Abstract

ABSTRACT 2017-333: In 2014, the Bureau of Safety and Environmental Enforcement (BSEE) commissioned a study to inform an update of Oil Spill Response Plan (OSRP) regulations for offshore oil and gas facilities and pipelines at Title 30, Code of Federal Regulations, Part 254. The study, Oil Spill Response Equipment Capability Analysis, was conducted by a team led by Booz Allen Hamilton (Booz Allen), with support from RPS Group (formerly ASA Sciences), Environmental Research Consulting (ERC), and SEA Consulting. In close coordination with BSEE, the Booz Allen team reviewed eleven worst case discharge (WCD) scenarios in the Gulf of Mexico, Alaska, and Pacific Outer Continental Shelf (OCS) Regions. The study, which involved literature reviews, oil spill modeling, and benchmarking against foreign and domestic regulatory regimes, concluded in February 2016, and highlighted many areas for improving the requirements for response capabilities in the OSRPs. This paper focuses on the key spill modeling methodologies, observations, and results in the Oil Spill Response Equipment Capability Analysis study, and its use of a concept of operations (CONOPS) for the application of various oil spill countermeasures in response to a WCD. The modeling results provided both new insights and reaffirmed many principles that have long guided oil spill response operations. The CONOPS systematically rolls them up into an offshore-based construct for employing multiple countermeasures in ways that will most effectively reduce oil contact with the environment. This effort did not attempt to quantify environmental impacts or provide guidance on applying countermeasures based upon a net environmental benefits analysis (NEBA) or spill impact mitigation analysis (SIMA). Decision-making for implementing the CONOPS will still require an additional overlying comparative analysis that evaluates the environmental, cultural, social and economic tradeoffs in order to find the preferred balance of spill countermeasures for a given planning scenario or incident. Regardless, the use of the construct (or CONOPS) as outlined in the study offers sound improvements for response planning involving very large spills in the offshore environment.

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