RECENT ACTIVITIES OF ITOPF
THE ‘AMORGOS’ INCIDENT AND CONSIDERATION OF NEBA
By
Dr. Karen Purnell, ITOPF

Since the beginning of 2001, ITOPF has attended 17 significant oil spills bringing thetotal to some 459 in 85 different countries. Interestingly, a la rge number of the recent
incidents have occurred in the Asia-Pacific region.

Learning from previous oil spill experiences is very important if predictions are to bemade about the possible outcome of following a particular response strategy in theaftermath of a new incident. Choosing the most appropriate spill response option involves
careful balancing of the advantages and disadvantages to minimise damage to sensitiveenvironmental and economic resources. Some sectors of the oil spill response community
have sought to formalise this process and have called it Net Environmental Benefit
Analysis (NEBA). Although the principles upon which NEBA is based are fundamentallysound and, indeed, are nothing new, this simple process of evaluating suitable response
strategies is in danger of becoming unnecessarily complex.

Two incidents that occurred in 2001 have been chosen for discussion during thispresentation as they provide good examples of the difficult choices that sometimes haveto be made in the interest of protecting resources that have been identified as having ahigh priority. They also demonstrate the importance of having well prepared contingency
plans in which these difficult decisions have already been considered hence, reducing thechance of conflict and delays in the response.

Some lessons learnt from previous

incidents will also be presented to illustrate the importance of transferring these lessons
from one incident to another.

PAJ OIL SPILL INTERNATIONAL SYMPOSIUM 2002 - RECENT ACTIVITIES OF ITOPF______________________________________________________________________________________INTRODUCTION
Learning from previous oil spill experiences is very important if predictions are to bemade about the possible outcomes of following a particular response strategy in theaftermath of a new incident. Fortunately, major incidents, like the ‘ERIKA’ do not occur
often. Nevertheless, regular occurrences of smaller oil spills worldwide ensure that agreat deal of information and knowledge continues to accumulate.

Net Environmental Benefit Analysis (NEBA) has been seen by some as a means of‘calculating’ the benefits obtained by choosing one response option over another.
Consequently, the basic principle of NEBA is in danger of becoming theoretical andunnecessarily complicated. In simple terms, NEBA is a means of utilising the experience
gained from previous oil spills to make sensible decisions regarding the response whilst
taking into account the importance of social, economic and environmental factors.

In this paper the incidents attended by ITOPF since the beginning of last year are briefly
reviewed. The incidents are categorised according to their cause, type of ship, oil spilt,
and location so as to highlight the interesting points. The lessons learned following the‘AMORGOS’ incident in Taiwan are used to illustrate the practical application of NEBA
during spill response.

RECENT INCIDENTS ATTENDED BY ITOPF

Since the beginning of last year, ITOPF has attended seventeen significant oil spills. The
busiest months were January, May and September, which between them, accounted forabout two thirds of the spills. Half resulted from ships grounding and about a third werecaused by collisions. A smaller number of oil spills resulted from hull or equipment
failure, human error and an explosion followed by sinking. Tankers accounted for ten of
the incidents and non-tankers accounted for seven. However, it is interesting to note that
only one incident involved a spill of crude oil. Intermediate fuel oil or heavy fuel oil(either being carried as fuel or as cargo) accounted for three-quarters of the spills. The
remainder were spills of non-persistent oils, such as gasoline. It is also pertinent to note______________________________________________________________________________________
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that a large number of the incidents took place in the Asia-Pacific region (Taiwan, Korea,
Japan, China, Vietnam, Thailand). One of these incidents involved the iron ore carrier,
M.V. ‘AMORGOS’.

TAIWAN – THE ‘AMORGOS’

The M.V. ‘AMORGOS’ (65,205 DWT) was en-route to northern China from India
carrying a cargo of about 60,000 tonnes of iron ore when she lost power and groundedthabout one nautical mile from the southern tip of Taiwan on 14 January 2001. Because of
the dangerous weather conditions at the time of the grounding, it was not possible forsalvors to remove the fuel oil before the ship began to break up. During the night of theth

18 January about 1,000 tonnes of IFO 180 spilled from the fuel tanks. While some ofthis oil dissipated at sea, much of it stranded along approximately 4 kilometres offossilised coral shoreline within the Kenting National Park.

