[Federal Register Volume 79, Number 151 (Wednesday, August 6, 2014)]
[Notices]
[Pages 45832-45837]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-18608]
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DEPARTMENT OF THE INTERIOR
Bureau of Safety and Environmental Enforcement
[Docket ID: BSEE-2014-0006; 14XE8370SD ED1OS0000.JAE000 EEGG000000]
Notice of Availability for GENWEST EDRC Study and the National
Academy of Sciences Letter Report (on the GENWEST Study); Comment
Request
ACTION: Notice.
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SUMMARY: The Bureau of Safety and Environmental Enforcement (BSEE) is
inviting you to provide comments on the GENWEST Systems, Inc.,
Effective Daily Recovery Capacity (EDRC) Study, National Academy of
Sciences (NAS) Letter Report summarizing its peer review of the GENWEST
Study, and comments provided by BSEE regarding each document.
Background: EDRC is a calculation method established within BSEE's
and the United States Coast Guard's (USCG) regulations to assign an oil
recovery capability value to oil skimming
[[Page 45833]]
equipment. Although the EDRC methodology was finalized in the early
1990's and has been an integral component of industry response planning
and readiness for the past 20 years, the methodology came under heavy
scrutiny in the wake of the 2010 Deepwater Horizon oil spill. This
spurred an open debate and ongoing dialogue on how to best improve the
EDRC planning standard. In late 2011, BSEE contracted with GENWEST
Systems Inc. to evaluate the EDRC methodology and to develop
recommendations for improving the planning standard for the mechanical
recovery of oil on water. GENWEST's final report produced the concept
of Estimated Recovery System Potential (ERSP), an oil encounter rate-
based calculator that evaluates mechanical recovery equipment as a
complete system as opposed to focusing on an individual component such
as a skimmer or an intake pump. Shortly thereafter, BSEE contracted the
National Research Council's Ocean Studies Board to conduct an
independent, third party peer review of the ERSP methodology. The
resulting National Academy of Sciences (NAS) Peer Review Letter Report
validated the ERSP standard as a sound methodology and a significant
improvement over EDRC. The peer review also identified a number of
areas for further consideration where ERSP might be improved. BSEE is
continuing to develop and refine the ERSP methodology, with the intent
of evaluating ERSP as a potential revision to BSEE's oil spill response
plan (OSRP) regulations. This notice provides a high level summary of
some of the key elements of both documents, as well as BSEE comments
regarding each document. It also includes BSEE's response to
recommendations in the NAS Letter Report. While the development of a
new planning standard for calculating the mechanical recovery of spills
continues to undergo additional research and refinement, this notice
provides an early opportunity for public viewing and comment on the
GENWEST EDRC Study and NAS Letter Report documents which are available
in the regulations.gov docket ID: BSEE-2014-0006 and on the BSEE Web
site at http://www.bsee.gov/Research-and-Training/Oil-Spill-Response-Research/Projects/Project-673/, as well as an opportunity to comment on
the BSEE's responses to the findings and recommendations contained in
each document.
DATES: You must submit comments by October 6, 2014. The BSEE may not
fully consider comments received after this date. While BSEE does not
intend to publish another notice in the Federal Register solely to
respond to comments submitted to this specific request, all comments
received will be posted in the docket and considered as inputs into the
ongoing analyses regarding the effort to improve the existing EDRC
planning standard, and will become part of the official agency record
for this project. As such, the contents of any comments received may be
used and/or cited, as appropriate, in the preambles of future BSEE
rulemaking documents that would implement an updated mechanical oil
recovery planning standard as part of BSEE's OSRP regulations.
ADDRESSES: You may submit comments and additional materials by any of
the following methods.
Electronically: Go to http://www.regulations.gov. In the
Search for box, enter BSEE-2014-0006, then click search. Follow the
instructions to submit public comments and view supporting and related
materials available for this notice.
Email: [email protected] or mail or hand-
carry comments to the Department of the Interior, Bureau of Safety and
Environmental Enforcement, Oil Spill Response Division, 381 Elden
Street, HE 3327, Herndon, Virginia 20170, Attention: Mr. John Caplis.
