Ecological Management Action Plans
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EM-9 Oil and Produced Water Spill Prevention and Early Detection
EVALUATION METHODS
Components of Plan
EM-9 establishes an accessible, comprehensive computerized database
of petroleum and related fluids spills in the BTES. Interpretive information
from the database will be provided to agency and industry personnel
and the public to keep them informed of the magnitude and impacts of
oilfield related spills. The usefulness of the database and transfer
of information will be evident in increased awareness of the impacts
of such spills and eventually increased prevention of such spills in
BTES. Ultimately, number and volume of spills will be reduced along
with petroleum-related contaminants in the BTES.
Interrelationships Among Components
Existing databases are housed in LDEQ (both petroleum and oilfield
brine spills) and the NRC, oil spill data from the USCG and EPA.
The Oil Spill Prevention and Response Act created an Interagency
Council which is to assist the LOSCO in the development of a statewide
oil spill prevention and contingency plan (finished in 1995). The
LDNR Office of Conservation is one of several state agencies with
responsibilities for oil spill prevention. The responsibilities
and authorities of the above-named agencies are outlined in the
Action Plan.
•. LDEQ is the suggested lead implementor with assistance
from each of the above-named agencies. The LOSCO has the authority
under the Oil Spill Prevention and Response Act 1) to use funds
from the Oil Spill Contingency Fund for oil spill prevention and
response purposes, and 2) to delegate responsibility for the implementation
of an oil spill prevention program. LOSCO is identified as the source
of funding; the designated implementor would logically be LDEQ.
•. The development of this database overlaps with the objectives
of EM-8 (Nutrient, Bacteria, and Toxic Contaminant Load Evaluation)
and EM-13 (Contaminated Sediment Database).
Documentation of Plan Implementation and Success
Monitoring for this Action Plan includes assessing the timely implementation
of the components of the Action Plan, and the eventual success of implementation
(i.e., oil spill prevention increased and petroleum-source contaminants
reduced). The first component is not conducive to monitoring in the
traditional sense of data collection and analysis (e.g., water quality
monitoring), but rather a tracking. The monitoring of implementation
is designed to determine whether such a database was developed, whether
it was used in interpretation of information to the public, and whether
a better informed public (including agencies and industry) resulted.
Eventual project success can be monitored with an analysis of data that
shows a reduction of petroleum-related spills, and a reduction in petroleum-source
contaminants in the water, sediments, and biota of BTES. The success
of various Action Plans that target reduced sewage pollution, reduced
oil related spills, and storm water management may all be manifested
in similar improvements in water quality. If all Action Plans are working
in parallel and water quality improves, it will be difficult to determine
the cause and effect. Since the scale of implementation will vary among
Action Plans, the level of success in improved water quality will also
vary. The probability is high that implementation of any single management
scenario may have varying effects in different environments. It is also
possible that no single indicator may indicate program success, but
rather success will be seen in a combination of indicators. The end
result of multiple actions to improve water quality, however, will be
noticeable in indicators of basinwide ecosystem-level health (see CCMP-Part
4, "Monitoring Plan for Ecological Indicators"). Specific
examples of project success are proposed below. They can be expanded
or modified, should be reviewed periodically, and should be amended
as appropriate.
Plan Implementation
A time line developed jointly by the funding agency and the implementor
will provide the basis for the monitor to assess plan implementation.
Because of the multiple components, interactions of components, and
involvement of many agencies, a more detailed time line should be developed
to track the progress of the development of the plan. Examples of time
landmarks are:
•. A lead agency is selected as implementor, a project work
group is identified and responsibilities outlined, and a detailed
time line for the project is established (months 0-1).
•. Source of funding is identified and secured (months 2-6).
•. Appropriate, current databases for spills are identified
and assessed (months 1-3).
•. A database is developed to compile appropriate data from
the various sources that meets the information needs of the Action
Plan and a preventative oil spill program, and is installed on the
LDEQ computer system (months 3-6).
•. Database is maintained by relying on LDEQ field offices
and by LDEQ obtaining data from NRC (months 6-12).
•. Educational programs to inform industry, federal, state
and local entities of the seriousness of petroleum and related fluid
spill issues are developed and implemented (months 6-12).
