DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Prince William Sound District Office, Drawer 1709, Valdez, AK 99686
Dennis Kelso, Commissioner/ADEC October 20, 1989
Amy Kyle, Deputy Comm/ADEC
Larry Dietrick, Director/EQ
Bill H. Lamoreaux, Reg.Sup/SCRO
Robert C. Flint, Prog Mgr/SCRO (907) 835-4698
Dan Lawn, Supervisor, PWSDO
NORWAY TRIP REPORT
This trip was very informative. It could have been more so if approval to go had been granted earlier.
As it was, I was able to make arrangements for some meetings once I arrived; however, there were many government and industry officials as well as their facilities that I was not able to see. The facilities that I did see and officials with whom I met provided a great deal of information that I have compiled in the following trip report.
My overall findings are briefly summarized below:
Strong laws administered by strong regulative procedure produce a cooperative industry that prevents pollution. The industry knows that they will pay for all cleanup costs regardless of who performs the cleanup. The industry is also required to have vast quantities of cleanup equipment with which to respond to a spill in an effort to keep it off the shores. In addition, the Norwegian government has large stockpiles of equipment ready to combat an oil spill.
CONTROL OF AN OIL SPILL IS CONSIDERED WAR AND ITS CLEANUP IS A COMBAT ACTIVITY!!
2 Purpose of Trip
2 Information Obtained
2 I. Norway
2-3 A. Regulatory Authority and Responsibilities
4 B. The Oil Industry's Attitude
4-5 C. Offshore Exploration and Production
6-8 D. Oil and Gas Pipelines, Offshore Loading Buoys, Terminals and Refineries
8-10 E. The "Tactical Oil On Water Exercise"
12 II. Scotland's Shetland Islands.
12-14 A. Regulatory Authority and Responsibilities
14. B. The Oil Industry's Attitude
14-15 C. The Terminal at Sullom Voe
15-16 D. Meetings at Sullom Voe
17-18 III. Norway Revisited
18-20 IV. Comments on Spill Response Equipment
20-21 V. Comments on Spill Prevention
21 VI. Comments on Risk Exposure
PURPOSE OF TRIP
The purpose of the trip was threefold:
1) To observe the "Tactical Oil-on-Water Exercise" conducted by Statoil, Amoco, and NOFO in Norway's North Sea Firgg gas field on September 19 - 22, 1989.
2) A side trip to the Sullom Voe Terminal in Scotland's Shetland Islands to observe their operation.
3) To meet with as many individuals as possible concerning oil pollution control as time would permit.
II. Scotland's Shetland Islands
- Regulatory Authority and Responsibilities
- 1. The Norwegian Government has a very committed attitude to protect the environment while developing their oil resources. To do this they have (i) central acts and regulations issued through Royal Decrees and (ii) regulations and guidelines issued pursuant to the central laws and regulations. Norway's main philosophy is "the one doing the activity is responsible for their actions". All industry accepts this. However Norway does not leave it with industry's promise to perform. Norway has developed several ministries and organizations that regulate the oil industry from the oil spill prevention and response perspectives. All of Norway's resources for cleanup response are available to combat an oil spill. Each and every oil spill training exercise includes industry, NPD,SPCA, local authorities and the Navy.
- 2. To implement their laws on the national level, prevention side, the Norwegian Petroleum Directorate (NPD) is ascribed authority related to the supervision of exploration, research drilling and surveys for natural resources on the Norwegian Continental Shelf. There are also other National Ministries who regulate the oil industry from the spill prevention side. The NPD was set up in 1973 as the Regulatory Authority for work on the Norwegian Continental Shelf. The NPD's area of influence is 56°N - 88°N. In the early days of the NPD the operators had no requirement to have their facilities in compliance prior to an inspection. Now the operator is required to have an extensive QA/QC Plan (thanks to a 1985 Royal Decree) and their facilities must be in compliance at the time of inspection. The NPDS also has stockpiles of cleanup equipment that are available to supplement cleanup activities should the spiller need additional equipment.
- 3. On the national pollution response side, the State Pollution Control Authority is assigned the role of Norway's On-Scene Coordinator. In that role they oversee the spiller's cleanup response, provide technical assistance and direct the spiller to take appropriate action if necessary. They are also charged with protecting Norway's coast. To do this there is an extensive network of people and equipment located at 12 depots along the Norwegian Coast. Total cleanup capacity is 15,000 bbls/hr. At each depot there are 10 people assigned on an "on-call" basis. The state training and inspection center located at Horten has a staff of 15 who oversee the large warehouse of cleanup equipment and provide training for the NPD, industry, local authorities as well as the in-house needs. SPCA's annual oil pollution budget is $3,000,000 for operation and for new equipment there is an additional $1,500,000, all of which is funded from Norway's general tax assessments. The SPCA equipment and personnel are available to supplement any response effort the spiller takes.
