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Oil Spill Disasters And Sethusamudram – III: Recipe For Disaster Is Ready. Are You?
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Oil Spill Disasters And Sethusamudram – III: Recipe For Disaster Is Ready. Are You?
In the previous parts of this article, we have seen that the proposed channel poses an imminent danger of Oil Spill disasters in Sethusamudram, which put to risk a unique paradise of nature that thrives there. In this concluding part we review the disaster management plan and spill response readiness envisaged by the project proponents.
In the previous parts of this article, we have seen that the proposed channel poses an imminent danger of Oil Spill disasters in Sethusamudram, which put to risk a unique paradise of nature that thrives there. In this concluding part we review the disaster management plan and spill response readiness envisaged by the project proponents.
When a project is going to expose a hitherto untouched ecosystem to an extremely high probability of disasters with enormous consequences, then the precaution and preparation can never be considered enough. Planning for the response to oil spill disasters must practically start in the very beginning of the planning for a shipping channel, strait, port or passage. In all the right senses, it must be one of the critical criteria to evaluate the very viability of any such proposal.
Disaster management must begin with a systematic assessment and modeling of the oil spill risk profile of the proposed project, and followed by building preventive measures; Laying out the contingency response strategy; Response infrastructure preparation and establishment of operational control.
Oil Spill Risk Modeling and Analysis done for Sethusamudram
Over the past few years, it has become growingly possible to quantify the risks of oil spills, as well as predicting their distribution and probabilities in a particular shipping zone. With these emerging methodologies, it has become possible for the planners of shipping infrastructure to be able to predict and statistically determine the oil spill risks involved.
Prof. Manju Mohan, of IIT-Delhi’s Centre for Atmospheric Sciences, has demonstrated one such statistical model to assess the oil spill risk in any shipping route [1]. Presenting the research at the 10th National Oil Spill Disaster Contingency Plan (NOS-DCP) Meet in September 2007, he demonstrated how risk analysis can be statistically achieved in 4 stages: Identifying the hazards; Analyzing the various factors to assess the potential frequencies; Identifying and quantifying the consequences; and finally calculating the disaster probability and ‘Risk Units’. He also presented the case studies of applying the methodology for oil spill risk profiling of shipping passages at Cretan Sea in Greece and at Gulf of Mexico.
Considering the grave potential consequences to the unique ecology of Sethusamudram, it is natural to expect that the SSCP authorities must have employed a thorough systematic methodology of oil spill risk profiling, like the one just described.
However, going through the Environmental Impact Assessment (EIA) report of the proposed project, it becomes astonishingly and disappointingly evident, that none of such risk modeling or determination techniques have been considered or discussed, much less employed.
A survey of how far the EIA goes about evaluating the oil spill risks in the proposed channel: [2]
1. Page 33: During the operation phase of the channel, the potential sources of marine pollution are spillage of oil and grease […] from the sea-borne vessels hence impacts due to such wastes are to be assessed.
2. Page 294:The Naval Staff of the Coast Guard Station at Mandapam are of the view that the implementation of the project will increase the potential for oil spill in the navigation canal. They also suggested that the above problem could be overcome by enanting (sic) a low (sic) by which any ship navigating through the canal and causing oil spill would not be allowed to use the canal in future.
3. Page 314: Spillage of oil and grease, rust and metallic wastes due to wear and tear, marine litter, float, including plastic bags, discarded articles would be the major pollutants. […] A potential source of pollution of the marine environment during the operation phase of the project relates to ship discharges – oily ballast, bilge water and sewage, and accidental spills. […] the frequent ship movements in the channel, maintenance dredging of the canal which could increase turbidity, oil spill, bilge water, marine litter etc. may have negative impacts if they are allowed to travel to the Gulf of Mannar Biosphere Reserve which supports a very fragile ecosystem.
It may sound shocking, but that is really all, that the EAI says about determining and assessing the oil spill risks in the SSCP.
Unfortunately, it fails to present any quantitative or qualitative discussion on oil spill risk specifications at all. No methodological, statistical, systematic risk modeling; no consequence assessment; no probability determination; no spill size, type, or frequency prediction; no simulation modeling of spillage trajectory or speed etc.
Clearly, EAI does not consider the oil spill risks and consequences as something that must be assessed as a prerequisite to determining the ecological viability of the Channel. To the contrary, EAI seems to have considered the channel as a fait accompli, and is only concerned half-heartedly (as we shall note subsequently) about discussing what can now be done about spills that might eventually take place anyways. EAI even fails to put on record the fact that this very region has been classified by NOS-DCP as one of the 10 priority areas of Indian coastline for oil spill disaster management and control.