The Kenting National Park extends over some 32,631 hectares of land and sea andincludes an ‘IUCN Category V’ protected area. This area is defined as being managed
mainly for landscape or seascape conservation and recreation. The protected area isprimarily terrestrial and is recognised as being an area of distinct character withsignificant aesthetic, ecological and/or cultural value, and often with high biologicaldiversity. Although, some conflicting practices are tolerated within the protected area,
entry to the shoreline by tourists is restricted and is mainly confined to educational visits.

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PAJ OIL SPILL INTERNATIONAL SYMPOSIUM 2002 - RECENT ACTIVITIES OF ITOPF______________________________________________________________________________________MANAGEMENT OF THE RESPONSE
Once oil has spilt, decisions on the most appropriate response need to be made quickly.
These decisions are made more easily if they have been considered before an oil spill
actually occurs. Although no contingency plan existed for responding to an oil spill in thePark, recently enacted legislation identified the Taiwanese Environmental Protection
Authority (EPA) as having the ultimate responsibility for matters relating to an oil spill.
The legislation called for the owner of the ship causing the pollution to initiate theresponse, in the first instance. The EPA is expected to take over if the owner is unable orunwilling to do this.

The ‘AMORGOS’ grounded at the start of the Chinese New Year celebrations making it
difficult for the ship owner to initiate a response. However, eventually a hybrid systemdeveloped in which the incident was managed by the Taiwanese EPA utilising the
shipowner’s contractors assisted by ITOPF’s technical guidance.

RESPONSE OFF-SHORE

Given the extreme weather conditions brought on by the northeast monsoons, there waslittle that could be done in the way of shoreline protection or response at sea. Booms
deployed against the shoreline by China Petroleum Corporation required constantmaintenance and were eventually destroyed by the strong winds and seas. The remotelocation coupled with heavy sea swells also precluded the use of offshore recovery
vessels. Nevertheless, as a possible contingency measure, the use of chemical dispersants
was considered.

NEBA has been described as the practice of weighing up the advantages anddisadvantages of different response options and comparing them with the benefits ofnatural processes {IPIECA, (2000)}. The deliberations involved in making the decision
to use dispersants are a good example of NEBA in practice. Of primary concern were thecoral reefs. The reefs in the Kenting National Park are of national and international
importance for the conservation of terrestrial and marine biodiversity and for scientific______________________________________________________________________________________
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research, as well as tourism {UNEP-IUCN (1988)}. The most important coral reefs arelocated inside Nan Wan Bay where it is more sheltered, rather than along the exposed
eastern shoreline where the ‘AMORGOS’ had grounded. Nevertheless, the potentiallydamaging effects of chemically dispersed oil on the coral in the area needed to bebalanced against the consequences of allowing the oil to strand on the shoreline.

During the first few days of the incident, the extent of coral coverage in the immediate
vicinity of the ship was not known. Given this uncertainty and the known sensitivity ofcoral to chemically dispersed oil, it was decided that dispersants would not be used.
However, after a few days, dive surveys revealed that the coral cover around the‘AMORGOS’ was less than 5% and was better defined as a ‘hardground community’.
Thus, chemical dispersants were accepted as an appropriate response to fresh oil offshore provided that the dispersed oil plume was unlikely to travel into the near -shore area
where the coral cover was higher, reaching about 85%.

Contingency plans were put in place to prepare to treat the oil using locally available
dispersants. Although no spraying capability previously existed, a temporary spray boom
was constructed using bamboo poles and spray nozzles. This was mounted at the front of
the boat and, when tested with water, was found to very effective. In practice, however,the location of the ship relative to the shoreline and the harsh environmental conditions
meant that the spilled oil stranded before any offshore response could be mounted.
Although, the spray booms were maintained as a contingency in case some oil remaining
in the tanks escaped, chemical dispersants were not actually used.

SHORELINE CLEAN UP – BULK OIL REMOVALThe ultimate aim of choosing a particular response option is to mimimise damage to theenvironment and socio-economic resources. Obviously and where possible, careful
removal of heavy or moderate concentrations of oil will, with few exceptions, provide a
net environmental benefit by reducing the time for recovery.

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Following the break up of the ‘AMORGOS’, heavy concentrations of oil accumulated in
the deep channels along the shoreline. Oil had also been thrown over the fossilised coralrock up to 70 metres from the shore following a storm that occurred a few days after the
initial stranding.

The Taiwanese authorities divided the shoreline clean up operation into three phases:
Phase I) bulk oil removal, Phase II) removal of residual oil and debris, and Phase III)
monitoring of the recovery of the marine environment. At the peak of the clean up, theworkforce reached 1,500 and for long periods averaged 400.

