Transport Publication - TP 15039 E (2010)
10. Designation of Places of Refuge
Proposal: Designated places of refuge for tankers in distress must be established.
In the aftermath of the Prestige incident in 2002, there has been a growing recognition worldwide of the importance of designating places of refuge ( POR ). It is important to distinguish “places of refuge” from “ports of refuge”, the latter referring to a sheltered area where a vessel may wait out a storm, or effect repairs if required. “Places of refuge” refers to areas where a stricken tanker could be anchored or beached to reduce the severity of a pollution incident. The general intent is to identify, prior to an incident, areas that are of relatively low sensitivity or that can be used to contain an oil release such that the area affected by the release is minimized.
Guidelines on how to designate POR 's, pre-spill or during an incident, usually entails documentation of the physical characteristics of potential sites, documentation of their potential sensitivities, and access to spill behaviour and trajectory information. There is a general reluctance to actually designate specific areas as POR 's prior to an incident for reasons that include:
- There are too many variables involved in a tanker incident that would affect POR designation that pre-spill designation would be meaningless. For example, proximity to the stricken vessel, availability of towing assistance, and seasonal variations in local environmental sensitivities are all key factors in site designation.
- The sheer number of potential sites that would need to be evaluated in a given area would make it an unmanageable exercise.
Rather than designating specific sites prior to a spill the preferred approach is to ensure that the required information is available at the time of an incident and that a process is in place to effectively manage various stakeholder inputs. The basic procedures are laid out in the Atlantic Region Places of Refuge Contingency Plan (Transport Canada, PORCP ATL ) and the National Places of Refuge Contingency Plan.
It is important that the procedure for site designation be practiced prior to a spill in an exercise or workshop setting to ensure that all required information can be made available on a timely basis and to adapt and refine the decision-making process in a non-emergency setting.
Action required:
TC , with CCG involvement, will commit to including use of the Places of Refuge Contingency Plan in upcoming exercises.
11. Location of Response Equipment
Proposal: Response capabilities for any such emergency be moved into Placentia Bay at a central location closer to risk than the current deployment ability in St. John's.
The proposal is clear in its goal of relocating response equipment from its primary location in Mt. Pearl to a location in Placentia Bay. The thinking is that this would drastically shorten the response time in the event of a spill and would presumably lead to a more effective response.
The rationale for locating the equipment in Mt. Pearl, on the southwest outskirts of St. John's is that the equipment is readily available to all locations within Newfoundland with tractors for moving equipment are readily available.
- Equipment can be easily moved by air through a major airport if needed in a cascading response in other parts of Canada;
- Other industrial infrastructure for equipment maintenance and repair is readily available.
None of these advantages would apply if the equipment were to be stationed at a location in Placentia Bay.
It should also be noted that the response structure, as currently in place, is well within the response regime time standards that apply to all Primary Areas of Response ( PAR 's) within Canada. The intention is to provide a tiered response structure with an on-site capability for initial spill containment, with skimming, storage, and beach-cleaning equipment brought in from centrally-located depots.
The tiered approach in Placentia Bay starts with an on-site initial response capability, as part of the requirements of the Oil Handling Facility regulations, and equipment is located dock-side at Come-By-Chance and Whiffen Head for this purpose. Additional equipment from Mt. Pearl is used to meet Tier 1 and 2, and cascading of equipment from Response Organizations ( RO 's) outside Newfoundland to meet Tier 3 and Tier 4 requirements according to the following schedule.
Tiered Response Capability Standards
|
Tier |
Rated response capability |
Response Time |
|---|---|---|
|
1 |
150 tonnes |
6 hours |
|
2 |
1,000 tonnes |
12 hours |
|
3 |
2,500 tonnes |
18 hours |
|
4 |
10,000 tonnes |
72 hours |
An alternative that might be considered would be to locate a small cache of equipment in Placentia Bay to shorten response times. Indeed, Eastern Canada Response Corporation ( ECRC ) presently does this to some extent by locating containment booms and one storage barge at the IMTT facility in Whiffen Head. The barge, in particular, provides an on-site capability of equipment not so easily moved by road. However, the general experience of both ECRC and CCG in locating small equipment depots in isolated locations has not been favourable. Problems with such an approach include equipment not being in good repair when needed, vandalism, theft, rodent infestation, and not being readily available for response to other locations within the area of responsibility.
