DRAFT. Drill Monitoring Contractor. Annual Report

3-1 Attachment A DRAFT Drill Monitoring Contractor Annual Report 2004 Prepared for the Prince William Sound Regional Citizens Advisory Council by Contractor: Tim Jones Contract No. 752.2004.1

TABLE OF CONTENTS Drill reports index...3 Major Developments...5 On-going concerns...7 Annual budget...13 The coming year...14 Drill Monitor Annual Report 2004 Page 2

2004 REPORTS INDEX DATE No. TYPE 12/11/03 1 Escort: Polar Discovery/ Tanerliq - data received 1/21/04 1/20/04 2 Escort: S/R Columbia Bay/Alert - data received 1/21/04 1/21/04 3 Escort: Polar Alaska 1/23/04 4 Escort: Marine Columbia 1/24/04 5 Escort: Overseas Washington 2/6/04 6 Overseas Washington / Heavy weather 2/11/04 7 Nearshore Free Oil 2/27/04 8 Whittier Nearshore 2/4 9 Decontamination demonstration 3/2-4/04 10 Operations Section tabletop 3/26 11 450-1 Transrec 4/19 12 ADDS Pack 13 Lightering 4/28 14 Jack Bay Spill 4/29 15 Valdez, Cordova Fishing Vessel Training 4/30 16 IRIC Training 5/25 17 Cordova CRC inspection 8/4 18 Conoco Phillips 8/30 19 Nearshore tabletop 9/1 20 Copper River Flats 9/22 21 Nearshore response 9/29 22 VMT Settlement Ponds 10/14 23 VMT Scenario 4 Drill 10/29 24 Polar Discovery Tanker assist 12/1 25 SeaBulk Arctic Tanker assist 12/12 26 Overseas Washington assist OTHER REPORTS 1/14 Towline breakage review 5-5 Krystal Sea analysis 6-24 Aware line parting 7/6 Alert line rewinding 7/9 Aware line rewinding Drill Monitor Annual Report 2004 Page 3

OTHER ACTIVITIES: CONTINGENCY PLAN REVIEW: Drill monitor was an active participating member of the project team. This involved attending weekly meetings, providing analysis and background for various escort and response issues and research into several aspects of the plan and related issues. DRILL AND EXERCISE OBJECTIVES DEVELOPMENT: In 2002 the Alaska Department of Environmental Conservation in conjunction with industry and RCAC began the process of developing standardized objectives to facilitate evaluation of industry escort and response training, exercises and drills. In 2003 evaluation standards were developed for open water responses. Nearshore evaluation standards were completed during 2004. RCAC's drill monitor was an active member of this working group. READINESS: Drill monitor maintains a state of readiness prepared to respond to an incident in Prince William Sound on a 24-hour basis and at times has assumed periodic formalized on-call duty in Valdez. This means accepting an on call status 24 hours a day in case of an oil spill. It also involves maintaining monitoring equipment for communications and documenting events, keeping batteries charged, and all stored and ready to go on a moment s notice. MEETINGS: The drill monitor regularly attends Oil Spill Prevention and Response Committee meetings, occasionally Port Operations and Vessel Traffic Committee meetings and council meetings as required. Drill Monitor Annual Report 2004 Page 4

