Section 3.18: Contingency Planning. TERMPOL Surveys and Studies

Transcription

1 TERMPOL Surveys and Studies ENBRIDGE NORTHERN GATEWAY PROJECT FINAL - REV. 0 Prepared for: Northern Gateway Pipelines Inc. January 20, 2010

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3 Table of Contents Table of Contents 1 Introduction Vessel Plans for Tankers Vessel Plans for Escort Tugs Terminal Plans Response Area and Spill Response Capability Response Strategies Financial Responsibility for a Spill Response Response to Marine Spills Ship Owner Liability Compensation International Oil Pollution Compensation Fund Ship-Source Oil Pollution Fund The International Supplementary Fund Project Documents Study Training and Exercises Vessel Contingency Plan Integration of Northern Gateway Plans with Canadian Coast Guard (CCG) Procedures and Other Plans Study Ship-Oriented Contingency Planning Study Terminal-Oriented Contingency Planning Study Terminal-Ship Communications Planning Study Response and Compensation Planning Conclusion Appendix A Appendix B General Oil Spill Response Plan (GOSRP) Typical Table of Contents... A-1 Generic Example of Marine and Terminal Oil Spill Contingency or Response Plans Table of Contents... B-1 January 20, 2010 Final - Rev. 0 Page i

4 Table of Contents Table of Contents (continued) Appendix C Appendix D Appendix E Appendix F Typical Table of Contents of a Ship-Oriented Contingency Plan (SOPEP)... C-1 Terminal Oil Pollution and Emergency Plan (OPEP) / Oil Pollution Prevention Plan (OPPP) - Draft Outline of Table of Contents... D-1 Technical Data Report: Oil Spill Response Planning for the Confined Channel Assessment Area (CCAA) - Draft Outline of Table of Contents... E-1 Technical Data Report: Oil Spill Response Planning for the Open Water outside the CCAA, within Canadian Jurisdiction - Draft Outline of Table of Contents... F-1 List of Tables Table 1-1 Typical Sequence of Initial Response Actions Table 3-1 Topics to be included in the Ship-Oriented Contingency Plan Table 4-1 Aspects of the Terminal-Oriented Contingency Plan of Interest to Transport Canada Table 5-1 Aspects of the Terminal Ship Communication Protocol Table 6-1 Summary of Preferred Treatment Tactics for Sand Beaches for Different Oil Types and for Surface and Subsurface Oiling Conditions List of Figures Figure 1-1 Figure 1-2 Figure 1-3 Relationship between Enbridge Corporate Plans and the Northern Gateway Project General Oil Spill Response Plan (GOSRP) Relationship between the Northern Gateway Project GOSRP and Other Project Plans Relationship between the Project Oil Spill Contingency Plans for Marine and Terminal operations Figure 2-1 Course of Action for ships in the Event of a Spill Page ii Final - Rev. 0 January 20, 2010

5 Section 1: Introduction 1 Introduction Contingency plans are prepared to ensure that a response capability is in place to address abnormal events. Prevention of accidents and injuries is of primary importance to Northern Gateway, whose policy is to operate in a manner designed to prevent incidents and, if an incident were to occur, to implement measures to prevent escalation of the incident. The objective of this study is to provide the framework of the detailed contingency planning associated with the Enbridge Northern Gateway Project (the Project), in accordance with the TERMPOL Code, TP473E 2001, and Study In the TERMPOL code Sections , and , Transport Canada has identified abnormal events of interest that should be addressed within the vessel and terminal contingency plans. This study identifies how these abnormal events will be addressed within those plans. The prevention of a possible oil spill is one of the highest priorities for Northern Gateway. In the event of an oil spill, including third-party accidents Northern Gateway and the designated Response Organization will provide the first response capability. Northern Gateway and the designated Response Organization will prepare a complete set of contingency plans for the prevention of and response to an oil spill. These plans will cover all aspects of the Project and potentially affected areas, including the pipeline and the Kitimat Terminal. They will also cover project-related vessel traffic in Canadian waters. The cornerstone of the contingency planning process is the General Oil Spill Response Plan (GOSRP), which will be developed to describe measures that would be implemented prior to or following an oil spill on land, at the terminal or along the marine transportation routes. The preliminary outline of the intended GOSRP is presented in Appendix A. The GOSRP covers any oil spill with actual or potential consequences to Project personnel, the environment, property or the public at large. The GOSRP includes an outline of the organization, which would be established (in cooperation with government and other agencies) to manage the oil spill response. The emphasis throughout the GOSRP is on practical actions to enhance the effectiveness of the response and mitigation of effects. Key features of the intended GOSRP are that it: provides a vision statement for the Project regarding oil spill response concepts and strategies provides an umbrella document that covers all aspects of an oil spill response, including potentially affected areas on the land, in rivers, near coasts, in the CCAA and in open water (within Canadian jurisdiction) describes the relationship (framework) that ties all of the various Northern Gateway documents (plans and reports) into a single cohesive program. describes how the Northern Gateway's plans relate to external documents, such as the Canadian Coast Guard (CCG) Pacific Response Plan, BC Ministry of Environment s Marine Oil Spill Response Plan, potential Geographic Response Plans (GRPs), and the Joint Contingency Plan (JCP) Canada-US- Dixon Entrance (JCP-CANUSDIX) Annex provides information and data to the Spill Management Team for the decision process and is a management tool. January 20, 2010 Final - Rev. 0 Page 1-1

6 Section 1: Introduction The GOSRP and the contingency plans for the Project will be part of the Enbridge corporate Emergency Response Plan (ERP) (Figure 1-1). The overall framework for the oil spill contingency plans within the GOSRP is shown in Figure 2-1. Specific elements of the Marine Area Oil Spill Response Plans (OSRPs) and the Kitimat Terminal Area OSRPs are identified in Figure 3-1. Emergency response at the corporate level of Enbridge is handled within the Health and Safety Management System through the Emergency Response Plan (ERP). The ERP is independent, though related to, the Crisis Management Plan (CMP) (Figure 1-1). Part 1 of the Corporate Operating and Maintenance Procedures contains all of the emergency response practices and procedures that are common throughout the company s operations, including: pre-emergency preparedness; the spill management system; the notification process; and containment, recovery and cleanup procedures. Part II provides region- and project-specific information for the Northern Gateway project related to oil spills and is titled the General Oil Spill Response Plan (GOSRP). Figure 1-1 Relationship between Enbridge Corporate Plans and the Northern Gateway Project General Oil Spill Response Plan (GOSRP) Figure 1-2 Relationship between the Northern Gateway Project GOSRP and Other Project Plans Page 1-2 Final - Rev. 0 January 20, 2010

7 Section 1: Introduction GOSRP CCG - Pacific Plan JCP - CANUSDIX BCMoE Marine OSRP BC GRPs RO Area Plan Marine Area Terminal Area Marine OSRP Vessel CP Tug SOPEP Terminal OSRP TDRs Vessel SOPEP OPPP OPEP TOM GOSRP General Oil Spill Response Plan SOPEP Shipboard Oil Pollution Emergency Plan CCG Canadian Coast Guard CP Contingency Plan BCMoE British Columbia Ministry of Environment TDR Technical Data Report GRP Geographic Response Plan OPPP Oil Pollution Prevention Plan OSRP Oil Spill Response Plan OPEP Oil Pollution Emergency Plan RO Response Organization JCP Joint Contingency Plan CANUSDIX Canada-US-Dixon Entrance TOM Terminal Operations Manual OPEP Figure 1-3 Oil Pollution Emergency Plan Relationship between the Project Oil Spill Contingency Plans for Marine and Terminal operations As a key element of the overall contingency and response planning process, Northern Gateway intends to develop a Marine OSRP and a Kitimat Terminal OSRP that will contain all required sub-plans and supporting technical reports. The Marine OSRP is similar in concept to the GOSRP but will be more technical. The Marine OSRP will be a required component of all vessel contingency plans and the SOPEPs required for each tanker and for Project support tugs greater than 300 gross tonnes. January 20, 2010 Final - Rev. 0 Page 1-3

8 Section 1: Introduction The Terminal OSRP will include the Terminal / Trans-shipment Site Operations Manual (TOM), the Oil Pollution Prevention Plan (OPPP) and the Oil Pollution Emergency Plan (OPEP). Other terminal plans, (but not oil spill related) would be cross referenced in the Terminal OSRP. These plans would address topics such as pipeline operational emergencies, fire, explosion, forest fire, earthquake, power failure, security incidents, and other non-spill emergencies. Another element of the overall planning process is the response plan owned by the Response Organization (RO), which will be engaged directly and individually by each of the visiting tankers and by the Kitimat Terminal management team (contracted services to comply with their large spill requirements under Canada Shipping Act, 2001). The RO geographic response plan for this area will complement and be used by the Marine OSRP (Figure 1-3). The Marine OSRP demonstrates the intent of the Project to provide leadership in the development of response concepts and strategies in the CCAA and in open water (within Canadian jurisdiction) in which project-related shipping will occur. This proactive role involves a requirement that the RO will participate in the development of, and comply with the Marine OSRP. The underlying concept of contingency planning is to ensure that all required plans and supporting strategy or technical documents (such as the Technical Data Reports) are part of a coordinated and integrated preparedness and response process. In particular, Figure 1-3 demonstrates how the various key internal and external plans relate to each other under the General Oil Spill Response Plan (GOSRP). A generic preliminary outline of the intended Marine Area and Terminal Area OSRPs is presented in Appendix B. Response to an oil spill in the marine environment involves the coordination of independent agencies and groups with well defined roles and responsibilities that are described in the various OSRPs. The GOSRP integrates these various documents to provide the framework for a successful cooperative and coordinated response strategy. Table 1 lists some, but not all, of the key actions that might take place following a spill into marine waters. Some of the actions may be a single, one-off event, such as a notification, whereas other activities initiate a series of actions, some of which are concurrent and depend on other ongoing activities. Table 1-1 Typical Sequence of Initial Response Actions 1. On-site supervisor (terminal spill) or vessel captain (on water) assumes role of the initial On- Scene Commander (OSC). 2. OSC notifies appropriate federal CCG, Provincial, Northern Gateway and RO contacts. 3. OSC initiates the first response actions prescribed in the OSRP. 4. OSC scales the problem and determines the most probable Tier response level (based on a Company philosophy of over responding rather than and under responding). Reports this assessment to ENPG contact(s). TIER 1 RESPONSE LEVEL FIRST RESPONSE 5. On-site resources deployed to contain, recover and cleanup under the direction of the OSC and staff. 6. OSC informs the CCG Federal Monitoring Officer (FMO) of actions taken and intended actions. Page 1-4 Final - Rev. 0 January 20, 2010

