PROVISION OF PROFESSIONAL SERVICES FOR THE PREPARATION OF A NATIONAL OIL SPILL CONTINGENCY (NOSCP) Needs Assessment Report

Transcription

1 PROVISION OF PROFESSIONAL SERVICES FOR THE PREPARATION OF A NATIONAL OIL SPILL CONTINGENCY (NOSCP) Needs Assessment Report Prepared by: R Perry, C Wood, R Maroun Date: 11 Nov 16 Approved: P A Winn

2 API CDR CLC CNRS DMU DGO EDL EIA FEMA ICAG ICS IMS IMO IOGP IOSC IOPC Fund Convention IPIECA JMOC LAF LOI LPA ABBREVIATIONS American Petroleum Institute Council for Development and Reconstruction Civil Liability Convention National Council for Scientific Research Disaster Management Unit Director General of Oil Electricité Du Liban Environmental Impact Assessment Federal Emergency Management Agency (US) Incident Command Advisory Group Incident Command System Incident Management System International Maritime Organization International Association of Oil and Gas Producers International Oil Spill Conference International Convention on the Establishment of an International Fund for Compensation for Oil Pollution Damage Global Oil and Gas Industry Association for Environmental and Social Issues Joint Maritime Operations Centre Lebanese Armed Forces Lebanese Oil Installations Lebanese Petroleum Authority MARPOL International Convention for the Prevention of Pollution from Ships 73/78. MCA MOA MOE MOEW MOF MOFA MOI MOJ MOIM MOL MOPH MOPWT [UK] Maritime and Coastguard Agency Ministry of Agriculture Ministry of Environment Ministry of Energy and Water Ministry of Finance Ministry of Foreign Affairs Ministry of Industry Ministry of Justice Ministry of Interior and Municipalities Ministry of Labor Ministry of Public Health Ministry of Public Works and Transport MOPWT - DGLMT Ministry of Public Works and Transport- Directorate General of Land and Maritime Transport i P a g e

3 MOTe NCA NIMS NOR NOSCP NOSPC NRF OGP Ministry of Telecommunications National Competent Authority National Incident Management System (US) National Operations Centre National Oil Spill Contingency Plan National Oil Spill Planning Committee National Response Framework [International Association of] Oil & Gas Producers OPRC Oil Pollution Preparedness Response and Cooperation Convention 1990 OSCP OSR OSRL PAR P&I Oil Spill Contingency Plan Oil Spill Response Oil Spill Response Limited Petroleum Activities Regulations Protection and Indemnity [Insurance Clubs] REMPEC Regional Marine Pollution Emergency Response Centre for the Mediterranean Sea. SCAT SEA SPA UNDP Shoreline Clean-up Assessment Techniques Strategic Environmental Assessment Specially Protected Areas United National Development Program ii P a g e

4 CONTENTS Abbreviations... i Contents... iii List of Tables... iv Executive Summary...v 1. Introduction National Oil Spill Response Needs Assessment Legislative and Legal Framework Institutional and Organizational Capacities Available and Required Technical Capacities Needs Assessment Short and Long Term Financial Needs Summary: Key Needs Conclusion Annex 1: Training Needs Analysis Oil Spill Awareness IMO 2 MCA Incident Command System (ICS) Media Awareness IMO IMO1 MCA 3 Beachmaster Shoreline Supervisor Aerial Observer Shoreline Clean-up Assessment Techniques (SCAT) Annex 2: Oil Spill Response Resource Capability Developing a National Response Capability Delivering the National Response Strategy Annex Protocol Adopted in Valletta, Malta, on 25 January Annex 4. The International Regime for Compensation for Oil Pollution Damage iii P a g e

5 LIST OF TABLES Table 2.1: Estimations of IOPC fund contributions of Lebanon... 4 Table 2.1: Needs Analysis... 8 Table 3.1: Oil spill response budget requirements Table 4.1: Key stakeholder requirements Table 6.1. Training requirements for personnel involved Table 7.1: Checklist for logistical and other support requirements for equipment mobilization and deployment iv P a g e

6 EXECUTIVE SUMMARY The submission of this Needs Assessment Report (Task 6 - Assess Specific Needs) forms part of the overall objective of Provision of Professional Services for the Preparation of the National Oil Spill Contingency Plan (NOSCP) for Lebanon. The analysis carried out gives specific needs which should be met in the NOSCP and this Needs Report. However, at a high level, there are key actions which can be taken to facilitate plan implementation, as given below. Assigning National Competent Authority (NCA), to the MOPWT - DGLMT and giving it the power and financial budget to fulfil the role, will provide a focal point for the ongoing implementation and improvement program. This decision, in line with the Oil Pollution Preparedness Co-operation and Response Convention 1990 (OPRC), is extremely important. Key legal requirements: Issue the NOSCP as a decree by the Council of Ministers, which also establishes the MOPWT - DGLMT as National Competent Authority Amend existing decrees to implement the new NOSCP. Specific decrees are given in Table 2.1. Implement current legislation, through the development of guidelines and procedures, to fulfil specific functions within the NOSCP. Key institutional and organizational set-up requirements: The relationship between the National Response Framework (NRF) and the National Oil Spill Incident Commander (NOSIC) has been explained in the NOSCP. However, there will be a need for a training workshop for all participants in the plan to attend, to clarify the situation which many organizations currently have difficulty in understanding. The roles and responsibilities of the various organizations have been described in the plan. There is now a requirement for them to produce the Standard Operating Procedures (SOPs) for their organization. Establish a National Operations Tier 3 response center with the required response facilities. Internet access, telephone exchange, with landline extension to the whole Incident Management Team. This should also be available for other emergencies for the Operational Team. Tier 2 sectoral response facilities need to be developed for all potential spillers such as the Lebanese Petroleum Administration (LPA), the Directorate General of Oil (DG Oil) and the Lebanese Oil Installations (LOI) including ensuring the Joint Maritime Operations Center (JMOC) facility is developed to assume the role defined in the NOSCP. Key technical requirements: Establish a national training framework. This has been included in the NOSCP. Establish an oil spill response capability to support the national response strategy as outlined in the NOSCP (see Annex 2: Oil Spill Response which recommends equipment and indicative costs ). Clearly, the resource and financial needs required will be considerable, with a large capital expenditure (particularly for equipment) as well as an ongoing budget requirement. Some general costs have been outlined for training and exercises. Indicative costs have been given in Annex 2 but this is only a budget cost and not a quote that could be very different in a competitive situation. v P a g e

7 1. Introduction To give the Lebanese National Oil Spill Contingency Plan (NOSCP) the best chance of successful implementation, this document seeks to identify any needs or issues that may become obstacles to its progress. The document incorporates feedback from a series of stakeholder engagement meetings held in Beirut in 2015 and 2016, the Gaps and Challenges Report issued by the consultancy in February 2016, and other items that have become apparent during the development of the NOSCP. Fundamental to implementation will be the legislative framework and the consultancy has worked to identify, as clearly as possible, the key legal requirements which will allow the plan to become a legal responsibility for each stakeholder. This framework has been described in the NOSCP and all stakeholders have said that they understand their role within the plan and have agreed their role within it. Work can now start to ensure that legal requirements and Ministerial procedures are implemented to fulfil the requirements of the Plan. As a minimum, each of the stakeholders will need to develop and implement internal notification and mobilization procedures. The organization and interaction of the stakeholders and new institutional setups are also essential to the effectiveness of the plan, facilitating good communication and incident management. Building of response capacity, both in terms of oil spill response knowledge and understanding (i.e. training), and a Tier 3 response capability, will be critical to deliver the national response strategy. Following the tiered response concept, and the requirements of the Oil Pollution Preparedness Co-operation and Response Convention 1990 (OPRC), and the 2002 Emergency Protocol of the Barcelona Convention, would include establishing a national equipment stockpile as well as building relationships with REMPEC and neighboring countries. Of course, with the current situation to the north and to the south, this will be very difficult. Therefore, as a minimum, this should include closer involvement with REMPEC. In addition, Lebanon should also look to develop a capability that would include access to industry equipment stockpiles. This may be through a contract with Oil Spill Response Limited (OSRL), or through requirements of local companies and operators to facilitate access to industry resources. Procurement of new equipment is likely to require high capital expenditure and careful consideration of costs. A gradual building of capability will be required. The financial barriers to plan implementation will be considerable. It is outside the scope of this report to prepare a full budget for implementation. However, an indication of the activities with a cost implication, and whether they will be a capital expenditure or a budget requirement are given. 1 P a g e

