Oil spill rsponse plan April 2018 - BP

Security Classification:

BP PublicBP Canada Energy Group ULC

B02 Issued for Use Mike Condon Allen Pere April 9 , 2018

B01 Issued Final Mike Condon Allen Pere February 5, 2018

A01 Issued for Review Mike Condon Allen Pere November 1, 2017

Rev Revision Description Content owner Approver/Issuing Authority Issue Date

Unique Identifier: CN001-HS-PLN-600-00003 Rev

B02

Uncontrolled when printed or stored locally

Scotian Basin Exploration Project

Oil Spill Response Plan

DocuSign Envelope ID: D652A638-4CBC-4F52-85B2-91C835A5928A


Oil Spill Response Plan Scotian Basin Exploration Project

CN001-HS-PLN-600-00003 Page i FINAL Rev: B02


Revision History

Revision Date Revision Number Approver Revision

9 April 2018 B02 Allen Pere

Fig 1-3 updated; Updated source control contact data in Fig 2-3; revised Fig 2-5; Fig 3-1& Sec 3.1.1: updated contact information for Wells Supt. and Naperville; added Sat phone #’s; replaced Fig 3-2; Sec 4.2.1& 6.6.2.2 updated to reflect change in containment/recovery system on standby vessels; Table 12-1 relabeled from 11-1 and updated; Misc. typos/minor edits throughout. Appendix 5 and Annex A updated to reflect changes in standby vessel containment system

Reviewers

Name Role Type of Review Date Reviewed

Signatures

RAPID Name Role Signature/Date

Decide Allen Pere Wells Manager, Western Hemisphere

Agree Multiple

Input Multiple

Recommend Mike Condon Crisis, Continuity Management & Emergency Response Lead, New Ventures, Nova Scotia


06 April 2018

06 April 2018


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Table of Contents Table of Contents .................................................................................................................. ii

List of Figures ........................................................................................................................ v

List of Tables ........................................................................................................................ vi

Acronyms, Abbreviations & Definitions................................................................................ vii

1 Policy, Responsibility and Planning Systems .................................................................... 1 1.1 Introduction .........................................................................................................................1 1.2 Scope ...................................................................................................................................1 1.3 OSRP Organisation ................................................................................................................2 1.4 Linked Plans .........................................................................................................................5 1.5 Multi-Tier Oil Spill Response Philosophy ................................................................................7 1.6 Policy ...................................................................................................................................8

1.6.1 Health, Safety and Environmental Policy ................................................................................ 8 1.6.2 Response Priorities ................................................................................................................ 10

1.7 Regulatory Background ....................................................................................................... 11 1.7.1 Area Contingency Plans ......................................................................................................... 14 1.7.2 Nova Scotia Emergency Response Plan (NSERP) ................................................................... 14 1.7.3 CANUSLANT ........................................................................................................................... 14

1.8 Plan Review, Updating and Access ...................................................................................... 15 1.8.1 Review and Updating Procedures ......................................................................................... 15 1.8.2 Electronic Plan Access ........................................................................................................... 15

2 Initial Oil Spill Response Actions .................................................................................... 16 2.1 On-scene Initial Response Actions ....................................................................................... 16 2.2 IMT Initial Actions Checklists ............................................................................................... 19 2.3 Hazards Assessment ........................................................................................................... 23 2.4 Initial Notifications ............................................................................................................. 23 2.5 Spill Assessment ................................................................................................................. 24

2.5.1 General .................................................................................................................................. 24 2.5.2 Spill Volume Estimation ........................................................................................................ 24 2.5.3 Oil Spill Surveillance and Tracking ......................................................................................... 26 2.5.4 Oil Spill Trajectory Modelling ................................................................................................ 27

2.6 Response Objectives and Strategies .................................................................................... 28 2.7 Response Information Management ................................................................................... 29

2.7.1 Information System ............................................................................................................... 29 2.7.2 Situational Awareness/Common Operating Picture ............................................................. 30

3 Notification Procedures ................................................................................................. 31 3.1 Notification Procedures ...................................................................................................... 31

3.1.1 Internal Reporting Requirements ......................................................................................... 33 3.1.2 External Reporting Requirements ......................................................................................... 36



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3.2 Notification Forms .............................................................................................................. 37 3.2.1 Internal Forms ....................................................................................................................... 37 3.2.2 External Forms ...................................................................................................................... 37

4 Response Resources ...................................................................................................... 38 4.1 Response Resources ........................................................................................................... 38 4.2 Resource Inventory ............................................................................................................. 38

4.2.1 Containment and Recovery Resource Inventory .................................................................. 38 4.2.2 Dispersant Resource Inventory ............................................................................................. 39 4.2.3 In-situ Burning Resource Inventory ....................................................................................... 39 4.2.4 Surveillance Resource Inventory ........................................................................................... 39 4.2.5 Shoreline Response Resource Inventory ............................................................................... 40

4.3 Cascading Resources ........................................................................................................... 40 4.3.1 Response Personnel .............................................................................................................. 40 4.3.2 Manufacturing of Expendables ............................................................................................. 40 4.3.3 Out-of-Region Resources ...................................................................................................... 40 4.3.4 Government-Owned Resources ............................................................................................ 40 4.3.5 International Resources ........................................................................................................ 41

4.4 Specific Expertise ................................................................................................................ 41 4.5 Other Potential Resources .................................................................................................. 41

4.5.1 Vessels of Opportunity (VOO) ............................................................................................... 41

5 Unified Coordination ..................................................................................................... 43

6 Spill Response Strategies and Tactics ............................................................................. 46 6.1 Introduction ....................................................................................................................... 46 6.2 Spill Events / Scenario ......................................................................................................... 46 6.3 Response Strategy and SIMA Summary for the Scotian Basin ............................................... 47

6.3.1 Spill Impact Mitigation Assessment (SIMA) .......................................................................... 48 6.3.2 Response Strategy Summary................................................................................................. 49

6.4 Response Tactic Selection Considerations............................................................................ 51 6.4.1 Windows of Opportunity....................................................................................................... 51 6.4.2 Non-Mechanical Countermeasures Authorisation Procedures ............................................ 52

6.5 Tactical Support Activities ................................................................................................... 53 6.5.1 General Overview .................................................................................................................. 53 6.5.2 Spill Surveillance .................................................................................................................... 53 6.5.3 Simultaneous Operations ...................................................................................................... 54

6.6 On-Water Response Tactics ................................................................................................ 55 6.6.1 Monitored Natural Attentuation........................................................................................... 55 6.6.2 Offshore Containment and Recovery .................................................................................... 56 6.6.3 Surface Dispersants ............................................................................................................... 58 6.6.4 In-Situ Burning ....................................................................................................................... 63 6.6.5 Sensitive Area and Shoreline Protection ............................................................................... 64

6.7 Monitoring & Sampling Activities ........................................................................................ 65

7 Wildlife Protection and Rehabilitation .............................................................................. 66

8 Waste Management ...................................................................................................... 67



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9 Decontamination and Demobilization ........................................................................... 68 9.1 Decontamination ................................................................................................................ 68

9.1.1 Personnel............................................................................................................................... 68 9.1.2 Equipment ............................................................................................................................. 69 9.1.3 Vessels ................................................................................................................................... 69

9.2 Demobilization ................................................................................................................... 69 9.2.1 General .................................................................................................................................. 69 9.2.2 Demobilization Plan .............................................................................................................. 70 9.2.3 Check-out Procedures ........................................................................................................... 70

10 Claims Management .................................................................................................. 71

11 Incident Termination and Debrief ............................................................................... 72 11.1 Termination of the Incident ............................................................................................. 72 11.2 Transition to Project Team(s) ........................................................................................... 72 11.3 Response Debrief/Critique .............................................................................................. 72 11.4 Incident Final Report ....................................................................................................... 73

12 Training and Exercise Program.................................................................................... 74 12.1 Overview ........................................................................................................................ 74 12.2 Training Program ............................................................................................................. 74 12.3 Exercise Program ............................................................................................................. 77 12.4 Equipment Deployment ................................................................................................... 77 12.5 Training and Exercise Documentation .............................................................................. 77

Appendix 1: Roles and Responsibilities of Government Agencies

Appendix 2: Surveillance Guidelines

Appendix 3: Notification Forms

Appendix 4: Resources Contact List

Appendix 5: Resource Inventory

Annex A: Offshore Containment and Recovery Tactical Response Plan

Annex B: Surface Dispersant Tactical Response Plan

Annex C: In-situ Burning Tactical Response Plan

Annex D: Shoreline Response Program Tactical Response Plan

Annex E: Waste Management Plan

Annex F: Monitoring and Sampling Tactical Response Plan

Annex G: Decontamination and Demobilization Plan



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List of Figures Figure 1-1: Aspy 11 Project Summary ........................................................................................................... 2

Figure 1-2: General Pattern of Oil Spill Response .......................................................................................... 3

Figure 1-3: BP Canada Scotian Basin Exploration Project OSRP – Linked Plans ............................................. 6

Figure 1-4: Tier Response Model (from IPIECA 2015) ................................................................................... 8

Figure 1-6: Regulatory Overview ................................................................................................................. 12

Figure 2-1: Initial Response Actions ............................................................................................................ 17

Figure 2-2: Oil Spill Initial Data Form ........................................................................................................... 18

Figure 2-3: Initial Response Actions IMT Incident Commander ................................................................... 21

Figure 2-4: Oil Trajectory – Manual Calculation .......................................................................................... 27

Figure 2-5: Response Strategy Flowchart .................................................................................................... 29

Figure 2-6: Concept of Simultaneous Operations ........................................................................................ 30

Figure 3-1. Oil Spill Notification Log ............................................................................................................ 33

Figure 3-2: BP Scotian basin exploration project Incident Notification Process .......................................... 35

Figure 5-1: BP Incident Management Organization .................................................................................... 43

Figure 5-2: BP Full IMT Structure for Major Event E.g. Oil Spill (Including MRT and Unified Coordination alignment) ................................................................................................................................................... 45

Figure 6-1: The Cone of Response ............................................................................................................... 47

Figure 6-2: Spill Response Strategy Decision Guide..................................................................................... 50

Figure 6-4: Offshore Containment and Recovery Decision Tree ................................................................. 56

Figure 6-5: Surface Dispersant Application Decision Tree ........................................................................... 59

Figure 6-6: In-Situ Burning Decision Tree .................................................................................................... 63



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List of Tables Table 1-1: Overview of OSRP ......................................................................................................................... 4

Table 1-2: Tier Level for this OSRP ................................................................................................................. 7

Table 1-3: Key Relevant Legislation or Guidelines with Potential Relevance to Spills ................................. 13

Table 2-1: Response Facilities ...................................................................................................................... 22

Table 2-2: Hazard Identification Chart ......................................................................................................... 23

Table 2-3: Spill Volume Estimation Chart .................................................................................................... 25

Table 2-4 Trajectory Modelling Sources ...................................................................................................... 27

Table 6-1: Potential Spill Events .................................................................................................................. 46

Table 6-2: Time- and Conditions-Related Windows of Opportunity Descriptions ....................................... 51

Table 10-1: KPMG Contacts ......................................................................................................................... 71

Table 12-1 Scotian Basin Exploration Project Oil Spill-Related Training and Exercise Schedule .............. 74



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Acronyms, Abbreviations & Definitions For purposes of this Plan, the following acronyms, abbreviations and definitions apply:

ADAP Aerial Dispersant Application Plan

AIS Automated Identification System

ALERT Atlantic Emergency Response Team Inc.

AOB Air Operations Branch

API American Petroleum Institute

Aspy D-11 Initial exploration well

bbl Barrel(s)

BOP Blowout Prevention

BP BP Canada Energy Group ULC, the Proponent

BSEE US Bureau of Safety and Environmental Enforcement

BST Business Support Team

CBT Computer-based training

CCG Canadian Coast Guard

CEAA Canadian Environmental Assessment Act

CEPA Canadian Environmental Protection Act

C & CM Crisis and continuity management

CMT Crisis Management Team

CNSOPB Canada-Nova Scotia Offshore Petroleum Board

CCO CNSOPB Chief Conservation Officer

COP Common Operating Picture

CSA Canada Shipping Act

CST Country Support Team

CWS Canadian Wildlife Service

DFO Department of Fisheries and Oceans Canada

DG Dispersant Group

DND Department of National Defence



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DOR Dispersant-to-oil ratio

DWH Deepwater Horizon

ECCC Environment and Climate Change Canada

ECRC Eastern Canada Response Corporation

EDSP Estimated Dispersant System Potential

EL Exploration Licence

EMO Nova Scotia Environment, Emergency Management Office

EO/IR Electro-optical/Infrared sensor

ER Emergency Response

ERP Emergency Response Plan

ERRV Emergency Response & Rescue Vessel

EST Executive Support Team

EU Environmental Unit

FOBS Field Observers

FRC Fast Rescue Craft

FS Finance Section

ft Feet

GoM Gulf of Mexico

GPS Global Positioning System

GRN Global Response Network

HSSE Health, Security, Safety, and Environment

IAP Incident Action Plan

IBC Intermediate bulk container

IC Incident Commander

ICP Incident Command Post

ICS Incident Command System

IMO International Maritime Organization

IMP Incident Management Plan

IMS Incident Management System

IMT Incident Management Team

IPIECA International Petroleum Industry Environmental Conservation Association



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ISB In-situ burning

IRIS BP’s global HSSE recording and reporting system

JEOC Joint Emergency Operations Centre

JMPCP Joint Marine Pollution Contingency Plan

JRCC Joint Rescue Coordination Centre

JRT Joint Response Team

JSA Job Safety Analysis

km2 Square kilometers

kts Knots

L Liters

LOG Logistics Section

m Meters

mm Millimeters

m3 Cubic meters

m/s Meters per second

MBCA Migratory Birds Convention Act

MCTS Marine Communications and Traffic Services

MODU Mobile Offshore Drilling Unit, the Seadrill West Aquarius

MoU Memorandum of Understanding

MRT Mutual Response Team

MSRC Marine Spill Response Corporation

NASP National Aerial Surveillance Program

NEBA Net Environmental Benefit Analysis

NEEC National Environmental Emergencies Centre

nm Nautical mile

NOTAM Notice to Airmen

NS Nova Scotia

NSE Nova Scotia Environment

NSERP Nova Scotia Emergency Response Plan

OC On-scene Commander

OIM Offshore Installation Manager



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OMS Operating management system

OPRC Oil Pollution Preparedness, Response and Co-operation

OPS Operations Section

OSCAR Oil Spill Contingency and Response Model

OSR Oil Spill Response

OSRL Oil Spill Response Limited

OSRP Oil Spill Response Plan

OSWMP Oil Spill Waste Management Plan

OWRO Oiled Wildlife Response Organization

PCC Public Safety Canada Provincial Coordination Center

Plan Scotian Basin Exploration Project Oil Spill Response Plan

PPE Personal Protective Equipment

PRB Protection and Recovery Branch

Project Scotian Basin Exploration Project

PS Planning Section

PSV Platform Supply Vessel

PSZ Platform Safety Zone

PTMS Point Tupper Marine Services Ltd.

