CHAPTER 7 Cold Weather (INCOMPLETE, see comments in Italics) Additional knowledge is needed for conducting ISB in the Arctic or other cold regions. All of the same issues and requirements need to be addressed but other considerations concerning the environment and personnel safety must be added. This chapter written in cooperation with the Arctic Council’s Emergency Prevention, Preparedness and Response (EPPR) working group. This will not address burning oil on land in polar regions. 7.1 PAST EXPERIENCES The experiences for ISB on offshore waters in ice conditions comes from years of research as no operational burns have occurred. At least 8 experimental spills have been conducted which involved ISB (Dickins 2011). These occurred off of Alaska, the Canadian Northwest Territories and Norway between 1970 and 2009. Most involved igniting oil in melt pools, on land fast ice or between ice floes (Buist 2007) but the latest involved the use of fire resistant booms. (Potter and Buist 2010). This last experiment proved that under the right conditions, a fire-resistant boom can be used to collect oil and ice and the oil can be ignited. (see Figure 7-1) Figure 7-1. ISB Experiment in Norway (SINTEF 2010) 7.2 The behaviour of oil spill in ice The complexity of an oil spill in ice can be much larger than a similar oil spill in open water. The different in oil distribution in scenarios with thick solid multiple-year and fresh first-year ice is large. Also an oil spill in an autumn freezing situation or a spring thawing scenario represents different challenges in predicting fate and behaviour of the oil. Traditionally has ISB in contingency plans targeted large quantities of oil usually gathered in the leads between the ice sheets (see Figure 7-2). 2 Figure 7-2: An illustration of the complex distribution of oil in different oil-in-ice scenarios (AMAP, 1998). The rate of the weathering processes is usually reduced in an oil spill in ice due to calmer conditions, high oil film thickness and low temperatures. Comparison between an experimental oil spill in open water (Haltenbanken-1989) and in dynamic broken ice with high ice coverage (Barents Sea 1993) is presented in Figure 7-3. There is a large difference between the water uptake between these two scenarios, giving large operational consequences regarding spill volume, viscosities, and influence area of the oil spill and life time. 90 Water content in emulsified oil (Vol.%) 80 70 60 Broken Ice (MIZ-93) 50 Open Water (Haltenbank-89) 40 30 20 10 0 -1 0 1 2 3 4 5 6 7 8 Time (days) Figure 7-3: Water uptake (volume %) in a surface oil slick as a function of time for an open water and broken ice scenario from a large-scale experiment (Haltenbanken-1989 and Barents Sea-1993 (Daling et al., 1989 and Sørstrøm et al., 1994). 3 7.3 Planning for the use of ISB in cold weather The same issues addressed for temperate climates such as identifying sensitive areas and species, understanding the risk trade-offs. The other issues unique to cold weather conditions include ice conditions and changes in the processes that the oil undergoes. 7.3.1 Ice Conditions (needs expansion) For evaluating the use of ISB, ice concentrations are the first consideration. General Guidelines are: Ice concentrations of 0-30%, use open water techniques Ice concentrations of 40-60%, attempt uncontained burning between floes. Booms may be useful in corralling ice and oil For 70-90% ice concentration, oil tends to thicken in small leads, using the ice as natural booms, and the oil may be easier to burn. 7.3.2 Ice Management There have been methods proposed to handle or deflect ice to separate the ice from the oil to facilitate recovery of the ice. This includes the use of vessels and booms for deflection or washing down the ice with water. To be supplied 7.4 Features of ISB in Cold Climate The conditions encountered in cold climates can change the properties of the oil which can influence how oil behaves. While oil is exposed to all of the same process as in temperate area, the lower temperatures can change the conditions encountered. The main processes that could limit use of ISB in Arctic areas are; 1. Weathering; make the oil more difficult to ignite (emulsification and evaporation) 2. Spreading; reduce the burn rate or burn effectiveness (spreading, interacting with ice, limiting access to oil…). The ignitability of the oil slick is often one of the main limiting processes of an ISB operation and ignitability could be reduced due to weathering processes like evaporation and emulsification. However, slower weathering in Arctic areas can reduce the effect of these processes and extend use of ISB. High burning effectiveness and high burn rates can be obtained in Arctic scenarios with thick oil layers for example oil captured between ice flows as indicated in Figure 7-2. If the oil is more spread in the ice, for example as thin layers in slush ice, burning rates could drop drastically. 7.4.1 Weathering Processes The major processes that drive the amount that the oil weathers appear to slow down in colder temperatures. In addition, the creation of emulsions also may take a different rate under these conditions due to damping of the waves by ice. These changes provide a larger window of opportunity for igniting oil in cold weather. New research of oil weathering in ice conditions indicate that the weather window could be more than 120 hours. (SINTEF 2010) When an oil spill emulsifies (water-in-oil emulsification) small oil droplets are incorporated into the bulk phase of the oil. The energy from wave action and especially breaking waves are important for the rate of this process. In open water conditions water contents can reach 60-90% dependant on oil properties. The incorporated water droplets prevents heating of the oil, by the ignite, above 100 ºC and heat has to be used to break the oil and heat the water free oil above the flash point to ignite. 