CONTENTS

Introduction

Section 1 PREVENTION OF OIL SPILLS – GENERAL

Some history
Prevention during routine operations
A – Bunkering Operations
B – Tanker Cargo Operations
C – Crude Oil Washing

Section 2 PREVENTION AND REACTION TO MARINE OIL SPILLS UNDER OPA 90

™
Glossary of selected terms used in OPA 90
™
What is the OPA 90 Vessel Response Plan?
™
Planning - Preparedness for Response Exercise Program (PREP)
™
Example of an on-board emergency procedures exercise
™
General conclusions
™
The results of the exercise
 Introduction
Section 1 of this Reference deals with the prevention of oil spills during bunkering
operations, during the loading and unloading of oil cargoes and during Crude Oil
Washing (COW) operations.

Section 2 of this Reference gives a brief summary of the key aspects of the OPA 90
Vessel Response Plan. It then outlines the various actions taken in the exercise shown
in the video. It also gives a glossary of the main terms used in connection with OPA 90.

Section 1

PREVENTION OF OIL SPILLS – GENERAL

Some history

In 1967, the Torrey Canyon ran aground while entering the English Channel and spilled
her entire cargo of 120,000 tons of crude oil into the sea. This resulted in the biggest oil
pollution incident ever recorded up to that time. The incident raised questions about
measures then in place to prevent oil pollution from ships and also exposed deficiencies
in the existing system for providing compensation following accidents at sea.

In December 1976, the Argo Merchant ran aground off Massachusetts. It was a small
tanker, carrying 27,000 tonnes of oil, but caused huge public concern as the oil slick
threatened New England resorts and Georges Bank fishing ground.

In March 1989, the Exxon Valdez, loaded with 1,264,155 barrels of crude oil, ran
aground in the northeastern portion of Prince William Sound, spilling about one-fifth of
its cargo. It was the largest crude spill to date in US waters and probably the one that
gained the biggest media coverage.

On 12 December 1999, the 37,238-dwt tanker Erika broke in two in heavy seas off the
coast of Brittany, France, while carrying approximately 30,000 tonnes of heavy fuel oil.
Although the crew were saved, some 14,000 tonnes of oil were spilled and more than
100 miles of Atlantic coastline were polluted.

In November 2002, the crippled oil tanker Prestige sank 130 miles off the northwest
coast of Spain. The ship's cargo, 70,000 tonnes (19.6 million gallons) of heavy fuel oil,
went to the bottom of the ocean. The 20,000 tonnes that leaked from the tanker created
an ecological disaster along Spain's coast that will cost an estimated $100 million to
clean up. The spill has devastated the $330 million fishing industry in the area.

These are examples of major oil pollution disasters. However, oil pollution also occurs
as a result of spillage during routine operations.
In the early days of oil tanker operations it was a common practice to clean tanks by
means of jets spraying seawater. The jets washed the oil residues from the tank
surfaces, resulting in a mixture of oil and water, which collected at the bottom of the tank
and was then pumped overboard. This naturally led to a considerable amount of oil
getting into the sea, and the ballast water, which was pumped overboard to make way
for a fresh cargo of oil, was also contaminated.

In the 1950s, there were no alternative ways of cleaning tanks and the aim of the
MARPOL Convention adopted in 1954 was to prohibit the discharge of oil or oily
mixtures within 50 miles of land. This limit was extended to 100 miles in certain areas,
which were regarded as being particularly endangered. During the 1960s, technical
advances made it possible to improve upon the requirements of the Convention and in
1969 further amendments were adopted which were designed to make even greater
reductions in operational oil discharges.

One of the most important technical advances was the development of the system
known as load-on-top. Although this was developed primarily as a means of saving
money, its environmental advantages were also appreciated. By the early 1970s,
concern about the global environment was growing and the Torrey Canyon disaster of
1967 had shown how damaging oil pollution could be. IMO was called upon to consider
the health of the marine environment and to take steps to improve it.

Load on top

When crude oil carriers discharge their cargoes, some of it is left clinging to the sides of
the tanks. These deposits have to be cleaned off before fresh cargo is loaded and in the
1950s and early 1960s the normal practice was to do so by using high-pressure hot-
water cleaning machines. The mixture of waste oil and water that resulted was then
pumped over the side.

By the late 1960s concern about the waste of oil and pollution caused by this process
led the industry to look for an alternative. The result was to become known as "load on
top."

Under this system, when the tanker departs on its ballast voyage to the loading port, it
ballasts approximately one third of its cargo tanks. A further one third of cargo tanks are
cleaned en route and the oily mixture is transferred to a special slop tank. Oil clinging to
the ballasted cargo tanks floats to the water surface during the voyage. Following this,
uncontaminated water is decanted from the bottom of these tanks at the same time as
filling the cleaned tanks with fresh ballast water. When the oil-water interface is
approached during decanting, discharge of ‘departure ballast’ to the sea is halted and
the remaining oily mixture is transferred to the slop tank, where further settling can take
place. The next cargo is then loaded on top of the separated oil. Thus only ballast water
from cleaned tanks is discharged into the sea at the oil-loading terminal.
The process has advantages for the owner of the oil, since the oil normally lost during
tank cleaning can be saved (as much as 800 tonnes of oil on a large tanker), but the
main beneficiary is the environment.

