Area Contingency Pla lan & Area Committee Goals ls USCG - - PowerPoint PPT Presentation

Area Contingency Pla lan & Area Committee Goals ls

USCG Sector Columbia River

Incident Management Division

National Contingency Plan

• 40CFR300.210 (c) (1) – Under the direction of an OSC and subject to approval

by the lead agency, each Area Committee, in consultation with the appropriate RRTs, Coast Guard DRGs, the NSFCC, SSCs, LEPCs, and SERCs, shall develop an ACP for its designated area.

• This plan, when implemented in conjunction with other provisions of the NCP,

shall be adequate to:

• remove a worst case discharge under §300.324, and
• to mitigate or prevent a substantial threat of such a discharge, from a vessel, offshore

facility, or onshore facility operating in or near the area.

Marine Environmental Response and Preparedness

• Area Committees prepare an ACP for their area, under the direction of the

FOSC and in consultation with the appropriate Regional Response Team (RRT), District Response Advisory Team (DRAT), National Strike Force (NSF) Strike Teams, Scientific Support Coordinators (SSCs), State Emergency Response Commissions (SERCs), and Local Emergency Planning Committees (LEPCs).

• The ACP shall be prepared as described in 40 C.F.R. § 300.210(c) and in

accordance with the format described in Appendix B of this Manual.

• Upon implementation of the ACP, it shall be adequate to:
• address response to a WCD, and to
• mitigate or prevent a substantial threat or release from a vessel, offshore facility, or
• nshore facility operating in the area.
• ACPs shall be approved by the District Commander and submitted to Commandant

(CG-MER) through the appropriate Coast Guard Area Commander.

Area Contingency Plan

• IAW 40 CFR 300.210 (c) (1) CG Headquarters (CG-MER) provided guidance
• n how each COTP/FOSC shall format their own Area Contingency Plan.
• The National Review Panel Checklist flows from 40 CFR 300.210 (c) (3).
• The NWACP is a regional policy document. The SCR ACP will be responder focused.
• The NWACP does not address WCDs scenarios in the plan, some local coordination

functions are missing amongst other items, and it doesn’t follow the MER checklist/required format.

Current Progress

• Included as much approved text from current NWACP as possible.
• Incorporated required missing information from approved/ ACPs

vetted through National Review Panel.

• Synchronized drafts with Sector Puget Sound.
• Promulgated draft for review comments.

Target Completion Dates

• Consolidate review comments – 2 Mar 2020
• Implement changes and complete final draft – 3 Apr 2020
• New SCR ACP signed – May 2020
• Submit to D13 for National Review Panel – 1 May 2021

Area Committee Meeting

• CY – 1st Quarter – Eastern AOR (Longview to Bonneville Dam)
• CY – 2nd Quarter – Southern Coast AOR (South of Tillamook to California Border)
• CY – 3rd Quarter – Northern Coast AOR Tillamook to Queets River)

Southern Coast AOR Northern Coast AOR Eastern AOR

Membership

De Deriv ived fr from

• m 40 CFR

CFR 300.205 (c (c)

• DHS
• USCG
• DOS
• DOD
• USACE
• DOJ
• DOI
• BIA
• BSEE
• NPS
• USFW
• USDA
• DOC
• NOAA
• NMFS
• DOL
• HHS
• DOT
• FRA
• PHMSA
• DOE
• EPA
• FEMA
• OSHA
• NRC
• Elected officials
• State and local

government representatives

• State and local

environmental agencies

• Emergency

Management Agencies

• State and local

police

• State and local fire

departments and associated marine units

• State Historical

Preservation Office

• Fish and wildlife

marine representatives

• Health agencies
• Local Emergency

Planning Committees

• Port Authorities
• River Commissions
• Tribal Governments
• Territorial

Governments

• Private Sector

Components

• Non-governmental

Organizations (NGOs) and Other Stakeholders

Federal State and Local Agencies Additional Members

Questions

Vessel Response Plans (V (VRPs)

Mandate fr from FWPCA

• Section 311(j) of the Federal Water Pollution Control Act (33 U.S.C.

1321, FWPCA) amended by section 4202 of OPA 90, requires the preparation and submission of response plans for all vessels defined as tank and non-tank vessels.

• These types of vessels, through their response plans, establish

preparedness measures and response protocols to mitigate the impact of oil discharges and hazardous substance releases within their area of operation.