MAJOR DEVELOPMENTS There did not seem to be an overriding theme or issue related to oil spill prevention and response exercises in 2004. however some significant changes in operations were made and exercised along with experimentation into new operations techniques that were attempted during the year. One significant change was the removal of response supervisors from escort tugs. In the past a SERVS supervisor had ridden with each escort but this was changed in 2004 to having two on duty who may or may not be on board a tug or on an escort. To assume their responsibilities during an event, Crowley masters and mates received training as initial response incident commanders (IRIC). Initially it had been a concern that this was too much to accomplish along with tug operations during an emergency, however, Crowley pointed out most of what the IRIC does would be done anyway. Of greater concern as evidenced in the training provided, was removal of initial decision making from the scene to the command center. On board IRIC was defined as largely information gathering and reporting to Operations personnel in the VEOC. Previously the SERVS supervisor could order equipment deployed on scene or sent from other sites. Thus one and perhaps two layers of decision making were added to the response away from the scene of an incident, most likely delaying the initial response deployment. Until the past couple of years, decontamination during a response had been largely an exercise of words. In 2003 plans were developed and drilled to include decon as part of any drill and exercise to refine techniques and develop strategies and equipment. On board the Transrec barges SERVS in 2004 went to what is called a dry decon system where instead of washing workers each time they moved from hot to cold zones, they removed and discarded contaminated clothing and worked their own way through a Connex placed on each of the barges with all the equipment necessary for personnel decontamination. This was demonstrated during an exercise in early February. See Report -- 752 Equipment 04 09 The Copper River Flats always have been an area of concern for RCAC and particularly citizens of Cordova including the gillnet fishermen who work the flats. Sept. 1 SERVS and several bowpickers ventured out onto the flats to test techniques and equipment. Because of weather and tides, a supply vessel, the Krystal Sea did not make the trip and instead equipment was loaded aboard the fishing vessels. On the flats this equipment was deployed in various configurations and observations and comments duly noted. A result of this exercise was a number of changes to planned strategies for the flats including loading out more powerful bowpickers in Cordova with equipment to take Drill Monitor Annual Report 2004 Page 5

to a response. Several other insights were gained as well. See Report -- 752 Nearshore 2004 20 Nine tanker assistance exercises were reported on during 2004, one of which occurred in December. Of most importance was a heavy weather exercise with the Overseas Washington in Hinchinbrook Entrance January 24. In that both a prevention/response azimuthing tug and a cycloidal drive tug attempted to control a ship suffering rudder and power failure. Weather at the time had seas approaching 13 feet and winds up to 40 mph. In both exercises, the tugs were able to bring the ship under control within the geographic limits of Hinchinbrook entrance effecting advances and transfers within one-half mile. As the PRT Aware recovered its line, the winch broke. See Report -- 752 Escort 04 06 The Aware also experienced line breaks during the year and eventually the line was rewound, a cover put over lower wraps to prevent the line from diving to the drum and the cheeks on the drum were changed as well. This was only sporadically reported through drill monitoring as others chose to observe some of the windings and alterations. One actual spill was reported in 2004, a fuel spill from a Crowley tug during an exercise in Jack Bay April 28. The estimates of the quantity spilled varied but was approximately 100 gallons. Initial response was delayed through decision making problems and eventually the best estimates showed only 15 to 20 gallons recovered. Several issues were raised by the spill and all are detailed in Report 752 Real 04 14. Drill Monitor Annual Report 2004 Page 6

