CHAPTER 5
Organization of the Aleutian Islands Risk Assessment

This chapter provides details on the organization of the Aleutian Islands risk assessment introduced in Chapter 2. The goal of the risk assessment is the implementation of effective and efficient risk reduction measures. To achieve this desired outcome within available resources, it is critical for the study to stay focused on the specific task at hand—assessment of risks related to accidental spills from vessels operating in the study region. The first section of this chapter sets the bounds for the study. The proposed Management Team should take care to ensure that the study remains within these established bounds.

Formulating an effective risk assessment approach that combines input from stakeholders, experts in risk analysis and risk assessment, and decision makers is also necessary to success. The second section of this chapter describes the committee’s recommended approach, which involves close cooperation among a Management Team representing decision makers, an Advisory Panel consisting of stakeholders and interested experts, a Risk Analysis Team made up of one or more contractors, and a Peer Review Panel providing technical review of the risk assessment.



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CHAPTER 5 Organization of the Aleutian Islands Risk Assessment This chapter provides details on the organization of the Aleutian Islands risk assessment introduced in Chapter 2. The goal of the risk assessment is the implementation of effective and efficient risk reduction measures. To achieve this desired outcome within available resources, it is critical for the study to stay focused on the specific task at hand—assessment of risks related to accidental spills from vessels operating in the study region. The first section of this chapter sets the bounds for the study. The proposed Management Team should take care to ensure that the study remains within these established bounds. Formulating an effective risk assessment approach that combines input from stakeholders, experts in risk analysis and risk assessment, and decision makers is also necessary to success. The second section of this chapter describes the committee’s recommended approach, which involves close cooperation among a Management Team rep- resenting decision makers, an Advisory Panel consisting of stake- holders and interested experts, a Risk Analysis Team made up of one or more contractors, and a Peer Review Panel providing technical review of the risk assessment. 96

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Organization of the Aleutian Islands Risk Assessment • 97 The assessment of risks associated with maritime transporta- tion can be extremely complex. The complexity arises from a multitude of factors. There are currently some 10,000 shipping companies flying the flag of 150 different countries, operating a world commercial shipping fleet of roughly 50,000 vessels. Many of these vessels transit the Aleutian Islands. Regulatory control of these vessels is divided among many entities, including the International Maritime Organization, flag states, port states, and classification societies. Jurisdictional issues are complex—the legal right of transit and the right of innocent passage limit the intervention measures available to state and federal agencies. The quality of vessel design and construction, crew training and experience, and the management standards of operating com- panies are inconsistent across the fleet. Classes of vessels are designed for specific commodities and services, leading to a large number of ship types and sizes carrying a wide variety of haz- ardous substances (see Chapter 4). The Aleutian region is subject to severe and highly changeable weather; it is remote, creating challenges for access and communications; and it is home to relatively unspoiled and unique habitats and extensive biodiversity (see Chapter 3). In view of this complexity, it is appropriate for the risk assess- ment to begin with qualitative and semiquantitative analyses and assessments and then to focus detailed quantitative assessment on the most significant risks and the more promising risk reduc- tion measures. For this reason, the committee recommends that the study be divided into two phases: a Phase A Preliminary Risk Assessment and a Phase B Focused Risk Assessment. Assessment and prioritization of potential risk reduction measures would be undertaken by the Advisory Panel and Management Team during and immediately after each phase. Technical details and background on each of these steps are provided in Chapter 6. PROBLEM DEFINITION The proposed risk assessment for shipping operations in the Aleutian Islands specifically addresses the risk of spills from marine vessels tran- siting through and servicing the region. The recommended bounds for the study are described below.