QA/QC Quality assurance/quality control

RCMP Royal Canadian Mounted Police

Regulations Nova Scotia Offshore Petroleum Drilling and Production Regulations

RO (Canadian) Response Organizations

ROC Resources of Concern

ROV Remotely Operated Vehicle

SBM Synthetic-based mud

SCAT Shoreline Clean Up Assessment Technique

Science Table National Environmental Emergencies Centre’s Environmental Emergencies Science Table

Seadrill Seadrill Partners LLC., the Drilling Contractor

SG Surveillance Group

SIMA Spill Impact Mitigation Assessment

SIMOPS Simultaneous Operations



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SLAR Side-looking airborne radar

SME Subject matter expert

SOPEP Shipboard Oil Pollution Emergency Plan

SRP Shoreline Response Plan

SSDI Subsea dispersant injection

SSP Site Safety Plan

SU Situation Unit

TBC To be confirmed

TBD To be determined

TC Transport Canada

THC Total Hydrocarbon Content

Tier 1 Local capability

Tier 2 Regional capability

Tier 3 National/international capability

TRG The Response Group

TRP Tactical Response Plan

TRT Tactical Response Team

UAV Unmanned Aerial Vehicles

UK United Kingdom

USA United States of America

USCG United States Coast Guard

UV/IR Ultraviolet/Infrared sensor

VOO Vessel of Opportunity

WCMRC Western Canada Marine Response Corp.

WOB On-Water Operations Branch

WSL Wellsite Leader



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Section

1 1 Policy, Responsibility and Planning Systems

1.1 Introduction

This Oil Spill Response Plan (OSRP) provides BP Incident Management Team (IMT) and response personnel with tactical and strategic guidance regarding response management, capabilities and resources in the unlikely event of an oil spill during the BP Canada Energy Group ULC (‘BP’) Scotian Basin Exploration Project. The OSRP follows international practices and the Canadian Coast Guard’s (CCG) Marine Spills Contingency Plan – National Chapter, ISO 15544 (Offshore production installations – Requirements and guidelines for emergency response) and the International Maritime Organization (IMO) Manual on Assessment of Oil Spill Risk and Preparedness. The tiered preparedness and response in this OSRP is consistent with the International Convention on Oil Pollution Preparedness, Response and Co-operation 1990 (OPRC 1990). The OSRP identifies potential types and magnitudes of oil spills and their relative potential impact. It provides key steps for initial actions, notification procedures, and important safety information. The OSRP establishes the role of the IMT, lists oil spill response resources, identifies the Spill Response Operating Team, describes response facilities, and provides information on implementing oil spill response strategies.

In the event of an actual spill, this OSRP cannot guarantee that all discharged oil will be recovered, or that all sensitive area protection strategies will be successful. However, the plan incorporates practical information intended to help achieve the best possible response. This Plan provides information to help guide a response; however, specific actions taken and response options employed will be dependent on the specifics of an incident and will, ultimately, be determined by the Incident Management Team.

1.2 Scope

BP, in its capacity as operator of the proposed Scotian Basin Exploration Project (herein referred to as the ‘Project’), proposes to drill an initial exploration well in 2018 with potential to drill up to seven exploration wells in phases over the term of the licences, from 2018 to 2022.

The exploration drilling project location is depicted in Figure 1-1 and encompasses portions of BP’s offshore ELs 2431, 2432, 2433, and 2434. These licences cover 13,982 km2 and, at their shortest distance, are located approximately 230 km southeast of Halifax and 48 km from Sable Island National Park Reserve. Water depths in the ELs range from 100 metres (m) to more than 3,000 m.

For the initial exploration well, designated Aspy D-11, (location indicated by red dot) the Seadrill West Aquarius will be utilized. The Seadrill West Aquarius is a 6th generation ultra-deepwater semi-submersible






pattern of oil spill response and sequence of activities that will normally occur over the duration of a response (Figure 1-2).

FIGURE 1-2: GENERAL PATTERN OF OIL SPILL RESPONSE











1.6.2 Response Priorities

BP’s key priorities and objectives during oil spill response include, but are not limited to, the following:

1. People – Preserve safety of human life. Consider the safety of all people in the immediate area including your own.

2. Environment – Minimize adverse effects to the environment. 3. Property – Protect BP’s assets. Stabilize the situation to prevent the event from worsening. 4. Business including reputation.

As part of the overall response, BP is committed to developing incident-specific objectives and strategies to address these priorities as well as developing incident-specific response objectives that minimize further spill impacts and protect resources at risk.

While incident-specific objectives will be determined by the IMT, they would likely include:

1. ensure the safety of asset personnel, response personnel and the public; 2. search and rescue; 3. control the source of the incident; 4. manage a coordinated response effort; 5. maximize protection of environmentally-sensitive areas (e.g., Sable Island); 6. treat, or contain and recover spilled material; 7. keep the public and stakeholders informed of response activities.

Response objectives will be clearly communicated, measurable and achievable. Effective planning and execution of response operations is based upon coordination with authorities and response partners to allocate response resources (i.e., people, equipment, time) effectively.

To make sure an adequate response is available to address the incident, BP will, as required, apply the following response philosophy:

• (Over) React. • Assessment. • Response. • Stand-down.

The IMT provides support in the event of an emergency at any facility for which it is responsible. Should the affected site (MODU, supply base, helicopter operations, PSVs, etc.) ask for BP IMT assistance, all such requests are complied with on every occasion through activation of the IMT.





1.7 Regulatory Background

Nova Scotia’s offshore petroleum activities are regulated by the Canada-Nova Scotia Offshore Petroleum Board (CNSOPB), which is a joint federal-provincial agency reporting to the federal Minister of Natural Resources and the provincial Minister of Energy. The CNSOPB is the lead regulatory agency for spill response in the offshore, with the Canadian Coast Guard (CCG), Environment and Climate Change Canada (ECCC), Department of Fisheries and Oceans (DFO), Canadian Wildlife Service (CWS) and Transport Canada (TC) acting as resource agencies.

All operators of offshore petroleum activities that occur in the waters off Nova Scotia are required to produce oil spill response plans, as per the Nova Scotia Offshore Petroleum Drilling and Production Regulations (the Regulations) pursuant to the Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act.

The following lists the major departments and agencies with key roles in marine oil spill response for the Project:

• Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) (Lead Agency);

• Canadian Coast Guard (CCG), including Joint Rescue Coordination Centre (JRCC) for any related SAR issues;

• Transport Canada (TC);

• Environment and Climate Change Canada (ECCC);

• Department of Fisheries and Oceans (DFO);

• Canadian Wildlife Service (CWS);

• Nova Scotia Environment;

• Department of National Defence (DND), including JRCC for any related SAR issues;

• Royal Canadian Mounted Police (RCMP);

• Port Authorities;

• Department of Justice;

• Industry, including response organizations such as Eastern Canada Response Corporation (ECRC).

Figure 1-6 below shows the relationships between agencies, regulators, operators and response contractors.





FIGURE 1-6: REGULATORY OVERVIEW

In the event of a spill, the CNSOPB can access scientific advice on a variety of issues from other agencies or groups through National Environmental Emergencies Centre’s (NEEC) Environmental Emergencies Science Table (the “Science Table”) chaired by ECCC. Science Table experts may include representatives from other government agencies such as CWS, CCG, DFO, Nova Scotia Environment, Emergency Management Office (EMO) or subject matter experts from response agencies, Indigenous representatives, local communities, fishermen’s associations, environmental non-government organizations, and academic institutions. The Science Table works to advise the lead agency on matters such as sensitivities, fisheries and wildlife, cultural resources at risk, etc. and helps to identify protection and response priorities.

In addition to the OSRP required for offshore operators for petroleum activities, the MODU and Platform Support Vessels must also have Ship Oil Pollution Emergency Plans (SOPEP) as per the Canada Shipping Act (CSA). The CCG is the lead regulatory agency for oil spills from vessel or MODUs while in transit. TC also has compliance, enforcement and implementation responsibilities of regulations relating to response organizations.

Legislation, regulations, guidelines and memoranda of understanding relevant to operations within the scope of this OSRP are summarized in Table 1-3. These are not exhaustive, and all parties are to be fully compliant with flag, port state, local, national, international laws, codes and standards.

For more details see Appendix 1: Roles and Responsibilities of Government Agencies.






The CNSOPB has active MOUs in place with numerous agencies describing their mutual roles and responsibilities in administering relevant legislation. These detailed MOUs are found at: http://www.cnsopb.ns.ca/reference.

1.7.1 Area Contingency Plans

Canadian Response Organizations (ROs; i.e., ECRC, ALERT) have their own Area Response Plans and BP has access to these plans through the contractual agreements for the provision of response resources.

1.7.2 Nova Scotia Emergency Response Plan (NSERP)

The Emergency Management Office (EMO) Nova Scotia has legislative responsibilities to ensure that emergency management planning occurs within all levels of the provincial government. The NSERP serves as the provincial master plan for the managing of emergency events and lays out the structure to be used the by EMO in coordinating a provincial response. The NSERP is designed to ensure an integrated response involving all provincial departments, municipalities, non-governmental organizations and the private sector. The plan includes the role of the Joint Emergency Operations Centre (JEOC), individual roles and responsibilities, an incident command system, planning assumptions and a concept of operations, as well as plan maintenance responsibilities. The NSERP is found at: http://novascotia.ca/dma/emo/resources/docs/the-ns-emergency-response-plan-150114.pdf

1.7.3 CANUSLANT

Through a bilateral Joint Marine Pollution Contingency Plan (JMPCP), Canada and the United States have established a coordinated system for planning, preparedness, and responding to harmful substance incidents in the contiguous waters along shared marine borders. This joint plan supplements each country's national response systems and coordinates the interface of these systems for boundary areas. The JMPCP calls for five Geographic Annexes that specify response procedures and are the responsibility of the Regional Directors of the Canadian Coast Guard and District Commanders of the United States Coast Guard. The Coast Guards also chair Joint Response Teams (JRTs) for each geographic area that consist of appropriate government representatives to provide advice and counsel to facilitate coordinated planning, preparedness, and response to a harmful substance incident, recommend amendments to the JMPCP or the Geographic Annexes, or provide advisory support to the CCG On-Scene Commander and the USCG On-Scene Coordinator.

The CANUSLANT Geographic Annex covers the Atlantic marine boundary between Canada and the United States, defines the CANUSLANT JRT, and is regularly tested and improved in an ongoing series of CANUSLANT exercises. If the CCG becomes aware of an incident in the adjacent or non-adjacent waters covered by this plan, they will notify the USCG without delay; similarly, the USCG would notify the CCG if they became aware of an incident.





1.8 Plan Review, Updating and Access

1.8.1 Review and Updating Procedures

OSRPs must be:

• reviewed prior to drilling of each well and changes submitted; • kept up-to-date; operations must follow the OSRP.

Significant modifications must be submitted to the CNSOPB within 15 days, such as:

• reductions in response capability; • change to any worst-case discharge scenario; • changes to IMT.

1.8.2 Electronic Plan Access

This document will be held in the project SharePoint site controlled versions and revision announcements will be published and communicated to the appropriate BP and contractor personnel to ensure local implementation. Copies or extracts of this document, which have been downloaded from the SharePoint site, are uncontrolled copies and cannot be guaranteed to be the latest version.





Section

2 2 Initial Oil Spill Response Actions

2.1 On-scene Initial Response Actions

Figure 2-1 below provides the sequence of steps and activities to be followed during the initial stages of an oil spill response.

For more details, including “first-in” and IMT role-specific checklists, refer to Appendix 2 of the Project IMP (CN001-HS-PLN-600-00002): ICP Checklists.

For more details, refer to Appendix 3 of the Project IMP (CN001-HS-PLN-600-00002): Incident Specific Incident Management Guides.







2.2 IMT Initial Actions Checklists

Once the IMT is activated, staff members will be mobilized to the designated ICP to manage the response. Figure 2.3 indicates the initial actions that will be taken by the IMT Incident Commander during an oil spill.









2.5 Spill Assessment

2.5.1 General

Spill assessment is conducted by the Planning section of the IMT using information provided by field personnel and involves:

• spill volume estimation; • oil spill surveillance; and • oil spill trajectory modelling.

2.5.2 Spill Volume Estimation

It is important to estimate the size of the spill so that it can be correctly categorised into a tier to alert onshore responders and regulators to the type of incident, possible impact and likely severity.

There are two methods to estimate a spill size:

1. Known quantity: for example, if you know that all the oil has been lost from a tank or a hose that contained a known amount, report that amount.

2. Unknown quantity: estimate the quantity visually based on the area the slick covers and the relationship between the observed oil colour/ appearance which determines its thickness.

For unknown quantities, follow the steps below in Table 2-3 to establish an initial best estimate of the quantity of oil observed.






Oil Appearance Code

Thickness [mm]

Loading [m3/km2]

Coverage [%] ÷ 100

Total oil area [km2]

Min volume [m3]

Max volume [m3]

1. Sheen 0.00004 to 0.04 X /100 X =

0.0003 0.3

2. Rainbow 0.0003 to 0.3 X /100 X =

0.005 5.0

3. Metallic 0.005 to 5.0 X /100 X =

0.05 50

4. Discontinuous true colour

0.05 to 50 X /100 X =

0.2 200

5. Continuous true colour

>0.2 +200 X /100 X =

Total Spill Volume

2.5.3 Oil Spill Surveillance and Tracking

The surveillance strategy will be implemented as soon as a notification of an incident is received with the following actions:

1. Obtain first visual observations from the MODU (if safe to do so) and support vessels on site;

2. Deploy satellite tracking buoys from MODU or support vessel in the area of the spill;

3. Mobilize ECRC for aerial surveillance aircrafts (See Appendix 4 for contact details);

4. Satellite imagery may be obtained from OSRL if necessary (See Appendix 4 for contact details);

5. Reassess aerial surveillance needs throughout the response.

If the spill scenario requires so, these assets may be supplemented by other means such as airborne remote sensing, aerostats (tethered balloons with remote sensing equipment) and Unmanned Aerial Vehicles (UAV/drones). These tools will be tasked to specific surveillance missions such as monitoring operations or wildlife. Each of these tools have advantages and disadvantages, and no single tool will provide all surveillance requirements and therefore a suite of surveillance tools will be deployed to provide a 24-hr comprehensive surveillance capability based around aerial visual observation and satellite imagery. Oil spill trajectory modelling will also be used and will be validated by the surveillance from multiple platforms.