ONGOING CONCERNS As part of the 1998 contingency plan review, the contractor was asked to compile a list of lessons learned over the years since the program began in 1992. That list is included again in the annual report with updates for those areas addressed during the year. WASTE STREAM MANAGEMENT: Disposal of recovered oil is an issue that has been discussed during several drills and exercises over the years, however without resolution. The most likely solution appears to be pumping secondary storage barges into a tanker of opportunity, however how to dispose of that oil has not been addressed to any extent. Apparently the recovered liquids cannot be put through the terminal's ballast water treatment plant without some measure of filtering and treatment beforehand. Putting the waste in a tanker of opportunity would take that ship out of service for a considerable period of time. The most likely disposal of a tanker full of recovered liquids is at the one R-2 refinery in Freeport, Texas which can handle highly emulsified oil. This is an issue that could be addressed and planned for prior to a spill. Solid waste disposal also has remained a question mark. This issue was discussed at length during VMT drills in 2003 and 2004 and by late 2004 a plan was reported near the exercising stage. MOVING A DAMAGED TANKER: Early drills had the ship taken to Outside Bay after an incident in the sound. This location has been questioned and no specific location to take a disabled tanker has been settled. This should be planned for ahead of time. UPDATE: During 2004 the issue became known as the bays of refuge, however drill monitor was not included in these discussions. During the Conoco Phillips drill in August, the stricken ship was allowed to return to the Alyeska marine terminal, however this was decided without consulting local officials and without any input from RCAC. GRAHAM REC SKIMMER: Even after its re-engineering in 1994/95 the skimmer s capability remains questionable, though use of it is mandated for 12 of the first 24 hours to meet the 72-hour/300,000 barrel planning standard. By definition it is to be used in a static situation in thick oil, yet it is part of a dynamic skimming operation, namely the Transrec barges. Without any testing ADEC assigned it an efficiency rating of 50%, also a questionable number considering its efficiency is based on the relative amounts of oil and water it pumps. That rating and to meet planning standard calculations was based on a pump capacity of 2,100 bph. The skimmers actually have Framo TK-6 pumps which have a capacity over 3,000 bph. Since the operator has to stand as far as 200 feet away, the ability to keep the weir at the oil/water interface is Drill Monitor Annual Report 2004 Page 7

questionable. Also, the Graham Rec has a shorter discharge hose than the Transrecs so that when it has been deployed, it does not reach the containment boom, thus limiting its ability to work in the thickest oil concentrations. Bringing the boom closer to the barge to make the Graham Rec more effective then limits the Transrec efficiencies and the skimmers most likely would tend to rob oil from each other. As late as 2003 the skimmer had not been deployed in oil, so its actual efficiency remains a question mark. It has been tested in rough water and while it maintained its floating characteristics, waves did wash over it. The VSP tractor tugs have been used for barge control in Transrec formations. Observations indicated the tugs could hold the barge in almost static position, increasing the efficiency of the Graham Rec skimmer along with the boom and Transrec skimmers. VALDEZ DUCK FLATS: Several exercises over the years have shown the planned boom configurations put the boom perpendicular to tidal currents which leads to entrainment under the boom and allows oil into the Duck Flats area. Studies of flats currents have been planned but not carried out and the boom plan has not been adjusted. Also, in winter operations, ice floats off the flats and can damage a boom or sink it. RCAC's drill monitor, an ADEC representative and SERVS personnel tested currents during a Duck Flats deployment March 17, 1999. At that particular time, currents were found to be of less velocity than could be expected to cause entrainment and from a direction making an effective angle to the boom. It was pointed out at the time, that currents needed to be studied over a variety of tide ranges in order to develop a full picture of tide direction and strength on the flats. 2004 Update: PROJECT Z404: SERVS has requested $1.1 million for a project to upgrade hatchery and Duck Flats protection. Part of an exercise June 12, 2003 was to capture items that would be included in that project request. Among considerations are new permanent anchors along the west side of the Container Dock and an evaluation of the east side boom with the idea of moving the shore side anchor point eastward to allow a better angle of boom to prevailing current in the area. None of these improvements were noted during a duck flats deployment during an exercise October 14, however the deployment was made faster than it has ever been accomplished previously. PORT VALDEZ CURRENTS: Experience in exercises and actual spills has shown currents in the port are not always predictable according to what would be the logical flow of ebb and flood tides. This has created difficulties with booms at the hatchery, Duck Flats, terminal and during various shoreline deployments throughout the port. Also, current information for Port Valdez in the ATOM model is marginal at best. Drill Monitor Annual Report 2004 Page 8

