Action, not Alarm: Preparing for Oil Sands Response at the Local Level

Canadian Oil Sands are composed primarily of grains of sand which are covered by a layer of water and coated in a heavy oil known as bitumen (Oil Sand Discovery Centre, 2013). The bitumen found in these oil sands has higher density and viscosity than conventional crude oils because of the heavy biodegradation that occurred in its geologic history (Crosby et. al., 2013). Because of its high density and viscosity, bitumen is typically heated or mixed with very low viscosity oil products (commonly referred to as diluents) to facilitate transport. In this paper, the variety of fuel sources derived from the bitumen found in Canadian Oil Sands will be referred to as Canadian Oil Sands Products (OSP). Examples of common Canadian OSP are Diluted Bitumen- DilBit (bitumen blended with a diluent), Synthetic Bitumen- SynBit (upgraded¹ bitumen), and Synthetic Diluted Bitumen-SynDilBit (upgraded bitumen blended with a diluent).

The transportation of Canadian OSP in the United States is not a new occurrence. Canadian OSP, in the form of Diluted Bitumen, has been transported through the US via the Trans Mountain pipeline since the late 1980s (Davies, 2013). In the past, the volume of Canadian OSP transported within the US was limited due to the relatively lower cost of conventional oils. Recently however, improvements in oil sands extraction technology and constraints on availability of conventional oil have made Canadian OSP a viable alternative (Crosby et. al., 2013). According to the Canadian Association of Petroleum Producers (CAPP) 2013 Crude Oil Forecast, Markets & Transportation report, Canada produced 1.8 million barrels of Canadian OSP per day in 2012. It is projected that the volume of OSP produced in Canada could increase by 77% to 3.2 million barrels per day by 2020 and by 189% to 5.2 million barrels per day by 2030 (CAPP, 2013). This elevated production has increased Canadian OSP transport into the United States via pipeline, railways, barge, and tanker (NOAA blog, 2013). According to recent statistics, approximately 70% of OSP from Canada is transported to refineries in the Midwestern United States (Welch et al, 2013). The increase in production and transportation of Canadian OSP into the US makes it vitally important for local and regional response communities to increase response planning and preparedness for spills of these products.

A major challenge related to a Canadian OSP response that necessitates additional preparedness activities stems from uncertainty about the physical fate of these products, including how they will behave in aquatic environments as well as if and when they will sink when spilled. In addition to the challenges stemming from uncertainties related to physical fate, responders are further challenged by the need for increased air monitoring and personal protective equipment due to the volatilization of benzene and other volatile organic carbons (VOCs) which occurs when Canadian OSP is spilled. More research is clearly needed on the physical and chemical fate of Canadian OSP, but unfortunately very little progress can be made in this arena by the local and regional response community. The local and regional response community can, however, improve their ability to launch a timely and effective response to Canadian OSP spills by planning for these challenges and uncertainties through targeted preparedness, training, and outreach activities.

Two relatively recent spills of Canadian OSP in the US and Canada provide valuable insights into the best practices associated with response to spills of these products. In 2010, 20,000 barrels of Canadian OSP spilled into the Kalamazoo River from the Enbridge pipeline. In this spill, the diluents in the Canadian OSP evaporated and the remaining bitumen (and diluent/bitumen emulsions) sank to the bottom of the river, mixing with the sediment and making the oil difficult to locate and recover (EPA letter, 2013). The evaporation of the diluent resulted in elevated levels of benzene in the air, which necessitated additional personal protective equipment for the oil spill responders and prompted voluntary evacuations for surrounding communities. The Agency for Toxic Substances and Disease Registry (ATSDR), Michigan Department of Community Health, and local Health Departments worked effectively with the Unified Command to establish appropriate thresholds for air monitoring. Despite the new challenges posed by this spill, the general assessment of the response presented by EPA at the Pacific States/British Columbia Oil Spill Task Force 2013 Annual Meeting was that the “timely use of conventional strategies works”(EPA ppt, 2013). The preparedness, training, and outreach activities outlined later in this paper can help ensure the best practice of timeliness in future responses.