4 Evaporation of light ends which raise the flash point of the bulk oil, will increase the demand of heating and could limit the ignitability of the oil. This will also be the fact with heavy bunker fuels as their content of light ends is very low. As a general rule-of-thumb, emulsified oil can be ignited when water content in the oil is less than 25%. For some light crude and fuel oils that form unstable emulsions the maximum ignitable water content can be even 50 percent (SLRoss et al., 2012 – API review) . This is because the emulsions formed by some of these oils will separate naturally when warmed. Crude oils and fuels that form stable emulsions will generally become unignitable when their water content reaches 25 percent. The point at which a slick becomes unignitable due to emulsification is a function of the oil type, ice conditions, wind/waves, other environmental cconditions (e.g. rain, snow) and the temperature of the ignition source. In ice conditions, the wave dampening effect of the ice will usually slow down the weathering processes (especially emulsification) and this will lower the water content of the oil slick. The wave dampening effect will be dependent on ice conditions (ice type, coverage and distance to open water). A recent Joint Industry Project (JIP) run by SINTEF of Norway investigate weathering both in the laboratory and in the field. Experiments in a laboratory were compared to field tests and emulsification and evaporative loss were evaluated. The field trials confirmed the laboratory studies and he results have been entered into the SINTEF Oil Weathering Model (OWM). (Brandvik, et al. 2010). For ISB, the results indicate a longer window for ignitability, but this is dependant of oil type, wind and ice conditions. 7.4.2 Oil spreading Oil slick thickness is a key parameter to determine both ignitability and burning effectiveness. If the oil is thick enough, it acts as insulation and keeps the burning slick surface at a high temperature by reducing heat loss to the underlying water. As the slick thins, increasingly more heat is passed through it; eventually enough heat is transferred through the slick to drop the temperature of the surface oil below its Fire Point/flash point, at which time the burning stops (Buist 2012). Table of required film thicknesses in here (from SLRoss et al, 2012, API review) Oil spreading in the ice (Figure 7-2) will cause thin oil films and reduced the potential of ISB. However, in many scenarios the ice will prevent the oil from spreading and increase oil film thickness. Tests performed in tanks using brash or slush ice typical during freeze-up and break-up indicate that the thickness of the oil needs to be increased over open water to obtain the same efficiencies. (Buist 2007) More on ISB in different ice conditions/film thicknesses from SLRoss 2012…? 7.5 Net Environmental Benefit Issues As in the use of ISB for other spills, the decision will be based on NEBA. In the case of colder regions near the poles, some wildlife have significant migratory patterns and the local 5 people rely on them for sustenance. Responders must be aware of the location of the species to understand when surface or subsurface response is an alternative. 7.5.1 Smoke and Soot (needs expansion) While most of the cold regions may not be near populated areas, smoke and soot are still concerns. Smoke may affect aircraft and local population centers. It can also affect birds and other wildlife as in any other location. Soot maybe more visibile if the burn occurs near clean ice and snow. Recent work indicates that soot deposition may be lower than originally calculated. (Fingas 2010) The key is that more efficient burns produce less soot. 7.5.2 Burn Residue (needs expansion) The efficiency of burning in cold temperatures may be reduced which may result in more residue. Field experiments collected residue and measured efficiencies which still exceeded 89 percent (Potter 2010) 7.5.3 Fire To be supplied 7.6 Safety (needs expansion) For operations in cold climates, additional considerations are needed to control additional risks. Besides the key risks listed in Section 4.2, responders must also consider: Operations lasting long hours during the summer season Operations limited by darkness in winter seasons Protection of personnel from the cold requires correct personal protective equipment (PPE) Exposure of the vessels and equipment to ice Freezing water and hydraulic lines, either for equipment or for supporting equipment Safety of personnel when placed on ice Transfer of personnel Visibility, movement and equipment handling in bulky PPE Potential exposure during decontamination In the polar regions, night burning can be conducted only after careful considerations for the safety of operations. 7.7 Decision Guide (needs expansion, revise charts from Chapter 2?) To be supplied 7.8 Equipment (needs expansion) The equipment used in cold conditions is the same as that in temperate waters but all may need modifications based on the risks identified previously. Some initial issues are: For open water techniques with limited ice, vessels should still be ice-qualified. For medium ice concentrations, vessels should be icebreaker qualified in order to be able to do manoeuvres to approach the oil For high ice concentrations, personnel may be placed on the ice. Local guidelines should be followed if available. 7.9 Logistics To Be supplied Moving personnel and equipment to remote locations and keeping them supplied is very difficult in the polar regions. 6 ANNEX 4 Conversation tables 7 REFERENCES AND BIBLIOGRAPHY Alaska 2008, “In Situ Burning Guidelines for Alaska,” Revision 1, Alaska Department of Environmental Conservation, US Coast Guard, US EPA Region 10, March 2008 Alaska Division of Spill Prevention and Response 2006, “Spill Tactics for Alaska Responders (STAR), http://dec.alaska.gov/spar/perp/star/docs.htm, April, 2006. Alaska Clean Seas, “Technical Manual, Volume 1, Tactics”, http://www.alaskacleanseas.org/tech-manual, June 2010. Allen, Al (2011), Nere Mabile, Senior Chief Drew Jaeger and Don Costanzo, “The Use of Controlled Burning during tha Gulf of Mexico Deepwater Horizon (MC-252) Oil Spill Response”, International Oil Spill Conference (IOSC), May, 2011. Allen, A. (1991). Controlled burning of crude oil on water following the grounding of the Exxon Valdez. Proceedings of the 1991 Oil Spill Conference. American Petroleum Institute, Washington, D.C., pp. 213-216. Allen, A. 2007, “Oil Spill Response Planning for Shell’s Offshore Exploration Program in the Alaskan Beaufort Sea, International Oil & Ice Workshop, Anchorage, AK, October 2007. Allen, A. (1999). Controlled burning of oil spills. Course book for training conducted with the U.S. Coast Guard R&D Center in Galveston, Texas, 21 June 1999. ARPEL 2006, “A Guide to In-situ Burning of Oil Spills on Water, Shore and Land, Regional Association of Oil and Gas Companies in Latin America and the Caribbean”, November, 2006. American Petroleum Institute (API) 2005, “In-Situ Burning – A Decision-makers Guide to Insitu Burning,” Publication Number 4740, April, 2005. American Petroleum Institute (API 2004), ”In-situ Burning – The Fate of Burned Oil, Publication Number 4735, April 2004. American Petroleum Institute (API 2002). Identification of oils that produce non-buoyant in-situ burning residues and methods for their recovery. American Petroleum Institute Publication Number DR145, produced under contract by S.L. Ross Environmental Research Limited. API. Washington, D.C. ASTM F1788- (American Society for Testing and Materials). “Standard guide for in situ burning of oil spills on water: Environmental and operational considerations. 