Changes in the United States Response Scheme
After the EXXON VALDEZ Incident 1
By
Captain Harlan Henderson
CommanderU. S. Coast Guard
National Strike Force
1461 North Road Street
Elizabeth City, NC 27909

ABSTRACTThis March marks the 12th year a nniversary of the EXXON VALDEZ oil spill. As a result of thevessel grounding, over 258,000 barrels of crude oil spilled into the pristine environment ofPrince William Sound, Alaska. The spill impacted one of our nation’s most sensitive ecosystems
and resulted in the largest and longest oil spill response in U. S. history. The spill also generated
more media and public interest, both nationally and internationally, than any previous U. S. spill.
The United States Congress responded with the unanimous passage of the Oil Pollution Act of1990 (OPA 90) which fundamentally changed this nation’s prevention, preparedness andresponse scheme.
This paper will outline the changes brought about as a result of OPA 90, but will primarily focus
on three key areas:(1) Response Management with the adoption of the Incident Command System 2 (ICS),(2) Preparedness through the National Preparedness for Response Exercise Program(PREP), and(3) Research and Development with emphasis on a new Viscous Oil Pumping System(VOPS).

1Opinions or assertions in this paper are solely those of the author and do not necessarily represent the views of theUnited States Coast Guard.
2In this paper, the term Incident Command System (ICS) is used to denote the National Interagency IncidentManagement System (NIIMS) based ICS.

Introduction
Twelve years ago on March 24, 1989, the tanker EXXON VALDEZ grounded on Bligh Reef inpristine Prince William Sound, Alaska spilling over 258,000 barrels of crude oil. The oil
impacted over 1,100 miles of non-continuous coastline making the EXXON VALDEZ incident
the largest spill to date in U. S. waters. The response and cleanup also involved more people andequipment than any other spill in U. S. history. At the peak of the response, over 11,000
personnel, 1,400 vessels, and 85 aircraft were involved. The oil impacted one of this nation’s
most sensitive ecosystems which included a national forest, four national wildlife refuges, threenational parks, five state parks, four state critical habitat areas, and a state game sanctuary. Thetoll on marine wildlife included over 300 harbor seals, 2,800 sea otters, and 250,000 birds.
The EXXON VALDEZ oil spill generated more media and public interest, both at the national
and international level, than any other spill in U. S. history. The U. S. Congress responded withthe unanimous passage of the Oil Pollution Act of 1990 (OPA 90). This single law is the mostcomprehensive legislation that the U. S. Coast Guard has ever had to implement. OPA 90
fundamentally changed spill prevention, prepare dness and response in the United States. The
requirements of OPA 90 are divided into five categories:
PREVENTIONPREPAREDNESSRESPONSE
LIABILITY AND COMPENSATIONRESEARCH AND DEVELOPMENT
I will provide a short overview of the key provisions of the Act and follow that with a moredetailed discussion of three areas where significant improvements have been made to allow thisnation to more efficiently and effectively respond to spills. These areas include responsemanagement, exercises, and a very promising research and development project for pumping
viscous oils.

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OPA 90 OVERVIEW 1
PREVENTION
Double hull requirements for tank vessels.
By 2015 all tank vessels must meet double hull specifications.
Operational measures to reduce oil spills from existing single – hull tank vessels.
Includes bridge resources management training, minimum rest
requirements for watchstanders, and enhanced vessel surveys.
Access to National Driver’s Register and Criminal Records Review.
Permits Coast Guard to review these records prior to issuing or renewing a
Merchant Mariner’s license or document.
Enhancements to civil and criminal penalty provisions.
Permits Coast Guard to take appropriate legal action against polluters.
PREPAREDNESSArea Committees and Area Contingency Plans.
Requires formation of response plans tailored specifically to areas that
could be effected by oil spills.
Vessel and Facility Response Plan.
Requires certain tank vessels and oil facilities to develop response plans toenhance private sector planning and capabilities to minimize the impactof spilled oil.
National Exercise Program.
In order to exercise the various new contingency plans, the Preparedness
for Response Exercise Program (PREP) was established. The Coast
Guard conducts six government-led exercises a year.
RESPONSEResponse Management System.
Established guidelines for creating a unified command that can coordinate
multiple federal, state, local, and industry responders.
National Strike Force.
A third Strike Team was re-established and the National Strike ForceCoordination Center (NSFCC) was established to coordinate the activitiesof the three teams.
LIABILITY AND COMPENSATION
National Pollution Fund Center.
Established to manage the billion dollar oil spill liability trust fund which
is used to fund spill responses, compensate claimants, fund environmental
assessments, and recover costs from responsible parties.
Financial Responsibility for Pollution.
Vessel owners or operators must establish and maintain evidence ofadequate insurance.
RESEARCH AND DEVELOPMENT (R&D)
Over 30 initiatives have been funded by the Coast Guard.
The Coast Guard has funded over 30 initiatives for oil spill prevention andresponse.