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98 • Risk of Vessel Accidents and Spills in the Aleutian Islands Hazardous Substances to Be Considered The risk assessment should consider spills of petroleum products, bulk chemicals, and packaged hazardous containerized cargoes moving through the Aleutians (see Table 5-1). Risks related to the introduction of invasive species should be considered on a qualitative basis. Types and Sizes of Vessels to Be Considered All marine vessels weighing more than 300 gross tons (GT) carrying hazardous substances as defined above and all smaller vessels having a fuel oil capacity of at least 10,000 gallons should be considered. Vessels transiting the North Pacific Great Circle Route between the west coast of the United States and Canada and the Far East con- stitute the traffic flow of primary public concern, since the largest oil spills in recent years were the result of accidents involving cargo ships on innocent passage through Unimak Pass. However, other ves- sel types pose risks that should not be ignored in a comprehensive risk assessment. In the region, for example, fishing boats account for TABLE 5-1 Hazardous Substances Marpol Annex Type or Other Code Name Example Annex I Oil cargo Crude oil, asphalt-blending Oil stocks, fuel oil no. 4, fuel oil no. 5, fuel oil no. 6, diesel oil Annex I Biofuels and base petroleum fuels Annex I Bunkers Diesel oil, lube oil, heavy fuel oil Annex II and IBC Noxious liquids in Vegetable oils, oil-like Chemicals Code (Chapters bulk and noxious substances 17 and 18) liquid substances Annex II and IBC Biofuels Biodiesel, fatty acid methyl Code esters, B100 and ethanol, ethyl alcohol E100 Annex III Dangerous goods in Microorganisms, rats Other package form and hazardous invasive species substances Note: IBC = international bulk container.

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Organization of the Aleutian Islands Risk Assessment • 99 the largest number of spills greater than 10,000 gallons in size (see Chapter 4). Single-hull tank barges, known to pose relatively high oil spill risks, supply products to the outer Aleutian Islands. There- fore, the risk assessment should consider all vessels above 300 GT, which include but are not limited to the following types: • Containerships, • Bulk carriers, • General cargo vessels, • Gas carriers, • Roll-on/roll-off vessels and pure car carriers, • Cruise ships, • Crude oil carriers, • Product tankers, • Tank barges, • Chemical carriers, • Fish processors, • Fishing vessels, • Tugs, and • Government vessels. The study should include vessels currently transiting the region, as well as those that can reasonably be anticipated to do so during the 25-year study period (the study period is discussed below). For example, oil production in the Bering Sea, the Chukchi Sea, and other northern areas may lead to increased traffic of exploration and production vessels, such as offshore supply vessels, drill ships, mobile offshore drilling units, and icebreakers. Accident Types to Be Considered The risk assessment and proposed risk reduction measures should focus on spills from accidents. Major accident categories to be con- sidered are collisions, allisions, powered groundings, drift ground- ings, founderings, structural failures, and fires and explosions. Spills from drift groundings and collisions have been responsible for the major spills from cargo ships in the Aleutian region and clearly must be given careful consideration. However, it is important that the Phase A Preliminary Risk Assessment be comprehensive and not limited solely to those types of accidents that have occurred in Alaskan waters in recent years and that may be perceived as having

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100 • Risk of Vessel Accidents and Spills in the Aleutian Islands the highest risk. In recent years, for example, catastrophic structural failure has led to a number of very large oil spills (e.g., the Prestige and the Erika). The risk assessment should exclude operational and intentional discharges from ships. Although it is recognized that the latter likely exceed the oil spillage from accidents (NRC 2003), the committee believes that limiting the study to accidents leading to spills and excluding discharges, which are smaller and chronic in nature, offers the most promise for significant risk reduction. Geographic Region to Be Considered Vessel traffic operating in the following geographic region should be considered: • North boundary, 55°30′ N; • South boundary, 50° N; • West boundary, 170° E and international date line; and • East boundary, 160° W. The study region (see Figure 5-1) is intended to cover vessels tran- siting in the vicinity of the Aleutian Islands; those calling on ports in the Aleutian chain; and fishing boats, processors, and other vessels operating within the region. This includes vessels on innocent passage transiting immediately to the south of the Aleutian chain. Should drift grounding simulation indicate that vessels transiting outside the above boundaries pose a significant risk to the Aleutian Islands, the boundaries should be adjusted accordingly. Whereas the assess- ment of vessel traffic and the locations of spill accidents should be 170°E 175°E 180° 175°W 170°W 165°W 160°W 55°N 50°N FIGURE 5-1 Complete Aleutian chain.