- 4. On the local level is the "Regional Oil Pollution Control Committee", an inter-municipal organization which consists of cooperating communities located within a particular region usually around the perimeter of a port or fjord where there is oil shipping activities. Each municipality is required to have necessary staff and equipment ready to prevent damage from small oil spills which may occur within its sea area or coastline. Their equipment and personnel are likewise available to the spiller to supplement the spiller's response. Each municipality also has a plan for oil spill protection. In addition to the mentioned "First Aid" equipment and local staff required for each community, the inter-municipal committee has a common oil spill emergency center in each region, with considerable equipment and also trained staff available on short notice. Funding for cleanup equipment and setting up each municipal response organization was provided 50% by the Norwegian Parliament with the balance by the local municipalities. All costs of cleanup is reimbursed by the spiller.
- 5. The Norwegian Navy also has vessels, personnel and cleanup response equipment that participates in spill response as well as training exercises with industry.
- The Oil Industries' Attitude
- 1. The oil industry in Norway seems to have a very cooperative attitude. This, in part, may be due to the fact that some oil companies such as Statoil (100%) and Norsk Hydro (49%) are owned in total or part by the Norwegian government. In addition the pipelines from the offshore fields and the major oil shipping terminals are owned in total or part by Norway. Many of the offshore fields are operated by the Norwegian owned oil companies or partnerships that include them. Those fields that are operated by multi-national oil companies are quick to comply with all requirements. Another major factor contributing to the oil industry's "cooperative" attitude is strong laws and regulations enforced by NO NONSENSE STRONG REGULATORS. They do not bend to the wishes or lobbying efforts of the oil industry. To this end, the oil companies are ready to comply with all regulatory requirements and to do so in a very open and agreeable way.
- Offshore Exploration and Production
- 1. All offshore exploration and production facilities are required to have state of the art oil spill contingency equipment. All of the drilling and production companies, whether they be multi-national oil companies, state owned oil companies or partnerships of different combinations of both, must have adequate cleanup capability.
- 2. In addition to their own individual oil spill contingency plans in order to accomplish the government mandated requirements, the oil companies have formed a cleanup cooperative called Norsk Oljevernforening for Operatoselskap hereafter called NOFO. On behalf of, and together with, the operating companies NOFO looks after the authorities' requirements for oil spill contingency. The association handles this task by having prepared a special contingency plan for mobilization and operation of the jointly-owned resources. NOFO has, in addition, set up depots of equipment and engaged personnel and vessels that are on permanent standby. In the event of an uncontrolled oil spill, any member of NOFO has access to the association's resources as part of its overall contingency scheme. This enables the operating companies to take action at short notice.
- 3. The thirteen sisters; AMOCO, ESSO, Shell, Norsk Hydro, BP, TOTAL, CONOCO, ELF, SAGA, MOBIL, Statoil, Phillips, and Norsk Agip, each have the requirement to be able to handle an uncontrolled blowout of 60,000 bbls/day in 3 meter seas with a 1.5 knot current. To accomplish this each platform must have skimming capacity standing by to respond to, contain and pick up a minimum of +/- 600 bbls/hr all within 2 hours while the NOFO equipment is enroute. Also, since there is more than one platform in each field, all equipment from each platform is available. The NOFO operating plan supplements the oil spill cleanup equipment that is required to be at each offshore facility. Exploration facilities, are determined to be seven (7) times more likely to have a blowout than a production facility. Exploration facilities share a bigger burden of the operating budget of NOFO and require more equipment.
- 4. NOFO has five (5) strategically located bases along Norway's West Coast. They are located at Stavanger, Austevoll, Kristiansund, Traena and Hammerfest. At these bases are: 8,750 meters (+/-27,000 ft) of oil booms, 14 Framo NOFO Transrec combined oil recovery and transfer systems (26,500 bbls/hr), 12 sets of dispersant-spraying units, various auxiliary equipment, spare parts, etc. NOFO has agreements with the operating companies covering 14 oil recovery vessels. That agreement requires that vessels, once notified, be at the NOFO base, load the equipment and be underway to the spill within two (2) hours. For spills off the coast at least 40 miles NOFO must have one response group at the spill site within 24 hours and four (4) additional groups within 48 hours. For spills closer than 40 miles the response must be much faster and with more equipment. NOFO also has direct contracts covering availability of 20 towing vessels for use during oil spill operations.
- 5. NOFO conducts several exercises each year with each oil company participating at least once but, more likely, several times. In addition to the NOFO exercises, each oil company conducts its own oil spill drills. NOFO's operating budget this year is $7,000.000 (U.S.) dollars. It will be larger next year.