•. Work group of LDEQ, EPA, USCG, and BTMC formed and informs
the Interagency Council of agency needs which must be met to comply
with the state oil spill contingency plan (months 6-9).
•. Work group of LDEQ, EPA, USCG, LOSCO and BTMC develops
plan for encouraging effective and fair enforcement of spill prevention
regulations and implements plan (months 4-12).
•. Plan developed and implemented for encouraging relevant
agencies to increase inspections of applicable facilities within
BTES (year 2).
•. Additional personnel assigned to inspect oil production facilities
(end of year 2).
•. Database is updated by relying on LDEQ field offices and
by LDEQ obtaining data from NRC (years 2-10).
•. Inspections for potential sources of petroleum spills conducted
by relevant agencies (years 2-10).
•. Work group of LDEQ, EPA, USCG, LOSCO and BTMC continues
encouraging effective and fair enforcement of spill prevention regulations
and implements plan (years 2-10).
•. Educational programs to inform industry, federal, state
and local entities of the seriousness of petroleum and related fluid
spill issues are modified to include costs associated with clean-up
vs. costs of prevention (year 2).
•. Educational programs disseminated to agency and industry
personnel and public (years 2-10).
•. Work group of LDEQ, EPA, USCG, LOSCO and BTMC works to
adjust and/or redirect spill prevention program into areas with
continuing problems (end of years 5 and 10).
•. State funds and resources dedicated specifically to petroleum
related spill prevention (within year 5-10 period).
•. Better informed public and agency personnel (end of years
5 and 10).
•. Increased petroleum and related spills prevention (end of
years 5 and 10).
Project success
•. Reduction in number of person-days in response to petroleum
related spills (end of years 5 and 10).
•. Reduction in the number and volume of spills reported and
responded to (end of years 5 and 10).
•. Reduction in contaminants from petroleum and related spills
in BTES (end of years 5 and 10).
Methods
Measurable parameters
Plan Implementation - The activities of various agencies outlined
above in implementing the plan will be monitored for indicators such
as:
•. Existence of spill database.
•. Spill database is functional (i.e., data can be accessed,
utilized, and analyzed). Data entered into database in acceptable
formats, etc.
•. Increased personnel assigned to oil production facility inspections.
•. Increased personnel assigned to and participating in educational
program development and dissemination.
•. Increased public, agency and industry awareness of petroleum
and related spill problems, causes, and preventative measures.
•. Problem areas for spills are addressed and efforts redirected.
Project Success - Any reductions in petroleum and related spills
will be assessed by a statistical analysis of:
•. Person-days dedicated to spill response.
•. Spill number and volume.
•. Petroleum spills and related fluids contaminants in water,
sediments, and biota of BTES.
•. Classification of non-compliance of water subsegments for
305(b) reports due to petroleum-related contamination.
Data collection methods
Plan Implementation - The monitor will contact the various
agencies involved in the implementation to gather data (examples below)
that will be incorporated into a monitoring project:
•. Check-off system according to time line of project developed
between funding agency and implementor as landmark dates are encountered
and project objectives are met.
•. List and descriptions of educational programs developed.
•. List of recipients of educational programs, including dates,
types of programs, and comments made by recipients of educational
programs as to usefulness of the program.
•. Project monitor accesses spill database and utilizes the
data in examples of data analysis listed above.
Project Success - The monitor will access appropriate databases
and conduct statistical analyses. Examples are:
•. Petroleum and related spills database.
•. Relevant agency personnel records.
•. Water, sediment, and biota contaminant data (e.g., LDEQ,
EPA EMAP, NOAA Status and Trends).
•. 305(b) Water Quality Inventory reports designation of water
subsegments.
Sample design and statistical methods
Plan Implementation - There are no relevant sample designs
or statistical analyses for the evaluation of plan implementation.
Project Success - Suitable baseline data may be available in
LDEQ, NRC, the proposed spill database, EPA EMAP, and NOAA Status and
Trends. Trends may not be identifiable after 5 years; however, the analysis
should be conducted. At a minimum, a determination of the usefulness
of the database will be made. Identification of any long-term trends
needs to be within the context of the variability of the system. Several
statistical methods applicable to analysis of trends may be suitable.
