Sakhalin Energy Tier 3 Exercise, July Summary of findings from a site visit to Sakhalin Island, 14 th 19 th July 2013

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1 Sakhalin Energy Tier 3 Exercise, July Summary of findings from a site visit to Sakhalin Island, 14 th 19 th July 2013 Brian Dicks, WGWAP Panel Member Introduction I visited Sakhalin Island from 14 th 19 th July The main purpose of the visit was to attend a Tier 3 Oil Spill Response (OSR) exercise based on a 5,000 tonne spill near the Piltun-A platform (Molikpak) and to follow up oil-related issues arising from WGWAP-13. Also in attendance at the exercise were Lenders representatives Frank Marcinkowski and Rick Muth of Environ/PCCI, and Dave Salt of Spillconsult, plus two Spillconsult colleagues, Adrian Payne and Bruce Johnson. Salt was a senior OSR manager at OSRL in Southampton and EARL in Singapore, which are Shell s and SEIC s international OSR stockpiles, and he is a well-respected and highly experienced oil spill practitioner. He retired from OSRL in 2012 and formed Spillconsult to provide spill management training and response equipment stockpile auditing. Johnson and Payne are ICS training colleagues. Spill Consult staff were on site for Shell International and SEIC to provide ICS training and he also assisted SEIC with setting up and running this Tier 3 exercise. Marcinkowski, Salt, Payne, Johnson and I were based in the control centre in Yuzhno whilst Muth was offshore on the response vessel Neftegas-55 to observe offshore operations. Tier 3 Exercise, Piltun-A (Molikpak) The exercise was run on 16 th and 17 th July 2013 and was based on a spill of 5,000 tonnes of Vityaz crude oil released from a breach in the sub-sea pipeline running between Piltun-B and Piltun-A (Molikpak) - the line holds about 5,500 tonnes of oil in that section. Two command centres were established in SEIC s offices. The first, designated as the Emergency Coordination Team (ECT), dealt directly with control of response through an on-site command centre based on Molikpak Site Control Team - SCT) for offshore operations and a control post established by the shoreline cleaning team at Piltun Bay. The other, designated as the Crisis Management Team (CMT), dealt with internal communications, all contacts with Russian regulatory bodies/agencies and the mass media. Initially the spill was estimated at 500 1,000 tonnes and was classed as regional Tier 2, which meant that SEIC initiated and controlled the immediate OSR response. As the day progressed, aerial observations revealed an increasing volume of oil on the water until in the 1

2 middle of the afternoon the spillage was estimated to be close to 5,000 tonnes and the incident was formally upgraded to Tier 3 which triggered federal notification. Under normal circumstances the Russian authorities (EMERCOM for shoreline clean up and SMPCSA for marine response) would have assumed command. This did not take place in the drill because EMERCOM had agreed to attend, but only as observers, and SMPCSA had not been able to provide a participant. Consequently SEIC continued the response (as they would anyway under federal leadership) and as it turned out EMERCOM did have some input at that stage (they were present in the ECT from the start of the exercise). The exercise was conducted over two days, which meant that as Day 1 closed, the response teams had to consider replenishing consumables, providing rest periods for responders, refuelling vessels and identifying all the requirements for the start of Day 2. This was the first occasion on which this had been tested for the SEIC response teams. At the start of Day 1, the ECT and CMT were rapidly established, and interestingly, although the players had a broad perception of what the exercise would comprise, my impression was that most did not have any detailed knowledge. This meant that they had to react to unknown and potentially changing conditions. I strongly support this approach (in line with WGWAP-12 recommendations about conducting exercises without responders having detailed prior knowledge). In my view this is a reasonable compromise with conducting exercises completely blind, i.e. with no prior knowledge on the part of the responders, which is an approach which SEIC have been unwilling to accept. Exercise weather and sea conditions at the time of the spill were fairly calm with gentle onshore winds from the north-east, which raised an immediate threat of coastal oiling in the Piltun area. For the exercise ECT mobilised three response vessels to the spill site to deploy booms and skimmers and a team of 27 responders was mobilised to the mouth of Piltun Lagoon for shoreline protection and clean up. The Piltun mobilisation had taken place the previous day to facilitate integration of this response with the exercise which is an acceptable exercise artificiality to facilitate integration of onshore and offshore response in a drill. In a real spill, they would only have been able to get to the site and deploy the booms by the afternoon of Day 1. The scale of this shoreline component of the drill was larger than that conducted in July Defensive booms (including chevron-booms see later for details) and skimmers were deployed and temporary storage facilities were established and 2

