Download - Heather Parker D13 DRAT - Seattle, WA Wrecks of the World II 07JUN11 source: Kip Evans Photography
Heather ParkerD13 DRAT - Seattle, WAWrecks of the World II07JUN11
source: Kip Evans Photography
Systems Approach to Addressing Wrecks and Derelicts under FWPCA/OPA Framework
Defining the Problem – Complexity What are Wrecks and Derelict Vessels? Who’s in Charge? Who Pays? When Should/Must Action Be Taken?
Challenges: Costs, Personnel Issues, Prioritization
Bounding the Problem: Area Committees Stakeholder Involvement and Expectations
Phased Approach – Through Area Committees1. AWARENESS PHASE – Inventory your Area2. RANKING PHASE – Prioritize (G-A-R)3. ACTION PHASE
INITIAL ASSESSMENT – DECISION TRIGGERS REMOVAL OPERATIONS – UNIFIED COMMAND
4. REVIEW AND REVISE
NRT GUIDANCE2
This approach, under authorities of CWA, as amended by OPA90, are under the direction of the Federal On-Scene Coordinator (FOSC).
CAVEAT: FOSC Involvement will end when threat of oil pollution ends.
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source: CA DFG
source : www.ussmississinewa.com
WRECK (for this discussion) is a vessel: SUNKEN BEACHED BURIED
DERELICT (for this discussion) is a vessel: FLOATING MOORED ANCHORED BEACHED PARTIALLY SUNK Usually more accessible
4Source: Greg Buie, NPFC
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Vessel Type Wreck (sunken, beached, buried) Derelict (floating, moored, anchored, beached, partially sunk
Threat Actively leaking oil
Substantial Threat of a Discharge of oil
Concern for eventual discharge
No concern (e.g. no oil on-board)
Location Offshore Nearshore Inshore River/Lake/Upland
Depth Deep Shallow Afloat Intertidal
Vessel Size Large (greater than 200’ LOA) Small (less than 200’ LOA)
Source: Greg Buie, NPFC
M/V M/V KALAKALAKALAKALA
ALERT
LST -1166
LCI -713
RIVER QUEEN
EL CONQUISTADOR
JEAN
SASANOA
DAVY CROCKETT
MANZANILLO
BRETT SCOTT BARGE
FOSC Decision and Authority to REMOVE OIL from Wrecks and Derelicts Within the bounds of the NCP, however is somewhere
between Prevention and Emergency Response
Must be polluting or pose a threat of pollution to use OSLTF/CERCLA “SUBSTANTIAL THREAT OF DISCHARGE”
OSLTF funds used primarily for oil removal, NOT salvage. Under FWPCA, as amended by OPA90, FOSC is authorized
response and removal action authority Salvage/removal only if best method to mitigate pollution
threat.
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10source : www.ussmississinewa.com
In most cases, there are a limited number of options:1. Defuel/ DeCargo the
Wreck or Derelict2. Seal/Encapsulate and
Monitor3. Vessel Destruction,
Removal, Dumping Some cases may
involve a combination, but often the preferred option will be Defueling or Wreck Oil Removal.
11source : www.ussmississinewa.com
FOSCs will make ultimate decisions, but will want/need input from their Area Committees.
Through a TRANSPARENT, COMPREHENSIVE, DEFENSIBLE Process Preferably Consensus-
Based12
source : www.ussmississinewa.com
COSTS - Oil Removal Ops from sunken or derelict vessels can cost MILLIONS of dollars
PERSONNEL BURDEN - Oil Removal Ops from sunken or derelict vessels can take MONTHS – heavy burden on Sector personnel and other agencies to sustain the response
PRIORITIZATION – How choose which one(s) to work on first? When is the right time to start threat assessment or removal ? What are the triggers?
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GAP: ESTABLISHED NATIONAL GUIDANCE ON FUNDING RESPONSE PLANNING, AND CONTRACTING PROCESSES
Adapted from: LTJG Chris Kimrey, IOSC 2011 Presentation
Defueling a Wreck is a very technically focused operation
Differs significantly from a “classic” spill response to an accidental release Where we keep responding to yesterday’s bad
news Oil Mitigation Operations on a wreck or
derelict is a Prophylactic Response Typically don’t have many “classic” spill
response actions/operations Shoreline Assessment and Cleanup, Oiled Wildlife
Recovery, etc15
Stakeholder involvement during a defueling or oil mitigation operation may look and feel different from a more “traditional” oil spill response May not have as robust staffing throughout
all the units
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1. AWARENESS PHASE – Inventory your Area2. RANKING PHASE – Prioritize (G-A-R)3. ACTION PHASE
INITIAL ASSESSMENT – DECISION TRIGGERS REMOVAL OPERATIONS – UNIFIED COMMAND
Adjust Operations as necessary, utilizing deliberate contingency planning
Public/Political Messaging – early, aggressive, often
4. REVIEW/REVISE PHASE – Comprehensive review of removal op, capture lessons learned, revise protocols/triggers/rankings/ACP as necessary
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18 Incorporate into Annual Area Contingency Plan Updates
Area Committees need to work together to help determine a COMPREHENSIVE INVENTORY of the wrecks and derelict vessels in their Area.