2008. ASTM F1990 (American Society for Testing and Materials), “ASTM Standard Guide for In-Situ Burning of Oil Spills - Ignition Devices”, 2007. ASTM F2152 (American Society for Testing and Materials), “Standard Guide for In-Situ Burning of Spilled Oil: Fire Resistant Boom”, 2007. ASTM F2230 (American Society for Testing and Materials), “Guide for In-Situ Burning of Oil Spills on Water: Ice Conditions”, 2008. 333 Brainer N., Walton W., “ISB consequences,” IOSC, 2003, Vancouver, Canada, 8 Brandvik, Per Johan , Daling, Per Snorre, Faksness, Liv-Guri, Fritt0Rasmussen, Janne, Lundmark Daae, Ragnmark, and Leirvik, Frode, 2010. “Experimental Oil Release in Broken ice – A Large-Scale Field Verification of results from Laboratory Studies of Oil Weathering and Ignitability of Weathered Oil Spills,” Oil-in-Ice Joint Industry Project, Report no. 26. 20 April, 2010. Buist, I.A., Ross, S.L., Trudel, B.K., Taylor, E., Campbell, T.G., Westphal, P.A., Meyers, M.R., Ronzio, G.S., Allen, A.A., and Nordvik, A.B. (1994). The science, Technology, and effects of controlled burning of oil spills at sea. MSRC Technical Report Series 94-013. Washington, D.C.: Marine Spill Response Corporation. Buist, I., Potter, S., McCourt, J., Lane, P., Newsom, P., Hillebrand, L., and Buffington S. (1999). Re-engineering of a Stainless Steel Fire Boom for use in Conjunction with Conventional Fire Booms. Twenty-second Arctic and Marine Oilspill Program Technical Seminar Proceedings. Environment Canada. Ottawa. p. 545-566. Buist, I., McCourt, J., Morrison, J., Schmidt, B., Devitis, D., Nolan, K., Urban, B., Moffatt, C., Lane, J., Mullin, J.V., and Stahovec, J. (2001). Fire Boom testing at OHMSETT in 2000. Twenty-fourth Arctic and Marine Oilspill Program Technical Seminar Proceedings. Environment Canada. Ottawa. p. 707-728. Buist I., Ross S.L. Test to determine the limits to in situ burning of thin oil slicks in brash and frazil ice // Environmental Research. 2005. On-line: Ian@slross.com. Buist, Ian 2007. :”In-Situ Burning for Oil Spills in Ice-Covered Waters,” Internationa Oil & Ice Workshop, Anchorage, AK, 2007. Buist,Ian, Thomas Coe, Donald Jensen, Steven Potter, Elizabeth Anderson, Kenneth Bitting and Kurt Hansen 2003, Oil Spill Response Offshore, In-Situ Burn Operations Manual, Report No. CG-D-06-03, March 2003. Camlin, T. and Mangranaro, J. (2001). In-Situ Burn Investigation: Exercise #3, Galveston, Texas. Unpublished. Groton, CT: USCG Research and Development Center. Camlin, T. (2000). In-Situ Burn Investigation: Exercise #2, Galveston, Texas. Unpublished. Groton CT: USCG Research and Development Center. Camlin, T. (2000). In-Situ Burn Investigation: Exercise #1, Galveston, Texas. (CG-D-18-00). Groton CT: USCG Research and Development Center. (NTIS No. ADA384650). Campbell T., Taylor E. and Aurand D. Ecological risks associated with burning as a spill countermeasure in a marine environment // Proceedings of the 17th Arctic and Marine Oil Spill Program (AMOP) Technical Seminar, 1994, June 8-10. Vancouver, British Columbia. P. 707716. Coe, T.J. and Hansen K. (2001). Oil Spill Response in Fast Currents - A Field Guide, (CG-D-0102). Groton CT: USCG Research and Development Center. (NTIS No. ADA400660). Coe, T.J. and Gurr, B. (1998). Fast Water Oil Spill Response; A Technology Assessment. (CGD-18-99). Groton CT: USCG Research and Development Center. (NTIS No. ADA369279). 9 Day Th., Mackay D., Nadeau S. and Thurier R. Emissions from in situ burning of crude oil in the Аrctic // Biomedical and Life Sciences and Earth and Environmental Science. 1979. Volume 11, Number 2 / February. Daykin, M., Sergy G., Aurand D., Shigenaka G., Wang Z., and Tang A. Aquatic toxicity resulting from in situ burning of oil-on-water // Proceedings of the 17th Arctic and Marine Oil Spill Program (AMOP) Technical Seminar. 1994. June 8-10. Vancouver, British Columbia. P. 1165-1193. DeCola E., Rodertson T., Fletcher S., Offshore Oil Spill Response in Dynamic Ice Conditions Nuka Research and Planning Group, LLC; Susan Harvey WWF, April 2006, 74 p. Dewling, R.T. and Leo McCarthy. Chemical treatment of oil spills. Environment International, 1980, 3, #2, pp155-162. Dickins, Daveid 2011, “Behavior of Oil Spills in Ice and Implications for Arctic Spill Response”, Paper NO OTC22126, Arctic Technology Conference, Houston, TX, February 7-9, 2011. Ferek R., Allen A. Allen, Kucklich J., Air quality consideration involving ISB. Marine Preservation Association, AZ, 1997, 29 pp. Fingas M., Ackerman F., Li K., Lambert P., Wang Z., Bissonnette M., Campagna P., Boileau P., Laroche N., Jokuty P., Nelson R., Turpin R., Trespalacios M., Halley G., Belanger J., Pare J., Vanderkooy N., Tennyson E., Aurand D., and Hiltabrand R. The Newfoundland Offshore Burn Experiment: NOBE preliminary results of emissions measurement // Proceedings of the 17th Arctic and Marine Oil Spill Program (AMOP) Technical Seminar. 