Some experts believe that without load on top, the amount of oil being dumped into the
sea as a result of tank cleaning could have reached more than 8 million tonnes a year.

Crude oil washing

The introduction of loading on top was a great contribution to the fight against marine
pollution but it did not completely eliminate pollution resulting from tank cleaning
operations. Although the amount and rate of discharge was carefully regulated, the
process still resulted in some pollution occurring.

In the late 1970s, an improvement was introduced. Instead of using water, the tank
cleaning machines used crude oil – in other words, the cargo itself. When sprayed onto
the sediments clinging to the tank walls, the oil simply dissolved them, turning them back
into usable oil that could be pumped off with the rest of the cargo. There was no need
for slop tanks to be used since the process left virtually no slops.

Crude oil washing was made mandatory for new tankers and certain categories of
existing tankers in the 1978 Protocol to the MARPOL Convention.

For product carriers, the use of dedicated clean ballast tanks are another way of dealing
with pollution. However, this does of course reduce the cargo carrying capacity.

Dedicated clean ballast tanks in product carriers

The 1978 MARPOL Protocol allows existing product carriers to operate with clean
ballast tanks (CBT) without limitation as to time. Once designated as CBT, those tanks
in product carriers are used exclusively for ballast water, but they may share the
pipework used for filling and emptying cargo tanks provided rinsing of cargo lines takes
place according to IMO’s CBT manual. This is distinct from tankers provided with
segregated ballast tanks, which must be provided with separate pipework for filling and
discharging of ballast water.

Prevention during routine operations

Most spills are small, less than seven tonnes or fifty barrels. The majority of these spills
occur during bunkering, during routine cargo operations and during Crude Oil Washing
(COW). They may also occur during ship-to-ship transfer operations.

These are controlled events, so with good planning and strict adherence to proper
procedures, the risk of spills is substantially reduced. Should there be an equipment
failure, minimizing the spill will depend on a rapid response from the deck watch and
good communications.
A Bunkering Operations

Bunkering: Prevention - Step 1 - a written plan.

A bunkering operation should be treated with the same care as a cargo loading
operation. Follow the procedures and checklists set out in your ship's manuals. Before a
bunkering operation begins:

¾Brief all officers and crew who will be involved and make sure they have access
to the plan
¾Arrange a meeting between the ship's staff and the bunker supplier to discuss the
bunkering plan
¾Make sure that nothing is overlooked. For example, activities such as cargo
operations or tank transfers which are taking place at the same time as the
bunkering. A sudden change in the ship’s trim during the bunkering operation
could be disastrous.
¾Make sure that everybody understands the units of measurement and rates of
flow
¾Agree procedures for both emergency shutting down and topping off
¾Agree a communications strategy
¾Discuss the checklist and sign it off

Bunkering: Prevention - Step 2 – before bunkering begins

¾Correctly line up the piping system

¾Close all bunker system valves and connections not required
¾Close and lash any sea or overboard valves connected to the bunker system
¾Ensure that the bunker supply personnel have checked the hoses to confirm that
they are in good condition
¾Plug all scuppers
¾Place drip trays below all connections and air vents
¾Open air vents so that the displaced air can escape freely
¾Make ready absorbent and/or adsorbent materials (sand is an effective
absorbent; provided it’s ready to hand and available in sufficient quantity)
¾Make sure that portable pumps are readily available
¾Once everything is agreed and the ship has checked the bunker tanks, make and
check the connections
¾Test lines of communication
¾When everything is secure, begin bunkering

Bunkering: Prevention - Step 3 – during bunkering

¾The Officer in charge gives the order to commence once he is certain that all the
valves to the designated tanks are open
¾Start and end the transfer at a low flow rate
¾Be aware that things can go wrong at any time. Have an action plan ready to
cope with the worst possibility
 ¾It is essential to keep a vigilant deck watch, including a regular check on the
mooring arrangements
¾Continually check all pipework and air vents for oil leaks
¾Monitor transfer rates carefully
¾Keep to the figures set out in the plan to ensure there is no over-pressurisation of
tanks
¾Keep continuous communication between ship and bunker operators, preferably
by visual, voice and radio contact. Most bunkering spills are caused, or made
worse, by a failure in the communications between the ship and the bunkering
personnel
¾Leave ample ullage space for draining the hoses
¾Make sure everyone is alert and ready to stop the procedure immediately there is
any sign of a leak. The quicker the pressure is reduced, the smaller the spill
¾Ensure that there is extra monitoring of the deck containment system when
transfer operations take place during rain. Note particularly that with scuppers
plugged, the deck can fill with water, so that any spillage will overflow quickly over
the side

Bunkering: Prevention - Step 4 – after bunkering operations are complete

¾Once topping off is complete, the disconnection procedure can begin

¾Drain all hoses before disconnection
¾Blank flange all bunker system connections as soon as the hose is disconnected
¾Securely close all fuel lines and tank filling valves
¾Perform final ullaging to confirm the quantity received and to ensure that there is
ample space for expansion

