NATIONAL CONTINGENCY PLAN FOR MARINE POLLUTION FROM SHIPPING AND OFFSHORE INSTALLATIONS
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APPENDIX H
COUNTER POLLUTION OPERATIONS AT SEA
Introduction
H.1
All ships carry oil as fuel. Some carry oil as cargo. So all shipping
accidents create a risk of oil pollution. Offshore oil and gas operations also create a risk of
oil pollution.
H.2 Many ships carry hazardous substances other than oil as cargo. Some carry just one hazardous substance. Others carry many hazardous substances in separate tanks or containers. A single incident may therefore require a response to more than one form of pollution.
H.3 The MCA CPR Branch forms a Marine Response Centre (MRC) at the scene of the incident to manage at-sea and aerial activities, as outlined in Section 6 of this Plan. This response Centre has three operational cells; aerial, at sea and logistics/finance. The MRC is headed by the MCA Deputy Director of Operations or the Head of CPR Branch. If activities are centred around a port area, it is likely that the MRC will merge with the harbour authority Tier 2 contracted responder.
H.4 This appendix summarises the response options for different forms of marine pollution.
Oil
Minor
oil spills
H.5 MCA receives many reports
of sightings of pollution at sea. Often the sightings are of oil pollution with no identified
source. The oil may have entered the sea during an operational discharge or because a storm disturbed
a wreck. When a small amount of oil is involved, counter pollution operations are neither practical
nor necessary. Instead, MCA allows the oil to disperse naturally.
Major oil spills
H.6
MCA responds to a major oil spill at sea in several different ways. However,
the aim of any response is always to minimise the damage that the oil could cause. MCA tailors
its response to each incident, consulting others as set out elsewhere in this plan.
H.7 MCA’s response to a major oil spill may be:
H.8 All techniques for cleaning up oil pollution at sea have limitations. The distance of the casualty from shore, the type of oil, weather conditions, currents, and the time taken for resources to reach the scene can significantly affect the effectiveness of different techniques. MCA therefore carefully evaluates the circumstances of each incident before mobilising equipment or other resources.
H.9 The most desirable option is to recover the oil from the surface of the sea. This prevents it from reaching the shoreline, reduces the possibility of damage to biological and other resources at sea and in the coastal zone, and avoids the high cost of removing oily material from the shore. In practice, however, oil recovery at sea is never fully effective.
H.10 Fluid oils spilt at sea spread rapidly to cover large areas. Evaporation causes a reduction in total volume, accompanied by an increase in viscosity. Some oils may form water-in-oil emulsions. These increase the viscosity and volume of the oily material, preventing effective treatment with dispersants and increasing the difficulty of mechanical recovery. With other oils, natural dispersion reduces the amount of oil on the sea surface. The rate at which these processes occur depends on oil type and weather conditions.
Monitoring oil movement
H.11
Wind and currents cause any oil remaining on the surface of the sea to drift.
Computer models can predict its movement. MCA, operating from the MRC, uses these models, advice
from the Environment Group, and environmental sensitivity maps to assess the risk to resources threatened
by an oil spill.
H.12 If the oil is drifting, away from sensitive resources, there may be no need to initiate active response measures. However, MCA continues to monitor the movement of the spill, because the wind direction can change rapidly. It initiates active response measures if the oil starts to move towards a sensitive resource.
H.13 During incidents, surveillance aircraft monitor the movement of oil and use remote sensing equipment to estimate the location of the greatest concentration of surface oil. Fixed-wing aircraft or helicopters survey the shoreline to assess the degree of oiling. Where possible, their crews take photographs and make recordings.
Satellite Surveillance
H.14
The United Kingdom is committed to augment its aerial surveillance programmes
to provide a deterrent against discharges of marine pollution into the UK Pollution Control Zone by
using synthetic aperture radar satellites. Using a combination of European Space Agency and Canadian
satellites working in partnership with other EU member states enhances and compliments more traditional
aerial surveillance activities. For a major marine pollution incident where satellite imagery
may be required this can be activated via the 24 hour Marine Information Centre, Civil Protection Mechanism,
DG Environment, Brussels.
Dispersant spraying operations
H.15
While many oil recovery systems are available, all suffer limitations in the
sea conditions often prevalent around the UK shoreline. It may take days to move them to the scene
of an incident. The use of dispersants is often a more effective response to oil pollution in
the turbulent seas around the UK.
H.16 It is a statutory requirement to obtain specific approval from the licensing authority for any use of oil treatment products in water depths of less than 20 metres, or within one nautical mile of any such area. If the use of such products is to take place in deeper waters, the licensing authorities wish to be consulted beforehand except under force majeure conditions (for example, if human life is at risk). MCA normally initiates dispersant spraying only if this statutory requirement is satisfied, dispersant spraying is likely to be effective, and either:
H.17 Should the MRC decide not to follow the advice of the Environment Group, it must record the reasons for this, and circulate the record to all other response centres as soon as possible.
