4 Unite@ States General Accounting Office Report to the Chairman, Subcommittee -GAO on Transportation and Related Agencies, Committee on Appropriations, U.S. Senate January 1990 COAST GUARD Preparation and ; Responsefor Oil Spills : in Philadelphia and ’ New York Ports ’ United States GAO General Accounting Office Washington, D.C. 20548 Resources, Community, and Economic Development Division B-236137.5 January 26, 1990 The Honorable Frank R. Lautenberg Chairman, Subcommittee on Transportation and Related Agencies Committee on Appropriations United States Senate Dear Mr. Chairman: On April 13, 1989, you requested that we (1) evaluate how well industry and government are prepared to respond to oil spills and (2) examine measures that can be taken to help prevent spills in the future. You requested that we address these issues for the March 24, 1989, Exxon Valdez spill in Alaska’s Prince William Sound and for the Philadelphia and New York ports. We discussed our observations on the Exxon Valdez spill in an October 1989 report, which stated that industry and government were not well prepared to respond to the spill and that pri- ority needs to be given to measures to help prevent similar situations from occurring in the future.* This report responds to your request con- cerning the Philadelphia and New York ports. We found that, similar to the situation in Prince William Sound, in the Results in Brief Philadelphia and New York ports, industry and the Coast Guard are not prepared to respond2 to major oil spills (over 100,000 gallons). Factors contributing to this unpreparedness include the lack of (1) specificity in the Philadelphia and New York Coast Guard’s and industry’s contin- gency plans on how spills of various sizes would be handled with avail- able resources and (2) Coast Guard authority to require ship owners and operators to have contingency plans or to require changes in existing plans. We also found that the response to a recent spill in the Philadel- phia area indicates a need to improve equipment capabilities for con- taining oil and removing it from the water. As we stated in our Exxon Valdez report, even with a substantially greater commitment to improving response capabilities, recent expe- riences indicate that the priority for dealing with major oil spills should be to prevent them from occurring in the first place. The experiences in ‘Coast Guard: Adequacy of Preparation and Response to Won Valdez Oil Spill (GAO/RCED-90-44. Oct. 30, 1989). ‘As used in this report, response to a spill includes containing oil and removing it from the water. Page 1 GAO/RCEIMO-M Oil Spilla in Philadelphia and New York Ports B238137.6 Prince William Sound and Philadelphia, and across the nation, however, show that much needs to be done to improve prevention measures such as monitoring and guiding ship movements and using harbor pilots or vessel escorts. Recent actions by the Coast Guard to identify what size spills can be handled effectively with existing resources in each port area, and recent bills passed by the Senate and House to require the development of plans by industry, the approval of such plans by the Coast Guard, and the establishment of a fund to support prevention, response, and research and development activities indicate a strong desire to reduce the risks associated with such spills. But leadership is needed to pull together the various options for making improvements nationally. The Clean Water Act provides for a national contingency plan to achieve Background efficient, effective, and coordinated action for minimizing damage from oil spills. The plan, set forth in regulations, defines an organizational structure that ranges from a national response team to coordinators on the scene. Collectively, this structure tries to ensure the coordination of oil spill contingency plans and response actions from the national to the local level. The Commandant of the Coast Guard, who is responsible for assuring that responses to spills are adequate, has designated the Coast Guard Captains of the Port in Philadelphia and New York as the “on- scene coordinators” for their respective areas. In general, the owner or operator of a vessel that discharges oil in viola- tion of the Clean Water Act is responsible and liable for removal costs, with the on-scene coordinator monitoring the removal operation to ensure it is being done properly. When a polluter is unknown or the Coast Guard on-scene coordinator determines the removal effort is insufficient, he shall assume total or partial control of response activi- ties by “federalizing” the response. This activates the 31 l(k) fund pro- vided under the act to cover expenses and allows the coordinator to take whatever actions are necessary to ensure proper cleanup. The area of responsibility of the Philadelphia Captain of the Port includes the Delaware Bay and River System and its seaward approaches. Over 70 percent of all oil entering the eastern United States does so on ships transiting the Delaware Bay. The area of responsibility of the New York Captain of the Port includes the Greater New York Har- bor and connecting waterways serving New York and northeastern New Jersey. According to the Coast Guard, on an average day, 76 vessels, Page 2 GAO/lEEB30-33 Oil Spills in Philadelphia and New York Ports B-236137.6 ranging