies' sources. Many NRT
members and staff associates worked within their agencies
doing the tasks that implement sound crisis management:
reporting, communicating policy and technical information,
canvassing for equipment and supplies and personnel,
providing liaison with State and local officials, researching
the answers to questions about jurisdictions, authorities,
liability, funding sources, accounting documentation, worker
health and safety, shoreline cleanup options, and
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environmental effects. Many such efforts went unseen or
unknown.
In fact, it was far from the worst-case scenario that could be
designed.
The media, and thus the public, did not know of the
existence of a National Contingency Plan, a National
Response Team, or a Regional Response Team--they were
not aware of the National Response System working for
them.
Newly appointed senior officials were overwhelmed by the
rush of questions about all aspects of a significant
environmental event which they were learning about under
the stress of both congressional and media questioning.
Airing the answers to questions raised new questions,
whether by coverage of Congressional hearings, network
news, or newspapers.
Effective use of the National Response System relies on the
expertise of industry, local responders. State response
officials, and individual RRT and NRT members to be
available and effective throughout the length of the incident
response period-operating in accordance with the NCP.
The extraordinary size and scale of the Exxon Valdez spill
response involved people who did not know to look to the
National and Regional Response Teams for answers to their
questions. They did not understand that the NCP provides
a strategy for coordinating the efforts of this large universe
of interested parties.
Inland
Relative Spill Sizes
Coastal
< 1,000 gallons Minor
1,000-10,000 gallons Medium
> 10,000 gallons Major
< 10,000 gallons
10,000-100,000 gallons
> 100,000 gallons
The size of the discharge from the Exxon Valdez, the
suddenness of its release-over 10 million gallons in a very
few hours-caused a buildup of national attention over a
weekend into an explosion of requests for information and
answers and stories that did not abate for many weeks. The
unfolding scenario suddenly involved all levels of government
and industry management. Because spills of this magnitude
are infrequent, many people were involved in oil spill
response decisions for the first time, learning the National
Response System and the National Contingency Plan as they
went along. It was a scenario that had plenty of elements of
a possible worst-case. Yet, less than half the oil on the ship
was spilled, no gale force winds or subfreezing temperatures
hindered the early response, no human life was lost during
the early emergency days, there was no explosion, or fire.
The NRT has the expertise to assist in the flow of
information to concerned senior officials in the Executive
Branch, to Congress, to Governors and Mayors, and to the
press. The NRT has the expertise and the contacts to
exercise effective leadership with national or international
organizations on appropriate roles and responsibilities
throughout the duration of a cleanup effort.
One of the lessons learned during the past year is that the
NRT must not only carry out its responsibilities in support
of oil spill response, but that it must also ensure that
Federal, State, local, and industry response officials~and the
public at large-know that the National Response System is
in place and understand what it can do.
The NRT conscientiously performs its responsibilities, which
include reviewing lessons learned, making recommendations,
and fostering actions that will improve contingency planning
and other measures that enhance the Nation's preparedness
to deal with all sizes of oil spills. The NRT annual work
plan for fiscal year 1990 contains specific work items in
response to recommendations from the 30-day Report as
well as items foreshadowing the conclusions of this report.
8. Regional Contingency Plans
Regional Contingency Plans (RCPs) have been updated
regularly. However, the most recent review of contingency
plans and MSO plans revealed many shortfalls in planning,
equipment, and personnel that need to be addressed to
respond adequately to a catastrophic oil spill. The RRTs
have already begun to revise their Regional Contingency
Plans in response to the Exxon Valdez spill, although some
are postponing final revision until the NCP is revised in
March 1990. Most RRTs are examining the use of
preapproval of dispersant use in their areas of response, as
well as the adequacy of dispersant stockpiles and equipment
in readily accessible locations.
Many RRTs are also examining with great urgency the
identification of disposal sites for oiled debris and the
clarification of permit requirements with the appropriate
States, especially since the number and amount of available
space in hazardous materials disposal sites is limited.
Several RRTs have stated that they will be examining the
option of in-situ burning of spilled oil. Region IX is
convening an oil spill technology workshop in spring of 1990,
which will include consideration of this option.
This most recent review of regional plans has resulted in
several RRTs evaluating the adequacy of contingency plans
in coordinating with adjacent areas since oil spills frequently
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"Federalizing" an Oil Spill
One of the sources of confusion throughout the early days of the Exxon Valdez spill response, certain aspects
of the June weekend spills, and indeed many major spills, is widespread discussion of the adequacy of funding
available to combat spill effects, using such terms as "to Federalize" or "Federalization" or even "partial
Federalization".
The "Federalization" terminology has come to be used to describe situations in which an OSC decides whether
to use Federal funding to pay cleanup contractors for a spill response effort, based on the adequacy of the
performance of the spiller's response. The question of "Federalization" is associated in people's minds, however,
not only with funding of the cleanup, but with the amount of control or command authority vested in the On-
Scene Coordinator. Can the OSC be in control of the spill scene, bringing all possible efforts to bear on the
response effort if he is relying on the spillers' activities and funding? Doesn't "Federalization" bring both more
money and more control to bear on the response operation?
The questions are answered in the following paragraphs taken almost word for word from the current Coast
Guard guidance to its OSCs:
Normally, the removal of the oil spill is done by the responsible party, and the OSC must ensure
that the operations are being conducted properly. "Proper" includes both the timeliness and the
adequacy of removal operations that are necessary to control the spread of the discharge and to
mitigate the environmental effects. When appropriate, the OSC shall guide the discharger on the
preferred course of action. The OSC shall use his or her good judgement in determining the
extent of monitoring required and the need for the presence of the Coast Guard, EPA, or other
agencies on scene. The extent of monitoring required will largely depend on the known
capabilities and the reliability of the discharger and/or the discharger's cleanup firm. The OSC
will monitor or ensure that a capable representative from another Federal, State, or local
government agency monitors, all responsible party cleanups.
Under the Clean Water Act, whenever a responsible party-the spiller or polluter--is unknown or
is not acting responsibly, or when the spiller's removal effort is insufficient, the OSC may assume
partial or total control of response activities. In some instances, the OSC may determine that the
spiller's response efforts should continue, but that some Federal assistance is necessary to augment
the cleanup, such as providing some cleanup resources that the spiller cannot or will not provide.
Whenever it is necessary for the Federal Government to expend funds in support of a cleanup
operation for purposes other than monitoring, the OSC may declare a Federal spill for the area,
activate the Pollution Fund established under the Clean Water Act to cover expenses and take
whatever actions are necessaiy to ensure a proper oil spill cleanup.
For years, the National Response System has operated effectively on the principle that the industry spiller is the
first line of defense, and further that the "polluter pays" principle can be an effective way to maximize use of
scarce public funds and limited equipment supplies. The existing system provides for On-Scene Coordinators
to have the control they need to be sure of maximum effect from available resources, and the tools to access
additional resources. For Exxon Valdez, the resources were inadequate. For the June weekend, they were
brought to bear effectively on three major spills occurring on the Gulf and East coasts within a two day time
span.
A different question also causing confusion at the time of the Exxon Valdez incident was whether or not there
should be "a Federal disaster declaration." Again, this question was usually raised in the context of the
availability of Federal funding, and often also with thought of additional Federal controls that could expedite spill
response actions.
The Federal Emergency Management Agency (FEMA) has the responsibility to advise the President on the need
for declarations of disaster, considered at the request of a Governor. Disaster declarations are not limited to
natural disasters such as Hurricane Hugo or the Loma Prieta earthquake, nor are disaster declarations precluded
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"Federalizing" an Oil Spill (Cont'd)
for oil spills within the larger categoiy of technological disasters. However, the primary focus of a disaster
declaration is for aid in repairing or replacing infrastructure and social services impaired by an event beyond the
ability of State governments to cope, coupled with a pre-designed emergency management structure.
There are well established criteria and procedures followed by FEMA in considering such a declaration. During
the Exxon Valdez response, FEMA consulted with NRT members at length in formulating its recommendation
that the benefits of such a declaration were not relevant to that incident, nor would the emergency management
structure add anything to the on-scene management capability already provided by the Coast Guard operating
with the backup provided for in the National Contingency Plan.
Hence, "Federalization," as used to describe the use of public money to pay for a cleanup, and "Federal disaster
declarations," for providing relief and assistance to those harmed by a situation are separate issues, but both are
potentially available during catastrophic oil spills.
Ms gg
AHHHl
U.S. Coast Guard photo
OPEN WATER OIL SPILL RESPONSE
Boats, boom, and skimmer appear dwarfed by the expanse of the Chesapeake Bay during a spill drill and equipment exercise in
Yorktown, VA. Exercises are essential in preparing for a real oil spill.
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cross planning zones. The Region X RRT identified the
need for examining the compatibility of plans between
adjacent MSOs and RRTs. Region IV is combining inland
and coastal contingency plans to prepare for spills that cross
the boundary of EPA/USCG OSCs' jurisdictions. The
RRTs from Regions IV and VI are examining the
compatibility between their plans and those of other
agencies, such as Department of Defense (Region IV) or
those required by MMS for offshore oil development
(Region VI).
Most RRTs and MSOs cannot command sufficient staff
whose sole purpose is to carry out the comprehensive
planning and coordination required for response to a
catastrophic oil spill. In order to meet this demand on
limited staff, RRTs will need to develop creative approaches
for integrating related activities, and focus more effort on
increasing the effectiveness of coordination with other
agendes to use scarce resources more efficiently.
9. Exercising Contingency Plans
Realistic exercises are a highly effective way to train
response personnel and to test contingency plans. Exercises
point out shortfalls in existing contingency plans and enhance
local and regional preparedness by clarifying lines of
authority and communication during an incident, identifying
response equipment and resource needs, testing mutual aid
agreements, and building strong response teamwork.
Exercises
Although agencies use different terminology, there are three
basic types of exercises:
standard operating procedures. A follow-up ensures that
valid recommendations are being implemented.
Regional reports reveal that exercises are common, albeit
sporadic, in all parts of the country. In Region V (Chicago),
for example, MSO Milwaukee followed up on an April 1989
OSC/RRT exercise by recently organizing an oil pollution
response field exercise in which three local agencies
participated. MSO Chicago assisted the AMOCO Oil
Corporation in conducting an in-house spill response exercise
in July 1988, and provided Shell Oil Company the same
assistance in September 1989.
While the following are good examples of spill response
exercises, they are scattered throughout the response system
and any given specific area. The half-dozen OSC/RRT
exercises per year hardly come close to providing each OSC
with sufficient simulated tests of his response plans.
Federal Agendes
Individual agencies as well as RRTs conduct emergency
exercises, provide training programs, and offer technical
assistance on the international, Federal, State, and local
levels.
The Coast Guard, with RRT support, sponsors six On-Scene
Coordinator /Regional Response Team (OSC/RRT)
simulation exercises across the country annually. Five of
these exercises normally involve coastal areas; the sixth
focuses on an inland incident. The OSC/RRT exercises
planned for fiscal year 1990 are listed below.
1. field exercises, which feature the actual deployment of
equipment at the site of a simulated emergency;
2. functional or Command Post exercises, which involve
the performance of response actions by participants
without deploying equipment; and
3. table-top exercises, which involve a verbal "walk-
through" of a response to an emergency situation.
These exercises are characterized by a simulated or
hypothetical emergency event designed to elicit responses
from the participants who are drawn from government
response agencies (e.g., police, fire, emergency medical, news
media, public health, public works), support groups (e.g., the
Red Cross), and other private sector representatives (e.g.,
the party responsible for a spill). One feature of any
successful exercise is an evaluation session during which
participants can discuss the exercise, identify weaknesses and
shortfalls, and recommend changes in contingency plans and
OSC/RRT Exercises Planned for FY 1990
RRT Location Date
VIII Denver, CO (EPA)» December 1989
X Seattle, WA (Coast Guard) February 1990
VII Kansas City, MO (EPA) April 1990
IV Miami, FL (Coast Guard) June 1990
III Baltimore, MD (Coast Guard) August 1990
VI Port Arthur, TX (Coast Guard) September 1990
Because of Hurricane Hugo, an OSC/RRT exercise originally planned
for Puerto Rico was transferred to Denver. Thus, there will be four
coastal and two inland exercises in fiscal year 1990.
OSC/RRT exercises are comprehensive and realistic
simulations of hazardous materials and/or oil incidents used
to test plans, policies, procedures, and personnel. The Coast
Guard Marine Safety School at Yorktown, Virginia, designs
the scenarios in coordination with local officials to reflect
actual patterns in the host community. The exercise lasts
two days, which includes eight hours of simulation activity
30
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conducted in real time and three hours of open forum
debriefing. The debriefing is a means to discuss deficiencies
and necessary corrective actions, as well as to reinforce
positive results. Response organizations interested in
participating in a simulation should contact either their OSC,
the RRT, or the Coast Guard Marine Safety School.
EPA's Environmental Response Team (ERT), located in
Cincinnati, Ohio, and Edison, New Jersey, is a group of
highly trained scientists and engineers who have expertise in
multimedia sampling and analysis, hazard evaluation,
environmental assessment, and cleanup techniques. The
ERT, which is available to provide overall technical support
to OSCs during actual incidents, conducts approximately
10 full-field exercises a year. The ERT also offers assistance
in conducting field exercises to States and local communities.
EPA supports interagency and international exercises as part
of their preparedness efforts. EPA Regional Chemical
Emergency Preparedness and Prevention Coordinators are
available at the request of State officials to assist local
jurisdictions in their efforts to ensure adequate testing of
new Title III plans. EPA assists in approximately one
exercise per State each year. On a bilateral level, EPA is
working with Mexico and Canada to include exercises as
part of joint preparedness activities.
All State and local jurisdictions receiving FEMA funds
through the Comprehensive Cooperative Agreements (CCA)
are required to exercise their "all-hazards" emergency
operations plans and procedures annually. Each jurisdiction
must submit as part of its annual CCA statement of work an
updated 4-year exercise plan. At least one field exercise
must be conducted during the four years, and a functional
exercise is to be held in each of the other years. FEMA also
conducts classroom and field exercise training at the
Emergency Management Institute (EMI) and at the State
level. Using the EMI facility located at FEMA's National
Emergency Training Center in Emmitsburg, Maryland,
FEMA conducts 12 to 14 exercises each year.
International Joint Response Teams
As specified by the Canada-U.S. Joint Marine Pollution
Contingency Plan, Canada-U.S. Lake Plans (CANUSLAK),
exercises have been conducted eveiy two years with the
Canadian Coast Guard and the U.S. Coast Guard alternately
serving as the host.
The exercise scenarios have always involved an oil release,
and hazardous materials threats have been introduced
recently. RRTs conducted two international exercises with
Canada during FY 1988, a team from the USSR observed an
exercise in Alaska which lead to the development of a
U.S./USSR Joint Contingency Plan, and Mexico also
sponsored a Joint Response Team drill in Tampico, Mexico
in November 1989, attended by representatives of the U.S.
Coast Guard, EPA, and the State of Texas.
Other Entities
Chemical Manufacturers Association (CMA) members
conduct simulation exercises involving local industry and
response officials through CMA's Community Awareness
and Emergency Response (CAER) program. The CAER
associations usually meet monthly and periodically have joint
industiy/agency training and spill response exercises. The
local Coast Guard OSCs typically have representatives
participate. Although oriented mainly toward hazardous
substance spills, the CAER associations facilitate and
enhance local interagency and industry communications
which carry over to oil spills.
Local Emergency Planning Committees (LEPCs) are
required by Section 303 of SARA Title III to include
methods and schedules for testing plans and conducting
training programs in their emergency plans, but these LEPC
activities currently focus on releases of hazardous substances
rather than oil spills.
Army installations/organizations that store nuclear, chemical,
or biological materials are required to conduct quarterly
exercises, one of which should involve testing existing State,
local, or other supporting agency plans on an annual basis.
States
States participate in many oil spill response exercises through
their membership on the RRTs. In addition, many States
conduct their own exercises. For example, Ohio recently
passed a Community Right-to-Know Law requiring the State
to sponsor one exercise per year that involves both
hazardous substances and oil. An agreement between the
Federal Government and the State of Hawaii concerning
notification of discharges of oil and hazardous substances has
been exercised and is well established. Each of New York's
58 LEPCs have independently exercised their plans. New
Jersey also has an extensive exercise schedule in which
Region II RRT has played a limited role. Training and
exercises in the regions of American Samoa, Guam, Saipan,
and Palau are also a priority because of the lack of response
resources in these areas.
D. Identifying the WorstCase Oil Spill Scenario
Identifying realistic, worst-case oil spill scenarios is the
critical first step in determining response equipment needs
and resulting shortfalls. In assessing a worst-case scenario,
the evaluator considers threats to life or human health, the
environment, property, the economy, and the difficulty of
cleanup. Moreover, a worst-case scenario should not be
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Training: OSC/RRT Exercises
There are a number of different types of drills and exercises that take place each year in the pollution response field.
Some, like the Regional Response Team/On Scene Coordinators exercises, involve "table-top" planning and accident
simulations. These exercises are conducted by personnel from the Coast Guard Marine Safety School in York town,
Virginia, six times per year. All actions within the drills are simulated. No people or equipment are moved. The
goal of these simulations is to exercise the various contingency plans which would be used in a real spill. The Design
Team, comprised of all levels of government and local agencies as well as industry and local response personnel,
specifically design these accident scenarios to test the local response network.
A good example of this type of drill was held in Long Beach, California on August 2, 1989. Over 400 individuals
from various agencies and organizations attended. The planning that went into organizing this exercise started a
full six months prior to the drill. Close coordination between the Coast Guard, RRT Region IX, various government
agencies, industry and members of the local emergency response system was necessary to ensure that the exercise
ran smoothly. After completion of the simulation, a critique identified the level of success that was achieved, and
identified any areas that might need further attention.
Some of the pollution response drills that are held each year involve the actual deployment of equipment and
personnel. An excellent example of this type of drill was performed at Yorktown, Virginia. At 2:00 a.m. on October
26,1989, a "no notice" drill was held. Except for a few key personnel, no advance notice of this drill was given. The
response was outstanding. By the time the drill had ended that evening, over 100 people, 10 boats, 5,000 feet of
boom, two skimmers, and one helicopter had been used to contain a "spill" of peat moss that was placed in the water
to simulate an oil spill. A critique was held the following day to evaluate the drill. A large number of organizations
were involved in this "cleanup." The Coast Guard, EPA, NOAA, RRT Region III, Navy, various state agencies and
departments of Virginia, Amoco Oil Company, and local contractors all participated in the drill. In fact, not only
did Amoco Oil Company participate, they originated the idea and paid all of the local contractor's fees. This is just
one good example of how industiy and the Federal, State, and local governments work together to combat oil spills.
based on events that are expected to occur on a day-to-day
basis. Rather, it should be based on an event that is
reasonably likely to occur.
As part of reporting on their contingency plans, each Coast
Guard and EPA OSC was asked to determine the realistic,
worst-case oil spill scenario for their area of responsibility.
OSCs were not given a set of assumptions for making these
determinations. Instead, they developed assumptions
tailored to the specific characteristics of their areas of
responsibility. However, nearly all OSCs made four common
assumptions: (1) the worst-case oil spill scenario only
involved oil and did not include oil in combination with a
hazardous substance, (2) all equipment inventoried in their
existing contingency plans would be available, (3) their
allotted personnel would be available, and (4) no other large
spill or other incident, such as search and rescue, was
occurring at the time of the worst-case oil spill.
The OSC-assumed characteristics of a catastrophic oil spill
can significantly affect required response equipment and
personnel, and the resulting shortfalls that would be
identified. With a wide variety of potential assumptions, the
OSCs performed a balancing act between the geographic and
transportation characteristics of their areas of responsibility,
the spill's location, and the types of oil spilled in developing
worst-case oil spill scenarios.
Evaluation of OSCs' worst-case oil spill scenarios showed
very different considerations for spills inland as compared to
those in coastal waters. For example, in the coastal areas,
environmental considerations included the potential for harm
to property, such as beaches and pleasure craft; harm to
fishing, both commercial and sport; and harm through direct
contact with birds and sea mammals. As significant as these
types of impacts are, oil spills into inland river waters
generally pose even more serious risks because of threats to
public drinking water quality, property, and aquatic species
due to a concentration of oil in a more confined area.
Assumptions about the type of oil also make a difference in
response required. For example, a lighter oil, such as
gasoline or diesel, may be less amenable to containment and
recovery, and more receptive to dispersion, either naturally
or with the use of chemical dispersants. Additionally, a
lighter oil may be more likely to evaporate than a heavy
product. However, lighter products may pose a more
immediate risk of toxicity to aquatic species than crude oil or
heavier products.
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In arriving at the worst-case scenario, the contingency
planner first performs a hazards analysis for potential
discharges in his or her area of responsibility. The
information developed in a hazards analysis provides both
the factual basis to set priorities for planning and the
necessary documentation for supporting response efforts. A
hazards analysis is composed of: 1) identifying hazards (e.g.,
potential spill sources), 2) a vulnerability analysis, identifying
in the community that which is susceptible to damage should
a spill occur, and 3) a risk analysis, assessing the probability
of damage in the community from the identified potential
hazard.
A good example of a detailed hazards analysis for a worst-
case scenario was provided by the Coast Guard COTP Long
Island Sound. This example is presented in Appendix B.
Examples of the scenarios and complete shortfall reports
which were developed from the worst-case scenarios are
found in those presented by the Coast Guard OSCs in Los
Angeles/Long Beach, CA, and Morgan City, LA. These are
also found in Appendix B. A summary of the Morgan City
worst-case scenario follows:
The worst-case scenario for MSO Morgan City
involves a crude oil producing platform located off
the coast of Louisiana, a 200,000+ gross ton
supertanker (the Exxon Valdez is 110,831 gross
tons) en route to off-load its cargo of Basrah crude
oil at the Louisiana Offshore Oil Platform
(LOOP)--both the platform and the supertanker
are common in this OSC's zone. In this scenario,
the tank ship suffers a loss of power and steering
and collides with the oil production platform. Both
the vessel and the platform sustain significant
structural damage, with two of the ship's forward
cargo tanks holing and the platform receiving
damage to the well head and blowout preventers.
As a result of the collision, fire erupts on the
platform and the tanker. Due to the loss of power
on the ship, the crew is unable to fight the fire with
the ship's main fire pump; the fire also blocks
access to the ship's emergency fire pump located
near the ship's forepeak. The fire rages out of
control for twenty-four hours and causes structural
weakening of the ship. The structural weakening
in turn allows the vessel to break apart and sink,
releasing 85 percent of its crude oil cargo of 50.4
million gallons.
The heavy crude oil carried has poor dispersion
characteristics which, coupled with the relatively
low daily sea and air temperatures (this scenario
occurs during early February), means that little
evaporation and dissipation will occur.
Containment of the spill in over two foot seas would
also be difficult.
Using typical offshore sea and wind conditions, MSO
Morgan City estimated that within ten hours from
the sinking, the leading edge of the oil slick would
impact the Louisiana shoreline. Within twenty-four
hours, twenty miles of shoreline is affected and tidal
action would cause inland marshes and bayous to be
oil covered for a distance of five miles. Within seven
days the slick would cover an area ten miles wide
and as far west as 150 miles, or 1,500 square miles.
As shown by the extent and difficulties encountered
in the Valdez, Alaska spill, the OSC estimated that
an incident of the magnitude of this scenario would
take one year or more to cleanup.
E. Themes Arising From OSC Analyses of Worst-
Case Oil Spill Scenarios
A number of generic themes were common among the
broad variety of OSC analyses of the realistic, worst-case
catastrophic oil spill, the projected response to them, and the
shortfalls. These generic themes are discussed in this
section.
1. Availability of Equipment
Even under optimal conditions of equipment availability,
virtually all OSCs, with the exception of some in inland
areas, concluded that there would be substantial shortfalls of
equipment to respond to a catastrophic oil spill.
Additionally, many OSCs observed that much of the
equipment that is stockpiled, by government agencies,
contractors, and other private sources, has been stockpiled
for a long time. Concern follows, therefore, that much of
the currently available equipment may not be reliable if used
to respond to a catastrophic spill. A nationwide database of
equipment available from government agencies and the
private sector would be beneficial. However, many OSCs
noted that there would be logistics problems in transporting
equipment from a remote location to the site of an oil spill
in their area of responsibility in sufficient time to effectively
gain control of the situation.
One particularly forceful analysis provided by a COTP in
New England [First Coast Guard District] identified
available equipment and response needs not only in terms of
numbers of items of equipment, but also in terms of the
time following the spill that the item would be needed. By
this analysis, the COTP was often able to conclude that
there was an ample supply of "72 hour boom," for example,
but a critical shortage of "six hour boom." These variations
were based on factors such as the distance equipment would
have to be transported and the remoteness of the location
where the equipment might be needed. For example, this
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COTP estimated that some equipment stockpiled locally
could be available in as little as five minutes, while
equipment that would be transported from a Coast Guard
Strike Team or the Navy's Supervisor of Salvage might not
be available for 11 hours. According to this COTP, "the
major constraints may not be equipment but the timely
deployment of that equipment and the associated personnel
needed to do it."
The analyses of equipment to respond to the worst-case
catastrophic oil spill clearly show that even in the best of
conditions, this country has not committed to making
response equipment available. Significantly, the U.S. oil
industry, through the American Petroleum Institute (API),
conducted a similar analysis of oil industry preparedness and
made similar conclusions concerning the response equipment
that would be available to the oil industry. The oil industry
proposes to establish the Petroleum Industry Response
Organization (PIRO). PIRO proposes to purchase and
stockpile significant quantities of equipment in five major
centers across the Nation.
The PIRO proposal represents an important recognition by
the petroleum industry regarding their primary role in the
pollution response arena. The focus of the PIRO proposal
addresses National shortfalls related to response to coastal
oil spills. The levels of equipment and trained response
personnel identified in the PIRO proposal are significantly
lower than the shortfalls identified in many OSC analyses of
their needs for responding to their worst case catastrophic oil
spill scenario. This is consistent since the OSC analyses
addressed total shortfalls for their respective areas. The
initial focus of PIROs research proposals were limited to the
objective of developing improved oil spill response
equipment. The most current plan is addressing other oil
spill research and development needs. However, the
petroleum industry has not as yet made a firm commitment
to implementing its PIRO proposal.
The contractors that the Federal Government relies upon to
provide equipment and personnel to respond to oil spills are
generally the same ones that the oil industry relies on. Many
U.S. Coast Guard photo
MECHANICAL RECOVERY
Mechanical recovery is the preferred oil spill cleanup method. Hundreds of pieces of mechanical equipment were needed
during the Exxon Valdez oil spill response like this belt-type skimmer used to remove oil from the waters of Alaska's
Prince William Sound.
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OSCs observed that if the industry could be relied upon to
stockpile equipment at the levels that have been promised in
the American Petroleum Institute report, and their
availability could be assured (i.e., PIRO), OSC shortfall
projections could be reduced substantially. However, in the
past, the Federal role in oil spill response has been viewed
as preparation for a Federal response, rather than ensuring
that potential spillers could support a response. Therefore,
except for some transfer operations, there is currently no
Federal regulatory requirement that potential spillers
prepare and implement response contingency plans. Note,
however, the earlier discussion on DOT pipeline regulations
that require operators to have emergency procedures are
designed to mitigate spill size and duration, and provide
notification to appropriate authorities.
In addition to the quantities and age of equipment that are
available, research to advance the state-of-the-art of oil spill
response equipment has been a low priority in this country,
both in the public and private sectors. As a result, there
have been few advancements in oil spill response technology.
For example, a report to the President in 1969 following the
grounding of the Torrey Canyon off of the coast of England
analyzed the capabilities of the United States to respond to
an oil spill similar to the Exxon Valdez. It was observed that
equipment then available to contain and recover such a spill,
like booms, skimmers, and sorbents, were inadequate in
other than optimal response conditions. Therefore, pressure
could be expected from spillers to disperse spilled oil or to
sink it. Although somewhat more efficient sorbents,
skimmers, and booms are now available, the situation
regarding available equipment for oil spill recovery has not
significantly changed since the report to the President in
1969.
As a part of its proposal to establish PIRO, the American
Petroleum Institute report, making similar observations
concerning the state-of-the-art of oil spill response
equipment, proposed an oil industry commitment to a five
year program of $30-35 million to develop improved
U.S. Coast Guard photo
MANUAL OIL RECOVERY
Booms, skimmers, and other mechanical recovery equipment are often insufficient for complete oil removal. Recovery requires
intense manual labor. Here workers remove oil and oily debris from a beach in Prince William Sound.
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equipment to respond to catastrophic oil spills in the coastal
waters. Similar commitments are being considered by a
number of Federal Government agencies and by Congress in
drafting proposed legislation in response to the Exxon Valdez
oil spill, and a number of industry and government forums
are being established or revitalized to coordinate these many
research efforts.
2. Personnel
Virtually every OSC concluded that they would be quickly
overwhelmed by the response requirements of a worst-case
scenario, and many, such as the small Coast Guard units on
the Great Lakes and in the New England area, would be
overwhelmed on some major or even larger medium spills.
The experienced personnel that would be available to
respond to a worst-case catastrophic oil spill would simply
be inadequate to control the spill, particularly in the critical
early hours following notification of the spill before
additional trained personnel could be brought to the area
from other sources. While Federal Government personnel
would be supplemented by personnel from private cleanup
firms and oil spill cooperatives, the amount of trained
personnel that such private sources could supply was
generally judged to be inadequate for the task of responding
to a catastrophic oil spill.
Moreover, trained Federal personnel, who would be available
to direct commercial operations and negotiate and
administer contracts for Federalized spills, were also judged
to be inadequate for catastrophic oil spill response.
Shortfalls of Federal personnel could range from less than
10, principally for response in some inland areas, to as many
as 200 for response to catastrophic spills in some coastal
areas.