B Tanker Cargo Operations

Tanker Cargo Operations: Prevention – Step 1 – before loading cargo

¾Have a cargo loading plan

¾Make sure that absorbent material (e.g. sawdust) is readily available
¾Check that oil booms (if carried) are ready
¾Check and lash sea valves
¾Check that cargo/pumproom/bulkhead and other valves are closed (where
practicable)
¾Check that the crude oil washing system is isolated and that the line up has been
checked
¾Ensure that adequate crew will be available to control changeover of tanks etc
¾Ensure that gauging arrangements are ready
¾Ship/shore agreement of maximum loading rate and maximum working pressure
¾Ship/shore agreement on emergency stop procedures
Tanker Cargo Operations: Prevention – Step 2 – during loading of cargo

General Procedure Guidance

¾Start loading slowly into one or few tanks

¾Check that cargo is entering these tanks
¾Check for leaks
¾Check levels of all tanks (including those not being filled and those completed)
¾Check hoses, loading arms and manifolds for pressure, safe support and
absence of leaks
¾Check unused manifold blanks for leaks
¾Check overside for any signs of leakage
¾Check pumproom for signs of leakage
¾Check for absence of build-up pressure in tanks (venting system)
¾Make sure that those now on watch know the loading plan, including the
arrangements for finishing and emergency stop
¾Ensure that there are enough crew members available to control the changeover
of tanks and that they understand the procedure
¾Ensure that enough space is left in each tank after completion to allow for
draining or blowing the hoses or loading arms

Tanker Cargo Operations: Prevention – Step 3 – completion of loading of cargo

Before disconnection

¾Check that hoses/loading arms have been properly blown or drained

¾Check that manifold valves have been closed
¾Check that there is space available in the drip trays
¾Check scupper plugs, particularly at aft end of main deck

After disconnection

¾Check that hoses/loading arms were blanked or sealed before lifting overside
¾Check that ship’s manifolds were blanked
¾Check that ship’s deck lines and drip trays were drained
¾Check that tank valves (including last tank) were closed
¾Check that scupper plugs, absorbent materials etc. were stowed

Tanker Cargo Operations: Prevention – Ballasting through Cargo System

Before commencement

¾Check that the COW system has been isolated and the line up checked
¾Check that there will be adequate crew available to control changeover of tanks
etc
¾Ensure that gauging arrangements are ready
¾Check that the cargo manifold valves are closed and blanked
 ¾Check that the vacuum is on the sea suction crossover line
¾Check that the risers above the cargo pumps have been drained of oil
¾Check that the valves into the tanks have been opened
¾Ensure that the pump start procedure was discussed and agreed with the engine
room
¾Check that the sea valve is closed until the pump is started

During ballasting

¾Ensure that pumps are slowed down in good time before completion
¾Ensure that ample ullage space is left on completion to reduce the risk of
overflowing contaminated ballast

After Ballasting

¾Check that the outboard and inboard sea chest valves were closed immediately
the pump is stopped
¾Check that the tank valves were closed
¾Check the security of the venting system, the gauging systems, hatches and
sighting ports

C Crude Oil Washing

The following should not be regarded as a comprehensive checklist for COW operations.
The ship’s COW Manual will give fuller directions.

Crude Oil Washing: Prevention – Step 1 – before arrival at Discharge Port

¾Check that the tank washing pipeline system has been isolated from the water
heater and the engine room
¾Ensure that all hydrant valves on the tank washing line have been blanked and
that all valves to fixed tank washing machines have been shut
¾Check that tank cleaning lines have been pressurised and leakages made good
¾Ensure that portable drive units for fixed tank washing machines have been
tested
¾Ensure that pressure gauges on top discharge line, manifold and tank cleaning
main have been checked
¾Ensure that the stripping system monitoring equipment has been checked
¾Check that the communication system has been checked and tested
¾Ensure that the organisation plan has been drawn up and posted with the duties
and responsibilities defined
¾Ensure that the discharge/crude oil wash operation plans have been drawn up
and posted
Crude Oil Washing: Prevention – Step 2 – before Crude Oil Wash Operation

¾Check that the communication link between deck/control station and shore/control
station has been established and is working properly
¾Ensure that the crude oil wash abort condition and procedures have been
discussed and agreed by both ship and shore staff
¾Ensure that fixed and portable oxygen analysers have been checked and are
working properly
¾Check that the inert gas system is working properly and that the oxygen content
is correct
¾Check that all cargo tanks have positive inert gas pressure
¾Ensure that a responsible person has been assigned to check all deck lines for
leaks as soon as washing starts
¾Ensure that valves and lines both in the pumproom and on deck have been
checked

