Environmental Issues Associated with Response Activities March 20, 2014
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Environmental Issues Associated with Response Activities
March 20, 2014
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Oil Spill - Two Distinct & Parallel Activities
Panel
Lawrence D. Malizzi, P.G Matrix New World Engineering, Inc., Wilmington, DE
Commander Ed BockUnited States Coast Guard, Washington, DC
Harry DiamondWater Quality Insurance Syndicate, New York, NY
William HazelMarine Pollution Control, Detroit, MI
Rhonda MurgatroydWildlife Response Services, LLC, Seabrook, TX
Robert Simmons, PEEnvironmental Science Services, Inc., Denham Springs, LA
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The “E” Word!
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The Two Most Frightening Words on a Spill Response:
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SPILL CONTROL ASSOCIATION OF AMERICA ANNUAL MEETING
MARCH 20 & 21, 2014
Office of Marine Environmental
Response Policy
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Environmental Consultation Requirements
Endangered Species Act (ESA) Section 7Essential Fish Habitat (EFH)National Historic Preservations Act (NHPA)Tribal – Executive Order 13175
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Office of Marine Environmental Response Policy
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ESA Section 7 Policy – Current State
The 2001 Interagency MOA provides guidance for ESA consultations.
MOA is used to identify & incorporate plans & procedures to protect listed species & designated habitat during spill planning & response activities
Signatories include USCG, EPA, DOI, Fish & Wildlife Service, NOAA’s NMFS & National Ocean Service (NOS)
Contains Purpose, Definitions, Procedures, & Planning Templates
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Office of Marine Environmental Response Policy
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ESA Section 7 Policy – Current State
The MOA states that the consultation process should be initiated and managed at the Area Committee level (i.e. where the action is planned).
Due to recent litigation the need for consultations during RRT & Area Committee planning is being reemphasized.
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Office of Marine Environmental Response Policy
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Regional Status
AK Region: Regional biological assessment (BA) update complete, awaiting concurrence
Region IX: California Dispersant Plan BA complete, awaiting concurrence
Region VI: Awaiting Deepwater Horizon BARegion IV: ESA &EFH dispersant pre-authorization
consultation out of date & needs EFH informationRegion III: Significant ACP updates with informal
consultation, awaiting concurrence
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Office of Marine Environmental Response Policy
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ESA Section 7 Policy – Future State
CGHQ released a policy letter in October to explain Section 7 & EFH consultation responsibilities
CG roles & responsibilities:Co-Chair: Assembles experts to assist OSCRRT Coordinator: Manages work & keeps group informedDRAT: Advises on response strategiesFOSC: Coordinates local planning & responseSSC: Provides scientific advice on response strategies, oil
fate and affect on endangered species
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Office of Marine Environmental Response Policy
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ESA Section 7 Policy – Future State
Cooperation & coordination between the FOSCs & Services is key
RRTs & Area Committees may consider using ERA Workshops to develop appropriate response strategies as part of the ESA consultation process
ESA Section 7 Toolkit include:Located on the MER Portal MOAArea Contingency Plan Job AidBest Management Practices Database
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Office of Marine Environmental Response Policy
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Way Forward
National Strategy Cooperation & collaboration among agencies & services High-visibility plans are a top priority Follow MOA & Policy All ESA Consultations Current by 2018
Continue to Clarify GuidanceProvide Technical & Legal Assistance Training Opportunities at CGHQ & USF&WConsider Updating the MOA in the Out Years
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Office of Marine Environmental Response Policy
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Training Resources
U.S. Fish & Wildlife Service National Conservation Training Center Interagency Consultation for Endangered Species 4-day course, offered every few months http://training.fws.gov/nctcweb/catalog/CourseDetail.aspx?