in capacity from 840,000 to 25,200,OOOgallons, transport oil in the Kew York port. Industry and Coast Guard response capabilities and preparations Response Plans and proved inadequate during the June 24, 1989,300,000-gallon Presidente Capabilities Need Rivera spill on the Delaware River. It is questionable whether the Improvement preparedness for spills of similar size in the New York port or for other spills of similar size in the Philadelphia port area would be any better. This unpreparedness exists primarily because the industry’s and New York Coast Guard’s plans neither specifically identify the sizes of spills that, based on experience, could reasonably be expected to occur nor say what personnel and equipment are required to respond to spills of vari- ous sizes. Although the Coast Guard’s recently revised plan for the Phil- adelphia port recognizes that spills of 1.5 to 2 million gallons are probably the worst that could occur, it states that local resource capabil- ities could handle effectively spills of no more than 50,000 gallons. Fur- ther, while the owners or operators of tankers in transit are responsible for responding to spills, the Coast Guard believes it does not have the authority to ensure beforehand that their preparations are adequate to deal with a spill. Bills recently passed by the Senate and House would require owners or operators of ships in transit to have contingency plans approved by the Coast Guard. Plans Lack Specifics on According to our consultant on oil spill response,3 because spills of over Response Capabilities 100,000 gallons occur at least annually and spills of over l,OOO,OOOgal- lons can be expected to occur every 5 to 10 years, it is important to have detailed, up-to-date contingency plans. Our consultant also stressed the importance of recognizing in contingency plans variables that could affect response capabilities. A major flaw our consultant found with both the Coast Guard’s and industry’s plans for Prince William Sound was the lack of specifics on resources and actions that would be employed for spills of different sizes that could occur in the area. For example, our consultant concluded that if the contingency plans for the Exxon Valdez spill had addressed questions such as how much equip- ment would be necessary and when it could arrive, the decision makers at the incident would have been in a better position to make informed decisions concerning containment and cleanup. 3Engineering Computer Optecnomics, Inc., (ECO) of Annapolis, Maryland, a firm with expertise in oil spill contingency planning, response, and prevention, assisted in our evaluation of the Exxon Valdez oil spill. As part of its efforts, the company evaluated the spill using the key elements of an adequate oil spill contingency plan. Page 3 GAO/RCED-!hM3 Oil Spills in Philadelphia and New York Ports B236137.6 Tankers transiting Philadelphia and New York port waters are not required to have oil spill response contingency plans. When spills occur with such vessels, the owners or operators generally contract with oil company cooperatives” and private companies to respond to them. While the Philadelphia and New York cooperatives have contingency plans, we found that the plans lack specifics on capabilities for handling spills. For example, our consultant believes that the Philadelphia plan does not specify what personnel and equipment would be needed to respond to spills of various sizes, nor does it indicate the largest spill the coopera- tive could handle. Similarly, the New York plan does not link resources to a spill of a specific size. While the New York plan contains details of equipment that cooperative officials said can handle a 1,680,000-gallon spill over 5 days, it does not indicate from where or how quickly person- nel could be obtained to use the equipment. We also found that neither of the cooperatives’ plans addresses variables, such as the time of day or week when a spill might occur, that could have an impact on the effectiveness of the spill response. Unlike the operationally oriented cooperative plans, the Coast Guard’s contingency plans for the Philadelphia and New York ports are primar- ily designed for the Coast Guard’s monitoring or directing the actions of others. Specifically, the Coast Guard’s plans (1) outline the duties and interactions of the responding agencies; (2) promote the coordination of federal, state, and local response systems; (3) encourage the develop- ment of capabilities by both local government and private interests to handle or prevent pollution discharges; and (4) provide detailed infor- mation on local geography and critically sensitive areas. Coast Guard officials in both ports acknowledged the plans’ lack of specifics on resources available to deal with spills of various sizes and explained that when a spill has occurred, they have employed an operational con- cept of using as many cleanup contractors as necessary. The officials also said that they have developed a knowledge of, and working rela- tionships with, contractors- information not written into the local plans. After the Exxon Valdez experience, the Coast Guard Commandant directed port captains to review their plans and include more informa- tion in them, such as historical spill considerations, worst case scenarios, and scenarios for the most