What really amazes one are the glaring pieces of typing mistakes in the EAI (e.g. “enanting a low”). EAI, which is the very foundation of the project viability, is supposed to be an extremely serious document for the policy makers, and expected to have been submitted only after careful rounds of grilling reviews and due diligence. One naturally wonders: has anyone in authority, worth the mention, ever reviewed the four-hundred-and-twenty-seven pages of this document since it was first drafted?
Spill Contingency Plan Envisaged by the Sethusamudram Project
A well thought out and analyzed disaster contingency plan, with participation from all the concerned authorities and stakeholders, is obviously the essential blueprint of the disaster management. However, if EAI failed to present any oil spill risk profiling of the proposed channel, the efforts of drawing a contingency plan are equally absent.
EAI says:
(7.2.2, p388 and repeated in other sections) An oil spill contingency plan will be drawn by Tuticorin Port Trust with preparedness to prevent spread of oil or any cargo spillage in Gulf of Mannar and Palk Bay and its immediate recovery by deploying equipments and ships.
This means that the oil spill contingency plan did not exist when EAI was presented and based upon which the project was approved by the Cabinet.
But then the EAI contradicts itself:
(EAI 7.2.2, p388) Tuticorin port has been handling oil ships for last 25 years and not a single incidence of oil spill has been reported. The oil spill contingency plan in operation at TPT will be extended to navigation in new channel.
So EAI is not really certain, whether the existing oil spill contingency plan in operation at TPT would suffice for the proposed Sethusamudram Channel, or whether to recommend preparing a new contingency plan.
The uncertainty about the contingency plan alone should be alarming enough. However what makes one really concerned is the boastful claim in the statement, that because TPT has handled ‘oil ships’ for the last 25 years without any oil spill occurrence, by implication the proposed Sethusamudram Channel is spill proof; or that the Contingency Plan in operation at TPT would suffice for the proposed channel anyways.
There are two serious flaws in this boastful presumption.
First, it lays bare that the authors of EAI have not done enough research into the nature of the oil spills. If they would have done it, they would know that rather than the oil ships, the most damaging oil spill accidents in the recent years have involved cargo vessels. We quote researchers Meche Lu and Mark Chernaik on this subject [3]:
Although spills of oil from tankers garner intense media coverage, spills of fuel oil from cargo vessels, which are more frequent, accounts for a large portion of the environmental damage resulting from accidental oil spills involving mechanized shipping. According to a recent publication, “The number of oil spills from tankers and barges in 1999 was only 12% the number in 1990. […] For the period of 1990-1999, there were 46,728 oil spills from non-oil cargo vessels in the United States, accounting for the release of 3,384,730 gallons of oil, more than the amount of oil spilled by oil tankers during the same period. In the past 10 years, some of the most environmentally damaging accidental oil spills have involved cargo vessels, not oil tankers.
Secondly, EAI proposes that the spill management required for a port would be sufficient for a channel. This is an ill-founded and disastrous assumption, because a channel involves entirely different scale of oil spill risks, nature of response operation and tactics, and therefore needs substantially different response capabilities from that at a port.
The long and short of it is that the Spill Disaster Management Plan is not given serious attention by the EAI which it deserves.
Preparedness Level of Sethusamudram Authority
The fundamental precepts of environmental assessment would require a detailed assessment of whether the authorities have adequate resources to respond to a large fuel oil spill from a cargo vessel transiting the proposed Sethusamudram Ship Canal.
In March of 2005, Union Ministry of Environment and Forests issued its clearance to the Sethusamudram project with certain conditions of environmental compliance [4]. The letter from the Joint Commissioner Mr. A Senthil Vel laid down those conditions in the clearance, and it included:
“Oil spill contingency plan should be drawn up by TPT within one year from the date of issue of this letter including the preparedness to prevent spread of spillage in Gulf of Mannar and Palk Bay and its immediate recovery by deploying equipments and ships.”
As mentioned before, the National Oil Spill Disaster Contingency Plan (NOS-DCP) is the blueprint of India’s planned response to any oil spill disaster, and is centrally coordinated and updated by the Director General of Indian Coast Guards.
The latest edition of the plan was updated in March 2006 – one year after the above mentioned letter from the Ministry of Environment – and includes a detailed survey of the response preparedness and capability of the different port authorities including Tuticorin Port Trust.
The Annexure AQ of the latest edition of NOS-DCP talks about the oil spill response capability of TPT and therefore of Sethusamudram Channel Authority. This data should leave anyone worried.
One stirrup pump, one Dolphin barge, and 360 liters of chemical dispersant: this is all that the Tuticorin Port Trust had to its disposal in name of oil spill response capability by March 2006. (As to what is the level of response capability as on date – we could not locate any source to this information. An RTI application by the author is in process with the Indian Coast Guards.)
If the statement of EAI that the TPT has not had any occurrence of oil spill in the last 25 years is any true, then we must indeed be very lucky considering the TPT’s response capability.