9 Section 1: Introduction 7. OSC establishes a first response Command Post (CP) location. 8. Northern Gateway regional management mobilizes the Spill Management Team (SMT) to the level (i.e., depth of personnel) necessary to take over command and management of the response. 9. SMT conducts assessment. TIER 2 and TIER 3 RESPONSE LEVEL FIRST 24 HOURS 10. SMT recommends to the OSC which resources are appropriate to cascade to the response area. 11. SMT recommends response objectives, strategies, and priorities to the OSC. 12. OSC informs CCG FMO of intended actions. 13. If appropriate, initial response OSC hands over to replacement OSC: CCG and Province are notified of that handover. 14. SMT establishes a Finance Section to provide funds, receive claims and document all costs and claims. 15. If necessary, SMT establishes a new CP. 16. Company participates in a Joint Information Center with the Province and issues press release(s) on the incident and the response. One of the keys to the successful implementation of a spill response is to ensure that actions are agreed to and coordinated between the parties involved. To a large degree the roles and responsibilities of the major players (i.e., BC Ministry of Environment, Regional Environmental Emergencies Team, and Canadian Coast Guard) are defined by regulations. In the event of a spill from the marine terminal or pipeline into the marine environment Northern Gateway would initiate, manage and implement the response operation. The Responsible Party (RP) for a spill from a vessel in transit to or from the Northern Gateway marine terminal or from an escort or berthing tug is the vessel owner. The first response would be implemented by the vessel captain as the initial On-Scene Commander (OSC). The vessel captain would, at some point in time as identified in the Marine OSRP, hand over to the Northern Gateway OSC or to an OSC designated by Northern Gateway even if Northern Gateway is not the RP. The Canadian Coast Guard (CCG) is the lead federal agency for all ship-source oil spills or pollution incidents in waters under Canadian jurisdiction. When the RP has been identified and is willing and able to respond, the CCG will advise the RP of its responsibilities and, once satisfied with the RP s intentions and plans, will assume the role of Federal Monitoring Officer (FMO) on behalf of the Crown. The BC Ministry of Environment (BCMoE) monitors on behalf of the Province, participates in the response and coordinates local involvement. Environment Canada (EC) provides scientific and technical support and coordinates environmental input to the response as chair of the Regional Environmental Emergencies Team (REET). Contingency plans provide the framework for the response organization and the decision process. Technical Data Reports (TDRs) have been prepared for the Project to provide data and information on resources at risk in the project area, as well as environmental and operating conditions, and are the basis for development of mitigation strategies to minimize the extent of the oiled area and to protect known vulnerable resources at risk. These mitigation strategies become an integral component of the OSRP. January 20, 2010 Final - Rev. 0 Page 1-5

10 Section 1: Introduction The intent is that the oil spill response capability for the Project will be designed to significantly exceed CSA requirements for a Primary Area of Response (PAR) as outlined in Termpol 3.15 Section 7, thereby ensuring a local Tier 1 through 3 capabilities for the Terminal. The current designed response capability is based on the requirement that the Marine OSRP will be a component of all tanker contingency plans and the SOPEPs required for each of the Project support tugs of 300 gross tonnes or more (Figure 1-3). 1.1 Vessel Plans for Tankers All ships carrying oil in bulk are required by MARPOL to have a contingency plan. This plan is often referred to as to as a Shipboard Oil Pollution Emergency Plan (SOPEP). The SOPEP describes procedures to be followed in the event of an oil spill. A SOPEP is based on the International Maritime Organization (IMO) Guidelines for the Development of Shipboard Marine Pollution Emergency Plans. Each inbound vessel would be required to have a contingency plan that would include the Marine OSRP. This vessel contingency plan (CP) would include the SOPEP as well as pre-planned response procedures for other emergencies 1. Given that marine shipping is not expected to be operational until at least 2015, a detailed Marine OSRP has not yet been prepared. A preliminary outline table of contents for the plan is presented in Appendix B. Some of the topics to be included in this ship contingency plan are discussed in Section 3. Northern Gateway will ensure that adequate material is provided to each of the tanker operating companies to support their contingency planning. The Marine OSRP will incorporate, either in content or through reference, much of the supporting field work and studies that have already been conducted, that are in progress or that are planned as part of the preparation of numerous Technical Data Reports (see Section 6). The OSRP would be source of relevant Canadian and United States information to supplement their existing contingency plans and SOPEP (For example shoreline sensitivities). Visiting tanker operators will also be provided with emergency planning information that addresses terminal-related incidents that could occur when a tanker is berthed at the Kitimat Terminal. The Northern Gateway information will be made available to the tanker operating companies well in advance of their first visit and at an orientation meeting upon arrival at the Kitimat Terminal before any cargo loading or discharge. 1.2 Vessel Plans for Escort Tugs In parallel with the requirements for vessel CPs, the Project will require that each tethered, escort or harbour support tug of 300 gross tonnes or greater have a SOPEP. The support tugs will not be required to have their own Marine OSRP because all response operations in which they might be involved would be covered under the umbrella of either the vessel OSRP or the RO OSRP, both of which will be required to contain the Marine OSRP. The preliminary outline of the intended SOPEP is presented in Appendix C. 1 Ships above 150 gross tonnes certified to carry noxious liquid substances in bulk are required by the IMO to carry an additional emergency plan, called the Shipboard Marine Pollution Emergency Plan for noxious liquid substances. This plan can be combined with the SOPEP to form the Shipboard Marine Pollution Emergency Plan (SMPEP). Page 1-6 Final - Rev. 0 January 20, 2010

11 Section 1: Introduction 1.3 Terminal Plans Comprehensive emergency procedures manual for the Kitimat Terminal, including the Terminal OSRP (Figure 1-3) will be completed and submitted to Transport Canada and the National Energy Board (NEB) at least six months before the Kitimat Terminal begins handling bulk oil. The Terminal OSRP will include an Oil Pollution Emergency Plan (OPEP) and an Oil Pollution Prevention Plan (OPPP). These plans will be directly linked to the RO OSRP, the tanker CPs and the support tug SOPEPs under the Marine OSRP. The OPEP will describe emergency response actions available to mitigate the effects of an oil spill from the Kitimat Terminal on the marine environment. The OPPP will describe measures that will prevent pollution during tanker transfers. These plans must be finalized for formal submission in the year before oil handling begins. The OPEP will be used by the terminal management and spill response staff. The OPPP will include operational procedures that must be practiced by both terminal and tanker personnel. For example, annual pressure testing of the terminal s tanker loading arms will likely be required under new OPPP rules (expected in 2010 from Transport Canada). At this stage in the planning process, Northern Gateway is considering the option to combine the OPEP and OPPP into one volume. A preliminary outline for the intended Terminal OSRP (OPEP and OPPP) is provided in Appendix D. Northern Gateway will comply with applicable legislation, regulations and standards. Appendix D and TERMPOL Study 3.19 demonstrate Northern Gateway s understanding of the Canada Shipping Act, and associated Response Organizations and Oil Handling Facilities Regulations (SOR ). 1.4 Response Area and Spill Response Capability The OPEP will cover the geographic area that could be affected by a spill from the Kitimat Terminal. The RO engaged by the Kitimat Terminal (to meet its 10,000-tonne response obligation) is required to have a response plan that addresses the areas beyond the Kitimat Terminal, specifically in the CCAA and in open water (within Canadian jurisdiction) and which will include the Project s Marine OSRP. The RO s plan is submitted to Transport Canada every three years as part of its certification process or when there is significant change of circumstances. Northern Gateway is committed to oil spill response that exceeds the requirements of the CSA. Details of the plan, response times, and equipment are outlined in Termpol 3.15 Section 7. To improve response time to a tanker incident, Northern Gateway will develop additional response capabilities in addition to the RO capabilities. The present concept is to place these additional capabilities onboard the tanker escort tugs and, at selected shore-side locations along the marine transportation routes in the CCAA. These additional capabilities will be documented in an addendum to the Kitimat Terminal OSRP and in the Marine OSRP. January 20, 2010 Final - Rev. 0 Page 1-7