1994. June 8-10. Vancouver, British Columbia. P. 1099-1164. Fingas, M. and Punt, M. (2000). In-situ Burning - A Cleanup Technique for Oil Spills on Water. Environment Canada. Ottawa, Ontario, Canada: Emergencies Science Division, Environmental Technology Centre. Fingas, Merv 2010. « Soot Production From In-situ Oil Fires : Literature review and Calculation of Values from Experimantal Spills », proceedings of the Thirty-third AMOP Technical Seminar on Environmental Contamination and Response, Halifax, June 7-9, 2010, pages 1017-1054. Guidebook. Developing Consensus Ecological Risk Assessments: Environmental Protection in Oil Spill Response Planning. Ecosystem Management & Associates, Inc. 2001. IMO, 2005, “Manual on Oil Pollution, Section IV-Combating Oil Spills, International Maritime organization, London. IMO 1995, “Guide to Producing Environmental Vulnerability Maps" The International Maritime Organization/International Association of Petroleum Industry Representatives, approved by the 37th Session of the Marine Environment Protection Committee of the International Maritime Organization on October 11, 1995. IMO 2010, “Manual of Oil Spill Risk Evaluation and Assessment of Response Preparedness”, The International Maritime Organization on October 11, 1995. IPIECA, 1996. Sensitivity mapping for oil spill response. Vol. 1. London: IMO-IPIECA, 1996. 10 IPIECA, 2000. Choosing spill response options to minimize damage. Net Environmental Benefit Analysis. IPIECA Report Series. Vol. 10. 2000. ITOPF, 2011, About Marine Spills, International Tank Owners Pollution Federation Limited Internet Site, http://www.itopf.com/marine-spills/fate/models/ Kulkarni A.,Walton D, Buffington S., and Mullin J, “ Combustion of Oil and Water-in-Oil Emulsion Layers Supported on Water,” Grant no. 60NANBD0036, National Institute of Standards and TechnologyUS Department of Commerce2000, 39 pp. NIST SP 995 “In situ burning oil spills” Resource Collection, CD, Willam D.Walton, Editor, March 2003. McCourt, J., Buist, I., Pratte, B., Jamieson, W., and Mullin, J. (1998). Continued development of a test for fire booms in waves and flames. Twenty-first Arctic and Marine Oilspill Program Technical Seminar Proceedings. Ottawa, Canada. p. 505-528. Moore J. Long term ecological impacts of marine oil spills // Proceedings of International Conference “Inter Spill – 2006”. London, 2006. No pages. Perring, A.E. et. al. (2011), “Characteristics of black carbon aerosol from a surface oil burn during the Deepwater Horizon oil spill,” Geophys. Res. Lett., 38, L17809, doi:10.1029/2011GL048356. Potter, Steve 2010, “Tests of Fire-Resistant Booms on Low Concentrations of drift Ice – Field Experiiments May 2009,” Oil in Ice Joint Industry Project, Report NO. 27, SINTEF Materials and Chemistry, March 20, 2010. Ross, S.L. A review of in situ burning as a response for spills of Alaska North Slope crude oil in Prince William Sound. Prepared for Prince William Sound Regional Citizens Advisory Council. 1997. May 20. Environmental Research Ltd. SMART: A Guided Tour http://response.restoration.noaa.gov/book_shelf/648_SMART.pdf 11 Shigenaka G., Barnea N. Questions about in situ burning as an open-water oil spill response technique // National Oceanic and Atmospheric Administration. HAZMAT. Report 93-3. 1993. June. 42 pages. SINTEF 2010, Joint industry program on oil spill contingency for Arctic and ice-covered waters, Oil on Ice, JIP, Report no.:32, April 10, 2010. Stahovec, J.G., Urban, R.W., and Wheelock, K.V. (1999). Water-cooled, fire boom blanket, test and evaluation for system prototype development. Twenty-second Arctic and Marine Oilspill Program Technical Seminar Proceedings. Environment Canada. Ottawa. p. 599-612. Thomassen J., Moe K.A., Brude O.W., Chivilev S.M., Pogrebov V., Gavrilo M., Zubarev S., Khlebovich V., Semanov G. A Guide to EIA implementation in INSROP phase 2. INSROP Working Paper II.5.10. No. 142-1999. United States Environmental Protection Agency (EPA 2011), http://www.epa.gov/bpspill/airmon.html. Walton, W.D., Twilley, W.H., Mullin, J., and Hiltabrand, R.R. (1998). Evaluating a protocol for testing fire-resistant oil spill containment boom. Twenty-first Arctic and Marine Oilspill Program Technical Seminar Proceedings. Environment Canada. Ottawa. p. 651-672. Walton, W.D., Twilley, W.H., Bryner, N.P., DeLauter, L., Hiltabrand, R.R., and Mullin, J. (1999). Second phase evaluation of a protocol for testing fire-resistant oil spill containment boom. Twenty-second Arctic and Marine Oilspill Program Technical Seminar Proceedings. Environment Canada. Ottawa. p. 447-466. Walton, William D., Editor, Joseph V. Mullin, Project manager “In Situ burning of oil spills: Resource Collection”. MMS, NIST, NIST SP 995, CD, Volume 1 and 2, March 2003. Westphal P., Taylor E., Aurand D. Human health risk associated with burning as a spill countermeasure // Proceedings of the 17th Arctic and Marine Oil Spill Program (AMOP) Technical Seminar. 1994. June 8-10. Vancouver, British Columbia. P. 685-705. World Wildlife Fund (WWF 2006), “Offshore Oil Spill Response in Dynamic Ice Conditions, “2006, April. World Health Organization (WHO) 2011, http://www.who.int/topics/air_pollution/en/ ANNEX 1 TEMPLATE FOR NATIONAL POLICY FOR THE USE OF IN-SITU BURNING (ISB) Executive summary This annex proposes a template for national policy for the use of in-situ burning (ISB). This document has been prepared for as a single document to be used separately from the other parts of the Guidelines. It describes what to be designed to assist competent authorities (regulators and managers) to define, develop, and/or revise a National Policy Document for the use of ISB. National competent authorities in charge of revising/developing the national policy for the use of ISB can adapt the current template to suite its national requirement. In this respect, the document offer the possibility to simply fill-in the “blanks” in blue italic according to national the structure and requirements. This Policy document considers successively each task to be completed to set a National Contingency Plan for In-situ or controlled burning (ISB). The document is built in such manner the reader can find at the beginning (chapters 1 to 6) and/or in each chapter the justification for these requirements. It is known that efficiency of an ISB operation is function of the degree of preparation of the operation itself. In this respect, the document lists what should be prepared before the spill incident in the planning stage in terms or scientific (e.g. burnability studies, principles for NEBA analysis, geographical limit….), technical (e.g. selection of vessels and equipment…) and logistical (e.g. pre-authorisation for flight, monitoring….) issues. Considering the environmental limitations for, the text proposes figures in terms of minimum depth and minimum distance to the coast; these figures are reasonable compromise of current knowledge on ISB. However they can