Crude Oil Washing: Prevention – Step 3 – during Crude Oil Wash Operation

¾Ensure that the quality of inert gas delivered is being frequently checked and
recorded
¾Ensure that all deck lines and machines are being checked often for leaks
¾Check that COW is in progress only in designated cargo tanks
¾Ensure that the pressure in the tank wash line is as specified in your COW
manual
¾Ensure that the washing machines in operation and their drive units are being
frequently checked and that they are working properly
¾Check that a responsible person is stationed continuously on deck
¾Ensure that the level in the holding tank is frequently checked to prevent any
possibility of overflow
¾Ensure that all valves between the discharge line and the tank wash line are
closed
¾Ensure that all valves to washing machines are closed
¾Ensure that the tank wash line has been drained of crude oil
¾Ensure that cargo pumps, tanks and pipelines have been properly drained as
specified in your COW manual

Prevention - Summary

The following points are essential in order to reduce the chance of an operational spill in
both bunkering and cargo operations:

¾Good planning
¾Thorough checking of equipment
¾Keeping to the correct procedures
General Prevention - Summary

Although attention to careful strategies for preventing routine oil spills is very important,
it is equally important to be aware of all of the potential causes of oil spills; including
poor navigation, inadequate voyage planning, stress and fatigue.

Section 2

PREVENTION AND REACTION TO MARINE OIL SPILLS UNDER OPA 90

Glossary of selected terms used in OPA 90

Area - that geographic area for which a separate and distinct Area Contingency Plan
has been prepared, as described in OPA 90.

Area Spill Management Team - the group of individuals within the Coast Guard or
Environmental Protection Agency (EPA) On-Scene Co-ordinator (OSC) organisation
with responsibility for spill response management within the respective area. It should
include state and local personnel whenever possible.

Average Most Probable Discharge

¾For Coast Guard regulated OPA 90 vessels, a discharge of 50 barrels of oil from
the vessel during oil transfer operations
¾For Areas, the size of the discharge as defined in the Area Contingency Plan.

Certification - the act of confirming that an exercise:

¾Was completed
¾Was conducted in accordance with the PREP guidelines, meeting all the
objectives listed
¾Was evaluated using a mechanism that appraised the effectiveness of the
response or contingency plan.

Command Centre - is a centre where expertise can be pooled and a shared approach
taken to reduce the impact of the spill. It is set up as close to the scene of the spill as
possible.
The personnel are those who will now take over the management response. This is the
nerve centre of the operation, where all activities associated with the spill and clean up
are co-ordinated.
Equipment Deployment Exercise - an exercise where response equipment is
deployed to a specific site and operated in its normal operating medium.

Exclusive Economic Zone (EEZ) - the zone from the shoreline of the United States out
to 200 nautical miles or to the international boundary of another national state where
such distance is less than 200 nautical miles

EPA - Environmental Protection Agency

Maximum Most Probable Discharge

¾For Coast Guard regulated vessels –
o A discharge of 2,500 barrels of oil for vessels with an oil cargo capacity equal
to or greater than 25,000 barrels
o 10 per cent of the vessel's oil cargo capacity for vessels with a capacity of less
than 25,000 barrels

National Response Centre - situated at US Coast Guard HQ in Washington DC, this is

the notification point for the Federal Government for any oil spill inside US waters (i.e.
within the EEZ)

National Response System - this includes:

¾ The National Response Team
¾ Regional Response Teams
¾ On-Scene Coordinators
¾ State and local Government entities involved with response planning and
coordination

The Preparedness for Response Exercise Program or PREP (see below), consistent
with OPA 90 objectives, specifically involves the private sector with the NRS in order to
ensure effective exercise development, delivery and coordination.

OPA 90 Vessel – a vessel carrying oil in bulk as cargo

Oil Spill Removal Organisation (OSRO) - this is a body that provides response
resources. These will be contracted by the Plan Holder to cope with the various
categories of oil discharge as specified under OPA '90. The term of the required contract
is not mandated by OPA ‘90 or the regulations. The contract simply must be binding
(quid pro quo) but its terms could be monthly, annually or of an other length agreed
upon by the parties.

On-Scene Coordinator (OSC) - (also referred to as the Federal On-Scene Coordinator

(FOSC)). The USCG Captain of the Port or their nominee will take on this role. The OSC
is the federal official predesignated by EPA or the USCG prior to the oil spill. This
official's duty is to coordinate and direct federal resources and to coordinate and direct
removal operations.
Plan Holder - this is the organisation for which a response plan is required. The
organisation can include vessels, MTR facilities, onshore and certain offshore non-
transportation related facilities, pipelines or offshore facilities. The vessel or facility's
owner or operator must submit the response plan. The plan holder is any owner or
operator who is required to have a Vessel Response Program (VRP) approved by the
Coast Guard, whether it is for a fleet or for a single vessel

Preparedness for Response Exercise Program (PREP) - this represents the minimum
guidelines for ensuring adequate response preparedness. It was developed to provide a
mechanism for compliance with the exercise requirements, while being economically
feasible for the government and oil industry to adopt and sustain.

¾The PREP Plan holders are responsible for addressing any issues that arise from
evaluation of the exercises, and for making changes to the response plans
necessary to ensure the highest level of preparedness.