12 Section 1: Introduction Based on oil volume handled, the Kitimat Terminal will be a Designated Port under the CSA. When this change in status occurs, the government-certified RO created or selected by Northern Gateway will be required to meet resident equipment requirements (inside the Kitimat Terminal port boundary) as well as more stringent response time planning standards. The RO must describe how it is prepared to respond to the presence of project-related shipping, including the Kitimat Terminal and new tanker operations within the RO s declared geographic area of response. Northern Gateway will provide information to the RO in order that they may complete their response planning. 1.5 Response Strategies In recent years, area committees in the US, such as the Northwest Area Committee (NWAC), comprising government agencies (federal, state and local) and other stakeholders, have compiled lists of significant sensitivities to oil spills in each marine area and subsequently developed Geographic Response Plans (GRPs) that detail oil spill countermeasures appropriate for the locations identified. Similar to these initiatives, BC Environment has developed GRPs for the Georgia Strait area and has begun the process of developing a GRP for the Kitimat area. It is Northern Gateway s intention to support and participate in this process, which will involve the local community. The marine transportation routes in the CCAA to be used by project-related tankers are expected to become areas of interest for identifying sensitivities and developing GRP strategies to deal with those sensitivities. In July 2007, Transport Canada released its Places of Refuge Contingency Plan (PORCP) to comply with IMO Resolution A.949 (23) Guidelines for Places of Refuge for Ships in Need of Assistance. This new Canadian initiative will require information to be gathered on potential places of refuge (PPOR) in advance of any incident involving a ship requesting a place of refuge. PPORs will be developed for the marine transportation routes. The PORCP includes guidance for collecting such information. It is Northern Gateway s intention to support and participate in this process. The GRPs that will be developed for BC s marine areas will also be relevant to the PPOR and the PORCP process. Developing these support information materials will involve each level of government, local area committees and the spill response community. To support the eventual RO and government response planning activities along the project-related marine transportation routes, Northern Gateway will prepare a Marine OSRP based on information contained in two sets of background documents: one Technical Data Report (TDR) will cover the Confined Channel Assessment Area (CCAA) between Kitimat, Camaaño Sound and Browning Entrance and a second TDR will cover portions of the open water area outside the CCAA but within Canadian jurisdiction. For the CCAA, the following documents will be prepared: a description of the weather, sea state, tidal and ocean current environment to characterize the operating environment for ship and tanker emergency response and for oil spill response activities Page 1-8 Final - Rev. 0 January 20, 2010

13 Section 1: Introduction a description of the oil spill sensitivities to include: shoreline sensitivity maps other maps of resources that may be at risk in the event of a spill: man-made (e.g., marinas, log dumps, jetties wharfs), fisheries, wildlife, biological, heritage and cultural resources a report on the properties of the oils and condensate that will be carried by the project-related tankers and handled by the Kitimat Terminal mass balances and narratives describing the movement over time for hypothetical oil spill examples at a number of locations along the project-related marine transportation routes presentation of countermeasures that would be used during the initial response (first 24-hours to 36- hours) after each hypothetical release forecasted (item above) a general discussion of the oil spill response countermeasures available that should be considered by tanker operators and the RO in response to a spill. The document will also include a discussion of the logistics support needed to mount and sustain a response operation in these remote areas as well as the effects of shoreline response choices on the volume of waste materials generated Similar documents will be produced for the open water outside the CCAA but within Canadian jurisdiction, but at a more general level. These documents should assist the process of identifying sensitivities and developing response strategies that will appear in the BC GRPs described earlier. The GRPs will be included in the Marine OSRP and the RO geographic area response plan. It is assumed that federal and provincial government agencies will play a lead role in the development of GRPs and PPORs. 1.6 Financial Responsibility for a Spill Response The response to a marine oil spill would follow established regulations and procedures and costs would be reimbursed following established claims procedures. Under Canadian law and international convention, the RP for a spill from a vessel in transit to or from the marine terminal or from an escort or berthing tug is the vessel owner. The first response would be initiated, managed and implemented by the vessel captain who would notify and mobilize a certified RO under the direction of Northern Gateway as prescribed in the Project Marine OSRP. The first response unit will be an escort tug, which will be designed and classed for this purpose. The RP makes funds available, as necessary, for costs of the response and claims. For vessels, these are claimed through their insurance carrier, a Protection and Indemnity (P&I) Club which is part of a larger non-profit mutual insurance system for marine transportation activities, including oil spills. Spill response financing and compensation amounts are provided below in Sections and 1.7. Agencies, authorities or private companies that participate in the response may have to bear the initial cost of their involvement or make arrangements with the RP or its insurer to cover those costs. Costs associated with the response and damage or other claims are charged to the RP. These initial response costs can be supported, in some cases, by the Canadian Ship-source Oil Pollution Fund (SOPF) but later would be charged to the RP. January 20, 2010 Final - Rev. 0 Page 1-9

14 Section 1: Introduction Response to Marine Spills Response Organizations (RO s), certified by the federal government, respond to marine oil spills. RO s have plans, resources, training and equipment in place to effectively implement marine oil spill response operations. Oil handling facilities in Canada and marine vessels of prescribed class that transit Canadian waters must have agreements in place with certified RO s and an oil spill emergency plan. Oil handling facilities and marine vessels pay an annual fee to RO s to ensure a level of preparedness to respond to an oil spill in the event that one occurs Ship Owner Liability Liability for marine oil spills in Canada is based on Canada s adoption of international conventions, which have been implemented through federal legislation. Canada is a party to the International Convention on Civil Liability for Oil Pollution Damage ( CLC ). In Canada, the Marine Liability Act, S.C. 2001, c. 6 ( MLA ) meets the requirements set out in the CLC. Under the CLC and MLA, ship owners are strictly liable for damage from oil spills. The MLA and CLC set limits on the liability of a ship owner, depending on the gross tonnage of the ship. Liability and compensation for marine oil spills is stated in Special Drawing Rights (SDR). The value of the SDR in Canadian dollars changes each day. Ships greater than 140,000 tonnes are liable for up to 89.8 million SDR ($152.2 million Canadian on October 1, 2009) 2. To ensure the ship owner is able to cover its liability costs, the ship owner must establish a fund in the amount of its maximum liability. Ship owners are required to carry insurance, which is ordinarily provided by international P&I Clubs, who provide coverage to ship owners against third party liabilities relating to the use and operation of ships. 1.7 Compensation In addition to ship owner liability, Canada has a tiered system of compensation for damage from oil spills not covered by a ship owner or its insurer. This system includes international funds available through Canada s participation in various international conventions and a national fund set up under the MLA International Oil Pollution Compensation Fund Under the first tier, compensation for oil spills is provided under the International Convention on the Establishment of the International Fund for Compensation for Oil Pollution Damage (1971) as amended by the 1976 and 1992 protocols ( IOPC ). The fund established under this convention ( IOPC Fund ) provides compensation for pollution damage from oil spills in the following situations: where the damage exceeds the limit of the ship owner s liability under the CLC (in Canada the MLA) where the ship owner is exempt from liability under the CLC (MLA) because the damage was caused by one of the events listed in Section where the ship owner is financially incapable of meeting his obligations in full under the applicable CLC, and the insurance is insufficient to pay valid compensation claims 2 On October 1, 2009 one SDR was equivalent to $ Canadian. Page 1-10 Final - Rev. 0 January 20, 2010

15 Section 1: Introduction The IOPC provides coverage such that the maximum compensation from the IOPC fund and the ship owner or its insurer is 203 million SDR ($345 million Canadian) Ship-Source Oil Pollution Fund The second tier in the system is the national fund, which in Canada is the Ship-Source Oil Pollution Fund ( SOPF ), established under the MLA. The maximum liability of the SOPF for one incident is $100 million, adjusted annually ($154.4 million during the fiscal year commencing April 1, 2009). The total compensation available from the SOPF, IOPC Fund and the ship owner as of October 1, 2009 was $499.3 million. The SOPF may be considered a fund of last resort because when all reasonable steps have been taken to recover payment of compensation from the owner of the ship and the IOPC and have been unsuccessful then compensation will be paid from the SOPF. It is also a fund of first resort because a person, other than a RO, may make a claim directly to the SOPF. If the SOPF pays the claim, the SOPF may then attempt to recover funds from the IOPC or the ship owner The International Supplementary Fund Canada recently amended the MLA to give effect to a third tier of compensation, the International Oil Pollution Compensation Supplementary Fund ( 2003 Supplementary Fund ). The amendments to the MLA will come into effect as soon as Canada ratifies the Supplementary Fund Convention. The 2003 Supplementary Fund makes additional compensation available so that the total amount payable for any one incident for pollution damage in Canada will be 750 million SDR ($1,274 million Canadian on October 1, 2009) including the amount payable from the ship owner or insurer and under the IOPC and SOPF. The Supplementary Fund is administered the same way as the IOPC Fund. 1.8 Project Documents The marine environmental protection program developed by Northern Gateway to anticipate, prevent, mitigate and manage oil spills will be used to develop the Marine OSRP (Appendix B) and will include, but not be limited to, the following documents: NORTHERN GATEWAY DOCUMENTS Oil Pollution Emergency Plan (OPEP) TDR and Oil Pollution Prevention Plan (OPPP) TDR for the Kitimat Terminal (combined document) (Appendix D) Oil Spill Response Planning for the Confined Channel Assessment Area TDR (Appendix E) Oil Spill Response Planning for Open Water TDR (Appendix F) Operations Manual for Oil Spill Response Equipment on Tanker Escort Vessels (and equipment at other than the Kitimat Terminal). Such a manual would be a supplement or addendum to the OPEP. This manual will be needed for training escort tug crews prior to commencing tanker escort operations. January 20, 2010 Final - Rev. 0 Page 1-11

