Worst Case Preparation – Environmental Risk Based Dimensioning of Oil Spill Response

Norway lies on top of Europe between 57 degrees North (at Lindesnes) and almost 81 degrees North (at Svalbard). The coastline is approx. 105 000 km when all the islands, skerries, fjords and inlets are measured. Further, the Norwegian Exclusive Economic Zone (EEZ) is approx. seven times larger than the land area (and almost equal to same area as the Mediterranean Sea). More than 80% of Norwegian imports and exports are by shipping. The Norwegian fishing industry, both high seas fishing and marine farming, is one of Norway’s largest export industries. Lastly, Norway is a large producer and exporter of petroleum product. Therefore, it is fair to say that Norway is dependent on the sea, and has a strong motivation for keeping our waters both safe and clean.

The Norwegian Pollution Control Act regulates all the contingency requirements and preparedness for the industry, the municipalities and the Government.

“Anyone operating an enterprise, which could cause acute pollution shall provide for the necessary emergency response system to prevent, detect, stop, remove, and limit the impact of the pollution. The emergency response system shall be in reasonable proportion to the probability of acute pollution and extent of damage and nuisance that may arise” (Pollution Control Act § 40). This means that all enterprises that have the potential to cause oil pollution must establish and maintain a level of preparedness relative to the possible pollution. The Norwegian Environment Agency makes requirements regarding contingency measures against oil and chemical contamination and supervises this aspect of preparedness. This applies, in particular, to; offshore oil and gas operating companies on the Norwegian continental shelf, crude oil terminals, refineries, companies distributing oil products, and other major industrial companies. In the event of a major oil pollution incident from offshore oil installations, the oil spill response resources that are administered on a daily basis by the Norwegian Clean Seas Association for Operating Companies (NOFO) will be activated (www.nofo.no). The oil and gas operator’s preparedness plans cover coordination and command of oil spill recovery operations in offshore, near shore and onshore locations. Hence the Norwegian oil industry has developed plans and built-up a substantial capacity for offshore, near shore, and onshore oil spill response operations.

“Municipalities shall provide for the necessary emergency response system to deal with minor incidents of acute pollution that may occur or cause damage within the municipality, and that are not covered by the private emergency response systems” (Pollution Control Act § 43).

Norway is divided into 32 intermunicipal preparedness regions, each with its own contingency plan. These plans cover the coastal waters out to the four nautical miles limit as well as onshore spills that are not covered by the private contingency. Local authorities, fire departments, port authorities, etc., all collaborate on municipal preparedness. The local authorities have the responsibility of dealing with minor acute spills occurring within the municipality due to normal activity, and have an obligation to assist the governmental preparedness in the event of major oil pollution operation. The latter applies especially to oil spill response operations involving extensive shoreline clean-up.

‘The government shall provide for the necessary emergency response system to deal with major incidents of acute pollution that are not covered by municipal, or private emergency response systems” (Pollution control act §43). This means, in effect, the discharge of oil from shipping and major spills from unidentified sources. In addition, the government can provide resources, such as consultants, contingency equipment, and/or personnel for response actions implemented under private or municipal management. The Norwegian Coastal Administration (NCA) is a Governmental agency under the Ministry of Transport and Communications being responsible for organising and maintaining the governmental oil spill response preparedness, and for co-coordinating the governmental, the municipal and the private industry’s preparedness in a national contingency system.

“In major cases of acute pollution or danger of such pollution the government may partially or totally take over the leadership of the efforts to fight the accident.” (Pollution Control Act § 46). This gives the NCA authority, on behalf of the government, to take operational command of the spill response operation. The government also has the responsibility of coordinating private, municipal, and governmental preparedness into a national emergency response system.

The national contingency plan describes the roles and responsibilities of the different governmental organisations that will take part in a governmental spill response operation led by the Norwegian Coastal Administration. Since the plan does not describe in detail what each organisation must do, the plan represents a superior and overarching link between the different authorities and their own contingency plans. The aim is to be better prepared to handle large incidents, not only from shipping incidents but also from large offshore petroleum incidents (Norwegian Coastal Administration, 2015).

The NCAs own contingency plan for oil spill response has been revised based on a common command structure (similar to the US Incident Command System (ICS) where all national emergencies involving acute pollution (oil and chemicals spills), natural disasters and large (forest) fires are handled according to the Norwegian version of the ICS (Norwegian Coastal Administration, 2015).

Norway has entered into a series of multi- and bilateral agreements with our neighbouring states agreements for notification and assistance in the case of an oil spill incident.