8 2. National Oil Spill Response Needs Assessment The needs identified broadly fall into the following categories: Legislative and legal frameworks Institutional and organizational setups Available and required technical capacities particularly in terms of training and equipment. A description of these categories is given in the sections below. 2.1 Legislative and Legal Framework A National Oil Spill Contingency Plan requires a legal framework for implementation. This will ensure that each of the stakeholders with obligations under the plan will be legally required to deliver those obligations. It will also allow for additional and targeted financial funding to stakeholders to allow them to undertake their role. It is critical, however, that the legislative framework allows for changes to be made to the plan, particularly whilst it is in its infancy and not fully implemented. Roles, responsibilities and procedures may change following exercises and drills. As such there is a balance between ensuring that firstly, stakeholders prioritize oil spill response planning and response and secondly that the financial resources are made available for them to carry out their role whilst giving flexibility within the plan. It has been agreed that, wherever possible, the current legal framework will be used to implement the plan. However, there are key areas where additional legislation, or an amendment to a current law or decree, may be required. Critical is that the designation of the Ministry of Public Works and Transport (MOPWT - DGLMT) as the National Competent Authority (NCA) be implemented in law or a decree. It is recommended that the decrees implementing the NOSCP, designates the MOPWT-DGLMT as NCA and empowers them to update and implement the NOSCP. The NOSCP has been agreed, with all stakeholders formally undertaking to fulfil their roles. Thereafter, updates to the plan will be carried out by the NCA activating the National Oil Spill Contingency Planning Committee. More specifically, following a thorough legal assessment the recommendation to legally implement the NOSCP is as follows: The National Oil Spill Contingency Plan ( NOSCP ) aims at establishing a national framework for preparing and responding to oil spill in the Lebanese waters. Thus, it should be issued by a decree of the Council of Ministers, upon the proposal of the Minister of Public Works and Transports and the Minister of Energy and Water, and based on the Oil Pollution Response and Co-operation (OPRC) Convention 1990 adopted by Lebanon by Law No. 605 dated 20 November The following items are proposed to be including in the Decree: - Approving the NOSCP, attached to the Decree, in all its volumes and requiring its execution, in implementation of Article 6(1)(b) of the OPRC that requires the adoption of a national contingency plan for preparedness, and response which includes the organizational relationship of the various bodies involved, whether public or private, ( ). - Appointing the Ministry of Public Works and Transports as the Competent National Authority, in implementation of Article 6(1)(a)(i) of the OPRC that requires the designation of the competent national authority or authorities with responsibilities for oil pollution preparedness and response. 2 P a g e

9 - Appointing the Ministry of Public Works and Transport as custodian of the NOSCP. - Appointing the National Oil Spill Planning Committee [provided for in the NOSCP] and identifying its role. - Granting the Ministry of Public Works and Transport the right to update the NOSCP through a ministerial decision, whenever needed, following proposal of the National Oil Spill Planning Committee [provided the update does not affect the substantial content]. This recommendation is justified by the following: - The NOSCP, being a national plan, should be approved by a decree issued by the Council of Ministers as it falls under the jurisdiction of the Council of Ministers that is vested with the right to set the general policy of the Government in all fields and draw up bills and organizational decrees, as per Article 65 of the Lebanese Constitution [1]. - The NOSCP, involving more than one ministry and including the organizational relationship of the various ministries and bodies involved (as required by the OPRC), should be approved by a decree issued by the Council of Ministers rather than by a ministerial decision in order to be effective and binding to the concerned ministries and bodies, particularly that the minister exercises jurisdiction over its ministry only in application of Article 66(2) of the Lebanese Constitution [2]. - We have previewed that its update can be done by a ministerial decision of the Minister of Public Works and Transport upon the proposal of the National Oil Spill Planning Committee, provided such update does not affect its substantial content. Necessary amendments to current decrees are given in Table 2.1, key changes include: Requirement for Tier 1 and Tier 2 planning: For onshore operations amend (i) Decree No. 8018/2002 to require industrial institutions to submit an OSCP to the Ministry of Industry as a prerequisite for granting the exploitation permit, and (ii) Decree No. 5509/1994 to require an OSCP from onshore oil facilities. Role of Lebanese Armed Forces (LAF): Amendment to decree-law no. 102 so that the duties of the LAF includes environmental pollution. Other institutional requirements, such as the establishment of the Incident Command Advisor Group (ICAG), has been incorporated in the NOSCP. Regarding relevant international conventions, and based on recent research, Lebanon should become a signatory to the IOPC Fund. Based upon oil import figures supplied by the LOI, and assuming the same imports since 2012, The Fund has estimated [1] Article 65 of the Lebanese Constitution: The Executive authority shall be vested in the Council of Ministers. It shall be the authority to which the armed forces are subject. Among the authorities that it shall exercise are the following: 1. It shall set the general policy of the Government in all fields, draw up Bills and organizational Decrees and take the decisions necessary for implementing them. [2] Article 66(2) of the Lebanese Constitution: The Ministers shall administer the Government's services and shall be entrusted with applying the laws and regulations, each one pertaining to matters relating to his department. 3 P a g e

10 the annual payments Lebanon would have been required to make during the period of 2010 and 2015 to range between 2,398 and 8,136 (Table 2.1). Note that it is the oil importers, not the Government that pays. The 1992 IOPC Fund is financed by contributions levied on any person who has received in one calendar year more than 150, 000 tonnes of crude oil and heavy fuel oil (contributing oil) in a State Party to the 1992 Fund Convention. Table 2.1: Estimations of IOPC fund contributions of Lebanon 08 November Fund Levies based on oil reports 2010 to 2015 for Lebanon-estimated oil tonnage 1.3 million tonnes 1992 Fund Levies Oil Received Year Fund Name Incident Date Invoice Due Date Total Levy Per Tonne Estimated tonnage Annual Contributions due in GBP 2010 General Fund /03/ ,346,080 3,089 Sub total Alfa I 05/03/ /03/ ,347,360 5,610 Major Claims Fund General Fund /03/ ,347,360 4,396 Sub total General Fund /03/ ,137,890 2,398 Sub total General Fund /03/ ,300,000 3,221 Sub total General Fund /03/ ,300,000 3,778 Sub total General Fund /03/ ,300,000 8,136 Sub total Year Total Levy ( ) ,628 4 P a g e