Another example of a Canadian OSP response is the 2007 spill of 1,400 barrels of synthetic crude (also known as upgraded bitumen or SynBit) into Canada's Burnaby Harbor (Crosby et al, 2013). This response employed the use of existing equipment and technology such as containment booms, vacuum trucks, and chemical shoreline cleaners. According to a 2013 report by the Government of Canada, “spill response operations [for the 2007 Burnaby inlet spill] were effective at removing oil from the environment and in limiting the short- and long-term effect of the spill” (GovtCanada, 2013). The report also noted that “Oil was recovered by skimming and booming, as well as by flushing and removal from the affected shorelines” (GovtCanada, 2013). While some of the success of this response can be contributed to the spilled product entering a storm sewer, allowing responders to quickly contain and recover it (Crosby et al, 2013), it is nevertheless a sound example of how existing equipment and tactics can be used to conduct a successful Canadian OSP response.

While each response poses its own unique challenges, the takeaway message is that response to Canadian OSP relies on the same basic technologies and strategies that are used to respond to spills of other types of oil. The key to effective Canadian OSP response is to ensure that response planning accurately captures Canadian OSP properties and prescribes the appropriate personal protective equipment, response technologies, and tactics so that a safe and effective response can be launched in a timely manner. Progress toward this goal can be accomplished at the local level by increasing understanding and awareness of Canadian OSP through preparedness, training, and outreach activities.

One of the most basic steps in improving preparedness for spills of Canadian OSP is simply awareness. Fortunately, awareness of the presence of Canadian OSP and the possible response challenges associated with them is growing due to media interest and coverage related to the Kalamazoo River Spill and the Keystone XL Pipeline Project.

Within the response community, increased interest and awareness of Canadian OSP is evidenced by various trainings and workshops held across the country. For example, the University of New Hampshire's Center for Spills in the Environment (UNH CSE) facilitated two recent trainings on Alberta Oil Sands designed to increase Canadian OSP awareness. The first was held in 2012 in Portland, Maine and the second was held in 2013 in Seattle, Washington. Both events brought together Regional Response Team (RRT) and Area Committee representatives from the federal, state and local level. These events generated numerous practical and insightful recommendations on how local response communities can prepare for Canadian OSP spills. The remainder of this paper captures some of these recommendations, along with a series of other suggested actions which local response communities can take to better plan and prepare for response to spilled Canadian OSP through preparedness, training, and outreach. There are arguably additional steps that can be taken to improve preparedness for Canadian OSP other than those suggested below, but rather than outlining a comprehensive (and likely unachievable) plan for increasing Canadian OSP preparedness, this paper provides a set of achievable, low cost, and high impact actions that local response communities can take using existing resources and authorities to improve preparedness for Canadian OSP incidents.

The suggested activities described below are meant to provide local response communities with a series of logical first steps that they can take to increase their Canadian OSP preparedness. These activities are focused on gathering relevant response information in advance of a Canadian OSP spill in order to facilitate a timely and effective response in the event of a spill. Area Committees should play a role in the majority of the suggested activities in this section.

• Identify locations in the local area of responsibility where Canadian OSP may be encountered. The first step in this identification process should be to evaluate the local area and identify the routes of Canadian OSP transport (shipping, rail, pipeline) as well as the locations of Canadian OSP production and storage. This can be accomplished through Area Committees discussions with industry partners.

• Identify natural collection areas where sunken oil would be most likely to collect/ pool. The cost-effectiveness of this activity will depend on the existing information and datasets available in each area. Area Committees can review collection points already identified within their Area Contingency Plans as well as materials produced by the US Geologic Survey, the National Oceanic and Atmospheric Administration, and the Army Corp of Engineers to help them evaluate the most probably areas for submerged oil to collect. Area Committees should consider focusing their effort on identifying natural deposition areas near Canadian OSP production and storage facilities and along Canadian OSP transportation routes. Identifying this information in advance can assist with the development of response strategies designed for submerged or sunken oil which may not be addressed in the current Area Contingency Plan or may differ from response measures outlined in existing Geographic Response Plans.