The hostile conditions and remote area where the oil had stranded made clean up
particularly difficult. No vehicular access to the shoreline was possible and much of theclean up was carried out manually using the Taiwanese army with assistance from local
villagers. Walking and carrying equipment was made treacherous by the deep channels
and jagged coral rocks and it was necessary to construct a wooden walkway, which
eventually, extended over most of the 4 kilometres of oiled shoreline. This wasconstructed above the high water level to minimise damage to the marine fauna and florain the inter-tidal area. Only small, lightweight and robust equipment could be used, as
this had to be manually carried from the top of the cliff to the place where it was needed.
Bulk oil was removed using buckets and then moved along a human chain to temporarystorage barrels. The oil was then filtered and moved to ‘staging areas’ at the base of thecliffs. Portable generators placed at strategic locations enabled pumps to be run in series
to transfer the oil from the staging areas into more drums and barrels at the top of the cliff.
From here, the oil was transported off-site to China Petroleum Corporation’s facilities in
Kaohsiung for re-processing. By the end of phase I of the clean up, some 600 barrels and3almost 400 drums (representing about 535m of oil) had been filled and taken for reprocessing.

A further complication was the vast quantity of oiled driftwood that needed to be
removed from the channels and shoreline. This was very labour intensive work which
involved using human chains again to transport the piles of wood to a track that had been______________________________________________________________________________________
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widened to allow a tracked excavator to gain access to the back of the shoreline.
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Eventually some 3,800m of oiled driftwood was collected. In attempt to reduce thevolume of waste for disposal, some of this wood was chipped and small amounts wereused to prevent the walkway from becoming slippery following rainfalls. The remainder
was transported to a local incinerator.

SHORELINE CLEAN UP – SECONDARY OIL REMOVAL

The final stages of the clean up are frequently the most difficult. Whilst it is easy to agree
that heavy accumulations of oil should be removed, deciding ‘how clean is clean’ and,thus, when to stop is more difficult. This is because the decision will involve striking abalance between the environmental and socio-economic concerns. Unless these concerns
have been expressed and addressed in a contingency plan prior to an oil spill occurring,
conflicts frequently arise as each party attempts to satisfy their different priorities during
the incident when emotions, naturally, run high.

The application of NEBA may assist in these situations. Trying to determine the mostbalanced approach will require taking into account the circumstances of the incident, thepracticalities of the clean up, scientific understanding of the relative impacts of the oiland clean up options, and a value judgement of the relative importance of the social,economic and environmental factors {IPIECA (2000)}. Valuable lessons have been learnt
about the effectiveness and consequences of different oil spill clean up methods fromprevious incidents and are well documented. These experiences allows oil spill
responders to predict the likely outcome of their choice of clean up method, comparedwith natural processes, and should be used to assist in achieving this balance of priorities.

Recognising the importance and sensitivity of the oiled shoreline within the Kenting
National Park, ITOPF endeavored to assist the Taiwanese authorities to achieve thedelicate balance between the desire to remove as much oil as possible and the need toprotect the vulnerable inter-tidal area from aggressive clean up measures. Arguably, once
the heavy accumulations of oil had been removed, the shoreline could have been left to______________________________________________________________________________________
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clean naturally, especially given the exposed nature of the shoreline. Experience frommany oil spills has shown that natural cleaning is not only the most effective option, butalso the least damaging. However, the shoreline is also a tourist attraction and the
Taiwanese authorities were reluctant to wait for the thick deposits of oil that had becometrapped in the pitted rock to be removed naturally. Part of the NEBA process involves
accepting that, whatever clean up option is chosen, it is not always possible to avoid all of
the disadvantages. In accepting that some degree of secondary cleaning was required, it
was necessary for the Taiwanese authorities to accept that some ‘trade-offs’ would also
have to be made.