11 Based on these figures, there is clearly every incentive to join the fund to provide reasonable compensation to the country and those affected from shipping spills at terminals, ports, in the open sea, and from oil spilled from shipping drifting into Lebanese waters from the south at a very small price. It is therefore strongly recommended that Lebanon Join the 1992 IOPC Fund at the earliest opportunity. The full document on Compensation is attached in Annex Institutional and Organizational Capacities Once the legal framework is in place, there will then be a need for all participants in the plan to make changes within their organizations to implement their new roles. These changes may include: Setting up of facilities for emergency response within Ministries, understood to be the Sectoral Center. Development of the Joint Maritime Operations Chamber (JMOC) as an emergency communication platform, until a Maritime Rescue Co-ordination Center is established. Identification of a national tier 3 response command center, be this as part of JMOC or the National Operations Room (NOR) Procedures must be in place for a duty officer on 24/7 call out within ministries, municipalities, authorities etc. Integration of oil spill response activity with the NRF. The NRF may be mobilized partially or fully in the event of a Tier 3 spill, especially when the National Oil Spill Commander requires strategic support. Implementation of the ICAG. This group will support the National Oil Spill Incident Commander with a range of technical advice, even if a ministry or authority is not directly involved in the response. They will form a bank of knowledge at the National Incident Commander s disposal. In the event of an incident, they may mobilize to the command center, or they may remain remote, offering advice as requested. It is also envisaged that this group will fulfill a planning function as a part of the National Oil Spill Contingency Planning Committee, offering guidance to the MOPWT - DGLMT, as NCA, on a range of issues which could include national response strategy, risk assessment, mapping and waste management planning. This committee would approve new plans and procedures relating to oil spill response. The framework for this group has been included in the NOSCP. Operational procedures, for example for the management and mobilization of equipment, aerial surveillance capability, approval of dispersants or management of oil spill waste will need to be produced as SOP s by the responsible Ministries and Directorates. 2.3 Available and Required Technical Capacities With procedures in place for implementation of the plan, and the organizational response established, the resources required to deliver the Tier 3 response capability must be identified. These include equipment for oil spill response and the necessary training for organizations and individuals carrying out the functions. Currently, Lebanon has two national stockpiles of response equipment, one kept with the LAF and the other with the Civil Defense. This is entirely composed of shoreline response equipment donated after the 2006 Jiyeh oil spill. To implement the national response strategy identified in the NOSCP, further equipment will be required, primarily for aerial surveillance, application of 5 P a g e

12 dispersants, and offshore response activities. These will include, but not be restricted to: Aerial surveillance aircraft helicopter and fixed wing Dispersant application aircraft Dispersant application system Stockpile of dispersants Offshore response vessels or access to vessels of opportunity through specific contracts Offshore containment and recovery equipment Offshore oil storage Logistical support equipment communication, PPE, welfare, spares, tools. An example of a national equipment stockpile is given in Annex 2, with very basic budget costs, together with a discussion of how this capability may be built, with in house and external resources being used. Equipment provision should be based on risk, specific sensitivities, and an understanding of regional and international equipment stockpiles. It is impossible to provide enough equipment and resource to deal with a Tier 3 spill in all countries and therefore the tiered response concept is built upon mutual aid between national governments and industry, as predicated in the OPRC Convention. Consequently, a Tier 3 capability will be built from MOU s with neighboring governments, oil industry response centers and other response providers. See Annex 1 for further information on capacity building. In developing a national response, consideration should be given to the national response strategy to be delivered, to determine the type of equipment required, but also to the mobilization and deployment requirements. Equipment should be based in strategic locations that will allow fast deployment to an airport or harbor, or by road to a shoreline location. As a result of the modelling, it has been suggested that the majority of equipment should be located towards the North of the country. However, the drill scenario showed that this would not always be the case. Therefore, there is a need for the equipment to be spread from south to North Furthermore, the equipment should be packaged for transport, well maintained and supported by the logistical resources necessary for transportation. See Annex 2 for an example of equipment which could form a national response stockpile, together with some technical considerations for mobilization and deployment. This will require a high initial capital investment as well as an ongoing budget. Some additional capability may be provided by commercial Tier 1 oil spill response capability and taking part in their training and drills. Clearly, these resources will be available to supporting a national response. However, the national stockpile of equipment must always be available to respond to a Tier 2/3 spill and/or a spill where the origin is unknown, and it is critical that this capability is not compromised. It has been suggested by MOPWT - DGLMT that a small levy per barrel of oil imported by the private oil terminals could provide some of the finance required. Indicative budget costs are included in Annex 2 with the recommended equipment. The consultancy believes that oil spill response and ICS training at all levels is the most critical requirement for the National Oil Spill Response in Lebanon. Valuable experience was gained during the spill in 2006, however improved knowledge and understanding of oil spill response techniques and issues will be necessary at all ministry levels. All those who may be involved in oil spill response, or oil spill response planning, are required to complete an oil spill training course. The IMT must be trained as a minimum to IMO2 level, with senior officers to the IMO3 standard. In addition, all facilities, ports and offshore installations must conduct training at IMO1 and 2 6 P a g e

13 levels, to ensure that operational personnel, whether within the public or private sector, are adequately prepared to carry out their role in oil spill response. Once again, this will require initial expenditure, followed by an ongoing budget to ensure that all personnel are kept up to date with regular training and exercises. The figures below were provided by a training provider fully accredited for the UK Maritime and Coastguard Agency by the Nautical Institute. This was the first, and as far as we know, the only accredited training system in the world at present. It would be essential that training personnel are fully familiar with the situation in Lebanon and therefore it is likely that the staff that has already been involved in preparing the NOSCP in Lebanon would be used. Their indicative budget costs for the training are as follows: IMO Level 2 12,600 IMO Level 3 13,300 These would be for courses for up to 30 delegates, so the consultancy would anticipate 1 IMO 3 course and at least 3 IMO2 courses. The higher cost of the IMO 3 is due to more senior trainers and more training aids. All costs do not include travel and accommodation but including all facilities manuals, training aids etc. In addition, there will be other technical requirements that will assist with oil spill response and planning. These will include: Further development of oil spill sensitivity mapping, by MOE, CNRS and Academia Further development of shoreline oil spill response assessment. A full survey will be required to be completed by the MOE team above to describe all the sensitive areas. This can be followed by a survey of all the shoreline to determine the best cleanup measures and the areas that can be protected by pre-agreed booming plans. Oil spill communication platforms 7 P a g e

14 LEGAL ORGANISATIONAL TECHNICAL PRIORITY 2.4 Needs Assessment Table 2.1 below provides detailed analysis of the needs identified. Each need has been labeled as a legislative, organizational or technical need, and has been prioritized. This should act as a guide as to the order in which the tasks should be addressed. The following classification is used: High priority (H): If these needs are not met in the plan, including procedures and organizational framework, the plan will not function. Medium priority (M): Once the high priority needs are met, these are elements which will ensure that the plan is effective in response to oil spill incidents. Low priority (L): These needs add further to the plan in general, allowing it to be more robust, and to the response in particular, improving environmental and socio-economic protection. Table 2.1: Needs Analysis No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS PREVENTION 1 Develop a compliance assurance framework covering audit, inspection and monitoring requirements X X Onshore: Amend Decree No. 9765/2003 (for industrial institutions) and Decree No. 5509/1994 (for onshore oil facilities) or issuance of new decrees setting the requirements for audit, inspection and monitoring of industrial establishments, in implementation of (i) the Develop a framework for inspection, monitoring and auditing of industrial facilities from which there is a risk of oil pollution. Include guidelines for preparation and the approval process. MOI to take the lead, however the MOPWT - DGLMT, MOE, and affected ministries should receive audit reports for ports, oil handling and storage facilities M 8 P a g e

15 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS Protocol for the Protection of the Mediterranean Sea against Pollution from Land-Based Sources and Activities that requires establishing systems of inspection and monitoring of industrial facilities and onshore oil facilities to assess compliance with authorizations and regulations, and (ii) article 32 of the Environment Law No. 444/2002 that requires setting the necessary measures to prevent oil pollution deriving from facilities or boats, Offshore: Issue a decree by the Council of Ministers to identify the concerned government authorities for carrying out inspection of offshore facilities (article 144 of PAR), and setting the standard procedures for audit and inspection. Amend decree No. 9765/2003 (for industrial institutions) so 9 P a g e

16 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS that the Ministry of Industry is granted a duty of general coordination with respect to supervision of industrial institutions. Other ministries and authorities (under article 4) shall be obliged to notify the Ministry of Industry about any information or action they may take under this article 4. 2 Establish a framework for the review and approval of environmental impact assessments and environmental management plans for facilities with a potential for significant environmental impact or emergencies. X Onshore: The EIA should be approved by the MOE, as per the current legislation. Offshore: A decree setting the procedures, requirements and conditions related to the EIA study for petroleum activities in the Lebanese waters should be issued by the Council of Ministers upon proposal of the Minister of Energy and Water following the LPA s opinion and coordination with the relevant ministries (article 29.3 of the OPRL and article 11 and seq. of the PAR). Implement current legislation through guidelines outlining requirements and the approval process. MOE to be the lead. LPA will contribute to this decree M 10 P a g e

