From Executive Director Mark Swanson:
The safe transportation of oil requires that the industry plan extensively for spill prevention and response. Beyond planning, extensive practice of the tactics described in the plans help verify that these spill response plans will work as written.
Drills and exercises conducted today are many and varied. These drills test different federal and state requirements. Some are aimed at maintaining proficiency, others verify response capabilities and strategies, or marine firefighting or salvage plans.
With so many drills and exercises, surely there must be an opportunity to combine drills for the needs of both shippers and regulators for cost savings and efficiency, particularly in Alaska, where companies often share the same response contractors, equipment, and plans, without sacrificing preparedness.
Drills and exercises in Prince William Sound
The Oil Pollution Act of 1990 requires the companies shipping North Slope crude oil out of Valdez to have a common spill response plan. Separate drills are conducted for the Valdez Marine Terminal and associated tankers, even when the same response contractor is used, because they have different plans. Alyeska, who operates the Valdez Marine Terminal, and the Prince William Sound shippers share an oil spill response organization: the Ship Escort/Response Vessel System, or SERVS. SERVS is responsible for initiating a spill response in an emergency. Both the State of Alaska and the federal government require at least one table top exercise and one field deployment exercise at the Valdez Marine Terminal every year. Some years there are more. SERVS conducts tanker towing exercises and numerous other field deployments each year. The Prince William Sound shipping companies take turns conducting a major response exercise each year.
The shipping companies send observers to each other’s exercises. Even though these companies bring their own corporate incident management teams, they are working from the Prince William Sound tanker contingency plan with the same equipment and performance expectations. This is a pretty efficient way to do business.
In most states outside of Alaska, these oil shipping companies and terminals have their own independent plans and must run their own independent exercises.
Looking for overlapping responsibilities for further efficiencies
Separate oil spill contingency plans are maintained by the federal government, regional and state agencies, and local industries. Local plans must conform to regional and state area plans, which in turn must conform to the national contingency plans.
The higher level national and regional area plans are less specific but contain valuable guidance on key matters such as how to engage and incorporate the concerns and resources of local communities and stakeholders, common geographic response strategies, spill response resources, the process for selecting potential ports of refuge, and how to deal with cultural and historical sites. They also, at least in Alaska, speak to the public expectations of transparency with the dissemination of incident information and sharing of incident action plans.
Much can be learned by observing the exercises that test these higher level plans. When one industry planholder conducts a drill, neighboring facilities and communities may learn from the principal player’s incident management team for combined benefit. This can mean valuable exposure to the guidance of the federal and state on scene coordinators and agency resource trustees that attend these exercises. Oil spill response organizations can hugely benefit from observing their colleagues and counterparts during drills.
Are there situations where we might not want to combine efforts?
There are other situations where the inclusion of other plan holders and neighboring communities doesn’t make much sense. Some exercises test plans for unique locations or a specific uncommon risk. There are facility-specific issues that may be of little instructive value for companies with dissimilar operations. It’s probably not appropriate for an outsider to observe an exercise that is being conducted to test a specific concern about a previous failure to demonstrate the ability to implement their plan effectively. There are some major elements unique to Alaskan plans. For instance, a drill to test the 400 plus fishing vessels that annually train with SERVS and remain ready to provide response to a crude oil spill may not be of interest to a company without such vessels.
Drills and exercises are expensive and take a lot of staff and time. So are spills and spill responses with equipment and responders that are not prepared and ready to work. While there are logical limits to what should be combined for drill credit purposes, and there are clearly opportunities for shippers to learn from each other, we must still verify that all responders are fully trained and have the capability and equipment to respond effectively. Let’s make sure we get the most from all of these efforts without reducing their ability to respond to an oil spill.
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