Please reference GENWEST EDRC Study and the National Academy of
Sciences Letter Report in your comments and include your name and
return address.
FOR FURTHER INFORMATION CONTACT: Mr. John Caplis, Oil Spill Response
Division, 703-787-1364, [email protected] to request additional
information about this notice.
SUPPLEMENTARY INFORMATION:
The Current EDRC Planning Standard: The current EDRC planning
standard was developed as part of a negotiated rulemaking process
involving Federal and state government, industry, and non-governmental
organizations following the passage of the Oil Pollution Act (OPA) of
1990 (Pub. L. 10, 1-380, Aug 18, 1990, as amended). This regulatory
methodology was intended to quantify the amount of oil spill response
equipment (i.e., skimmers) needed by plan holders for an effective
response to their worst-case discharge (WCD) spill scenario. The
formula for EDRC has not changed since its adoption in 1992:
EDRC = T x 24 hours x E
In this formula, ``T'' is a skimmer's throughput (or recovery) rate
in ``barrels per hour'' and ``E'' is an efficiency factor that was set
at 20 percent (or 0.2).
In practice, the method has been applied as the hourly throughput
rate (as determined by the manufacturer's assigned nameplate recovery
rate) multiplied by 24 hours and then discounted by a 20 percent
efficiency factor. The result is an estimate of the number of barrels
(bbls) of oil that can be recovered in any daily operational period. If
a skimmer requires a pump that determines the throughput of fluids, the
pump capacity becomes the determining factor in assigning an EDRC value
to a piece of skimming equipment.
The 20 percent efficiency (de-rating) factor was determined through
consensus by an Oil Spill Response Plan Negotiated Rulemaking Advisory
Committee. The de-rating factor accounts for a mix of environmental and
operational considerations (such as temperature, sea state, oil
viscosity, hours of daylight, the presence of debris, and the ability
to separate oil and water) that would limit or reduce the effectiveness
of a skimmer's capability to recover oil over a 24-hour operational
period. There are other critical influences on mechanical recovery that
were not incorporated into the EDRC calculation. Some of the most
important factors omitted include oil encounter rate (i.e., the rate at
which a skimmer is able to access spilled oil), onboard storage
capacity, and human factors (proficiency in skimmer operation).
Observations and Criticisms of EDRC During the Deepwater Horizon
Oil Spill: The Deepwater Horizon oil spill dramatically highlighted how
mechanical recovery systems can be significantly limited by low
encounter rates. Emanating from a well nearly a mile below the ocean
surface, the spilled oil surfaced over a wide geographical area and had
already thinned much in terms of oil thickness. The oil slick that was
available for recovery was widely discontinuous, had a large, expanding
areal footprint, and a rapidly diminishing surface thickness. An
unprecedented quantity of skimmers, boom, and other types of spill
response equipment were cascaded in from across the United States, as
well as from other nations, resulting in a massive amount of offshore
mechanical recovery capability that was used during the response.
Despite this effort, the aforementioned factors worked against the
mechanical recovery task forces operating offshore--reducing their
overall effectiveness in encountering, containing and recovering the
oil. As a result, significant amounts of shoreline oiling occurred
across the Gulf of Mexico. Both government and industry-sponsored
lessons learned reports identified the performance and effectiveness of
skimming systems as a
[[Page 45834]]
focal point in their observations and findings.
The National Commission on the BP Deepwater Horizon Oil Spill and
Offshore Drilling's Final Report, BP Deepwater Horizon Incident
Specific Preparedness Review (ISPR) Final Report, and Joint Industry
Oil Spill Preparedness and Response Task Force (JITF) Second Progress
Report all highlight the limitations of the EDRC methodology, and
recommend improvement of the mechanical recovery planning standard. The
National Commission report states that EDRC should be revised to
encourage the development of more efficient systems. The BP Deepwater
Horizon ISPR Report points out that the total EDRC for equipment used
on-scene during the spill far exceeded BP's mandated OSRP requirements.
