On the 6th March 2008 a desk based training exercise indicating the roles and responsibilities of all parties involved in the mitigation, clean up and compensation of a spill of persistent oils from an oil tanker was played out by students and staff at Falmouth Marine School. This exercise was developed by the 2nd Year FdSc Marine Environmental Management students as part of their Environmental Policies B module to provide training to a conservation team comprising representatives from the National Trust, Cornwall Wildlife Trust and Natural England.
The training exercise was intended to provide these conservation bodies with a full briefing on all aspects of dealing with a catastrophic oil spill along the Cornish coastline. The main resource used to develop this exercise was the National Contingency Plan for Marine Pollution from Shipping and Offshore Installations (NCP) provided by the Maritime and Coastguard Agency (MCA), a statutory agency of the United Kingdom government and the competent authority that responds to pollution from shipping and offshore installations in U.K. waters.
Planning and Research
On the 4th March 2008 a planning session was held at which the various responses to a maritime oil spill were examined in the context of the NCP. Tasks were assigned within the group, several of which corresponded with the framework provided by the NCP. This gave the group two days to research and develop the training exercise. The research roles and responsibilities assigned to the group were as follows;
Tony Arden – Coordination, general issues, initial information and scenario, forms and checklists.
Rowena Johnson – Level of response and salvage issues.
Lucas Lowe-Houghton – At sea response.
Amy Brock-Morgan – Harbour response.
John Deane – Shoreline response.
Ken McMullen – Environmental monitoring.
Matt Reed – Media relations.
Luke-Edwyn Marsh – Finance and prosecution.
Simon Pattenden – Compensation.
Joe Reavis – International cooperation and assistance.
Rory McPhee (lecturer) – Insurance and shipping regulation.
The command and control procedures for incident response, based on the NCP, are flexible and depend on the level of pollution or tier assigned to the individual incidents by the Counter Pollution and Response (CPR) Branch of the MCA. This is represented at a regional level by the duty Counter Pollution & Salvage Officer (CPSO) who is informed of any incidents by one of the 19 HM Coastguard (HMCG) stations around the UK.
In the UK, spills are categorised by the internationally adopted tier system. Tier one is a small operational spill employing local resources during any clean-up. Tier two is a medium sized spill, requiring regional assistance and resources. Tier three is a large spill, requiring national assistance and resources and the National Contingency Plan would be activated in this case.
Three main control centres would be set up:
A Salvage Control Unit (SCU) – Led by the Secretary of State’s Representative for Marine Salvage and Intervention (SOSREP), who oversees and approves any salvage operation and has statutory powers to intervene if necessary. The SOSREP can also impose a Total Exclusion Zone (TEZ) around the incident site. The SCU would coordinate and control salvage and refloating operations, emergency bunker transfers and if possible, movement to a shelter port for the damaged ship.
A Marine Response Centre (MRC) – Led by the MCA to coordinate all at-sea counter pollution and clean-up operations such as dispersal spraying, monitoring oil movement, oil recovery operations and the cleaning of oil recovery equipment. It would also liaise with the local harbourmaster to provide a harbour response.
A Shoreline Response Centre (SRC) – Led by the Local Authority with technical support from the MCA. This centre coordinates the shoreline clean-up operations, waste disposal and health and safety monitoring for workers, volunteers and sub-contractors. It would also liaise with the emergency services to provide a land based exclusion zone and support for clean up operations. It would also implement any local contingency plans held by the Local Authority.
An Environment Group provides expert environmental advice to all three specialist response centres including environmental impact assessments and data on threatened habitats and species. The Environment Group is made up of representatives of the statutory nature conservation body (in this case Natural England), the environmental regulator (Environment Agency), the local Wildlife Trust (Cornwall Wildlife Trust) and relevant fisheries departments (Cornwall Sea Fisheries Committee and the Marine Fisheries Agency). Other conservation bodies such as the National Trust, RSPB, Wildlife and Wetlands Trust etc. may also be invited to take part in an advisory capacity.
The Incident Scenario
At 0345 hours on the 6th March 2008 Falmouth Coastguard received a distress call from the FMS Grey Tuna (formerly the MV McPhee), a 49 377 tonne oil tanker. The vessel was adrift in Falmouth Bay and subsequently grounded at 0400 hours, 1000 metres south of Rosemullion Head, in the vicinity of August Rock, at 50o 06.2N 005o 04.4W. The cause of the incident was established as engine failure and possible human error as the ship was too close to land at the time. The duty CPSO was informed and declared a Tier 3 incident with activation of the NCP. The pollution incident control and SOSREP were activated at 0730 hours, along with the duty press relations officer.
The 36 man Russian and Phillippino crew were evacuated, with 2 casualties being airlifted by a Royal Navy SAR helicopter from RNAS Culdrose directly to Truro hospital at 0430 hours and the remainder by the Falmouth RNLI lifeboat to Falmouth Docks at 0630 hours. There were two harbour tugs standing by at Falmouth Docks and a Coastguard Emergency Towing Vessel (ETV) enroute from Penzance. Members of the SCU boarded the vessel at 0830 and initial reports stated that a spill of 200 tonnes of light crude from a pumping tank were in the water.
The current weather at 1000 hours 6th March 2008 (start of exercise) was a westerly wind at 16 knots with the tide dropping (high water 0414, low water 1055 1.1 metres, next high water 1641 4.9 metres).