¾It is the responsibility of the plan holder to ensure that the Emergency Procedures
exercise is conducted. If a plan holder has a fleet of vessels covered by one
response plan, the plan holder must ensure that each vessel in the fleet conducts
this exercise. Since vessels do not always sail with the same crews, it is
important that each vessel conducts this exercise quarterly to ensure that the
personnel on board are familiar with the procedures for mitigating a spill occurring
from that vessel.

¾It is the responsibility of the plan holder to ensure that the Qualified Individual
Notification exercise is also conducted

Qualified Individual (QI) - this is the person located in the United States who meets the
requirements identified in the respective federal regulations. The QI must speak fluent
English and be available 24 hours a day. The QI will be the individual or designee
identified in the response plan. The QI is authorised to do the following:

¾Activate and engage in contracting with oil spill removal organisations

¾Act as liaison with the On-Scene Coordinator
¾Obligate the necessary funds for effective response activities.

Regular notification exercises with the QI are mandatory.

Response Manager - this is the individual in the Spill Management Team who is
designated to manage the response to the oil spill. This function may be accomplished
by the Qualified Individual or undertaken by an additional party.
Responsible Party - this is any person owning, operating or demise-chartering the
vessel concerned.

Self-Certification - this is where the plan-holder declares that he or she has met the
following standards:
¾Completion of the exercise
¾Conducting of the exercise in accordance with the PREP guidelines, meeting all
the objectives listed
¾Evaluation of the exercise using a mechanism that appraises the effectiveness of
the response or contingency plan.

Self-Evaluation - this means that the plan holder is responsible for carefully examining
the effectiveness of the plan for response during the exercise. The plan holder:
¾May choose the mechanism for conducting this appraisal, as long as it carefully
measures the plan's effectiveness
¾Is responsible for addressing issues that arise in the exercise that would lead to
improvements in the response plan or any aspect of preparedness for spill
response
¾Is responsible for incorporating necessary changes to the response plan as a
result of the exercise.

Tabletop Exercise - for the purpose of the PREP, this is an exercise of the response
plan and the spill management team's response efforts. It will not involve the actual
deployment of response equipment.

Unified Command - this is a command structure consisting of:

¾The On-Scene Coordinator
¾The State
¾The Responsible Party
The Unified Command is used during a spill response to achieve the coordination
necessary to carry out an effective and efficient response.

Verification - this is the act of ensuring that an exercise was properly documented and
certified. Verification of the exercise records may be conducted through inspections,
boarding, spot checks, or other systems developed to ensure that exercises are being
conducted and properly documented.

Vessel - for the purpose of the PREP, a vessel is any vessel required to submit a
response plan. It includes unmanned barges.

Vessel Response Plan (VRP) - This is the response plan of the ship that fulfils the
requirements of the OPA 90 regulations. It will need to have been approved and filed
with the US Coast Guard and will need to be reviewed regularly.
Worst Case Discharge - this differs according to the agency involved:
¾For Coast Guard regulated vessels, a discharge in adverse weather conditions of
a vessel's entire cargo as defined in 33 CFR 155.1020
¾For Coast Guard regulated facilities, the size of the discharge as defined in
33CFR 154.1020. (In the case of an on-shore facility and deepwater port, the
largest foreseeable discharge in adverse weather conditions meeting the
requirements of 33 CFR 154.1029).

What is the OPA 90 Vessel Response Plan?

The Vessel Response Plan (VRP) is a response plan required for all vessels carrying oil
in bulk as cargo. The VRP must identify the Qualified Individual; identify the availability
of the resources necessary to respond to cargo spills and define the procedures by
notifications and mobilizations, which will be made for all of the areas in US waters
where the vessel may trade.

In United States waters one of the consequences of an oil spill is that criminal and civil
proceedings can be brought against the shipping company and the personnel involved.
Unlike most countries, where governments take responsibility for the clean-up, under
OPA 90, the clean-up must be carried out by the organisation, which spilled the oil, or is
taking responsibility for the consequences of the spill. Under OPA 90, this organisation
is known as the ‘responsible party’.

The response to any spillage of oil in United States waters, be it petroleum or animal or
vegetable oil, will be governed by OPA 90, the Oil Pollution Act of 1990.

The OPA 90 Vessel Response Plan will be always be in English. There may be copies in
other languages. It will contain at least ten sections dealing with the following topics:

¾general information about the ship

¾notification procedures and contact numbers
¾onboard spill mitigation procedures
¾shore based response activities
¾a list of contacts
¾training procedures
¾drill procedures
¾plan review and update procedures
¾specific information for each US Coast Guard Zone
¾an appendix for vessel specific information

Depending on when this information was prepared, it may not be divided into ten clear
sections in your vessel plan, but all the information will be included. However, for Vessel
Response Plans prepared after the effective date of the regulation, the sections must be
divided and must be presented in the order specified by the regulation.
Failure to follow the procedures in it can lead to penalties and the loss of limits of
liability.

The OPA 90 Vessel Response Plan will be consistent with the ship's MARPOL SOPEP,
but will contain additional information on the shore based organisations and individuals
that are named in it. Some states have requirements that are more rigorous than those
defined in OPA 90. The plan is complex and does need study.

