prevention and response day
TRANSCRIPT
Prevention and Response DayWest Coast Regulatory Update
The Role of the Qualified Individual (QI)Spill Management Team (SMT)
Thomas J. WikerGallagher Marine Systems, [email protected]
The Beginning of Oil Spill Casualty-Driven Maritime Legislation World-Wide
S/T TORREY CANYON aground off Lands End, UK 1967 >
The Beginning of Oil Spill Casualty Driven Maritime Legislation World-Wide
The primary response to TORREY CANYON was made by the Royal Navy.
The final tactic employed to stop the spill was destruction of the vessel and cargo with thousand- pound bombs.
The Implementation of Oil Spill Casualty-Driven Maritime Legislation in the U.S.
Through the 1970’s and early 1980’s, significant maritime spills continued in U.S. waterways.
• S/T ESSO BRUSSELS (5,166 tonnes spilled) New York harbor in May of 1973 (collision, explosion and fire)
• @47,000 bbls
• S/T CORINTHOS (37,700 tonnes spilled) in the Delaware River in January of 1975 (explosion and fire)
• @318,500 bbls
• S/T ARGO MERCHANT (95,166 tonnes spilled) stranded off Nantucket Island, Massachusetts in December 1976
• @805,000 bbls
• And many more into the 1980s…>
The Implementation of Casualty-Driven Maritime Legislation in the United States
In March of 1989, the fully laden M/T EXXON VALDEZ grounded on Bligh Reef in Prince William Sound, Alaska.
On February 7, 1990 the AMERICAN TRADER spilled approximately 417,000 gallons of crude oil off Huntington Beach in Southern California.
American Trader and Exxon Valdez inspired the California Legislature to enact the
Lempert-Keene-Seastrand Oil Spill Prevention and Response Act.
Oil Pollution Act of 1990As a direct result of the Exxon Valdez spill inPrince William Sound, Alaska …
…Congress passed the Oil PollutionAct of 1990 (OPA 90)
OPA 90 - General Established:
– requirements for Terminals, Pipelines and Tank Vessels.
– double hull requirements for tankers.
– requirements for Vessel Response Plans to include: Qualified Individual (QI) Spill Management Team (SMT) Oil Spill Removal Organization (OSRO) Salvage & Marine Firefighting Provider (SMFF) Etc.
USCG & CaliforniaVRP/NTVRP/FRP
U.S. Coast Guard– 33 CFR 154.1010 Subpart F (Facilities)– 33 CFR 155.1010, Subpart D (Tankers) – 33 CFR 155.5010 Subpart J (Nontankers) Above require Tanker VRP and Nontanker NTVRP and
Facility FRPs, respectively.
California– California Code of Regulations Title 14, Division 1, Subdivision 4, Chapter 3 Requirements for Facility, Tank and Nontank Vessel
Contingency Plans
Designation of Response Resources
33 CFR 154.1026 – FRP must designate a QI– Under Part 154, Subpart F – identification of SMT,
OSRO, etc. 33 CFR 155.1026 – VRP must designate a QI
– Under Part 155, Subpart D – identification of SMT, OSRO, SMFF, etc.
33 CFR 155.5026 Subpart J (Nontankers)– Under Part 155, Subpart J – identification of SMT,
OSRO, SMFF, etc.
– Above require Facility, Tanker & Nontanker Response Plans to designate a QI/SMT, OSRO, SMFF, etc..
USCG & California Contingency Plans
These are USCG & California approved, correct?
We have an incident…how does the RP activate the plan?
Notification to agent?
Notification to superintendent?
Notification to a regulatory agency?
NOTIFICATION TO PLAN LISTED QI!
Plan Activation
The planholder must activate the plan.
As an “RP”, we must follow the plan.
Often times an agent is directed to “activate” the plan…
Proper Plan Activation
QIs are fluent with:– notification protocols Time constraints
– Resource activation needs/expectations Inclusive of RA&C
– Communications with regulatory authorities
Qis are contractually permitted to fulfill this role
Remote Assessment & Consultation(RA&C) Another reason to follow the
plan…the RA&C requirement:
enables SMFF provider to assess a situation to determine an appropriate course of action.
Timing of notifications is critical –– Don’t delay notification to the
Qualified Individual
SMFF Provider SMFF #
The owner or operator shall provide each qualified individual and alternate qualified individual identified in the VRP/FRP with a document designating them as a qualified individual and specifying their full authority to: Activate and engage in contracting with oil spill removal
organization(s) OSRO and other response-related resources noted in the plan;
Act as a liaison with the pre-designated Federal On-Scene Coordinator (OSC/FOSCR);
Obligate funds required to carry out response activities.
Roles & Responsibilities of the QI
• The QI acts on behalf of the planholder as the “Responsible Party representative”
during an incident.• QI in 2014…other responsibilities..
QI Grant of Authority
Planholder appointment of QI:
Common misconceptions:– Agency understanding of the QI role/function “RP is a bad player”
– Plan activation means calling the QI…not the OSRO, SMFF…
– Understanding the difference between a QI, P&I, SMT, SMFF, OSRO and their respective roles…
– Use of an agent during an incident Do not involve the agent in QI protocols (i.e. notifications) There is no mention of this in the VRP/NTVRP. Regulatory authorities should not direct the agent to activate
resources; that should be undertaken by the QI.
Roles & Responsibilities of the SMT:
- Organize/Manage Response Operations;
- Planning, directing, and coordinating response assets;
- Ensure Safety for Public and Workers;
- Provide/Locate Response Resources;
- Meet Regulatory Requirements for Response;
- Track/Control response expenditures
QI/SMT Initial Response Positions
Incident Command Post Equipment & Support
GMS maintains fly away kits that enable us to quickly standup a command post in any location.Our kits provide the capability to standup an ICP ACER Computer
– serves as a system data base and will serve GMS FileMaker software.
– Capability to create IAP, etc. Internet service
– Will support 50 to 60 units on WIFI– Modem– Router
Telecommunication– Telephone line with dedicated number
Projection– Capability to project situation updates
Printers Scanners/fax
INSERT PICS of ICPIn a box from drill
Common misconceptions:– SMT will fill Deputy roles
– Agency response is separate from RP response
– Understanding of industry knowledge Prior USCG, prior OSRO, prior commercial/USCG seafarers
– Understanding of capabilities Training, experience, software/hardware resources
– Familiarity with the VRP/NTVRP/FRP implementation.
Summary Under approved USCG/CA Plans, the QI serves as
the primary “RP” point of contact.
The SMT is prepared to fully integrate into the ICS and will staff Section Chief and many other roles.– Additionally, they will setup a full ICP and staff field
supervisory positions
Agents should NOT be tasked with plan activation and/or QI responsibilities.
QI/SMTs are valuable resources with a wealth of knowledge and capability.
Gallagher Marine Systems -Overview
General Email Address:
www.gallaghermarine.com