- Oil and Gas Pipelines, Offshore Loading Buoys, Terminals and Refineries
- 1. The gas fields in the North Sea on the Norwegian Continental Shelf are linked by several gas pipelines which allow gas from different fields to be directed to other pipelines which come ashore in England, Scotland, West Germany and Norway. In Norway, two pipelines terminate at a large terminal at Karsto on the west coast of Norway.
- 2. The oil fields in the North Sea on the Norwegian Continental Shelf are also linked by pipelines which connect with other pipelines which come ashore in England, Scotland (Sullom Voe) and Norway. Norway is connected to the oil fields by the Oseberg pipeline which crosses the Norwegian Trench some 360 meters deep.
- 3. There are also offshore oil loading facilities in the North Sea on the Norwegian Continental Shelf. One such facility is at the Statfjord oil field where oil is stored in tanks that hold several hundred thousand barrels located on the platforms. The platforms are linked to mooring buoys which are used to load oil onto tankers at three locations.
- 4. The Karsto Terminal has a capacity of five billion cubic meters of gas per year with the possibility of expansion to eight billion cubic meters.
- 5. The Sture Crude Terminal is a new facility which has just come on line at the terminus of the Oseberg pipeline. At present it receives about 300,000 bbls/day; once the pipe-line is at full capacity it will receive 600,000 bbls/day. It has two berths, one of which can take 30,000 -300,000 dwt crude tankers, the other 50,000 - 150,000 dwt vessels. It has underground storage vaults carved out of bedrock with a total capacity of 700,000 cubic meters (4,410,000 bbls). Only clean, segregated ballast may be discharged into the water. Random samples are taken. Dirty ballast is treated ashore. The tidal range is about three feet with maximum tidal current of 1.2 knots, but the average is 0.4 knots. Vessels are not allowed to dock in wind speeds in excess of 14 meters/second or 27 knots. During periods of high winds loading is stopped and the loading arms are disconnected. All pollution from vessels is reported to the local police. The emission of smoke, including soot blowing, is prohibited. Vessels that have a pollution incident are not allowed to leave the berth before a bank guarantee is given to cover the cost of cleanup and fines. The terminal's cleanup equipment must be able to respond to spills at the terminal within 15-20 minutes. For spills in waters adjacent to the terminal out to the entrance of the Fjords response must be within 2 hours with the capability of picking up 36,500 bbls recovered within 24 hours. They must also be able to respond to a discharge of the "total contents" of any tanker that uses their facility (+/-2,250,000 bbls) within 6 hours. They stress prevention! To keep the oil in the tanker and the tanker off the beach tug escorts are provided to the entrance of the fjord for each laden tanker to or from the terminal, and pilots accompany all tankers to a point 4 miles offshore. Equipment at the Sture Terminal consists of two tugs; each is equipped with a Norwegian designed 500 bbls/hr Foxtail rope mop skimmer and a boom on a reel. These tugs also provide escort service. There are permanent booms installed in the water and others in houses at the waters edge where they can be immediately deployed by one of the several boom pulling vessels or other cleanup equipment. In addition they have several smaller skimmers The terminal has agreements with the local Regional Oil Pollution Control Committee which has an assortment of skimmers, booms and response equipment. In addition, the terminal is linked to contingency plan coverage by NOFO.
- 6. The refinery at Mougstad is a new facility just coming on line. It has two berths that can handle tankers up to 300,000 dwt. It has oil storage facilities of about 9,000,000 bbls and is expected to handle about 300 vessels per year. It is owned and operated by Statoil. Mougstad, like the Sture Terminal, must have cleanup equipment able to respond to spills at the terminal within 15-20 minutes. For spills in waters adjacent to the terminal and out to the entrance of the Fjords response must be within 2 hours with the capability of picking up 36,500 bbls recovered within 24 hours. There must also be a response to a discharge of the "total contents" of any tanker that uses their facility (+/-2,250,000 bbls) within 6 hours. Again prevention is stressed! Escort tugs are provided to the entrance of the fjord for each laden tanker to or from the refinery and pilots accompany all tankers to a point 4 miles offshore. Equipment at the Mougstad Terminal consists of two tugs; each equipped with a Norwegian designed 500 bbls/hr Foxtail rope mop skimmer and a boom on a reel. These tugs also provide escort service. There are permanent booms, instal-led in the water and others in houses at the waters edge where they can be immediately deployed by one of the several boom pulling vessels or other cleanup equipment. In addition they have several smaller skimmers. Mougstad also has agreements with the local Regional Oil Pollution Control Committee which also has an assortment of skimmers, booms and response vessels. In addition, their terminal is linked to contingency plan coverage by NOFO.
- 7. ESSO (Exxon) owns and operates a refinery at Harstad which accommodates tankers at least as large as 250,000 dwt. This facility, like all refineries/terminals, is required to have extensive stockpiles of cleanup equipment as well as ties to the NOFO Coop and all government cleanup resources. Frequent drills are also required. (At this time I have no additional information on this facility.)