Based upon the experiences worldwide, typical response equipment maintained by competent authorities entrusted with oil spill response, includes oil spill control booms of varying types and sizes, self-propelled oil recovery vessels, static oil recovery devices and sorbents, a range of storage devices including free standing tanks and towable storage bladders and bags. Spilled oil is most commonly contained and recovered using booms and skimmers. An absence of all the equipment mentioned, but most astonishingly of booms and skimmers, at the Tuticorin Port, should be sufficient to demonstrate the sense of seriousness of the authorities towards the oil spill response capability for Sethusamudram.
Besides, it also goes to show that either the TPT did not sufficiently fulfill the condition laid down by the Ministry of Environment’s project approval, or TPT failed to inform the NOS-DCP/Indian Coast Guards. It must be noted that the TPT is one of the identified participating agency of the NOS-DCP and is supposed to diligently update the central NOS-DCP plan with any response infrastructure or capability change. In either case, TPT has failed to meet its obligations towards environmental compliance.
CAG Report – An Eye Opener
The traffic volume and infrastructure of Tuticorin Port is insignificant when compared with other ports of India like Vishakhapatnam, Mumbai or Kandla.[5] While we don’t have access to any audit of Tuticorin Port Trust done by any independent audit agency towards its compliance with Environment Regulations, the one done at Mumbai Port – a much busier and larger port – by Comptroller and Auditor General of India comes as an eye-opener about the oil spill response readiness of the Indian ports in general.
Last year, in 2007, Dr. A.K. Banerjee, Director General of Audit, submitted a unique audit report - probably first of its kind in India - to the Comptroller and Auditor General of India (CAG) [6]. The audit was undertaken at Mumbai Port Trust (MbPT) with regards to its performance and capabilities towards compliance to Environmental Regulations. The findings of this audit were extremely alarming from the point of view of Oil Spill response readiness. Amongst other things, the report highlighted:
• The port did not have a documented Environmental Management Plan (EMP).
• MbPT did not attend to its responsibilities relating to the National Oil Spill Disaster Contingency Plan (NOS-DCP).
• MbPT failed to take adequate measures to mitigate the adverse effects of sludge, slop and dirty ballast.
• The equipments already procured by Port during 1991-94 were not maintained properly. The Coast Guard in their inspection report on the equipments maintained by the port observed (June 2003) damage, corrosion and deterioration to all equipments inter alia self-inflatable boom, multipurpose oil recovery system, dispersant spray system and mobile surface cleaning system. In spite of this report, Audit could not find any corrective action taken by the authorities to replace equipments or overhaul them adequately to meet the needs of the Port. As a result, they had been rendered unusable as of August 2006.
• The Coast Guard citing (1999) slow progress in implementing the NOS-DCP had suggested that personnel from the Coast Guard be taken on deputation till the Port officials were able to operate and maintain the equipment. However, no action was taken in this regard.
• The Port was not attending to the annual NOS-DCP preparedness meetings organised by the Coast Guard. This indicates non-compliance of the directives of NOS-DCP.
Remember, CAG is talking about the India’s third largest and one of the best equipped ports. If this is any indication of the state of the affairs with the Indian port authorities in general, then do we have any reason to believe that the ground situation of disaster preparedness at Tuticorin Port Trust, and by implication of Sethusamudram Channel would be any different? We have no independent means of ascertaining this, however if the NOS-DCP update of 2006 on TPT is any indication, then situation is not much better at TPT.
How feasible is disaster recovery in Sethusamudram Channel?
We should recall that the proposed channel is about 200 to 400 meters wide for a two-way traffic. So if a collision of vessels takes place within the channel, it would mean an effective blockade of the channel for any traffic from the either end of the channel. So in this case, how easily would the oil spill response vessels be able to reach the spill area? After all wouldn’t these response ships carrying the necessary equipment and personnel be needed to make use of the same 167 Km long-300 meter wide channel itself?
What will happen if the channel is blocked? What will happen if there are more that one ships grounded along the route? What will happen if accidents take place at both the ends of the channel? This does happen – recall the accident in Sea of Azov with which we began this article – there were at least a dozen individual incidents taking place along the Kerch Strait within a matter of hours due to the severe storms.
Meche Lu and Mark Chernaik, Staff Scientists at Environmental Law Alliance Worldwide conclude: “The most common means of limiting the impact of an oil spill is to contain the spill at the earliest possible time with booms and other equipment and recover the oil with skimmers and other devices. How would the proponents of this project bring booms and skimmers to the site of an oil spill if a vessel grounded itself just outside the canal? The answer is that doing so would be extremely difficult if not impossible because the area surrounding the proposed canal is shallow and inaccessible to boats carrying such equipment. By failing the submit a detailed contingency plan about how the proponents of this project would respond to a major spill of oil from a cargo vessel transiting the proposed Sethusamudram Ship Canal, the proponents are covering over the fact that responding to these kinds of spills would be difficult if not impossible.”