16 Section 1: Introduction OIL SPILL RESPONSE ORGANIZATION (RO) DOCUMENTS RO response plan (for all BC coastal waters) RO geographic area response plan TANKER OPERATING COMPANIES DOCUMENTS Shipboard Oil Pollution Emergency Plan (SOPEP), which will be held by those companies operating tankers that will visit the Kitimat Terminal SUPPORT TUG OPERATING COMPANY DOCUMENTS Shipboard Oil Pollution Emergency Plan (SOPEP), which will be held by those companies operating escort tugs and berthing tugs for the Kitimat Terminal Page 1-12 Final - Rev. 0 January 20, 2010

17 Section 2: Study Study TERMPOL notes the importance of (i) regular exercising, (ii) plan outlines for ships in transit and alongside the terminal, and (iii) integration with CCG procedures. Each of these topics is addressed in this section. 2.1 Training and Exercises The effectiveness and success of any contingency plan depends to a large degree on regular exercising by personnel to better understand roles and responsibilities and the process of integration both by the Northern Gateway spill management team and with responsible agencies and stakeholders. Each oil spill response plan will list training and exercise requirements, including: personnel requiring training minimum training levels training and exercise frequencies requirements for management and operational staff integrated training and exercises with CCG, BC, ROs, and community representatives tabletop and deployment exercises 2.2 Vessel Contingency Plan To satisfy one of the requirements of study a preliminary outline of a ship-oriented contingency plan is presented (Appendix C). In general, the ship-oriented contingency plan will be structured in the following format (per International Maritime Organization [IMO] Guidelines for SOPEP). Section 1 Section 2 Section 3 Section 4 Section 5 Introduction Preamble Reporting Requirements Shipboard Response Procedures For Tanker Incidents away from a Terminal For Tankers at Berth at a Terminal Spill Response Guidance Vessel Damage, Stability and Stress Assessments Vessel Lightering Procedures Damaged Vessel Towing National and Local coordination January 20, 2010 Final - Rev. 0 Page 2-1

18 Section 2: Study Section 6 Section 7 Mandatory Appendices Non-Mandatory Appendices To further expand on the above preliminary outline, Figure 1-4 outlines the course of action that shipboard personnel should follow in responding to an oil pollution emergency, based on the Guidelines published by the IMO (2002). In order to ensure that best practices are followed and that the initial actions are consistent with first response objectives and strategies, Northern Gateway will require that vessels include the Marine OSRP in the vessel contingency plan (Figure 1-3). Page 2-2 Final - Rev. 0 January 20, 2010

19 Section 2: Study SHIP ACTIONS IN THE EVENT OF A DISCHARGE OF OIL (probable or actual) ASSESSMENT OF THE NATURE OF THE INCIDENT ACTIONS REQUESTED Alert crew members Identify and monitor spill source Personnel protection Spill assessment Vapour monitoring Evacuation REPORTING By master and/or designated crew member When to report All probable and actual spills How to report By quickest means to coastal radio station or designated ship movement reporting station or rescue co-ordination centre (at sea) By quickest available means to local authorities Whom to contact Nearest coastal State Harbour and terminal operators (in port) Shipowner s manager, P&I insurer / correspondent Head charterer, cargo owner Refer to contact lists What to report Initial report (res. A.851(20)) Follow-up reports Characteristics of oil spilled Cargo / Ballast / Bunker dispositions Weather and sea conditions Slick movement Assistance required Salvage Lightening capacity mechanical equipment External response team Chemical dispersant / degreasant ACTION TO CONTROL DISCHARGE Measures to minimize the escape of oil and threat to the marine environment Navigational measures Alter course / position and/or speed Change of list and/or trim Anchoring Setting aground Initiate towage Assess safe haven requirements Weather / Tide / Swell forecasting Slick monitoring Record of events and communications taken Seamanship measures Safety assessment and precaution Advice on priority countermeasures / preventive measures Damage stability and stress considerations Ballasting / Deballasting Internal cargo transfer operations Emergency ship-to-ship transfers of cargo and/or bunker Set up shipboard response for: Leak sealing Firefighting Handling of shipboard response equipment (if available) etc. STEPS TO INITIATE EXTERNAL RESPONSE Refer to coastal port State listings for local assistance Refer to ship interest contact list External clean-up resources required Continued monitoring of activities Figure 2-1 Course of Action for ships in the Event of a Spill January 20, 2010 Final - Rev. 0 Page 2-3

20 Section 2: Study Integration of Northern Gateway Plans with Canadian Coast Guard (CCG) Procedures and Other Plans The plans developed by Northern Gateway are an integral part of the overall spill contingency and response planning process. These form an integrated internal process and are linked directly with Coast Guard and Marine Safety Emergency Operations Procedures and with other regional plans, such as the BC Ministry of Environment Marine Oil Spill Response Plan, the JCP and the CANUSDIX (Canada-US Dixon Entrance) Annex, as well as with the RO s geographic area response plan (Figure 1-3). This integration is an essential component of spill management and is addressed in the GOSRP. The roles and responsibilities of the Corporate Crisis Management Team and the Project Spill Management Team will be clearly defined in the GOSRP in relation to both the federal and provincial response. Specific details regarding notification, reporting and other critical communications actions are a required part of the individual vessel SOPEPs and the Terminal OPPP and OPEP. Page 2-4 Final - Rev. 0 January 20, 2010

21 Section 3: Study Ship-Oriented Contingency Planning 3 Study Ship-Oriented Contingency Planning Transport Canada has identified several topics to include within the ship-oriented contingency plans. Table 3-1 is designed to respond to TERMPOL study , by addressing those topics that should be dealt with in the ship-oriented contingency plan for a vessel en route to, from, or at the terminal, which in turn is a part of the Marine OSRP (Figure 1-3). These topics form only a small component of a complete contingency plan and a comprehensive preliminary outline of the intended ship-oriented plan for a tanker vessel carrying oil or condensate related to the Project is provided in Appendix C. Separate SOPEP outlines will be prepared for the escort tugs as well as the tankers. Table 3-1 Topics to be included in the Ship-Oriented Contingency Plan TERMPOL Topic of Interest to Transport Canada Incidents involving the release of cargoes Fire and explosions Operations monitoring systems Terminal ship communications Inspection, testing and preventative maintenance procedures Cargo handling precautions applicable to the ship Comments Sections on such incidents will be included for the tanker in transit as well as for the tanker at berth Sections on such incidents will be included for the tanker in transit as well as for the tanker at berth Terminal Regulations will address terminal and tanker systems for monitoring oil transfer operations. If either monitoring system fails the discharge / loading would be stopped in a coordinated manner with clear communications by radio between terminal control room and the tanker s oil transfer supervisor Communications protocol and discussion of radio equipment will be included as an appendix to the Shipboard Oil Pollution Emergency Plans (SOPEP) Will be included in the Terminal Regulations. Any maintenance work will require pre-authorization from the Terminal Manager. No maintenance will be allowed that will prevent a tanker from leaving the berth. For emergency situations, these precautions will be included in the detailed emergency response checklists under each applicable casualty situation January 20, 2010 Final - Rev. 0 Page 3-1

22 Section 3: Study Ship-Oriented Contingency Planning TERMPOL Topic of Interest to Transport Canada Neutralizing electrical hazards Detection and alarm systems at the ship s berth Emergency responses to incidents involving the uncontrolled release of cargo(es) at or near the ship s berth or transhipment site during cargo transfer operations Countermeasures which ameliorate, contain or neutralize the harmful effects of cargo released into the marine environment Outline of personnel emergency equipment proposed for berth area and the evacuation procedure for personnel Comments For a tanker-in-transit incident, this topic will be included in the emergency response checklists as part of eliminating ignition sources after a release incident occurs For a tanker at berth, procedures for electrical isolation or dissipation of static electricity will be addressed in the Terminal Regulations as part of tanker berthing procedure and preparations prior to cargo loading or discharge Dealing with difference in electrical potential for a tanker berthed at the terminal is a prevention measure to eliminate ignition sources that may cause fire or explosion Inert gas systems will be checked and ships will be required to conform to oil tank inerting regulations to ensure that tank gases are non-explosive. The tanker s contingency plan will have an emergency response section to respond to a failure of the discharge / loading system Such an event would be part of the terminal s discharge / loading procedure Ship spills have been included in the SOPEP emergency situations when the tanker is at berth SOPEP response checklists will include access to terminal s spill response resources Cargo loading operations at the terminal will be closed loading Ships loading at the berth will be pre-boomed, and the terminal will have additional containment and recovery capabilities on site. The Response Organization (RO) certified by Transport Canada will also have a manned depot inside the Port of Kitimat at or near the Kitimat Terminal The basic assumption is that oil containment and recovery with booms and skimmers and shoreline treatment are the main countermeasures available to the tanker from the RO Dispersants and in-situ burning requires evaluation and dialogue with regulatory agencies before special permits will be issued Kitimat Terminal will be closed loading pre-boom oil loading operations and will have additional containment capability. Condensate will not be pre-boomed due to fire and explosion risk from inherently high volatility of the condensate The personnel emergency equipment on the berth will be described in the OPEP (Appendix D) as well as the Terminal Regulations document The evacuation procedures will also be in Appendix A of the SOPEP and in the Terminal Regulations Page 3-2 Final - Rev. 0 January 20, 2010