Bonn Agreement. All the countries bordering the North Sea have entered into an agreement on mutual notification, assistance and environmental surveillance in order to limit acute oil and chemical pollution in the North Sea.

Copenhagen Agreement. Denmark, Iceland, Finland, Sweden and Norway are parties to this agreement, which covers mutual notification, assistance and aerial surveillance of oil and other chemicals at sea.

NORBRIT Agreement. Norway and the UK have the Norbrit Agreement for joint counter pollution operations in the zone extending 50 miles either side of the median line separating the UK and Norwegian continental shelf.

Barets Sea Agreement between Norway and Russia. Agreements on mutual notification, drills and combating acute oil spills in the Barents Sea area.

The Agreement on Cooperation on Marine Oil Pollution Preparedness and Response in the Arctic. Agreement between the eight Arctic states (Canada, Denmark, Finland, Iceland, Norway, Russia, Sweden and the USA) for notification, cooperation, coordination and mutual assistance on oil pollution preparedness and response in the Arctic.

EMSA and EU ERCC: Norway is a member of EMSA (European Maritime Safety Agency), and take part in European cooperation on Marine Pollution. In addition, The Norwegian Coastal Administration is Norway’s contact unit for notifications of marine pollution via the European Union Emergency Response Coordination Centre (ERCC).

Between 2011 and 2015, The Norwegian Coastal Administration performed two environmental risk based assessments of the preparedness level for governmental response to oil spills, primarily resulting from shipping incidents. The two assessments cover the entire Norwegian coastline in 1) Contingency assessment for the Norwegian coastline (Kystverket, 2011) and 2) Contingency assessment for Svalbard and Jan Mayen (Kystverket, 2014). They consist of a probability analysis, an environmental risk analysis and a final preparedness assessment that will build upon the results from the two reports and provide an analysis of the governmental oil spill response resources necessary to establish a recommended preparedness level.

This assessment used a risk-based approach, based on a probability analysis and an environmental risk assessment regarding oil spills from maritime transportation. Based on the probability analysis, a most probable scenario of a 400 tonnes spill was identified. This scenario was used for dimensioning the base-line preparedness, defined as the level of response that has to be assured at any time and any place along the Norwegian coastline. Further, based on the environmental risk assessment, a contingency analysis for seven representative scenarios for various areas along the Norwegian coast was performed. Based on these seven scenarios, it was proposed to increase preparedness in areas with relatively high environmental risks

The scenarios were analysed using the oil spill simulation model OSCAR (Oil Spill Contingency and Response). The model calculates and records oil spill trajectories and oil weathering and forecasts the distribution of oil on the water surface, in the water column, in sediments and along shorelines. The seven scenarios were used in the OSCAR model, together with three different packages of measures, according to three different response times. These packages consist of a set of pre-defined oil spill response systems. Each of these systems is autonomous, and consists of the material and competent personnel necessary for combating the oil spill. The results of the simulations, together with a relative cost-benefit analysis, form the basis for the recommended target levels of increased preparedness .

Present preparedness was compared to the recommended target levels in a gap analysis. The results from the gap analysis were used by the project to identify the measures considered necessary in order to achieve the recommended national oil spill preparedness. The following 16 recommendations were the result of the gap analysis. Most of the recommendations are already in place.

In 2014, The Norwegian Coastal Administration finalised an environmental risk based assessment of the preparedness level for governmental response to oil spills, primarily resulting from shipping incidents in the waters off Svalbard and Jan Mayen (Kystverket, 2014).

The area of the assessment covers a large sea-area where climate conditions can be challenging, due to i.a. low temperatures, fog, sea-ice, snow, and darkness. The overall assessment has been divided into three consecutive reports; analysis of the probability for oil spill incidents, analysis of the environmental risk and analysis of the preparedness level.

The reports concluded that:

• The probability of incidents followed by oil spill is low, with one incident every 6th year (independent of spill size).

• Svalbard has a higher probability for incidents than Jan Mayen, which is only estimated to experience one incident every 225^th year.

• The average spill size (for the whole area of research) is estimated to 3 tonnes per/year.

• Bjørnøya and the western part of Spitsbergen are classified as the areas with highest environmental risk. These are also the areas where the chance of an incident is most likely to occur.

• The most likely scenario is an oil spill with marine diesel (distillate).

The preparedness level analysis is based on six different scenarios; one in Jan Mayen, four in Spitsbergen and one in Bjørnøya. Five of the scenarios involve diesel, while two involve heavy fuel oil. The size of the spills varies between about 200 m³ to 2000 m³. Each scenario is analysed by looking at different measures and current accessible oil protection equipment.