Since the port is accepted as the most likely location for a spill, studies of currents need to be made and this should include local knowledge from fishermen with experience in the port. SOLOMON GULCH HATCHERY PROTECTION: It was noted during the Eastern Lion spill in May 1994 that oil can move from Berth 1 to the hatchery in about an hour on certain tides and currents. Several improvements have been made since then in the hatchery protection program, but the deployment still takes more than four hours. It was recommended that a plan be developed for interim deflection away from the hatchery while the booms are being deployed. See Duck Flats comment above. In 2002 SERVS attempted a deployment on the west side of the hatchery in March, using CSI boom rather than the slower deploying Shore Guardian See Report 752 Nearshore 2002 05. Though tide and winds interfered with the deployment, the boom was out, in place and could have been deflecting oil away from the net pens in just about an hour, compared with four and a half or more to complete the formations with Shore Guardian. In addition, during two exercises involving the terminal, personnel addressed hatchery protection early and sent mitigating equipment between the terminal and the hatchery. BURNING: It has been shown in tests that 3% by weight of burned oil sinks to the bottom in a consistency of peanut brittle. This aspect is not mentioned in considerations before the decisions allowing burning. In 2002, SERVS personnel agreed there was a taffy-like substance after a burn, but insisted this could be recovered during the first half hour or so. It was agreed to research this aspect of burning, but to date no report has been issued. COMMUNICATIONS: There are several communications issues beginning with the fact that in a major response there won't be enough VHF frequencies to go around. Some specifics: Use of frequencies: In a nearshore exercise Sept. 22, 2004 in which two strike teams were deployed, five VHF channels were used for various parts of the operation. In a real response with as many as 45 strike teams in operation this would quickly clog VHF communications. One improvement was noted during an exercise in 2004 in which strike team vessels worked the deployments off the deployment barge on their strike team frequencies rather than designating another for the barge deck. Boom deployment: It has been observed in several boom deployments involving fishing vessels, particularly from the Barge 500-2, that there is not consistent communication with the deploying vessel. At times the fishing vessel has been Drill Monitor Annual Report 2004 Page 9

observed maintaining strain on tow lines while barge deck crew was working on the boom reel, creating the potential for a serious accident. A watch needs to be maintained to monitor the vessel and the deployment crew constantly. Also, voice commands and hand signals should be standardized. Transrec formations: Often the tug captain controlling the barge holds the command. However this operator cannot see the boom apex or the position of the skimmers within the boom. A watch should be maintained and commands given from a position at the stern of the barge in order to ensure the proper positioning of boom and skimmers. During discussions among industry, ADEC and RCAC to develop objectives for evaluating open-water exercises, communications were addressed with specific goals identified and to be included as objectives and evaluation criteria in future exercises. OFFSHORE RESPONSE: Only one exercise has been held to demonstrate offshore capabilities outside Prince William Sound. That was August 8, 1996. It happened on a very calm day near Seal Rocks and as a result did not give any realistic picture of offshore capabilities. Among questions raised from that exercise were: 1. The choice of Vikoma Ocean Boom and whether it was adequate for offshore work considering North Sea operators have abandoned it in favor of the RO 3500 which is larger, stronger and takes less tending. 2. Derated capacities of barges to meet offshore manning requirements. 3. Effectiveness of electronic communications equipment to reach the operating units. SERVS took delivery of two NOFI 1000 boom systems in 1998 for use with the Transrec barges. These appeared to be more suitable booms for offshore work and held out other possibilities as well, including helping with barge control. These booms were being refined before adding them to the SERVS inventory. To date these have not been observed in use. In 2001 SERVS did one mobilization drill sending a barge from Port Valdez to Hinchinbrook Entrance, testing response time. TECHNIQUES: Much of the strategy and technique appears to be rigid according to the contingency plan. World wide, techniques and strategies differ and training, particularly for supervisory personnel should include instruction in techniques employed by other OSROs. For example, during an exercise in Chenega during 1997, a standard technique used by Clean Coastal Waters was attempted and appeared to work with fishing vessels and the landing craft Krystal Sea. Considering the constantly fluid nature of an oil spill response, supervisors should have as many Drill Monitor Annual Report 2004 Page 10