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Organization of the Aleutian Islands Risk Assessment • 101 restricted to the study region, the environmental and socioeconomic consequences of these spills may extend outside the study region, depending on the fate of the spill. Time Frame to Be Considered The study period should be 25 years, from 2009 to 2033. The study period needs to be sufficiently long to provide a basis for life-cycle cost–benefit analysis and to reflect anticipated changes in vessel traffic and vessel types and designs, as well as the impact of known and reasonably expected regulatory changes. ASSESSMENT ORGANIZATION AND MANAGEMENT STRUCTURE The committee proposes an organization and management structure for the Aleutian Islands risk assessment consisting of four groups: a Management Team, an Advisory Panel, a Risk Analysis Team, and a Peer Review Panel. Management Team The Management Team would consist of those agencies respon- sible for allocating the funds for the risk assessment, as well as for ensuring that the work is carried out in an effective and useful way. The following agencies should have representatives on the Management Team: • The U.S. Coast Guard (USCG), • The Alaska Department of Environmental Conservation and Department of Natural Resources, and • The National Fish and Wildlife Foundation (NFWF). This team should work in a collaborative manner to • Oversee the use of funds; • Refine the study work scope, issue requests for proposals, and award contracts for the risk analysis; • Establish the Advisory Panel and appoint its facilitator;

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102 • Risk of Vessel Accidents and Spills in the Aleutian Islands • Establish the Peer Review Panel and appoint its chairperson; • Work collaboratively with the Advisory Panel to establish risk tolerance guidelines and prioritize risk reduction measures; and • Prepare a final summary of findings, conclusions, and recommen- dations, written in collaboration with the Advisory Panel. As described in Chapter 1, the courts have given responsibility for allocation of funding for the risk assessment to NFWF. NFWF has in turn signed a cooperative agreement with USCG giving USCG responsibility for contracting for and overseeing the risk assessment. Therefore, although the Management Team should work on a col- laborative basis and seek consensus in reporting its findings and rec- ommendations, the ultimate responsibility rests with USCG. Advisory Panel The idea of the Advisory Panel is to take advantage of experience gained through the Presidential/Congressional Commission on Risk Assessment and Risk Management, the Prince William Sound study, and other collaborative risk assessment efforts discussed in Chapter 2 while avoiding the potential limitations resulting from frequent interactions with stakeholders that can compromise the study team’s objectivity. The Advisory Panel would repre- sent a structured stakeholder-participatory approach intended to build trust, clarify the values and goals that should inform the assessment, incorporate local information and knowledge that would otherwise be easily missed, and potentially provide a path to organizational learning and policy change that might not other- wise be available. The Advisory Panel would consist of stakeholders and experts who would offer local knowledge and expertise on all issues pertinent to the assessment, such as local infrastructure, relevant industries, water- ways and their navigation, weather, and habitats. The panel should include representatives from the following: • Municipalities; • Environmental organizations and interests; • Subsistence users; • Landowners and managers (e.g., the Maritime National Wildlife Refuge); • Different sectors of the fishing industry;

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Organization of the Aleutian Islands Risk Assessment • 103 • Industry (including salvors, pilots, mariners, and port authorities); • Government agencies offering special expertise (e.g., the National Oceanic and Atmospheric Administration); and • Others with expertise in local weather, habitats, waterways, infrastructure, and so forth. The Advisory Panel would provide stakeholders’ perceptions of current risks, assist in identifying hazards and offer local knowl- edge critical to proper characterization of the risks, brainstorm on potential risk reduction measures, help establish tolerance parame- ters for risks, and perform an initial prioritization of risk reduction measures. It should be recognized that, regardless of how rigorous a risk assessment may be, no analytical approach alone will be suf- ficient for decision-making purposes. The needs and values of stake- holders will play a key role in understanding the issues and must be considered in the decision-making process. The Advisory Panel is intended to operate as an independent entity, although the Management Team should generally be invited to its meetings as nonvoting participants. The Management Team should also allocate funds for meeting facilities and administrative expenses, as well as for the cost of a facilitator. The facilitator should ensure that the Advisory Panel has adequate representation from the full range of stakeholders and sufficient expertise in risk assessment and the local environment. The committee envisions the Advisory Panel as a volunteer group, although some compensation for travel expenses may be necessary to ensure the desired representation of stakeholders. Risk Analysis Team The Risk Analysis Team would perform the risk analysis under the direction of the Management Team, be called upon to make presentations to the Management Team and the Advisory Panel, and present the technical basis for its work to the Peer Review Panel. The Risk Analysis Team should consist of one or more contractors with demonstrated expertise in the following: • Maritime transportation and qualitative and quantitative spill risk assessment, including human factors analysis and uncertainty analysis; • Marine traffic analysis and modeling;