While training is available for response personnel from a
variety of sources (such as the National Strike Teams,
Environmental Response Team, the Coast Guard training
center in Yorktown universities, and some private
companies), several problems exacerbate the availability of
trained response personnel. Because major spills are
relatively infrequent and also because response personnel
almost always have other duties, response-related activities
tend to be high priorities only at the time of a spill.
Consequently, when it comes time for someone to receive
training, it is often delayed due to more pressing matters at
hand.
Training issues are also aggravated by the high staff turnover
that occurs in the EPA Regional Offices and Coast Guard
Marine Safety Offices (MSOs). Coast Guard personnel are
generally rotated to new assignments every three years. For
many personnel, there is no career path that involves
specialization in environmental protection. Therefore,
personnel beginning a tour of duty in an MSO may not have
The Petroleum Industry
Response Organization (PIRO)
Following the Exxon Valdez oil spill, representatives of
the major oil companies, under the auspices of the
American Petroleum Institute (API), analyzed the oil
industry preparedness to respond to catastrophic oil spills
in situations other than that presented by the Exxon
Valdez spill. The oil industry concluded that it would be
overwhelmed by the demands for personnel and
equipment that would be required to respond to a large
oil spill in the coastal waters of the United States.
As a result of this analysis, on June 20, 1989, API and
approximately 20 member oil companies (that together
receive almost three quarters of the oil delivered to U.S.
ports) recognized that the petroleum industry had neither
the equipment nor the trained response personnel in
place and ready to respond to catastrophic tankship spills,
particularly in the open coastal waters, and announced
their intention to establish a Petroleum Industry
Response Organization (PIRO). The oil industry's
principle proposal is to establish five regional emergency
response centers located around the coastal areas of the
country. The centers would each be equipped with a
broad variety of equipment and will have trained
personnel available, the amount of which was calculated
as necessary for response to the target maximum spill
size of 10 million gallons. The centers purpose would be
to supplement the capabilities of a spiller in the event of
a catastrophic coastal oil spill. In addition to the
establishment of these regional response centers, the oil
industry proposed committing $30 to $35 million, also
through the PIRO structure, for a joint
government/private research and development program
over five years to improve oil spill prevention, response,
and mitigation. In total the oil industry has proposed a
gross commitment of $250 million over five years.
The PIRO proposal represents an important first step by
the petroleum industry toward addressing the current
National state of preparedness for response to
catastrophic oil spills. The levels of equipment and
trained response personnel identified in the industry's
PIRO proposal, however, are significantly lower than the
shortfalls identified in many OSC analyses of their needs
for responding to their worst case catastrophic oil spill
scenario. In addition, the focus of the PIRO proposal is
limited to addressing National shortfalls related to
response to coastal oil spills, and the focus of the
industry's research proposals are limited to the objective
of developing improved oil spill response equipment.
The PIRO plan would not address other oil spill research
and development needs. Additionally, the petroleum
industry has not as yet made a firm commitment to
implementing its PIRO proposal.
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prior experience or training in oil spill response. One Coast
Guard OSC observed that it takes approximately one year to
train the typical person with no prior oil spill experience.
The OSC observed that in a typical group of Coast Guard
personnel, one-third are insufficiently experienced and one-
third are minimally experienced. Similar problems exist in
some EPA Regional Offices because of staff turnover. In
some EPA regions, the average length of time that an EPA
OSC stays in a response position is similar to a Coast Guard
tour of duty, resulting in similar problems.
Some oil spill response activities do not require extensive
experience or training or could be adequately performed by
persons with other related experience. However, recently
promulgated Department of Labor regulations (29 CFR
1910) require that personnel conducting response operations
receive 24 hours of formal training in hazardous substances
release operations. Response organizations perceive these
training and paperwork requirements to be a significant
obstacle to providing a sufficient cadre of trained personnel
from both government and private sources for oil spill
response in a timely manner. Many safety training
organizations now have formal courses available to meet
these Labor Department regulatory requirements, and
responsible parties should routinely be providing this training
as part of their preparedness program.
3. Contractors and Cooperatives
The Federal Government relies heavily on private
contractors and industry cooperatives to provide the
equipment and personnel needed to respond to all types of
oil spills, including catastrophic incidents. Cleanup
contractors and cooperatives are a valuable resource, and
they have the capability to respond effectively to the vast
majority of oil spills. However, they do not have the
resources to respond adequately to a catastrophic spill.
Concern was raised that the Federal Government might not
be able to sufficiently influence the priorities of a private
contractor to provide all of their available personnel and
equipment if the firm had competing demands for their
services from non-governmental clients.
The existing procedures by which the Federal Government
procures contract services were also identified as a potential
problem. These procedures are designed to ensure that the
Federal Government obtains the best quality services
possible at the best available price, and that procurement is
done by the fairest and most competitive process possible.
This is done through a Basic Ordering Agreement (explained
in Section 8, Funding). While these procedures are viewed
as necessary during non-crisis periods, flexibility in adapting
these procedures to a crisis situation is viewed as essential to
the acquisition of equipment and personnel when most
needed. Despite the important objectives of these
procedures, it makes little sense to apply rigorous
procurement procedures when services and equipment are
needed immediately in an emergency situation.
Problems were also noted with respect to the system by
which some response contractors are available under existing
contract. For example, some contracts are old and contain
rates and other provisions that may be out of date. Concern
was expressed that during the critical early hours of a spill,
time could be lost while firms sought to renegotiate out-of-
date terms before they would be willing to mount an all-out
response to a catastrophic spill.
Additionally, many OSCs expressed skepticism that several
Arms could provide all of the personnel and equipment that
they claim they can provide in the event of a non-routine
response. Tight pollution response resources do not permit
adequate testing through simulated exercises and other
mechanisms to discover and document the capability of these
firms, who are relied upon very heavily for oil spill response
and are expected to deliver.
4. Communications/Information
Many OSCs observed that weaknesses in communications
systems have been a significant shortfall in responses to
virtually eveiy previous catastrophic oil spill, whether
conducted by the Federal Government or the spiller. When
a large-scale response team moves into virtually any potential
area in which an oil spill might occur, it is almost inevitable
that existing systems for normal communication will be
overwhelmed. Many OSCs concluded that increased use of
cellular telephone technology could improve this situation
and identified cellular telephone equipment as a part of their
shortfalls. However, many OSCs also observed that, while
cellular telephone equipment could improve the existing
communications shortfalls, they would not eliminate them.
In some rural areas, for example, there is not as yet
sufficient coverage with "cells" to support a reliable large-
scale response effort. By contrast, in some urban areas
routine cellular telephone traffic is so heavy that the system
cannot be counted on to support a large-scale response
effort. Therefore, while, increased use of cellular telephone
technology is recommended by the OSCs, increased efforts
to explore expanded use of other communications tech-
nologies, such as shortwave and microwave, were also
recommended. While a uniform national communications
system, perhaps based on a satellite system would be
preferable, many analyses recognized that such a uniform
system could be difficult to establish because of existing and
differing communications customs that have developed in
different parts of the countiy. Therefore, regional solutions
to these communications issues are viewed as having more
potential than one, uniform solution.
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Another communications technology that has developed in
recent years is the electronic bulletin board and electronic
mail. Many analyses observed that some communications
problems, particularly those of getting large amounts of
timely information to many local communities, might be
addressed using bulletin board and electronic mail technol-
ogy. NOAA has developed an electronic mail system that
can be used to network RRT and NRT members. However,
other electronic mail and bulletin boards used in many
different localities, regions, and in EPA and USCG offices
are not compatible, and many smaller local government
response organizations do not yet have access to such
technology.
5. Public Affairs
A catastrophic oil spill generates enormous interest and
concern from the public, the media, and elected officials.
Without adequate planning or implementation, response to
a catastrophic spill can become "media driven." Answering
public requests for information and analysis too often results
in a considerable diversion of important response personnel
from their task of responding to the oil spill. These
diversions happen not only at the spill site, but also in the
regional and headquarters offices of the many Federal
agencies involved. Answering inquiries is an important
function during a response, despite the resources it requires.
The answers provide necessary management information
rather than simply satisfying curiosity. In addition to the
right of the public and elected officials to know what is
happening, the perceptions that can develop if they are not
fully and accurately informed can create significant pressure
to change the spill cleanup plan and can also damage the
credibility of the government agencies involved. Therefore,
providing a steady stream of information always will and
should be a high priority. There is often inadequate
coordination among the many government agencies
regarding requests for information. A number of different
agencies may be gathering information about the events at
the spill site in response to an inquiry, or they may be
gathering information that has already been obtained by
another agency. These duplications are unnecessary and
could be corrected by expanded use of the NRT, RRTs, or
special information support to provide a central source of
information collection and dissemination for inquiries from
the media and Federal, State, and local officials.
6. Disposal
Issues regarding the disposal of recovered oil, oily debris,
and oil-soaked sorbent material are widely viewed as
intractable. These issues are so severe that they can create
a disincentive to choosing response methods that are based
on removing spilled oil from the environment. Recovered oil
and oily material are not generally considered a hazardous
waste under Federal law requiring disposal in facilities
permitted as hazardous waste treatment or disposal facilities
under the Resource Conservation and Recovery Act
(RCRA). However, these wastes are often considered
hazardous under State law. These determinations further
limit disposal options open to responders. Many landfills do
not accept oily waste, and transportation costs to distant
facilities that will accept such wastes can be prohibitive.
Disposal by burning the wastes at the spill site can create
emotionally charged concerns about health and air quality or
other environmental impacts among the States, local
governments, and residents.
7. Chemical and Biological Countermeasures
A number of response techniques, in addition to traditional
physical containment, diversion, and collection are available.
Most involve the use of chemicals or microorganisms to
enhance the recovery or natural biodegradation of oil or
chemical dispersants to enhance the natural dispersion of oil
into the water. The use of chemical and microbiological
countermeasures requires the approval of the Federal
Government and the affected States whether a response is
conducted by the government or the spiller.
a. Chemical Dispersants
The use of dispersants to break up an oil slick on the water
surface and to transport oil droplets below the water surface
has been a particularly controversial oil spill response issue
for decades. Unlike other oil spill response methods, the use
of dispersants does not require a significant amount of
equipment or personnel to mount a response. It, therefore,
has the potential to eliminate or substantially reduce the
shortfalls that most OSCs and their counterparts in the
industiy have identified concerning their ability to respond to
a catastrophic oil spill. Moreover, the cost of a response
using dispersants is generally orders of magnitude lower than
response by containment and mechanical recovery.
However, once a dispersant has been applied, the
effectiveness of oil containment and/or recovery technology
is generally significantly reduced whether the dispersant is
effective or not.
The Clean Water Act (Section 311) requires that the use of
"dispersants and other chemicals" for response to oil spills in
the navigable waters of the United States and the adjoining
shorelines be approved by the Federal Government, in
consultation with the States, whether the response is being
conducted by the spiller or by the government. The statutory
standard that is required for the Federal Government to
approve the use of such products is a finding that their use
will be "safe." The range of potential oil spill situations
described in currently available scientific literature
concerning the effectiveness of dispersant technology and the
relative environmental risks of dispersing oil as opposed to
leaving oil on the surface of the water, leaves room for a
broad spectrum of scientific opinion concerning both of these
issues. Many OSCs and RRTs have concluded that the many
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parties affected by a catastrophic oil spill or a potential
catastrophic oil spill, both proponents and opponents of
dispersants use, have exaggerated perceptions as to the
effectiveness of dispersants and the effects of dispersed oil,
as opposed to undispersed oil. The number of States
involved in a catastrophic oil spill could heighten the
emotions in the debate. The OSCs and RRTs are perceived
as being caught between the proponents of all sides of the
potential scientific issues in making decisions on whether to
approve a spiller's request to use dispersants. Additionally,
it is generally perceived that such complex scientific issues
cannot be best considered during the crisis of a response to
a catastrophic oil spill. It is therefore perceived that such
issues should be debated and resolved-whether in favor of
use or not--in advance of the response, to the extent
possible.
The statutory requirement that the Federal Government
approve the use of dispersants has been included in the
NCP. Under those provisions, the use of dispersants must
be approved by an OSC. Additionally, there must be a
concurrence with the OSCs approval except when the use of
a dispersant or other chemical will, in the judgement of the
OSC, significantly reduces a substantial threat to human life.
Concurrence may either be from both the EPA
representative to the RRT and the representative of the
State(s) affected by the spill, or be in accordance with a
preauthorization contained in a Regional Contingency Plan
(RCP). Thus, the issue of dispersant use is an issue for both
the OSC and the RRT.
Because of the uncertainty that exists in the scientific
literature and concern about the potential effects of
dispersant use, States are perceived as being reluctant to
approve the use of dispersants in a short enough period of
time to permit their use as a realistic oil spill response
option. The result is that OSCs and RRTs generally
consider dispersant use as not being an available technology
for response to a catastrophic oil spill. Comments
concerning this conclusion ranged from identifying the
conclusion that dispersion technology would not be
considered unless the current approval process is changed to
dilute the role of the States in the approval, to suggestions
for research or demonstration projects that might be
conducted to decrease the range of scientific doubt
concerning the substantive issues relevant, to the
consideration of requests for approval of dispersant use.
b. Viscoelastic and Plasticising Agents
In contrast to chemical dispersants, viscoelastic and
plasticising agents are designed to change the physical
properties of spilled oil to enhance oil removal with
traditional booms and skimmers. With these products, OSCs
find themselves in a situation that is similar to the one they
face when dealing with chemical dispersants. However, in
this case private industry does not appear anxious to use
these agents. As a result, OSCs perceive themselves to be
caught between proponents of such products and the spillers.
At this point, hard scientific evidence is not available to
document the effectiveness of such products or to define
circumstances under which OSCs could evaluate whether
using these products would significantly improve mechanical
recovery rates. As with dispersants, there is a need for more
research on these agents. If further research determines that
they are both safe and effective, there may be a need to
encourage their use.
c. Bioremediation
Bioremediation products range from microorganisms to
nutrients and enzymes. Their purpose is to enhance the
natural degradation of oil that occurs in the environment.
They appear to hold the most promise for treating shorelines
and beaches that have been contaminated with oil. As with
viscoelastic agents, such products have not been used to any
significant degree for oil spill response in this country prior
to the Exxon Valdez oil spill. However, based on other
applications, such methods appear to hold promise.
Therefore, following the Exxon Valdez oil spill, EPA sought
and obtained the agreement of the Exxon Corporation to
support a research project to demonstrate the use of certain
nutrients to enhance natural biological processes to
accelerate recovery of contaminated shorelines. While the
results of this demonstration project are still being analyzed,
this effort appears to hold promise for motivating the oil
industry to build on this demonstration and sponsor further
research to better demonstrate the circumstances under
which bioremediation will significantly accelerate the
recovery of contaminated shorelines and beaches.
d. In-situ Burning
In-situ burning involves attempting to burn spilled oil on the
water or shoreline. It, therefore, can be viewed in part as a
spill response technique and in part as a disposal technique.
Unlike bioremediation and the use of viscoelastic agents, in-
situ burning has been attempted in previous catastrophic oil
spills, generally without significant success. Therefore, in-
situ burning, like some other methods discussed previously,
has not been used by the industry in recent years. However,
recent research suggests that advancements may have been
made that may make in-situ burning a technology that merits
additional consideration by industry and government. Early
in-situ burning agents were chemical agents that required
government approval prior to their use. Most current
burning agents, however, are not traditional chemicals and
may not be subject to such preapproval authorities.
However, because of potential smoke problems, preplanning
to address local and State air pollution requirements will be
necessary.
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Response Options to an Oil Spill
Only a few basic options exist for response to any oil spill. However, the ability to use these options may be limited
by factors such as weather conditions. The major options include:
Containing the spilled oil with barriers such as booms, which are floating barriers that are
placed in the water. The oil is then recovered from the surface of the water with skimmers,
which remove the oil directly from the surface of the water using suction or an oleophilic
surface, and sorbent materials, which soak up the oil into a solid material that can be removed
from the water.
Using booms to divert floating surface oil from impacting ecologically sensitive areas or other
high priority areas.
Physical removal of oil from shorelines, beaches, etc. that have been impacted using water
sprays or by removing oiled sand or other material.
Dispersing the oil from the surface of the water to the subsurface using chemical dispersants.
Two other options are in-situ burning of oil and bioremediation of impacted shorelines. In-situ burning involves
burning the oil on the surface of the water by placing a wicking material in the oil, lighting the oil, and allowing it
to burn in place. Bioremediation involves using bacteria to decompose the oil either on the surface of the water
or on oiled shorelines. The last two options are still in their infancy, have many limitations, and have not been
extensively researched.
8. Funding
Many of the OSC analyses included as a part of their worst-
case oil spill response scenarios the assumption that they,
rather than the spiller, would conduct the response. Section
311 of the Clean Water Act requires the OSC to assume
control of the response if he determines that the spiller is
not conducting a "proper" response or if the spiller is
unknown. Many of the analyses, however, observed that the
revolving fund established from appropriated funds under
Section 311 of the Clean Water Act, and that would be used
to fund a Federal Government response, is authorized to be
at a funding level not to exceed $35 million and, in recent
yean, has been at a much lower level. As of January 1,
1990, less than $1 million remained in the revolving fund.
Many OSCs observed that a response to a worst-case
catastrophic oil spill could cost millions of dollars each day.
They observed that the OSCs* decision to determine that the
response of the spiller is inadequate and decisively assume
Federal control of an oil spill response could be influenced
by the low levels of funding in the revolving fund. OSCs
also expressed concern that problems with the Federal
procurement system could create a disincentive to aggressive
federalization of a response.
As discussed previously, Basic Ordering Agreements (BOAs)
are the primary contracting method for hiring oil spill
cleanup contractors. However, many of these are out-of-
date or they do not cover the expansive range of types of
equipment required for responding to a catastrophic spill.
The lack of Federal contracting officers and support staff
both to negotiate BOAs and to monitor contractor
performance further exacerbates the problem.
Lacking BOAs with every potential contractor in a response,
the only alternative is to negotiate contracts competitively
when a spill occurs. This, however, tends to be cumbersome
and time consuming when time is of the essence. A solution
may be to receive an exemption from the Federal
Acquisition Regulations (FAR), similar to that currently
allowed for nuclear release cleanup contracts. Until such a
waiver is granted, procurement regulations will continue to
be a disincentive to federalizing a cleanup.
As discussed previously, restricted agency funding levels are
viewed as preventing a sufficient number of exercises
involving the government contractors that would be relied
upon for response to a catastrophic oil spill. Additionally,
the Clean Water Act is interpreted as only permitting monies
from the 311 (k) Pollution Fund to be used for spill response,
meaning that these funds are not available to test the
capabilities of response contractors.
9. Storage Tank Spill Prevention
Many OSCs observed that because of the limitations of oil
spill response technology, the most effective response to the
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U.S. Coast Guard photo
MILES OF BOOM
More than 50 miles of boom were flown in from around the world to aid in the Exxon Valdez oil spill response. Trained personnel
are needed to deploy, set, and tend boom.
potential for a catastrophic oil spill is to aggressively pursue
programs to prevent them. In particular, EPA's prevention
program under the Oil Pollution Prevention regulation
(known as the SPCC program because of the Spill
Prevention, Control and Countermeasures Plans that are
required by the regulation) was cited as a program that has
been effective in reducing the risk of catastrophic as well as
smaller oil spills. The Oil Pollution Prevention regulation
applies to non-transportation related facilities, such as above-
ground storage tanks and oil production facilities, that have
a potential to spill oil to the navigable waters of the United
States. However, in addition to shortfalls in the ability to
respond to catastrophic oil spills, many EPA reviewers
reported significant shortfalls in their ability to effectively
implement the SPCC program despite the perceived success
of the program. These shortfalls included inadequate
resources to inspect for compliance with the regulation and
to aggressively pursue enforcement actions, because of the
lack of enforcement staff.
10. Organization of Response to Catastrophic Oil Spill
The intense interest of the public and elected officials in
responses to catastrophic oil spills often creates pressure for
leadership by higher levels of government officials than that
anticipated in the Local and Regional Contingency Plans.
These higher level officials may not be experienced in oil
spill response or in the procedures for interagency
coordination established in the NCP and the RCPs.
Therefore, it may be necessary to formally anticipate these
organizational differences for oil spills of national
significance. In addition to options in which a higher level
OSC would be designated for oil spills of national
significance, it may be possible to return to the concept that
was included in earlier versions of the NCP in which the
NRT was automatically activated in cases of spills of national
significance to coordinate actions in Washington in support
of the OSC.
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U.S. Coast Guard photo
HIGH PRESSURE WATER WASHDOWN OF ROCKY SHORELINE
One technique of removing oil from rocky shorelines involves high pressure water washdown. The flushed oil is collected
by booms and removed with skimmers.
11. Priority of Oil Spill Response Readiness
In many OSC analyses, observations were made that support
for oil spill response readiness has declined over the years.
Similar declines have been observed in the readiness of
industry and the States. Following the Torrey Canyon oil
spill off the coast of England in 1967 and the Amoco Cadiz
oil spill off the coast of France in 1978, the priority of oil
spill response became very high for the public, industry and
government. Reports similar to this one and those of the
American Petroleum Institute and the State of Alaska have
been written, expanded legislation has been passed, and
commitments have been made to improve support for oil
spill response. However, in each case, as time has passed
following these catastrophic oil spills, the system has
gradually deteriorated. During each annual budget cycle,
support for oil spill response has become increasingly
vulnerable to other priorities, as have priorities for staff
assigned to oil spill response in industry as well as Federal
and State governments. In each of these cases, as the
memory of a catastrophic oil spill fades, we as a Nation have
appeared to become complacently confident that we can
handle any situation-or that we believe we have become
immune to catastrophic oil spills. The exception to this
trend, in many cases, is in the perspective of the OSCs, who
are called upon to be prepared to respond to such spills.
Many OSC reports, therefore, contained observations, some
forceful, that a reliable response system cannot be
maintained in the face of such uneven commitments to oil
spill response. These observations were made by Federal
OSCs concerning the Federal response system. However,
similar observations, while not documented in this study, can
also be made about industry and State oil spill response
organizations.
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IV. CONCLUSIONS
The following conclusions note strengths as well as deficiencies or limitations of the National
Response System which are of priority concern. These issues result from both the contingency
plan reviews and the worst-case scenario analyses. They reflect lessons learned in the response
to the Exxon Valdez incident. These findings apply particularly to a response to a catastrophic
or worst-case scenario, but they also reflect some aspects of the system in day-to-day
operations. The order in which items appear is not an indication of their priorities; however,
these conclusions do correspond by number to the recommendations in Chapter V.
CONCLUSIONS REGARDING THE
NATIONAL RESPONSE SYSTEM
These conclusions pertain to the overall National Response
System.
1. The National Response System is not generally able to
handle a catastrophic spill.
Hie system shows itself to be "stretched thin" handling
simultaneous responses to medium or major spills
whose plans depend on the same contractors, strike
forces, and other key personnel mobilized from other
locations.
Our national capacity to respond to catastrophic oil spills,
such as the Exxon Valdez oil spill, is currently high on the
national agenda, as it had similarly become following other
catastrophic oil spills resulting from the accidents of the
Torrey Canyon in 1967 and the Amoco Cadiz in 1978.
However, because such catastrophic oil spills occur only
infrequently, industry and public agencies at all levels often
become complacent in their commitment to respond to such
events as the time between them increases.
Developing the worst-case scenarios, envisioning "high-risk,
low probability" spills for various locales, underlines certain
weaknesses of the response system's performance in
implementing procedures described in the National
Contingency Plan (NCP). The three June weekend spills,
each in the neighborhood of 300,000 gallons, proved the
strength of the plan, but they also validated lessons learned
from the Exxon Valdez incident. The National Response
System-local and private responders, Federal agencies,
States, RRTs, and the NRT-will not always be able to
mobilize qualified manpower and appropriate equipment
and still maintain the sufficient depth in reserve to deal with
cumulative impacts of simultaneous spill cleanup operations
(three June weekend spills while the Exxon Valdez cleanup
continued), or sustained operations when a complex cleanup
lasts for an extended period of time.
The Exxon Valdez spill in excess of 10 million gallons was
clearly an incident that showed the limitations of both the
National Response System and the underlying assumptions
made in most contingency plans. However, the quantity of
oil spilled is not the sole test of the response system. Local
conditions such as weather, nature of the product, geography
and location of the spill, media attention, and public and
political interest can all greatly affect the ability of the
system to respond. Had the Exxon Valdez spill occurred
under different conditions, the effectiveness of the response
could have been significantly different.
The NCP defines minor, medium, and major spills. The
Exxon Valdez experience and the worst-case scenario
projections point up the lack of an additional definition to
delineate how the NCP framework works in response to a
catastrophic spill or other spills of national significance.
2. Hie fundamental concepts of the National Contingency
Plan are sound, and the National Response System
routinely handles minor, medium, and major spills
successfully.
On June 23 and 24, 1989, three major spills took place in
Rhode Island, Delaware, and Texas, each approximately
300,000 gallons, and were handled quickly and effectively,
while the massive Exxon Valdez effort was still underway.
The responses followed existing National, Regional, and local
contingency plans and in each case the response system
performed well. Current RRT and OSC reports say in
various ways that even for major spills, call-up of the wide
range of support services provided for in the NCP and RCPs
results in successful responses.
3. There is no clear-cut strategy for applying National
Contingency Plan concepts to the mobilization of the full
strength of the nation for response to spills of national
significance.
The National Contingency Plan establishes the membership
and the general roles of the National Response Team and
the Regional Response Teams in support of the OSC and
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provides for them to convene when necessary. The NCP,
however, was not intended to serve as a step-by-step guide
or cookbook for responders' actions, nor to detail facilities
and duty rosters-what the military calls "watch, quarter, and
station bills"—for appropriate coordination and
communications, public information, record-keeping, and
reporting at the national levels on the large-scale and for the
long-term as required by a "low probability-high risk"
incident such as the Exxon Valdez. The best organization
and logistics scheme cannot be implemented without ready
access to sufficient manpower and equipment.
The NCP provides the policy and an action framework
readily applicable to spills that are catastrophic or of national
significance. What is missing is the strategy for the elevation
of response management from the local level to the regional
or national level as may be demanded by the exigencies of a
spill of national significance. There is no strategy for a
large-scale marshalling of additional manpower and
equipment reserves to coordinate widespread use of national
and international, Federal, and private industry sources to
sustain a response to an incident lasting for weeks or
months.
The lack of such a strategy results in two kinds of
problems-Federal management of the incident is fragmented
among agencies with diverse legislative responsibilities and
the information that circulates among senior Executive
Branch officials, Congress, and the public press is sometimes
contradictory and often confusing.
CONCLUSIONS REGARDING
RESPONSE SHORTFALLS
These conclusions were mainly derived from the shortfall
lists prepared by OSCs in evaluating their worst-case
scenarios.
4. Sufficient reliable response equipment is not always
readily available.
The response community relies on a common pool of
equipment. Industry-maintained, contractor-supplied, and
supplemental government-owned equipment does not exist
in adequate supplies, nor is it sited in appropriate locations.
Cleanup contractors and cooperatives are a valuable
resource, with the response capability to respond to the vast
majority of spills. However, they do not have sufficient
resources to handle a catastrophic spill. Also, much of the
known stockpiled response equipment may no longer be in
a usable condition. Much of the equipment stockpiled for
spill response was procured ten or more years ago. These
were shortfalls common to most OSCs. All others expressed
deep concerns about the lack of readily available equipment
to be mobilized at potential spill locations.
The lack of a credible equipment inventory is a major
handicap. When this equipment is needed for a major spill,
it must be tracked down by a series of phone calls and
referrals while the incident response is in progress.
Furthermore, there exists no good analysis of what the real
capabilities are for the response equipment that is out there,
as opposed to the advertised capabilities.
S. There is a shortage of trained and experienced response
personnel certain to be on duty or readily available upon
notification of a major spill.
There is a shortage of trained Federal response personnel in
position to be mobilized, particularly in the critical early
hours following notification of the spill and before additional
trained personnel can be brought to the area from other
sources. In some port areas, due to a lack of sustaining
business, there is also a shortage of both trained cleanup
contractor personnel and manual labor needed for shoreline
cleanup.
A shortage of personnel also occurs within the Federal
Government for several reasons:
Cost-saving personnel reductions or relocations for
higher priority missions have often stripped Federal
agency response units to the minimum necessary to
handle common day-to-day occurrences, with no reserves
and no depth at key positions.
Personnel rotations and job turnovers often mean
untrained personnel must fill front-line response
positions until they are adequately trained and
experienced.
Many RRTs and NRT agencies have a need for
additional people on their staffs with the knowledge,
seniority, and experience to assist with planning, review,
and liaison.
The multi-mission organization of the Coast Guard gives
the public more "bang for its buck," but occasionally
mission priorities conflict and oil spill response
preparedness has not always been the winner. Similarly
within other agencies, corollary duties of both planning
and response personnel often have higher priority than
oil spill contingency planning and response preparedness.
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6. The private sector cleanup capability on which the
National Response System relies has dwindled over the
years.
Actual contractor availability and capabilities may not
match what contingency plans say and OSCs expect
Federal response agencies rely primarily on contractors to
provide cleanup equipment and personnel. Private industry
also relies largely on the same contractors.
There is no provision for systematic testing of contractors
through drills or exercises to verify the advertised capabilities
and ensure that the contractor is available for a variety of
spill response scenarios.
CONCLUSIONS REGARDING
CONTINGENCY PLANNING EFFORTS
These conclusions are about the various oil spill contingency
planning activities throughout the country.
7. While there are some bright spots among examples of
contingency plan coordination at local community levels,
coordination is not good enough to assure consistent
nationwide coverage.
Predesignated Coast Guard OSCs often have good
interaction with local governments, contractors, and industry
representatives and are often actively involved with groups
jointly addressing response problems. One of the reasons
for this is that the nature of the Coast Guard organization
traditionally involves it closely with port communities.