probable and realistic spills. Although the plans for the Philadelphia and New York ports were revised in October ‘Cooperatives are organizations voluntarily formed by member oil companies who share certain com- mon resources in the event of a spill. Page 4 GAO/RCEDSO-gg 011 Spilla in Philadelphia and New York Ports 5236137.6 1989, improvements are still needed. For example, the Captain of the Port for Philadelphia analyzed the local response capability, specifically addressing the personnel and equipment shortfalls for the worst case scenario -which he defined as involving a spill of 1.5 to 2 million gal- lons. (See app. I for more details.) The revised plan, however, acknowl- edges that response capabilities in the area are not adequate to deal with a spill of that size, but does not describe how resources could be brought in from other areas to handle the spill; rather the revised plan is limited to describing capabilities that are available locally to respond to a spill of 50,000 gallons. In his recent review of the Coast Guard’s plan for New York, the Cap- tain of the Port recognized that a spill of severe consequence could occur but did not specify what size spills could be handled effectively. He said that the effectiveness of the response depends on the location, tempera- ture, wind velocity, current velocity, type of oil, and many other factors. As a result, he said it is impossible to state that spills of any particular size can be handled. (See app. I for more details.) Resources Needed for Experience in the Philadelphia port area has demonstrated that Major Spills Not Always resources will not always be available to respond to spills as the cooper- ative and Coast Guard assume. For example, during the first 2 days of Available the Presidente Rivera spill, the response contractor was not able to obtain enough people and workboats to remove the oil from the water and the beaches. Industry could not provide personnel in sufficient num- bers because the spill occurred on a weekend-a factor our consultant said should be addressed in plans-and because personnel were han- dling other spills. Running into the same obstacles, Coast Guard officials said they and the local response organization tried but could not add large numbers of resources from all of their known sources. Ultimately, Delaware’s National Guard supplied manpower to do the job, and equip- ment was provided by various sources, including the Coast Guard National Strike Team (a Coast Guard group equipped to provide supple- mental response support for, or on behalf of, federal on-scene coordinators). Resource shortages have been problems in the response to other major Delaware River spills as well. For example, the on-scene coordinator for the Grand Eagle spill (a 462,000-gallon spill that occurred on the Dela- ware River in September 1985) said that contractors had problems obtaining cleanup personnel for the response during hunting and fishing seasons. Similar worker availability problems occurred during the Page 6 GAO/RCED-96433 Oil Spills in Philadelphia and New York Ports B-236137.5 Intern-tar Alliance spill (a 176,000-gallon spill that occurred on the Dela- ware River in March 1986). Recent reviews of the Coast Guard’s plans have identified more specific limitations in response capabilities. Although the Philadelphia port has had in the past 5 years four oil spills in excess of 100,000 gallons, in his October 1989 revised plan, the Captain of the Port recognized that response capabilities in the area could deal effectively with spills of no more than 50,000 gallons. He added that response effectiveness would be affected by the time it could take area contractors to arrive on the scene and deploy their equipment, as many as 6-9 hours, Further, he pointed out, “There are simply not enough personnel and equipment available locally to be able to conduct effective cleanup operations for a worst case spill,” which, he said, would cause him to rely on the Strike Teams and Navy for assistance. In the New York port, two major spills-one of 102,000 gallons and the other of 301,000 gallons-have occurred in the last 5 years, but neither was as complex as the Presidente Rivera spill. The New York on-scene coordinator for these spills did not prepare reports on them; conse- quently, no written assessment was made of the preparations or response. The recently revised New York Coast Guard’s plan does not describe specifically the resource capabilities in the area. Authority Is Needed to The Coast Guard believes it lacks authority to require private ship own- ers, operators, or others, such as industry cooperatives, to have contin- Ensure Response gency plans for dealing with oil spills by vessels in transit. Furthermore, Preparations Are if the owner, operator, or cooperative has such a plan, the Coast Guard Adequate believes it cannot dictate the size of the spill that the plan should address, ensure that the resources called for in the plan are in place, or ensure that the plan is tested for its effectiveness. However, the Coast Guard asserts that once a spill occurs, it has author- ity to monitor the response or assume partial or total control of the response. Thus, while the Coast Guard has a major role in ensuring the effectiveness of a response, it believes it does not have the necessary authority