Report to the Legislature on Columbia River Vessel Traffic ...advisory company. DNV GL’s role was...

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Report to the Legislature on Columbia River Vessel Traffic Evaluation and Safety Assessment (CRVTSA) November 2017 Publication no. 17-08-010

Transcript of Report to the Legislature on Columbia River Vessel Traffic ...advisory company. DNV GL’s role was...

Page 1: Report to the Legislature on Columbia River Vessel Traffic ...advisory company. DNV GL’s role was to evaluate spill risks for oil1 transported on vessels as bulk cargo (cargo oil)

Report to the Legislature on

Columbia River Vessel Traffic

Evaluation and Safety

Assessment (CRVTSA)

November 2017

Publication no. 17-08-010

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Publication and Contact Information

This report is available on the Department of Ecology’s website at https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html For more information contact: Spill Prevention, Preparedness, and Response Program P.O. Box 47600 Olympia, WA 98504-7600

Phone: 360-407-6251

Washington State Department of Ecology - www.ecy.wa.gov o Headquarters, Olympia 360-407-6000 o Northwest Regional Office, Bellevue 425-649-7000 o Southwest Regional Office, Olympia 360-407-6300 o Central Regional Office, Yakima 509-575-2490 o Eastern Regional Office, Spokane 509-329-3400

Accommodation Requests: To request ADA accommodation for disabilities, or printed materials in a format for the visually impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech disability may call TTY at 877-833-6341.

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Report to the Legislature on Columbia

River Vessel Traffic Evaluation and

Safety Assessment

Prepared by DNV GL for

Washington State Department of Ecology

Spill Prevention, Preparedness, and Response Program

Olympia, Washington

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Table of Contents Page

List of Figures and Tables.................................................................................................. ix

Figures.......................................................................................................................... ix

Tables .............................................................................................................................x

Executive Summary .............................................................................................................1

Background ..........................................................................................................................6

Study Requirements .......................................................................................................6

Methods..........................................................................................................................6

Scenario Workshop – October 6, 2016 ..................................................................9

Risk Analysis of Cargo Oil Spills for the Three Traffic Cases .............................9

Risk Results and Mitigation Workshop – January 25, 2017 ...............................10

Analysis of Potential Risk Reduction Measures .................................................11

Best Achievable Protection Workshop – February 23, 2017 ..............................11

Development of Recommendations – March 21, 2017 .......................................11

Evaluation Assumptions and Limitations ....................................................................12

Columbia River Vessel Traffic ..........................................................................................14

Baseline Traffic ............................................................................................................15

Potential Future Traffic ................................................................................................17

Modeled Traffic Cases .................................................................................................19

Existing Safety Measures ...................................................................................................20

Government Oversight .................................................................................................22

International Maritime Organization ...................................................................22

U.S. Coast Guard .................................................................................................22

Pilotage ................................................................................................................22

Washington State Department of Ecology ..........................................................24

Oregon Department of Environmental Quality ...................................................25

Industry Standards and Practices .................................................................................25

Classification Societies ........................................................................................25

American Petroleum Institute ..............................................................................26

American Waterways Operators ..........................................................................26

Towing Vessel Company Practices .....................................................................26

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Merchants Exchange of Portland, Oregon ...........................................................27

Vetting Practices ..........................................................................................................27

Ship Inspection Report Program .........................................................................27

Tanker Management & Self-Assessment ............................................................27

Company Vetting .................................................................................................28

Terminal Vetting .................................................................................................28

Navigation Route Risk Controls ..................................................................................28

The U.S. Army Corps of Engineers .....................................................................28

U.S. Coast Guard .................................................................................................29

National Oceanic and Atmospheric Administration ............................................29

Other Safety Practices ..................................................................................................30

Lower Columbia Region Harbor Safety Committee ...........................................30

Under Keel Clearance ..........................................................................................31

TransView 32 ......................................................................................................31

Sea IQ ..................................................................................................................32

Coastal Data Information Program ......................................................................32

LoadMax ..............................................................................................................32

Columbia River Bar Prediction Models ..............................................................32

Evaluation of Cargo Oil Spill Risk ....................................................................................34

Background ..................................................................................................................34

Modeling ..............................................................................................................34

Spill Risk Terms ..................................................................................................35

Baseline Cargo Spill Risk ............................................................................................36

Cargo Spill Risk in Columbia River ....................................................................36

Cargo Spill Risk on Columbia River Bar ............................................................42

Potential Future Cargo Spill Risk ................................................................................43

Columbia River ...................................................................................................43

Columbia River Bar .............................................................................................46

Potential Risk Reduction Measures ...................................................................................47

Measures for Columbia River ......................................................................................47

Tug Escorts of Tankers and ATBs ......................................................................48

Additional Pilotage on Tugs/Towing Vessels .....................................................49

Measures for the Columbia River Bar .........................................................................51

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Risk Reduction Measure Model Results ............................................................................52

Columbia River ............................................................................................................53

Tethered Tug Escort of Laden Tankers ...............................................................53

Untethered Tug Escort of Laden Tankers ...........................................................55

Pilots on Tugs with Oil-barges-in-tow ................................................................57

Tethered Tug on Laden ATBs .............................................................................59

Fully Redundant Propulsion and Steering Systems on Tankers ..........................61

Columbia River Bar .....................................................................................................63

Wave Prediction Tool ..........................................................................................63

Surface Radar ......................................................................................................63

AIS on Towed Barges .........................................................................................64

Best Achievable Protection Analysis .................................................................................65

Process .........................................................................................................................66

Guiding Principles .......................................................................................................66

Columbia River Best Achievable Protection ...............................................................66

Sensitivity Analysis .............................................................................................69

Columbia River Bar Best Achievable Protection ........................................................71

Evaluation Findings ...........................................................................................................73

Department of Ecology Recommendations .......................................................................76

Risk Reduction Measures Considered but Not Recommended .........................................78

Conclusion .........................................................................................................................80

Ecology / DNV GL Evaluation Team ................................................................................81

Acknowledgments..............................................................................................................82

References ..........................................................................................................................84

Glossary, Acronyms, and Abbreviations ...........................................................................87

Glossary of Terms ........................................................................................................87

Acronyms .....................................................................................................................90

Abbreviations and Units of Measure ...........................................................................91

Summary of Appendices ....................................................................................................92

Appendix A. ESHB 1449, Chapter 274, Laws of 2015; Washington Oil

Transportation Safety Act ....................................................................................92

Appendix B. List of Project Contributors and Workshop Attendees ..................92

Appendix C. Case Descriptions ...........................................................................92

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Appendix D. Marine Safety Risk Controls ..........................................................92

Appendix E. Description of Risk Methodology ..................................................92

Appendix F. Study Basis .....................................................................................92

Appendix G. MARCS Baseline Model Description ............................................92

Appendix H. MARCS Model Validation ............................................................93

Appendix I. Cargo Oil Spill Risk Results ...........................................................93

Appendix J. Assessment of Best Achievable Protection .....................................93

Appendix K. Characterization of the Middle Columbia River-Snake River .......93

Appendix L. Marine Fuel Spills ..........................................................................93

Appendix M. Oil by Rail .....................................................................................93

Appendix N. Considerations Regarding Escort Tug Capabilities .......................94

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List of Figures and Tables

Figures

Figure 1: CRVTSA Study Area ...........................................................................................7

Figure 2: Non-oil AIS Vessel Types in Case A (Baseline Traffic) ...................................15

Figure 3: Distribution of Laden Oil Cargo Traffic based on Transited Miles in Case A

(Baseline Traffic) ..............................................................................................16

Figure 4: Number of Global Oil Spills, 1970 to 2016, by Spill Quantity in Metric Tons

(ITOPF, 2017) ...................................................................................................21

Figure 5: Spill Risk by Vessel and Incident Type .............................................................38

Figure 6: Oil Spill Risk Contributors River Case A (Baseline Traffic) .............................39

Figure 7: Oil Spill Risk per River Mile Case A (Baseline Traffic, River Mile 0 to 58) ....40

Figure 8: Oil Spill Risk per River Mile River Case A (Baseline Traffic, River Mile 59-

105) ...................................................................................................................41

Figure 9: Key Risk Contributors in River Case B (Baseline Traffic+ 25% Projects) .......44

Figure 10: Key Risk Contributors in River Case C (Baseline Traffic+ 100% Projects) ...44

Figure 11: Case Comparison – Detailed Cargo Oil Spill Risk Contributors .....................45

Figure 12: Risk Reduction: Tethered Tug Escort of Laden Tankers, Case C ....................53

Figure 13: Risk Reduction: Untethered Tug Escort of Laden Tankers, Case C ................55

Figure 14: Risk Reduction: Pilots on Tugs with Oil-barges-in-tow, Case C .....................57

Figure 15: Risk from All Laden Vessels on the River Mitigated by Tethered Tug on

Laden ATBs, Case C .........................................................................................59

Figure 16: Risk from Project Tankers on the River Mitigated by Fully Redundant

Propulsion Systems, Case C ..............................................................................61

Figure 17: Comparison of Sensitivity – Baseline Traffic + 10% Project Vessels to

Other Traffic Cases ...........................................................................................70

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Tables

Table 1: CRVTSA Workshops ............................................................................................8

Table 2: Transits of Laden Cargo Oil Vessels in Case A (Baseline Traffic) .....................16

Table 3: Proposed Terminal Projects .................................................................................17

Table 4: Traffic Cases Studied ...........................................................................................19

Table 5: Summary of Pilotage Requirements ....................................................................23

Table 6: Cargo Oil Spill Results for Four Selected Scenarios ...........................................36

Table 7: Cargo Oil Spill Risk River Case A (Current Traffic) ..........................................37

Table 8: River Cargo Oil Spill Risk Comparisons ............................................................43

Table 9: Evaluated Potential Risk Reduction Measures ....................................................47

Table 10: Comparison of Risk Reduction Results, Tethered Tug Escort of Laden Oil

Tankers ..............................................................................................................54

Table 11: Comparison of Risk Reduction Results, Untethered Tug Escort of Laden

Tankers ..............................................................................................................56

Table 12: Comparison of Risk Reduction Results, Pilots on Tugs with Oil-barges-in-

tow .....................................................................................................................58

Table 13: Comparison of Risk Reduction Results, Tethered Tug on Laden ATBs ...........60

Table 14: Comparison of Risk Reduction Results, Fully Redundant Propulsion

Systems on Tankers ..........................................................................................62

Table 15: Cost-Benefit Summary Case C ..........................................................................67

Table 16: Cost-Benefit Summary Case B ..........................................................................67

Table 17: Cost-Benefit Summary Case A ..........................................................................68

Table 18: Sensitivity – Future Project Transits for Lower Traffic Growth .......................69

Table 19: Cost-Benefit Summary – 10% Project Traffic Sensitivity ................................71

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Executive Summary

There are new, emerging sources of crude oil in North America and increasing amounts of it are

moving across Washington by vessel, rail, and pipeline. Each year, approximately 180 tank

vessels deliver refined petroleum products, such as gasoline and jet fuel, to ports on the

Columbia River in Washington and Oregon. Vessels cross the Columbia River Bar when

entering or departing the Columbia River.

A robust set of prevention and preparedness safety standards is in place to reduce the risk of

accidents and oil spills on the Columbia River. These regulatory and voluntary standards are

developed, implemented, and reviewed by government, industry, and non-governmental

organizations, including the International Maritime Organization, federal and state governments,

vessel operators, waterway users, oil refiners, and industry associations. Notably, all tank vessels

operating on the Columbia River have double hulls, which help reduce the risk of a cargo oil

spill. There has not been a major cargo oil spill on the river since 1984, before double hull

standards were implemented.

However, a major spill would have high consequences for both Washington and Oregon.

Ecology’s Spill Prevention, Preparedness and Response Program focuses on preventing oil spills

to Washington waters and land, and planning for and delivering a rapid, aggressive, and well-

coordinated response to oil and hazardous substance spills wherever they occur. Ecology’s goal

is zero spills.

Legislative Direction

The Washington State Legislature recognizes that vessels transport oil across some of

Washington’s most special and unique marine environments, which are sources for beauty,

recreation, and economic livelihood. It has identified oil spill prevention as the best method to

protect these environments (RCW 90.56.005).

In 2015, the Oil Transportation Safety Act (Chapter 274, Laws of 2015) required Ecology to

evaluate and assess vessel traffic management and safety within and near the mouth of the

Columbia River. The Act directed Ecology to consult with tribes and stakeholders and

determine:

The need for tug escorts for vessels transporting oil as cargo.

Tug capabilities to ensure safe escort.

The Best Achievable Protection, or the highest level of protection that can be attained using

the best technology, staffing, training, and operational methods, while considering cost,

achievability, and the additional protection added by the measure.

The Legislature asked Ecology to develop recommendations for vessel traffic management and

safety, including tug escort requirements.

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Study Approach

To determine the need for tug escorts for vessels transporting oil as cargo, tug capabilities to

ensure safe escort, and identify measures that could provide Best Achievable Protection, Ecology

hired DNV GL, a maritime classification, technical assurance, software and independent expert

advisory company. DNV GL’s role was to evaluate spill risks for oil1 transported on vessels as

bulk cargo (cargo oil) on the Columbia River and the Columbia River Bar. Ecology, working

with DNV GL, consulted with tribes and stakeholders through a series of workshops and

meetings to identify evaluation inputs and review results. The evaluation identified current safety

practices and how these practices influence existing and future risks. Cargo oil spill risks on the

Columbia River were modeled quantitatively for current vessel traffic and two potential future

traffic cases. Vessels that do not carry cargo oil (e.g., grain ships, passenger vessels, fishing

vessels) were included in the model, as these vessels could have an accident resulting in a

collision with a ship or barge carrying cargo oil. Fuel spills were not modeled due to resource

constraints, and because the model used was not optimal for studying fuel spills. Appendix L,

Marine Fuel Spills, provides a discussion of fuel spill potential.

Because the Columbia River Bar is a unique and dynamic environment, it was not possible to

model risks on the bar. Instead, cargo oil spill risks on the Columbia River Bar were considered

qualitatively through discussions with workshop participants.

Current Situation

Tank barges, Articulated Tug Barges (ATBs)2 and tank ships (tankers) carry cargo oil on the

river and across the bar. Collectively, these are referred to as tank vessels. Tank vessels typically

move refined petroleum products upriver. There are currently no shipments of crude oil on the

Columbia River by tank vessels. The evaluation reviewed a year of vessel traffic data and

identified 110 transits by ATBs entering the Columbia River with cargo oil, 42 entering transits

of tugs with oil-barges-in-tow, and 29 entering tankers. There were 2 outbound ATB transits and

2 outbound tanker transits with cargo oil.

The Columbia River and Columbia River Bar safety record has been maintained during periods

with greater numbers of vessels operating on the Columbia River than were included in the

vessel traffic data reviewed during this evaluation.3

1 Oil as defined by RCW 88.40 and 90.56

2 An Articulated Tug Barge is a combination vessel consisting of a barge and a tug boat connected by mechanical

equipment.

3 In 2015-2016, Ecology Vessel Entries and Transits data indicates there were approximately 1,400 entering transits

of tank ships, articulated tug barges, and cargo and passenger vessels per year on the Columbia River. Ecology

VEAT data for 1993-2000 show approximately 2,000 entering transits per year

(http://www.ecy.wa.gov/programs/spills/publications/publications.htm).

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Findings of the Evaluation

Cargo oil spill risk was evaluated for baseline traffic and two potential future increases. The

possible level of protection afforded by potential additional safety measures was also evaluated.

The quantitative and qualitative analysis resulted in the following technical findings, which

informed Ecology’s recommendations:

1. The need for tug escorts for tank vessels transporting oil as cargo:

Tankers. Tug escorts that are tethered to a laden oil tanker on the Columbia River would

offer a significant and cost-effective level of protection for tankers. Untethered tugs

accompanying tankers do not provide a significant or cost-effective risk reduction on the

Columbia River. On the bar, tug escort may not increase maritime safety.

ATBs. The ATBs on the river and bar have partially redundant propulsion and steering

systems, which offer a significant level of protection. As a result, tethered tug escort of ATBs

on the Columbia River offers a relatively small reduction in oil spill risk. Untethered tug

escort of ATBs would not offer a measurable level of protection.

Tugs with oil-barges-in-tow. The equivalent of tethered tug escort is already in place for tugs

with oil-barges-in-tow. Tugs towing oil barges employ “tag tugs,” which are typically

smaller tug boats that are attached to the stern of the oil barge. The tag tug assists with

steering the barge. Additional tug escorts beyond tag tugs would not offer a measurable level

of protection.

2. Tug capabilities to ensure safe escort.

The tug capabilities needed to escort a tank vessel should be aligned with the characteristics of

the specific vessel it will escort. This is to assure the safety of both vessels and their crews. In-

depth studies are warranted, as the size and steering capabilities of a specific tank vessel design

need to be paired with the capabilities of a specific tug design. Guidelines should be developed

for tug escort on the Columbia River.

3. Best Achievable Protection

The following measures met the criteria to be considered Best Achievable Protection:

Tethered tug escorts for oil tankers on the Columbia River. Based on the modeling and

qualitative analysis, this measure was more effective for the potential future traffic cases than

the current vessel traffic case in reducing cargo oil spill risk.

Tethered tug escorts for ATBs on the Columbia River. This measure meets the criteria for

Best Achievable Protection because model results indicate it could reduce cargo oil spill risk.

The current risk is relatively low, however, and Ecology considered additional factors when

determining recommendations as described below.

Three measures were considered qualitatively that could improve the information available to

the Columbia River Bar Pilots, who provide a key risk control for vessels crossing the bar:

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o A predictive wave model for the Columbia River Bar. Other bars on the west coast

have high-resolution forecast models, but the Columbia River Bar has proven to be

complex to model. This measure would provide additional information to mariners,

providing better forecasts of wave height and support decisions made based on

minimum depths under keel.

o A land-based radar to provide coverage of the Columbia River Bar and approaches.

This measure would improve vessel traffic management by the Columbia River Bar

Pilots and navigation safety on the bar in general.

o Automatic Identification System (AIS) transponders on barges crossing the Columbia

River Bar. This would assist pilots and other vessel masters with identifying and

avoiding barges.

Additional Considerations

Ecology considered the following additional information when developing recommendations:

The evaluation results are consistent with a well-managed system. The robust safety

measures in place appear to be largely effective at reducing risk.

Quantitative risk models are designed to produce conservative results (i.e., overestimate,

rather than underestimate, actual risks).

ATBs do not have as deep of a draft as tankers. An ATB can operate outside the federal

navigation channel if the vessel’s master decides it is safer to do so in a given situation.

The future traffic cases assume all of the additional vessels carrying cargo oil would be

tankers. If different vessels are used to carry cargo oil in the future, this evaluation should be

updated.

Recommendations

Ecology recommends the following safety measures be implemented; neither require a change to

laws or rules:

1. Continue to support existing collaborative maritime safety programs.

Existing, collaborative maritime safety programs represent the best opportunity to prevent

cargo oil spills on the Columbia River and Bar.

Ecology will continue to support these programs through participation as a member of the

Lower Columbia Region Harbor Safety Committee, Northwest Area Committee, and the

Sector Columbia River Area Maritime Security Committee. It will continue to attend Oregon

Board of Maritime Pilots meetings and participate in U.S. Coast Guard waterways

management studies.

Through participation in these programs, Ecology will encourage practices and technologies

to meet Best Achievable Protection. These could include:

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o Regular discussions through the Harbor Safety Committee and other forums about

current practices, evolving risks, and opportunities for improvement for the

movement of cargo oil.

o Tools to enhance the safe navigation and piloting of vessels on the Columbia River

and Bar.

2. Seek tethered tug escort of laden tankers when tanker traffic increases.

Ecology will work with the Lower Columbia Region Harbor Safety Committee to develop a

Harbor Safety Plan Standard of Care, to be considered for implementation when a newly

constructed or expanded facility to move oil4 on the Columbia River becomes operational

and increases tanker traffic. This standard will address tethered tug escort of laden oil tankers

on the Columbia River and considerations for laden oil tankers crossing the Columbia River

Bar.

The Standard of Care should also:

o Include tug and tanker equipment capabilities.

o Consider exempting tankers with double hulls, when the tanker also has fully

redundant steering and propulsion (i.e., independent systems that can maintain

propulsion/steering with any single failure).

4 A facility meeting the requirements of 33 CFR 126, 154, 155, and the Class 1 facility requirements in Chapter 173-

180 WAC

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Background

Study Requirements The Legislature passed Engrossed Substitute House Bill 1449 (the Oil Transportation Safety Act)

during the 2015 legislative session, which was codified in RCW 90.56.568 and directs the

following of the Department of Ecology:

1. The department must complete an evaluation and assessment of vessel traffic

management and vessel traffic safety within and near the mouth of the

Columbia river. A draft evaluation and assessment must be completed and

submitted to the legislature consistent with RCW 43.01.036 by December 15,

2017. A final evaluation and assessment must be completed by June 30, 2018.

In conducting this evaluation, the department must consult with the United

States coast guard, the Oregon board of maritime pilots, Columbia river

harbor safety committee, the Columbia river bar pilots, the Columbia river

pilots, area tribes, public ports in Oregon and Washington, local governments,

and other appropriate entities.

2. The evaluation and assessment completed under subsection (1) of this section

must include, but is not limited to, an assessment and evaluation of: (a) The

need for tug escorts for oil tankers, articulated tug barges, and other towed

waterborne vessels or barges; (b) best achievable protection; and (c) required

tug capabilities to ensure safe escort of vessels on the waters that are the

subject of focus for each water body evaluated under subsection (1) of this

section.

3. The assessment and evaluations submitted to the legislature under subsection

(1) of this section must include recommendations for vessel traffic

management and vessel traffic safety on the Columbia river, including

recommendations for tug escort requirements for vessels transporting oil as

bulk cargo.

4. All requirements in this section are subject to the availability of amounts

appropriated for the specific purposes described.

5. This section expires June 30, 2019.

Ecology hired DNV GL to conduct the evaluation and prepare the draft report. Ecology retains

responsibility for the evaluation, the report, and the recommendations to the legislature.

Methods

The evaluation examined the risks of a cargo oil spill on the Columbia River and Columbia River

Bar. For the river, cargo oil spill risk was quantified for baseline vessel traffic conditions and for

two potential future scenarios. For the bar, the risk analysis was qualitative.

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The study area for the evaluation is shown below in Figure 1. Distances on the Columbia River

are measured in River Miles. River Mile 0 is at the mouth of the Columbia River, near Ilwaco,

Washington. Locations westward of River Mile 0 are shown using negative numbers, and

locations eastward of River Mile 0 are shown with positive numbers.

Figure 1: CRVTSA Study Area

In conducting the evaluation, DNV GL:

Identified existing safety practices.

Modeled current vessel traffic on the Columbia River.

Assessed risks quantitatively using the model, and qualitatively through discussions with

tribes and stakeholders.

Identified potential risk reduction measures.

Conducted cost-benefit analyses.

Determined evaluation findings.

Ecology considered the findings, input from tribes and stakeholders, and the direction from the

Legislature to determine recommendations.

A quantitative model was used where possible in the evaluation because the risks described in

this report relate to events that are both severe and infrequent. Cargo spill scenarios are

fortunately rare in the Columbia River and throughout the world. No cargo oil spills have

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occurred on the Columbia River since 1984 (Ecology, 1997). So it was not possible to review

local historical data to estimate the risk with any degree of detail on the Columbia River and Bar.

Based on global historical data, without conducting risk analysis modeling, the best estimation of

risk on the river would probably be about 1 large spill every 1,000 to 10,000 years. Without

information about the causes of historical spills, it would be impossible to identify risk

contributors using this approach. The most useful method to support making risk reduction

recommendations was to build a model for the Columbia River.

The natural forces at work on the Columbia River Bar prevented building a quantitative risk

model for the bar because of its complexities (e.g., wind, ocean swells, river outflow, and

changing water depths over the bar). Instead, a qualitative process was used to describe baseline

risks and potential risk reduction measures for the bar.

Ecology consulted with tribes and stakeholders throughout the evaluation. Consultation included

workshops, meetings with a workgroup of the Lower Columbia Region Harbor Safety

Committee, and conversations with organizations and individuals. A website provided

information on the status of the project and opportunities to engage (Ecology, 2016).

Ecology and DNV GL held five workshops with tribes and stakeholders during the evaluation.

These events are listed in Table 1. Not listed are several planning meetings that were held before

May 12, 2016, or smaller discussions which focused on specific topics (e.g., identifying towing

vessels that typically move oil barges). All workshops took place in Portland, Oregon; some

workshops included an option to participate remotely by phone. These events were used to help

identify inputs to the quantitative and qualitative analysis, review analysis results, and inform the

recommendations. People who participated in evaluation events are listed in Acknowledgements,

and in Appendix B, List of Project Contributors and Workshop Attendees. Participation in

project events does not imply endorsement of the study findings and recommendations by these

individuals or their organizations.

Table 1: CRVTSA Workshops

Briefing Date Purpose

Project Briefings May 12, 2016 Ecology and DNV GL introduced the CRVTSA, described the opportunities for tribes and stakeholders to participate, and encouraged participation.

Scenario Workshop October 6, 2016 DNV GL reviewed proposed model assumptions with participants. After this meeting, the assumptions were finalized so modeling could begin.

Risk Results and Mitigation Workshop

January 25, 2017 DNV GL presented the model risk results and risk contributors. A brainstorming session was used to develop the list of potential risk reduction measures to be evaluated.

Best Achievable Protection Workshop

February 23, 2017 DNV GL presented the evaluation of each potential risk reduction measure, including the cost-benefit analysis.

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Briefing Date Purpose

Recommendations Workshop March 21, 2017 Ecology presented preliminary draft recommendations and gathered feedback from participants.

The sections below describe the key outcomes from the engagement events, and how the

evaluation methods were implemented.

Scenario Workshop – October 6, 2016

The goal of the Scenario Workshop was to review and finalize study inputs and assumptions.

These key decisions are documented in Appendix F, Study Basis. Topics discussed at the

Scenario Workshop included existing risk controls on the waterway, environmental data, tank

vessel types and configurations, and traffic scenarios to consider.

Three marine traffic cases were evaluated:

Case A, which included baseline year traffic. The baseline year for the evaluation was

October 1, 2015 – September 30, 2016; this was the most recent year of Automatic

Identification System data available.

o For vessels that carry cargo oil, Ecology reviewed Vessel Entries and Transits

(VEAT) (Ecology, 2017a) analysis to determine the number of transits within the

study area and routes traveled.

o For vessels that do not carry cargo oil, the model used processed AIS data for the

baseline year, to represent the actual flows of traffic within the study area.

Case B, the baseline traffic plus all the proposed projects defined in Appendix F, Study Basis

operating at 25% of their proposed maximum number of vessel trips (laden and unladen

transits).

Case C, the baseline traffic, plus all the proposed projects defined in Appendix F, Study

Basis operating at their proposed maximum number of vessel trips (laden and unladen

transits).

A complete description of the vessel traffic for each case is provided in Appendix C, Case

Descriptions. Existing risk controls, and how they are represented in the evaluation, are listed in

Appendix D, Marine Safety Risk Controls.

Risk Analysis of Cargo Oil Spills for the Three Traffic Cases

The quantitative risk method used in this study is described in Appendix E, Description of Risk

Methodology. The primary tool used for the risk analysis was Marine Accident Risk Calculation

System (MARCS), DNV GL’s proprietary navigation risk model. Appendix G, MARCS

Baseline Model Description, and Appendix H, MARCS Model Validation, describe the model

and its validation.

The study looked at low-frequency, high-consequence events (i.e., cargo oil spills) and modeled

the underlying failures that could cause these events. Typical underlying failures for cargo spills

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are propulsion system failures, human errors, steering system failures, and structural defects in

the ship. These types of failures are about as likely to occur in the study area (see Figure 1) as

anywhere else, so MARCS uses global data for failure frequencies.

To tailor MARCS for the study area, the model inputs included local data for risk controls (e.g.,

the presence of Columbia River Pilots on tankers and cargo ships) and route conditions (e.g.,

parts of the river where rocks are close to the channel edges). Model inputs and assumptions are

described in Appendix F, Study Basis.

The model’s input data included:

Vessel traffic data for the baseline year.

Environmental information, such as wind, visibility, and locations where grounding on rocks

is possible.

Existing risk controls.

Many of the existing risk controls were common to most navigated waters, like pilotage of

vessels carrying hazardous cargoes, electronic navigation systems, under keel clearance

management, and aids to navigation. A few of the identified risk controls were unique to the

Columbia River and Bar. For example, tugs towing oil barges behind them on a tow wire employ

“tag tugs,” as described in the Lower Columbia Region Harbor Safety Plan. Tag tugs are

typically smaller tug boats that are attached to the stern of the oil barge. The tag tug assists with

steering the barge, and keeps the barge behind the towing tug.

By combining global incident data and local route and risk control information, the results from

the MARCS model were used to identify the highest risk contributors for the modeled area,

vessel types, and traffic scenarios. Each combination of vessel, incident type, and location was a

unique scenario in the risk model. The risk for each of nearly a million possible scenarios was

estimated in terms of how often it could occur (frequency) and how severe it could be (spill

quantity). These numerical risk calculations were an intermediate step in the study process.

Appendix I, Cargo Oil Spill Risk Results contains the detailed risk results.

Risk Results and Mitigation Workshop – January 25, 2017

Ecology held this workshop to review risk results for the three traffic cases and identify potential

risk reduction measures to be evaluated as Best Achievable Protection. After the main risk

contributors were identified, the participants reviewed an initial list of possible reduction

measures and brainstormed others for consideration by DNV GL and Ecology. The evaluated

potential risk reduction measures are shown below. The first five measures were evaluated

quantitatively. The remaining risk reduction measures were discussed qualitatively.

Evaluated quantitatively:

Tethered tug escort of laden tankers.

Untethered tug escort of laden tankers.

Tethered tug escort of laden ATBs.

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Pilots on laden traditional towed barges and ATBs.

Fully redundant propulsion on laden tankers (e.g., independent systems that can maintain

propulsion/steering with any single failure).

Evaluated qualitatively:

A wave model/tool to provide near real-time information about conditions on the Columbia

River Bar.

A land-based radar at Cape Disappointment to provide coverage of the Columbia River Bar

and approaches.

AIS on towed barges.

Analysis of Potential Risk Reduction Measures

For the five measures that could be quantified, DNV GL analyzed the potential benefits of the

risk reduction measure using the MARCS model. For the risk reduction measures that could not

be quantified, descriptions of the hazards they control and the potential benefits of the measures

are provided in this report.

Best Achievable Protection Workshop – February 23, 2017

Ecology and DNV GL presented the evaluation of potential risk reduction measures for the

additional protection they could provide, their achievability, and their cost in a workshop. The

results are summarized in the Best Achievable Protection section of this report, and described in

detail in Appendix J, Assessment of Best Achievable Protection.

Development of Recommendations – March 21, 2017

Using the risk analysis and assessment of Best Achievable Protection, Ecology discussed

preliminary draft recommendations with stakeholders during a workshop in March 2017.

Following the workshop, Ecology provided a preliminary draft report to tribes and stakeholders.

Based on feedback Ecology received and Ecology’s review of additional data sources,5 Ecology

and DNV GL revised the number of tank vessel transits in the base case traffic and the size of

tank vessels to more accurately reflect operations on the Columbia River. The findings and

recommendations in this report and appendices reflect the revised vessel traffic data.

5 Ecology reviewed 2015 and 2016 VEAT analysis for tank vessels. VEAT reports are available at:

http://www.ecy.wa.gov/programs/spills/publications/publications.htm. Data sources for VEAT reports are AIS and

Ecology’s Advance Notice of Transfer system.

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Evaluation Assumptions and Limitations

The risk of cargo oil spills and the potential effect of risk reduction measures were modeled

quantitatively for the Columbia River, from River Mile 0 to River Mile 105.

The risks of a cargo oil spill were not quantitatively modeled for the Columbia River Bar,

between River Mile -5 and River Mile 0. Risk contributors and potential risk reduction

measures were discussed qualitatively with the Columbia River Bar Pilots and workshop

participants.

Risk models are designed to produce conservative results. The model used in this evaluation,

like most risk models, overestimates the risk of a cargo oil spill by as much as 5 to 7 times

what the actual risks of a cargo oil spill may be. This conservative approach is intended to

ensure that potential causes of cargo oil spills are not overlooked in the evaluation.

Not all of the safety practices in operation on the Columbia River could be quantified in the

model. Risk results are overestimated by at least the amount of oil spill prevention provided

by safety practices that could not be modeled.

Model results do not represent an expected spill volume per year, and should not be

interpreted as predictions of how many cargo oil spills will happen in the future. The purpose

of the model results is to allow a comparison of potential risk causes, and an assessment of

the relative benefit of potential risk reduction measures.

The model results should not be taken out of context of this evaluation.

The modeling approach for the Columbia River was designed specifically to study oil spills

from cargo tanks on vessels transiting the river only. It was not designed to study other

sources or types of spills like fuel oil spills or spills during transfer operations.

Cargo oil spills on the Columbia River are rare events. The model summarized risk

calculations for a large number of low-probability scenarios to determine a numerical

aggregate risk per year. The aggregate risk per year numbers in this report are used to review

potential causes of spills to find risk contributors, and to compare potential changes in risks

under different scenarios.

This evaluation did not include fate, effect, and transport modeling of oil spills or intentional

spill events (i.e., sabotage or terrorism). Instead, the evaluation focused on accidental events.

Comparison of the model results with cargo oil spill risks for other waterways is valid only if

similar models are built for the other waterways.

The report includes two types of appendices, technical and informational. Technical

appendices give details about the study methodology and results. Informational appendices

provide a broader understanding of the region, in addition to the requirements of the

Washington Oil Transportation Safety Act, and identify potential topics for future study.

Informational appendices include:

o Vessel traffic on the Middle Columbia River-Snake River Waterway System

(Appendix K).6

6 Appendix K is provided for information and describes the waterway east of the I-5 Bridge. The quantitative and

qualitative analysis, findings, and recommendations of this evaluation are focused on the Columbia River west of

the I-5 Bridge.

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o A method that could be used to examine fuel oil spills (Appendix L).

o A discussion of the volume of oil shipped out of Washington on the river that is

received by rail (Appendix M).

Participants were concerned that future traffic levels may be lower than modeled in the two

future scenarios. A sensitivity analysis examined the change in cargo oil spill risk if 10% of

vessel traffic associated with proposed terminal projects were added to baseline traffic. The

results of this sensitivity analysis is presented in Appendix J, Assessment of Best Achievable

Protection.

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Columbia River Vessel Traffic

The baseline traffic is a combination of the AIS data for vessels that do not carry cargo oil, and

Ecology data for transits of oil-carrying vessels. The baseline year for the evaluation was

October 1, 2015 – September 30, 2016; this was the most recent year of AIS data available. AIS

is a shipboard system that sends and receives signals with information about vessels (U.S. Coast

Guard, 2017a). The information includes a ship name, course and speed, classification, call sign,

registration number, and other information. In the AIS software, the vessel operator must choose

a vessel type from a dropdown list.

Tank barges, Articulated Tug Barges (ATBs)7 and tank ships (tankers) carry cargo oil on the

river and across the bar. Collectively, these are referred to as tank vessels. Tank vessels typically

move refined petroleum products upriver. Ecology reviewed 2015 and 2016 VEAT analysis to

determine the number of tank vessel transits (Ecology, 2017a). Data sources for VEAT reports

are AIS and Ecology’s Advance Notice of Transfer system.

For vessels that do not carry cargo oil, the model used processed AIS data for the baseline year,

to represent the actual traffic flows within the study area. The number of times each vessel type

was operating and transmitting AIS data at each river mile in the baseline year was an input to

the navigation risk model.

Vessel types were defined to differentiate tank vessels moving cargo oil and to account for risk

controls that applied to only some vessels. For easy identification, vessels have the word

“Laden” in their name to note they are carrying cargo oil (e.g., ATB Laden, Oil Tanker Laden).

Appendix F, Study Basis, provides a complete list of vessel types and safety measures associated

with each vessel type, defines the vessel traffic cases, and describes the data used for the study.

The AIS data included all transits of vessels carrying AIS transponders in the study area. On-

board AIS is required by the International Convention for the Safety of Life at Sea (SOLAS) and

U.S. regulations for the commercial vessels of interest in the CRVTSA. Because of its obvious

value to mariners, many smaller vessels have AIS transmitters even though not required. These

vessels appeared in the AIS data used for the study, but due to their size, these smaller vessels

did not contribute to cargo oil spill risks.

Vessel traffic was analyzed for the Columbia River (River Mile 0 to 105). Cargo oil spill risks

were not modeled quantitatively for the Columbia River Bar (River Mile -5 to 0), so vessel

traffic was not analyzed in detail for the bar. Risks and potential risk reduction measures were

considered qualitatively for the Columbia River Bar.

7 An Articulated Tug Barge is a combination vessel consisting of a barge and a tug boat connected by mechanical

equipment.

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Baseline Traffic

More than 95% of vessels transiting the Columbia River do not carry oil as cargo. Figure 2

shows the traffic that did not carry oil cargoes on the river during the baseline year (October 1,

2015 to September 30, 2016).

Figure 2: Non-oil AIS Vessel Types in Case A (Baseline Traffic)

Coastal tugs and cargo carriers represented nearly 60% of the traffic on the river based on miles

sailed. Coastal, or seagoing, tugs generally tow cargo barges.

The cargo oil vessels in the baseline traffic were ATBs, tugs with oil-barges-in-tow, and oil

tankers. Vessels typically transit in one direction with cargo onboard, indicated as laden, and

transit the other direction without oil cargo, indicated as unladen. For Case A, approximately 3%

of the vessel traffic was oil laden vessels.

The breakdown of laden oil cargo traffic by vessel type is shown in Figure 3.

Coastal Tugs, 31%

Cargo Carriers, 28%

Service, 10%

Other, 10%

Fishing Vessels, 6%

Undefined, 5%

Passenger Vessels, 4%

Pleasure Craft, 4%Cruise Ships,

2%

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Figure 3: Distribution of Laden Oil Cargo Traffic based on Transited Miles in Case A (Baseline Traffic)

About 88% of the oil cargo vessel traffic is inbound to terminals in Washington and Oregon. The

remaining 12% of laden traffic was outbound oil cargos. Much of this “outbound” cargo oil is

barges delivering fuel and other refined products to vessels berthed on the river; it is included in

the outbound total because the loaded barges begin their transit at River Mile 101, and in the

baseline year, traveled as far downriver as River Mile 15.

ATBs represented half of the laden miles travelled in the baseline year. Approximately one-

quarter of the laden miles travelled on the river was tugs with oil-barges-in-tow. Inbound laden

oil tankers represented 13% of laden miles.

Figure 3 above shows the relative distribution of distance travelled per laden vessel type. Table 2

lists the actual number of transits. Participants in the evaluation noted that greater numbers of

vessels have operated on the Columbia River in the past, without a significant cargo oil spill,

than were included in the vessel traffic data reviewed during this evaluation.8

Table 2: Transits of Laden Cargo Oil Vessels in Case A (Baseline Traffic)

Laden Cargo Oil Vessel Type Comments Laden Trips per Year

ATB Inbound Carry refined products across the bar to terminals on the river

110

ATB Outbound Carry refined products from terminals down the river and over the bar

2

8 In 2015-2016, Ecology Vessel Entry and Transit data indicates there were approximately 1,400 entering transits of

tank ships, articulated tug barges, and cargo and passenger vessels per year on the Columbia River. Ecology VEAT

data for 1993-2000 show approximately 2,000 entering transits per year

(http://www.ecy.wa.gov/programs/spills/publications/publications.htm).

50%

25%

13%

11%

1%

ATB (laden) inbound

Tug, Oil Barge in Tow (laden) inbound

Oil Tanker (laden) inbound

Tug, Oil Barge in Tow (laden) outbound

Oil Tanker (laden) outbound

ATB (laden) outbound (<1%)

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Laden Cargo Oil Vessel Type Comments Laden Trips per Year

Oil Tanker Inbound Carry refined products across the bar to terminals on the river

29

Oil Tanker Outbound Carry refined products from terminals down the river and over the bar

2

Tug with Oil-barge-in-tow transiting eastward beyond River Mile 105 (Inbound)

Carry refined products upriver after loading at terminals east of River Mile 100

214

Tug with Oil-barge-in-tow transiting eastward from the bar (Inbound)

Carry refined products across the bar to terminals on the river

42

Tug with Oil-barge-in-tow used for fuel bunkering (Outbound)

Carry marine fuel and other refined products to vessels at berths

77

Potential Future Traffic

The evaluation considered two potential future scenarios. Five proposed projects within the study

area were identified (Table 3). Publicly available information was used to determine the

maximum proposed laden transits per year for each project. The table was current at the time of

issue of this report.

Table 3: Proposed Terminal Projects

Project Name Proposed Location

Cargo

Assumed Vessel Size for Model (Metric Deadweight Tons)

Proposed Maximum Loaded Transits per Year

Details

Millennium Bulk Terminal (Cowlitz County, 2016)

Longview, WA

Coal 44,894 840 No oil cargo transits

Tesoro Savage JV, Vancouver Energy Project (Energy Facility Site Evaluation Council, 2016)

Vancouver, WA

Oil

41,408 (laden)

20,554 (ballast)

365

365 ballasted inbound transits plus 365 laden, outbound transits

Northwest Innovation Works LLC (Cowlitz County and Port of Kalama, 2016)

Port of Kalama-Cowlitz County, WA

Methanol 44,894 72 No oil cargo transits

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Project Name Proposed Location

Cargo

Assumed Vessel Size for Model (Metric Deadweight Tons)

Proposed Maximum Loaded Transits per Year

Details

Northwest Innovation Works LLC (Cowlitz County and Port of Kalama, 2016)

Port Westward in Clatskanie, OR

Methanol 44,894 72 No oil cargo transits

Columbia River Carbonates Woodland Marine Terminal

Woodland, WA

Calcium carbonate

8,061 30 No oil cargo transits

Total of Proposed Loaded Transits 1,379

The participants in the Scenario Workshop discussed future traffic at length. It was difficult to

estimate future laden tank vessel traffic when most of the proposed terminal projects were still in

the review process, neither approved nor disapproved.

Workshop participants agreed that it was highly unlikely that all the proposed projects would be

built. They also agreed that it was possible for the terminals that are built to operate at lower

traffic levels than their proposed maximum capacities. The workshop participants did not make

any judgments or predictions about which proposed projects would be built, or the associated

traffic levels. They did, however, express a desire to see risk analysis results for cases less than a

full build out of proposed projects.

To resolve the challenging issue of uncertainty with future projects, the CRVTSA analyzed two

future cases:

Case B - the baseline year traffic plus all the proposed projects operating at 25% of their

proposed maximum number of vessel trips (laden and unladen transits).

Case C - the baseline traffic plus all the proposed projects operating at their proposed

maximum number of vessel trips (laden and unladen transits).

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Modeled Traffic Cases

Table 4 lists the traffic cases modeled in the evaluation.

Table 4: Traffic Cases Studied

Case General Description Details

Case A Baseline year The baseline year for the evaluation was October 1, 2015 – September 30, 2016; this was the most recent year of AIS data available. For vessels that carry cargo oil, Ecology reviewed VEAT analysis for the baseline year to determine the number of transits within the study area and routes traveled. Data sources for the VEAT include AIS and information from Ecology’s Advance Notice of Oil Transfer system. For vessels that do not carry cargo oil, input to the MARCS model was processed AIS data for the baseline year for the study area. The AIS data defined vessel traffic patterns, traffic densities, and vessel speeds.

Case B Baseline year plus 25% of project transits

Baseline year plus 345 vessel trips (25% of Project vessel transits listed in Table 3)

Case C Baseline year plus 100% of project transits

Baseline year plus 1,379 vessel trips (100% of Project vessel transits listed in Table 3)

The baseline year case (Case A) represented the baseline traffic. The maximum scenario

(Case C) was the baseline traffic, plus all the proposed projects operating at their proposed

maximum number of vessel trips (laden and unladen transits). An intermediate growth scenario

(Case B) was the baseline year traffic plus all the proposed projects operating at 25% of their

proposed maximum number of vessel trips (laden and unladen transits). The additional oil-

carrying traffic in the future cases was from one proposed project in Vancouver, with a

maximum of one laden tanker transit per day.

The evaluation did not make assumptions about how marine bunkering (e.g., providing fuel and

other refined products to a vessel at a berth) might change in the future. No additional bunkering

transits were added to Case B or Case C.

An additional future case was requested to be modeled, but the project did not provide for that

level of effort and complexity. Instead, a separate sensitivity analysis looked at the effect on the

end results if only 10% of the proposed transits were to occur. It is presented in Appendix J,

Assessment of Best Achievable Protection.

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Existing Safety Measures

Robust, collaborative maritime safety programs are in operation today, reducing risks in marine

transport of oil cargoes on the Columbia River and Bar. These existing safety systems play an

important role in achieving the high level of safety currently seen on the Columbia River and

Bar. In the past 30 years, one recorded significant spill of cargo oil on the Columbia River and

Bar has occurred. In 1984, the single-hulled tanker SS MOBILOIL grounded on Warrior Rock in

the Columbia River, rupturing five cargo tanks on the vessels starboard side, and spilling an

estimated 163,800 gallons of heavy fuel oil carried as cargo (National Transportation Safety

Board, 1984).9

Since 1984, significant changes have occurred in maritime safety. The vessel fleet has improved

as newer vessels enter service that incorporate additional safety and stability requirements, and

industry groups have improved how vessels are operated and managed. Perhaps the most notable

changes were the amendment of the International Maritime Organization (IMO) International

Convention for the Prevention of Pollution from Ships (MARPOL), and the passage of the Oil

Pollution Act of 1990 (OPA 90). MARPOL and OPA 90 included double hull standards and

requirements for tank vessels.

OPA 90 amended the Clean Water Act and increased federal oversight of maritime oil

transportation, including:

Setting new requirements for vessel construction, and crew licensing and manning.

Mandating contingency planning.

Enhancing federal response capability.

Broadening enforcement authority.

Increasing penalties.

Creating new research and development programs.

Increasing potential liabilities.

Significantly broadening financial responsibility requirements.

Enforcement of MARPOL Annex I, Regulations for Preventing Oil Pollution from Ships, began

in October of 1983. In a recent statement, the IMO said:

The operational and construction regulations introduced by MARPOL, which

entered into force in 1983, have been a success, with statistics from reputable

industry and independent bodies showing that these regulations, along with other

safety-related regulations such as the introduction of mandatory traffic separation

schemes and international standards for seafarer training, have been instrumental

in the continuous decline of accidental oil pollution that has taken place over the

last 30 years. (IMO, 2017)

9 A historical analysis of oil spills and near miss events in Washington waters, including the Columbia River, is

available at: https://fortress.wa.gov/ecy/publications/documents/97252.pdf.

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According to the International Tanker Owners Pollution Federation Limited (ITOPF), the

number of spills has been decreasing over the past few decades (Figure 4). ITOPF maintains a

database of accidental oil spills from tankers, combined carriers, and barges. Spill quantities are

shown in metric tons (MT).

Figure 4: Number of Global Oil Spills, 1970 to 2016, by Spill Quantity in Metric Tons (ITOPF, 2017)

Many entities, including the IMO, U.S. Coast Guard, State of Washington, the Oil Companies

International Marine Forum (OCIMF), and the Harbor Safety Committee made efforts to

improve maritime safety and reduce the risk of oil spills from vessels. Examples of these

practices are described below. More detailed descriptions can be found in Appendix D, Marine

Safety Risk Controls.

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Government Oversight

Multiple international, federal and state governments provide oversight of waterway safety,

including the United Nations IMO, the U.S. Coast Guard, U.S. Army Corps of Engineers

(USACE), National Oceanic and Atmospheric Administration (NOAA), Oregon State Board of

Maritime Pilots, Washington State Department of Ecology, and the Oregon State Department of

Environmental Quality (DEQ).

International Maritime Organization

The main role of the IMO is to create a regulatory framework for the shipping industry that is

effective, universally adopted, and universally implemented. IMO regulations and standards are

agreed upon, adopted and implemented on an international basis. Their standards cover all

aspects of international shipping—ship design, construction, equipment, manning, operation and

disposal—to ensure that shipping remains safe, environmentally sound, energy efficient and

secure (IMO, 2017). U.S. laws and the Code of Federal Regulations have incorporated IMO

regulations and standards. The U.S. Coast Guard enforces compliance by foreign flagged vessels

through its Port State Control authorities, and by U.S. flagged vessels through its Flag State

authorities.