On the other hand, local Federal oil spill contingency plans
addressing specific inland areas are generally not in place as
they are for coastal areas, or if they exist, they are not as
comprehensive. Local inland plans addressing specific
geographic areas are developed by communities, industry,
and States rather than by Federal OSCs. For local inland
contingency plans, Federal OSCs provide technical assistance
at the request of community leadership in developing plans
involving local government, industiy, and the State. In both
coastal ports and inland OSC areas, the resources for this
leadership role in contingency planning and coordination are
not accorded high priority among the other corollary duties
of OSCs and qualified planning personnel.
The number of private industiy facilities with the potential
to spill oil into the inland waters is large, but these
contingency plans, when they exist, are rarely coordinated
with Federal oil spill contingency plans. There is a lack of
coordination among various contingency plans required by
different Federal, State, and local regulations for the same
geographic area/facility.
At the local level, the Local Emergency Planning
Committees (LEPCs) have not generally addressed oil spill
response in the emergency response plans required under
Title III of the Superfund Amendments and Reauthorization
Act of 1986. Some State Emergency Response Commissions
and LEPCs, however, have expressed an interest in
expanding their planning to address oil spill hazards
identified by the facility reporting required by Title III.
The existing NCP provides the framework within which to
develop a mechanism or strategy for assuring compatibility
among various plans at all levels of government as well as
the private sector, perhaps for areas that are identical to or
complementary with already existing planning areas (such as
LEPC plans for planning districts.) Implementation of the
full NCP framework has been haphazard and needs to be re-
emphasized throughout the universe of responders.
8. Although most States have oil spill contingency plans,
the Federal Government and the States do not maintain
consistently good interface between their plans.
The Federal Government and the States each have their own
areas of authority and responsibility in preventing and
responding to oil spills. While this is as it should be, a lack
of coordination often results in each level of government
going its own way, reducing the effectiveness of the Nation's
oil spill prevention and response system and leading to
duplication of efforts and resources.
Most States have oil spill contingency plans. However,
effective coordination of those plans with the National and
Regional Contingency Plans now depends primarily on good
personal relations among officials rather than on specific
plans developed together and well-known to all of the
players-Federal, regional, State, local, and industry.
While most States have oil spill contingency plans, some
States had not regularly reviewed or updated their plans until
they were prompted to do so by the Exxon Valdez oil spill.
Preparedness at the State level is widely variable, but it
generally focuses on inland oil spills. One State said that it
leaves the coast to the Coast Guard.
9. Governors often do not have adequate knowledge of
Federal response plans, resources, and activities,
particularly during responses to catastrophic spills.
While States and Regional Response Teams may cooperate
in some planning and preparedness activities, they often do
not have a clear picture of each others' plans, resources, and
capabilities. This can result in misunderstandings and
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duplication of efforts, particularly during responses to
catastrophic spills. Federal and State agencies with shared
or overlapping responsibilities often do not know what to
expect from each other in the event of catastrophic spills and
have little information about each others' resources, technical
concerns, and decisionmaking processes.
10. There is a general lack of information transfer and
coordination between private industry oil spill plans and
the plans of various levels of government
Industiy plans are not generally known or coordinated at the
regional level. Consequently, there has only been limited
review and coordination of non-Federal plans by RRTs.
RRT or OSC knowledge of industry and co-op capabilities
and contingency plans could provide a better allocation of
scarce response resources by dovetailing availability of
industry equipment caches and skilled personnel with those
of the Federal, State, and local governments. The staffing
and equipping of additional Coast Guard Strike Teams and
the proposed Petroleum Industiy Response Organization
(PIRO) are two significant elements needing coordination
for such a response.
Spills can occur from industiy facilities or vessels, but also
from pipelines. Pipelines now rival waterborne commerce as
the primary transport mode for oil and oil products. There
is no requirement for pipeline operators to develop
contingency plans, although they must follow federally
prescribed procedures in the event of an emergency. This
absence of federally mandated pipeline contingency plans
leaves the local planners to deal with an uncertain planning
burden.
The Spill Prevention, Control, and Containment (SPCC)
program is a regulatory approach geared to enforcement of
prevention measures for above-ground storage tanks. There
is no focus on contingency plans in the event of a tank
failure, nor on information-sharing with local governments
on potential risks to neighboring communities. However,
EPA plans to revise the SPCC regulations to require
contingency plans.
11. Neither worker safety and health, nor health effects for
local residents potentially affected by a spill are properly
addressed in most oil spill contingency plans at any
planning level.
The health and safety of cleanup workers is an area of
concern, both for short-term and long-term cleanups, where
workers may be located in remote locations. Workers are
often not properly trained and not aware of potential
hazards.
Advance planning can address many of the human health
problems potentially associated with catastrophic or other
significant spills. However, the potential for human health
effects and stress-inducing socioeconomic effects are less
likely to be considered in oil spill contingency planning than
in planning for hazardous materials emergencies. Spill
responders need information on critical infrastructure and
socioeconomic features in the predicted path of the slick-
notably drinking water intakes—and expert knowledge on the
best protective and cleanup strategies. Access to alternative
water supplies is generally not pre-planned for in oil spill
contingency plans.
12. Sensitive or unique natural environments are
inadequately addressed in many existing contingency
plans.
There are many environmental problems potentially
associated with oil spills. Spill response teams need expert
knowledge on the best protective and cleanup strategies
available for use in different environments, and management
information on critical environmental and socioeconomic
features in the predicted path of the slick. Equipment and
procedures now exist for a computerized system that
combines trajectory modelling capabilities with digitized
maps, which can not only aid planners but also OSCs making
decisions on-scene about national resource protection during
an incident. Although environmental sensitivity mapping has
been done for many coastal areas in recent years, there are
areas not yet studied for environmental mapping, particularly
the remaining two-thirds of the Great Lakes shore areas.
The Nation's major navigable waterways and scenic rivers
are priority candidates for such mapping.
13. Procedures are not known or planned in advance for
transportation and disposal of oily waste from cleanup
operations.
Disposal of oil, oiled debris, and other oily waste creates
many problems even with spills of less than national
significance. The laws regarding the disposal of oil and oily
waste vary with each State. A catastrophic spill magnifies
the problems for the decisionmaker faced with the necessity
of waste disposal, whether by recycling, open burning, closed
incineration, or landfill dumping. Identification of licensed
or other appropriate disposal sites often does not start until
needed in the spill cleanup, rather than being pre-planned.
Difficulty in obtaining permits from State or Federal
agencies under the pressure of the urgent timeframes in spill
response situations may hamper the speed or effectiveness of
the cleanup. Public debate about such issues during the
stress of spill response operations is often ill-informed.
What response officials see as "bureaucratic red tape" may
be seen by local residents and media as a threat of adverse
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environmental or health effects. Less emotional, more
reasoned public dialogue is possible in a pre-planning mode.
14. There is a lack of a national guidance to assist RRTs
and OSCs in making reasoned decisions on the use or
non-use of chemical dispersants and other chemical and
biological agents.
In order to use dispersants and other chemical and biological
agents, the concurrence of the OSC, the EPA representative
to the Regional Response Team, and the affected State is
needed because of the potential for unwanted effects on
environmental resources such as marine ecosystems. The
approval process is perceived by industry responders and
others as taking too long to allow for the effective use of
dispersants during a particular spill, since delays can diminish
the effectiveness of the dispersant product. In contrast,
OSCs and RRT members perceive that the existing scientific
information does not adequately address the technical issues
that they must consider when evaluating whether dispersants
will be effective. Even if dispersion is effective, balancing
the harmful and beneficial consequences of dispersant use
requires a complicated, site-specific judgement, a situation
that would be aided but not entirely remedied by additional
information.
With respect to viscoelastic agents, bioremediation, and in-
situ burning, there is a lack of adequate experience in using
such response methods on actual oil spills. Additionally,
there is a lack of adequate research upon which spill
responders may base policies to more actively consider the
use of such techniques as a part of their spill response
planning and upon which OSCs may base decisions to more
actively encourage spillers to consider such techniques.
Some Regional Contingency Plans include pre-approval for
use of dispersants or other agents in specific geographic
areas, denoting on a map decisions made in advance.
However, State and Federal resource agencies are often
reluctant to grant pre-approval, and so plans call for
consideration of dispersant or agent use on a case-by-case
basis for all areas not so designated.
Many OSCs view this reluctance on the part of natural
resource agencies as a hindrance to timely and effective
response (i.e., another thing that must be worked out under
the pressure of an actual spill response). Such reluctance
may represent a de facto decision not to permit use of
dispersants in certain locations during a response under any
circumstances, but this "no-use" decision is not represented
in the contingency plan like the allowable use areas are.
Mechanisms are needed to facilitate rapid decisionmaking
regarding the use or non-use of dispersants, other chemical
and biological techniques, and in-situ burning for response
to oil spills.
Conclusive information is lacking on the effectiveness of
dispersants in responding to various kinds and sizes of
oil spills.
Certain spills may be so massive or occur under such adverse
conditions that dispersants cannot be expected to be
effectively applied. It may be impossible to stockpile or
otherwise access a large enough supply of dispersant, or the
equipment to apply it, in a timely and efficient manner to
assist in the response. There are no pre-established
parameters for making such determinations, and there is
conflicting evidence from scientists and others as to
dispersant effectiveness under a range of conditions. The
National Research Council has only recently completed a
major study on this topic, entitled "Using Oil Dispersants on
the Sea."
15. Exercises that realistically stress and test plans and
response system readiness are not held frequently
enough.
Exercising plans only once every few years is not enough.
Successful exercises have been conducted in recent years at
the local, State, regional, and international levels. In some
cases, the private sector has sponsored exercises that
included active government participation and tested all
phases of a coordinated response. However, none of these
kinds of exercises are held on a recurring, regularly
scheduled basis. Currently, no government agency routinely
conducts exercises that fully address the difficulties and
stresses presented by a major oil pollution incident.
Exercises conducted by individual agendes to ensure their
own mission capabilities often do not include participation by
neighboring or other concerned jurisdictions for such reasons
as a lack of coordinated exercise planning schedules or a lack
of funding available for participation. Mechanisms to share
training and exercise information among regions either do
not exist or are not used effectively.
16. Insufficient resources have been devoted to research and
development in the area of oil spill response, and there
has been a lack of coordination in focusing research and
development efforts.
There has been a decline in the level of research and
development during the past several years that has affected
research into more effective spill response equipment (e.g.,
booms, skimmers, and other methods of containing and
removing large volumes of spilled oil). This decline has also
resulted in a shortage of conclusive research on the effects
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of chemical and biological agents such as oil dispersants and
dispersed oil on the environment.
Consequently, we are little better off to respond to oil spills
than we were during the early 1970s. In a report to the
President following a catastrophic oil spill from the
grounding of the tank ship Torrey Canyon off the coast of
England in 1967, it was observed that equipment then
available to contain and recover such a spill were inadequate
in other than optimal conditions, and that pressure could be
expected, therefore, from spillers to disperse spilled oil or to
sink it. The same holds true today. Public and private
sector budgets to support research and development have
declined dramatically in recent years.
Efforts involving several Federal agencies and industry are
already underway on an informal basis to develop a more
coordinated approach to research and development in
anticipation of new Federal oil spill response legislation that
is likely to place greater emphasis on research and
development. The NRT has established a Research
Committee which plans to identify and assess the needs of
ongoing research and development efforts. This Committee
will serve as a forum for information exchange.
17. Operational communications between the OSC and on-
scene representatives are poor in many instances,
particularly during remote spill responses and in urban
areas.
Poor voice communications can severely hinder the OSCs'
decisionmaking ability. Problems include: use of different
frequencies by various responders and cleanup agencies;
distances which limit use of low output VHF radios to
basically "line of sight" communications; and high buildings
or hills between an OSC and OSC representatives which
limit communications.
Many OSCs believe that the use of cellular telephones is the
short-term answer to improving communications. However,
the lack of knowledge of cellular phones' capabilities and
coverage, coupled with budget restrictions, has hindered the
procurement of cellular telephones as standard equipment.
Satellite communication systems also offer great promise but
the use of these systems in response operations have not
been fully explored.
Electronic mail is a good way to transmit information which
is less urgent or otherwise impractical for voice phone
transmission; however, the different systems used by Federal,
State, and local agencies and industry are often not
compatible. The incompatibility of these systems hinders the
timely input of decisionmaking information.
18. The enormous demand for information from media, the
public, and from government officials during a
catastrophic oil spill response cannot be handled
exclusively at the OSC level and is not well-coordinated
among the various levels of the many agencies involved
During a catastrophic spill, information requests are directed
to the OSC, at the regional and national levels of the OSCs
parent organization, and to all other agencies involved at
their various levels. However, only limited public
information resources are available to assist existing means
of responding to these requests. A unified strategy for
responding to inquiries at the local, regional, and national
level will relieve many of these problems and promote public
awareness of the National Contingency Plan.
Frequent visits to the scene by local, State, and Federal
officials who feel they are deserving of the OSCs personal
attention distract the OSC from response management
duties, adversely affecting the effectiveness of the spill
response effort, especially during the first critical hours and
days. The randomly scheduled or unscheduled briefings and
on-the-spot interviews prompted by such visits can
undermine the sense of a well-ordered, credible information
flow.
19. Adequate payment for spill response manpower,
equipment, and support services from private and
government sources must be available at the time of the
incident
Whether funds to pay for cleanup and other activities
following an oil spill come from the responsible party or
from the Federal Government, the procedures for enabling
responders and other support personnel access to such funds
are not clearly understood, and determining the source of
funds and the method of payment may delay time-critical
response actions. Lack of certainty as to funding sources
may give rise to reluctance on the part of some cleanup
contractors to accept cleanup assignments. Further, it may
result in extraordinary expenditures by Federal agencies
participating in the response in support of the OSC being
paid by Federal treasury funds intended to be used for
mission program expenses, rather than costs being passed on
to the responsible party, the spiller.
20. Federal emergency procurement procedures and the
guidance for using them are cumbersome and not well
understood
Some contractors who do not get regular work may allow
their standing contracts to expire. Hence, they are not
available when needed. The alternative, hiring contractors
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through emergency procurement procedures, creates its own
problems-whether because of a lack of training in use of
these procedures, because of the complexity of the
procedures themselves, or because they are not used often
enough to become familiar. Contracting officers in the
Coast Guard are available only in area offices remote from
spill sites and are few in number. In addition, complex and
stringent governmental contracting procedures can make it
difficult for response officials to obtain contractor support
and equipment needed to respond rapidly to an oil spill.
21. Prevention is the most significant protection against the
potential for oil spills.
By focusing efforts on prevention, the Nation can do much
to protect the environment and public health while avoiding
the high costs of oil spill cleanups. Coast Guard spill
prevention programs such as the Vessel Traffic System and
the EPA's spill prevention, control and countermeasures
(SPCC) program have suffered from reductions in resources
in recent years which have kept the programs from
maintaining their maximum effectiveness.
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V. RECOMMENDATIONS
More must be done at all levels of government and by industry to improve the Nation's oil
spill preparedness and response capabilities. This chapter contains specific proposals for
meeting the challenge posed by oil spills of all sizes, including those of national significance,
and for augmenting areas in which support for oil spill response has been "stretched thin."
These proposals are almost identical to those resulting from previous evaluations of "lessons
learned" from previous incidents. These recommendations correspond by number to the
conclusions that appear in Chapter IV.
RECOMMENDATIONS REGARDING
THE NATIONAL RESPONSE SYSTEM
1. Oil spill response should have a high place on the
national agenda reflecting public awareness and concern
about oil spills. Further analyze the resource needs of
preparedness.
The task of shoring up the national capability to respond to
oil spills through the National Response System is imposing.
While the Federal Government can and should be a leader,
all levels of government-Federal, State, and local~and the
private sector must share the responsibility for improving the
Nation's response capability. Both industry and government
should make long-term commitments to increasing our oil
spill response capability which recognize that despite our
best efforts, catastrophic oil spills will occur. If we, as a
nation, rebuild our response capabilities in reaction to the
current priority of oil spills, and then again become
complacent, allowing the system to deteriorate as time
passes, we will have lost the most important lesson of the
Exxon Valdez oil spill.
This report is based on the presumption that all coastal areas
should be prepared to respond to a catastrophic spill. As the
following recommendations indicate, the potential resource
demands could be significant. We do no endorse
preparedness at any cost. As we have seen in the past,
funding for prevention and preparedness tends to drop as
time passes between events. A better approach for
preparedness is a level that can be sustained over time. We,
therefore, will analyze in the next months the
recommendations in this report to estimate their costs and
to determine how best to be prepared for catastrophic spills
over the long run.
2. Retain the basic structure and concepts of the National
Response System.
The basic National Response System relies upon industiy to
clean up most oil spills. The Federal On-Scene Coordinator
(OSC) stands ready to monitor cleanups to back up industry
responders or take control, if needed. The concepts are
sound; however, specific deficiencies in the National
Response System have been identified which require
corrective action by all levels of government and industry.
3. Develop a national strategy, implementing the National
Contingency Plan at the national level, involving top
levels of industry, the Federal Government, States, and
international organizations in response to "high-risk
low-probability" spills of national significance.
Spills of national significance require specifically preplanned
strategies for accessing and coordinating nationwide or
worldwide resources of equipment and expertise, to provide
additional support to the OSC commensurate with the
increasing demands of public and political interests.
Some key elements of the strategy would include:
Defining a spill of national significance.
Formally activating the NRT to coordinate actions in
Washington in support of the OSC, considering such
things as the need for qualified, experienced officials to
provide rotating backups for NRT member agencies with
key roles in the particular response, in the event of a
long-term response.
Providing for a smooth handoff of decisionmaking
authority from one managerial level to another as
demanded by a spill of national significance.
Providing for large-scale marshalling of additional
personnel and equipment from all available sources-
Federal, State, and local government agencies, and
private industiy (foreign as well as domestic)~and
identifying protocols to fully utilize these resources
during a response.
Developing additional considerations for "Federalizing"
a spill of national significance, if appropriate, for
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Presidential declarations, and other related jurisdictional
options.
Authorizing the Federal OSC specifically to direct
removal actions without assuming cleanup costs.
RECOMMENDATIONS REGARDING
RESPONSE SHORTFALLS
4. Stockpile larger amounts of state-of-the-art oil spill
response equipment
The current stockpiles of response equipment is not
sufficient nor adequate to respond to catastrophic oil spills
at the level that current technology permits. Even the
ambitious amounts of equipment included in the proposal of
the petroleum industry to establish the Petroleum Industry
Response Organization (PIRO) would not be sufficient to
respond to a catastrophic oil spill.
Since a catastrophic oil spill is by definition a high impact,
low probability event, and since it is impossible to predict
where the next such event could occur, it is not feasible for
either government or industry to stockpile these levels of
equipment at every location at which a catastrophic oil spill
may occur. Therefore, equipment should be stockpiled in
central locations. However, increases are also needed in the
equipment that is currently available in local areas, such as
major port areas, to support first response to catastrophic
oil spills until centrally stored equipment arrives.
Additionally, better ways of identifying how all equipment
can be mobilized in the event of a catastrophic release need
to be found, such as computerized inventories of equipment
available nationally.
Much obviously needs to be done, and the Federal
Government, through the NRT and the RRTs, should lead
the effort to further define the needs and responsibilities of
the private sector and the Federal, State, and local govern-
ments.
5. Provide response managers with a larger cadre of
trained personnel.
Industry, particularly the petroleum industry, and Federal,
State, and local governments should share a commitment to
expanding the number of trained personnel that would be
readily available to support oil spill response. Because the
sheer number of people that are needed to conduct a
response to a catastrophic oil spill is so great, it is not
feasible to expect that a complete, dedicated cadre of
personnel can be maintained either in the industry or the
government to respond to catastrophic spill events.
However, a core response network should be established
with other people in reserve that may have other day-to-day
responsibilities. These backup responders should have
sufficient training and current experience in spill response to
ensure that they can realistically be considered a part of a
reserve cadre. The priorities of these responders should be
such that they will be immediately available in the event of
a catastrophic spill. The Federal Government, through the
NRT and RRTs, should assume the leadership in
coordinating efforts to ensure that such a cadre of oil spill
response personnel is established. The NRT and RRTs
should coordinate the development of a national strategy to
resolve the difficult issues, such as training and liability, that
arise concerning the use of the many citizens who always
seek to volunteer their services during a catastrophic spill
event.
6. Challenge response contractors.
Effective incentive mechanisms need to be established by the
contracting agencies to motivate response contractors to
increase the depth of their capabilities to respond to oil
spills, including the numbers of trained response personnel
and the amount and quality of equipment they are willing to
have available to support either a responsible party or
Federal Government response to a catastrophic oil spill.
More aggressive procedures, such as realistic and
unannounced drills, should be established to better ensure
that contractors can deliver all that is promised in a crisis.
RECOMMENDATIONS REGARDING
CONTINGENCY PLANNING
7. Industry should lead aggressively in rebuilding our
national oil spill response capability, since it has the
primary responsibility for cleaning up oil spills.
Spillers of oil should continue to be primarily responsible for
cleaning up oil spills-catastrophic spills and smaller spills.
Therefore, potential spillers of oil, mainly the petroleum
industiy, should bear the primary share of a national
commitment to rebuilding our oil spill response capability.
The petroleum industry should fully implement its
commitment to the Petroleum Industry Response
Organization (PIRO), which includes five regional response
centers, manned with adequate trained personnel and
stockpiled with the levels of equipment that have been
proposed by the American Petroleum Institute, at a
minimum. Additionally, the petroleum industry should make
similar commitments to establishing a revitalized response
capability for oil spills on inland waters. The industry should
also make commitments to other proposals designed to
revitalize the network of private oil spill response contractors
and cooperatives.
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Finally, the petroleum industry should lead a national effort
to revitalize research and development designed to improve
our ability to respond to all oil spills. The proposals of the
industry following the Exxon Valdez oil spill to invest $30-35
million over five years to develop improved equipment to
respond to catastrophic coastal oil spills should be
implemented and expanded to include inland oil spill
response and the many oil spill response issues other than
equipment.
8. The Federal Government and the States should
coordinate their activities in a manner that provides the
Nation with the most efficient and effective oil spill
prevention and response system.
At the national level, the Federal Government and the States
should work together to define the roles and responsibilities
of the two levels of government in preventing and responding
to oil spills. At the State and local levels, the Federal
Government and the States should adopt formal agreements
that specify their responsibilities in planning for and
responding to oil spills.
9. Establish close liaison with Governors' offices.
To better support an effective National Response System,
heightened attention to Regional Response Team (RRT)
activities and State contingency planning should be fostered
among Governors. RRTs should consider assigning an
experienced, professional representative to the Governor's
office during a catastrophic spill response to assist in
coordination of Federal and State interests.
10. Exercise leadership to increase coordination between
industry and the RRTs on contingency planning.
RRTs should exercise leadership to increase the coordination
between Federal plans and some major industry contingency
plans, and to better allocate scarce response resources by
dovetailing available industry equipment and personnel with
those of the government. These methods of cooperative
planning would be far more effective and efficient than
Federal Government review and approval of industry plans.
The increasing risk of oil spills from pipelines, in addition to
other fixed facilities and vessels, and their associated risk of
spills into some areas that may not have previously been a
high priority for contingency planning should be incorporated
into both industry and government contingency plans.
11. Address worker and public safety and health more
thoroughly in contingency plans.
Better advance planning is needed to address the many
human health problems associated with large oil spills,
including catastrophic oil spills. Issues concerning the
application of Department of Labor training regulations to
the needs of a major mobilization in an emergency oil spill
response need to be resolved. Spill response teams need
better information on critical socioeconomic features in the
predicted path of the slick and expert knowledge on the best
protective and cleanup strategies, including strategies for
protecting drinking water intakes and for mitigating airborne
effects of oil spills.
12. Develop additional tools to support comprehensive
contingency planning for environmental features.
Sophisticated computer dedsion support systems can provide
valuable assistance to the OSC in identification of critical
environmental areas to be protected and assist in the
development of response strategies. While such systems are
currently under development for many areas, comprehensive
planning should more fully address the Nation's major
navigable and scenic rivers, the Great Lakes, and other
sensitive environments that could be affected by pipeline
spills as well as those from other fixed facilities and vessels.
13. Solve disposal issues.
Longstanding and difficult issues surrounding disposal of oily
waste can only be resolved by a cooperative effort among all
parties to the contingency planning process to find solutions
that meet the many legitimate interests of States, local
residents, responders, and responsible parties. RRTs should
provide a forum for airing these interests and seeking
constructive solutions.
14. Seek a national consensus concerning the use of
dispersants, other chemicals, biological techniques, and
in-situ burning for response to oil spills.
There is no clear national policy on the use of dispersants or
viscoelastic, bioremediation and in-situ burning agents, and
the state of current knowledge does not support development
of such a policy. Barriers to developing such a national
policy and to making decisions to use or not use such
response methods should be removed. There should be
more action under the existing preplanning authorities in the
NCP to narrow the range of doubt concerning locations and
circumstances, if any, in which dispersants and other agents
may be considered as an available response method. When
appropriate, this action should channel preauthorization fay
Federal and State officials through the RRTs to provide
OSCs with more guidance, a mechanism which exists in the
NCP as an alternative decisionmaking process. However, the
petroleum industiy, the States, and other parties affected by
oil spills along with Federal agencies have an equally
important role in promoting a constructive consideration of
national policy concerning the use of dispersants. The
extremes in which such issues are too often presented must
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be moderated on all sides. Realistic assessments of the
circumstances under which chemical dispersants will and will
not work to disperse an oil slick—and the circumstances
under which dispersing an oil slick will increase or reduce
overall risk-must be a goal of all parties, addressing first
those geographic areas in which the risk of major oil spills is
the greatest. Procedures need to be developed to allow for
rapid decisionmaking regarding the use or non-use of
dispersants, other chemical and biological techniques, and in-
situ burning for response to oil spills. Agreements may be
made to preapprove or to designate areas of non-approvals,
resulting in a narrower range of factors that an OSC must
consider at the time of a spall. More also needs to be done
to promote active, realistic consideration of viscoelastic
agents, bioremediation, and in-situ burning in appropriate
circumstances. More use of such techniques on a trial basis
during actual spill responses should be considered, and more
research should be sponsored to resolve issues that may
deter responders from more actively considering such
response methods.
IS. Make contingency plan exercises a higher priority.
Oil spill contingency plans at all levels of government and
industry should be exercised more frequently to ensure that
plans remain active and planning assumptions continue to be
challenged. Exercises should be coordinated among all levels
of government and industry that more realistically simulate
actual response situations. Exercises should be designed that
genuinely stress response mechanisms. A goal of exercising
all contingency plans periodically should be established.
Existing mechanisms, such as interregional conferences,
should be better structured to permit frank dissemination of
weaknesses and other lessons learned from exercises.
Emergency planning requirements for potential pipeline
discharges should, to the extent practical, be comparable to
those for nonpipeline-connected facilities (e.g., nonpipeline-
connected storage facilities) and other transportation-related
operations (e.g., rail, truck, and barge). Consideration
should be given to establishing regular and intense exercises
of pipeline emergency plans, on the order of that required
for these other facilities and operations. It is also important
to increase coordination of pipeline oil spill contingency
plans with other applicable contingency plans, such as RRT,
OSC, and LEPC plans.
Although the Federal Government maintains an effective
program for ensuring public safety, more can be done to
address oil spill response and cleanup capabilities,
particularly in the areas of training and the use of equipment
under emergency conditions. In order to make these
improvements, an effort should be made to establish an
ongoing relationship between the Department of
Transportation's (DOT) five regional pipeline offices and the
RRTs. As a first step, the DOT Office of Pipeline Safety
should use industry data to take an inventory of oil pipeline
spill plans and communicate that information to the RRTs
through each of the DOT regional pipeline offices.
16. Strengthen research and development
Governmental and private research is needed to advance the
current state of oil spill response technology and must be a
high priority. Research is needed to find better ways to
contain and remove large volumes of spilled oil under less
than ideal operating conditions and to resolve issues
concerning the effectiveness and environmental consequences
of dispersants and other chemical and biological
countermeasures. Research is also needed to evaluate
emerging response technologies, such as in-situ burning of
oil, bioremediation, and chemical shoreline cleaning.
Federal agencies and industry efforts are currently underway
to accomplish this goal, and should continue to encourage
and enhance ongoing and coordinated research and
development activities.
17. Improve operational communications capabilities.
Procedures and equipment for on-scene communications
should be assessed and upgraded, and communications
systems should be standardized to the greatest degree
possible. The forum of the RRTs and NRT should be used
to determine legitimate tradeoffs concerning standardization.
Communications equipment should be stockpiled for all
reasonable response scenarios, including spills that occur in
urban areas with heavy radio traffic and in remote settings
such as rural areas and at sea where geographic features and
distances may impede radio communication. RRTs should
involve Federal, State, local, and industry planners and
responders in a timely nationwide effort to evaluate
communications needs, including procedures and hardware,
and to adopt recommendations to improve communication
capabilities.
Broader communications mechanisms, including standard
and networked electronic mail systems are needed to provide
RRT members and others with time-sensitive information for
response to OSC requests and to facilitate agency response
decisionmaking. This wider electronic network can also
serve the needs of Washington-based executive branch
officials by providing up-to-date incident reports during
major or potential major spills.
RRTs should establish communications networks or other
mechanisms to ensure that responders and all concerned
government agencies consistently receive timely information
concerning the issues relevant to the response. This will
make it unnecessary for agencies to establish redundant
information gathering mechanisms.
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Electronic data bases providing scientific and technical
information to responders, and both historical and current
statistical information to managers and decisionmakers
should be identified, and standardized procedures developed
for accessing them.
18. Communicate more effectively with the public.
The NRT and RRTs should assist the lead responding
agency in operating centralized information centers at the
national and regional levels during spills of national
significance. By providing sources of coordinated, timely,
and accurate information, the NRT and RRTs allow the
OSC and staff more time to assimilate input and prepare
information to be relayed through these regional and
national information centers to the public via the media. A
greater emphasis on media and public relations should also
be a part of routine NRT and RRT planning, exercises, and
strategy development activities.