This is required under OPA90 for Area Contingency Plans Title IV, section 4202, amended subsection 311(j) of the
Federal Water Pollution Control Act with respect to the National Planning and Response System.
Defines Area Committees and Area Contingency Plans, and requirements.
COMMANDANT INSTRUCTION 16471.3 (2000) AREA CONTINGENCY PLAN ORGANIZATION, CONTENT,
REVISION CYCLE, AND DISTRIBUTION 94XX - Risk Assessment 94XX - Planning Assumptions - Background Information 94XX - Planning Scenarios 19
Area Committees need to work together to help PRIORITIZE INVENTORY of the wrecks and derelict vessels in their Area.
Area Committees must also help determine a set of TRIGGERS FOR ACTION or KEY DRIVERS to aid the FOSC to make a decision to act on a wreck or derelict.
These prioritizations should take into account RESOURCES AT RISK, as well as the VESSEL CONDITION, among other factors.
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Two primary phases:1. INITIAL ASSESSMENT – DECISION TRIGGERS
We’ve been triggered to conduct a threat assessment (by drivers/recommendations from Area Committee)
FOSC likely establish limited Unified Command Set Objectives, Priorities and Endpoints for the Assessment
Typically includes ROV and/or diver surveys, etc. Might also include real time natural/cultural resource
assessment
2. REMOVAL OPERATIONS – UNIFIED COMMAND1. This is active removal and includes establishing a full UC,
daily planning cycles, IAPs, etc.2. FOSC/UC may want to consider several options for
management of these longer-term removal cases: SECTOR run/managed Hiring private SMT and Salvors NST/Strike Team managed Combination
ALSO Consider:3. MONITOR ING PHASE
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After the completion of an Oil Removal Operation, review our progress
Capture Lessons Learned and ensure we are improving our process
Do we need to adjust our Priority Rankings or Triggers for Action for other Area Wrecks/Derelicts?
Area Contingency Plans – Include a section on Strategies for
Wreck/Derelicts Include FOSC Decision Memo examples:
Funding for Initial Threat Assessment Reaching Endpoints for an Oil Removal Operation Tie in to Annual Update Cycle
22BEST RESPONSE = Includes continual improvement
Area Committees are “programmed” to respond to accidental releases of oil Where we are responding to yesterday’s bad news. Plan for Average Most Probable Discharges, Worst Case
Discharges, etc. Challenge will be to adopt this traditional Area
Committee Response Planning Model to Pro-Active mode.
Bound the problem: must be very clear about goals/objectives for wreck oil removal Endpoints and Objectives of an Operation should be clear
and socialized Stakeholder Engagement and Effective Public and
Political Messaging is key.
23NATIONAL RESPONSE TEAM (NRT) GUIDANCE WILL BE KEY
Area Committees need to support FOSCs in making informed decisions. Permitting, Consultations for Sect 7 and Sect 106, EPA-
Ocean Dumping, etc NRT should develop overall consistent National
guidance to Area Committees to guide the development of: Awareness Ranking and Triggers for Action Action Review/Revise
Needs to be keyed to Area Contingency Plans And Annual Update Cycles Area Contingency Plans – need to capture these Wrecks
and Derelicts as a specific class of issue and include strategies, systems approach, etc.
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Wreck/Derelict Oil Removal, under the OPA90 Regime has specific limits and bounds Once the threat of pollution is gone, FOSC authorities
end Wreck/Derelict Oil Mitigation is “Prophylactic”
Still under NCP and Emergency Response, but not a “classic” response to large oil discharge event
FOSCs need support from Area Committees Develop TRANSPARENT, COMPREHENSIVE approach to
address these sources of potential pollution This will provide a defensible, repeatable process that will
continue on through the 2-3 year change over of Active Duty CG personnel, and help maintain consistency.
Oil Removal Ops – Heavy Personnel Burdens Can Sectors, Agencies sustain multi-month responses?
NRT – Needs to develop National Guidelines
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