to ensure that industry response preparations are adequate. If the Coast Guard would have the authority to approve industry plans to ensure their quality, it would be in a better position to develop its own plans to guide actions if it would have to assume control of the response. Coast .Guard officials believe this lack of authority is the most signifi- cant limiting factor in the contingency planning process. Page 6 GAO/RCED-90433 Oil Spills in Philadelphia and New York Ports R-236137.6 To address this deficiency, bills passed by the Senate (S. 686) and House (H.R. 1465) in August and November 1989, respectively, require all owners and operators of tank vessels carrying oil in US. waters to pre- pare and submit to the Coast Guard a contingency plan for the preven- tion, containment, and cleanup of oil spills from their vessels or facilities. The bills require that the plans provide full details of the method of response to a worst case spill and a detailed description of equipment to be used. Further, these bills require the Coast Guard to approve all contingency plans and to require changes to the plans or response capabilities it deems necessary. Coast Guard officials told us that this new authority will require substantial additional resources and clarification of federal liability relating to the use of approved plans. The Congress is expected to act early in 1990 on this proposed legisla- tion, which we endorse in concept. The responses to the Presidente Rivera and Exxon Valdez spills also Deficiencies Noted in indicated a need to improve equipment for containing and removing oil. Capabilities of For example, a lesson learned from the response to the Presidente Response Equipment -skimmers, Rivera spill was that the equipment normally used, such as booms and would not effectively contain or recover the heavy tar-like clumps of spilled oil. During the initial stages of the spill, the contain- ment booms used were not heavy enough and did not go deep enough into the water to prevent the heavy oil from passing under them. Skim- mers could recover the material, but it was almost impossible to off-load the collected material. Initially, oil was recovered by physically picking up the clumps, either by hand or by fishing net, and placing them in containers. Later, according to Coast Guard officials, clamshell dredges were more effective in picking up the oil. In our Exxon Valdez report, we said that current recovery technology could not have addressed effectively a spill of the size encountered. Coast Guard officials told us that the response to that spill was ham- pered by breakdowns in equipment and by techniques rendered ineffec- tive by weather and water conditions. Further, Coast Guard officials told us that with current technology, the best that typically can be expected after a major spill, such as the one from the Exxon Valdez, is to recover 10 to 15 percent of the oil. Notably, however, while concern exists that response technology has not changed much since the 197Os, federal funding for research and development has been cut back in recent years. For example, according to an official of the Environmental Protection Agency, in fiscal year Page 7 GAO/RCEXHO-83 Oil Spilla in Philadelphia and New York Ports B23613’7.5 1988 the agency suspended research and development in prevention and cleanup of oil spills in favor of higher priority needs. Also, in fiscal year 1989 the Coast Guard’s budget for research, development, testing, and evaluation in its Marine Environmental Protection Program, of which oil spill response is only a part, was about $.5 million-$8.3 million less than was expended in 1983. Acknowledging the need for improvement, the Senate and House bills, which we endorse in concept, authorize the establishment of a program that would provide for research, development, and demonstration of new or improved technologies effective in preventing or mitigating oil discharges under both moderate and harsh environmental conditions. The nation’s limited ability to deal with spills of the size or nature of Priority Needs to Be those from the Exxon Valdez or Presidente Rivera demonstrates the Given to Spill importance of preventing such spills from occurring in the first place. Prevention The examinations after these spills show that improvements are needed in prevention measures, including such important ones as the monitoring and guiding of ship movements, and the use of vessel escorts and harbor pilots. One method to guard against vessel groundings or collisions that could result in oil spills is the use of a Vessel Traffic Service (WS) system. According to Coast Guard officials, because of budget constraints, VTS systems across the country have been cut back, including the elimina- tion of the New York Harbor VTSin 1988. The Coast Guard currently operates a VTSin five areas of the nation’s waterways. Recently, how- ever, supplemental appropriations were passed, making up to $5.6 mil- lion available for the development, acquisition, installation, and operation of, and support for a ITS in the New York Harbor area. The Philadelphia port has no Coast Guard VTS,but private organizations operate a ITS at the mouth of Delaware Bay to track ship arrivals and departures. The Coast Guard is currently examining the role of the vrs system nationwide in monitoring