be adapted to cope with the general views at the national level. More, the document proposes basic practical recommendations how to conduct a NEBA on which will be based the decision on the use of ISB. This document also facilitates decision making procedures when considering the application of ISB at the time of the incident. And decision scheme is proposed through 3 essential basic questions: oil burnability, potential impact, and logistical capability. The document tackles what should be prepared to operate the different means needed to manage properly the operation including with resort to foreign resources. At last but not the least the document lists also the requirements to keep the National Contingency Plan on ISB up to date by the completion of drills and training. -1- Template for National Policy for the Use of ISB Part II proposes a template for national policy for the use of ISB. This document has been prepared as a single document to be used separately from the other parts of the Guidelines. It describes what is to be designed to assist competent authorities for the revision or development of the national policy for the use of ISB including. It also facilitates decision-making procedures when considering the use of ISB at the time of the incident. National competent authorities in charge of revising/developing the national policy for the use of ISB can adapt the current template to suit their national requirements. In this respect, the document offers the possibility to simply replace what is in blue italics with the information related to national the structure and requirements. Considering the environmental limitations for ISB, the text proposes figures in terms of minimum depth and minimum distance to the coast. These figures compromise reasonably the current knowledge on ISB. However, they can be adapted to cope with the general views at the national level. -2- TABLE OF CONTENTS 1. Preamble. 2. Objectives of ISB. 3 The ISB process. 4. Role of the ISB response option in the at sea combating strategy. 5. Advantages and disadvantages. 5.1 5.2 6. Advantages Disadvantages Recommendations for the use of ISB. 6.1 Recommendation for the decision making on the use of ISB. 6.1.1 6.1.2 6.1.3 6.2 6.3 7. The decision making process. Logistics related to ISB. ISB Processes 7.1 7.2 7.3 7.4 7.5 8. Oil burnable and non burnable Locations where the ISB can be undertaken. Logistics for ISB. On location ISB efficiency test and ISB monitoring. ISB procedure. Assistance to foreign experts. Involvements on fisheries activities. considerations regarding the public perception and the external communication associated with ISB Precautions and operational recommendations. 8.1 8.2 8.3 Drills. Training. Protection of persons and equipment. 3 Template for National Policy for the Use of ISB In “Country Name” Marine Waters 1. Preamble ISB is one of the response options to combat oil spillages. This technique is designed for offshore and not for shoreline situations. This technique has clear operational advantages, however it requests some precautions. These points are developed in this document which is to be used in conjunction with the National Oil Spill Contingency Plan (NOSCP). 2. Objectives of ISB ISB aims at minimizing the impact of oil pollution. The use of ISB at sea aims at reducing the amount of oil which would reach the coast, or environmentally or economically sensitive areas. 3. The ISB process The ISB process consists of safety containing oil in a fire resistant boom or by the use of physical constraints (e.g. ice floes) and performing tactics that make it thick enough to ignite. The burning oil is than closely monitored for smoke and residuals in order to reduce the overall impact. By removing the oil from the surface it helps to protect waterfowl that may land/hunt at the surface as well as stopping the wind effect on the oil slick’s movement that may otherwise push the surface slick towards sensitive areas (often the shoreline). 4. Role of the ISB response option in the at sea combating strategy At sea there are different response options: Recovery possibly associated with Confining, Dispersants, In Situ Burning, Monitor and Wait for action – refer to IMO manual). In the decision making process, each of these options considered alone and/or combined should be examined in a comparative way. ISB is generally not compatible with the other response options (especially the confining and recovery). However, in the same case of pollution, the use of ISB simultaneously with other response options can be considered on different locations. 5. Advantages and disadvantages 4 5.1 Advantages: 5.2 Efficient and quick removal of large volumes of oil from the water surface. Fewer logistic, storage and personnel requirements than mechanical recovery methods. Prevention of oil from affecting shorelines, where cleanup is slower and more costly, and the environment is more fragile. Useful in situations where other options are not feasible (e.g., in ice conditions and spills in very shallow water). Disadvantages: Large fire and smoke plume Residues heavier than water that are difficult to track Limited operational window Cannot be used during severe weather 6. Recommendations for the use of ISB. 6.1 Recommendation for the decision making on the use of ISB. Taking into account that ISB can be most efficient only during the beginning of the oil release, it is of utmost importance that the decision to use or not to use ISB can be taken very quickly, without loss of time in assessment and discussions. The speed of decision depends on a close preparation in which decision criteria will have been first studied from the physical, environmental and logistic viewpoints. 