However, this extensive armada of mechanical recovery equipment did not
recover oil quantities that corresponded to their aggregated EDRC
values. The ISPR Report recommends that the regulations be revised to
include a reliable, dynamic efficiency measure that accurately reflects
the limitations of encountering significant volumes of oil on the
water, and also should encourage more research and development to
improve the effectiveness of skimmer systems. The JITF Second Progress
Report states that government and industry must recognize the
limitations of existing mechanical recovery equipment, and pursue
incentives to improve boom and skimmer designs, especially in the
offshore environment. Furthermore, the JITF also recommends that the
government revisit the EDRC regulations in order to determine if
improvements to the planning standard are necessary.
The EDRC Study: Through a competitive procurement, BSEE initiated a
third party, independent research contract to:
(1) Evaluate existing EDRC methodologies,
(2) examine de-rating in order to identify the key variables that
impact skimming system recovery rates,
(3) develop recommendations for an improved mechanical recovery
planning standard, and
(4) create a user-friendly, computer-based planning tool based on
those recommendations.
GENWEST Systems, Inc., a private sector information management and
environmental services consulting firm, was awarded the research
contract in September 2011 and completed its final project report in
December 2012.
The capstone of the GENWEST report is a new methodology and
computer-based planning tool for estimating mechanical oil recovery
capability called the ERSP calculator. Based on algorithms similar to
those within the GENWEST developed Response Options Calculator, the
ERSP calculator is an oil encounter-rate based planning tool that
measures the performance of an entire mechanical recovery skimming
system.
The ERSP calculator addresses the effect of encounter rate on a
skimmer through three key variables: The swath width of the skimming
system configuration, the speed of advance of the skimming system
relative to the motion of the oil slick, and the thickness of the oil
being collected. The calculator uses three different nominal oil
thicknesses that decrease with time over a 3-day period in order to
model the reduced amounts of oil available to a skimming system due to
the effects of spreading. The selection of the nominal oil thickness
values (0.1 inch for Day 1, 0.05 inch for Day 2, and 0.025 inch for Day
3) are based on the results of over 400 computer simulations of oil
spreading where temperature, wind, discharge volume, and oil type were
varied in different combinations. The three resulting thicknesses that
were selected are representational values that are reasonably
acceptable across a wide range of scenarios. The calculator enables the
plan holder to input customized values for both the swath width and the
speed of advance for a skimming system, which are then used to estimate
areal coverage for a recovery system during an operational period. The
calculator then applies the nominal oil thicknesses to the areal
coverage achieved in order to estimate the oil encountered.
The next steps in the ERSP methodology apply the ``recovery''
parameters of the skimming system to the amount of the oil encountered.
These parameters include an estimate of the oil recovered compared to
the total volume of the fluids recovered (i.e., the oil/water recovery
ratio otherwise referred to as the system's Recovery Efficiency), an
estimate of the oil removed compared to the oil encountered (i.e., the
effectiveness of the containment elements of the skimming system as
opposed to entrainment of the oil, referred to as Throughput
Efficiency), the skimmer nameplate recovery rate, the amount of onboard
fluid storage, decanting or oil/water separation abilities, intake and
offload pump rates, and offloading set up and transit times. The
application of the ``encounter rate'' and ``recovery'' system
variables, when applied to the available oil thicknesses for each
operational period, create estimates of the system's effective recovery
potentials for Day 1, Day 2, and Day 3 of a spill. If a skimming
system's configuration remains fixed over time, then the recovery
potential of the system will decrease from day to day as the oil
available for skimming also decreases; however, a skimming system's
configuration can often be adjusted during subsequent operational
periods to maintain or minimize the loss of recovery potential.
The National Academy of Sciences Letter Report: The National
Academy of Sciences (NAS) is a nonprofit, self-perpetuating society of
scholars dedicated to the furtherance and use of science and technology
for the general welfare. Under the charter granted to it by Congress,
the Academy has a mandate to advise the Federal government on
scientific and technical matters. The National Research Council was
organized by the NAS as the principal operating agency for the
Academies in providing services to government, the public, and the
scientific communities. In the spring of 2013, BSEE contracted the
National Research Council's Ocean Studies Board to conduct an objective
technical evaluation of the GENWEST EDRC Report and the ERSP
methodology. The Ocean Studies Board assembled an ad hoc study
committee of five subject matter experts that completed and delivered
their Peer Review Letter Report in November of 2013.
