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5.1 Planning

5.2 Incident Action Plan

5.2.1 Initial Analysis
5.2.2 Potential Impacts
5.2.3 Prioritization of Actions
5.2.4 Alternative Response Methods
5.2.5 Response Resource Availability
5.2.6 Other Plans

5.3 Documentation

5.3.1 Reports and Status Updates
5.3.2 History Documentation

5.4 Environmental Issues

5.4.1 Sampling and Monitoring
5.4.2 Wildlife Considerations
5.4.3 Permits

Table 5.1: Permitting Requirements for Response Activities

5.5 Health And Safety Issues

5.5.1 Site Characterization
5.5.2 Sampling and Monitoring
5.5.3 Site Safety Planning

5.6 Waste Management And Disposal

5.6.1 Temporary Storage
5.6.2 Disposal Plan

5.7 Response And Planning Assistance

5.7.1 Technical Specialists and ScientificSupport
5.7.2 Volunteers
5.7.3 Additional Assistance

Table 5-2: NOSC Incident Command System Planning Section

Planning Section Chief
Plan Development Unit Leader
Document Unit Leader
Reports and Status Division Supervisor
History Division Supervisor
Environmental Unit Leader
Technical Specialists

Chapter 5: RESPONSE MANAGEMENT - PLANNING

The Planning Section is part of the Incident Command Spill Management Team and is responsible for developing an Incident Action Plan defining the response and operational goals. With the assistance of the Operations Section, the Planning Section develops mission assignments and schedules and identifies resource requirements to accomplish the defined goals. Alternative response strategies are evaluated by the Planning Section and incorporated into the Incident Action Plan on a case by case basis. The Planning Section is also responsible for documenting and disseminating all technical and environmental information to concerned parties, including updates on response actions and changes to the Incident Action Plan. Finally, the Planning Section is responsible for recording all events and actions taken during the spill incident for future reference.

The Planning Section is lead by the Planning Section Chief. Depending on the spill scenario, the following unit leaders are appointed to assist the Chief: Plan Development Unit Leader, Documentation Unit Leader, Reports and Status Supervisor, History Supervisor, Environmental Unit Leader, and Technical Specialists. The responsibilities and duties of these individual unit leaders are listed in Table 5-2.

5.2 Incident Action Plan [top]

After the initial incident briefing meeting, the Planning Section begins to form an Incident Action Plan. This plan is organized to present information on manpower, equipment and support resources needed to meet specific response and operational goals based on the information from the initial incident briefing meeting. During the first few days of the spill event, the Operations Section provides updates on response actions performed during the emergency phase and input for developing the plan. Once this plan is developed, implementation of the plan can begin, moving response operations into the project phase. Appendix C provides a sample of Incident Action Plan Forms which can be used to ensure the correct information is provided in the Incident Action Plan.

Once the Incident Action Plan is put into place, it continues to develop and expand, becoming more specific as response operations proceed. Any changes to the Incident Action Plan are documented and disseminated to the appropriate individuals by the Planning Section.

5.2.1 Initial Analysis [top]

An initial analysis of the spill site is performed by the local facility response team and should be provided by the FIC to the COMXXXX NOSC. This analysis determines the size and location of the incident, the nature and status of source control operations, and the status and adequacy of response operations. Initial impacts of the spill may also be known at this time, and should be taken into consideration. The Operations Section Chief may also provide additional information on the initial status of the spill.

5.2.2 Potential Impacts [top]

Once the locations of potential impacts are established, the amount of time for each area to be impacted should also be predicted. Technical assistance for predicting the fate of the spill may be necessary. The NOAA SSC may assist by modeling the spill to determine the potential impact area. Additional information is provided by over flights, site surveys, and spill impact and risk assessments from the Operations Section. The local U.S. Fish and Wildlife and state fish and game or DNR team members may also be helpful in determining the wildlife areas at risk (see section 5.7 "Response and Planning Assistance" for more detail).

More references pertaining to the potential impacts can be found in the following appendices: Appendix D "Area Committee/State Data", Appendix F "Environmental Protection Strategies", Appendix I "Vessel and Facility Worst Case Discharges", and Appendix M "Wildlife Management".

5.2.3 Prioritization of Actions [top]

Once the trajectory and time of potential impacts of the spill are predicted, response actions are considered and prioritized in order to prevent these impacts from occurring. Prioritization of these response actions should take into account recommended actions from the (Applicable Region) ACP and other local contingency plans. The Operations Section assists the Planning Section in developing this prioritized list of actions, giving updates of response actions performed during the emergency phase. A schedule is then developed to complete the prioritized list of response actions. Forms in Appendix C are provided to assist in developing these actions.

