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Letter Report on a Technical Peer Review of the Buzzards Bay Risk Assessment (2013)

Chapter: Enclosure F: BBRA Statement of Objectives

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Page 55
Suggested Citation:"Enclosure F: BBRA Statement of Objectives." National Academies of Sciences, Engineering, and Medicine. 2013. Letter Report on a Technical Peer Review of the Buzzards Bay Risk Assessment. Washington, DC: The National Academies Press. doi: 10.17226/22480.
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Page 55
Page 56
Suggested Citation:"Enclosure F: BBRA Statement of Objectives." National Academies of Sciences, Engineering, and Medicine. 2013. Letter Report on a Technical Peer Review of the Buzzards Bay Risk Assessment. Washington, DC: The National Academies Press. doi: 10.17226/22480.
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Page 56
Page 57
Suggested Citation:"Enclosure F: BBRA Statement of Objectives." National Academies of Sciences, Engineering, and Medicine. 2013. Letter Report on a Technical Peer Review of the Buzzards Bay Risk Assessment. Washington, DC: The National Academies Press. doi: 10.17226/22480.
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Page 57

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55 Enclosure F BBRA Statement of Objectives 1. The USCG and MassDEP seek contractor support to conduct a technical study that will identify and evaluate whether adopting the additional federal pilot and escort system requirements for Buzzards Bay in 33 CFR 165.100 for double-hulled tank barges is likely to reduce the risks of future oil spills from tank barges, and by how much and at what cost. a. An analysis of oil spill probabilities from double-hull tank barges operating in the Buzzards Bay RNA. This analysis should consider, at a minimum, navigational safety risks; the effect of weather and environmental parameters on vessel safety; causal data from past incidents and oil spills; and published reports and data. b. An analysis of the potential consequences of oil spills from double-hull tank barges operating in the Buzzards Bay RNA. This analysis should consider, at a minimum, environmentally sensitive habitat and resources at risk; threatened and endangered species; seasonality associated with vulnerabilities; and limits to available oil spill containment and recovery techniques due to weather or environmental factors. c. An evaluation of risk mitigation costs and benefits associated with a requirement for federally licensed pilots who are not also members of the crew onboard all double- hull tank barges transiting the RNA. The evaluation of mitigation measures should follow a recognized methodology. d. An evaluation of risk mitigation costs and benefits associated with a requirement for escort vessels (tugboats) to accompany all double-hull tank barges transiting the RNA. The evaluation of mitigation measures should follow a recognized methodology. e. Data analyzed as part of the evaluation under tasks 3 and 4 should include, at a minimum: i. Published studies and reports; ii. Review of safety data and incident reports from tank barges operating in Buzzards Bay since 2006; and iii. A review of other vessel escort systems in place in the United States. 2. Technical Study Components

56 a. Describes the geophysical properties of Buzzards Bay and the Cape Cod Canal, including currents, weather conditions, and the geomorphology and bathymetry as they apply to and influence vessel traffic, risks to navigation, and the ability to assess, contain, and remediate an oil spill in Buzzards Bay. b. Describes and compares the present towing vessel escort requirements in MOSPA and 33 CFR § 165.100(d)(5) and includes the history of and rationale for the Federal and State regulatory systems. c. Describes how towing vessels and tank barges are currently escorted in the subject waters, including tug and barge industry operational practices and experiences with tugboat escorts and Buzzards Bay and Canal Control vessel traffic procedures. The description should include data on vessel traffic, volume of oil transported, utilization of tugboat escorts (including the availability of tugboat escorts with appropriate specifications, how they are utilized, distances between escorts and barges and their towing vessels, and tying up to barges), and other relevant information. d. Describes and compares the present Federal and State marine pilot requirements in MOSPA and 33 CFR § 165.100(d)(5), as they apply to single- and double-hulled tank barges. The description shall include an evaluation of the current “recency” provisions as they apply to federal pilotage in Buzzards Bay, including their effectiveness and enforceability. e. Describes the environmental and economic values potentially protected by the current Federal and State towing vessel escort system, including natural resources, recreational and commercial fishing, and tourism, and by any proposed federal system that requires federal pilots and tug escorts for double-hulled tank barges. f. Describes the capabilities and limitations of single-propulsion and dual-propulsion towing vessels that presently operate on Buzzards Bay. g. Describes the phase-out of single-hull tank barges and the anticipated changes in the use of tank barges and articulated towing vessel–barge vessels. h. Describes the safety enhancements and redundant systems of double-hull tank barges that operate on Buzzards Bay as compared to single-hull tank barges, and includes the size of the vessels (length and width), the volume of oil they transport, internal cargo tank configurations, the amount of water they draw when fully loaded, and ability to stop in the event that the towing vessel loses propulsion and/or steering. Provides data from outflow analyses that considers the relative preventative value of double hulls to various types of casualties (e.g., soft grounding, hard grounding, collision, and allision). i. Describes the range of technological, human and external factors that influence risk management as it applies to the towing vessels and single- and double-hulled tank barges transiting Buzzards Bay and the Cape Cod Canal. An evaluation of the effects of fatigue on vessel crews shall be included.

57 j. Compares the current Buzzards Bay towing vessel escort practices with other mandatory towing vessel escort systems in place in other parts of the United States. k. Identifies potential direct and indirect effects any proposed changes to the towing vessel escort system may have on the population of towing vessels operating on Buzzards Bay. l. Describes the expected costs and benefits of providing federal pilots and escorting double-hull tank barges, including an analysis of the anticipated safety, environmental, and economic consequences of requiring federal pilots and tugboat escorts for double-hull tank barges. This shall include the estimated costs associated with the assessment and clean-up of an oil spill in Buzzards Bay vs. the cost of risk mitigation measures.

Next: Enclosure G: Description of Escort Tugs and How They Are Used »
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At the request of the Massachusetts Department of Environmental Protection (MassDEP), the TRB/Marine Board Committee to Review the Buzzards Bay Maritime Risk Assessment has evaluated the methods and conclusions of the Buzzards Bay Risk Assessment (BBRA).

The BBRA was originally commissioned by the United States Coast Guard and MassDEP. The committee’s task was to provide an independent technical review of the BBRA focusing on its scope, methods, and supporting data. The committee finds that the choices made in the formulation and execution of the study bring into question the conclusions of the risk assessment on technical grounds and that the ranking of risk mitigation options is not justified and could be reversed with slightly different and more defensible methods or assumptions.

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