Vessel Response Plans General Requirements

VRPs support the Coast Guard’s strategic goals of protecting natural resources and ensuring marine mobility. VRPs shall meet the following minimum requirements:

• Be consistent with the requirements of the NCP and applicable RCP and ACP;
• Identify the Qualified Individual (QI) having full authority to implement the removal actions and require

immediate communications between that individual and the appropriate federal official and the persons providing personnel and equipment;

• Identify and ensure, by contract or other approved means, the availability of private personnel and

equipment necessary to remove the maximum extent practicable a WCD, including a discharge resulting from a fire or explosion, and to mitigate or prevent a substantial threat of such a discharge;

• Describe the training, equipment testing, exercise requirements, and response actions of persons on the

vessel, proposed under the plan to ensure the safety of the vessel and to mitigate or prevent the discharge

• r substantial threat of a discharge per 33 C.F.R. § 155;
• Be periodically updated and/or resubmitted for approval of each significant change; and
• Be exercised fully to ensure the plan can effectively supply the appropriate level of response and

preparedness to which the plan applies.

Tank Vessels

CFR Cite: 33 CFR 155, Subpart D

• VRPs are required for all tank vessels that are constructed or adapted to carry oil in bulk

as cargo or cargo residue. Exception: vessels exempted in 33 C.F.R § 155.1015 and fishing/fish tender vessels of not more than 750 gross tons when engaged only in the fishing industry.

Non Non-Tank Vessels (N (NTVs)

CFR Cite: 33 CFR Subpart J

• Vessel owners and operators of self-propelled NTVs that are 400 gross tons and above

are required to prepare and submit response plans for vessels operating on the navigable waters of the Untied States.

Vessel Response Plan Activation

CFR Cite: 33 CFR 155

• VRPs provide clear guidance to vessel operators, QIs, and the Federal On-scene Coordinator (FOSC) regarding

the vessel’s pre-designated marine salvage companies and OSROs, and how these entities are to be activated during a response. VRPs ensure that qualified and effective professionals engage safely and efficiently.

U.S. Coast Guard Policy and Guidance:

• When the master of a vessel determines the resources and personnel available on board the vessel cannot

meet the needs of an actual or potential incident, the master follows the procedures approved in the VRP.

• The master must notify resource providers identified in the VRP and, as appropriate, activate when a

discharge of oil or substantial threat of such discharge of oil exists.

• FOSCs possess the regulatory authority to approve a deviation from an approved VRP under exceptional

circumstances and if the proposed alternative actions would clearly enable a more effective response.

• States have similar VRP content requirements and submittal agreements that commit to the execution of the

plan and ensure expenses are obligated to activate the VRP.

Scenario: : M M/V SEMPER P

Situation:

• An anonymous NRC report is made for:
• Unknown sheen from an unknown source
• On the Columbia River.
• Sheen described as rainbow in color, 30FT x

10FT, in the vicinity of the M/V SEMPER P.

What’s your role if/when the VRP is activated?

2020 Columbia River Operations Level Training

Purpose

• Develop and Facilitate Public/Private Partnership and

Shared Response Posture for the Columbia River Corridor

• Introduce new responders, planners and others interested

partners to the unique operational and logistical realities of the AOR.

• Share best practices, lessons learned and new challenges

in an open forum.

Example of Previous Agenda

September 26, 2018 2018 Columbia River Operations Level Training Agenda

0900-0930 Welcome to Clean River. Meet & Greet 0930-1000 Tour of Clean Rivers Operations Facility & Unique Assets 1000-1030 Clean Rivers Cooperative Program Overview- Casey Comer 1030-1100 MFSA Program Overview – Holly Robinson 1100-1130 OR DEQ Program Overview- Mike Greenburg/Scott Smith 1130-1200 WA DOE Program Overview- Sean Orr 1200-1230 Lunch Provided 1230-1300 DOI Program Overview – Allison O’Brien 1300-1330 USCG IMD Program Overview – CWO Shannon McGregor 1330-1430 Tactical Resource Availability, Acquisition and Tracking 1430-1500 Local GRP’s 1500-1530 Emerging Response Challenges & OSLTF use of Funds Insight 1530 Day Complete. Day 2 is Boom Rodeo. Note: All times are approximate.

LOWER Columbia River GRP’s

What is a GRP?

• “Prioritized tactical response strategy based on locations

where spills might occur and the proximity of those locations to natural, cultural, and economic resources at risk of injury.”

• Just a start to a response strategy.

WHO Determines a GRP?

• NWAC & RRT (USCG, US EPA, WA DOE, DOI, US F&W,

Tribes etc.)

• Take input from Industry, Activist Groups, Contractors
• r other concerned parties.
• Most recent update Oct. 2015 (current one in progress)

Emerging Response Challenges

Tactical Resources

Tactical response Resources

• Resources that are used to fulfill the operational tactics set-

forth by the response.

• For oil spills this includes vessels, boom, skimmers, liquid

storage, pumps etc.

• Knowledge and preparedness is crucial!

