4
Barriers to Effective Response

In presentations at the four committee meetings and at the workshop, leading experts from the spill-response, regulatory, environmental, and oil-transportation communities consistently identified a number of barriers to effective responses to spills of nonfloating oils. The major managerial, technological, and financial barriers identified by these experts and supported by the experience of committee members are summarized below.

Managerial Barriers

A major managerial barrier in responding to spills of nonfloating oils is the lack of experience at the local level. The knowledge base for planning and responding to oil spills is primarily derived from responses to actual oil spills. Significant oil spills are infrequent by their very nature, and spills of nonfloating oils are only a small fraction of all oil spills. Thus, it is difficult to acquire and maintain a sufficient knowledge base at the local level to respond to nonfloating-oil spills, particularly because few organizations have full-time, dedicated response teams. Furthermore, planning for nonfloating-oil spills generally has a low priority because of their infrequency. Responding to a spill of nonfloating oils is, therefore, often a new or very rare experience for local response teams who are likely to have trouble anticipating problems and formulating effective response strategies.

Planning for spills of nonfloating oils at the regional level has often been inadequate. There are 44 area committees in the USCG's jurisdiction. None of the area plans, however, has a well developed strategy for responding to spills of



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4 Barriers to Effective Response In presentations at the four committee meetings and at the workshop, leading experts from the spill-response, regulatory, environmental, and oil-transportation communities consistently identified a number of barriers to effective responses to spills of nonfloating oils. The major managerial, technological, and financial barriers identified by these experts and supported by the experience of committee members are summarized below. Managerial Barriers A major managerial barrier in responding to spills of nonfloating oils is the lack of experience at the local level. The knowledge base for planning and responding to oil spills is primarily derived from responses to actual oil spills. Significant oil spills are infrequent by their very nature, and spills of nonfloating oils are only a small fraction of all oil spills. Thus, it is difficult to acquire and maintain a sufficient knowledge base at the local level to respond to nonfloating-oil spills, particularly because few organizations have full-time, dedicated response teams. Furthermore, planning for nonfloating-oil spills generally has a low priority because of their infrequency. Responding to a spill of nonfloating oils is, therefore, often a new or very rare experience for local response teams who are likely to have trouble anticipating problems and formulating effective response strategies. Planning for spills of nonfloating oils at the regional level has often been inadequate. There are 44 area committees in the USCG's jurisdiction. None of the area plans, however, has a well developed strategy for responding to spills of

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nonfloating oils. As a result, planners have limited experience in identifying the likelihood and potential sources of spills of nonfloating oils, determining resources at risk, establishing protection priorities and strategies, or evaluating response capabilities in federal, state, and industry plans. Area committees and other constituencies have not adequately resolved emergency regulatory issues associated with responses to nonfloating-oil spills, such as obtaining permits for emergency dredging and the discharge of co-collected water. As a result, even though every spill of nonfloating oils is a true emergency, difficult regulatory issues must be faced without the benefit of prior discussions of response options. Consequently, regulatory agencies cannot usually provide timely approvals. The resources and information necessary to respond effectively to nonfloating-oil spills have not been identified, including divers capable of operating in contaminated waters, the capability of updating bathymetric maps to determine potential accumulation zones, and the selection and implementation of systems to track the movement and distribution of subsurface oil. Furthermore, few, if any, drills or exercises have been carried out with scenarios focused on spills of nonfloating oils. In the absence of a real spill, exercises are an excellent mechanism for verifying response plans and improving response capabilities. The lack of drills, combined with limited experience with actual spills, has seriously impeded the development of a practical knowledge base for responders. Misconceptions about the behavior, fate, and effects of nonfloating-oil spills are widespread. Descriptions of the transport and fate of spills of nonfloating oils have been confused and inconsistent. Consequently, the documentation of actual spills is poor and difficult to interpret, and no formal system for sharing lessons learned from previous spills has been developed. Without field experience or adequate literature on which to base predictions of behavior and effects, resource managers and responders have been forced to develop their own conceptual models of how nonfloating oils might behave and their environmental impacts. These conceptual models are often inadequate or incorrect, leading to erroneous assumptions about the viability or effectiveness of response options. Technological Barriers Existing methods for tracking spills are not effective for tracking nonfloating oils. One of the first questions asked after an oil spill is where the oil is going. The answer to this question often determines subsequent decisions. Most conventional methods for predicting the trajectory and tracking oil spills rely on two dimensional (e.g., surface) transport and fate models and visual observations, none of which is effective for tracking nonfloating oils. Methods used to track nonfloating oils in past spills have been largely ineffective. Most existing methods have low encounter rates and limited areal coverage for tracking oil suspended in the water column. Thus, it is impossible to

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generate a synoptic map of the dispersed oil plume over time. The problems are similar for tracking oil deposited on the seabed, but generally the movement of deposited oil is less dynamic. Bottom sampling methods for large areal searches (e.g., video and sonar searches) are limited by site constraints, difficult logistics, and the need for extensive ground truthing (i.e., in situ verification). The most commonly used techniques (e.g., sorbent drops and drags, diver observations, bottom trawls) can only sample limited areas and are slow, labor intensive, and logistics intensive. The options for effectively containing and recovering nonfloating oils are limited. Even the most promising methods have not been effective for containing and recovering oils mixed in the water column, except under ideal conditions (e.g., small spills of emulsified oils in areas with very low currents and little wave activity). Generally, oil in the water column disperses quickly over large areas and volumes, becoming unavailable for effective recovery. Containment of oil deposited on the seabed is only feasible where the oil accumulates naturally. In these cases, recovery rates can be very high with the use of manual, pumping, or dredging techniques. However, each of these methods requires handling large volumes of water and solids. Because of a general lack of knowledge about benthic habitats and resources, assessing resources at risk from nonfloating oils is extremely difficult. Area plans include annexes, in which sensitive areas are identified and prioritized for protection. One of the tasks of area committees is to discuss cleanup methods and end points appropriate for different habitats. Although nonfloating-oil spills threaten both the water-column and bottom (benthic) habitats, data on benthic habitats and resources at risk are either very sparse or not available. Benthic habitats are often described in very general terms, and few areas have been mapped in detail. Areas with high concentrations of plant or animal species or sites important to the sensitive, early life stages of organisms are usually poorly known, even for species with high commercial value. Without this information, it is difficult for resource managers to evaluate the potential effects of unrecovered oil or to decide on how aggressive their containment and recovery efforts should be. Financial Barriers Funding levels for testing and evaluating potential response options for all oil spills are low, but they are especially low for spills of nonfloating oils (NRC, 1998). Even after the watershed Exxon Valdez oil spill, federal, state, and industry funding for research and development have remained low. Funding for research and development on the containment, recovery, and effects of nonfloating oils has also been low and is generally targeted toward emulsified fuels for which funding is provided by the producers of these fuels. The lack of research, development, testing, and evaluation has left responders with a very limited number of unproven options for responding to nonfloating-oil spills. Information about how these options might be used under specific spill conditions is also limited.