Lessons Learned:

Followup On Foss Maritime Barge 248-P2 Oil Spill

 

 

Background:  There were sixteen lessons in the “lessons learned” report issued after the Foss Maritime barge spill at Point Wells.  In addition, upon receiving this report, Ecology selected four lessons and put them in the foreword of the report as those considered most important.  Those four lessons are discussed below, followed by the original sixteen lessons provided by the consultant.  Also shown are the followup actions that Ecology has taken since the spill in December 2003.  Finally, this summary includes an indication of how these lessons were acted upon during the mid-October 2004 Dalco Passage oil spill. 

 

Ecology’s Top Four Lessons Learned from the Foss Maritime Barge Oil Spill, December 2003

 

1.   Lesson:  Trained Beach Cleaners and Immediate Access to Beach Cleaning Equipment 

Actions: 

• Shoreline cleanup planning standards have been proposed in the current draft of the comprehensive update of the Oil Spill Contingency Planning Rules (Chapters 173-181 and 317-10 Washington Administrative Code).  The Rule Advisory Committee is currently considering those standards.
• Dalco Passage Spill Relevance:  No shortage of trained beach cleaners experienced.
• Dalco Passage Spill Relevance:  82 Washington Conservation Corps (WCC) members were identified by Ecology and trained by the second day of the spill response.  Fifteen WCC members were deployed to beach cleanup crews.

 

2.   Lesson:  Tracking Oil at Night

Actions:

• Availability of infrared resources is being investigated by the Northwest Area Committee to be added to the chapter on Logistics and made available to Washington’s regulated oil spill plan holders.
• Use of other such technology is being researched by Ecology.   
• Dalco Passage Spill Relevance:  When conditions prohibited aerial over flights to support the spill cleanup, the Unified Command developed alternative strategies, such as a large number of field observers sent by boat and automobile to gather information on the spill and investigate reports of oil.

 

3.   Lesson:  Immediate and Sufficient Aircraft

Actions: 

• Updated over flight procedures issued on October 7, 2004, in major revision to the Spill Response Operations Manual.
• Dalco Passage Spill Relevance:  Earliest possible over flights made.
• Dalco Passage Spill Relevance:  Continuous skimmer direction from over flights conducted.
• Dalco Passage Spill Relevance:  Frequent air evaluation in support of beach cleaning and sheen locating.
   

4.   Lesson:  Rigorous Drill Program Including Unannounced Drills

      Actions: 

• Established and executed DRILLTRAC, a comprehensive training program in which each Ecology staff person must train and demonstrate competency in the Incident Command System (ICS).
• Established and executed a fully functioning Incident Management Response Team (IMAT).  As part of DRILLTRAC, all Spills Program personnel are assigned ICS positions and must demonstrate competency to work under this system.
• Conducted Ecology drill testing the IMAT team functions and capability in

September 2004.

 

Genwest Systems, Inc. recommendations appear below.  The bolded recommendations below are similar to the four chosen by Ecology, above.  Following are Genwest’s Foss Barge spill recommendations and Ecology’s followup:                                                           

 

1.      Lesson:  Safety is always the most important objective.  Document concerns and aggressively pursue the issue.

Actions:

• Fully updated safety policy and procedures for Ecology spill responders were released on October 7, 2004, in the updated Spill Response Operations Manual.
• Dalco Passage Spill Relevance:  U.S. Coast Guard Auxiliary security personnel at staging areas.
• Dalco Passage Spill Relevance:  Immediate assignment of Air Operations position within the Incident Command structure at the spill to manage and coordinate all over flights. Coordination with Tacoma Fire Department at the Command Post landing zone.  Landing zone area clearly flagged and monitored.
• Dalco Passage Spill Relevance:  Safety Officer assigned within the first few hours of the incident.  Updated safety message was written on each day’s work assignments.
• Dalco Passage Spill Relevance:  Zero injuries to workers during the Dalco Passage spill response.

 

2.      Lesson:  Need to have more than one person monitoring oil transfers.

Actions: 

• Major study of oil transfer practices in Washington in progress since fall 2004 for comprehensive safeguarding of oil transfers.
• Interim report due to the Legislature by December 15, 2004.
• Oil Transfer Advisory Committee formed.  Ecology will complete rules requiring pre-booming or other alternative measures by June 2006.