19. Find adequate methods of funding Federal oil spill
response.
The Federal Government should not relieve parties
responsible for spilling oil of the obligation to be the primary
responders to oil spills, large and small. However, when a
spiller cannot be found or if a spiller is not conducting a
proper response, the OSC should be certain of his or her
ability to assume the cleanup. Therefore, a better method is
needed than is currently available under the Clean Water
Act for funding a "Federalized" response by the OSC, when
it is necessary. Moreover, the OSC should not be
constrained to consider only a complete federalization of an
oil spill response if a spiller is conducting a proper response
of some portions of the removal. Additionally, policies
should be established to more efficiently channel funding, in
cases in which a response is not "Federalized," to agendes
of the government that provide services requested by a
responder, such as supervision of wildlife rehabilitation.
Comprehensive oil spill legislation should address many of
these concerns.
20. Streamline Federal emergency contracting procedures.
Federal Government emergency contracting procedures
should be periodically reviewed to ensure that they permit
the maximum possible authority to procure unforeseen
support that is necessary in an emergency. Existing contracts
should also be reviewed periodically to ensure that they
remain current and support realistic response needs.
21. Increase the commitment to prevention.
The priorities of successful prevention programs, which have
been raised by the government and industry alike following
several large oil spills, must remain high. Examples include
the EPA spill prevention, control and countermeasures
(SPCC) program and the Coast Guard marine safety
program and commercial vessel safety mission. Priorities
must also be raised for enforcing compliance with these
programs.
Effective prevention programs require substantial, long-term
commitment of resources. During periods of budgetary
austerity or when no catastrophic spills have occurred for
several years, there may be a temptation to reduce efforts in
this area. But the commitment to prevention is an
investment that will more than pay for itself in protection of
the environment and public health, and in avoiding the high
costs of cleaning up catastrophic oil spills such as that which
occurred with the Exxon Valdez.
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APPENDICES
Appendices-i
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APPENDIX A
Summary of Regional Response Team Contingency Plans
The following are summaries of the status of contingency plans, training and activities as submitted by the Regional Response
Team (RRT) co-chairs. The content of each summary depicts the plans and activities within the particular RRT and reflects
the unique and individual character of the respective RRTs.
REGION I
(Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont)
STATUS OF CONTINGENCY PLANS:
The Atlantic Operational Appendix to the Canada-United
States Joint Marine Pollution Contingency Plan was
reviewed, updated and approved on October 3, 1989.
The Region One RCP is in the process of review and update
by the Preparedness Committee of the RRT. Sections of the
plan have been assigned to individual agencies for particular
scrutiny.
As per direction of the Commandant of the USCG, the
Captains of the Port have reviewed and, in many cases,
substantially revised their local contingency plans. This effort
included the validation of emergency notification lists,
coordination with state and local contingency plans,
development of worst-case, credible worst-case and average
case oil spill scenarios.
EPA Region One's current oil spill contingency plan is contained in the Regional Contingency Plan. EPA Region One
developed six sub-regional plan, one for each state. However, they have not been revised or updated since the early
1980's due to reprogramming of funding into the hazardous waste site clean up activities.
Three of the six states in the region report having numerous plans in effect - most have been updated in the past two
years.
Department of the Interior, Navy and Department of Agriculture all have plans in place.
TRAINING AND EXERCISES:
MSO Portland, ME and the State of Maine held a table-top response drill in August 1989. Casco Bay 89, a spill
response exercise, was held on September 11-13, 1989. This drill involved approximately 150 personnel from the State
of Maine, Group Portland, MSO Portland, Air Station Cape Cod, PIAT, District, RTC Yorktown, and the three primary
local response contractors. Field operations included deployment of over 4,500 feet of boom, vac trucks/barge
combination, and skimmers at three sites in Casco Bay. Two spill response symposiums were held on September 26
and 30.
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COASTAL ZONE ACTIVITIES:
On June 23, 1989, the tankship Worid Prodigy ran aground at the mouth of Narragansett Bay, RI, spilling 293,000
gallons (10,000 bbls) of heating oil.
INLAND ZONE ACTIVITIES:
On June 17, 1988, during a major chlorine release and fire in Springfield, MA, the OSC requested the RRT to assist
with CAMEO information. CAMEO's air model was used to determine the downwind impact area.
In July 1989, a 70,000 gallon (1,667 bbls) tank in South Boston, MA, began leaking into it's dike at the floor/wall
interface. No oil was lost to the harbor.
FUTURE PLANS:
FEMA will assist the State of Vermont in the development of an oil spill prevention and response plan for Lake
Champlain.
A table-top exercise in cooperation with Vermont, New York, Quebec, RRT Region II and industry is planned for
March 1990 with a field simulation planned for May 1990.
A joint Canada-United States oil and hazardous substances simulation will be held in 1990.
REGION II
(New York, New Jersey)
STATUS OF CONTINGENCY PLANS:
Region II RRT has developed a Regional Contingency Plan
(RCP) and it is updated three or four times per year.
The Coast Guard COTP New York Local Contingency Plan
was computerized and updated in 1987. The plan has been
subsequently updated to reflect the latest information along
with information requested by the Commandant of the Coast
Guard as a result of the Exxon Valdez.
EPA Region II has developed a Local Oil and Hazardous
Substances Contingency Plan (LCP) for its OSCs. An
extensive revision was completed in September 1989 and it
will be updated semi-annually.
EPA Region II indicates that New York and New Jersey have contingency plans with well developed response
capabilities and have outlined them in their contingency plans. Each state has detailed guidelines on when to notify
the Federal government of a major incident in its Chemical Emergency Preparedness Program State Implementation
Memorandum (SIM), which it signs with the EPA each year.
The International Joint Commission has the St. Lawrence River supplement - Marine Contingency Plan for spills of oil
and other noxious substances.
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TRAINING AND EXERCISES:
On July 13-14, 1988, an OSC/Joint Region II/III RRT exercise was conducted in Philadelphia, PA.
COASTAL ZONE ACTIVITIES:
On January 25, 1989, the tank barge Bouchard 15 grounded in the Hudson River spilling 11,300 gallons (269 bbls) of
number 2 oil.
On May 5, 1989, the tank barge B-45 grounded in the Hudson River near Catskill, NY, spilling 78,000 gallons (1,857
bbls) of gasoline.
On June 14, 1989, a 10,000 gallon (238 bbls) spill of number 2 oil entered the Manasquan River, NJ.
On September 14, 1989, the tank barge Morania 440 grounded in New York City's East River spilling 76,000 gallons
(1,810 bbls) of gasoline.
INLAND ZONE ACTIVTTIES:
In April 1989, a 15,000 gallon (357 bbls) storage tank in Somerville, NJ leaked 5,500 gallons (131 bbls) of number 4 fuel
oil.
REGION III
(Delaware, District of Columbia, Maryland, Pennsylvania, Virginia, West Virginia)
STATUS OF CONTINGENCY PLANS:
The Regional Contingency Plan was developed by the RRT
working with representatives of Delaware, Maryland,
Pennsylvania, Virginia, West Virginia and the District of
Columbia and was revised in July 1988.
The Coast Guard MSOs have all completed an evaluation of
worst-case scenarios and equipment shortfalls in accordance
with the Commandants order. In addition, each MSOs full
LCP is being revised. The RRT has been an active
participant in this process.
All the states in the region reported having one or more
plans in effect.
Various organizations of the federal government have plans maintained by Region III RRT.
TRAINING AND EXERCISES:
On July 13-14, 1988, an On-Scene Coordinator/Regional Response Team Simulation Drill was conducted in
Philadelphia, PA. Approximately 450-500 people attended this combined Region II and III activity. This exercise
included a real time notification drill conducted in advance. All member States participated except Maryland and West
Virginia who cited out-of-State travel bans or personnel shortages for their non-participation.
On October 26-27, 1989, an unannounced spill drill and equipment exercise was conducted at the Amoco Refinery in
Yorktown, VA and included personnel and equipment from SUPSALV, Lant Area Strike Team, local Navy commands
and contractors. The drill was sponsored by Amoco, MSO Hampton Roads and the Commonwealth of Virginia.
Appendices-3
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On May 30,1989, a Hazmat Drill/Exercise was conducted at the Conrail Conway Yard in Conway, PA. The drill was
sponsored by EPA Region III, MSO Pittsburgh and the RRT. It involved Federal, State and local response
organizations as well as local industry.
REGION ACTIVITIES:
On January 2, 1988, an Ashland Oil storage tank collapsed spilling 1,000,000 gallons (23,810 bbls) of number 2 diesel
oil into the Monongahela River in Pittsburgh, PA.
On October 7, 1988, the RRT was activated for a potential major spill of light Nigerian crude oil 35,243,670 gallons
(839,135 bbls) from the tankship Jahre Spray, at Big Stone Anchorage, Delaware Bay (included members of both
Federal Regions II and III).
On October 7, 1988, the RRT was activated for a potential major spill of 924,000 gallons (22,000 bbls) of asphalt and
15,000 gallons (357 bbls) of diesel fuel due to fire on the tank barge Smith Point, five miles due east of Atlantic City,
New Jersey (included members of both Federal Regions II and III).
On October 25, 1988, the RRT was activated for a potential major spill of 21,367,374 gallons (508,747 bbls) of Arabian
crude oil from the tankship Sea King aground seven nautical miles east-southeast from Cape Henry, VA.
On June 24, 1989, the tankship Presidenie Rivera grounded in Marcus Hook, PA, spilling 307,000 gallons (7,310 bbls)
of number 6 oil.
RRT III has averaged 20 incident-specific activations each year for the last few years, and that number is expected to
increase as common communication systems improve and activation criteria are refined.
FUTURE PLANS:
An OSC/RRT drill is scheduled for August 1990 in Baltimore, MD.
EPA and USCG OSCs will meet during 1990 to develop Multi-Agency Local Response Teams (MALRT) using the
COTP Philadelphia MALRT as a model.
REGION IV
(Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee)
STATUS OF CONTINGENCY PLANS:
The Region IV Regional Contingency Plan has been
reviewed and is presently being updated.
All U.S. Coast Guard OSC Local Contingency Plans (LCPs)
are currently under revision. Each has been reexamined by
the OSCs to determine whether the plan provides for
response to catastrophic releases of oil. The results of this
review and the identified shortfalls developed from that
review have been provided to the NRT by the Coast Guard
Appendices-4
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OSCs. The estimated date of completion of the revision of the LCPs is now February 1, 1990. The RRT has not had
the opportunity to review these plans.
EPA OSCs within Region IV do not maintain local contingency plans.
The RRT has not had the opportunity to conduct a review or compile an accurate inventoiy of all existing response
plans.
TRAINING AND EXERCISES:
The RRT held an OSC/RRT exercise in Wilmington, NC in February 1989.
COASTAL ZONE ACTIVITIES:
On June 4, 1988, the dredge Crest sank in heavy weather in the entrance channel to St. Mary's River spilling
approximately 10,000 gallons (238 bbls) of fuel oil. RRT members were actively engaged in salvage planning to
minimize any environmental damage during the raising of the vessel.
INLAND ZONE ACTIVITIES:
On January 23, 1989, a spill of 90,000 gallons (2,143 bbls) of gasoline from a tank occurred in Greensboro, NC.
FUTURE PLANS:
An OSC/RRT response simulation is scheduled for Miami, FL in June 1990.
REGION V
(Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin)
STATUS OF CONTINGENCY PLANS:
The Region V Regional Contingency Plan (RCP) was last
updated in March 1986. The RCP also serves as the local
plan for EPA OSCs.
The Ninth and Second Coast Guard Districts' plans are being
revised and will be completed by February 1, 1990.
The Contingency Plans Branch of the Fourth U.S. Army is
currently revising the military contingency plan.
Five of the six Region V states have formal spill contingency
plans. Three of the five plans were last revised in 1980.
TRAINING AND EXERCISES:
An RRT/State of Illinois/City of Chicago tabletop exercise was held on April 18, 1988.
An OSC/RRT exercise was held in Milwaukee, WI in April 1989.
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COASTAL ZONE ACTIVrTIES:
In September 1988, the tankship Sibyl W. grounded, resulting in a potential spill of 1,300,000 gallons (30,952 bbls) of
gasoline and cleaning fluids.
In April 1989, the tank barge Scurry grounded, resulting in a potential spill of 1,300,000 gallons (30,952 bbls) of carbon
black feedstock.
FUTURE PLANS:
The Ninth District and the Canadian Coast Guard are exploring the possibility of deploying open water equipment as
an element of the FY 1990 CANUSLAK exercise.
REGION VI
(Arkansas, Louisiana, New Mex
STATUS OF CONTINGENCY PLANS:
The Regional Contingency Plan (RCP) was last completely
revised in 1985. Annual updates with the latest being
01 August 1989, have been made to the list of personnel
comprising the RRT. A complete review will be undertaken
after publication of the revised National Contingency Plan.
The "Agreement of Cooperation Between the United States
of America and the United Mexican States Regarding
Pollution of the Marine Environment by Discharges of
Hydrocarbons and other Hazardous Substances" provides for
the establishment of a United States-Mexico Joint
Contingency Plan (JCP) for the Gulf of Mexico and the
Pacific Ocean. The USCG and the Mexican Navy are the
responsible agencies for the JCPs.
Updated Coastal OSC Contingency Plans are to be revised by the Coast Guard OSCs and approved by the District
Commander not later than February 1, 1990.
Of the five states in Region VI, only Texas and Oklahoma have oil-specific contingency plans.
The DOD, DOE, DOI and other federal agencies have contingency plans addressing oil spill response at their facilities.
The level of involvement by the RRT varies for each plan.
The Louisiana Offshore Oil Port (LOOP) maintains an oil spill contingency plan that is regularly updated.
Oil Facilities on the Outer Continental Shelf are required to have Contingency Plans. The Coast Guard and Minerals
Management Service have been meeting to discuss review and exercise procedures for these plans.
TRAINING AND EXERCISES:
An OSC/RRT exercise was held in New Orleans, LA in September 1988.
An OSC/RRT exercise was held in Morgan City, LA in June 1989.
Minerals Management Service is requiring lease operators to fully deploy equipment during spill response exercises.
Oklahoma, Texas)
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The Atlantic Area Strike Team conducted an exercise involving deployment of open water containment boom in Corpus
Christi, TX, on June 21, 1989.
The Louisiana Offshore Oil Port (LOOP) conducted an oil spill response exercise in April 1989 which involved all levels
of response and included deployment of equipment.
A Joint Response Team Oil Spill Drill was held at Tampico, Mexico on November 15, 1989. Representatives of the
Coast Guard, EPA and State of Texas participated. The Mexican Navy and PEMEX, the Mexican National Oil
Company, deployed spill response equipment during the drill. The Joint Response Team draft Contingency Plan, based
upon an international agreement, was reviewed.
COASTAL ZONE ACTIVTTIES:
In March 1988, the Amoco Oil company had an oil well blowout in Charenton, LA, of 1,000,000 gallons (23,810 bbls).
On July 13, 1988, the tankship Nord Pacific spilled 645,000 gallons (15,357 bbls) of heavy crude oil into the Corpus
Christi Industrial Canal.
On September 3, 1988, the tankship Esso Puerto Rico, spilled 990,000 gallons (23,571 bbls) of carbon black into the
Lower Mississippi River at mile 114.
INLAND ZONE ACTIVITIES:
On May 5, 1988, the Shell Oil Company refinery in Norco, LA, had a major explosion and fire involving approximately
1,092,000 gallons (26,000 bbls) of miscellaneous hydrocarbons.
In April 1989, Chevron Oil Company had a 5,880,000 gallon (140,000 bbls) tank spill in Port Arthur, TX. Spill
containment prevented any oil from reaching the water.
FUTURE PLANS:
Two spill exercises are planned, one by the Coast Guard in Port Arthur, TX in September 1990 and one by the Texas
Emergency Management Agency at Corpus Christi, TX, in April 1990. The RRT is recommending that a dispersant use
exercise be conducted in the Gulf of Mexico that would include the use of oil. The purpose would be to gain necessary training
and experience in the use of dispersants.
REGION VII
(Iowa, Kansas, Missouri, Nebraska)
STATUS OF CONTINGENCY PLANS:
The Regional Contingency Plan (RCP), dated 1982, is being
completely revised - contact lists are updated regularly.
Recent Coast Guard direction has extended the time to
review and update each Local Sub Regional Oil and
Hazardous Material Contingency Plan to February 1, 1990.
The rewrite of the LCP will change the plan from a resource
document to one that also includes an action plan to respond
to a worst-case scenario within the marine environment of
Appendices-7
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OSCs. The estimated date of completion of the revision of the EPA MOU area. Coast Guard plans will not address
initial pollution response outside the MOU area. This remains the responsibility of the EPA.
All the responding federal land managing agencies reported that they have national and/or regional contingency plans
which address oil spills. In addition, many individual facilities or land management units (e.g., National Parks, National
Forests) have or are in the process of preparing facility-specific or area-specific lands. In addition, all contractors,
lessees, or permittees, utilizing non-DOD Federal lands are required to prepare and maintain a spill contingency plan
as a condition of their contract, lease, or permit.
TRAINING AND EXERCISES:
The most recent OSC/RRT exercise was held in St. Louis, MO, in 1987.
COAST GUARD ACTIVITIES:
On December 24, 1988, a pipeline ruptured in Vienna, MO, spilling 840,000 gallons (20,000 bbls) of sweet crude oil into
the Gasconade River.
EPA ACTIVITIES:
On June 12, 1989, a leak in underground tank piping released 15,000 gallons (357 bbls) of gasoline in Memphis, MO.
FUTURE PLANS:
An OSC/RRT exercise is scheduled for Kansas City, MO, in April 1990.
REGION VIII
(Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming)
STATUS OF CONTINGENCY PLANS:
The Regional Contingency Plan (RCP) was last updated in
1985 and is currently being revised.
The 2nd Coast Guard District encompasses both Regions VII
and VIII. Comments regarding Coast Guard contingency
plans for Region VII apply to Region VIII as well.
While individual Federal and State RRT members may be
reviewing their oil spill contingency plans, the RRT has
focused on identifying plans and response capabilities, rather
than reviewing individual plans.
Although all 6 states have spill reporting, notification, and/or
cleanup policies, only two have specific oil spill contingency
plans. At the local level, oil spill response (if addressed)
would be included in the local emergency operations plans.
In addition to the RCP, Region VIII EPA has also developed the North Platte River Federal-Local Oil and Hazardous
Substances Pollution Contingency Plan.
Various pipeline companies maintain oil spill contingency plans.
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TRAINING AND EXERCISES:
An OSC/RRT exercise was held in Denver, CO, in December 1989.
INLAND ZONE ACTIWIES:
In June 1989, 13,000 gallons (310 bbls) of light crude oil spilled from a pipeline into the Yampa River in Colorado.
In September 1989, 168,000 gallons (4,000 bbls) of crude oil spilled from a pipeline south of Stanford, Montana.
REGION IX
(Arizona, California, Nevada)
STATUS OF CONTINGENCY PLANS:
The "Region IX - Mainland Oil and Hazardous Substance
Pollution Contingency Plan" (RCP) was completely revised
in September 1988 and updated November 30, 1989.
Some of the RRT member agencies maintain supplemental
plans, (e.g., U.S. Department of Interior, Fish and Wildlife
Service's "Pollution Response Plan for Oil and Hazardous
Substances").
The "Joint U.S.A.-United Mexican States Contingency Plan
for Accidental Releases of Hazardous Substances Along the
Border" plan covers oil (and other pollutants) spilled along
the inland border between the two countries.
The Region IX RRT is a member of the U.S./Mexico Pacific Coast Joint Response Team (JRT). The "Agreement of
Cooperation Between the United States of America and the United Mexican States Regarding Pollution of the Marine
Environment by Discharges of Hydrocarbons and other Hazardous Substances" provides for the establishment of a
United States-Mexico Joint Contingency Plan (JCP) for the Gulf of Mexico and the Pacific Ocean. The USCG and
the Mexican Navy are the responsible agencies for the JCPs. The RRT has drafted "Standard Operating Procedures
for the.. Joint Response Team" which is currently under review.
The Coast Guard OSC contingency plans are currently being revised. Two of the three plans have been recently
updated (Los Angeles/Long Beach in October 1988 and Central and Northern California in August 1989). Updates
of risk assessments were completed by each OSC in July 1989.
The State of California maintains an oil pollution contingency plan (May 1983) and is presently updating it. California
also has a State Interagency Oil Spill Committee (SIOSC) which is the State's version of an RRT.
The State of Nevada has a "Hazardous Materials Operations Support Plan" (June 1986) and the State of Arizona has
a "Hazardous Materials Response and Recovery Plan" (January 1989). Both cover oil spill responses.
The RRT has developed a Supplement to Region IX - Mainland RRT Oil and Hazardous Substance Pollution
Contingency Plan for the Colorado River. This is the first Federal inland plan in the region, and the first plan to
address the entire river system.
Each major Department of Defense facility has its own pollution contingency plan.
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Most coastal counties in California have a pollution contingency plan (e.g., Los Angeles County Department of Beaches'
"Oil Spill Contingency Plan").
Additionally, in California there are 2 groups known as Emergency Response Coordinating Committees (ERCC),
Northern California and Southern California.
Similarly, the CAER organization (Community Awareness and Emergency Response) is well established within the
region, particularly in the larger metropolitan and port areas. Although oriented mainly toward hazardous substance
spills, the CAER associations facilitate and enhance local interagency and industry communications which certainly
carries over to oil spills.
All areas within the region are part of Local Emergency Planning Committees (LEPCs). The predesignated Federal
OSCs have established liaison with those LEPCs which cover coastal areas. The LEPCs are in process of preparing
contingency plans for their respective areas. These plans have not been reviewed by the RRT.
Each bulk petro/chemical marine terminal is required to maintain a Coast Guard approved Operations Manual.
Similarly, each offshore oil platform is required to maintain an Operations Manual/Contingency Plan which is reviewed
by the Coast Guard and approved by the Minerals Management Service.
There are three industry oil spill cooperatives in Region IX; Clean Bay, which covers the San Francisco Bay area, Clean
Seas, which covers the south-central California coast, and Clean Coastal Waters, which covers the southern California
coast. Each co-op has an up-to-date oil spill contingency plan/operations manual.
TRAINING AND EXERCISES:
An OSC/RRT exercise was held in Los Angeles/Long Beach, CA, in August 1989.
On March 29,1988, All American Pipeline conducted a drill in Bakersfield, CA. The drill tested shutdown and response
procedures for a simulated rupture in a major oil pipeline. RRT members participated.
An OSC/RRT exercise was held in Henderson, NV in December 1988.
Coast Guard OSCs regularly participate in industry oil spill cooperative exercises.
COASTAL ZONE ACTIVITIES:
On April 22-23, 1988, the Shell Oil Company Manufacturing Complex in Martinez, CA, spilled over 365,400 gallons
(8,700 bbls) of San Joaquin crude oil into Peyton Slough and Shell Marsh which eventually spilled into Carquinex Straits
On October 17, 1989, a potential major spill 882,000 gallons (21,500 bbls) occurred when an earthquake damaged
three gasoline storage tanks in Richmond, CA. Several thousand gallons were released from the bermed area.
INLAND ZONE ACTIVITIES:
On September 10,1988, a crude oil pipeline ruptured spilling 32,000 gallons of oil via storm drains into the Los Angeles
River.
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REGION X
(Idaho, Oregon, Washington)
STATUS OF CONTINGENCY PLANS:
CANUS PAC JRT Marine Plan coordinates U.S. and
Canadian response capabilities.
CANUS-WEST is a draft inland zone JRT plan that was not
reviewed.
The Region X Regional Contingency Plan is out-of-date.
The RCP will be revised upon issuance of the new NCP.
As per direction of the Commandant of the USCG, the
Captains of the Port have reviewed and, in many cases,
substantially revised their local contingency plans. This effort
included the validation of emergency notification lists,
coordination with state and local contingency plans,
development of worst-case, credible worst-case and average
case oil spill scenarios.
EPA has no inland zone Federal OSC plans.
Two of the three states maintain plans.
The Navy has prepared a regional contingency plan and requires local contingency plans for subareas. These plans
are being reviewed.
TRAINING AND EXERCISES:
The Pacific Area Strike Team conducted a chemical response exercise in Port Angeles, WA, on September 21, 1988.
COASTAL ZONE ACTIVITIES:
On January 31, 1989, the tank barge MCN No. 5 sank off Shannon Point, WA, resulting in a spill of 67,357 gallons
(1,604 bbls) of heavy cycle gas oil.
FUTURE PLANS:
An OSC/RRT exercise is scheduled for Seattle, WA, in February 1990.
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ALASKA
STATUS OF CONTINGENCY PLANS:
Because of the tankship Exxon Valdez oil spill the RRT
contingency plan was thoroughly tested and it worked as
designed. All members were contacted, numerous tele-
conferences were conducted, and numerous annexes of the
plan were utilized, including the dispersant use guidelines
and the wildlife protection guidelines.
In response to instructions from Coast Guard headquarters,
each Marine Safety Office is conducting an extensive review
and rewrite of their contingency plans. When this
review/rewrite is completed the plans will be distributed to
the RRT members for comment.
EPA does not maintain a separate response plan for inland
spills.
Contingency plans with foreign governments include the Canada-United States Joint Marine Pollution Contingency Plan
and the United States of America and Union of Soviet Socialist Republics Joint Marine Pollution Contingency Plan.
The Canada-US plan (CANUS), signed in 1983, provides for joint pollution response in five areas of common
concern. Two of these areas are located in the Alaska region, specifically they are Dixon Entrance and Beaufort
Sea. The annexes that pertain to these areas are the CANUSDIX and CANUSNORTH, respectively. The
operational appendices for these two annexes have been submitted for signature.
The US-USSR plan has been reviewed and signed by both parties. Draft operational appendices to this plan
were submitted to the Soviet Union in October 1989 for review. The operational appendix is modeled after
the CANUSDIX document.
Alaska's pollution laws require each oil terminal and offshore oil exploration or production platform to maintain a
contingency plan. State law also requires each tank vessel and oil barge to have a contingency plan for that vessel,
approved by the state, prior to transporting oil products. Communities responding to the SARA Title III regulations
are developing contingency plans for response to hazardous substances, but these plans could also be utilized for oil
spills. At present, there are very few communities in Alaska that have active/approved LEPCs under the SARA Title
III regulations.
Numerous federal agencies in Alaska maintain contingency plans. These plans range from Minerals Management
Service plans for offshore exploration operations to plans with the National Park Service and DOD facilities. The status
of these plans is unknown.
TRAINING AND EXERCISES:
An OSC/RRT exercise was held in Anchorage in May 1988 with a scenario that involved USSR participation with a
delegation at the exercise, as well as communication with Moscow.
A River Booming exercise observed by RRT personnel on the Chena River in Fairbanks in 1988 was sponsored by
Aleyska Pipeline Services.
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COASTAL ZONE ACTIVITIES:
On January 21, 1988, the motor vessel Frank H Brown grounded in Wrangell Narrows with the loss of about 5,500
gallons (131 bbls) of diesel oil.
On March 24,1989, the tankship Exxon Valdez ran aground in Prince William Sound spilling 11 million gallons (261,905
bbls) of crude oil.
CARIBBEAN
(Commonwealth of Puerto Rico, U.S. Virgin Islands)
STATUS OF CONTINGENCY PLANS:
The Regional Contingency Plan is maintained by EPA and
updates are published regularly.
The Coast Guard Local Contingency Plan is currently under
revision. The plan has been reviewed to identify shortfalls in
planning, equipment and personnel resources. The results
of this review have been forwarded to the NRT separately.
The estimated date of the completion of the revision of the
Local Plan is February 1, 1990. The RRT has not had the
opportunity to review this plan.
The EPA Region II, as Co-Chair of the Caribbean Regional
Response Team, maintains a Federal Local Oil and
Hazardous Materials Contingency Plan which includes Puerto
Rico and the Virgin Islands.
The U.S. Navy maintains an Oil and Hazardous Materials response plan for Naval Base at Roosevelt Roads, Puerto
Rico.
The U.S. Army Corps of Engineers, Jacksonville District maintains the "Employment of Army and Other Resources,
Oil and Hazardous Materials Contingency Plan."
The Commonwealth of Puerto Rico Environmental Quality Board maintains "Oil and Hazardous Substances Pollution
Contingency Plan" which was revised in 1988.
The Territories of the U.S. Virgin Islands, Department of Planning and Natural Resources, maintains "The Virgin
Islands Contingency Plan for the Control of Oil and Hazardous Substances."
The Hess Oil Refinery at Limetree Bay maintains a response plan and equipment capable of responding to a 100,000
gallon (2,381 bbls) spill.
TRAINING AND EXERCISES:
The most recent OSC/RRT exercise was held in San Juan, PR, in May 1987. The RRT has requested another exercise.
EPA OSCs provided training for first responders in Puerto Rico and St. Thomas in the spring of 1989.
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COASTAL ZONE ACTIVITIES:
On May 22, 1988, approximately 21,000 gallons (500 bbls) of diesel fuel and gasoline were spilled from the Texaco
Caribbean Terminal on St. Croix, VI.
On July 28,1988, the container vessel Sealand Discovery grounded at the entrance to San Juan. The vessel was refloated
without spilling any of its 756,000 gallons (18,000 bbls) of fuel.
INLAND ZONE ACTIVITIES:
On December 31, 1987, a spill of gasoline from an underground storage tank occurred in St. Thomas, VI.
On September 18, 1989, a storage tank at the Virgin Islands Water and Power Authority on St. Croix released 588,000
gallons (14,000 bbls) of number 6 oil, of which 105,000 gallons (2,500 bbls) entered Christianstad Harbor as a result
of damage from Hurricane Hugo.