Data may be normalized and standard linear regression models can be
used to detect trends once sufficient data points have been obtained
(e.g., 15 years is considered the minimum for similar trend analyses
conducted by Rabalais et al. 1995). If data cannot be normalized, nonparametric
trend analysis techniques should be employed (e.g., modified Mann-Kendall
tau tests and seasonal Kendall slope estimator tests; see Hirsch et
al. 1982). Seasonal Kendall tau test is a nonparametric trend test that
is appropriate for detecting monotonic trends in "time series"
data, i.e., data routinely collected over time (or space). Differences
can also be assessed geographically by an analysis of variance on transformed
data for site differences. Where sites differ significantly, post-hoc
comparisons are run to determine which sites differ from others. Power
analysis will estimate the probability of detecting trends of a certain
magnitude given a certain number of observations (see Appendix D in
Regional Monitoring Program for The Galveston Bay Plan, Lane 1994).
N.B. Identification of trends or correlations does not provide cause
and effect relationships.
Cost estimates
Estimate one person-month per year for monitoring all the aspects of
the Action Plan and the cooperative efforts of each agency. Including
salary, fringe, incidental costs, and indirect costs = $8,000 for each
year (no inflation). Costs of statistical analyses are estimated at
4 person-months ($32,000 in each of years 5 and 10). A statistical consultant
should also be used in year 1 to help design the statistical analysis
to be employed at the end of years 5 and 10 and to determine the suitability
of existing data and what baseline data are needed ($16,000 in year
1). Modifications in monitoring plan (see below) should result in modifications
of cost.
Implementation of Monitoring
Monitor
A monitor selected by BTMC will prepare reports to be submitted to
BTMC. Although individuals involved in the implementation of the Action
Plan may prefer a team member to monitor the project, usually a Third
Party offers the best option as the responsible individual for the monitoring.
Independent reviewers should be free of vested interests, historic commitments,
unrestrained by mission statements, and free from personnel or budgetary
actions. The implementor and cooperating agencies will provide the project
monitor with data products listed above for subsequent assessment of
accuracy and incorporation into reports. The monitor should interact
directly with each cooperating agency to determine their level of commitment
and activities for the various reports. Success of the monitoring strategy
depends on the commitment of participating agencies and individuals
to make monitoring an integral part of the CCMP and to provide the Action
Plan monitor with the data required to develop reports to BTMC. An additional
outside monitor (i.e., statistician) should be contracted by BTMC in
years 1, 5 and 10. The results of the statistical analysis should be
provided to the overall monitor of the Action Plan for presentation
to the BTMC.
Reporting schedule
The monitor will prepare quarterly reports. Reports will be submitted
not less than 15 days prior to a regularly scheduled meeting of the
BTMC. The party responsible for the monitoring should be available to
discuss the report at the meeting if requested to do so by the BTMC.
Monitoring reports will also be provided to the agencies or institutions
participating in implementation. Interim reports can be prepared by
the monitor at any time to draw BTMC attention to significant problems,
delays, etc. Statistical analysis of petroleum and related spills data
will be conducted at the end of years 5 and 10.
Guidance for monitoring reports
•. Quarterly reports to BTMC shall provide suitable components,
such as:
¨ . Check-off of project landmarks
according to the project time line.
¨ . Assessment of cooperating agency
contributions.
¨ . Description of educational programs.
¨ . Compilation of recipients of
educational programs and their comments.
¨ . Assessment of petroleum spill
database (accessibility and usefulness).
¨ . Statistical analyses.
•. Technical details may be included in the report, in a presentation
suitable for the Scientific Technical Committee and/or BTMC. A summary
of the report shall be less than one page and be suitable for presentation
to and understanding by the general public.
•. In addition to the evaluation of the technical accomplishments
of the project, the monitor shall
¨ . identify problems observed during
the reporting period and their potential causes;
¨ . predict the short- and long-term
consequences of the problems;
¨ . recommend actions to address
the problems, as well as a potential implementor(s);
¨ . identify a time frame for accomplishment
of the recommendations.
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