17 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS PLANNING 3 Implement the requirements of the Protocol concerning cooperation in preventing pollution from ships and, in cases of emergency, combating pollution of the Mediterranean Sea Adopted in Valetta Malta on 25 th January Improved relations with regional and international organizations offering support for oil spill response i.e. REMPEC. X X Law 254 dated 15 April 2014 has ratified this Prevention and Emergency Protocol. This protocol imposes some new requirements upon Lebanon, for example HNS plans and aerial surveillance to detect illegal discharges. This protocol is attached as Annex 3 for review and action by the NCA and affected Ministries. X N/A MOPWT - DGLMT, as NCA, to work with MOFA to enhance regional and international relationships, promoting mutual aid, specifically the existing relationship with REMPEC in the Mediterranean. Work to incorporate regional and international resources into the development of a Tier 3 response capability. M 5 Identification of a port or ports of refuge for shipping in Lebanon. X X No international or national legislation in place. IMO has issued non-binding guidelines A Port of Refuge is an identified area to which a vessel in difficulties could be towed to reduce the impact of a potential marine pollution. This should be considered for inclusion in the NOSCP in the future. MOPWT - DGLMT to lead the planning process M 11 P a g e

18 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 6 MOPWT - DGLMT to be appointed, in law, as the National Competent Authority under OPRC Establish the Terms of Reference for the ICAG committee. 8 Establish the link between the NOSCP incident management and the NRF X X Issue a decree by the Council of Ministers which shall (i) appoint the Ministry of Public Works and Transports (MOPWT - DGLMT) as the competent authority under OPRC, (ii) empower the MOPWT - DGLMT to prepare the NOSCP, and (iii) appoint the MOPWT - DGLMT as the custodian of the NOSCP, implementation of OPRC. 12 P a g e through National Oil Spill Planning Committee Recognition of MOPWT - DGLMT as the NCA will be critical in successful implementation of the plan. This decree should outline the roles and responsibilities of the NCA to include, but not be limited to: Management of National Oil Spill Planning Committee, management of the Tier 3 response capability, management of the national oil spill response training strategy, approval of Tier 1 and 2 planning. X N/A The ICAG is the new organization set up to support oil spill response with a range of technical expertise. This is described in the NOSCP MOPWT - DGLMT, as National Competent Authority, should establish the ICAG, which when not involved in an OSR incident will also act as the National Oil Spill Planning Committee and on which will act as chair. X N/A This link has been established within the NOSCP and briefly tested in the drill, however there is still considerable lack of understanding and a workshop will be needed to explain this relationship to all parties. Its implementation will be critical to ensure that spill Incident Command at a tactical and strategic H H H

19 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 9 Establish requirements for ports, oil terminals, offshore installations, and other facilities to have in place Tier 1 plans which integrate with the NOSCP. This should include the provision of the necessary equipment to combat pollution from the facility or installation. 10 Establish requirements for regional Governorates Shoreline Protection and Clean-up Plans X X Onshore: Amend (i) Decree No. 8018/2002 to require all relevant industrial institutions to submit an OSCP to the Ministry of Industry as a prerequisite for granting the exploitation permit, and (ii) Decree No. 5509/1994 to require an OSCP from onshore oil facilities. OFFSHORE: The PAR requires emergency plans be submitted by the operators to the Minister of Energy and Water with a copy to the LPA (article 137). 13 P a g e level is as effective as possible. LPA, DGLMT and DRMU should convene a workshop to demonstrate the link between the NOSCP and the NRF. Guidance documents issued by the NCA to all facilities, ports and offshore operators outlining planning requirements. Procedures for approval of plans to be established. All onshore plans to be approved by MOPWT - DGLMT and key stakeholders. Existing facilities shall be given a designated period of time to prepare and submit the required OSCP. X X Guidance documents issued by the NCA to all Governorates on the requirements of their shoreline protection and clean-up plans. Procedures for approval of plans to be established. All plans to be approved by the MOPWT - DGLMT Governorates given the opportunity to discuss issues; maybe facilitated via a national planning meeting. H M

20 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 11 National framework for response identifying oil spill response training requirements across all industries, ministries and sectors. This should include the requirement for oil spill response exercises at a local and national level. 12 Training Health and Safety Advisors in relation to oil spill response activities. This is not normally part of H&S training but is extremely important in Oil Spill Response due to the many hazards that may be encountered. X X N/A Identify who, within government agencies, requires oil spill response training. LPA to assist the NCA utilizing NOSCP Vol C. Identify the level of training required by ports, oil handling and storage facilities and offshore operators. Ensure this training is undertaken. Identify qualified training organizations. Identify budget and funding arrangements. A training needs analysis is included as Annex 1 of this report. X X Under Article 6(2) of the OPRC Convention, Lebanon should establish a program of exercises for oil pollution response organizations and training of relevant personnel. The Ministry of Labor (MOL) and LAF have H&S advisors who should be trained to the specifics of oil spill response and made available for emergency deployment on site. MOL to organize specific oil spill safety training The MOL and LAF should identify health and safety advisors with clear responsibility to advise the National Incident Command in the event of an incident. Further duties may include travelling to specific response sites to monitor activities and to advise on health and safety procedures. H M 14 P a g e

21 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 13 Baseline studies of shoreline ecology, biodiversity and typology to enhance the sensitivity mapping. This will need to be extended to offshore areas for the same reason. 14 Establish a national database of oil types, grades and quantities imported and stored in Lebanon. X N/A Baseline studies are an essential part of OSR preplanning. Unless these have been carried out and updated, there is no yardstick against which to measure post spill damage. A sensitivity map, based on data currently available, has been developed as part of this project. This should be enhanced by further studies to identify environmental and socio-economic resources which may be impacted by oil pollution. The location of proposed marine protected areas should be agreed and finalized to be included in the sensitivity mapping. Program to be led by MOE, liaising closely with the MOPWT - DGLMT to ensure oil spill response objectives are met. Resources of academia will be useful in this task. X N/A This task has been started by the project team and should be completed By DG Oil and LOI as part of ongoing spill preparedness. M L 15 P a g e

22 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 15 Continued improvement of GIS sensitivity mapping, risk assessment and oil spill modelling 16 Shoreline surveys to assess clean-up strategy and logistical requirements i.e. beach access points, beach cleanup plans, local facilities etc. 17 Further planning needs include: The financial requirements i.e. allocate budgets in the annual budget of relevant entities to undertake the actions needed to build competences and capacities i.e. training, X N/A MOE to liaise with the MOPWT - DGLMT as appropriate to make sure that these oil spill response planning objectives are met. X N/A MOE together with CNRS and Academia could lead this. External expertise would help to train local teams. this information is essential as part of shoreline protection and cleanup plans, and would therefore add robustness to national planning. This should be done in collaboration with municipalities. X 16 P a g e These issues will need to be considered by the NCA, with MOF and the National Oil Spill Planning Committee (NOSPC) M H

23 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS equipment, etc. The need for national drills (not only as part of Need #11 but highlighted as a requirement) The need for training and practice on oil spill risk assessment and oil spill modeling RESPONSE 18 National Incident Command Centre for the management of Tier 3 oil spills X N/A In practice this could be an extension of the MOPWT - DGLMT and/or LPA sectoral center or the JMOC facility. The current JMOC facility would not be adequate without additional resources. Identification of additional facility requirements and necessary budget, for example it is possible that JMOC could be used for this purpose but the capacity and resources of the facility would need to be significantly increased. MOPWT - DGLMT as NCA, together with the LPA to review, available facilities to identify which could be used. H 17 P a g e