On September 18, 1989, eight storage tanks were heavily damaged by Hurricane Hugo at the Hess Oil Virgin Island
Corporation releasing 420,000 gallons (10,000 bbls) of number 6 oil of which 42,000 gallons (1,000 bbls) entered Krause
Lagoon, St. Croix, U.S.V.I.
OCEANIA (PACIFIC BASIN)
(American Samoa, Commonwealth of the Northern Mariana Islands, Guam, Hawaii)
STATUS OF CONTINGENCY PLANS:
Oceania Region Oil and Hazardous Substance Pollution
Contingency Plan was revised July 1, 1989.
U.S. EPA Region IX Oil and Hazardous Substance Pollution
Contingency Plan is presently under review.
U.S. Coast Guard Marine Safety Office Honolulu, HI, Oil
and Hazardous Substance Contingency Plan will be revised
by February 1, 1990.
U.S. Coast Guard Marine Safety Office Guam Oil and
Hazardous Substance Contingency Plan will be revised by
February 1, 1990.
The Commonwealth of the Northern Mariana Islands Coastal Resources Management Oil Contingency Plan was revised
in June 1988.
The State of Hawaii Oil Contingency Plan was last revised in March 1983. The State of Hawaii also has a Dispersant
Use Agreement with the RRT which was accepted in July 1989.
The agreement between the U.S. and the Territory of Guam concerning oil pollution outlines the responsibilities
between agencies during an oil spill response. This agreement was accepted in August 1983.
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TRAINING AND EXERCISES:
The RRT was exercised in March 1988 during a RRT/OSC drill held in Honolulu, Hawaii. The agreement between
the Federal government and the State of Hawaii concerning notifications of discharges of oil and hazardous substances
was exercised and worked well.
The RRT sponsored a field exercise on October 19 and 20, 1989, in Honolulu, HI. The exercise tested the state and
local first response to a hazmat incident. The RRT also held a table-top exerdse on Maui on October 23 and 24,1989.
FEMA and EPA conducted First Responder Training and Hazardous Materials Contingency Planning classes in Guam,
Commonwealth of the Northern Marianas, and American Samoa.
Coast Guard Pacific Area Strike Team conducted oil and hazardous material spill response training in Hawaii, Guam,
Commonwealth of the Northern Marianas, and American Samoa.
COASTAL ZONE ACTIVITIES:
In March 1989, the tank vessel Exxon Houston grounded off Barbers Point, Oahu, HI, spilling 25,200 gallons (600 bbls)
of Alaskan crude oil.
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APPENDIX B
Examples of Hazards Analyses and Worst-Case Scenarios
Introduction
All 47 of the Coast Guard OSCs were tasked with developing a scenario for the worst-case incident that could occur in their
port. These scenarios required a tremendous amount of research, planning, coordination, and review by many levels in the
Coast Guard as well as the RRT. The overall quality of these scenarios was quite high and demonstrates considerable effort.
These scenarios are discussed in Chapter 3 to highlight the process involved in developing the worst cases and how shortfalls
were derived. This Appendix provides three different worst-case scenarios, either partial or complete, as prepared by three
Coast Guard OSCs. The first example of a hazards analysis, scenario development and shortfall conclusions was provided by
the Commanding Officer, COTP Long Island Sound, New Haven, CT. Also appended is the MSO Morgan City, LA, worst-
case scenario and resulting shortfall list and the MSO Long Beach, CA, shortfall list.
COTP LONG ISLAND SOUND WORST-CASE SCENARIO
COTP Long Island Sound, New Haven, CT, performed the following hazards analysis to arrive at their worst-
case scenario. It is an excellent example which clearly illustrates the steps involved in a thorough hazards
analysis. The steps as mentioned in Chapter 3 include: 1) hazard identification, 2) vulnerability assessment, and
3) risk analysis.
HAZARD IDENTIFICATION, VULNERABILITY RISK ASSESSMENT SUMMARY
L HAZARD/THREAT ASSESSMENT
A. WATERBORNE THREAT
Connecticut and New York use Long Island Sound (1300 square miles
with 577 miles of coastline) for waterborne commerce. Over 23 million
tons, or 153 million barrels or 6.4 billion gallons of petroleum products
are delivered to Sound ports annually. These products represent 86
percent of all commodities received via the marine mode. In addition,
substantial amounts (approximately Z5 billion gallons or 8.6 million short
tons) of petroleum products are transported through Long Island Sound
from New York City and New Jersey enroute ports north such as
Providence, RI and Boston, MA.
The table below illustrates the volume of traffic in 1986 for each port by
visits and total volume of product in short tons. (Based on
"Waterboume Commerce of the U.S., 1986 Part 1 Waterways and
Harbors Atlantic Coast," Department of the Army, Corps of Engineers.)
Also shown are totals for the transient petroleum products.
PETROLEUM
SHORT TON
BBLS
GALLONS
% OF
PORT
VISITS
(MILLIONS)
(MILLIONS)
(MILLIONS)
G/T
New Haven, CT
1,315
8.625
58.677
2,464.460
86
Riverhead, NY
264
3.520
23.945
1,005.714
100
Port Jefferson, NY
494
3.168
21.554
905.269
88
Bridgeport, CT
430
2.106
14.332
601.960
74
Connecticut River
565
1.719
11.697
491.296
100
Island Park, NY
250
.813
5.700
239.400
100
Norwalk, CT
145
.619
4.213
176.968
86
Housatonic River, CT
60
.431
Z937
123.720
100
Thames River, CT
95
.388
Z645
111.120
91
Stamford, CT
144
.344
Z344
98.482
59
Oyster Bay, NY
166
.270
1.842
77.377
100
North port, NY
25
.260
1.769
74.313
100
New London, CT
173
.248
1.689
70.944
52
TOTAL DELIVERED
4,126
23.430
153.349
6,441.027
86
TOTAL TRANSIENT
8.6
Z500.00
GRAND TOTAL
3Z08
8,944.027
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L Traffic Routes
Entry into the COTP Long Island Sound zone is achieved via either the
western end at a line between Port Chester New York and Glen Cove
New York, or the eastern end at the Race via PT. Judith and Block
Island Sound or Block Island Sound via the Atlantic Ocean. Tank barges
enter the Sound from the west and travel to ports throughout the zone.
Small vessels transit Fishers Island Sound when ideal weather conditions
exist Tank barges are destined for facilities scattered widely throughout
the zone: Connecticut River, Stamford, Housatonic River, Bridgeport,
New Haven, Thames River, Island Park NY (south shore of Long Island),
Oyster Bay and Norwalk. Tank barges enroute Island Parte transit from
NY/NJ harbor area. Tank ships enter the east and visit the following
ports: New Haven, CT; Bridgeport, CT; Port Jefferson, NY; Riverhead,
NY, Northport, NY and the Thames River.
Z Vessels
There are a relatively high number of vessels delivering petroleum
products to facilities in the zone and a high number of vessels transiting
this zone. Approximately 4500 tank vessels (4130 tank barges, 370 tank
ships) visited the ports in this zone in 1988. The tank vessels range from
a 131 foot self propelled tank barge to an 856 foot tankship. Their
capacities range from 300,000 to 27.6 million gallons (71,428 to 657,142
bbls). Their drafts when loaded range from 12 to 45 feet The largest
barges in the zone are capable of carrying 10,842,678 gallons (258,159
bbls) of product
1 Cargo
Roughly 6.4 billion gallons of oil products are delivered to ports in this
zone annually. These products are primarily NO. 6 and NO. 2 heating
oils and gasoline. Oil products transiting the zone enroute Rhode Island,
Massachusetts, New Hampshire and Maine ports (over Z5 billion gallons)
are also primarily NO. 6, NO. 2, and gasoline. On rare occasions crude
oil is offloaded at the Northville Platform on Long Island for long term
storage. LPG is also offloaded at Northville.
a SHORESIDE THREAT
There are 70 designated waterfront facilities widely dispersed in this zone,
66 of which handle petroleum products. Total storage tank capacity for
these facilities is approximately 1.2 billion gallons. New Haven CT is the
busiest port comprising approximately 435 million gallons of storage
capacity. The largest single storage tank has a capacity of 25 million
gallons and is located at Northville Industries in Riverhead, NY. This
facility also has the largest storage capacity of any single facility (218
million gallons). Petroleum products held by these facilities may include
crude oil, NO. 2 and NO. 6 fuel oil, diesel, gasoline, jet A, kerosene, and
AC20. Two of the facilities, (Northport, NY and Riverhead, NY) have
offshore platforms. Six major power plants are located in Connecticut;
New Haven, Bridgeport, Norwalk, Middletown, Hartford and Montville
and receive large quantities of NO. 6. Island Park New York on the
south shore of Long Island has 5 facilities, including one NO. 6/LNG
fueled power plant, and ranks number 6 in total tonnage for this zone.
C. MISCELLANEOUS THREATS
Other pollution threats (mostly "minor") are posed by:
L Stonn Runoff especially via storm drains. Hartford/ Connecticut
River, Green Harbor and Thames River are particularly
vulnerable.
Z Private Citizen Dumping usually from dumping of motor oil into
storm drains.
1 Road Accidents especially tank trucks carry petroleum products
throughout the COTP zone. This is of particular concern where
highways run near coastal waters and cross rivers.
4. Rail Transportation - Railroad tank cars carrying petroleum
products along the northeast corridor near Connecticut coastal
areas pose a pollution problem in the event of a derailment
5. Pleasure Boats - Overfilling during fueling, and sinking of
pleasure boats are other sources of pollution. However,
because of their large numbers in this COTP zone, boats (over
200,000) and boat marinas can present a significant hazard to
the environment
6. I rarhing - Due to the age of some waterfront facilities and
long term use and neglect of some areas along the coast,
leaching has been notable in places. Leaching problems are
often disguised as storm runoff problems.
7. Government Agencies-primarily waste lube oil, public vessels.
&. Electrical Transmission Cable - Seven electrical transmission
cables extend from Northeast Utilities in Norwalk, Connecticut
to Long Island Lighting Company in Northport, New York.
These cables use mineral oil for cooling and have leaked in
the past
9. Pipeline ¦ The Jet line, Inc. pipeline transports petroleum
products from facilities in New Haven harbor and on the
Connecticut River. The pipeline is underground except where
terminating at a facility. It follows the railroad bed from the
Middletown area to Hartford and then north to points in
Massachusetts. Although several safety systems are installed
to prevent a catastrophic spill, accidents on pipeline could
conceivably result in a discharge into the Connecticut River
or New Haven Harbor.
D. NAVIGATIONAL HAZARDS
The Connecticut shoreline is rocky with ledge extensions and is very
unforgiving. The Connecticut River bottom is sand and mud so the
consequences of groundings are less severe, except in the Old Saybrook
area. Bottom contours within Long Island Sound vary widely but the
Sound is relatively wide open Places in Long Island Sound where
groundings have occurred in the past are Watch Hill, the Race, Bartlett's
Reef, Old Saybrook Breakwater, Stamford, New Haven Harbor Entrance
and Port Jefferson Harbor. The most pronounced navigational hazards
in this zone are the rock coastline of Connecticut and ledge extensions
which are present at key choke points. Some of the most prominent
navigational hazards encountered when transiting Long Island Sound,
Block Island Sound and Fishers Island Sound are listed below:
L Long bland Sound. Race Rock, Little Gull Reef, New
London Ledge, Bartlett Reef, Saybrook Breakwater, Southwest
Ledge, Stratford Shoal Middle Ground, Penfield Reef, Pecks
Ledge, and Greens Ledge.
Z Block bland Sound. Endeavor Shoals, Southwest Ledge,
Block Island Sound South Entrance Obstruction, and Cerberus
Shoal
3l The Race and vicinity. Valiant Rock, Long Sand Shoal, and
Sue Mile Reef
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E. CLIMATOLOGICAL/METEOROLOGICAL CONDITIONS
Temperatures vary from an average daily high in July of about 81 * F to
an average daily low in February of about 21 * F. The average wind
ranges from 8.8 mph in March to 6.3 mph in July and the annual average
humidity varies from 79 percent in the morning to 64 percent at noon.
Water temperatures in Long Island Sound range from 32 * F in the winter
to about 72 * F in the summer, a range as great as that of any body of
water in the world. The mean date of the springtime air temperature of
32°F or lower is April 22, and the mean date of the first autumn
temperature of 32° F is October IS. Seasonally, weather characteristics
vary from the cold and dry continental polar air of winter to the warm,
maritime air of summer (the one from Canada, the other from the Gulf
of Mexico, Caribbean Sea, or Atlantic Ocean). Storm patterns are from
the north/northwest and the southwest On clear nights in the late
summer or early autumn, cool air drainage into the valley and moisture
from the Connecticut River, produce steam and/or ground fog which
becomes quite dense throughout the valley, hampering ground, air, and
marine river transportation.
F. HYDROLOGICAL CONDITIONS
Long Island Sound is a protected coastal body of water with open
connections to the sea, in which saline sea water is measurably diluted by
fresh water. Ocean water flows in and out of the Sound through the
opening in the eastern end, "The Race." Typical of many estuaries. Long
Island Sound experiences "estuarine circulation" of water. The heavy,
saline bottom water sinks and flows under the fresher surface water.
Thus the saline bottom water flows westward into the sound while the
less saline surface water flows eastward out of the Sound. The estuarine
circulation flows all the time during both ebb and flood tides.
L Currents
The tidal currents throughout Block Island Sound have considerable
velocity; the greatest velocities occur in the vicinity of The Race and in
the entrance between Montauk Point and Block Island. In the middle of
The Race, the flood sets 295* true and ebb at 100° true, with the
average velocities of Z9 knots flood and 3.S knots ebb. Currents up to
5 knots are possible. There are always strong rips and swirls in The
Race, except for about one-half hour at slack time. The rips are
exceptionally heavy during heavy weather, and especially when a strong
wind opposes the current, or the current sets through a heavy sea. In the
middle of the passage between Montauk and Block Island the flood sets
generally northwestward at l.S knots and the ebb southeastward at 1.9
knots. At approximately 1.2 miles eastward of Montauk Point, the flood
sets 345* true, ebb 162* true with a velocity of 2.8 knots. Due to tidal
current condition in Long Island Sound the window for containment of
oil spills at the source is extremely limited.
Z Tides
The tides in Long Island Sound are driven by the oceanic tide outside
The Race. Because of the Sound's size and shape, it is particularly tuned
to amplify the oceanic tide. Therefore, the tidal range at the western
Sound, is larger than the tidal range at the east The average tidal range
at Stamford (west) is about 7.2 feet while at New London (east) it is only
3 feet Associated with the tidal change in water level are strong tidal
currents.
IL VULNERABILITY ANALYSIS
A. ENVIRONMENTALLY SENSITIVE AREAS
The State of Connecticut has identified 99 environmentally sensitive areas
in the coastal zone. (24 high, 49 medium, 25 low vulnerability.) The
state of New York has identified 102 environmentally sensitive areas on
Long Island. These areas require special consideration during an oil
discharge. Although these areas may not be initially affected by a
discharge, they must be considered for protective booming to prevent
contamination. The most sensitive shoreline types present in Long Island
Sound are the exposed and sheltered tidal flats and marshes. These
habitats are present in every area of the zone but especially in the
numerous small inlets and estuaries near Niantic Bay, New London
Harbor, Fishers Island Sound, Napeague Bay, and Gardiners Bay. Tidal
flats and marshes may experience long-term impacts from spilled oil,
particularly to the resident biological communities present in these areas.
They undergo slight-to-moderate changes in sensitivity to spilled oil as
the seasons change but are considered to be highly sensitive at all times.
Numerous fish and wildlife species of ecological importance are also
present
L Bird Populations
Major areas of concern in Connecticut are: Faulkner Island, Guilford;
Tuns Island, Madison; Chimon Island, Norwalk; Ram (Shea) Island,
Norwalk; Menunketesuck Island, Westbrook; and Long Beach, Stratford.
Major areas of concern on Long Island are the entire southern shore,
various locations in the eastern fork, and the western portion of the
northern shore.
X Fishery Resources
The fishery resources of Long Island Sound support a very important
industry which may be susceptible to impacts from oil pollutioa
Sheltered habitats such as marshes, tidal flats, and certain rocky shores
may be particularly vulnerable. Major areas of concern in Connecticut
are the mouths and tidal waters of estuaries (Thames River, Connecticut
River, Housatonic River). Major areas of concern in New York are:
Oyster Bay; Huntington Harbor/Northport Bay; Mt Sinia Harbor;
Northwest Bay; Orient Harbor Bay/Hallock Bay, Great South Bay;
Moriches Bay; Shinnecock Bay; Middle Hempsted Bay; and East
Rockaway Inlet
3. Shellfish
All crustacean and mollusk shellfish species of Long Island Sound should
be considered sensitive resources and vulnerable to oil spills. Clams and
oysters living in intertidal mud flats are particularly sensitive. They are
both substantial industries. Considerable efforts have been expended to
reestablish the oyster in the Sound. Major areas of concern in New York
are Oyster Bay, Huntington Harbor, Northport Harbor, Port Jefferson
and in Connecticut the entire coastline is considered to be a shellfish
production area.
B. SOCIOECONOMIC CONCERNS
Areas/facilities vulnerable from a socioeconomic perspective are:
L Beaches/Parks/Tourism
Widely scattered throughout the zone. Recreational and commercial
industries (over 600 marinas in zone for example).
2. Channels
A major spill could force the closure of one or more of the critical
channels in the zone simultaneously resulting in lost revenue for the
facilities that use them and cause a shortage of petroleum products in the
area. Thames River area is vulnerable from a national security
interest/strategic standpoint
3l Water Intakes
The operation of these facilities would be adversely effected if oil were
to enter their cooling water intakes. Some of the facilities that draw
suction from the waters of Long Island Sound and its tributaries are
listed below.
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Connecticut
Millstone Nuclear Power Plant - Waterford, CT
Connecticut Yankee Nuclear Power Plant - Hadem Neck, CT
CL&P Montville - Uncasville, CT
UI • English Station • New Haven, CT
UI - Harbor Station - New Haven, CT
CL&P - Devon - Milford, CT
CL&P South Meadow Station - Hartford, CT
CL&P Middletown - Middletown, CT
UI - Bridgeport Station - Bridgeport, CT
CL&P Norwalk - South Norwalk, CT
New York
L1LCO Northport Power Station - Northport, NY
LILCO Port Jefferson ¦ Port Jefferson, NY
LILCO E.F. Barrett Station - Island Park, NY
Shoreham Nuclear Power Plant • Shoreham, NY
IIL SPILL HISTORY
Records for 1985 to present show 550 reported spills, most of them
minor in nature. Since 1970 there has been 5 major oil discharges of
between 100,000-600,000 gallons and one potential discharge caused by
the sinking of a fully loaded barge. The barge was raised without major
incident The 600,000 gallon spill was a facility tank spill primarily
confined to the tank area and a small tributary. With respect to the five
major discharges, the cleanups proceeded satisfactorily and the effected
areas appear to be free of any long term affects. Over the last two years
there have been approximately 130 spills per year in Long Island Sound,
all but one being in the minor spill categoiy. There have been two large
facility tank spills that have ranged in the 600,000-1,000,000 gallon range
but both were contained within the dike. The five major spills are
summarized below:
SOURCE:
DATE:
AMOUNT:
TYPE:
AREA EFFECTED:
CAUSE:
SOURCE:
DATE:
AMOUNT:
TYPE:
AREA EFFECTED:
CAUSE:
SOURCE:
DATE:
AMOUNT:
TYPE:
AREA EFFECTED:
CAUSE:
SOURCE:
DATE:
AMOUNT:
TYPE:
AREA EFFECTED:
CAUSE:
SOURCE:
DATE:
AMOUNT:
TYPE:
AREA EFFECTED :Long Island Sound, Atlantic Ocean
CAUSE:Grounding in Watch Hill Passage
Records indicate that the average oil spill in the COTP Long Island
Sound zone is a 100-150 gallon spill of No. 6 oil or No. 2 oiL The
"typical" spill is under 100 gallons.
IV. RISK ASSESSMENT
A. Lang bland Sound-General
The number of vessels transferring product in the zone, the high number
of transient oil carriers, the wide dispersion of sensitive areas, the wide
dispersion of oil delivery points, and the variety of navigational hazards
all combine to pose substantial risk. New Haven Harbor and approaches,
Bridgeport, the Connecticut River/Eastern end of zone, Port Jefferson
and Island Park, NY are higher risk areas after considering such factors
as the number of visits, volume, environmental factors and/or remoteness
from response assets. Natural choke points because of traffic density and
severe hydrological conditions also pose considerable risk. The Race in
particular represents our highest risk area. A major spill at The Race
would result in widespread environmental damage to the Connecticut and
New York shoreline. A single spill could effect both shorelines at the
same time in a matter of four hours or less. Regardless of the scenario,
a spill occurring at The Race could not be contained at the source.
Areas at risk will vary depending on wind and current conditions. Based
on oil spill trajectory modeling, areas of impact would most likely include
Fishers Island Sound and adjacent shoreline, Block Island Sound, the
north fork of Long Island, the Connecticut shoreline from the Thames
River to the Connecticut River.
Minor spills will continue to occur throughout the zone. However, these
spills should not present a significant threat to the environment Current
response levels to these spills and current cleanup techniques should
continue to be sufficient to mitigate these spills.
B. Connecticut
There are over twenty highly vulnerable environmentally sensitive areas
along the Connecticut shoreline. A major open water spill anywhere
along the coast could easily impact several of these areas simultaneously.
A major spill from a facility or vessel on the Thames or Connecticut
River could also result in severe damage to the environment The river
currents would severely hamper containment efforts. Both rivers support
a large amount of barge traffic and have a significant number of facilities
on their shores. The Connecticut River has a concentration of
environmentally sensitive areas from the Haddam area to the mouth of
the river. The Thames River has environmentally sensitive areas though
not as numerous or concentrated as those on the Connecticut
C. New York
The North and South shores of Long Island are comprised of much more
beach area than found along the Connecticut shoreline. However, there
are several bays on both shores of Long Island which are environmentally
sensitive. The south shore is at much less risk than the north shore from
an open water spill... it is exposed to far less barge traffic. The only
exception to this is the East Rockaway Inlet/Island Park area.
Island Park (Middle Hempstead Bay) is an environmentally sensitive
wetland area which is connected to West Hempstead Bay (also a sensitive
wetland area) by an intercoastal waterway. Total storage capacity at the
facilities in this area is approximately 47 million gallons. Product is
transported to these facilities via barge. A major incident in this bay
area from either a storage tank or barge could result in significant
environmental damage. Its remoteness from Long Island Sound COTP
resources further complicates our ability to stage effective and timely
response operations.
Shell Tanker
15 June 1970
600,000
#6
Bridgeport Harbor, Johnson's Creek
Overfill
Tanker ESSO Gettysburg
17 February 1971
386,000
#2
New Haven Harbor
Vessel struck a rock in New Haven Harbor
Tanker Messiniaki Bergen
06 October 1974
150,000
#6
New Haven Harbor
Vessel struck a rock in New Haven Harbor
Tank Barge Bouchard 100
08 February 1978
200,000
#2
Long Island Sound, Huntington Bay
Grounding
Tank Barge Ocean 250
16 March 1978
200,000
Gasoline
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Oyster Bay is among the environmentally vulnerable northshore bays.
This bay is at risk due to the storage tanks at the facility in this area and
the transfer operations that occur at the facility.
Cold Spring Harbor is also environmentally sensitive with a petroleum
transfer/storage facility. This bay is connected to Oyster Bay.
Although there are no oil facilities on Northport Bay, this water body is
adjacent to the Northport powerplant which stores #6 fuel oil. This
facility receives its fuel via an offshore platform and has a storage
capacity of 81 million gallons. A major release from a storage tank or
the offshore platform could pose a problem in this area.
Great South Bay is the largest of the south shore bays. West Islip, West
Babylon, and Patchogue combined total petroleum storage capacity is 2.6
million gallons in this bay. This oil is not transported by barge.
D. General Conclusions
Based on history and overall risk assessment the following conclusions
are drawn:
5. The entire shoreline of Connecticut is particularly vulnerable
due to its location near marine oil transportation routes and
its extensive tidal marshes, flats and estuarine areas.
6. Long Island Sound is a complex marine system with intense
and diversified recreational, commercial, and public interests.
Pressures from the recreational boating public, marine
industry, commercial enterprises, and environmental groups
to respond to and mitigate any major spill will be intense.
7. Threats from sources other than facilities or vessels exist and
'Mil continue to pose a threat to the environment throughout
the zone.
8. The national strategy adopted by the Coast Guard calls for
commencement of initial containment and recoveiy operations
for major spills within 6 hours. The geographical and
meteorological constraints of Long Island Sound combined
with the wide dispersion of sensitive areas may make this
response time standard inadequate, as major
environmental/socioeconomic danger is likely to occur under
6 hours.
1. The number of vessels visiting ports and transiting the zone
primarily from (west to east) combined with the wide dispersion
of facilities and environmentally sensitive areas leaves no area
i/l this Zone exempt from the threat of a major oil spill
Z A large portion of Long Island Sound (mid South traffic routes)
is relatively free of navigational hazards. However, certain
hazards and choke points in selected areas increase the possibility
of vessel groundings and/or collisions which could result in a
major spill
3. The higher risk areas in the zone are the approaches and harbor
of New Haven, Bridgeport, and Port Jefferson, the Connecticut
River (mid-state south), the Island Park NY area (East
Rockaway Inlet) and the entrance to the eastern end of the zone
considering factors such as number of visits, volume of oil,
remoteness, hydrological conditions and navigational hazards.
4. The velocity of the tidal currents, the variability of wind, and the
configuration of shoreline (Connecticut shore to the north, New
York shore to the south) in the Sound area creates the potential
for a large impact area during a major spill Because of tidal
and current conditions, many spills in the zone do not lend
themselves to containment at the source.
9. Response to a major spill in the Island Park NY area or to
a major offshore spill off Jones Inlet west may be more
effectively prosecuted by COTP New York considering the
location's distance from COTP Long Island Sound resources.
10. The Race clearly represents the highest risk area in the zone
when considering entering traffic, navigational hazards, and
hydrological conditions.
11. A worst case, high rate spill in the zone could result in up to
8-10 million gallons of discharged product
V. SCENARIOS
The "average spill" for the Long Island Sound zone was obtained by
taking numerical average of the data available over the past nine years.
The worst spill in zone scenario is not an exact recounting of an actual
spill but does reflect location and volume spilled based upon worst spill
history and risk assessment The worst case likely scenario was
developed as a result of our risk analysis. The three scenarios are listed
below.
Average SpQl - ISO gal Spill at DWFF During Transfer Operation
Want Spfll in Zone -Tank Barge striking a submerged ledge and
grounding in New Haven Harbor Entrance Channel
resulting in a 300,000 gal spill of No. 6 fuel oil
Worst Case Likely - Grounding of 800 ft Vessel in the Race resulting
in a 6 million gal spill of No. 6 fuel oil
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MSO LONG BEACH WORST-CASE SCENARIO
After the worst-case scenario is developed resource shortfalls can be derived. Here the OSC must consider all
aspects of the spill scenario, determine an effective response and then identify all personnel and equipment
necessary to effect that response. The following shortfall list is from MSO Long Beach, CA, and is an excellent
example from the west coast.
RECOMMENDATIONS AND POTENTIAL SOLUTIONS FOR EQUIPMENT/PERSONNEL SHORTFALLS
This enclosure discusses projected equipment and manpower shortfalls
based on the preceding worst case oil spill scenario for MSO / Group LA-
LB's area of responsibility. For each item, the methodology used to
determine the minimum quantity needed for response action is given
followed by recommended solutions for overcoming each shortfall
1. Harbor boom - All marinas, harbors, and ecologically sensitive
areas were identified and the amount of boon needed to protect
each area was determined. Approximately 45,500 feet of harbor
boom would be required to boom off and protect all significant
marinas, harbors, and ecologically sensitive areas within this
zone. Local oil spill cooperatives and local BOA contractors
have 53,500 feet of harbor boom in inventory. Therefore, no
shortfall exists.
Recommendation: None
Z Open sea boom - The quantity of open sea boom needed to
surround the main body of 10,000,000 gallon crude oil slick 36
hours after the initial discharge was calculated using the
spreading pool assessment formula (Hazard Assessment Code
ATUVW) on page 135 of the CHRIS Hazard Assessment
handbook, COMDINST. M16465.13. According to this
assessment, the oil slick would cover approximately 7 square
miles and have a perimeter of 10.6 miles 36 hours after the
collision. Response strategy calls for isolating pockets of the oil
and skimming. The 7 square miles slick would require 56,000
feet of boom to contain. Local oil spill cooperatives and BOA
contractors have 68,000 feet of open sea boom readily available.
An additional 22,000 feet of open sea boom is available from the
CG Pacific Strike Team and Pacific Navy SUPSALV. Therefore,
no shortfall exists.
Recommendation: None
3. Dispersants - Dispersant quantities needed for this spill are
based on the following assumptions.
a. The maximum size of the oil discharge would be
10,000,000 gallons of which twenty percent would have
evaporated within 24 hours of discharge.
b. Of the remaining 8,000,000 gallons of oil, 75 percent
of the product (6,000,000 gallons) would be in locales
that would facilitate dispersant without irreparable
damage to the aquatic environment and would be
accessible to aircraft or vessels capable of using
dispersants.
c. That a 1:20 ratio of dispersants to oil would be utilized
(as recommended by dispersant manufacturers and oil
spill experts).
Given the response scenario in enclosure (1), 300,000
gallons of dispersant would be needed for an initial
treatment (one application) of all of the remaining
spilL Local and BOA contractors have 27,000 gallons
of Corexit 9527 dispersants. An additional 273,000
gallons would have to be procured from the
manufacturer (Exxon) to overcome the shortfall
Recommendation: (1) Co-ops should increase dispersant
inventory.
(2) Formulate a plan to gain immediate
access to additional dispersants for major spill response.