2019 Deployment

2018/2019 Participants

• US Coast Guard
• US Environmental Protection Agency
• US Dep. Of Interior
• OR Dep. Of Environmental Quality
• WA Dep. Of Ecology
• Clean Rivers Cooperative
• Marine Fire & Safety Association
• NRC Environmental Services

Questions? Casey Comer Clean Rivers Cooperative comer@pdxmex.com

Worst Case Dis ischarge Scenarios

USCG Sector Columbia River

Incident Management Division

Mandate fr from FWPCA

• Section 1321 (j)(4) of the Federal Water Pollution Control Act

(33 U.S.C. 1321) (FWPCA) mandates that Area Committees prepare ACPs that “[w]hen implemented with the National Contingency Plan (NCP), be adequate to remove a Worst Case Discharge (WCD), and to mitigate or prevent a substantial threat of such a discharge, from a vessel, offshore facility, or onshore facility operating in or near the area.”

Worst Case Discharge: Defi fined

• CFR Cite: 33 CFR 155.5020 / 33 CFR 154.1020
• Vessel: a discharge in adverse weather conditions of a

vessel's entire fuel or cargo oil, whichever is greater.

• Onshore or Offshore Facility: the largest foreseeable

discharge in adverse weather conditions.

• VRPs and FRPs are required to provide for a response to a WCD.
• The planning volumes are established in 33 CFR 154 & 155.

WCD Definitions: Facility

33 CFR 154.1029

(1) Where applicable, the loss of the entire capacity of all in-line and break out tank(s) needed for the continuous operation of the pipelines used for the purposes of handling or transporting oil, in bulk, to or from a vessel regardless of the presence of secondary containment; plus (2) The discharge from all piping carrying oil between the marine transfer manifold and the non-transportation-related portion of the facility. The discharge from each pipe is calculated as follows: The maximum time to discover the release from the pipe in hours, plus the maximum time to shut down flow from the pipe in hours (based on historic discharge data or the best estimate in the absence of historic discharge data for the facility) multiplied by the maximum flow rate expressed in barrels per hour (based on the maximum relief valve setting or maximum system pressure when relief valves are not provided) plus the total line drainage volume expressed in barrels for the pipe between the marine manifold and the non-transportation-related portion of the facility; and (3) For a mobile facility it means the loss of the entire contents of the container in which the oil is stored or transported.

Discussion Starters

(Se Sectio ions 9300 and 9440 of SC SCR ACP)

• What are the potential sources (e.g., facility, vessel, etc.) and

volumes for an oil spill?

• What local areas could be impacted?
• Which areas are the most important for protection?
• What strategies are available to mitigate economic &

environmental impacts?

• What equipment and capabilities are available to implement

these strategies?

• Future WCD scenarios will coordinate with GRPs/GRSs workgroup

US Coast Guard Recommended Guidance

• At a minimum, ACPs should include the WCD from:
• The largest tank vessel operating in the area of responsibility.
• The largest facility that poses the greatest risk to environmental or

economically important areas in or near the Sector AOR.

T/V AMERICAN FREEDOM

• U.S. Flag: Chemical/Oil Products Tanker
• Frequent flyer: Between Puget Sound & Portland
• Products:
• Ultra-Low Sulphur Fuel Oil (ULSFO)
• Vacuum Gas Oil (VGO)
• Diesel
• Capacity: 348,000 barrels (14,616,000 gallons)
• Vessel Particulars:
• 600ft long,
• 62ft beam,
• 29,801 G/T

• Oil Terminal: 9421 St Helens Road, Portland OR
• Modes Served: Ship, Barge, Pipeline, Truck
• Products/Materials:
• Medium Fuel Oil (MFO)
• Ethanol
• Gasolines
• Diesel, Biodiesel, Renewable Diesel
• Ethanol
• Lube Oil
• Capacity: 53,525,638 gallons (31 Tanks)
• Worst Case Discharge: 4,200,000 gallons

Past In Incidents

M/V GORGOYPIKOOS (6/2/2019)

Past In Incidents

M/V NENITA (11/19/2016)

Presentation to the Sector Columbia River Area Committee (SCRAC)

February 11, 2020 Portland, Oregon

Geographic Response Plans

Don Pettit | Oregon Department of Environmental Quality

The National Response System

GRPs

Northwest Area Contingency Plan

• The Northwest Area Contingency Plan (NWACP) is a planning tool that

provides for a safe, appropriate, and timely response to reports of oil

• r hazardous substance spills.
• The NWACP documents specific policies, identifies required

notifications, and provides tools and information to aid in undertaking an effective response to a spill of oil or hazardous materials.