 

3.   Lesson:  Equipment critical to the initial response must be in proper working order at all times.

Actions:

• Stepped up the design and evaluation of equipment deployment drills, including the “cold start” of response equipment belonging to oil spill cleanup contractors.
• Ecology staff has conveyed this lesson from the Foss spill to plan holders during these drills.
• The current draft of the Oil Spill Contingency Plan Rule proposes equipment maintenance and recordkeeping requirements for plan holders and response contractors.

 

4.      Lesson:  Continuous aerial observation of the oil and coordination of skimmers are critical, especially in the early hours of a response.  

Actions: 

• Complete update of over flight procedures issued on October 7, 2004, in Spill Response Operations Manual.
• Dalco Passage Spill Relevance:  Earliest possible over flights made.
• Dalco Passage Spill Relevance:  Continuous skimmer direction conducted throughout the on-water recovery portion of the response.
• Dalco Passage Spill Relevance:  Additional and separate over flight resources available for concurrent and frequent air evaluation for environmental monitoring.  The environmental flights made observations on beach cleaning, and provided sheen locations and wildlife reconnaissance.  

 

5.   Do not rely entirely on trajectory model information for slick movement information.  Take advantage of available infrared technology to position skimmers in darkness.

Actions: 

• Use and availability of infrared resources are being investigated by the Northwest Area Committee to be added to the chapter on Logistics in the Area Committee Plan.
• Use of other such technology being researched by Ecology.
• Dalco Passage Spill Relevance:  When conditions prohibited aerial over flights to support the spill cleanup, Unified Command developed alternative strategies such as a large number of field observers sent by boat and automobile.

 

6.      EDRC is a planning standard and should not be used as an actual capability.  If the oil is not contained immediately before it has a chance to thin and spread out over a wide area, low recovery volumes will result regardless of how much EDRC is available to fight the problem (excerpt from the report).  Derive a more meaningful planning standard.

Actions: 

• EDRC being evaluated in the context of planning standard in the overhaul of the Oil Spill Contingency Planning Rule.
• Dalco Passage Spill Relevance:  Dalco Passage was also a spill that was not immediately contained. The spreading had already begun before the spill was first discovered by the tugboat operator.  Similar (to the Foss spill) low results of on-water recovery were experienced in the Dalco Passage spill; however, there were continuous over flights to direct the skimmers to the thickest oil, and the skimmers were configured into enhanced formation to maximize oil recovered. 

 

7.   Since an early response is difficult, assume the oil will impact beaches.  More trained SCAT personnel are needed.

Actions: 

• Fifty Ecology response staff were trained in SCAT principles and procedures on

October 6, 2004.

• Dalco Passage Spill Relevance:  The U.S. Coast Guard, NOAA, and Ecology quickly formed teams and assessed shorelines as far north as Bainbridge Island and as far south as Anderson Island.  These teams worked on boats and over land by automobile. 
• Dalco Passage Spill Relevance:  No lack of trained SCAT personnel noted.

 

8.      Lesson:  Any spill in Puget Sound is likely to go ashore.  The next one could easily require more trained beach cleaners than this incident.

Actions: 

• Shoreline cleanup planning standards have been proposed in the current draft of the comprehensive update of the Oil Spill Contingency Planning Rules (Chapters 173-181 and 317-10 Washington Administrative Code).  The Rule Advisory Committee is currently considering those standards.
• Dalco Passage Spill Relevance:  No shortage of trained beach cleaners experienced.
• Dalco Passage Spill Relevance:   82 Washington Conservation Corps members trained and 15 WCC workers deployed to beach cleanups.

 

9.      Lesson:  While the initial trajectory was in error, it did not cause a significant problem in resource allocation.  Do not depend on a trajectory model as the sole source of information for the oil slick movement, especially when the source is close to shore.

Actions:

• Have stepped up the evaluation of marker buoys to deploy at future spills.
• The current draft of the Contingency Plan Rule proposes new requirements for spill detection and tracking.
• Dalco Passage Spill Relevance:  Because of the foggy weather conditions experienced throughout the response, alternative strategies for oil observation were developed and used.  For example, numerous field observers were sent out each day to document the oil and response conditions to ensure that the GRPs were in place, to ensure that the skimmers were using enhanced formations, and to track the movement of oil on water.
• Dalco Passage Spill Relevance:  Helicopter mounted infrared tracking considered.  Fog prevented safe helicopter flying conditions.

 

10.        Lesson:  Check-in personnel need to ensure that everyone entering the Command Post has an ICS position or role.  It is better to overreact with the number of personnel and there must be one and only one Situation Display.  If the Situation Unit and Operations are close together it is easier to make this happen.