Dispersant eqiripiiiwu - Equipment quantities needed for this
spill are based on the following assumptions:
a. Dispersants use would be immediately approved by
the RRT within 24 hours.
b. Dispersants would be applied during the first 72
hours after the spill, since later applications would
have limited effectiveness on the weathered and
thickened slick.
Dispersant application
dispersant to oil ratio.
rates would be 1:20
d. Dispersant application would be limited to daylight
hours (12 hours/day).
Based on Clean Seas literature, existing dispersant
application vessels, aircraft, and helicopters are
capable of delivering 50,000 gallons per day
maximum. Therefore, over a 72 hour period,
150,000 gallons of dispersant can be delivered with
existing equipment (one DC-4 aircraft; four co-op
vessels, and three contracted helicopters). In order
to deliver the initial dispersant application of
300,000 gallons within the first 72 hours, dispersant
equipment resources would have to be doubled.
Recommendation: Additional planes and vessels
could be contracted in order to overcome
shortfall.
Skimmers - Equipment quantities needed for this spill
scenario are based on the following assumptions:
a. The average skimmer under average sea conditions
(2 ft-4 ft) would have an oil recovery rate of 10
percent (1 part oil for every 10 parts fluid
skimmed).
b. At any given time, 75 percent of all available
skimmers would be operational; Le., an equipment
operability factor of .75 is sustainable.
c. Skimming equipment shall be utilized for 10 hours
per day.
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e. Adequate storage for skimmed oil/water mixture is
available.
The total open sea skimming capability available from
all local Co-ops and BOA contractors is 744,000
gallons of recovered oil per day. When CG Pacific
Strike Team and Navy SUPSALV resources are added,
the skimming capability is 864,000 gallons of recovered
oil per day. This figure is -well above the 50,000
gallons per day standard established for local skimming
capabilities in COMDT (G-MER-2) letter 16465 dated
July 26, 1989. Therefore, local resource skimming
capability is considered excellent Considering we have
year round favorable sea/weather conditions that are
conducive to skimming, open water recovery of spilled
oil in conjunction with open water booming is very
feasible. For the response scenario described in
enclosure (1), it would be possible to recover a
tremendous amount of spilled oil in two weeks with
local resources. Therefore, no shortfall exists.
Recommendation: None
6. Bin boom-When burning is determined to be a viable method,
burn boom should be utilized. Burn boom is utilized as a fire
barrier. When burning oil, small patches are ignited and
contained within the fire bocm Fire boom is reusable. Only
500 feet of fire boom is readily available (Seattle area). Clean
Coastal Waters should have 1000 feet of fire boom in inventory
commencing next year. Because only small patches of oil are
burned at one time (controlled burn), it is arbitrarily estimated
that 5,000 feet of fire boom would be needed for response. Oil
on the water surface burns rather quickly, so the same 5,000 feet
of fire boom could be readily reused. Based on this estimate,
there is a 4000 feet shortfall of fire boom within the local area.
Recommendation: Co-ops should increase burn boom inventory
to 5000 feet
7. ShoRiide mrrtwacal deait-up equipment - If the response
strategy outlined in enclosure (1) is implemented, shoreline
impact would be minimized. The vast majority of the South
California shoreline is comprised of accessible sandy beaches.
Heavy equipment such as graders, elevating scrapers, front end
loaders, and bulldozers would be utilized for sandy beach clean-
up. According to the EPA Shoreline dean Up Manual
graders and elevating scrapers can dean at a rate of 1 to 3 hours
per acre. Front end loaders can clean at a rate of 7 to 27 hours
per acre depending on if the loader is equipped with tracked
belts or rubber tires. Bulldozers can clean at a rate of 10 to 20
hours per acre. The time variance is based on the haul distance.
It is impossible to forecast bow much shoreline would be
impacted and to determine exact equipment needs. Regardless,
it does not pose a problem because there are numerous sources
of heavy equipment in the local area. Sources include beach city
governments, county agencies, Navy Sea Bees, Army Corps of
Engineers, U.S. Marines, U.S. Army, and numerous commercial
contractors/developers. Therefore, no shortfall exists.
Recommendation: None
8. Recovered oil mllnrtinn equipment - Skimmer operations can
be hindered by a lack of recovered oil collection equipment
(dracones; barges; vacuum trucks). We identified recovered oil
collection equipment within the zone and readily available
resources outside the zone (CG Strike Team and Navy
SUPSALV). We identified 79 vacuum trucks with a total
capacity of 300,000 gallons; 9 local Crowley tugs with a total
capacity of 8 million gallons; and dracones with a total capacity
of just over 1 million gallons. Based on total skimming
capability per day (see paragraph 5), skimming operations
would not be limited by recovered oil collection equipment
Therefore, no shortfall exists.
Recommendation: None
9. Civilian Personnel - There are two Co-ops and 6 BOA
contractors within the zone. Combined, they employ a full
time work force of 464 trained personnel. Additionally, 680
(combined) trained personnel are "on call" status. Total
trained available force is 1144 personnel. For open seas
containment and skimming operations, there are sufficient
trained personnel (1144) to deploy, operate, and maintain the
equipment For impacted shoreline areas, unskilled laborers
could easily be hired in this area. Considering that this is a
major metropolitan area, additional manpower resources are
readily available. Therefore, there are no known civilian
personnel shortfalls.
Recommendation: None
10. Coast Guard Resources and Personnel - Equipment For
initial response, vessel support resources would be readily
available. With 6 82' WPB's and several 41' and 44' utility
boats under the commanding officer's operational control,
safety zone enforcement and mobilization of pollution
response personnel are easily accomplished. However, for
long term spill mitigation other operational commitments
(SAR/LE) would place a strain on MSO/Group LA-LB vessel
resources. Additional vessel support would be needed. For
pollution overflight support, CG Airsta Los Angeles is nearby
with H-65 helicopters. Additionally, CG Airsta San Diego is
located approximately 120 miles south and could provide
overflight support If needed, the very active local CG
Auxiliary can provide overflight support CG Airsta LA, CG
Airsta SD, and the Auxiliary could provide long term aerial
support
Recommendation: In the event of a major spill, shift vessel
resources to the LA-LB zone to facilitate clean-up monitoring
and field operations.
Personnel: MSO/Group LA-LB Port Operations department
is insufficiently staffed as outlined in Commander, Eleventh
CG District MSO/Group LA-LB Staffing Requirements
Planning Proposal dated October 3, 1989. Should a major
spill occur, MSO/Group LA-LB resources would be further
strained. CG augmentation by regular and reserve forces
would be necessary. It is difficult to determine the exact
amount of additional CG personnel needed. As a yardstick,
MSO Valdez and MSO Anchorage were augmented with up
to 200 CG personnel during the Exxon Valdez clean-up. A
major spill in our zone would probably not require as many
additional resources because (due to the geographical area
and its characteristics) the clean-up effort would not be as
complex and tedious. Therefore, a personnel shortfall of
approximately 100 to 150 can be projected.
Recommendation: In the event of a major spill, augment
MSO/Group LA-LB with 100 to 150 CG personneL
Personnel would be utilized for monitoring, field operations,
and command post support
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Presently
Item
Ideal
Owned
Shortfall
Transportable cellular phones
10
3
7
Transportable Macintosh computer
3
1
2
Modem
2
1
1
Portable fax machine
1
0
1
Fax attachment for cellular phone
2
0
2
Hand held radios
30
16
14
Communications - Communications is an essential element of
pollution response. Without proper information and network
flow, response efforts may be hampered and delayed. The Coast
Guard Communications System depends on a fixed base of
equipment The existing system lacks the flexibility to quickly
provide communications support for a major incident such as a
large oil spill and it's not compatible with the communications
systems used by civil agencies. The Exxon Valdez and Pac
Baroness pollution incidents illustrated this point Pollution
incidents occurring within this zone, especially those at remote
locations, would pose unique problems.
MSO/Group LA-LB Comms Center is located in Long Beach,
CA. Capabilities include HF, VHF-FM with one remote site,
secure comms, and direction finding capabilities. The Comms
Center is normally manned with one SAR/LE controller and two
radio personnel. Communications capabilities are often taxed
during normal operations such as search and rescue and law
enforcement If a major pollution incident occurred within our
zone, MSO/Group LA-LB Comms Center would have
insufficient comms equipment capabilities for handling the major
pollution incident traffic, affected vessel traffic, and normal
operational commitments (SAR/LE). We would request
communications assistance from Dll OPCEN. For a long term
major spill, we would request the Transportable Comms Center
(TCC).
Recommendation; In the event of a major spill, a fully
functional Transportable Comms Center (TCC) would be
beneficial Conduct a review of TCC utilization for the Exxon
Valdez spilL Modify and improve TCC.
Portable communications equipment (cellular phones and hand
held radios) would be necessary for monitoring, field operations,
and inter-agency communications. MSO/Group LA-LB has
limited numbers of portable cellular phones and hand held
radios. Additional radios would have to be borrowed from Dll
(dttm) (18 available). Additionally, an additional portable
Macintosh computer would significantly enhance inter-agency
communications since most agencies (federal, state, and local)
have E-mail capabilities. Enhanced information flow, increased
information speed, and networking would result in a more
efficient and coordinated response effort The chart below
identifies presently owned portable equipment, ideal amounts for
major spill response and shortfalls (combined for MSO/Group
LA-LB and MSD Santa Barbara):
Recommendations: Purchase fax attachment for cellular phone,
portable fax machine, modem, and transportable Macintosh
computers. Equipment shortfalls should be funded by CG
Headquarters. Cellular phones and hand held radios can be
procured on a "as needed" basis. Cellular phones can be rented.
Hand held radios can be borrowed from Dll (dttm).
Installed telephone lines are in demand after a major oil spill
has occurred. After the Exxotl Valdez incident, the number
of phones lines available for response comms was inadequate
due to frequent use by the press. MSO/Group LA-LB has 48
installed phone lines, and MSD Santa Barbara has 2 installed
phone lines. Since there are numerous media agencies within
our zone, installed phone lines might become inadequate at
MSO/Group LA-LB and would definitely become inadequate
at MSD Santa Barbara. Additional phone lines can be
installed by local phone companies.
Recommendations: To enhance inter-agency coordination and
pollution response, "dedicated phone lines" should be
connected between key agencies and involved parties.
FEEDBACK: CONTINUOUS PLAN REVIEW PERSONNEL
RESOURCES AND AGENCY/MARITIME COMMUNITY LIAISON
1. Oil spill and hazardous chemical release contingency planning
is a continuous, evolving process that requires constant
refinement and updating. Within the MSO/Group LA-LB
zone, there are numerous federal/state/local agencies,
pollution response organizations, and private industry
companies that have pollution contingency plans
(approximately SO plans). Realistically, the task of
rewriting/updating this unit's Local Contingency Plan and
ensuring its compatibility with State/Federal/local agency and
industry plans would require the attention of a junior officer
for 30 hours/week. The remainder of this officer's work week
would consist of liaison/meetings with other agencies and
industry in order to establish a coordinated multi-organization
response mechanism. The ideal candidate would be a
lieutenant (junior grade) with a background in marine
environmental response and strong writing skills.
2. Unfortunately, unit manpower shortages (as outlined in the
MSO/Group LA-LB personnel study dated 28 February 1989)
have made it possible to assign an officer to this task full
time. Unit oil spill contingency planning has been an "as time
allows* assignment delegated to the Chief, Marine
Environmental Response Division. Trainee" officers assigned
to the Port Operations Department on a short rotation baas
are not suitable for this assignment as they lack the
prerequisite knowledge I experience and are not assigned to the
MER Division long enough to ensure project continuity. This
unit's personnel shortage (existing and projected) is the only
resource inadequacy that prevents on-going contingency
planning.
3. Developing a workable Local Contingency Plan has been
especially difficult for several reasons. Key unit MER
personnel were on extended TAD (Valdez, RTC) during this
past summer and the experience level of those who remained
onboard was low. Public concern for oil pollution abatement
has increased since the ExXOtl Valdez incident resulting in
more spill notifications and a corresponding increase in the
unit's pollution investigation workload. The unit's
participation in a major MARDEZ exercise in September and
the RRT/OSC drill in August further exacerbated the
manpower shortage in relation to this project
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4. Our current level of liaison with response agencies is less than
optimal due to insufficient unit staffing to support this objective.
Although MSO/Group LA-LB Marine Environmental Response
personnel participate in industry oil spill drills and attend
state/local agency and private industry emergency planning
committee meetings (CAER; ERCC; SCIOSH), -we do not
have adequate manning to permit regular response strategy
meetings -with these groups. As mentioned in paragraph 1, an
additional junior officer billet (full time local contingency
planner/MER liaison officer) -would alleviate this shortcoming.
MSO MORGAN CITY WORST-CASE SCENARIO
Another major Coast Guard region which deserves scenario/shortfall attention is the Gulf coastal region. The
following Coast Guard MSO Morgan City, Louisiana, scenario/shortfall analysis is an excellent model from this
region:
Situation
A 218,447 gross ton, 1240 ft supertanker, is en route the LOOP
anchorage area to transfer its cargo. About 10 miles from the anchorage,
the supertanker suffers a total loss of power and steering and collides
with an oil production platform at LAT 28-53'N, LONG 090-02'W. Both
the vessel and the platform suffer significant structural damage. The
supertanker's #1 port and #1 center cargo tanks are holed below the
waterline losing all cargo 2,856,000 gallons (68,000 bbls). The well, which
produces approximately 42,000 gallons (1,000 bbls) of oil per day, suffers
major damage to the well head and the blow out preventers. Fire erupts
on the supertanker as a result of the collision. Due to the total loss of
power the crew is unable to engage the main fire pump. They are unable
to reach the emergency pump, located in the forepeak, due to it being
blocked by the damaged tanks and the massive fire. The fire rages out
of control for 24 hours. With no hope of restoring power or reaching the
emergency fire pump, the crew abandons ship. The fire causes structural
weakening of the vessel. The supertanker subsequently breaks apart and
sinks. Eighty-five percent of the cargo onboard is lost as a result of the
sinking approximately 26 hours after the collision 50,400,000 gallons
(1,200,000 bbls).
wx
O/S WX: Winds 30 knots SE, seas 6-8 feet, air temperature 44 * F, sea
temperature 52' F. Date: February 12.
Cargo
This supertanker is cariying BASRAH, a heavy Iraqi crude with an API
of 33.7. This is a persistent oil with poor dispersion characteristics. It
has a dispersion factor of 3L, and may be difficult to disperse in all
expected sea temperatures.
Impact
A spill of this magnitude would be expected to impact the Louisiana
coastline immediately north of the LOOP anchorage area, and continue
westward for up to several hundred miles. Using typical offshore sea and
wind conditions for this time of year, this spill would be expected to
progress as follows:
Within 10 hours: Leading edge of slick would impact
the barrier islands in the vicinity of East Timbalier
Island, affecting the coastline westward to Whiskey Pass.
15 hours: Slick penetrates marshes within protected
waters, such as Terrebonne Bay and Timbalier Bay, as
far north as Bayou de Mangue.
24 hours: Slick affects the coastline for a distance of 20
miles westward. Tidal action causes marshlands and
bayous inland of lakes and bays to be oil covered
for a distance of five miles.
48 hours: Slick progresses westward to East Cote
Blanche Bay. The coastline immediately north of
the spill site is saturated with oil to a depth of 5
feet or more. First signs of large scale fish and
wildlife deaths are observed.
7 days: The slick covers an area of 1,500 square
miles; it is now 10 miles wide and extends as far
west as Southwest Pass, 150 miles west of the
incident.
Containment and Countenneasures
Due to the extreme persistence of heavy oils of this nature, the relatively
low daily sea and air temperature, and typical overcast conditions during
winter, this spill would not evaporate and dissipate as rapidly as
otherwise expected. Containment of heavy oil in seas over two feet
would be extremely difficult Boom entrainment would be likely, making
booming of sensitive shoreline areas ineffective.
Cleanup of affected marshlands would be greatly hampered due to the
inaccessibility of remote areas. Access by swamp buggy, johnboat, or
airboat would be necessary, making on-scene delivery of large amounts
of equipment difficult
As shown by the extent and difficulties encountered in the Valdez, AK
spill, an incident of this magnitude would be expected to take a year or
more to dean up.
MSO MORGAN CITY LOCAL CONTINGENCY PLAN
SHORTFALLS
1. Listed below are MSO Morgan City's shortfalls and problem
areas that may occur in the event of a major oil spill as
described in our worst-case scenario. This, shortfall list is
divided into two main categories: personnel (including the
assistance from local, state, and federal agencies); and
equipment (including the staging and transportation of this
equipment to the spill ate).
Personnel
a. MSO personnel resources are currently over utilized and
unable to adequately perform changes and updates to the spill
contingency plan. In order to provide a continuous review of
the plan to keep the LCP current, and for interagency
liaison/coordination, an additional Lieutenant, MST1 and
MST2 billet would be necessary. All current MSO functions
suffer due to the shortage of adequate personnel
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b. Other resources, such as reserve personnel during their two -week
drills, would be helpful for the planning and coordination needed
for the plan. We have requested this type of support in FY 90.
c. Input from local agencies is lacking. It is impossible to maintain
the required level of liaison with local agencies due to work load
and a lack of personnel to participate in their drills and Local
Emergency Planning Committee (LEPC) meetings. With the
exception of Terrebonne Parish and the Lafourche Parish Port
and Terminal Harbor District, emergency response agency (civil
defense/ police) interest in routine oil spills is low. Also, many
of the local agencies aren't staffed for pollution response and
therefore lack interest in what we are trying to accomplish.
d. There is currently a lack of cooperation between the U.S.
Minerals Management Service and the Coast Guard OSC
regarding sharing of information about pollution incidents in the
Gulf of Mexico. This command and the Eighth Coast Guard
District Marine Safety Staff have discussed these problems with
the staff of the USMMS Gulf of Mexico regional office, with an
aim toward improved coordination.
e. Lack of state agency input into the contingency plan is a major
shortfall due to the need for their available resources and local
knowledge in response to a major oil spilL As On-Scene
Coordinator for pollution incidents in the Gulf of Mexico, it is
in our best interest to share information with other agencies so
a coordinated response can be undertaken. The OSC/RRT drill
held in Morgan City during June 1989 was invaluable and
highlighted areas necessaiy to obtain our goal of improved
information sharing and response coordination liaison.
£ Input and assistance from other federal agencies has been
valuable. We have access to numerous federal agencies with a
wealth of knowledge and advice concerning spill response,
however, we are lacking in any type of formal wildlife
rehabilitation response program for Region VI. This is mainly
due to lack of proper personnel to coordinate the drafting of a
contingency plan for this specialized subject area.
g. In the event of a catastrophic spill where we would need the
additional support of personnel from other units, similar to the
Exxon Valdez spill response, there are insufficient facilities to
accommodate a large number of people. They could not be
housed in close proximity to the shoreline where possible cleanup
would need to be done. This would create a logistics problem,
similar to the Prince William Sound oil spill response.
a. Radio communication in southern Louisiana is poor. There are
presently two high level VHF-FM sites available to this unit:
one in Leeville, on our eastern most boundary, and one in Salt
Point, southwest of Morgan City. Both towers only provide
coverage in a SO mile radius. Hie local VHF tower in Morgan
City that we currently use does not cover an area greater than
approximately 10 miles outside of the city. In short, this leaves
out approximately 85% of the MSO Morgan City zone where a
majority of spills occur. There have been numerous incidents
where the lade of communications support has impeded proper
response to a pollution incident We have requested purchase
and rental of air time for 800 MHz trunk system portable
telephones for communications support in our zone. Cellular
telephone coverage is not yet adequate, however, it is improving
¦with time. By the end of 1990, construction of a tower in the
Morgan City area for cellular phones should be completed which
may provide communications throughout most of the zone.
b. Currently, there is no requirement for large oil transfer
facilities to have detailed contingency plans or pre-staged
equipment on smaller facilities. Due to the remote location
of most facilities within the zone, positioning of spill response
equipment on scene within a reasonable time frame is
sometimes difficult to achieve. Water is the only mode of
transportation to the majority of these locations. Due to
Louisiana's extensive marsh area, there are only two roads
which lead to the Gulf Coast One leads to the eastern most
boundary of the zone at Grande Isle and Fourchon; the other
to the western most boundary at Freshwater City. They would
provide us no access to other locations along the coastline if
there were to be a spill response in these areas. If equipment
is to be staged in other locations along the Gulf Coast, an
alternate means of transporting the equipment will be
required. Freight barges, tugs, or offshore supply vessels are
not on standby and in most cases not readily available for
immediate response. Due to the nature of the coastline
(bayous and marshland) oil spill response is quite difficult
There are numerous sensitive areas along the coast
c. Besides transportation for staging equipment, other means of
transportation for evaluating the spill is minimal. The most
reliable source of transportation to spill sites is by boat which
takes time, depending on the area of the spill, and may cause
a delay in evaluating the spill to determine the necessary
response equipment Helicopters from Air Station New
Orleans can be requested for spill evaluation in remote
locations such as the marshes, however, availability of aircraft
is low due to other operational commitments plus the likely
event that a proper analysis of the spill may be hard to
achieve by air. Helicopters under contract for inspection of
OCS facilities may not be used for oil spill response due to
current funding policies. These factors may cause delays in
evaluating a spill of major proportions which requires
response. The vast majority of spills in this zone are minor
and do not require response.
d. There is no heavy offshore cleanup equipment readily available
for an offshore response that is staged in this area.
(1) Clean Gulf Association (CGA) maintains the HOSS
barge which is a MARCO skimming barge capable
of picking up oil offshore. It is normally made
available to the offshore drilling production fariHties
which are members of the Assoaatioa It is
theoretically capable of removing oil from seas of
up to 8 feet, which does not meet the requirement
for state-of-the-art equipment as outlined in the
Marine Safety Manual, VoL VI (although the barge
has never actually been used). In addition, in order
to use the HOSS barge, the contractor must first
contract towing vessels to tow the barge to the spill
site. Tugs are not always readily available, finding
them on short notice is sometimes a lengthy hit-
or-miss process. The Coast Guard would also be
looking at contractual problems with CGA for the
use of this barge. There is not a standard
contracting procedure for use by non CGA
members.
(2) Peterson Riedel, another major cleanup company
for southern Louisiana, has a minimal amount of
offshore skimmers and boom which is staged outside
of New Orleans posing the problem of
transportation delays. There would be a minimum
delay of four hours in responding to any o&hore oil
spill.
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(3) LOOP maintain* a variety of pollution response
equipment in Grand Isle, LA. However, the Deep
Water Port Act requires them to have on hand cleanup
capabilities at all times. If the OSC were to request
this equipment, LOOP would need a waiver from that
act before releasing any equipment The amount of
LOOP equipment that would be available is not clear.
Regardless, LOOP equipment remains our primary
resource for a prompt offshore oil spill response in
and around the Grand Isle offshore area.
(4) A self-propelled Mexican split hull skimming vessel,
the ECOPEMEX, may be available to the United
States in the event of a major spill. An Agreement
of Cooperation between the United States and Mexico
has been executed, however it leaves out all of the
formalities in acquiring the barge from Mexico (Le.,
Jones Act). Significant delay would be encountered in
obtaining this resource.
(5) Another source, even though the practicality of
obtaining the equipment is questionable, is from
Biegert Aviation in Phoenix, Arizona. Biegert Aviation
manufactures the Airborne Dispersant Delivery System
(ADDS) which is made to fit inside a C-130 for
spraying. Rental costs begin at $100,000 for system
installation and do not include the cost of fuel, aircraft
rental (approximately $4,000 - $5,000 per hour), flight
crew fees, or rental of the ADDS pack. The C-130
would have to be rented from California, the only
known commercial source other than Florida, flown
into Phoenix to have the system installed, and finally
to this area, creating significant delays. Possible use
of a military C-130 may be a solution, however, flight
crews are not trained in dispersant spraying. Marine
Industry Group (MIRG), in conjunction with Clean
Caribbean Co-op, maintain an ADDS pack in Ft
Lauderdale, FL, however acquisition of this equipment
is dependent upon contractual negotiations and may
be limited due to contingency requirements of
association members.
Staging heavy cleanup equipment for a spill offshore seems to
be our biggest problem. Due to the lack of resources for a spill
of significant magnitude, we would be relying heavily on the use
of Coast Guard Strike Team equipment Equipment will have
to be obtained and flown in possibly by C-130 to one of only
three available airports with the facilities to accommodate a
loaded C-130. The transportation problems previously identified
would still cause a significant delay in response time for cleanups
if they have to originate from these airports.
A pre-agreement between the Coast Guard and LOOP Inc., as
well as between the Coast Guard and Clean Gulf Association,
needs to be arranged because they are major resources for
cleaning up a significant offshore spill. Such an agreement would
eliminate delays in response times.
g. Preapproval authorizing the OSC to use oil dispersants is still
in the discussion stage. LOOP'S oil spill contingency plan
relies heavily on this approval to respond to an oil spill Since
there is no current preapproval and due to the possibility that
dispersants would not be approved through the RRT, LOOP
and CGA have been reluctant to stage any large quantities of
dispersants in the local area. This again would cause delays
if dispersants are shipped in. By then, it may be too late to
spray efficiently. There are virtually no aircraft readily
available for dispersant spraying. Lack of preapproval
authority makes this resource capability not economically
feasible to maintain.
Subj: Additional Shortfalls
1. The following figures are estimates for shortages in amounts
of boom, dispersants, and skimmers that we would need in the
event our worst-case scenario occurred. Resources which we
consider readily available are from Clean Gulf Association,
LOOP, LAST and local contract companies.
2. Booms:
a. Open water boom - we currently have approximately
15,500 feet of open water boom or boon we could
use out in the Gulf of Mexico depending on sea
conditions. This amount includes 43" and 30"
Expandi-Boom. For our worst-case scenario, this
would leave us about 100,000 feet short to
adequately control the spill
b. Calm water boom - for protection of sensitive areas
along the beaches and marshes, including Expandi-
Boom, 18" and T foam boom, 24" and 14" Fence
type boom, there are 30,800 feet available. Because
of the extensive marsh area and the large area of
impact in our worst-case scenario, we would be short
about 400,000 feet of calm water boom.
3. Dispersant Clean Gulf Association and LOOP have 41,000
gallons of Corexit 9527 dispersant on hand in local
warehouses. Approximately 160,000 gallons of dispersants
would be needed.
4. Sl'imitn:
a. Inshore skimmers - most of these skimmers are
floating skimmers, hand held skimmers, and small
skimming vessels. Assuming all skimmers in the
area are available and in operating condition, we
would still be short about 40 skimmers. This does
not take into account the efficiency of the skimmers.
b. Offshore skimmers - the HOSS barge from Clean
Gulf Association would be our primary skimmer for
offshore spills. Even with this high efficiency
skimmer and 20 other offshore skimmers, we would
still need approximately 25 additional large
skimmers.
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APPENDIX C
Summary of International Agreements
Bilateral Agreements
The following bilateral agreements and joint contingency plans currently exist to assist in the protection of U.S. interests.
US/Canada - The "Canada/US Joint Marine Pollution Contingency Plan (JCP)" is the basis for all contingency planning and
emergency response activities along the maritime boundaries of the United States and Canada. In addition to the basic
national plan there are five annex plans covering the specific areas of the Great Lakes, Atlantic Coast, Pacific Coast, Beaufort
Sea, and Dixon Entrance off the Pacific Coast. The U.S. and Canadian Coast Guards are responsible for the maintenance
of the JCP and for holding periodic exercises to insure vitality of the JCP and the individual annex plans. A Canada/U.S. Joint
Inland Pollution Contingency Plan is being negotiated. Regional Contingency Plans currently address inland responses along
the Canadian/U.S. border.
US/Mexico - The "Agreement of Cooperation Between the United States of America and the United Mexican States Regarding
Pollution of the Marine Environment by Discharges of Hydrocarbons and other Hazardous Substances" provides for the
establishment of a United States-Mexico Joint Marine Contingency Plan (JCP). Two separate JCPs in support of the
Agreement now exist in draft form for the Gulf of Mexico and the Pacific Ocean. The USCG and the Mexican Navy are the
responsible agencies for the Marine JCPs. The latest cooperative effort was a joint exercise for the Gulf of Mexico hosted
by Mexico in November 1989.
The "Agreement of Cooperation Between the United States of America and the United Mexican States on Cooperation for
the Protection and Improvement of the Environment in the Border Area" establishes a Joint Response Team (JRT) for the
inland border area and provides for development of a U.S.-Mexico Joint Contingency Plan for the inland border area. The
U.S. Environmental Protection Agency (EPA) and the Secretaria de Desarrollo Urbano y Ecologia (SEDUE) serve as co-
chairs of the Inland JRT. The bilateral plan was completed in January 1988. It will include as annexes hazardous materials
contingency plans for the 28 Sister cities along the border. In 1989, the U.S. and Mexico sponsored a Joint Hazardous
Materials Conference in April 27-29 to discuss issues involved in preparing for hazardous materials incidents. Several joint
exercises have been held in the border area, the most recent involving emergency officials in Calexico, California and Mexicali,
Mexico. A second conference is planned for June 1990 to focus on development of the Sister cities plans.
US/USSR - The "US/USSR Joint Contingency Plan Against Pollution in the Bering and Chukchi Seas (JCP)" was signed on
October 17,1989. It resulted from the USCG headed project entitled "Prevention and Clean-up of Pollution of the Marine
Environment from Shipping" under the present US/USSR environmental agreement. Currently efforts continue at the regional
working level (Juneau - Vladivostok) to develop an operational appendix to the JCP. The operational appendix will cover such
areas as communications, reporting systems, designated and/or potential Joint Response Team members, useful points of
contacts and abbreviations.
US/Bermuda - The "Agreement Between the Government of the United States of America and the Government of Bermuda
Concerning Assistance to be Rendered on a Reimbursable Basis by the United States Coast Guard" is a standing agreement
instituted in 1976 as a result of several tankship groundings and other pollution incidents in Bermuda.
