Mr. Brent Pyburn, Chief Executive Officer
Eas asia Response Pte Ltd (EARL)

Contingency Planning For Oil Spills
General Response Planning
Oil spills can arise from a number of different sources ranging from small operational
spills like overloading tanks and burst hoses to the more serious such as a
catastrophic failure in a large tanker's hull integrity due to a collision or a grounding.
There are also other non operational sources such as urban runoff and natural
seepage.
However this presentation will be dealing with the former sources of pollution.
Without doubt the most crucial aspect of dealing with any emergency is to beprepared. However unlike most emergencies that occur with little warning but areover in a relatively short period of time an oil spill incident can also occur with little
warning but may extend for weeks, months or even years.
Therefore planning for oil spills must not only look at the immediate tacticalresponse and managing the immediate aftermath but must be prepared to cater for amuch lengthier tactical response and must have a more strategic view with regard toan aftermath that may extend for years.
It is extremely important also to ensure that your planning process is not done inisolation but includes all of those constituents who would be affected by the oil spill.
The Exxon Valdez incident showed how important it is to have pro-active
relationships with local authorities, communities and the environmental lobby.
Any company either large or small operates in a working environment made up of thegeneral public, legislators, regulators, customers, stakeholders in the company andthe communities in which it's facility operates.
When an incident occurs and depending on the consequences there is an explosion of
impacts on the operating environment as shown in Figure 1.

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IMPACT ON CONSTITUENCIES

Fig 1
Depending on how a company manages the reaction from the impacts (Figure 2.) on
these constituents will determine whether the company is effectively managing theincident and whether the incident will have a short term or a long term effect.

Fig 2

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Thus by including those constituents in your response planning the relationship andinteraction between the company and the constituents in an emergency is wellestablished.

Tiered Response Planning
It is obvious that the response to a minor spill will be completely different to that ofa major incident. The strategy for managing the incident, response time and thelevel of resources required to effectively respond will not be the same for both endsof the scale.
However this does not mean that planning for a small spill is any less important thanfor a large one although certainly it will not be as complex.
The Tiered Response concept of planning for oil spills is an effective (both cost wise
and tactical) method and is now generally accepted throughout the oil industry. It
also allows you to preposition an appropriate amount of equipment in appropriate
locations.
If you look at the diagram shown in Figure 3 you will see that the size of spill and it's
proximity to operations influences the spill category.

Fig 3

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It should always be borne in mind that designating tiers to oil spills if for planningpurpose only. When an oil spill occurs whether it is a small or a large release there
are number of other complicated and sensitive factors that will determine the impactof the spill and could influence the scale of response to the spill. For instance asmall spill close to an environmentally sensitive or recreational area will havesubstantially more impact than a large spill in the middle of the China Sea and the
response to each would be different.
The media and political implications may also determine your response to an
incident.

Tier 1 Contingency Plan
A Tier one plan should be prepared to cover the risk of a small local spill occurring
due to normal operations within the confines of a terminal or facility operated or
co-operated by a clearly designated authority or authorities.
Examples of such spills are ruptures of oil transfer hoses, thank overloading or valve
leakage where the period of uncontrolled flow of oil can be quickly curtailed
resulting in a spill of a relatively small amount.
However just because the spill size is small it does not lessen the need for a quick
and effective response. Statistics will show that there is a greater number of Tier
One type spills than any other and unless they are dealt with effectively they can havea more chronic effect on the immediate environment than any other category of spill.
Apart from the environmental effects ineffective response to operational spills
attracts the attention of the local statutory authorities to the operational proceduresat the terminal. In the worst case this may cause close down or at the least acurtailing of transfer operations until the authorities are satisfied that the terminal or
facility has an adequate response capability.
The response to a tier one spill should be immediate if not then at least within thefirst hour of the spill taking place.

4For instance an operator working in the high risk area such as the jetty must be
designated as an authority to activate the Tier One response plan. He must be clear
about the procedures to activate the resources and to set in motion the response.
Sufficient oil spill equipment capable of dealing with a Tier One incident should be
kept in a state of constant readiness close to the high risk area and in such a way as
there is the minimum amount of effort needed to deploy it on the water. Enoughtrained personnel should be readily available to carry out the deployment andmaintain the response until the oil has been dealt with.
It should also be remembered that in certain circumstances when the location of the
facility is appropriate and if the oil is amenable then the use of dispersant application
may be the most practical Tier One response option. If dispersant application is
being considered as part of your plan then it is important at the planning stage todiscuss the option with local authorities and environmental groups. Because the"window of opportunity" to use dispersants is small due to the changing
characteristics of the spilt oil, pre-approval for dispersant use is essential.
If a Tier One response is successful then the facility should not need to involve
outside resources other than pre-arranged contractors. Of course it will need tomeet the necessary reporting, information and legal requirements.