The FMS Grey Tuna (master a Russian national, Josef Stalin) was registered in Liberia, gross tonnage 49 377, net tonnage 26 500, carrying 22 000 tonnes of light crude oil in 12 main tanks plus 500 tonnes of diesel fuel. She was enroute from Nigeria to Rotterdam and calling in to Falmouth to pick up more bunker fuel. A single bottom hull the vessels particulars were as follows; length 173.6m, beam 32.2m, draught 11.2m, 1x diesel motor driving 1x shaft with a top speed of 14 knots.
The vessel was owned by Global Transport of Monaco whose agents are Malaka SA of Pireaus, Greece and was bare boat chartered by Doe SA based in Monrovia, Liberia. The hull insurers were Lloyds of London. The cargo was owned by Shell of Rotterdam (agents De Groening of Rotterdam) and the third party insurers (P&I Club) were Steamship Mutual of London while the cargo was insured by Zurich in London.
This was the initial information available at the start of the exercise at 1000 hours on the 6th March 2008.
The exercise to respond to this pollution incident was initially straightforward with the spill limited to 200 tonnes of light crude washed ashore on the beach below Rosemullion Head, part of the Fal and Helford Special Area of Conservation (SAC). The command and control elements of the NCP were activated and the initial response was to establish a TEZ across Falmouth Bay and install boom defences (held by the Truro Harbourmaster) across the entrances to the Fal and Helford estuaries.
The SCU (established at the Falmouth Coastguard station) arranged for the transfer of the bulk cargo and diesel fuel to smaller vessels available from Falmouth Docks and the stricken vessel was refloated on the next high tide and towed into Falmouth harbour for repair. The MRC (also at the Falmouth Coastguard station) had vessels standing by in Falmouth Bay to monitor oil movement and any further spills and dispersant spray planes on standby to move to RNAS Culdrose if needed. The SRC (established at Rosemullion Head by Kerrier District Council) initiated the shoreline cleanup with resources provided by Kerrier and Carrick District Councils with an exclusion zone enforced by Devon and Cornwall Police. Advice on environmental impact was provided by the Environmental Group to all three response centres with the major impact being on the beach below Rosemullion Head where the majority of the oil came ashore.
Dealing with the aftermath of the incident was more complicated. Although compensation for the cleanup and salvage operations is available through the International Oil Pollution Compensation Funds, establishing a case for prosecution would be complicated by the Byzantine nature of the international shipping world. An inquiry into the incident might be able to establish whether the master was at fault by being too close inshore and the owners’ responsibility for maintenance on the power plant but the multiple interests involved and the foreign registration might make prosecution difficult. The use of a single bottomed ship is also against current regulations.
The major lesson learnt from this exercise was the need for close cooperation and liaison between all the different organisations involved in dealing with an incident of this nature. The exercise itself was a good tool in understanding the various processes involved and familiarising the exercise participants with the command and control structure dictated by the NCP. The prepositioning of boom defences, dispersant spray, clean up materials and other resources is of vital importance in a situation where time is of the essence.
My initial brief for the counter-pollution exercise was co-ordination, general issues, initial information and scenario, forms and checklists. During the planning phase of the exercise I acted as group chair as the group developed the exercise. Subsequently I created the scenario for the exercise using "real world" information such as the vessel involved which is based on the RFA Oakleaf, a support tanker of the Royal Navy and topographic maps and marine charts. Most of the forms and checklists were obtained from the National Contingency Plan for Marine Pollution from Shipping and Offshore Installations (NCP). At the start of the exercise the scenario and checklists were distributed and I then acted as the group co-ordinator whilst the exercise was played through.
A need for a greater understanding of shipping law and the mechanisms for mitigation and prosecution were highlighted by the lack of a section of the exercise dealing with these issues. The mechanism for shipping insurance claims was not really made very clear although information on the compensation funding was available if a little complicated. These issues need to be addressed before this exercise is repeated for the target group of conservation organisations. The introduction of an umpire to control variables in the scenario as it plays through and access to resources such as maps, charts and the internet during game play are also of equal importance.
Maritime and Coastguard Agency Scientific, Technical and Operational Advice Notes [online];
STOp 2/94: Low Viscosity Type 3 Dispersants.
STOp 2/95: Operational Guidelines for the Application of Bioremediation Agents.
STOp 1/98: Health, Safety & Welfare during Shoreline Clean-up.
STOp 5/98: A National Framework for Dealing with Hazardous Containers Washed Up on the UK Shoreline.
STOp 5/99: Guidelines for the Preparation of Coastal and Estuarine Booming Plans.
INF 3/00: MCA Contacts for Local Authorities.
STOp 1/01: Maritime Pollution Response in the UK - the Environment Group.
STOp 2/01: The Establishment, Management Structure, Rolesand Responsibilities of a Shoreline Response Centre during a Maritime Pollution Incident in the United Kingdom.
STOp 4/01: Advice to Local Authorities on the Collection and Handling of Oil Samples.
STOp 1/2003: Guidance for the Operation of the Technical Team, Waste Management Sub Group within a National Contingency Plan Shoreline Response Centre.
STOp 3/2003: Preparing Local Authority Oil and Chemical Spill Contingency Plans in line with the 'National Contingency Plan for Marine Pollution from Shipping and Offshore Installations'.
STOp 1/2004: Implications of the EU Landfill Directive for Oily Waste Disposal.
All available at: http://www.mcga.gov.uk/c4mca/mcga07-home/emergencyresponse/mcga-pollutionresponse/mcga-stop.htm [07.04.08].
National Contingency Plan for Marine Pollution from Shipping and Offshore Installations [online]. Available at: http://www.mcga.gov.uk/c4mca/ncp_final_version_-_august_2006.pdf [04.04.08].
The International Regime for Compensation for Oil Pollution Damage [online]. Available at: http://www.iopcfund.org/npdf/gen