and guiding ship movements. Coast Guard officials believe VTSsystems should be mandatory since some sys- tems now in use are voluntary. Using vessel escorts and harbor pilots can help lower the likelihood of accidents by assisting vessels and by possibly providing the captains with more knowledge of local water conditions and hazards. The use of these prevention measures is important in ports where a large number of foreign ships enter, such as the New York and Philadelphia ports. For Page 8 GAO/ICED-90433 oil Spills in Philadelphia and New York Ports B-236137.6 these ports, the Coast Guard requires vessels transporting hazardous cargo, such as liquified petroleum gas, to have vessel escorts as an added safety measure, but does not routinely require oil tankers to use escorts. If a ship transporting oil has mechanical problems or has to transit hazardous waters, however, the Captain of the Port can direct that escorts be used. The use of pilots in the Philadelphia and New York ports differs. In the Philadelphia port area, Delaware and Pennsylvania require that a state- licensed pilot remain on board the vessel from the time it enters the Del- aware Bay until it is docked. In the New York port area, New York requires a state-licensed pilot be on board a vessel while it is entering New York harbor, but not while it is being docked or moved within the harbor. The Coast Guard is currently examining pilotage authorities and requirements to consider any need for change. The Exxon Valdez spill has generated many recommendations for Recent Spills Have improving prevention and response nationwide. A Department of Trans- Generated portation and Environmental Protection Agency May 1989 joint report Recommendations to the President, done in response to that incident, identifies many efforts needed in prevention, contingency planning, readiness of That Will Need response resources, designation of roles and responsibilities of parties Focused Action and involved in a response, and research and development. Also, the Ameri- can Petroleum Institute issued a June 1989 report that includes recom- Greater Funding mendations for improving prevention, response, and research and development. In addition, the Coast Guard completed a comprehensive evaluation of alternatives to help prevent oil spills, and many other activities are still underway that will add to possible nationwide actions. Similarly, the Presidente Rivera spill has generated suggestions for improving prevention and response in the Delaware River area, sugges- tions that may be applicable elsewhere. For example, Philadelphia Coast Guard officials believe that advance planning should be done with state .government sources of manpower, such as the National Guard, so that the manpower is ready for quick activation in an emergency when com- mercial personnel are unable to meet the need. In its preliminary report on the Delaware River spill, the Coast Guard suggested that private industry develop an emergency management team to assist in mobilizing resources. Subsequently, the Philadelphia Coast Guard established such a team to advise the on-scene coordinator. Page 9 GAO/RCED-!30-83 Oil Spills in Philadelphia and New York Porta B-236137.6 Although the many suggested actions stemming from the Exxon Valdez and Presidenta Rivera spills are positive signs, these actions may not be as effective as possible if implemented only on a local basis, that is, if only local changes are made in the use of VTS,escorts, or pilots. Thus, it may be appropriate to establish a single entity or leader for recom- mending and pulling together the specific actions that are likely to achieve a higher level of protection nationally. As we previously reported on the Exxon Valdez spill, achieving greater protection will require greater funding. The recent Senate and House bills, which we endorse in concept, would establish a fund to pay for response activities and damages if full compensation is not available from the party that spills the oil. Money for the fund would come from a per barrel tax on crude oil and petroleum products shipped in US. waters. Planning and readiness for oil spills in the Philadelphia and New York Conclusions ports need improvement, as they do elsewhere in the nation. Industry and the Coast Guard cannot respond effectively to oil spills if they do not have the plans and resources necessary to do the job. Although recent Coast Guard assessments of response capabilities in the Philadel- phia and New York ports raise questions about industry’s ability to han- dle major spills in these areas, the Coast Guard does not believe it has the authority necessary to ensure that adequate industry response prep arations have been made. Past experiences with major spills have shown that a greater commitment to planning and response will probably not fully protect the environment. Thus, priority should be given to prevent- ing spills. Industry and government efforts are already underway nationally and locally to improve prevention and response capabilities, but achieving greater protection wiIl require greater funding. To estab- lish and maintain the desired higher levels of protection and to help maximize the effectiveness of actions taken, leadership will also be needed. We believe a single entity within the federal government should