Prevention Program. Safe and Effective Oil Transfer Operations

Transcription

1 Prevention Program Safe and Effective Oil Transfer Operations Washington State Department of Ecology Spill Prevention, Preparedness and Response Program Harbor Safety Committee Conference

2 WA Prevention Philosophy Prevention Goal: Zero Spills Prevent Accidents & Mitigate Impacts Emergency Response Tug Oil Spill Response Equipment Caches Aggressive Drill & Exercise Program Augment federal and international standards Acknowledges USCG primacy over vessels Established MOA & protocols for collaboration WA focus on Best Achievable Protection Fills in the Gaps

3 Facility & Vessel Prevention Exceptional Compliance Program - ECOPRO Cargo & Passenger Vessel Inspections Bunker Inspections Incident & Spills Investigations Oil Handling/Transfer Inspections

4 2004 Legislature Set a Zero Spills Goal for Washington Purpose of the rules: Establish minimum prevention & response standards for safe oil transfers in Washington

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6 Who do the rules apply to? All classes of oil handling facilities (Class 1-4) delivering oil in bulk to non- recreational vessels. All vessels delivering oil in bulk to any non-recreational vessel (incl. tank, cargo, passenger vessels) or Class 1, 2 or 3 facilities

7 Facility Classifications Class 1: 1 Large refineries, oil terminals, pipelines Class 2: Tank trucks, railcars, and other mobile devices Class 3: Small tank farms and terminals (transfers to vessels with a capacity of >10,500 gallons) Class 4: Class 4: Marine Fueling Outlets, Marinas (transfers to vessels with a capacity <10, 500 gallons) Includes boatyards that services vessels under 300 G.T.

8 Notification of a Transfer Class 1, 2 and 3 facilities transferring >100 gal. 24 hours in advance of a transfer or ASAP Class 4s have no Advance Notice of Transfer, but they must report transfer volume twice a yearly For any delivering vessel transferring > 100 gal. Ecology must be notified per USCG COTP reporting requirements (minimum 4 hrs.) State system meets the Coast Guard advance notice requirement

9 Facility and Vessel Prevention/Preparedness Oil Transfer procedures including: Pre-transfer conference, adequate communications during oil transfers Pre-load plans (tank levels, order, shut down) Shutdown procedures Training and Certification program (Class 1 & 2 facilities only) Operations Manuals (Class 1 & 2 facilities only) Spill Response Plans and Drills Inspections determined using the advance notice and history Six Full Time Equivalent dedicated to monitoring effort - Target 25%

10 Oil Transfer Requirements Pre-Transfer Conference by Person(s) in Charge (PICs) that covers: Pre-load plan Declaration of Inspection (DOI) Adequate Communications Emergency shutdown procedures Environmental conditions affecting safe transfer

11 Oil Transfer Requirements Pre-load plans from receiving vessel that include: Location and capacity of oil tanks Level and oil type in each tank prior to loading Final planned ullage or innage, volume of tanks to be filled Sequence of tanks to be filled Vessel s s procedures for monitoring oil transfer

12 Oil Transfer Requirements Oil transfers must follow approved operations manual Method to control spills from connections in oil transfer system Maintain, test oil transfer equipment

13 Oil Spill Containment and Recovery Standards Two standards apply to Class 1, 2, and 3 facilities and all delivering vessels based on the oil transfer rate: Rate A transfers >500 gallons per minute MUST pre-boom when safe and effective. Rate A deliverers must submit S&E threshold values determination report for approval If NOT safe and effective to pre-boom, then facility must meet alternative measures.

14 Containment and Recovery Standards (cont.): Rate B transfers <500 gallons per minute Choice of protection measures Pre-boom (implied safely and effectively) or Use alternative measures. Equivalent Compliance Plan (must provide at least an equivalent level of protection to alternative measures). Public review process Standards for Marinas (Class 4) - spill notification, training, testing/maintenance and response equipment

15 Safe and Effective Threshold Determination Reports Ecology Adequacy Review Presumes pre-booming to occur Boom selection & the means of deployment appropriate for prevailing environmental & operational conditions Both S & E criteria must be met Acknowledge combination of factors may create unsafe or ineffective booming condition, BUT. Entrainment = Ineffective Pre-booming >80% oil recovery rate

16 Pre-booming Requirements Deploy boom to surround vessel/dock or provide maximum containment of spilled oil Minimum of 4X vessel length or 2000 (Rate A) Provide at least a 5 5 standoff Recovery and oil storage equipment Within 1 hour of a spill, must be able to complete deployment of remaining boom

17 Alternative Measures Enough containment boom to encircle vessel or maximize containment Recovery and oil storage equipment Ability to track oil in low visibility and on-scene < 30 minutes of a spill (Rate A only) Within 1 hour of a spill, must be able to completely deploy required amount of boom Within 2 hours of a spill, have additional equal amount of boom available Skimming/recovery system on-site (Rate A only)

18 Implementation Status All Operations Manuals are conditionally approved Includes S & E thresholds and pre-booming procedures Final approvals pending validation of prevailing operational & Wx conditions Ecology focus has shifted from plan review/approval to inspections Ecology has monitored approximately 12% of reported transfer operations. Frequently found inadequate PIC exchange of pertinent information Lack of PIC awareness of response capabilities required Developing targeting matrix to better address highest risk transfers S & E Threshold Determination Reports all reviewed for adequacy; conditionally approved reports pending environmental data collection and booming system adequacy/verification Pre-booming Rate 84% of transfer operations are being boomed Training and Certification Program 90 days > Final ops manual approval Reviews are in progress Beginning to review the rules for adjustments based on experience e using legislative and agency intent