- 8. Norske Shell (Shell) owns and operates a refinery in Stavanger. This facility, like all refineries/terminals, is required to have extensive stockpiles of cleanup equipment as well as ties to the NOFO Coop and all government cleanup resources. Frequent drills are also required. (At this time I have no additional information on this facility).
- The "Tactical Oil On Water Exercise"
- 1. The purpose of the exercise was: - to train the Exercise Commander in oil spill operations and in tactical organization of NOFO's resources with oil on water under realistic conditions offshore. - to practice team-work between the operating company and the relevant authorities. - to test a new adhesion ban skimmer and a two-phase flow-meter. - to gain operational experience with new vessels and existing equipment.
- 2. The operational plan included the discharge of 150 cubic meters (950 bbls) of crude oil which was to be recovered by an armada of recovery vessels. There were four offshore rig supply vessels each with a skimmer for a total skimming capability of about 8,000 bbls/hr. Each supply vessel was also equipped with about 2,500 feet of boom and accompanied by a boom towing vessel. In total, there were 14 vessels deploying and recovering the oil and equipment. The rig supply vessels, called multi-purpose safety service vessels, have speeds of 17.5 knots with all four engines. They are 230 feet long, 50 feet wide, 3,000+ tons. They have bow and stern thrusters, twin rudders, twin screws, bollard pull of 150 tons and cabins for 45 people. Equipped with every piece of navigation and communication equipment desirable, they are designed and constructed to work staying on station in any weather the North Sea can serve up and are classified as +A1-EO-Supply SF-Oil Rec-Rescue. They do it all and are classified to carry oil. In Norway, as in Scotland, there are literally hundreds of these vessels. In addition to the 14 vessels conducting the exercise, there was a 240 foot observer vessel with 47 observers from oil companies, equipment representatives, NOFO officials and State and Federal regulators from Norway, France, Mexico, Canada, California and Alaska's DEC representative.
- 3. I arrived in Stavanger, Norway late Monday afternoon, September 18th after a rather lengthy flight which departed Valdez Saturday evening. Due to problems with scheduling on short notice the flights were routed through Seattle, Chicago and Copenhagen and required 30 hours to complete. Tuesday evening at 1900 hours the observer vessel departed Stavanger for the Firgg Gas Field, 100 miles off the West Coast of Norway, in the middle of the North Sea. The weather forecast was encouraging and although there were 20-knot winds and moderate seas, they were predicted to subside by early Wednesday morning. We arrived on Station early the next morning; the subsiding 20 knot winds had increased to 50 knots and the moderate seas were then 20 - 30 feet (7 - 10 meters). The encouraging forecast continued with predictions to subside by mid day. At 2300 hours Wednesday, in steady winds of 50 knots with gusts to 70 knots and seas 10 - 13 meters (30 - 40 feet) it was decided to depart the area for a fjord outside Bergen where an exercise (sans the oil) would be conducted. This was done so that some observers with other travel commitments could see the equipment in operation prior to continuing their trips. In addition to our observer vessel the rig vessel Viking Queen and another large boom towing vessel left the Firgg area for Bergen. The other 12 vessels remained on station in hopes of the seas subsiding in two or three days per the new prediction.
- 4. After sailing all night we arrived at the fjord outside Bergun the morning of Thursday, September 21, where we transferred from the observer vessel to the safety service vessel Viking Queen. This rig service vessel was equipped with the NOFO boom reel containing a NOAS 800 type C boom and Transrec 300 skimmer. This system is rated at 300 cubic meters per hour (1850 bbls/hr). Once the boom is deployed in a "J" configuration, the skimmer is put into the apex of the boom. The boom/skimmer combination is designed to work in less than 2 meter seas and 30-knot winds. It took about 3 hours to deploy the boom and 15 minutes to deploy the skimmer. This particular boom was an older style with clip-on floats. It is scheduled to be replaced by another style which will have a greater operating window and can be deployed in about one third the time. This Transrec skimmer is a typical weir skimmer. The newer version weir's height is hydraulically controlled from the deck of the vessel. This feature allows instant control for changing oil depths. This demonstration showed how the equipment is deployed and designed to work.
- 5. After the exercise I was invited to go to the Norsk Hydro offices in Bergen. Once there I was shown their extensive Oil Spill Emergency Command Center (floor plan attached) by Bjorn Holst one of their Contingency Planners. The Emergency Center is a group of rooms with individual peripheral offices, conference rooms and telephone switchboard which surround the main operating room. In it there is a command console where each desk is equipped with telephones, radios, a computer - all of which are interfaced with recorders for information storage. This console overlooks a conference table, blackboards, movable planning boards with each piece of response equipment pre listed and large screen television that also functions with an overhead projector. In addition there are extensive map racks and book-shelves with volumes of supplemental Contingency Plans and equipment lists with contact numbers of contingency equipment located throughout the world. Within 6 months they expect to have direct video link-ups with oil pollution control activities. The whole essence of the room projects the image that control of an oil spill is treated as a major priority. Later in the evening I flew back to Stavanger.