Note: The United Kingdom is now considering a similar arrangement either with the U.S. Government or with private U.S.
response organizations for pollution response in the British dependent territories of the Caribbean (BVI, Caymen Islands,
Turks & Caicos, Monserrat, and Anguilla). Both the US/Bermuda Agreement as weU as this effort may be replaced with the
new International Convention on Pollution Response now being developed.
US/France - The "Marine Pollution Control Project of the US/France Cooperative Agreement on Oceanography" is a technical
information exchange program vice an active response agreement. The objective is to. exchange technical information and
national/industry developments on all aspects of marine pollution prevention, response and contingency planning. Both parties
have found this project to be an excellent interchange.
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Multilateral Agreements
Caribbean - The U.S. involvement in the Caribbean can be summarized under three separate but related efforts.
First, as a parly to the "Convention for the Protection and Development of the Marine Environment of the Wider
Caribbean Region (Cartagena Convention)" and the "Protocol Concerning Cooperation in Combatting Oil Spills in the Wider
Caribbean Region" the U.S. has agreed to cooperate and to assist nations in the region in the field of marine pollution.
Second, under the Protocol the U.S. is participating in the "Sub-Regional Oil Spill Contingency Plan for the Island States
and Territories of the Wider Caribbean Region." This active participation helps to provide protection for the U.S. Virgin
Islands and Puerto Rico.
Third, the Coast Guard provides an officer to the International Maritime Organization to act as their Regional
Consultant on Marine Pollution, Port Safety and Security for the Wider Caribbean.
South Pacific - The U.S. is a party to the "Convention for the Protection of the Natural Resources and Environment of the
South Pacific Region." It contains two Protocols on exchange of information and cooperation in combatting pollution
emergencies and dumping. Neither the Convention nor the Protocols have entered into force yet. In the interim, the Coast
Guard has been actively participating in regional workshops and other efforts to promote the Convention as well as to provide
response protection to U.S. interest in the region.
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APPENDIX D
NRT Member Agencies
The Environmental Protection Agency (EPA) chairs the NRT, co-chairs the standing RRTs, provides predesignated On-
Scene Coordinators for the inland zone, and Remedial Project Managers (RPMs) for remedial actions, and generally provides
scientific support coordinators for the inland zone. When the NRT is activated for response actions, the chairman shall be
the EPA or USCG representative, based on whether the discharge occurs in the inland or coastal zone. EPA provides
expertise on environmental effects of releases and on environmental pollution control techniques. EPA provides guidance,
technical assistance, and training in hazardous materials preparedness and response. EPA also provides legal expertise on the
interpretation of CERCLA and other environmental statutes. EPA may enter into a contract or cooperative agreement with
the appropriate State to implement response actions.
The United States Coast Guard (USCG) provides predesignated On-Scene Coordinators for the coastal zone, co-chairs for
the standing RRTs, and the NRT vice-chair. When the NRT is activated for response actions, the chairman shall be the EPA
or USCG representative, based on whether the discharge occurs in the inland or coastal zone. The USCG staffs and
administers the National Response Center; maintains the continuously manned facilities that can be used for command,control,
and surveillance of releases in coastal waters; and serves as fund manager for the Pollution Fund established under the Clean
Water Act. The Coast Guard's National Strike Force is specially trained and equipped to respond to major marine pollution
incidents. In water pollution incidents in which the USCG has financial responsibility jurisdiction, the USCG ensures that
responsible parties, both U.S. and foreign, are able to compensate the U.S. and other damaged parties through the Certificate
of Financial Responsibility program.
The Federal Emergency Management Agency (FEMA) provides guidance, policy, and program advice, and technical assistance
in hazardous materials and radiological emergency preparedness activities (planning, training, and exercising) to state and local
governments. In a response, FEMA provides advice and assistance to the lead agency on coordinating relocation assistance
and mitigation efforts with other Federal agencies, State and local governments, and the private sector. FEMA may enter into
an agreement with the appropriate political entity to implement relocation assistance in a response.
The Department of Defense (DOD) must take all action necessary with regard to releases of hazardous substances where the
release is on, or the sole source of the release is from, a facility or vessel under jurisdiction, custody, or control of the DOD.
DOD may also, consistent with its operational requirements and at the request of the On-Scene Coordinator, provide locally
deployed U.S. Navy oil spill equipment and provide assistance to other Federal agencies on request. The following two
branches of DOD have particularly relevant expertise:
The U.S. Army Corps of Engineers has specialized equipment and personnel for removing navigation
obstructions and accomplishing structural repairs. Additional Corps support capabilities include: the
recoveiy of oil using hopper dredges or the Reserve Fleet, contracting, construction management, real
estate, engineering, environmental review and monitoring, regulatory permitting, research and
development, and power generation.
The U.S. Navy (USN) has an extensive array of specialized equipment and personnel available for use
in ship salvage, shipboard damage control, and diving. The Navy also has a vast array of open water
pollution response equipment prestaged on both coasts. At each major shore facility, the Navy also has
equipment staged for immediate response, while the more extensive equipment is in transit.
The Department of Energy (DOE), except as otherwise provided in Executive Order 12580, provides designated On-Scene
Coordinators/ RPMs that are responsible for taking all response actions with respect to releases of hazardous substances
where either the release is on, or the sole source of the release is from, any facility or vessel under its jurisdiction, custody or
control. In addition, under the Federal Radiological Emergency Response Plan (FRERP), DOE provides advice and
assistance to other On-Scene Coordinators/RPMs for emergency actions essential for the control of immediate radiological
hazards.
Appendices-31
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The Department of Agriculture (USDA) has scientific and technical capability to measure, evaluate, and monitor, either on
the ground or by use of aircraft, situations where natural resources including soil, water, wildlife, and vegetation have been
impacted by hazardous substances. The USDA may be contacted through Forest Service emergency staff officers who are the
designated members of the RRT. Agencies within USDA with relevant expertise are: the Forest Service, the Agriculture
Research Service, the Soil Conservation Service, and the Food Safety and Inspection Service, and the Animal and Plant Health
Inspection Service.
The Department of Commerce (DOC), through the National Oceanic and Atmospheric Administration (NOAA), provides
scientific support for responses and contingency planning in coastal and marine areas, including assessments of the hazards
that may be involved, predictions of movement and dispersion of oil and hazardous substances through trajectory modeling,
and information on the sensitivity of coastal environments to oil or hazardous substances. NOAA provides scientific expertise
on living marine resources it manages and protects. It also provides information on actual and predicted meteorological,
hydrologic, ice, and oceanographic conditions for marine, coastal, and inland waters as well as tide and circulation data.
The Department of Health and Human Services (HHS) is responsible for providing assistance on matters related to the
assessment of health hazards at a response and protection of both response workers and the public's health. HHS is delegated
authorities under CERCLA relating to a determination that illness, disease, or complaints may be attributable to exposure to
a hazardous substance, pollutant, or contaminant. Agencies within HHS that have relevant responsibilities, capabilities, and
expertise are the Agency for Toxic Substances and Disease Registry (ATSDR) and the National Institutes for Environmental
Health Sciences (NIEHS).
The Department of the Interior (DOI) has expertise on and jurisdiction over a wide variety of natural resources and Federal
lands and waters as well as certain responsibilities for native Americans and U.S. territories. The DOI may be contacted
through Regional Environmental Officers (REO), who are the designated members of RRTs. Bureaus and offices with
relevant expertise are: Fish and Wildlife Service; Geological Survey; Bureau of Indian Affairs; Bureau of Land Management;
Minerals Management Service; Bureau of Mines; National Park Service; Bureau of Reclamation; Office of Surface Mining and
Reclamation Enforcement; and Office of Territorial Affairs.
The Department of Justice (DOJ) provides expert advice on complicated legal questions arising from discharges or releases,
and Federal agency responses. In addition, the DOJ represents the Federal government, including its agencies, in litigation
relating to such discharges or releases.
The Department of Labor (DOL), through the Occupational Safety and Health Administration (OSHA) and the States'
operating plans approved under the Occupational Safety and Health Act of 1970, has authority to conduct safety and health
inspections of hazardous waste sites to assure that employees are being protected and to determine if the site is in compliance
with safety and health standards and regulations. On request, OSHA will provide advice and assistance regarding hazards to
persons engaged in response activities.
The Department of Transportation (DOT) provides response expertise planning to transportation of oil or hazardous
substances by all modes of transportation. Through the Research and Special Programs Administration (RSPA), DOT offers
expertise in the requirements for packaging, handling, and transporting regulated hazardous materials, including transportation
by pipeline. RSPA promulgates and enforces the Hazardous Materials Regulations. RSPA provides technical assistance in
the form of Emergency Response Guidebooks and, in a joint effort with FEMA, has developed HMIX. RSPA also provides
planning support in the development of protective action decision strategies and exercise scenarios.
The Department of State (DOS) takes the lead in the development of international joint contingency plans. It also helps to
coordinate an international response when discharges or releases cross international tx>undaries or involve foreign flag vessels.
Additionally, DOS coordinates requests for assistance from foreign governments and U.S. proposals for conducting research
at incidents that occur in waters of other countries.
The Nuclear Regulatory Commission responds, as appropriate, to releases of radioactive materials by its licensees, in
accordance with the NRC Incident Response Plan (NUREG-0728). In addition, the NRC will provide advice to the On-
Scene Coordinator/RPM when assistance is required in identifying the source and character of other hazardous substance
releases where the Commission has licensing authority for activities utilizing radioactive materials.
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Current National Response Team Members
Environmental Protection Agency, Chair
U.S. Coast Guard, Vice-Chair
Department of Agriculture
Department of Commerce (NOAA)
Department of Defense
Department of Energy
Federal Emergency Management Agency
Department of Health and
Human Services (ATSDR)
Department of the Interior
Department of Justice
Department of Labor
(OSHA)
Department of State
Department of Transportation
(Research and Special Programs
Administration)
Nuclear Regulatory Commission
Mr. Jim Makris
Capt. Richard Larrabee
Mr. Bill Opfer
Mr. George Kinter
Dr. Brian Higgins
Mr. Richard Dailey
Mr. Craig Wingo
Ms. Georgi Jones
Dr. Jonathan Deason
Mr. Bruce Gelber
Mr. Frank Frodyma
Mr. Bob Blumberg
Mr. Alan Roberts
Mr. Gary Zech
Appendices-33
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Current Co-Chairs of Regional Response Teams
Region EPA
I Edward Conley, Boston, MA
II Richard Salkie, New York, NY
III Dennis Carney, Philadelphia, PA
IV Bob Jourdan, Atlanta, GA
V Mary Gade, Chicago, IL
VI Charles Gazda, Dallas, TX
VII Ron Ritter, Kansas City, KS
VIII Robert Duprey, Denver, CO
IX Kathleen G. Shimmin, San Francisco, CA
X James Everts, Seattle, WA
Alaska Alvin E. Ewing, Anchorage, AK
Caribbean Richard Salkie, New York, NY
Oceania Kathleen G. Shimmin, San Francisco, CA
(Pacific
Basin)
USCG
Capt. D.L. Folsom, First CG District,
Boston, MA
Capt. D.L. Folsom, First CG District,
Boston, MA
Capt. C.C. Martin, Fifth CG District,
Portsmouth, VA
Capt. D.H. Whitten, Seventh CG District,
Miami, FL
Capt. R.W. Mason, Ninth CG District,
Cleveland, OH
Capt. K.P. Pensom, Eighth CG District,
New Orleans, LA
Cdr. M.R. Perkins, Second CG District,
St. Louis, MO
Cdr. M.R. Perkins, Second CG District,
St. Louis, MO
Capt. GA. Casimir, Eleventh CG District,
Long Beach, CA
Capt. R.N. Roussel, Thirteenth CG District,
Seattle, WA
Capt. D.E. Bodron, Seventh CG District,
Juneau, AK
Capt. D.H. Whitten, Seventh CG District,
Miami, FL
Capt. A.E. Tanos, Fourteenth CG District,
Honolulu, HI
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APPENDIX E
NATIONAL RESPONSE TEAM GUIDANCE DOCUMENTS
This appendix contains the guidance documents requesting the information that was consolidated into this report. The first
letter in the appendix was sent from the National Response Team to the 13 Regional Response Teams. The second letter,
with accompanying enclosures, from Coast Guard Headquarters was sent to the 47 Coast Guard Captains of the Port who
serve as pre-designated On-Scene Coordinators (OSCs). The third letter, with enclosures, from the Environmental Protection
Agency (EPA) Headquarters was sent to the 10 EPA regions, EPA Oil and Hazardous Materials Coordinators and EPA
Chemical Emergency Preparedness Program Coordinators.
-------
National Response Team
of the National Oil and Hazardous
Substances Contingency Plan
G-WER/12, 2100 2nd Street SW, Washington, D C 20593
SEP 1 1 1989
NRT
I nvironmental
Protection
Agency
United States
C oast Ciuard
Department of
Commerce
Department of
Interior
Department of
Agriculture
Department of
Defense
Department of
Slate
Department of
Justice
Department of
Transportation
Department of
Health and
Human Services
Federal
hmergency
Management
Agency
Department of
Einergy
Department of
Labor
To: Regional Response Team Co-Chairs
Regional Response Team Representatives
(distributed by Co-Chairs) ^ / .
)//
From: Jim Makris, Chairman, jj //>¦'
National Response Team ji //C..
- /
CaptaifTRichard M. Laprabee, Vice Chairman,
National Response Team
Subj: Six Month Oil Spill Contingency Plan Study
The EXXON VALDEZ oil spill focused national attention on this nation's ability to respond
to incidents of major proportions. At a press conference on April 7, 1989, the President said
"This situation has demonstrated the inadequacy of existing contingency plans. And
consequently, I have directed a nationwide review of contingency plans of this type to determine
improvements that may be necessary." A White House press release the same day stated "...the
President has directed a review of contingency plans of this type nationwide, to determine their
adequacy in light of the lessons of this situation and the response. The National Response
Team... has been directed to undertake this reevaluation of existing planning and to report
findings and recommendations within 6 months." This letter is to update you on this study.
The NRT established a work group under the leadership of the Coast Guard. Due to the limited
time frame in which the report must be completed, the NRT is restricting the scope of the study
and concentrating on those aspects which will yield the most relevant information. The NRT's
goal is to produce a highly credible report that accurately reflects the state of national
preparedness for oil spills.
This study is limited to oil spills. A good deal of information coming out of this study will have
applications to hazardous substances releases and will benefit that area too. A corollary effort
to look at planning for response to hazardous substances releases is expected at a later date.
The current study is not all-encompassing, nor will every oil spill contingency plan in the country
be reviewed. However, the process of following up on various recommendations and reporting
on results may continue for some time after this study.
The primary focus of this study is on major port areas and inland zones. The Coast Guard is
taking the lead in the major port areas and has provided their OSCs with guidance for review
of their plans. EPA is taking the lead in the inland zones and has provided their OSCs and
Chemical Emergency Preparedness and Prevention (CEPP) coordinators with appropriate
guidance for information to be gathered and forwarded to the RRTs. We will also address
contingency plans required for outer continental shelf activities and pipelines transporting oil.
Report Oil and Chemical Spills Toll Free (800)424-8802
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Page 2 of 3
As an important and integral part of the contingency planning community, we request your participation
on two different levels. As individual agency representatives, we ask each of you to stress the importance
of this study and lend your full support to the USCG and EPA OSCs. As members of the RRT, we
request your active participation in the submission of an RRT report addressing the broader contingency
planning efforts in your region. The information collected from the EPA OSCs, USCG OSCs and RRT
reports will be consolidated and presented in one report to the President.
We have enclosed an outline of the work plan for the study and a schedule for your information. We
envision the bulk of information provided by the RRTs to be included in the third section of the report
"State of Preparedness/Contingency Planning."
Status of known contingency planning currently in place - We ask that you identify all
contingency planning that you are aware of within your regional boundaries. "Planning" can
include efforts other than plan documents (e.g., regular meetings of the response community).
We request that you review all CG and EPA OSC Oil Spill contingency plans. Please provide
comments on your review to the appropriate CG and EPA OSCs. Other planning efforts should
be addressed for their relationship with the local OSC plans. Examples of other activities
impacting on local OSC plans include federal facilities, state planning, local emergency planning
committees (LEPCs), cross-boundaiy agreements, industry efforts, and cooperative plans. We
don't expect all plans to be reviewed. We do request that all CG and EPA OSC oil spill
contingency plans be reviewed by the RRT. We also request that you review your Regional
Contingency Plan and address any joint contingency plans the RRT may be involved in with
Canada, Caribbean countries, Mexico, or the USSR. We would like to know what you know
about each of these international plans as well as the plans mentioned above. Plans should be
consistent with each other and there should be no conflicts with the Federal plans. Planning
efforts should be coordinated and you should address the extent to which they are. Whatever
is not known at this time would become the basis of a recommendation for further
investigations, surveys or other activities to improve the state of our knowledge and the
effectiveness of our system.
Describe the process by which the RRT reviewed the plans, including your assumptions. We
seek to understand the level of thoroughness of the plans that you have reviewed. For example,
if you telephone various contacts in the plans to verify the currency of the plans, that is one level
of detail. If you assume all names, telephone numbers and addresses are current, that is a
different level of review. We are not requesting any particular level, we only need to know what
level of review you conducted for the various plans.
Discuss the personnel and equipment shortfalls. This information should be addressed in detail
in the reviews conducted by the CG and EPA OSCs in their reports. However, we request that
the RRTs look at the broader picture such as: What are the regional capabilities? In your
judgement how well-prepared are regions to work together? What joint arrangements have been
made and how often have these been exercised? Where are your areas of greatest concern?
How do you plan to cover these until the identified shortfalls are adequately addressed?
Discuss topics such as disposal of oil and oiled-debris problems, need for pre-planning for use
of dispersants, communications problems, etc. Other topics that should be addressed are
bioremediation, in-situ burning guidelines and any other natural resource-protection guidance.
We ask that the RRT serve as a forum to share ideas and progress with EPA and CG OSCs, EPA
Regions, CG Districts, states, and Federal agencies throughout this effort. To the extent that you can
provide information for any other section of the work plan, we welcome it. The schedule calls for your
report to be received by the NRT by November 3,1989. We know this is a very tight schedule but for
us to meet our commitment to the President, we must receive your report by then. We ask that the
report be done on a computer and that a disc containing the report in ASCII language be submitted
along with a hard copy of your report.
Appendices-37
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Page 3 of 3
We recognize and appreciate the tremendous effort this will require and urge that maximum resources
be made available to undertake this task. The President specifically requested that the NRT undertake
this study, and the NRT is committed to deliver a complete and accurate report. We believe that this
report will have major impacts on us as individual agencies and as members of the federal response
system (NRT, RRTs, OSCs). In the climate of EXXON VALDEZ, this is an excellent opportunity to
honestly evaluate and build on the existing response system. If you have any questions please contact
one of the following: CDR Doug Lentsch (FTS 267-0440) regarding the Coast Guard OSC input,
John Riley (FTS 382-2190) regarding the EPA OSC input, and LCDR Harry Schultz (FTS 267-2616)
regarding the consolidated report.
Enclosures (1) work plan for report to the President
(2) schedule for NRT Contingency Plan Study to the President
(3) CG guidance for "Review of Local Oil and Hazardous Substances Pollution Contingency
Plans
(4) EPA Guidance
-------
U.S. Department
of Transportatioi
Commandant
United States Coast Guard
Washington, D C. 20593-0001
Staff Symbol: G-MER-2
Phone (202) 267-0434
United States
Coast Guard
16465
July 26, 1989
From: Commandant
To: Distribution
Subj: REVIEW OF LOCAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY
PLANS
Ref: (a) ALDIST 087/89 of 26 Apr 89
(b) ALDIST 115/89 of 26 May 89
1. PURPOSE.
a. As a result of the EXXON VALDEZ major oil spill, national attention has been focused once again
on the Federal government's ability to respond to incidents of major proportions. As the lead federal agency
for the coastal area of this country, the Coast Guard is committed to ensuring the Federal government is
adequately prepared to execute a coordinated, rapid, efficient, and successful response to major oil and
hazardous substance spills. The purpose of this letter is to provide District Commanders and pre-designated
Federal On-Scene Coordinators (OSCs) with a logical and practical means of conducting contingency plan
review and to require this review and appropriate revision in a timely manner. This effort is focused on
response to oil spills. Hazardous substances will have to be done at a later date; however, this is not to
discourage ports from including hazardous substances in their review and revision if they desire.
b. The guidance contained herein is not inclusive or all-encompassing. It is not intended to provide
answers to all questions or scenarios. It should not, in any way, impede innovative ideas or sound judgement.
Commandant (G-MER) is soliciting any suggestions or recommendations that would improve the review
process or result in a better contingency plan.
c. Contingency planning is an ongoing, dynamic process that must be kept current to be of value. This
is true for spill response as well as port security, civilian disturbance, or natural disasters. In this area, there
are no shortcuts for liaison, understanding, and sound judgement. Captain of the Port (COTPs) are expected
to exercise their best, professional judgement when using the guidance and criteria provided herein.
a. With the passage of the Federal Water Pollution Control Act (FWPCA) in 1972, the Coast Guard
launched its marine environmental response program. As this program developed, pre-designated federal
OSCs were required to develop and maintain local contingency plans for responding to oil pollution discharges.
Hazardous substance releases were added at a later date. As our marine environmental response (MER)
program developed, more and more planning guidance in the form of reference material, as well as
Commandant directives, was distributed. Enclosure (1) is a list of currently available contingency planning
guidance. These publications should be maintained and reviewed at the office of every OSC. Replacement
copies are available from Commandant (G-MER-2). Copies of two references are enclosed for your use.
b. Certain areas of emphasis have been identified. Any review of existing contingency plans should focus
on the entire response effort, including those areas identified below:
(1) Define the "maximum potential" for a spill in your area (i.e., largest tank vessel, offshore oil rig,
largest tank on a facility).
(2) Define the "maximum realistic potential" for a spill in your area.
(3) Hazard identification ("What and where are the hazards?")
2. DISCUSSION.
ENCLOSURE (3)
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Page 2 of 5
Subj: REVIEW OF LOCAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY
PLANS
(4) Vulnerability analysis ("What is especially sensitive and thereby susceptible to damage?")
(5) Risk Assessment ("What is the probability of damage taking place and the actual extent of
damage that might occur?")
(6) Availability of response resources (equipment and personnel).
(7) Existing shortfall of response resources, (Response personnel and equipment, specific expertise,
use of dispersant policy, etc.)
(8) Determination of response times and levels to remote areas within the zone. (Are they
acceptable and within the guidelines of enclosure 4?)
(9) Effective public information system, and Protocol Officer to brief and escort visiting dignitaries.
(10) Response organization (command and control structure; roles and responsibilities).
(11) COTP's estimate of the Port's response capability ("What is the largest spill that the Port can
handle?)
(12) Policy regarding use of dispersants, burning, disposal, and other options.
c. It has become apparent that all too often "lead agency" has been translated to "only agency" when it
comes to contingency planning. This type of Coast Guard-only plan development is not only undesirable,
but can be detrimental to effecting a coordinated response. While conducting this review, OSCs should ensure
that all Regional Response Team (RRT) agencies and other appropriate response organizations at the federal,
state, local, industry, and public levels are involved in the planning, review, and exercise process. Some
examples include: the Corps of Engineers (which can be found in most every major port area) which can
provide valuable statistics and waterway data, as well as cleanup expertise; the Department of Energy (DOE)
can provide information on petroleum supply and transportation networks including facility data; and
Occupational Safety and Health Administration (OSHA) should be consulted concerning worker safety and
health. The Regional Response Team agencies (RRT) are a valuable source of information and should be
used to their fullest benefit. The National Response Team (NRT) will be directing the various RRTs to
provide assistance to the COTPs, as required. Don't be hesitant to task an RRT with projects that are within
their purview such as developing a policy on use of dispersants or burning or assisting with disposal problems.
d. OSCs should further ensure that response organizations established by state and local entities do not
conflict with existing federal plans. This can only be accomplished by sharing contingency planning information
and conducting appropriate liaison to ensure all parties are aware of each other's responsibilities. Command
and control structure, as well as roles and responsibilities, should be clearly delineated in the plan. A multi-
agency local response and planning group should be utilized to assist in this review and planning process. One
should be formed in those areas where such a group does not exist. This response and planning group should
meet periodically to discuss such items as contingency plan review, response strategy and problems, scheduling
exercises, etc.
e. In conducting any meaningful review of contingency plans, it is not only helpful, but essential, to
consult local experts, such as pilots, port authorities, facility managers, pollution contractors, state and local
agencies, etc., in an effort to get the best possible information necessaiy to identify hazards, assess the risks,
and formulate effective response plans. TTiese are some of the people and organizations that could make up
the previously mentioned multi-agency response and planning group.
f. In conducting the review and revision of contingency plans, OSCs are expected to identify the following
scenarios and then critically examine their plans to ensure they address a response to them. If the response
resources necessary are not available, then address the level to which the port is prepared to respond and
determine shortfalls.
(1) The average oil spill that has occurred within your zone. Review whatever data is available to
you (local pollution logs, MSIS, etc.); however, it should not be necessary to look further back than 10 years.
(2) The largest or most complex oil spill that has occurred within your zone during the last 10 years.
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Page 3 of 5
Subj: REVIEW OF LOCAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY
PLANS
(3) The "catastrophic" type incident that most likely would occur within your zone, after review of
hazard identification assessment and transportation patterns.
g. The contingency plan review should also include a thorough review of the response capabilities of oil
terminals (as outlined in their Operations Manual) and offshore exploration and production platforms (as
described by contingency plans required by Minerals Management Services).
h. The EXXON VALDEZ spill has pointed out some areas of contingency planning that are often
overlooked, but are critical for a large response. These include, but are not limited to:
(1) Logistics of getting the response equipment to the site.
(2) The "response organization" for a normal spill will not support the "big spill". The organization
must be sized appropriately. Include not only the response organization, but the support organizations as well,
such as contracting and legal assistance.
(3) While building up the big initial response, you must use foresight. Mobilizing large pieces of
equipment is time consuming.
(4) Adequacy of number of phone lines, use of cellular phones, set up two dedicated facsimile
machines (incoming and outgoing), have a contact for telephone service and predetermine the number of extra
phone lines needed, etc.
(5) Establishment of a long-term, 24 hour watch system for all levels (including Scientific Support
Coordinator's) if necessary.
(6) Establishment of dedicated public affairs personnel and a protocol officer to handle political
questions, visits, briefings, etc. Consider establishment of a joint information center for coordinated news
releases, etc., from associated state and federal agencies. Request assistance from district and Maintenance
and Logistics Command (MLC) public affairs personnel. Remember that the Public Information Assist Team
(PIAT) is available upon request to Commandant (G-MER-2).
(7) An accounting process for the oil including:
How much was on the vessel/facility?
How much was spilled?
How much has evaporated?
How much has been contained?
How much has been cleaned up?
How much has impacted the shoreline?
(8) Assess the need for additional Coast Guard personnel as well as berthing/messing facilities for
them.
(9) If you anticipate the need to fly in CG Strike Team equipment, or Navy Supervisor of Salvage
equipment, be ready to direct them to the closest airport that has the size to land the plane and the proper
equipment to off-load it. This is a time-consuming effort and may impact negatively on your response if you
can't locate the nearest airport to the spill. Some Air National Guard airports can handle this type of traffic.
(10) Large spills create the need to dispose of huge amounts of contaminated oil, oiled logs, dead
animals, etc. Many disposal solutions (burning, at sea dumping, etc.) require permits from other federal and
state agencies. Check into these and have appropriate contacts in place. Permit issuance can be a very lengthy
process.
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Page 4 of 5
Subj: REVIEW OF LOCAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY
PLANS
(11) If you reasonably expect to do this response in a credible manner, it will take coordination,
cooperation, and pre-planning. Districts and MLCs may be in the position to provide additional support.
(12) All units should have received a copy of the NRT's report to the President regarding the initial
response to this spill. It includes some excellent "food for thought".
(13) Particular portions of pollution response readily lend themselves to action plans and checklists.
These prepared checklists preclude the possibility of failing to make critical decisions or complete some
necessary action that could impact negatively at a future point of the response.
i. Spill information is available from the Marine Safety Information System (MSIS). Units should obtain
this information locally, if at all possible. For those units requiring additional spill history information from
MSIS, Ms. Mary Robey is the point of contact at Headquarters, phone number FTS 267-0452. She will need
the exact latitudes and longitudes for each particular area as well as specific types of information needed.
Direct contact with her is encouraged. Each request will require a few days to process.
j. In planning for the catastrophic incident, it is an accepted conclusion that the OSC does not have
adequate local resources to combat such an incident. However, it is just as important to identify shortfalls
as it is to identify available resources. The shortfalls should be based on the response strategy to the particular
scenarios above, with certain assumptions being made concerning response times, equipment efficiencies,
sensitive areas, weather, time of day, and season of year, etc. The particular scenario, along with the list of
assumptions, should be submitted to Commandant (G-MER) with the list of shortfalls.
k. I recognize that OSCs are also COTPs/OCMIs/COs and, as such, are tasked with numerous program
and command responsibilities. However, this particular review and revision of pollution contingency plans is
of the highest priority and must be accomplished without the benefit of additional resources. Despite the high
interest now on contingency planning, it is very important that strong emphasis remain on pollution prevention,
since this is the key to a successful pollution response program.
1. OSCs shall use the criteria in enclosure (2) and the reference material in enclosure (1) for reviewing
their local contingency plans. These same materials should prove valuable to district commanders in their
review and approval of these plans.
m. I recognize that most units may not perform this type of liaison, coordination, development, and
review on a continual basis. Your feedback regarding the areas identified in enclosure (3) is desired.