U.S. Coast Guard

The U.S. Coast Guard protects the maritime economy and the environment, defends the maritime

borders, and rescues those in peril (U.S. Coast Guard, 2017b). The Columbia River is located in

U.S. Coast Guard District Thirteen. It is managed by Sector Columbia River in Astoria, Oregon

and the Marine Safety Unit in Portland, Oregon. The Coast Guard operates through authorities as

the Sector Commander; Officer in Charge, Marine Inspection; Captain of the Port; Federal On-

Scene Coordinator; and Federal Maritime Security Coordinator. Coast Guard missions related to

oil spill prevention, safe navigation and vessel safety on the Columbia River include:

Port safety, waterways management, and port and coastal security.

Aids to navigation.

Port State Control.10

Vessel inspections.

Oil spill response planning.

Marine casualty investigations.

Pilotage

A marine or maritime pilot is a person who has demonstrated expert local knowledge of a

particular waterway. They also have experience in ship handling, seamanship and vessel

10 The Coast Guard’s Port State Control (PSC) program verifies that foreign flagged vessels operating in U.S. waters

comply with applicable international conventions, U.S. laws, and U.S. regulations.

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navigation. A ship’s captain is responsible for the safe operation of the ship. However, for certain

vessel types, particular waterways, or hazardous cargoes, a marine pilot is required as an

additional risk control. Compulsory pilotage is used in most of the world’s large ports and in

many environmentally sensitive waterways.

Pilotage requirements on the Columbia River vary, based on the vessel size, country of registry,

and trade the vessel is engaged in. Tank ships and tank barges on the Columbia River must be

under the direction and control of an individual qualified to serve as pilot (46 CFR 15.812).

Depending on the voyage, tank vessels, tugs towing oil barges, and ATBs may take a pilot

credentialed by the state, or operate with a pilot credentialed by the U.S. Coast Guard (federal

pilotage).

The State of Oregon Board of Maritime Pilots oversees the Columbia River and Columbia River

Bar Pilots. For Federal pilotage, the U.S. Coast Guard runs the licensing program.

Whether a vessel on the Columbia River or Bar requires a state pilot, federal pilot, or other

appropriate federal licensed mariner depends on the vessel’s (1) country of registry and (2) type

of trade (Table 5).

Table 5: Summary of Pilotage Requirements

General Vessel Description

Pilotage Requirement

Notes

U.S. flag registered, coastal transit and subject to inspection under 46 U.S.C. 3301*

Federal Pilot required under 46 U.S.C. 8502, with exceptions

A federal first class pilot is required for oil barges over 10,000 gross tons (GT) For oil barges less than 10,000 gross tons and other vessels less than 1,600 GT, the Master, Mate, or Operator may serve as Pilot if the individual meets age and health requirement, and

Maintains current knowledge of the waters to be navigated.

Has at least six months’ service in the deck department on a towing vessel.

Exceptions are granted if federal manning standards are met for the licensing requirements

Any flag registration, international transit

State Pilot required under ORS 776.405, with exceptions

Exceptions: foreign recreational or fishing vessels 100 feet long or shorter, or 250 GT or less

U.S. flag registered, coastal transit and not subject to inspection under 46 U.S.C. 3301*

N/A Pilot not required, vessel master (captain) is required

* Vessels subject to inspection are: freight vessels, nautical school vessels, offshore supply vessels, passenger

vessels, sailing school vessels, seagoing barges, seagoing motor vessels, small passenger vessels, steam vessels,

tank vessels, fish processing vessels, fish tender vessels, Great Lakes barges, oil spill response vessels, and

towing vessels.

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Columbia River pilots and Columbia River Bar pilots assume navigation control of the vessels

they pilot. Two key aspects that support the value of pilotage on risk reduction are that he/she is:

Experienced in handling all oceangoing vessels on the waterway.

An independent decision informer, dedicated to safe maneuvering of the vessel.

Columbia River Bar Pilots board inbound vessels near the Columbia River Entrance Buoy,

outside of the Columbia River Bar. They navigate ships beyond the Astoria-Megler Bridge,

where vessels are turned over to a Columbia River Pilot. For outbound vessels, Columbia River

Pilots board at the terminal, and turn over to a Columbia River Bar Pilot prior to the Astoria-

Megler Bridge.

Washington State Department of Ecology

The Ecology Spill Prevention, Preparedness, and Response Program focuses on preventing oil

spills to Washington’s waters and land, and planning for and delivering a rapid, aggressive, and

well-coordinated response to oil and hazardous substance spills wherever they occur (Ecology,

2016). The program works with communities, industry, state and federal agencies, tribes, and

other partners to prevent and prepare for oil spills. The program also responds to spills 24/7 from

six offices located throughout the state and works to assess and restore environmental damage

resulting from spills. Spills Program activity includes:

Preventing oil spills from vessels and oil handling facilities.

Preparing for aggressive response to oil and hazardous material spills.

Rapidly responding to and cleaning up oil and hazardous material incidents.

Restoring public natural resources damaged by oils spills.

Ecology inspects commercial vessel cargo and passenger vessels over 300 gross tons, oil transfer

facilities, and oversees the transfer operations between ships and terminals (Ecology, 2017b). An

Ecology inspection includes the following elements:

Reviewing and approving operating manuals for large, fixed shore-side facilities (refineries

to small tank farms) and terminals with a fuel capacity of 10,500 gallons or more.

Monitoring oil transfer procedures.

Inspecting facilities for compliance with their prevention plan, operations manual, training

and certification program, and facility design standards.

Reviewing and approving oil spill contingency plans.

Evaluating required oil spill response drills.

Ecology also manages voluntary programs for the safe and pollution-free operation of tank

vessels (Ecology, 2017b). The Voluntary Best Achievable Protection (VBAP) and Exceptional

Compliance programs (ECOPRO) identify standards that represent many of the best practices

found on tank vessels throughout the world.

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VBAP and ECOPRO standards were developed jointly with industry representatives. The goal is

to provide standards higher than those required by law but achievable by today’s proactive

marine transportation companies.

Oregon Department of Environmental Quality

Oregon DEQ has an active role in prevention, response and mitigation of oil and hazardous

materials cleanup. They also respond to oil spills around the clock (DEQ, 2017). DEQ

communicates with local, tribal, state and federal partners and industry to begin a quick and

coordinated response. DEQ:

Works to develop oil spill response plans, train staff, and conduct exercises to confirm

successful execution of plans.

Develops plans that identify sensitive natural or cultural resources and specific response

strategies to minimize impacts to these resources. Plans have been developed for the

Columbia River.

Coordinates with other local and state agencies, federal partners and industry to cleanup oil

and hazardous material spills.

Develops policy to ensure spill response planning and preparedness activities occur inland to

address risks of increased oil transport.

Industry Standards and Practices

Several marine transportation industry organizations develop standards of operation to ensure

safety and environmental protection. These organizations engage in continuous activity to

improve technical and operational safety standards throughout the industry.

Classification Societies

Classification societies are independent, non-governmental organizations that develop standards

and best practices for the maritime, oil and gas industries. Ships are classified to verify the:

Structural strength and integrity of essential parts of a ship’s hull and its appendages.

Reliability and function of the propulsion and steering systems, power generation and

auxiliary systems.

They achieve this by applying their own rules and verifying compliance with international and/or

national regulations on behalf of flag administrations.

Most commercial ships in the world, and all commercial ships on the Columbia River, are built

to and surveyed for compliance with the standards developed by Classification Societies

(International Association of Classification Societies, 2017).

Classification societies verify vessel plans prior to and during construction, wherever the ship is

built. Once in service, the vessel must receive periodic class surveys, carried out onboard the

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vessel. These surveys verify that the ship meets the requirements for continuation of class. This

is in addition to inspections which may be carried out by the U.S. Coast Guard or other agencies.

American Petroleum Institute

The American Petroleum Institute (API) is an industry trade association that represents all

aspects of the oil and natural gas industry including marine transporters. One of API’s missions

is to promote safety across the industry globally.

API conducts or sponsors research ranging from economic analyses to toxicological testing. The

organization also develops safety standards and recommended practices for safe operations.

Currently, API maintains 685 different safety standards and recommended practices. Many of

these have been incorporated into state and federal regulations. They also certify oil and natural

gas equipment used onboard vessels and at bulk oil marine terminals.

American Waterways Operators

The American Waterways Operators (AWO) is a trade organization representing the U.S.

tugboat, towboat and barge industry. They have developed a program to assist the tug and barge

operators in developing safety management systems and assistance in complying with

regulations. The AWO Responsible Carrier Program is a U.S. Coast Guard accepted Towing

Safety Management System as defined in 46 CFR Subchapter M.

Towing Vessel Company Practices

Safety measures for towing oil barges on the Columbia River and Bar were discussed with

towing industry representatives. Examples of company guidance for towing oil on the Columbia

River and Bar include:

Specifications for towing equipment size and strength.

Regular tow wire inspection and replacement.

Requirement for daylight arrivals at the Columbia River Bar.

Guidance to tug Masters to determine bar conditions before arrival, and determine if crossing

will be safe.

Prohibition on towing more than one oil barge at a time across the bar.11

Pre-arrival notifications and standard call-in points along the river.

Use of tag tugs on the Columbia River.

The installation and use of safety equipment including barge retrieval wires (“insurance

wires”) and barge recovery systems (Orville Hook).

11 In addition to company guidelines, in May 2017 the Lower Columbia Region Harbor Safety Plan Towed Barge

Guidelines were amended to state that barges carrying oil should not be towed in tandem so that if the tow wire

parts, the tug is free to recover the barge.

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Merchants Exchange of Portland, Oregon

The Merchants Exchange of Portland operates a communications center that is available 24

hours a day, 365 days a year to provide information and to assist vessels in the Lower Columbia

and Willamette Rivers. The Merchants Exchange monitors communication channels and tracks

vessel movements between Astoria, Portland, and Vancouver (Merchants Exchange of Portland,

Oregon, 2017).

Vetting Practices

Oil companies manage their risks through screening vessels and terminals to a set of minimum

standards, including regulatory compliance. Over the past 25 years, oil companies have raised

the standards for tank vessels through a process referred to as vetting. Vetting includes

inspections and audits of vessels and terminals. While vetting practices are not mandatory,

compliance is normally required to be eligible for contracts to carry oil.

The OCIMF is a key organization that enables an effective global vetting system. The forum,

established in 1970, develops safety and environmental protection standards and regulations in

the maritime transportation and handling of oil. It also hosts data for charterers and regulatory

authorities on tankers and barges through the Ship Inspection Report (SIRE) program.

Ship Inspection Report Program

The OCIMF introduced SIRE to specifically address concerns about sub-standard shipping

practices. The SIRE Program is a tanker risk assessment tool. It provides common information to

charterers, ship operators, terminal operators and government bodies about the safety systems,

practices, and material conditions of particular vessels.

SIRE inspections are conducted by third party auditors who meet OCIMF qualification

requirements and use a uniform inspection protocol. More than 180,000 inspection reports are in

the SIRE database. In the past 12 months, over 22,500 reports on over 8,000 vessel inspections

have been added to the SIRE database (OCIMF, 2017a).

Incomplete or unsuccessful SIRE inspections can result in:

Loss of contracts.

Additional safety, equipment, and management requirements.

Probationary periods where contracts are not awarded until SIRE inspection deficiencies are

corrected.

Tanker Management & Self-Assessment

The OCIMF also hosts the Tanker Management & Self-Assessment program (TMSA). This

program provides a set of industry best practices for vessel operating companies to assess

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operator safety management systems. It is based on the International Safety Management Code.12

Vessel operators use the assessment results to continuously improve their safety management

systems.

As with SIRE reports, results of TMSA assessments are shared among the oil handling supply

chain and government regulators. The same conditional requirements of the SIRE are also

applicable to the TMSA with respect to contracting.

Company Vetting

In addition to the OCIMF programs (SIRE and TSMA), individual companies each have their

own vetting programs. Company vetting programs often exceed the requirements of SIRE and/or

TSMA, as well as U.S. Coast Guard or Ecology requirements. They may also be specific to a

particular voyage or route.

The programs often add requirements not part of a regulatory scheme, or provide an incentive for

compliance with voluntary requirements. For example, the Lower Columbia Region Harbor

Safety Plan includes a Standard of Care stating that tugs towing oil loaded barges astern should

use an additional tug to assist tugs towing oil barges astern (tag tug) (LCRHSC, 2016). A

company may require a tag tug on all barges carrying its cargo as part of its vetting program. In

such a case, the tag tug and its operating company would be subject to company vetting. The

effect is that the tag tug becomes a condition of the contractual relationship and the voyage.

Terminal Vetting

Terminals also can be vetted by ship owners under the Marine Terminal Information System

(MTIS). Compared to SIRE, it is a relatively new repository. It captures information offered by

terminal operators about their physical arrangements such as depth and mooring, and the

terminals’ management systems. Though the new system is voluntary, some of the terminals on

the Columbia River have already entered their data in the MTIS (OCIMF, 2017b).

Navigation Route Risk Controls

The U.S. Army Corps of Engineers

The U.S. Army Corps of Engineers (USACE) maintains safe and reliable channels, harbors, and

waterways for the transportation of commerce, support to national security, and recreation

(USACE, 2017). The USACE Northwest Division in Portland, Oregon maintains the 43-foot

deep, federally-authorized navigation channel in the Columbia River to a minimum width of 600

feet.

During the CRVTSA Risk Results and Mitigation Workshop, participants identified that

additional dredging in and near the channel could enhance navigation safety. In some spots, there

is an accumulation of sediment along the edge of the channel. This shoaling reduces the available

12 Adopted by the International Maritime Organization, the International Safety Management Code provides

guidance for the safe management and operation of ships and for pollution prevention.

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depth of water near the channel boundaries. The pilot of a deep draft vessel must be highly

attentive and make multiple course adjustments to prevent turning on the shoals. If these shoals

were removed by dredging, grounding risk would be reduced in these areas.

In the navigation channel, shoaling reduces the available depth. As a result, the vessels wait at

their berths for the tide to increase to allow a minimum of two feet under keel clearance. When

the minimum depth of water is available, the vessel will leave the berth and head downriver.

Additional dredging would improve vessel wait times and under keel clearance.

USACE is developing a Channel Maintenance Plan to cover the next 20 years. The plan will

define the necessary activities to assure safe deep draft navigation. The formal planning effort

began in early 2017.

The USACE also manages water flow through the upriver pools and dams to ensure water depths

are maintained for safe navigation. Refer to Appendix K, Characterization of the Middle

Columbia River-Snake River Waterway System, for more information on the management of

upriver dams and locks.13

U.S. Coast Guard

The U.S. Coast Guard manages aids to navigation on the Columbia River including an array of

audio, visual, radar, and radio aids to navigation, such as lights, buoys, sound signals, range

markers, and radio beacons. In addition, the U.S. Coast Guard consults federal agencies, state

representatives, waterway users, and the general public to study waterways for safety and

efficiency. The Coast Guard is engaged locally with the Harbor Safety Committee.

National Oceanic and Atmospheric Administration

NOAA provides climate predictions and projections; weather and water reports; forecasts and

warnings; nautical charts and navigational information; and the continuous delivery of Earth

observations and scientific data for use by public, private, and academic sectors. Two NOAA

offices, the National Ocean Service and the National Weather Service deliver products and

services that support navigation on the Columbia River and Bar.

The National Ocean Service is responsible for providing real-time oceanographic data and other

navigation products to promote safe and efficient navigation. Mariners rely on the mapping,

charting, and water level information provided by National Ocean Service offices around the

country. On the Columbia River, the National Ocean Service operates and manages the Physical

Oceanographic Real-Time System (PORTS).

The PORTS water level information is received directly onboard vessels. It is used with

electronic nautical charts and real-time vessel location data to provide vessel operators and pilots

with voyage planning information. PORTS data are also incorporated into the Port of Portland

LoadMax system, described below.

13 Appendix K is provided for information, and describes the waterway east of the I-5 Bridge. The quantitative and

qualitative analysis, findings, and recommendations of this evaluation are focused on the Columbia River west of

the I-5 Bridge.

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The National Weather Service provides weather, water, and climate data, forecasts and warnings

for the protection of life and property, and enhancement of the national economy. The National

Weather Service owns and operates National Data Buoy Center buoys. The National Centers for

Environmental Prediction, which produce the Nearshore Wave Predictive System model, are part

of the National Weather Service, as is the Weather Forecast Office, Portland.

Other Safety Practices

This section describes other safety practices and functions unique to the Columbia River and

Bar, in addition to those described above.

Lower Columbia Region Harbor Safety Committee

The primary function of the Harbor Safety Committee is to assure safe navigation to protect the

environment, property, and personnel of the Lower Columbia Region waterways.14 It is made up

of an Executive Steering Committee, a Managing Board, Subcommittees, and General

membership. Its membership is intended to be inclusive of all interested waterway user groups

and other members of the public who want to participate.

Harbor Safety Committee standards and guidelines are contained in the Lower Columbia Region

Harbor Safety Plan. The elements of this plan are developed by subcommittees made up of

stakeholders and experts. The plan is cooperatively drafted by regulators and industry

representatives. Compliance with the Harbor Safety Plan is voluntary; however, there are strong

industry and regulatory controls in operation that collectively ensure compliance. These include

the good practices of companies operating on the Columbia River, the role of the Columbia

River Bar Pilots and Columbia River Pilots onboard vessels during transits, and the authority of

the Coast Guard Captain of the Port to direct vessels to comply with the Harbor Safety Plan if

needed.

Elements of the plan include:

Aids to Navigation Guidelines.

Anchorage Guidelines.

Bunkering Guidelines.

Dam Lockage Guidelines.

Incident Management Guidelines.

Lightering15 Guidelines.

Plan Enforcement.

Required Charts and Publications Guidelines.

Restricted Visibility Guidelines.

14 The Lower Columbia Region encompasses the Columbia River and its navigable tributaries from the seaward

approaches to the Columbia River Entrance to Bonneville Dam (LCRHSC, 2016).

15 Lightering is the transfer of petroleum cargo in bulk from one tank vessel to another tank vessel while at anchor,

or at a dock that is not regulated under the facility response plan and other requirements of 33 CFR 154.

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Severe Weather and Natural Disaster Guidelines.

Small Vessels and Make Way Rule Guidelines.

Towed Barge Guidelines.

The Towed Barge Guidelines state tag tugs should be used when towing a loaded oil barge

astern, when the barge is of more than 25,000 barrel capacity (LCRHSP, 2016).

Tag tugs are typically smaller tug boats that are attached to the stern of the oil barge. The tag tug

assists with steering the barge, and keeps the barge behind the towing tug. Some of the benefits

of tag tugs (e.g., reduced powered grounding and drift grounding frequencies) were quantified

and included in the navigation risk model used in this study. The potential for tag tugs, as

described above, to reduce collision risks could not be evaluated.

The Towed Barge Guidelines were amended in May, 2017 to state that barges carrying oil should

not be towed in tandem so that if the tow wire parts, the tug is free to recover the barge.

Under Keel Clearance

The USACE maintains the Columbia River navigational channel at 43 feet below Columbia

River Datum.16 All vessels are piloted with a minimum of two feet under keel clearance. Vessels

with a freshwater draft of less than 36 feet are generally able to transit the river and bar at any

time, weather permitting. Occasionally, water levels are lower than the Columbia River Datum.

When this happens, the River Pilots may manage under keel clearance by reducing the vessels’

maximum operating draft in the river to ensure that the two feet under keel clearance is

maintained throughout the transit. Additionally, the Bar Pilots may adjust vessel transits to make

use of available water during tidal windows. Vessels that exceed the minimum draft may be

required to either wait outside the bar, or, if already inside, wait at anchor or at the berth.

TransView 32

TransView 32 (TV-32) is custom-made software jointly developed by the Columbia River Pilots,

the Columbia River Steamship Operators’ Association, and the U.S. Department of

Transportation’s Volpe National Transportation System Center. The vessel agent members of the

Columbia River Steamship Operators’ Association continue to contribute a per-vessel

assessment to fund ongoing maintenance and operation of the TV-32 system and work

collaboratively with the Columbia River Pilots to ensure a safe and effective system for river

users. Columbia River Pilots run the software on laptops brought onboard the vessels they pilot.

The function of TV-32 is to display vessel contacts on a Graphical User Interface. It can be used

to calculate the distance between any two points on the display to determine vessel meeting

points, closest point of approach, and the estimated time of arrival of any vessel contacts on the

display. It continuously imports the most recent sounding data from the USACE and provides an

exact replica of the channel’s depths.

16 The reference plane for measuring depths on the Columbia River, representing the mean lower low water during

lowest river stages.

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TV-32 information is also available to other river stakeholders and operators, including the U.S.

Coast Guard, the Merchants Exchange of Portland, Oregon, vessel agents, and terminal

operators.

Sea IQ

Sea IQ is a commercially available pilot tool that combines bridge navigation equipment, NOAA

charts, Corps of Engineers hydro surveys and NOAA tide gauges into a single display. Similar to

TV-32, Sea IQ is currently used by the Columbia River Bar Pilots.

Coastal Data Information Program

The Coastal Data Information Program (CDIP) measures, analyzes, archives, and disseminates

coastal environmental data (Scripps Institution of Oceanography, 2017a). The CDIP program

deployed two wave buoys (buoys 46243 and 46248) on the Columbia River Bar in 2011, in

addition to the buoys maintained by the NOAA National Weather Service. The USACE funded

one buoy; the second was funded by the Columbia River Bar Pilots and the State of Oregon. An

additional buoy was purchased by the Bar Pilots and Oregon; this buoy serves as a spare for

rapid deployment if a buoy fails. The USACE funds the ongoing maintenance and repair of the

CDIP buoys. These buoys are an important improvement to bar safety because they supply real-

time data to Columbia River Bar pilots. Severe weather can cause the buoys to be out of service

and also hampers replacement of the buoys.

LoadMax

LoadMax is a program developed for the river and bar pilots that forecasts hourly river levels. It

uses real-time river gauge information and combines it with rainfall runoff predictions and dam

and lock operator information (Port of Portland, 2017). LoadMax information is used with TV-

32. Based on the estimated arrival and departure times provided by agents and terminal

operators, the pilots can predict with relatively high level of accuracy what the river levels will

be for the days’ requested transits. This helps them determine if under keel clearances will be

met.

Columbia River Bar Prediction Models

On the bar, under keel clearance changes frequently and is not monitored real-time. The best

available information is from a computer-based Dynamic Under-keel Clearance system. It was

developed by OMC International in coordination with the Columbia River Bar Pilots.

The system uses information from several other data sources to estimate under keel clearance on

the bar, including:

LoadMax.

Coastal Data Information Program buoy data.

Tide gauge data.

NOAA current and forecast data.

A wave forecast model.

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Researchers at Oregon State University developed a wave forecast model, which was validated

using OMC data. The model is run once per day and the output is available 25-hours to 48-hours

into the 84-hour forecast. This is not frequent enough to support pilot decision making about the

safety of crossing the bar, discussed further in the Risk Reduction Measures section.

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Evaluation of Cargo Oil Spill Risk

Background

This evaluation estimated cargo oil spill risk using basic principles of engineering, marine safety,

and risk assessment and was designed to analyze Best Achievable Protection. The cargo oil spill

risk results are reported in a format that is well suited for the intended purpose (i.e., analyzing

Best Achievable Protection). The cargo oil spill risk results in this format are not intended to be

used for other purposes, such as predicting how much oil is likely to be spilled in the future.

An estimate of current cargo oil spill risk on the Columbia River was an important intermediate

step toward an analysis of Best Achievable Protection. If an area has a history of oil spills, then

statistical analysis of past cargo oil spills can be used to estimate the number and size of future

events. However, likely as a result of robust improvements in vessel traffic management and

vessel safety, such as double hull requirements, there have been few cargo oil spills on the

Columbia River and Bar in recent history.

Modeling

The most credible way to estimate cargo oil spill risk on the Columbia River and Bar is to

develop a model based on underlying failures that relate to the global fleet of vessels. The

international nature of the shipping industry gives further justification of this approach. This

study built a Columbia River-specific model using the Marine Accident Risk Calculation System

(MARCS) tool. MARCS was developed in 1998 at the request of the Commission of European

Countries as part of a large study on the Safety of Shipping in Coastal Waters (Fowler and

Sørgård, 2000).

The Safety of Shipping in Coastal Waters project analyzed the contributors to marine accidents

to determine factors that could increase the safety of shipping in coastal waters. It included

significant research and development on marine risk control options. Historical accident data

were analyzed to establish the basis for modeling of aspects that did not have generic models and

to validate the overall model. Independent data sources were used. The result was a systematic

listing and ranking of causes, conditions, and risk reduction measures that most significantly

affect risk levels.

MARCS has been updated and re-validated several times since then, including a river-optimized

version of the model to complement the open water model. The river version was used in this

work, and is described in Appendix E, Description of Risk Methodology. Its validation is

described in Appendix H, MARCS Model Validation.

Analysis of historical ship incident data indicates that almost all shipping losses (except for

intentional events, such as war or piracy) can be categorized into the following generic incident

types:

Ship-to-ship collision.

Powered grounding (groundings which occur when the ship is able to navigate safely yet

goes aground).

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Drift grounding (groundings which occur when the ship is unable to navigate safely due to

mechanical failure).

Structural failure (inability of the structure to withstand loads) / foundering (taking on water

and sinking).

Fire / explosion (most often in the engine room).

The MARCS model used global failure rates on all vessels for:

Human decisions in critical situations.

Human actions in critical situations.

Critical onboard equipment (average failure rate per sailing hour).

The evaluation assumed that either (1) oil cargo vessels on the Columbia River have the same

above failure rates as the global fleet, or (2) all the oil cargo vessels on the Columbia River have

lower failure rates than the global fleet – by the same relative factor.

To account for local variations, adjustment factors were applied to the global failure rates to

account for differences between local and global practices. These include, pilotage, under keel

clearance management, port state control, and others.

Not all of the safety practices on the river and bar could be quantified (e.g., the effect of tag tugs

on reducing barge collision risks). So this study overestimates the cargo oil spill risk by at least

the additional protection provided by the unquantifiable risk controls.

The model calculated frequencies and spill volumes for every vessel type (34) along every sailed

mile of river (105 miles), and did this for each of the five relevant incident types. The frequency

of collision was calculated for every vessel type potentially passing every other vessel type at

every river mile where they might cross. The number of calculated scenarios is almost 750,000

frequency-volume pairs for each of the 8 modeled situations (3 cases + 5 risk reduction

measures).

Spill Risk Terms

Spill risk was calculated as spill quantity [metric tons (MT) per event] multiplied by the spill

frequency (events per year). One calculation was carried out for each of the incident types for

each of the vessel types, including all combinations of collision between the vessel types. Per

river mile, this resulted in thousands of risk scenarios, each the product of a quantity and

frequency.

Risk = consequence x frequency

Spill Risk (MT/year) = quantity (q; metric tons/event) x frequency (f; events/year)

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Two types of scenarios do not spill cargo oil: the vessel is not carrying cargo oil or the energy in

the incident is too low to breach the double hull that protects the cargo oil. Most of the vessels on

the river do not carry oil cargo, so most of the scenarios pose zero risk of spilling cargo oil.

To illustrate how the data model developed risk quantities, Table 6 lists four sample spill

scenarios. The river model had 19,000 spill scenarios in Case A, and another 186,000 scenarios

that did not spill cargo oil. Because of the large number of scenarios, publication of them is not

practical.

The spill quantity in Table 6 is in metric tons (MT) because the risk model was programmed

using the IMO guidance to estimate oil spill quantities and their related probabilities (IMO Res.

MEPC. 122(2)). The IMO curves are based on vessel size, in metric tons, and therefore the

output is in metric tons.

Table 6: Cargo Oil Spill Results for Four Selected Scenarios

Spilling Vessel Type

Incident Type

Spill Frequency

(events/year, f)

Spill Quantity in

MT/event, q)

Spill Quantity in

gallons/event*

Risk (MT/yr) = f x q

ATB Powered grounding

0.0020 510 160,000 1.00

Oil Tanker Powered grounding

0.0016 840 270,000 1.35

Future Project Oil Tanker

Drift grounding

0.0041 860 270,000 3.48

Tug, Oil Barge In Tow

Collision 0.0001 180 57,000 0.01

* A density of 0.827 g/cm3 for Bakken crude was assumed for the conversion of MT to gallons.

The model summarized the risk calculations for all 750,000+ scenarios to calculate the aggregate

risk per year. It is important to note that aggregate risk per year does not represent an expected

spill volume per year but is useful for quantifying and analyzing risks. Determining aggregate

risk was an intermediate step in the evaluation. The aggregate risk per year for each scenario was

used to compare risks before and after risk reduction measures were applied, as part of the cost-

benefit analysis.

Baseline Cargo Spill Risk

Cargo Spill Risk in Columbia River

Risk results for the Columbia River were modeled from River Mile 0 to River Mile 105. As

mentioned earlier, the risk was calculated for each of the many scenarios in the Case A model.

For each scenario, the frequency and spill quantity were multiplied to get an annual average risk

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in MT/yr. The scenario risks were added together, and the sum for each laden vessel type shown

in Table 7. The Columbia River risk was estimated to be 11 MT/yr, measured in aggregate oil

spill risk.

Table 7: Cargo Oil Spill Risk River Case A (Current Traffic)

Vessel Type Aggregate Oil

Spill Risk (MT/yr)

ATB Laden Inbound 6

Oil Tanker Laden Inbound 3

Tug Oil-barge-in-tow Laden Inbound 1

Tug Oil-barge-in-tow Laden Outbound <1

Oil Tanker Laden Outbound <1

ATB Laden Outbound <0.1

Total17 11

The risk was generally proportional to the relative volume of traffic. Laden ATBs amount to

approximately 50% of current laden tank vessel traffic, and laden ATBs moving upriver, or

inbound, were the highest risk for Case A. This finding does not imply that ATBs are “high risk”

vessels, but that they contribute the most to the current risk profile since they have the most

transits.

17 Note that rounded numbers may add to a different total than shown.

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Figure 5: Spill Risk by Vessel and Incident Type

The results displayed in Figure 6 indicate that two-fifths of the oil spill risk was from powered

groundings, followed by collisions, which contribute about one third. The data also show that the

estimated spill risk from a drift grounding was about double the risk from an onboard fire, a very

infrequent event that rarely shows up on a risk map such as this. This indicates that current safety

systems are highly effective.

Additionally, few opportunities exist to ground on rocks on the Columbia River because most of

the river bottom and sides (88%) are soft, dispersing the energy of a grounding event.

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Figure 6: Oil Spill Risk Contributors River Case A (Baseline Traffic)

Oil Spill Risk Per River Mile

As expected, the risk profile for the baseline traffic generally aligned with the vessel count in

AIS sailing at a given place (Figure 7 and Figure 8). The peaks in risk due to powered grounding

correspond to locations on the river where rocks are near the navigational channel. For example,

the peak at River Mile 39 is due to a turn in the channel and the presence of a rock hazard.

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Figure 7: Oil Spill Risk per River Mile Case A (Baseline Traffic, River Mile 0 to 58)

0

0.1

0.2

0.3

0.4

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0.6

0.7

0.8

0 10 20 30 40 50

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ill R

isk

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Structural Failure

Powered Grounding

Fire/Explosion

Drift Grounding

Collision

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Figure 8: Oil Spill Risk per River Mile River Case A (Baseline Traffic, River Mile 59-105)

0

0.1

0.2

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0.5

0.6

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59 69 79 89 99

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Structural Failure

Powered Grounding

Fire/Explosion

Drift Grounding

Collision

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Cargo Spill Risk on Columbia River Bar

Risk contributors on the bar, which include unanticipated weather conditions, equipment failures,

poor ship handling characteristics, crew competency, and other vessel material and human

factors, were identified through conversations with the Columbia River Bar Pilots and

discussions with evaluation participants. The cargo oil spill risk on the Columbia River Bar

(River Mile -5 to River Mile 0, in this evaluation) could not be modeled or quantified, due to the

complex nature of the interactions between forces that effect vessels in the area (e.g., waves,

wind, currents, water depths).

The incident types of greatest concern are related to severe weather conditions, and include

structural failure, grounding, and the loss of an oil barge by a towing vessel.

In general, the existing safety measures that apply on the Columbia River are also in place on the

bar. In addition, a key risk control for all vessels is the decision about whether or not it is safe to

cross the bar. Several individuals and organizations play a role in this decision making process.

Each vessel master has the ultimate responsibility for the safety of his or her crew, vessel, and

cargo. The Columbia River Bar Pilots conduct vessel traffic management, and determine whether

it is safe to bring each vessel across the bar, for every transit they conduct. The Columbia River

Bar Pilots suspend pilotage and resume pilotage services as needed, based on the conditions.

Tools that support the Columbia River Bar Pilots include:

A fast-response pilot transportation system.

Regular communications with the maritime community, including the U.S. Coast Guard, the

NOAA Weather Forecast Office, the Merchants Exchange of Portland, Oregon, the Columbia

River Pilots, and individual vessels.

The safety culture of the Columbia River Bar Pilots.

The U.S. Coast Guard coordinates closely with the Columbia River Bar Pilots and controls the

status of the bar. The Coast Guard can issue restrictions on bar crossings, or close the bar to

vessel traffic entirely.

Four buoys provide important environmental data for the Bar. Two are owned by the NOAA

National Data Buoy Center (buoy 46029 and 46089). Two are owned by the Coastal Data

Information Program (buoy 46243 and buoy 46248). These buoys supply real-time data to the

Columbia River Bar Pilots but are frequently out of service in the winter, when storms are more

frequent.

Key results of a recent bar under keel clearance study (OMC International, 2011) stress the

complexity of the sailing conditions on the bar. The study noted that pilot judgment is a key

existing risk control. The Columbia River Bar Pilots stated that risks are well managed now, and

identified enhancements that could help further reduce risks. These are described below, in

Potential Risk Reduction Measures.

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Potential Future Cargo Spill Risk

Columbia River

This section describes spill risk from oil cargoes on the river for two potential future scenarios,

Case B and Case C. As described above, Case B included baseline vessel traffic (Case A) plus

25% of traffic from proposed terminal projects. Case C included baseline vessel traffic plus

100% of traffic from proposed terminal projects.

Analysis

The model output for all three cases is shown in Table 8 for total cargo oil spill risk. Laden

inbound ATBs was the biggest risk contributor in Case A. In Case B, and C, new project tankers

transporting oil cargo outbound became the biggest risk contributor.

Table 8: River Cargo Oil Spill Risk Comparisons

Vessel Type

Aggregate Oil Spill Risk (MT/yr)

Case A Case B Case C

ATB Laden Inbound 6 6 7

Future Project - Oil Tanker Laden Outbound - 12 50

Oil Tanker Laden Inbound 3 3 4

Tug Oil-barge-in-tow Laden Inbound 1 1 1

Tug Oil-barge-in-tow Laden Outbound <1 1 1

Oil Tanker Laden Outbound <1 <1 <1

ATB Laden Outbound <0.1 <0.1 <0.1

Total18 11 23 63

When all the scenarios were summed, Case C risk was about five times the baseline risk

(Case A). The large increase in cargo spill risk is because most of the additional traffic is from

deep draft vessels, and a larger fraction of the new traffic is carrying cargo oil.

Risk contributors for Cases B and C are shown in Figure 9 and Figure 10. The total cargo oil

spill risk for Case B from all vessel types and incident types is 23 MT/yr. For Case C, the total is

63 MT/yr. Future project tankers contribute the most to cargo oil spill risk in Cases B and C.

18 Note that rounded numbers may add to a different total than shown.

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Figure 9: Key Risk Contributors in River Case B (Baseline Traffic+ 25% Projects)

Figure 10: Key Risk Contributors in River Case C (Baseline Traffic+ 100% Projects)

Comparison of risks

An overview of the summed scenario risks per incident type is shown in Figure 11. Case A is the

shown on the left, Case B is in the middle, and Case C is on the right. ATB powered groundings

contributed the most to Case A cargo oil spill risk on the river. For Cases B and C, future project

– oil tankers contributed the most, distributed among groundings and collision.

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Figure 11: Case Comparison – Detailed Cargo Oil Spill Risk Contributors

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Columbia River Bar

It is expected that cargo oil spill risk on the river and the bar are closely related, but the hazards

on the bar interact with the different sized vessels in dissimilar ways. The future traffic Case C

for the river shows an increase in risk, to a level more than five times the baseline cargo oil spill

risk. It could reasonably be expected that an increase would be seen for the bar.

The incident types of greatest concern are likely to be structural failure, grounding, and the loss

of an oil barge by a towing vessel. Knowledge of how the environment on the bar interacts with

the various vessel types is still being developed. It is not possible to identify which vessel types

contribute the most to the risk on the bar.

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Potential Risk Reduction Measures

This evaluation analyzed and compared potential risk reduction measures for preventing cargo

oil spills. Based on input from workshops, Ecology and DNV GL finalized the list of potential

risk reduction measures (Table 9). The measures were evaluated quantitatively using the

MARCS model, and the results are discussed following the table.

Measures for Columbia River

Table 9: Evaluated Potential Risk Reduction Measures

Potential Risk Reduction Measure

Affected Risk Contributors Impact of Reduction Measure

Tethered tug escort of laden tankers

Drift grounding of laden tankers

Powered grounding of laden tankers

Reduces the likelihood of drift grounding and powered grounding from an equipment failure.

Untethered tug escort of laden tankers

Drift grounding of laden tankers

Reduces the likelihood of drift grounding from an equipment failure.

Tethered tug escort of laden ATBs

Drift grounding of laden ATBs

Powered grounding of laden ATBs

Reduces the likelihood of drift grounding and powered grounding from equipment failure. The relative effect from this is smaller than for the other vessel types, because of existing risk controls: the ATBs on the river have two engines and two rudders.

Pilot on laden traditional towed barges and ATBs19

Collision of laden towed tank barges

Powered grounding of laden tank barges

Reduces the likelihood of collision and powered grounding from human error.

Fully redundant propulsion on laden tankers (e.g., independent systems that can maintain propulsion/steering with any single failure)

Drift grounding of laden tankers

Powered grounding of laden tankers

Reduces the likelihood of drift and powered grounding due to equipment failure

19 Note that ATBs larger than 10kGT are required to have a federal first class pilot. This measure evaluates the value

of an additional qualified person joining the captain on the bridge to assist with navigation. Further details are

provided in the pilotage section.

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Tug Escorts of Tankers and ATBs

The benefits of tug escorts for tankers were modeled, assuming both tethered tugs and untethered

tugs. Tethered tug escort can significantly reduce the potential consequences of loss of

propulsion or steerage in a narrow waterway. An escort tug that is tethered at the beginning of a

voyage is more effective than an untethered escort tug. It has a much better opportunity to

control the tanker if the tanker loses its propulsion or steering ability.

Studies and simulation reports reviewed for this evaluation (e.g., OCIMF, 2007) showed an

appropriately-sized escort tug tethered at the stern provides good control of an underway vessel.

From the stern, it has a large lever to work with because of its distance from the central pivot

point of the tanker.

Untethered tugs were also modeled to determine the amount of risk reduction benefit they could

provide, and to identify differences in the cost-benefit ratio between tethered and untethered

escort tugs. Because ATBs have some level of redundancy already, as discussed below, only

tethered escort tugs were modeled for ATBs.

Tugs towing oil barges on a tow wire employ “tag tugs” as described in the Lower Columbia

Region Harbor Safety Plan. Tag tugs are typically smaller tug boats that are attached to the stern

of the oil barge. The tag tug assists with steering the barge, and keeps the barge behind the

towing tug. Due to the use of tag tugs, tug escorts for towed oil barges were not evaluated.

To determine the maximum possible risk reduction from tug escorts of tankers and ATBs, the

following tug abilities were assumed:

The escort tug has sufficient bollard pull and maneuverability to achieve its intended aims in

all weather conditions under which laden vessels are allowed to transit the river.

The tug is designed and maintained to withstand the forces it would see in the most severe

conditions it might encounter during an escort.

The model assumed that vessels escorted by tethered tug experienced the same equipment and

human failures as unescorted tankers. The tug could intervene and take control of the vessel

should a propulsion or steerage failure occur. The model showed the likelihood of success to

prevent the grounding that would have otherwise occurred.

A review of global best practices (e.g., OCIMF 2007) in tethered tug escort found several

important features to consider:

1. Waterway-specific tug escort guidelines: The procedures and requirements for tethered tug

escort are identified and agreed to in advance. The tank vessel master, the pilot, and the

escort tug master hold a pre-escort conference to discuss and agree voyage details. The

purpose of the towing guidelines is to assure an expected standard for the safety of all.

Guidelines also reduce the likelihood of miscommunication, misalignment, and human error.

2. Requirements for the towing vessel: The tug capabilities required to prevent a disabled tanker

from grounding.

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3. Requirements for the tanker: Tankers are required to have certain equipment and

certifications to ensure they can safely be controlled by their tugs. Examples include testing

of strengthened bitts and the maximum age of the vessel.

4. Cargo owner (charterer) requirements: There are requirements for the charterer that will help

to assure a safe intervention if it were needed. These include minimum manning/experience

requirements for the vessels and management system standards.

Columbia River Tug Escort Guidelines

Consistent with what has been done in other waterways, the Harbor Safety Committee could

develop and adopt tug escort guidelines that define practices for safe tug escort of laden oil

tankers on the Columbia River. The guidelines ideally should cover a wide range of topics such

as:

Communications.

Exchange of information between the vessel master(s) and pilot.

Contents of a towing plan.

Preparations.

Connecting.

Safe speed.

Guidelines for pilots and masters.

Visibility.

Escort training requirements (ideally using full mission tug simulators).

Tug manning.

Tug capabilities (such as braking force, bollard pull, and drive type).

Tanker requirements.

Considerations for the Columbia River Bar.

Experts such as pilots, terminal operators, naval architects, and simulation modelers can provide

technical input to such plans. A Columbia River guideline can help to assure best practices are

implemented safely. In addition, it could reduce errors during an implementation phase for tug

escorts. This section does not intend to limit decisions made by the tanker’s master, or the state

or federal pilot concerning safe navigation.

For additional discussion, see Appendix N, Considerations Regarding Escort Tug Capabilities.

Additional Pilotage on Tugs/Towing Vessels

This measure was applied in the model to tugs towing barges that are inbound with oil cargoes.

Tugs towing laden oil barges were given the risk reduction benefit of having a pilot onboard, as

defined below.

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Pilotage

The risk quantification in this assessment was neutral to regional or local definitions of pilotage.

The study used the best available information on the quantified benefits of “pilotage.” This

information can provide a basis for local regulators and legislators to develop a definition that

suits the local context.

To help protect against harm, federal and Oregon state laws require certain ships to use pilots

who have detailed knowledge of local conditions. These conditions include water depth,

currents, tides, how other vessels are typically navigated, and navigational hazards. Vessel

operators or charterers also sometimes choose to hire state-licensed pilots as an additional safety

measure, or to meet federal pilotage requirements. Pilots take navigational control of vessels in

pilotage waters. Vessel masters retain ultimate responsibility for safe navigation of their vessels,

although their options to relieve a pilot are limited to gross negligence or incapacity of the pilot.

For this evaluation, the pilotage benefit information was based on previous studies involving

large international ports. In these studies, the pilot was always a person with a credential who

boarded the vessel for the voyage across the pilotage waters, usually defined as all waters

between a specific seaward demarcation, like a buoy, and the intended berth. The pilot remained

on the bridge while the vessel was in pilotage waters, and had an advisory role focused on safe

navigation, with no other onboard responsibilities.

The key benefits of this arrangement are:

Pilots know the local waters very well.

The pilot is rested and boards for the specific voyage, joining the captain on the bridge.

The pilot has a portable pilotage unit, such as TV-32, which is continually updated.

The pilot meets significant requirements for experience sailing a wide variety of vessels and

documented time sailing the specific waterway.

The pilot meets annual training/recertification requirements which keeps him/her current on

navigation technologies.

In most ports, pilots are free from any commercial influence, and their job performance

evaluations are not negatively affected if they decide not to sail.

Fully Redundant Propulsion and Steering Systems

Propulsion or steerage failures are key mechanical contributors to spill risk from groundings.

Fully redundant propulsion and steering systems (e.g., independent systems that can maintain

propulsion/steering with any single failure) significantly reduce risks from equipment failures.

When one system is down, the other is still capable of controlling the vessel.

Tankers typically do not have fully redundant propulsion or steering systems; this risk reduction

measure looked at the protection that having fully redundant systems could provide. ATBs and

traditional tugs towing barges that carry cargo oil already have partially redundant systems (e.g.,

two engines, two rudders that are not independent; a single failure could result in a loss of

propulsion/steering). Therefore, this measure was only applied to tankers.

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Measures for the Columbia River Bar

As noted previously, pilot judgement is an existing key risk control for the Columbia River Bar.

The Columbia River Bar Pilots stated that additional tools could enhance their ability to make

decisions about whether or not it is safe to bring a vessel across the bar:

A real-time wave forecast model with high resolution to support decision making. This

would be a clear improvement in navigation safety on the bar. Other bars on the west coast

have high-resolution forecast models, but the Columbia River Bar is the most complex to

model.

A land-based radar would provide coverage of the Columbia River Bar and approaches.

AIS transponders on barges crossing the Columbia River Bar would assure that pilots and

other vessels have a way to identify the location of the barge.

The potential effect of these tools and implementation considerations are described in detail in

Risk Reduction Measure Results for the Columbia River Bar.

Global best practices for tethered escort (e.g., OCIMF 2007) were developed for tows in calm

waters, like the Columbia River. Opportunities may exist to use escort tugs to reduce risk on the

Columbia River Bar. An example that was discussed with workshop participants was the San

Francisco Bar. In San Francisco, the escort tug is tethered in the sheltered waters, releases the

tanker before the tanker crosses the bar, and waits at a designated location until the tanker is in

open water. Additional studies, discussions, and guidelines would be required to determine

conditions when an escort tug for tankers crossing the bar could improve safety.

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Risk Reduction Measure Model Results

Each of the five risk reduction measures that could be evaluated quantitatively were assessed

using the MARCS model and are discussed in this section. Each risk reduction measure is

discussed in detail below. Results are shown as the potential amount of risk reduction compared

to Case C.

Case C included baseline vessel traffic, plus 100% of potential future vessel traffic associated

with proposed projects. The list of proposed projects and vessels is provided in Appendix F,

Study Basis.

Risk reduction is expressed in metric tons per year. This indicates how much less cargo oil, in

metric tons per year, would be spilled after applying the risk reduction measure, compared to the

traffic case with no risk reduction measures. For example, tethered tug escort of laden tankers

was evaluated in the Case C model to reduce cargo oil spill risk by 27 metric tons per year, from

63 to 36 MT / yr.

It is important to note that metric tons per year of cargo oil spilled is an aggregate value

determined by summing a large number of scenarios, where each scenario has a low likelihood

of occurring. The results do not predict how much cargo oil loss is expected on an annual basis.

See the discussion on Spill Risk Terms for additional details.

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Columbia River

Tethered Tug Escort of Laden Tankers

Escorting laden oil tankers with tethered tugs significantly reduced cargo oil spill risk (Figure

12). Case C is presented in the figure. This measure’s benefit in Case C was a reduction in risk of

27 MT/yr (43% of Case C risk).

Figure 12: Risk Reduction: Tethered Tug Escort of Laden Tankers, Case C

The Case B scenario includes all the baseline vessel traffic on the river plus 25% of all the

proposed project transits. The risk reduction resulting from use of tethered tug escorts in Case B

is about 8 MT/yr (about 36% of Case B risk). In Case A, the risk reduction would be about

2 MT/yr (18% of Case A risk), because relatively few oil tankers currently sail the river. (About

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31 laden oil tanker transits were in the baseline year of data.) A comparison of Case A, B, and C

results is shown in Table 10.

Table 10: Comparison of Risk Reduction Results, Tethered Tug Escort of Laden Oil Tankers

Case Total Risk

(MT/yr)

Percentage of proposed future vessel traffic, added to baseline

traffic

Risk Reduction (MT/yr)

Risk Reduction (% of Total Risk)

C 63 100% 27 43%

B 23 25% 8 36%

A 11 0% 2 18%

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Untethered Tug Escort of Laden Tankers

The risk of a cargo oil spill with untethered tug escort of laden oil tankers was very similar to the

risk without the escort (Figure 13). This is because an untethered tug would have to pass a

towline to the tanker before it could begin reducing the ship’s headway. This would add to the

reaction time after a casualty such as a loss of propulsion or loss of steering.