23 Section 3: Study Ship-Oriented Contingency Planning TERMPOL Topic of Interest to Transport Canada Emergency procedures which would require the vacating of the terminal berth and the disposition of the vessel Security at the ship s berth Comments Will be included in the tanker at berth emergency situations. These are included in the Terminal Regulations that govern loading and discharge operations The International Ship and Port Facility Security Code (ISPS Code) will apply In transit and at anchor the tanker operator will be responsible for its own security arrangements but will have escort tug support during transits The terminal site will be fenced and gated with 24-hour security personnel on site The berths will each have an operations room manned during oil transfer operations There will be radio contact between the ship, the berth operators and the Terminal Control Room operator. Both the berth and the Control Room will be able to notify onsite security of a security breach January 20, 2010 Final - Rev. 0 Page 3-3

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25 Section 4: Study Terminal-Oriented Contingency Planning 4 Study Terminal-Oriented Contingency Planning Transport Canada has identified several topics of interest within the terminal-oriented contingency plan. Table 4-1 is provided to respond to TERMPOL study by addressing the listed items of interest to Transport Canada within the terminal-oriented contingency plan. These topics form only a relatively small component of a complete contingency plan. The Terminal OSRP (Figure 1-3) and a comprehensive preliminary outline of the intended terminal-oriented plan for oil cargos are provided as Appendix D. This outline will be modified to take into account condensate cargos at the terminal in addition to the oil cargos. Table 4-1 Aspects of the Terminal-Oriented Contingency Plan of Interest to Transport Canada TERMPOL Topic of Interest to Transport Canada Fire in the engine room, compressor, deck stores or ship s accommodation spaces Releases resulting in structural damage and/or personnel injuries Equipment malfunctions Comments The Terminal Regulations may require the tanker to depart the berth and proceed to anchorage normally with support tug assistance. Depending on the situational risk factors and the level of risk, the tanker may be directed to an anchorage at the head of Kitimat Arm or to an alternate location. Personnel injuries would be the highest priority for response by trained tanker and terminal emergency response personnel once a safety assessment is conducted considering the risks to response personnel. Equipment malfunctions may or may not contribute to an emergency situation Immediate notification of Terminal Control Room and berth operator by tanker Master in clear language will be required under the Terminal Regulations. Conversely, the terminal berth operator or Control Room will notify the tanker Master immediately if any equipment malfunction using clear concise language Discharge / loading operations will be stopped until the problem is assessed A response that prevents an incident is best. The response would be situation specific and would require considering the risks of taking any particular action January 20, 2010 Final - Rev. 0 Page 4-1

26 Section 4: Study Terminal-Oriented Contingency Planning TERMPOL Topic of Interest to Transport Canada Rapidly deteriorating weather conditions and possible evacuation of the berth Grounding or collision at or near the berth Fires on dockside, pipelines in the immediate vicinity of the berth, and the tank farm and sabotage Comments During the detailed design stage, Northern Gateway will develop weather limitation criteria for cargo transfer, such as the following: loading or discharge operations cease if there is an electrical storm nearby loading or discharge operations cease if sustained wind exceed defined limits Loading arms will be disconnected in the event of sustained wind speeds above the loading arm design criteria limits. The Terminal Regulations will have weather criteria at which the tanker may be required to leave the berth. The decision whether the ship should remain at the berth or move to anchorage or to a holding area will be taken in consultation with the terminal and the ships master as a measure to prevent damage to the berths as well as to the tanker itself The tanker Master would assess the situation and respond according to his checklists for tanker grounding or tanker collision, keeping in mind the response priorities to protect people, the environment, the ship and other property. Tug assistance will be provided at the request of the Master or Pilot or as deemed necessary by the Terminal. The terminal response team of trained fire fighters would respond using a disciplined approach to deal with fire suppression and to prevent escalation of the incident. Evacuation routes would be planned in advance. Evacuation routes to a safe location both by water and by road would be planned and prepared in advance To reduce the risk to people, property and the environment, the tanker Master would be requested to cease operations, move the tanker from the berth and move to a safe anchorage or holding area Firefighting classified support tugs will be called to assist in removing the ship from the berth, or in fighting any berth or foreshore area fire Additional security resources would be activated in the event of sabotage and RCMP would be called to investigate Page 4-2 Final - Rev. 0 January 20, 2010

27 Section 5: Study Terminal-Ship Communications Planning 5 Study Terminal-Ship Communications Planning Several circumstances will require collaboration of ship-based and terminal personnel. A terminal-ship communications plan will be included as part of the Terminal / Trans-shipment Site Operations Manual (TOM) required by TERMPOL study A concise terminal-ship chain of command and communication standards is critical in the event of an emergency to direct response efforts. The communication protocol must be tested by both parties prior to any incident. The ship personal must also be familiar with emergency drills and procedures at the terminal. Table 5-1 is designed to satisfy TERMPOL study , by outlining how the above issues will be addressed within final contingency plans. Table 5-1 Aspects of the Terminal Ship Communication Protocol TERMPOL Topic of interest to Transport Canada Procedures relating to incidents which require active responses from the ship s personnel should be explicit, succinct, unequivocal, and communicated in the operational language(s) of the ship. The ship s personnel should be aware of the terminal-ship chain of command and of emergency drill requirements and procedures and be able to communicate with the terminal s personnel Comments The Kitimat Terminal Regulations will specify language requirements for tanker / terminal communications in accordance with Transport Canada regulations The Terminal Regulations will also specify radio communications checks and emergency drill requirements so that tanker personnel can practice procedures to communicate with terminal personnel. These will be done prior to any cargo loading and offloading. The most effective method to ensure clear communications is to follow a set of Standard Operating Procedures (SOPs) for each activity so that each step in that activity follows a pre-planned or scripted sequence of actions and commands The Terminal Regulations will require a review by a representative from the terminal be held with personnel from each tanker prior to any oil transfer taking place. The communications and the chain of command on both sides of any transfer will be reviewed The OPEP will include an Appendix entitled Clear Language Protocol and Communications between Tanker Crew and Terminal personnel. Some examples of explicit, succinct and unequivocal language to be considered for inclusion are: Ship is ready to begin transfer operation. Commence transfer when ready. reduce loading rate [to xy M3 per hour] Stand by to stop transfer. Stop transfer. Each sequenced command or communication should be repeated back to the sender to ensure that the recipient has understood that command or communication. The latter is SOP in the military and in many civilian sectors, even for crews which are English speaking. January 20, 2010 Final - Rev. 0 Page 5-1

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29 Section 6: Study Response and Compensation Planning 6 Study Response and Compensation Planning The response to a marine oil spill in British Columbia (BC) would follow established regulations and procedures and the costs would be reimbursed following established claims procedures. The Responsible Party (RP) for a spill from the Northern Gateway marine terminal or from the pipeline up to the ship / shore interface (at the ship s cargo manifold) into the marine environment would be Northern Gateway who would initiate, manage and implement the response operation.. The RP for a spill from a vessel in transit to or from the Northern Gateway marine terminal or from an escort or berthing tug is the vessel owner and the first response would be initiated and implemented by the vessel captain who would notify and mobilize a certified Response Organization (RO) as prescribed in the Project Marine OSRP. Similarly, the vessel owner RP would pay for the response and claims, and would then claim these costs from the insurer from applicable oil spill funds. The response to a marine oil spill would be managed by the RP, as described in the Marine OSRP, and monitored on behalf of the Crown by the Canadian Coast Guard (CCG). The BC Ministry of Environment (BCMoE) would monitor on behalf of the Province, participate in the response and coordinate local involvement. Environment Canada (EC) would provide scientific and technical support and coordinate environmental input to the response as chair of the Regional Environmental Emergencies Team (REET). The RP makes funds available, as necessary, for costs of the response and claims. For vessels, these are then claimed through their insurance carrier, a Protection and Indemnity (P&I) Club which is part of a larger non-profit mutual insurance system for marine transportation activities, including oil spills. Agencies, authorities or private companies that participate in the response may have to bear the initial cost of their involvement or make arrangements with the RP to cover those costs. In any event, the costs associated with the response and damage or other claims are charged to the RP. In Canada, these initial response costs can be supported, in some cases, by the Canadian Ship-source Oil Pollution Fund (SOPF). These would later be charged back to the RP and/or its insurer. Supplementary layers of compensation for oil spills from tankers are supported by international conventions, to which Canada is a signatory, if the claims against the P&I Club exceed their limit of liability (as described in Section 1.7 above). The GOSRP (Figures 1-2 and 1-3, Appendix A) is intended to present the overall strategy for the mitigation of any spilled oil. The Project plans to develop two Technical Data Reports (TDRs) to provide a detailed description of the environmental setting and logistical considerations for the area. The Marine and Terminals OSRPs will provide specific procedures and guidelines for the spill management team and would draw on the TDRs and other documents in the decision process. In the event of a product release, the detailed OSRPs will be followed to contain, remove, eliminate or treat spills oils. To demonstrate the type of information that is considered when planning for oil spill response two draft tables of contents for the TDRs, which are one part of the Marine OSRP (Figure 1-3), are included for the ship route(s) in the CCAA (Appendix E) and in open water (within Canadian jurisdiction) (Appendix F). January 20, 2010 Final - Rev. 0 Page 6-1

30 Section 6: Study Response and Compensation Planning The TDRs provide the environmental, social and economic background information necessary to support the response decision process. The Marine and Terminal OSRPs describe the response options available to the spill management team to mitigate the potential effects of spilled oil. General oil spill response and remediation techniques may include: On water mechanical containment and recovery containment boom mobile on-water containment and recovery (sweep systems) On water recovery or elimination In-situ burning dispersant application skimmers Shoreline protection Shoreline treatment or cleanup. Typically, Environment Canada uses 15 different shore types, one example of which (for Sand Beaches) is shown in Table 3-4. Page 6-2 Final - Rev. 0 January 20, 2010