- 6. On Friday September 22, I met with Magne Ognedal the Director of the Norwegian Petroleum Directorate's Safety and Working Environmental Division. He gave me an overview of the NPD's function. Odd Bjerre Finnestad, the Section Head of the Worker's Protection and Working Environment group, continued the presentation (see I A 1).
- 7. Later that day I met with the Stavanger Port Authority. Their new Port Director, Michael Odland, and Harbor Master Edgard Bergsvik provided an overview of the local level "Regional Oil Pollution Control Committee". At the Stavanger Harbor they have 6 or 7 people with one person on standby 24 hours per day 7 days per week. They have a ware-house full of equipment for response and several contractors on standby lists. (See I A 3).
- 8. I was unable to set up any meetings with the State Pollution Control Authority; however, I was told that NOFO would conduct an additional exercise on Wednesday, September 27. After returning from Scotland, during the NOFO replacement exercise, I had a short conversation with Oyvind Schreiner the head of the SPCA's Oil Pollution Control Department. Mr. Schreiner was with the Norwegian group that came to Valdez in the early days of the EXXON Valdez spill. He will be sending copies of the State Regulations and requirements.
- Regulatory Authority and Responsibilities
- 1. The British Parliament enacted legislation in 1974 empowering the Shetland Island Council (SIC) to become the Harbor Authority. The Act called the "Zetland County Council Act of 1974" gave the council the power to regulate the oil industry at Sullom Voe by adopting "By-laws for the Port of Sullom Voe". Other British shipping laws and IMO (International Maritime Organization) Regulations were also incorporated as Laws of the Land. In addition the Shetland Island Council and Oil Industry worked out 5 separate agreements which became in effect the Law under which the Sullom Voe Terminal is operated.
i. The Disturbance Agreement of July 11, 1974 set up a tax structure where the SIC received revenue to compensate for disruption of the Island's way of life.
ii. The Sullom Voe Association Agreement is still a secret but is thought to specify how the SIC and the Oil Companies interact and their relationship.
iii. The Port & Harbor Agreement of 1978 sets up the conditions under which the terminal's shipment of oil with tankers interacts with the local Port Authority which operates the Port of Sullom Voe. This includes a pollution indemnity clause which assesses unlimited liability to the spiller of any oil. (This agreement is 89 pages).
iv. Busta House Agreement of 1988 settles various financial disputes and sets forth renewal options for the Port & Harbor Agreement.
v. The fifth agreement requires the oil companies to issue "voyage instructions" for all tankers calling at Sullom Voe. Their instructions set forth no-go areas, including a 10-mile Exclusion Zone around the Shetland Islands for all tankers, reporting-in requirements, minimum ballast requirements (35% ballast & stores) and prohibited discharge of oily ballast within 200 miles of Shetland's Coast. The instructions are not enforced by state law but by commercial contract between the oil companies and their customers. If a tanker violates the instructions it can be "blacklisted" and refused permission to enter Shetland waters. (See II A.3.)
All these laws set up a very strict set of operating conditions that dictate tanker movements, terminal operation and oil pollution response.
- 2. The Port of Sullom Voe is a deep water harbor owned and operated by the Shetland Island Council as Harbor Authority.
a. The Sullom Voe Harbor Authority is in direct control of all tanker movements. That control is exercised and monitored from the Port Administration building's Port Control Room which is located on Sella Ness approximately ½ mile directly across from the terminal's docks. It has a clear view of the port and terminal. The control center is staffed by Port Controllers who each hold an unlimited Masters Certificate to command tankers of any size in any waters
At the Port Control Center they:
i. operate the radio and vessel traffic system;
ii. provide the required tanker pilot service (by pilot boat and helicopter);
iii. control all tanker movements with radar tracking in the Sound and vessel position plotting as each vessel reports it's position in and out to 200 mi;
iv. dispatch helicopters for surveillance of all tanker movement by air;
v. provide and maintain navigational aids;
vi. dispatch personnel to inspect all tankers which includes testing of all segregated ballast;
vii. levy and collect fees for these and other services.
b. Other required services in which the Port Authority is involved through joint venture or partnership arrangements include:
i. operation of the escort tugs which also dock the tankers (4 tugs per tanker - 2 of which are tractor type). The tugs make up to each tanker with hard line connections well out in the Sound, remaining made up till tanker is safely berthed. For outbound tankers the reverse is observed;
ii. dock space and warehousing of the terminal's oil spill response equipment is provided;
iii. provision of additional SIC owned pollution response equipment.
c. In addition to the above, the Shetland Island Council owns the jetties (berths) at the terminal. The terminal has an exclusive use contract and has also repaid the SIC for the construction of those facilities.
d. The SIC also acts as OSC during an oil pollution response and will, when necessary, direct the terminal operator's oil pollution response.