• Update Contingency Plans to account for Canadian OSP. If Canadian OSP is present in the local area, Area and Regional Contingency Plans should be updated to account for these products (CSE, 2012). One example of an Area Contingency Plan being updated to account for Canadian OSP is the Northwest Area Contingency Plan (NWACP), which encompasses the States of Washington, Oregon, and Idaho. In 2014, the NW Area Committee added a section to the NWACP titled ‘Submerged or Sinking Oils – Policy and Operational Tactics’, which addresses the presence, response considerations, and best practices for sinking oils (including Canadian OSP) within their area of responsibility. The recommendation to update Contingency Plans so that they adequately address Canadian OSP was also voiced by the Alliance for the Great Lakes in their 2013 report, ‘Oil and Water: Tar Sands Shipping Meets the Great Lakes’. When conducting Contingency Plan updates, planners should keep in mind that, although Canadian OSP may behave like highly persistent Group V oils (oils that have a specific gravity greater than 1.0) once weathered in the environment, they are often classified as (and subject to the regulations for) Group IV oils (oils that have a specific gravity greater than 0.95 and less than 1.0) due to their physical characteristics as a blended product (Crosby et al, 2013). It is critical that planners acknowledge and plan for this reality when updating the Contingency Plans to account for the presence of Canadian OSP. Information about the locations where Canadian OSP may be encountered and the areas of deposition where sunken oil could collect/ pool should also be included in these Contingency Plan updates.

• Conduct local area exercises that address Canadian OSP spill scenarios. Once the Contingency Plans have been updated, the information outlined in the plan should be assessed by conducting an exercise based on a Canadian OSP spill scenario. Federal and State exercise designers should make every effort to include industry partners and plan holders that produce, store, or transport Canadian OSP in their PREP exercises.

The suggested training activities described below are meant to generate thought and conversation and to provide a starting point to help catalyze Canadian OSP training in local response communities. The goal of these training activities is to arm members of the response community with knowledge that will allow them to respond to spilled Canadian OSP in a timely and effective way. Ideal participants for this training would be local federal and state responders and members of Tribal Emergency Planning Committees, Local Emergency Planning Committee, and State Emergency Response Commission.

• Conduct Canadian OSP Indicator Training for the local response community: Hold local response community training about red flags and indicators of a Canadian OSP spill which may include the location of spill (near a known transportation route for Canadian OSP i.e. railway or pipeline), Reporting Party (company or corporation which transports these products) and other indicators found at the scene such as a sweet aromatic odor or high levels of benzene or other VOCs indicated by air monitoring. The possibility of incomplete or inaccurate reporting to the National Response Center (NRC) makes this type of training doubly important because responders armed with this knowledge will be much more likely to recognize an incomplete or inaccurate report by picking up on the right cues and asking the right follow-up questions. It is critical that responders identify spilled Canadian OSP as quickly as possible so that they can direct appropriate air monitoring, don the proper protective equipment, prepare for response activities at pre-identified collection points, and ensure that the appropriate response equipment is deployed to the spill site in a timely manner.

• Conduct Canadian OSP Response Considerations Training for the local response community: Hold local training/workshops for responders about challenges and uncertainties of Canadian OSP responses. This training should remind responders that in a Canadian OSP response, they need to be prepared for the possibility that they may encounter a floating oil product (potentially laden with toxic and/or flammable VOCs) in the initial phase of the Canadian OSP response followed by subsurface and sunken oil later on as the response progresses. Examples of topics this training should cover are Canadian OSP response hazards (benzene and VOCs for example); best practices and response strategies; and factors that could increase probability of the spilled product sinking (high sediment interaction for example – see Fingas et al and GovtCanada 2013).

• Conduct Canadian OSP Response Equipment Training for the local response community: Hold local training on response equipment available in the local area for response to floating, submerged, and sunken oil. It is important to provide training on equipment that can address oil in each of these three locations (floating, submerged, sunken) because of the ongoing uncertainty associated with the physical fate of spilled Canadian OSP. A useful document to reference during the sunken oil portion of this training is the 2013 Coast Guard Research and Development Center Report: Development of Bottom Oil Recovery Systems. This report documents the results of a four-year Coast Guard Research and Development Center project to identify and develop prototype systems for the detection and recovery of heavy oils without the use of divers. Part B of this report contains valuable information to assist Federal On Scene Coordinators during responses to spills of heavy oil. This training should also include a session on protective equipment and air monitoring necessary for Canadian OSP response.