If required, assets from Transport Canada’s National Aerial Surveillance Program (NASP) could assist with surveillance activities. Transport Canada operates a fleet of surveillance aircrafts equipped with SLAR, EO/IR, UV/IR and video and still cameras. These assets may be activated through the CNSOPB.

For more details see Appendix 2: Surveillance Guidelines.






For smaller spills, ECRC will be requested to run trajectories using OilMap with results likely available within a 6-hour period.

For larger or more complex spills (such as loss of well control), modelling will be done internally at BP using OSCAR with results likely available within a 12- to 24-hour period. OSRL modelling capacity is used as a backup solution.

All models will require spill data to calculate trajectory and behaviour such as:

• oil properties; • spill information (location, volume, source, continuous spill or not, etc.); • met-ocean data (weather forecast, currents, tides).

It is important to note that oil spill trajectory calculations provide an estimate of oil movement and potential behaviour. The results must be validated by actual spill surveillance.

2.6 Response Objectives and Strategies

In the event of a spill, BP will implement several strategies and tactics to minimise potential impacts. BP’s priorities and objectives will be:

1. People: Employees, contractors, suppliers, customers and communities.

2. Environment: Air, water, land.

3. Property: Communities, contractors, 3rd party, BP and Joint Venture facilities and offices.

4. Business: BP and Join Ventures-production, supply, business reputation and brand.

Environmental protection priorities in case of an oil spill event will be to prevent oil from reaching Sable Island or the Nova Scotia shoreline. Appropriate response strategies will be selected using decision making guidelines (Figure 2-5).

The IMT will identify the appropriate response strategy based on incident specific conditions such as weather, sea state (degree of turbulence at sea based on wave height), oil type, location, source of spill, etc. The IMT may also conduct an expedited Spill Impact Mitigation Assessment (SIMA) to ensure that the overall response strategy will minimise potential environmental impacts.

For more details, refer to Section 6: Spill Response Strategies and Tactics.






2.7.2 Situational Awareness/Common Operating Picture

During an oil spill response, all effective and feasible response tools will be activated and used simultaneously to maximize the effectiveness of the response.

Should simultaneous response operations (SIMOPS) occur, the probability of a hazardous or conflicting event is increased as numerous assets will be working at the same time in close proximity. Coordination of SIMOPS and effective communications are necessary to ensure all activities are performed in a safe and controlled manner. BP has established SIMOPS procedures which will be followed during a spill response, and an incident-specific SIMOPS plan will be developed if required and adapted with the scale of the spill (Figure 2-6). Additional information can be found in Section 6.5.3 of this Plan.

FIGURE 2-6: CONCEPT OF SIMULTANEOUS OPERATIONS





Section

3 3 Notification Procedures

3.1 Notification Procedures

In the event of a spill, BP will ensure that proper notifications are made in a timely manner, both internally and externally. This section contains:

• an oil spill-specific notification log (Figure 3-1); • information on the internal BP notification process; • external notification requirements.

Note - BP’s full notification procedure and notification matrix are found in Section 3 and Appendix 9, respectively, of the Project IMP (CN001-HS-PLN-600-00002).






OIL SPILL RESPONSE NOTIFICATION LOG (for full notification matrix and log, see Appendix 9 of Project IMP)

Organization / Agency to be notified

Contact # When to contact

Tim

e/Da

te o

f N

otifi

catio

n

Nam

e of

Pe

rson

Co

ntac

ted

Nam

e of

Pe

rson

Mak

ing

cont

act

Refe

renc

e #

/ Co

mm

ents

RESPONDERS

ECRC (Tier 2 oil spill responder) (24/7)

+

OSRL (Tier 3 oil spill responder (24/7)

+44 23 8033 1551

FACILITIES

West Aquarius OIM (bridge)

West Aquarius Rig Manager

West Aquarius BP Well Site Leader Satellite phones

Woodside Supply Base (Bluewater)

Richmond Terminal Pier 9

Horizon Maritime (Marine Vessel Contractor)

CHO (Helicopter Company)

(via PAL Dispatch) Emergency

FIGURE 3-1. OIL SPILL NOTIFICATION LOG

Details for all HSE-related incident reporting and investigation are detailed in BP’s Scotian Basin Exploration Project Incident Investigation and Reporting Guide (CN001-HS-GLN-600-00001).

3.1.1 Internal Reporting Requirements

All those that may be required to assist in an emergency are to be notified as early as possible. They are to be stood down as per instruction from the BST or BP Halifax Incident Commander (IC) respectively, only when their level of involvement has been accurately assessed. Therefore, the following notification process is to be used:

1. The incident is reported to the Wells Superintendent via the duty phone # . Should the Wells Superintendent not be immediately reachable, a Duty Manager can be reached via the on-call phone # . At this point the person contacted becomes the Incident Commander and, as such, is now accountable for managing the BP response to the incident.





2. Wherever possible the IC will discuss the incident details with the On-scene Commander (OC) and mobilize the IMT accordingly. The nature of the incoming report may be such that the IMT is mobilized without contact with the OC (e.g., ditched helicopter). In these cases, the IMT must form and gather the incident details.

3. If this is a well control event, the IC will notify the VP of Wells for New Ventures, as per the Incident Notification Chart for Non-US Waters for mobilization of Source Control resources.

4. The IMT will action any appropriate response plans and mobilize the required resources for the incident.

5. If the IMT is activated, the IC will notify the BST Leader (or alternate) via the Naperville Notification Centre using Send Word Now. The IC and BST Leader will decide if a BST needs to be stood up, and what type of support it would provide. For example, depending on the nature and scale of the incident, the BP Halifax IC may request additional support from Calgary such as HR and C&EA, or MRT support.

6. If the BST mobilizes, the BST Leader will notify the Group Duty Manager, by calling the Response Information Centre, who will liaise with the Duty Segment Executive and Head of Region as required.

7. The BST Leader and Group Duty Manager will review the situation and will consider the requirement to mobilize the EST in St James’s Square or request assistance from the MRT.

Figure 3-2 below summarises the BP Scotian Basin Exploration Project incident notification process.






3.1.2 External Reporting Requirements

BP will comply with the CNSOPB Incident Reporting and Investigation Guidelines (October 2017), in accordance with the Accord Acts, the regulations, and the terms and conditions of Board approvals and authorizations for the reporting and investigation of incidents that occur in the offshore area. The Guidelines outline:

• what constitutes an incident that is reportable to the Board; • the process for the operator to report an incident; • the Boards’ expectations for incident investigations conducted by the operator; and • the process for periodic reporting of statistics and reports describing continual improvement

initiatives based on the results of incident trending and analysis.

CNSOPB

The CNSOPB, as lead regulatory agency for offshore oil and gas activities, typically coordinates communications regarding incidents.

• Must be verbally notified as soon as possible following spills greater than 25L. o Including but not limited to crude oil, natural gas, condensate, lubricants,

hydraulic oils, fuels, petroleum based synthetic drilling fluids, or any other refined petroleum product or for a collision during spill response that results in an injury or major damage / impairment.

• For spills <25L, written notification must be submitted via the CNSOPB website as soon as possible following the incident.

o Written notification must also be submitted via the CNSOPB website if any collisions occur during spill response that do not result in an injury or major damage / impairment within 24 hours of the incident.

Canadian Coast Guard (CCG)

• CCG must be notified verbally immediately following any spill or any other marine pollution incident.

o This can be done via telephone or VHF radio. o CCG will initiate notification of TC Marine Safety, ECCC, and DFO as part of their

own notification procedures.

Joint Rescue Coordination Centre (JRCC)

• The JRCC must be notified immediately following a marine incident that requires search and rescue services or a medevac.

o This can be done directly via telephone or by VHF/MF radio via MCTS (Marine Communications and Traffic Services).

Transport Canada Aviation

• Transport Canada Aviation must be notified immediately following an aviation emergency or incident during the spill response operations.





Halifax Port Authority

• The Halifax Port Authority must be notified immediately following any spill incidents within the Halifax Harbour Limits.

Hess

• As a partner in the project, Hess may be able to supply additional technical and IMT personnel support through the Hess Incident Support Manager.

Response Organizations

• BP requires that the following response organizations must be notified in the event of a spill as described below:

o Eastern Canada Response Corporation (ECRC) requires notification upon escalation to Tier 2;

o OSRL (Southampton, UK) requires notification on escalation or potential escalation to Tier 3 or for dispersant use.

For more details regarding external notifications refer to Appendix 9 of BP IMP: Incident Notification Matrix and Contacts Lists.

3.2 Notification Forms

3.2.1 Internal Forms

For all incidents, the operator will complete the BP Initial Spill Data Collection Form found in Section 2.4 of this document.

3.2.2 External Forms

CNSOPB: For all incidents, the operator shall provide a written notification to the CNSOPB as soon as reasonably practicable, but no later than 24 hours after the operator becomes aware of any incident. A copy of the CNSOPB Notification Form is provided in Appendix 3: Notification Forms.

• The written notification may be submitted to the CNSOPB by email to [email protected]. • E-mailed notifications will contain a short descriptive title and any incident identification number

assigned by the operator. An operator will use the Incident Notification Form posted on the CNSOPB website (www.cnsopb.ns.ca/environment/incident-reporting) for this purpose.

ECRC: ECRC is notified by calling the 24-hour emergency number provided to members. A copy of the ECRC Call out Data Collection Sheet is provided in Appendix 3: Notification Forms, of this document.

OSRL: OSRL is notified by calling the 24-hour emergency number provided in the Notification Log. The OSRL notification form is provided in Appendix 3: Notification Forms, of this document. Note that written mobilization is required for dispersant use.





Section

4 4 Response Resources

4.1 Response Resources

Resources for spill response include those available locally, regionally and internationally through contracts and MoUs. Some or all of these will be activated during a spill response depending upon the severity and nature of the spill. In the event of an incident, the initial response operations will be conducted by BP-contracted vessels assisting with drilling operations. Pre-staged equipment will be deployed if it is feasible and safe to do. This includes equipment for containment and recovery and vessel dispersant application.

For larger spills that cannot be managed by resources on site or for in-situ burning operations, additional Vessels of Opportunity (VOOs) will be activated and fitted with the required equipment in the Port of Halifax. The IMT will escalate the response by cascading response equipment from the shore supply base, from the ECRC response base in Dartmouth and/or St. John’s, and/or OSRL, as required. If aerial dispersant application is employed, resources will be deployed from OSRL in the UK, with additional resources from Global Alliance (a collaboration of major oil spill organisations) in the USA, if required. Lists of names and contact information for first-call resources, supplemental resources and support resources are in Appendix 4: Resource Contacts List.

4.2 Resource Inventory

4.2.1 Containment and Recovery Resource Inventory

Tier 1 containment and recovery to be available onsite on the Standby vessel includes:

• Sorbent Side-Sweep System – sorbent boom (8”) deployed using ship’s crane as an outrigger to create a 10m swath system with a single vessel

• Side-Sweep Recovery system – A Desmi Termite skimmer paired with 150ft of 24’ containment boom towed with the vessel FRC or paravane to create a 15m swath system

Tier 2 containment and recovery equipment includes:

• BP-owned Lamor MOS15 Sweep systems with paravanes and integrated skimmers and pumps that are deployed from a single vessel. These systems (3) will be stored onshore in Halifax and will be mobilized onboard the PSVs assisting with drilling operations that are contracted to BP, and/or by an appropriate VOO. This equipment is designed to work in the offshore environment and can be towed at speeds up to 4 knots in 3m seas.





• ECRC resources for containment and recovery are available through the Standing Agreement with ECRC and will be mobilized from the base in Halifax and cascaded from other ECRC bases in eastern Canada, as needed.

Tier 3 resources for containment and recovery are available through the Standing Agreement with OSRL and will be shipped from their Global bases by aircraft.

For more details see Appendix 5: Resources Inventory.

4.2.2 Dispersant Resource Inventory

The initial application of dispersants will be conducted, if authorized, by platform supply vessels (PSVs) assisting with drilling operations. Dispersant spraying systems and dispersants will be pre-installed on 3 vessels. Each vessel will carry 3-4m3 of Corexit 9500A stored in 1m3 intermediate bulk containers (IBCs). An additional ~40m3 of Corexit 9500A will be staged and available at the supply base for use in vessel or aerial dispersant application. For larger spills that cannot be managed by resources on site, the IMT will escalate the response by cascading response equipment from the shore supply base or from ECRC for a Tier 2 incident and OSRL for a Tier 3 incident. Three additional vessel dispersant spraying systems are available from the ECRC response base in Dartmouth. These systems would be mounted on VOOs.

If aerial application of dispersants is implemented, B727 aircraft will be mobilized from OSRL in the UK. These aircraft can carry 15m3 of dispersants and would operate from Halifax Airport where fuelling and dispersant re-loading activities would take place. If additional dispersant capability is required, resources from the Global Response Network (GRN) would be sought. Should a well control incident occur for which the use of subsea dispersant injection is approved, the Capping and Containment Response Plan (CN001-HS-PLN-600-00005) will be utilized.


4.2.3 In-situ Burning Resource Inventory

In-situ burning (ISB) resources are available regionally and internationally through contracts and MoUs. Some, or all, of these will be activated, if authorized, during a spill response depending upon the severity and nature of the spill. If weather and sea state are favorable, strike teams using VOOs in the area will be established. These will deploy ECRC’s pyro-boom located at the Dartmouth response base. For larger spills that cannot be managed by resources on site, the IMT will escalate the response by cascading response equipment from OSRL and other BP global operations if necessary. OSRL has pyro-boom systems in Southampton (UK) and Singapore (Hydro Fire boom), as well as Fort Lauderdale (USA; American Fire boom).