6.1.1 Oil burnable and not burnable The effectiveness of ISB depends on the nature of the pollutant. The factor to be evaluate include oil type, and environmental conditions The viscosity of an oil pollutant increases with the time spent in the environment (since the release), under the effect of ageing (evaporation, emulsification), so its burnability tends to also decrease with time: Higher temperatures and higher wind speeds tend to accelerate these characteristics. In general, an oil pollutant is burnable only during a 5 certain time -We speak about “window opportunity for ISB”. This time varies among products and may change wither respect to weather. For example, the window for the same type of oil appears to be longer in cold/Arctic conditions. To have an idea of the density of an oil pollutant, and/or its “window opportunity for ISB”, certain data-processing models designed to estimate the evolution of a pollutant according to its nature and the environmental conditions can be used (model of ageing: ADIOS freeware from US NOAA1). On the other hand, in terms of environmental concerns, non persistent oils - refined products, (e.g. petrol, diesel oil, kerosene.) do not require the application of ISB as they are expected to evaporate and self disperse when released at sea. On these products ISB should not be considered for safety reasons. General information for favourable/unfavourable burning is given in Table 1 below. Reminder in order to prepare the ISB response option: for oils frequently transported inside or in the vicinity of “COUNTRY NAME” waters / regularly imported in “COUNTRY NAME harbours”, specific studies should be conducted on these oils in order to assess the windows of opportunity for ISB (time delay during which the oil remains burnable): 1 National Oceanographic & Atmospheric Administration [lien] 6 i) ii) weathering study using modelling (e.g. ADIOS); completion of lab tests to assess oil burnability. Results from these studies are given in the document “to be specified” in form of tables giving the [oil viscosity / the window of opportunity] of each studied oil according to different environmental conditions (temperature, wind) – to be done by “administration or institute in charge” in collaboration with “list of administration, institutes etc involved”. 6.1.2 Locations where ISB can be undertaken The potential toxicity of the plume and residue can affect marine fauna, flora and people, hence ISB is not applicable everywhere. The proximity of the smoke plume to people also will remove some areas from consideration. ISB is not generally adapted on or in the immediate vicinity of the ecologically vulnerable or sensitive areas and in shallow water. The definition of the areas where ISB can be reasonably undertaken is a relatively complex and long process since it must take into account different local environmental parameters and data (current, biological diversity…). Such a task would be hardly carried out during an incident. Areas where ISB can be reasonably undertaken from an environment point of view should be pre-established and geo-localised: geographical limits for the use of the ISB. The choice of these areas should be based on studies of scenarios which aim at comparing the evolutions and the environmental and socio-economic impacts of the pollutant of burnable and non-burnable oil (reference to the concept of “NEBA” Net environmental benefit analysis – IMO/UNEP Guidelines). These studies of scenarios would take into account all local characteristics: type of ecological and socio-economic resources – marine protected areas and the fisheries related resources-, currents, seasons – climate variations and migrations of the marine species of interest… (a summary of these issues is given in the table below). The geographical limits must be defined for increasing spill scenarios, corresponding to pollution situation of Tiers 1, Tiers 2 [expected up to 200 t of oil] and Tiers 3 [expected: larger than 200 tons of oil]. As a general regulation, ISB operations can be achieved in the following limits: Off the [proposed depth: 20 m] isobath depth and [proposed distance: 5 Km] distance to the shore for burning Tier 3. 7 Off the [proposed depth: 10 m] isobath depth and [proposed distance: 5 Km] distance to the shore for burning Tier 1 and Tier 2. However, a technical committee, - led by “name of the administrative body in charge”, - and composed of: “list of the administrations, laboratories, institutes, harbour authority, private bodies... involved” 1. 2. 3. etc… with consultation of : “list of the administrations, laboratories, institutes, harbour authority, private bodies…. involved” 1. 2. 3. etc... - - The technical secretary of the technical committee is carried out by “name of the administrative body in charge”, will examine and study, when necessary [on areas of special interest such as harbour entrance (risky area), marine protected areas (high environmental interest: fisheries and marine critical habitats)], modifications of these general limits at local scale to take into account local characteristics (environmental and socio-economic). This technical committee can take advantage of consulting Non Governmental Organisations dealing with marine conservation, scientific experts in marine environment. Considering harbour areas “list of the concerned harbours”, the possibility of using ISB should be examined on realistic scenarios in terms of quantity of oil to be involved in expected spill incidents, the main locations where the risk for incident is the most important, the prevailing weather conditions, the tidal stream and the surface agitation. These scenario studies will aim at comparing realistically (according to the available equipment) the possibilities for containment and recovery, ISB and letting oil to come ashore for shoreline cleanup. For each of these options the environmental damage and the associated cost will be considered and compared in order to determine the most appropriate option. “Name of the administration in charge” is in charge of conducting these investigations. The charts of the limits are integrated in the contingency plan. They assist persons in charge of the response to decide without delay to burn or not (to decide quickly as long as the pollutant is still burnable). 8 The local specific regulations to the use of ISB decided by the commission are presented (or described) as charts in the Annex “to be specified”. These charts are regularly updated by “name of the administration in charge” under the supervision of the technical committee designed above. Note on the use of oil spill ISB in inland waters: in inland waters the rationale can be different and the environmental considerations may differ. This document deals only with the marine application and not with the use in inland waters or in marshland. Summary Basic principles to set environmental considerations to the use of ISB particularly in coastal waters As a first approach, the following basic principles can be considered: 1) Consider the use of ISB in open sea / offshore / away from sensitive resources, to avoid oil to reach the shoreline or possibly sensitive items (where water quality need to be preserved). 