The suggested outreach activities described below are meant to provide local response communities with achievable outreach goals that should help open the dialogue on Canadian OSP with key interagency and stakeholder groups.

• Conduct outreach to Canadian OSP transporters. Transporters of Canadian OSP may vary depending on the industry within the local area; they could include the shipping industry, the pipeline industry, or the railroad industry. Outreach to the rail industry is particularly important because under the current regulations their response plans are submitted to, but not reviewed or approved by, the Federal Railroad Administration (FRA). Participation in Area Committee meetings could help the railroad industry to gain a better understanding of how response plans for vessels and facilities are approved, which could inspire them to internally adopt similar frameworks for their own plans. Regardless of the industry, one topic that should be discussed is the importance of accurate product characterization in reports to the National Response Center (NRC). This is a key topic because responders use the information they receive in NRC reports to plan and mobilize the response effort. This outreach should impress upon the industry that it is not possible for responders to organize the most effective and timely response to Canadian OSP if they are not aware that they are responding to Canadian OSP due to an incorrect or incomplete initial report

• Conduct Outreach to the Federal Railroad Administration (FRA) (CSE, 2012). The FRA is a government entity with the potential to become more directly involved in oil spill response planning the future. In January 2014, the National Transportation Safety Board sent a Safety Recommendation letter to the FRA which stated that, “Although [the Code of Federal Regulations] requires comprehensive response plans to be submitted to the FRA, there is no provision for the FRA to review and approve plans…NTSB recommends that the FRA develop a program to audit response plans for rail carriers of petroleum products to ensure that adequate provisions are in place to respond to and remove a worst-case discharge to the maximum extent practicable and to mitigate or prevent a substantial threat of a worst-case discharge”(NSTB, 2014). Area Committee members have a wealth of experience with the family of response plans encompassed within the National Contingency Plan. This information can be shared with the FRA though outreach activities including inviting representatives from the FRA to participate in Area Committee Meetings.

• Conduct Outreach to the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA): Build a relationship between the Regional Response Teams and Area Committees (RRTs/ACs) and PHMSA. PHMSA oversees pipeline contingency plans developed by pipeline owners which should be consistent with area, regional, and national contingency plans. While it is the responsibility of PHMSA to review pipeline contingency plans and ensure their alignment with the National Contingency Plans, it would benefit RRTs/ACs have awareness of these plans (including awareness of pipelines and breakout tank locations within their area). Area Committees wishing to further ensure consistency between PHMSA-regulated pipeline contingency plans and Regional and Area Contingency Plans might consider establishing informal working relationships with PHMSA or even formal mechanism such as a memorandum of agreements (Crosby et al, 2013).

• Prepare Outreach material for community Stakeholders: Prepare briefing materials and outreach tools to share with local politicians, media, fire departments, and emergency planning committees related to Canadian OSP (CSE, 2012). Area Committees can consider crafting both background material for educating stakeholders in the quiet times as well as targeted ‘just in time’ material to be used to educate stakeholders at the time of a spill. This information will help educate local leaders and the stakeholders in the community so that they are more informed and better able to understand the challenges and strategies related to Canadian OSP response in the event of a spill.

The increased development and transportation of Canadian OSP presents new challenges for the oil spill response community. The activities proposed in this paper can help local response communities enhance their ability to launch a timely and effective response to spilled Canadian OSP. These enhancements can be accomplished through preparedness activities to ensure contingency plans adequately address this new challenge; training activities to ensure that responders have the knowledge they need to conduct an effective and timely Canadian OSP response; and outreach activities to ensure that the responders, regulators, and stakeholders are coordinated and informed and to promote awareness of the importance of accurate product characterization in reports to the National Response Center (NRC). The need for additional research to reduce the uncertainty related to the physical and chemical behavior of Canadian OSP when spilled into the aquatic environment still exists. While local response communities may not have the resources and abilities to reduce this uncertainty; they can nevertheless conduct impactful preparedness, training, and outreach activities to better prepare themselves and their communities for this new era in oil development.

The views expressed herein are those of the authors and are not to be construed as official or reflecting the views of the Commandant or of the U. S. Coast Guard.