strategies and techniques as possible available to them. In 2002 SERVS management considered this suggestion and said they would look into developing a handbook of alternative techniques. Through 2003 it did not appear this was accomplished. MATCHING FISHING VESSELS AND EQUIPMENT: Almost since nearshore operations began, fishing vessel operators have suggested SERVS match equipment with individual vessel hydraulic systems rather than place a power pack on the deck of each vessel. To date there is no evidence this has been accomplished. A large part of the difficulty with this is most SERVS equipment demands a specific type of hydraulic oil and there is no guarantee fishermen would be using the same type short of SERVS purchasing the oil for them. EXCLUSION BOOMING: The contingency plan shows exclusion booming of a bay with the boom straight across the mouth or with two layers of boom. As tidal currents generally move in and out parallel to the lay of the bay, this puts the boom directly perpendicular to the flow and, as experience in exercises has shown, causes entrainment, allowing oil into a bay that is being protected. Diversions at the points, constantly tended, provide better protection. As the development of geographic response strategies continued into 2002, baycrossing exclusion booming appeared to be the method of choice for protecting bays. A GRS exercise in July used exclusion deployments across both ends of a channel behind an island near Montague Island which showed obvious difficulty maintaining exclusion and appeared to allow considerable entrainment. The same type of booming was observed during GRS deployments in 2003. BOOM TOWING DIRECTION: Several reports beginning in 1993 mentioned vessels towing boom into the wind. This causes splashover and entrainment. Several times it had been suggested boom be towed downwind, but this has not been demonstrated to any degree in subsequent exercises. Tugs have more difficulty controlling barges downwind than they do towing upwind. This was observed in a 2002 exercise and as expected, the new VSP and PR tugs were able to maintain a steady, almost static barge position no matter what the current. However, fishing vessels towing the boom downwind experienced difficulty maintaining the formation and tended to overtake the barge because of higher towing speeds necessary to maintain the shape of the boom. ENTRAPMENT MODULE DEFLECTION BOOMS: Booms directing floating oil into a beach area for skimming over the past several exercises have been difficult to maintain as they tend to belly, collect oil and then entrain allowing oil to pass. These booms generally are anchored at the shoreline and offshore. Dynamic deflection with Drill Monitor Annual Report 2004 Page 11

two vessels holding the boom has been shown to maintain shape and better serve to keep oil away from sensitive areas. This was evidenced in GRS deployments in 2003 and in an exercise at Chenega in early December. SHORELINE PROTECTION: Though it is understood SERVS maintains its contract for shoreline protection, no exercises have been observed with this contractor since 1999. Drill Monitor Annual Report 2004 Page 12

DRILL MONITORING 2004 BUDGET/EXPENSES 2004 DRILL MONITORING BUDGET TRACKING CATEGORY PROF SERVICES MONITORING EXPENSES TOTALS OIL SPILL RESPONSE BUDGET $61,200.00 $2,911.68 $65,000.00 JANUARY $5,100.00 $0.00 $5,100.00 FEBRUARY $5,100.00 $523.44 $5,623.44 MARCH $5,100.00 $0.00 $5,100.00 APRIL $5,100.00 $0.00 $5,100.00 MAY $5,100.00 $302.80 $5,402.80 JUNE $5,100.00 $1,336.12 $6,436.12 JULY $5,100.00 $0.00 $5,100.00 AUGUST $5,100.00 $0.00 $5,100.00 SEPTEMBER $5,100.00 $0.00 $5,100.00 OCTOBER $5,100.00 $21.98 $5,121.98 NOVEMBER $5,100.00 $0.00 $5,100.00 DECEMBER $5,100.00 $0.00 $5,100.00 TOTALS $61,200.00 $2,184.34 $63,384.34 REMAINDER $0.00 $494.59 NOTE: Fiscal 2004 contract was extended twice for three months each into fiscal 2005, but with expense amount using the remainder left from 2004. Drill Monitor Annual Report 2004 Page 13