31 Section 6: Study Response and Compensation Planning Table 6-1 Summary of Preferred Treatment Tactics for Sand Beaches for Different Oil Types and for Surface and Subsurface Oiling Conditions Source: Environment Canada-Field Guide to Oil Spill Response on Marine Shorelines January 20, 2010 Final - Rev. 0 Page 6-3

32 Section 6: Study Response and Compensation Planning In addition to the OSRPs, planned counter-measures and logistical considerations for oil spill containment, clean-up, restoration and public safety are provided in TERMPOL study Other key regional topics in the TDRs which will be developed as the project progresses will include: environmental descriptions shoreline sensitivity maps logistics support examples of hypothetical spills designated potential places of refuge (PPORs) Geographic Response Plans (for site specific protection strategies) trans-boundary spill responses In summary: the GOSRP provides the high-level framework Plan which integrates internal company plans and other documents, such as the Technical Data Reports, and external plans and documents (Figures 1-1, 1-2 and 1-3). Together these documents combine to provide information on, among other topics: resources at risk in the project area, their vulnerability and the potential effects of spilled oil, organization and management of a spill response operation, response resources available on site to the RP and the RO (manpower, equipment, logistics support etc.,), regional and/or mutual aid cascading response resources, prescribed initial notification and response actions to be taken by the RP, roles and responsibilities of the participants in a response organization and operation, specific plans such as wildlife rehabilitation and waste management plans, and financing of the response and claims procedures both for response operation and third-party claims. Page 6-4 Final - Rev. 0 January 20, 2010

33 Section 7: Conclusion 7 Conclusion The underlying concept of the contingency plans described in this Section (3.18) is a hierarchy that provides for vertical responsibility and continuity between the most general (corporate) and the most specific (e.g., SOPEP) plan levels (Figures 1-1, 1-2 and 1-3). Within this systematic structure there is a horizontal integration and coordination of the various related pipeline, terminal and marine plans, manuals, and supporting documents that are designed to enable the implementation of an effective and successful spill response operation (Figures 1-1 and 1-3). This set of contingency plans and related documents is intended to address regulatory requirements and to describe the extended responsibility and coordinated operational response capabilities that Northern Gateway proposes to implement through the Marine Area OSRP for a potential marine oil spill from a vessel in transit to or from the Kitimat Terminal. January 20, 2010 Final - Rev. 0 Page 7-1

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35 Section 7: Conclusion Appendix A General Oil Spill Response Plan (GOSRP) Typical Table of Contents A.1 Introduction A.1.1 A.1.2 A.1.3 A.1.4 A A A A A.1.5 Plan purpose and Scope Project description Regional Response Strategy Overview of Oil Spill Management Approach Command Management Team (CMT)-Spill Management Team (SMT) Overall response strategy marine responsibility Tiered Response Approach Preparedness and Response Plan Framework Corporate Environmental Policy A.2 Immediate Response Actions and Notification Procedures A A A Emergency Checklists Immediate Response Actions Steps Notifications and Regulatory Reporting A.3 Response Organizational Structure and Role Descriptions A.3.1 A.3.2 A.3.3 Enbridge Corporate Crisis Management Team Northern Gateway Spill Management Team Tiered Response Levels January 20, 2010 Final - Rev. 0 Page A-1

36 Section 7: Conclusion A.3.4 A.3.5 A.3.6 A.3.7 Incident Command system (ICS) Roles and Responsibilities Incident Actions Forms Technical Response Support A.4 Spill Sources, Risks and Effects A.4.1 A.4.2 A.4.3 A.4.4 A.4.5 A.4.6 A.4.7 A.4.8 A A Potential Sources Risk Analysis Fate and Effects of Spills Pathway Analyses and Scenarios Spill Surveillance and Tracking Sensitive Areas Resource Protection Strategies Response Concepts NEBA (Net Environmental Benefit Analysis) ALARP (As Low as Reasonably Practicable) A.5 Waste Minimization and Waste Management Guidelines A.5.1 A.5.2 A.5.3 A.5.4 A.5.5 Waste Minimization Strategy Waste Characterization Waste Segregation and Labelling Collection, Packaging and Storage Transfer Page A-2 Final - Rev. 0 January 20, 2010

37 Section 7: Conclusion A.5.6 A.5.7 A.5.8 Disposal Options for Liquid Waste Disposal Options for Solid Waste Disposal Options for Special Waste A.6 Land Response A.6.1 A.6.2 A.6.3 A.6.4 A.6.5 Assessment and Monitoring Containment Recovery and Removal Treatment Groundwater Remediation A.7 River Response A.7.1 A.7.2 A.7.3 A.7.4 A.7.5 Assessment and Monitoring Containment Control Points Mechanical Recovery In situ Burning in Rivers River Bank Treatment A.8 Marine (CCAA and Open Water) Response A.8.1 A.8.2 A.8.3 A.8.4 A.8.5 Response Decision Process Containment Mechanical Recovery Chemical Dispersion In Situ Burning January 20, 2010 Final - Rev. 0 Page A-3

38 Section 7: Conclusion A.9 Shoreline Protection A.9.1 A.9.2 Sensitivities and protection decision process Protection strategies (Geographic Response Plans) A.10 Shoreline Cleanup A.10.1 A.10.2 A.10.3 A.10.4 A.10.5 A.10.6 Cleanup Strategies and Decision Process SCAT Plan (surveys, segmentation, teams, participation) Shoreline Treatment End points Cleanup Tactics Treatment Recommendations Inspections and Segment Sign-off Procedure A.11 Wildlife Response Plan A.11.1 A.11.2 A.11.3 A.11.4 A.11.5 Coordination with Canadian Wildlife Service Safety Hazing Wildlife Treatment Response Resources A.12 OSR Manpower, Resources, Communications Guidelines and Logistics Support A.12.1 A.12.2 A.12.3 Command Post External Communications Communications Network Page A-4 Final - Rev. 0 January 20, 2010

39 Section 7: Conclusion A.12.4 A.12.5 A.12.6 A.12.7 A A A Field Operations Support staging areas Procurement Logistics Support equipment, supplies Transportation Ground Marine Aircraft A.13 Safety and Health Guidelines A.13.1 A.13.2 A.13.3 A.13.4 A.13.5 A.13.6 A.13.7 A.13.8 Risks Implementation Training Industrial Hygiene Emergency medical response Personal Protective Equipment Decontamination Site-Specific and Activity-Specific Safety Plans A.14 Education, Training, Drills and Readiness Programs A.14.1 A.14.2 A.14.3 A.14.4 Objectives Minimum Recommended Training Plan Familiarization Health and Safety Training Emergency Response January 20, 2010 Final - Rev. 0 Page A-5

40 Section 7: Conclusion A.14.5 A.14.6 A.14.7 Health and Safety Training Post Emergency Response Training, Exercises and Drills Schedules Records A.15 Document Control A.16 Finance Documentation Procedures A.16.1 A.16.2 Contracts Claims Center(s) A.17 Spill Response Resources A.17.1 A.17.2 A.17.3 A.17.4 Tier 1 Equipment Tier 2 Equipment Tier 3 / 4 Equipment Support Services (food, accommodation) A.18 Tiers 2 and 3 Incident and Responsibilities Checklists A.19 Response Forms A.20 Response and Mutual Aid Contracts and Agreements A.21 Material Safety Data Sheets (MSDS) A.22 Dispersant Use Approval Process A.23 In Situ Burn At Sea Use Approval Process A.24 Places of Refuge A.25 Shoreline In Situ Burn Approval Process Page A-6 Final - Rev. 0 January 20, 2010

41 Section 7: Conclusion A.26 Environmental and Shoreline Sensitivity A.27 Regulatory Framework January 20, 2010 Final - Rev. 0 Page A-7

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43 Section 7: Conclusion Appendix B Generic Example of Marine and Terminal Oil Spill Contingency or Response Plans Table of Contents B.1 Introduction and Scope B.1.1 B.1.2 B.1.3 B.1.4 B.1.5 Purpose and Objective of Plan Regulatory Requirements, Relevant Agreements, and Guidelines Geographical Limits of Plan Interface with other Plans Plan Review and Updates B.2 Oil Spill Risks B.2.1 B.2.2 B.2.3 B.2.4 B.2.5 B.2.6 B.2.7 Description of Vessel / Facility / Operations and Risks Types and Properties of Oil Probable Fate and Trajectories of Spilled Oil Development of Oil Spill Scenarios Sensitivity Mapping Resources at Risk and Priorities for Protection Special Local Considerations B.3 Response Organization B.3.1 B.3.2 B.3.3 Organization Structure Chart(s) Tiered Response Management Roles and Responsibilities January 20, 2010 Final - Rev. 0 Page B-1

44 Section 7: Conclusion B.3.4 B.3.5 Transitions between Tiers Coordination with External Organizations B.4 Safety B.4.1 B.4.2 B.4.3 B.4.4 Initial Assessment Access Control and Safety Zones Worker Health and Safety Site Safety Plan B.5 Notification B.5.1 B.5.2 B.5.3 B.5.4 B.5.5 B.5.6 Internal Notifications Information to Relay Community notifications Federal and Provincial Agency Notifications Public Information Required Reports B.6 Initial Response Actions B.6.1 B.6.2 B.6.3 B.6.4 Initial Assessment Checklists and Response Diagrams Emergency Procedures for Likely Sources Tier 1 Tactical Response B.7 Response Operations B.7.1 Response Priorities Page B-2 Final - Rev. 0 January 20, 2010