4.2.4 Surveillance Resource Inventory

Resources for surveillance and spotting include BP owned iSphere satellite tracking buoys, which are stored on board each ERRV/PSV and the MODU and can be launched immediately following an incident. Additional resources available regionally and internationally through contracts and MoUs include satellite imagery, surveillance aircraft, airborne remote sensing, aerostats, UAVs and trajectory modelling. Some or all will be activated during a spill response depending upon the severity and nature of the spill.

For more details see Appendix 5: Resource Inventory.





4.2.5 Shoreline Response Resource Inventory

Resources for shoreline response include equipment available regionally and internationally through contract and MoU. Some or all will be activated during a spill response depending upon the severity and nature of the spill. ECRC provides Tier 2 equipment from the Dartmouth Response Centre, and if additional resources are required, from ECRC response centres in Newfoundland, Quebec and Ontario, as well as equipment from other RO’s, ALERT and PTMS. A Tier 3 incident would be supported operationally through the Global Response Network (GRN). Members include Western Canada Marine Response Corporation (WCMRC), Marine Spill Response Corporation (MSRC) in the USA, and Oil Spill Response Limited (OSRL) in the UK, Singapore, Bahrain, and USA. These organizations are able to provide subject matter experts and response personnel to support large-scale response activities or specific tactical needs.

For more details see Appendix 5: Resource Inventory.

4.3 Cascading Resources Acquiring and mobilizing additional response resources should a spill escalate into a sustained response may require cascading equipment from unplanned sources and/or exhaust immediately available inventories of expendable supplies. This may include human resource needs, manufacturing of expendable supplies, out-of-region resources, government-owned resources and international resources.

4.3.1 Response Personnel

Additional personnel resources for spill response may be procured by cascading from within BP via the MRT, detailed in Appendix 1 of the IMP, and through ECRC. ECRC has response centres with trained and experienced personnel in Ontario, Quebec, and Newfoundland that may be available. The certified ROs, ALERT in Saint John, NB and PTMS in Point Tupper, NS could also supply additional response personnel from the Maritimes. Additionally, Hess personnel can be requested to assist via the Hess Incident Support Manager.

4.3.2 Manufacturing of Expendables

Inventories of expendable resources (dispersants, fire boom, sorbents, personal protective equipment, etc.) may be replaced by manufacturers during the incident. ECRC maintains a current list of major suppliers for key resources.

4.3.3 Out-of-Region Resources

BP may request mobilization of spill response resources (skimming vessels, fire boom, dispersants, aircraft, etc.) from response contractors or other providers located in other regions of Canada. ECRC also has an agreement with the certified RO WCMRC in British Columbia. Resources may also be made available through this agreement if required.

4.3.4 Government-Owned Resources

CCG maintains an inventory of oil spill equipment including offshore containment and recovery equipment and vessels. If required, a request for a contract could be made at the time of the incident.





4.3.5 International Resources

OSRL maintains an inventory of oil spill equipment including offshore containment and recovery equipment, ISB equipment, a dispersants stockpile and dispersant application equipment. A current list of equipment is available on the website: http://www.oilspillresponse.com/activate-us/equipment-stockpile-status-report

OSRL may also supply response personnel that can be dispatched to offer support to BP in the event of an oil spill incident or a strong potential for an incident to occur. If a full response team is then mobilized, the technical advisor team will form part of the response team headcount.

The GRN is a forum for oil spill response organisations to improve their individual performance and effectiveness by fostering strong collaborative relationships amongst Members; establishing functional teams to exchange operating information, response techniques and share good practice; and assisting oil companies and other stakeholders to enhance industry standards for spill response. GRN Operational Teams comprise subject matter experts from key functional areas of response, and provide a forum for exchange of information. GRN maintains an inventory of dedicated response resources available worldwide from among the GRN Membership.

More information is available at http://www.globalresponsenetwork.org/index.htm

4.4 Specific Expertise BP maintains a roster of specialized oil spill response experts who are readily available and managed through the MRT. Additional technical specialists may be procured through the Standing Agreement with ECRC and OSRL who maintain current lists of advisors and specialized service providers. Subject matter experts and consultants who may be utilized include, but are not limited to:

a) scientific support (including hazard assessment and spill/air trajectory modeling); b) shoreline cleanup assessment technique (SCAT) specialists; c) wildlife protection experts.

4.5 Other Potential Resources

4.5.1 Vessels of Opportunity (VOO)

VOO Plan – ECRC maintains an “evergreen” list of local VOOs to supplement its response vessel resources and support specific spill response activities as necessary. This list may be accessed through the Standing Agreement with ECRC.

Typical categories of VOOs that may utilized include:

a) contracted maritime vessels (vessels already contracted, owned or operated by the responsible party, but not dedicated to spill response services);

b) dual-certified commercial vessels (vessels authorized and configured for quick conversion to skimming and oil storage operations);

c) public vessels (CCG, DFO);





d) commercial maritime vessels (platform supply vessels, offshore supply vessels, crew boats, commercial tugs or push boats, maritime construction vessels, lift boats, tank barges, and tank ships);

e) commercial fishing vessels;

f) private vessels.

The identified response activity, required support for that activity, and the operating environment will dictate which type of VOO is most appropriate. Considerations for VOO selection include, but are not limited to:

a) type of vessel required for the response function (size, storage, berthing, safety systems);

b) proximity to spill location or load-out port;

c) availability of above deck storage for response equipment (as appropriate);

d) availability and appropriateness of on-board tankage to contain the grade of oil being recovered;

e) sea keeping and weather related operational characteristics;

f) level of crew training required based on assigned activities.

VOO Training - In some cases, the VOO’s existing crew may be able to perform the requested activities. For more technically challenging operations, the crew will likely require additional training or may be supplemented by qualified Spill Response Operating Team personnel or other technical specialists.





Section

5 5 Unified Coordination BP’s incident management organization is based upon a tiered, scalable system illustrated in Figure 5-1. This structure is designed to co-ordinate an efficient, timely and effective response using teams based at the worksite, BP offices in Halifax and Calgary, and BP head offices in Houston and London where appropriate. The IMT has access to a global network of expertise to support response efforts and details of the tiered response system and activation are contained within BP’s IMP (CN001-HS-PLN-600-00002).

FIGURE 5-1: BP INCIDENT MANAGEMENT ORGANIZATION

Globally, BP utilizes the internationally accepted Incident Command System (ICS), as the company’s preferred incident management system (IMS). As a result, ICS has been adopted as the IMS that BP will use to manage events that arise from the Project as it is not only compatible with the system used by the Nova Scotia Emergency Management Office & Public Safety Canada Provincial Coordination Centre (PCC), but is expandable to suit the nature and scale of any incident. The structure also identifies that the





management of a large and complex incident will rely upon ‘Unified Coordination’ that incorporates the key response organisations and agencies.

For more details see Appendix 1: Roles and Responsibilities of Government Agencies.

Figure 5-2 below depicts the full BP ICS MRT structure and how it will align as part of a local Unified Coordination response. Appendix 1 of the IMP (CN001-HS-PLN-600-00002) details the process to follow when expanding the IMT and Section 4 of the IMP outlines the IMT roles and responsibilities.




Oil Spill Response Scotian Basin Exploration Project



A loss of well control with a release rate of approximately 36,000 barrels of oil per day has been taken as the event for developing the base case scenario for response planning, representing the worst case requiring the most extensive planning and capability.

Using a SIMA approach, the response planning uses results from both stochastic and deterministic model runs. The stochastic modelling was used to help determine the full geographic area for response. A worst case seasonal deterministic model run was used to help further define various planning criteria and for individual response techniques and capability. Additional modelling runs were conducted for additional sites and seasons to validate the assumptions of the primary modelling site. Details are presented in the project-specific SIMA (Project SIMA) and summarized in the sections below.

For more details refer to the Project SIMA – Sponson Group (2017). Spill Impact Mitigation Assessment in Support of BP Canada Energy Group ULC Scotian Basin Exploration (CN001-EV-RPT-600-00002).

6.3 Response Strategy and SIMA Summary for the Scotian Basin

The response strategy is the combination of different oil spill response techniques that are used in the event of a spill, at defined tier levels and indicative timeframes. The way in which these techniques are utilized, from the source of the spill to the shoreline, is often referred to as the “cone of response” (Figure 6-1). Zoning of the different response techniques allows the most effective overall response strategy to be developed, considering the conditions at the time. The strategy is based on the spill scenario(s) and is informed by a SIMA.

FIGURE 6-1: THE CONE OF RESPONSE





6.3.1 Spill Impact Mitigation Assessment (SIMA)

A SIMA (formerly Net Environmental Benefit Analysis, NEBA) is a structured, scientific and consensus-based tool used by BP to help select the most effective and feasible oil spill response option(s) that will yield the greatest benefit with the least net environmental and socio-economic effects.

The SIMA conducted for this project utilized stochastic modelling runs, based on the selected scenario, to help determine the full geographic area for response. A worst case seasonal deterministic model run was used to help further define various planning criteria and for individual response techniques and capability. Additional modelling runs were then conducted for additional sites and seasons to validate the assumptions of the primary modelling site. The results of the planning SIMA for this project are summarized below.

For more details refer to the Project SIMA – Sponson Group (2017). Spill Impact Mitigation Assessment in Support of BP Canada Energy Group ULC Scotian Basin Exploration (CN001-EV-RPT-600-00002).

Key considerations and operational limitations and assumptions identified in the Project SIMA include:

• The probability of some oil reaching Sable Island is high, if left untreated, with the shortest modelled time less than 4 days from the time of a release, based on stochastic modelling runs for untreated oil;

• The probability of oiling of shorelines on the Nova Scotia mainland is generally less than 5%; • Given the sea sates and weather conditions that exist in the Project area, Subsea Dispersant Injection

(SSDI) can be utilized for the highest frequency of time; • Aerial dispersant also can be utilized for a significant period of time. Vessel dispersant application,

being more weather dependent, is significantly reduced on how frequently it can be used; • Mechanical containment and recovery, even utilizing high-speed “sweep” systems, would still likely

have limited opportunities for use; • ISB would have considerable ‘down time’; • It is assumed that surface (vessel and aerial) application of dispersants could be initiated within 48-

hours of an incident (allowing time for regulatory review and approvals), and that SSDI operations would commence by Day 10.

It should be noted that, in the unlikely event of an actual spill, an incident-specific expedited SIMA will be conducted, with appropriate and stakeholder input (e.g. CNSOPB, Science Table), to confirm and/or modify the response strategy to reflect the specific circumstances at the time of the spill.





6.3.2 Response Strategy Summary

Based on the worst-case scenario, and informed by the considerations and limitations as presented in the SIMA, BP’s response strategy to a loss of well control event in this plan consists of:

• A comprehensive situational awareness (surveillance and monitoring) from many different platforms;

• A focus on mounting a timely, robust, continuous dispersant operation offshore initially using vessels, followed by the use of aerial platforms and then subsea delivery;

• Implementation of booming tactics (containment & recovery, ISB, shoreline protection) when conditions permit – both offshore and nearshore;

• A robust oiled wildlife response, including measures to keep wildlife from the oil to the extent practical;

• An effective shoreline response and waste management strategy planned and executed in conjunction with affected/likely to be affected jurisdictions.

A decision guide is provided in Figure 6-2 and indicates the progression of decisions and considerations used to select the most appropriate response options and develop an overall strategy for the response.





FIGURE 6-2: SPILL RESPONSE STRATEGY DECISION GUIDE







dispersant based on the incident-specific SIMA and dispersant operations plan submitted at the time of the incident. BP will submit a dispersant use request to the CNSOPB as indicated in section 2.4 of the Surface Dispersant Application TRP (Annex B).

6.5 Tactical Support Activities

6.5.1 General Overview

When developing a response strategy (or strategies), the associated tactical support activities must be identified and included in each strategy. The most common tactical support activities include spill surveillance, and simultaneous operations (SIMOPS). Descriptions of these support activities are provided below and include how they are used to enhance the effectiveness and/or safety during the implementation of a tactic.

6.5.2 Spill Surveillance

Upon discovery of a spill, satellite tracking buoys will be launched from the ERRV, PSVs, and/or MODU, as appropriate and available. Buoys should be launched as near to the leading edge of the spill as is safe and practical to do.

During daylight hours, initial spill surveillance activities will be provided by any available offshore support vessel(s) unless otherwise engaged with safety support at the asset. Vessel based surveillance activities will remain in place until aerial surveillance is established.

When notified of an oil spill incident the IMT will request Provincial Airlines or Transport Canada to re-task the nearest available contract aircraft (within operational and safety limits) to provide the oil spill verification and assessment. Further and on-going aerial surveillance flights will be planned according to the incident requirements and flight scheduling roster, as coordinated through the Air Operations Branch.

Trajectory modelling will be initiated through the Environmental Unit (see Section 2.5.3 of this document). Satellite imagery data may be commissioned through OSRL or through government agencies.

For response resources information, refer to Appendix 5: Resources Inventory.

Specifically, spill surveillance will be used to:

a) validate spill movement trajectory analysis, and provide updated data for analysis;

b) determine the spilled oil’s characteristics;

c) aid in locating the greatest accumulations of oil;

d) provide an aerial view of some aspect of the response;

e) assess shorelines for pre-cleaning or pre-existing oil (baseline).

Depending on the size and complexity of an incident, the IMT may assign an Air Operations Branch as part of the Operations Section. The Air Operations Branch is tasked to coordinate aerial support based on operational needs. The Air Operations Branch Director is responsible for addressing response considerations including flight authorisations and restrictions, air clearances, government support, aerial logistics and operational constraints (e.g., weather, visibility). Operational assignments will be





documented in an ICS-220 Air Operations Summary form and included in the IAP. All air operations must follow the Site Safety Plan and additional emergency procedures specific to the operation.

Communications for vessel and aerial support will be coordinated with the Logistics Section/Communications Unit and documented in the Communications Plan. There may be the need to establish aerial and marine exclusion zones for reasons that may include the following: to grant full geographical access control to the IMT, maximising response operations using platforms in the area; to prevent secondary contamination of vessels and areas as vessels transit through the affected area. Aerial exclusion zones are established by the Civil Aviation Safety Authority and requesting NOTAMs be put in place. The Canadian Coast Guard will be contacted to request the same for marine operations.