Action required:
Coincident with the assignment of the CCGS Louis St. Laurent to the Newfoundland Region, and the intent to locate the vessel in Argentia, the CCG is considering positioning a quantity of response equipment to this location. Similar caches of response equipment are currently located at other sites in the region where the CCG maintains a facility.
12. Additional Response Capability
Proposal: An additional 2500 tonnes of rapid deployment response equipment should be added in strategic locations in Placentia Bay. These locations should be determined through further study of sensitive areas and likely spill trajectory scenarios.
13. Response Time Standards
Proposal: The response time standards set by Transport Canada should be cut in half for all spill categories. To illustrate, for a Tier 4 spill in the Georgraphic Area of Response ( GAR ), ,the response time standard should be 41 hours as opposed to the current 82-hour standard. The Regional Advisory Council ( RAC ) recommends Transport Canada review and consider response standards similar to those imposed by Norwegian responsible authorities.
The current response regime was established through a negotiated process with response capacity and time standards set through a combination of what was needed for an effective spill response and what could reasonably be achieved given the infrastructure base in potentially affected areas.
The response capacity and time standards could be included in a broader review of the Canadian response regime, but at present, no change to the current response time standards seems warranted. It is also important to note that any review of the Canadian response regime must be done on a national basis, comparing response capacities and response times in the context of comparable spill risk.
Action required:
TC is satisfied that the current RO equipment capabilities and response time standards are being met.
14. Designation of Waste Handling Sites
Proposal: There is an immediate requirement for Provincial responsible authorities to designate areas and capacity for handling collected oil and oiled debris from a major spill.
The province has responded to item #14 with the following information:
The province, through the NL Department of Environment & Conservation ( NL DEC ), recognizes this as an important issue and has identified a number of sites in the province on a preliminary basis for temporary storage and disposal of oil spill wastes. In general, these have been pre-selected based on their previous use as waste-handling sites, or their proximity to similar industrial activity.
Prior to any of these or other sites being used for oil spill waste disposal, significant work will be required to determine their suitability. This may include hydrogeological testing, soil permeability testing, and other environmental baseline information. This work has been identified as a necessary work item and will be followed through by NL DEC .
A Working Group on Marine Oily Waste Management has been formed by the Atlantic Regional Environmental Emergencies Team ( REET ), including the four Atlantic Provinces and Environment Canada, to work on standards and guidelines for marine oily waste handling treatment and disposal. The focus is to develop guidance materials on oily waste management that can be adopted on a regional basis. The guidance documents would provide the basis for a coordinated, comprehensive, planning approach for developing plans for large marine oil spill events that meets all requirements of provincial legislation/regulations, and provides for efficient and effective decision-making by responsible parties and response organizations. (http://www.on.ec.gc.ca/pollution/ecnpd/contaminassist_e.html).
Action required:
The planning, evaluation, and initial site selection for areas to be used for storage, handling, and disposal of oily wastes generated in an oil spill cleanup operation will be completed over the next couple of years.
15. Bird Rescue and Rehabilitation
Proposal: Local bird rescue and rehabilitation capacity must be increased and this local capacity must be used first in oil pollution cases. Placentia Bay is a safe haven for many species of seabirds and effective local response capacity will be a necessity in the event of a spill.
Contingency plans for both government and industry are based on the principle of mobilizing equipment and materials for rescue and rehabilitation at the time of a spill, if warranted. It is felt that this can be done effectively at the time of a spill, rather than establishing a rehabilitation capacity on a pre-spill basis. Clearly the planning elements must be in place within the applicable area and national contingency plans, and this will be confirmed.
In particular, advice on bird rescue and rehabilitation will be taken from Environment Canada, Canadian Wildlife Service ( CWS ), whose procedures are detailed in their Oil Spill Response Plan.
Action required:
TC and CCG will confirm that bird rescue and rehabilitation is adequately addressed in their own and industry's area and national contingency plans.
The CWS will take the lead in providing advice on bird rehabilitation and other wildlife issues.
16. Testing of Equipment Cascading
Proposal: The capability of ECRC to cascade equipment should be tested under conditions as realistic as is possible. This should include the capability to obtain the required amount of equipment from other provinces in all weather and in all Gulf of St. Lawrence ice conditions within the stated time limits, and should be confirmed in an unplanned test.