Tier Two Contingency Plan
The Tier Two plan will cover those types of incidents at a company facility or withinpublic or multi-user facilities where the company has limited control over events andthe physical size of the spill or the effect of its impact is beyond the scope of the Tier
One response capability.
Examples of such risks are shipping accidents with a limited release of oil in ports
and harbours or estuaries and coastal waters, pipeline failures or accidents on
offshore exploration and production facilities.
In this case a company will know that the Tier One response capability is not
sufficient and that it requires further resources as quickly as possible to supplement
it's Tier One resources.
It may be that resources are available from local government stockpiles or by5

persuading other local operators to pool their resources into a mutual aid facility.
Two good examples of such mutual aid can be found in the Arabian Gulf and in
Malaysia.
In the Arabian Gulf the Gulf Area Oil Companies Mutual Aid Organisation(GAOCMAO) during 1972 formed the first mutual aid organisation of its kind -- apioneering approach to collective response capability. When activated by the
GAOCMAO secretariat thirteen companies operating in the Gulf area can donate
their own Tier One oil spill equipment in a coordinated response to a major incident.
Malaysia is also developing a mutual aid strategy to deal with Tier Two type
incidents on the east and west coasts of Peninsular Malaysia and in Sabah andSarawak.
The Petroleum Industry of Malaysia Mutual Aid Group has been established as a
Malaysian company limited by guarantee whose members include the national oil
company and the oil majors operating inn Malaysia.
In this case the mutual aid group is establishing stockpiles of equipment at strategic
locations in Malaysia managed by a technical team, secretariat and a team ofcontractors.
Equipment already owned or money will be donated by the members to establish thestockpile. Each of the members will also pay an annual charge for administrativeand operating costs.
Because there are a number of outside agencies involved in a Tier Two plan as
mentioned before it is important that all of these agencies are brought into theplanning process and roles and responsibilities are clearly defined within the plan.
Clear paths of communication must be established between all the parties concernedand agreement reached on the method of reimbursement.
Where equipment has not been stockpiled under a mutual aid agreement then liability
issues need to be settled prior to donation of the equipment to a Tier Twocoordinated response effort.

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The line drawn between Tier Two and Tier Three is never clear therefore it isimportant to ensure that a Tier Two plan can be simply escalated into a Tier Threeplan. Always remember that one man's Tier Two incident is another man's Tier
Three.
For instance a company may well consider an incident within the Tier Two response
capability but the media and environmental lobby may push the event into the Tier
Three category by raising the profile and speculating on the consequences. The
Braer incident in Shetland was a prime example of speculation by the media on thepossible consequences of the spill on the local environment.

Tier Three Contingency Plan
The Tier Three plan is the ultimate plan to respond to a spill of catastrophic
proportions.
Normally this will consist of a plan drawn up by a government to protect the national
interest. Reason being since only governments can draw upon massive resources
like the military who would be required in the event of a catastrophic spill.
Governments can also commandeer resources from the public and private sectors aswell as legislating for emergency powers.
Examples of the types of incidents covered by such a plan would be catastrophic
failure of a tanker's hull integrity causing a major if not total release of the oil cargoor bunkers. This is normally due to a collision and subsequent foundering of thevessel or a grounding.
However one should bear in mind that such catastrophic failures may not lead to a
Tier Three situation. The Braer incident off Shetland in 1993 where the wholecargo was lost, resulted in no response other than some dispersant spraying andclose monitoring being required. The very weather that drove the tanker ashore
greatly assisted in the natural breakup and degradation of the oil.
As can be imagined when a Tier Three situation does cause problems they can be ona tremendous scale as most of us remember in the Exxon Valdez incident.
Planning for this type of incident is no small feat as you not only have to source7massive amounts of resources but you also have to effectively manage thoseresources and in what may be an inhospitable and isolated location.
Most governments plan for this type of worst case scenario and it is extremely
important that industry, whilst operating in or near to a particular country, works
with the national government to produce an integrated Tier Three contingency plan.
This cooperation is called for in the IMO's International Convention on Oil Pollution
Preparedness Response 1990 (OPRC 1990).
The national contingency plan most certainly will clearly define the designated leadauthority to manage the incident and define roles and responsibilities. It should
also include the organisational relationship of the various bodies involved whether
public or private.
Resources for a Tier Three incident will not only be sourced nationally but alsointernationally and that is where the role of international oil spill cooperatives like
EARL are so important.
Preparing a Contingency Plan
Keeper of the Plan
One of the most important aspects of a contingency plan is ensuring that it is kept
upto date. There is nothing more frustrating than trying to use a plan when theinformation in the plan is out of date.
Someone needs to be clearly identified who will have responsibility for the plan andensure that the information contained within the plan is kept updated.