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104 • Risk of Vessel Accidents and Spills in the Aleutian Islands • Environmental impact studies; • Spill cleanup and socioeconomic and cultural impact assess- ments; and • Human factors. The contractor(s) should have a proven record in preparing reports and presentations suitable for both technical and nontechnical audi- ences and the ability to communicate effectively with stakeholders and the public. Peer Review Panel The Peer Review Panel would consist of approximately five experts (in the areas of marine risk assessment, environmental modeling and assessment of socioeconomic impacts, and human factors evaluation) appointed by the Management Team after consulta- tion with the Advisory Panel. It could be expanded, however, if the members determined at the first meeting that crucial expertise necessary for the activity was lacking. It should have collective expertise in all aspects of marine risk assessment. Its role would be to perform a peer review of the approaches, method- ologies, models, and algorithms used by the Risk Analysis Team to ensure that assumptions are based on the best available data, that uncertainties have been properly described, that analyses have the appropriate rigor for the level of assessment, that the work is of a consistently high quality, and that findings are properly justified. Risk Assessment Tasks and Time Line The basic steps and time line for the risk assessment are shown in Figures 5-2 and 5-3. The diagrams show the relationships among the above four groups with respect to management, oversight, and con- duct of the risk assessment. The primary responsibilities of each group are indicated in the respective columns. The committee believes that approximately 2 years will be required for the full assessment. The process is structured so that a qualitative prioritization of risk reduction measures will be available after the first year, which may allow earlier implementation of those measures that stand out as particularly effective.

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Organization of the Aleutian Islands Risk Assessment • 105 Management Advisory Risk Analysis Peer Review Team Panel Team Panel Semiquantitative Studies Review Draft RFP for Develop Draft RFP Phase A Preliminary for Phase A Preliminary Risk Assessment and Risk Assessment Provide Input/Comments Update Phase A RFP Considering Advisory Panel Input/Comments Solicit Responses to RFP Review and Comment and Award Contract on Responses for Phase A Study to RFP Phase A Contractor(s) Selected Meeting of Management Team, Advisory Panel, and Contractor (review overall work process and responsibilities; Advisory Panel and Management Team provide input to Contractor) Select Members of Peer Review Panel Peer Review Panel Established Draft Report on Phase A Discuss and Draft Risk Matrix 8 Months Traffic and Spill Evaluation Approach Likelihood/Size Review Phase A Review Phase A Review Phase A Traffic and Spill Traffic and Spill Traffic and Spill Likelihood/Size Analysis Likelihood/Size Analysis Likelihood/Size Analysis Update Draft Report on Provide Comments on Phase A Traffic and Spill Draft Phase A Traffic/Spill Likelihood/Size Report to Contractor Meeting of Management Team, Advisory Panel, and Contractor (discuss baseline spill risk report; review risk matrix evaluation approach; discuss scope of Phase A consequence analysis) Specify Scope of Phase A Draft Report on Phase A Consequence Analysis Consequence Analysis Review Phase A Review Phase A Review Phase A Consequence Analysis Consequence Analysis Consequence Analysis Provide Comments on Final Report on Phase A Draft Phase A Consequence Traffic/Spill/Consequence Report to Contractor Studies Qualitative Assessment and Prioritization of Risk Reduction Options Meeting of Management Team, Advisory Panel, and Contractor (establish list of potential risk reduction measures; prioritize list of risk reduction measures) Develop rankings for 3 Months accident scenarios Identify and qualitatively evaluate potential risk reduction options Prioritize risk reduction options FIGURE 5-2 Phase A Preliminary Risk Assessment. (RFP = request for proposals.)

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106 • Risk of Vessel Accidents and Spills in the Aleutian Islands Management Advisory Risk Analysis Peer Review Team Panel Team Panel Focused Risk Assessment Select Measures for Phase B Evaluation Develop Draft RFP Review Draft RFP for for Phase B Phase B Evaluation and Focused Risk Assessment Provide Input/Comments Update Phase B RFP Considering Advisory Panel Input/Comments 10 Months Solicit Responses to RFP Review and Comment and Award Contract for on Responses Phase B Study to RFP Phase B Contractor Selected Draft Phase B Report Review Phase B Study Review Phase B Study Review Phase B Study Provide Comments on Draft Final Report on Phase B Study Phase B Focused to Contractor Risk Assessment Development and Reporting of Findings and Recommendations Meeting of Management Team, Advisory Panel, and Contractor (discuss results of Phase B study; 3 Months prioritize list of risk reduction measures) Recommend Measures Management Report on for Implementation Findings/Recommendations and Process for Implementation FIGURE 5-3 Phase B Focused Risk Assessment. The risk assessment has four main stages: • Phase A semiquantitative studies, • Phase A qualitative assessment and prioritization of risk reduc- tion options, • Phase B Focused Risk Assessment, and • Phase B development and reporting of findings and recommen- dations. The estimated times for completion of each stage are approxi- mate and subject to refinement. However, the Management Team should attempt to keep the risk assessment generally on sched-