3 from the post-exercise de-brief it was clear that as in last year s exercise, all had been conducted professionally and effectively. However, given the amount of equipment and the numbers of personnel on site, it was an opportunity missed that the recommended deployment of a deflection boom on the south side of the outer entrance to the lagoon, which was identified last year (recommendation WGWAP-12/011), was not tried. In addition to resources which were actually mobilised offshore, SEIC simulated the deployment of five additional response vessels to spray dispersant and to move equipment and personnel between operations and from onshore to offshore. A shuttle tanker based at Aniva Bay was also allocated for recovered oil storage and theoretically mobilised to site. The helicopter dispersant spray bucket sharing agreement with ENL was activated, as was an agreement for assistance and resource sharing between SEIC and ENL. Regrettably, dispersant spraying (which would normally involve spraying water rather than dispersant in an exercise) both from the air and from vessels was only simulated. Vessel systems had been tested with water spraying prior to the drill (SEIC provided photos), but this had not been done from helicopters and was an opportunity missed (but see below regarding restrictions on helicopter activity by weather). ECT made arrangements for replenishing dispersant supplies from the Aniva Bay stockpile by train and also contacted the international OSR stockpile in Singapore to investigate arrangements for replenishing dispersant stocks by airlift from abroad. During Day 1 only limited attention was given to forward planning, which would normally be conducted regularly to review weather and sea conditions with the aim of predicting likely oil spread and movement. With some prompting the players got to grips with this approach and used it to assess potentially escalating needs for offshore and shoreline resources. As the response was escalated in response to reports of increasing spill size, and with the declaration of a Tier 3 incident, EMERCOM were persuaded to join the operating team in ECT. They confirmed that with the declaration of Tier 3, they would have begun to activate their manpower, vehicles and equipment, as they are legally required to, but in reality they did not assume command. Thus I was unable to determine how these individuals would perform in a real spill or the extent of their oil spill knowledge. After the exercise, Sakhalin Energy noted that EMERCOM had provided some information on available resources to the ECT planning section. EMERCOM said that they had placed their emergency response system to a state of increased readiness and that they would be able to provide 67 heavy- 3

4 machines (types not specified) and 108 persons to assist with clean up. At the close of Day 1, instructions were issued to responders to complete operations at dusk and re-start at 06:00 the following day. The operations onshore at Piltun were very similar to those in last year s exercise which I attended, although they were slightly larger in scale with more boom deployed and more temporary storage capacity. Since last year, the company have acquired boom vanes, which help to anchor and orientate booms correctly in strong currents. These were reported to have worked well and allowed deployment of several lengths of boom in a chevron configuration, which has the benefit of increasing oil deflection capacity. Unfortunately, in spite of my comments and suggestions last year, no arrangements for transportation of recovered wastes away from site for intermediate storage or final disposal were tested in this drill and deflection boom deployment on the outer coast was not attempted. These remain priorities for the future. It had been planned to mobilise a helicopter during the drill to test the transfer of containerised equipment from Nogliki to the shoreline operations at Piltun, but real weather conditions of fog at Nogliki airfield and along the coast during both days of the exercise prevented this and also would have prevented dispersant spraying from helicopters and prevented aerial tracking of oil at sea. These response options should be a priority for testing in future drills. As has been noted on many previous occasions, the commonest constraint on oil spill response is the weather, which often prevents timely intervention, no matter how well prepared the responders may be. Day 2 started in the ECT at 09:00 with updates from Molikpak on at-sea clean up and from the shoreline cleaning operations at Piltun. Operations were continued as for Day 1. By this stage, reports of recovered oil were being assessed and were reported as being several hundreds of tonnes and it was clear that the response vessels were reaching their short-term storage capacity. This raised two issues. How much of the recovered material was oil, and where could it be stored, given that the shuttle tanker would not reach site until late on Day 2? Whilst the volume of recovered liquids could well be of that magnitude after 24 hours, there was considerable over-optimism amongst the responders that this would all be oil. All 4

