Preparedness and Response (OSEPR) Subcommittee Update

Transcription

1 API Oil Spill & Emergency Preparedness and Response (OSEPR) Subcommittee Update Greg DeMarco March 11, 2015 Outline Joint Industry Projects Overview API Joint Industry Task Force (JITF) Recap Background Completed Work Ongoing Work Other Subcommittee Activities Subpart J Impressions External Engagement Confident Ambassador Program Path Forward 1

2 Joint Industry Projects Overview API JITF formed initially, followed by IOGP/IPIECA JIP and separately, Arctic JIP Multi year programs and progress on track Initial API and IOGP-IPIECA JIPs approaching completion Close collaboration between JIPs High levels of Industry commitment remain Complete JITF work program Pursue broader API mandate Execute IOGP/IPIECA JIP Phase 2 Key themes and deliverables Assessing and demonstrating current Industry OSR capabilities and priorities for improvement Promoting use of all response tools, ideally on a pre approved basis Emphasis on NEBA and selection of appropriate p tools to minimize environmental impact Education, communication materials, external influence Fact sheets on dispersants and in-situ burning Complete refresh of Industry Good Practice Guides Development of scan/glance materials for key influencing topics Developing new and improving existing tools and technologies Subsea dispersants, surveillance, common operating picture, Arctic/cold weather tools API Joint Industry Task Force Websites Contain Completed Deliverables API-JITF OGP/IPIECA JIP Bulk of remaining API JITF work focused on Dispersants and In-Situ Burning 2

3 Ongoing JITF Project Activity Recommended Practice on Offshore OSR Plans progressing well Consensus document emerging Extensive government representation Draft RP expected in 2Q Dispersants Subsea Injection (Effectiveness, Fate & Effects, Modeling, Monitoring) Stakeholder engagement (GOMRI, JIP) In-Situ Burning Igniter Enhancement Soil Heating Tests ISB Guidelines for Operations, Safety/IH, Selection & Training Shoreline Protection Mechanized Clean-Up of Sand Beaches Phase 3 Subsurface Oil Detection 5 Other Subcommittee Activities Review and comment on emerging regulation/guidelines ERSP Subpart J PREP Guidelines OSRO Guidelines (Inland, Group V oils) Inland Response Crude By Rail Development and delivery of safety course for first responders Sharing information/practices Recommended Practice for Pipeline Emergency Response Addresses planning, communications, training, exercises, sharing learnings Extensive government representation Draft RP is out for comment Study on Spill Behavior and Response for Oil Sands Derived Crude Oils Sunken Oil Detection and Recovery: Response Guide Options for Minimizing Environmental Impacts of Inland Spill Response Formation of Midstream Group Communications and Outreach ongoing (JIP, SAG, GOMRI, Conferences) 6 3

4 Concerns Re: Subpart J NPRM 1. Severely restricts/eliminates an important response option from the toolbox Arbitrary toxicity and effectiveness thresholds Complex and onerous pre-authorization pathway 2. Promotes bias that dispersants are toxic will only heighten public apprehension 3. Lacks NEBA perspective (minimize harm to the environment) and favors protecting the water column species at the expense of other shared values (shorelines, fishing, beaches) 4. Hampers/weakens/limits long-standing role of the FOSC in operational decision-making 5. Is inconsistent with polices in other parts of the government (USCG, BSEE) 6. Fails to quantify the true costs of taking dispersants out of the toolbox Market impacts (lost value of stocks, equipment, services) Costs of additional environmental damages that could result without this tool 7 External Engagement Industry supported Scan and Glance materials on key topics are enabling improved advocacy efforts Oil Spill Preparedness and Response Framework view animation at JIP link Net Environmental Benefit Analysis (NEBA) Role of Dispersants in Oil Spill Response Tiered Preparedness and Response Framework Incident Management System (e.g. ICS) Regulatory Approval and Use of Dispersants OGP-IPIECA and API outreach programs Utilizing existing Industry vehicles Confident Ambassador Program Expand pool of active Industry and responder supporters 4

5 Confident Ambassador Key OSR Principles Prevention is a basic design and operational goal for industry. Source control is a crucial part of prevention. Equipment + people + planning + training + exercising + review = response capability. Operators should have effective and deliverable contingency plans, up to and including the worst credible case discharge. Plans must have detailed, executable components that can be translated into a physical spill response capability. Net Environmental Benefit Analysis (NEBA) should be used to select response options that will result in the least overall damage to the environment. As time is of the essence following a spill, pre-authorization of response tools and tactics is paramount. Key OSR Principles (Continued) Picture an evolving response as a cone : use the most effective tool first to knock down the most oil before it gets away think big and quick. For a large offshore spill, NEBA will often support the use of dispersants The Tiered Response Concept (i.e. cascading resources) remains the preferred approach for ensuring adequate resources are quickly available. Oils behave differently: know your oil properties and behavior as these dictate response strategy decisions in a given situation. An Incident Management System based on Incident Command System (ICS) principles is the preferred tool for organizing a response. Even the best planned and executed response will be judged to have failed if stakeholder communications are poor. 5

6 Path Forward Complete JITF committments (coastal/offshore spills) Improve inland spill response capabilites Active stakeholder engagement Continue parternship with other OSR programs/initiatives Maintain Industry s commitment to enhancing Oil Spill Preparedness and Response 6