The Letter Report concluded that the ERSP methodology was sound and
a substantial improvement over the current EDRC methodology. While the
committee cited many improvements, they felt that the greatest strength
of the new ERSP methodology was its evaluation of the entire skimming
system as a whole as opposed to any single part of it.
The committee's most significant concerns regarding the ERSP's
methodology focused on the nominal oil thicknesses selected by the
GENWEST team. These thicknesses were meant to be representative of the
``thickest'' oil available during each operational period. The ERSP
methodology assumes that a skimming system will be able to operate in
oil at these nominal thickness values for the entire time it is
skimming during the operational periods on the first three days. The
committee, however, felt that the real distribution of thick oil will
be discontinuous, or patchy, and that the ERSP model should address
this factor in its calculations. The Letter Report also goes on to
suggest that some field observations for slick thicknesses are
generally less than those used by the ERSP calculator. The study
[[Page 45835]]
committee concluded that the GENWEST thicknesses are likely to
overestimate actual encounter rates and would provide an overly
optimistic assessment of a skimming system's actual recovery potential.
The committee recommended applying a ``patchiness de-rating factor'' to
the encounter rate calculation, and also suggested adding the ability
to enter different oil thickness values into the calculator. Encounter
rates would then be adjusted for the discontinuous nature of the thick
oil patches, and more customized thicknesses could be entered into the
calculator based on the circumstances of the release scenario and the
particular properties of the plan holder's oil type.
The committee also recommended that regulators work with the
GENWEST team to develop a more detailed user manual that would further
explain the ERSP calculator assumptions, provide additional guidance to
users on the selection of certain input values, and would provide
default values for some of the more uncertain or unknown parameters.
The committee also recommended the use of the American Society for
Testing and Materials (ASTM) Standard F2709-08, as the means to
determine the Nameplate Recovery Rate value in the ERSP calculator.
Finally, the committee recommended a broader approach of considering
all potential response options in future rulemakings.
BSEE Comments Regarding the GENWEST Study: BSEE believes the
GENWEST EDRC study provides a solid foundational work for building an
improved mechanical recovery planning standard. The ERSP methodology
has necessarily sacrificed the increased accuracy of a more complex and
customizable model in order to create a simple, accessible planning
tool that is applicable across a wide range of planning scenarios. In
striking this important balance, the ERSP methodology successfully
addresses many of the issues identified concerning EDRC, and also
incorporates some key compromises into its assumptions and algorithms
that BSEE will have to examine carefully. BSEE submits the following
statements for public review and comment regarding its assessment of
the ERSP calculator and the GENWEST EDRC Study:
ERSP Creates Incentives for More Effective Skimming Systems: The
ERSP methodology is a practical approach to evaluating mechanical oil
recovery systems that includes incentives for improving system
performance. The ERSP calculator rewards recovery systems that maximize
encounter rate and minimize skimming downtime during offloading
periods. The calculator provides plan holders and Oil Spill Removal
Organizations (OSROs) with a very useful tool for assessing and
comparing different configurations for almost any type of skimming
system. Plan holders can input different values into the calculator for
many of the recovery system's variables, such as swath width, speed,
decanting, onboard storage, and pump rates, in order to explore the
resultant effects on encounter rate and recovery potential. Plan
holders and OSROs will be able to identify the parameters that will
best increase a system's recovery potential, and should be able to use
this information to guide their design, investment, and operational
deployment decisions.
The calculator's algorithms will encourage plan holders and OSROs
to acquire and configure skimming systems with higher areal coverage
rates (through increased swath widths or increased speeds of advance
relative to the motion of the oil), higher nameplate capacities and
recovery efficiencies, and more effective collection and containment
arrangements that limit the entrainment of oil. The calculator will
also create incentives for developing skimming systems that have
increased onboard storage, faster oil transfer rates, and effective
decanting capabilities.