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More details on OPA 90 requirements can be obtained at www.nrt.org

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RESPONSE MANAGEMENT SYSTEM:The U. S. Coast Guard’s decision in 1996 to formally adopt the Incident Command System as
the standard response management system to oil spills as arguably the most significant initiative
to improve the United States ability to effectively and efficiently manage a spill response.
Whenever a spill occurs, the common goal is to mount a timely, effective, and efficient response
in order to protect human life and safety, and to minimize impact to the environment and theeconomy. Common sense dictates tha t all stakeholders, which includes the U. S. Coast Guard,
other federal agencies, the affected state and local governments, and the responsible party, canbest achieve this by working together cooperatively. While the U. S. National Oil andHazardous Substance Pollution Contingency Plan (NCP) recognized the need for a responsemanagement structure that allowed all stakeholders to work together, prior to EXXON VALDEZ,
no national standard response management system was in use.
WHY ICS?
The EXXON VALDEZ incident highlighted many of the problems frequently encounteredduring a spill which included different organizational structures among the various responsegroups, non-standard terminology, ineffective communications among agencies, poor joint
planning and information gathering and dissemination, and lack of accountability.
ICS is simply a model that allows all stakeholders to work together under a single organizationalstructure. ICS incorporates the sound principles of modern business management into auniversally accepted and proven response management system. The basic components include:
a.
b.
c.
d.
e.
f.
g.
h.

Common terminology
Modular organization (which can easily expand or contract)
Integrated communications
Unified Command structure
Consolidated action plans
Manageable span of control
Pre-designated incident facilities
Comprehensive resource management

To implement these components, the ICS structure has five functional areas of responsibility:
Command, Planning, Operations, Logistics, and Finance. Each of these functional areas may
sub-divide into additional organizational elements as the response dictates. These functional
areas transcend boundaries and, therefore, can be implemented for all types of incidents.
Although ICS works very well when managing an incident wholly within an organization, it isespecially useful when responding with different organizations. For this reason, the key
underlying principle of the system is flexibility. The “all risk, all hazard” model can be used torespond to any contingency including natural disasters (earthquakes, hurricanes), accidents(airplane crashes, train derailments, search and rescues), and planned events (major athleticevents, parades).