H.18 MCA balances the likelihood of dispersant spraying being effective against its environmental consequences and cost. While dispersant spraying removes the problem of disposing of waste oil recovered on shore, dispersed oil may remain in the marine environment for a considerable time.
H.19 Dispersant spraying is most effective if carried out as soon as possible after an oil spill. Research findings provide important guidance on the likely effectiveness of dispersants. They show that the time available for spraying oils that are amenable to dispersants is limited and depends on the type of oil and the weather conditions. Aerial spraying resources should therefore be alerted quickly when spraying missions are anticipated and an early decision should be made on whether and where to spray.
H.20 MCA uses information gained from aerial surveys to assess the effectiveness of the response operation, including aerial spraying, and to inform future operational decisions. Monitoring sub-surface oil concentrations from a suitably equipped ship is a more definitive indicator of dispersant performance than visual observation. MCA CPR branch mobilises such equipment wherever possible.
Aerial spraying operations
H.21
MCA has a contract for dedicated dispersant spraying aircraft with spray-monitoring
systems. They deliver dispersant under the direct control of surveillance aircraft to ensure the strict
observation of geographical or other limits on spraying.
H.22 MCA stores stocks of dispersant at selected sites at or near airfields. It may charter other aircraft and helicopters in the UK capable of carrying out aerial spraying of dispersants.
Shipborne spraying operations
H.23
Ships can provide support for operations in harbour or coastal waters or in
waters at the limit of the operating range of aerial spraying aircraft. Such ships are particularly
useful in maintaining a permanent response if there is an imminent threat of a spill or a continuous
release of oil.
H.24 MCA also has stocks of portable sets of spray equipment for deployment on ships of opportunity.
H.25 Wherever possible, MCA's remote sensing aircraft direct and control shipborne spraying operations to ensure maximum effectiveness.
Oil recovery operations
H.26
The recovery of spilt oil from the surface of the sea causes the least damage
to the environment. There is a wide range of systems available. These generally consist
of a boom to collect or contain the spilt oil and a skimmer to pick up the oil.
H.27 MCA has several types of mechanical recovery equipment available to fit to ships of opportunity.
H.28 When deploying oil recovery equipment MCA considers the following issues:
H.29 Taking these factors into account, MCA uses mechanical recovery equipment from:
Cleaning
of oil recovery equipment
H.30 It may be
appropriate to establish a centralised cleaning station to deal with equipment used in oil recovery
operations at sea and on the shoreline. MCA discusses the design, location, and operation of such
a cleaning station with the EA, SEPA or EHS, as appropriate, and the Technical Team in the SRC and the
Environment Group. These discussions include consideration of location, capacity, health and safety,
waste disposal and support facilities.
In situ burning
H.31
The purpose of in situ burning is to remove oil from the surface of the sea
through combustion. If successful, only a small fraction of the original volume of oil remains
as a residue. The rest of the oil enters the air column in the form of particulates and gases
contained within a discharge plume.
H.32 In situ burning is not a viable option in the turbulent waters around the UK. It is not government policy. This appendix mentions it for reference purposes only. Any change in policy would require in depth consultation, particularly on the threat to human health and to fishing, shellfish, agriculture and the environment as a whole.
Other hazardous substances
Responsibilities
H.33
The table below contains a list of organisations that are likely to become involved
in responding to incidents involving hazardous substances other than oil, and sets out their responsibilities.
| Organisation | Responsibilities |
| Fire and rescue services |
To inspect, contain and make safe suspect containers. To provide hazchem data to responders. To notify the Environment Agency, SEPA or EHS (depending on location) and relevant local authorities if they consider that there is a threat to human health or to the environment. |
| Local authorities |
To remove containers that have come ashore in consultation with fire and rescue services. To store and dispose of hazardous substances in the appropriate manner. To inform the MCA RCC and the Receiver of Wreck. |
|
Environment Agency SEPA EHS |
To provide advice to local authorities on environmental issues associated with hazardous substances. To provide advice on the handling, storage and disposal of hazardous substances. |
| MCA, RCCs |
To receive reports of hazardous substances and containers lost at sea and found on the shoreline. To receive reports on hazardous substances and containers washed up on the shoreline. To inform the duty counter pollution and salvage officer. To activate the MIRG. To co-ordinate communications with a casualty. |
| MCA, Dover RCC | To provide information on ships’ cargoes by accessing the database of notifications from the operators of ships carrying dangerous and polluting goods. |
| MCA, Counter Pollution and Response Branch |
To assimilate information on incidents and take initial steps such as alerting the Hazardous and Noxious Substance Response Team (HNSRT). To disseminate information received to local authorities that MCA consider to be under threat. To inform the appropriate fisheries department. To inform HPA if there is a potential risk to public health. |
H.34 Scientific, Technical and Operational (STOp) Notice 5/98 “A national framework for dealing with hazardous containers washed up on the UK shoreline” provides further information.