ERSP Challenges in the Nearshore and Inshore Operating
Environments: ERSP algorithms and operating incentives are well suited
for offshore skimming operations, but are less so for the nearshore and
inland operating environments. Decanting in the offshore environment
provides a tremendous advantage that maximizes the use of onboard
storage and reduces offload times. However, decanting is not realistic
for many nearshore and inshore scenarios. In more confined, shallow
areas, skimming systems with large swath widths and large onboard or
tethered storage solutions are likely to be ineffective. Advancing
skimmers used in nearshore areas will still require high recovery
efficiencies; however, shallow drafts and maneuverability now become
more important than large swath widths and bulky onboard storage
arrangements. As a result, many nearshore skimming systems are likely
to have ERSP potential values significantly below their EDRC ratings,
despite being optimally configured for their operating environments.
Mechanical recovery in inshore areas is even more disassociated with
many of the incentives of the ERSP calculator, as mechanical recovery
in these settings often relies on deflection and collection booming and
stationary skimming arrangements.
While ERSP may still be a useful measure of potential in the
nearshore area, limits may be necessary on the use of certain ERSP
variables, such as swath width and decanting. It may also be necessary
to consider a mixture of different equipment rating schemes and
requirements for mechanical recovery in these operating environments.
The rating of skimming systems and the reviews of OSRPs in these
operating areas may require a more scenario-based approach than
regulators have used in the past.
ERSP Emphasizes a Rapid Response Capability: As the calculator
applies substantially decreasing oil thicknesses over the first 3 days
of a spill, the ERSP methodology creates a powerful incentive for
skimming systems to arrive onsite as quickly as possible. The
calculator clearly demonstrates that plan holders and responders will
reach a point of diminishing returns for bringing in additional
mechanical recovery equipment as time progresses and oil becomes less
available for skimming. While this circumstance is somewhat mitigated
during a sustained release such as a well blowout (where there may be
fresh, thick, concentrated oil available each day), the fact remains
that mechanical recovery equipment performs at its highest recovery
potential in the earliest hours of a spill when encounter rates can be
maximized.
ERSP Does not Address Staging, Mobilization, or Transit Times:
While the ERSP methodology emphasizes a rapid response, it does not
factor into its calculations the time it takes to mobilize and deliver
a mechanical recovery system to the site of a spill. GENWEST, at the
direction of BSEE, used a fixed operational period of 12 hours for the
EDRC Study, and did not incorporate the effects of equipment
mobilization and delivery times on recovery potentials. The ERSP
calculator does, however, have an input variable for each day's
``operating period'', which could be reduced to account for these
factors related to response time.
The OSROs and plan holders could adjust the operating period
accordingly if BSEE provides guidance on how to account for each
mobilization factor. The BSEE currently does not factor response times
into its regulations and currently does not require adjustments to EDRC
values based on mobilization times. Additional guidance and regulations
may be needed in order to adequately account for mobilization times
when inputting the operational period into the ERSP calculator.
[[Page 45836]]
ERSP Calculations Assumes the Use of Best Practices and Best
Commercially Available Technology: In the selection of representative
oil thicknesses for each operational period, the ERSP calculator
assumes that operators will be using the best technologies commercially
available, such as remote sensing tools, as well as operational best
practices, in their skimming activities. This is especially important
for ensuring operator proficiency, and for identifying, tracking, and
keeping recovery systems in thick oil continuously during skimming
operations. If operators do not employ such technology and best
practices, then the ERSP calculator is likely to provide an overstated
recovery potential for a system. The calculator does not include any
built in incentives for the use of these critical best practices and
technologies. Creating these incentives or requirements may therefore
have to be addressed through regulatory requirements, industry
standards, and recommended practices.