CourseCodeLong=FWS-CSP3116
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Office of Marine Environmental Response Policy
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Thank-you for your time
Stewards of the Environment and Public Trust
Questions
Office of Marine Environmental Response Policy
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HARRY DIAMONDVice President, Claims
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An Insurance Company View of Environmental Response Impacts
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The Insurance Company Interest is Largely Financial
We are not out to make every response as inexpensive as possible
We make long term profits by paying fair and reasonable claims
We don’t skimp on environmental responsibility
However:
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Who Pays for Raising This Vessel?
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Claims by the Numbers
We handle about 100 to 150 claims per year. We have about $4 M to $6 M in claims per
year. Claims that exceed our coverage limit are rare,
about one every 2 – 3 years on average The average claim costs about $50,000 Claims can generally be closed in one year or
less WQIS claims that go into litigation are rare
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Claims Involving Natural Resource Damage
For us these are rare.
Usually happen in the larger claims
These claims are not just pollution claims so often other underwriters are involved.
Most WQIS spills are minor in nature, do not involve hazardous products and do not involve a Natural Resource Damage Assessment
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EVERY RESPONSE HAS THE POTENTIAL TO CAUSE ENVIRONMENTAL DAMAGE
Decisions made in the initial response to a spill or threat of a spill can have significant impact later on in the event
It is critical to bring the right team to the spill to prevent causing environmental damage in the response.
This is why WQIS sends a Spill Response Manager to every spill no matter how small.
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Biggest Problems Occur When Underwriters Have Divergent Interests.
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Takeaway
The key point is that the Insurance stake holder should be involved early in the decision making process at the command center.
Should be kept in mind that the insurance stakeholder is usually not just one party.
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Environmental ConsiderationsDuring Oil Spill Response Operations:
An OSRO’s Perspective
Presented:Spill Control Association of America (SCAA) Annual Meeting
Bill Hazel – Director of Marine ServicesMarine Pollution Control
Detroit, Michigan USAMarch 20, 2014
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SpillEvent
ResponseTactics
EnvironmentalImpacts
BestResponse
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Principles, mechanisms and systematic processes used to evaluate and guide the environmental
aspects of spill response operations:
Best Response Principles (ICS-based)
Sensitivity Indexes (ESIs) and Geographic Response Plans (GRPs)
Net Environmental Benefit Analysis (NEBA)
Shoreline Cleanup Assessment Technique (SCAT)
Natural Resources Damage Assessments (NRDA)
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Principles of Best Response(from SE Michigan Area Contingency Plan)
Generalized protection priorities:
Priority 1 – Protection of public health & safetyPriority 2 – Ecological
Priority 3 – CulturalPriority 4 – Economic
Priority 5 – Social
Priority classes:
A = Highest PriorityB = Protect after AC = Protect after B
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CASE STUDY:Tug Boat Seneca – Deer Park, MI – December 2006
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Seneca Operations/Ecological Considerations:
Begin from expectation that the response activities will cause ecological damage
Specialist biologist contracted to develop an access plan and 4-stage site restoration plan:
1. Rebuilding of primary dune and level beachfront2. Evaluation of area following winter months3. Replanting native vegetation after winter months4. Evaluation following the next growing season
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Seneca Operations/Ecological Tactics:
Limit damage by restricting travel to specific routes
Utilize “light-footprint” logistic assets
Perform as many actions as possible on water
Communicate access/restoration plan to responders
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Recommendations:
NEBA and Best Response concepts should be conveyed to field response personnel through periodic training initiatives and through daily communications processes during incidents
Drills and exercises should incorporate injects that test NEBA and Best Response concepts
NEBA and Best Response concepts should be applied to GRP processes based on lessons derived
from drills and exercises
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WILDLIFE RESPONSE WITH A FOCUS ON NRDA
DOCUMENTATION
Spill Control Association of America20 March 2014
Presented by: Rhonda MurgatroydWildlife Response Services, LLC
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Wildlife Response“Back In The Day”
Mobilize Where – I Need A Place to Set Up Wildlife CenterAre Response Trailers On The Way?
Which Responders Are Mobilizing (Even this has changed with more response activity away from coast).
Who Am I Working For (RP)What Is The Trajectory? This Will Give Me A Good Idea
of Wildlife Concentrations.