2) Generally speaking, no use of ISB on or in the immediate vicinity of sensitive items. 3) On coastal areas where several sensitive items are of concern, NEBA based on realistic scenarios is needed. 4) When NEBA needed: a. Local sensitive items should be listed and their possible vulnerabilities assessed; b. Consider the NEBA approach in terms of vulnerability rather than sensibility (vulnerability=sensitivity and restoration time); c. If conflicting conclusions: o Preserved the habitat before the species; o Preserved the reproduction possibilities rather the young stages; 5) Warning: special concerns for the application of ISBs when the wind is blowing in the direction of wildlife or populated areas 6.1.3 Logistics for ISB application Note 1: The use of ISBs should be a response to incidental pollution; in sheltered area, a chronic-usage on repeated can of lead to chronic Logistics required for the incidents application ISB includecontamination. the vessels, containment systems and ignition capability. These products and means required are listed in the contingency plan (location, quantities, characteristics, compatibility, availability, operational limit conditions and mobilisation and deployment timeframe) such as: operational stocks of fire-resistant boom; towing vessels capable of handling boom spotter/control vessels; facilities from where means would be deployed (airports, ports…). 9 and eventually: aerial surveillance aircrafts aiming at following, and guiding the operations; communication means; transport means... The plan must include information (characteristic, performances, requirements, and conditions of availability ...) related to the equipment which are likely to be mobilized: at national level public and private equipment; at regional level equipment available through bilateral or regional agreement(s) with neighbour countries; at international level equipment available through international, regional, subregional or bilateral agreements or through contracts with international cooperative companies. The plan provides details on the persons in charge of the equipment (contact person). “Name of the administration in charge” in cooperation with the stakeholders (private companies, ports….) is in charge of keeping the listing of equipment and related logistics up to date. 6.2 The decision making process The decision at the time of the incident is led through 3 questions: Q1) Is ISB a priori possible or not from a physical point of view? That is, is the condition of the pollutant compatible with ISB? This question refers to the recommendations put forth in § 7.1.1. Q2) Is ISB acceptable from an environmental point of view? Is the pollution located in an area where a priori ISB is possible? This question refers to the recommendation mentioned in § 7.1.2. Q3) Is ISB feasible from a logistic point of view? Are the logistics available (products and spraying equipment) a priori available and sufficiently mobile to conduct the operation within the time limit (period when ISB remains effective “window of opportunity for ISB”)? This question refers to the recommendation mentioned in § 7.1.3. 10 At the time of the incident the decision of using ISB is taken by “name of the administration in charge”. For this decision “name of the administration in charge” can request the assistance of other relevant institutions. See Annex 1 Decision tree for decision making process which details the decision making process. Note on the use of oil spill ISB in inland waters: the depth of water, the location of sensitive areas and population locations are primary issues and ISB is generally not recommended except for very large lakes. 6.3 Logistics related to ISB The application of ISB requires a complete logistics; in addition to the ignition equipment, it is necessary to envisage the logistics to carry this equipment (ships,), the required consumable (in particular fuel), adapted facilities (port, airport and runways) as well as other related provisions (e.g. means of transport of the equipment). In addition, provisional plans for evaluation of the final residue locations should be considered. The equipment used for the ignition of the ISB is either hand-held or aircraft deployed. Use of hand-held igniters is recommended for offshore or small applications. Use of aerial ignition techniques is recommended for larger near-shore spills if a suitable airport or landing area is available. The choice of the ignition equipment should be approved by “name of the administrative body in charge” with technical advice of “list of the administrations, institutes and/or private bodies involved”. Aircrafts can be in “COUNTRY NAME” or coming from external countries; they can belong to public sector or to private companies. In case of aircrafts owned by external private or public bodies, contracts should be set to ensure the availability of the equipment at the time of the incident (e.g. availability within 6 hours after call for mobilization.). Reciprocal compatibilities of the equipment and materials deployed must be checked in order to guarantee the reliability of the whole logistic chain (e.g. compatibility of the containment systems with the ships, compatibility of planes or helicopters with the local facilities…). Moreover, for these aircrafts, the different authorisations linked to the Civil Aviation regulations should be prepared in advance in order to allow a fast deployment of the aircrafts at the time of the incident. Operational stocks of ISB equipment: In order to ensure prompt ISB application, fireresistant booms must be set up. These stockpiles should be quickly deployed. They must 11 be also dimensioned to enable a reasonable amount of time of burning depending upon a potential spill. The fire-resistant boom stockpiles are checked periodically (physical parameters – aspect, operating mechanisms, (pumps, reels,...)