Some response actions may have to consider environmental conditions. Environmental response strategies are presented in Appendix F for several types of sensitive areas, which may be encountered during response operations. The Environmental Unit Leader should make the Logistics and Operations Sections Chiefs aware of any environmental requirements or permits needed for operations taking place in environmentally sensitive areas or wildlife habitats. Environmental issues and permits are discussed in more detail in section 5.4.

5.2.4 Alternative Response Methods [top]

The primary method of spill cleanup used by the Navy is mechanical recovery. However, other response methods are available which may be more productive under certain circumstances. These alternative response methods are in situ burning, bioremediation, and dispersant use. The use of these methods is usually restricted. The Environmental Unit Leader should consult with the applicable FOSC and RRT before using any alternative response methods.

In situ burning is the controlled burning of spilled oil. The burning of oil can take place while the spill is contained or not contained. Most uses of in situ burning of oil on water focus on contained burns since a minimum thickness of 2 to 3 mm is required. In the event that this method of response is used, additional equipment is needed, such as fire resistant containment boom. In general, the window of opportunity to burn is limited due to weathering of the oil, which makes it more difficult to burn. In most instances, burning has to take place during the emergency phase, which may be before the Initial Action Plan is finalized. Approval from the FOSC and RRT is required before in situ burning can be used. In some regions, pre-approval has been established. Refer to Appendix D to determine COM's approval process.

Bioremediation uses nutrients to enhance the activity of indigenous organisms and/or the addition of naturally occurring non-indigenous organisms. In the case of an oil spill, the addition of nutrients can enhance the degradation of the spilled oil. The application of bioremediation products should be considered for specific environmental conditions. The Environmental Unit Leader should be aware of which bioremediation products can be used as stated in subpart J of the National Contingency Plan (NCP). Presently, this alternative has not been used at sea, nor during the emergency phase of response operations.

Dispersants are another alternative response method. Dispersants contain surfactants which, with the proper concentration and mixing energy, cause droplets of oil to break off from the slick. Certain products may be harmful in some environmentally sensitive environments. The Environmental Unit Leader should be aware of which dispersant products meet the criteria established in subpart J of the National Contingency Plan (NCP). However, due to the low viscosity of most Navy fuels, dispersants are not generally a viable option.

5.2.5 Response Resource Availability [top]

Once the response actions are prioritized and alternative response methods have been considered, the availability of response resources to implement response actions needs to be established, for both short and long term use. These resources include both equipment and manpower required for implementation of the Incident Action Plan. The schedule of response events is contingent on the amount of time required for resources to arrive on-scene. The NOSC has regional resources available to respond to Tier I levels of the worst case discharge scenario (see Appendix I). The Operations Section Chief assists the Planning Section Chief in updating the availability of response resources for recovery and cleanup of the spill and the level of response resources needed based on operations in the emergency phase.

Resources other than oil recovery resources, such as resources for personnel and waste storage and removal, need to be addressed. Specific resources for COM are listed in Appendix E.

Additional manpower may also be necessary to implement response actions. The Logistics and Operations section Chiefs should be consulted to determine the manpower needed to meet each section's operational goals throughout the spill event.

5.2.6 Other Plans [top]

The Plan Development Unit Leader is responsible for coordinating with Section Chiefs and Command Staff to gather information for the Incident Action Plan. Including the information listed above, the Incident Action Plan should include the following plans:

• Environmental Operations Plan (coordinate with Environmental Unit Leader and Operations Section Chief);

• Communications Plan (coordinate with Logistics Section Chief);

• Air Operations Plan (coordinate with Operations and Logistics Section Chiefs);

• Medical Plan (coordinate with Logistics Section Chief and Medical Officer);

• Site Safety Plan (coordinate with Logistics and Operations Sections Chiefs and Safety Officer).

A generic Site Safety Plan is provided in Appendix K. Site Safety Plan requirements are also discussed in section 5.5.

5.3 Documentation [top]

Once the Initial Action Plan is complete and implemented, the Planning Section must document all response activities. This task is essential in keeping the command up to date on the use of resources, response accomplishments, and activities of personnel. The Planning Section Chief supervises the documentation efforts and is assisted by the Documentation Unit Leader. However, two support personnel can be assigned to assist the Chief in completing these tasks, the Reports and Status Division Supervisor and the History Division Supervisor.

5.3.1 Reports and Status Updates [top]

This information should also be posted in the Command Center for reference throughout the spill event, and should include maps showing the location of the spill, spill trajectories, response operations, and staging areas.

The Documentation Leader and the Reports and Status Division Supervisor should also coordinate efforts with the FOSC reports and status personnel. This is to ensure information on all non-Navy response activities is recorded and provided to appropriate response personnel.