- 3. A test case has been settled where the Port Authorities spotter plane observed the tanker "Mahalis" dumping dirty ballast off the coast. That tanker was not allowed to enter Shetland's waters and the oil company cancelled it's contract. It is "blacklisted" and will not be allowed to call at the terminal.
- The Oil Industry's Attitude
In the Shetland Islands there seems to be a more cooperative attitude within the oil industry. It may have been bred in the early days when the industry needed Shetland's Sullom Voe yet the Shetland Islands did not need or want the oil industry's terminal. The Islanders demanded protection of their Environmental Resources. Most of their demands seem centered around keeping tankers from running aground and preventing other oil spills. This hard bargaining produced results. The Industry complied and as a result has had very few oil spills.
- The terminal at Sullom Voe
The terminal began shipping crude in December, 1978. It is operated by British Petroleum for a consortium of oil companies. It receives crude oil containing gas liquids via two pipelines from the North Sea oil fields some 100 miles to the east. Those pipelines have a total combined capacity of 1.2 million bbls/day, although the terminal for the last few years has transported 600,000 - 800,000 bbls/per day. There is a crude oil stabilization facility that receives the incoming crude stream. It receives the spiked crude and liquifies the gas fraction, which is stored in 4 LPG tanks as butane and propane. The stabilized crude is then routed to and stored in the 16 floating roof 600,000 bbl crude oil storage tanks. Four berths were constructed (although one has been moth-balled) to accommodate crude tankers up to 350,000 dwt. One of the berths also is designed for the shipment of crude as well as LPG where LPG tankers up to 75,000 cubic meters can be accommodated. Crude berths can load at a maximum rate of 150,000 bbls/per hour. The rate of LPG delivery is a maximum of 3,000 cubic meters per hour. There are very stern restrictions and drastically reduced rates for topping off cargo tanks. Unlike Alyeska's Valdez Marine Terminal each berth is fully fendered. The ballast treatment facility has 4 ballast tanks. All dirty and non-segregated ballast must go ashore to be processed. Twenty-four (24) hours of gravity settling takes place in the receiving tanks before the water moves on to the chemical treatment process. After extensive chemical treatment the ballast water goes to a 130,000 cubic meter (819,000 bbls) impound basin which has a retention time of 4 - 6 days. After the impound basin aerobic and anaerobic treatment occurs, the water is discharged into the Sound which is continually flushed by a 5-knot current. Oil spill equipment consists of a number of response craft and skimmers of several types. They have decided that they are prepared to respond to a 15,000 bbl spill with the equipment at the facility. For larger spills additional equipment would be required. Major stockpiles of equipment are located within 24 hours response time. The main philosophy is spill prevention; consequently they have implemented tight control over tanker movement. Their unannounced daily overflights and strict NO POLLUTION ALLOWED policy makes the difference.
- Meetings at Sullom Voe
- 1. Saturday morning September 23, I flew from Stavanger, Norway to the Shetland Islands. On Sunday morning I met with Captain Keith Radley who had just returned to the Port Authority at Sullom Voe as second-in-command. I found Captain Radley very friendly and helpful. He provided a very informative overview of the Port Authority which included their role in the movement of tankers and showed me through the vessel traffic control center which was manned by two tanker captains/pilots. He also arranged for me to meet Jim Dickson the Port Authority's Oil Spill Control Officer the following morning. On Monday morning I met with Jim Dickson who provided a brief overview of the Port Authority Oil Spill Response Program and also took me along on one of their helicopter surveillance flights to observe tanker movements. Since the wind on Monday was over 30 knots, no tankers were allowed to come into Sullom Voe (they have a 30-knot cutoff). We flew out over the YELL SOUND and beyond into the North Sea. There we found the waiting tanker on its prescribed heading at a position some 40 miles off the coast where it was sailing a prescribed waiting course until the weather abated enough to enter the YELL SOUND (the Port Authority would advise the tanker when the Authority determined the weather permitted). We next flew around the coast to the west side of the Shetland Island group to the only approved anchorage for tankers. We found a Greek tanker which was anchored apparently gas-freeing a tank for probable internal tank work. All of this was highly curious for the Port Authority who planned to investigate further. Their overflights prove very useful. They feel they have been responsible for significant reductions in pollution (see II A 3). Returning to Sollum Voe we detoured around the perimeter of the terminal so that I could get a bird's-eye-view and take some video pictures. Captain Radley made arrangements for me to tour the terminal at 1400 hours.