45 Section 7: Conclusion B.7.2 B.7.3 B.7.4 B.7.5 B.7.6 Tracking, Monitoring and Sampling Containment Strategies Protection Strategies Cleanup Strategies Tiered Response Capabilities B.8 Waste Management B.8.1 B.8.2 B.8.3 B.8.4 B.8.5 B.8.6 Waste Minimization and Segregation Temporary Transfer / Storage Temporary Storage Containers Decanting Waste Transportation Disposal Options B.9 Wildlife Care B.9.1 B.9.2 B.9.3 B.9.4 B.9.5 B.9.6 Strategies Permits and Agency Coordination Hazing Collection of Oiled Wildlife Disposition of Dead Animals Volunteers B.10 Logistics B.10.1 Facilities (Command, Staging) January 20, 2010 Final - Rev. 0 Page B-3

46 Section 7: Conclusion B.10.2 B.10.3 B.10.4 B.10.5 B.10.6 Site Security Communications for Emergencies (plan and internal and external resources) Transportation (air, land, water) Personnel Support (e.g., meals, housing, equipment) Trans-boundary Movement of Equipment and Personnel (permits, customs) B.11 Finance / Procurement / Administration B.11.1 B.11.2 B.11.3 Contracting Claims Procedures Cost Documentation B.12 Training and Drills B.12.1 B.12.2 B.12.3 Response Training Programs Drills / Exercises (tiered) Record-keeping B.13 Contacts Directories B.13.1 B.13.2 B.13.3 B.13.4 B.13.5 B.13.6 Internal External (Federal, Provincial, Local) Contractors Mutual Aid Experts Logistical Support (medical, communications, transport, supplies) Page B-4 Final - Rev. 0 January 20, 2010

47 Section 7: Conclusion B.13.7 Public Information (radio, TV, press) B.14 Equipment Lists B.14.1 B.14.2 B.14.3 Equipment (spill response, communications, safety) Specifications (oil types, limits, capacities) Quantities and Location B.15 Maps B.15.1 B.15.2 B.15.3 B.15.4 Facilities and Infrastructure Sensitive Areas Oil Movement Directions (trajectories) Tactical Control Points B.16 Forms B.16.1 B.16.2 B.16.3 Initial Response Assessment Safety Spill Documentation January 20, 2010 Final - Rev. 0 Page B-5

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49 Section 7: Conclusion Appendix C Typical Table of Contents of a Ship- Oriented Contingency Plan (SOPEP) C.1 Introduction C.2 Preamble C.2.1 C.2.2 C C C.2.3 C.2.4 C.2.5 C.2.6 C.2.7 C.2.8 C.2.9 C.2.10 C.2.11 Purpose and Use of this plan Scope and Limitations Vessel Response Plan SOPEP How SOPEP relates to other Plans How the plans will be integrated Coastal states rights to approve oil pollution response in their waters General Description of Vessel Operations Area of Operations Vessel Particulars Locations where Plan will be kept onboard ship Plan review and revision responsibilities Response Priorities C.3 Reporting Requirements and Procedures C.3.1 C C General Summary Action Flow Chart Summary Reporting Flow Chart January 20, 2010 Final - Rev. 0 Page C-1

50 Section 7: Conclusion C.3.2 C C C C C C C.3.3 C C C C.3.4 C C C C C.3.5 C When to Report Oil discharge from damage to ship or ship s equipment Oil discharge during ship operations Emergency discharge A probable discharge Damage or failure affecting safety of the vessel, crew or other shipping Failure of machinery or equipment which impact the safety of navigation Reports Initial Report Follow-up Reports Post-Incident Report Information Required Initial Incident Report Initial Spill Report Follow-up Reports Post-incident Report Whom to Contact Internal Notifications Shipboard reporting to Vessel Master Notification of Vessel Operator s Emergency Response Team C External Notifications Page C-2 Final - Rev. 0 January 20, 2010

51 Section 7: Conclusion Coastal State Contacts for Ship Reporting Notification of Terminal Manager (if applicable) Other External Notifications C.3.6 C.3.7 C Who will contact each interest and in what priority Communications Methods Methods of Contact VHF Marine Radio Satellite Telephone Cellular telephone or text messaging Internet Facsimile (Fax) Transmission Telex C Communications Record Keeping Communications Log Form C.4 Shipboard Response Procedures C.4.1 C C For Tanker Incidents away from a Terminal Section introduction Section references for Response Checklists Operational Discharge Incidents Vessel Casualty Incidents with Discharge or Discharge Potential C C Other Emergency Incidents Shipboard Response Team Duties (Response to a Discharge) January 20, 2010 Final - Rev. 0 Page C-3

52 Section 7: Conclusion On-Scene Commander Priorities Emergency Response Checklist C Response to Operational Spills (Checklists) Pipe or Hose Leaks Bunker or cargo tank overflow Casualty Incidents with Discharge of Discharge Potential C.4.2 C.4.3 C C C C C C C C C C C.4.4 C C Incidents when Tanker is at Berth at Terminal Spill Response Guidance Spill situation assessment and monitoring Oil slick surveillance and tracking Safety zones Health and Safety assessment and Hazard Identification Protection of response personnel Spill containment and control Oil recovery Decontamination Segregation and temporary storage of recovered oil and oily materials Disposal Vessel Damage, Stability and Stress Assessment Damage Stability Page C-4 Final - Rev. 0 January 20, 2010

53 Section 7: Conclusion C C.4.5 C.4.6 Hull Stress Vessel Lightening Procedures Damaged Vessel Towing C.5 National and Local Coordination C.5.1 Incident Management Team C.6 Attachments Mandatory Attachments Tanker operators internal emergency contacts Contacts for incident reporting to coastal state administrations responsible for receiving and processing incident reports List of parties with financial interest in the ship Non-Mandatory Attachments Vessel drawings and tables Vessel damage stability and stress assessments Vessel lightering procedures Damaged vessel towing Reporting forms and checklists Communications between tanker crew and Kitimat Terminal personnel Emergency equipment and evacuation procedures when berthed at Terminal Oil spill response resources Organizational structure for an emergency response Charts and publications for West Coast of Canada Tanker routes and refuges (if available) on West Coast of Canada Sensitivity Maps Geographic response plans Public affairs guidance Response record keeping Plan training and exercises January 20, 2010 Final - Rev. 0 Page C-5

54 Section 7: Conclusion Generic health and safety plan Kitimat Terminal regulations Meteorological, sea state and current summary information Page C-6 Final - Rev. 0 January 20, 2010

55 Appendix D: Terminal Oil Pollution and Emergency Plan (OPEP) / Oil Pollution Prevention Plan (OPPP) - Draft Outline of Table of Contents Appendix D Terminal Oil Pollution and Emergency Plan (OPEP) / Oil Pollution Prevention Plan (OPPP) - Draft Outline of Table of Contents D.1 Introduction D.1.1 D.1.2 D.1.3 D.1.4 D.1.5 Purpose Scope Who Should Use This Manual Relationship to Other Manuals Manual Custodian and Manual Updates D.2 Kitimat Terminal D.3 Notification D.4 Organization for Response D.4.1 Policies and Priorities D.5 Emergency Checklists for Response Team Members D.5.1 D.5.2 D.5.3 D.5.4 D.5.5 D.5.6 Kitimat Terminal Manager Emergency Response Manager Terminal Operations Response Manager Oil Spill Response Manager Source of Equipment Resources for Spill Response Sources of Response Personnel January 20, 2010 Final - Rev. 0 Page D-1

56 Appendix A: D.6 Site Information D.7 Response Strategies D.7.1 D.7.2 D.7.3 D.7.4 D.7.5 D.7.6 D.7.7 D.7.8 D.7.9 D.7.10 D.7.11 D.7.12 D.7.13 Oil Containment with Floating Boom Deployment of Oil Exclusion Boom On-Water Containment and Recovery with Tanker Support Tugs On-Water Containment and Recovery over Deeper Waters Oil Properties Oil Recovery Oil Spill Response Vessels Surveillance and Tracking Shoreline Treatment Oil Spill Drift Forecasting Wildlife Protection Disposal of Recovered Oil and Oily By-products Activation of the Response Organization D.8 Health and Safety Plan D.8.1 D.8.2 Initial Safety Assessment Health and Safety Plan for the Spill Response Activities D.9 References D.9.1 Literature Cited D.10 Attachments Page D-2 Final - Rev. 0 January 20, 2010

57 Appendix D: Terminal Oil Pollution and Emergency Plan (OPEP) / Oil Pollution Prevention Plan (OPPP) - Draft Outline of Table of Contents List of contacts Spill report form Response equipment Trucking routes to Kitimat for response mobilization Response services Communications Oil spill response management and the Incident Command System Training program Exercise program Scenario analysis Material safety data sheets (MSDS) Management and disposal of recovered materials Draft Oil Pollution Prevention Plan (OPPP) for Kitimat Terminal Distribution list for the OPEP and OPPP Oil handling facility declaration January 20, 2010 Final - Rev. 0 Page D-3