BSEE Comments Regarding the NAS Letter Report: The BSEE agrees with
the NAS Letter Report findings that the new approach for evaluating
mechanical recovery equipment, Estimated Recovery System Potential
(ERSP), is basically sound and an improvement over methods currently
employed by BSEE and USCG oil spill response planning regulations. The
BSEE also acknowledges each of the insightful recommendations offered
for possible improvement in the NAS Peer Review Letter Report, and has
carefully considered their potential for improving the existing EDRC
and proposed ERSP methodologies. As stated earlier in this document,
BSEE believes that the ERSP methodology has necessarily sacrificed a
degree of accuracy associated with a more complex and customizable
model in order to create a simple, accessible planning tool that is
applicable across a wide range of planning scenarios. In striking this
important balance, the ERSP methodology successfully addresses many of
the issues concerning EDRC, but also incorporates some key compromises
into its assumptions and algorithms. The NAS Letter Report identifies
some of these compromises as shortfalls, and provides several
recommendations that would increase the accuracy of the ERSP
calculator, but would also significantly increase the complexity of
using the calculator. BSEE carefully weighed these sometimes opposing
factors when evaluating the NAS recommendations, and ultimately placed
a premium on ensuring the calculator remained a simple, useful planning
tool that is best suited to the needs of plan holders and government
reviewers. Where BSEE could not fully address the NAS's concerns or
suggested improvements with changes to the ERSP calculator itself, BSEE
will work to address the issues where possible through other associated
processes such as potential changes to the OSRP regulations. As such,
BSEE provides the following comments with regard to the NAS
recommendations:
Using a ``System of Response Options'' Approach: The NAS recommends
BSEE consider adopting a systems approach in the OSRP regulations that
incorporates other response options in addition to mechanical oil
recovery capabilities. BSEE fully agrees with this statement and will
be conducting further studies to explore the development of additional
planning tools and potential requirements for other response options
such as dispersants and in situ burning.
Using an ASTM Standard to Estimate Nameplate Recovery Rate and
Recovery Efficiency of a Skimming System: The NAS recommends that the
nameplate recovery rate input parameter for a skimmer be generated
through the use of operational testing using a standard such as ASTM
F2709-08. The NAS also recommends that the input value for skimmer
Recovery Efficiency (RE) could be generated by using ASTM F2709-08 or a
similar standard. While BSEE would agree with the suggestion to use
ASTM standards whenever appropriate, it should be noted that the ASTM
F2709-08 standard tests a skimming system's performance in ideal
conditions to determine a skimmer's nameplate recovery rate, and does
not account for the effects of sea state or other operating conditions
that may reduce a system's effectiveness and efficiency. ASTM F2709-08
does offer the promise as a low cost, easily replicated test for
producing Nameplate Recovery Rate input values. As this testing method
provides an assessment of optimal recovery rates measured under ideal
skimming conditions, BSEE has been in discussions with members of the
ASTM F20 Committee on how to best apply the existing standard or with
regard to possible adjustments to the F2709-08. BSEE will continue to
discuss and evaluate the practicality of using ASTM 2709-08, or of
developing a new or revised standard that would complement the use of
ERSP with ASTM.
Developing More Guidance on Selecting Input Values and a More
Detailed ERSP User Manual: The NAS recommends developing a more
detailed user manual that provides the logic behind the default values
for certain parameters, and provides additional guidance for selecting
and entering each of the user-defined inputs. BSEE agrees that
additional information in a more detailed user manual would be
beneficial to both response plan holders and government reviewers. BSEE
will implement this recommendation to provide more background
information on ERSP assumptions and any specified default values, and
develop additional guidance on the selection of user-defined input
variables in a more detailed user manual.