FOR THE COMING YEAR Since the beginning of the drill monitoring contract project, concern has been expressed that time and distance from Exxon Valdez in addition to improvements in the escort and response system could lead to the onset of complacence and a tendency toward false security relative to oil spills in Prince William Sound. As this will be the last annual report under that project as currently contracted, perhaps it is time to point out that complacence along with other developments may already have led to that false sense of security. Perhaps most disconcerting at least from the point of view of drill monitoring and participation is the diminishing role of RCAC in the industrial community surrounding oil transportation in Prince William Sound. There was a time when with all the changes in personnel in the industry, RCAC was considered to have the corporate memory that gave historic insight into what ever issues may develop. However, with changes in personnel, the loss of original council members and a general trend toward accommodating industry and regulators, that memory has faded along with RCAC s influence and fulfillment of its mandate to advise industry and assure the residents of the EVOS region that effective escort and response capabilities exist. Again from the perspective of drill monitoring, this was nowhere more obvious than during the Conoco Phillips drill in August. To begin with, the RCAC executive director was not even on the list of persons to be allowed into the Valdez Emergency Operations Center during the drill. Only a request to the Coast Guard and the Valdez MSO commander s intervention opened the door for the head of RCAC. There was a time when RCAC s battle was to be included in the Unified Command in order to bring RCAC issues to the process, not a battle to be let in the door. Also during that drill, a decision was made to bring the disabled tanker to the Valdez Marine Terminal. In the past this had been a major issues, with local officials absolutely not wanting a stricken ship brought into Port Valdez so close to the city. When asked if local officials were contacted about this decision, an RCAC staff person said, We didn t have to ask local officials. Whose side is RCAC on? Several times in the past few years, the RCAC drill monitor has been questioned as to the number of drills observed in a year, with the implication being that with fewer drills, maybe RCAC hasn t been getting its money s worth. Each time it was suggested that the larger issue is whether or not SERVS is performing enough exercises and drills to maintain its proficiency. Yet, no effort has been made by RCAC to encourage SERVS to perform more exercises and to open up those they do have to observation. No where was the need for this more obvious than in a surprise drill in 2003 when SERVS was Drill Monitor Annual Report 2004 Page 14

tasked with performing the most basic and best trained for operations in its repertoire and could not do it. A few months later a second drill was held during which the response was improved greatly. However since that time only one Transrec exercise was performed and observed, along with only two others that were concurrent with other exercises. In another area, RCAC joined the process with ADEC and industry to develop evaluation criteria for drills and exercises. These were written over the past two years for open water operations and for nearshore. While they do provide everyone with consistent criteria to evaluate exercises, they follow a path that could be detrimental to the RCAC mission. It has always been the belief in drill monitoring that RCAC has a slightly different obligation than regulators have. Regulators are limited to holding industry to regulatory standards. Regulation does not always provide for assurances that industry can actually do what it says it can. The biggest discrepancy is in the use of nameplate standards for equipment -- for example, granting the Graham Rec skimmer 50 percent efficiency pumping at 2,000 barrels per hour. In earlier versions of the Prince William Sound tanker plan industry even admitted nameplate was developed under laboratory conditions and a good day would see perhaps half of nameplate capacity in actual recovery. As a result, volumes stated in contingency plans are not guarantees that those amounts can actually be recovered. The recent project to address response gaps in Hinchinbrook Entrance is an effort in that direction, however it does not go far enough, nor does it seem to include people experienced with the process. It would seem RCAC s mandate from residents of the EVOS area would allow some separation from regulators in favor of what actually can be accomplished during a response. Working with regulators can be beneficial to all concerned, however citizens groups need to keep an objective distance as well, in order to protect the interests of the citizens they are tasked with representing. In conclusion, the complacence and confidence that has been expressed as a concern in the past appears to be growing, rather than diminishing and should be the primary concern for future drill monitoring as well as for RCAC in general. Respectfully submitted, Tim Jones December 28, 2004 Drill Monitor Annual Report 2004 Page 15