The use of chemical dispersion was also assessed, and simulations indicated that chemical dispersion of diesel was effective. In 2014 SINTEF delivered a report (SINTEF 2014) to the NCA concluding that heavy fuel oils (IFO 180, IFO 380) are not dispersible in 0°C sea temperature, but that IFO 80, is dispersible in 0°C sea temperature.

The report suggests that agreements drawn up, so that equipment and resources can be provided or accessed:

• Fast system for deploying booms around leaking vessels: Agreements should be established with local vessels on Svalbard that can handle this equipment, during high season, May – November.

• Contractual coastal oil recovery vessels: Enter into agreements with 6 vessels on Svalbard. The contracts should include a demand for certification and training programs.

The assessment further suggests:

• To accomplish a laboratory program to test disintegration and spreading of light distillates, and to test distillates and mechanical recovery equipment at the NCA test centre. Based on the results from the tests one should consider a full-scale test on light distillates.

• To evaluate alternative methods for waste treatment. During an operation in the shoreline zone, large quantities of oil-polluted matter need to be handled on site. Hence, the focus should be on methods that can work more or less independently.

• To install equipment on the Governor of Svalbards vessel “Polarsyssel”, and to strengthen the competence to handle it. Polarsyssel should also be equipped as a single vessel sweep system, and be considered to work as a platform for dispersion.

• That the Coast Guard’s vessels which operate around Svalbard are designed, and equipped with adequate oil response systems, including infrared (IR) capacity and oil detection radars.

• Equipment for remote measurement that serve important functions under arctic conditions, where operations will be challenged by darkness, fog and ice covered waters.

• To improve communication-methods and remedies, and to further develop map based systems to support a common operational picture.

In other words, within the research area there should be a broad selection of vessels and resources. This will enhance the ability to handle operational challenges that are common in arctic conditions. Finally, the NCA will need to cooperate closely with the Governor of Svalbard to clarify expectations and operational patterns in cases where oil spills may occur.

The worst-case analysis (Kystverket, 2015) follows a different methodology by being more descriptive. Responding to the worst-case scenarios will depend upon using all available resources nationally, and include international assistance.

The two scenarios that the NCA analysed for worst case assessment for oil spill response were taken from a national risk analysis that the Norwegian Directorate for Civil Protection finalised in 2014 (DSB, 2014). This analysis consisted of 20 different scenarios that might affect Norwegian society, and may demand extraordinary efforts. The two scenarios were:

1. Oil and gas blow-out on the Norwegian continental shelf.

2. Collision at sea between two vessels off the coast of Western Norway

Based on the scenario and an assessment of the available resources and response strategies, including international notification and request for assistance, The Norwegian Coastal Administration recommends, among other things:

• - Finalising the work on establishing a system for unified command between the government and the operator for very large oil spill incidents, and describe this in a bridging document.

• - Annual exercise between the government and the oil industry based on the bridging document.

• - Annual exercise involving the regional and municipal response organisations.

• - Continue the annual exercise between the Norwegian Petroleum Safety Authority and the Norwegian Coastal Administration.

• - Establish a common system for decision-making and common operating picture.

• - The decision making process, and external communication related to large-scale use of dispersants shall include training and exercises.

• - Routines for receiving international aid and support (i.e. Host Nations Support) shall include training and exercises.

Based on the scenario and an assessment of the available resources and response strategies, the Norwegian Coastal Administration recommends, among other things:

In the acute phase:

• - Finalise the National plan, and exercise the plan annually between cooperating governmental organisations

• - Assess the use of military resources beyond the use of Coast Guard vessels, e.g. use of National Guard and transport capacities.

• - Clarify to what extent the oil industry can support with their oil spill response resources before the industry’s own activities will be affected.

• - Better system for requesting international support, finalise the plan for host nation support and exercise the plan on a regular basis.

In the shoreline clean-up phase:

• More robust systems for logistic support of long-term shoreline clean up operations over a large geographic area.

• Enter into agreements for treatment of recovered oil and oil-polluted waste.

• Annual exercise with specific focus on shoreline clean-up.

In 2015, the Norwegian Coastal Administration (NCA) conducted the Rogaland exercise, with a scenario based on an offshore incident. One of the goals of the exercise was to train unified command between NCA and one operating company during an oil spill response operation. The exercise was organised in cooperation between NCA and Statoil.

NCA conducted a governmental takeover of the incident command, by following the contingency plan. In practice, this was implemented by joining the operating company’s incident command with a staff organization. The exercise was carried out in several phases. In the first phase, the operations was led by the operating company’s incident command, which had activated the emergency response organisation NOFO. A group from NCA travelled to Statoil’s location at Sandsli in Bergen, and exercised regulatory oversight of the responsible polluter from the operator’s location. In the second phase of the exercise, NCA assumed the incident command, and established a unified command structure in cooperation with Statoil.