adopt the leadership role. In our Exxon Valdez report, we presented several matters for congres- sional consideration to help ensure that an effective course of action is developed for improving the nation’s capabilities to prevent and respond to oil and other hazardous spills, and to help ensure that suffi- cient funds are available to support improved prevention and response capabilities. In that report we stated that the Congress may wish to consider Page 10 GAO/RCED90-33 011 Spib in Philadelphia and New York Ports B-236137.6 l designating through legislation a single entity or leader for developing an action plan; . establishing a fund, or modifying existing funds, to finance the improve- ments; and l providing the Coast Guard with explicit authority to carry out the role of ensuring adequate response preparations have been made. We believe our findings for the Philadelphia and New York port areas further support these considerations. As we have noted in this report, the last two considerations are addressed in bills passed by the Senate and House in 1989. Regarding the last consideration, Coast Guard offi- cials stated that the new authority will require substantial additional resources and clarification of federal liability relating to the use of approved plans. Our objectives were, for the ports of Philadelphia and New York, to Objectives, Scope, and evaluate oil spill response preparation and capabilities, Coast Guard Methodology authority to manage responses for these ports, and measures that can be taken to help prevent major oil spills from occurring in the future. We conducted our work from May through September 1989 primarily by interviewing Coast Guard officials in headquarters, Philadelphia, and New York, and by reviewing relevant reports and documents. Details of our objectives, scope, and methodology are contained in appendix II. As you requested, we did not obtain official agency comments on a draft of this report. We did, however, discuss our findings and conclusions with Coast Guard headquarters and local officials. We performed our work in accordance with generally accepted government auditing stan- dards, under the direction of Kenneth M. Mead, Director, Transportation Issues, who can be reached at (202) 275-1000. Appendix III lists the major contributors to this report. Page 11 GAO/IUXDM Oil Spills in Philadelphia and New York Ports B236137.5 As arranged with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 7 days after the date of this letter. At that time, we will send copies to the Secretary of Transportation, the Commandant of the Coast Guard, and other inter- ested parties. Sincerely yours, J : J. Dexter Peach Assistant Comptroller General Page 12 GAO/RCTRKWMU oil Spillm in Philadelphia and New York Porta Page 13 GAO/lWED90-83 Oil Spille in Philadelphia and New York Ports Contents Letter Appendix I 16 Coast Guard Analysis Philadelphia Port Resource Capabilities 16 New York Port Resource Capabilities 18 of Adequacy of Spill Response R&ources in the Philadelphia and New York Ports Appendix II Objectives, Scope, and Methodology Appendix III 22 Major Contributors to This Report Abbreviations Captain of the Port GAO General Accounting Office osc on-scene coordinator PIRO Petroleum Industry Response Organization WED Resources, Community, and Economic Development Division VT3 Vessel Traffic Service Page 14 GAO/WED-!W-S3 Oil Spilla in Philadelphia and New York Porta . Page 16 GAO/ICED-9043 Oil Spills in Philadelphia and New York Ports Appendix I CoastGuard Analysis of Adequacy of Spill ResponseResourcesin the Philadelphia and New York Ports The Commandant of the Coast Guard, after the Exxon Valdez spill and as a result of the Congress’ recent focus on contingency plans, identified certain important issues, including existing shortfalls of response resources, that should be addressed in local Coast Guard plans. Conse- quently, all on-scene coordinators were required to report personnel and equipment shortfalls identified during their planning process. The Captain of the Port, Philadelphia, drafted the following response Philadelphia Port for spills of approximately 1.5 to 2 million gallons, a worst case spill for Resource Capabilities the port: “Obtaining sufficient personnel to assist with cleanup efforts has proved to be diffi- cult Many local cleanup contractors are small companies with only a few people on hand. Other companies are large, but have offices spread out over a large region. In addition, none of the companies keep a large number of personnel on hand in case a major spill occurs. They are performing jobs in other areas of their business and may not have any personnel available at the time you need them. An estimated 1,200-l ,500 civilians will be needed to assist in various cleanup operations for spills around 1.5-2 million gallons. At best, only 1,000 civilians from 17 different cleanup companies can be obtained. All of the available companies have to rely on other sources to increase their staff. Each company typically obtains extra personnel from other firms, a labor pool (temporary labor supplies), part-timers, or state unemploy- ment offices. Many of these alternatives are not a guarantee that extra personnel can be obtained. “It will take all of these cleanup companies a number of hours to mobilize their