6.5.3 Simultaneous Operations

Simultaneous operations (SIMOPS) refers to conducting two or more operations at the same time, in the same place (or immediately adjacent), where there is potential for interaction and conflict between the multiple operations. Simultaneous operations may result in potential safety hazards, logistical conflicts, operational conflicts and /or the need to schedule activities in a certain order. For the purposes of oil spill response planning, SIMOPS involves multiple concurrent activities such as, but not limited to, source control operations (i.e., well containment), subsea dispersant application, in-situ burning, surface dispersant application, and mechanical recovery. SIMOPS includes multiple entities and multi-disciplined workforces engaged in a wide variety of 24-hour activities.

The SIMOPS function, accountable to the Ops Section Chief will:

• Track operations activity; • Ensure that simultaneous operations are conducted in a safe manner; • Liaise closely with marine and aviation functions in the IMT in preparing SIMOPs plans; • Advise marine and aviation parties of the rules and policies regarding SIMOPS.

If required, a SIMOPS Plan will be developed for the incident. The potential elements of the SIMOPS Plan may include, but are not limited to:

a) general roles and responsibilities of SIMOPS positions onshore and offshore;

b) SIMOPS facilities and contact information (both onshore and on-scene);

c) specific role and responsibilities of the SIMOPS Group Supervisor, Offshore Vessel Control SIMOPS Task Force Leader, and any other designate positions;

d) SIMOPS Area boundaries (size, description and charts/diagrams);

e) communication procedures in the SIMOPS Area;

f) acoustic frequency management and position referencing for subsea objects and operations (e.g., ROVs, tools, wet storage items);

g) check-in/check-out procedures for the SIMOPS Area;

h) metocean limitations for major activities including severe weather operating and evacuation procedures;





i) SIMOPS Daily Operations Action Schedule (master activity tracking tool for vessels working in SIMOPS area as well as vessels in stand by status and in staging area);

j) figures, tables and illustrations that show examples of SIMOPS vessel tracking, communications plan, daily operations schedule, SIMOPS boundary area;

k) required forms or work plan templates.

A SIMOPS situation status display will be used to display subsea equipment, vessel and aircraft locations, and track the status of all concurrent operations. This information will be updated (real time or periodically) as well as accessed, viewed and/or communicated to external parties (e.g., technical specialists).

6.6 On-Water Response Tactics

This section identifies and describes the primary on-water tactics that BP will consider for implementation when responding to offshore oil spills and includes decision guides where applicable. The information included in this section is intended to introduce each tactic and aid in the selection of the most applicable and effective option(s); the detailed TRP must be referred to for implementation of a tactic.

The primary on-water response tactics include, but are not limited to:

1. Monitored natural attenuation;

2. Mechanical containment and recovery (see Annex A: Offshore Containment and Recovery TRP);

3. Surface dispersants (see Annex B : Offshore Surface Dispersant Application TRP);

4. In-Situ Burning (see Annex C: In-Situ Burning TRP).

6.6.1 Monitored Natural Attentuation

Monitored natural attenuation involves periodic aerial or vessel surveillance of the floating oil to confirm its location, that its volume is steadily decreasing, and that it is not threatening any sensitive areas. During inclement weather or sea state conditions, this may be the only feasible response option (refer to Table 6-3: Time- and Conditions-Related Windows of Opportunity Descriptions). Monitored natural attenuation may also be appropriate for smaller spills that will not affect sensitive areas or pose a significant threat to the environment, including sheens or residual floating oil that may remain after other operations are complete.

It will be necessary to provide vessel and/or aircraft assets to monitor the progression of natural attenuation of the floating oil. Accurate documentation of location, size, and appearance of the oil slick is needed to provide an estimate of the remaining volume. Only trained observers will conduct the monitoring and the results of each successive monitoring event will be compared to the previous to demonstrate the oil is dispersing naturally. If vessels are used, samples of the remaining floating oil may need to be collected and analyzed to confirm the oil is dispersing naturally. As this tactic is essentially the same as conducting spill surveillance, refer to Section 6.6.2 on spill surveillance for additional tactical guidance.






6.6.2.2 Containment and Recovery Tactics

Offshore containment and recovery tactics use various types of mechanical devices, including boom and skimmers, to collect, contain and recover oil from the sea surface that has been located by surveillance. For this project, high-speed MOS sweep systems will be used. Recovered oil is temporarily stored in support vessel in-built tanks, on deck storage containers or floating storage units. Spreading, sea state and weather conditions may decrease the effectiveness of these mechanical recovery methods; therefore, on water recovery activities rely on the Surveillance Group providing oil monitoring and targeting services direct to in-field recovery vessels.

The main objectives in using offshore containment and recovery is to remove as much oil from the surface of the water as soon as possible:

• to collect close to the spill site while oil slicks are recoverable and have not spread; • to minimize the migration of the oil by containing and recovering at sea; • to reduce shoreline habitat damage; • to reduce offshore wildlife impact.

On-water mechanical recovery can be hampered by weather restrictions, limitation to daylight operations, time required for deployment, and relatively low operational efficiency. Although there will be recovery vessels in the area available to assist with the immediate response, these vessels will have a limited recovery capability. Thus, there will be a lag time from the time of the spill to the time of conducting on-water mechanical recovery on a large scale, reducing the window of opportunity to conduct on-water mechanical recovery. Once additional equipment has been deployed from the Halifax supply base, the low encounter rate and need to dispose of captured oil limit the effectiveness of this technique. Beyond the encounter rate limitations, typical wave heights are a key consideration in the Scotian Basin. For example, open water booming with associated oil skimming operations begins to fail in sea states with waves over approximately 2m. However, equipment capable of functioning in high sea states will be available and deployed during an actual spill. In the Scotian Basin area, wave heights typically exceed this operational limit during winter season. Even when sea states are conducive to on-water mechanical recovery operations, these techniques typically recover no more than approximately 10 percent of the oil spilled in open ocean environments. During the Deepwater Horizon (DWH) response in which wave height was seldom restrictive, less than 5% of the oil released was estimated to have been removed (Federal Interagency Solutions Group, 2010). Despite the logistical and operational limitations to the effectiveness of mechanical recovery in these scenarios, it remains a desirable response option since it is the only method that physically and immediately removes oil from the environment. For that reason, mechanical recovery equipment will be maintained on site and on the shore, and will be used in the event that weather conditions are favorable.





Overall containment and recovery operations will be managed by the onshore IMT, while a “command vessel” on site coordinates the field activities and reports back to the IMT. For all operations (aerial, vessel) the priority will be to target oil slicks close to the source where slicks are thicker and to prevent spreading. In the event of an incident, the initial containment and recovery will be conducted by BP contracted vessels fitted with pre-staged equipment that are assisting with drilling operations. Additional vessels will be fitted with BP and/or ECRC sweep systems, and cascading equipment from the ECRC response bases in Dartmouth and/or St. John’s, and/or OSRL, as required. These additional systems would be outfitted on VOOs at the time of the incident.

In the offshore environment, weather is a major factor in conducting any aerial or marine operations. Both safety and operational limitations of the equipment will be affected by sea state and weather. All containment and recovery operations will be conducted during daylight hours (approximately 12 hours in summer and 8 hours in winter). Mechanical recovery equipment should not be deployed in wind speeds exceeding 15m/s (30kts), wave heights exceeding 3m (10ft), or in visibility less than 1nm. Air monitoring must also be conducted to ensure the safety of responders.

For a detailed description of the implementation of this tactic, refer to Annex A: Offshore Containment and Recovery TRP.

6.6.3 Surface Dispersants

6.6.3.1 Surface Dispersants Tactical Decision Guide

The following decision-tree (Figure 6-5) is provided to guide responders through the decision-making process for using surface dispersants.





FIGURE 6-5: SURFACE DISPERSANT APPLICATION DECISION TREE





6.6.3.2 Dispersant Use and Tactics

Surface Dispersants Application Dispersants are applied to oil slicks to reduce the size of oil droplets. These droplets are dispersed into the water column (typically in the upper 0-10m for surface application) by wind and wave energy where their smaller size results in an increase in the rate of biodegradation and other weathering processes. The goal of dispersant use is to reduce the amount of oil on the ocean surface, thereby reducing impacts to sensitive near-surface biota and to shorelines.

The limitations on effectiveness of surface dispersant application in the Project Area are primarily related to weather, and the conditions in which aircraft or spray-vessels can be used safely. Aerial application requires daylight and good visibility, while vessel-mounted spray brooms require a safe sea state. High wind, wave conditions and water temperature not only affect the safety of surface dispersant operations, but also the efficacy of dispersants. At wave heights above 4m, breaking waves entrain oil in the water column and prevent appropriate interaction between the oil and the dispersant. A calm sea state is also not appropriate for effective dispersant use.

All dispersant application operations will begin only when and if approval is received from the CNSOPB following an expedited incident specific SIMA submitted to CNSOPB as part of the approval request package. All “in field” support vessels will have a dispersant test kit to conduct sampling and dispersant efficacy testing prior to any application of dispersants (The dispersant test kit consists of small bottles filled with oil and sea water where dispersant is added at the appropriate ratio. Efficacy is determined visually once the oil/dispersant mixture is shaken. If dispersion is observed during this simple test, BP will proceed with a vessel test spray (if approved by CNSOPB) before proceeding with dispersant operations).

For all dispersant application operations (aerial, vessel), the priority will be to target oil slicks moving in the direction of:

1. Sable Island; and

2. Nova Scotia shoreline.

Other areas can also be prioritised for the application of dispersants; for example, oil slicks moving in the direction of protected areas and/or critical habitat. Exact priorities will be determined at the time of an incident with stakeholder input, as available.

In the event of an incident, the initial application of dispersants will be conducted by the support vessels (ERRV/ PSVs) assisting with drilling operations. Dispersant spraying systems and dispersants will be pre-installed on each vessel. Each vessel will carry 3-4m3 of Corexit 9500A stored in 1m3 IBCs. If additional capacity is required, one additional BP-owned spraying system will be available at the shore supply base to be mounted on a fourth vessel or a VOO.

For larger spills that cannot be managed by resources on site, the IMT will escalate the response by cascading response equipment from the shore supply base or from ECRC and OSRL. Three additional vessel dispersant spraying systems that can be mounted on VOOs will also be available from the ECRC response base in Dartmouth. If aerial application of dispersants is implemented, B727 aircraft will be mobilized from OSRL in the UK. These can carry 15m3 of dispersants and would operate from Halifax Airport where fuelling and dispersant re-loading activities would take place. If necessary, additional aerial resources can be obtained from the US and other sources through the Global Alliance.





All surface dispersant application operations will be conducted during daylight hours (approx. 12 hours in summer and 8 hours in winter).

BP has a total stockpile of 50m3 of Corexit 9500A dispersant in Nova Scotia. Approximately 10m3 of dispersant is on the vessels, with a stock of ~40m3 available at the shore supply base to re-supply vessels and/or aircrafts in the event of a spill. This stockpile is stored in 1m3 totes. Assuming a 1:20 application ratio, this supply of dispersants can be used to treat a spill of 1000 m3 of oil. If additional dispersants are required, they will be procured from global stockpiles in the UK, USA and Brazil.

For a detailed description of the implementation of this tactic, see Annex B: Offshore Surface Dispersant Application TRP.

Subsea Dispersant Injection (SSDI)

SSDI is used to inject dispersant directly into the flow of subsea oil released from a fixed point(s). SSDI operations are conducted from a vessel that contains the delivery system and storage for dispersants. As with surface application, SSDI of dispersants will only be conducted with approval from the CNSOPB after submittal of an incident-specific SIMA and a SSDI Operations Plan.

Prior to capping stack deployment, dedicated remotely operated vehicles (ROVs) are used to oversee the operation, deploy injection equipment, and assist in monitoring to ensure dispersant efficacy. Dispersant efficacy will be determined visually and the results used to re-adjust the dispersant to oil ratio as needed. ROVs will also monitor flow rate, with the potential for source-sample collection. Additional capabilities, including as a platform for more specialized cameras and other instrumentation, would be determined based on the specific nature of an incident. Configuring and loading a vessel to support SSDI takes several days, but once deployed SSDI operations are less sensitive to weather than other response methods, and can continue 24 hrs per day.

In general, the same chemical dispersion principles apply with a few key distinctions. With SSDI, the encounter rate is extremely high because the dispersant is being applied directly to the oil source as it is released from the sea floor. Because of the high encounter rate, an initial dispersant-to-oil ratio (DOR) of 1:100 should be targeted, then adjusted (up or down) based on real-time monitoring to optimize efficiency of the response option (API, 2017; Brandvik et al., 2014; IPIECA, 2015a). The lower subsea DOR of 1:100, compared to surface DOR of 1:20, means that less dispersant is required for SSDI versus surface dispersant application. Because the injection is occurring at the sea floor, the dispersed oil will dilute vertically and horizontally with a much greater volume of water. Rapid dilution equates to lower concentrations of dispersed oil than those typically measured after a surface application (where the dispersed oil is typically limited to 10m of vertical dilution). During the DWH spill event, measured dispersed oil concentrations at about 1 km distance from the well head and 1,200m depth were consistently below 1 ppm.





SSDI use offers several unique benefits when compared to other response methods. Chief among those are improved worker safety, higher oil encounter rates, lower dispersant DORs, lower sensitivity to weather conditions, no daylight restrictions, and the ability to operate somewhat continuously. During the DWH response in 2010, SSDI was observed to reduce the size and thickness of surface slicks, and reduce VOC levels at the water surface. This lowers the risk to workers in the immediate release area by reducing the potential for fire and explosions, and reducing inhalation risks for volatile hydrocarbons. Ultimately, SSDI allows workers to more effectively engage in well capping and source control operations. Since most of the SSDI operations are carried out by ROVs at the sea floor, the potential for workers to be exposed to oil, dispersants, and dispersed oil is also lower than for most other response methods.

Once SSDI vessels and equipment are in place, dispersant injection operations can run continuously in much higher sea states than ISB (limited to < 1m) or mechanical recovery (limited to < 2m). Vessels are still needed to support dispersant resupply and pumping. In the Scotian Basin region, metocean conditions will hamper SSDI sea surface logistics in sea states above 5m.

