Preparation of Response Plans for Oil Spills from Offshore Facilities

API RECOMMENDED PRACTICE 1145 SECOND EDITION, FEBRUARY 2018

Special Notes

API publications necessarily address problems of a general nature. With respect to particular circumstances, local, state, and federal laws and regulations should be reviewed.

Neither API nor any of API’s employees, subcontractors, consultants, committees, or other assignees make any warranty or representation, either express or implied, with respect to the accuracy, completeness, or usefulness of the information contained herein, or assume any liability or responsibility for any use, or the results of such use, of any information or process disclosed in this publication. Neither API nor any of API’s employees, subcontractors, consultants, or other assignees represent that use of this publication would not infringe upon privately owned rights.

API publications may be used by anyone desiring to do so. Every effort has been made by the Institute to ensure the accuracy and reliability of the data contained in them; however, the Institute makes no representation, warranty, or guarantee in connection with this publication and hereby expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any authorities having jurisdiction with which this publication may conflict.

API publications are published to facilitate the broad availability of proven, sound engineering and operating practices. These publications are not intended to obviate the need for applying sound engineering judgment regarding when and where these publications should be utilized. The formulation and publication of API publications is not intended in any way to inhibit anyone from using any other practices.

Any manufacturer marking equipment or materials in conformance with the marking requirements of an API standard is solely responsible for complying with all the applicable requirements of that standard. API does not represent, warrant, or guarantee that such products do in fact conform to the applicable API standard.

All rights reserved. No part of this work may be reproduced, translated, stored in a retrieval system, or transmitted by any means, electronic, mechanical, photocopying, recording, or otherwise, without prior written permission from the publisher. Contact the Publisher, API Publishing Services, 1220 L Street, NW, Washington, DC 20005.

Copyright © 2018 American Petroleum Institute

Foreword

Nothing contained in any API publication is to be construed as granting any right, by implication or otherwise, for the manufacture, sale, or use of any method, apparatus, or product covered by letters patent. Neither should anything contained in the publication be construed as insuring anyone against liability for infringement of letters patent.

The verbal forms used to express the provisions in this document are as follows.

Shall: As used in a standard, “shall” denotes a minimum requirement in order to conform to the standard.

Should: As used in a standard, “should” denotes a recommendation or that which is advised but not required in order to conform to the standard.

May: As used in a standard, “may” denotes a course of action permissible within the limits of a standard. Can: As used in a standard, “can” denotes a statement of possibility or capability.

This document was produced under API standardization procedures that ensure appropriate notification and participation in the developmental process and is designated as an API standard. Questions concerning the interpretation of the content of this publication or comments and questions concerning the procedures under which this publication was developed should be directed in writing to the Director of Standards, American Petroleum Institute, 1220 L Street, NW, Washington, DC 20005. Requests for permission to reproduce or translate all or any part of the material published herein should also be addressed to the director.

Generally, API standards are reviewed and revised, reaffirmed, or withdrawn at least every five years. A one-time extension of up to two years may be added to this review cycle. Status of the publication can be ascertained from the API Standards Department, telephone (202) 682-8000. A catalog of API publications and materials is published annually by API, 1220 L Street, NW, Washington, DC 20005.

Suggested revisions are invited and should be submitted to the Standards Department, API, 1220 L Street, NW, Washington, DC 20005, standards@api.org.