ECRC is required under current regulations to conduct exercises on an annual basis to simulate management and operational aspects of their contingency plans. As part of these exercises it is a requirement that they demonstrate the capability to deliver equipment from other response depots, aka cascading, to meet their tiered response capability. The demonstration of cascading does not necessarily mean that the equipment must be physically delivered as part of the exercise, but some ability to contact and arrange logistical requirements must be demonstrated. Nonetheless, as part of a major exercise in March 2008, a Current Buster oil recovery system was moved from Quebec City to Dartmouth for deployment to demonstrate the cascading ability. Other examples of equipment cascading by ECRC in actual spill incidents include:
- In 1998, four sea trucks, a GT-185, boom, bird scaring buoys, and a 50-tonne barge were moved from Sept-Iles and Quebec City to Havre St. Pierre.
- In 2005, 20,000 ft of 18-inch boom was air lifted from Montreal to Edmonton/Wabamun, AB plus three sea trucks from Sarnia and Montreal and a belt skimmer from Montreal by road. A boom trailer was moved from Dartmouth to Montreal to backfill the boom requirements at Montreal.
- In 2006, two sea trucks were moved by road to Wabamun from Montreal and Sarnia along with an 18 ft workboat, two rock washers, porta-tanks, and miscellaneous pumps.
- In 2007, two sea trucks and a small work boat were moved from Sarnia to Wabamun.
The concern expressed in the above proposal seems to relate specifically to the ability to deliver equipment to Newfoundland under all conditions. It must be accepted that the response time standards and tiered capability were established for planning purposes rather than as performance measurements. It must also be accepted that the delivery and use of equipment in an exercise or actual incident will be subject to weather limitations. It would seem to be of questionable value to actually deliver equipment by truck or ferry as part of an exercise in order to simulate a routine part of the ECRC 's operation.
It should also be noted that the amount of equipment stationed in Newfoundland by ECRC is somewhat greater than that maintained by other major Response Organizations ( RO 's) across Canada, in recognition of the fact that there may be more logistical difficulties in delivering equipment to Newfoundland from mainland depots.
Nonetheless, TC audits the capabilities of Response Organizations through the National Exercise Program, and will consider the use of unscheduled exercises if deemed necessary.
Action required:
TC will continue regular audits of RO capabilities by various means, including the National Exercise Program and unscheduled exercises (if deemed necessary).
ECRC is scheduled to have a Tier 4 exercise in 2010 and has offered to make this a community involved exercise.
17. Training of Fishermen for First Response
Proposal: Provide funding for community-based training of local fishermen.
A program was initiated by One Ocean in 2005 to train 500 fisheries workers in 15 communities. The major objective of the project was to enhance understanding of oil spill countermeasures at a community level. Due to the funding restrictions, One Ocean has not been able to deliver the training program as scheduled. They have a specific request for $500k funding to train 500 first responders. (They actually refer to unused funds in the Ship-Source Oil Pollution Fund ( SOPF ) as a potential source.)
CCG has run similar programs in the past but they have been discontinued over concerns of safety and liability of non- CCG personnel being involved in a response.
ECRC maintains a roster of 120 personnel within the province who could be contracted in the event of a spill response. These personnel include local contractors and fishermen who have been trained in ECRC procedures and with ECRC equipment. They do not, however, train a volunteer force for similar safety and liability issues.
Action required:
CCG continues to provide guidance to local authorities on spill issues and concerns, but does not support a volunteer work force in a spill response for safety and liability issues.
18. First Responder Equipment
Proposal: Financial incentives should be available to encourage fishers and aquaculture farmers to acquire first responder kits.
The concept would involve marrying local knowledge and expertise with first-responder equipment. It is expected that this would be limited to a narrow range of tasks such as initial spill containment, protection of aquaculture sites, and possible shoreline protection. Periodic training (annual exercise or refresher course) would ensure knowledge retention and provide opportunity for equipment inspection and maintenance.
A similar program was attempted in the mid-1990s in CCG Maritimes Region. Known as the Community Action Partnership Program ( CAPP ), it was to generate “self help” with community preparation, and included training and exercising of volunteers from local municipalities. Participants were included in CCG area contingency plans and in the contingency plan of Atlantic Emergency Response Team ( ALERT ), the spill Response Organization ( RO ) for facilities in and around Saint John and the Bay of Fundy. The program died due to a lack of funding to support equipment acquisition.
CCG does not support the concept of funding equipment acquisition by local authorities for reasons that include: initial capital costs, ongoing maintenance, and safety and liability issues with non- CCG responders.
Action required:
CCG continues to provide guidance to local authorities on spill issues and concerns. CCG will not provide financial support for first responder kits.