Case C is presented in the figure. This measure’s benefit in Case C was a reduction in risk of

2 MT/yr (3% of Case C risk).

Figure 13: Risk Reduction: Untethered Tug Escort of Laden Tankers, Case C

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Case B would have 25% of the project vessel transits that Case C had. Therefore, the risk

reduction for Case B was 1 MT/yr (3% of Case B risk). For Case A, the benefit was much less

than 1 MT/yr (about 1% of Case A risk).

In all cases, this measure offered little benefit. A comparison of Case A, B, and C results is

shown in Table 11.

Table 11: Comparison of Risk Reduction Results, Untethered Tug Escort of Laden Tankers

Case Total Risk

(MT/yr)

Percentage of proposed future vessel traffic, added to baseline

traffic

Risk Reduction (MT/yr)

Risk Reduction (% of Total Risk)

C 63 100% 2 3%

B 23 25% 1 3%

A 11 0% <1 1%

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Pilots on Tugs with Oil-barges-in-tow

The risk reduction offered by a pilot on tugs with oil-barges-in-tow is shown in Figure 14 for

Case C. This measure’s benefit in Case C was a reduction in risk of less than 1 MT/yr (1% of

Case C risk).

Figure 14: Risk Reduction: Pilots on Tugs with Oil-barges-in-tow, Case C

All the transits of tugs with oil-barges-in-tow were in the baseline traffic. The risk reduction for

all of the cases was the same, less than 1 MT / yr, and was less than a 3% reduction in risk for all

cases.

A comparison of Case A, B, and C results is shown in Table 12.

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Table 12: Comparison of Risk Reduction Results, Pilots on Tugs with Oil-barges-in-tow

Case Total Risk

(MT/yr)

Percentage of proposed future vessel traffic, added to baseline

traffic

Risk Reduction (MT/yr)

Risk Reduction (% of Total Risk)

C 63 100% <1 1%

B 23 25% <1 2%

A 11 0% <1 3%

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Tethered Tug on Laden ATBs

The risk reduction offered by a tethered tug on ATBs is shown in Figure 15. Case C is shown in

the figure. This measure’s benefit in Case C was a reduction in risk of 2 MT/yr. It was the same

in Cases A and B.

Figure 15: Risk from All Laden Vessels on the River Mitigated by Tethered Tug on Laden ATBs, Case C

All the transits of ATBs were in the baseline traffic. The risk reduction for all of the cases was

the same, 2 MT / yr, representing 3% to 17% reduction in risk.

A comparison of Case A, B, and C results is shown in Table 13.

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Table 13: Comparison of Risk Reduction Results, Tethered Tug on Laden ATBs

Case Total Risk (MT/yr)

Percentage of proposed future vessel traffic, added to baseline

traffic

Risk Reduction (MT/yr)

Risk Reduction (% of Total Risk)

C 63 100% 2 3%

B 23 25% 2 8%

A 11 0% 2 17%

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Fully Redundant Propulsion and Steering Systems on Tankers

The risk reduction offered by fully redundant propulsion and steering systems (e.g., independent

systems that can maintain propulsion/steering with any single failure) is shown in Figure 16 for

Case C. This measure’s benefit in Case C was a reduction in risk of 17 MT/yr (27%).

Figure 16: Risk from Project Tankers on the River Mitigated by Fully Redundant Propulsion Systems, Case C

The benefit of this measure in cases A and B was not estimated in this evaluation. This is

because the cost-benefit ratio would depend on exactly how many tankers would need to be built,

which is highly speculative for Cases A and B.

A comparison of Case A, B, and C results is shown in Table 14.

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Table 14: Comparison of Risk Reduction Results, Fully Redundant Propulsion Systems on Tankers

Case Total Risk

(MT/yr)

Percentage of proposed future vessel traffic, added to baseline

traffic

Risk Reduction (MT/yr)

Risk Reduction (% of Total Risk)

C 63 100% 17 27%

B 23 25% Not Estimated Not Estimated

A 11 0% Not Estimated Not Estimated

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Columbia River Bar

The cargo oil spill risk on the Columbia River Bar could not be modeled or quantified. Risks and

potential risk reduction measures for the Columbia River Bar were discussed qualitatively with

the Columbia River Bar Pilots and workshop participants. The Columbia River Bar Pilots,

working with the U.S. Coast Guard and individual vessels, provide a key risk control for the bar.

The Columbia River Bar Pilots identified these tools as potential enhancements that could aid

their decisions about whether it is safe to bring a vessel across the bar.

Wave Prediction Tool

Wave prediction tools for hazardous harbor entrances are used in many locations in the U.S. and

around the world. They are becoming the best achievable standard of technology. For example,

the San Francisco Bar poses navigational hazards similar but in differing degrees to the

Columbia River Bar. In 2005, a bar forecast model was made available for the San Francisco

Bar. As a result, the number of marine casualties, including collisions, striking objects, and

groundings, has shown a strong downward trend (NOAA, 2010).

The CDIP, a university-based network for monitoring waves and beaches along the coastal

United States, provided the models for the San Francisco Bar and entrance to Long Beach/Los

Angeles harbors (Scripps Institution of Oceanography, 2017b). In 2011, the CDIP program

deployed two wave buoys on the Columbia River Bar. The Columbia River Bar Pilots and the

State of Oregon funded them but determined that modeling for this bar was too complex and

decided not to pursue building a model.

In 2012, Oregon State University built a wave forecast model which does provide sufficient

resolution to support decision making (Garcia-Medina et al., 2013). The OSU model is being

used, but it is currently only run once a day. Since it takes 24 hours for the results to be available,

the forecast is not issued until about 24 to 48 hours into its 84-hour forecast period. The

Columbia River Bar Pilots have explored solutions that would allow the model to be run more

frequently, including hosting the model on National Weather Service servers. So far, a funding

source has not been identified to resolve this issue.

The National Centers for Environmental Prediction, part of the National Oceanic and

Atmospheric Administration (NOAA, 2017a), maintains a Nearshore Wave Predictive System

for Weather Forecast Offices. Based on discussions with the Columbia River Bar Pilots, the

Nearshore Wave Prediction System does not currently provide model elements or sufficient

resolution to support decisions about safely navigating the bar.

Surface Radar

A land-based radar to provide coverage of the Columbia River Bar and approaches would

improve vessel traffic management by the Columbia River Bar Pilots, and navigation safety on

the bar in general. A radar located at Cape Disappointment, for example, could provide coverage

for the Columbia River Bar pilotage grounds.

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AIS on Towed Barges

Towed barges do not carry AIS transponders, only the tugs towing them. As a result, the tugs are

visible on navigational displays and information systems like Sea IQ and TV-32, but the barges

are not.

The AIS data from tugs may not indicate whether a barge is in tow. The lack of information

available about the presence of barges is compounded by the fact that due to wind, current, and

turns in the navigational channel near the bar, barges may not follow directly behind the towing

tug. This can result in situations where the tug is one side of the channel, and the barge is on the

opposite side.

On the river, tag tugs keep the barge behind the tug, and tag tugs are equipped with AIS.

However, tag tugs are not typically used on the bar, as weather conditions may make the use of a

tag tug unsafe. In discussions with the Columbia River Bar Pilots, they noted several instances

while piloting a deep draft ship across the bar, where they saw the AIS signal for the tug but had

limited time to react to the towed barge and the towline after sighting the barge. Unnoticed

vessels are a hazard to all other vessels whether or not they carry oil cargo. AIS transponders on

barges could help reduce this risk.

Implementing this measure would require changes to international standards and federal

regulations. The IMO publishes guidance for the use of AIS. AIS standards are incorporated in

the Code of Federal Regulations, and the U.S. Coast Guard issues AIS encoding guidance for

vessels in U.S. waters. Current AIS guidance does not include codes that could be used to

identify a vessel as a barge. States would have to work with the Coast Guard to request any

changes to AIS guidance.

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Best Achievable Protection Analysis

The 2015 Washington Oil Transportation Safety Act directed Ecology to evaluate Best

Achievable Protection for the study area. To complete this evaluation, Ecology and DNV GL

considered potential risk reduction measures, in addition to the existing safety measures on the

Columbia River and Bar.

Best achievable protection is defined in RCW 88.46.010 as:

. . . the highest level of protection that can be achieved through the use of the best

achievable technology and those staffing levels, training procedures, and

operational methods that provide the greatest degree of protection achievable. The

director's20 determination of best achievable protection shall be guided by the

critical need to protect the state's natural resources and waters, while considering:

(a) The additional protection provided by the measures;

(b) The technological achievability of the measures; and

(c) The cost of the measures.

Best achievable technology is also defined in RCW 88.46.010 as:

. . . the technology that provides the greatest degree of protection taking into

consideration:

(i) Processes that are being developed, or could feasibly be developed, given

overall reasonable expenditures on research and development; and

(ii) Processes that are currently in use.

In determining what is best achievable technology, the director shall consider the

effectiveness, engineering feasibility, and commercial availability of the

technology.

20 In this context, the director of the Department of Ecology.

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Process

The process of identifying Best Achievable Protection included:

1. Identifying potential risk reduction measures with input from tribes and stakeholders.

2. For measures that could be assessed quantitatively:

Analyzing the potential risk reduction for each risk reduction measure using the DNV GL

MARCS model.

Evaluating the cost to implement.

Calculating cost/benefit.

3. For measures that were assessed qualitatively:

Assessing measures to determine if they would be effective.

Evaluating the cost to implement.

Evaluating whether their costs are a greater burden than the risk they reduce.

Guiding Principles

In addition to the 2015 Washington Oil Transportation Safety Act (Chapter 274, Laws of 2015)

and evaluation discussions between the Department of Ecology Spills Program and DNV GL,

several continuous improvement standards informed the determination of Best Achievable

Protection. These included:

Best Available Technology – U.S. Environmental Protection Agency.

As Low As Reasonably Practicable (ALARP) – UK Health and Safety Executive.

Best Available Technologies (or Techniques) Not Entailing Excessive Costs (BATNEEC) –

EU Air Pollution from Industrial Plants Directive 84/360/EEC.

Ecology also considered the interests of the public, stakeholders, and tribes in developing

recommendations.

Columbia River Best Achievable Protection

As described throughout this report, robust, collaborative safety measures are already in

operation for vessels transiting the Columbia River. To determine if any additional measures

should be recommended, the evaluation considered the costs and benefits of the five quantifiable

risk reduction measures.

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Costs for each measures are shown in Table 15. Costs were determined with input from

evaluation participants. In the first column of Table 15, the yearly cost of implementation is the

cost of preventing or reducing spill risk. The amount of spill risk prevented is the benefit of the

measure, in metric tons per year.

For tethered tug escort of laden tankers, the cost was $38,000 per trip. Multiplying this by the

number of trips per year yielded the annual cost. The benefit was 27 MT/yr, so the cost-benefit

ratio was $550,000 per metric ton. Put another way, every $550,000 spent per year reduced the

aggregate risk by one metric ton.

Table 15 summarizes the costs and benefits for all of the measures for which the risk could be

quantified.

Table 15: Cost-Benefit Summary Case C

Risk Reduction Measure

Annual Cost of Implementation

($/yr)

Risk Reduction (MT/yr)

Cost-benefit Ratio ($/MT)

Normalized Cost-benefit

Ratio‡

Tethered tug escort of laden tankers

$15,000,000 27 $550,000 1

Pilot on tug with laden oil-barge-in-tow

$180,000 <1 $440,000 1

Tethered tug on laden ATBs

$4,300,000 2 $2,200,000 4

Redundant propulsion on project tankers

$80,000,000 17 $4,700,000 9

Untethered tug escort of laden tankers

$15,000,000 2 $7,800,000 14

‡Ratio of each cost-benefit to the lowest cost-benefit measure; provides the relative ranking of each risk reduction

measure.

Table 16 and Table 17 similarly summarize the costs and benefits when applied to traffic Cases

B and A.

Table 16: Cost-Benefit Summary Case B

Risk Reduction Measure

Annual Cost of Implementation

($/yr)

Risk Reduction (MT/yr)

Cost-benefit Ratio ($/MT)

Normalized Cost-benefit

Ratio‡

Tethered tug escort of laden tankers

$4,600,000 8 $560,000 1

Pilot on tug with laden oil-barge-in-tow

$180,000 <1 $480,000 1

Tethered tug on laden ATBs

$4,300,000 2 $2,200,000 4

Untethered tug escort of laden tankers

$4,600,000 <1 $8,000,000 14

Redundant propulsion on project tankers

- - - -

‡Ratio of each cost-benefit to the lowest cost-benefit measure; provides the relative ranking of each risk reduction

measure.

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Table 17: Cost-Benefit Summary Case A

Risk Reduction Measure

Annual Cost of Implementation

($/yr)

Risk Reduction

(MT/yr)

Cost-benefit Ratio ($/MT)

Normalized Cost-benefit

Ratio‡

Tethered tug escort of laden tankers

$1,200,000 2 $580,000 1

Pilot on tug with laden oil-barge-in-tow

$180,000 <1 $530,000 1

Tethered tug on laden ATBs

$4,300,000 2 $2,200,000 4

Untethered tug escort of laden tankers

$1,200,000 <1 $8,500,000 15

Redundant propulsion on project tankers

- - - -

‡Ratio of each cost-benefit to the lowest cost-benefit measure; provides the relative ranking of each risk reduction

measure.

Tethered tug escort of laden tankers

The risk reduction measure that provided the best return on investment was tethered tug escort of

laden tankers. Almost all of the future case tanker transits were from proposed projects, but the

measure was cost-beneficial even in the baseline traffic.

The measure had a cost/benefit of $550,000 / MT of avoided cargo oil spill risk in Case C. This

scenario assumed that the proposed projects are fully built out, and were exporting cargoes at the

terminals’ maximum proposed capacity. Implemented fully, this measure could reduce the future

cargo oil spill risk by approximately 27 MT / yr at a cost of $15 million / yr. Even assuming the

baseline traffic, this measure provided the highest level of protection that can be achieved

through the use of the best achievable technology and operational methods that provide the

greatest degree of protection achievable.

Tethered tug on laden ATBs

The other risk reduction measure that met the definition of best achievable technology was

tethered tug escort of laden ATBs. All of the modeled ATB transits were in the baseline traffic.

The measure had a cost/benefit of $2.2 million / MT of avoided cargo oil spill risk in Case C.

This scenario assumed that the proposed projects are fully built out, and were exporting cargoes

at the terminals’ maximum proposed capacity. Implemented fully, this measure could reduce the

future cargo oil spill risk by approximately 2 MT/yr at a cost of $4.3 million / yr. This measure

provided the highest level of protection that can be achieved through the use of the best

achievable technology and operational methods that provide the greatest degree of protection

achievable.

In the Columbia River vessel traffic, ATBs did not have as deep a draft as tankers. The risk

model allows only one river lane width; it cannot be modified per vessel type. Therefore, the

width of the river was assigned considering the federal navigation channel width and draft

requirements for tankers and other vessels on the river. An ATB can operate outside the federal

navigation channel if the vessel’s master decides that it is safer to do so in a given situation.

Therefore, the benefit of the tethered escort is likely overestimated by the numerical model.

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This section focused on the Columbia River, which has relatively calm waters. The Columbia

River Bar is a more complex, open environment. This evaluation is not suggesting requirements

for tankers to have tethered or untethered escort tugs while crossing the bar. Additional towing

force may be required on the bar due to the increased wave height and complex currents on the

bar that are not present in the river. Further study would be needed to determine best equipment

and operational practices to ensure safe passage of oil tankers across the Columbia River Bar.

Other evaluated measures

The risk reduction measure that is tied for best return on investment is a pilot on tug with laden

oil-barge-in-tow. All of the modeled tug-tow transits were in the baseline traffic. The risk

reduction offered by this measure is less than 0.5 MT / yr. Compared to the Case A risk of

11 MT / yr, the additional protection provided by the measure is small. For that reason, this

measure does not meet the definition of best achievable protection.

Untethered tug escort of laden tankers provides less risk reduction than tethered tug escort, and at

greater cost.

For this waterway, redundant propulsion on laden tankers would provide less risk reduction at

greater cost than tethered tug escort.

Sensitivity Analysis

This sensitivity looked at the study results if only 10% of all the proposed traffic was added to

the baseline year traffic. Table 18 shows the laden and ballast transits per year for this sensitivity,

and shows Case C (100% of all of the proposed traffic) for purposes of comparison.

Table 18: Sensitivity – Future Project Transits for Lower Traffic Growth

Terminal Location Cargo Sensitivity Case Laden Transits per Year

Case C Laden Transits per Year

Longview, WA Coal 84 840

Vancouver, WA Oil export 36.5 365

Port of Kalama-Cowlitz County, WA Methanol 7.2 72

Port Westward in Clatskanie, OR Methanol 7.2 72

Woodland, WA Calcium carbonate 3 30

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The risk results for this case are shown in Figure 17. The lower traffic growth sensitivity case

was very similar to Case A, the baseline traffic case.

Figure 17: Comparison of Sensitivity – Baseline Traffic + 10% Project Vessels to Other Traffic Cases

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The cost benefit results for this sensitivity are shown in Table 19.

Table 19: Cost-Benefit Summary – 10% Project Traffic Sensitivity

Risk Reduction Measure

Annual Cost of Implementation

($/yr)

Risk Reduction (MT/yr)

Sensitivity Cost-benefit Ratio ($/MT)

Case C Cost-benefit Ratio

($/MT) ‡

Pilot on tug with laden oil-barge-in-tow

180,000 <1 510,000 440,000

Tethered tug escort of laden tankers

2,600,000 5 560,000 550,000

Tethered tug on laden ATBs

4,300,000 2 2,200,000 2,200,000

Untethered tug escort of laden tankers

2,600,000 <1 8,100,000 7,800,000

‡Ratio of each cost-benefit to the lowest cost-benefit measure; provides the relative ranking of each risk reduction

measure.

The cost of implementation and the risk reduction were both related to the number of affected

laden transits. As a result, the cost-benefit ratios for this sensitivity were very similar to those for

Case C. Looking at the relationship between the four cost-benefit ratios, the relative cost-

effectiveness of the measures did not change compared to Case C.

Columbia River Bar Best Achievable Protection

Risk reduction measures for the bar could not be quantified in this study. For the bar, meeting the

criteria “best achievable” means considering all effective risk reduction measures. As described

throughout this report, robust safety measures are already in operation for vessels transiting the

bar, including:

Vessel traffic management by the Columbia River Bar Pilots.

Pilot judgment.

A fast-response pilot transportation system.

Regular communications between the Columbia River Bar Pilots and the maritime

community, including the U.S. Coast Guard, the NOAA Weather Forecast Office, the

Merchants Exchange of Portland, Oregon, the Columbia River Pilots, and individual vessels.

The safety culture of the Columbia River Bar Pilots.

The measures listed below could enhance the existing safety measures. Their costs were not

greater than their risk benefits; therefore, they are put forward as Best Achievable Protection:

Making a model available to support decision making would be a clear improvement in

navigation safety on the bar. Other bars on the west coast have high-resolution forecast

models, but the Columbia River Bar has proven to be the most complex to model. If

agreements were reached between Oregon State University and the National Weather

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Service, it could cost an estimated $75,000 to relocate the current Oregon State University

model to the National Weather Service and ongoing costs to maintain the model.

A land-based radar would provide coverage of the Columbia River Bar and approaches. A

rough order of magnitude estimate is a one-time investment of $40,000 plus operational,

maintenance, and human resources costs.

AIS transponders on barges crossing the Columbia River Bar would assure that other vessels

have a way to identify the presence of the barge. AIS on barges would be a per-barge cost of

about $5,000. Existing AIS coding guidance does not include codes for barges; implementing

this measure could involve identifying the steps necessary to modify existing U.S. and

international standards to create AIS codes specific to barges.

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Evaluation Findings

This section presents the DNV GL findings based on the quantitative and qualitative evaluations.

The findings should be considered in the context of the evaluation assumptions and limitations.

This evaluation focused on vessels that either currently carry oil cargoes or are part of a

currently-proposed project to do so. The oil-carrying vessel types are tankers, ATBs, and tugs

with oil-barges-in-tow. Per the 2015 Washington Oil Transportation Safety Act, three focus areas

were evaluated, as discussed below.

1. The need for tug escorts for vessels transporting oil as cargo.

Traditional tug escorts are not currently utilized for transits of oil cargoes on the Columbia

River or Bar. However, there are robust, collaborative maritime safety programs in operation

that are designed to prevent oil spills on the Columbia River and Bar. For example, tugs with

oil-barges-in-tow take on a tag tug on the river, providing a comparable level of safety to a

tug escort.

The conclusions from the modeling regarding the need for tug escorts were:

Tankers. Tug escorts that are tethered to a laden oil tanker on the Columbia River would

offer a significant and cost-effective level of protection, which was estimated using a model

as 27 MT / yr. Untethered tugs accompanying tankers do not provide a significant or cost-

effective risk reduction on the Columbia River, because they cannot respond to an incident as

quickly as a tethered tug. On the Columbia River Bar, the potential exists for tug escort to

decrease rather than increase maritime safety. However, opportunities may exist to use escort

tugs to reduce risk on the bar. An example is the potential to have a river escort tug waiting

inside the Columbia River Bar while its escorted vessel crossed the bar. It might be able to

respond to a vessel incident if needed. Further study, including a review of OCIMF

standards, is suggested to identify the minimum tug characteristics for this purpose.

ATBs. The ATBs on the river and bar have partially redundant propulsion and steering

systems, which offer a significant level of protection from drift grounding. That protection

overlaps with the protection that might be provided by a tug escort. As a result, tethered tug

escort of ATBs on the Columbia River offers a relatively small reduction in oil spill risk,

even though more cargoes transit the river on ATBs than on tankers. Untethered tug escort of

ATBs would not offer a measurable level of protection for the reasons discussed above.

Tugs with oil-barges-in-tow. The equivalent of tethered tug escort is already in place for tugs

with oil-barges-in-tow. Tugs towing oil barges employ “tag tugs,” as described in the Lower

Columbia Region Harbor Safety Plan. A tag tug is typically a smaller tug boat that is

attached to the stern of the oil barge. The tag tug assists with steering the barge, and keeps

the barge behind the towing tug. Tug escort of tugs with oil-barges-in-tow was not modeled,

but would not likely offer a measurable level of protection because of the use of tag tugs.

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2. Tug capabilities to ensure safe escort.

The tug capabilities needed to escort a tank vessel should be aligned with the characteristics

of the vessel it will be tethered to. This is to assure the safety of both vessels and their crews.

The size and steering capabilities of a specific tanker design need to be paired with the

bollard pull and steerage capabilities of a specific tug design. Conducting the necessary

navigation simulation modeling to specify safe and effective tug designs for the tank vessels

on the river or bar was beyond the scope and resources of this evaluation. As a result,

specific in-depth studies are warranted on the following topics:

Columbia River tug escort guidelines. Columbia River-specific guidelines will be necessary

to facilitate safe use of tug escorts. Tug escort guidelines reduce the likelihood of

miscommunication, misalignment, and human error. They should cover many aspects of the

tow, including:

o Requirements for the towing vessel: This could be either specified tug capabilities for

a range of tank vessels and sizes, or performance-based specifications that require the

a demonstration of the capability to prevent a vessel from grounding.

o Requirements for the tank vessel: The cargo oil vessel must have certain equipment

onboard (with relevant certifications) to ensure it can safely be controlled by the tug.

Examples include testing of strengthened bitts and the maximum age of the vessel.

o Cargo owner (charterer) requirements: There are requirements for the charterer that

will help to assure a safe intervention if it were needed. These include minimum

manning/experience requirements for the vessels and management system standards.

Tug escort on the Columbia River Bar. The bar is a more complex, open environment than

the Columbia River. Greater towing force may be required on the bar due to the wave heights

and complex currents on the bar that are not present in the river. This evaluation does not

suggest requirements for any tank vessel to have an escort tug while crossing the bar. Further

study and recommendations would likely be needed prior to tug escort operations on the bar.

The primary goal of a tug escort is to reduce the risk of pollution from a grounding of a tank

vessel. This can be most effective when the initiating event is a failure of the tankers’

steerage or propulsion. Therefore, this evaluation does not suggest that tethered tug escort is

a highly effective measure for vessels with fully redundant steering and fully redundant

propulsion as defined in 33 CFR 157.03.

3. Best Achievable Protection

Best Achievable Protection provides the highest level of protection that can be achieved

through the use of the best achievable technology and operational methods that provide the

greatest degree of protection achievable. It considers:

The additional protection provided by the measures.

The technological achievability of the measures.

The cost of the measures.

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The following were identified as measures offering Best Achievable Protection:

Tethered tug escorts for oil tankers on the Columbia River. Based on the modeling, this

measure could reduce cargo oil spill risk by 18% for the baseline year and 43% for the

maximum future traffic case. The following additional information could be considered when

developing recommendations:

o Tethered tug escort of tankers offers greater protection in the future than it offers in

today’s traffic environment, because there are relatively few tankers operating on the

Columbia River today.

Tethered tug escorts for ATBs would reduce cargo oil spill risk by about 2 MT / yr and meet

the definition of Best Achievable Protection. The level of protection offered by this measure

varies directly with the number of ATBs carrying oil cargoes. As a result, it offers effectively

the same level of protection in the modeled future cases as it offers in today’s traffic

environment. The following additional information could be considered when developing

recommendations:

o For Columbia River vessel traffic, ATBs did not have as deep a draft as tankers. The

risk model allows only one river lane width; it cannot be modified per vessel type.

Therefore, the width of the river was assigned considering the federal navigation

channel width and draft requirements for tankers and other vessels on the river. An

ATB can operate outside the federal navigation channel if the vessel’s master decides

that it is safer to do so in a given situation.

o The modeled future traffic cases assumed growth only for tanker transits.

o Changes in the number of ATB transits would change the risk results of this

evaluation.

Three measures were considered qualitatively that could improve the information available to

the Columbia River Bar Pilots, who provide a key risk control for vessels crossing the bar:

o A predictive wave model for the Columbia River Bar.

o A land-based radar to provide coverage of the Columbia River Bar and approaches.

o AIS transponders on barges crossing the Columbia River Bar.

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Department of Ecology Recommendations

Based on the findings, no new legislation is required. Ecology recommends the following safety

measures; neither require a change to laws or rules.

1. Continue to support existing collaborative maritime safety programs.

Existing, collaborative maritime safety programs represent the best opportunity to prevent

cargo oil spills on the Columbia River and Bar.

Ecology will continue to support these programs through participation as a member of the

Lower Columbia Region Harbor Safety Committee, Northwest Area Committee, and the

Sector Columbia River Area Maritime Security Committee; attendance at Oregon Board of

Maritime Pilots meetings; and participation in U.S. Coast Guard waterways management

studies.

Through participation in these programs, Ecology will encourage practices and technologies

to meet best achievable protection. These could include:

o Regular discussions through the Harbor Safety Committee and other forums as

appropriate of current practices, evolving risks, and opportunities for improvement

for the movement of cargo oil.

o Tools to enhance the safe navigation and piloting of vessels on the Columbia River

and Bar.

2. Seek tethered tug escort of laden tankers when tanker traffic increases.

Ecology will work with the Lower Columbia Region Harbor Safety Committee to develop a

Harbor Safety Plan Standard of Care, to be considered for implementation when a newly

constructed or expanded facility to move oil21 on the Columbia River becomes operational

and increases tanker traffic.

This standard will address tethered tug escort of laden oil tankers on the Columbia River, and

considerations for laden oil tankers crossing the Columbia River Bar.

The Standard of Care should also:

o Include tug and tanker equipment capabilities.

o Consider exemption from tug escort requirement for tankers with double hulls, when

the tanker also has fully redundant steering and propulsion (e.g., independent systems

that can maintain propulsion/steering with any single failure).

Legislation is not required for this recommendation. Standards of care are voluntary measures,

adopted by the Lower Columbia Region Harbor Safety Committee through their Harbor Safety

Plan. Compliance with the Harbor Safety Plan is voluntary; however, there are strong industry

and regulatory controls in operation that collectively ensure compliance. These include the good

21 A facility meeting the requirements of 33 CFR 126, 154, 155, and the Class 1 facility requirements in Chapter

173-180 WAC.

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practices of companies operating on the Columbia River, the role of the Columbia River Bar

Pilots and Columbia River Pilots onboard vessels during transits, and the authority of the Coast

Guard Captain of the Port to direct vessels to comply with the Harbor Safety Plan if needed.

Work to develop this Standard of Care should begin now, to ensure it is ready before any

potential increase in tanker traffic. Implementing the Standard of Care would be a decision of the

Lower Columbia Region Harbor Safety Committee, as part of their mission to assure safe

navigation to protect the environment, property, and personnel on the waterways within the

Lower Columbia Region. Ecology is a member of the Lower Columbia Region Harbor Safety

Committee.

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Risk Reduction Measures Considered but Not Recommended

Additional potential risk reduction measures that were considered in this assessment but not

recommended include:

Tug escorts for tugs with laden oil-barge-in-tow. Tank barges are, by nature, tethered, and all

oil laden barges employ a tag tug per the Towed Barge Guidelines in the Lower Columbia

Region Harbor Safety Plan (LCRHSP, 2016). Given the nature of the waterway, an

additional tug might add to incident risk more than it would mitigate the risk. Therefore, this

study did not evaluate a third tug on the towed oil barges.

Tug escorts for ATBs.

o ATBs that move cargo oil on the Columbia River have partially redundant systems

(e.g., two engines, two rudders that are not independent; a single failure could result

in a loss of propulsion/steering). That protection overlaps with the protection that

might be provided by a tug escort.

o For Columbia River vessel traffic, ATBs did not have as deep a draft as tankers. The

risk model allows only one river lane width; it cannot be modified per vessel type.

Therefore, the width of the river was assigned considering the federal navigation

channel width and draft requirements for tankers and other vessels on the river. An

ATB can operate outside the federal navigation channel if the vessel’s master decides

that it is safer to do so in a given situation.

Pilots for tugs with laden oil-barges-in-tow. The risk reduction offered by this measure is less

than 0.5 MT / yr in the baseline year. Compared to the Case A baseline risk of 11 MT / yr,

the additional protection provided by the measure is small. No known projects are proposing

tugs with laden oil-barges-in-tow, and given the industry’s current direction, none are

reasonably expected. For those reasons, this measure does not meet the definition of best

achievable protection.

Fully redundant propulsion and steering (e.g., independent systems that can maintain

propulsion/steering with any single failure) on ATBs and tugs with laden oil-barge-in-tow.

ATBs that carry cargo oil already have partially redundant systems (e.g., two engines, two

rudders that are not independent; a single failure could result in a loss of propulsion/steering).

Tank barges on the river have a tug ahead connected by a tow line and a tag tug made fast

astern. Therefore, fully redundant propulsion and steering was evaluated as a potential risk

reduction measure only for tankers.

Requirements to ban certain vessel types from carrying oil cargo on the river or bar. This was

considered unrealistic from an economic and regulatory perspective.

A formal vessel traffic service (VTS). The primary benefit of a VTS is notification and

directives to avoid a potential collision. A VTS would probably not reduce the risk of

collision on the river because the traffic level is not high enough to capture the value from a

VTS, and because the navigation channel on the river is relatively narrow. This limits the

time available for a remote VTS operator to notice an issue, communicate with the vessels

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involved, and help resolve the situation. The U.S. Coast Guard determined VTS to be

unnecessary on the Columbia River.

Improved aids to navigation on the river. Participants indicated that improved aids (e.g.,

visual ranges on Desdemona Channel) could assist with navigation. The U.S. Coast Guard

leads periodic reviews of aids to navigation; this evaluation deferred discussion of potential

improvements to the existing Coast Guard process.

Reducing risk at higher-risk locations. This concept was reviewed and brainstormed by

workshop participants. No location-specific risk reduction measures are evaluated in this

study because no effective measures were identified or put forward by the CRVTSA team or

by the participants in the Risk Results and Mitigation Workshop.

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Conclusion

The Columbia River Vessel Traffic Evaluation and Safety Assessment provides an evaluation of

vessel traffic management and vessel safety within and near the mouth of the Columbia River.

Ecology, working with DNV GL, and in consultation with tribes and stakeholders assessed:

The need for tug escorts for oil tankers, articulated tug barges, and towed barges.

Best Achievable Protection.

Required tug capabilities to ensure the safe escort of vessels on the waters that are the subject

of this assessment.

The evaluation included:

Examining current vessel traffic data for the Columbia River and Bar.

Describing existing safety systems.

Modeling baseline risks of a cargo oil spill.

Identifying proposed projects that could increase vessel traffic.

Defining, modeling, and analyzing the cost-benefit of potential risk reduction measures.

Determining Best Achievable Protection.

Drafting recommendations.

Ecology conducted regular meetings and workshops with tribes and stakeholders throughout the

CRVTSA. Ecology also met with a working group of the Lower Columbia Region Harbor Safety

Committee. The expertise and insights provided by participants in these workshops and meetings

was invaluable to this study.

As described throughout this report, there are robust, collaborative systems in operation that help

reduce the risk of a cargo oil spill on the Columbia River and Bar. Cargo oil spills are rare

because of these existing processes. However, cargo oil spills are high consequence events, and

could be devastating to the unique ecological, cultural, and economic resources of the region.

These potential consequences demand continuing efforts to prevent an oil spill from occurring.

Ecology’s recommendations are intended to recognize the admirable safety record of the

Columbia River system; leverage existing, collaborative processes to continuously reduce risks;

and facilitate the adoption of Best Achievable Protections that incorporate best available

technologies.

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Ecology / DNV GL Evaluation Team

Scott Ferguson, Prevention Section Manager, Washington Department of Ecology

Brian Kirk, Marine Risk Management Lead, Washington Department of Ecology

Karen Phillips, Vessel Inspector, Washington Department of Ecology

Sara Thompson, Vessel and Oil Transfer Unit Supervisor, Washington Department of Ecology

Mia Ersepke, Consultant, DNV GL

Dennis O’Mara, Principal Consultant, DNV GL

Cheryl Stahl, Senior Principal Consultant, DNV GL

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Acknowledgments

The Ecology/DNV GL evaluation team appreciates the significant input and assistance from the

Lower Columbia Region Harbor Safety Committee (Harbor Safety Committee) workgroup,

chaired by Captain Rick Gill from the Columbia River Pilots.

We are grateful to the Merchants Exchange of Portland, Oregon and the Port of Vancouver USA

for hosting the CRVTSA workshops and Harbor Safety Committee workgroup meetings. A

special thanks to Bekah Canfield of the Merchants Exchange for logistical support for the

meetings.

Subject matter experts from pilots’ associations, industry groups, operators, associations, tribes,

and state and federal agencies participated in project webinars, workgroup meetings, and

workshops. They are listed below. Many of these individuals generously donated their time to

provide input and feedback into this evaluation. This list may not be all inclusive; Ecology

apologizes for any omissions. Participation in project events does not imply endorsement of the

study findings and recommendations by these individuals or their organizations. This list is

provided to thank and acknowledge the participants.

Barb Aberle Washington Department of Transportation

Steve Ackerman Columbia River Bar Pilots

Scott Anderson NOAA Fisheries

Herb Barrow Williamson & Associates

Bill Bart Crowley Marine Services, Inc.

David Bartz Schwabe Williamson & Wyatt

Marc Bayer Tesoro Maritime Company

Dale Beasley Coalition of Coastal Fisheries

Peter Bennett Millennium Bulk Terminals-Longview

Kirk Bonnin Olympic Tug & Barge

Amy Boyd Cowlitz Indian Tribe

Eric Burnette Oregon Board of Maritime Pilots

Amber Carter Amber Carter Government Relations, LLC

Julie Carter Columbia River Inter-Tribal Fish Commission

Mike Cassinelli Beacon Charters

Debra Cobb Tesoro Maritime Company

Bill Collins Tidewater Transportation & Terminals

John Corbin Oregon Dungeness Crab Commission

Charles Costanzo The American Waterways Operators

Shayne Cothern Washington State Department of Natural Resources

William Crabbs Phillips 66 Company

Janet Curran NOAA Fisheries

Brien Flanagan Schwabe Williamson & Wyatt

Brian Fletcher Tidewater Transportation & Terminals

Terry Ganuelas Confederated Tribes and Bands of the Yakama Nation

Rick Gill Columbia River Pilots

Fred Harding Shaver Transportation Company

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Dave Harlan Oregon Public Ports Association

Chris Hathaway The Lower Columbia Estuary Partnership

Eric Haugstad Tesoro Companies, Inc.

Paul Hendriks Foss Maritime Company

Frank Holmes Western States Petroleum Association

Ashley Helenberg Port of Longview

Audie Huber Confederated Tribes of the Umatilla Indian Reservation

Susan Johnson Oregon Board of Maritime Pilots

Dan Jordan Columbia River Bar Pilots

Brady Kent Confederated Tribes and Bands of the Yakama Nation

David Konz Tidewater Transportation & Terminals

Zach Lamebull Confederated Tribes and Bands of the Yakama Nation

Mark Landauer Oregon Public Ports Association

Ken Lawrenson U.S. Coast Guard

Paulette Lichatowich Port of St. Helens

Rob Lothrop Columbia River Inter-Tribal Fish Commission

Andrea Mickelson American Queen Steamboat Company

Kate Mickelson Columbia River Steamship Operators’ Association

Paula Miranda Port of St. Helens

Fred Myer Port of Portland

Christopher Peterson Crowley Petroleum Services

Bruce Reed Tidewater Transportation & Terminals

Holly Robinson Maritime Fire & Safety Association

Don Russell Morrow County, Oregon

Rudy Salakory Cowlitz Indian Tribe

Daniel Serres Columbia Riverkeeper

John Schneider Tesoro Maritime Company

Scott Smith Oregon Department of Environmental Quality

Rich Softye Harley Marine Services

Laura Springer U.S. Coast Guard

Lars Uglum Port of Vancouver USA

Elizabeth Wainwright Merchants Exchange of Portland, Oregon

Krystyna Wolniakowski Columbia River Gorge Commission

Mike Zollitsch Oregon Department of Environmental Quality

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References

Cowlitz County. (2016). Millenium Bulk Terminals‒Longview: SEPA Environmental Impact

Statement SEPA Vessel Transportation Technical Report. Prepared for Cowlitz County in

cooperation with Washington State Department of Ecology, Southwest Region. Prepared by ICF

International, Rodino, Inc., and DNV GL. April 2016.

http://www.millenniumbulkeiswa.gov/assets/mbtl_technicalreport_vesseltransportation.pdf.

Accessed May 2, 2016.

Cowlitz County and Port of Kalama. (2016). Kalama Manufacturing & Marine Export Facility:

SEPA Final Environmental Impact Statement. September 2016.

http://nwinnovationworks.com/projects/port-of-kalama. Accessed October 11, 2016.

Energy Facility Site Evaluation Council. (2016). Tesoro Savage Vancouver Energy Project.

Application No. 2013-01. http://www.efsec.wa.gov/Tesoro%20Savage/SEPA%20-

%20DEIS/DEIS%20PAGE.shtml. Accessed January 27, 2017.

Fowler, T. G. and Sørgård, E. (2000). Modeling Ship Transportation Risk. Risk Analysis.

Commission of the European Communities. 20: 225–244. doi:10.1111/0272-4332.202022.

www.transport-research.info/sites/default/files/project/documents/safeco.pdf.

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(2013). An Inner-shelf Wave Forecasting System for the U.S. Pacific Northwest. January 10,

2013. J American Meteorological Society. June 2013. DOI: 10.1175/WAF-D-12-00055.1.

International Association of Classification Societies. (2017). IACS International Association of

Classification Societies: Safer and Cleaner Shipping. IACS explained, Introduction. Website.

http://iacs.org.uk/explained/default.aspx. Accessed March 27, 2017.

International Maritime Organization (IMO). (2005). Guidance on Shipboard Towing and

Mooring Equipment. MSC/Circ. 1175. May 24, 2005. Ref. T4/3.01.

International Maritime Organization (IMO). (2017). International Maritime Organization –

MARPOL Annex I – Prevention of Pollution by Oil. Website.

http://www.imo.org/en/OurWork/Environment/PollutionPrevention/OilPollution/Pages/Default.a

spx. Accessed March 30, 2017.

The International Tanker Owners Pollution Federation Limited (ITOPF). (2017). Oil Tanker

Spill Statistics 2016. February 2017.

Lower Columbia Region Harbor Safety Committee (LCRHSC). (2016). Lower Columbia Region

Harbor Safety Committee Harbor Safety Plan.

http://lcrhsc.org/documents/2016_Updated_HSP_FINAL_July_20_2016.pdf. Downloaded

September 13, 2017.

Merchants Exchange of Portland, Oregon. (2017). 2016 Annual Report: Merchants Exchange of

Portland, Oregon. https://www.pdxmex.com/media/MEX/AnnualReport/mex-annual-report--

2016_web.pdf. Downloaded April 4, 2017.

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National Transportation Safety Board. (1984). Marine accident report: Grounding of United

States tankship SS MOBILOIL in the Columbia River near Saint Helens, Oregon, March 19,

1984. Adopted November 20, 1984.

https://ntrl.ntis.gov/NTRL/dashboard/searchResults.xhtml?searchQuery=PB84916409.

National Oceanic and Atmospheric Administration (NOAA). (2010). “Building Relationships”

with the Marine Community. Presentation.

www.crh.noaa.gov/Image/ama/decisionsupport/2010_presentations/strobin.pptx. Accessed

February 19, 2017.

National Oceanic and Atmospheric Administration (NOAA). (2017a). National Weather Service,

Environmental Modeling Center. Nearshore Wave Prediction System. Website.

http://polar.ncep.noaa.gov/nwps/. Accessed February 19, 2017.

Oil Companies International Marine Forum (OCIMF). (2007). Briefing Paper for OCIMF

Member Companies: Guidelines for Transiting the Turkish Straits. August 2007.

https://www.ocimf.org/media/8922/Turkist%20Straits.pdf.

Oil Companies International Marine Forum (OCIMF). (2017a). OCIMF Ship Inspection Report

Programme: About SIRE. Website. https://www.ocimf.org/sire/about-sire/. Accessed March 27,

2017.

Oil Companies International Marine Forum (OCIMF). (2017b). OCIMF Marine Terminal

Information System: Terminal Map. Columbia River Area. https://www.ocimf-

mtis.org/Microsite/Terminals. Accessed March 23, 2017.

OMC International. (2011). Columbia River Bar UKC Study and DUKC® System

Implementation. Prepared for Columbia River Bar Pilots. May 20, 2011.

Oregon Department of Environmental Quality (DEQ) (2017). Department of Environmental

Quality, Hazards and Cleanup, Environmental Cleanup: Emergency Response. Website.

http://www.oregon.gov/deq/Hazards-and-Cleanup/env-cleanup/Pages/Emergency-

Response.aspx. Accessed June 16, 2017.

Port of Portland. (2017). Port of Portland – Marine – Columbia River Forecast. Website.

https://www2.portofportland.com/Marine/RiverDepthForecasting. Accessed March 28, 2017.

Scripps Institution of Oceanography. (2017a). The Coastal Data Information Program:

Integrative Oceanography Division. Website. http://cdip.ucsd.edu/. Accessed March 30, 2017.

Scripps Institution of Oceanography. (2017b). The Coastal Data Information Program:

Monitoring and Prediction of Waves and Shoreline Change. About the CDIP Wave Forecast

Model. Website. http://cdip.ucsd.edu/themes/cdip?pb=1&d2=p20&u3=tab:1:display:faq3.

Accessed March 31, 2017.

U.S. Army Corps of Engineers (USACE). (2017). U.S. Army Corps of Engineers, Portland

District. Missions: Navigation. Website.

http://www.nwp.usace.army.mil/Missions/Navigation.aspx. Accessed March 27, 2017.

U.S. Coast Guard. (2017b). Navigation Center. The Navigation Center of Excellence: Automatic

Identification System Overview. Website. United States Department of Homeland Security,

United States Coast Guard. https://www.navcen.uscg.gov/?pageName=AISmain. Accessed

March 24, 2017.

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U.S. Coast Guard. (2017b). U.S. Coast Guard: America’s Maritime Guardian. Coast Guard

Publication 1. May 2009. www.uscg.mil/history/docs/uscg_pub1_2009.pdf. Downloaded May

28, 2017.

Washington Department of Ecology (Ecology). (1997). Oil Spills in Washington State: A

Historical Analysis. April 1997. Rev. March 2007. Publication No. 97-252.

https://fortress.wa.gov/ecy/publications/documents/97252.pdf.

Washington Department of Ecology (Ecology). (2014). Focus on Cargo and Passenger Vessel

Inspections: Spill Prevention, Preparedness, & Response Program. April 2014. Publication no.

11-08-004. Rev. 04/14. https://fortress.wa.gov/ecy/publications/documents/1108004.pdf.

Accessed February 28, 2017.

Washington Department of Ecology (Ecology). (2016). Department of Ecology, State of

Washington: Spills – Spill Prevention: Risk Assessments. Website.

http://www.ecy.wa.gov/programs/spills/prevention/RiskAssessment.html. Accessed March 27,

2017.

Washington Department of Ecology (Ecology). (2017a). Vessel Entries and Transits (VEAT)

Counts for Washington Waters by Calendar Year. Data downloaded for 2015 and 2016 on May

31, 2017. http://www.ecy.wa.gov/programs/spills/publications/publications.htm.

Washington Department of Ecology (Ecology). (2017b). Department of Ecology, State of

Washington: Spills – Spill Prevention. Website.

http://www.ecy.wa.gov/programs/spills/prevention/prevention_section.htm. Accessed March 27,

2017.

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Glossary, Acronyms, and Abbreviations

Glossary of Terms

Articulated Tug

Barge (ATB)

a combination vessel consisting of a barge and a tug boat connected by

mechanical equipment.

Baseline Year for this evaluation, the time period from October 1, 2015 to September

30, 2016.

Best Achievable

Protection

the highest level of protection by using the best achievable technology,

staffing levels, training, and operational methods (RCW 88.46.010(1)).

Cargo oil oil transported on a vessel as bulk cargo.

Cargo Oil Spill

Risk

in the CRVTSA, this is evaluated qualitatively and quantitatively. It is

quantified as the sum of a large number of scenario risks. It is expressed

as an aggregate, or sum, of each average annual spilled quantity

calculated for each spilling scenario.

Case A the baseline year of vessel traffic. The data were gathered for October 1,

2015 – September 30, 2016; this was the most recent year of Automatic

Identification System (AIS) data available.

For vessels that carry cargo oil, Ecology reviewed Vessel Entries and

Transit (VEAT) analysis for the baseline year to determine the number

of transits within the study area and routes traveled. Data sources for the

VEAT include AIS and information from Ecology’s Advance Notice of

Oil Transfer system.

For vessels that do not carry cargo oil, input to the MARCS model was

processed Automatic Identification System (AIS) data for the baseline

year for the study area. The AIS data defined vessel traffic patterns,

traffic densities, and vessel speeds.

Case B the baseline traffic plus all the proposed projects operating at 25% of

their proposed maximum number of vessel trips (laden and unladen

transits).

Case C the baseline traffic, plus all the proposed projects operating at their

proposed maximum number of vessel trips (laden and unladen transits).

DNV GL provides classification, technical assurance, software and independent

expert advisory services to the maritime, oil & gas and energy industries.

DNV GL also provides certification services to customers across a wide

range of industries.

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Documented U.S.

vessel

a U.S. vessel over 5 net tons with a U.S. Coast Guard-issued Certificate

of Documentation that authorizes trade under Registry (foreign) and/or

Coastwise (domestic, U.S.).

Ecology the Washington Department of Ecology.

Fully redundant

propulsion and

steering

Independent systems for propulsion and steering that can maintain

propulsion/steering with any single failure.

Harbor Safety

Committee

the Lower Columbia Region Harbor Safety Committee.

Incident a marine accident that may or may not result in an oil spill.

Laden a vessel descriptor indicating that cargo is onboard; in the CRVTSA, this

is always oil cargo.

LoadMax a tool that forecasts hourly river levels using real-time river gauge

information, rainfall runoff predictions, and dam and lock operator

information.

Lower Columbia

River

for this study, the part of the Columbia River from River Mile -5 to

River Mile 105.

MARPOL Annex

I

International Maritime Organization Regulations for the Prevention of

Pollution by Oil, as amended. Annex I requires all oil tankers delivered

on or after 1996 to have double hulls.

