National Oil Spill Contingency Plan
The National Oil Spill Contingency Plan (NOSCP) has been in operation since 1986 and has seen a number of revisions with the latest revision done in November 2009. The aim of the NOSCP is to bring together the combined resources of the nation, the oil, shipping and exploration industries, to provide a level of preparedness to the threat posed to the environment by oil and chemical spills.
The National Oil Spill Contingency Plan sets out a clear definition of the responsibilities of the major participants: the national and the industries. This is provided in a set of national arrangements by way of an Inter-Agency Agreement (IAA), which also details such matters as divisions of responsibilities, contingency planning, access to national equipment, and the management and control of financial affairs.
Measures to be employed in the event of oil spill have also been identified in the plan in accordance to the circumstances of the spill and conditions prevailing.
As a policy the NOSCP identified following as the primary aims of an oil spill response:
- - protecting human health and secure their safety
- - minimizing environmental impacts; and
- - restoring the environment, as near as is practicable, to pre-spill conditions.
The NOSCP organization
In line with established international practice, the NOSCP followed a three-tiered approach to all aspects of oil spill preparation and response. Local/Industry (Tier 1), Regional Statutory Agency directing the Area response efforts, and EPA directing the National (Tier 2) response efforts, all have clear roles and responsibilities.
The National Contingency Plan hierarchy outlined in Figure 1 consists of national oil and chemical spill plans, the regional, port, and industry plans.Based on these arrangements the prescribed role of the national (Tier 3), through the Environmental Protection Agency (EPA), is one of coordination and provision of technical advice, logistic and maintenance support, materials and equipment, and training. Additionally, the Plan proposes that the EPA and the industries explore the possibility of the nation entering into an agreement for mutual assistance and access to the National Contingency Plan and Response equipment stockpiles.
Other key institutions identified in the NOSCP are:
Maritime Operators (MO) (GMA, Ghana Navy, GPHA, GNPC)
The plan indicates that Maritime Operators (MO) should provide advice relating to intervention powers, ship safety, structural integrity and stability of marine casualties. In addition, MO can advice relating to coordinating rescue and saving of life. The MO can provide drift calculations and advice on offshore currents. The plan recognizes that the MO has a range of communication facilities that can be utilised during an incident including International Maritime Satellite (Inmarsat) systems, enabling messages to be communicated directly to vessels.
In particular the Ghana Navy has been given the responsibility of providing the On-Scene Commander or the incident controller during spill situations. The Ghana Maritime Authority (GMA) can advise on matters relating to the sea dumping, including the permitting and reporting of emergency dumping of material at sea. GMA can also advise on Ghanafs obligations under the International Convention on the Prevention of Marine Pollution by Dumping of Waste and Other Matter (London Dumping Convention) and its 1996 Protocol. GMA can also advise on potential impacts of oil spills on threatened marine and migratory species, such as seabirds, seals, marine turtles, whales and dolphins.
In addition the Ghana Maritime Authority (GMA), Ghana Ports & Harbours Authority and Ghana Navy have been identified as the authorities who can grant a request for a place of refuge. However, all requests for a place of refuge are to be made through GMA
Ghana Armed Forces (GAF)
Ghana Armed Forces (GAF) can assist in coordinating the movement of National Contingency Plan equipment. Where necessary GAF will facilitate access to Defence Force resources where commercial operators are unable to provide this service. All GAF assistance will be coordinated through the national HOSR.
Wildlife Division (WD) of Forestry Commission
The Wildlife Division (WD) develops and implements national policies, programs and legislation to protect and conserve Ghanafs wildlife. Some responsibilities relevant to the marine environment include conservation of listed threatened, migratory and marine species.
As outlined in part 2.6 of the NOSCP, the industries can provide equipment and personnel resources and advice on a range of issues, including oil characteristics and local industries resource availability.
Regional, Local Authorities and NGOs
Regional, local authorities and NGOs, such as have responsibility for transport, conservation, resource management, environmental protection, emergency services, Port/Harbour Authorities, and local conservation groups are able to provide a wide range of site-speci?c information and resources, either in relation to environmental impacts, or response activities.
National Response Team (NRT)
The plan envisage the formation of a National Response Team (NRT) of operational, technical, environmental, Scientific and chemical experts ranging from operator to senior spill response manager level.
In the event of a major oil spill incident, it is likely that assistance may be sought from overseas in accordance with the International Convention on Oil Pollution Preparedness, Response and Cooperation (OPRC 1990). Customs, Excise & Preventive Service and Immigration Department will expedite the temporary import of equipment and experienced personnel should the need arise on a request from EPA. If additional overseas resources are required to respond to an incident in Ghana, then EPA in conjunction with Industry will arrange for assistance from the oil industryfs Global Alliance providing services through Oil Spill Response Limited (OSRL) located in Southampton, UK.
EPA, in accordance with relevant Memoranda of Understanding and relevant International Conventions (such as Abidjan Convention), may also assist or receive assistance from neighbouring countries in relation to oil spill incidents.
Supporting Documents for the NOSCP
The NOSCP stated that risk assessment should underpin all preparation and planning for oil spill response in Ghana. Consequently, an Environmental Sensitivity Atlas of the coastal areas of Ghana has been prepared (EPA, 2004). In this atlas, amenity areas, ecologically sensitive areas, industrial sea water intakes, fisheries, birds, marine and fresh water mammals, ground water resources and other resources likely to be threatened are identified. Two associated reports (the Coastal Environment and Sensitivity Ranking, EPA, 2004) have also been prepared. These reports describe in detail the features identified in the Atlas. The Risk Index for each area was determined by simple environmental and economic sensitivity factors taking into account the vulnerability and importance of the main environmental and economic resources in each area. Digital copies of the Atlas and its associated reports are available at the EPA. Changes observed along the Coastal Areas of Ghana over time shall be mapped out and the Atlas updated accordingly.
The NOSCP envisages formation of a National Contingency Plan Operations Group (NPOG) to support the National Plan Management Committee by considering the overall operational aspects of the National Contingency Plan.
Three working groups are envisaged. These are:
- the Oil Operations Working Group (OOWG), which shall consider issues such as the National Oil Spill Contingency Plan, oil spill response equipment and training, fixed wing aerial dispersant spraying and contingency plan audits;
- the Chemical Operations Working Group (COWG), which shall consider issues such as National Chemical Spill Contingency Plan ( ChemPlan), and chemical spill response equipment and training; and
- the Environment Working Group (EWG), which shall address research, development, technology and the environmental and wildlife interests of all the parties to the National Contingency Plan.
Ultimately, the majority of oil spill debris (that results during spill situations) will require land disposal, therefore proper site selection is fundamental to an effective oil spill response plan. Proper site selection can be assured only if it occurs through a rational planning process before a spill. Problems which can arise if oil spill debris is disposed of at an improperly situated site are:
- - Environmental pollution
- + oil migration through the soil
- + groundwater contamination
- + surface water runoff of oily material
- + washout of disposal area due to floods
- + long term effects of vegetation
- - Operational problems (availability of all-weather access roads, and ease of construction)
- - Social, Institutional and legal problems (approvals, adverse public reactions, lack of resources, time to secure suitable sites)
This realization also led to the development of a waste management plan to support the NOSC
Dispersants use as a response option
Another document developed to support the NOSCP is the Dispersant Use Policy and Guidelines to control dispersant importation and application in Ghanaian waters during spills.
The above are the key areas of the National Oil Spill Contingency Plan. Further details and other information could be obtained in the NOSCP itself or from the Oil and Gas Desk of the EPA.