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The public domain aspect of ICS is important in that all the training and qualification material isreadily available at a low cost. This increases accessibility and encourages implementation by
the many different organizations that need to respond to the same incident.
Today the Coast Guard has adopted ICS as the response ma nagement system for “all risk, allhazards”. Further, ICS has been adopted by many other federal, state, and local agencies as wellas industry. ICS is also rapidly growing international acceptance.
PREPAREDNESS FOR RESPONSE EXERCISE PROGRAM (PREP):
With the enactment of OPA 90, the federal government needed to establish a workable exercise
program to validate the new contingency plans that were mandated. A valuable lesson from
EXXON VALDEZ was the need to exercise for a spill as realistically as possible. ThePreparedness for Response Exercise Program (PREP) was developed to meet that goal.
PREP exercises should be viewed as an opportunity for planholders to make continuous
improvements to their response plans and their response system. Planholders can use issues thatarise during the evaluation of the exercise to make necessary changes to their response plans tomaintain the highest level of preparedness.
Every three years, all components of the entire response plan must be exercised. Rather thanrequiring each plan holder to conduct a major exercise every three years, PREP allows for theindividual components to be exercised in portions through the required exercises. While the plan
may be exercised in segments over a period of three years, each component of the response plan
must be exercised at least once in the triennial cycle. PREP is comprised of a series of internaland external exercises.
Internal exercises are those that are conducted wholly within the planholders organization.
While the internal exercises include personnel such as the Qualified Individual, the Spill
Management Team, and those affiliated with the Oil Spill Removal Organization (OSRO), theinternal exercises usually do not involve other members of the response communit y. Theseinternal exercises are designed to examine the various components of the response plan to ensure
the plan is adequate to meet the needs of the organization for spill response. All internal
exercises should be self-evaluated and self -certified.
External exercises are exercises that extend beyond the internal focus of the plan holder’sorganization and involve other members of the response community. The external exercises aredesigned to examine the response plan and the plan holder’s ability to coordinate with theresponse community to conduct an effective response to a pollution incident. The key to theseexternal exercises is the area exercises.
The primary purpose of the area exercise is to activate and observe the response infrastructure ina given area, and the ability of the entire response community to effectively conduct a spillresponse. An area is defined as that geographic area for which a separate and distinct Area
Contingency Plan (ACP) has been prepared as described in OPA 90. These areas generally
correspond to our field units Area of Responsibility (AOR). For example, we have an ACP for5

Hawaii and one for Guam. The focus of the area exercise is on the interaction between theresponsible party and the federal, state, and local governments and other stakeholders to exercise
both the Area Contingency Plan and the responsible party’s plan.
PREP calls for 17 area exercises per year nationwide, 51 within the triennial cycle. This ensuresthat all areas of the country are exercised triennially. The federal government leads six of theseannual area exercises, and industry response planholders lead 11.
PREP area exercises offer a wide range of flexibility on incident types, and actual length ofexercise play. Area exercises can var y from an eight-hour, real-time tabletop exercise, that
focuses on the formation of a Unified Command and those initial response activities which occur
in the early hours of a response, to a 12 - 36 hour, real-time exercise, which includes actual
equipment deployments and shift changes. An industry planholder that participates in an area
exercise is not required to participate in another area exercise for a minimum of six years.
Area exercises are designed and developed by a joint design team. The joint design team iscomprised of representatives from the federal, state, and local governments, industry players, andother stakeholders in the response community. The organization that holds the primary plan tobe exercised will take the lead on the joint de sign team, and has the final word on designing thescope of the exercise. However, exercises are designed as a cooperative effort of the entire joint
design team.
Once an area exercise has been conducted, an evaluation report is completed to document thelessons learned and the recommended improvements to the respective contingency plans. It isincumbent on the planholders to incorporate these changes into their plans.
Planholders may take credit for internal and external exercises for those actions conducted inresponse to an actual spill. The plan holder must determine which of the exercise objectives
were completed as part of the actual response, and the spill response must be evaluated.
To ensure preparedness for an incident the size of the EXXON VALDEZ, the Coast Guard has
developed processes and procedures to conduct a Spill of National Significance (SONS) exercise
periodically. Two SONS exercises have been held, and the next one is scheduled for the springof 2002.
A SONS is a rare, catastrophic spill that greatly exceeds the capabilities of the response
community at the local and regional level. They are generally characterized as:(1) Spills which affect more than one Area Contingency Planholder or crossinternational borders;(2) Involve a significant impact, or threat, to public health and welfare, wildlife,
economy or property;(3) Have a protracted period of discharge and/or expected cleanup;(4) Generate significant public concern and demand for action;(5) And, if there is the existence of, or potential for, a high level of political or media
interest.

6As a result of OPA 90, the federal government revised its national level planning andorganization to be capable of responding to any size spill including a SONS. The periodic
cooperative exercising of the national, regional and local response agencies and organizations
ensures a continued level of preparedness for the next spill incident.