per- sonnel, Approximately 300 personnel are available on call at any time. The follow- ing is a list of how many personnel from the 17 companies could be on scene in a certain number of hours. It is estimated that only about 500 personnel can be obtained for a response. a) Within 6 hours 419 personnel b) Within 12 hours 575 personnel c) Within 24 hours 726 personnel d) Within 36 hours 88 1 personnel e) Within 48 hours 1,008 personnel “Although the contractors stated that they could have over 1,000 people on scene within 48 hours, it could take as long as 3-5 days to provide that number of people if the spill occurs on a weekend or holiday. In addition, these people can be provided only so long as they are not doing any other work or responding to oil spills in other areas. We believe that the actual number of people that could be provided for cleanup operations will probably be much less than the stated amounts. Page 16 GAO/‘RCED9O433 Oil Spilla in Philadelphia and New York Ports Appendix1 CoastGuardAnalyArulysieofAdequacyofSpHl Responsel?esonrcealnthePhiladelpklaand NewYorkPorta “The Coast Guard Marine Safety Office, Philadelphia, will be severely undermanned in the event of a 1.6-2 million-gallon spill. We estimate that approximately 250 per- sonnel will be needed to conduct operations and support. If the spill has to be feder- alized, then we estimate that approximately 460-600 personnel will be needed. This does not include personnel from the Strike Team that will be needed. Our staff can be augmented by Coast Guard Reservists as well as active duty members from other units. “ .There is an inadequate supply of response equipment available locally to be . able to respond to a very large spill. Many contractors do not keep a large inventory of equipment that is expensive and may be used very little. In addition, some of the listed equipment could already be in use in other projects or oil spills at the time that they may be needed locally. Many of the contractors are not within the local or regional areas and will take some time to be on scene if called upon. “The following is a basic list of personnel and equipment that are available pro- vided all 17 contractors were available and not busy, as well as what we estimate will be needed: Personnel needed Personnel available Coast Guard 500 100 Contractors 1,200-l ,500 1,000 Equipment needed Equipment available Inner harbor boom 75,000 feet 66,350 feet Sorbent boom 75.000 feet 40.000 feet Deep sea curtain 25,000 feet 5,000 feet Vacuum trucks 50 55 Vactors 10 10 Skimmers 12 2 Oil storaae bladders 3 million-aallon capacitv none Oil storage tanks ashore 3 million-gallon capacity none dedicated‘ Lightering barges 3 million-gallon capacity none dedicated’ Workboats 100 101 Workboats (over 26 feet) 20 none Command post trailers wrth communications 4-6 none Radios 200 24 Cellular teleohones 20 8 Beepers with displav/voice feature 60 none Fax machines for all command posts 6-8 2 Passenger vehicles 25 7 ‘These will never be dedicated, but there are resources available locally to meet these requirements. It will depend on whether or not the tanks or barges are full and/or available and the type of product spllled vs. what type of products the tanks hold. Page17 GAO/RCED-gO-g3OilSpillsinPhlladelphiaandNewYorkPorts Appendix I of Adequacy of Spill Coast Guard Analysis ReapomeResourcealn the Philadelpkh and New York Ports “There is a need for backup communications equipment. All radios . . . available for use are limited in their range and battery life. Cellular telephones are also limited in their battery life, and are only useful so long as they are within range of an avail- able network and so long as the network is not tied up with other users. “Currently there is an inadequate number of telephone lines at the base. While there are 200 telephone line connections, only 12 are active. This means that in the event of a major spill, there will be a flood of incoming and outgoing calls. All currently available telephone lines will be busy whether or not they are in actual use. This could severely hamper operations and the ability of the OSC[on-scene coordinator] to effectively coordinate response actions. In general, telephone and electrical com- panies are reluctant to provide emergency service connections without conducting the required credit checks. The Coast Guard needs to make the telephone and elec- tric companies aware of the situation to help ensure rapid hookup services are pro- vided for the base and satellite command posts.” The Captain of the Port, New York, provided this general overview of New York Port response capabilities, without reference to a specific worst case spill Resource Capabilities size: “As a major industrial area, the Port of New York has tremendous commercial resources available in the event of a major oil spill. The port has vessel repair facili- ties, a large fleet of tugs and barges, and numerous marine service companies that can assist with different emergency vessel-related incidents. With excellent intermodal transportation links, the port can fully support any out-of-region logisti- cal needs by air, rail, and highway when necessary. In addition, the Port of New York has more than adequate sources of commercially available oil pollution response equipment. “There are ten pollution cleanup