3. ACTION.
a. All OSCs shall conduct a review of their local pollution contingency plans, keeping in focus the areas
of emphasis previously identified. District(m) officers should oversee progress in plan review and should assist
with RRT coordination. Prior to 1 December 1989, the revised OSC local contingency plan shall be approved
by the District Commander. A copy of the plan shall be submitted to Commandant (G-MER-2), who will
act as a central repository of approved plans. Individual agencies of the RRT should be actively involved in
this review and revision process. In addition, the RRTs should conduct a final review of the local contingency
plans prior to approval by the District Commander. Their comments should be provided to the respective
OSC if further revision is necessary. RRT comments regarding shortfalls (such as dispersant or burning in-
situ policy) within RRT purview may be provided to the District Commander to assist with his review and
approval of the plan.
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Page 5 of 5
Subj: REVIEW OF LOCAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY
PLANS
b. Prior to 1 November 1989, all OSCs shall submit to Commandant (G-MER), via the normal chain
of command, a preliminary letter report identifying all shortfalls in equipment and personnel encountered in
this planning process. The format for this report is in enclosure (5).
c. The oil spill response procedures and associated equipment for all marine oil transfer facilities (in
Operations Manual) and the offshore industiy (coordinate with Minerals Management Services) shall also be
reviewed and revised and referenced in the local contingency plan.
d. Answers to the questions posed in enclosure (3) and any other additional comments and
recommendations may be submitted to Commandant (G-MER) along with the list of shortfalls described in
3.b. above.
e. All pre-planning does not necessarily end with the On-Scene Coordination (OSC). District offices
should plan for this type of response. Appropriate support teams and their functions, as well as the potential
temporary assignment of necessary assets, should be assessed.
f. Commandant (G-MER) is currently reviewing some of the "lessons learned" in the EXXON VALDEZ
spill. Appropriate supplemental information will be sent to the field or included as future amendments to the
Marine Safety Manual.
g. Questions regarding this endeavor should be forwarded to CDR Lentsch or LCDR Hollingsworth
at (FTS) 267-0440, or 267-2612 respectively.
MO. SCHIRO
Actjng Chief, Office of Marine Safety,
Security and Environmental Protection
Planning Reference Material (2 copies)
Criteria for Reviewing a Local Contingency Plan
OSC Contingency Planning Feedback
Criteria for Shortfalls
Format for Shortfall Report
ITOPF Technical Information Paper "Contingency Planning For Oil Spills"
Technical Guidance for Hazards Analysis, Emergency Planning for Extremely Hazardous Substances
End:
1)
2)
3)
4)
5)
6)
7)
Dist All MSOs
All Captain of the Ports
All District (m) Offices
All District Commanders
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LIST OF REFERENCES
National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR Part 300)
Marine Safety Manual (M16000.ll), Vol. VI. Chapter 6
Hazardous Materials Emergency Planning Guide (NRT-1)
Criteria for Review of Hazardous Materials Emergency Plans (NRT-1A)
ITOPF Technical Information Paper "Contingency Planning for Oil Spills"
Technical Guidance for Hazards Analysis, Emergency Planning for Extremely Hazardous Substances
Appendices-44
ENCLOSURE (1)
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Page 1 of 2
CRITERIA FOR REVIEWING A LOCAL CONTINGENCY PLAN
Each OSC will develop and maintain a Federal contingency plan for response in his or her area of responsibility. The
plan should provide for a well-coordinated response and should meet the following criteria:
1. Plans should be compatible with all state, local and other emergency plans within the OSCs zone.
Have you reviewed all Federal, state and local plans to ensure that there is no conflict within the respective
response organizations? Is industry aware of the Federal response mechanism and are you aware of the industry
response organization and responsibilities? What liaisons do you maintain with other state and local response
emergency organizations? Have these organizations been consulted? Has the state representative to the RRT
been consulted in this review process? If a state has numerous agendes involved in spill response, their concerns
should be channeled through the governor's designated representative.
2. Take the following steps to assess the probable locations and sizes of discharges or releases:
a. Define the "maximum potential spill" and the "maximum realistic spill" for your area as per paragraphs 2.b(l)
and (2) of the forwarding letter.
b. Conduct a hazards analysis. (Include any new potential for increasing or decreasing amounts of traffic.)
c. Assess the vulnerability of your zone with respect to environmentally sensitive areas, threatened or endangered
species, loss of shipping lanes, recreational areas, water intakes, etc.
d. Develop a risk analysis based on your identification of hazards in the zone (a. above) and the vulnerability
of the various areas (b. above).
Excellent guidance for this process can be found in Chapter 3 of NRT-1, NRT-1 A, Technical Guidance for Hazards
Analysis, and in Chapter 6 of the Volume VI of the Marine Safety Manual (MSM).
Does your risk analysis include a thorough and recent hazards assessment and vulnerability analysis? Does it
include input from all appropriate Federal, state, local, industry, and public sources of information? Is each step
a separate yet intertwined process?
3. Does your Local Contingency Plan (LCP) adequately address specific criteria for notification and possible activation
of the RRT/NRT?
4. Institute prompt and effective actions to restrict the spread of pollutants, by mechanical means.
What is the response time for deploying booms and skimmers to respond to the three scenarios addressed in
paragraph 2i. of the forwarding letter? Are your response times adequate? What are the response times for
MSO/COTP personnel and cleanup contractors? Is that adequate? What are your shortfalls? Is the amount of
response equipment available in your port area adequate to handle those spills outlined in letter? What are the
shortfalls? Keep in mind that not all equipment works well, or to the same efficiency, in every environment (i.e.,
booms in fast moving rivers vs. protected waters).
5. Institute an effective dispersant use plan.
Is there an adequate amount of dispersant and equipment on hand or readily available to handle a spill outlined
in the letter? What type of pre-planning does your region maintain? Are personnel available that are trained in
dispersant application? What is the state's position on the use of dispersants? If no dispersant use plan or pre-
plan is in effect, task the RRT to develop one.
ENCLOSURE (2)
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Page 2 of 2
6. In the event of a major spill, ensure that the public health and welfare are adequately protected.
Has the Agency for Toxic Substances and Disease Registry (ATSDR) as well as your Occupational Safety and
Health (OSHA) representative been consulted? What procedures are in effect to coordinate with local hospitals
and Emergency Medical System (EMS) personnel?
7. Minimize damage to wildlife and the environment from oil and hazardous substance incidents.
Have local environmental concerns been incorporated into the LCP? Have all environmentally sensitive areas been
addressed? Has the SSC been included in the planning?
8. Identify government, commercial, and industry resources and equipment capable of responding to pollution
incidents and providing expertise to the OSC in specific areas. Also, identify where they are located and how they
may be obtained.
How can you utilize the RRT in this process? Is there enough response equipment within the port area to cover
a major spill of national significance? What are the shortfalls? What are the procedures and what is the response
time for accessing this equipment? Are the response times adequate? Have all U.S. Coast Guard resources been
addressed, such as AIREYE and NSF. Have the Navy's Supervisor of Salvage resources been considered?
9. Identify procedures for initiating actions for the recovery of cleanup costs and performance of enforcement actions
as necessary.
What are your procedures for acquiring 311 (k) and CERCLA funds? What are your contracting procedures for
Basic Ordering Agreement (BOA) and Non-BOA Contractors? What assistance can be anticipated from the
District and MLC? Are your cost documentation and recovery procedures adequate? This particular section is
being revised by the Commandant and new guidance on these procedures is forthcoming. For current cost recovery
actions, reference MSM and appropriate MLC guidance.
10. Provide techniques for removal and locations for the disposal of collected pollutants. Analyze and determine waste
disposal methods and facilities that are available, consistent with RCRA/state/local regulations.
Can the MLC contract for these services? Can this topic be tasked to and handled by the RRT? Have you
discussed proper disposal methods and facilities with your state RCRA representative, as well as the Environmental
Protection Agency (EPA) Regional Solid Waste (RCRA) representative? Have you identified a specific point of
contact to address the issue of waste disposal during a spill response.
11. Establish liaison with local news media and develop an effective public information system, which includes the office
public affairs person as well as PIAT and district public affairs personnel. The task of developing sound public
and community relations is incumbent on each unit. It is much better to have met and worked with necessary
public officials prior to a spill than to try to develop a working relationship during the spill. This area cannot be
overemphasized. District and MLC offices cannot do this for you.
How is your public affairs system handled in the event of a major oil spill, prior to support arriving from PIAT
or district public affairs? What contingencies do you have if the district and area are not able to provide support?
The public affairs system needs to be proactive. Is the spill scenario likely to raise Congressional interest? If yes,
have you considered an organizational position for a congressional liaison officer?
12. Does your LCP planning process include developing various scenarios covering reasonable spills within your zone,
including exercising of the LCP and developing detailed action plans for each scenario? How are your exercises
being conducted? Are they conducted once a year? To what extent?
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OSC CONTINGENCY PLANNING FEEDBACK
1. What personnel resources would be needed to conduct continuous plan review?
2. Are those resources currently available?
3. Are your currently assigned marine environmental response personnel considered sufficiently qualified to conduct
such a review?
4. What is the ideal grade level for contingency planners and interagency liaison/coordination personnel? Does your
current billet structure and workload permit this level of assignment?
5. What other resources besides Coast Guard personnel are needed to conduct on-going contingency planning?
6. What obstacles did you have to overcome to produce an effective and workable contingency plan?
7. Is your current level of liaison with response agencies and the marine community adequate? What restraints
prevent you from improving that level?
8. Are you actively involved in city, county, industry or Local Emergency Planning Committee (LEPC) planning
initiatives for spill response?
9. What legislative actions could improve your current authority and/or capabilities?
ENCLOSURE (3)
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Page 1 of 3
GUIDELINES FOR DETERMINING RESPONSE RESOURCE NEEDS AND SHORTFALLS
1. Aside from reevaluating contingency plans, the adequacy of available response equipment must be determined.
It should be understood that the guidelines presented below for identifying equipment shortfalls are planning
criteria for desired response capability, and not mission performance standards. The diversity of possible spill
scenarios makes it necessary for each OSC to determine response strategies and evaluate the adequacy of response
equipment available from all sources.
2. Response time is one of the most critical constraints over which some degree of control can be exercised. For this
reason cleanup performance criteria are highly time dependent. Quicker responses result in less wide-spread
impacts and less extensive total cleanup efforts. No matter how rapid the response, adverse environmental impacts
cannot be totally avoided because they begin the moment oil enters the marine environment. Each OSC must
determine what constitutes an adequate cleanup considering the guidance in Volume VI, Chapter 7 of the Marine
Safety Manual.
3. Identifying worst-case spill scenarios is the critical first step in determining response equipment needs. The area
of interest centers on those spills which pose the most difficult cleanup problems. A worst-case scenario should
be based on a reasonably likely event which could result in a massive discharge. Then all sensitive or critical
resources which could be impacted should be identified. Petroleum behavior in the marine environment and
biomass concentrations make it likely that in most cases the worst-case scenario will involve persistent oils (heavy
product or crude) discharged in an area where near-shore impacts will result. Members of the Regional Response
Teams (RRT) and Local Response Team (LRT) should be consulted in developing worst-case scenarios, identifying
sensitive areas, and assessing resource needs and shortfalls.
4. The purpose here is to provide guidelines and a common basis for all Coast Guard OSCs to work from in
determining resource needs and evaluating shortfalls. It is recognized that some areas may have unique
characteristics which must be considered. This could include problems with access to spills in remote geographic
areas. If you feel your zone has unique conditions which necessitate divergence from the parameters presented
herein, then fully explain the situation and resultant information provided. Notwithstanding unique conditions, a
systematic methodology for identifying response equipment needs and shortfalls follows:
a. Determine the worst-case scenarios which could result in the most difficult cleanup effort. Considerations in
identifying these scenarios include:
(1) A reasonably possible event given the nature of marine activity in the port area.
(2) Critical resources which could be impacted.
(3) Geographical extent of the spill impact.
(4) Length of time to complete deanup.
(5) Cost of the cleanup.
(6) Technical difficulty of the cleanup.
b. Identify the sensitive resources which must be protected. This could include actual sensitivities, political
sensitivities, or publicly perceived sensitivities. (RRT and LRT should be consulted.) Specific areas to be
considered include:
(1) Public health-related resources.
(2) Community or municipal resources.
(3) Sensitive environments, or endangered or threatened species.
(4) Commercial resources or species.
(5) Recreational resources.
ENCLOSURE (4)
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Page 2 of 3
Develop a response strategy keeping in mind the resources which must be protected and the response time
criteria given below. The strategy must include a detailed list of the equipment and personnel needed, and
the time frame in which they are required. The response strategy should consider local conditions such as
dispersant use policies, and the type of equipment available, but it should not be dictated by current equipment
availability (LRT and RRT should be consulted). Reference material on skimmer recovery rates (50%
efficiency rate recommended for use) and shoreline cleanup labor requirements are attached. This material
is intended to be a helpful guide only. You are cautioned that the published capabilities for response
equipment are frequently potentials for ideal conditions. Actual expected performance could be significantly
less. Skimmers for example usually operate at less than h their ideal potential. The optimum response
strategy should accomplish the performance objectives listed below in the time frame specified.
(1) Initial response to the scene, investigation and evaluation should be accomplished for any spill within 2-
3 hours of notification, depending on the location of the spill. This includes getting a qualified team of
appropriate level personnel on scene (personnel from the MSO, Group, SAR, Reserve, Auxiliary, etc.),
assessment of the situation, notification of needed response resources (NSF, commercial contractors), and
of LRT and RRT as appropriate.
(2) The type and amount of equipment needed to respond to major spills differs from that needed for average
size spills. For this reason the response time objectives for worst-case spills are somewhat longer than
for average spills. Logistics problems must also be considered, and will generally be greater for major
spills, and for spills in remote or difficult to access areas. In some instances geographic location may
introduce more variation in response time than volume. If that is so, then explain the situation in your
planning and analysis documents. Initial containment/recovery for worst-case scenarios should commence
within 6 hours of the report. For average spills or less this should be within 3 hours. Preliminary
assessment of the threats to resources and potential for additional problems should be completed.
Deployment of containment and recovery equipment to restrict the spread of the spill and protect sensitive
or critical resources should have begun. Mobilization of other needed response and organizational
resources (including LRT and RRT) should be in progress. Note that any open water containment
equipment is usually only effective in conditions up to 4 to 5 foot seas.
(3) The protection of critical or sensitive resources is a very important primary consideration during any spill
incident. In a worst spill scenario, the protection of all critical or sensitive resources within 18 hours
seems reasonable. For average spills an objective of 6 hours appears appropriate. These times, of course,
are dependent upon the extent of the oil spill and the amount of sensitive areas. In most cases, the
sensitive areas need to be prioritized.
(4) A fully operational cleanup effort should be mounted within 48 hours for worst-case spills. The command
structure and response organization should be established and fully functional. Communications networks
and systems should be established, and dispersant use should have been considered and decided upon by
the RRT. Booming to restrict the spread of the oil and protect critical or sensitive resources should be
completed. Isolation of pockets for recovery should be underway, and multiple skimmers (as required
by the scenario and response strategy) should be fully operational. This does not, however, mean that
every piece of equipment which may be ultimately needed is on scene. For average spills these actions
should be accomplished within 12 hours.
(5) If the scenario involves a vessel, lightering equipment should be on scene and ready to be put in operation
within 12 hours. This can often be a critical function in preventing further discharge and averting a
maritime disaster. Salvage or stabilization of the vessel is one of the most important aspects of a
successful response operation. It is imperative that a salvage master arrive on scene as soon as possible;
but no later than 12 hours. A salvage plan should then be completed shortly thereafter. The National
Strike Force can provide valuable resources to assist in this aspect of the response operation. The OSC
must be able to assess the situation, must be able to isolate and remove the threat of additional pollution,
and recognize and identify salvage expertise and/or independent vessel surveyors.
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Page 3 of 3
(6) Recoveiy of oil from the water's surface is usually much less labor-intensive and time-consuming than
shoreline cleanup. Every effort should be made to effect recovery from the water's surface and minimize
shoreline impact. In worst-case spills cleanup duration goals may be based on an objective of
recovering/skimming 50,000 gallons per day from the water. The cleanup of average size spills should
be completed within 2 weeks.
(7) Response resources within the COTP/MSO zone should be adequate to deal with spills of up to 50,000
gallons. The plan should incorporate the idea of using reserve and national guard resources.
After determining a spill response strategy and equipment needs using the above guidelines, available response
resources must be carefully itemized. These resources include both equipment and trained personnel from
all response entities (commercial contractors, marine and petroleum industry, Coast Guard, and other
government agencies). Response resources available from the local area and from extended areas should also
be considered.
The final step is to develop an itemized list of response resource shortfalls. This includes equipment and
trained personnel. In determining shortfalls, the resources needed to implement your optimum response
strategy and meet the response performance objectives defined in paragraph c. should be compared to the
available resources identified under paragraph d. Equipment resources should be identified by generic
categories in lieu of brand names or models.
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FORMAT FOR RESPONSE REGARDING SHORTFALLS
1. Assumptions, worst-case scenario and response strategy should be outlined in sufficient detail to allow assessment
of the process that was used to review your contingency plan.
2. List of shortfalls (include personnel, equipment, information, policy or procedures, etc.).
3. Recommendations regarding potential solutions for the shortfalls must be realistic.
4. Information of the type outlined in Enclosure 3.
iAppendices-51
ENCLOSURE (5)
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o^t0S\
£ to
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OF MCE OF
SOLID WASTf AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Nationwide Review of I
Coordinators,
FROM:
imothy
lothy Fields, Jr., DireCtftr/
lergency Response DivRiJn
7°
TO:
Jim Makris, Director \r/ / Is' '—
Chemical Emergency Preparedness and Prevention (CEPP) Office
Oil and Hazardous Materials' Coordinators, Regions I-X CEPP Coordinators, Regions I-X
As you are aware, the President directed that a nationwide review of oil spill contingency planning
be conducted by the National Response Team (NRT). The U.S. Coast Guard is the overall lead agency
for this very important assignment and is responsible for assessing oil spill preparedness in the coastal
zones. EPA's Oil and Hazardous Materials Coordinators, with assistance from the CEPP Coordinators,
will lead the assessment of oil spill preparedness in inland areas. The Regional Response Teams (RRTs)
have been tasked with coordinating input from all participating Federal agencies in each Region.
The purpose of this memo is to advise you of the information that each EPA Regional office is being
requested to submit to its RRT. Attached is the workplan for the analysis of oil spill preparedness in
inland areas. It very closely parallels the guidance developed by the U.S. Coast Guard for assessing oil
spill preparedness in coastal areas.
The RRTs have been given a deadline of November 3,1989 for providing the NRT with a summary
report on oil spill preparedness in their Regions. Therefore, we are requesting that you provide the
information outlined in the workplan to the RRT by October 6, 1989. This will allow the RRT enough
time to meet their deadline.
Thank you in advance for the work this will require. If you have any questions, please contact John
Cunningham (Emergency Response Division) at FTS 382-4130 or Martha Colvin (CEPP Office) at FTS
382-4514.
Attachment
cc: EPA RRT Co-Chairs
Printed on Recycled Paper
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Page 1 of 4
WORKMAN FOR
ANALYSIS OF PREPAREDNESS FOR RESPONDING TO
INLAND OIL SPILLS
1. Purpose of this Work
As a follow-up to the thirty-day Report to the President on the Exxon Valdez Oil Spill, the President
has requested the National Response Team to prepare a report assessing preparedness to respond to
oil spills nationwide. This effort will focus on preparedness to respond to both coastal and inland oil
spills. The U.S. Coast Guard will have lead responsibility for the assessment of coastal planning, and the
U.S. Environmental Protection Agency (EPA) will lead the study of inland planning. Inland areas are
those for which EPA provides an On-Scene Coordinator (OSC).
The purpose of this effort is a constructive assessment of the current state of preparedness to respond
to inland oil spills. Most Regional Contingency Plans (RCPs) were written during a time in which
preparedness for responding to major oil spills did not have a high priority. Both the priority and the
standards for reviewing oil spill contingency plans have been raised by the Exxon Valdez incident.
Therefore, the objective of this effort is to provide the input for determining what needs to be done to
conform to those standards, not to be critical if they are not yet achieved.
As part of this effort, OHM coordinators with assistance from the CEPP coordinators in each Region,
are being asked to take the lead in gathering information about inland oil spill contingency plans for their
Region as well as information about related contingency plans undertaken by non-Federal entities or the
private sector. The focus of this study will be on spills of petroleum-based oil. In a separate
memorandum from the Chair and Vice Chair of the National Response Team (NRT), the Regional
Response Teams (RRTs) are being asked to coordinate for their Regions the analyses of preparedness
to respond to oil spills in both coastal and inland waters. OHM and CEPP coordinators should, therefore,
provide their input to the RRTs concerning preparedness for response in inland areas.
For convenience, this information gathering process has been broken down into five tasks listed
below. Each task focuses on a particular aspect of oil spill contingency planning, preparation, and
response.
2. Background
The National Contingency Plan (40 CFR Part 300) requires RRTs, working with the States, to
develop Regional Contingency Plans (RCPs) to coordinate timely, effective response by Federal agencies
and other organizations to discharges of oil or releases of hazardous substances, pollutants, or
contaminants. RCPs should, as appropriate, include information on all useful facilities and resources in
the Region from government, commercial, academic, and other sources. In addition, for inland areas,
the OSC, in consultation with the RRT, may develop a contingency plan for the OSCs area of
responsibility. An OSC Contingency Plan should provide for a well coordinated response that is integrated
and compatible with all appropriate response plans of State, local, and other non-Federal entities,
especially with emergency response plans under Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA). Such a plan should, as appropriate, identify: the probable location
of discharges and releases; the available resources to respond to multi-media incidents; where such
resources can be obtained; waste disposal methods and facilities; and a local structure for responding to
discharges or releases.
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Page 2 of 4
3. Tasks
Task 1: Current Contingency Planning
Each Region should analyze its currently applicable oil spill contingency plans and any related
information that explains their development and use, such as the schedule for reviewing, exercising, and
modifying the plan. From these plans, each Region should prepare a summary of the key provisions of
the response plan as related to inland spill response. Key provisions might include:
Maximum spill response scenario assumptions
Equipment and personnel available
Response times to various areas of the Region
States, localities, and the private sector may also develop contingency plans for responding to releases
of oil or hazardous substances beyond the emergency response planning required under SARA Title III.
To the extent such plans are relevant to the Federal government's response or relied upon for response
preparedness, information should be provided on related contingency plans developed by other entities
and the extent of coordination among these plans and the RCP.
The analysis should identify any high risk areas or activities for which oil spill contingency plans
should be developed or required but have not yet been prepared.
The intent of SARA Title III is to provide a planning structure which enhances State and local
community capability in preparing for and responding to hazardous materials incidents. Because Sections
311 and 312 of Title III do cover petroleum products and because the information submitted under these
sections is to be a primary consideration in developing local response plans, some of these plans might
specifically address oil. Also, the NRT's Hazardous Materials Emergency Planning Guide (NRT-1)
emphasizes the comprehensive nature of the Title III planning process for all hazardous materials
(including petroleum products). Therefore, we ask that the CEPP coordinators contact appropriate State
Emergency Response Commissions to identify local Title III plans that address oil spills. At this time,
we are unsure that any Local Emergency Planning Committees have included such provisions in their plan.
Finally, the OHM and CEPP coordinators should provide copies of applicable oil spill response plans
to the RRT to insure that in conducting its analyses, the RRT has available all applicable contingency
plans relating to inland oil spill response.
Task 2: Summary of Recent Experiences
To further define the nature of the problem and assess the need for additional equipment and other
resources, a baseline of actual experience is needed. This baseline of case histories will provide a basis
for assessing existing planning, preparation, and response efforts against both past oil spills and potential
future ones. Such information would provide the basis for evaluating the types and amount of equipment
and personnel that would be needed to respond to the normal types of oil spills that the Federal
government and responsible parties routinely respond to and the less frequent catastrophic spills.
To provide this basis for analysis, each Region should provide summary information on the
characteristics of known inland oil spills (including those from pipelines and transportation-related
facilities) that have occurred over the past two years. To the extent that reasonably accessible information
is available, information concerning spills that have occurred over the past ten years should be considered
in the analysis. The information provided should include, as available, the size, timing, duration, and cause
of each spill as well as the petroleum product involved, the equipment and other resources used to
respond to the spill and the environmental effects. In addition, aggregate and average figures should be
provided for those categories for which such data are relevant. Of particular concern and interest are
spills that represent an "average" or representative event and a largest" event. In identifying "average"
and "largest" cases, the basis for this characterization (e.g., largest in size, most destructive in
environmental impact, highest cleanup cost) should be defined explicitly.
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Page 3 of 4
Task 3: Potential Future Oil Spills
Because the past is not necessarily a good predictor of the future, each Region is requested to provide
available information on potential future oil spills. Obviously, in the short time available to conduct this
analysis, it will not be possible to generate new information concerning the potential sources of spills.
However, as a part of the analysis, OHM Coordinators should identify information that should be
collected to form the basis of improving current oil spill contingency plans. Such information might
include needs for improved information concerning sources of potential major oil spills. Specifically, the
analysis should identify important trends in oil spills in that Region, or larger trends (e.g., increased vessel
traffic) that potentially may affect the number, type, and severity of future oil spills. In addition, based
on such information, each Region should develop a credible worst-case scenario inland oil spill and
describe its principal features.
In developing this credible worst-case scenario, consideration should be given to the major potential
sources (including pipelines), the kinds of spill incidents that can occur from different facilities and vessels,
the quantity and kind of petroleum that can be released, and the combination of geographic,
meteorological, and environmental factors that can exacerbate an oil spill incident.
Task 4: Response Capability
To assess the existing capacity for timely response to oil spills, each Region is requested to provide
information on the ability of the Region's response capability to respond to an "average" release as defined
in Task 2. Specifically, the analysis should provide information regarding:
The amount of time it would take to respond to key inland areas in the Region;
Any limiting factors that inhibit the response effort;
The types of equipment that are available through:
USCG Strike Teams
Contract Support (ERCS, BOAs, etc.), including the levels of equipment that contractors
are required to maintain and other equipment
Other sources
The performance of the equipment (i.e., equipment for spills in quiet bodies such as lakes vs.
faster moving streams or rivers);
Whether the resources are commensurate with the size and severity of the spill;
Skilled response personnel; and
Shortfalls that can be identified in available equipment and other resources.
Similar information is requested for the "largest" spill described in Task 2 and the worst-case scenario
developed in Task 3.
To allow a more general understanding of the current level of response capability, information should
be provided on the existence of specific inventories of equipment and on the geographic location of
equipment and materials. Types of equipment that may merit mention include booms, skimmers,
dispersants, and disposal facilities. After a review of existing contracts for oil spill response, the analysis
should also address experience requirements for contractor personnel and the type and size of the largest
spill for which the contractor must be prepared.
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Page 4 of 4
Task 5: Summary of Oil Spill Prevention Activities
Because the first line of being prepared for oil spill response is insuring that oil spills are prevented
whenever possible, information concerning oil spill prevention activities should also be a part of the report.
Therefore, OHM coordinators should provide through the RRTs available information concerning the
Spill Prevention, Control and Countermeasures (SPCC) program. Such information should include a
summary of inspections conducted during the past year, trends in compliance and, where available,
discussions of instances in which serious spills may have been averted by good spill prevention practices.
4. Deliverables
Task 1: Current Contingency Plans
Currently applicable oil spill contingency plans
Information on contingency plans that have been developed for areas of special concern
Information on related contingency plans by other government and private sector entities and
the extent of coordination among these plans
List of areas of high risk for which special contingency plans should be developed or required
but are not currently in place
Information on SARA Title III plans addressing oil spills
Task 2: Summary of Recent Experiences
Summary data on characteristics of past oil spills
Notation of an "average" oil spill from recent experience within Region and the basis for selection
Notation of the "largest" oil spill from recent experience within Region and the basis for selection
Task 3: Potential Future Oil Spills
Summary of trends that may affect the size, type, and characteristics of potential future oil spills
Priorities for information that should be collected to form the basis for revising current oil spill
contingency plans
Worst-case scenario oil spill and important underlying assumptions
Task 4: Response Capability
Assessment of existing resources (equipment and personnel) to respond to the "average" and
"largest" case oil spills defined in Task 2 and the worst-case scenario conceived in Task 3
Task 5: Summary of Oil Spill Prevention Activities
Summary of SPCC activities, including inspections and trends
Summary description of serious events that have been prevented or mitigated by good prevention
practices
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APPENDIX F
Acronym Glossary
BBLS: Barrels
BOA: Basic Ordering Agreement
CERCLA: Comprehensive Environmental Response,
Compensation, and Liability Act
CG: U.S. Coast Guard
COTP: Captain of the Port
CWA: Clean Water Act
DOD: Department of Defense
DOI: Department of Interior
DOMS: Director of Military Support
EPA: Environmental Protection Agency
ERT: Environmental Response Team
FOSC: Federal On-Scene Coordinator
ISCP: Installation Spill Contingency Plan
JRT: Joint Response Team
JTF: Joint Task Force
LCP: Local Contingency Plan
LEPC: Local Emergency Planning Committee
MARAD: United States Maritime Administration
MMS: Minerals Management Service
MOU: Memorandum of Understanding
MSO: Marine Safety Office
M/V: Motor Vessel
NCP:
NOAA:
NOSC:
NRC:
NRS:
NRT:
OCS:
OJT:
OSC:
RCP:
RCRA:
RRT:
SAR:
SARA:
SERC:
SPCC:
SSC:
TAPS:
USCG:
National Contingency Plan
National Oceanographic and Atmospheric
Administration
Naval On-Scene Coordinator
National Response Center
National Response System
National Response Team
Outer Continental Shelf
On-the-Job Training
On-Scene Coordinator
Regional Contingency Plan
Resource Conservation &nd Recovery Act
Regional Response Team
Search and Rescue
Superfund Amendments and
Reauthorization Act
State Emergency Response Commission
Spill Prevention Control and
Countermeasure
Scientific Support Coordinator
Trans Alaskan Pipeline System
U.S. Coast Guard
Appendices-57
*U.S. GOVERNMENT PRINTING OFFICE:
1990—725-
762/09452
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