NWACP

• Serves as the State of Oregon’s Hazardous

Materials Response Plan under the State’s Emergency Operations Plan

• Serves as both policy guiding response,

and tools to accomplish safe and effective response

• Updated annually

NWACP Organization

• Front Matter – Required Notifications/First Responder Guidelines
• Chapter 1000 Introduction/Authorities
• Chapter 2000 Command
• Chapter 3000 Operations
• Chapter 4000 Planning
• Chapter 5000 Logistics
• Chapter 6000 Finance/ Administration
• Chapter 9000 Response Tools
• 9202 JIC Manual
• 9210 Liaison Manual
• 9310 Northwest Wildlife Response Plan
• 9402 NWACP Permit Summary Table
• 9405 Disposal Guidelines
• And a lot more great response tools…27 sections in Ch 9000

State Emergency Management Plan

• Volume I – Natural Hazard Mitigation Plan
• Volume II – State Preparedness Plan
• Volume III – Emergency Operations Plan
• DEQ Responsible (with OSFM) for ESF 10 Hazardous Materials, DEQ Supports

numerous other ESFs

• Incident Annexes for 10 Disaster Types, Functional Annexes and Supporting

Plans for Cascadia, Debris Management, Wildfire (smoke), etc.

• Volume IV – State Recovery Plan

Other State Plans

Hazardous Materials Transportation by Rail Annex to ESF10 in the State Emergency Operations Plan DEQ shares the ESF10 with OSFM and helped develop the Coordination Plan

Snapshot of Oregon’s Risk to Spills

10 years of program data show…

• The predominant type of spill

involves oil products

• Chemical products next most

common type of spill

• Unknown or other 14%

Snapshot of Oregon’s Risk to Oil Spills

10 years of program data show…

• For oil spills, larger events do
• ccur along waterways most
• ften
• The more typical “large” event

can occur anywhere in the state

Snapshot of Oregon’s Risk to Oil Spills

For Railroad Spills

• Many larger events occur within

rail yards…

However

• Many larger events
• ccur outside of rail

yards as well

Geographic Response Plans

• Geographic Response Plans (GRPs) are site-specific plans for responding

to oil spills, tailored to a specific beach, shore, or waterway and are developed to minimize impact on sensitive areas threatened by the spill.

• Sensitive areas can be natural, cultural or socio-economic resources.

They can be a combination of these as well.

• GRPs contain described strategies, which become the initial “marching
• rders” for responders in the early hours of a response.

Geographic Response Plans

How to Use a GRP…

Geographic Response Plans

• Columbia River (including Willamette River) 2001, 2015 with Washington
• Dept. of Ecology lead
• Northern/Southern Oregon Coast 1995, additions 1997
• Tillamook Bay 1995 + minor additions in 2000
• Yaquina Bay 1995 + reissue in 2005
• Coos Bay 1995 + minor changes 2000/2004
• Lower Deschutes River 2004 with EPA lead
• Other local plans for McKenzie, Upper Deschutes, and Clackamas rivers

developed by 3rd parties, not to standards

Oregon Coastal GRP Update

https://goo.gl/jfno7q

What other tools does DEQ have?

OR-IRIS

• Geodatabase w/ >250

datasets

• Resources at Risk
• Contaminant Sources
• Response Resources

What other tools does DEQ have?

OR-IRIS

• State-wide coverage
• Ability to leverage external

databases

• Data supports other

emergency management applications (RAPTOR)

Pacific NW ERMA

Geographic Response Strategies (GRS) Tiered Validation Levels

USCG Sector Columbia River

Incident Management Division

US Coast Guard Recommendation

• Area Committees should employ a risk-based decision-making

methodology to validate GRS (formerly referred to as Geographic Response Plans)

• Five Validation Levels:

I. Desktop II. Visual Confirmation

• III. Equipment Deployment
• IV. Full Scale Exercise (FSE)

V. Incident

I – Desktop

• Evaluation of GRS data by subject matter experts (SMEs)* in an office

setting or workshop setting with or without computer simulations

*** All GRS data should attain Level I Validation

II – Visual Confirmation

• Deployment of SMEs to a specified geographic area.
• Visual inspection,
• No equipment deployment,
• Possible computer simulation (NOAA)

*** Targeted for moderate to high-risk area where a degree of uncertainty exists.

III – Equipment Deployment

• Deployment of identified equipment to verify its performance in the

specified operating area

*** Targeted for inconclusive Level II validation strategies. *** Performed in high-risk areas where rapid and efficient response is critical.

IV – Full Scale Exercise

• Deployment of all appropriate response personnel and equipment

under an area full scale exercise setting

*** As dictated by the area exercise design/objectives

V – Incident

• Deployment of all appropriate response personnel and equipment for

an actual incident

*** Real world event.

Recommended Validation Team Members

40 CFR 300.600

• Dept. of Commerce: NOAA (Scientific Support Coordinator, National Marine

Fisheries Service)

• Dept. of Interior: Bureau of Indian Affairs, U.S. Fish and Wildlife Service,

National Park Service

• State Historical Preservation Officers
• Tribes and Tribal Historic Preservation Officers
• State trustee agencies
• Oil Spill Removal Organizations
• Industry Representatives
• USCG or EPA