- 2. The chief of the Public Relations Department, with whom I was to meet, was detained; arrangements were made by him for one of the terminal's Environmental Officers to show me around. (See II c). The terminal has a no-camera policy for visitors; my guide was authorized to take pictures and we took the 35mm camera. Of special note; at the Sullom Voe facility there was NO smell of hydrocarbons as I was shown around the facility by Ronnie Gallagher; an Environmental Officer. I observed hundreds of rabbits running around the grassy hills and slopes between the terminal facilities. Mr. Gallagher's attitude was open and constructive. He did not hesitate, when asked to discuss those areas where improvement was found to be needed. I believe that Mr. Gallagher may also be a Norsk Hydro direct employee on loan to BP which may explain his attitude.
- 3. Around 1500 I departed the terminal for Lerwick where I met with Dr. Mike Richardson who is with the Nature Conservancy Council. The NCC is a British Government Group which looks after conservation of environmental resources. In part they examine a proposed activity to see if it is consistent with conservation prior to development. They also recommend set-aside areas for preservation. NCC has membership on the Shetland Oil Terminal Environmental Advisory Group (SOTEAG) and the SOTEAG Monitoring Committee. SOTEAG duties include examination of environmental issues at the Sullom Voe terminal during all stages of construction, site rehabilitation and operation. Their Monitoring Committees set up the Sullom Voe initial environmental monitoring programs and continues to initiate and oversee additional monitoring reports and studies. Tuesday morning 9-26-89. I departed the Shetland Islands for Bergen, Norway.
III. Norway Revisited
On Wednesday 9/27/89 I attended an oil spill drill put on by NOFO as a replacement for the "Tactical Oil on Water" exercise that, due to bad weather, was not conducted. This new exercise was held about 70 kilometers north of Bergen where the Fedjefjorden (Fedje Fjord) meets the North Sea. This entrance is about equal distance from the Sture Terminal, 20 km to the south and the Mongstad refinery 20 km to the east. We left Flesland Kai approximately 1 hour late due to the delayed arrival of a plane carrying 30 government observers aboard M/V Godoysund Express, a fast (45 knots) passenger charter boat. As we proceeded to the exercise site, I observed dozens of the multi-purpose service vessels at the many offshore supply bases scattered throughout the area's waterways. About 50 km out of Bergen we passed the Sture Terminal (see I.D.5). When we arrived at the exercise site, the spill drill was well underway. There was an impressive assemblage of response equipment. I have not yet received a copy of the drill scenario, but it went something like this. The tanker XYZ approaching the Fjord entrance and hit a rock where it spilled mass quantities of crude. Sometime thereafter it caught fire and broke in half. The crew abandoned ship. The response equipment came from all around the spill area. The Sture Terminal sent their two tugs and other response craft with a combined recovery rate of 1000 bbls/hr. The Mongstad refinery's two tugs with a combined 1000 bbls/hr recovery rate were there also. A NOFO Transrec skimmer whose recovery rate is 2000 bbls/hr was on board a multi-purpose service vessel with attending boom pulling vessel, was present. A Navy vessel with Foxtail 500 bbls/hr skimmer was part of the exercise. There were also two other groups of vessels with skimming ability of 500 -1000 bbls/hr each. All of these vessels had deployed their boom and skimmers. They were working as groups and appeared to be well organized and efficient. There was a vessel deploying foam which was used as the oil simulant. A small coastal tanker was standing by to lighter recovered oil from all of the recovery vessels. Aerial surveillance was provided by a twin turbine aircraft with SLAR, IR and video equipment. A large Puma helicopter, which doubles as a dispersant application aircraft, was hoisting the "tanker crew from life rafts". This whole activity took place at the entrance to the Fjords, in rolling seas with waves up to 3 meters. We then moved closer to the mainland where the local Regional Oil Pollution Control Committee was busy operating their skimming equipment which included a few hundred meters of boom, a Foxtail skimmer and a belt skimmer that had the ability to pick up trash. It was difficult to count all the equipment and vessels participating in the exercise; however, it appeared there was in excess of 7000 bbls/hr skimming capability provided by the 30+ boats involved in the exercise. The cost of the exercise was about $570,000 all of which comes out of the NOFO $7,000,000 operating budget for 1989. All of the vessels and equipment involved in their respective locations appeared adequate in the seas observed. This exercise was typical by the standards used in Norway in demonstrations of cleanup response for an area where the tanker traffic is less than 500,000 bbls/day. The oil industry in Alaska has never put on an exercise this massive and we have tanker traffic with 4 times the volume at a single terminal.