iii

Contents

Page

1. Scope and Purpose 1

2. Terms and Definitions 1

3. General Recommendations for Oil Spill Response Plans 6

   1. Oil Spill Response Plan Content and Layout Concepts 6

   2. Optional Quick Guide 7

   3. Regulatory Compliance Cross Reference 8

   4. Tier Planning 8

   5. Referencing Other Documents and Information 9

   6. Other Concepts in Offshore Oil Spill Response Planning 9

4. Oil Spill Response Plan and Quick Guide Templates 11

   1. Purpose 11

   2. Template Use 11

   3. Tables and Figures 12

   4. Appendices 12

Annex A (informative) Offshore Oil Spill Response Plan Template 13

Annex B (informative) Quick Guide Template 123

Bibliography 131

Figures

Quick Guide Template Contents 124

1 Response Deployment Strategies and Considerations 130

Annex A Figures

1-1 General Pattern of Oil Spill Response 14

2-1 On-Scene Response Actions Sample Flowchart 18

3-1 Sample Notification Flowchart 28

1. Team Relationships 43

2. Sample Tier 1 Incident Management Team 44

3. Sample Tier 2 Incident Management Team 44

4. Sample Tier 3 Incident Management Team 45

5. Sample Unified Command Structure 48

6. Sample Area Command Structure 48

1. Sample Spill Response Strategy Decision Guide 50

2. Sample Nonmechanical Spill Strategies Authorization Flowchart 55

3. Example “Concept of Operations” Diagram 59

4. a Example Response Strategies Illustration 60

1. b Example Response Strategies Illustration 61

2. Example Mechanical Recovery Tactical Guide 64

3. Example Dispersant Tactical Guide 66

4. Example In-Situ Burning Tactical Guide 68

1. Tier 1 Safety Management Organization 98

2. Tier 2 Safety Management Organization 99

3. Tier 3 Safety Management Organization 99

Annex A Tables

1. Example On-Scene Initial Response Actions 19

   v

   Contents

   Page

2. Qualified Individual or Incident Commander Checklist 20

3. Sample Oil Volume Tracking Table 25

4. Example List of Response Objectives and their Related Strategies 26

5. Sample Response Asset List Table 27

3-1 Sample Notification Contact List 30

4-1 Sample Oil Spill Containment and Removal Resource List 34

5-1 Sample Team Member Roles and Responsibilities 46

6-1 Example “Windows of Opportunity” Table 53

1. Sample Oil Discharge Scenario Report 88

2. Sample Impact Values 90

3. Oil Discharge Scenarios—Consequence Priority Rankings 93

4. Worst-Case Discharge Scenarios 94

Introduction

This API Recommended Practice (RP) for the preparation of offshore oil spill response plans was developed for organizations engaged in the oil and gas exploration, production, and transportation (pipeline) industry to capture lessons learned during the response to the 2010 BP/Deepwater Horizon oil spill in the Gulf of Mexico. It was prepared by the API Oil Spill Preparedness and Response Subcommittee - Spill Planning Workgroup which consisted of oil spill planning and response subject matter experts from various API member companies as well as non-member oil and gas companies, consulting firms, Oil Spill Removal Organizations (OSROs) and the regulatory community. It was originally developed as a guidance document but subsequently converted to a Recommended Practice to facilitate wider distribution and utilization.

In developing the original guidance document, the Workgroup identified the types of information and guidance that would be most useful in implementing a response to an offshore oil spill particularly in the initial or reactive phase. Current best practices in oil spill planning and preparedness developed and/or utilized by the Workgroup members were incorporated where practical and appropriate. Lessons learned from the Deepwater Horizon incident, available oil spill planning and preparedness guidelines (both U.S. and International), and current U.S. oil spill planning regulations for offshore and coastal areas were also used to inform the development of the document content and format.

The guidance document was well received by API members resulting in the decision to convert it to an RP. RPs require additional rigor with respect to content and format as well as the involvement, to the extent practical, of external parties including the regulatory community. The aforementioned, more inclusive, Spill Planning Workgroup was then formed and over the course of close to two years, made significant revisions to the original guidance document to incorporate additional best practices and lessons learned as well as to improve the content and format and to comply with API's RP standards.

It is important to note that the use of this RP in the development of an oil spill response plan will not guarantee 100 percent recovery of subsequent oil spills nor will it eliminate all potential environmental impacts. Plans developed using this guidance should, however, increase the chance of an expeditious, well-coordinated and effective response to an oil spill.

The main body of this RP provides general information on references, terminology and considerations that were taken into account when developing this document. The recommendations developed by the Workgroup in Section 3 include a number of features and concepts that were incorporated into the design of this RP. Annex A of the RP contains a template and detailed recommendations for preparing offshore oil spill response plans whereas Annex B contains guidance for the optional "Quick Guide" that often accompanies an oil spill response plan. Annex C contains a bibliography of documents used to inform the development of this RP or that can be used to inform the content for selected sections of an oil spill response plan.