5 skimmers recover water with oil, and the proportion of water increases as sea conditions get rougher. Skimmer efficiency is also lower with very light oils (such as Vityaz crude) than more viscous oils. In this exercise sea conditions were quite choppy and in my view skimmer choice for deployment was not ideal. Muth reported after the exercise that Neftegas-55 had deployed small floating weir skimmers and side-sweep brush skimmers, which would have had relatively poor performance in these conditions and that they would therefore recover a high proportion of water. Deployment of rope mop and/or grooved disc skimmers, which are more effective on light oils and less susceptible to choppy conditions, would have been preferable. Thus, recovered liquids would comprise both oil and sea water and very likely more than 50% sea water in these circumstances. The presence of sea water often poses problems for final disposal of recovered liquids, as the salt content can damage oil processing units. This is an important reason why many refineries are unable to accept and deal with recovered oil. Discussions between ECT and the Molikpak command centre revealed that the Molikpak platform had the capacity to accept considerable volumes of recovered liquids, which could be transferred into storage tanks for water injection to the main oil reservoir. They also confirmed that the presence of salt water (possibly in large volume) mixed with the recovered oil would not cause them any problems, as their facilities were able to deal with it. This is a useful step forward for SEIC s OSR planning as it identifies a significant potential means of dealing with the need for temporary storage of liquids recovered by response vessels. The ECT noted that they had advised vessels to make the transfers of recovered wastes overnight after Day 1 operations, but I have not been able to establish whether this was actually done in the field. It will be important to confirm for the future that all response vessels have the necessary hoses and couplings to make transfers to Molikpak so that this reception capacity is fully effective. Overall, the temporary short-term storage of oily wastes had been dealt with well in this exercise, both offshore and onshore at Piltun, but no attention was given to final disposal arrangements. This shortcoming was noted in my reports of last year s exercise and was not addressed in this one in my view an opportunity missed. An exercise which addresses this issue remains a priority for the future. Briefings from ECT to CMT were excellent throughout the two days. CMT kept SEIC and all Russian regulatory bodies informed and produced a series of fact sheets (holding 5

6 statements) and press releases. They were given the task of seeking regulatory approval for dispersant application during Day 1 and this was successfully obtained in writing from Rospotrebnadzor. In my understanding this is a first on Sakhalin (at least for SEIC) and is also a potentially important step forward in spill response. Late in the morning of Day 2, local weather reports showed that the wind had changed to offshore and aerial observations showed the spill to be moving North-East and away from the coast. Longer-range weather forecasts and spill movement predictions from the OILMAP computer software confirmed that offshore oil movement was likely to continue for the next five days. This resulted in defensive booming operations at Piltun being demobilised back to Nogliki, with instructions to remain on standby (in case the weather and oil movements changed). Offshore operations were instructed to continue, but were officially transferred from emergency status to operational mode at this point. This is normal procedure during a spill when threats are perceived to be declining. In reality, this state would likely not be reached as early as day 2, but it suited the purpose of the drill. The ECT assumed responsibility for monitoring all aspects of the response over the days following the drill, and vessels were instructed to continue with recovery where the quantity of floating oil merited it. At this point the exercise was terminated and all response activities were stood down. Exercise debriefing, 18 th July 2013 As in any drill, especially a large one, areas were identified by Lenders representatives, Spillconsult and myself where improvements might be made for the future. This is, of course, one of the main reasons for conducting such exercises. As specialist consultants in the OSR training and exercise fields, Environ/PCCI and Spillconsult will report in detail on the practical items for improvements at the field locations and in the ECT and CMT. Whilst I expect to see their reports in due course, the majority of their findings were summarised at a close-out meeting held on the morning of 18 th July. SEIC personnel who had been at the shoreline exercise in Piltun also joined this meeting. Unfortunately, poor sea conditions prevented Muth from leaving the offshore response vessel Neftegas-55 on 17 th July and he could not attend the meeting, but Marcinkowski provided a brief summary of Muth s on-site observations. I was able to be briefed by Muth on his return on 19 th July. In this report I have not spelled out all of the fine details of my and the other observers points, but instead have 6