Public perception of SSDI is often negative due to misunderstandings about dispersed oil fate and transport. Since oil is dispersed into the water column and cannot be readily seen, the public may incorrectly assume that the oil is sinking rather than dispersing and will surface in the future. However, during the DWH response, continuous sampling and monitoring at thousands of locations failed to detect the presence of undispersed subsea oil slicks (OSAT 2010), which demonstrates the benefits of SSDI to effectively disperse oil.

For a detailed description of the implementation of this tactic, see the Cap and Containment Response Plan (CN001-HS-PLN-600-00005).





6.6.4 In-Situ Burning

6.6.4.1 In-Situ Burning Tactical Decision Guide

The following decision-tree (Figure 6-6) is provided to guide responders through the decision-making process for using in-situ burning.

FIGURE 6-6: IN-SITU BURNING DECISION TREE

6.6.4.2 In-Situ Burning (ISB) Use and Tactics

Offshore in-situ burning will remove surface oil slicks through combustion of oil vapours generated by heat from fire. This will produce a significant smoke plume mainly composed of CO2, water and soot. ISB may eliminate significant quantities of oil in a relatively short period of time.

The decision to use ISB is dependent on the feasibility under existent environmental conditions at the time of an incident. Reductions in air quality due to gases and particulate material may be a concern in some jurisdictions (if there are populated areas nearby) and ISB creates limited by-product burn residues that can sink into the ocean and cannot be recovered. ISB has many of the same limitations that on-water mechanical recovery has with respect to speed, weather, and daylight. Oil must first be collected using





vessels and booms so the encounter rate is relatively low. In addition, specialized “fire booms” must be used, which are fire resistant booms designed for ISB operations.

In this region, the most significant limitation is wave height. ISB is more sensitive to wave height than on-water mechanical recovery since the booms must concentrate oil to a much greater thickness to burn and this wave action is disruptive to combustion. Effective ISB requires wave heights typically below 1 m and wind speeds below 20 knots (IPIECA 2016), conditions that rarely exist in this Project Area. On-water ISB has been used once as a response method, for the DWH incident, on sea states that were essentially flat, and yielded a recovery rate of approximately 5% (Federal Interagency Solutions Group 2010).

Prior to initiating ISB, BP will advise the CNSOPB. BP understands that the CNSOPB may solicit advice from the Science Table. Unless explicitly advised to halt the ISB by the CNSOPB, BP will proceed with ISB operations if it is determined to be an effective and feasible option for the specific incident. ISB operations will be managed by the onshore IMT. The priority will be to target oil slicks moving in the direction of:

1. Sable Island; and

2. Nova Scotia shoreline.

If weather and sea state are favorable, up to 3strike teams using VOOs in the area may be established. These would primarily deploy ECRC’s pyro-boom located at the Dartmouth response base. For larger spills that cannot be managed by resources on site, the IMT will escalate the response by cascading response equipment from OSRL and other BP global operations if necessary. OSRL has pyro-boom systems in Southampton (UK) and Singapore (Hydro Fire boom), as well as Fort Lauderdale (USA; American Fire boom).

Each ISB strike team requires 2 boom tow vessels, 1 command and monitoring vessel, 1 igniter/safety small craft and 1 spotter aircraft. It is important to remember that pyro-booms are considered to have a limited life expectancy of 2 to 3 burns. Thorough inspection of equipment will be conducted prior to any burn being conducted. At sea, containment and recovery activities may also be necessary to recover any burn residues on the water surface. All ISB operations will be conducted during daylight hours (approx. 12 hours in summer and 8 hours in winter). Environmental sampling and monitoring of air emissions will also be implemented to ensure responder health and safety and to document potential environmental impacts

For a detailed description of the implementation of this tactic, see Annex C: Offshore ISB TRP.

6.6.5 Sensitive Area and Shoreline Protection

The Shoreline Response Program (SRP) provides a comprehensive spill management approach to shoreline response, from the planning and preparedness stages through to the initiation of a response and the completion of shoreline assessment and treatment operations. The SRP is a part of the Environmental Unit of the IMT.

The SRP is activated at the beginning of a spill incident to provide strategic planning and recommendations for shoreline protection, treatment and operational closure. The SRP clearly defines the roles and responsibilities of the spill management team and the actions that must be taken to activate a rapid response to potential shoreline oiling. Responding rapidly to oil that has reached shorelines is critical for minimizing risk to resources, including a wide range of organisms, many of which have limited mobility. Key implementation tactics of the SRP includes:





• The SRP focuses on strategic planning for shoreline response.

• The SRP works within or closely with the Environmental Unit (EU) to develop the decisions that define the shoreline response and with the Operations Section (OS) to understand and implement those decisions.

• These decisions are developed, to a large degree, based on data and information generated by the SCAT Program field surveys.

• The focus of the EU is on the decision process that addresses environmental and cultural resource issues and on achieving consensus within the IMT and with stakeholders regarding decisions that define the shoreline response objectives, priorities, constraints, good practices, and end points.

• The focus of the SRP is to (a) generate information and recommendations for the EU on shoreline protection and treatment issues, (b) create Shoreline Treatment Recommendations (STRs) as part of the Shoreline Response Program Plan for shoreline segments that do not meet the treatment endpoint criteria, and (c) liaise with and support Operations to ensure that the STRs and the Plan are understood and implemented.

For a detailed description of the implementation of this tactic, see Annex D: Shoreline Response Program.

6.7 Monitoring & Sampling Activities

An important part of the on-water response tactics is monitoring and sampling (M&S) to evaluate the effects on the environment, and to inform decision-making within the ISC. M&S activities are related to the measurement of environmental (physical, chemical, biological) parameters in specific areas of the response zone(s). This typically includes documenting the character, location, and/or behaviour of natural or introduced elements in the environment and provides important information to support safety, resourcing, response techniques, and communications.

BP’s approach provides a clear framework to accommodate a range of response scenarios and the associated M&S activities. As incidents evolve, the M&S will naturally shift, however BP will employ a First Strike Monitoring Plan (FSMP) to address early phase needs. In a specific response scenario, this framework is used to guide the overall M&S approach and aims to:

• Describe the rationale for specific M&S activities; • Identify individual M&S plans; • Provide linkages between M&S activities and ICS teams; • Set expectations about the intended use and audience for M&S outputs; and • Provide the First Strike Monitoring Plan (FSMP) for this specific location/incident.

For a detailed description of the M&S activities including the FSMP, see Annex F: Monitoring & Sampling Framework.





Section

7 7 Wildlife Protection and Rehabilitation Any incident releasing product into the marine environment has the potential to negatively impact wildlife. The Scotian Shelf and Slope provides habitat for a wide variety of species and large numbers of birds, marine mammals, terrestrial mammals, and reptiles. As such, rapid establishment of the Wildlife Branch and the immediate implementation of wildlife response actions are in the best interest of both mitigating the impact to wildlife and responding to oiled animals through capture and rehabilitation.

As a stand-alone plan, the BP Scotian Basin Wildlife Response Plan CN001-HS-PLN-600-00004, has been developed to provide specific guidance and strategies to effectively manage the wildlife response. The wildlife response plan includes information and procedures regarding all aspects of wildlife response including:

• an incident management system for oiled wildlife response that is fully integrated into BP’s oil spill response command structure;

• the function and structure of an effective professional oiled wildlife response; • essential information regarding procedures to be implemented immediately after a release

potentially impacting wildlife; and • data and procedures that will facilitate the assessment of a situation, the identification of response

options, and decision-making.

The timeliness of initiating wildlife response is critical to success of the effort. Within the initial few hours of an incident where wildlife impacts might be anticipated, the Operations Section will establish the Wildlife Branch. Numerous actions will be initiated in the first 24 hours to ensure an effective and successful wildlife response. These include, but are not limited to:

• establishing the Wildlife Branch under the Operations Section of ICS; • reporting the incident to wildlife regulatory agencies, both federal and provincial; • activating a designated professional Oiled Wildlife Response Organization (OWRO); • completing the initial Resources at Risk (ICS 232).

Once the Wildlife Branch is operational, it can then begin coordinating response actions and strategies as specified in the BP Scotian Basin Wildlife Response Plan (CN001-HS-PLN-600-00004). For detailed information refer to the BP Scotian Basin Wildlife Response Plan CN001-HS-PLN-600-00004.





Section

8 8 Waste Management Oil spills to the marine environment can generate significant amounts of oily waste that need to be collected and disposed of properly, in accordance with all applicable laws and regulations. BP has developed an Oil Spill Waste Management Plan (OSWMP) as Annex E of this OSRP to address the following objectives:

• identify all potential sources and understand the character of all wastes associated with oil spill response activities within the Scotian Basin Region;

• align the OSWMP with Canadian and Nova Scotian regulatory requirements and BP Group Practices; • provide a framework for incident-specific spill plans to manage waste, as far as practicable, under the

waste management hierarchy and treat waste close to its source of generation; • identify potential waste management facilities, including third-party facilities, that are Approved to

receive wastes; • assign responsibilities and define the required resources for implementing the OSWMP, and describe

the verification and monitoring measures that are required.

The OSWMP provides the framework for contingency planning and response preparation for waste management activities associated with the clean-up operations for a potential oil spill resulting from exploratory drilling within the Scotian Basin. As a Tactical Response Plan, the OSWMP provides the details as to how recovered oil and other wastes will be segregated, classified, stored, and shipped for treatment and/or disposal after recovery.

Specific details provided in the OSWMP include the types of waste expected to be generated, analytical requirements for characterizing the waste, waste segregation procedures, storage and handling procedures, equipment requirements, requirements for temporary storage sites, waste documentation and tracking, transportation requirements, temporary handling sites, and the location of approved facilities for final treatment /disposal of various solid and liquid waste streams. Because waste disposal is primarily a provincial responsibility, the OSWMP reflects the waste management practices and procedures applicable in Nova Scotia, including a range of recycling or re-use options.

For detailed information refer to Annex E: Oil Spill Waste Management Plan.





Section

9 9 Decontamination and Demobilization

9.1 Decontamination The overall objective of decontamination is to minimize worker exposure and limit secondary contamination through the spread of oil to uncontaminated areas.

In the event of a spill, an incident-specific Decontamination Plan will be developed by BP to be appropriate with the nature and extent of the spill. The Decontamination Plan describes the general strategies for decontaminating personnel and small equipment at localized decontamination facilities during on-going response operations; decontamination must be coordinated with Site Safety Plan requirements. A separate plan may be required to describe larger-scale decontamination facilities and procedures for major equipment (vessels, barges, storage tanks, skimmers, boom, etc.) at designated locations, often performed as part of demobilization.

Prior to implementation of the Decontamination Plan, BP will engage with the relevant regulatory agencies dependant on where decontamination activities will occur to ensure acceptance of the proposed plan (e.g., CNSOPB, CCG, TC, ECCC, Nova Scotia Environment, Port Authorities, etc.). The Planning Section will support development of the Decontamination Plan with input from Operations and Logistics. Templates for a Personnel and Equipment Decontamination Plan and for a Vessel Decontamination Plan are included in Annex G.

The decontamination procedures will depend on the type and volume of oil that has been spilled, and the type of equipment used during the clean-up operation. Regular decontamination during the response is necessary for the personnel involved with direct clean-up efforts, the vessels involved in the response, and a wide range of spill-related equipment. BP’s spill response contractors will follow guidance (such as available through OSRL) for decontamination operations to facilitate proper decontamination through the duration of the clean-up effort. Below is a summary of decontamination procedures for personnel, equipment, and vessels.

9.1.1 Personnel

Personnel who are involved in clean-up activities that have direct contact with oil will be equipped with appropriate personal protective equipment (PPE) to protect them from contamination. Specific areas that are designated “dirty” and “clean” will be established to organize personnel who are in the process of suiting up or decontaminating. A sequential decontamination process will be established for all personnel to follow.

Fluids generated during the decontamination process must be collected as oily waste and will be added to the spill waste management storage. Any solid waste generated must be segregated and disposed of per approved procedures. Personnel may reuse PPE, but dirty PPE must be kept in a specific area where it





can be recovered when personnel returned to cleaning tasks. Any discarded PPE must be put in the segregated garbage bags.

9.1.2 Equipment

The decontamination of equipment must take place in designated areas. A dry cleaning of equipment may take place depending on the level of oiling and potential re-use of equipment. If equipment is washed with fluids, the fluid must be collected because it is classified as oily waste, and specific regulations apply to its disposal. For this reason, pressure washing and steam cleaning should generally be avoided because these processes generate significant amounts of oily waste.

Equipment such as skimmers and hoses that are not being used and are awaiting decontamination, should be stored in such a way that any oil dripping from the equipment is captured. This can be achieved by storing such equipment in dedicated containers designed for this purpose, which are stored on the deck of the vessel.

Upon completion of the clean-up effort, all equipment must be cleaned thoroughly so that the equipment is ready for subsequent use. Following dry-cleaning on deck of the vessel, equipment is typically transported to shore. Equipment may need to be wrapped or otherwise protected during transportation to prevent secondary oiling. Onshore, equipment will typically be steam cleaned or pressure washed, and all fluids will be collected and handled appropriately. It is important to minimize the potential for secondary oiling and secondary waste, so cleaning should be undertaken as close as possible to the receiving onshore area.

9.1.3 Vessels

Vessels involved in the spill response will be exposed to oil in varying degrees, depending on the role of the vessel in the clean-up effort. Vessels may receive an initial decontamination (pre-wash) in the field if the oil poses a hazard or the vessel must return to port. Criteria for varying levels of decontamination procedures will be identified based on operational needs. Special hull cleaning techniques may also be needed if recreational or fishing boats with wood or fiberglass hulls or decks are contaminated.

As vessels complete operations or are identified for demobilization, they must be thoroughly cleaned in accordance with regulatory requirements. When clean-up takes place in a harbour, contaminated vessel(s) will be managed based on several factors, including severity of contamination.

For detailed information refer to Annex G: Decontamination and Demobilization Plan.

9.2 Demobilization

9.2.1 General

In the unlikely event of a spill, an incident-specific Demobilization Plan will be developed by BP to be appropriate with the nature and extent of the spill. The demobilization and repatriation of resources shall be conducted in accordance with the Demobilization Plan developed by the IMT for all OSR resources utilized on the oil spill. Resources will be demobilized in accordance with priorities and procedures set by the Incident Command.

As the response transitions from emergency response phase to a planned recovery effort, the demobilization of incident resources must be conducted in an efficient and safe manner and shall not interfere with ongoing incident operations.





All incident Unit Leaders are responsible for identifying surplus resources, receiving approval by the Section Chief, and submitting lists to the Demobilization Unit Leader.