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59 Appendix E: Technical Data Report: Oil Spill Response Planning for the Confined Channel Assessment Area (CCAA) - Draft Outline of Table of Contents Appendix E Technical Data Report: Oil Spill Response Planning for the Confined Channel Assessment Area (CCAA) - Draft Outline of Table of Contents E.1 Introduction E.2 Studies and mapping to support spill response planning E.2.1 E.2.2 E.2.3 E.2.4 E.2.5 E.2.6 E.2.7 E.2.8 Map of the CCAA showing the tanker routes Map of the CCAA showing the three hypothetical release locations Description of the CCAA physical environment Description of percentage of time that spill countermeasures can be conducted, based on weather and sea state limitation criteria Study of oil spill response properties of oils handled by Project Shoreline sensitivity mapping Other sensitivities in the CCAA- description and mapping Drift forecasting of hypothetical tanker spills E.3 Oil spill response E.4 Possible oil spill response countermeasures E.4.1 E.4.2 E.4.3 E.4.4 E.4.5 On-water containment and recovery over deep waters Mobile on-water containment over shallow waters and near shorelines Recovery of floating oil that has drifted against steep shorelines Dispersant application Application of fine sediment to induce oil mineral aggregation January 20, 2010 Final - Rev. 0 Page E-1

60 Appendix A: E.4.6 E.4.7 E.4.8 E.4.9 E E E E E E E.4.10 E.4.11 E.4.12 E E E E E.4.13 In-situ burning Shoreline exclusion booming Pre-contact debris removal Shoreline treatment Summary of shoreline types Shoreline treatment methods available Waste generation from different shoreline treatment methods Logistics implications of waste volumes generated In-situ treatments that minimize waste generation Shoreline washing agents for removal of heavy oils Capability to contain, recover and transfer over-washed oil Spill related surveillance capabilities Spill response management Emergency operations centre (EOC) Incident command system Outfitting an EOC Communications Wildlife response E.5 Logistics support (also addresses Termpol study logistical considerations) E.5.1 E.5.2 Primary and secondary temporary oil storage Waste handling, transport and disposal Page E-2 Final - Rev. 0 January 20, 2010

61 Appendix E: Technical Data Report: Oil Spill Response Planning for the Confined Channel Assessment Area (CCAA) - Draft Outline of Table of Contents E.5.3 E.5.4 E.5.5 E.5.6 E.5.7 Emergency Operations Centre and warehouse facilities Geographic Information System Marine logistics support infrastructure Decontamination capability Locating response equipment in the tanker route area E.6 Example spill situations E.6.1 E E E E E.6.2 E.6.3 E E E.6.4 E E E.6.5 E E Methodology Spill drift forecast Equipment Availability Assumptions Proposed Countermeasures Oil drift re-forecasted with countermeasures introduced Introduction of Sites Emelia Island Outflow season Drift pathways before countermeasures Proposed countermeasures Wright Sound Inflow season Drift pathways before countermeasures Proposed countermeasures Principe Channel Inflow season Drift pathways before countermeasures Proposed countermeasures January 20, 2010 Final - Rev. 0 Page E-3

62 Appendix A: E.7 Potential Places of Refuge in the CCAA for a vessel needing assistance E.8 Geographic Area Response Plans E.9 References Page E-4 Final - Rev. 0 January 20, 2010

63 Appendix F: Technical Data Report: Oil Spill Response Planning for the Open Water outside the CCAA, within Canadian Jurisdiction - Draft Outline of Table of Contents Appendix F Technical Data Report: Oil Spill Response Planning for the Open Water outside the CCAA, within Canadian Jurisdiction - Draft Outline of Table of Contents F.1 Introduction F.1.1 General description of open water within Canadian Jurisdiction and the two areas sites to be reviewed F.2 Studies and mapping conducted to support spill response planning F.2.1 F.2.2 F.2.3 F.2.4 F.2.5 F.2.6 Description of the open water physical environment Description of percentage of time that spill countermeasures can be conducted based on wind, wave, darkness and visibility limitation criteria Study of oil spill response properties of oils handled by project-related tankers Shoreline sensitivity mapping Other Sensitivities in the open water- description and mapping Drift forecasting of hypothetical spills F.3 Oil spill response for a tanker release F.3.1 F.3.2 F.3.3 Role of Responsible Party (tanker operator) Role of Response Organization Role of Northern Gateway F.4 Possible oil spill response countermeasures January 20, 2010 Final - Rev. 0 Page F-1

64 Appendix A: F.4.1 F.4.2 F.4.3 F.4.4 F.4.5 F.4.6 F.4.7 F.4.8 F.4.9 F F F F F F F.4.10 F.4.11 F.4.12 F F F On-water containment and recovery over deep waters Mobile on-water containment over shallow waters and near shorelines Recovery of floating oil that has drifted against steep shorelines Dispersant application Application of fine sediment to induce oil mineral aggregation In-situ burning Shoreline exclusion booming Pre-contact debris removal Shoreline treatment Summary of shoreline types Shoreline treatment methods available Waste generation from different shoreline treatment methods Logistics implications of waste volumes generated In-situ treatments that minimize waste generation Shoreline washing agents for removal of heavy oils Capability to contain, recover and transfer over-washed oil Spill related surveillance capabilities Spill response management Emergency operations centre Incident command system Outfitting an EOC Page F-2 Final - Rev. 0 January 20, 2010

65 Appendix F: Technical Data Report: Oil Spill Response Planning for the Open Water outside the CCAA, within Canadian Jurisdiction - Draft Outline of Table of Contents F F.4.13 Communications Wildlife response F.5 Logistics support (also addresses Termpol Study logistical considerations) F.5.1 F.5.2 F.5.3 F.5.4 F.5.5 F.5.6 F.5.7 Primary and secondary temporary oil storage Waste handling, transport and disposal Emergency Operations Centre and warehouse facilities Geographic Information System Marine logistics support infrastructure Decontamination capability Locating response equipment in the marine transportation routes F.6 Hypothetical tanker release scenarios F.6.1 F.6.2 F.6.3 F.6.4 Methods Introduction of sites Ness Rock Outflow Season Butterworth Rocks Inflow Season F.7 Planning Analysis of Open Water, Ness Rock (Caamaño Sound) F.7.1 F.7.2 F.7.3 Summary of the environmental operating conditions for Caamaño Sound Discussion of drift trends Sensitivity maps for Caamaño Sound January 20, 2010 Final - Rev. 0 Page F-3

66 Appendix A: F.7.4 F F F.7.5 F.7.6 F.7.7 Composition of the shoreline on sensitivity maps Percentage of each shoreline type Percentage of shoreline in each exposure class (oil residency index) Discussion of the shorelines and sensitivities most likely to be impacted Countermeasures applicable for Caamaño Sound Countermeasures limitations due to environmental operating conditions F.8 Planning Analysis for Open Water, Butterworth Rocks (Dixon Entrance East) F.8.1 F.8.2 F.8.3 F.8.4 F F F.8.5 F.8.6 F.8.7 Summary of the environmental operating conditions for Dixon Entrance East Discussion of drift trends Sensitivity maps of Dixon Entrance East Summary of the composition of the shoreline on sensitivity maps Percentage of each shoreline type Percentage of shoreline in each exposure class (oil residency index) High level discussion of the shorelines and sensitivities most likely to be impacted Countermeasures applicable for Dixon Entrance East Countermeasures limitations due to environmental operating conditions F.9 Logistics Support Requirements to Support a Response Operation F.10 Geographic Response Plans for the Open Water (Canadian Jurisdiction) Page F-4 Final - Rev. 0 January 20, 2010

67 Appendix F: Technical Data Report: Oil Spill Response Planning for the Open Water outside the CCAA, within Canadian Jurisdiction - Draft Outline of Table of Contents F.11 Places of Refuge Contingency Plan (Transport Canada) F.11.1 F.11.2 F.11.3 Brief Description of the PORCP process Data gathering to support the PORCP Potential Places of Refuge for a tanker needing assistance F.12 Response Process for a Trans-boundary spill (Canada / Alaska) F.13 References January 20, 2010 Final - Rev. 0 Page F-5

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69 Appendix F: Technical Data Report: Oil Spill Response Planning for the Open Water outside the CCAA, within Canadian Jurisdiction - Draft Outline of Table of Contents Appendix G Abbreviations ADEC...Alaska Department of Environmental Conservation BC... British Columbia CANUSDIX... Canadian US Dixon Entrance CCAA... confined channel assessment area CCG... Canadian Coast Guard CLC... Civil Liability Convention COTP... Captain of the Port (USCG) CP... contingency plan CSA... Canada Shipping Act, 2001 CMT... Command Management Team EC... Environment Canada the Project... Enbridge Northern Gateway Project FMO... Federal Monitoring Officer (CCG) FOSC... Federal on Scene Coordinator (USCG) GOSRP... General Oil Spill Response Plan GRP... geographic response plan ICS... Incident Command System IMO... International Maritime Organization (United Nations) IOPC... International Oil Pollution Compensation (Fund) ITOPF... International Tanker Owners Pollution Federation MoE... Ministry of Environment (BC) MLA... Marine Liability Act NCC... North Central Coast NEB... National Energy Board OSC... on scene commander OPEP... oil pollution emergency plan OPPP... oil pollution prevention plan January 20, 2010 Final - Rev. 0 Page F-1

70 Appendix G: Abbreviations OSR... oil spill response OSRP... oil spill response plan P and I... Protection and Indemnity (Club) PAR... Primary Area of Response REET... Regional Environmental Emergencies Team RMS... Response Management System (CCG) RO... response organization RP... responsible party SERVS... Ship Escort Response Vessel System (Alyeska - Alaska) SMT... Spill Management Team SOPEP... ship oil pollution emergency plan SOPF... Ship-source Oil Pollution Fund TC... Transport Canada TDR... technical data report TOM... Terminal / Trans-shipment Site Operations Manual UC... unified command USCG... United States Coast Guard Page F-2 Final - Rev. 0 January 20, 2010