IV. Comments on Spill Response Equipment
- 1) The Foxtail skimmers use the typical oilophilic rope mop with a new twist. Norway has suspended the roller arrangement from a crane and added several endless loops of mop. By this suspension method the mop is in contact with the liquid surface at all times regardless of wave height or sea state. These units are relatively small and can be carried on any vessel with a boom and auxiliary hydraulic system to power the skimmer. The oilophilic properties of the mop limit the amount of water recovered to 10% while oil and/or oily emulsion is 90% of the liquid recovered. It is said to work well in fairly fresh mousse. One industry representative says it recovers 60-90% of its rated nameplate capacity while an official with the Norwegian State Oil Pollution Authority rates the recovery rate as 90-100% of nameplate. The skimmer comes in a variety of capacities which is dependent on how many belts are involved. The eight-belt model is rated at +/-500 bbls/hr.
- 2) The Transrec skimmers are again an old idea with a new twist. FRAMO (the manufacturer) has taken a wier skimmer, floated it and made it easier to deploy. Deployment is accomplished by use of a self-contained lifting boom attached to a reel. The units are skid mounted and easily transferable to any vessel of sufficient size. The floating skimmer is attached to the reel by means of a floating hose containing control cables, hydraulic lines and a recovered oil hose. Inside the skimmer is a screw-type transfer pump capable of pushing viscous oil along at a high rate. An emulsion breaker chemical can be added just prior to the pump to initiate oil water separation. They are also available with optional disc or rope mop cassettes as auxiliary equipment. The system comes in several different sizes and models with recovery rates of 250 - 1900 bbls/hour. Actual field trials in the North Sea have confirmed recovery rates exceeding 300 cubic meters/hr (+/- 1900 bbls/hr) of emulsion of oil. During the Piper/Claymore spill in December 1986, the recovery rate was confirmed during an actual spill from the North Sea platforms. FRAMO is in the process of developing an even larger skimmer.
- Response Vessels
- 1) The response vessels observed in Norway, as well as Scotland were varied in size ability, but, for the most part, were very large and had the ability to do the job in the seas expected to be encountered. The primary response vessel used in the North Sea offshore, near shore and within the Fjords is the multi-purpose safety service vessel. It provides a big stable platform on which to stage skimming equipment and has the ability to carry recovered oil below deck. The 10-12 ft. deck height from the water's surface allows crews to work in bigger seas. The bridge also provides an excellent observation post as it is about 40 ft. above the water's surface. As demonstrated by my observations of these vessels in the North Sea, they can ride out a severe storm providing comfort and safety for response personnel until the storm abets and cleanup can resume. With top speeds of 17.5 knots, joystick controls, twin rudders, bow and stern thrusters as well as the propellers in nozzles, these vessels are highly maneuverable and far superior to the ERV now at the Alyeska terminal. The other response vessels include small tankers to receive recovered oil from the recovery vessels, large fishing type vessels (150 - 200 ft.) to pull boom as well as a host of smaller craft. The tugs observed from the Sture as well as the Mongstad refinery are equipped with skimmers and boom. The Sullom Voe tugs include tractor-type propulsion systems that are highly maneuverable and better able to influence the movements of a wayward tanker.
V. Comments on Spill Prevention
Norway has a very aggressive spill prevention program. They long ago realized the best response to cleaning up a spill is to prevent it from happening, and once one occurs to clean it up immediately. The Norwegian government has the attitude that "industry is totally responsible for it's actions". This attitude has been transformed into laws that make the spiller responsible for the cost of spill prevention and totally financially responsible for all costs associated with spill cleanup. It is evident that the industry has been very cooperative in responding to Norway's requirements by the amount of equipment that is assembled for response as well as prevention. Some of their prevention measures include: no tanker movements to or from terminals when winds reach 27 knots, pilots board tankers from 4 miles off shore, tugs join tankers shortly thereafter, cleanup equipment standing by at offshore platforms, and the creation and annual funding of the NOFO cleanup cooperative. In Scotland's Shetland Islands the attitude of the government has been transformed into very strict requirements for tanker movements as their major focus is prevention. The industry does not argue and has agreed to impose limits on tankers that state all tankers: remain offshore 10 miles, report position to the Port Authority, enter coastal waters only with permission, pilots and tug escorts, and then, only when winds are less than 30 knots. The black-listing of tankers that do not follow the rules is also industry-imposed. All this is to prevent spills.
VI. Comments on Risk Exposure
Norway's oil production takes place 40 to 100 miles offshore. Their 4 major terminals/refineries have approximately 50% of the daily throughput of the Alyeska Terminal. The aggregate capacity of their cleanup equipment is well over 100,000 bbls/hr by some estimates. Their exposure risk is much than ours but their prevention, cleanup and enforcement capability is several orders of magnitude greater than ours.
Like in Norway, the offshore oil platforms are more than 100 miles off their Scottish Coast. This fact coupled with the Sullom Voe Port Authority and terminal requirements have reduced the risk of a major spill in Scottish waters to very low. Should a spill occur there is a vast amount of cleanup equipment available within 24 hours. It is estimated the aggregate capacity of that equipment is, likewise, well over 100,000 bbls/hr.
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