USCG information on recent changes to OPA 90

When asked what products are considered oils for OPA 90, the USCG answer was that
the Federal Water Pollution Control act served as the defining reference for oils. The
most common are the various petroleum oils, but OPA 90 regulated oils also include
non-petroleum oils such as turpentine and various animal and vegetable oils when
carried in bulk. For further information see http://www.uscg.mil/vrp/oil.htm

Preparedness for Response Exercise Program - PREP

Most companies will participate in the Preparedness for Response Exercise Program or
PREP. PREP is a program which fulfils OPA 90 requirements.

Exercises must be carried out quarterly under the PREP guidelines. Some of these
exercises may be confined to the ship, but once a year there must be a full scale
exercise to test both the ship’s and shore-based emergency response capabilities.

No plan, however good, will be any use in an emergency unless everyone on board is
familiar with their role and has participated in drills.

OPA 90 regulations define the frequency and type of these drills. Some are self-
evaluated and self-certified, which allows the shipboard staff the flexibility to design ship-
specific exercises. A ship may also be ordered to participate in unannounced exercises
by the US Coast Guard Captain of the Port.

Internal Exercises

Internal exercises are those that are conducted wholly within the plan-holder's
organisation. They are designed to examine the various components of the response
plan. They will test the plan and make sure it is adequate to meet the needs of the
organisation for spill response. The exercises include:

¾qualified individual (QI) notification exercises

¾emergency procedures exercises for vessels and barges
¾emergency procedures exercises for facilities (optional)
¾spill management team tabletop exercises
¾equipment deployment exercises
In addition, each plan-holder should ensure that one of the following exercises is
conducted unannounced:

¾emergency procedures exercises for vessels and barges

¾emergency procedures exercises for facilities (optional)
¾spill management team tabletop exercises
¾equipment deployment exercises

Providing it was evaluated, the response to an actual spill can count as an unannounced
exercise.

External Exercises

External exercises are those that involve other members of the response community.
They are designed to examine how well the response plan and the plan-holder can
coordinate with the response community in the event of a pollution incident. They will
test the effectiveness of such a response. The exercises include:

¾area exercises
¾government initiated unannounced exercises

A ship may also be asked to participate in unannounced exercises by the US Coast

Guard Captain of the Port. These exercises are infrequent, no more than four per port
area per year.

Example of an on-board emergency procedures exercise

This type of exercise must be carried out quarterly under the PREP guidelines. It is
important that each exercise is planned with a specific training objective.

Here the objective is to try out the ship and shore based emergency response
capabilities following a simulated collision with a barge.

This will take place in an environmentally sensitive area, the Delaware Bay, where ships
usually lighter before unloading at the terminal.

The exercise will involve the company's emergency response team at Head Office and a
‘Unified Command’ set up at the scene of the spill.

Training - Step 1 Starting the exercise

¾the Master informs the barge that the exercise is to begin

o NB the difference between OPA 90 (with VRPs) and MARPOL (with
SOPEPs): Under MARPOL, the vessel operator has the duty to notify and
then deal with problems on board. The authorities will normally deal with
the spill. Under OPA 90, the vessel must notify and deal with the spill while
under surveillance by the authorities.
¾the first action is to sound the ship's emergency alarms. The General Emergency
Signal gets everyone working to a system. This pulls together the ship's company. In
a real emergency, there would be a few minutes of uncertainty as everyone tries to
find out what has happened.

Training - Step 2 First notifications

When giving notification to the various bodies, senior officers should never be
tempted to underestimate the size of the spill, as this could compromise the
response.

¾once he has assessed the situation the Master must, under OPA 90, first notify the
National Response Centre, the NRC, in Washington D.C. This must be the first
notification. It must be done by telephone, even before calling head office or anyone
else

The Response Plan contains a standard form for reporting to the NRC. This will
include:

¾the ship's position

¾type of ship
¾type of product
¾the quantity at risk
¾the type of incident

Notify the NRC immediately even if all the information is not yet available. They
will usually notify the nearest Coast Guard Captain of the Port, although the
responsibility to do so remains that of the Responsible Party. The Responsible
Party is the organisation which had the spill or is taking responsibility for
responding to the spill. For ship board spills, this will generally be the ship's
operator or owner

¾the next to be informed is the vessel QI, the Qualified Individual. The QI is a central
figure in any OPA 90 spill response:
¾ the QI is employed by the operator and has the authority to activate the
contracted oil spill removal organisations (OSRO's) as specified in the Vessel
Response Plan. This provides the QI with immediate contact numbers.
¾ the QI must be resident in the US and available twenty-four hours a day
¾ the role of the QI is to initiate the first response
¾ the QI must speak fluent English
¾ the QI has the power to obligate funds for the clean-up
¾ the QI will make the first call to the Coast Guard’s local office and then establish
the command centre at the scene of the spill
 ¾
the QI may either be the ships’ managers (as in the exercise shown on the video
– where the managers have been trained and designated as the QI) or could be a
separate contractor or a specialist from the company’s head office
¾
the QI will need honest and reliable information about what’s happening on the
ship. This will enable him to activate the available resources to minimise the
effects of the spill.