….) to check their good comdition. (suggestion: periodic checking plan: every year). An inventory of stockpiles of fire-resistant booms and certified vessels should be kept upto-date. The public stockpiles of ISB are under the responsibility of “name of the administrative body in charge”. Considering the equipment, “name of the administrative body in charge” makes an inventory of the possible available resources at a regional level (e.g. existing vessels or spotting aircraft) Considering application equipment taking into account that private resources will be needed contracts must be set with bodies owning this equipment. “Name of the administrative body in charge” is in charge of establishing contracts with fire-resistant equipment and vessels which are planned to be mobilised in the contingency plan. “Name of the administrative body in charge”, keeps updated the inventory of equipment and products available from public and private sector. 7. ISB Procedures 7.1 On location ISB efficiency test and ISB monitoring The weathering degree of the oil is generally unknown; therefore the burnability of the pollutant remains uncertain when the treatment starts and further. For this reason, any ISB operation should begin with careful observation of the burn effect (e.g.). It is necessary to carry out when starting an ISB with a test burn in order to decide whether to continue or to stop the ISB application and establish ignition parameters and processes. Such tests should be repeated along the operations to check periodically the ISB keeps efficient. When available, remote aerial sensing techniques such as IR can be used to confirm the disappearance of the surface oil resulting from the ISB process. “Name of the administrative body in charge” must designate the person on location who will complete these controls in order to be informed on the efficiency of the burn. 12 “Name of the administrative body in charge” in consultation with the Ministry Responsible for the Environment will decide to continue or to stop the burn. 7.2 ISB procedure Success of an operation is based on the determination of burn procedures. The burn should be conducted: on the thick parts of the slick (colour brown to black) without taking into consideration the thinnest parts (iridescence, shine…); in a systematic way, taking into account the wind; (Reference Appendix 6 – Operational procedures from IMO / UNEP recommendations on ISB application) and ISB guide at TBD. As often as possible, ships with containment equipment are guided during the ISB operation by a spotter aircraft which indicates the slick zones where the ISB should be targeted. When necessary, these parts to be burned can be marked out (with buoys or smoke canisters). As often as possible, the burn is monitored in order to assess its efficiency; such a monitoring can be carried out by estimating burn rates and collecting residues, or by aerial photography or remote sensing technique (e.g. IR) to assess the amount of oil remaining on sea surface (reduction of the slicks due to the ISB process). This monitoring can be useful to justify the decision to use ISB and to claim for compensation afterward. “Name of the administrative body in charge” with, if necessary, the help of other institutions, is responsible for organising the monitoring of the efficiency of the ISB. 7.3 Assistance to foreign experts / operators In case of large incident (Tier 3) involving foreign experts / operators (from neighbouring countries, international service companies...), it is necessary to plan national contact persons in charge of welcoming these external teams and facilitating their involvement in the national context (example, a contact person at the airport to take care of a foreign team in charge of running a spraying aircraft, for accommodations, jet-fuel supply, various authorisations…). Foreign exchanges and cooperations can be pre-planned through formal agreement set at the regional level between neighbouring countries, or at the international level, (e.g. with Specialized International Service Companies, ). 13 7.4 Involvements on fisheries activities The ISB of significant amount of oil may impact some environmental resources as fisheries (e.g. areas where trawling nets are used or a bottom species is harvested. Methods to evaluate the sea bottom for the location of residual oil should be considered. The monitoring of the effects of the use of ISB as well as the appropriate decisions (e.g. fishing ban) is under the responsibility of the “name of the administrative body in charge” in consultation with the “list of the administrations, institutes and/or private bodies involved”. 7.5 considerations regarding the public perception and the external communication associated with ISB treatment operations The main issues with public perceptons are the smoke and the burn residue that may remain. 8. Precautions and operational recommendations 8.1 Drills Drills are organized periodically to validate the combating procedures, to train the operators and to check the capability of the contingency plan (through table top exercises to check the availability of persons to be mobilized – level 1 exercise) and through practical field exercise to check the capability of the combating equipment to respond to a pollution situation (through real simulations, mobilizing people and equipment on site – level 2 exercise). One level 1 exercise (table top) per year should be organised in each riparian district, and one level 2 exercise per year should be organised at the national level, in a different riparian district each year. Level 2 exercise could be organised in the frame of the whole NOSCP (National Oil Spill Contingency Plan) (involving other techniques than ISB). Corrective actions will be taken according to the observations made during the exercises. Drills are coordinated by the “name of the administrative body in charge” with the concerned organisations. 8.2 Training 14 People in charge of operating the ISB equipment are specifically trained. This training can be integrated in the general training plan planed in the NOSCP (National Oil Spill Contingency Plan). The “name of the administrative body in charge” coordinates and supervises the training. 8.3 Protection of persons and equipment People in charge of the burning operations are protected against smoke (Individual Protective Equipment; e.g. mask, protective impermeable clothes, gloves…). Solid surfaces (especially ship decks) are protected by maneuvering the boom so that the smoke moves down wind and away from the towing vessels. Equipment is rinsed with fresh clear water after use. 15