Those who unwittingly or ignorantly fancy comparing the proposed Sethusamudram Channel with Suez, should better also compare the salvage capabilities. Suez being a land-based canal, has heavy bollards installed every 200 Ft, on either bank of the canal, to tug out any grounded vessel. There are absolutely no such provisions of this kind or any other to salvage vessels in the proposed Sethusamudram Channel, and nor are such provisions possible considering that the proposed channel is a mid-ocean passage unlike the land-locked Suez.
A taste of what is coming can be had from an incident that took place during the dredging operations which were happening near Rama Setu before those were halted by the orders of the Supreme Court of India.
A large spud, 50-tonnes in weight and 15-metres long, broke off during the dredging and stone-breaking operations near Rama Setu, from a dredger ship called Aquarius, and fell into the Gulf waters. Spud is a tool which is used to break huge rocks. To retrieve this spud, a rescue ship named Thangam was dispatched for the salvage operations. While it could not succeed in retrieving the spud from the sea-bed, the crane of this rescue ship also broke. For the last 12 months, the spud is still lying on the sea-bed un-retrieved and un-salvaged by authorities, between the 5th and 6th tidal reefs, 11.4 nautical miles from Mukundarayar Chattiram, and keeps damaging the fishing vessels and equipments that pass through this zone. So far, 20 fishing vessels and over 100 fishing nets have been lost or damaged. [7]
If authorities could not salvage this tug for over 12 months now, one can only speculate on the dangers which await ships which will get grounded in these turbulent waters of the Indian Ocean, and on how a large oil spillage would be responded to.
No wonder that Mr. K.S. Ramakrishnan, former Deputy Chairman of the Chennai Port Trust is extremely alarmed about the proposed channel [8]. He said: “The canal cannot be a free seaway because the grounding of a wayward coal or oil ship that strays from the alignment or a collision of two ships in the channel will result in an ecological disaster of unimaginable proportions to the Gulf of Mannar and the Palk Bay.”
Conclusion
The very features of the proposed channel make oil spill disasters extremely probable and an imminent danger. Considering this, and the significant consequences to the unique environmental paradise of Sethusamudram, it is naturally expected that the proponents of the channel project would leave ‘no stone unturned, no wires unplugged, and no cutlets uncooked’, in mitigating the risks and preparing for the response capability.
However, the proposal of Sethusamudram is a case where the authorities seem to be either ignorant about the dangers of Oil Spill, or they are in hurry to not pay heeds to it.
In the Environment Assessment for the project, there is absolutely no qualitative or quantitative, systematic or methodological, analysis done to ascertain the oil spill risks or consequences. The contingency plan is left for others to decide, and there is enough confusion about that. The mitigation is half-cooked at best, and there is no independent assessment done about the capability and preparedness of the authority trusted with the response. The very feasibility of a practical response itself seems extremely doubtful, considering the channel features.
In short, the recipe for disaster is ready, at the cost of the ecology and fishermen. Are you ready?
References
1. Mohan, Manju, “OIL SPILLS RISK ANALYSIS:AN OVERVIEW” presented at THE TENTH NATIONAL OIL SPILL DISASTER CONTINGENCY PLAN MEETING (NOS-DCP) in SEP 2007 http://tinyurl.com/2xsa2y
2. Environmental Impact Assessment for Proposed Sethusamudram Ship Channel Project, August 2004. Prepared by National Environmental Engineering Research Institute Nagpur for Tuticorin Port Trust. http://sethusamudram.gov.in/Study.asp
3. Lu, Meche and Chernaik, Mark (2004),"Evaluation of the Environmental Impact Assessment for the Proposed Sethusamudram Ship Canal Project" http://tinyurl.com/38hjqs
4. Environment Ministry Letter No. J-16011/6/99-IA-III, March 31 2005, By A. Senthil Vel, Joint Director http://www.sethusamudram.gov.in/EnvMinistry.asp
5. In the rank of Traffic handled by the major ports of India for the calendar year 2007, Vishakhapatnam tops the list with 47,833 thousand tons, followed by Kandla with 47,733 thousand tons and Mumbai with 43162 thousand tons. Tuticorin handled only 15,375 thousand tons and was much behind many other ports like Chennai, Haldia, Mangalore and Paradip. http://www.mumbaiport.gov.in/newsite/updates/majorports.htm
6. Comptroller & Auditor General of India, Report No. 3 of 2007, CHAPTER III : MINISTRY OF SURFACE TRANSPORT, “Environmental management by Mumbai Port Trust” http://www.cag.gov.in/html/reports/civil/2007_3_peraud/3%20of%202007%20Civil%20PerAU/chap_3.swf
7. Dinathanthi Tamil daily (Madurai Edition) February 19, 2008.
8. The Hindu, December 21, 2004
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