7 focussed on the main issues of what was positive and what opportunities were missed in the exercise which might have implications for the overall success of clean-up and hence for the grey whales. At the debriefing, I provided a general overview of the exercise and gave practical examples of what had gone well and where improvements could be made for the future. These are summarised below under Exercise Critique. PCCI and Spillconsult then gave a much more detailed breakdown of the running of the command posts and the deployment of personnel and equipment. In line with their role of comparing SEIC s performance with international good practice, they made a range of practical suggestions for improving information display and communications in ECT and CMT (including paying more formal attention to OSRPs during their activities), the tracking of deployed resources, obtaining further international support and various aspects of the practical response both onshore and offshore. Overall we were in broad agreement that the exercise had been executed safely and effectively, that the ECT and CMT had performed their tasks well, that positive involvement of response partners like ENL had been beneficial and that communications with regulatory bodies and the media had been effective. Exercise critique The exercise was generally well organised and run. Consistent with previous exercises which I have attended, the personnel involved were well trained and committed, response equipment was deployed rapidly, professionally and efficiently at both field locations (offshore at Molikpak and at the Piltun Lagoon mouth) and the control operations at the two command centres were professional, efficient and effective. Some observations from the exercise (not in any order of priority), which are intended as constructive and could lead to Panel recommendations in due course, are as follows: It was important that EMERCOM were represented at the ECT. Although formally they were present only as observers, when invited to join the command team they did so. During the exercise they confirmed that once Tier 3 status was confirmed, they would have assumed command of shoreline clean-up and provided additional personnel, vehicles and resources, but they were not able to provide details of what these would be. 7

8 In the brief post-drill analysis on Day 2, EMERCOM s representatives indicated that they were happy with the overall conduct of the drill. EMERCOM did not attend the close-out briefing on the morning of 18 th July I was unable to assess the EMERCOM spill response knowledge or the actual command role that would be assumed in a real spill. Active, role-playing participation by EMERCOM in a future exercise would be of considerable value and would allow SEIC and observers to identify their resources, capabilities and intentions. Temporary, short-term oily waste storage was handled well both onshore and offshore. It emerged during the exercise that Molikpak has a substantial storage capacity (provided vessels have suitable hoses/couplings to transfer recovered liquids, which needs to be checked and acted upon as necessary). Onshore at Piltun, temporary storage was well organised, but once again the ability to transfer recovered wastes away from site for intermediate or final disposal was not tested and needs to be included in a drill. Final waste disposal remains an important concern and needs to be formally organised and tested, both for shoreline wastes and for recovered oil/water mixes offshore. Skimmers offshore - the units deployed (a small weir skimmer and a side-sweep brush skimmer) were not really appropriate for Vityaz crude oil in these conditions. More appropriate skimmers would have been rope-mop and grooved disk types. SEIC would benefit from reviewing the skimmer units which they hold and should ensure that a range of skimmers are readily available on response vessels to meet the requirements of different oils and differing conditions. Shoreline boom deployment proved effective and the use of boom vanes allowed chevron boom configurations to be deployed, which has the potential for improved oil deflection/recovery capacity. Unfortunately, no attempt was made to try deflection booming on the outer coast at the lagoon mouth, which remains a priority for a future drill. The fact that approval was obtained for dispersant application was a potential step forward for spill response as the technique has real potential for dealing quickly with substantial amounts of offshore oil. SEIC would benefit from reviewing the status and location of their stockpiles and potential arrangements for getting more in as needed in a spill. This exercise included activation of the joint agreement with ENL for using helicopter-mounted spray pods, but it would also be beneficial to conduct an exercise to actually deploy these resources and to test dispersant spraying from vessels. Water should be sprayed rather than chemicals. 8

9 As noted in my reports of the 2012 exercises, in a Tier 3 incident it is likely that the company will need to enlist and manage considerable numbers of additional personnel and non-specialist resources such as trucks, diggers and support boats. Sakhalin Energy recognises this concern and after the exercise advised me that in addition to the EMERCOM resources noted earlier in this report, CREO also have access to about 200 response personnel from other Russian regions and that they would be able to mobilise small vessels from other PMDs and request them from other oil and gas operators in the area. However, these arrangements have not been formalised or tested in an exercise, and this should be a priority for Brian Dicks, September