Oil “Oil” as defined in RCW 88.40 and 90.56.

OPA 90 U.S. Oil Pollution Act of 1990; among other measures, it requires all oil

tankers to have double hulls based on a phase-in schedule.

Orville Hook a barge retrieval device. In the event that the tow wire between a tug and

a barge breaks, the tug’s crew can deploy the Orville Hook to retrieve the

towing bridle connected to the barge, and regain control of the barge.

Partially redundant

propulsion and

steering

two engines and two rudders, where the propulsion systems and steering

systems are not independent from each other. A single failure could

result in a loss of propulsion and/or steering.

Pilot a person who has demonstrated expert local knowledge of a particular

waterway. They also have experience in ship handling, seamanship and

vessel navigation.

Redundant

propulsion and

steering

two independent propulsion and steering systems. A single failure could

not result in a loss of propulsion and/or steering.

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River Mile a measure of distance on the Columbia River in statute miles, equal to

5,280 feet.

Sea IQ a commercially available pilot tool that combines bridge navigation

equipment, NOAA charts, Corps of Engineers hydro surveys, and

NOAA tide gauges into a single display. Columbia River Bar Pilots use

this software.

Tag tug typically a smaller tug boat attached to the stern of an oil barge. The tag

tug assists with steering the barge.

Tank barge tug with an oil-barge-in-tow.

Tank ship tanker.

TransView 32 custom-made software that displays vessel contacts. It can be used to

calculate the distance between any two points on the display to

determine vessel meeting points, closest point of approach, and the

estimated time of arrival of any vessel contacts on the display. It

continuously imports the most recent sounding data from the USACE

and provides an exact replica of the channel’s depths. The Columbia

River Pilots use this software.

Tug In the CRVTSA, this refers to towing operations in general, including

traditional tows, ATBs, and support vessels.

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Acronyms

AIS Automatic Identification System

ALARP As Low As Reasonably Practicable

API American Petroleum Institute

ATB Articulated Tug Barges

AWO American Waterways Operators

BATNEEC Best Available Technologies (or Techniques) Not Entailing Excessive Costs

CDIP Coastal Data Information Program

CFR U.S. Code of Federal Regulations

CRVTSA Columbia River Vessel Traffic Evaluation and Safety Assessment

ECOPRO Exceptional Compliance Program

ESHB Engrossed Substitute House Bill

IMO International Maritime Organization

ITOPF International Tanker Owners Pollution Federation Limited

LCRHSC Lower Columbia Region Harbor Safety Committee

MARCS Marine Accident Risk Calculation System

MARPOL International Convention for the Prevention of Pollution from Ships

MTIS Marine Terminal Information System

NOAA National Oceanic and Atmospheric Administration

OCIMF The Oil Companies International Marine Forum

ORS Oregon Regulatory Statutes

OSU Oregon State University

PORTS Physical Oceanographic Real-Time System

RCW Revised Code of Washington

RM River Mile

SIRE Ship Inspection Report Program

SOLAS International Convention for the Safety of Life at Sea

TMSA Tanker Management and Self-Assessment program

TV-32 Transview 32

U.S.C. United States Code

USACE U.S. Army Corps of Engineers

VBAP Voluntary Best Achievable Protection

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VEAT Vessel Entries and Transits

VTS Vessel Traffic Service

Abbreviations and Units of Measure

bbl barrel(s)

°C degrees Celsius

GT gross tonnage

gal gallon(s)

MT metric ton(s)

yr year(s)

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Summary of Appendices

Appendix A. ESHB 1449, Chapter 274, Laws of 2015; Washington Oil Transportation Safety Act

This appendix contains the definition of Best Achievable Protection and Section 11 of the law.

Appendix B. List of Project Contributors and Workshop Attendees

This appendix lists the participants in project meetings held during the study.

Appendix C. Case Descriptions

This appendix provides a detailed description of the three scenarios modeled in the CRVTSA.

Appendix D. Marine Safety Risk Controls

This appendix describes cargo oil spill risk reduction practices, policies, and standards that are

currently in operation in the marine oil transportation industry on the river, but were not

quantified in the risk assessment.

Appendix E. Description of Risk Methodology

This appendix describes how potential cargo oil spill risk reduction measures were identified and

evaluated.

Appendix F. Study Basis

This appendix documents the assumptions used in cargo oil spill risk modeling conducted for the

CRVTSA. It focuses on aspects of the marine transit route, including the marine traffic itself, and

how they were collected, interpreted, and applied in the risk model and analysis.

Appendix G. MARCS Baseline Model Description

This appendix describes background information and the design of the MARCS model used to

estimate navigation event frequencies in this risk assessment.

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Appendix H. MARCS Model Validation

This appendix describes the validation of the MARCS model.

Appendix I. Cargo Oil Spill Risk Results

This appendix reports the quantitative modeling results and describes the baseline cargo oil spill

risk profile for the CRVTSA.

Appendix J. Assessment of Best Achievable Protection

This appendix describes how potential cargo oil spill risk reduction measures were identified and

evaluated.

Appendix K. Characterization of the Middle Columbia River-Snake River

This appendix provides a high-level characterization of the Columbia River system east of the

I-5 bridge to the Port of Benton on the Columbia River and to the Lewiston, Idaho/Clarkston,

Washington area on the Snake River. For purposes of this report, the area is called the Middle

Columbia River-Snake River Waterway System. Appendix K is provided for information, and

describes the waterway east of the I-5 Bridge. The quantitative and qualitative analysis, findings,

and recommendations of this evaluation are focused on the Columbia River west of the I-5

Bridge.

Appendix L. Marine Fuel Spills

This appendix provides a high-level view of fuel spill risk on the Columbia River and Bar.

Appendix M. Oil by Rail

This appendix presents an estimate of the volume of crude oil rail transshipment operations

within the Columbia River for the study area beginning five miles seaward of the Columbia

River Bar to the I-5 bridge. It also describes any current crude oil rail-vessel transfers and all

proposed projects in the corridor that include crude oil rail-vessel transfers.

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Appendix N. Considerations Regarding Escort Tug Capabilities

This appendix provides general information regarding tug escort capabilities for the Columbia

River.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix A

Washington State Department of Ecology A-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix A:

Engrossed Substitute House Bill (ESHB) 1449, the Washington Oil Transportation Safety Act

(Chapter 274, Laws of 2015)

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix A

Washington State Department of Ecology A-2 Publication No. 17-08-010

Introduction

This appendix contains the sections of ESHB 1449 (Chapter 274, Laws of 2015) that pertain to the CRVTSA. The complete text of the bill is available at: http://lawfilesext.leg.wa.gov/biennium/2015-16/Pdf/Bills/Session%20Laws/House/1449-S.SL.pdf.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix A

Washington State Department of Ecology A-3 Publication No. 17-08-010

CERTIFICATION OF ENROLLMENT

ENGROSSED SUBSTITUTE HOUSE BILL 1449

Chapter 274, Laws of 2015

64th Legislature 2015 Regular Session

OIL TRANSPORTATION SAFETY

EFFECTIVE DATE: 7/1/2015

Passed by the House April 24, 2015 Yeas 95 Nays 1

Frank Chopp

CERTIFICATE I, Barbara Baker, Chief Clerk of the House of Representatives of the State of Washington, do hereby certify that the attached is ENGROSSED SUBSTITUTE HOUSE BILL 1449 as passed by House of Representatives and the Senate on the dates hereon set forth.

_________________________________________ Speaker of the House of Representatives

Passed by the Senate April 24, 2015 Yeas 46 Nays 0

Brad Owen

Barbara Baker _____________________________________ President of the Senate Approved May 14, 2015 12:17 PM

______________________________________ Chief Clerk

Filed

May 14, 2015

Jay Inslee _____________________________________ Governor of the State of Washington

Secretary of State State of Washington

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix A

Washington State Department of Ecology A-4 Publication No. 17-08-010

ENGROSSED SUBSTITUTE HOUSE BILL 1449

AS AMENDED BY THE SENATE

Passed Legislature - 2015 Regular Session

State of Washington 64th Legislature 2015 Regular Session

By House Environment (originally sponsored by Representatives Farrell, Carlyle, Fitzgibbon, Ortiz-Self, Peterson, Walkinshaw, Gregerson, Senn, McBride, Robinson, Tarleton, Pollet, Cody, Ormsby, Riccelli, Kagi, Blake, Fey, Hudgins, Lytton, Bergquist, Sells, Takko, Tharinger, Jinkins, Wylie, S. Hunt, Stanford, Reykdal, Sawyer, Appleton, Van De Wege, Clibborn, Ryu, Goodman, and Kilduff; by request of Governor Inslee) READ FIRST TIME 02/19/15. AN ACT Relating to oil transportation safety; amending RCW 90.56.005, 90.56.010, 90.56.200, 90.56.210, 90.56.500, 90.56.510, 88.40.011, 82.23B.010, 82.23B.020, 82.23B.030, 82.23B.040, 81.24.010, 81.53.010, 81.53.240,and 88.46.180; reenacting and amending RCW 88.46.010, 38.52.040, and 42.56.270; adding new sections to chapter 90.56 RCW; adding a new section to chapter 81.04 RCW; adding a new section to chapter 88.16 RCW; adding a new section to chapter 81.44 RCW; adding a new section to chapter 81.53 RCW; creating new sections; providing an effective date; providing an expiration date; and declaring an emergency. BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF WASHINGTON: Sec. 1. RCW 90.56.005 and 2010 1st sp.s. c 7 s 72 are each amended to read as follows: (1) The legislature declares that waterborne transportation as a source of supply for oil and hazardous substances poses special concern for the state of Washington. Each year billions of gallons of crude oil and refined petroleum products are transported as cargo and fuel by vessels on the navigable waters of the state. The movement of crude oil through rail corridors and over Washington waters creates safety and environmental risks. The sources and transport of crude oil bring risks to our communities along rail lines and to the Columbia river, Grays Harbor, and Puget Sound waters. These shipments are expected to

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Washington State Department of Ecology A-5 Publication No. 17-08-010

increase in the coming years. Vessels and trains transporting oil into Washington travel on some of the most unique and special marine environments in the United States. These marine environments are a source of natural beauty, recreation, and economic livelihood for many residents of this state. As a result, the state has an obligation to ensure the citizens of the state that the waters of the state will be protected from oil spills. (2) The legislature finds that prevention is the best method to protect the unique and special marine environments in this state. The technology for containing and cleaning up a spill of oil or hazardous substances is at best only partially effective. Preventing spills is more protective of the environment and more cost-effective when all the response and damage costs associated with responding to a spill are considered. Therefore, the legislature finds that the primary objective of the state is to achieve a zero spills strategy to prevent any oil or hazardous substances from entering waters of the state.

(3) The legislature also finds that: (a) Recent accidents in Washington, Alaska, southern California, Texas,

Pennsylvania, and other parts of the nation have shown that the transportation, transfer, and storage of oil have caused significant damage to the marine environment;

(b) Even with the best efforts, it is nearly impossible to remove all oil that is spilled into the water, and average removal rates are only fourteen percent;

(c) Washington's navigable waters are treasured environmental and economic resources that the state cannot afford to place at undue risk from an oil spill;

(d) The state has a fundamental responsibility, as the trustee of the state's natural resources and the protector of public health and the environment to prevent the spill of oil; and

(e) In section 5002 of the federal oil pollution act of 1990, the United States congress found that many people believed that complacency on the part of industry and government was one of the contributing factors to the Exxon Valdez spill and, further, that one method to combat this complacency is to involve local citizens in the monitoring and oversight of oil spill plans. Congress also found that a mechanism should be established that fosters the long-term partnership of industry, government, and local communities in overseeing compliance with environmental concerns in the operation of crude oil terminals. Moreover, congress concluded that, in addition to Alaska, a program of citizen monitoring and oversight should be established in other major crude oil terminals in the United States because recent oil spills indicate that the safe transportation of oil is a national problem.

(4) In order to establish a comprehensive prevention and response program to protect Washington’s waters and natural resources from spills of oil, it is the purpose of this chapter:

(a) To establish state agency expertise in marine safety and to centralize state activities in spill prevention and response activities;

(b) To prevent spills of oil and to promote programs that reduce the risk of both catastrophic and small chronic spills;

(c) To ensure that responsible parties are liable, and have the resources and ability, to respond to spills and provide compensation for all costs and damages;

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(d) To provide for state spill response and wildlife rescue planning and implementation; (e) To support and complement the federal oil pollution act of 1990 and other

federal law, especially those provisions relating to the national contingency plan for cleanup of oil spills and discharges, including provisions relating to the responsibilities of state agencies designated as natural resource trustees. The legislature intends this chapter to be interpreted and implemented in a manner consistent with federal law;

(f) To provide broad powers of regulation to the department of ecology relating to spill prevention and response;

(g) To provide for independent review on an ongoing basis the adequacy of oil spill prevention, preparedness, and response activities in this state; ((and))

(h) To provide an adequate funding source for state response and prevention programs; and

(i) To maintain the best achievable protection that can be obtained through the use of the best achievable technology and those staffing levels, training procedures, and operational methods that provide the greatest degree of protection achievable.

Sec 2. RCW 88.46.010 and 2011 c 122 s 1 are each reenacted and amended to read as

follows: The definitions in this section apply throughout this chapter unless the context clearly

requires otherwise. (1) “Best achievable protection” means the highest level of protection that can be

achieved through the use of the best achievable technology and those staffing levels, training procedures, and operational methods that provide the greatest degree of protection achievable. The director’s determination of best achievable protection shall be guided by the critical need to protect the state’s natural resources and waters, while considering:

(a) The additional protection provided by the measures; (b) The technological achievability of the measures; and (c) The cost of the measures. (2) ( a ) “Best achievable technology” means the technology that provides the greatest

degree of protection taking into consideration: (i) Processes that are being developed, or could feasibly be developed, given overall

reasonable expenditures on research and development; and (ii) Processes that are currently in use. (b) In determining what is best achievable technology, the director shall consider the

effectiveness, engineering feasibility, and commercial availability of the technology.

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Washington State Department of Ecology A-7 Publication No. 17-08-010

NEW SECTION. Sec. 11. A new section is added to chapter 90.56 RCW to read as follows:

(1) The department must complete an evaluation and assessment of vessel traffic management and vessel traffic safety within and near the mouth of the Columbia river. A draft evaluation and assessment must be completed and submitted to the legislature consistent with RCW 43.01.036 by December 15, 2017. A final evaluation and assessment must be completed by June 30, 2018. In conducting this evaluation, the department must consult with the United States coast guard, the Oregon board of maritime pilots, Columbia river harbor safety committee, the Columbia river bar pilots, the Columbia river pilots, area tribes, public ports in Oregon and Washington, local governments, and other appropriate entities.

(2) The evaluation and assessment completed under subsection (1) of this section must include, but is not limited to, an assessment and evaluation of: (a) The need for tug escorts for oil tankers, articulated tug barges, and other towed waterborne vessels or barges; (b) best achievable protection; and (c) required tug capabilities to ensure safe escort of vessels on the waters that are the subject of focus for each water body evaluated under subsection (1) of this section.

(3) The assessment and evaluations submitted to the legislature under subsection (1) of this section must include recommendations for vessel traffic management and vessel traffic safety on the Columbia river, including recommendations for tug escort requirements for vessels transporting oil as bulk cargo.

(4) All requirements in this section are subject to the availability of amounts appropriated for the specific purposes described.

(5) This section expires June 30, 2019.

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Washington State Department of Ecology B-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix B:

List of Project Contributors and Workshop Attendees

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Washington State Department of Ecology B-2 Publication No. 17-08-010

Table of Contents Page Summary ..............................................................................................................................3 Events and Participants ........................................................................................................4

List of Tables

Page Table 1: Columbia River Vessel Traffic Safety Assessment (CRVTSA) Tribal

Briefing ...............................................................................................................4 Table 2: Columbia River Vessel Traffic Safety Assessment (CRVTSA) Stakeholder

Briefing ...............................................................................................................5 Table 3: Lower Columbia Region Harbor Safety Committee (LCRHSC) July 2016

Workgroup Meeting ............................................................................................6 Table 4: LCRHSC CRVTSA Workgroup Meeting September 2016 ..................................7 Table 5: Scenario Workshop ................................................................................................8 Table 6: LCRHSC CRVTSA Workgroup Meeting January 2017 .......................................9 Table 7: Risk Results and Mitigation Workshop ...............................................................10 Table 8: LCRHSC February 2017 Workgroup Meeting....................................................11 Table 9: Best Achievable Protection Workshop ................................................................12 Table 10: CRVTSA Recommendations Workshop ...........................................................13

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Washington State Department of Ecology B-3 Publication No. 17-08-010

Summary

This appendix lists the participants in project meetings held during the study between May 12, 2016 and June 30, 2017. This appendix does not include several planning meetings that were held before May 12, 2016, or smaller discussions that occurred during the evaluation which focused on specific topics (e.g., identifying towing vessels that typically move oil barges). Ecology consulted with a wide range of entities during the execution of this evaluation, including the U.S. Coast Guard, Oregon Board of Maritime Pilots, Lower Columbia Region Harbor Safety Committee, Columbia River Bar Pilots, Columbia River Pilots, area tribes, Columbia River Gorge Commission, public ports in Oregon and Washington, local governments, and other appropriate entities. A website (http://www.ecy.wa.gov/programs/spills/prevention/RiskAssessment.html) provided information on the interim status of the project, and upcoming opportunities to engage. The information gathered in workshops and meetings was vital to the study. The participants at events and group meetings are listed in the tables below. This list may not be all inclusive; Ecology apologizes for any participants who were omitted. Participation in project events does not imply endorsement of the study findings and recommendations by these individuals or their organizations.

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Events and Participants

Table 1: Columbia River Vessel Traffic Safety Assessment (CRVTSA) Tribal Briefing

May 12, 2016 Oregon Department of Environmental Quality Northwest Region Office

700 NE Multnomah St., Suite 600, Portland, OR 97232

Name Tribe/Organization

Boyd, Amy Cowlitz Indian Tribe

Carter, Julie Columbia River Inter-Tribal Fish Commission

Huber, Audie Confederated Tribes of the Umatilla Indian Reservation

Kent, Brady Confederated Tribes and Bands of the Yakama Nation

Lothrop, Rob Columbia River Inter-Tribal Fish Commission

Salakory, Rudy Cowlitz Indian Tribe

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Table 2: Columbia River Vessel Traffic Safety Assessment (CRVTSA) Stakeholder Briefing

May 12, 2016 Oregon Department of Environmental Quality Northwest Region Office

700 NE Multnomah St., Suite 600, Portland, OR 97232

Name Tribe/Organization

Aberle, Barb Washington State Department of Transportation

Anderson, Scott NOAA Fisheries

Beasley, Dale Coalition of Coastal Fisheries

Bennett, Peter Millennium Bulk Terminals-Longview

Bro, Peter J. Lauritzen

Carter, Amber Amber Carter Government Relations, LLC

Collins, Bill Tidewater Transportation and Terminals

Cummins, Chris General Steamship Agencies

Curran, Janet NOAA Fisheries

Flanagan, Brien Schwabe, Williamson & Wyatt

Harlan, David Oregon Public Ports Association

Hathaway, Chris The Lower Columbia Estuary Partnership

Hendriks, Paul Foss Maritime Company

Holmes, Frank Western States Petroleum Association

Klaas, Andrea Port of the Dalles

Konz, David Tidewater Transportation and Terminals

Landauer, Mark Oregon Public Ports Association

Lichatowich, Paulette Port of St. Helens

Lyzell, Russ General Steamship Agencies

McDonald, Ross Sause Bros.

Mickelson, Kate Columbia River Steamship Operators’ Association

Miranda, Paula Port of St. Helens

Rich, Rob Shaver Transportation Company

Robinson, Holly Maritime Fire & Safety Association

Russell, Don Morrow County, Oregon

Serres, Daniel Columbia Riverkeeper

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Table 3: Lower Columbia Region Harbor Safety Committee (LCRHSC) July 2016 Workgroup Meeting

July 14, 2016 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Bayer, Marc Tesoro Maritime Company

Bonnin, Kirk Olympic Tug and Barge

Burnette, Eric Oregon Board of Maritime Pilots

Ferguson, Scott Washington State Department of Ecology

Gill, Rick Columbia River Pilots

Harding, Fred Shaver Transportation Company

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Konz, David Tidewater Transportation and Terminals

Lawrenson, Ken U.S. Coast Guard

Mickelson, Kate Columbia River Steamship Operators’ Association

Moreira, Bruce DNV GL

Myer, Fred Port of Portland

O’Mara, Dennis DNV GL

Smith, Scott Oregon Department of Environmental Quality

Springer, Laura LCDR U.S. Coast Guard

Stahl, Cheryl DNV GL

Wainwright, Liz Merchants Exchange of Portland, Oregon

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Table 4: LCRHSC CRVTSA Workgroup Meeting September 2016

September 23, 2016 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Bayer, Marc Tesoro Maritime Company

Burnette, Eric Oregon Board of Maritime Pilots

Ferguson, Scott Washington State Department of Ecology

Harding, Fred Shaver Transportation Company

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Lawrenson, Ken U.S. Coast Guard

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Table 5: Scenario Workshop

October 6, 2016 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Ackerman, Steve Columbia River Bar Pilots

Beasley, Dale Coalition of Coastal Fisheries

Bonnin, Kirk Olympic Tug and Barge

Cassinelli, Mike Beacon Charters

Corbin, John Oregon Dungeness Crab Commission

Costanzo, Charles American Waterways Operators

Cothern, Shayne Washington Department of Natural Resources

Crabbs, William Phillips 66 Company

Ferguson, Scott Washington State Department of Ecology

Flanagan, Brien Schwabe, Williamson & Wyatt

Gill, Rick Columbia River Pilots

Harding, Fred Shaver Transportation Company

Haugstad, Eric Tesoro Companies, Inc.

Helenberg, Ashley Port of Longview

Holmes, Frank Western States Petroleum Association

Jensen, Dale Washington State Department of Ecology

Johnson, Susan Oregon Board of Maritime Pilots

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Lawrenson, Ken U.S. Coast Guard

Lichatowich, Paulette Port of St. Helens

Lothrop, Rob Columbia River Inter-Tribal Fish Commission

Mickelson, Kate Columbia River Steamship Operators’ Association

O’Mara, Dennis DNV GL

Robinson, Holly Maritime Fire & Safety Association

Schneider, John Tesoro Maritime Company

Springer, Laura U.S. Coast Guard

Stahl, Cheryl DNV GL

Uglum, Lars Port of Vancouver USA

Wainwright, Liz Merchants Exchange of Portland, Oregon

Wolniakowski, Krystyna Columbia River Gorge Commission

Zollitsch, Mike Oregon Department of Environmental Quality

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Table 6: LCRHSC CRVTSA Workgroup Meeting January 2017

January 18, 2017 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Bartz, David Schwabe, Williamson & Wyatt

Bonnin, Kirk Olympic Tug and Barge

Burnette, Eric Oregon Board of Maritime Pilots

Costanzo, Charles American Waterways Operators

Ferguson, Scott Washington State Department of Ecology

Gill, Rick Columbia River Pilots

Harding, Fred Shaver Transportation Company

Helenberg, Ashley Port of Longview

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Lawrenson, Ken U.S. Coast Guard

Mickelson, Kate Columbia River Steamship Operators’ Association

O’Mara, Dennis (by phone) DNV GL

Phillips, Karen Washington State Department of Ecology

Robinson, Holly Maritime Fire & Safety Association

Stahl, Cheryl (by phone) DNV GL

Uglum, Lars Port of Vancouver USA

Wainwright, Liz Merchants Exchange of Portland, Oregon

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Table 7: Risk Results and Mitigation Workshop

January 25, 2017 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Ackerman, Steve Columbia River Bar Pilots

Bartz, David Schwabe, Williamson & Wyatt

Bayer, Marc Tesoro Maritime Company

Beasley, Dale Coalition of Coastal Fisheries

Bonnin, Kirk Olympic Tug and Barge

Burnett, Eric Oregon Board of Maritime Pilots

Cothern, Shayne Washington State Department of Natural Resources

Ferguson, Scott Washington State Department of Ecology

Flanagan, Brien Schwabe, Williamson & Wyatt

Ganuelas, Terry Confederated Tribes and Bands of the Yakama Nation

Gill, Rick Columbia River Pilots

Harding, Fred Shaver Transportation Company

Helenberg, Ashley Port of Longview

Holmes, Frank Western States Petroleum Association

Jensen, Dale Washington State Department of Ecology

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Konz, David Tidewater Transportation and Terminals

Lamebull, Zach Confederated Tribes and Bands of the Yakama Nation

Lawrenson, Ken U.S. Coast Guard

Mickelson, Kate Columbia River Steamship Operators’ Association

O’Mara, Dennis DNV GL

Phillips, Karen Washington State Department of Ecology

Robinson, Holly Maritime Fire & Safety Association

Schneider, John Tesoro Maritime Company

Springer, Laura U.S. Coast Guard

Stahl, Cheryl DNV GL

Uglum, Lars Port of Vancouver USA

Zollitsch, Mike Oregon Department of Environmental Quality

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Table 8: LCRHSC February 2017 Workgroup Meeting

February 16, 2017 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Bartz, David Schwabe, Williamson & Wyatt

Bayer, Marc Tesoro Maritime Company

Bonnin, Kirk Olympic Tug and Barge

Costanzo, Charles (by phone) American Waterways Operators

Ferguson, Scott Washington State Department of Ecology

Gill, Rick Columbia River Pilots

Harding, Fred Shaver Transportation Company

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Lawrenson, Ken U.S. Coast Guard

Mickelson, Kate Columbia River Steamship Operators’ Association

O’Mara, Dennis (by phone) DNV GL

Robinson, Holly Maritime Fire & Safety Association

Stahl, Cheryl (by phone) DNV GL

Wainwright, Liz Merchants Exchange of Portland, Oregon

Zollitsch, Mike Oregon Department of Environmental Quality

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Table 9: Best Achievable Protection Workshop

February 23, 2017 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Ackerman, Steve Columbia River Bar Pilots

Barrow, Herb Williamson & Associates

Bart, Bill Crowley Marine Services, Inc.

Bartz, David Schwabe, Williamson & Wyatt

Bayer, Marc Tesoro Maritime Company

Beasley, Dale Coalition of Coastal Fisheries

Bonnin, Kirk Olympic Tug and Barge

Boyd, Amy Cowlitz Indian Tribe

Corbin, John Oregon Dungeness Crab Commission

Cothern, Shayne Washington Department of Natural Resources

Ferguson, Scott Washington State Department of Ecology

Gill, Rick Columbia River Pilots

Harding, Fred Shaver Transportation Company

Holmes, Frank Western States Petroleum Association

Jensen, Dale Washington State Department of Ecology

Johnson, Susan Oregon Board of Maritime Pilots

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Konz, David Tidewater Transportation and Terminals

Lawrenson, Ken U.S. Coast Guard

McDonald, Ross Sause Bros.

Mickelson, Kate Columbia River Steamship Operators’ Association

O’Mara, Dennis DNV GL

Peterson, Christopher Crowley Petroleum Services

Phillips, Karen Washington State Department of Ecology

Robinson, Holly Maritime Fire & Safety Association

Stahl, Cheryl DNV GL

Uglum, Lars Port of Vancouver USA

Wainwright, Liz Merchants Exchange of Portland, Oregon

Wolniakowski, Krystyna Columbia River Gorge Commission

Zollitsch, Mike Oregon Department of Environmental Quality

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Table 10: CRVTSA Recommendations Workshop

March 21, 2017 Merchants Exchange of Portland, Oregon

200 SW Market Street, Suite 190, Portland, Oregon 97201

Name Tribe/Organization

Ackerman, Steve Columbia River Bar Pilots

Bartz, David Schwabe, Williamson & Wyatt

Bayer, Marc Tesoro Maritime Company

Beasley, Dale Coalition of Coastal Fisheries

Bonnin, Kirk (by phone) Olympic Tug and Barge

Burnette, Eric Oregon Board of Maritime Pilots

Costanzo, Charles (by phone) American Waterways Operators

Ferguson, Scott Washington State Department of Ecology

Harding, Fred Shaver Transportation Company

Helenberg, Ashley Port of Longview

Holmes, Frank Western States Petroleum Association

Jensen, Dale Washington State Department of Ecology

Jordan, Dan Columbia River Bar Pilots

Kirk, Brian Washington State Department of Ecology

Konz, David Tidewater Transportation and Terminals

McDonald, Ross Sause Bros.

Mickelson, Kate Columbia River Steamship Operators’ Association

O’Mara, Dennis (by phone) DNV GL

Stahl, Cheryl (by phone) DNV GL

Uglum, Lars Port of Vancouver USA

Wainwright, Liz Merchants Exchange of Portland, Oregon

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix C

Washington State Department of Ecology C-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix C:

Case Descriptions

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech disability may call TTY at 877-833-6341.

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Washington State Department of Ecology C-2 Publication No. 17-08-010

Table of Contents Page

Introduction ..........................................................................................................................3

Case A: Baseline Marine Traffic on the Columbia River ....................................................4

Baseline Traffic Data .................................................................................................4

Traffic Analysis ..........................................................................................................5

Case B and Case C: Baseline Traffic + Project Vessels on the Columbia River ................8

References ..........................................................................................................................10

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix C

Washington State Department of Ecology C-3 Publication No. 17-08-010

Introduction

This appendix provides a detailed description of the three marine traffic cases modeled in the Columbia River Vessel Traffic Evaluation and Safety Assessment (CRVTSA). The sections of this document describe the Columbia River traffic cases listed in Table 1.

Table 1: Evaluated Traffic Cases

Case General Description Details

Case A Baseline year traffic The baseline year for the evaluation was October 1, 2015 – September 30, 2016; this was the most recent year of AIS data available.

For vessels that carry cargo oil, Ecology reviewed VEAT analysis for the baseline year to determine the number of transits within the study area and routes traveled. Data sources for the VEAT include AIS and information from Ecology’s Advance Notice of Oil Transfer system (Ecology 2017a, Ecology 2017b).

For vessels that do not carry cargo oil, input to the MARCS model was processed AIS data for the baseline year for the study area. The AIS data defined vessel traffic patterns, traffic densities, and vessel speeds.

Case B Baseline year traffic plus 25% of Project Transits

Baseline year plus 345 transits, 25% of Project vessel trips listed in Appendix F, Study Basis:

• Laden tankers/ballast tankers

• Laden barges/ballast barges

• Tanker/cargo vessels (not laden with oil)

Case C Baseline year traffic plus 100% of Project Transits

Baseline year plus 1,379 transits, 100% of Project vessel trips listed in Appendix F, Study Basis:

• Laden tankers/ballast tankers

• Laden barges/ballast barges

• Tanker/cargo vessels (not laden with oil)

Vessel traffic was analyzed for Cases A, B, and C for the Columbia River (River Mile 0 to 105). Cargo oil spill risks were not modeled quantitatively for the Columbia River Bar (River Mile -5 to 0), so vessel traffic data was not analyzed for the bar. Risks and potential risk reduction measures were considered qualitatively for the Columbia River Bar, as discussed in the report.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix C

Washington State Department of Ecology C-4 Publication No. 17-08-010

Case A: Baseline Marine Traffic on the Columbia River

Baseline Traffic Data

The baseline traffic is a combination of Automated Identification System (AIS) data for non-oil carrying vessels, and Ecology VEAT analysis for transits of oil-carrying vessels. The combination of both data sets more accurately depicts the waterway traffic for oil cargoes. The MARCS model using baseline vessel traffic is designated Case A. For vessels carrying oil as cargo, Ecology gathered the best available information for the purposes of this study, which is published in an annual Vessel Entries and Transits report for Washington waters. Data for the VEAT analysis comes from AIS records compiled by the Merchants Exchange of Portland, Oregon (Merchants Exchange of Portland, 2016) and information from Ecology’s Advance Notice of Oil Transfer system (Ecology, 2017a and 2017b). Ecology reviewed VEAT data for the baseline year (October 1, 2015 through September 30, 2016) to identify transits of oil-carrying vessels. AIS is the best available data for general marine traffic. The evaluation used AIS data for the baseline year (Merchant’s Exchange of Portland, 2016) as the basis for the baseline vessel traffic in the study area. AIS is a shipboard system that sends and receives signals with information about vessels, including their location and direction (U.S. Coast Guard, 2014). AIS data captures all transits of vessels carrying AIS transponders in the study area of Columbia River and Bar. The International Convention for the Safety of Life at Sea (SOLAS) and U.S. regulations require AIS transmitters on all vessels of concern to this study. Because of its obvious value to mariners, many smaller vessels are fitted with AIS transmitters even though it is not required. The following vessels are required to carry AIS (33 CFR 164.46):

• A self-propelled vessel of 65 feet or more in length, engaged in commercial service. • A towing vessel of 26 feet or more in length and more than 600 horsepower, engaged in

commercial service. • A self-propelled vessel with a certificate to carry more than 150 passengers. • A self-propelled vessel engaged in dredging operations in or near a commercial channel or

shipping fairway in a manner likely to restrict or affect navigation of other vessels. • A self-propelled vessel engaged in the movement of dangerous cargo, or bulk liquid cargo

that is flammable or combustible. • A vessel of 300 gross tonnage or more, on an international voyage. • A vessel of 150 gross tonnage or more, when carrying more than 12 passengers on an

international voyage. • A vessel determined to have mitigated safety risk through voluntary installation of AIS by

the Captain of the Port. The AIS data contain timestamps, coordinates and vessel information that make it possible to track vessels in real time and to analyze the sailing routes of the traffic in retrospect. Vessels that do not carry AIS are not included the above estimate or accounted for in the modeling conducted for this assessment. However, disregarding these vessels does not affect the

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outcome or validity of the evaluation. These smaller vessels do not have the capability to directly cause a cargo oil spill by colliding with a tanker or barge. In separate studies, DNV GL has analyzed the amount of force required to breach double-hulls. In this relatively narrow waterway, all vessels with the potential to generate the necessary 40 Megajoules of force are required to carry AIS transponders. In the AIS software, the vessel operator must choose a vessel type from a dropdown list. This evaluation used the basic AIS system names for vessel types, and has subdivided several of them for modeling purposes. Vessel types used in the evaluation are shown in Appendix F, Study Basis.

Traffic Analysis

More than 95% of vessels transiting the Columbia River do not carry oil as cargo. Figure 1 shows the traffic that did not carry oil cargoes on the river during the baseline year (October 1, 2015 to September 30, 2016).

Figure 1: Non-oil AIS Vessel Types in Case A (Baseline Traffic)

Coastal tugs and cargo carriers represented nearly 60% of the traffic on the river based on miles sailed. Coastal tugs generally tow cargo barges.

The cargo oil vessels in the baseline traffic were ATBs, tugs with oil-barges-in-tow, and oil tankers. Vessels typically transit in one direction with cargo onboard, indicated as laden, and transit the other direction without oil cargo, indicated as unladen. For Case A, approximately 3% of the vessel traffic was oil laden vessels.

Coastal Tugs, 31%

Cargo Carriers, 28%

Service, 10%

Other, 10%

Fishing Vessels, 6%

Undefined, 5%

Passenger Vessels, 4%

Pleasure Craft, 4%Cruise Ships,

2%

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The breakdown of laden oil cargo traffic by vessel type is shown in Figure 2.

Figure 2: Distribution of Laden Oil Cargo Traffic based on Transited Miles in Case A (Baseline

Traffic)

About 88% of the oil cargo vessel traffic is inbound to terminals in Washington and Oregon. The remaining 12% of laden traffic was outbound. Much of this “outbound” cargo oil is barges delivering fuel and other refined products to vessels berthed on the river; it is included in the outbound total because the loaded barges begin their transit at River Mile 101, and in the baseline year, traveled as far downriver as River Mile 15.

ATBs represented half of the laden miles travelled in the baseline year. Approximately one-quarter of the laden miles travelled on the river was tugs with oil-barges-in-tow. Inbound laden oil tankers represented 13% of laden miles.

Figure 2 above shows the relative distribution of distance travelled per laden vessel type. Table 2 lists the actual number of transits.

Table 2: Transits of Laden Cargo Oil Vessels in Case A (Baseline Traffic)

Laden Cargo Oil Vessel Type Comments Laden Trips per year

ATB Inbound Carry refined products across the bar to terminals on the river

110

ATB Outbound Carry refined products from terminals down the river and over the bar

2

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Laden Cargo Oil Vessel Type Comments Laden Trips per year

Oil Tanker Inbound Carry refined products across the bar to terminals on the river

29

Oil Tanker Outbound Carry refined products from terminals down the river and over the bar

2

Tug with Oil-barge-in-tow transiting eastward beyond River Mile 105 (Inbound)

Carry refined products upriver after loading at terminals east of River Mile 100

214

Tug with Oil-barge-in-tow transiting eastward from the bar (Inbound)

Carry refined products across the bar to terminals on the river

42

Tug with Oil-barge-in-tow used for fuel bunkering (Outbound)

Carry marine fuel and other refined products to vessels at berths

77

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Case B and Case C: Baseline Traffic + Project Vessels on the Columbia River

The evaluation considered two potential future scenarios, which added vessels from proposed facilities to the baseline traffic. Six proposed projects within the study area were identified (Table 3). Publicly available information was used to determine the maximum proposed laden transits per year for each project. The table was current at the time of issue of this report.

Table 3: Proposed Terminal Projects

Project Name Proposed Location

Cargo

Assumed Vessel Size for Model (Metric Deadweight Tons)

Proposed Maximum Loaded Transits per Year

Details

Millennium Bulk Terminal (Cowlitz County, 2016)

Longview, WA

Coal 44,894 840 No cargo oil transits

Tesoro Savage JV, Vancouver Energy Project (Energy Facility Site Evaluation Council, 2016)

Vancouver, WA

Oil 41,408 (laden)

20,554 (ballast)

365

365 ballasted inbound transits plus 365 laden, outbound transits

Northwest Innovation Works LLC (Cowlitz County and Port of Kalama, 2016)

Port of Kalama-Cowlitz County, WA

Methanol 44,894 72 No cargo oil transits

Northwest Innovation Works LLC (Cowlitz County and Port of Kalama, 2016)

Port Westward in Clatskanie, OR

Methanol 44,894 72 No cargo oil transits

Columbia River Carbonates Woodland Marine Terminal

Woodland, WA

Calcium Carbonate

8,061 30 No cargo oil transits

Total of Proposed Loaded Transits 1,379

The participants in the Scenario Workshop discussed future traffic at length. It was difficult to estimate future laden tank vessel traffic when most of the proposed terminal projects were still in the review process, neither approved nor disapproved.

Workshop participants agreed that it was highly unlikely that all the proposed projects would be built. They also agreed that it was possible for the terminals that are built to operate at lower traffic levels than their proposed maximum capacities. The workshop participants did not make

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any judgments or predictions about which proposed projects would be built, or the associated traffic levels. They did, however, express a desire to see risk analysis results for cases less than a full build out of proposed projects.

To resolve the challenging issue of uncertainty with future projects, the CRVTSA analyzed two future cases:

• Case B - the baseline year traffic plus all the proposed projects operating at 25% of their proposed maximum number of vessel trips (laden and unladen transits).

• Case C - the baseline traffic plus all the proposed projects operating at their proposed maximum number of vessel trips (laden and unladen transits).

The evaluation did not make assumptions about how marine bunkering (e.g., providing fuel and other refined products to a vessel at a berth) might change in the future. No additional bunkering transits were added to Case B or Case C. Participants were concerned that future traffic levels may be lower than modeled in the two future scenarios. A sensitivity analysis examined the change in cargo oil spill risk if 10% of vessel traffic associated with proposed terminal projects were added to baseline traffic. The results of this sensitivity analysis is presented in Appendix J, Assessment of Best Achievable Protection.

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References

Merchant’s Exchange of Portland (2016). Automatic Identification System data obtained from the Merchant’s Exchange of Portland, Oregon. Data from October 1, 2015 to September 30, 2016.

U.S. Coast Guard (2014). Navigation Center: The Navigation Center of Excellence – Automatic Identification System Overview. U.S. Department of Homeland Security. U.S. Coast Guard. Website. https://www.navcen.uscg.gov/?pageName=AISmain. Accessed March 15, 2017.

Department of Ecology (2017a). Vessel Entries and Transits (VEAT) Counts for Washington Waters by Calendar Year. Data downloaded for 2015 and 2016 on May 31, 2017. http://www.ecy.wa.gov/programs/spills/publications/publications.htm.

Department of Ecology (2017b). Advance Notice of Oil Transfer. http://www.ecy.wa.gov/programs/spills/prevention/antsystem.html.

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Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix D:

Marine Safety Risk Controls

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech disability may call TTY at 877-833-6341.

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Table of Contents Page

Introduction ..........................................................................................................................3

Government Oversight .........................................................................................................5

International Maritime Organization and International Conventions ........................5

U.S. Coast Guard Inspections ....................................................................................7

Pilots ...........................................................................................................................9

Ecology .....................................................................................................................11

Oregon Department of Environmental Quality ........................................................11

Industry Standards and Practices .......................................................................................13

Classification Societies ............................................................................................13

American Petroleum Institute ...................................................................................14

American Waterways Operators ..............................................................................14

Merchants Exchange of Portland, Oregon ...............................................................14

Vetting Practices ................................................................................................................16

OCIMF Vetting Programs ........................................................................................16

Additional Company Vetting Programs ...................................................................17

Navigation Route Risk Controls ........................................................................................18

U.S. Army Corps of Engineers .................................................................................18

U.S. Coast Guard ......................................................................................................18

National Oceanic and Atmospheric Administration ................................................19

Other Safety Practices ........................................................................................................20

Lower Columbia Region Harbor Safety Committee ................................................20

Under Keel Clearance ..............................................................................................22

TransView 32 ...........................................................................................................22

Columbia River Bar Prediction Models ...................................................................22

LoadMax ..................................................................................................................23

Sea IQ .......................................................................................................................23

Coastal Data Information Program Buoys ...............................................................23

Columbia River Bar .................................................................................................24

References ..........................................................................................................................25

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Introduction

The risk modeling conducted for the Columbia River Vessel Traffic Safety Assessment (CRVTSA) quantified many of the risk controls currently in place on the Columbia River and Bar. This appendix describes risk control practices, policies, and standards that are currently in place in the marine oil transportation industry on the river.

The risk controls described here are standard good practice, and are commonly accepted to reduce oil spill risk. Some could not be added to the risk model because the benefits they offer have not been studied in isolation and quantified. It remains unknown the exact degree to which they reduce risks. The modeled oil spill volumes and marine incident frequencies in this report do not include consideration of these additional risk controls. Thus, one could generally interpret the reported results as conservative; that is, the actual risk is lower than the model shows because not all existing risk reduction measures were included in the modeling.

Most of the risk controls described in this appendix apply to tank vessels transiting any waters in the world and transiting the Columbia River and Bar. However, some are specific to tank vessels on this waterway. The regulations and policies described in this appendix apply to all tank vessel carrying oil as cargo, as well as most other commercial vessels on the Columbia River and Bar.

Vessels operating in the study area were designed and constructed to international standards and /or domestic standards. They are inspected by federal and state agencies for compliance with construction and operational standards, and are subject to scrutiny on an ongoing basis from the various contracting entities involved in the transit of oil.

Robust, collaborative maritime safety programs are in operation today, reducing risks in marine transport of oil cargoes on the Columbia River and Bar. The waterway itself is managed under a scheme of regulations, standards, and best practices, all of which are communicated continuously throughout the regional maritime industry. As depicted in Figure 1, a combination of agencies and entities have institutionalized good practices and continuous improvement on the bar and river.

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Figure 1: Risk Controls on the Columbia River and Bar

Government Oversight

• International Maritime Organization

•Flag State Control

•Port State Control

•U.S. Coast Guard

•State of Washington

•State of Oregon

Industry Standards and

Practices

•Classification Societies

•American Petroleum Inst

•American Waterway Assoc

•Merchants Exchange of Portland

Vessel Risk Controls

•Vessel Design and Construction

•Vessel Operations

•Vetting

•Pilots

Navigation Route Risk Controls

•USACE

•US Coast Guard

•NOAA

Terminal Risk Controls

•USCG Terminal Insp

•State of Washington Terminal Insp

Other Safety Practices

•Lower Columbia Region Harbor Safety Committee

•Under Keel Clearance

•TransView 32

•LoadMax

•Sea IQ

•Channel Width/Depth

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Government Oversight

Multiple international, federal and state governments play a part in ensuring the safety of marine transportation. This section describes only a few of the agencies that exercise oversight of vessel operations on the Columbia River:

• United Nations International Maritime Organization (IMO). • U.S. Coast Guard. • U.S. Army Corps of Engineers (USACE). • National Oceanic and Atmospheric Administration, National Ocean Service. • Oregon State Board of Maritime Pilots. • Washington State Department of Ecology. • Oregon State Department of Environmental Quality.

The governing jurisdiction for every ship rests with the flag state, that is, the country in which the ship is registered. The government of the flag state ideally enforces upon its ship owners standards of design, construction, maintenance and operation.

The port state, the government of the ports or anchorages at which the ship calls, may enforce the international standards and its own regulations to protect its own interests. To drive consistency and excellence in trade, the United Nations created the IMO in 1948.

International Maritime Organization and International Conventions

The main role of the IMO is to create a regulatory framework for the shipping industry that is effective, universally adopted, and universally implemented.

IMO regulations and standards are agreed upon, adopted, and implemented on an international basis. Their standards cover all aspects of international shipping—ship design, construction, equipment, manning, operation and disposal—to ensure that shipping remains safe, environmentally sound, energy efficient, and secure (IMO, 2017).

Foreign flagged vessels carrying oil on the Columbia River are subject to the conventions and protocols established by the IMO. These have generally been adopted by law and regulation in the U.S. and are enforced by the U.S. Coast Guard. U.S. flagged vessels carrying oil on the Columba River are subject to U. S. Code of Federal Regulations (CFR) for shipping.

Foreign flagged oil-carrying vessels on the Columbia River follow the below conventions. This list is not intended to be all inclusive, but to provide a general idea of the breadth and scope of the IMO and other standards that apply to vessels transiting the Columbia River.

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IMO Conventions

• International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended. • International Convention for the Prevention of Pollution from Ships, 1973, as modified by

the Protocol of 1978 relating thereto and by the Protocol of 1997 (MARPOL). • International Convention on Standards of Training, Certification and Watchkeeping for

Seafarers (STCW) as amended, including the 1995 and 2010 Manila Amendments.

Other conventions relating to maritime safety and security and ship/port interface

• Convention on the International Regulations for Preventing Collisions at Sea (COLREG), 1972.

• Convention on Facilitation of International Maritime Traffic (FAL), 1965. • International Convention on Load Lines (LL), 1966. • International Convention on Maritime Search and Rescue (SAR), 1979. • Convention for the Suppression of Unlawful Acts Against the Safety of Maritime Navigation

(SUA), 1988, and Protocol for the Suppression of Unlawful Acts Against the Safety of Fixed Platforms located on the Continental Shelf (and the 2005 Protocols).

Other conventions relating to prevention of marine pollution

• International Convention Relating to Intervention on the High Seas in Cases of Oil Pollution Casualties (INTERVENTION), 1969.

• Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (LC), 1972 (and the 1996 London Protocol).

• International Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC), 1990.

• Protocol on Preparedness, Response and Co-operation to Pollution Incidents by Hazardous and Noxious Substances, 2000 (OPRC-HNS Protocol).

• International Convention on the Control of Harmful Anti-fouling Systems on Ships (AFS), 2001.

• International Convention for the Control and Management of Ships' Ballast Water and Sediments, 2004.

Conventions covering liability and compensation

• International Convention on Civil Liability for Oil Pollution Damage (CLC), 1969. • 1992 Protocol to the International Convention on the Establishment of an International Fund

for Compensation for Oil Pollution Damage (FUND 1992). • Convention on Limitation of Liability for Maritime Claims (LLMC), 1976. • International Convention on Liability and Compensation for Damage in Connection with the

Carriage of Hazardous and Noxious Substances by Sea (HNS), 1996 (and its 2010 Protocol). • International Convention on Civil Liability for Bunker Oil Pollution Damage, 2001.