companies in the COTP [Captain of the Port] New York zone with which the Coast Guard maintains basic ordering agreements. These companies maintain varying amounts of oil containment and recovery equipment, including booms, portable skimmers, vacuum trucks, small boats, and trained per- sonnel. If a spill is federalized, the OSCcan call any number of them for response to the incident. “The Clean Harbors Co-op, founded by a number of oil companies in the port, has sufficient equipment to deal with an estimated 40,000-barrel [ 1,680,000-gallon] oil spill. This includes nine miles of containment booms, six workboats, fifteen deploy- ment boats, seven self-propelled skimmer boats, dispersant spray equipment, a high volume oil transfer system, a mobile command post, and many other pieces of equip- ment for oil containment and recovery. The resources of this cooperative are avail- able not only to its members, but other parties, including the Coast Guard on a rental basis. “As a recent development, the Petroleum Industry Response Organization (PIRO) is planning to establish one of five regional response centers in the Port of New York. . Page 18 GAO/RCEBM Oil Spilla in Philadelphia and New York Ports Appendix I Coast Guard halyda of Adequacy of Spill Response Resources in the Philadelphia and New York Porta The New York PIRO center will be equipped for a 200,000-barrel[8,400,000-gallon] oil pollution incident and will be responsible for the New England and Mid-Atlantic areas of the U.S.” Page 19 GAO/WED-90-M Oil Spilla in Philadelphia and New York Porta Appendix II Objectives,Scope,and Methodology On April 13, 1989, Senator Frank R. Lautenberg, Chairman, Subcommit- tee on Transportation and Related Agencies, Senate Committee on Appropriations, asked us to investigate the government response to the Exxon Valdez oil spill, and more broadly, federal policies and practices for preventing and responding to oil spills. As part of that request, he also asked us to examine the adequacy of contingency plans and equip- ment for the Philadelphia and New York ports. We subsequently met with his staff and agreed that an ongoing Coast Guard assignment would address the Exxon Valdez issues raised. We also agreed to evalu- ate oil spill response preparations and capabilities, and Coast Guard authority to manage responses for the ports of Philadelphia and New York, and to examine measures that can be taken nationally to help pre- vent major oil spills from occurring in the future. We testified on the results of our work on the Exxon Valdez oil spill incident before the Subcommittee on Coast Guard and Navigation, House Committee on Merchant Marine and Fisheries, on August 10, 1989,’ and issued a follow-up report on October 30, 1989.2 For the portion of the request regarding Philadelphia and New York, we conducted our work from May through September 1989 at the U.S. Coast Guard headquarters, in Washington, D.C.; Coast Guard district offices in Boston, Massachusetts, and Portsmouth, Virginia; the Marine Safety Office, in Philadelphia, Pennsylvania; and Group New York, Cap- tain of the Port and the Marine Inspection Office, in New York, New York. To achieve our objectives, we interviewed Coast Guard officials at the Coast Guard headquarters and at the district and local offices we vis- ited. We also interviewed officials from the Delaware Bay and River Cooperative, Lewes, Delaware; the Clean Harbors Cooperative, Perth Amboy, New Jersey; and oil spill cleanup contractors having agreements with the Coast Guard in the Philadelphia and New York ports. In addi- tion, we interviewed officials from the Pilots Association for the Bay and River Delaware, Philadelphia, Pennsylvania, and the United New York/New Jersey Sandy Hook Pilots Benevolent Association, Staten Island, New York. ‘Adequacy of Preparation and Response Related to Ekxon Valdez Oil Spill (GAO/T-RCED-89-59). 2Coast Guard: Adequacy of Preparation and Response to Exxon Valdez Oil Spill (GAOiRCED-90-44). Page 20 GAO/RcED-m Oil Spilla in Philadelphia and New York Ports Appendix II Objectives, Scope, and Methodology We reviewed pertinent reports and documents at Coast Guard headquar- ters, district, and local offices. We also attended a July 17, 1989, hearing on the Presidente Rivera oil spill before the Subcommittee on Oversight and Investigations, House Committee on Merchant Marine and Fisheries, and attended a July 13, 1989, hearing on oil spills in the coastal waters off Rhode Island, the Delaware River, and the Houston Ship Channel before the Subcommittee on Environmental Protection, Senate Commit- tee on Environment and Public Works. Page 21 GAO/BCED-90-82 Oil Spih in Philadelphia and New York Porta Appendix III Major Contributors to This Report Resources, Steven R. Gazda, Assignment Manager Community, and Robert G. Taub, Evaluator Economic Development Division, Washington, D.C. 1 Office of General Counsel Philadelphia Regional Michael R. Piskai, Evaluator-in-Charge Office Lindley R. Higgins, Evaluator Galen van Rensselaer, Evaluator (344448) Page 22 GAO/B(lTED90-83 011 Spilla ln Philadelphia and New York Ports
Coast Guard: Preparation and Response for Oil Spills in Philadelphia and New York Ports
Published by the Government Accountability Office on 1990-01-26.
Below is a raw (and likely hideous) rendition of the original report. (PDF)