Reducing Oil Thickness Values to Account for the Discontinuous
Nature of Oil Slicks: The NAS recommended adjustment of the ERSP
methodology to account for the discontinuous nature of oil slicks,
specifically as it relates to a skimming system's ability to
continuously encounter oil for removal. Additionally, NAS reviewers
observed that the representative oil thickness values chosen by GENWEST
are higher than those gathered during field observations from actual
spills or laboratory tests. The NAS concluded that the lack of a
spatial element for the patchiness of oil slicks along with the current
values chosen for oil thicknesses in the ERSP calculator would
overstate oil encounter rates and recovery potential values, especially
on Day 2 and Day 3 of a spill. The BSEE acknowledges the discontinuous
nature of most oil spills as well as the fact that choosing a set of
oil thickness values that adequately represent actual encounter rates
over a wide range of scenarios is a very important but extremely
challenging aspect of developing the ERSP calculator. The BSEE
discussed this process at length with the GENWEST study team, and
believes the values selected for oil thicknesses by the GENWEST team
are valid planning values that adequately cover the very wide range of
variables involved across a very broad set of industry response plans,
and do not need to be further adjusted. The GENWEST study team ran over
400 modeling simulations varying for oil type, spill size, and ambient
conditions such as wind and temperature in order to generate the
distribution of expected thickness values. GENWEST informed BSEE that
they factored in the discontinuous nature of oil slicks in their
modeling when they selected the thickness values. GENWEST also
commented that the thickness values were selected with a bias toward
responding to a very large worst case discharge (WCD) spill volume,
which
[[Page 45837]]
would increase the thickness values over those measured during smaller
controlled discharges and spills of opportunity. BSEE agrees with these
statements and believes the thickness values selected by GENWEST are
valid for addressing response planning to a WCD as required under the
OPA.
Incorporating Multiple Oil Thickness Scenarios Into the ERSP
Calculator: The NAS recommends developing several planning scenario
options that would allow plan holders to fine tune and customize their
oil thickness values based on their oil type and facility-specific
parameters. This would allow a plan holder to tailor their ERSP
calculations for their specific operational conditions (such as a
sustained subsea loss of well control of medium crude oil in the Gulf
of Mexico or a well with heavy crude in the Arctic). While these
recommendations may improve the accuracy of individual plan holders'
specific ERSP calculations, BSEE believes the significant increase in
complexity associated with using this approach far outweighs the
minimal gains in accuracy that might be realized for an individual plan
holder's ERSP values. At this time, BSEE does not plan to incorporate
multiple scenarios that would require the customized inputs for oil
thickness values to be estimated or selected based upon a plan holder's
oil type, environmental operating conditions, and discharge scenarios.
Assigning Uncertainty Values to ERSP Input Values: The NAS suggests
adding the ability for users to input uncertainty values attached to
user-selected inputs, and that additional guidance in the user manual
should be developed to guide users on how to interpret and use the
outputs that would result. The end result of using these uncertainty
values would be to create a probability range of ERSP outcomes rather
than a singularly defined number, which the NAS believed would provide
additional clarity on the accuracy of the ERSP data generated. BSEE
does not believe it is necessary for users to develop and input
uncertainty data, as this may unnecessarily complicate the use of the
calculator tool, and would not result in additional information that is
necessary for developing and/or reviewing effective OSRPs.
Additional Public Review: The NAS recommended the calculator
methodology be exposed to an additional round of public review by a
broad range of subject matter experts. Currently, BSEE relies on the
NAS Letter Report itself as the primary means for subjecting the ERSP
study to a rigorous ``expert'' assessment. However, BSEE fully
acknowledges the value of additional public review of critical
documents such the EDRC Study. BSEE believes publishing this Federal
Register notice that announces the results of both the EDRC Study and
NAS Letter Report (as well as BSEE's analysis and response to these
documents), and providing an opportunity for public review and comment,
successfully meets the intent of the NAS recommendation. Additionally,
if any portion of the ERSP methodology were to be incorporated into a
future Notice of Proposed Rulemaking (NPRM), there would be another
opportunity, in addition to this Federal Register notice, for public
review and comment.
Public Availibility of Comments: Before including your address,
phone number, email address, or other personal identifying information
in your comment, you should be aware that your entire comment including
your personal identifying information may be made publicly available at
any time. While you can ask us in your comment to withhold your
personal identifying information from public review, we cannot
guarantee that we will be able to do so.
Docket: All documents in the docket are listed in the http://www.regulations.gov index. Although all documents submitted will be
listed in the index, some information may not be publicly available,
e.g., confidential business information or other information whose
disclosure is restricted by statute. Certain other material, such as
copyrighted material, may be publicly available only in hard copy.
Otherwise, publicly available docket materials are available
electronically in http://www.regulations.gov.
Dated: July 29, 2014.
David M. Moore,
Chief, Oil Spill Response Division.
[FR Doc. 2014-18608 Filed 8-5-14; 8:45 am]
BILLING CODE 4310-VH-P