Heather Parker D13 DRAT - Seattle, WA Wrecks of the World II 07JUN11 source: Kip Evans Photography

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Heather Parker D13 DRAT - Seattle, WA Wrecks of the World II 07JUN11 source: Kip Evans Photography Slide 2 Systems Approach to Addressing Wrecks and Derelicts under FWPCA/OPA Framework Defining the Problem Complexity What are Wrecks and Derelict Vessels? Whos 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 Committees 1.AWARENESS PHASE Inventory your Area 2.RANKING PHASE Prioritize (G-A-R) 3.ACTION PHASE INITIAL ASSESSMENT DECISION TRIGGERS REMOVAL OPERATIONS UNIFIED COMMAND 4.REVIEW AND REVISE NRT GUIDANCE 2 Slide 3 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. 3 source: CA DFG source : www.ussmississinewa.com Slide 4 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 4 Source: Greg Buie, NPFC Slide 5 5 Vessel TypeWreck (sunken, beached, buried)Derelict (floating, moored, anchored, beached, partially sunk ThreatActively leaking oil Substantial Threat of a Discharge of oil Concern for eventual discharge No concern (e.g. no oil on-board) LocationOffshoreNearshoreInshore River/Lake/Upland DepthDeepShallowAfloatIntertidal Vessel SizeLarge (greater than 200 LOA) Small (less than 200 LOA) Source: Greg Buie, NPFC Slide 6 M/V KALAKALA Slide 7 Slide 8 ALERT LST -1166 LCI -713 RIVER QUEEN EL CONQUISTADOR JEAN SASANOA DAVY CROCKETT MANZANILLO BRETT SCOTT BARGE Slide 9 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. 9 Slide 10 10 PREVENTION WRECK/DERELICT OIL REMOVAL RESPONSE TO DISCHARGE source : www.ussmississinewa.com Slide 11 In most cases, there are a limited number of options: 1.Defuel/ DeCargo the Wreck or Derelict 2.Seal/Encapsulate and Monitor 3.Vessel Destruction, Removal, Dumping Some cases may involve a combination, but often the preferred option will be Defueling or Wreck Oil Removal. 11 source : www.ussmississinewa.com Slide 12 FOSCs will make ultimate decisions, but will want/need input from their Area Committees. Through a TRANSPARENT, COMPREHENSIVE, DEFENSIBLE Process Preferably Consensus- Based 12 source : www.ussmississinewa.com Slide 13 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? 13 Slide 14 14 GAP: ESTABLISHED NATIONAL GUIDANCE ON FUNDING RESPONSE PLANNING, AND CONTRACTING PROCESSES Adapted from: LTJG Chris Kimrey, IOSC 2011 Presentation Slide 15 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 yesterdays bad news Oil Mitigation Operations on a wreck or derelict is a Prophylactic Response Typically dont have many classic spill response actions/operations Shoreline Assessment and Cleanup, Oiled Wildlife Recovery, etc 15 Slide 16 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 16 Slide 17 1.AWARENESS PHASE Inventory your Area 2.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 17 Slide 18 18RANKING ACTION REVIEW/REVISE AWARENESS Incorporate into Annual Area Contingency Plan Updates Slide 19 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 Slide 20 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. 20 Slide 21 Two primary phases: 1.INITIAL ASSESSMENT DECISION TRIGGERS Weve 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 COMMAND 1.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 21 Slide 22 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 22 BEST RESPONSE = Includes continual improvement Slide 23 Area Committees are programmed to respond to accidental releases of oil Where we are responding to yesterdays 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. 23 NATIONAL RESPONSE TEAM (NRT) GUIDANCE WILL BE KEY Slide 24 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. 24 Slide 25 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 25 Slide 26 26