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Organization of the Aleutian Islands Risk Assessment • 107 ule. There is a sense of urgency to the study given the high level of traffic through the area, combined with the limited infrastruc- ture in place for mitigating risks (e.g., the lack of traffic separa- tion and vessel traffic services) and for providing effective responses to incidents (e.g., the lack of rescue-capable tugs). Rec- ognizing this sense of urgency, the proposed schedule is purpo- sively aggressive. Meeting the schedule will require careful management of parallel work efforts, avoidance of scope creep, and attention to work package delivery dates. The importance of meeting the schedule is ultimately the responsibility of the Man- agement Team and should be emphasized from the beginning of the project. At a minimum, the Management Team, Advisory Panel, and Risk Analysis Team should meet after each major step to review assumptions and findings; these meetings are shown in the figures. It is likely that more frequent meetings will be needed. However, the Risk Analysis Team will be able to take full advantage of the knowledge and expertise of the Advisory Panel and the Manage- ment Team. Although collaboration is necessary for the success of this study, each group has specific responsibilities, and some indepen- dence is therefore required. The Management Team is responsi- ble for defining the work scope of the Risk Analysis Team. The Management Team, Advisory Panel, and Risk Analysis Team are encouraged and expected to share expertise and knowledge. However, the Risk Analysis Team must perform its specified tasks in an unbiased manner, without predisposition toward any par- ticular outcome. One of the concerns expressed by the National Research Council committee reviewing the Prince William Sound study was that the study was “less an independent analysis of risk than a mutually agreed upon description of issues and recommendations for mitigating risk” (NRC 1998, 2). A balance must be struck between the obvious benefits of close collabora- tion and consensus building and the need for independent and critical thinking. The role of the Peer Review Panel is less collaborative—its job is to ensure that the science is right. Nev- ertheless, the critiques prepared by the Peer Review Panel should be instructive and constructive, with the goal of improving the final product.

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108 • Risk of Vessel Accidents and Spills in the Aleutian Islands Budgetary Considerations In accordance with the Selendang Ayu court settlement, $3 million has been set aside for the overall risk assessment and projects iden- tified by the risk assessment (Selendang Ayu Settlement 2007). The committee is confident that the available funds are more than sufficient to cover the costs of a credible comprehensive risk assess- ment. Funds remaining at the end of the assessment can be applied to risk reduction measures. Principal expenses for the risk assessment include the following: • Administration and meetings, • Facilitator for the Advisory Panel, • Peer Review Panel, and • Phase A and Phase B analyses by the contractor(s). The Management Team must control the scope of the work to ensure that it is conducted in a timely fashion, without early effort being expended on detailed analyses that will have little or no influence on the final decisions. The Phase A analysis involves the characterization of risks, needed as background for the qualitative assessment of potential risk reduction measures and as a baseline for the focused quan- titative assessment of risk reduction measures. As noted earlier, care must be taken to avoid spending too much of the budget on the Phase A analysis, leaving inadequate resources for the Phase B assessment. The committee’s best estimate is that about one- quarter of the overall budget should be allocated to the Phase A effort. Approximately two-thirds of that portion of the budget should be allocated for the traffic, spill likelihood and size, and causality studies, and one-third for the spill consequence studies. The budgeted amount should be adhered to, and expansion of the scope of these efforts should be avoided. In Phase B, there may be a natural tendency to assess more risk reduction options in greater detail than resources allow. Again, the scope of the work should be defined and adhered to as far as is practical. Contingencies should be provided for in the budget and time line to ensure that the final report is delivered without undue delay. If additional studies are deemed desirable, they should be considered following completion of the study as part of the ongoing effort of risk management.

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Organization of the Aleutian Islands Risk Assessment • 109 REFERENCES Abbreviation NRC National Research Council NRC. 1998. Review of the Prince William Sound, Alaska, Risk Assessment Study. National Academy Press, Washington, D.C. NRC. 2003. Oil in the Sea III: Inputs, Fates, and Effects. National Academies Press, Washington, D.C. Selendang Ayu Settlement. 2007. United States of America vs. IMC Shipping Co. PTE Ltd. Aug. 13.