RESEARCH AND DEVELOPMENT:The Coast Guard is a leader in cooperative research and development efforts, actively working
with other federal agencies, industry, and research partners from abroad to share resources for
R&D projects. Since the passage of OPA 90, the Coast Guard has funded over 30 new initiatives.
As federal spending decreases, these cooperative efforts become even more important.
Significant improvements have been made in response equipment since the EXXON VALDEZ
incident, such as fast current booms and vessel of opportunity skimming systems as well as
better use of computer simulation and training programs. However, we are now on the verge ofa major breakthrough for the age -old problem of how to effectively pump viscous oil. The basic
problem with pumping viscous oil is that pump flow rates were too low and the line pressure wastoo high, and exceeds the pressure rating of the fittings. Several recent high visibility cases
highlighted these problems and again very clearly point the need to improve existing pumping
equipment to achieve the capability of removing viscous oil.
Vessel groundings in the United States such as the tank barge MORRIS BERMAN (1994), thefreight vessel KUROSHIMA (1997), and the freight vessel NEW CARISSA (1999) are just afew recent examples where pumping off viscous oil presented a major challenge. As a result of
these cases, a unique partnership was established to try and resolve the problem. A team of
Coast Guard, Navy, industry and equipment manufacturers met in September 1999 to shareexperiences and technology. The outcome of this workshop was the development of a prototype
viscous oil pumping system (VOPS) based on the Annular Water Injection (AWI) method.
The core of the system is a water injection annulus flange mounted on the discharge side of aDESMI: DOP 250, DS-250 OR DOP-160 screw pump. The ring is stainless steel with two oneinch pipe connections for water injection ports. The annulus delivers a small amount of water(approximately 5% if the oil flow) at high pressure of about 220 psi to surround the oil stream
moving through the hose and largely eliminates the friction between the oil and the hose
allowing much thicker oil to be pumped greater distances without hose failure or overpressurization at the pump. A water “ring” is created which reduces the friction between thehighly viscous oil and the pipe or hose wall and thereby reduces the high pressure to the system
historically incurred during viscous oil lightering operations. The concept was to inject a
relatively small volume of water through a specially-designed flange at the discharge side of apump. The flange causes the water to form a thin layer that coats the inside wall of the hose orpipe. The thin film tends to lubricate the flow of fluid and greatly reduce line pressures.
Significant findings from the first workshop were validated and expanded upon during a followon workshop held in November 1999. The prototype VOPS was successful in reducing
discharge head pressure by ratios of greater than 10:1, and enabling viscous oil to be pushed

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longer distances without increasing the quantity or size of the discharge pumps. This system wastested again in the fall of 2000 in the North Slope of Alaska with great success. Altogether, threeworkshops and an exercise were held to share information on how best to lighter viscous oil andprovide hands -on training and experience that will lead to major improvements in the Coast
Guard, Navy, and industry salvage, lightering and viscous oil pumping capabilities and readiness.
Currently, each of the three Coast Guard National Strike Force Strike Teams have a VOPS ininventory ready to be used for future viscous oil lightering events.
Further tests of this system, through partnership between industry and government, are planned
to improve VOPS capability, as it applies to overall vessel salvage and pollution abatement. The
cooperative effort that led to this promising new response technology is yet another example ofimprovements to response capabilities as a result of a major incident.

CONCLUSION:
The passage of the Oil Pollution Act of 1990 has had a profound, positive effect in improving
this nation’s prevention, preparedness and response posture for oil spills. This comprehensive
legislation mandated a wide range of measures directly geared towards preventing spills andbetter protection of the environment.
As a measure of success since the passage of OPA 90:•Both the number and volume of oil spilled has declined significantly in the U. S.. TheUnited States preparedness for oil spills is at on all time high.

•The adoption of the Inc ident Command System is a key reason for this increased
preparedness level by providing the framework to coordinate all responders under oneorganization.

•Through the various contingency plans required under OPA-90, we have further
increased our preparedness. However, the only viable way of knowing if our plans willwork is to exercise them. The Preparedness for Response Exercise Program (PREP) is adynamic program that achieves that goal.

•Research and development along with strong partnerships have led to advancements inoil spill technology and prevention. The latest project with the Viscous Oil Pumping
System (VOPS) is a prime example of how working together to address a problem can
led to, at least in this case, what looks to be a major break through is response capability.

While we have made positive strides in preventing pollution, we must not rest on our laurels.
We must continue to identify areas for improvement, implement promising ideas, and build
future partners.

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