The Incident Commander will approve the demobilization of critical resources identified by command staff prior to demobilization from the incident. Those resources shall be identified daily in the daily operational period planning cycle. All releases from the incident will be initiated in the Planning Section, Demobilization Unit after Incident Commander approval.

9.2.2 Demobilization Plan

Once an incident has stabilised and operations are being completed, a decision will be made to commence demobilization of resources (personnel and equipment) as appropriate. An incident specific Demobilization Plan will be developed incorporating guidance from regulatory authorities and the Resource Unit Lead, Operations, Logistics and Legal. The Resource Unit will then coordinate demobilization of resources in accordance with the approved Demobilization Plan. A template for a Demobilization Plan is included in Annex G.

9.2.3 Check-out Procedures

9.2.3.1 Equipment

The check-out procedures for equipment upon demobilization include:

a) final decontamination inspection; b) turning-in small equipment and unused supplies; c) equipment inspection; d) final repairs; e) returning equipment to rightful owners; f) damage settlement process; g) final storage of purchased equipment and supplies.

9.2.3.2 Personnel

The check-out procedures for personnel upon demobilization include:

a) require debriefing to ensure critical information is recorded; b) ensure turn-in of documentation and equipment; c) ensure downloading of spill response information from personal computers; d) describe any policy concerning the passing of spill related information to unauthorized sources; e) describe individual personnel check-out forms and process (refer to IMP Appendix 10: Demobilization

Process).

For detailed information refer to Annex G: Decontamination and Demobilization Plans.





Section

10 10 Claims Management In the unlikely event of a spill, the Finance Section Chief, following consultation with the Business Support Team Leader, will activate an emergency response claims process by contacting BP’s global claims management contractor, KPMG (see below for the KPMG contact and Alternates). KPMG will work with Crawford & Company (insurance claims manager) to coordinate the claims management process.

The Finance Section Chief should provide the following information to KPMG:

• Provide details of incident to include: a) Date and time of the incident b) Business and location (country, province / territory, and / or city) c) Description of incident, parties impacted, and extent of impact to parties impacted

• Provide contact information for the Finance Section Chief and/or Deputy

KPMG will coordinate with Crawford to:

• Initiate the process to establish a toll-free claims reporting telephone number for the incident • Establish a Claims Call Center for to manage claims reporting • Provide claims handling, management and reimbursement processes • Manage information requests and reporting, including distribution and frequency

The Finance Section Chief or Deputy will communicate the telephone number to be utilized to report claims to the Situation Unit. This number will be prominently displayed in the Incident Command Post.

The Finance Section Chief or Deputy may coordinate with KPMG, the Information Officer, Liaison Officer and Legal to determine procedures for publication of the claims reporting telephone number to the general public.

The Finance Section Chief or Deputy will facilitate establishment of an incident specific Claims Response Plan.

TABLE 10-1: KPMG CONTACTS





Section

11 11 Incident Termination and Debrief 11.1 Termination of the Incident Termination of response will be determined by the IMT in collaboration with government agencies. Considerations for terminating a response include:

a) sensitive areas are no longer threatened; b) no recoverable oil remains on the water; c) only residual, immobile oil remains on the shorelines; d) shoreline cleanup endpoints have been met.

Termination will identify the last Operational Period for planning purposes. The incident site will return to normal management and business activities. At termination, the IMT will be deactivated and turn in all equipment and documentation.

11.2 Transition to Project Team(s) After spill response activities have terminated, additional activities may continue for some time. These may include investigations, legal challenges, financial claims, restoration, long–term monitoring, and human resource activities. BP may establish a project team (or teams) to continue long-term incident-related activities.

11.3 Response Debrief/Critique After incident termination, the Incident Commander will initiate an evaluation of the response. This evaluation is focused on how the response was managed, not the cause of the incident. All appropriate personnel and external responders that participated in the response may be asked to contribute to the evaluation through a formal or informal lessons-learned briefing.

The evaluation may include, but is not limited to:

a) general site characterization information; b) description of incident type and circumstances; c) immediate emergency actions undertaken; d) notification and alert; e) organization and efficiency of Incident Management Team; f) resources utilized and their efficiency; g) lessons learned.





11.4 Incident Final Report A final report of the incident will be developed for internal use. The final report will capture all incident documentation and information from response evaluations.

The final report may include, but is not limited to:

a) initial event summary; b) key response activities; c) response resource use and efficacy; d) summary of lessons learned; e) recommended improvements in response planning or preparedness; f) financial impact analysis; g) legal impact analysis; h) future operational or business recommendations.








12.3 Exercise Program

The Exercise Program helps to ensure that the Training Program has been effective and that personnel are well prepared to respond to an incident. It also helps to test the plans and the procedures that are in place and provides an opportunity to correct any shortfalls before an incident occurs. Large scale exercises bring together responders in various roles and from various agencies, including regulatory agencies, support agencies, contractors and subject matter experts. This allows those most likely to be involved in an incident a chance to work together in a constructive environment and to practice their roles and responsibilities.

Exercises will be scheduled and conducted in accordance with regulatory requirements and/or internal requirements. An outline of oil spill response-related exercises is shown in Table 12-1.

12.4 Equipment Deployment

Each crew on a vessel serving in the capacity of a Standby Vessel will be trained on, and deploy, the “termite” and boom sweep-systems and other associated spill response equipment (dispersant spray systems, bird handling, product sampling, tacker buoy deployment), prior to that vessel crew serving in a Standby Vessel capacity. In addition, each PSV (Troms Sirius and Lundstrom Tide) will conduct at least one deployment training session of the BP-owned Lamor MOS 15 system prior to reaching the “pay zone” during drilling operations. The crew not “on-rotation” for the MOS deployment will be given an orientation session on the equipment prior to reaching the “pay zone”.

BP will ensure the contractors have met the equipment deployment requirements for their equipment.

12.5 Training and Exercise Documentation A record of the training and exercises undertaken will be maintained. Records will contain details of the attendee, training/exercise scenario, aim, objectives and lessons learned.

For training and exercises to be useful and to continuously improve, they must be accompanied by:

• clear objectives, i.e., what is the purpose of the exercise and what aspects are being tested; • a process for evaluating the exercise against the agreed objectives; and • an appropriate process for addressing recommendations arising from the exercise.

Following each exercise, a debriefing session will be conducted and opportunities to improve shall be identified, noted and the action to incorporate changes to plans recorded in BP’s Incident reporting & safety management database with an identified individual, clearly articulated actions and a completion time. The process for identifying and addressing recommendations is described in Section 6 of the IMP.



APPENDIX 1 Roles and Responsibilities of Government Agencies

Appendix 1 Page 1 of 8 vB02 Uncontrolled when printed or stored locally

1 Regulatory Summary

FEDERAL

Canada-Nova Scotia Offshore Petroleum Board

Jurisdiction Lead agency responsible for the oversight of, and potential intervention for, environmental emergency response from offshore drilling and production installations on location in the Nova Scotia offshore area.

Authority under the Canada - Nova Scotia Offshore Petroleum Resources Accord Implementation Act Sub-section 166(4) to take direct action that is necessary to clean up a spill.

Expertise/Advisory Role Lead agency for requesting and following-up on spill information from the polluter. Responsible for the investigation of spill events that emanate from offshore installations while on location.

Legislated authority regarding the use of approved STAs for mitigating spills.

Legislation, Acts and Regulations

CNSOPB is responsible for the administration of the following Acts, Regulations and Guidelines and related pieces of legislation:

• Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act

• NS Offshore Petroleum Drilling & Production Regulations • NS Offshore Petroleum Installations Regulations • NS Offshore Area Petroleum Diving Regulations • NS Offshore Certificate of Fitness Regulations • NS Offshore Area Petroleum Geophysical Operations Regulations • Canada-NS Oil and Gas Spills and Debris Liability Regulations • NS Offshore Petroleum Occupational Health & Safety Requirements • Drilling and Production Guidelines • Safety Plan Guidelines • Environmental Protection Plan Guidelines • Offshore Waste Treatment Guidelines • Chemical Selection Guidelines for Drilling and Production Activities on

Frontier Lands • Offshore Physical Environment Guidelines • Measurement Guidelines • Data Acquisition and Reporting Guidelines • Compensation Guidelines Respecting Damage Relating to Offshore

Petroleum Activity • Atlantic Canada Offshore Petroleum Industry Standard Practice for the

Training and Qualifications of Personnel • Guideline for the Reporting and Investigation of Incidents • Guidelines Respecting Financial Responsibility for Work or Activity in

the Newfoundland and Nova Scotia Offshore Areas • CAPP Safe Lifting Practices • Statement of Canadian Practice with Respect to the Mitigation of

Seismic Sound in the Marine Environment • Safety/Environmental Notices and Directives • Notices to Operators




Environment and Climate Canada (ECCC)

Jurisdiction Responsible for environmental subject areas related to petroleum operations such as:

• Disposal at sea • Air quality (air emission reporting, GHGs, halocarbons) • Species at risk, migratory birds • Chemical management (substances lists) • Wetlands • Pollution prevention provisions dealing with the deposit of deleterious

substances (under Fisheries Act) Will advise CNSOPB as soon as possible of the application of federal legislation/regulations in relation to offshore petroleum operations.

Expertise/Advisory Role Federal authority for environmental and scientific advice during a marine pollution incident, largely under the regulations of the Canadian Environmental Protection Act (CEPA) and the Fisheries Act. Key aspects of CEPA include the prevention and management of risks posed by toxic and other harmful substances, marine pollution, disposal at sea, interprovincial and international movements of hazardous wastes, environmental emergencies involving CEPA-regulated substances, and other sources of pollution not regulated by provincial jurisdictions.

The primary role of ECCC’s National Environmental Emergencies Centre (NEEC) is to provide technical and scientific environmental advice and assistance to the lead agency, such as expertise on spill countermeasure and remediation options.

Environment Canada has been assigned responsibility for administration and enforcement of the Fisheries Act pollution prevention provisions dealing with the deposit of deleterious substances (including oil) into water frequented by fish.

May convene the Environmental Emergencies Science Table (the “Sciences Table”) (formerly REET), to provide advice to the lead agency. The Science Table brings together relevant experts from response agencies, all levels of government, Aboriginal representatives, local communities, industries, environmental non-government organizations, and academic institutions to provide advice on scientific and technical issues including, but not limited to, resource protection and spill clean-up priorities, spill behaviour, environmental/human health impacts of hazardous substances, spill countermeasures, and waste disposal.


EC is responsible for the administration of all or selected parts of the following Acts and Regulations, as well as related regulations, guidelines, and other pieces of legislation:

• Canadian Environmental Protection Act & Regulations • Canada Water Act • Disposal at Sea Regulations • Environmental Emergency Regulations • Environmental Enforcement Act • Fisheries Act (pollution prevention provisions) • Federal Halocarbon Regulations • Species at Risk Act • Migratory Birds Convention Act (MBCA) & Regulations




Canadian Wildlife Service (directorate within ECCC)

Jurisdiction Administration of the MBCA. There will be an additional responsibility for the federal government under SARA for all listed species at risk under its jurisdiction. The Canada Wildlife Act, also administered by CWS, broadens responsibility providing enabling mechanisms for habitat and all wildlife conservation.

Expertise/Advisory Role Responsible for issuing permits for wildlife recovery and care as well as taking over a wildlife response if the one initiated by a polluter is determined to be inadequate.

Assess the development of an incident-specific wildlife plan.

Assess any wildlife surveys conducted (e.g., surveys need to be done with observers trained to identify birds, use standardized protocols, and record and report data).

CWS has a role in oil spill response in three main areas as outlined within the EC document National Policy on Oiled Birds and Oiled Species at Risk January 2000:

1. Knowing and providing information on the migratory bird resource and species at risk (under CWS jurisdiction) in a spill (this includes damage assessment and restoration planning after the event);

2. Minimizing the damage to birds by deterring unoiled birds from becoming oiled; and,

3. Ensuring the humane treatment of captured migratory birds and species at risk by determining the appropriate response and treatment strategies which may include euthanization or cleaning and rehabilitation.

CWS also assesses damages caused by oil spills to wildlife and habitats to help determine whether responsible parties should be prosecuted and the costs that they should bear, and conducts studies to determine the status of recovery efforts. In association with this expertise and advisory role, CWS will be consulted regarding any marine bird monitoring or recovery efforts to ensure appropriate protocols and approaches are proposed and agreed upon.


MBCA Canada Wildlife Act SARA

National Energy Board (NEB)

Jurisdiction NEB jurisdiction is defined under the Canada Oil and Gas Operations Act and certain provisions of the Canada Petroleum Resources Act.

Expertise/Advisory Role Independent federal agency that reports to the Minister of Natural Resources and regulates the exploration and drilling for, and the production, conservation, processing, and transportation of petroleum in the non-Accord Frontier offshore areas. They may be included in the Science Table for expertise in this field.


National Energy Board Act Canada Oil and Gas Operations Act Canada Petroleum Resources Act




Transport Canada (TC)

Jurisdiction Regulatory responsibility for marine safety, including Canada’s marine oil spill response regime in the case of spills from ships, but does not have any responsibility to respond to spills from offshore facilities.

Prepared to assist and support the CNSOPB in carrying out its mandate respecting the safety of offshore facilities and other vessels engaged in petroleum activities by providing advice and assistance when requested.

Expertise/Advisory Role Responsible for the Environmental Prevention and Response National Preparedness Plan and the Canadian Marine Oil Spill Preparedness and Response Regime for safety oversight, pollution prevention, monitoring of compliance with regulations and enforcement action.

Conducts investigations of ship-source pollution occurrences aboard polluting vessels, and provides technical expertise about the ship and the ship’s on-board activities, which can help mitigate ship-source spills.