¾once the initial work is completed, the QI may travel to the command centre to join
the spill response team. He may remain responsible for the company’s spill
response but, in this case, the QI will transfer that responsibility to an ‘On Scene
Incident Co-Ordinator’ but will remain on hand if needed
¾the Coast Guard Captain of the Port is the designated Federal On-Scene Co-
ordinator. Once notified, he may also travel to the command centre. Here again, the
head office team will remain on hand to give advice and support.
¾once on board, this officer will be the liaison between the ship and the command
centre
¾at the ship operator’s headquarters, the emergency team is assembled. They will
manage the response until the key personnel involved in coordinating the clean-up,
have reached the command centre. Here again, the head office team will remain on
hand to give advice and support
¾it is likely that the Captain of the Port will send an officer to be the Federal On-Scene
Co-ordinator representative on the ship. The FOSC Rep will get to the ship quickly
by whatever means necessary
¾the Master will probably remain on the bridge to supervise all activities on the ship

¾the Coast Guard will have their own list of people to notify including environmental
organisations
¾ in a real incident it is possible that the cargo owner or terminal will set up their
own additional Response Teams
¾ the Coast Guard will usually set up a Field Command Post near to the incident
¾ if the ship's operator is based outside the United States they will set up the Spill
Management Team at their head office
¾ their QI may also have his own response organisation in the United States. So
the response organisation may span continents and time zones. Substantial
resources will be required to manage a spill and its long-term clean up.

¾on the ship, the process of notification continues. Having called the NRC and the QI,
the Master can delegate further notifications (as listed in the plan) to the officer
handling communications. Conversation need to be as clear, concise and as brief as
possible.
¾a record must be kept of all these notifications
Training - Step 3 Assessing the damage

¾the Ship's response teams will now have a better idea of the extent of the damage to
the hull and the leakage of cargo.
The exercise scenario calls for minor damage to the ship, resulting in a spill of
about 250 tonnes1. This is in the range of a 'Maximum Most Probable Spill'
(MMPD) under OPA 90 and requires a full scale response
¾the barge is relatively unscathed. There are no injuries on board and no visible
rupturing of the empty tanks
¾although there is no fire, a team stands by with fire fighting equipment, as in any
collision the risk of fire is always present
¾all tanks, both cargo and ballast tanks, especially those near the collision area, will
need to be regularly ullaged to determine the extent of damage and of oil loss to the
sea. This is done using the ship’s automatic ullaging system and confirming the
results manually
¾in the engine control room the officers are checking that there has been no damage
to any equipment

Training - Step 4 Preventing further damage

¾as the tanks have leaked, inert gas will need to be introduced to keep the tanks fully
inerted
¾water may be needed on deck for fire fighting
¾in a real emergency it may be necessary to close air vents to the engine room and to
close sea water intakes

Training - Step 5 Action on shore

¾the command centre is set up as close to the scene of the spill as possible. It is a
centre where expertise can be pooled and a shared approach taken to reduce the
impact of the spill. These are the personnel who will now take over the management
response. This is the nerve centre of the operation, where all activities associated
with the spill response are co-ordinated. The command centre will include:
¾ the responsible party, represented by the QI or his representative
¾ the State representative
¾ the clean up contractors
¾ environmental organisations
¾ other government organisations
¾ the ship’s agent, cargo owners and the P & I club may also participate.
¾ It is likely that the command structure will operate in clearly defined sections:

1
To find a rough guide of the number of barrels (US measurement) divide the number of
tonnes by 7.
 ¾
Planning
¾Will co-ordinate and distribute information concerning the actual and
forecast condition of the spill
¾ Give information on the status of resources
¾ Co-ordinate the preparation of the ‘incident action plans’
¾
Operations
¾responsible for the management of all tactical operations required to
execute the company’s emergency response plan
¾this will include supervising the clean up operation carried out by the
OSRO: the designated Oil Spill Response Organisation
¾
Logistics
¾Obtain manpower, equipment, material, food, protective clothing and
other facilities needed to support the emergency response
¾
Finance
¾Handle compensation claims
¾Take responsibility for all financial and cost analysis aspects of the
response

¾a ‘joint information centre’ will be set up in the command centre. This is where
anyone can have access to coordinated up-to-date information regarding the nature
and status of the response operation
¾The ‘Unified Command’ takes responsibility for the overall management of the
response. The Unified Command provides the basis for joint decision making at the
highest level. This group is kept small in number to facilitate decision making. It is
supported by a team which will manage communication with the ship, outside
agencies and the media. This brings together representatives of three parties:

¾Federal authorities represented by the US Coast Guard

¾State authorities
¾The Responsible Party represented by the incident commander

Training - Step 6 Communications established

¾the FOSC Rep arrives on the ship to provide a direct link to the Unified Command.
The Coast Guard alone have a legal right to be on board. Other organisations may
seek to gain access to the ship to offer their advice to the Master, but no-one should
be let on board with out the owner's permission.