Actions:

·        Established comprehensive training program, DRILLTRAC, and completed full Incident Command System (ICS) training of all 65 Ecology staff by summer of 2004.

·        Established fully assigned and trained Incident Management Assist Team (IMAT) by summer of 2004.

·        Held internal all-staff drill in September.  The scenario was a mystery (no responsible party) spill on the Columbia River.

·        Immediately began working on the lessons learned during that drill; for example, equipment gaps.

·        Dalco Passage Spill Relevance:  The U.S. Coast Guard and Ecology deployed full IMAT to command center and field positions.

·        Dalco Passage Spill Relevance:  Effectively blended Ecology and U.S. Coast Guard personnel to complete the spill management organization.

·        Dalco Passage Spill Relevance:  Effectively filled the command and general staffs.

·        Dalco Passage Spill Relevance:  Specifically included Command Center check-in station from the first day through the entire response.  All staff were fully employed; however, the lesson on the importance of check-in was reinforced during this response by the large number of people who showed up at the command post and were organized, managed, and assigned.

·        Dalco Passage Spill Relevance:  Unified Command ensured adequate staffing continuously throughout the spill.  When shortages were observed, additional staff was reassigned or temporarily reassigned to cover the shortages.

·        Dalco Passage Spill Relevance:  Situation Unit fully staffed from the beginning of the incident.  The spill situation was effectively displayed and maintained for the Command Post.

·        Dalco Passage Spill Relevance:  A Demobilization Plan was developed even before the first resources were demobilized from the spill.  This phase of the response was done in an orderly manner.

 

11.        Follow up on objectives to ensure they are being addressed.  Disposal plan was late.

Actions: 

·        Increased emphasis in DRILLTRAC training on incident objectives and disposal plans.

·        Dalco Passage Spill Relevance:  Incident objectives (Form 202) rigorously updated and followed.

·        Dalco Passage Spill Relevance:  Disposal plan was begun immediately.  The plan ensured proper waste disposal and tracking of waste throughout the response.

 

12.    Wildlife impacts could have been much worse.  Need to plan for Worst Case Discharge. More ICS training for Wildlife responders.

Actions:

·        Wildlife care standards were developed by rule in September 2004 by Washington Department of Fish and Wildlife.

·        DRILLTRAC ICS training planned for natural resource agencies beginning in 2005.

·        Dalco Passage Spill Relevance:  Wildlife Branch staff and care trailers on-scene timely and effective in handling wildlife issues.

·        Dalco Passage Spill Relevance:  Handling large-scale wildlife casualties still an issue.

 

13.    Lesson:  Tribes need ICS training - emphasize the need for them to send more people to spills, especially those authorized to speak for the tribes.

Actions:

·        DRILLTRAC planning to include tribal members in 2005 training.

·        Dalco Passage Spill Relevance:  New legislation requires tribal notification; no failures in Dalco Passage spill.

·        Dalco Passage Spill Relevance:  Tribal cultural resources were protected by the hiring of an archeologist for the response.

 

14.    Lesson:  Who can put up a website?  Are the photos the issue?
Actions: 

·        Full update on procedure issued on October 7, 2004, in new Spill Response Operations Manual.

·        Dalco Passage Spill Relevance:  A Joint Information Center (JIC) was established and Ecology posted JIC information on its website.

 

15.    Lesson:  Modify GRPs identified as needing changes in this spill response.  Develop procedure for approving deviation from the GRPs.

Actions:

·        GRPs are updated as staff time is available.  The updates are posted on the Ecology website.

·        Dalco Passage Spill Relevance:  One of the GRPs was identified as an area of cultural resource concern.  The GRP strategy was modified on-the-spot so as not to harm the cultural resource.

·        Dalco Passage Spill Relevance:  Notes taken on GRP performance.  Corrections will be put into effect if necessary after the spill debrief.

·        Dalco Passage Spill Relevance:  Protective strategies for resources identified during the response (but not identified as GRPs) were deployed during the spill.

·        Dalco Passage Spill Relevance:  Debriefing of the spill will include a discussion of the effectiveness of the GRPs.

 

16.    Lesson:  Continue working on transponder software.
Actions:

·        The software was tested at a recent U.S. Coast Guard/Navy deployment exercise with mixed results.

·        This project is under continuing development; however, it suffers from no budget and very limited staff time.  Technical problems exist in the area of communications.