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Wildlife Response“Back In The Day” cont.
Have Oiled Animals Already been sited?Are Wildlife Trustees Already Engaged? Contacts?Resources Available (Wildlife Supplies, Boats, Vans,
Lodging)WRS Documentation, Surveys, Capture, Rehabilitation,
Carcass Collection, Hazing, Relocation and Pre-Emptive Capture
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Wildlife Response“The Here And Now”
All WRS Documentation Merging With . . . .Wildlife Trustee Specific Forms [e.g., Evidence Storage
Log, Oiled Bird Intake Form, Wildlife Branch Daily Asset Report, Live Oiled Animal Data Log, Wildlife Branch Daily Report Form (to populate 209), Carcass Collection Documents, Field Survey Log (photos, GPS coordinates and tracks)].
Wildlife Rehabilitation Personnel Are Writing More Plans (field mobilization, communications, hazing, hacking, release, severe weather, trapping, relocation), the list goes on – we don’t just “do it” any longer.
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Wildlife Response“The Here And Now” cont.
Photo Documentation Becoming More Labor Intensive (being looked at closer).
All Data To Be Entered Into Excel Spreadsheets For Future Use.
Wildlife Responders Becoming More Engaged In Overall Incident.
This Is A Positive Move For Both Trustees And RP’s; Just More Labor Intensive For Us, Requiring Additional Personnel.
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Wildlife Capture
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Spacious Wildlife Facility
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Rehabilitation Center
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Bath Time
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Husbandry/Medical Care
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Outside Flight Pen
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Wild Again
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Questions?
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Spill Control Association of America2014 Annual Meeting
Panel Session: Environmental Issues Associated with Spill Response
Topic: Role of the Environmental Unit (EU) and Interaction with Operations
Robert A. Simmons, P.E.President, Environmental Science Services, Inc.
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Overview
• Importance of EU Interaction with Ops• Minimizing collateral damage and
additional cost and liability for the RP• As a Practical Matter - How this interaction
works in the ICS• Experience factor of EU personnel
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Minimizing collateral damage and additional cost / liability for RP• Appropriate Cleanup techniques
–When this is obvious or intuitive–When this is not obvious or intuitive–Determining and assessing cleanup
methodology and endpoints• Identification and coordination with Ops
relative to sensitive resources (RAR)
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Minimizing collateral damage and additional cost / liability for RPContinued
• Implementation and monitoring of results of ESA section 7 consultation When Necessary (Federal Requirement)
– BMPs– Buffer zones– Modification of cleanup methodology– Formality or informality depending on
circumstance of spill and response
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• Implementation and monitoring of NHPA section 106 consultation When Necessary (Federal Requirement)
– Archaeologists or cultural resources experts, SHPO, DOI
– Secretive nature of some cultural resource issues
– Formality or informality depending on circumstance of spill and response
Minimizing collateral damage and additional cost / liability for RPContinued
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Minimizing collateral damage and additional cost / liability for RPContinued
• Endpoints, “How Clean is Clean”• Net Environmental Benefit Assessment
(NEBA)– Informal approach– Formal approach
• NRDA Considerations
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As a Practical Matter - How this interaction works in the ICS
• Starting Point might be ICS 232 – Resources at Risk
• Planning Section specific EU links with Ops– Wildlife– Dispersants– Insitu Burning– Other
• Agency Coordination and Documentation
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As a Practical Matter - How this interaction works in the ICS - CONTINUED• SCAT• Relationship between Planning and
Operations Section–More than just thru the IAP–Establishing awareness–Navigating thru the “Us and Them”
Mentality• Other EU presence in the field
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As a Practical Matter - How this interaction works in the ICS - CONTINUED
• Experience factor of EU personnel and Operational Familiarity• Reactive approach• Proactive approach
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End of Presentation
Robert A. SimmonsEnvironmental Science Services, Inc. (Es²)
Cell: (985) [email protected]
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Thank You
Questions