TC is responsible for the administration of all or selected parts of the following Acts and Regulations, as well as related regulations, guidelines, and other pieces of legislation:

• Canada Shipping Act • Canadian Aviation Regulations • Ballast Water Control and Management Regulations • Classed Ships Inspection Regulations • Collision Regulations • Crew Accommodation Regulations • Environmental Response Arrangements Regulation • Fire and Boat Drills Regulations • Fire Detection and Extinguishing Equipment Regulations • Life Saving Equipment Regulations • Load Line Regulations • Marine Occupational Health & Safety Regulations (under the Canada

Labour Code) • Marine Personnel Regulations • Navigation Protection Act • Navigation Safety Regulations • Pollutant Discharge Reporting Regulations • Regulations for the Prevention of Pollution from Ships and for

Dangerous Chemicals • Response Organizations and Oil Handling Facilities Regulations • Safe Working Practices Regulations • Safety Management Regulations • Ship Station (Radio) Regulations and Technical Regulations • Transportation of Dangerous Goods Act • Vessel Certificates Regulations • VHF Radiotelephone Practices and Procedures Regulations




Fisheries and Oceans Canada (DFO)

Jurisdiction Responsibilities under the Fisheries Act, which are administered by EC, include pollution prevention provisions dealing with the deposit of deleterious substances (including oil) into water frequented by fish; marine mammals, turtles and fish under the Species at Risk Act, and the Oceans Act.

Powers, duties and functions pursuant to Section 678 of the Canada Shipping Act and therefore is the support for the CCG in the case of ship-source pollution spills.

Expertise/Advisory Role As a participant of the Science Table, DFO provides scientific and technical advice respecting the location of critical fisheries resources and their habitat, the timing and location of fishing activities, oceanographic information, support in spill tracking and trajectory modelling, general advice in support of clean-up operations and strategies, the impact of pollutants on sensitive resources, monitoring the potential impact of response strategies, and priorities for environmental protection related to the fisheries.


Canada Shipping Act Fisheries Act Species at Risk Act Oceans Act Marine Mammal Regulations

Canadian Coast Guard (CCG; Special Operating Agency of DFO)

Jurisdiction Mandate to respond to spills from ships (supply and support vessels or rigs/platforms during transit), but not from offshore facilities in Canadian waters (under the CNSOPB).

The CCG’s Environmental Response (ER) program’s mission is to ensure an appropriate level of preparedness and response capability for all ship-source and mystery source pollution incidents in waters under Canadian jurisdiction.

Expertise/Advisory Role Lead federal agency for the response component of Canada’s Marine Oil Spill Preparedness Response Regime. The ER program monitors or manages the clean-up efforts for any ship-source or mystery source pollution incident in waters under Canadian jurisdiction, with support from DFO.

Responsible for monitoring an oil spill response and taking over the response if it is seen not to be appropriate or sufficient.

CCG assistance may include advisory services, technical support, monitoring and surveillance, equipment or personnel, for the purposes of responding to an oil pollution incident in the offshore upon the request of the CNSOPB.


Marine Spills Contingency Plan Canada-US Joint Marine Spills Contingency Plan Canada Shipping Act –Part 8 Oceans Act




Department of National Defence

Jurisdiction Government of Canada

Expertise/Advisory Role Provide people, facilities, logistics, naval and airborne support and other resources during a marine pollution incident. The availability of these resources is dependent upon National Defence established priorities and operational requirements.

Legislation, Acts and Regulations National Defence Act

Indigenous and Northern Affairs Canada (INAC)

Jurisdiction Land, royalty and benefit matters

Expertise/Advisory Role INAC can provide advice to the CCG regarding pollution incidents near Indigenous lands regarding land claims agreements, cultural and other issues.

They may participate in the Sciences Table, provide expertise in specific areas and/or act as a community liaison to Indigenous groups.

Legislation, Acts and Regulations First Nations Land Management Act

Natural Resources Canada (NRCAN)


Expertise/Advisory Role On behalf of the Government of Canada, NRCAN has responsibilities related to the management of offshore petroleum resources and petroleum related work and activity conducted in the offshore area, including matters respecting safety, protection of the environment, conservation of petroleum and joint production arrangements.


Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act Canada Oil and Gas Operations Act Canada Petroleum Resources Act Canada-Nova Scotia Oil and Gas Spills and Debris Liability Regulations Nova Scotia Offshore Area Petroleum Diving Regulations Nova Scotia Offshore Area Petroleum Geophysical Operations Regulations Nova Scotia Offshore Petroleum Drilling and Production Regulations

Parks Canada


Expertise/Advisory Role Custodians of: • Sable Island National Park Reserve; • Kejimkujik National Park Seaside.

Legislation, Acts and Regulations Canada National Parks Act




Public Safety Canada


Expertise/Advisory Role Responsible for the Federal ERP and can provide support for a large-scale incident requiring additional coordination of federal resources to support CCG’s role of lead federal agency.

Legislation, Acts and Regulations Federal Emergency Response Plan

PROVINCIAL

Nova Scotia Environment (NSE)

Jurisdiction Nova Scotia Environment Act

Expertise/Advisory Role Lead agency for regulatory activities involving the onshore storage, transportation, treatment, or disposal of oily wastes and recovered materials in the event of a marine spill.

In addition, expertise and advisory capacity regarding the following subjects, which may be affected by spills and / or clean-up activities.

• Air Quality • Wetlands


Environment Act (Nova Scotia) and applicable regulations and guidelines including, but not limited to:

• Activities Designation Regulations (Water Approvals) • Air Quality Regulations • Dangerous Goods Management Regulations • Emergency Spill Regulations • Environmental Assessment Regulations • Greenhouse Gas Emissions Regulations • Solid Waste-Resource Management Regulations • Sulphide Bearing Material Disposal Regulations • Used Oil Regulations • Nova Scotia Wetland Conservation Policy

Nova Scotia Department of Natural Resources

Jurisdiction Endangered Species Act (Nova Scotia), Wildlife Act (Nova Scotia), and Beaches Act (Nova Scotia)

Expertise/Advisory Role Lead agency for the protection, recovery, and other relevant aspects of conservation of species at risk in Nova Scotia, including habitat protection, during marine spill response.


Endangered Species Act Wildlife Act Beaches Act




Nova Scotia Labour and Advanced Education

Jurisdiction Safe and healthy workplaces, and work practices, and safety standards protecting the general public.

Expertise/Advisory Role Onshore Occupational Health & Safety during marine spill response.


Occupational Health & Safety Act (Nova Scotia) and applicable regulations including, but not limited to:

• Occupational Health and Safety First Aid Regulations • Occupational Safety General Regulations • Workplace Hazardous Materials Information System Regulations • Worker’s Compensation Act



APPENDIX 2 Aerial Surveillance Guidelines


1 Aerial Surveillance

The following guidance is provided for conducting aerial surveillance:

a. flight preparation:

i. ensure trained oil spill observers are utilized;

ii. prepare flight plan;

iii. prepare communications plan;

iv. use a GPS tracking system;

v. assemble documentation, equipment and supplies (camera, iPad with Rapid Oil Spill Surveillance app, compass, charts, maps, etc.);

vi. receive status briefing and tasking information.

b. surveillance:

i. Using the predicted spill location as a starting point, it may be necessary to conduct a localized search to determine the position of the spill. Search patterns for locating a spill include:

a. expanding square/spiral – fly in ever-decreasing circles around the predicted position until the spill is sited; used to determine the exact location and extend of an oil spill;

b. ladder – fly a predetermined length and width from the last known position of the oil to its predicted position; used when the location of the spill is expected to be anywhere in the allocated search area with equal probability.

ii. calculating the spill area:

a. fly the length of the spill (record time taken and air speed);

b. fly the width of the spill (record time taken and air speed); c. calculate the distance for spill length and width using the following equation:

TIME TAKEN TO FLY (SECONDS) X SPEED (KNOTS)

3600 (SECONDS) OR 60 (MINUTES)

Note: divide answer by 1.85 to convert to kilometers

d. Calculate the area of the spill (km2) using the following equation: LENGTH (KM) X WIDTH (KM)

iii. quantifying the spill volume by visual appearance

a. using the Bonn Oil Appearance Code, estimate the percentage of spill coverage that is: silvery/grey sheen; rainbow sheen; metallic; discontinuous true oil colour; continuous true oil colour; no cover;

b. use the following equation to calculate the minimum spill volume (m3) for each oil type: OVERALL AREA (KM2) X AREA COVERED WITH SPECIFIC APPEARANCE (%) X MINIMUM

THICKNESS (MILLIMETRES (mm))





Surveillance information reported to IC includes:

• Unit/Personnel log; • Location of oil identified (either on map/chart, waypoints on GPS, or geo-referenced photograph on mapping software); • Quantity of oil observed: • Use a standard aerial surveillance log as a guide to calculate and report the quantity of oil observed; • Information on any response activities observed.

Industry standard aids to support surveillance are available in the NOAA Aerial Observation Job Aid (http://response.restoration.noaa.gov/sites/default/files/OWJA 2016.pdf) and OSRL Aerial Surveillance Field Guide (https://www.oilspillresponse.com/technical-library/aerial-surveillance-field-guide/). An example of an aerial surveillance log is provided below.




Aerial surveillance log








APPENDIX 3 Notification Forms








ECRC Notification Form

Call-Out Data Collection Sheet - ECRC 24hr Emergency Number

Activation Time: Date: Completed By:

Contact Name/s:

Company/Agency:

Facility/OHF: Vessel:

Land Based: Offshore Platform/Drill Rig:

Contact Numbers:

(Business) (Cellular)

(Home) (Pager)

(Fax) (Email) Contract #: Authorized Individual:

Problem:

Spill Time:

Product:

Approved Oil: Yes No MSDS Requested: Yes No

Status/Leaking: Yes No

Spill Volume: Volume at Risk:

Conditions at Scene:

Wind: Wave Height: Visibility: Tide:

Latitude: Longitude:

Geographic Location:

Highway #/Civic Address:

NOTES:



APPENDIX 4 Resources Contact List


Response Organizations

ECRC Emergency 24hr

Dartmouth, NS 1-902-631-4960

OSRL Southampton, UK 44(0)23 8033 1551

Fort Lauderdale, FL, USA 1-954-983-9880

Search and Rescue CHO Helicopters

JRCC

PAL Dispatch

Emergency

Halifax, NS

1-709-570-1481

1-709-576-4023

1-902-427-8200

Surveillance and Tracking OSRL Southampton, UK 44(0)23 8033 1551

Transport Canada Activate through CNSOPB

Spill Trajectory Specialists BP Sunbury

OSRL Southampton, UK +44 23 8033 1551

ECRC Dartmouth, NS 1-902-631-4960

TRG Cypress, TX, USA 1-281-880-5000

Ambulance and Medevac Nova Scotia EHS Dartmouth, NS 911

Hospitals QEII Halifax, NS 1-902-473-2700

Dartmouth General Dartmouth, NS 1-902-465-8300

Vessels Horizon Maritime Halifax, NS 1-902-401-0229

Aircraft Provincial Airlines (PAL) Halifax, NS 1-902-873-3575

Dispersant Application OSRL Southampton, UK 44(0)23 8033 1551

Fort Lauderdale, FL, USA 1-954-983-9880

SSDI (see Cap and Containment Response Plan)

Dispersant Manufacturer Nalco Sugar Land, TX, USA

Salvage Atlantic Towing 24hr 1-506-648-2790

Wildlife Response Cobequid Wildlife and Rehabilitation Centre

Truro, NS 1-902-893-0253

Atlantic Wildlife Institute

Sackville, NB 1-506-364-1902

Tri-State Bird Rescue and Research

Newark, Delaware, USA 1-302-737-9543

FOCUS Wildlife Anacortes, WA, USA 1-800-578-3048

Sea Alarm Foundation OSRL (UK; USA) 44(0)23 8033 1551;

1-954-983-9880




Supplemental Resources

Advisors (Subject Matter Experts)

Triox Environmental Emergencies

Port Hood, NS Montreal, QC

1-902-631-4960 1-514-663-2991

Dillon Consulting Halifax, NS 1-902-450-4000

Stantec Consulting Ltd. Dartmouth, NS 1-902-468-7777

Pinchin LeBlanc Dartmouth, NS 1-902-461-9999

OSRL Southampton, UK 44(0)23 8033 1551

TRG (IAP Software) Cypress, TX, USA 1-281-880-5000

Shoreline Response Experts including SCAT

Triox Environmental Emergencies

Port Hood, NS Montreal, QC

1-902-631-4960 1-514-663-2991

Owens Coastal Consulting (OCC)

Bainbridge Is, WA, USA 1-206-369-3679

Polaris Applied Sciences Bainbridge Is, WA, USA 1-206-842-5667

Oil Spill Contractors

Envirosystems Dartmouth, NS 1-902-468-9011

Aafinity Contracting and Environmental Ltd.

Dartmouth, NS 1-902-209-0730

Clean Harbors 24 hr Dartmouth, NS

1-800-645-8265

MSRC Herndon, VA, USA 1-730-326-5617

Communications Systems Nova Communications 24 hr Dartmouth, NS

1-877-721-7070

Bell Mobility Radio Halifax, NS 1-902-457-5727 Waste Management Envirosystems Dartmouth, NS 1-902-468-9011

Clean Harbors 24 hr Dartmouth, NS

1-800-645-8265

Terrapure 24 hr Dartmouth, NS

1.800.567.7455

Dillon Consulting Halifax, NS 1-902-450-4000 Pinchin LeBlanc Dartmouth, NS 1-902-461-9999 Stantec Consulting Ltd. Dartmouth, NS 1-902-468-7777

Lifting Equipment A.W Liel Dartmouth, NS 1-902-468-6620 Atlantic Tiltload Ltd. Dartmouth, NS 1-902-468-9438 ALL Cranes Goodwood, NS 1-902-876-2506

VOOs ECRC Dartmouth, NS 1-902-631-4960 Secunda Marine Dartmouth, NS 1-902-482-4730 Atlantic Towing Dartmouth, NS 1-902-494-5400




Support Services

Fueling

Irving MGO Halifax, NS 1-902-222-3248 RST Dartmouth, NS 1-800-463-8551

1-902-494-5468 Ground Transportation Budget Car and Truck

Rental Dartmouth, NS 1-902-492-7550

Enterprise Van Rentals Dartmouth, NS 1-902-469-1689 Gray Line Bus Halifax, NS 1-800-565-7173

Security Services First Strike Security Sydney, NS 1-877-400-6745 1-902-539-9991

Securitas Dartmouth, NS 1-902-434-2442 Weather Forecasting Oceans Ltd. Halifax, NS 1-902-492-9220

Hotels Westin Nova Scotia Halifax, NS 1-902-421-1000 1-800-937-8461

Marriott

Halifax, NS

1-902-421-1700 1-800-228-9290

Hollis Doubletree Halifax, NS 1-902-429-7233 1-800-445-8667












Documents

Oil spill rsponse plan April 2018 - BP