5.3.2 History Documentation [top]

Historic documentation of spill response events is essential in keeping all response personnel well informed, and for tracking manpower, equipment, and material needs. The Documentation Unit Leader is responsible for assisting the Legal Officer in developing documentation and distribution guidelines and in supervising all duplication and filing of official forms and reports related to the spill incident. The History Division Supervisor obtains copies of all records, reports, plans, log books, etc., for filing.

5.4 Environmental Issues [top]

Another responsibility of the Planning Section is to ensure that systems are in place during operations to collect, evaluate, analyze, and disseminate information on environmental, cultural, and social aspects of the spill event. The Planning Section is assisted mainly by the Operations Section in obtaining information in these areas. Appendix L contains specific information on Natural Resource Damage Assessment (NRDA) and is a separate process. Additional assistance should be coordinated with other government agencies, including NOAA, U.S. Fish and Wildlife, and local and state environmental agencies. Refer to section 5.7 for additional response and planning assistance.

5.4.1 Sampling and Monitoring [top]

A sampling and monitoring program should be established during response operations to obtain data for determining the spill’s overall impact on the environment and to determine shoreline measures for response and cleanup options. This program can also provide input for real time modeling of the spill as well as important information for NRDA procedures (refer to Appendix L). Results from the sampling and monitoring program are also used by the Operations Section to determine if various response operations are effective.

The type of program established depends on its objective, which may range from determining the effectiveness of a bioremediation product on the spill to determining if shoreline contamination is a result of the spilled oil. For the environmentally sensitive areas within the impact zone, the monitoring program should have a specific objective, an adequate sampling method for gathering data (e.g. control groups, significant number of random samples, specific habitats, specific rate of sampling), and a definitive method for comparing results.

5.4.2 Wildlife Considerations [top]

The Environmental Unit Leader is responsible for providing updates on the impact of the spill on wildlife. The wildlife which may be affected by an oil spill at COM are identified in (Applicable Region) ACP and the FRP. Refer to these documents when initially determining wildlife considerations. To determine the types and number of wildlife affected by the spill, the Environmental Unit Leader is assisted by the Wildlife Rescue Unit Leader. Status on the number of species captured, cleaned, released, or found dead should be recorded by the Wildlife Rescue Unit Leader and made available to the Environmental Unit Leader.

5.4.3 Permits [top]

When responding to a spill, many response activities may require government authorization or permits. These operations may include the following: road access, air logistic support, beach cleaning, boom deployment, buoy mooring, dispersant use, fish harvesting, hazardous material transport, in situ burning, mobile camp establishment, oil skimming operations, oily waste disposal/incineration, and performance of scientific studies.

Local permits and reporting pertaining to response operations may be required. The Local Emergency Planning Committee for should be consulted as well as the EPA Region XXX and USCG District for additional requirements. Various states may require the permits for the operations mentioned above. The states in COM’s region should be consulted to determine which state requirements may affect response operations. Refer to Appendix D for more specific information on state and local data.

Table 5.1 is a list of permits, which may apply to response operations at COM. A comprehensive list of federal and possible state requirements has been provided for various response activities. The Environmental Unit Leader verifies which permits are required and informs appropriate response personnel. The Operations and Logistics Section Chiefs must be made aware of any permits, which would affect their operations.

5.5 Health And Safety Issues [top]

During all response operations, a safe working environment should be provided for all response personnel. Safety concerns can range from physical hazards (slips, trips, and falls) to risks from exposure to hazardous materials. A site safety plan must be developed for all response operations.

The Safety Officer is responsible for ensuring that a Site Safety Plan is developed and implemented (see Appendix K). The Planning Section Chief is the liaison for the Safety Officer, reporting on all site safety incidents and actions taken by the Operations and Logistics Sections.

Updates and changes to the Site Safety Plan are documented by the Documentation Unit Leader. The Environmental Unit Leader informs the Planning Section Chief of any permits needed with regard to worker health and safety which should be included in the Site Safety Plan. The Environmental Unit Leader should also coordinate with the Operations and Planning Sections Chief to ensure that all workers are HAZWOPER certified. The Documentation Unit Leader may want to obtain copies of HAZWOPER certification for filing purposes.

5.5.1 Site Characterization [top]

An initial site characterization of the spill area and region should be performed to determine its possible effects on worker health and safety. These characterizations should relate to specific operations and should include the following information:

The Environmental Unit Leader coordinates efforts with Operations and Logistics Section Chiefs to obtain this information. The ACP(s) and FRP(s) should be referenced for maps and site characterizations already developed.

5.5.2 Sampling and Monitoring [top]

A monitoring program should be conducted as directed by the Safety Officer. This program monitors exposure levels of chemicals and vapors during response operations. The Environmental Unit Leader ensures all industrial hygiene compliance requirements are met and reports on the status of the monitoring program to the Planning Section Chief. The Planning Section Chief provides updates to the Safety Officer for his/her review. Components of the monitoring program are presented in Appendix K.