Training - Step 7 Action on-board

¾on deck the situation has stabilised. The ship has acted promptly to mitigate further
spillage, but there is little that they can do about the oil already in the water except to
monitor its movement
¾ullaging indicates there may be more than one tank leaking. What can now be done
to ensure no further discharge?
¾trying out the ship's facilities for damage assessment and emergency lightering is
one of the drill’s specific objectives and to exercise the liaison between the ship and
the shore
¾as long as the incident is being handled properly, the Coast Guard will observe and
monitor the clean up, doing what they can to help
¾lightering the cargo from the tanks nearest to the damaged area seems a good idea
to both the Master and the Coast Guard. The barge involved in the collision is
relatively undamaged and can be used for lightering, but they will need to seek
advice first to confirm the safety of this operation
¾the Officer handling communications brings the Unified Command up to date

Training - Step 8 Action on shore

¾at the Command Centre, it is decided to obtain accurate stability information from
the team at Head Office. Here, they have access to damage stability data services
to confirm that transferring cargo will not further damage the ship or cause further
spillage. Providing this engineering expertise is just one example of the key support
role played by the Head Office team.
¾they link up with the classification society for stability calculations. This computerised
service already has all the ship’s data input and can provide advice rapidly
¾the Coast Guard Officer talks to the On-Scene Co-ordinator at the Command
Centre.
¾the Unified Command there does not stay in constant session, but may meet
separately with the section chiefs, depending on circumstances

Training - Step 9 Action on-board

¾on the ship the emergency lightering equipment is made ready during the time the
stability calculations are being made
¾the engine room is informed. They already have the inert gas system operational
and ready for use
¾the automatic ullage system is watched carefully to ensure that there is no damage
to lines or valves that might lead to slow leaks. Using this system the temperature
and pressure in each tank can be monitored
¾by now the precise amount of oil lost is calculated and relayed to the bridge.
¾the ship notifies the Unified Command.
¾the engineering department are now getting ready the cargo pumps. They are
keeping a close watch on the IG pressure

Training - Step 10 Action on shore

¾at Head Office, the damage stability calculations have been made and the advice is
that the proposed lightering will pose no increased risk to the hull or cargo, hence it
can go ahead
¾the Unified Command is immediately informed
NB Communications are the most important thing for those organising and co-
ordinating the response. Conversations need to be clear, concise and as brief as
possible.

¾with the lightering plan approved, the Unified Command assembles to confirm that it
is in the best interests of all parties
¾formal agreement is sought for the lightering which has already been discussed
informally in meetings outside
¾the Federal On-Scene Commander gives the decision to go ahead and the ship is
informed
¾all decisions and communications are logged by a clerk at the Unified Command

Training - Step 11 Action on-board

¾all decisions and communications must also be logged on the ship. These records,
of who said what to whom and when, are useful during an incident and invaluable
afterwards. Charts with any notes or plots, as well as cargo arrangements and other
relevant paperwork must all be kept
¾the Officer handling communications talks to the Master.
¾the Master then gives the order to start the lightering
¾the exercise objectives have been achieved. The FOSC Rep calls the Captain of the
Port
¾the Captain of the Port agrees that the exercise should be concluded
¾the Master thanks everyone and stands them down
¾the Unified Command at the Command Centre and the team at head office are
notified and thanked
¾there is a debriefing session on ship and on shore for all those who are available
and have taken part in the exercise
¾in a real incident involving shoreline clean-up, it is possible that these organisations
would need to stay operational for several months

General conclusions
The liabilities involved in any pollution incident are so huge now that it is impossible for
one individual to call the shots.

¾On the ship the Master is on the scene and knows the ship. But unless he
has serious concerns for safety, he will follow the advice he receives from
the command centre. The liabilities involved in any pollution incident are so
huge now that it is impossible for one individual to call the shots
¾The experts and authorities ashore make suggestions and
recommendations. They need to approve any major operation, such as
transferring cargo or moving the ship
¾Things may change quickly in any incident and the Unified Command must
be kept up to date with the situation
 ¾The Master should stay on the bridge and follow the communications plan,
otherwise he risks becoming the communications bottleneck for the entire
operation

If the Responsible Party accepts responsibility for the spill and the clean up, the
Coast Guard will integrate themselves into the company system. They will make
sure that the response is appropriate to the NCP; the National Oil and Hazardous
Substances Pollution Contingency Plan, and in the best interests of all parties.
Only if asked, or if they think things are getting out of control, will they take over.

Only if asked, or if they think things are getting out of control, or if the
Responsible Party is reluctant to accept responsibility will the Coast Guard take
over.

The results of the exercise

Soon afterwards there is a formal debriefing. All aspects of the exercise are analysed.
The Response Plan holder has completed its quarterly emergency procedure exercise
under the PREP program.

Responding to an oil spill under OPA 90 may appear complex, but exercises like these
should be as familiar as lifeboat drills to those on board tankers operating in US waters

There is no substitute for good training, and the exercise program associated with OPA
90 ensures that in the moments when things do go wrong, everyone on board will know
what needs to be done.