It was relatively easy to agree that shoreline cleaning agents would not achieve a net
environmental benefit even if it would make the shoreline ‘look’ cleaner for the sake ofthe visitors to the park. The extremely pitted and convoluted surface of the fossilised
coral rock made application of any cleaning agent very difficult. It would also be almost
impossible to collect the run-off from these chemicals and prevent it from being carried
into the sensitive inter-tidal area. However, identifying an effective alternative was moredifficult. The use of sawdust generated from the piles of oiled debris collected during thefirst phase of the clean up was considered as a potential adsorbent and as a means ofrecycling the waste {SAN JORGE, Uruguay, 1997}. However, the wood chips were toolarge and were not effective as an adsorbent on the weathered IFO 180 spilt from the‘AMORGOS’. It was also found impractical to apply uniformly to the rocks or to recoverafterwards. Eventually, high pressure steam cleaning was identified as being thetechnique most likely to achieve the desired results. Recognising that this is an aggressive
clean up method for a productive shoreline, especially one that is fringed by coral, only
the oiled rocks in the splash zone and upper inter-tidal area were cleaned. This
necessitated careful delineation of the shoreline and supervision to avoid over-cleaning
the coral rock or damaging the sensitive lower shore. To collect the oily run-off, sorbent
booms and pompoms were strung across the rocks and entrances to the channels. As
these pompoms were not readily available, local villagers s hredded packing material fromtelegraph poles and sewed them together to make their own. Mesh screens were also used
to prevent oily spray from contaminating other areas.
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PAJ OIL SPILL INTERNATIONAL SYMPOSIUM 2002 - RECENT ACTIVITIES OF ITOPF______________________________________________________________________________________At the end of May 2001, representatives of the ship-owner and the Taiwanese authorit ies
carried out a joint inspection of the oiled shoreline and agreed that the clean-up wascomplete.

NEBA IN PRACTICE
The examples of balancing different priorities that have been taken from the‘AMORGOS’ incident demonstrate that, in practice, NEBA is a simple process. It is also
not a new concept. Responding to an oil spill normally involves consideration of factors
such as the type of oil spilled, degree of oiling, location, weather conditions and theenvironmental and socio -economic sensitivities. All of these are balanced when weighing
up whether some damage is justifiable in order to achieve the desired goal or whether
natural cleaning is the best response option.

Evaluation of the different offshore response options during the ‘AMORGOS’ incident
initially indicated that chemical dispersants should not be used because of concerns about
the presence of corals. However, after realising that the coral cover in the vicinity of theship was low, dispersants then became a viable option. In a future incident, and provided
that the oil is sufficiently far from the shore to prevent the dispersed oil plume from
affecting corals in the near-shore area, chemical dispersants could be used.

Removal of bulk oil and oiled driftwood using manual labour helped to limit damage tothe shoreline. During the secondary cleaning, careful delineation of the areas to becleaned and the use of a small number of labourers under close supervision ensured thatdamage to the lower inter-tidal area was also minimised. Accepting that it was necessary
to permit vehicular access to the back of the shoreline and the cliff top (in order totransport pumps and remove the waste) also meant that some dirt tracks had to be
widened. Although some damage to the surrounding vegetation resulted, the tracks are
now being repaired and new vegetation planted.

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PAJ OIL SPILL INTERNATIONAL SYMPOSIUM 2002 - RECENT ACTIVITIES OF ITOPF______________________________________________________________________________________In deciding to take some action to address the spilt oil, acceptance that some damage
would occur was necessary. However, the response actions used were chosen andimplemented in a way that meant that any damage would be limited. Both the goals ofprotecting the environment and the socio -economic concerns were addressed to thesatisfaction of the Taiwanese authorities, and the cleaning that was carried out should notdelay the ecological recovery of the shoreline. Indeed, the Kenting National Park was reopened in October 2001 and our observations indicate that the coral has not beendamaged by the oil or the clean up.

CONCLUSION

Previous oil spill experiences provide excellent opportunities to learn about the response
techniques that worked well and those that did not. Important information regarding theimpact of different clean up methods on various environments, relative to natural clean
up, is also obtained. Utilising this information in contingency plans enables those lessons
to be transferred effectively to a new incident. It also reduces the chances of conflict anddelays during the response. The selection of appropriate response measures during the‘AMORGOS’ incident illustrated due consideration of the environmental and socioeconomical benefits. Sometimes this is called NEBA but, most importantly, it is a processof using ‘common-sense’ and the lessons learned from previous experiences to arrive at
the most sensible solution.

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PAJ OIL SPILL INTERNATIONAL SYMPOSIUM 2002 - RECENT ACTIVITIES OF ITOPF______________________________________________________________________________________REFERENCESIPIECA (2000), IPIECA report series, Volume 10, Choosing Spill Response
Options To Minimize Damage – Net Environmental Benefit Analysis.
IUCN-UNEP. 1988. Coral reefs of the world. Volume 3: Central and Western
Pacific, edited by Susan M. Wells and Martin D. Jenkins. Taiwan section Compiler,
Dr. Lee-Shing Fang, National Sun Yat-San University, Kaohsuing, Taiwan: 271 –287.
‘SAN JORGE ‘, Incident at Punta del Este, Uruguay, 1997, ITOPF.

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