Plan Structure
In general the plan should be comprise of three main parts:
Strategy Section.
‑
Authorities and responsibilities: which should indicate the various
authorities encompassed by the plan and their responsibilities. It should
also outline any statutory requirements that the plan may be required toadhere to, particularly if the plan interfaces with a national contingency
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plan or local authority regulations.
‑

Dimensions of plan: which will indicate the area the plan covers and it'sgeographical limits. For instance it may cover a refineries operations
plus the sea approaches to the marine terminal at the refinery.

‑

Risks: the part will describe the types of risks involved from the chanceof a hose burst or pipeline failure to the possible grounding or collision ofan approaching tanker. From these scenarios plus a knowledge of thetypes of oils being handled at the facility an indication of the fate andeffect of an incident can be predicted. By being able to predict the fateand effect shoreline resources can be prioritised for protection‑

Response strategy: will define the philosophy and objectives of
response. It will indicate the problems due to local limiting and adverse
conditions as well as setting out the strategies for sea and coastal zones.
Arrangements for dealing with waste storage and disposal will beoutlined.

‑

Equipment: what equipment is available and how it can be effectively
used in the strategies previously outlined.

‑

Organisation and manpower: this sub-section will clearly outline themanagement organisation from the on scene commander to the cleanup
workers in the field. It will also show the relationship with the relevant
government authorities and how they fit into the incident management
system.

‑Communications: the communications network will also be described inthis sub-section, listing the communications equipment fitted into thecommand center and a description of the field communications equipment.
Examples of reports and incident logs etc.

Action and Operations Section‑

Initial procedures: Which set out the arrangements for notifying therelevant authorities of an incident.

9‑Emergency activation procedures for calling out response teammembers and setting up the command centre. Emergency activation andmobilisation procedures that will allow rapid sourcing and deployment of
resources particularly from contractors and third parties.

‑

Planning: What requires to be done in the form of planning in the short
medium and long term.

‑

Guidance on specific cleanup operations and the critical factors when
deciding the final and optimum levels of shoreline cleanup.

And finally a:
Data Directory which should contain all the relevant maps, (particularly sensitivitymaps) lists and local wind, weather and environmental data sheets to assist in theassessment of the situation and the development of a strategy for dealing with thesituation.
Such a list would contain:‑

Primary oil spill equipment (manufacturer type, size, location and costof hire where applicable.)‑

Support equipment needed to deploy the equipment ie workboats tugs
tractor and trailors etc.

‑

Sources of manpower, contractors local authorities etc.

‑

Source of experts and advisors ie salvors, environmental safety etc.

‑

Local, national and international contacts who required to be notifiedof the incident and who may be able to offer assistanceFor more detail on what should be contained within each of the main sections I
recommend referring to the IPIECA Report Series Volume 2 entitled 'A Guide toContingency Planning for Oil Spills On Water."10

Another important general point about the plan is that it must be practicable andachievable in it's objectives.
It certainly must not raise levels of expectations above what it can realisticallyachieve. For instance response times for equipment and personnel must reflect theworst case scenario rather than unrealistic best case.

