National Contingency Plan Phase II Activities: A Problem Analysis & Decision Framework for Understanding & Evaluating Oil Pollution Threats from Sunken Ships Off California

Abstract

ABSTRACT The National Contingency Plan (NCP) provides an assessment framework through which to manage pollution threats in the United States. Although the NCP delivers an assessment framework for evaluating Comprehensive Environmental Response, Compensation & Liability Act (CERCLA) threats through formalized Site Assessments, Feasibility Studies, and Remedial Investigations, the NCP falls short of delivering a similar iterative process through which to evaluate non-emergent oil pollution threats. Recent experience with two historical wrecks in California (SS MONTEBELLO and M/V FERNSTREAM) suggest an opportunity to develop a problem analysis and decision framework enabling assessment/response (A&R) teams to evaluate more fully the nature of a problem, as well as the relative efficacy of alternative courses of action available to the Federal On-Scene Coordinator (FOSC). Using those two experiences as case studies, promising practices are distilled and adapted thru a formal policy analytic process to develop a problem analysis and decision framework for non-emergent oil threats. The intent is to bolster the utility of the NCP's Operational Response Phases for Oil Removal with emphasis on Phase II activities, and to provide FOSCs, Area Committees and Regional Response Teams a more robust evaluation tool.