24 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 19 Establish sectoral incident command centers. 20 JMOC, as the identified 24/7 contact point for oil spill response, will require additional facilities to support this function. X N/A In the event of a Tier 2 spill, the sectoral center, together with the facility, will manage the spill, and therefore must have the facilities required to do this. Requirements will include information management and communications. Identify ministries with a requirement for an emergency response room. As a minimum, this is expected to be: MOPWT - DGLMT MOEW LPA & DGO LOI In the short term, all spills could be managed at the Tier 3 command facility (see above) X N/A Identify needs and budget requirements. MOPWT - DGLMT to work with LAF to design an adequate facility. Additional equipment and facilities may include: Charts Additional communication equipment Information Technology (IT) M H 18 P a g e

25 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 21 Establish the role of the LAF in oil spill response. 22 Assign salvage responsibilities. X The Lebanese Army is responsible for the defense and security of the Lebanese territory. Its human resources and equipment have been used for combatting the 2006 oil spill in the Lebanese waters. The responsibilities assigned to the Lebanese Armed Forces ( LAF ) in the NOSCP have been agreed upon by the LAF (upon circulation of the NOSCP draft to the concerned ministries and bodies). In addition, the NOSCP will be issued by decree of the Council of Ministers and the LAF is a member of the National Oil Spill Planning Committee. Thus, we do not foresee a legal impediment to the involvement of the LAF in combatting oil spill incidents in the Lebanese waters, particularly that the LAF can be assigned missions by the Council of Ministers in application of the National Defense Law No. 3/79 dated 24 March X X There is no specific legal framework defining roles and responsibilities for salvage. Salvage of the vessel will be required and operations are likely to be managed alongside the oil spill response operations. Plans and facilities should be in place to deal with the salvage operation. MOPWT DGLMT to lead. H H 19 P a g e

26 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 23 Implementation of a 24/7 call out procedure 24 Development of a national Tier 3 response capability, including a national stockpile of pollution control equipment to support the national response strategy. See Annex 2: Oil Spill Response Resource Capability X N/A Currently the only organizations that are set up to respond on a 24/7 basis are the JMOC and the NOR. All ministers and authorities will be required to have a 24/7 point of contact and procedure for 24/7 mobilization. All sectoral centers must establish a procedure for 24/7 mobilization. All stakeholders need to establish internal notification and mobilization procedures in line with their responsibilities. Procedure to be tested regularly. NCA to lead X X X Identify dispersants allowed to be used to combat oil spill and their mode of use in a decree of the Council of Ministers that might be in implementation of article 44 of Law No. 444/ P a g e Currently, all existing equipment is for shoreline response and clean-up. Additional capability is required. This should include, but not be limited to: Aerial response capability Aerial dispersant spray capability Oil spill response vessels At sea containment, recovery and storage. Careful identification of equipment needs should be undertaken in consultation with equipment manufacturers and oil spill experts. Identify necessary financial requirements. These equipment needs should be assessed in line H H

27 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS with regional and international response capabilities. Consideration should be given to establishing a contract with Oil Spill Response Limited (OSRL) to gain access to international industry stockpiles. Response capacity building should include development of mutual aid agreements with industry and regional governments. MOPWT - DGLMT, together with the LAF, to look at options for aerial response in country. MOPWT - DGLMT, together with the LAF, to identify response vessels in public sector that could be used for OSR. MOPWT - DGLMT, together with the LAF, to identify vessels in the public sector (regionally if appropriate) that could be used for OSR. Establish contracts with the necessary authorities/companies for the provision of OSR vessels in the event of an emergency. Details of response capability, including examples of the equipment packages which would support the national response strategy are given in Annex P a g e

28 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 24 An oil spill waste management framework to be implemented to deal with oil spill waste. X X X Issue an implementing decree of Article 44 Law No. 444/2002 setting forth the requirements, including the necessity for a prior permit, for the treatment, storage, and disposal of hazardous waste. Issue a decree setting the procedures and principles, at the national level, for the management and disposal of hazardous waste including waste oil (article 44 of the Environmental Law 444/2002) Transport of waste collected at site of incident to appropriate disposal facilities and disposal of waste as such shall be carried out in accordance with the principles as established in the NOSCP. Management of oil spill waste will be critical to a successful operation. It is recommended that this be a focus of the ICAG group once established with MOE taking the lead. H 22 P a g e

29 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS 25 Establish procedures with MOL and General Security to facilitate the granting of work permits and visas for emergency oil spill response X This is actioned by the NOR. NOSIC calls the Liaison Officer (LO) in the Co-ordination Unit (CU). In future, it may be implemented by the Host Nation Support Unit (HNSU) M 26 Develop financial procedures for emergency funding in the event of an oil spill X X Several options are available for the transfer of funds under the public law account. The transfer of credit from the country s budget reserve based on a decree following a request from the concerned ministry sent to the MOF for the combat of a disaster, whereby the request is studied and a decree is proposed to be approved as per standard procedures. The opening of an additional exceptional credit by a law, knowing that the President of the Republic is allowed by law to open exceptional credits below a certain ceiling. Ensuring funding through the Higher Relief Council based on a request from the concerned administration presented based on standard procedures, knowing that the source of funding may be from the treasury as a credit given to the HRC for this purpose or through the budget of the HRC itself. M 23 P a g e

30 LEGAL ORGANISATIONAL TECHNICAL PRIORITY No. IDENTIFIED NEED LEGAL REQUIREMENT OTHER REQUIREMENTS AND FURTHER ACTIONS RECOVERY 27 Procedures to claim compensation for oil spill response. X N/A Financial provision should be in place to compensate Lebanese companies and individuals which may have been financially impacted by the spill. Further procedures in place to recover this expenditure from the polluter/insurance/p&i club to ensure that, as far as possible, costs to Lebanon are compensated for. Provision in place to assess environmental impact as necessary. MOF, together with the MOPWT - DGLMT, to take the lead in putting the necessary procedures in place and issuing information to stakeholders. M 24 P a g e

31 Short Term Long Term Annual Budget Capital Expenditure 3. Short and Long Term Financial Needs At this stage an estimation of the total cost to implement and maintain the NOSCP is not possible. In Table 3.1 below, we have taken each high priority need and identified the associated funding requirements. Once the draft NOSCP has been agreed, the MOPWT - DGLMT, together with the LPA and other key stakeholders, should undertake a full cost analysis. Ultimately, the MOPWT - DGLMT, as NCA, will manage an annual Oil Spill Response Budget that will address the key needs over several years. Table 3.1 gives the overview of the areas which an oil spill budget will need to address. In addition, more resources will be required by stakeholders to implement current or draft legislation such as environmental auditing, port state control procedures, and waste management. Table 3.1: Oil spill response budget requirements Financial Requirement Comment Establishing the MOPWT - DGLMT -as National Competent Authority Tier 1 and 2 facility oil spill response planning, including local Governorate plans. National training and exercise framework. Tier 3 response capability A small team of 2-3 people should be established to manage oil spill response capability within Lebanon. Duties to include management of equipment stockpiles, management of ICAG, management of the OSR budget. Budget and resources will be required as a capital expenditure to establish guidelines for the writing of facility level plans and then implementation of procedures to approve them. An ongoing budget within stakeholder ministries will be required to ensure review and approval of new plans. This will be a continuing financial requirement, and is critical to a successful plan. Training will need to be carried out and refreshed on a regular basis. In addition, exercising of the plan should be regular with some activity on a bi-annual basis. This will be the responsibility of the NCA with the NOSCP input and probably with external assistance Establishing an equipment stockpile to support the national response strategy will be a fundamental part of the plan, but one with high capital expenditure and ongoing running costs. In the short to medium term, this could be a service provided solely by a contractor such as OSRL, with a membership contract ( 25 P a g e X X X X X X X X X X X X X X X X

32 Short Term Long Term Annual Budget Capital Expenditure Financial Requirement Comment Incident management facilities JMOC Tier 3 and sectoral Oil spill sensitivity mapping Emergency management facilities, and communications are essential. This is likely to be a capital expenditure for each sector with maintenance of the facilities being relatively low cost. To include development of the JMOC facility. Further development of the mapping element of this project to enhance planning and response X X X X X X X X 26 P a g e