Among the lessons learned were

• The concept of unified command as described in the national plan works as intended.

• It would be desirable that the ICS structure was used at all types of incidents, and in particular for oil spill response operations.

• NCA must look into how the regulatory functions are used in such operations

• The operator concludes that the NCA established incident command in a good and appropriate manner during this exercise, and wants more similar exercise.

The Norwegian Coastal Administration together with the Governor of Svalbard conducted an oil spill exercise at Svalbard in late September 2016. The main objectives for the exercise were to train the transfer of incident command from the local authorities (i.e. The Governor of Svalbard) that lead the initial response to the “accident”, to the national authorities (i.e. The Coastal Administration). Further objectives were to test communications in remote areas, the transfer of equipment, ships, crew etc. both from the mainland to Svalbard, and from the staging area to the clean-up site. An additional objective was to test out the working conditions for responders in cold climate.

A simulated grounding of a container vessel followed by a large spill of heavy fuel oil was the scenario for the exercise. The simulated oil drift resulted in oil recovery operations both at sea and on the shoreline. The exercise area was selected to comply with the restrictions for exercising on the shorelines at Svalbard. The exercise involved eight vessels, two helicopters and a surveillance aircraft. The Norwegian Coastal Administration, The Governor of Svalbard, The Norwegian Coast Guard, The Joint Rescue Centre North-Norway, The Norwegian Polar Institute, The Norwegian Clean Seas Organization for Operating Companies (NOFO) and other private organizations took part in the exercise.

Among the lessons learned were:

• It is important to send experienced personnel that can facilitate the transfer of command from the local authorities and at the same time incorporate the local authorities’ competence and knowledge into the operation.

• It takes time to transfer people and resources to Svalbard. Arctic weather challenges can delay this process even more. Therefore, it is important to store more equipment at Svalbard, have more local ships and crew under contract, trained and equipped with oil recovery equipment.

• Our response plans, maps of sensitive areas, common operational picture and internal and external communications are based on communications through the Internet. Internet access (and other means of communication) is very limited in the Arctic and other solutions must be prepared beforehand.

• Fragile vegetation, long and costly (both economically and environmentally) transport of recovered oil and polluted waste were other specific concerns.

SCOPE 2017 is a comprehensive collaboration exercise in response to an oil spill and other harmful substances that threaten humans and the marine environment. The Norwegian Coastal Administration (NCA) has been assigned project funding from the EU Commission Directorate-General Humanitarian Aid and Civil Protection, to plan and conduct this exercise. The exercise will take place between 25^th and 29^th September 2017 in the Grenland area, Norway. The exercise is a joint project between NCA as the coordinator and the Swedish Coast Guard, the Royal Danish Navy, the Environment Agency Iceland, South-East Police District Norway and Intermunicipal Emergency Response Organisation (IUA) in Telemark.

The aim of the exercise is to improve national and international coordination of vessel accidents involving hazardous and polluting cargoes. Further, the exercise shall strengthen collaboration between the signatories to the Copenhagen Agreement, Bonn Agreement and with EU support, make the best possible use of the resources, services and guidelines offered through the EU.

This will be achieved through the following activities and exercise elements:

• - Implement correct notification measures nationally and internationally, including activation of the mechanism and the mobilisation of international support

• - Have arrangements for host nation support in accordance with the EU’s Host Nation Support Guidelines, Norwegian National Guidelines and the NCA’s plans

• - Train and exercise collaboration between Norwegian participants and international participants related to conditions involving serious oil and chemical pollution.

• - Train and exercise plans for claims management and plans for place of refuge

• - Train and exercise EUCP-team related to a marine pollution incident.

• - Chemical operation at sea (MIRG)

• - Oil spill response at sea and onshore.

• - Operations during night time.

In this paper, I have outlined how the Norwegian Coastal Administration has worked methodically to strengthen the Norwegian governmental oil spill response preparedness. First, by assessing the preparedness through two environmental risk-based preparedness analyses which have been used as a basis for recommending a response level and response time for equipment, vessels, personnel, training, exercises etc to The Ministry of Transport and Communications. To a large extent these recommendations have been followed up. Secondly, by assessing two worst-case scenarios, the outcomes of which focused at a national level; in being better prepared to handle very large shipping incidents and offshore oil blow-out situations were identified. The national plan, together with large-scale exercises has focused on following up on these recommendations, including strengthening the systems and routines for international assistance and host nation support to facilitate this.