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U.S. Coast Guard Inspections

The Coast Guard administers navigation and vessel inspection laws and regulations governing marine safety and environmental protection. The Coast Guard accomplishes this by prescribing regulations published in CFR Titles 33, 46 and 49. These regulations incorporate international laws to which the United States is signatory, as well as various classification society and industry technical standards. It is the Coast Guard’s responsibility to inspect the vessels regulated by those laws (U.S. Coast Guard, 2016). 1

Port State Control (PSC) is the process by which a nation exercises its authority over foreign vessels in waters subject to its jurisdiction. Through the PSC program, the Coast Guard verifies that foreign flagged vessels operating in U.S. waters comply with applicable international conventions, U.S. laws, and U.S. regulations. The goal of the PSC program is to identify and eliminate substandard ships from U.S. waters.

All commercial vessels, both U.S. and foreign flagged, operating in the Columbia River are subject to inspection by the Coast Guard. These vessels include tank barges, articulated tug/barge (ATB) combinations, and tank ships. Collectively, these are referred to as tank vessels in this report.

The Coast Guard recently published regulations in 46 CFR Subchapter M to require towing vessel certification. Tow vessel operators have maintained their own and/or industry safety standards prior to Coast Guard inspections; however, the addition of this new oversight is expected to contribute to further risk reduction.

Plan Review and Construction Oversight

Risk controls in commercial shipping begin before a ship is built. Flag states verify that each vessel meets specific design and equipment standards. Prior to construction, a vessel’s plans are reviewed and approved, either by the flag state administration or by a Classification Society, described below.

Vessel design plan review and approval for U.S. flag vessels includes a detailed engineering examination of vessels. If a vessel owner desires to alter a vessel significantly, the Coast Guard and Classification Societies also review and approve plans for modifications. The U.S. Coast Guard and Classification Societies inspect vessels under construction in shipyards to ensure the construction meets the approved design and meets quality assurance requirements. Upon completion, the Coast Guard issues a vessel Certificate of Inspection, which defines all the operating, equipment, and manning requirements of the vessel and authorizes the vessel to operate.

1 46 U.S.C. 3305, 3307, and 3714 provide the legal basis for Coast Guard inspection of vessels that are subject to inspection under 46 U.S.C. 3301.

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Tank Ship Inspections

Each foreign tank vessel must undergo a compliance verification exam conducted by the U.S. Coast Guard at its initial U.S. port of call and at least annually thereafter (46 U.S.C. 3714) (U.S. Coast Guard, 2016). A Coast Guard Certificate of Compliance Exam ensures compliance with:

• Pollution prevention requirements. • Navigation safety regulations. • The bulk liquid, liquefied gas, or compressed gas hazardous materials regulations. • General health and safety. • Structural integrity. • Ground tackle. • Cargo operations. • Fire prevention, firefighting and foam systems. • Inert gas systems. • Vapor control systems.

Mariner Credentials and Licensing

The U.S. Coast Guard issues credentials to U.S. mariners through its Regional Exam Centers. They pre-screen applications, administer examinations, and conduct oversight of Coast Guard approved courses. As a condition of receiving a Coast Guard credential, a mariner must undergo a background check and be granted a Transportation Worker Identification Credential from the Transportation Security Administration.

Coast Guard ensures mariners have received training from approved training providers, for approved courses, and evaluates trainers regularly to measure their competence.

Terminal Inspections

Marine terminals have plans and operations manuals approved and inspected by the Coast Guard to assure conformance to the plans. The plans include:

• Operations Manual: An overview of facility infrastructure, personnel training, storage capacity, operating characteristics.

• Facility Response Plan: A detained description of pollution response strategies, training, exercises.

• Facility Security Plan: Includes a security assessment and tiered security measures to prepare for potential security threats.

In addition, the Coast Guard ensures that facilities are contracted with an approved Oil Spill Response Organization to respond to spills from the facility or that may occur during transfer operations with vessels.

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Other requirements include minimum standards for:

• Personnel qualifications. • Training. • Drills. • Fire fighting equipment. • Warning signs. • Lighting. • Electrical systems. • Transfer system. • Small (not in water) discharge containment and removal. • Emergency shutdown. • Communications. • Pollution response equipment maintenance.

Pilots

A marine or maritime pilot is a person who has demonstrated expert local knowledge of a particular waterway. They also have experience in ship handling, seamanship and vessel navigation. A ship’s captain is responsible for the safe operation of the ship. However, for certain vessel types, particular waterways, or hazardous cargoes, a marine pilot is required as an additional risk control. Compulsory pilotage is used in most of the world’s large ports and in many environmentally sensitive waterways.

The safety effects of pilotage have been quantified and the associated risk reduction factor is included in the navigation risk model used in this study. Pilotage requirements on the Columbia River vary, based on the vessel size, country of registry, and trade the vessel is engaged in. Tank ships and tank barges on the Columbia River must be under the direction and control of an individual qualified to serve as pilot (46 CFR 15.812). Depending on the voyage, tank vessels, tugs towing oil barges, and ATBs may take a pilot credentialed by the state, or operate with a pilot credentialed by the U.S. Coast Guard (federal pilotage).

Federal Pilotage

Where a U.S. vessel is sailing under its coastwise endorsement, it is subject to Federal pilotage requirements. Coastwise trade is generally defined as the transportation of merchandise or passengers between points in the U.S. and its territorial sea (U.S. Coast Guard, 2015a).

According to U.S. Coast Guard Navigation and Vessel Inspection Circular (NVIC) No. 8-94, there are two types of individuals who may serve as a Federal pilot:

• One is an individual holding a Federal first class pilot's license with endorsement for the route, in accordance with 46 CFR 15.812(b)(1).

• The other is an individual generally referred to as an "acting as" pilot. An "acting as” pilot is an individual who is a licensed member of the vessel's crew and who also satisfies the qualification requirements found at 46 CFR 15.812(b)(2) and (b)(3). In 46 CFR 15.812(b)(2), the phrase "employed aboard a vessel" is interpreted by the Coast Guard to mean that the

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individual is a licensed member of the vessel's crew, or an appropriately licensed permanent employee of the vessel owner or operator serving aboard the vessel.

On the Columbia River, it is common for each tug crew to include enough vessel operators who meet pilotage requirements (either by holding a federal first class pilot endorsement or by being qualified to serve as a pilot) to complete the voyage within the required regulatory framework. In some cases, a pilot credentialed by the state may be hired to act in their capacity as a federal first class pilot.

State Pilotage

A vessel is subject to state pilotage laws as long as it meets one of the below criteria. It is then said to be operating on its registry endorsement.

• Carries any domestic cargo for delivery to a foreign port. • Carries any foreign cargo for delivery to a U.S. port or place embraced within the coastwise

laws. • Carries any foreign cargo for delivery to a foreign port (even though there may be

intermediate stops in U.S. ports). • Sails in ballast from a U.S. port to a foreign port or from a foreign port to a U.S. port.

If a documented U.S.2 vessel is not engaged in any of the above activities on any given voyage leg, it is deemed to be operating on its coastwise endorsement for pilotage purposes.

The State of Oregon requires pilotage as follows:

“Pilotage across the Columbia River bar and up or down the river is compulsory for U.S. vessels enrolled or sailing under Registry and all foreign vessels, except foreign recreational or fishing vessels not more than 100 feet in length or 250 gross tons international (NOAA, 2016).”

The Oregon Board of Maritime Pilots manages two pilot organizations who provide services on the Columbia River:

• The Columbia River Bar Pilots. Pilotage grounds for the Columbia River Bar Pilots (2014) extend from five nautical miles offshore to 123 degrees, 44 minutes West longitude.

• The Columbia River Pilots. The Columbia River Pilots provide pilotage services from Astoria to the head of navigation on the Columbia or Willamette Rivers and their tributaries (NOAA, 2016).

2 A U.S. vessel over 5 net tons with a USCG issued Certificate of Documentation that authorizes trade under Registry (foreign) and/or Coastwise (domestic, U.S.).

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The Columbia River Bar Pilots and Columbia River Pilots assume navigation control of the vessels they pilot.

Ecology

The Washington Department of Ecology Spill Prevention, Preparedness, and Response Program focuses on preventing oil spills to Washington’s waters and land, and planning for and delivering a rapid, aggressive, and well-coordinated response to oil and hazardous substance spills wherever they occur (Ecology, 2016). The program works with communities, industry, state and federal agencies, tribes, and other partners to prevent and prepare for oil spills. The program also responds to spills 24/7 from six offices located throughout the state and works to assess and restore environmental damage resulting from spills. Spills Program activity includes:

• Preventing oil spills from vessels and oil handling facilities. • Preparing for aggressive response to oil and hazardous material spills. • Rapidly responding to and cleaning up oil and hazardous material incidents. • Restoring public natural resources damaged by oils spills.

Ecology inspects commercial vessel cargo and passenger vessels over 300 gross tons and oil transfer facilities, and it oversees the transfer operations between ships and terminals (Ecology, 2017b). An Ecology inspection includes the following elements:

• Reviewing and approving operating manuals for large, fixed shore-side facilities (refineries to small tank farms) and terminals with a fuel capacity of 10,500 gallons or more.

• Monitoring oil transfer procedures. • Inspecting facilities for compliance with their prevention plans, operations manuals, training

and certification programs, and facility design standards. • Reviewing and approving oil spill contingency plans. • Evaluating required oil spill response drills.

Ecology also manages voluntary programs for the safe and pollution-free operation of tank vessels (Ecology, 2017). The Voluntary Best Achievable Protection (VBAP) and Exceptional Compliance programs (ECOPRO) identify standards that represent many of the best practices found on tank vessels throughout the world.

VBAP and ECOPRO standards were developed jointly with industry representatives. The goal is to provide standards higher than those required by law but achievable by today’s proactive marine transportation companies.

Oregon Department of Environmental Quality

Oregon Department of Environmental Quality (DEQ) has an active role in prevention, response, and mitigation of oil and hazardous materials cleanup. They also respond to oil spills around the

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clock (DEQ, 2017). DEQ communicates with local, tribal, state, and federal partners and industry to begin a quick and coordinated response. DEQ:

• Works to develop oil spill response plans, train staff, and conduct exercises to confirm successful execution of plans.

• Develops plans that identify sensitive natural or cultural resources and specific response strategies to minimize impacts to these resources. Plans have been developed for the Columbia River.

• Coordinates with other local and state agencies, federal partners, and industry to cleanup oil and hazardous material spills.

• Develops policy to ensure spill response planning and preparedness activities occur inland to address risks of increased oil transport.

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Industry Standards and Practices

Several industry organizations develop standards of operation to ensure safety and environmental protection. These organizations engage in continuous activity to improve technical and operational safety standards. Some of these organizations are described below.

Classification Societies

Classification societies are independent, non-governmental organizations that develop standards and best practices for the maritime, oil, and gas industries. They help industry and regulatory agencies assure marine safety and pollution prevention. Classification societies are sources of maritime safety and pollution prevention knowledge and technology.

The objective of classification of ships is to verify the structural strength and integrity of essential parts of a ship’s hull, and verify the reliability and function of the propulsion and steering systems, power generation, and key safety systems. Classification societies achieve this through the development and application of their own rules and by verifying compliance with international and/or national regulations on behalf of flag administrations.

Most commercial ships in the world, and all commercial ships on the Columbia River, are built to and surveyed for compliance with a set of Classification Society standards and international and national statutes (International Association of Classification Societies, 2017).

Classification societies verify vessel plans, typically, prior to and during construction.

The classification process during construction consists of:

• A technical review of the design plans and related documents for a new vessel to verify compliance with the applicable Rules.

• Attendance at the construction of the vessel in the shipyard by a Classification Society surveyor(s) to verify that the vessel is constructed in accordance with the approved design plans and classification Rules.

• Attendance by a classification society surveyor(s) at the relevant production facilities that provide key components such as the steel, engine, generators and castings to verify that the component conforms to the applicable Rule requirements.

• Attendance by a classification society surveyor(s) at the sea trials and other trials relating to the vessel and its equipment prior to delivery to verify conformance with the applicable Rule requirements.

A vessel enters service only after is has satisfied all of the above items. Upon satisfactory completion of the above items, the ship owners typically request the issuance of a class certificate from the classification society. If deemed satisfactory, a certificate of classification is issued.

Once in service, the vessel must undergo periodic class surveys, carried out onboard the vessel, to verify that the ship continues to meet the class requirements. This is in addition to inspections which may be carried out by the U.S. Coast Guard or other agencies.

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American Petroleum Institute

The American Petroleum Institute (API) is an industry trade association that represents all aspects of the oil and natural gas industry including marine transporters. One of API’s missions is to promote safety across the industry globally.

API conducts or sponsors research ranging from economic analyses to toxicological testing. The organization also develops safety standards and recommended practices for safe operations. Currently, API maintains 685 different safety standards and recommended practices, many of which have been incorporated into state and federal regulations. They certify oil and natural gas equipment used on board vessels and at bulk oil marine terminals. API also provides quality, environmental, and occupational health and safety management systems certification to oil transporters.

American Waterways Operators

The American Waterways Operators (AWO) is a trade organization representing the U.S. tugboat, towboat and barge industry. The AWO has developed a program to assist tug and barge operators in developing safety management systems and provides general assistance in complying with regulatory requirements.

The AWO Responsible Carrier Program (RCP) is a U.S. Coast Guard accepted Towing Safety Management System as defined in 46 CFR Subchapter M. In addition to complying with other regulations, members of the RCP develop and document written policies and procedures covering the following minimum items (AWO, 2013):

• Vessel operating policies and procedures. • Safety policy and procedures. • Security policy and procedures. • Environmental policy and procedures. • Incident reporting procedures. • Emergency response procedures. • Internal audit and review procedures. • Vendor safety. • Organization and levels of authority. • Personnel policies and procedures.

Merchants Exchange of Portland, Oregon

The Merchants Exchange of Portland operates a communications center that is available 24 hours a day, 365 days a year to provide information and to assist vessels in the Lower Columbia and Willamette Rivers. The Merchants Exchange monitors communication channels and tracks vessel movements between Astoria, Portland, and Vancouver (Merchants Exchange of Portland, 2017).

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The Merchants Exchange provides other services related to safe vessel transits, including:

• Marine radio to phone patches. • Notification to government agencies on vessel arrivals. • Industry notification of ship arrivals, moves and departures. • Monitoring and response for the Maritime Fire & Safety Association and Clean Rivers

Cooperative. • Emergency notifications.

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Vetting Practices

The marine oil transportation chain consists of multiple entities, which experience different risk exposures. A typical transit of a tank ship or barge laden with oil involves multiple entities with varying financial interests. Oil companies manage their risks through screening vessels and terminals to a set of minimum standards, including regulatory compliance.

Over the past 25 years, oil companies have raised their acceptance standards for tank vessels through a process referred to as vetting. Vetting includes inspections and audits of vessels and terminals. While vetting requirements are not mandatory, conformance is normally mandatory to be eligible for contracts to carry oil.

The Oil Companies International Marine Forum (OCIMF) is a global industry organization that enables an effective global vetting system.

OCIMF Vetting Programs

The OCIMF was established in 1970 to provide expertise and leadership in the development of safety and environmental protection standards and regulations in the maritime transportation and handling of oil. The OCIMF addresses issues related to:

• Developing standards. • Contributing to new regulations. • Promoting the implementation of international conventions and regulations. • Encouraging flag states, port states, and classification societies in the enforcement of

standards and regulations. • Promulgating data to charterers and regulatory authorities on tankers and barges through the

Ship Inspection Report (SIRE) program.

OCIMF collects, stores and shares tanker related data. OCIMF does not provide any qualitative data or opinion on vessel quality or risk of use. Each company using the data has their own risk profile/tolerance. The member companies interpret the data to come to their own decision of whether a specific tanker presents an acceptable risk and therefore can be used by that company.

Ship Inspection Report Program

The OCIMF introduced the Ship Inspection Report Program (SIRE) to specifically address concerns about sub-standard shipping. The SIRE Program is a tanker risk assessment tool that provides common information to charterers, ship operators, terminal operators and government bodies about the safety systems, practices, and material conditions of particular vessels.

SIRE inspections are conducted by third party auditors who meet the qualification requirements of the OCIMF. The results of SIRE audit are entered into a database of up-to-date quality and ship safety information about tankers and barges. More than 180,000 inspection reports are in the SIRE database. In the past 12 months, over 22,500 reports on over 8,000 vessel inspections have been added to the SIRE database (OCIMF, 2017a).

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The SIRE program uses a uniform inspection protocol. Vessel specific information is captured on standard forms, and includes particulars of each vessel audited. This assures reliable information is available and provides a level of transparency within the industry.

One key component of the OCIMF vetting program is the transparency of SIRE inspections. Incomplete or unsuccessful SIRE inspections result in losing contracts, imposition of additional requirements, or probationary periods where contracts are not awarded until SIRE inspection deficiencies are corrected.

Tanker Management & Self-Assessment

The Tanker Management & Self-Assessment program (TMSA) provides a standard set of industry best practices for vessel operating companies to assess operator safety management systems. It is based on the International Safety Management Code.3 Vessel operators use the assessment results to continuously improve their safety management systems.

As with SIRE reports, results of TMSA assessments are shared among entities in the oil handling supply chain and government regulators. Similar to SIRE, transparency and conditional requirements of contracting also apply to the TMSA.

Terminal Vetting

Terminals also can be vetted by ship owners under the Marine Terminal Information System (MTIS). Compared to SIRE, it is a relatively new data repository. It captures information offered by terminal operators about their physical arrangements such as depth and mooring, and their management systems. In line with the proactive culture typical of operators on the Columbia River, some of the terminals on the Columbia River have already entered their data in the MTIS (OCIMF, 2017b).

Additional Company Vetting Programs

In addition to the OCIMF-prescribed SIRE, TMSA, and MTIS programs, individual companies have their own vetting programs. Company vetting programs often have additional requirements beyond the minimums in SIRE, TMSA, MTIS, the U.S. Coast Guard, or Ecology. They may also be specific to a particular voyage or route. The programs often add requirements not part of a regulatory scheme, providing an incentive to meet voluntary requirements. For example, the Lower Columbia Region Harbor Safety Plan includes a Standard of Care stating that an additional tug (a tag tug) be used to assist tugs towing oil barges astern (LCRHSC, 2016). A company may require a tag tug on all barges carrying its cargo as part of its vetting program. In such a case, the tag tug and its operating company would be subject to company vetting. The effect is that the tag tug becomes a condition of the contractual relationship and the voyage.

3 Adopted by the International Maritime Organization, the International Safety Management Code provides guidance for the safe management and operation of ships and for pollution prevention.

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Navigation Route Risk Controls

Federal agencies with authority and responsibility to manage the waterway provide services to mariners and maintain the river for safe navigation. The primary federal agencies active on the Columbia River and Bar are the U.S. Army Corps of Engineers (USACE), the U.S. Coast Guard, and the National Oceanic and Atmospheric Administration.

U.S. Army Corps of Engineers

The U.S. Army Corps of Engineers (USACE) maintains safe and reliable channels, harbors and waterways for the transportation of commerce, support to national security, and recreation (USACE, 2017). The USACE Northwest Division in Portland, Oregon maintains the 43-foot deep, federally-authorized navigation channel in the Columbia River to a minimum width of 600 feet.

During the CRVTSA Risk Results and Mitigation Workshop, participants identified that additional dredging in and near the channel could enhance navigation safety. In some spots, there is an accumulation of sediment along the edge of the channel. This shoaling reduces the available depth of water near the channel boundaries. The pilot of a deep draft vessel must be highly attentive and make multiple course adjustments to prevent turning on the shoals. If these shoals were removed by dredging, grounding risk would be reduced in these areas.

In the navigation channel, shoaling reduces the available depth. As a result, the vessels wait at their berths for the tide to increase to allow a minimum of two feet under keel clearance. When the minimum depth of water is available, the vessel will leave the berth and head downriver. Additional dredging would improve vessel wait times and under keel clearance.

USACE is developing a Channel Maintenance Plan to cover the next 20 years. The plan will define the necessary activities to assure safe deep draft navigation. The formal planning effort began in early 2017.

The USACE also manages water flow through the upriver pools and dams to ensure water depths are maintained for safe navigation. Refer to Appendix K, Characterization of the Middle Columbia River-Snake River, for more information about the management of locks and dams.

U.S. Coast Guard

The U.S. Coast Guard manages Aids to Navigation (ATON) on the Columbia River including an array of audio, visual, radar, and radio aid to navigation, such as lights, buoys, sound signals, range markers, and radio beacons. In addition, the U.S. Coast Guard consults federal agencies, state representatives, waterway users, and the general public, to study waterways for safety and efficiency. The Coast Guard is engaged locally with the Lower Columbia Region Harbor Safety Committee.

The Coast Guard conducts a series of studies to identify navigation needs:

• The Waterways Analysis and Management System (WAMS) study is used to determine the effectiveness of ATON. It identifies needs to add or remove navigation aids or to alter technical aspects of the aids. The Columbia River WAMS is updated every five years.

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• The Port Access and Route Studies (PARS) is a study of potential traffic density and the need for safe access routes for vessels. A primary purpose of this study is to reconcile the need for safe access routes with other waterway uses. A PARS study is typically done before the Coast Guard establishes or changes Regulated Navigation Areas or Traffic Separation Schemes.

• A Port and Waterways Safety Assessment (PAWSA) is a risk assessment process to identify major waterway safety hazards, estimate risks, and evaluate potential mitigation measures. The process involves convening a select group of waterway users and conducting a structured workshop to meet these objectives. A sponsor (e.g., Captain of the Port) initiates and manages the workshop. However, the process is a joint effort involving waterway users, stakeholders, and the agencies/entities responsible for implementing the risk mitigation measures (COMDTINST 16001.1).

National Oceanic and Atmospheric Administration

The National Oceanic and Atmospheric Administration (NOAA) provides climate predictions and projections, weather and water reports, forecasts and warnings, nautical charts and navigational information, and the continuous delivery of Earth observations and scientific data for use by public, private, and academic sectors. Two NOAA offices, the National Ocean Service and the National Weather Service, deliver products and services that support navigation on the Columbia River and Bar.

The National Ocean Service is responsible for providing real-time oceanographic data and other navigation products to promote safe and efficient navigation. Mariners rely on the mapping, charting, and water level information provided by National Ocean Service around the country. On the Columbia River, the National Ocean Service operates and manages the Physical Oceanographic Real-Time System (PORTS).

The PORTS water level information is received directly on board vessels. It used with electronic nautical charts and real-time vessel location data to provide vessel operators and pilots with voyage planning information. PORTS data are also incorporated into the Port of Portland LoadMax system, described below.

The National Weather Service provides weather, water, and climate data, forecasts and warnings for the protection of life and property and enhancement of the national economy. The National Weather Service owns and operates National Data Buoy Center buoys. The National Centers for Environmental Prediction, which produce the Nearshore Wave Predictive System model, are part of the National Weather Service, as is the Weather Forecast Office, Portland.

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Other Safety Practices

This section describes other safety practices and functions unique to the Columbia River, in addition to those described above.

Lower Columbia Region Harbor Safety Committee

The primary function of the LCRHSC is to assure safe navigation to protect the environment, property and personnel of the Lower Columbia Region waterways. It is made up of an Executive Steering Committee, a Managing Board, Subcommittees, and General membership.

Its membership is intended to be inclusive of all interested representatives of waterway user groups and other members of the public who want to participate. Membership includes representatives from the following specific groups:

• Vessel owners and operators. • Pilots and pilot associations. • Marine exchanges. • Shipping agents. • Stevedores. • Terminal operators. • Shipyards. • Port authorities. • Industry associations. • Organized labor. • Commercial fishing industry associations. • State and local government agencies from both Oregon and Washington including:

o State Marine Board. o Concerned law enforcement agencies. o Washington Department of Ecology. o Oregon Department of Environmental Quality.

• Federal government agency representatives including: o United States Coast Guard. o National Oceanic and Atmospheric Administration. o U. S. Army Corps of Engineers.

• Environmental citizens groups. • Other interested citizens groups. • Waterfront developers. • Recreational waterway users including:

o Power squadrons. o Boaters. o Rowing clubs. o Yacht racing associations.

• Environmental response organizations. • Members of the general public.

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The committee meets every two months in an open forum to adopt or develop standards and guidelines that address environmental and operational elements of maritime operations unique to the Lower Columbia Region (LCRHSC, 2015).

Harbor Safety Committee standards and guidelines are contained in the Lower Columbia Region Harbor Safety Plan. The elements of this plan are developed by subcommittees made up of stakeholders and experts. The plan is cooperatively drafted by regulators and industry representatives. Compliance with the Harbor Safety Plan is voluntary; however, there are strong industry and regulatory controls in operation that collectively ensure compliance. These include the good practices of companies operating on the Columbia River, the role of the Columbia River Bar Pilots and Columbia River Pilots onboard vessels during transits, and the authority of the Coast Guard Captain of the Port to direct vessels comply with the Harbor Safety Plan if needed.

Elements of the plan include:

• Aids to Navigation Guidelines. • Anchorage Guidelines. • Bunkering Guidelines. • Dam Lockage Guidelines. • Incident Management Guidelines. • Lightering4 Guidelines Plan Enforcement. • Required Charts and Publications Guidelines. • Restricted Visibility Guidelines. • Severe Weather and Natural Disaster Guidelines. • Small Vessels and Make Way Rule Guidelines. • Towed Barge Guidelines.

The Towed Barge Guidelines state tag tugs should be used when towing a loaded oil barge astern, when the barge is of more than 25,000-barrel capacity astern (LCRHSP, 2016).

Tag tugs are typically smaller tug boats that are attached to the stern of the oil barge. The tag tug assists with steering the barge, and keeps the barge behind the towing tug. Some of the benefits of tag tugs (e.g., reduced powered grounding and drift grounding frequencies) were quantified and included in the navigation risk model used in this study. The potential for tag tugs, as described above, to reduce collision risks could not evaluated.

The Towed Barge Guidelines were amended in May of 2017 to state that barges carrying oil should not be towed in tandem so that if the tow wire parts, the tug is free to recover the barge.

4 Lightering is the transfer of petroleum cargo in bulk from one tank vessel to another tank vessel while at anchor, or at a dock that is not regulated under the facility response plan and other requirements of 33 CFR 154.

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Under Keel Clearance

The USACE maintains the Columbia River navigational channel at 43 feet below Columbia River Datum.5 All vessels are piloted with a minimum of two feet under keel clearance. Vessels with a freshwater draft of less than 36 feet are generally able to transit the river and bar at any time, weather permitting.

Occasionally, water levels are lower than the Columbia River Datum. When this happens, the River Pilots may reduce the maximum operating draft in the river to ensure that two feet of under keel clearance is maintained throughout the transit. Additionally, the Bar Pilots may adjust vessel transits to make use of available water during tidal windows. Vessels that exceed the minimum draft may be required to either wait outside the bar, or, if already inside, wait at anchor or at the berth.

TransView 32

TransView 32 (TV-32) is custom-made software jointly developed by the Columbia River Pilots, the Columbia River Steamship Operators’ Association, and the U.S. Department of Transportation’s Volpe National Transportation System Center. The vessel agent members of the Columbia River Steamship Operators’ Association continue to contribute a per-vessel assessment to fund ongoing maintenance and operation of the TV-32 system and work collaboratively with the Columbia River Pilots to ensure a safe and effective system for river users. Columbia River Pilots run the software on laptops brought onboard the vessels they pilot.

The function of TV-32 is to display vessel contacts on a graphical user interface. It can be used to calculate the distance between any two points on the display to determine vessel meeting points, closest point of approach, and the estimated time of arrival of any vessel contacts on the display. It continuously imports the most recent sounding data from the USACE and provides an exact replica of the channel’s depths.

TV-32 information is also available to other river stakeholders and operators, including the U.S. Coast Guard, the Merchants Exchange of Portland, Oregon, vessel agents, and terminal operators.

Columbia River Bar Prediction Models

On the bar, under keel clearance changes frequently and is not monitored real-time. The best available information is from the computer-based Dynamic Under-keel Clearance system. It was developed by OMC International in coordination with the Columbia River Bar Pilots. It uses information from several other data sources to estimate under keel clearance on the bar, including:

• LoadMax. • Coastal Data Information Program buoy data. • Tide gauge data.

5 The reference plane for measuring depths on the Columbia River, representing the lowest low-water potential at each point

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• NOAA current and forecast data. • A wave forecast model.

Researchers at Oregon State University developed a wave forecast model, which was validated using OMC data. The model is run once per day and the output is available 25-hours to 48-hours into the 84-hour forecast. This is not frequent enough to support pilot decision making about the safety of crossing the bar, discussed further in the Risk Reduction Measures section.

LoadMax

LoadMax is a program developed for the river and bar pilots that forecasts hourly river levels based on real-time river gauge information, rainfall runoff predictions, and dam and lock operator information (Port of Portland, 2017). LoadMax information is used with TV-32. Based on the estimated arrival and departure times provided by agents and terminal operators, the pilots can predict with relatively high level of accuracy what the river levels will be for the day’s requested transits. This helps them determine if under keel clearances will be met.

Participants discussed how the existing system could be improved: additional tide gauges and running the LoadMax software report twice per day instead of once per day. Seven sensing stations measure tide and current to provide data for the LoadMax water depth predictions. The model is currently run once per day. The pilots use the real-time data from the stations and compare it to the LoadMax predictions to determine if adjustments are needed for the predictions. Additional tide gauges and running LoadMax twice per day would reduce the amount of expert judgment needed to identify when the minimum under keel clearance will be available.

Sea IQ

Sea IQ is a commercially available pilot tool that combines bridge navigation equipment, NOAA charts, Corps of Engineers hydro surveys, and NOAA tide gauges into a single display. Similar to TV-32, Sea IQ is currently used by the Columbia River Bar Pilots.

Coastal Data Information Program Buoys

The Coastal Data Information Program (CDIP) measures, analyzes, archives and disseminates coastal environmental data (Scripps Institution of Oceanography, 2017). The CDIP program deployed two wave buoys (buoys 46243 and 46248) on the Columbia River bar in 2011, in addition to the buoys maintained by the NOAA National Weather Service. The USACE funded one buoy; the second was funded by the Columbia River Bar Pilots and the State of Oregon. An additional buoy was purchased by the Bar Pilots and Oregon; this buoy serves as a spare for rapid deployment if a buoy fails. The USACE funds the ongoing maintenance and repair of the CDIP buoys. These buoys are an important improvement to bar safety because they supply real-time data to Columbia River Bar pilots. Severe weather can cause the buoys to be out of service and also hampers replacement of the buoys.

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Columbia River Bar

In general, the existing safety measures that apply on the Columbia River are also in place on the bar. In addition, a key risk control for all vessels is the decision about whether or not it is safe to cross the bar. Several individuals and organizations play a role in this decision making process. Each vessel master has the ultimate responsibility for the safety of his or her crew, vessel, and cargo. The Columbia River Bar Pilots conduct vessel traffic management, and determine whether it is safe to bring each vessel across the bar, for every transit they conduct. The Columbia River Bar Pilots suspend pilotage and resume pilotage services as needed, based on conditions.

Tools that support the Columbia River Bar Pilots include:

• A fast-response pilot transportation system. • Regular communications with the maritime community, including the U.S. Coast Guard, the

NOAA Weather Forecast Office, the Merchants Exchange of Portland, Oregon, the Columbia River Pilots, and individual vessels.

• The safety culture of the Columbia River Bar Pilots.

The Coast Guard coordinates closely with the Columbia River Bar Pilots and controls the status of the bar. The Coast Guard can issue restrictions on bar crossings, or close the bar to vessel traffic entirely.

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References

American Waterways Operators (AWO). (2013). Responsible Carrier Program.

International Association of Classification Societies. (2017). IACS International Association of Classification Societies: Safer and Cleaner Shipping. IACS explained, Introduction. Website. http://iacs.org.uk/explained/default.aspx. Accessed March 27, 2017.

International Maritime Organization (IMO). (2017). International Maritime Organization: Introduction to IMO. Webpage. http://www.imo.org/en/About/Pages/Default.aspx. Accessed March 13, 2017.

Lower Columbia Region Harbor Safety Committee (LCRHSC). (2015). Lower Columbia Region Harbor Safety Committee Charter. Updated March 11, 2015. http://www.lcrhsc.org/index.cfm?display=pages&pageid=4666&sub=b. Downloaded March 27, 2017.

Lower Columbia Region Harbor Safety Committee (LCRHSC). (2016). Lower Columbia Region Harbor Safety Committee Harbor Safety Plan. http://lcrhsc.org/documents/2016_Updated_HSP_FINAL_July_20_2016.pdf. Downloaded September 13, 2016.

Merchants Exchange of Portland (2017). 2016 Annual Report: Merchants Exchange of Portland, Oregon. https://www.pdxmex.com/media/MEX/AnnualReport/mex-annual-report--2016_web.pdf. Downloaded April 4, 2017.

National Oceanic and Atmospheric Administration (NOAA) (2016). Chart 18521: Columbia River Pacific Ocean to Harrington Point. Ilwaco Harbor. U.S. Department of Commerce. National Oceanic and Atmospheric Administration. National Ocean Service. Coast Survey. https://www.nauticalcharts.noaa.gov/nsd/searchbychart.php?chart=18521. Downloaded March 27, 2017.

Oil Companies International Marine Forum (OCIMF) (2017b). OCMIF Marine Terminal Information System: Terminal Map. Columbia River Area. https://www.ocimf-mtis.org/Microsite/Terminals. Accessed March 23, 2017.

Oil Companies International Marine Forum (OCIMF). (2017a). OCIMF Ship Inspection Report Programme: About SIRE. Website. https://www.ocimf.org/sire/about-sire/. Accessed March 27, 2017.

Oregon Department of Environmental Quality (DEQ) (2017). Department of Environmental Quality, Hazards and Cleanup, Environmental Cleanup: Emergency Response. Website. http://www.oregon.gov/deq/Hazards-and-Cleanup/env-cleanup/Pages/Emergency-Response.aspx. Accessed June 16, 2017.

Scripps Institution of Oceanography (2017). The Coastal Data Information Program: Integrative Oceanography Division. Website. http://cdip.ucsd.edu/. Accessed March 30, 2017.

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U.S. Army Corps of Engineers (USACE). (2017). U.S. Army Corps of Engineers, Portland District. Missions: Navigation. Website. http://www.nwp.usace.army.mil/Missions/Navigation.aspx. Accessed March 27, 2017.

U.S. Coast Guard. (2015a). Documentation and Tonnage of Smaller Commercial Vessels. U.S. Department of Homeland Security. United States Coast Guard. https://www.uscg.mil/hq/msc/tonnage/docs/Brochure_Documentation_and_Tonnage.pdf. Downloaded March 27, 2017.

U.S. Coast Guard. (2015b). Local Notice to Mariners - Special Notice to Mariners 2015, Chapter III: Hazardous Bars. https://www.navcen.uscg.gov/?Do=lnmArchives&path=2015. Downloaded April 3, 2017.

U.S. Coast Guard. (2016). USCG Marine Safety Manual Volume II.

Washington Department of Ecology (Ecology). (2017). Department of Ecology, State of Washington: Spills – Spill Prevention. Website. http://www.ecy.wa.gov/programs/spills/prevention/prevention_section.htm. Accessed March 27, 2017.

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Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix E:

Detailed Description of Risk Methodology

November 2017 Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Table of Contents Page Introduction ..........................................................................................................................3

General Approach ................................................................................................................4

Foundational Information ....................................................................................................5

Scenario Frequency and Consequence .................................................................................6

Frequency ...................................................................................................................7

Consequence ...............................................................................................................7

Risk per Scenario ...............................................................................................................13

Sum Scenario Risks (Aggregate Risk) ...............................................................................14

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Introduction Risk is the combination of the likelihood of an event and the consequence if the event occurs. In this study, the risk evaluated was the risk of a cargo oil1 release from a vessel on the Columbia River. Likelihood was the annual frequency of a cargo oil spill, i.e., how likely it is that a cargo oil spill occurs in a given time period. The consequence for this study was the potential quantity of a cargo oil spill. Three interrelated processes were used to determine cargo oil spill risk:

• Model vessel traffic, environmental factors, vessel failure frequencies, and maritime safety features for the study area.

• Define scenarios that could result in a cargo oil spill, and scenarios to test possible risk reduction measures.

• Using the model, calculate cargo oil spill risks for each scenario. Cargo oil spill risk was calculated for a given scenario by multiplying the frequency of a cargo oil spill with the potential oil spill quantity. In principle, this is simple. For this study, modeling each of the three traffic cases (Case A, B, and C) and each of the modeled risk reduction measures required the calculation of risk for about a million scenarios, with each having a low likelihood. The frequency of every incident for every ship type was calculated for each river mile. Most of the scenarios could not result in a cargo oil spill because vessels with oil cargoes were not part of the scenario. Only about 15% of the scenarios per case could result in a cargo oil spill. Because of the large number of scenarios, the risk picture cannot be understood by reviewing the list of scenarios. The information must be grouped and viewed in a variety of ways to determine the largest risk contributors. The purpose of the risk calculation was to compare traffic cases, and the effects of potential risk reduction measures. Risk was expressed in terms of annual cargo oil spill risk in metric tons. This single number represented the aggregate of a large number of scenarios, each with a very small likelihood of occurring in any given year. The calculated average annual risk was useful for the comparisons described in this study; risk results do not predict the quantity of oil expected to be spilled every year. Readers are cautioned that interpreting the average annual risk as an expected value would misrepresent the methodology used in this study.

1 Oil (as defined by RCW 88.40 and 90.56) transported on vessels as bulk cargo.

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General Approach The flow chart in Figure 1 gives an overview of the risk calculation process. This process was applied to the cases and risk reduction measures evaluated in the study, which were:

• Case A, which included baseline year traffic. The baseline year for the evaluation was October 1, 2015 – September 30, 2016; this was the most recent year of Automatic Identification System data available.

o For vessels that carry cargo oil, Ecology reviewed Vessel Entries and Transits (VEAT) (Ecology, 2017a) analysis to determine the number of transits within the study area and routes traveled.

o For vessels that do not carry cargo oil, the model used processed AIS data for the baseline year, to represent the actual flows of traffic within the study area.

• Case B, the baseline traffic plus all the proposed projects defined in Appendix F, Study Basis, operating at 25% of their proposed maximum number of vessel transits.

• Case C, the baseline traffic, plus all the proposed projects defined in Appendix F, Study Basis, operating at their proposed maximum number of vessel transits.

• Each of the five quantified risk reduction measures.

Figure 1: Risk Calculation Process

Sum Scenario Risks

One number, in metric tons per year

Scenario Frequency and Consequence Calculations

One scenario for each combination of: bar/river mile, vessel type, and spilling incident type

One risk result per scenario

Foundational Information

Marine traffic

Environment (route, fog, rocks, etc)

Vessel systems’ failure frequencies (global fleet)

Current maritime safety measures

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Foundational Information This study used the Marine Accident Risk Calculation System (MARCS), a proprietary DNV GL model, to calculate scenario frequencies and consequences from the foundational information shown above. Appendix G, MARCS Baseline Model Description, and Appendix H, MARCS Model Validation, provide more information about the model. The model was built using proprietary data on failure rates for vessel systems and human actions, and its output has been peer reviewed and validated over several decades of public projects. Appendix F, Study Basis, provides details concerning the model inputs, which include:

• Marine traffic o Vessel traffic data for the most recently available one year period. o Marine traffic cases in the study. o Study area boundaries. o Vessel assumptions for average deadweight tonnage and average speed.

• Environmental parameters o Visibility along the route. o Wind along the route. o Seabed or riverbed type along the route. o Width of the navigable channel.

• Existing risk controls o Port state control. o Aids to navigation. o Pilotage. o Portable pilotage unit. o Areas of cooperative coordination. o Several navigation and position awareness systems. o Under keel clearance management.

Additional existing risk controls were discussed with tribes and stakeholders, but could not be quantified. Risk controls are discussed in the main report and in Appendix D, Marine Safety Risk Controls.

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Unique model (Cases: A/B/C + potential measures)

Scenario Frequency and Consequence Each unique combination of river mile, incident type, and vessel type (Figure 2) was a scenario. For each scenario, the model calculated frequencies and consequences as pairs. There were hundreds of thousands of scenarios for each unique model.

Figure 2: Relationship of Frequency and Consequence Pairs to Modeled Cases

The evaluated cases were the three traffic cases (Case A, B, and C) plus one “case” for each of the potential risk reduction measures that could be quantified. The modeled incident types were collisions, powered groundings, drift groundings, fire/explosion, and structural failure/foundering. The list of vessel types is in Appendix F, Study Basis.

Scenario(frequency and consequence pair)

One river mile(105 in the model)

One incident type(5 types in the model)

One vessel type with unique existing risk

controls (34 in the model)

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Frequency

Figure 3 shows the steps needed to estimate oil spill frequency from transiting vessel cargo spills. The three steps were followed for each scenario. The cargo spill frequency was calculated to be zero for vessels that do not carry oil cargoes.

Figure 3: Steps in the Spill Frequency Calculation for each Scenario

Estimated frequency of critical situations per scenario was the first calculation step toward cargo oil spill risk. Critical situations are potential incidents, which can be caused by an equipment failure on the vessel, a human error on the vessel, or a failure/error on another vessel. The model calculated the location-dependent frequency of critical situations. In this study, the incident types were collision, drift grounding, powered grounding, structural failure, and fire/explosion—any of which may, or may not, result in a release of cargo oil. Incident frequencies related to a wide range of outcomes, from the most minor events without damage to the most severe events with a release of cargo oil. Estimated incident frequency per scenario was the second calculation step toward cargo oil spill risk. Successful intervention to prevent escalation to an incident depends on many conditions, such as available time before grounding and the risk controls in place. Many of the existing marine controls listed in the Study Basis increased the likelihood of a successful intervention.

Consequence

If the vessel involved in a (modeled) incident was laden with oil, then a calculation determined if the incident was severe enough to breach a cargo tank and result in a spill. The average spill quantity was then calculated for that incident and vessel. Key factors in the evaluation of severity were:

• Ship structure. All tank ships, ATBs, and barges are double hulled on the Columbia River. The likelihood of an event leading to an oil spill was reduced compared to single hulled vessels.

1. Critical Situation Frequency

Calculated for each scenario

2. Incident Frequency

Calculated for each scenario

3. Cargo Spill FrequencyCalculated for each scenario involving a

cargo oil vessel

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• Probability of grounding on rocks. Grounding on rocks has a greater probability of causing a spill than grounding on a soft bottom type. Along the Columbia River, the vast majority of shoreline and river bottom is soft/sandy. Specific rocky locations were identified by the Columbia River Pilots, as shown in Appendix F, Study Basis.

• Force impacting a ship. A ship struck by another vessel with high momentum has a greater probability of causing a spill than a ship struck by a vessel with less momentum. This was dependent on the mass and speed of the striking vessel.

Cargo oil spill frequencies were zero for all vessels that do not carry cargo oil. The oil spill frequencies for oil laden vessel scenarios represented the underlying critical situation frequencies, conditional probabilities of successful intervention, and conditional probabilities of cargo tank failure. The potential amount of oil spilled was estimated by applying a percent-spill probability curve to the gross tonnage of the oil laden vessel. Three curves were used: grounding, collision, and fire/structural failure. The grounding and collision curves were developed using a model based on the International Maritime Organization resolution for Marine Environmental Protection (IMO Res. MEPC. 122(2)) for collision and grounding events. A software package called Naval Architecture Package (NAPA) by NAPA Ltd. was used to develop spill probability curves for oil tanker ships. The NAPA software utilized Monte Carlo simulations based on probability distribution functions developed by the IMO. The NAPA curves incorporate the naval architecture of a double-hull design ship. All of the oil cargo vessels coming to U.S. ports are double hulled, which reduces the probability of the cargo tank being punctured when compared to a single hull design. The curves relate a spill probability to a certain percentage of the total cargo capacity. Selection of a representative NAPA curve is based on the overall vessel structure more than on the vessel capacity. The double-hulled oil tank vessels relevant to this study are similar in ship structure, and therefore the relevant NAPA curves are interchangeable for the purposes of this study. Consistent with standard practice in oil spill risk studies, the curve was proportionately scaled to the vessel capacity of each of the laden vessel types. Collision incidents are assumed to be side impact, and grounding incidents are assumed to be bottom impact. Although this is not true for all conceivable possibilities, it is a valid representation of the majority. The simplification may prevent over-estimating spill volumes from groundings. For collision, the calculation assumes hydrostatic balance between the cargo tank and the water level outside the vessel. In contrast, tide is a factor for spill quantities from grounding, as the vessel is assumed to be at a static elevation and the water level changes. Two curves were developed for grounding. The 3 m tide curve was applied from seaward to River Mile 86. The 1 m tide curve was applied from River Mile 86 to 105. Figure 4 and Figure 5 are the NAPA curves for collision and grounding events.

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Figure 4: NAPA Curves for Grounding

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Figure 5: NAPA Curve for Collision

For the fire/explosion and structural failure incidents, simple generic outflow models were used (Figure 6 and Figure 7). This is a reasonable approach for these two types, since the spill quantity from a ship failure is not affected by very many parameters, and has a significant spill quantity based on historical accidents.

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Figure 6: Spill Probability Curve for Fire / Explosion

Figure 7: Spill Probability Curve for Structural Failure

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Specific curves for each laden vessel type, relevant tide, and incident type were used to calculate the average spill quantity for each vessel-incident-tide combination. The resulting output was a single estimated fractional cargo loss for each combination. The quantity was calculated as the fraction multiplied by the deadweight tonnage of the laden vessel. To estimate the quantity of a cargo oil spill for a scenario, the average fraction of cargo spilled was taken from the specific curve for the relevant vessel type and incident type. An example calculation is a powered grounding of a project tanker on a rocky area, River Mile 52. The spill fraction for a powered grounding of a tanker is the weighted average from the relevant curve. At River Mile 52, the 3 m tide curve is relevant. The average spill fraction calculated from the curve is 0.0204, or 2.04% of the cargo onboard. The scenario spill quantity was the cargo capacity 41,108 MT multiplied by 0.0204, and is 839 MT.

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Risk per Scenario Once the frequency and consequence were estimated for each scenario, they were multiplied together to calculate a risk result per scenario. The frequency is in events per year, between about 10-3 (0.001) events per year and 10-14 (0.00000000000001) events per year for each scenario. The consequence is in metric tons (MT) per event. When multiplied, the risk result is in units of MT per year. For the above scenario at River Mile 52, the frequency of the tanker experiencing a powered grounding leading to a cargo spill was calculated to be 0.000055 per year (an average of 5.5 in 100,000 years). The average spill amount for this scenario was 839 MT. Therefore, the cargo oil spill risk was 0.046 tons per year from powered grounding of an in-bound laden tanker at River Mile 52 (839 MT multiplied by the oil spill frequency of 0.000055).

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Sum Scenario Risks (Aggregate Risk) Since there are so many scenarios, the risk from each one represents a small piece of the risk experienced in the study area. The risk for the entire study area is the sum of all of the scenario risks. The study area risk also has units of MT per year. The calculated aggregated average annual risk is useful for the comparisons described in this study; risk results do not predict the quantity of oil expected to be spilled every year. There are limitations on how the aggregated cargo spill risk for the study area can be properly interpreted. It is useful when comparing potential risk reduction measures. One cannot infer any individual event from the sum. It is important to keep in mind that the summed average annual risk is a snapshot in time. Should even one of the cargo spill scenarios occur, actions would be taken immediately affecting all similar operations. It is unlikely that all of the scenarios modeled could occur in today’s risk situation; the occurrence of the first one would trigger proceedings to make the next one much less likely.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

Washington State Department of Ecology F-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix F:

Study Basis

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

Washington State Department of Ecology F-2 Publication No. 17-08-010

Table of Contents Page

Introduction ..........................................................................................................................3

Study Objectives ..................................................................................................................3

Route Input Data ..................................................................................................................5

Vessel Route and Study Area .....................................................................................5

Environmental Data ....................................................................................................7

Vessel Input Data ...............................................................................................................11

Traffic Data ..............................................................................................................11

Vessel Categories .....................................................................................................12

Future Projects and Changes to Background Vessel Traffic Levels ........................14

Risk Controls .....................................................................................................................16

Existing Risk Controls .............................................................................................16

Oil Spill Risk Evaluation ...................................................................................................18

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

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Introduction

This appendix documents the assumptions used in modeling conducted for the Columbia River Vessel Traffic Evaluation and Safety Assessment (CRVTSA). It focuses on aspects of the marine transit route, including the marine traffic itself, and how they were collected, interpreted, and applied in the risk model and analysis.