33 4. Summary: Key Needs Section 2 of this report gives a detailed analysis of the needs, at a national level, required for implementation of the NSOCP. As a summary, Table 4.1 below outlines, in simple terms, the requirements for each ministry/directorate. Table 4.1: Key stakeholder requirements Key Stakeholder MOPWT - DGLMT MOE MOEW LPA Key Organizational Needs for NOSCP Implementation Identify National Incident Commanders. Establish ICAG/ National Oil Spill Planning Committee and facilitate its work. Establish internal oil spill notification and mobilization procedure. Establish sectoral emergency response facilities. Ensure oil spill response training is carried out in line with training needs analysis. Identify Oil Spill Response focal point individual with responsibility for oil spill response. Establish Tier 3 oil spill response capability through equipment stockpiles and international mutual aid. Manage the national oil spill response training and exercise framework, including building a database with all ministries and directorates of who has carried out current OSR training. Implement procedures in place to manage the guidelines and approval process for Tier 1 and 2 plans. Establish JMOC as a notification and response communication facility. Establish internal oil spill notification and mobilization procedures. Establish sectoral emergency response facilities. Put procedures in place to manage dispersant application. Put procedures and planning in place to manage oil spill waste. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Put procedures in place to review and approve, as consultee, Tier 1 and 2 plans. As part of the training framework, identify any individuals who have undergone oil spill response training and inform MOPWT - DGLMT Establish internal oil spill notification and mobilization procedure. Establish sectoral emergency response facilities. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Put procedures in place to review and approve, as consultee, Tier 1 and 2 plans. LPA will approve all offshore plans. As part of the training framework, identify any individuals who have undergone oil spill response training and inform MOPWT - DGLMT 27 P a g e

34 Key Stakeholder MOEW DGO MOEW- LOI MOEW-EDL MOIM/ General Security/ ISF MOIM Civil Defense MOIM Coastal Governorates LAF Key Organizational Needs for NOSCP Implementation Establish internal oil spill notification and mobilization procedures. Establish sectoral emergency response facilities. Carry out oil spill response training in line with training needs analysis. Put procedures in place to review and approve, as consultee, Tier 1 and 2 plans. Establish internal oil spill notification and mobilization procedures. Establish sectoral emergency response facilities. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Produce Tier 1 and 2 plans for approval by MOEW and thence to MOPWT - DGLMT. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis Produce Tier 1 and 2 plans for approval by MOEW and thence to MOPWT - DGLMT. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Member of the NOSIC Support Staff Security. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Put procedures in place to review and approve, as consultee, Tier 1 and 2 plans. As part of the training framework, identify any individuals who have undergone oil spill response training and inform MOPWT DGLMT. Audit of current pollution control equipment to establish current inventory. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Put procedures in place to review and approve, as consultee, Tier 1 and 2 plans. Establish Shoreline Protection and Response plans for each Governorate. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Put procedures in place to review and approve, as consultee, Tier 1 and 2 plans. As part of the training framework, identify any individuals who have undergone oil spill response training and inform MOPWT - DGLMT Audit of current pollution control equipment to establish inventory. 28 P a g e

35 Key Stakeholder Coastguard MOI MOInf MOL MOJ MOPH MOT MOF Key Organizational Needs for NOSCP Implementation Establish internal oil spill notification and mobilization procedures. Established defined memorandum of co-operation for liaison with other agencies. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis MOI has a role in ICS in the ICAG and providing Health and Safety inspectors. Oil spill response training will be required to understand its role in ICAG. MOI has a major role in Tier 1 plan approval and oversight. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT in line with training needs analysis. Set internal procedures for management of media and public information during a spill. Establish internal oil spill notification and mobilization procedures Carry out oil spill response training organized by MOPWT DGLMT carried out in line with training needs analysis. Set internal procedures for management of health and safety during oil spill response. Organize oil spill safety training for the response organization. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT carried out in line with training needs analysis Set internal procedures for management, together with the MOF, insurance and compensation claims. Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT carried out in line with training needs analysis. Set internal procedures for the treatment of casualties suffering the effects of exposure to and contamination with hydrocarbons. Establish internal oil spill notification and mobilization procedures. Assist in the provision of extended communications during an oil spill response. Carry out oil spill response training organized by MOPWT DGLMT carried out in line with training needs analysis Establish internal oil spill notification and mobilization procedures. Carry out oil spill response training organized by MOPWT DGLMT carried out in line with training needs analysis. Advise on and facilitate the co-ordination of stakeholder bids for additional funding for oil spill response. Liaise with the Directorate General of Customs to implement or enhance current procedures for the swift importation of equipment in support of oil spill response 29 P a g e

36 5. Conclusion The needs identified in this report go some way to facilitating a full implementation plan for the NOSCP. Key to the success of the plan is that these needs are met and that the MOPWT - DGLMT, as NCA and the focal point for planning activities, continue to develop oil spill planning activities. In line with management principles, this should be carried out as part of a planning cycle which should set priority objectives to be met. In this way, the capability and expertise in country will be developed over time. This capability and expertise should be developed through training, and tested through regular exercises in line with the requirements of the plan. Planning a response for an unknown incident, at an unknown time, in an unknown location, is notoriously difficult. However, the concept of tiered response is used in order that response to a large incident uses international resources, both from government and industry, to respond and as such the building of these relationships regionally (through REMPEC) and through industry in country will be invaluable to a response capability for Lebanon. 30 P a g e

37 6. Annex 1: Training Needs Analysis To effectively carry out their assigned duties under the NOSCP, it is crucial that personnel in the various response teams must be given the relevant training. As with any assigned position in business or the country, this will ensure that, together with regular continuation exercises, they will be capable and confident in carrying out these duties. 6.1 Oil Spill Awareness Introduction to the processes involved in an oil spill response. Prepares delegates to become a member of an oil spill response team. Topics covered include: Spill causes, properties and fate of oil, impacts of oil spills, international conventions, assessment and evaluation, contingency planning, response strategies, command and control and spill management. Applicability: Personnel who are in very junior roles or administrative positions to help them to understand the process of spill response Duration: 1 day 6.2 IMO 2 MCA 4 Content: The objective of the course is to train members of an oil spill response team organization to effectively respond to an oil spill through the deployment of equipment and resources at the local level. The course focus, therefore, is on the operational management and tactics involved in responding to oil spills. These procedures represent the critical delivery element of any national contingency plan and must include all the key players from government, industry and the other interested parties. The course is 5 full days in length composed of lectures, group assignments and exercises. The course should be delivered within the local context of the Lebanon. The instructional staff will establish the course objectives and content in relation to the participants and the National Oil Spill Contingency Plan. Applicability: Supervisors and On Scene Commanders and members of the oil spill management team, including the leaders reporting to the Head within the four main Sections. Duration: 5 days 6.3 Incident Command System (ICS) The Incident Command System was developed in the United States and is used internationally to manage large scale incidents in the oil and gas industry and in other sectors. ICS 300 is appropriate to expanding incidents where existing operational or facility contingency plans have been exhausted in the initial response phase. It prepares delegates to deal with a large scale ongoing response requiring pre-planning and the ability to scale up the response organization to match the event. It is based upon the concept of management by objectives, provides a modular response organization and describes in detail the planning process and development of an effective response plan. Applicability: Senior personnel with management responsibility in oil spill response 31 P a g e