Container ships
H.35
The twenty-foot equivalent unit (TEU) fitted with doors and a hard top is the
most common type of container. However, there are other types, including half-heights, open tops,
flats, tanks, and out of gauge units. If an open top or half height container breaks free, there
is an immediate risk of pollution. The seriousness of the risk depends upon the type of cargo
carried.
H.36 A conventional hard-topped TEU fitted with doors is less likely to break open and spill its contents. If the container remains intact, nobody should open it before identifying its contents identified from the cargo manifest. If the cargo is hazardous, responders should take appropriate safety precautions before opening it.
H.37 International Standards Organisation (ISO) tank containers present a unique problem. Responders cannot know the integrity of the unit and its valves. If there is a risk that tanks contain hazardous materials, air and water monitoring must take place before attempting to approach or remove the tank.
MCA Response to Lost Packaged Goods
(including containers)
H.38 Such goods can
be at sea, within a port area or stranded on the shoreline. The initial risk assessment is carried
out by the Watch Manager at the RCC. An assessment is made to determine whether the goods are
a danger to navigation and/or a threat of pollution. The duty CPSO is contacted as required and
appropriate remedial action taken. The MCA Receiver of Wreck is also contacted.
Other types of pollution
H.39
Other hazardous substances include any substance liable to create a hazard to
human health, the environment, the economy or the security of any place in the UK. The response
to such hazards is similar to that outlined in paragraph H.36 above.
Identifying the Substances Involved
H.40
The rapid identification of the hazardous substances involved is vital. The
response required, including the treatment of casualties, is different depending on the different hazardous
substances identified. De-contamination procedures and choice of protective clothing may also
vary.
Radioactive materials
H.41
MCA’s response to an incident involving a ship carrying radioactive materials
generally follows the same principles as its response to any other pollution incident. However,
if a ship operated by British Nuclear Fuels plc or by one of its subsidiaries, such as, Pacific Nuclear
Transport Limited, is involved in an incident, the special arrangements agreed between the MCA and those
companies apply.
H.42 Radioactive Material Transport, Dangerous Goods Division (DGD) in DfT is the UK’s Competent Authority responsible for approving package designs for the transport of radioactive materials. Packages containing radioactive material are designed to demanding international standards. DGD maintains expertise in package design and development and should be informed in the event of any incident involving the transport of radioactive materials.
Resources and sources of advice available
to MCA
H.43 MCA uses the following resources
and sources of advice to assess and contain the risks arising from an incident involving hazardous substances:
Response
on shore
H.44 In 1974, local authority associations
agreed that shoreline county councils would extend their oil spill contingency plans, in consultation
with district councils, to cover emergencies arising from hazardous substances washed ashore. EHS
deals with hazardous substances washed ashore in Northern Ireland.
H.45 Once alerted, the emergency services need to consider the control and co-ordination requirements of the incident. Where hazardous substances have been released, the senior fire and rescue service officer is responsible for managing the hazard area. The senior police officer present is responsible for co-ordination of the incident.
H.46 When a significant land-based incident occurs the police appoint a Tactical43 level incident manager, known as the Police Incident Commander. This officer is located at or close to the scene of the incident and has responsibility for co-ordinating the incident response and arranging, and chairing, regular inter-agency ‘tactical’ meetings.
H.47 In order to achieve an integrated response to the incident each agency represented at the scene, including local authorities, appoints their own ‘Tactical’ representative. Each of the Tactical representatives is responsible for tailoring their own response plans to the incident, and any resources they have attached to it, to interface with the plans of the others. Co-ordination of the response to these plans occurs at the Tactical inter-agency meetings. Tactical representatives also maintain communication links with their own agency/authority.
H.48 Each agency appoints its own operational (bronze) managers who are responsible for a specific part of the operational response to the incident. These operational managers report to the Tactical manager.
H.49 In exceptional circumstances one or more agencies may find it necessary to implement a Strategic level of management. Where the incident is of such a scale or significance that a strategic overview is required then the Police normally establish and chair a Strategic Coordinating Group attended by the appropriate representatives from all necessary bodies. This Strategic group will formulate a policy framework within which Tactical managers will work.
H.50 The bodies who may be represented at both Tactical and Strategic level include:
H.51 Where such management structures are put in place for a maritime incident, then effective liaison with the SRC is essential. Plans should include arrangements to provide liaison officers in each location. Consideration should also be given to co-location where appropriate.
H.52 Local major incident plans contain details of the control structure for the response on land.
42 The Pink Book is a free publication sponsored by the Transport Container Standardisation Committee (TCSC) which lists the names and contact details of people in the UK concerned with the transport of radioactive materials. Copies are available from Mr Neil Carr, Technical Secretary TCSC Tel: 01235 825429, email: neil.carr@tcsc.org.uk back 43 In some organisations, strategic, tactical and operational may be referred to as gold, silver and bronze back |