Study Objectives

Category: Analytical Item no. 1

Relevant Analysis: Navigation Incident Frequency Model

Implication of Assumption: Assumptions fulfilled these objectives:

• Defined spatial boundaries for the model inputs for the marine incident frequency assessment. • Defined the cases to be modeled: the base case, plus two future cases. • Specified the vessel traffic data for input to the model.

The marine traffic incident frequency assessment estimated the frequency of navigational incidents and cargo oil spill risk during transit for traffic from Columbia River Mile 0 to River Mile 105. Columbia River Mile -5 to River Mile 0 were evaluated qualitatively, but incident frequencies and cargo oil spill risks were not modeled, as discussed in the main report. The CRVTSA evaluation used the Marine Accident Risk Calculation System (MARCS) model, developed by DNV GL. MARCS combines three different types of data to estimate incident frequencies:

• Vessel traffic data (e.g. ship types, routes, transit frequencies). • Environmental data (e.g. visibility, wind sea state). • Marine shipping operational data (e.g. pilotage, tugs, etc.). The results included estimated frequencies of the following incident types:

• Collision. • Drift grounding. • Powered grounding. • Striking an object. • Fire / explosion. • Structural failure.

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Three traffic cases were modeled for this study (Table 1). Table 1: Cases Modeled in MARCS

Case A Baseline Year and Traffic Conditions

Case B Future Case

Case C Future Case

Vessel Traffic

Automatic Information System (AIS) data for vessels that do not carry cargo oil, for October 1, 2015 to September 30, 2016.

Ecology Vessel Entries And Transits (VEAT) analysis for vessels that carry cargo oil for October 1, 2015 to September 30, 2016. Data sources for the VEAT includes AIS and information from Ecology’s Advance Notice of Oil Transfer system.

Baseline traffic plus 25% of annual transits from all proposed future projects

Baseline traffic plus 100% of annual transits from all proposed future projects

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Route Input Data

This section describes route-related inputs for the navigation risk assessment.

Vessel Route and Study Area

Category: Data and Operational Item no. 2

Relevant Analysis: Navigation Incident Frequency Model

Implication of Assumption: The routes selected for the study influence the types of navigational hazards and risk control measures modeled for the study vessels.

The route for inbound and outbound vessels travelling along the main channel of the Columbia River is presented in Figure 1. The route was defined utilizing the local nautical charts (Ref. /A/, /B/, /C/, and /D/). The route extended from 5 miles seaward of the Columbia River Bar to the I-5 bridge. The channel width for the route on the river was applied in the model as 800 feet (Ref. /E/). The navigable channel in the model was wider in open areas such as the anchorage areas.

Figure 1: Columbia River Route and Channel

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References A. National Oceanic and Atmospheric Administration (NOAA) (2016). Chart 18521: Columbia

River Pacific Ocean to Harrington Point; Ilwaco Harbor. U.S. Department of Commerce. National Oceanic and Atmospheric Administration. National Ocean Service. Coast Survey. 2016. U.S. Department of Commerce.

B. National Oceanic and Atmospheric Administration. Columbia River – Harrington Point to Crims Island. 18523.

C. National Oceanic and Atmospheric Administration (NOAA) (2016). Chart 18524: Columbia River – Crims Island to Saint Helens. U.S. Department of Commerce. National Oceanic and Atmospheric Administration. National Ocean Service. Coast Survey. 2016.

D. National Oceanic and Atmospheric Administration (NOAA) (2016). Chart 18525: Columbia River –Saint Helens to Vancouver. U.S. Department of Commerce. National Oceanic and Atmospheric Administration. National Ocean Service. Coast Survey. 2016.

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Environmental Data

Category: Data Item no. 3

Relevant Analysis: Navigation Incident Frequency Model

Implication of Assumption: The environmental data was a direct input into the MARCS model and therefore affected the risk results.

This evaluation utilized met-ocean data that includes wind speed, wind direction, visibility, and seabed type for the study area. To ensure high levels of accuracy, this data was gathered for areas in close proximity to the navigable channel. The categories of data were:

• Visibility data. • Wind data. • Seabed data. The wind data input into MARCS were:

• Magnitude. • Corresponding probabilities of occurrence. In the model, wind speed is used as a primary indicator of sea state, which is a simplified approach suitable for river environments. The wind data was divided into four speed categories (0-20, 20-30, 30-45, 45+ knots), as shown in Table 2.1

1 Buoy 46029 was ‘out of service’ for several periods of time included in the coverage period. The weather stations identified as possible replacements/supplements to the data were Buoy 46243 and Clatsop Spit land-based station. However, neither offers available historic wind data.

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Category: Data Item no. 3

Relevant Analysis: Navigation Incident Frequency Model

Table 2: Wind Speeds Applied in MARCS (Percentage of occurrence) (Ref. /A/,/B/,/C/,/D/,/E/,/F/,/G/)2

Weather Station 0-20 knots 20-30 knots 30-45 knots >45 knots

Buoy 46029 0.871 0.116 0.013 -

Buoy 46243 (not used in the study)

0.878 0.110 0.012 -

Astoria Airport 0.982 0.017 0.001 << 0.001

Astoria 0.994 0.006 < 0.001 -

Kelso/Longview Airport 0.999 0.001 - -

Longview 0.998 0.002 - << 0.001

Pearson Field Airport 0.999 0.001 - -

Portland 0.990 0.001 < 0.001 -

Good visibility was defined as greater than two nautical miles; poor visibility was less than two nautical miles. The probability of occurrence for good and poor visibility used in the model is presented Table 3. Table 3: Visibility Data Applied in MARCS (Percentage of occurrence) (Ref. /B/,/D/,/F/,/G/)

Weather Station Good (>2 nm) Poor (<2 nm)

Astoria Airport 0.87 0.13

Kelso/Longview Airport 0.98 0.02

Pearson Field Airport 0.93 0.07

Portland 0.94 0.06

In the model, the seabed bottom type determines the probability of a cargo tank breach in the event of vessel grounding.

2 When wind data is gathered, the recorded value is the average over a measuring period determined by the provider. For example, if a data point is recorded every 2 minutes, the average wind speed over the 2 minutes would be in the data. If a gust of wind exceeded 45 knots, it would have been included in the weighted wind speed average.

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Category: Data Item no. 3

Relevant Analysis: Navigation Incident Frequency Model

Table 4: Locations of Rocky Bottom Type3 (relevant to grounding consequences) (Ref. /H/)

River Mile begin

River Mile end

Side of the Channel Notes

27.25 +20 ft Washington Pillar Rock

30.5 33 Washington Skamokawa

39 40.5 Oregon Bugby Hole

52 54.5 Washington Abernathy

55 56.5 Washington Bunker Hill

72 73 Oregon Coffin Rock

74 75.5 Washington Kalama

78 79 Washington Kalama

83.5 84 Oregon Columbia City

87.25 88 Oregon Warrior Rock

3 All other areas were assumed to be soft bottom, not able to penetrate the double hull of a tanker or barge at normal sailing speed.

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Category: Data Item no. 3

Relevant Analysis: Navigation Incident Frequency Model

References A. NOAA Buoy Station: 46029. 01/01/2006 - 12/31/2015. B. NOAA Weather Station: Astoria Airport - USAF 727910. 01/01/2006 - 12/31/2015. C. NOAA Weather Station: Astoria - USAF 994011. 01/01/2006 - 12/31/2015. D. NOAA Weather Station: Kelso/Longview Airport - USAF 727924. 01/01/2006 - 12/30/2015. E. NOAA Weather Station: Longview - USAF 997801. 01/01/2007 - 12/31/2015. F. NOAA Weather Station: Pearson Field Airport - USAF 727918. 01/01/2006 - 12/01/2015. G. NOAA Weather Station: Portland - USAF 726980. 01/01/2006 - 12/31/2015. H. Meeting Minutes. CRVTSA and Columbia River Pilots, Oct. 5, 2016.

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Vessel Input Data

This section describes vessel-related inputs for the navigation risk assessment.

Traffic Data

For vessels that do not carry cargo oil, input to the MARCS model was processed Automatic Identification System (AIS) data for the for the most recently available one-year period (baseline year) for the study area. The baseline year for the evaluation was October 1, 2015 – September 30, 2016 (Ref. /A/). The AIS data defined vessel traffic patterns, traffic densities, and vessel speeds. For vessels that carry cargo oil, Ecology reviewed Vessel Entries and Transits (VEAT) analysis for the baseline year to determine the number of transits within the study area and routes traveled. Data sources for the VEAT include AIS and information from Ecology’s Advance Notice of Oil Transfer system (Ref. /B/ and /C/).

Category: Data Item no. 4

Relevant Analysis: Navigation Incident Frequency Model

Implication of Assumption: Vessel traffic data (ship types, routes, transit frequencies) was a direct input into the MARCS model, and therefore affects the risk results.

References A. Merchants Exchange of Portland, Oregon (2016). Columbia River and Columbia River Bar

area: Automatic Information System data for the period October 1, 2015 – September 30, 2016. B. Department of Ecology (2017a). Vessel Entries and Transits (VEAT) Counts for Washington

Waters by Calendar Year. Data downloaded for 2015 and 2016 on May 31, 2017. http://www.ecy.wa.gov/programs/spills/publications/publications.htm.

C. Department of Ecology (2017b). Advance Notice of Oil Transfer. http://www.ecy.wa.gov/programs/spills/prevention/antsystem.html.

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Vessel Categories

Category: Data Item no. 5

Relevant Analysis: Navigation Incident Frequency Model

Implication of Assumption: The MARCS model provides results per vessel category, affecting how results can be interpreted.

The vessel types defined how traffic descriptors were grouped. Each type of vessel was assigned voyages per river mile, an average speed, and size in Deadweight Tonnage (DWT). Table 5 lists the sum of all the transits for the 105 river miles per vessel type. Vessel transit information was determined through a review of VEAT analysis for vessels that carry cargo oil, and calculated using processed AIS information for vessels that do not carry cargo oil. Table 5: Vessel River Miles per Vessel Type (River Mile 0 to 105)

Vessel type (Vessels with oil cargoes are in bold text)

Vessel Transit Count – Summed for all

River Miles

ATB Laden Inbound 10,973

ATB Laden Outbound 20

ATB Unladen Inbound 116

ATB Unladen Outbound 11,069

Oil Tanker Laden Inbound 2,714

Oil Tanker Laden Outbound 204

Tug Oil-barge-in-tow Laden Inbound 5,405

Tug Oil-barge-in-tow Laden Outbound 2,450

Oil Tanker Unladen and Non-oil Tanker Inbound 3,705

Oil Tanker Unladen and Non-oil Tanker Outbound 6,320

Coastal Tug Inbound (under Coastwise Articles) 114,385

Coastal Tug Outbound (under Coastwise Articles) 117,382

Foreign Tug Inbound 1,606

Foreign Tug Outbound 1,606

Future Project – Barge Inbound 2,520

Future Project – Barge Outbound 2,520

Future Project – Bulker or Non-oil Tanker Inbound 63,120

Future Project – Bulker or Non-oil Tanker Outbound 63,120

Future Project – Oil Tanker Unladen Inbound 38,325

Future Project – Oil Tanker Laden Outbound 38,325

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

Washington State Department of Ecology F-13 Publication No. 17-08-010

Table 6 lists the average estimated speed and average DWT for each tank vessel type. Except where noted, Ecology determined DWT numbers for the evaluation based on a review of VEAT analysis for the baseline year.

Table 6: Deadweight Tonnage and Speed for Each Vessel Type

Vessel Type (Vessels with oil cargoes are in bold text)

DWT (metric tons)

Speed (knots) (Ref. /A/)

ATB Laden 24,756 8

ATB Unladen 12,378 8

Tug Oil-barge-in-tow (laden and unladen) 8,061 8

Cargo Carrier 42,123 12

Commercial Fishing Vessel 1,744 (Ref. /A/) 9

Other Fishing Vessel 100 9

Other Vessel 100 9

Cruise Ship 8,800 10

Passenger Vessel 100 10

Pleasure Craft 100 9

Service Vessel 1,600 15

Oil Tanker Laden 41,108 12

Oil Tanker Unladen and Non-oil Tanker 37,854 12

Coastal Tug (under coastwise articles) 536 (Ref. /A/) 8

Foreign Tug (under foreign articles) 756 8

Undefined Vessel 100 9

Future Project – Barge 8,061 8

Future Project – Oil Tanker Unladen 20,554 12

Future Project – Oil Tanker Laden 41,108 12

Future Project – Bulker or Non-oil Tanker 44,894 12

References A. Merchants Exchange of Portland, Oregon (2015).

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

Washington State Department of Ecology F-14 Publication No. 17-08-010

Future Projects and Changes to Background Vessel Traffic Levels

It was recognized that certain types of marine traffic on the bar and river have documented decreasing trends, and others, increasing trends; however, there has not been a specific economic study to support future assumptions either way. As described in the main report, this study opts to assume that the baseline traffic remains steady into the future, with only additional proposed projects changing the traffic. The number of vessels/transits from the proposed projects in Table 7 were added to Cases B (25% of the proposed maximum number of laden and unladen vessel transits) and C (100% of the proposed maximum number of laden and unladen vessel transits). All future project vessels were modeled as fully laden in one direction, and in ballast, without cargo, in the other direction. The evaluation did not make assumptions about how marine bunkering (e.g., providing fuel and other refined products to a vessel at a berth) might change in the future. No additional bunkering transits were added to Case B or Case C. Table 7: Future Projects Included in the MARCS Model

Project Location Cargo Proposed Loaded Transits per Year

Millennium Bulk Terminal Longview, WA Coal 840 (Ref. /A/)

Tesoro Savage JV, Vancouver Energy Project

Vancouver, WA Oil export 365

(Ref. /B/)

Northwest Innovation Works LLC Port of Kalama-Cowlitz County, WA

Methanol 72

(Ref. /C/)

Northwest Innovation Works LLC Port Westward in Clatskanie, OR

Methanol 72

(Ref. /C/)

Columbia River Carbonates Woodland Marine Terminal

Woodland, WA Calcium carbonate

30 (Ref. /D/)

Category: Operational Item no. 6

Relevant Analysis: Navigation Incident Frequency Model

Implication of Assumption: This assumption defines the baseline and future marine traffic input into the model, which was delineated per ship type. The input includes number of transits, oil cargoes, and DWT. The assumptions about changes in traffic levels directly affected the incident frequency estimates and spill risk estimates.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

Washington State Department of Ecology F-15 Publication No. 17-08-010

References A. Cowlitz County (2016). Millenium Bulk Terminals‒Longview: SEPA Environmental Impact

Statement. SEPA Vessel Transportation Technical Report. Prepared for Cowlitz County in cooperation with Washington State Department of Ecology, Southwest Region. Prepared by ICF International, Rodino, Inc., and DNV GL. April 2016. Tesoro Savage DEIS. http://www.efsec.wa.gov/Tesoro%20Savage/SEPA%20-%20DEIS/DEIS%20Chapters/DEIS%20Ch%205%20Cumulative%20Impacts.pdf. Accessed May 2, 2016.

B. Energy Facility Site Evaluation Council (2016). Tesoro Savage Vancouver Energy Project. Application No. 2013-01. http://www.efsec.wa.gov/Tesoro%20Savage/SEPA%20-%20DEIS/DEIS%20PAGE.shtml. Accessed January 27, 2017.

C. Cowlitz County and Port of Kalama (2016). Kalama Manufacturing & Marine Export Facility: SEPA Final Environmental Impact Statement. September 2016. http://nwinnovationworks.com/projects/port-of-kalama. Accessed October 11, 2016.

D. Vancouver Hearing Examiner (2015). Findings, Conclusions, and Decision. Appeal of NuStar Terminal Services, Inc. of an April 3, 2015 Determination of Significance and Request for Comments on Scope of Environmental Impact Statement. October 3, 2015. No. PRJ-145874/LUP-40862.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

Washington State Department of Ecology F-16 Publication No. 17-08-010

Risk Controls

This section describes risk control inputs for the navigation risk assessment.

Existing Risk Controls

Category: Operational Item no. 7

Relevant Analysis: Navigation Incident Frequency Model

Implication of Assumption: Existing risk controls were accounted for in the MARCS modeling process to provide a more accurate value for the frequency of incidents.

The explanation of risk controls should include all relevant information including the nature of measure (e.g. preventative, response, regulatory). Potential risk reduction measures are discussed separately in the main report.

Areas of Cooperative Coordination In select areas along the navigation route, pilots practice cooperative coordination between vessels. As a safety practice, pilots avoid overtaking other deep draft vessels in these areas. These Areas of Cooperative Coordination are listed in Table 8. Because this is a widely-used practice of collision avoidance, a 90% reduction in the number of vessel encounters was applied in the MARCS model in these areas.

Table 8: Cooperative Coordination Areas Defined in MARCS Model (Ref. /A/)

Area Description River Mile Range Practice

Miller Sands 22-23 No overtaking or meeting

Brookfield 28-29 No overtaking or meeting

Skamokawa 30.5-33 No overtaking or meeting

Abernathy 35-37 No overtaking or meeting

Bugby Hole 39-40.5 No overtaking or meeting

Bunker Hill 55-57 No overtaking or meeting

Near Coffin Rock 72.5-73.5 No overtaking or meeting 50% of the time

Duck Club 88.5-90.5 No overtaking or meeting 50% of the time

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Washington State Department of Ecology F-17 Publication No. 17-08-010

Table 9 lists the existing risk controls incorporated into the MARCS model. Table 9: Risk Controls Applied in Cases A, B, and C

Vessels

TV

-32

Pilo

t

Po

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le P

ilo

tag

e

Un

it

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al

Po

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av

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on

Ele

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on

ic C

hart

Dis

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y a

nd

Info

rmati

on

Sy

ste

m

Po

rt S

tate

Co

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ol

Un

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Ke

el

Cle

ara

nce

Man

ag

em

en

t

Part

ially R

ed

un

dan

t

Pro

pu

lsio

n a

nd

Ste

era

ge

*

ATB Unladen - - - X X X X X X

ATB Laden X X X X X X X X X

Fishing, Passenger (non-cruise), Pleasure, Other, Service, Undefined

- - - - X - - - -

Tanker, Carrier, Tug (foreign articles), Cruise

X X X X X X X X -

Coastal Tug - - - X X X X X -

Tug Oil-barge-in-tow - - - X X X - X X

* Two engines and two rudders, where the propulsion systems and steering systems are not independent from each other. A single failure could result in a loss of propulsion and/or steering.

Transview 32 and SeaIQ Two specific tools used by Columbia River and Bar captains and pilots are Transview 32 (TV-32) and SeaIQ. These specific tools have not been quantified as risk reduction measures; however, Portable Pilotage Units (PPUs) have been quantified, and are very similar. For this study, they were considered PPUs, which are a form of Vessel Traffic Information System (VTIS). In a VTIS, vessel location, course, and speed data is made available directly to vessels operating in the area. This is viewed by marine pilots as a significant benefit. Navigation decisions on the river are agreed upon between the pilots using TV-32 and SeaIQ. Additional risk controls are in use, but are not quantifiable in the model at this time. These are discussed in Appendix D, Marine Safety Risk Controls.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix F

Washington State Department of Ecology F-18 Publication No. 17-08-010

Oil Spill Risk Evaluation

Category: Data Item no. 8

Relevant Analysis: Navigation Model Oil Spill Volume

Implication of Assumption: The oil spill analysis estimated the risk of an oil spill in metric tons (MT) per year.

MARCS has the capability to estimate the oil spill risk for each vessel category. The oil spill risk results were provided in terms of MT of cargo oil spilled per year during transit (not including cargo transfer operations). The potential quantity of oil spilled per year from all vessel types was based on the incident frequencies (spill events per year) and estimated spilled oil quantities (in MT). MARCS utilizes curves of the frequency and amount of oil estimated to be spilled based on DNV GL’s finite element analysis. The curves were derived from the finite element analysis of an oil tanker that was then adjusted based on average size of the vessel category in MARCS. A description of the method used to estimate spill volumes is in Appendix E, Description of Risk Methodology.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix G

Washington State Department of Ecology G-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix G:

MARCS Baseline Model Description

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech disability may call TTY at 877-833-6341.

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Table of Contents Page

Figures..................................................................................................................................2

Introduction ..........................................................................................................................3

Model Overview ..................................................................................................................4

Input Data ...................................................................................................................4

Fault Tree Analysis ....................................................................................................5

Data used by MARCS ..........................................................................................................6

Traffic Image Data .....................................................................................................6

Internal Operational Data ...........................................................................................7

Environmental Data ....................................................................................................7

Accident Types ....................................................................................................................9

The Collision Model ...................................................................................................9

The Powered Grounding Model ...............................................................................10

The Drift Grounding Model .....................................................................................11

The Structural Failure Model ...................................................................................12

The Fire and Explosion Model .................................................................................13

References ..........................................................................................................................14

Figures

Page

Figure 1: Block Diagram of MARCS Incident Frequency Model .......................................4

Figure 2: Graphical Representation of the Collision Model ................................................9

Figure 3: Graphical Representation of the Powered Grounding Model ............................10

Figure 4: Graphical Representation of the Drift Grounding Model ..................................11

Figure 5: Graphical Representation of the Self-Repair Save Mechanism .........................12

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix G

Washington State Department of Ecology G-3 Publication No. 17-08-010

Introduction

This appendix describes background information and the design of the Marine Accident Risk Calculation System (MARCS) model used to estimate cargo oil spill risk in the Columbia River Vessel Traffic Evaluation and Safety Assessment (CRVTSA).

Transportation by sea using conventional shipping operations results in both economic benefits and associated risks, which can result in safety and environmental impacts. Analysis of historical ship incident data indicates that almost all open-water shipping losses (except for intentional events, such as war or piracy) can be categorized into the following generic incident types:

• Ship-to-ship collision. • Powered grounding (groundings which occur when the ship has the ability to navigate safely

yet goes aground). • Drift grounding (groundings which occur when the ship is unable to navigate safely due to

mechanical failure). • Structural failure / foundering. • Fire / explosion. • Allision (a ship striking a fixed object).

These generic incident types are applicable for most marine transportation systems.

A marine transport incident frequency assessment can be performed by assessing the frequency of the above incident types in a defined study area. DNV GL developed the MARCS model to perform such marine transport risk analyses in a structured manner. The results of the analysis can be used to determine if the estimated incident frequencies are acceptable or if risk reduction measures are justified or required.

Two versions of MARCS were developed to address different traffic systems. The version of MARCS used for this study was designed for river systems. As with all risk-predictive models, MARCS is necessarily conservative; that is, when inputs of calculations are uncertain, the goal is to have any resulting error result in a greater estimate than reality should bear out.

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Model Overview

The MARCS incident frequency model provides an estimate of the frequency of incidents that may occur on a river system. A block diagram of the model is shown in Figure 1.

Figure 1: Block Diagram of MARCS Incident Frequency Model

Input Data

The MARCS model classifies data into four main types:

• Shipping lane data describes the movements of different vessel types within the study area. • Environmental data describes the conditions within the study area, including the location of

geographical features (land, structures, etc.) and meteorological data (visibility, wind, water currents, and sea state).

• Internal operational data describes operational procedures and equipment installed onboard ships – such data can affect both incident frequency and incident consequence factors.

• External operational data describes factors external to the ship that can affect ship safety, such as Vessel Traffic Services, Traffic Separation Schemes, any navigation or collision avoidance aids that are commonly used but are not part of the ship’s onboard systems, and the location and performance of emergency tugs – such data can affect both incident frequency and incident consequence factors.

The four types of data are discussed in separate sections, below.

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Fault Tree Analysis

To calculate the incident frequency, MARCS first identifies what are called critical situations. The definition of a critical situation varies with the incident type; see the discussion about incident types below.

It calculates a location-dependent frequency for critical situations. The frequency is defined in terms of the number of situations which could result in an incident at a location per year. These situations could be called potential incidents.

MARCS uses Fault Trees, a common risk assessment methodology to identify causal factors of incidents. A fault tree is a visual logical model that is used to describe how a specific unwanted event in a system may be caused by the effects of a single failure or a combination of failures e.g., Henley et. al. (1981) and Cooke (1995). The specific unwanted event is known as the “top event.” The analysis considers the ways in which this top event can occur and, with the inclusion of the correct data, can calculate with what frequency or probability that event will occur. Fault Tree Analysis is particularly suited to the analysis of complex systems which may have a number of subsystems.

Fault Tree Analysis involves breaking down an accident into its component causes, including human error, and estimating the frequency of each component from a combination of generic historical data and informed judgment. Utilizing a deductive technique, it focuses on one particular incident or primary system failure as a top event. Then working backwards, it identifies combinations of equipment failures and human errors that can lead to the top event.

Fault trees are used when other types of hazard identification or analysis have identified a potential incident or system failure scenario that requires a more detailed analysis. Fault Tree Analysis is used in MARCS to quantify the probabilities of an incident or primary system failure occurring.

Fault Tree Analysis identifies risk reduction measures focused on causes with the highest probabilities of occurrence. The advantages of this type of analysis include:

• It ensures a thorough understanding of the system operation and the relationship between various functional elements.

• It provides a graphical representation of the combination of events that could cause the top event to occur.

• It can be used qualitatively to indicate combinations of events or single events that need to occur for the top event to occur. Additionally, by quantification of the single events, the frequency or probability of the top event can be calculated. Sensitivity studies can then be completed to determine which events make the largest contribution to the top event.

• It can identify the combinations of basic equipment failures and human errors that can lead to an accident. This allows focus to be placed on the significant basic causes of the accident for identification of preventive or mitigative measures to reduce the likelihood of the event.

• It allows the identification of common-mode or common-cause failures that may not be apparent when considering subsystems in isolation.

• It is often used when other hazard evaluation procedures have identified an accident of interest that requires more detailed analysis.

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Fault tree models have been constructed to assess many of the parameters within MARCS, including collision probabilities per encounter (collision model) and failure probabilities to avoid a powered grounding given a critical situation (powered grounding model) (European Commission, 1998 and 1999). The analysis specifies an undesired state, and the system is then analyzed in the context of its environment and operation to find all credible ways in which the undesired event can occur.

The fault trees developed for MARCS are proprietary to DNV GL. Therefore, model validation is an important aspect underpinning the credibility of the model, and is presented in Appendix H, MARCS Model Validation.

Data used by MARCS

Traffic Image Data

Oil cargo vessel traffic and background vessel traffic were key inputs into the model. For vessels that carry cargo oil, Ecology reviewed Vessel Entries and Transits (VEAT) analysis for the baseline year (October 1, 2015 – September 30, 2016) to determine the number of transits within the study area and routes traveled. Data sources for the VEAT include Automatic Identification System (AIS) data and information from Ecology’s Advance Notice of Oil Transfer system (Ecology 2017a, Ecology 2017b).

For background traffic consisting of vessels that do not carry cargo oil, processed Automatic Identification System (AIS) data for the baseline year was input into the MARCS model (Merchants Exchange of Portland, 2016).

AIS data for a full calendar year was plotted geospatially in a geographic information system as individual points for each AIS ping, or entry. Each AIS entry had a location and timestamp for each individual vessel. From the plotted entries, the traffic patterns were identified. Each vessel’s entries were linked using the location and time stamps to create tracks for each vessel transit. The tracks revealed the general traffic patterns and routes in the study area.

The vessel tracks were consolidated into primary traffic routes and crossing traffic routes. The narrowness of a river hinders the representation of tracks of individual ships; therefore, MARCS characterizes shipping lanes as lines. The number of times each vessel type traveled along the defined main traffic route on the river was input into the model.

A vessel track was included in the count for a given route when its track was at a 0° to 27˚ angle to the main traffic route. Additionally, when vessel track crossed or merged into the main channel (i.e. a ferry crossing the channel), these vessel tracks exceeded 27˚, and were counted in the “crossing routes.” This method allowed for the large of AIS dataset to be accurately and efficiently represented in the MARCS model.

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To input the information into the MARCS model, the following items are defined for all lanes:

• The lane number (a unique identifier used as a label for the lane). • The lane directionality (one-way or two-way). • The annual frequency of ship movements along the lane. • A list of waypoints. • The vessel size distribution on the lane.

Additional data may be attached to the lane, such as: the hull type distribution (single hull, double hull, etc.) for tankers; the loading type (full loading, hydrostatic loading) for tankers; ship type, etc.

The marine traffic description used by MARCS is completed by the definition of additional parameters for each type of traffic:

• Types of vessels. • Average vessel speed (generally 8 to 18 knots) per type of vessel. • Location-specific speed (where the ships are known to slow down or go faster). • Risk reducing measures or restrictions that apply per vessel type.

Internal Operational Data

Internal operational data is how the MARCS model accounts for the capabilities of a crew to prevent or reduce the consequences of an accident. It is represented within MARCS using either worldwide data, frequency factors obtained from fault tree analysis, or location-specific survey data. Fault tree parameters take into consideration factors such as crew watchkeeping competence and internal vigilance (where a second crew member, or a monitoring device, checks that the navigating officer is not incapacitated). Examples of internal operational data include:

• The probability of a collision given an encounter. • The probability of a powered grounding given a ship’s course close to the shoreline. • The frequency (per hour at risk) of fires or explosions. Internal operational data may be defined for different vessel types type on a location-specific basis.

Environmental Data

The environmental data describes meteorological conditions (visibility, wind, sea currents, and sea state). Poor visibility is defined as restriction of visibility by fog, snow, rain, or other phenomena to less than 2 nautical miles. It should be noted that night-time is categorized as good visibility unless fog is present.

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Wind data is divided into four wind speed categories: calm (0 to 20 knots, Beaufort 0 to 4); fresh (20 to 30 knots, Beaufort 5 to 6); gale (30 to 45 knots, Beaufort 7 to 9); and storm (greater than 45 knots, Beaufort 10 to 12). Sea state (wave height) within MARCS is inferred from the wind speed and the nature of the sea area (classified as sheltered, semi-sheltered or open water).

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Accident Types

This section describes how input data (traffic image, internal operational data, external operational data, and environment data) is used to calculate the frequency of incidents in the study area. It is organized by accident type, as they are independently calculated in the model.

The Collision Model

The collision model calculates the frequency of powered collisions at a given geographical location in two stages. The model first estimates the frequency of encounters (critical situations for collision – when two vessels pass within 0.5 nautical miles of each other) assuming no collision-avoiding actions are taken. This enables the calculation of either total encounter frequencies, or encounter frequencies involving specific vessel types. Second, the model applies a probability of a collision for each encounter, obtained from fault tree analysis, to give the collision frequency. The collision probability value depends on several factors including, for example, visibility or the presence of a Pilot. Figure 2 shows a graphical representation of the collision model.

Figure 2: Graphical Representation of the Collision Model

In Figure 2, d1 is the density of traffic associated with Lane 1 (Ship 1 direction) at the location (x, y). The frequency of encounters at location (x, y) is proportional to the product of d1, d2, and the relative velocity of ships in each lane.

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The Powered Grounding Model

The powered grounding model estimates the frequency of powered grounding incidents by calculating the frequency of critical situations, as illustrated in Figure 3. Critical situations arise when a course change point (waypoint) is located such that failure to make the course change would result in grounding within 20 minutes’ navigation from the planned course change point if the course change is not made successfully. The frequency of powered groundings is calculated as the frequency of critical situations multiplied by the probability of failure to avoid grounding.

Figure 3: Graphical Representation of the Powered Grounding Model

The powered grounding probabilities are derived from the fault tree analysis of powered grounding because of failure to make a course change while on a dangerous course. A dangerous course is defined as one that would ground the vessel within 20 minutes if a course change were not made. The powered grounding frequency model considers internal and external attentiveness, visibility, and the presence of mitigation measures (e.g., radar) in deducing failure parameters.

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The Drift Grounding Model

The drift grounding frequency model is illustrated in Figure 4.

Figure 4: Graphical Representation of the Drift Grounding Model

The drift grounding frequency model consists of two main elements. First, the ship traffic image is combined with a ship breakdown frequency factor to generate the location and frequency of vessel breakdowns. Second, the recovery of control of a drifting ship can be regained by one of two mechanisms: repair and emergency tow vessel assistance. A drifting ship that is not saved by one of these mechanisms (and does not drift out into the open sea) contributes to the drift grounding incident frequency results. The number and size distribution of the ships which start to drift is determined from the ship breakdown frequency, the annual number of transits along the lane, and the size distribution of vessels using the lane. The proportion of drifting vessels that are saved (fail to ground) is determined from the vessel recovery models. Implicit in Figure 4 is the importance of the time taken for a ship to drift aground. When this time is lengthy (because the distance to the shore is large and / or because the drift velocity is small), then the probability that the ship will recover control before grounding (via repair or tug assistance) is greater.

Repair Recovery Model Vessels that start to drift may recover control by effecting repairs. Figure 5 shows the model inputs regarding recovery from repair of a vessel. Data were derived under the SAFECO project by structured expert judgment principles (European Commission, 1998 and 1999). For a given vessel breakdown location, grounding location, and drift speed, there is a characteristic drift time to the grounding point. The proportion of drifting vessels that have recovered control by self-repair is estimated from this characteristic drift time and the distribution of repair times.

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Figure 5: Graphical Representation of the Self-Repair Save Mechanism

Recovery of Control by Emergency Tow Drifting vessels may be brought under control (saved from grounding) by being taken in tow by an appropriate tug. It should be noted that the tug save model assumes a save is made when the ship is prevented from drifting further towards the shoreline by the attachment of a suitable tug. The tug model contains parameters to take explicit account of:

• The availability of a tug (some tugs have other duties). • The performance of a tug (identified as the maximum control tonnage for the tug) as a

function of wind speed and location (since the wind speed and the fetch control sea state).

The Structural Failure Model

The structural failure / foundering incident frequency model applies incident frequency parameters derived from incident data or fault tree analysis with calculations of the ship exposure time to obtain the incident frequency. The structural failure / foundering parameters consider the structural strength of some hull designs, such as double-hulled vessels. The total ship exposure time (number of vessel hours) in any area for a given wind speed category (used by MARCS to infer the sea state) can be calculated from the traffic image parameters (locations of lanes, frequencies of movements and vessel speeds) and the local wind speed parameters. The structural failure / foundering frequency is then obtained by multiplying these vessel exposure times by the appropriate structural failure frequency factor for the wind speed (sea state) category.

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

0 5 10 15 20 25 30

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ir P

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Repair Time (Hours)

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The Fire and Explosion Model

The fire / explosion incident frequency model applies the incident frequency parameters derived from incident data or fault tree analysis with calculations of the ship exposure time to obtain the incident frequency. The total ship exposure time (number of vessel hours) in any area can be calculated from the traffic image parameters (locations of lanes, frequencies of movements and vessel speeds). The fire / explosion incident frequency is then obtained by multiplying these vessel exposure times by the appropriate fire / explosion frequency factor (incidents per vessel-hour). It should be noted that fire / explosion frequency factors are assumed to be independent of environmental conditions outside the vessel.

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References

Cooke, R.M. (1995). Methods and Code for Uncertainty Analysis, UNICORN, AE Technology. TUDelft.

Department of Ecology (2017a). Vessel Entries and Transits (VEAT) Counts for Washington Waters by Calendar Year. Data downloaded for 2015 and 2016 on May 31, 2017. http://www.ecy.wa.gov/programs/spills/publications/publications.htm.

Department of Ecology (2017b). Advance Notice of Oil Transfer. http://www.ecy.wa.gov/programs/spills/prevention/antsystem.html.

European Commission (1998). Safety of Shipping in Coastal Waters (SAFECO I) Summary Report, DNV 98-2038, 1998.

European Commission (1999). Safety of Shipping in Coastal Waters (SAFECO II) Summary Report. Transport Research Fourth Framework Programme Waterborne Transport. DNV 99-2032, 1999.

Henley E. J. and H. Kumamoto (1981). Reliability Engineering and Risk Assessment, Prentice-Hall Inc.

Merchants Exchange of Portland, Oregon (2016). Columbia River and Columbia River Bar area: Automatic Information System data for the period October 1, 2015 – September 30, 2016.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix H

Washington State Department of Ecology H-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix H:

MARCS Model Validation

November 2017 Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Washington State Department of Ecology H-2 Publication No. 17-08-010

Table of Contents Page Introduction ..........................................................................................................................3

Comparison with Historical Accident Statistics ..................................................................3

Categorization of Accidents .......................................................................................4

Accuracy and Completeness of Reported Data ..........................................................4

Statistical Significance of Historical Accident Data ..................................................4

Justification of Use of Worldwide Data as the Basis for MARCS ......................................4

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Washington State Department of Ecology H-3 Publication No. 17-08-010

Introduction

This appendix describes the validation of the Marine Accident Risk Calculation System (MARCS) model. With MARCS, as with any model, it is always relevant to ask the question: Why do we believe the results of the model that are presented? Showing that a risk model is validated and that its results are verified is not a straightforward process. Like other computer models, risk models may reference hundreds or thousands of parameters and probably have thousands of lines of computer code. It is not practical, efficient or even desirable to validate such a model by manually checking input parameters or lines of code. DNV GL’s response to this legitimate question is described here. When the models are first written and after any significant modifications, they are subject to manual checking. This includes inspecting the outputs from simple systems against analytical solutions (where possible) or against back-of-the-envelope estimates. Discrepancies are understood and either eliminated or documented. Models which have been used regularly over a longer period gain additional credibility and hence validation, which is the case for MARCS. MARCS was first developed in the early 1990s. It has been used extensively since then in several countries by many different types of projects. As part of two different projects in the U.S. in 1996 and 2010, the methods and results of MARCS were subjected to third-party academic peer review by the National Academy of Sciences. MARCS, like many risk models, generates aggregate risk numbers (e.g., numerical results representing an entire study area) and distributed risk numbers (e.g., numerical results for different operations within a study area). For this evaluation, a set of risk results is generated for each river mile segment, and the result for the entire study area is the sum of each of the river mile segments. Analysts perform check-sums to verify that numbers derived by different parts of the calculation tool that should agree do, in fact, agree. Finally, it is DNV GL’s view that the main benefit of a risk model is gained from comparing the results of a base case with the results of separate cases with varying parameters. This promotes understanding of the key risk drivers and allows the identification of an optimized set of risk reduction options. The risk results of individual cases may be secondary to the value gained from case comparisons.

Comparison with Historical Accident Statistics

The review and comparison of historical accident statistics with model results is an important task. Local casualty data provides an indication of the safety performance of the assessed system in the recent past with the currently applied controls. They also suggest the types of accidents that may be more likely to occur. Regional or worldwide statistics provide a more statistically significant indication of average safety performance of the sector under study (ship transportation in this case). Comparison of location-specific statistics with risk results calculated by MARCS can also provide assurance (or validation) that the risk model (data and methods applied) is reasonable. However, there are many challenges with this comparison, as noted in this section, so weak

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agreement is often observed. This does not discredit the value of the risk model results for the reasons discussed below. Usually the accident frequency (spilling and non-spilling accidents per year) is the most appropriate model output to compare to historical accident data. This is because near miss data is not well reported and spilling accidents are relatively rare events (not statistically representative).

Categorization of Accidents

Different data sources are maintained for different reasons. This is the reason the data recorded in different sources are usually different even without complications. There is rarely a simple relationship between the classes of reportable events used by different data sources and the major shipping accident types evaluated by MARCS.

Accuracy and Completeness of Reported Data

An additional problem regarding accident data is the accuracy and completeness of the reported data. In many cases, data can be incomplete, under-reported or duplicated. Another potential issue is inconsistent categorization of events over the recording period. This may be random (e.g. because several people categorize the events) or may vary systematically (e.g. due to changes of policy). Often the use of a new data source for risk assessment purposes requires a “data review and cleaning” process, which is time consuming, and if flawed, can lead to bias. While data are important to risk assessments they must always be used with critical evaluation.

Statistical Significance of Historical Accident Data

The number of serious navigational accidents recorded in a river is often low. This is, of course, a good thing, but it does present challenges to risk assessment work. MARCS uses seven main accident types. To assure the uncertainties are within a reasonable range, there should be at least two to three, and preferably more than five, accidents per accident type to get results with reasonable statistical significance. Ideally, these accidents should have occurred within five to ten years, otherwise changes in operational procedures or trades could introduce bias. There are very significant challenges to comparing historical accident data with predictions made by MARCS. In general, good agreement (to better than a factor of about two to five) is not expected. This does not discredit the MARCS model or the results produced, particularly if the variance can be understood considering the above issues.

Justification of Use of Worldwide Data as the Basis for MARCS

MARCS uses only local data when it can and combines this with data derived from worldwide historical accidents where there is no reasonable alternative. The reasons cited above offer ample justification for the use of worldwide historical accident data to form the basis of the accident parameters used in MARCS. Furthermore, DNV GL considers that the international nature of the shipping industry gives further justification of this approach.

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It should be noted that the worldwide accident data are used in a very specific way. In general, MARCS calculates accident frequencies from:

• The frequency of critical situations: This is calculated from the local traffic levels in the study area taking account of study area specific risk controls and study area specific environmental data. This is a local calculation.

• The probability of an accident given a critical situation: These probability factors are calculated from worldwide historical accident data.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix I

Washington State Department of Ecology I-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix I:

Cargo Oil Spill Risk Results

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at:

https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Table of Contents Page

Background ..........................................................................................................................3

Baseline Cargo Spill Risk ....................................................................................................3

Cargo Oil Spill Risk in Columbia River ....................................................................3

Cargo Spill Risk on Columbia River Bar ...................................................................8

Potential Future Cargo Spill Risk ........................................................................................9

Columbia River ..........................................................................................................9

Columbia River Bar .................................................................................................13

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Background

Risk results for the Columbia River were modeled from River Mile 0 to River Mile 105 for each

of the three marine traffic cases:

Case A, which included baseline year traffic. The baseline year for the evaluation was

October 1, 2015 – September 30, 2016; this was the most recent year of Automatic

Identification System data available.

o For vessels that carry cargo oil, Ecology reviewed Vessel Entries and Transits

(VEAT) (Ecology, 2017a) analysis to determine the number of transits within the

study area and routes traveled.

o For vessels that do not carry cargo oil, the model used processed AIS data for the

baseline year, to represent the actual flows of traffic within the study area.

Case B, the baseline traffic plus all the proposed projects defined in Appendix F, Study

Basis, operating at 25% of their proposed maximum number of vessel transits.

Case C, the baseline traffic, plus all the proposed projects defined in Appendix F, Study

Basis, operating at their proposed maximum number of vessel transits.

Baseline Cargo Spill Risk

Cargo Oil Spill Risk in Columbia River

Cargo oil spill risk was calculated for each of the many scenarios in the Case A model. For each

scenario, the frequency and spill quantity were multiplied to get an annual average risk in metric

tons per year (MT/yr). The scenario risks were added together, and the sum for each laden vessel

type shown in Table 1.

The baseline cargo oil spill risk for the Columbia River was estimated to be 11 MT/yr.

Aggregate oil spill risk estimates do not represent an expected spill volume per year, and should

not be interepreted as how many cargo oil spills will happen in the future.

Table 1: Cargo Oil Spill Risk River Case A (Baseline Traffic)

Vessel Type Aggregate Oil

Spill Risk (MT/yr)

ATB Laden Inbound 6

Oil Tanker Laden Inbound 3

Tug Oil-barge-in-tow Laden Inbound 1

Tug Oil-barge-in-tow Laden Outbound <1

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Vessel Type Aggregate Oil

Spill Risk (MT/yr)

Oil Tanker Laden Outbound <1

ATB Laden Outbound <0.1

Total1 11

The risk was generally proportional to the relative volume of traffic. Laden ATBs amount to

54% of current laden tank vessel traffic, and laden ATBs moving upriver, or inbound, were the

highest risk for Case A. This finding does not imply that ATBs are “high risk” vessels, but that

they contribute the most to the current risk profile since they have the most transits.

Figure 1: Spill Risk by Vessel and Incident Type Case A (Baseline Traffic)

The results displayed in Figure 2 indicate that two-fifths of the oil spill risk was from powered

groundings, followed by collisions, which contribute about one third. The data also show that the

estimated spill risk from a drift grounding was about double the risk from an onboard fire, a very

1 Note that rounded numbers may add to a different total than shown.

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infrequent event that rarely shows up on a risk map such as this. This indicates that current safety

systems are highly effective.

Additionally, few opportunities exist to ground on rocks on the Columbia River because most of

the river bottom and sides (88%) are soft, dispersing the energy of a grounding event.

Figure 2: Oil Spill Risk Contributors River Case A (Baseline Traffic)

Oil Spill Risk Per River Mile

As expected, the risk profile for the baseline traffic generally aligned with the vessel count in

AIS at a given place (Figure 3 and Figure 4). The peaks in risk due to powered grounding

correspond to locations on the river where rocks are near the navigational channel. For example,

the peak at River Mile 39 is due to a turn in the channel and the presence of a rock hazard.

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Figure 3: Oil Spill Risk per River Mile Case A (Baseline Traffic, River Mile 0 to 58)

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0 10 20 30 40 50

Sp

ill

Ris

k (

MT

/yr)

River Mile

Structural Failure

Powered Grounding

Fire/Explosion

Drift Grounding

Collision

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Figure 4: Oil Spill Risk per River Mile River Case A (Baseline Traffic, River Mile 59-105)

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Cargo Spill Risk on Columbia River Bar

Risk contributors on the bar, which include unanticipated weather conditions, equipment failures,

poor ship handling characteristics, crew competency, and other vessel material and human

factors, were identified through conversations with the Columbia River Bar Pilots and

discussions with evaluation participants. The cargo oil spill risk on the Columbia River Bar

(River Mile -5 to River Mile 0, in this evaluation) could not be modeled or quantified, due to the

complex nature of the interactions between forces that affect vessels in the area (e.g., waves,

wind, currents, water depths).

The incident types of greatest concern are related to severe weather conditions and include

structural failure, grounding, and the loss of an oil barge by a towing vessel.

In general, the existing safety measures that apply on the Columbia River are also in place on the

bar. In addition, a key risk control for all vessels is the decision about whether or not it is safe to

cross the bar. Several individuals and organizations play a role in this decision making process.

Each vessel master has the ultimate responsibility for the safety of his or her crew, vessel, and

cargo. The Columbia River Bar Pilots conduct vessel traffic management, and determine whether

it is safe to bring each vessel across the bar, for every transit they conduct.

Tools that support the Columbia River Bar Pilots include:

A fast-response pilot transportation system.

Regular communications with the maritime community, including the U.S. Coast Guard, the

NOAA Weather Forecast Office, the Merchants Exchange of Portland, Oregon, the Columbia

River Pilots, and individual vessels.

The safety culture of the Columbia River Bar Pilots.

The Coast Guard coordinates closely with the Columbia River Bar Pilots and controls the status

of the bar. The Coast Guard can issue restrictions on bar crossings, or close the bar to vessel

traffic entirely.

Four buoys provide important environmental data for the Bar. Two are owned by the NOAA

National Data Buoy Center (buoys 46029 and 46089). Two are owned by the Coastal Data

Information Program (buoy 46243 and buoy 46248). These buoys supply real-time data to the

Columbia River Bar Pilots but are frequently out of service in the winter, when storms are more

frequent.

Key results of a recent bar under keel clearance study (OMC International, 2012) stress the

complexity of the sailing conditions on the bar. The study noted that pilot judgment is a key

existing risk control. The Columbia River Bar Pilots stated that risks are well managed now, and

they identified enhancements that could help further reduce risks. These are described in the

main report.

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Washington State Department of Ecology I-9 Publication No. 17-08-010

Potential Future Cargo Spill Risk

Columbia River

This section describes spill risk from oil cargoes on the river for the two potential future

scenarios, Case B and Case C. Case B included baseline vessel traffic (Case A) plus 25% of

traffic from proposed terminal projects. Case C included baseline vessel traffic plus 100% of

traffic from proposed terminal projects.

The evaluation did not make assumptions about how marine bunkering (e.g., providing fuel and

other refined products to a vessel at a berth) might change in the future. No additional bunkering

transits were added to Case B or Case C.

Analysis

The model output for all three cases is shown in Table 2 for total cargo oil spill risk. Laden

inbound ATBs were the biggest risk contributor in Case A. In Case B, and C, new project tankers

transporting cargo oil outbound became the biggest risk contributor.