38 Pre requisites: ICS 100 Introduction to the ICS and ICS 200 ICS for single resources and initial actions On line courses are available through the Federal Emergency Management Agency ICS Resources website: Duration: 3 days 6.4 Media Awareness It is understood that within the Lebanon, the Ministry of Information is designated to lead the Media response. Nevertheless, experience has shown that the media will always wish to talk to people who are actively involved in the response. As a result, it is considered that the several senior members of the ICAG and General Staff should receive media training. In particular, this should also focus on social media, which if mishandled can cause misconceptions and unwarranted criticism. Applicability: National Incident Commanders, ICAG, General Staff Heads Duration: 1 day 6.5 IMO 3 The objective of the seminar is to inform senior officials on the responsibilities of the members of an oil spill response team organization to effectively respond to an oil spill through the deployment of equipment and resources at the national level. The seminar focus, therefore, is on the operational management and policies involved in responding to oil spills. These procedures represent the critical delivery element of any national contingency plan and must include all the key players from government, industry and the other interested parties. The seminar is 2 full days in length composed of modules, group discussions and an exercise. The course should be delivered within the Lebanese context. The instructional staff will establish the seminar objectives and content in relation to the participants and the National Oil Spill Contingency Plan. Applicability: Senior Managers with Oil Spill Responsibilities Duration: 2 days 6.6 IMO1 MCA 3 Beachmaster Shoreline Supervisor The content of the course will be geared towards the Lebanese context and relevant to the National and local contingency plans and responsibilities of the delegates. The instructor will be aware of the local community response limitations and the types of resources available to respond to an oil spill The course is designed to develop the individual s awareness of site assessment, risk assessment and set up of the clean-up sites, shoreline types, environmental issues, response strategies, shoreline clean-up assessment technique (SCAT) equipment and waste management. It includes a practical deployment exercise. 32 P a g e

39 Applicability: Port and Harbor personnel, municipal authorities and supervisors of shoreline oil spill clean-up teams. Duration: 3 days. 6.7 Aerial Observer Topics covered: Operational Remote Sensing of the oil spills by Optical, Microwave, Satellites, Aircraft. In Situ observation: Visual, Imaging, spectrometry. Need for Regional aerial surveillance, Monitoring MARPOL and Special Areas Visual and electronic surveillance. Electronic equipment types, uses and limitations. Search profiles Applicability: LAF and Aerial Surveillance team Duration: 2 days 6.8 Shoreline Clean-up Assessment Techniques (SCAT) The Shoreline Clean-up Assessment Technique (SCAT) process is now a familiar part of an oil spill response in many countries. SCAT teams play a key role in the assessment of the scale and scope of a shoreline response program. The course is designed to introduce the technique in the classroom and then to carry out a practical exercise on the shoreline. Applicability: Shoreline supervisors, environmental team members and local authority personnel responsible for shoreline clean-up. Duration: 2 days 33 P a g e

40 Table 6.1. Training requirements for personnel involved POSITION National Incident Commander OIL SPILL AWARENESS IMO 2 - MCA 4 ICS IMO 3 34 P a g e IMO 1 - MCA 3 Beachmaster Shoreline Supervisor Aerial Observer Shoreline Response Shoreline - Clean-up Assessment (SCAT) X X X X X Incident Command Advisory Group X X X X X Command Staffs Public Affairs Advisor X X X X X Security Officer X X X X X Safety Officer X X X X X Legal Advisor X X X X X Technical Specialists X X X X X General Staffs Planning Planning Head X X X X X X Environment Leader X X X X Resources Leader X X X X Response Planning Leader X X X X Documentation Leader X X X Operations Operations Head X X X X X X MEDIA

41 POSITION Aviation Division Aviation Division Head Aerial Surveillance Leader Aerial Dispersants Leader Marine Division Containment and Recovery Leader OIL SPILL AWARENESS X IMO 2 - MCA 4 ICS IMO 3 X IMO 1 - MCA 3 Beachmaster Shoreline Supervisor Aerial Observer X X X X X X X X X X X Shoreline Response Shoreline - Clean-up Assessment (SCAT) Marine Dispersants Leader X X X Shoreline Division Shoreline Manager X X X X X Response Team Leaders X X X X X Wildlife Division Wildlife Manager X X X Health & Safety H&S Advisors X X X Waste Management Waste Manager X X X MEDIA 35 P a g e

42 POSITION OIL SPILL AWARENESS IMO 2 - MCA 4 ICS IMO 3 IMO 1 - MCA 3 Beachmaster Shoreline Supervisor Aerial Observer Shoreline Response Shoreline - Clean-up Assessment (SCAT) Logistics Logistics Head X X X X X Supply Leader X X X Transport Leader X X X Communications Leader X X X Subsistence Leader X X X Facilities Support Leader X X X Medical Unit Leader X X X Finance Finance Head X X X X X Accounts Leader X X X Insurance - Compensation X X X Leader Cost Recovery Leader X X X Time Unit Leader X X X MEDIA 36 P a g e

43 7. Annex 2: Oil Spill Response Resource Capability 7.1 Developing a National Response Capability In line with the national response strategy as identified in the NOSCP, Lebanon will need to develop its oil spill response capability. Currently, only shoreline equipment is held in country and its distribution is fragmented. Capability must be developed in three ways: 1. It is a requirement under the OPRC convention, that ports, oil handling facilities, and offshore operators must produce an Oil Spill Contingency Plan and provide their own equipment, commensurate with the risk to be able to respond to Tier 1 spills from their own operations. These resources, held both by the public and private sector, will then combine in the case of a National Tier 3 spill to contribute t. 2. It is imperative that agreements with regional governments and organizations be sought to facilitate the sharing of resources. Under the Barcelona Convention, Emergency Plan, this will be required. It is clearly impossible for one country to hold enough equipment to deal with a large spill of international significance and therefore the only way to facilitate additional equipment will be through international channels. REMPEC is the organization that will facilitate this Mediterranean co-operation 3. Developing a national equipment stockpile that is government owned and kept for responding to all spills, where local resources are not adequate. It does not restrict the deployment of this equipment to only Tier 3 level, but it may be used for any spill. This resource is to allow a Tier 3 response to start as soon as possible whilst international resources are being deployed. The International Convention of Oil Pollution Preparedness, Response and Co-operation 1990 (OPRC) requires that each Party, within its capabilities either individually or through bilateral or multilateral co-operation and, as appropriate, in co-operation with the oil and shipping industries, port authorities and other relevant entities, shall establish a minimum level of pre-positioned oil spill combating equipment, commensurate with the risk involved, and programs for its use and a mechanism or arrangement to co-ordinate the response to an oil pollution incident with, if appropriate, the capabilities to mobilize the necessary resources As such, Lebanon must work towards fulfilling this and developing a stockpile that is suitable to deliver the national response strategy, but that can be built on using further international resources if necessary. In the international context, this will be defined as a Tier 2 resource, i.e. one that is for national or regional deployment. Some recommendations are given here about how a national response capability may be put together. It is, however, critical to remember that it is not simply the equipment that is required, but the full supply chain and mobilization network that will be critical to its success. Factors to consider include: Training: The provision of the necessary skills to personnel to permit safe, competent and effective response delivery. Personnel: The provision of sufficient, experienced, trained and motivated personnel to deliver the required response output. Infrastructure: The acquisition, development, management, of all fixed, permanent buildings and structures, land, utilities and facility management services in support of oil spill response capabilities. 37 P a g e

44 Doctrine: Doctrine or response philosophy is an expression of the principles that guide oil spill response and is a codification of how the activity is conducted. Organization: Relates to the operational and non-operational organizations relationships. It typically includes internal corporate structures, incident response and reporting structures and liaison with external parties providing support. Information: The provision of a coherent development of data, information and knowledge requirements for capabilities and all processes designed to gather and handle data, information and knowledge. Logistics: The planning and conduct of the operational movement of equipment and responders is critical. Equipment must be transported, loaded, lifted, secured and operational effectively and efficiently. Safety: Relates to the safety arrangements in place within the response organization to ensure a safe and secure working and operating environment. Of critical importance is the ability to mobilize the equipment in a timely manner. It must either be stored in pre-loaded vehicles, or with facilities for loading and guaranteed availability of appropriate vehicles. Similarly, when reaching the deployment location, there must be the appropriate facilities for unloading and transport to site or vessel. This could include the provision of forklift trucks, cranes, or welding equipment/facilities for securing to deck. When selecting equipment for a national spill response capability, it is critical to consider these factors otherwise the equipment will not be deployable and there will be further delay to the response. Equipment must also be well maintained and in good operational order at all times and ready for deployment, equipment which arrives on site with no fuel, broken hoses, missing parts etc. once again cannot be deployed. A checklist, as an example of the issues, is give below in Table 7.1. Table 7.1: Checklist for logistical and other support requirements for equipment mobilization and deployment TRAINING Training plans in place Demonstration of training records EQUIPMENT The response equipment is fit for purpose to meet its operational requirements in terms of operating environment, oil type, response strategy and equipment quantity. Equipment is maintained in good condition under the control of a functioning planned maintenance system. Maintenance records to be kept Equipment defects and failures are recorded and monitored Equipment lifting gear is inspected and coded Lifting Gear register to be maintained Equipment hydraulic hoses are subject to a management plan Response equipment is stored under suitable conditions. Dispersant stocks are properly stored and are subject to a management plan testing and replaced when no longer effective. Response equipment is stored in a mobilization ready mode. 38 P a g e

