The BP Oil Spill Regional Plan (BP Regional Plan) is online here. This document is relied on and incorporated in the Exploration Plan for the Macondo site (online here) via the following certification:
since BP Exploration & Production Inc has the capability to respond to the appropriate worst case spill scenario included in its regional OSRP approved on November 14, 2008 and since the worst-case scenario determined for our Exploration Plan does not replace the appropriate worst-case scenario in our regional OSRP, I hereby certify that BP Exploration & Production Inc has the capability to respond to the maximum extent practicable to a worst-case discharge …resulting from the activities proposed in our Exploration Plan.
The BP Regional Plan was prepared by The Response Group, 13231 Champion Forest Dr., Suite #310, Houston, TX 77069 281-880-5000 url. They appear to be an American group – as are the drilling contractor (Transocean) and major suppliers such as Haliburton.
In light of recent events, some surprising aspects of the BP Regional Plan have attracted little to no comment thus far despite the massive coverage.
First and perhaps most surprisingly, the scale of the blowout (even if 20,000 barrels per day) is an order of magnitude lower than the “Worst Case Scenario” contemplated in the BP Regional Plan. On page 509, the Worst Case Scenario for an offshore blowout of an exploratory well is said to be 250,000 barrels per day.
Given the anticipated reservoir thickness and historical productivity index for the Miocene, worst case discharge is expected to be 250,000 barrels of crude oil per day. Calculations are based on formulas defined by MMS regulations.
In addition, the pro forma location of such a blow out in the regional plan (28° 30’ 47.42” N, 88° 52’ 40.84” W, Distance to Shore: 33 miles ) is a reasonable pro forma location for Macondo. The Response Plan even shows Plaquemines Parish as the landfall most likely to be affected by an unabated spill, so Billy Nungasser’s problems were not exactly unanticipated.
Although the Response Plan is 583 pages in total, there are only a couple of pages (see 509 ff) that say what they will do in the event of an offshore blow out. And these couple of pages say little more than that they have standing contracts with regional responders (Marine Spill Response Corporation (MSRC) and the National Response Corporation (NRC) ) who are said to have more than sufficient skimming capacity to deal with the Worst Case Scenario of a 250,000 barrel/day blow out. (I presume that the BP Oil Spill Response Plan is more or less similar to Response Plans by other operators in the region.)
Here are the salient paragraphs:
BP will make every effort to respond to the Worst Case Discharge as effectively as possible. BP has contracted with Clean Caribbean & Americas (CCA), Marine Spill Response Corporation (MSRC) and the National Response Corporation (NRC) as primary Oil Spill Removal Organizations. Contact information for the OSROs can be found in Figure 7-6A. Upon notification of the spill, BP would request a partial or full mobilization of the resources identified in the attached Appendix E, including, but not limited to, dispersant aircraft from CCA, ASI & MSRC and NRC & MSRC skimming vessels.
Offshore response strategies may include attempting to skim utilizing MSRC &NRC’s Oil Spill Response Vessels (OSRVs), Oil Spill Response Barges (OSRBs), ID Boats, and Quick Strike OSRVs, which have a combined derated recovery rate of 491,721 barrels/day. Temporary storage associated with the identified skimming and temporary storage equipment equals 299,066 barrels.
The Plan has a short discussion of dispersants – a discussion that shows that dispersion capacity of 6-7,000 barrels/day is far short of Worst Case requirements – though not the original discharge estimates. Corexit is specified as the dispersant, so this should not have been a surprise to regulators and environmental organizations.
Plaquemines Parish is mentioned as the most likely area to be affected. However, the Response Plan contains nothing specific to Plaquemines Parish – only B-school generalities e.g. the following:
If the spill went unabated, shoreline impact would depend upon existing environmental conditions. Nearshore response may include the deployment of shoreline boom on beach areas, or protection and sorbent boom on vegetated areas. Strategies would be based upon surveillance and real time trajectories provided by the Response Group that depict areas of potential impact given actual sea and weather conditions. Strategies from the Area Contingency Plan, The Response Group and Unified Command would be consulted to ensure that environmental and special economic resources would be correctly identified and prioritized to ensure optimal protection. The Response Group shoreline response guides depict the protection response modes applicable for oil spill clean-up operations. Each response mode is schematically represented to show optimum deployment and operation of the equipment in areas of environmental concern. Supervisory personnel have the option to modify the deployment and operation of equipment allowing a more effective response to site-specific circumstances. (For information on resource identification, see Section 11; for more information on resource protection methods, see Section 13.)
Overall, the “plan” for a Worst Case blow out of an exploratory well is extraordinarily cursory (though elsewhere the Plan is remarkably specific. For example, they specify that the center for public relations should have a podium and a wall clock.)
It seems to me that the response problem is a little different than characterized by commentators to date.
The blow out is “only” 20,000 barrels/day or so, while the Regional Plan says that the various response organizations have a skimming capacity of 491,721 barrels/day.
It’s not that the Response Plans didn’t contemplate a Worst Case as bad as the present blow out (they contemplated much worse scenarios). The problem seems to be that the effective skimming capacity seems to be vastly less than the rated capacity.
Obvious questions: how real is the rated capacity of 491,721 barrels/day? Is this apples and apples relative to a point discharge of 20,000 barrels/day? Does a larger dispersion cone reduce the effective capacity of the skimmers by a couple of orders of magnitude? Or is there some elementary mismatch between the apparent skimmer capacity and the job that needs to be done?
I have no personal knowledge of the technologies and am more or less throwing the topic up for discussion by readers more knowledgeable than me.
Another point. I also presume that the BP Oil Spill Response Plan (including prior editions) and Response Plans of other operators have been available not merely to regulators, but to environmental organizations for many years (I don’t know this, I am presuming it.) If effective skimming capacity is insufficient to deal with the present blow out – or whatever else is missing in the remediation capacity – shouldn’t this have been apparent to someone in the environmental movements? Has this been an ongoing topic of controversy for environmental organizations over the past 10 years? Not just in the abstract way of condemning all offshore drilling, but in the practical way of pointing out potential shortfalls in skimming capacity (or other practical defects in the Response Plan)? Just asking.
Climate Audit 