Table 2: River Cargo Oil Spill Risk Comparisons

Vessel Type

Aggregate Oil Spill Risk (MT/yr)

Case A Case B Case C

ATB Laden Inbound 6 6 7

Future Project - Oil Tanker Laden Outbound - 12 50

Oil Tanker Laden Inbound 3 3 4

Tug Oil-barge-in-tow Laden Inbound 1 1 1

Tug Oil-barge-in-tow Laden Outbound <1 1 1

Oil Tanker Laden Outbound <1 <1 <1

ATB Laden Outbound <0.1 <0.1 <0.1

Total2 11 23 63

When all the scenarios were summed, Case C risk was about five times the baseline risk

(Case A). The large increase in cargo spill risk is because most of the additional traffic is from

deep draft vessels, and a larger fraction of the new traffic is carrying cargo oil.

2 Note that rounded numbers may add to a different total than shown.

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Washington State Department of Ecology I-10 Publication No. 17-08-010

Risk contributors for Cases B and C are shown in Figure 5 and Figure 6. The total cargo oil spill

risk for Case B from all vessel types and incident types is 23 MT/yr. For Case C, the total is

63 MT/yr. If all the proposed projects operate at the traffic levels modeled in Case B or Case C,

the primary risk contributed by each vessel type would shift from the baseline risk. The future

project tankers would become the vessel type contributing the most to cargo oil spill risk.

Figure 5: Key Risk Contributors in River Case B (Baseline Traffic+ 25% Projects)

Figure 6: Key Risk Contributors in River Case C (Baseline Traffic+ 100% Projects)

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Washington State Department of Ecology I-11 Publication No. 17-08-010

Comparison of Risks

An overview of the summed scenario risks per incident type is shown in Figure 7. Case A is the

shown on the left, Case B is in the middle, and Case C is on the right. ATB powered groundings

contributed the most to Case A cargo oil spill risk on the river. For Cases B and C, future project

– oil tankers contributed the most, distributed among groundings and collision.

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Washington State Department of Ecology I-12 Publication No. 17-08-010

Figure 7: Case Comparison – Detailed Cargo Oil Spill Risk Contributors

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Washington State Department of Ecology I-13 Publication No. 17-08-010

Columbia River Bar

It is expected that cargo oil spill risk on the river and the bar are closely related, but the hazards

on the bar interact with the different sized vessels in dissimilar ways. The future traffic Case C

for the river shows an increase in risk, to a level more than five times the baseline cargo oil spill

risk. It could reasonably be expected that an increase would be seen for the bar.

The incident types of greatest concern are likely to be structural failure, grounding, and the loss

of an oil barge by a towing vessel. Knowledge of how the environment on the bar interacts with

the various vessel types is still being developed. It is not possible to identify which vessel types

contribute the most to the risk on the bar.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix J

Washington State Department of Ecology J-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix J:

Assessment of Best Achievable Protection

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at:

https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Washington State Department of Ecology J-2 Publication No. 17-08-010

Table of Contents Page

List of Figures and Tables....................................................................................................3

Introduction ..........................................................................................................................4

Risks and Potential Risk Reduction Measures.....................................................................6

Quantitative Risk Reduction and Cost Benefit Analysis – Columbia River .......................8

Tethered Tug Escort of Oil Laden Tankers ................................................................9

Untethered Tug Escort of Laden Tankers ................................................................12

Pilots on Tugs with Laden Oil-barges-in-tow ..........................................................15

Tethered Tug on Laden ATBs ..................................................................................18

Redundant Propulsion Systems on Tankers .............................................................21

Qualitative Risk Reduction Measures – Columbia River Bar ...........................................24

Wave Prediction Tool ...............................................................................................24

Land-based Radar at Cape Disappointment .............................................................25

AIS on Towed Barges on the Bar .............................................................................25

Sensitivity Analysis ...........................................................................................................26

BAP Results and Conclusions ...........................................................................................29

Columbia River ........................................................................................................29

Columbia River Bar .................................................................................................31

References ..........................................................................................................................33

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Washington State Department of Ecology J-3 Publication No. 17-08-010

List of Figures and Tables

Figures Page

Figure 1: Future River Traffic: Major Risk Contributors Case C ........................................6

Figure 2: Overview of Risk After Application of Risk Reduction Measures to Case C .....8

Figure 3: Residual Risk from All Laden Vessels on the River: Tethered Tug on Laden

Tankers in Case C .............................................................................................10

Figure 4: Residual Risk from All Laden Vessels on the River: Untethered Tug on

Laden Tankers in Case C ..................................................................................13

Figure 5: Residual Risk from All Laden Vessels on the River: Pilots on Tugs with

Laden Oil-barges-in-tow in Case C...................................................................16

Figure 6: Residual Risk from All Laden Vessels on the River: Tethered Tug on Laden

ATBs in Case C .................................................................................................19

Figure 7: Residual Risk from All Laden Vessels on the River: Redundant Propulsion

Systems on Tankers in Case C ..........................................................................22

Figure 8: Comparison of Sensitivity – Baseline Traffic + 10% Project Vessels to other

Traffic Cases .....................................................................................................27

Tables Page

Table 1: Potential Risk Reduction Measures for the Columbia River (Assessed

Quantitatively).....................................................................................................7

Table 2: Potential Risk Reduction Measures for the Columbia River Bar (Assessed

Qualitatively).......................................................................................................7

Table 3: Risk Reduction from Tethered Tug Escort of Laden Tankers .............................11

Table 4: Risk Reduction from Untethered Tug Escort of Laden Tankers .........................14

Table 5: Risk Reduction from Pilots on Tugs with Laden Oil-barges-in-tow ...................17

Table 6: Risk Reduction from a Tethered Tug on Laden ATBs ........................................20

Table 7: Risk Reduction from Redundant Propulsion Systems on Tank Vessels .............23

Table 8: Sensitivity – Future Project Transits for Lower Traffic Growth .........................26

Table 9: Cost-Benefit Summary – 10% Project Traffic Sensitivity ..................................28

Table 10: Cost-Benefit Summary Case C ..........................................................................29

Table 11: Cost-Benefit Summary Case B ..........................................................................30

Table 12: Cost-Benefit Summary Case A ..........................................................................30

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Washington State Department of Ecology J-4 Publication No. 17-08-010

Introduction

This appendix describes how potential risk reduction measures were identified and evaluated.

“Risk,” as used throughout this report, refers to the risk of a cargo oil spill.

The Columbia River Vessel Traffic Evaluation and Safety Assessment (CRVTSA) requires an

evaluation of Best Achievable Protection (BAP) and Best Available Technology, defined as:

Best Achievable Protection:

. . . the highest level of protection that can be achieved through the use of the best

achievable technology and those staffing levels, training procedures, and operational

methods that provide the greatest degree of protection achievable. The director's

determination of best achievable protection shall be guided by the critical need to protect

the state's natural resources and waters, while considering:

(a) The additional protection provided by the measures;

(b) The technological achievability of the measures; and

(c) The cost of the measures. (revised RCW 88.46.010 and 2011 c 122 s 1)

Best Available Technology:

. . . the technology that provides the greatest degree of protection taking into

consideration:

(i) Processes that are being developed, or could feasibly be developed, given overall

reasonable expenditures on research and development; and

(ii) Processes that are currently in use. (revised RCW 88.46.010 and 2011 c 122 s 1)

The 2015 Washington Oil Transportation Safety Act states that the need to protect State waters

shall be guiding and the determination shall consider:

(a) The additional protection provided by the measures;

(b) The technological achievability of the measures; and

(c) The cost of the measures. (Appendix A)

To meet these requirements, the analysis process included quantifying spill risk using the

DNV GL MARCS model for the baseline case (Case A) and potential future cases (Case B and

Case C).

The evaluation process was:

1. Identifying potential risk reduction measures with input from tribes and stakeholders.

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2. For measures that could be assessed quantitatively:

o Analyzing the potential risk reduction for each measure using the DNV GL MARCS

model.

o Evaluating the cost to implement.

o Calculating cost / benefit.

3. For measures that were assessed qualitatively:

o Analyzing measures to determine if they would be effective.

o Evaluating the cost to implement.

o Evaluating whether their costs are a greater burden than the risk they reduce.

Quantified risk results from the MARCS model for Cases A, B, and C are in Appendix I, Cargo

Oil Spill Risk Results. They are reported as potential aggregated metric tons per year of cargo oil

spilled. Quantified results for each risk reduction measure are shown in potential metric tons per

year of avoided cargo oil spills, and cost-benefit results are assessed using the avoided cost per

each metric ton per year of avoided cargo oil spills.

It should be noted that model results do not represent an expected spill volume per year, and

should not be interpreted as predictions of how many cargo oil spills will happen in the future.

The purpose of the model results is to allow a comparison of potential risk causes, and an

assessment of the relative benefit of potential risk reduction measures.

Representatives from tribal and stakeholder organizations reviewed the risk results during a

workshop on January 25, 2017. Participants at the workshop reviewed potential risk reduction

measures and provided inputs on the measures and potential costs. Ecology and DNV GL

finalized the list of measures following the workshop.

Mitigated risk results and an initial cost-benefit analysis were presented during a workshop in

February 23, 2017. A list of participants in CRVTSA workshops is available in Appendix B, List

of Project Contributors and Workshop Attendees.

The Preliminary Draft CRVSTA Report was provided to project contributors and workshop

attendees for review on April 27, 2017. During the evaluation, Ecology reviewed additional data

on oil laden vessels transiting the river. The MARCS model input was revised based on that

review and feedback from project contributors and workshop attendees. The revised results are

presented in this appendix.

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Risks and Potential Risk Reduction Measures

Figure 1 shows major risk contributors for Case C. The largest risk contributor for Case C was

tanker traffic carrying oil from proposed projects. ATBs were the second greatest contributor in

Case C with collision comprising the largest part of oil barge cargo spill risk.

Figure 1: Future River Traffic: Major Risk Contributors Case C

Table 1 and Table 2 show potential risk reduction measures evaluated for the Columbia River

and the Columbia River Bar.

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Table 1: Potential Risk Reduction Measures for the Columbia River (Assessed Quantitatively)

Risk Reduction Measure Risk It Reduces

1. Tethered tug escort of laden tankers

Reduces the likelihood of drift grounding and powered grounding from an equipment failure.

2. Untethered tug escort of laden tankers

Reduces the likelihood of drift grounding from an equipment failure.

3. Tethered tug escort of laden ATBs

Reduces the likelihood of drift grounding and powered grounding from equipment failure. The potential effect from this is smaller than for the other vessel types because of existing risk controls: some of the ATBs on the river have redundant propulsion and steerage components.

4. Pilot taken aboard on laden towed barges and ATBs

Reduces the likelihood of collision and powered grounding from human error.

5. Redundant propulsion on laden tankers

Reduces the likelihood of drift and powered grounding due to equipment failure.

Table 2: Potential Risk Reduction Measures for the Columbia River Bar (Assessed Qualitatively)

Risk Reduction Measure Risk It Reduces

6. A wave model / tool to provide near real-time information about conditions on the Columbia River Bar

Reduces the likelihood of grounding incidents.

7. Land-based radar at Cape Disappointment to enhance the Electronic Charting Software at the pilot’s dispatch office

Reduces the likelihood of grounding and collision incidents.

8. AIS on towed barges Reduces the likelihood of collision incidents. May reduce likelihood of grounding incidents due to vessels maneuvering to avoid barges across channel.

Per the 2015 Washington Oil Transportation Safety Act, all combinations of tank vessels and tug

escorts were considered in this evaluation. However, tethered tugs on tugs with oil-barge-in-tow

would not reduce the risk of a cargo spill beyond current practice. Current practice is for a tail /

tag tug to be fastened at the stern of the barge. The barge is required to be under positive control,

within one barge width of the tug’s trackline. This practice is part of the Towed Barge Standard

of Care in the Lower Columbia Region Harbor Safety Plan (Lower Columbia Region Harbor

Safety Committee, 2016). Since two tugs are already on these barges, consensus was that a third

tug would not further reduce the risk of a cargo spill.

Potential risk reduction measures that could be modeled quantitatively were further analyzed for

cost-benefit. Measures that were assessed qualitatively could not be included in the cost-benefit

calculations, because the amount of potential risk reduction could not be determined.

The five potential risk reduction measures identified for the Columbia River were suitable for

quantitative assessment and cost-benefit analysis, as discussed in the following section. The

remaining measures were evaluated qualitatively regarding potential benefits compared to their

cost. They relate to the Columbia River Bar.

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Quantitative Risk Reduction and Cost Benefit Analysis – Columbia River

Five potential risk reduction measures for the Columbia River were modeled quantitatively, and

included in cost benefit analysis:

1. Tethered tug escort of laden tankers on the river.

2. Untethered tug escort of laden tankers on the river.

3. Pilots on laden traditional towed barges and ATBs on the river.

4. Tethered tug on laden ATBs on the river.

5. Redundant propulsion on laden tankers.

The MARCS model was re-run for each of the five risk quantifiable risk reduction measures, and

BAP was evaluated for each Case (A, B, and C). The model output for each measure was the

remaining, or residual risk, for each measure. Summary residual risk results for Case C are

shown in Figure 2. More detailed figures are presented with the discussion of each measure

below.

Figure 2: Overview of Risk After Application of Risk Reduction Measures to Case C

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In the above figure, the risk reduction can be observed by comparing the mitigated risk with the

Case C risk. For instance, if all laden petroleum tankers were escorted by tethered tugs, the risk

reduction would be about 27 MT / yr: 63 (Case C) minus 36 (Case C assuming all tankers have

tethered escort tugs).

Tethered Tug Escort of Oil Laden Tankers

Description

For analysis of this measure, tethered tug escort of a laden oil tanker included the following key

characteristics:

The tug is tethered to the tanker such that it can gain control of the tanker if it experienced a

loss of propulsion.

The escort tug has sufficient bollard pull and maneuverability to achieve its intended aims in

all weather conditions under which laden vessels are allowed to transit the river.

The tug is designed and maintained to withstand the forces it would see in the most severe

conditions it might encounter during an escort.

The Potential Risk Reduction Measure section of the main report contains additional discussion

about the necessary characteristics of an escort tug suitable for oil tankers on the Columbia

River.

Risk Reduction

The risk reduction offered by tethered tug escort of laden tankers was significant compared to the

risk without the tug (Figure 3). Case C represents the situation with the greatest possible risk

reduction from the measure: all proposed projects are fully built out and are exporting oil at the

maximum capacity they have proposed.

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Figure 3: Residual Risk from All Laden Vessels on the River: Tethered Tug on Laden Tankers in

Case C

Table 3 shows details of the measure’s benefit in terms of reducing risk from oil cargo spills in

Case C, which is 27 MT / yr.

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Table 3: Risk Reduction from Tethered Tug Escort of Laden Tankers

Vessel Type Case C (MT / yr)

Case C mitigated by Tethered Tug Escort of Laden Tankers (MT / yr)

Risk Reduction (benefit in MT /

yr)

Future Project Oil Tanker Laden Outbound 50 25 25

ATB Laden Inbound 7 7 -

Oil Tanker Laden Inbound 4 2 2

Tug Oil-barge-in-tow Laden Inbound 1 1 -

Tug Oil-barge-in-tow Laden Outbound 1 1 -

Oil Tanker Laden Outbound <1 <1 <1

ATB Laden Outbound - - -

TOTAL RISK 63 36 -

Total Risk Reduction (benefit) - - 27

Greyed out rows in the table have risk benefits <0.1 MT / yr.

Rounded numbers may sum to a different total than shown.

The benefit of this reduction in Case B was 8 MT / yr. For Case A, the benefit was 2 MT / yr.

Cost

The estimated cost of tethered tug escort of proposed laden tankers was about $38,000 per

transit, as provided by members of the Lower Columbia Region Harbor Safety Committee

CRVTSA workgroup.

For Case C:

The number of laden trips per year was:

o 365 for laden future project oil tankers.

o 29 for laden tankers inbound in the baseline traffic.

o 2 for laden tankers outbound in the baseline traffic.

The resulting annual cost was $15.0 million / yr.

For Case B:

The number of laden trips per year was:

o 91 for laden future project oil tankers.

o 29 for laden tankers inbound in the baseline traffic.

o 2 for laden tankers outbound in the baseline traffic.

The resulting annual cost was $4.6 million / yr.

For Case A:

The number of laden trips per year was:

o 0 for laden future project oil tankers.

o 29 for laden tankers inbound in the baseline traffic.

o 2 for laden tankers outbound in the baseline traffic.

The resulting annual cost was $1.2 million / yr.

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Cost / Benefit Ratio

The cost-benefit ratio for this risk measure is the cost divided by the benefit, and was $550,000 /

MT for Case C.

For Case B, the cost-benefit ratio was $560,000 / MT, in the same range as for Case C, because

the cost and benefit are both dependent on the number of laden transits. The cost-benefit ratio for

Case A was $580,000 / MT.

Untethered Tug Escort of Laden Tankers

Description

For analysis of this measure, untethered tug escort of a laden oil tanker included the following

key characteristics:

The tug is not physically attached to the tanker, but transits in company with the tanker.

The escort tug has sufficient bollard pull and maneuverability to achieve its intended aims in

all weather conditions under which laden vessels are allowed to transit the river.

The tug is designed and maintained to withstand the forces it would see in the most severe

conditions it might encounter during an escort.

Risk Reduction

The risk reduction offered by an untethered tug escort of laden tankers was not very different

than the risk without the escort (Figure 4). Case C is shown in the table and represents the

situation with the greatest possible risk reduction from the measure: all proposed projects are

fully built out and export oil to the greatest extent they have proposed publicly.

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Figure 4: Residual Risk from All Laden Vessels on the River: Untethered Tug on Laden Tankers in

Case C

Table 4 shows details of the measure’s benefit in terms of reducing risk from oil cargo spills in

Case C, which is 2 MT / yr.

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Table 4: Risk Reduction from Untethered Tug Escort of Laden Tankers

Vessel Type Case C (MT / yr)

Case C mitigated by Untethered Tug on Laden Tankers

(MT / yr)

Risk Reduction (benefit in MT / yr)

Future Project Oil Tanker Laden Outbound

50 48 2

ATB Laden Inbound 7 7 -

Oil Tanker Laden Inbound 4 4 <1

Tug Oil-barge-in-tow Laden Inbound

1 1 -

Tug Oil-barge-in-tow Laden Outbound

1 1 -

Oil Tanker Laden Outbound - - -

ATB Laden Outbound - - -

TOTAL RISK 63 61 -

Total Risk Reduction (benefit) - - 2

Greyed out rows in the table have risk reduction <0.1 MT / yr.

Rounded numbers may sum to a different total than shown.

The benefit of this reduction in Case B was <1 MT / yr. For Case A, the benefit was <1 MT / yr.

Cost

The estimated cost of an untethered tug escort of laden tankers was about $38,000 per transit, as

provided by members of the Lower Columbia Region Harbor Safety Committee CRVTSA

workgroup.

For Case C:

The number of laden trips per year was:

o 365 for laden future project oil tankers.

o 29 for laden tankers inbound in the baseline traffic.

o 2 for laden tankers outbound in the baseline traffic.

The resulting annual cost was $15.0 million / yr.

For Case B:

The number of laden trips per year was:

o 91 for laden future project oil tankers.

o 29 for laden tankers inbound in the baseline traffic.

o 2 for laden tankers outbound in the baseline traffic.

The resulting annual cost was $4.6 million / yr.

For Case A:

The number of laden trips per year was:

o 0 for laden future project oil tankers.

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o 29 for laden tankers inbound in the baseline traffic.

o 2 for laden tankers outbound in the baseline traffic.

The resulting annual cost was $1.2 million / yr.

Cost / Benefit Ratio

The cost-benefit ratio for this risk measure is the cost divided by the benefit, and was $7,800,000

/ MT for Case C. For Case B, the cost-benefit ratio was $8,000,000 / MT, in the same range as

for Case C. The cost-benefit ratio for Case A was $8,500,000 / MT.

The primary reason the ratios differ for the three cases was that the measure reduces the

frequency part of the risk, but it did not change the consequence part of the risk. Case C project

vessels had, on average, larger quantity spills, than Case A baseline traffic vessels.

Pilots on Tugs with Laden Oil-barges-in-tow

Description

The benefits of taking a pilot on board are described in Appendix J, Marine Safety Controls. For

this analysis of measures, the main risk reduction was from having an additional, appropriately

experienced, and credentialed mariner on the bridge, with the vessel’s captain or mate, who also

brings real-time information with him. Key characteristics of this additional person are:

Possesses demonstrated, significant local experience navigating the Columbia River.

Current on bridge and navigational technologies.

Has access to TV-32 or an equivalent near real-time information system providing vessel

traffic and sailing conditions.

Remains on the bridge the entire voyage.

Risk Reduction

The risk reduction offered by a pilot on tug with laden oil-barge-in-tow is shown in Figure 5.

Case C is shown in the table and represents the situation with the greatest possible risk reduction

from the measure: all proposed projects are fully built out and export oil to the greatest extent

they have publicly proposed.

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Figure 5: Residual Risk from All Laden Vessels on the River: Pilots on Tugs with Laden Oil-

barges-in-tow in Case C

Table 5 shows details of the measure’s benefit in terms of reducing risk from oil cargo spills in

Case C, which was <1 MT / yr.

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Table 5: Risk Reduction from Pilots on Tugs with Laden Oil-barges-in-tow

Vessel Type Case C (MT

/ yr)

Case C mitigated by Pilots on Tugs

with Laden Oil-barges-in-tow

(MT / yr)

Risk Reduction (benefit in MT /

yr)

Future Project Oil Tanker Laden Outbound 50 50 -

ATB Laden Inbound 7 7 -

Oil Tanker Laden Inbound 4 4 -

Tug Oil-barge-in-tow Laden Inbound 1 1 <1

Tug Oil-barge-in-tow Laden Outbound 1 1 -

Oil Tanker Laden Outbound - - -

ATB Laden Outbound - - -

TOTAL RISK 63 63 -

Total Risk Reduction (benefit) - - <1

Greyed out rows in the table have risk reduction <0.1 MT / yr.

Rounded numbers may sum to a different total than shown.

The benefit of this reduction in Case B was <1 MT / yr. For Case A, the benefit was <1 MT / yr.

The three Cases have similar benefits because most of the mitigated risk is from vessels in the

current marine traffic.

Cost

The estimated cost of pilotage of tugs with oil-barges-in-tow was about $4,200 per transit, as

provided by members of the Lower Columbia Region Harbor Safety Committee CRVTSA

workgroup.

None of the proposed projects stated an intent to use barges to transport oil. The only barges

sailing the river in Case C were from the baseline traffic.

To avoid overestimating both costs and benefits of this risk reduction measure, the laden transits

of tug with oil-barge-in-tow were reviewed. Eastbound transits upriver from River Mile 101

were identified as carrying refined products to eastern Washington ports. These transits differ in

two significant ways:

The tows are typically configured differently than barges-in-tow on the lower part of the

river.

The waterway east of the I-5 bridge (near River Mile 105) is significantly different regarding

the channel characteristics, and the density and types of marine traffic.

As a result, the potential for risk reduction was evaluated only for tug with oil-barge-in-tow

transits west of River Mile 100.

For Cases A, B, and C, there were 42 transits for tugs with laden oil-barge-in-tow in the baseline

year. The resulting annual cost was $180,000 / yr.

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Cost / Benefit Ratio

The cost-benefit ratio for this risk reduction measure is the cost divided by the benefit, and was

$440,000 / MT for Case C. For Case B, the cost-benefit ratio was $480,000 / MT, in the same

range as for Case C. The cost-benefit ratio for Case A was $530,000 / MT.

The primary reason the ratios are similar for the three cases is that the measure applied mostly to

vessels in the current traffic. They vary slightly because collision risk leading to spills is greater

in Cases B and C than in A.

Tethered Tug on Laden ATBs

Description

For analysis of this measure, tethered tug escort of a laden ATB included the following key

characteristics:

The tug is tethered to the ATB such that it can gain control of the ATB if it experienced a

loss of propulsion.

The escort tug has sufficient bollard pull and maneuverability to achieve its intended aims in

all weather conditions under which laden vessels are allowed to transit the river.

The tug is designed and maintained to withstand the forces it would see in the most severe

conditions it might encounter during an escort.

The Potential Risk Reduction section of the main report contains additional discussion about the

necessary characteristics of suitable escort tugs.

Risk Reduction

The risk reduction offered by a tethered tug on laden ATBs is shown in Figure 6. Case C is

shown in the table, and represents the situation with the greatest possible risk reduction from the

measure: all proposed projects are fully built out and export oil to the greatest extent they have

publicly proposed.

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Figure 6: Residual Risk from All Laden Vessels on the River: Tethered Tug on Laden ATBs in

Case C

Table 6 shows the measure’s benefit in terms of reducing risk from oil cargo spills. The risk

reduction for the three cases was 2 MT / yr. All of the laden ATBs were in the existing traffic.

None of the proposed terminals included ATBs in their proposed transits.

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Table 6: Risk Reduction from a Tethered Tug on Laden ATBs

Vessel Type Case C (MT / yr)

Case C mitigated by Tethered Tug on Laden ATBs

(MT / yr)

Risk Reduction (benefit in MT / yr)

Future Project Oil Tanker Laden Outbound

50 50 -

ATB Laden Inbound 7 5 2

Oil Tanker Laden Inbound 4 4 -

Tug Oil-barge-in-tow Laden Inbound 1 1 -

Tug Oil-barge-in-tow Laden Outbound

1 1 -

Oil Tanker Laden Outbound - - -

ATB Laden Outbound - - -

TOTAL RISK 63 61 -

Total Risk Reduction (benefit) - - 2

Greyed out rows in the table have risk reduction <0.1 MT / yr.

Rounded numbers may sum to a different total than shown.

Cost

The estimated cost of an untethered tug escort of project proposed laden tankers was about

$38,000 per transit, as provided by members of the Lower Columbia Region Harbor Safety

Committee CRVTSA workgroup.

None of the proposed projects stated that they plan to use ATBs to transport oil. The only ATBs

sailing the river in Case C were in the baseline traffic. There were 112 transits of laden ATBs

between RM 0 and RM 105 during the baseline year, 110 inbound and 2 outbound.

The resulting annual cost of this measure is $4.3 million / yr.

Cost / Benefit Ratio

The cost-benefit ratio for this measure is the cost divided by the benefit, and was $2.2 million /

MT, the same for Cases A, B, and C. There are two main reasons the ratio is the same for all of

the cases:

The number of mitigated vessels was the same in all three cases.

The measure affected grounding risk, which is independent of the traffic level.

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Redundant Propulsion Systems on Tankers

A redundant propulsion system provides significant risk reduction from equipment failure. When

one system is down, the other is still capable of maneuvering the vessel.

The two other vessel types that carry cargo oil already have highly reliable propulsion and

steerage systems; therefore, this measure was not applied to the other types. The tugs that tow

barges have a tug ahead connected by a tow line and a tag tug made fast astern. The ATBs

currently on the river have redundant propulsion and steerage components, increasing their

reliability.

Description

For analysis of this measure, it was assumed that enough tankers with redundant propulsion

would need to be built to service the proposed project. The new oil tankers would be built to

requirements for the least stringent class notation for redundant propulsion. An estimated 12

additional tankers would be built to serve proposed terminals at maximum proposed throughput.

Risk Reduction

The risk reduction offered by redundant propulsion systems on tank vessels is shown in Figure 7.

Case C is shown, and represents the situation with the greatest possible risk reduction from the

measure: all proposed projects are fully built out and export oil to the greatest extent they have

publicly proposed.

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Figure 7: Residual Risk from All Laden Vessels on the River: Redundant Propulsion Systems on

Tankers in Case C

Table 7 shows details of the measure’s benefit in terms of reducing risk from oil cargo spills in

Case C, which was 17 MT / yr.

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Table 7: Risk Reduction from Redundant Propulsion Systems on Tank Vessels

Vessel Type Case C (MT / yr)

Case C mitigated by Redundant

Propulsion on Laden Tankers (MT / yr)

Risk Reduction (benefit in MT / yr)

Future Project Oil Tanker Laden Outbound

50 33 17

ATB Laden Inbound 7 7 -

Oil Tanker Laden Inbound 4 4 -

Tug Oil-barge-in-tow Laden Inbound 1 1 -

Tug Oil-barge-in-tow Laden Outbound 1 1 -

Oil Tanker Laden Outbound - - -

ATB Laden Outbound - - -

TOTAL RISK 63 47 -

Total Risk Reduction (benefit) - - 17

Greyed out rows in the table have risk reduction <0.1 MT / yr.

Rounded numbers may sum to a different total than shown.

The benefit of this measure in the other cases was not estimated in this study because it would

highly depend on exactly how many tankers would need to be built. The economic drivers are

key to the proponent’s business case for the project.

Cost

It is assumed that 12 new tankers would be built in the U.S. to at least the lowest class notation

for redundant propulsion. The cost of each tanker was estimated at $200 million, with an

expected 30-year lifetime.

The total average annual cost was $80,000,000 / yr.

Cost / Benefit Ratio

The cost-benefit ratio for this risk reduction measure is the cost divided by the benefit, and was

$4,700,000 / MT.

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Qualitative Risk Reduction Measures – Columbia River Bar

Multiple factors combine to make crossing the Columbia River Bar challenging. These include

the interaction of long-period swells, wind-driven waves, shallow depths, frequent high winds,

and the strong outflow of the Columbia River. Pilotage across the Columbia River Bar is

compulsory for U.S. vessels sailing under registry and for all foreign vessels, except foreign

recreational or fishing vessels not more than 100 feet in length or 250 gross tons.

The Columbia River Bar Pilots decide, on a case-by-case basis, whether it is safe to bring each

vessel across the bar. Improved tools could better inform this decision-making process.

Discussions with the Columbia River Bar Pilots and the Lower Columbia Region Harbor Safety

Committee CRVTSA workgroup identified three potential areas for improvement: a predictive

wave model, a surface radar, and a process to equip barges with AIS transponders. This study

does not suggest that tugs escort laden vessels across the bar. Under some scenarios, the escort

could increase the risk. The San Francisco Bar has a process that might work for the Columbia

River Bar. The escort tug is tethered in the sheltered waters, releases prior to crossing the bar,

and then waits at a designated location while the ship transits the bar out to a specified marker.

The reverse applies to an inbound ship. Additional studies may find specific conditions where an

escort tug crossing the bar could improve safety, but no such studies are known to the CRVTSA.

Wave Prediction Tool

Winter storms in the Pacific Ocean commonly generate waves 10 to 25 feet high resulting in

hazardous navigation conditions on the bar. These hazardous conditions are amplified when they

coincide with strong tidal currents. Predictive tools for hazardous harbor entrances are in use and

have become or are becoming the best achievable standard of technology. For example, the San

Francisco Bar poses hazards to navigation similar but in differing degrees to the Columbia River

Bar. A bar forecast model was made available in 2005 for the San Francisco Bar, and the number

of incidents occurring since then shows a strong downward trend (NOAA, 2010).

The Coastal Data Information Program provided the models for the San Francisco Bar and

entrance to Long Beach / Los Angeles harbors. The program deployed two wave buoys on the

Columbia River Bar in 2011 funded by the Columbia River Bar Pilots and the State of Oregon,

but determined that modeling for this bar was too complex and decided not to pursue building a

model.

In 2012, Oregon State University (OSU) built a wave forecast model (OSU, 2012). The OSU

model is still running, but only once a day and it takes 24 hours for the results to be available, so

the forecast is essentially 24 to 48 hours into its 84-hour forecast. After the model was validated,

the Columbia River Bar Pilots worked with the university in hope of housing the model at the

National Weather Service, but the funding needed to relocate it wasn’t available.

The National Centers for Environmental Prediction, part of the National Oceanic and

Atmospheric Administration, is building a new Nearshore Wave Prediction System. The current

system does not provide high enough resolution to support decisions about safely navigating the

bar.

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A wave model / tool to provide near real-time information about conditions on the bar would be

an important next step toward protecting the bar from potential spills. The ideal model would:

Provide predictive conditions four times per day.

Provide a high-resolution graphical presentation.

Calibrate to the Coastal Data Information Program wave buoy observations.

Provide data for a point on the center channel at River Mile 0 on the bar.

The Columbia River Bar Pilots estimate the Oregon State University model is anticipated to cost

about $75,000 to relocate to the National Weather Service, and thereafter, it could be run by the

National Weather Service. There could be ongoing costs to maintain the model.

Land-based Radar at Cape Disappointment

A land-based radar to provide coverage of the Columbia River Bar and approaches would

improve vessel traffic management by the Columbia River Bar Pilots, and navigation safety on

the bar in general. A rough order of magnitude estimate is a one-time investment of $40,000 plus

operational, maintenance, and human resources costs.

AIS on Towed Barges on the Bar

Tug boats use AIS codes to designate whether they are towing astern, towing alongside / pushing

ahead, or operating as a “light boat” (i.e., transiting without a barge). Barges do not carry AIS

transponders, and the U.S. Coast Guard AIS Encoding Guide does not include “type of ship”

parameters for barges. As a result, the barges are not visible on the vessel traffic information

system used by the Bar Pilots to monitor other vessels. This can be a serious hazard whether the

barge is carrying oil or not. Conditions in the vicinity of the bar can result in a tug being on one

side of the channel, and the barge being on the other, with the tow wire stretching across the

channel.

Implementing this measure would require changes to international standards and federal

regulations. The IMO publishes guidance for the use of AIS. AIS standards are incorporated in

the Code of Federal Regulations, and the U.S. Coast Guard issues AIS encoding guidance for

vessels in U.S. waters. Current AIS guidance does not include codes that could be used to

identify a vessel as a barge. States would have to work with the Coast Guard to request any

changes to AIS guidance.

Creating AIS encoding guidance for barges and placing AIS transponders on barges would allow

pilots and other captains to track them, potentially reducing the frequency of incidents (e.g.,

collisions, or groundings from collision avoidance actions). An AIS transponder could cost

approximately $5,000 per barge.

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Sensitivity Analysis

This sensitivity looked at the study results if only 10% of all the proposed traffic was added to

the baseline year traffic. Table 8 shows the laden and ballast transits per year for this sensitivity,

and shows Case C (100% of all of the proposed traffic) for purposes of comparison.

Table 8: Sensitivity – Future Project Transits for Lower Traffic Growth

Terminal Location Cargo Sensitivity Case

Laden Transits per Year

Case C Laden Transits per Year

Longview, WA Coal 84 840

Vancouver, WA Oil export 36.5 365

Port of Kalama-Cowlitz County, WA Methanol 7.2 72

Port Westward in Clatskanie, OR Methanol 7.2 72

Woodland, WA Calcium carbonate 3 30

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The risk results for this case are shown in Figure 8. The lower traffic growth sensitivity case was

very similar to Case A, the baseline traffic case.

Figure 8: Comparison of Sensitivity – Baseline Traffic + 10% Project Vessels to other Traffic Cases

The cost benefit results for this sensitivity are shown in Table 9.

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Table 9: Cost-Benefit Summary – 10% Project Traffic Sensitivity

Risk Reduction

Measure

Annual Cost of

Implementation

($ / yr)

Risk Reduction

(MT / yr)

Sensitivity

Cost-benefit

Ratio ($ / MT)

Case C Cost-

benefit Ratio ($

/ MT)

Pilot on tug with laden oil-barge-in-tow

180,000 <1 510,000 440,000

Tethered tug escort of laden tankers

2,600,000 5 560,000 550,000

Tethered tug on laden ATBs

4,300,000 2 2,200,000 2,200,000

Untethered tug escort of laden tankers

2,600,000 <1 8,100,000 7,800,000

The cost of implementation and the risk reduction were both related to the number of affected

laden transits. As a result, the cost-benefit ratios for this sensitivity were very similar to those for

Case C. Looking at the relationship between the four cost-benefit ratios, the relative cost-

effectiveness of the measures did not change compared to Case C.

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BAP Results and Conclusions

The BAP analysis used a workshop process to identify potential additional risk reduction

measures, and evaluated them on the basis of avoided spill risk and cost. Some potential

measures could not be quantified, and these were evaluated using available information and

expert judgment.

The BAP analysis focused on Case C for two reasons: 1) the current risk profile is low, and 2)

the list of potential measures relates to all of the laden vessel types in both the current and future

marine traffic on the river and bar.

Columbia River

Quantified Measures

Table 10 summarizes the costs and benefits for all of the measures for which the risk could be

quantified.

Table 10: Cost-Benefit Summary Case C

Risk Reduction Measure

Annual Cost of Implementation

($ / yr)

Risk Reduction (MT / yr)

Cost-benefit Ratio ($ / MT)

Normalized Cost-benefit

Ratio‡

Tethered tug escort of laden tankers

$15,000,000 27 $550,000 1

Pilot on tug with laden oil-barge-in-tow

$180,000 <1 $440,000 1

Tethered tug on laden ATBs

$4,300,000 2 $2,200,000 4

Redundant propulsion on project tankers

$80,000,000 17 $4,700,000 9

Untethered tug escort of laden tankers

$15,000,000 2 $7,800,000 14

‡Ratio of each cost-benefit to the lowest cost-benefit measure; provides the relative ranking of each risk reduction

measure.

Table 11 and Table 12 similarly summarize the costs and benefits when applied to traffic Cases

B and A.

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Table 11: Cost-Benefit Summary Case B

Risk Reduction Measure

Annual Cost of Implementation

($ / yr)

Risk Reduction (MT / yr)

Cost-benefit Ratio ($ / MT)

Normalized Cost-benefit

Ratio‡

Tethered tug escort of laden tankers

$4,600,000 8 $560,000 1

Pilot on tug with laden oil-barge-in-tow

$180,000 <1 $480,000 1

Tethered tug on laden ATBs

$4,300,000 2 $2,200,000 4

Untethered tug escort of laden tankers

$4,600,000 <1 $8,000,000 14

Redundant propulsion on project tankers

- - - -

‡Ratio of each cost-benefit to the lowest cost-benefit measure; provides the relative ranking of each risk reduction

measure.

Table 12: Cost-Benefit Summary Case A

Risk Reduction Measure

Annual Cost of Implementation

($ / yr)

Risk Reduction (MT / yr)

Cost-benefit Ratio ($ / MT)

Normalized Cost-benefit

Ratio‡

Tethered tug escort of laden tankers

$1,200,000 2 $580,000 1

Pilot on tug with laden oil-barge-in-tow

$180,000 <1 $530,000 1

Tethered tug on laden ATBs

$4,300,000 2 $2,200,000 4

Untethered tug escort of laden tankers

$1,200,000 <1 $8,500,000 15

Redundant propulsion on project tankers

- - - -

‡Ratio of each cost-benefit to the lowest cost-benefit measure; provides the relative ranking of each risk reduction

measure.

Tethered tug escort of laden tankers

The risk reduction measure that provided the best return on investment was tethered tug escort of

laden tankers. Almost all of the future case tanker transits were from proposed projects, but the

measure was cost-beneficial even in the baseline traffic.

The measure had a cost / benefit of $550,000 / MT of avoided cargo oil spill risk in Case C. This

scenario assumed that the proposed projects are fully built out and exporting cargoes at the

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terminals’ maximum proposed capacities. Implemented fully, this measure could reduce the

future cargo oil spill risk by approximately 27 MT / yr at a cost of $15 million / yr. Even

assuming the baseline traffic, this measure provided the highest level of protection that can be

achieved through the use of the best achievable technology and operational methods that provide

the greatest degree of protection achievable.

Tethered tug on laden ATBs

The other risk reduction measure that met the definition of best achievable technology was

tethered tug escort of laden ATBs. All of the modeled ATB transits were in the baseline traffic.

The measure had a cost / benefit of $2.2 million / MT of avoided cargo oil spill risk in Case C.

This scenario assumed that the proposed projects are fully built out and exporting cargoes at the

terminals’ maximum proposed capacities. Implemented fully, this measure could reduce the

future cargo oil spill risk by approximately 2 MT / yr at a cost of $4.3 million / yr. This measure

provided a high level of protection for the investment.

In the Columbia River vessel traffic, ATBs did not have as deep a draft as tankers. The risk

model allows only one river lane width; it cannot be modified per vessel type. Therefore, the

width of the river was assigned considering the federal navigation channel width and draft

requirements for tankers and other vessels on the river. An ATB can operate outside the federal

navigation channel if the vessel’s master decides that it is safer to do so in a given situation.

Therefore, the benefit of the tethered escort is likely overestimated by the numerical model.

Measures that are not Best Achievable Protection

The risk reduction measure that is tied for best return on investment is a pilot on tug with laden

oil-barge-in-tow. All of the modeled tug-tow transits were in the baseline traffic. The risk

reduction offered by this measure is less than 0.5 MT / yr. Compared to the Case A risk of

11 MT / yr, the additional protection provided by the measure is small. For that reason, this

measure does not meet the definition of best achievable protection.

Untethered tug escort of laden tankers provides less risk reduction than tethered tug escort, and at

greater cost.

For this waterway, redundant propulsion on laden tankers would provide less risk reduction at

greater cost than tethered tug escort.

Columbia River Bar

For the bar, the risk reduction from potential risk controls could not be quantified in this study;

therefore, it was presumed that any effective risk reduction measure should be strongly

considered for recommendation. The BAP process for these measures was not one of balancing

the costs and benefits. Instead, the process recommended effective measures unless their costs

were a greater burden than the risk they reduced.

For the bar, the three effective measures had costs that were less of a burden than their risk

benefits, and are best achievable protection:

Making a model available to support decision making would be a clear improvement in

navigation safety on the bar. Other bars on the west coast have high-resolution forecast

models, but the Columbia River Bar has proven to be the most complex to model. If

agreements were reached between Oregon State University and the National Weather

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Service, it could cost an estimated $75,000 to relocate the current Oregon State University

model to the National Weather Service.

A land-based radar would provide coverage of the Columbia River Bar and approaches. A

rough order of magnitude estimate is a one-time investment of $40,000.

AIS transponders on barges crossing the Columbia River Bar would assure that other vessels

have a way to identify the presence of the barge. AIS on barges would be a per-barge cost of

about $5,000. Existing AIS coding guidance does not include codes for barges; implementing

this measure could involve identifying the steps necessary to modify existing U.S. and

International standards to create AIS codes specific to barges.

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References

Lower Columbia Region Harbor Safety Committee (2016). Lower Columbia Region Harbor

Safety Plan. 2016 ed.

National Oceanic and Atmospheric Administration (NOAA). (2010). “Building Relationships”

with the Marine Community. Presentation.

www.crh.noaa.gov/Image/ama/decisionsupport/2010_presentations/strobin.pptx. Accessed

February 19, 2017.

National Oceanic and Atmospheric Administration (NOAA) (2017). NWPS Significant Wave

Height (ft) and Peak Wave Direction, Hour 12, Feb 16, 2017. Website.

http://polar.ncep.noaa.gov/nwps/para/nwpsloop.php?site=PQR&cg=3. Accessed February 19,

2017.

Oregon State University (OSU) (2012). Thesis: Wave Modeling at the Mouth of the Columbia

River. Sarah Kassem. September 5, 2012. http://hdl.handle.net/1957/33838.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix K

Washington State Department of Ecology K-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix K:

Characterization of the Middle Columbia River-Snake River

Waterway System

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at:

https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Table of Contents

Page

List of Figures and Tables..............................................................................................3

Figures..................................................................................................................................3

Tables ...................................................................................................................................3

Introduction ..........................................................................................................................4

Description of the Waterway ...............................................................................................6

Overview ....................................................................................................................6

Dams and Locks .........................................................................................................6

Management of the Federal Columbia River Power System .....................................7

Role of the Columbia River Gorge Commission .......................................................8

Dredging .....................................................................................................................9

Natural Hazards ..........................................................................................................9

Description of Marine Traffic ............................................................................................10

Marine Cargo ............................................................................................................10

Ports and Infrastructure ............................................................................................12

Non-commercial Uses ..............................................................................................14

Risk Management Strategies / Resources ..........................................................................16

Operator Practices ....................................................................................................17

Pilots .........................................................................................................................18

Emergency Response Strategies / Resources .....................................................................19

Marine Incident History .....................................................................................................21

Conclusion .........................................................................................................................22

References ..........................................................................................................................23

Exhibit 1: Input from the Columbia River Gorge Commission ...................................25

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List of Figures and Tables

Figures

Page

Figure 1: Map of the Middle Columbia River-Snake River Waterway System ............................. 6

Figure 2: Typical Lock (Columbia River System Operations, 2016) ............................................. 7

Figure 3: Examples of Entities Involved in the Federal Columbia River Power System ............... 8

Figure 4: Tonnage Transiting the Locks (November 1, 2015 to October 31, 2016) .................... 11

Figure 5: Monthly Tonnage Transiting Bonneville Locks ........................................................... 11

Figure 6: Columbia River Zone 6 Tribal Fishing Access Sites (CRITFC, 2017c) ....................... 15

Tables

Page

Table 1: Cargo Transport by Commodity Group (metric tons x 1000) (BST Associates, 2017) . 12

Table 2: Cargo Ports on the Middle Columbia River-Snake River Waterway System (BST

Associates et. al, 2009) ................................................................................................................. 13

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Introduction

The main body of this report contains an evaluation and assessment of vessel traffic management

and vessel safety on the lower Columbia River as directed by the Washington Oil Transportation

Safety Act of 2015 (ESHB 1449). This appendix provides a characterization of the upriver

Columbia River system, where vessel traffic and the associated safety risks are substantially

different. The appendix describes the commercially navigable extent of the Columbia River

system east of the I-5 bridge, to the Port of Benton on the Columbia River and to the Clarkston,

Washington/Lewiston, Idaho area on the Snake River. This upriver portion of the Columbia and

Snake rivers is called the Middle Columbia River-Snake River Waterway System in this

document.

Ecology sought input from tribes, industry, and other stakeholders throughout development of

the appendix. The appendix covers the following topics:

The waterway (e.g., physical characteristics and marine hazards).

Traffic volumes, river system users (e.g., commercial, tribal, fishing, and recreational) and

commodities transported.

Marine incident history.

Navigation risk management strategies/resources.

Emergency/spill preparedness.

The Middle Columbia River-Snake River Waterway System comprises approximately 360 miles

of navigable waterway. Eight dams operate on the Middle Columbia River-Snake River

Waterway System. The dams provide irrigation and flood control, generate electricity, support

commercial navigation through locks, and create recreation opportunities. The dams also pose

obstacles that affect salmon and steelhead migration and habitat (USACE, 2016a). Navigation

past the dams on the Middle Columbia River-Snake River Waterway System is provided by

locks. The maximum under keel clearance for navigating vessels, and therefore vessel size, is

primarily limited by the sill depth at the locks.

The eight dams on the Middle Columbia River-Snake River Waterway System are part of the

Federal Columbia River Power System (FCRPS), which includes a total of 31 federally operated

multipurpose dams (Bonneville Power Administration, 2003) and the transmission system to

deliver and market electric power (Bonneville Power Administration, 2006). Management of the

FCRPS is accomplished via a complex collaborative system led by three U.S. agencies: the

Bonneville Power Administration, the U.S. Army Corps of Engineers (USACE), and the U.S.

Bureau of Reclamation.

The principal hazards to navigation in the Middle Columbia River-Snake River Waterway

System are strong winds, currents, rocks, rocky banks, and accumulation of ice. Detailed

information on locations and markers for navigation hazards is available in Coast Pilot 7

(NOAA, 2017).

Commercial traffic on the Middle Columbia River-Snake River Waterway System consists of

cargo and passenger transportation. Most of the commercial ports on the waterway are in pools

formed by the dams. Grain is the principal cargo moved on the Middle Columbia River-Snake

River Waterway System; down-bound grain shipments comprised 57% of all commodity

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tonnage moving through the Bonneville Locks from 2000-2015. Barge service also provides

refined petroleum products to inland Washington and Oregon markets, accounting for an average

of 20% of cargo movements at Bonneville.

The Middle Columbia River-Snake River Waterway System supports an abundance of

recreational opportunities, from fishing and boating to wildlife viewing and sightseeing as well

as a robust cruise boat industry.

The Confederated Tribes and Bands of the Yakama Nation, the Confederated Tribes of the

Umatilla Indian Reservation, the Confederated Tribes of Warm Springs, and the Nez Perce Tribe

have treaty-reserved rights for commercial, subsistence, and ceremonial fishing on the Columbia

River. Along with Washington and Oregon, these tribes are co-managers of the fishery and the

Upper Columbia River’s natural resources.

Risk management strategies on the Middle Columbia River-Snake River Waterway System are

much the same as those on the lower Columbia River. They include requirements for vessel

operations, aids to navigation, channel maintenance, practices of waterway operators, and

mandatory pilots for certain types of vessels.