Training and Exercises
People sometimes ask me why an oil spill response can go wrong if a comprehensive
contingency plan has been put in place. The trouble is a large number ofcontingency plans are gathering dust on a shelf somewhere or propping open a door.
Any contingency plan should be seen as a living document which requires periodic
nourishment in the form of updating. To be effective it requires training of it's
resources, and to remain healthy it requires exercising.
Within the consider the wide ranging elements contained within an oil spill cleanup
operation from the frenetic activity of the short term tactical response to the moremeasured considerations of the long term strategic response it is easy to see thedepth and breadth of training required.
Figure 5. shows a typical management structure associated with a tier 3 type incident.
From the diagram you can see that managing an incident is not dissimilar to
managing a factory. Where the similarity ends is that oil spill management iscarried out under intense public scrutiny with unusually heavy political implications.
(how many political and industrial careers do you think have been made or lost in theaftermath of a major oil spill? I should know!!).

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Fig 5
Therefore a thorough understanding by the team on the response options and theenvironmental effects of an oil spill coupled with an ability to solve problems
effectively whilst communicating your thinking and strategy to a hostile audience iscritical in managing a spill successfully.
Only training and regular exercising under simulated pressure will ensure that yourteam has at least a fighting chance to effectively deal with a real life incedent.

The End12

East Asia Response Private Ltd (EARL)
The company East Asia Response Private Limited was established in Singapore on
May 18 1992 as a non-profit making company by the founding shareholders BP
Singapore, Caltex Services Ltd., Esso Eastern, Mobil Spill Response Inc. and
Shell Response Ltd. In 1994 BHP Petroleum a wholly owned subsidiary ofAustralia's biggest company became a shareholder.
EARL's prima role is as a Tier Three Response Centre or in other words a majorinternational resource for responding to catastrophic oil spills in the Asia Pacificregion in support of the oil spill response operations of the companies participating
in EARL.
At its Regional Centre in Jurong it stores and maintains to a very high level a wide
range of oil spill response equipment capable of responding to a major incident.
In addition to the equipment the Centre is staffed with 18 specialist technicians who
have had extensive training in the maintenance and operation of the oil spill
equipment. They also act as the crew for the 20m fast response vessels.
In the event of an incident the technicians would supervise teams of labour, using theCentre's and other equipment in the clean up operation.
To enable the equipment to be quickly airlifted to the scene of the incident EARL has
a Lockheed C-130 transport aircraft on a "wet lease" continuously on standby at
Sclctar Airport. To offset the lease costs the aircraft is sub chartered for flights notexceeding four hours from Singapore which is the maximum time it would take toactivate EARL and mobilise the team and equipment to Changi Airport where theequipment would be loaded.
In addition to its Tier Three regional role EARL also provides a waterborne response
to incidents in the Port of Singapore, Singapore Straits and the Straits of Malacca.
It has recently responded to a number of minor incidents in the Malacca Straits.
Plans are at present being developed to establish a quick response marine base in
Port Dickson Malaysia. Earl is presently discussing joint occupation of the old
Shell Distribution Depot at Port Headland P.D. with the Petroleum Industry of
Malaysia Mutual Aid Group who wish to set up Tier Two facility on the West Coast13

of the Malaysian Peninsular.
A Tier Two response facility is to cover spills which are outside the capability of anoil terminal's Tier One but has not rcached the stage of a Tier Three. A rapid
response vessel fitted with quick deployment equipment will be stationed at the baseat Port Dickson. Combined with the two rapid response vessels in Singapore thevessel at Port Dickson will provide a fast initaial response to incidents occuring in
the Singapore Straits and the Straits of Malacca.
Training.
During 1993 EARL was involved in over twenty training course and seminars acrossthe region. some of the training was held at the Regional centre where there is asuite of rooms especially designed for training and syndicate work.
The main training room located on the 2nd level of the administration block cancater for upto thirty students and is fitted out with the latest audio visual aids.
Consultancy
EARL has provided a consultant for a number of projects in Hong Kong, China,
Vietnam, Guam and Bahrain. The work in Hong Kong and Guam consisted ofdeveloping a Tier Two response facility at these places. The work in Vietnam is at
grass roots level of developing a national contingency plan. In Bahrain EARL has
been assisting the national oil company to develop their contingency plan and toencourage industry and government cooperation in the planning process.
EARL has also provided an expert for the expert's panel on the IMO/Industry
Regional Seminar Programme on Joint Oil Spill Contingency Planning. The
seminars have been held in Jakarta, Cairo, Libreville, Caracus, Bahrain, Curacao andHong Kong.
EARL is a good example of the industry's contribution to the OPRC Convention inproviding equipment and expertise to the region and compliments the activity of thePetroleum Association of japan in protecting the marine environment in the region.

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