45 PERSONNEL Guaranteed access to a trained team of responders or contractors to operate and deploy equipment. A functioning duty roster to ensure 24/7 cover. Capability to effectively maintain equipment. Evidence of welfare, health, medical and vaccination programs to meet response needs. INFRASTRUCTURE Sufficient operational bases and offices to deliver response. Sufficient warehousing and equipment storage facilities to deliver its response services Suitable fire and security arrangements to protect facilities and assets. Suitable communications capacity to manage mobilization and deployment of equipment. Suitable lifting and materials handling equipment to deliver response. Suitable mobilization links (road, sea and air) to deliver a response. 7.2 Delivering the National Response Strategy The NOSCP identifies the following response strategies that could be used for spills in Lebanese waters: Aerial surveillance Dispersants Containment and recovery Protection Shoreline clean up Consequently, a national response capability must be able to deliver each of these strategies in a timely manner. The plan also outlines guidelines for response times and, as such, equipment must be stored in strategically considered locations, i.e. airports and ports and/or near to major road networks. Clearly, given the considerable planning effort and financial implications of establishing an in-country resource, this is something which must be carefully planned and which will develop over time as expertise in country increases and financial constraints allow. As described in section 8.1 simply purchasing equipment does not constitute a response capability. Responsibility for building the capability over time will be with the MOPWT - DGLMT as National Competent Authority and it will be within their remit to carry out activities focused on resource building. The first phase should be comprised of the following activities: 1. Establishing a national equipment inventory: The requirement for ports, oil handling facilities, and offshore installations to have a Tier 1 resource must be establishing and enforced. This will increase the stockpiles of locally available equipment. This equipment should then be registered on a national database. Where these facilities are, government owned, this should be straightforward, however the co-operation of APIC companies will also be necessary. Memorandums of Understanding (MOUs) should be put in place to facilitate the deployment of equipment for national response. 2. Establishing a national equipment stockpile: This will be equipment offering a first line of defense before the arrival of additional regional and international resources. Without further analysis, research, and budget, the consultancy is not able to specify exact requirements. What is necessary that 39 P a g e

46 it delivers the response strategies identified under emergency conditions and an addition is something that can be built on. As a starting point, the following packages and locations is given as an example: Strategy: Aerial surveillance Location: Domestic airport or military airbase with access to suitable facilities Equipment package Digital camera GPS tracking Remote sensing equipment Quantity: Fixed wing and helicopters as available for aerial surveillance and dispersant application. Strategy: Dispersant application - aerial Location: Domestic airport or military airbase with access to suitable facilities Equipment package Suitably adapted fixed wing aircraft Dispersant delivery system Suitably adapted helicopter TC3 Helicopter dispersant bucket. Chemical dispersant, stored in intermediate bulk containers (IBCs) Quantity: Fixed wing and helicopters as available for aerial surveillance and dispersant application. Strategy: Dispersant application - vessel Location: Vessel mounted Beirut, Tripoli, Zahrani or alternative Government oil terminals, if Zahrani and Tripoli already have acceptable packages. Equipment package Dispersant pumping system with spray arms or AFEDO nozzles Five cubic meters Slickgone NS Dispersant approved chemical dispersant, stored in intermediate bulk containers (IBCs) Quantity: 3 Packages, TOTAL PRICE FOR 3 x PACKAGES = 80K 40 P a g e

47 Strategy: Open Sea Equipment Recovery packages: Locations: To be based in Beirut and Trablous, but will also need suitable vessels to be based there with them Equipment package 1x 400m Offshore Boom on Reels, deployable in 2 x 200 meter sections if required. 2 x Air Fan inflators 2 multi capable skimmers plus hydraulic Power Pack 1 Weir Skimmer with heavy oil accessories water injection in discharge or oil loader plus hydraulic power pack 1 25 cu meter inflatable storage barge Quantity: 2 Packages for open sea. Could be split into 2 x 200 metre boom sections for inshore operations or with more recovery vessels. Total budget price = 600k Strategy: Shoreline response package Locations: To be based in 3 locations north of Beirut, as recommended by the Risk Assessment, close to sensitive areas. Equipment package: 1 response trailer 1 x 500 m inflatable boom, to include 100 m shore sealing boom 1 x Brush or shallow water weir skimmer and pump unit for heavy oil and 1 disk skimmers for medium and light oils 4 x Fastank 2000, including box/ground sheet/liner 1 x sets Shoreline flushing equipment 1 x packages of Absorbent pads and 600m absorbent boom 1 set Shoreline ancillary equipment, PPE sets for 60 personnel oil resistant coveralls, gloves, boots, vapor masks, goggles. 1 x Inflatable boat with water jet or outboard engine for shoreline protection fitted with center of rotation towing posts deployments Stored in 10ft ISO container Quote for 3 shoreline packages, Total budget price = 620k Strategy: Port response package (Tier 1) Location: Ports requiring a Tier 1 package, to be determined by qualified OSR surveyors Tier 1 Equipment package: 200 m fence or inflatable boom Multi oil Skimmer and hydraulic Pump Unit Fastank 2000, including box/ground sheet/liner Absorbent pads 1 bale 200 meters Adsorbent boom 41 P a g e

48 5 Personal Protective Equipment sets Boots, oil resistant coveralls, gloves, goggles, vapor masks 10 foot ISO container Quote for 1 port package Total budget price = 65k Strategy: Offshore installation Tier 1 package (supplied at Tier 1 level, crude oil only) Location: As required by LPA Equipment package to be carried on platform standby vessels 200m Offshore Boom on Reel Air Fan inflator Light to medium oil type skimmer and power pack Weir Skimmer with hydraulic power pack and accessories - water injection to discharge and optional oil loading ramp 25cum Inflatable Storage Barge Boatspray Dispersant Application System (Ayles Fernie Boatspray 100 with AFEDO Nozzles) 5 x 1cu mtrs. Slickgone NS Dispersant Quote for one standby package for drilling operations. This may be amended if the drilling suggests only gas or condensate. This to be provided by the concession operator. This will not be a Lebanon Cost Total budget price = 300k Other packages that may be required include: Communications package Welfare package Wildlife response package Tracking buoys Utility vehicle packages These resources would represent a significant financial equipment. It is therefore recommended, and in line with contingency planning principles, that these resources are developed in conjunction with industry. Tier 1 port packages and Tier 1 offshore packages will clearly be provided by the operator, however, in addition, industry could contribute to the national stockpile, possibly though a small levy on all imported oil. It may also be possible to build it as a regional resource with other governments contributing. 3. Establishing access to Tier 3 resources: Key to the provision of a Tier 3 response capability will be the analysis of the response resources available regionally and internationally. This will include an understanding of what is available in other national stockpiles and what equipment is held by industry. The OGP/IPIECA Finding 6: The global distribution and assessment of major oil spill response resources, gives an overview of the distribution of industry, or privately run, response stockpiles, Figure 1 below. If Lebanon was a member of OSRL, it would have access to this network through the Global Response Network (GRN). In addition, by working closely with REMPEC Lebanon will facilitate access to regional government owned equipment and a wealth of technical expertise. 42 P a g e

49 Figure A1: Global distribution of response stockpiles 43 P a g e