Preparation of Response Plans for Oil Spills from Offshore Facilities

1. Scope and Purpose

   
   

   This API Recommended Practice (RP) provides information and guidance for the development of oil spill response plans primarily for the offshore U.S. oil and gas exploration, production, and transportation (pipeline) industry. However, the general plan concepts described in Section 3 can be applied to oil spill response plans developed for all types of coastal/marine assets or operations, both in U.S. and international locations. Additionally, this RP, or selected components of it, may be used to inform the development of response plans for any company, organization, or public agency that oversees or conducts the response to oil spills.

   
   

   The primary purpose of this RP is to compile a series of best practices and other information from workgroup members into a document that can guide the user in the preparation of effective and functional oil spill response plans for offshore facilities. The RP can also be used to modify portions of existing oil spill response plans to enhance effectiveness and functionality.

   
   

   Although plans prepared or modified using this RP can be used to replace existing response plans required by regulation, the RP is not intended to be a regulatory compliance guideline or to supersede current regulations. The content recommended by this RP was, however, benchmarked against Bureau of Safety and Environmental Enforcement (BSEE) regulations (30 CFR Part 254 and associated guidance in NTL 2012-N06) and found to be in general compliance but will depend on the specific information plan holders include in each section. Conversely, the recommended content is not limited to addressing current BSEE or other regulatory requirements and exceeds those requirements in many areas. Consequently, the incorporation of additional information may be necessary to comply with agency- specific requirements and information not required by regulation can be removed if it does not apply, or add value, to the plan holder.

   
   

2. Terms and Definitions

For the purposes of this document, the following definitions apply:

2.1

agency

A division of federal, state, local, or tribal government with a specific oil spill preparedness or response function.

2.2

area command

An organization established to

1. oversee the management of multiple incidents that are each being handled by an Incident Command System Incident Management Team organization, or

   
   

2. oversee the management of large or multiple incidents to which several incident management teams have been assigned.

NOTE Area command has the responsibility to set overall strategy and priorities, allocate critical resources according to priorities, ensure that incidents are properly managed, and ensure that objectives are met and strategies followed (see also: Unified Area Command).

1

2 API RECOMMENDED PRACTICE 1145

2.3

area contingency plans ACP

The plan prepared by an area committee that is developed to be implemented in conjunction with the National Contingency Plan (NCP) and Regional Contingency Plan (RCP), in part to address removal of a worst-case discharge and to mitigate or prevent a substantial threat of such a discharge from a vessel, offshore facility, or onshore facility.

2.4

asset

Any facility, installation, or device installed at a fixed offshore location for the purposes of engaging in oil or natural gas exploration, production, or transportation by pipeline.

NOTE This includes mobile offshore drilling units (MODU’s), platforms, subsea oil pipelines, oil/gas wells, flowlines, etc. Also refer to “offshore facility” in applicable regulations.

2.5

boom

Floating barriers used to contain or control the spread or movement of oil on the surface of the water.

2.6

company

Any entity engaging in business, such as a proprietorship, partnership, or corporation (either for-profit or not-for-profit).

NOTE A plan holder may be a company, but not all plan holders are necessarily companies.

2.7

decanting

A process to separate mixtures, such as oil and water, by allowing the mixture of liquids to settle and separate by gravity before pumping or draining the water from the bottom of the container.

2.8

discharge

Any emission (other than natural seepage) of oil, intentional or unintentional; includes, but is not limited to spilling, leaking, pumping, pouring, emitting, or dumping.

2.9

dispersant

Chemical agents consisting of surfactants and solvents that facilitate breaking oil into tiny droplets that are dispersed into the adjacent water column by wave or turbulent energy.

2.10

Federal On-Scene Coordinator FOSC

The federal official designated to direct and coordinate responses to oil or hazardous-substance releases under the NCP.

2.11

In-situ burning

The ignition and controlled burning of floating oil, at or near the location of the spill, with the aid of a specially-designed fire-containment boom or other suitable barriers.