Emergency response strategies are coordinated jointly by the U.S. Environmental Protection

Agency and the U.S. Coast Guard through the area contingency plan covering Washington,

Idaho, and Oregon. There are nine Geographic Response Plans for the Middle Columbia River-

Snake River Waterway System; each plan provides a detailed list of spill response and support

resources, and specific response strategies.

Marine incidents and oil spills to Washington waters are reported to Ecology. Ecology reviewed

vessel incident data for the Middle Columbia River from 2005-2017. There were no cargo oil

spills from vessels during this time.

This characterization does not analyze risks of cargo oil spills on the Middle Columbia River-

Snake River Waterway System, nor does it contain recommendations. All recommendations

from the CRVTSA are offered in the main report, and are specific to the Columbia River west of

the I-5 Bridge.

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Description of the Waterway

Overview

The Middle Columbia River-Snake River Waterway System comprises approximately 360 miles

of navigable waterway (Figure 1). From Lewiston, Idaho, the Snake River flows approximately

140 miles to its confluence with the Columbia River near Kennewick, Washington (NOAA,

2017). The commercially navigable portion of the Columbia River begins just north of Richland

at the Port of Benton, and extends for approximately 222 miles to the I-5 Bridge near Portland,

Oregon. The I-5 bridge is approximately 107 miles upriver of the mouth of the Columbia River.

The federally authorized shipping channel in the Middle Columbia River-Snake River Waterway

System is 27 feet deep and 300 feet wide. The channel is typically dredged to a depth of 14 to

17 feet.

Figure 1: Map of the Middle Columbia River-Snake River Waterway System1

Dams and Locks

The eight dams on the Middle Columbia River-Snake River Waterway System are part of the

Federal Columbia River Power System. The dams provide irrigation and flood control, generate

1 Adapted from USACE, 2016b.

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electricity, support commercial navigation through locks, and create recreation opportunities.

The dams also pose obstacles that affect salmon and steelhead migration and habitat (USACE,

2016a).

Navigation past the eight dams on the Middle Columbia River-Snake River Waterway System is

provided by locks (Figure 2). On the Snake River, the locks are at Ice Harbor, Lower

Monumental, Little Goose, and Lower Granite. On the Columbia River, locks are at Bonneville,

The Dalles, John Day, and McNary (NOAA, 2017). The locks lift or lower vessels an average of

100 feet relative to the lock's downstream and/or upstream entrances. The defined lower water

level of each lock gives the clearance needed for a typical barge draft of 14 feet. The depths over

the lower sills of the locks at The Dalles, John Day, and McNary Dams are typically the limiting

depth for navigation of this stretch of the Columbia River. The least sill depth in the system (at

McNary Dam) usually exceeds 12 feet at normal pool level (NOAA, 2017).

Figure 2: Typical Lock (Columbia River System Operations, 2016)

Navigating the locks requires awareness of specific hazards. For typical conditions, Coast Pilot 7

(NOAA, 2017) gives instructions on safe navigation of each lock. For changing conditions,

Notices to Mariners communicate the controlling depths for transits of the Middle Columbia

River-Snake River Waterway System.

Management of the Federal Columbia River Power System

The Federal Columbia River Power System (FCRPS) consists of 31 federally operated

multipurpose dams, including the eight dams on the Middle Columbia River-Snake River

Waterway System, and the transmission system to deliver and market electric power (Bonneville

Power Administration, 2006). Management of the FCRPS is accomplished via a complex

collaborative system led by three U.S. agencies: the Bonneville Power Administration, the

USACE, and the U.S. Bureau of Reclamation. The agencies balance the management of power

generation, protection of fish and wildlife, flood control, irrigation, navigation, and cultural

resources. The USACE operates dams, maintains the channel depths, operates the locks, and

manages water flows to ensure safe passage of vessels (33 CFR 207.718). The Bureau of

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Reclamation also operates dams within the FCRPS (Bureau of Reclamation, 2017). Bonneville

Power Administration markets the power generated from the dams and distributes power through

its transmission system (Bureau of Reclamation, 2017).

Many agencies and groups give input and oversight to FCRPS operations. Figure 3 lists some of

these entities; because of the complex jurisdictions and multiple uses of the Columbia River, a

comprehensive list of agencies, international agreements, tribes, and interest groups is beyond

the scope of this appendix.

Figure 3: Examples of Entities Involved in the Federal Columbia River Power System

Role of the Columbia River Gorge Commission

The Columbia River Gorge Commission (CRGC) was established to manage the bi-state,

292,500 acre Columbia River Gorge National Scenic Area, which was approved by Congress in

1986. The National Scenic Area covers both Oregon and Washington.

Bonneville Power AdministrationU.S. Army Corps of Engineers

Bureau of Reclamation

FEDERAL AGENCIESNational Oceanic and Atmospheric

AdministrationU.S. Fish and Wildlife Service

Bureau of Indian AffairsEnvironmental Protection Agency

U.S. Forest ServiceU.S. Geological Survey

Bureau of Land Management

Columbia River Gorge Commission

STATE AGENCIESIdaho Dept. of Fish and Game

Oregon Dept. of Fish and WildlifeWashington Dept. of Fish and Wildlife

INTEREST GROUPSEnvironmental, Fishery, and Industry

TRIBES, TRIBAL ORGANIZATIONS

Confederated Tribes and Bands of the Yakama Nation

Confederated Tribes of the Umatilla Indian Reservation

Confederated Tribes of Warm Springs

Nez Perce Tribe

Columbia River Inter-Tribal Fishing Commission

Northwest Power and Conservation Council

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The CRGC oversees all policies, rules and regulations for implementing the National Scenic

Area Act which has two purposes:

1. Protection and enhancement of the natural, cultural, recreational and scenic resources of the

National Scenic Area.

2. Supporting and enhancing economic development compatible with the first purpose. Given

that the CRGC was established as a bi-state compact agency, the Columbia River Gorge

Compact and the commission's rules and regulations are federal law, which supersede state

rules and regulation in the National Scenic Area.

The CRGC also works in consultation with the four treaty tribes with fishing rights along the

Columbia River in the National Scenic Area: the Confederated Tribes of the Warm Springs, The

Confederated Tribes of the Umatilla Indian Reservation, the Nez Perce Tribe, and the

Confederated Tribes and Bands of the Yakama Nation. Exhibit 1 provides additional information

about the CRGC.

Dredging

Deposition of sediment creates areas of shallow water that limit navigation and affect other uses

of the waterway. Dredging is the primary method to remove accumulated sediment on the

waterway, although additional measures are taken to reduce sediment deposition.

For the Snake River, the USACE is implementing a Programmatic Sediment Management Plan

for upstream of the Lower Granite Reservoir to the confluence with the Columbia River

(USACE, 2014). Additional information on the planned projects is available on the USACE

Walla Walla District website for the Programmatic Sediment Management Plan (USACE, 2014).

Natural Hazards

The principal hazards to navigation in the Middle Columbia River-Snake River Waterway

System are strong winds, currents, rocks and rocky banks, and accumulation of ice (NOAA,

2017). Detailed information on locations and markers for navigation hazards is available in Coast

Pilot 7 (NOAA, 2017).

Winds are highly variable along the route. Average monthly wind speeds range from 8 to

58 knots, with the highest winds occurring in spring and summer months. The wind generally

blows upstream in summer and downstream in winter. Between the I-5 bridge and The Dalles,

the river flows through the Columbia River Gorge in the Cascade Range, which funnels the wind

in the region. Surface winds greater than 35 knots can flow down from the gaps and passes, and

Gorge winds can exceed 60 knots (Sharp and Mass, 2003).

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Description of Marine Traffic

Marine Cargo

Marine cargo information for the Middle Columbia River-Snake River Waterway System is

available from three main sources:

A marine cargo forecast is updated every five years for the Columbia River, Puget Sound,

and Washington coast (BST Associates, 2017). The 2016 report used many data sources,

including tonnage transit data for the locks from 2000 through 2015.

Washington State University Extension recently completed a peer-reviewed study of export

trends for all of Washington State (2016).

USACE collects data on tonnage transiting through the locks on the Columbia (USACE,

2016b). This study used lock data for January 1, 2015 through October 1, 2016.

The 2016 Washington Marine Cargo Forecast provides several important summary statements

about this waterway system:

Barge transportation of grain down the river is very important to grain shippers.

The barges that currently navigate this part of the river are designed to make optimum use of

the depths of the waterway and locks.

The largest vessels on the waterway are capable of carrying 3,600 tons of grain with a draft

of 13.5 feet. (Other barges typically have a draft of ten to eleven feet.)

One year of USACE tonnage data is presented in Figure 4 for each set of locks in the Middle

Columbia River-Snake River Waterway System. The Bonneville locks, which are closest to

Vancouver/Portland, saw the most tonnage. Up-bound tonnage was less than 25% of the total

transiting tonnage.

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Figure 4: Tonnage Transiting the Locks (November 1, 2015 to October 31, 2016)

When the tonnage transiting the locks is viewed monthly (Figure 5), the cargo volumes are

relatively flat, except when the locks are closed during regularly scheduled maintenance periods

(for example in March 2015 and 2016). Figure 5 shows the tonnage passing through Bonneville

locks; the other locks show a similar monthly pattern.

Figure 5: Monthly Tonnage Transiting Bonneville Locks

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Table 1 shows the quantities of the various products transiting the Middle Columbia River. The

largest quantities are in the categories of food and farm products, followed by petroleum

products, and logs, wood chips, and other non-manufactured materials (e.g., crude materials).

Table 1: Cargo Transport by Commodity Group (metric tons x 1000) (BST Associates, 2017)

Commodity Group

Year Compound Annual Growth Rate

2000-2015 2000 2005 2010 2015

Food and Farm Products

5,812 4,696 4,454 3,391 -3.5%

Petroleum Products

1,766 1,738 1,587 1,186 -2.6%

Crude Materials 1,358 1,593 1,222 1,282 -0.4%

Other 693 488 356 475 -2.5%

Total 9,629 8,515 7,618 6,334 -2.8%

Commercial Passenger Operations

Since 2013, cruise boat traffic has steadily increased, with existing cruise lines adding more

boats, and thus more passengers. The Port of Clarkston estimates that for the full Columbia and

Snake River system, the economic benefits of the cruise boat industry are presently $6 million

per year (Stebbings, 2016).2

Ports and Infrastructure

A description of ports and types of cargo for the Middle Columbia River-Snake River Waterway

System are shown in Table 2. This list may not include all ports and facilities, or reflect changes

in operations.

2 Baseline analysis by Dr. Eric Fruits (Fruits, 2013) adjusted for current conditions.

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Table 2: Cargo Ports on the Middle Columbia River-Snake River Waterway System (BST Associates et. al, 2009)

River Mile Port Facility Commodities Shipped

Lower Granite Pool

Snake River 138 Clarkston, WA Grain, containers, logs

Snake River 135 Wilma, WA Grain, wood, cement, petroleum

Little Goose Pool

Snake River 104 Almota, WA Grain

Snake River 83 Central Ferry, WA Grain, fertilizer

Snake River 83 Garfield, WA Grain

Lower Monumental Pool

Snake River 61 Lyons Ferry, WA Grain

Ice Harbor

Snake River 38 Windust, WA Grain

Snake River 29 Sheffler, WA Grain

McNary Pool

Snake River 2 Burbank, WA Grain

Columbia River 328 Pasco, WA Petroleum, chemicals, fertilizer, plate glass

Columbia River 328 Kennewick, WA Chemicals, petroleum

Columbia River 314 Wallula, WA Grain

Columbia River 312 Port Kelley, OR Grain

Columbia River 293 Umatilla, OR Containers, logs, wood chips, general cargo

John Day Pool

Columbia River 275 Morrow, OR Grain, containers, logs, wood chips

Columbia River 240 Roosevelt, WA Grain

Columbia River 240 Arlington, OR Grain

Columbia River 278 Hogue-Warner, OR Logs, wood chips, general cargo

The Dalles Pool

Columbia River 208 Biggs, OR Grain

Bonneville Pool

Columbia River 190 The Dalles, OR Wood chips, grain

Columbia River 190 Klickitat, WA Lumber, grain, aggregate

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Non-commercial Uses

Non-commercial activities on the Middle Columbia River-Snake River Waterway System

include tribal uses and recreation.

Tribal Uses

The Confederated Tribes and Bands of the Yakama Nation, the Confederated Tribes of the

Umatilla Indian Reservation, the Confederated Tribes of Warm Springs, and the Nez Perce Tribe

are the four federally recognized tribes with treaty-reserved rights for commercial, subsistence,

and ceremonial fishing on this part of the Columbia River (Yakama Nation, 2017; Cayuse –

Umatilla – Walla Walla, 2017; Warm Springs Nation, 2017; Columbia River Inter-Tribal Fish

Commission, 2017a). Along with Washington and Oregon, these tribes are co-managers of the

fishery and are co-managers of the Upper Columbia River’s natural resources.

Tribal uses of the ecosystem include fishing for salmon and other fish species, and hunting,

gathering, and harvesting of natural resources for income and physical and spiritual sustenance

(Columbia River Inter-Tribal Fish Commission [CRITFC], 2017b). The Department of the

Interior has defined 31 fishing access sites on the Columbia River between Bonneville Dam and

McNary Dam (Public Law 100-581, 1988). The sites are managed by CRITFC for fishers from

these four member tribes. Of the 31 sites, 20 are on the Washington side of the Columbia River

(Figure 6). The U.S. Congress set aside these sites to provide fishing access to tribal fishers

whose traditional fishing grounds were inundated by the Columbia River dams. The sites are

culturally significant to the treaty tribes – they are at or near traditional villages or fishing

locations on the Columbia River (CRITFC, 2017b). Tribal fishers use the access sites to gather,

camp, and access fishing sites by boat.

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Figure 6: Columbia River Zone 6 Tribal Fishing Access Sites (CRITFC, 2017c)

Recreational Uses

The primary recreational uses of the Middle Columbia River-Snake River Waterway System

include:

Fishing.

Swimming.

Windsurfing, kayaking, rafting, etc.

Wildlife viewing.

Sightseeing.

Boating.

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Risk Management Strategies / Resources

In general, the regulatory environment and services that exist on the lower Columbia River are

also in place on the Middle Columbia River-Snake River Waterway System. These include:

The U.S. Coast Guard protects the maritime economy and the environment, defends the

maritime borders, and rescues those in peril (U.S. Coast Guard, 2017). The missions of the

Coast Guard are:

o Ports, waterways, and coastal security.

o Drug interdiction.

o Aids to navigation.

o Search and rescue.

o Living marine resources.

o Marine safety.

o Defense readiness.

o Migrant interdiction.

o Marine environmental protection.

o Ice operations.

o Other law enforcement.

The USACE maintains safe and reliable channels, harbors, and waterways for the

transportation of commerce, support to national security and recreation (USACE, 2017).

The Washington Department of Ecology Spill Prevention, Preparedness, and Response

Program focuses on preventing oil spills to Washington’s waters and land, and planning for

and delivering a rapid, aggressive, and well-coordinated response to oil and hazardous

substance spills wherever they occur (Ecology, 2016). The program works with communities,

industry, state and federal agencies, tribes, and other partners to prevent and prepare for oil

spills. The program also responds to spills 24/7 from six offices located throughout the state

and works to assess and restore environmental damage resulting from spills. Spills Program

activity includes:

o Preventing oil spills from vessels and oil handling facilities.

o Preparing for aggressive response to oil and hazardous material spills.

o Rapidly responding to and cleaning up oil and hazardous material incidents.

o Restoring public natural resources damaged by oil spills.

The role of the Oregon Department of Environmental Quality (DEQ) in prevention, response,

and mitigation of oil and hazardous materials cleanup includes actively responding to oil

spills on a round-the-clock basis (DEQ, 2017). DEQ initiates communications with local,

tribal, state and federal partners and industry to commence a timely and coordinated

response. The DEQ:

o Works to develop oil spill response plans, train staff, and conduct exercises to

confirm successful execution of plans.

o Develops plans that identify sensitive natural or cultural resources and specific

response strategies to minimize impacts to these resources. Plans have been

developed for the Columbia River.

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o Coordinates with other local and state agencies, federal partners and industry to

cleanup oil and hazardous material spills.

o Develops policy to ensure spill response planning and preparedness activities occur

inland to address risks of increased oil transport.

Operator Practices

Waterway users play a significant role in assuring safe management of navigation and

environmental hazards. Towing and barge companies use safety management systems, and most

of the companies that operate on the Middle Columbia River / Snake River participate in the

American Waterway Operators Responsible Carrier Program (RCP). The RCP is a safety

management system for tugboat, towboat, and barge companies that provides a framework for

continuously improving their safety performance. The RCP incorporates best industry practices in

three areas: company management policies, vessel equipment, and human fctors. The program

requires companies to undergo an audit by an independent third party auditor to verify compliance.

When two different companies are involved in transportation of cargo, which is usually the case,

their safety management systems typically require a vetting process. Vetting consists of a review

of safety management and vessel operational practices. Vetting is a standard best practice to

ensure that:

The terminal and barge comply with rules, regulations, and accepted industry practices for

safety, environmental protection, and operational procedures.

The terminal and barge meets federal, state and local government compliance as well as

terminal and company specific requirements.

The barge can safely berth, load or unload, and depart.

Operators on the Middle Columbia River-Snake River Waterway System have also implemented

additional controls. While these vary between companies, examples include (Konz, 2017):

Apprentice Deck Mechanic Training Program. Apprenticeship program for new hire Deck

Mechanics. The program includes classroom training and on the job training with an

experienced Deck Mechanic trainer. New hires are evaluated by trainers and must meet the

program’s requirements before they can work as a Deck Mechanic.

Mate Training Program. New Boat Operators must first sail as a Mate and go through a

training program before they can stand their own watch. The program includes classroom

training and on the job training with an experienced tug Captain trainer. Mates are evaluated

by trainers and meet the program’s requirements, including a “check ride” with a Port

Captain, before they can work as a Boat Operator.

Pilot House Alert System. Motion sensors in the pilot house send alerts after a period of time

if no movement is detected from the Boat Operator. The motion sensors are tied to the tug’s

general alarm, which will alert the crew if the Boat Operator becomes non-responsive.

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Communication with USACE. Examples of regular communications include, but are not

limited to, the following:

o Daily communication with reservoir control for updates on items such as flows

coming out of the dams.

o Routine communication on dam spillway patterns. Reviewing and providing input

into changes to spillway patterns at dams.

o Attendance at Portland and Walla Districts Fall and Spring Navigation Meetings.

Pilots

Pilots exercise independent professional judgment and act as a risk control for the vessels they

serve. In the U.S., two types of pilot licenses exist: state and federal. The Oregon Board of

Maritime Pilots provides oversight for the Columbia River and Columbia River Bar. The

Columbia River pilotage grounds include the navigable portion of the Columbia River and the

Willamette River. The U.S. Coast Guard administers vessel manning, federal pilotage, and

licensing of mariners for navigation and marine engineering for U.S. vessels sailing U.S. waters

to include the Columbia River.

Whether a vessel on the Middle Columbia River-Snake River Waterway System requires a state

pilot, federal pilot, or other appropriate federal mariner depends on the country of registry and

the type of trade the vessel is engaged in. All vessels operate under the control of licensed vessel

masters/mates/operators whether a pilot is embarked or not. Each vessel engaged in international

trade (sailing on registry), whether foreign or U.S. flag, must take a state pilot (ORS 776.405).

Each U.S.-flag vessel on a coastal transit (enrolled) must take a pilot with a federal pilot license

issued by the U.S. Coast Guard (46 U.S.C. 8502) or based on federal manning standards to meet

the licensing requirements for the route.

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Emergency Response Strategies / Resources

Planning, preparedness, and response actions for oil and hazardous substance incidents on the

Middle Columbia River-Snake River Waterway System are conducted by the Region 10

Regional Response Team and the Northwest Area Committee. (Region 10 Regional Response

Team, 2017a).

Membership in the Regional Response Team and Northwest Area Committee includes:

U.S. Coast Guard Sector Puget Sound.

U.S. Coast Guard Sector Columbia River.

U.S. Environmental Protection Agency Region 10.

Washington State Department of Ecology.

Oregon Department of Environmental Quality.

Idaho Office of Emergency Management.

National Oceanic and Atmospheric Administration (Department of Commerce).

Department of the Interior.

Other federal agencies, including the U.S. Fish and Wildlife Service, U.S. Navy, U.S. Food

and Drug Administration.

Other state agencies, including the Oregon State Public Health Officer, Oregon State Fire

Marshal, Washington Department of Health, Washington Military Department Division of

Emergency Management, Idaho Department of Environmental Quality, and Idaho

Department of Health and Welfare.

Local government agencies.

Tribes.

Nongovernmental organizations.

Industry.

Response contractors.

As defined in federal and state regulations, the Northwest Area Committee is an interagency

committee charged with planning and preparedness for oil spills. The Area Committee maintains

the Northwest Area Contingency Plan, which covers Washington, Idaho, and Oregon, and

contains instructions, tools, manuals, contacts, guidance, practices, and available resources.

Within the plan, regional Geographic Response Plans are available to local, state, Tribal, and

federal agencies to use as a guide in minimizing the impacts from oil. The geographic plans

provide direction for federal and state on-scene coordinators during the intial phase , from the

time a spill occurs until a Unified Command is established.

Nine Geographic Response Plans (GRPs) cover the Middle Columbia River-Snake River

Waterway System:

Lower Columbia River GRP.

Four Middle Columbia River GRPs:

o Bonneville Pool.

o The Dalles Pool.

o John Day Pool.

o McNary Pool.

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Four Snake River GRPs:

o Ice Harbor Pool.

o Little Goose Pool.

o Lower Granite Pool.

o Lower Monumental Pool.

Included in each plan is a detailed list of resources, including agencies, response contractors, site

information, and response strategies.

The U.S. Coast Guard is the pre-designated Federal On-Scene Coordinator for a response to a

marine pollution incident below the Bonneville Dam. Above the Bonneville Dam, the U.S.

Environmental Protection Agency is the pre-designated Federal On-Scene Coordinator for a

response to a marine pollution incident (Region 10 Regional Response Team, 2017b). The Coast

Guard keeps all other regulatory authorities above the Bonneville Dam.

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Marine Incident History

Ecology reviewed vessel incident data for incidents, accidents, and spills occurring on the

Middle Columbia River from 2005 to 2017. There were no cargo oil spills from vessels during

this time.

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Conclusion

Commercial navigation on the Middle Columbia River-Snake River Waterway System can be

characterized by the effects of the eight dams and locks, and the movement of cargo by tug and

barge. Grain from upriver accounts for a substantial part of the grain exports from ports on the

Lower Columbia River (BST Associates, 2017). Barges also transport refined petroleum

products for inland Washington and Oregon markets. Seasonal river flow, and the effects of the

dams and locks on both river flow and water levels, directly affect navigation.

Additional, unique aspects of the Middle Columbia River-Snake River Waterway System include

the role of tribes as trustees and co-managers of the regions resources, and the management

structures for the Federal Columbia River Power System and the Columbia Gorge National

Scenic Area.

Risk management strategies on the Middle Columbia River-Snake River Waterway System are

largely the same as on the lower Columbia River. Federal government agencies, the two states,

and industry operators all contribute to reducing the risk of accidents and spills on the river.

Ecology reviewed vessel incident data for incidents, accidents, and spills occurring on the

Middle Columbia River from 2005 to 2017. There were no cargo oil spills from vessels during

this time.

Emergency response plans are in place at the federal, regional, and local levels, and are

purposefully interrelated to assist with efficient response should an event occur.

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References

Bonneville Power Administration (2003). Federal Columbia River Power System.

https://www.bpa.gov/power/pg/fcrps_brochure_17x11.pdf. Accessed February 6, 2017.

Bonneville Power Administration (2006). Federal Columbia River Power System Definition List.

https://www.bpa.gov/power/pgf/fcrps_definitions.shtml. Website. Accessed February 6, 2017.

BST Associates (2017). Washington State Marine Cargo Forecast Draft Report. Prepared for

Washington Public Ports Association and The Washington State Freight Mobility Strategic

Investment Board. Prepared by BST Associates. January 22, 2017.

BST Associates, IHS Global Insight, and Mainline Management, Inc. (2009). 2009 Marine

Cargo Forecast: Technical Report. Prepared for Washington Public Ports Association and

Washington State Department of Transportation. March 23, 2009.

Bureau of Reclamation (2017). Reclamation: Managing Water in the West: Pacific Northwest

Region – Federal Columbia River Power System Biological Opinion Hydrosystem. Website.

https://www.usbr.gov/pn/fcrps/hydro/. Accessed February 6, 2017.

Cayuse – Umatilla – Walla Walla (2017). Confederated Tribes of the Umatilla Indian

Reservation. Treaty of 1855. Website. http://ctuir.org/treaty-1855. Accessed February 6, 2017.

Columbia River Inter-Tribal Fish Commission (CRITFC) (2017a). Treaty with the Nez Perces,

1855. http://www.critfc.org/member_tribes_overview/nez-perce-tribe/treaty-with-the-nez-perces-

1855/. Accessed February 6, 2017.

Columbia River Inter-Tribal Fish Commission (CRITFC) (2017b). Tribes & Culture. Website.

http://www.critfc.org/. Accessed February 2, 2017.

Columbia River Inter-Tribal Fish Commission (CRITFC) (2017c). Columbia River Zone 6.

Website. http://www.critfc.org/about-us/columbia-river-zone-6/. Accessed February 6, 2017.

Columbia River System Operations (2016). Navigation. Poster. Rev 2.

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Fruits, Eric (2013). Letter from Eric Fruits to U.S. Army Corps of Engineers, Walla Walla

District. Response to Comments Submitted by American Rivers et al., and Ernie Niemi on the

Draft Environmental Impact Statement. August 9, 2013.

Konz, David (2017). Email communication to Scott Ferguson, Brian Kirk, and Karen Phillips.

Tidewater’s Input for the Upper River Characterization. January 24, 2017.

National Oceanic and Atmospheric Administration (NOAA) (2017). United States Coast Pilot 7,

Pacific Coast: California, Oregon, Washington, Hawaii, and Pacific Islands. U.S. Department of

Commerce, National Oceanic and Atmospheric Administration and National Ocean Service. 49th

Edition. March 5, 2017.

Oregon Department of Environmental Quality (DEQ) (2017). Emergency Response. Website.

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Response.aspx. Accessed February 22, 2017.

Public Law 100-581, 1988. Title 1 – Indian Reorganization Act Amendments.

http://treatiesportal.unl.edu/indianaffairsvetoes/pdf/PV2465.04.pdf.

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Region 10 Regional Response Team and the Northwest Area Committee (2017a). Regional

Response Team Mission Statement. Website. http://www.rrt10nwac.com// Accessed February 22,

2017.

Region 10 Regional Response Team and the Northwest Area Committee (2017b). Northwest

Area Contingency Plan. January 1, 2017.

http://www.rrt10nwac.com/Files/NWACP/2017/Chapter%201000%20v18.pdf. Accessed March

6, 2017.

Sharp, Justin and Clifford F. Mass (2003). Columbia Gorge GapWinds: Their Climatological

Influence and Synoptic Evolution. University of Washington. December 17, 2003. Rev. May 4,

2004.

Stebbings, Heather (2016). Email communication to Brian Kirk. RE: Washington State

Department of Ecology, Columbia River Vessel Traffic Evaluation and Safety Risk Assessment

(CRVTSA). December 21, 2016.

U.S. Army Corps of Engineers (USACE) (2014). Regional Sediment Management Program,

Portland District (NWP): Lower Columbia River – Regional Sediment Management Plan,

Oregon. December 2015.

U.S. Army Corps of Engineers (USACE) (2016a). Northwestern Division: Columbia River Basin

Dams. Webpage. http://www.nwd.usace.army.mil/Media/Fact-Sheets/Fact-Sheet-Article-

View/Article/475820/columbia-river-basin-dams/. Accessed December 15, 2016.

U.S. Army Corps of Engineers (USACE) (2016b). Lock Performance Monitoring System, Data

Web Services. Data accessed for: Columbia River Locks 1, 2, 3, and 24. January 2015 through

October 2016. http://corpslocks.usace.army.mil/lpwb/f?p=121:7:0. Accessed November 3, 2016.

U.S. Army Corps of Engineers (USACE), Portland District (2017). Navigation. Website.

http://www.nwp.usace.army.mil/Missions/Navigation/. Accessed March 6, 2017.

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http://www.overview.uscg.mil/Missions/. Accessed March 6, 2017.

Warm Springs Nation (2017). Treaty of 1855. https://warmsprings-nsn.gov/treaty-

documents/treaty-of-1855/. Accessed February 6, 2017.

Washington Department of Ecology (2016). Spill Prevention, Preparedness and Response

Program. 2015-2017 Program Plan. 2016 Update.

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Andrew J. Cassey, Associate Professor, School of Economic Sciences, Community and

Economic Development Extension, Washington State University, Jeremy Sage, Washington

State University.

Yakama Nation (2017). Yakama National History. Yakama Nation Treaty of 1855. June 9, 1855

12 Stat., 951. Ratified Mar. 8, 1859. Proclaimed Apr. 18, 1859. http://www.yakamanation-

nsn.gov/treaty.php. Accessed February 6, 2017.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix K

Washington State Department of Ecology K-25 Publication No. 17-08-010

Exhibit 1: Input from the Columbia River Gorge Commission

The below submission was received from the Columbia River Gorge Commission during

CRVTSA stakeholder and Tribal engagement activities (CRGC, 2016).

The spectacularly beautiful Columbia River Gorge

National Scenic Area (NSA) stretches 85 miles and

includes portions of three Oregon and three

Washington counties. Formed by ancient volcanoes

and sculpted by incredible floods, the Columbia River

Gorge carves an impressive corridor through the

Cascade Mountains in Oregon and Washington as the

great Columbia River flows to the Pacific Ocean. As

the only sea-level route from the Great Basin to the

Pacific Ocean, the Columbia River Gorge is a land of

contrasts. The western Gorge, with an average annual

rainfall of 75 inches, is a place of misty mountains,

rich forestlands and more waterfalls than any area in

the country. The eastern Gorge, with an annual rainfall

of less than 15 inches, is a place of rim-rock bluffs,

rolling hills, farms and ranchlands. The Columbia

River Gorge is renowned for its extraordinary beauty,

cultural resources and geologic history. The Gorge's

scenic resources span a diverse array of landscapes

including rain forests, rolling farmlands and semi-arid

grasslands. Cultural resources, epitomized by the Indian petroglyph “She Who Watches,” trace a

human history in the Gorge that is 10,000 years old. They include prehistoric sites and historic

structures. Natural resources include wildlife, plants, streams, lakes, wetlands and riparian

corridors that are found in abundance throughout the National Scenic Area. And then there is

recreation . . . The National Scenic Area is known worldwide for the variety and quality of

recreational opportunities: windsurfing, hiking, fishing, mountain biking, kayaking, kiteboarding,

and rafting on the two wild and scenic rivers—the Klickitat and White Salmon Rivers in

Washington.

The National Scenic Area is categorized into three areas: Special Management Areas, General

Management Area, and Urban Areas.

Special Management Areas cover approximately 114,600 acres and contain some of the

Gorge’s most sensitive resources. Special Management Areas are managed by the U.S. Forest

Service National Scenic Area Office in Hood River, Oregon.

Although the management plan

covers the 292,500 acres of

shoreline, air quality, aquatic and

terrestrial resources within the NSA,

and is not specific to the Columbia

River itself, any accidents involving

vessels transporting hazardous cargo

on the Columbia River could

significantly impact NSA resources

and violate the NSA Act. It is critical

that any risk assessments and risk

reduction measures developed for

the portion of the Columbia River

that lies upstream and within the

NSA, consider the higher levels of

protections needed to reduce

possible impacts and comply with

the NSA.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix K

Washington State Department of Ecology K-26 Publication No. 17-08-010

The General Management Area covers approximately 149,400 acres of land and all of the

Columbia River – which contain a mixture of land uses including farming, logging, cattle

grazing, public recreation and rural residential uses. Development on private lands is

administered by Columbia River Gorge counties and the Gorge Commission in Klickitat County,

Washington. Development on Federal lands is reviewed by the U.S. Forest Service National

Scenic Area Office.

Thirteen Urban Areas are exempt from Scenic Area regulations: Cascade Locks, Hood River,

Mosier and The Dalles in Oregon, and North Bonneville, Stevenson, Carson, Home Valley,

White Salmon, Bingen, Lyle, Dallesport and Wishram in Washington. Lands held in trust by the

Bureau of Indian Affairs are also exempt from National Scenic Area regulation.

Congress called for the preparation of the Management Plan for the Columbia River Gorge

National Scenic Area (Management Plan) to ensure that land in the National Scenic Area is used

consistently with the purposes and standards of the National Scenic Area Act. The Gorge

Commission and Forest Service must revise the management plan at least every 10 years. The

Gorge Commission and Forest Service adopted the management plan in 1991 with input from

Indian tribal governments, county and city governments, state and federal agencies, citizens, and

non-governmental organizations. In 2004, the agencies completed the first 10-year revision. The

Gorge Commission may amend the management plan between revisions if it finds that

conditions in the National Scenic Area have significantly changed. The Secretary of Agriculture

must concur with revisions and amendments to the management plan. The management plan

contains the land use and resource protection standards, non-regulatory programs, and actions for

protecting and enhancing Columbia River Gorge resources, as well as a description of roles and

relationships of governments and agencies responsible for implementation of the National Scenic

Area Act. The Forest Service develops the land use regulations for federal land and land in the

“special management areas.” The Gorge Commission develops the land use regulations for the

general management area. The management plan does not directly apply to the 13 urban areas.

Additional information is available at www.gorgecommission.org.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix L

Washington State Department of Ecology L-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix L:

Marine Fuel Spills

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at:

https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix L

Washington State Department of Ecology L-2 Publication No. 17-08-010

Introduction

This appendix provides a high-level view of fuel spill risk on the Columbia River from the vessel

(e.g., tugs, cargo ships, etc.) and incident types (e.g., grounding, collision, etc.) evaluated in the

CRVSTA. Many smaller vessels sail the waterway and would contribute to the fuel spill risk.

Background

The Department of Ecology, the U.S. Coast Guard, and the Oregon Department of

Environmental Quality keep records of marine fuel spills on the river, but the systems are not

designed to easily distinguish between ship-source fuel spills and other fuel spills. An analysis of

the historical data was beyond the scope of this evaluation. It is evident, however, that marine

fuel spills occur every year on the Columbia River. See, for example, past incidents in U.S.

Coast Guard’s Marine Information for Safety and Law Enforcement database.1 Most of these

fuel spills involve smaller vessels and are the result of transfer/refueling errors or mechanical

failure of transfer equipment, rather than the incident types modeled for this evaluation.

Because the focus of the Columbia River Vessel Traffic Evaluation and Safety Assessment

(CRVTSA) is on cargo oil spills, the model was not structured to precisely estimate the

frequency of fuel spills; however, the model can provide an approximation of what fuel spill

risks would be from the modeled incident types. The MARCS model was designed to estimate

marine incidents and cargo spills. Therefore, the model is much more sophisticated in its

estimates of cargo spill risk than for fuel spill risk.

To obtain a high-level estimate of fuel spill risk, the following assumptions were made based on

DNV GL expert judgement and knowledge gained from past projects:

Assumption 1 – The quantity of fuel oil onboard is assumed to be about 5% of the deadweight

tonnage. For individual vessel types, this provides a low level of detail. However, when the

vessel estimates are combined for the entire study area for all vessel types, the results average to

a reasonable result. The same incident frequency model was used for fuel oil spills as was used

for cargo oil spills. For vessels that carry oil cargoes, the fuel spill risk is less than 5% of the

cargo risk, with the exact percentage dependent on the probability curves utilized – but only for

the oil cargo vessels. All other vessel types carry fuel. Therefore, they contribute to fuel spill risk

even though they do not contribute to cargo spill risk.

Assumption 2 – The marine incidents that could lead to fuel spills are the same incidents that

could lead to cargo spills. However, the likelihood that a tank will be breached is higher for fuel

tanks than for cargo tanks, because in the global fleet, fuel tanks are less protected from external

damage.

1 https://homeport.uscg.mil/mycg/portal/ep/editorialSearch.do

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix L

Washington State Department of Ecology L-3 Publication No. 17-08-010

The high-level approach to fuel spill risk in this report does not account for:

Newer Vessels. Vessels contracted to be built August 2007 or after, or vessels that were

delivered August 2010 or after (IMO, 2003). These vessels are required to meet MARPOL

Annex I 12A and therefore have protected fuel tanks.

Hull Damage Location. The most likely locations of grounding and collision damage on the

hull given the waterway and vessel traffic characteristics.

Fuel Tank Location. Relative percentage of the hull potentially exposed to external damage

that is protecting fuel tanks. Cargo tanks typically lie behind 50 to 80 percent of the sides of a

ship, and are often not located at the fore of the ship. Fuel tanks can be located at the fore of

the ship, but are small in comparison to the ship length.

Results

This broad-view approach likely overestimates fuel spill risk from the vessels in the CRVTSA

traffic. For Case C (baseline traffic plus 100% of vessel traffic from proposed projects), the

estimated fuel oil spill risk for the Columbia River is 561 gal/yr assuming a density of 0.94 kg/L

at 15°C.

Figure 1 shows the fuel spill risk contribution from each vessel type. The list of vessel types is in

Appendix F, Study Basis. The contributions are proportional to the number of miles sailed in the

year of AIS data. The simple approach used in this rough estimate assumes each vessel on the

river has equivalent protection for its fuel tanks, which is not strictly true, but provides a

conservative basis on which to derive the estimate.

The analyzed incident types that cause fuel spills are drift grounding, powered grounding, and

collision. This analysis used the same approach that was used to estimate the frequency for

scenarios leading to cargo spills, including:

A large number of scenarios was modeled (about 750,000).

Sailing conditions such as proximity to rocks and density of vessel traffic affect whether a

scenario is likely to result in a spill.

As a result, the fuel risk profile for each vessel type is unique, demonstrated by the varying

relative heights of the bands of color for each vessel type.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix L

Washington State Department of Ecology L-4 Publication No. 17-08-010

Figure 1: Estimated Fuel Spill Risk per Vessel Type

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix L

Washington State Department of Ecology L-5 Publication No. 17-08-010

Fuel Spill Risk Conclusions

Taken together with the baseline safety information, this high-level review of fuel spill risk

concludes:

1. A sufficient number of fuel spill accidents has occurred on the river that the existing

historical data are probably sufficient to support identification of key risk contributors.

2. Significant effort would be needed to parse and verify the available data to quantify fuel spill

risk and identify potential risk reduction measures.

3. If a model were preferred over data analysis, a sophisticated model would need to be

developed to identify risk drivers and support risk reduction decisions.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix L

Washington State Department of Ecology L-6 Publication No. 17-08-010

References

International Maritime Organization (IMO) (2003). International Convention for the Prevention

of Pollution from Ships (MARPOL). MARPOL 73/78 Annex I 12 A – Oil fuel tank protection.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix M

Washington State Department of Ecology M-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix M:

Oil by Rail

November 2017 Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually

impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html. Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech

disability may call TTY at 877-833-6341.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix M

Washington State Department of Ecology M-2 Publication No. 17-08-010

Analysis

Oil is transported to the areas around the Columbia River and Bar by vessel, pipeline, or train. It is either used by a consumer or shipped to another location. The majority of the CRVTSA report focuses on oil transported by tank vessel. This appendix focuses on oil transported by rail in tank cars. This appendix presents an estimate of the volume of crude oil rail transshipment operations within the Columbia River for the study area beginning five miles seaward of the Columbia River Bar to the I-5 bridge. It also describes any current and proposed crude oil rail-to-vessel transfers. No documented rail-vessel transfers have occurred in the study area since 2015. The crude-by-rail facility owned by Global Partners at Port Westward stopped shipping crude oil in 2015 and began receiving ethanol by rail in mid-2016. It is possible the facility could begin receiving oil by rail again in the future. NuStar and Tesoro (existing terminals in Vancouver) also have rail access, but oil by rail is not being transshipped from these facilities at this time. Vancouver Energy Terminal, proposed by Tesoro Savage Joint Venture, awaits a decision to deny or approve the terminal from the Governor of Washington. If approved, up to 360,000 barrels (bbl) per day of crude would be brought in by rail, loaded on ships, and sailed downriver and across the Columbia River Bar (Energy Facility Site Evaluation Council, 2016). Ecology’s 2014 Marine and Rail Oil Transportation Study provides baseline information about rail transport of crude in Washington. It identified potential growth based on proposed projects and lagging indicators. More recent data on crude oil by rail in Washington is available in the quarterly reports published by Ecology for crude oil movements by rail and pipeline (State of Washington, 2017a and 2017b). The quarterly reports summarize crude oil received by rail in Washington or moved via pipeline, and crude oil spills related to rail and pipeline transportation. The data from that report show an average of about 1.0 million barrels (43 million gallons) of oil is received in Washington every week.

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Washington State Department of Ecology M-3 Publication No. 17-08-010

Figure 1: Oil Received by Rail in Washington (State of Washington, 2017a/b)

More than ninety percent of it is light crude originating in North Dakota. It is very likely that most of it arrives at refineries in northern Washington. The report does not provide summary information on whether the shipments arrived at facilities on the Columbia River.

-

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

40 42 44 46 48 50 52 1 3 5 7 9 11 13

Volu

me (

bbl)

Calendar Week in 2016 and 2017

4-week Moving Avg

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix M

Washington State Department of Ecology M-4 Publication No. 17-08-010

References

Energy Facility Site Evaluation Council (2016). Tesoro Savage Vancouver Energy Project. Application No. 2013-01. http://www.efsec.wa.gov/Tesoro%20Savage/SEPA%20-%20DEIS/DEIS%20PAGE.shtml. Accessed January 27, 2017. State of Washington (2017a). Crude Oil Movement by Rail and Pipeline, Quarterly Report: October 1, 2016 to December 31, 2016. Department of Ecology. Publication no. 17-08-002. Revised February 2017. State of Washington (2017b). Crude Oil Movement by Rail and Pipeline, Quarterly Report: January 1, 2017 to March 31, 2017. Department of Ecology. Publication no. 17-08-12. April 2017.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix N

Washington State Department of Ecology N-1 Publication No. 17-08-010

Report to the Legislature on Columbia River Vessel Traffic Evaluation and

Safety Assessment (CRVTSA)

Appendix N:

Considerations Regarding Escort Tug Capabilities

November 2017

Supplement to Publication No. 17-08-010

This appendix is linked as a supplementary document to the report at: https://fortress.wa.gov/ecy/publications/SummaryPages/1708010.html

To request ADA accommodation for disabilities, or printed materials in a format for the visually impaired, call Ecology at 360-407-7455 or visit http://www.ecy.wa.gov/accessibility.html.

Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech disability may call TTY at 877-833-6341.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix N

Washington State Department of Ecology N-2 Publication No. 17-08-010

Table of Contents

Page

Introduction ..........................................................................................................................3

Columbia River Tug Escort Guidelines .....................................................................3

Tug Requirements ......................................................................................................4

Tanker Requirements .................................................................................................5

References ............................................................................................................................6

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix N

Washington State Department of Ecology N-3 Publication No. 17-08-010

Introduction

The risk assessment results show that tethered tug escort would be the most cost-effective risk reduction measure for cargo oil spills from tankers. Tug escort is required in an increasing number of ports, including in the U.S., Europe, and Australia. The primary goal of a tug escort is to reduce the risk of pollution from a grounding of a tank vessel. This is most effective when the initiating event is a failure of the tanker’s steerage or propulsion. Therefore, this study does not suggest that tethered tug escort is a useful risk reduction measure for tankers with fully redundant steering and fully redundant propulsion as defined in 33 CFR 157.03.

This section focuses on the Columbia River, which has relatively calm waters. The Columbia River Bar is a more complex, open environment. Additional towing force may be required on the bar due to the increased wave height and complex currents on the bar that are not present in the river. Additional study is required to determine best practices to ensure safe passage of oil tankers across the Columbia River Bar. This study is not suggesting requirements for any tanker to have a tethered or escort tug while crossing the bar prior to further study and resulting recommendations.

Tethered tug escort is a multi-faceted activity. Global best practices in tethered tug escort cover a range of aspects:

1. Waterway-specific tug escort guidelines. The procedures and requirements are written and agreed to in advance. They assure a common foundational understanding of the process, and reduce the likelihood of miscommunication, misalignment, and human error.

2. Requirements for the towing vessel. Tug capabilities to prevent a disabled tanker from grounding are specified for a range of tanker sizes.

3. Requirements for the tanker. The tanker equipment and equipment certifications (e.g., strengthened bitts that are tested on a regular basis) help ensure it can safely be controlled by the tug, including maximum age of the vessel.

4. Cargo owner (charterer) requirements. In addition to equipment, other aspects of the tanker and its operation must be in place to assure a safe intervention could occur if it were needed. These include minimum manning/experience requirements for the vessels and management system standards.

Columbia River Tug Escort Guidelines

Consistent with what has been done in other waterways, the Harbor Safety Committee could develop and adopt tug escort guidelines that define practices for safe tug escort of laden oil tankers on the Columbia River. The guidelines ideally should cover a wide range of topics such as:

• Communications. • Exchange of information between the vessel master(s) and pilot. • Contents of a towing plan. • Preparations.

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix N

Washington State Department of Ecology N-4 Publication No. 17-08-010

• Connecting. • Safe speed. • Guidelines for pilots and masters. • Visibility. • Escort training requirements (ideally using full mission tug simulators). • Tug manning. • Tug capabilities (such as braking force, bollard pull, and drive type).

Experts such as pilots, terminal operators, naval architects, and simulation modelers can provide technical input to such plans.

A guideline specific to the Columbia River can help to assure best practice is implemented safely. In addition, it could reduce errors during the initial implementation of tug escorts. This section does not intend to limit decisions made by the tanker’s master, or the state or federal pilot concerning safe navigation.

Tug Requirements

This section offers general guidance for tug requirements, which could be considered in the development of Columbia River Tug Escort Guidelines. Based on a review of several simulations studies, tug capabilities for escorting 50,000 to 80,000 DWT tankers could include:

• Tug delivers a minimum of 80 tons bollard pull. • Preferred tethering of tug escort is stern tow. • Towing equipment meets Classification Society requirements. • Tug can generate the braking forces in Table 1 (assumes a maximum tanker displacement is

50,000 to 80,000 DWT) (taken from 14 CCR 851.9 Tanker and Tug Matching Criteria and Tanker Crew and Equipment Requirements).

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Columbia River Vessel Traffic Evaluation and Safety Assessment Appendix N

Washington State Department of Ecology N-5 Publication No. 17-08-010

Table 1: Suggested Interim Braking Force Guidelines1

Assisting Current Tug Braking Force

(tons)

Slack 23

1 kt 32

2 kt 41

3 kt 54

4 kt 64

Tanker Requirements

Tanker connections (and those on the tug) should be able to withstand the forces that could be placed on them during an emergency. It is important to pair the escort tug and tanker to assure their capabilities are matched. Tanker requirements for tethered tug escort can be covered in the Tug Escort Guidelines described above, with input from existing standards such as:

• U.S. Coast Guard rules for towing vessels (e.g., 46 CFR Subchapter M, Part 138). • International Maritime Organization recommendations for towing equipment (IMO, 2005). • Oil Companies International Marine Forum recommendations for towing fittings (OCIMF,

2002).2

1 Taken from tug matrix developed by Glosten; maximum tanker displacement is 50,000 to 80,000 DWT because of the depth of the navigable channel (The Glosten Associates, Inc. and Maritime Simulation Center Netherlands, 1995). 2 Note the OCIMF standards were developed for tows in calm waters like the Columbia River. However, for the bar, the OCIMF standards should be reviewed by relevant experts to determine if sea state affects required tug capabilities.

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Washington State Department of Ecology N-6 Publication No. 17-08-010

References

International Maritime Organization (IMO) (2005). Guidance on Shipboard Towing and Mooring Equipment. MSC/Circ. 1175. May 24, 2005. Ref. T4/3.01.

Oil Companies International Marine Forum (OCIMF) (2002). Recommendations for Ships' Fittings for Use with Tugs: With Particular Reference to Escorting Other High Load Operations. January 2002.

The Glosten Associates and Maritime Simulation Center Netherlands. (1995). Tanker Escort-Requirements, Assessments and Validation. J. Society of Naval Architects and Marine Engineers. No. 14. Shridar Jagannathan, David Gray, Thomas Mathai, and Johann deJong. 1995.