5.5.3 Site Safety Planning [top]

As operations change to meet response needs, updates may be required to the Site Safety Plan. For example, if the spill has impacted the shoreline, an additional site might be added to the plan, requiring site characterization, possible permits, and additional monitoring. The Environmental Unit Leader should inform the Planning Section Chief of any safety or health issues as the Incident Action Plan changes to meet operational goals. The Planning Section Chief, in turn, informs the Safety Officer of any changes in Site Safety Plans and updates on monitoring efforts.

5.6 Waste Management And Disposal [top]

The Planning Section is also responsible for reporting to Section Chiefs and the Command Staff on the status of waste management operations. The Planning Section is assisted by the Operations Section which provides updates on waste management operations. The Initial Action Plan should address response actions which would eliminate or reduce the amount of waste generated. The Waste Management Unit Leader of the Operations Section and the Environmental Unit Leader of the Planning Section work together to ensure all necessary permits are obtained for storing and removing wastes generated during operations (refer to section 5.4.3 "Permits").

Some of these wastes may be generated during the cleanup phase, and may not be of concern to the NOSC operations. Oiled animal carcasses must be disposed of accordingly. The regional U.S. Fish and Wildlife representative should provide technical assistance in this area.

5.6.1 Temporary Storage [top]

Prior to disposal, most of the wastes generated during response operations have to be temporarily stored. Temporary storage should be identified in the FRP. Further resources may be listed in Appendix E and Appendix I.

When determining where wastes should be stored, efforts should be made to reduce the amount of waste which could be classified as hazardous waste. This can be achieved by separating liquid and solid wastes at all phases of response operations, including at sea, on board recovery vessels, and on shore. By segregating liquid and solid wastes, additional temporary storage may not be needed for classified hazardous waste. The Waste Management Unit Leader should be consulted to determine the amount of temporary storage needed for short and long term operational goals. This amount may change as the response situation develops.

5.6.2 Disposal Plan [top]

The Disposal Plan should be developed by the Plan Development Unit Leader with assistance from the Waste Management Unit Leader and the Support Services Leader. This plan should include several different phases of the waste process such as collection, storage, and treatment of spill-generated waste prior to transport and disposal.

This plan should include information on a survey of wastes (obtain from Waste Management Unit Leader), disposal alternatives for hazardous and non-hazardous wastes, and permit requirements for these alternatives (obtain from Environmental Unit Leader). The field survey of the wastes generated should determine the origin of the waste, the type of waste, the location of the waste, its volume or weight, method of containment, and means of transferring the waste. Most generated wastes are handled by the Defense Reutilization Marketing Service (DRMS). Refer to section 4.3.6 of this plan for more information on disposal actions.

5.7 Response And Planning Assistance [top]

Other federal, state, and local agencies are available to provide assistance to the NOSC during response operations. These agencies can provide assistance to the Planning Section in various technical and scientific areas. They also provide other sources of personnel and equipment resources which are not on-site. Requests for assistance from federal resources should be coordinated with the Federal On-Scene Coordinator (FOSC). State and local resources should also be coordinated with the appropriate state agencies. The ACP should be consulted for a listing of local and state scientific support.

Appendices D and E provides additional information on ACPs and state and local regulations. Appendix G lists inter-agency agreements which may be useful in determining which personnel and equipment resources can easily be accessed by the NOSC.

5.7.1 Technical Specialists and Scientific Support [top]

To complete the Incident Action Plan, taking into consideration all environmental issues, technical assistance may be needed by the Planning Section. The following are areas where additional expertise may be needed:

The Scientific Support Coordinator is one asset, which is available to the NOSC to provide scientific and environmental expertise in most of these areas. The Scientific Support Coordination Branch is part of the Hazardous Materials Response and Assessment Division (HAZMAT) of NOAA’s Office of Ocean Resources Conservation and Assessment. Appendix F lists additional resources for scientific and environmental support.

5.7.2 Volunteers [top]

During any spill event, individuals from environmental organizations or in the locality of the spill may offer to volunteer their services to assist in response operations. All volunteers should be referred to the FOSC and not be directed by the NOSC. However, the Reports and Status Division Supervisor should be aware of volunteer operations and disseminate this information to appropriate response personnel. The History Division Supervisor should document and file all status reports on volunteer activities.

5.7.3 Additional Assistance [top]

Additional response assistance can be provided by the Navy Supervisor of Salvage (SUPSALV). Appendix E lists additional equipment, which can be provided by SUPSALV at the Tier II and Tier III levels. The Operations Section Leader should be aware of SUPSALV’s resources, and access these resources when developing the Incident Action Plan. The Reports and Status Division Supervisor should include these additional resources when providing updates on the status of response equipment and operations.