Department of Fish and Wildlife

Office of Spill Prevention and Response

GUIDANCE DOCUMENT
For use in the preparation of

Contingency Plans

Response Strategies for Protection of

Ecological Resources at Risk and
Environmentally Sensitive Sites
Title 14, CCR Section 817.04(l)

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BACKGROUND

The Lempert-Keene-Seastrand Oil Spill Prevention & Response Act [the Act; Gov. C.
§8670.1 et seq.; significantly amended in 2014 by Senate Bill 861 (SB 861)] requires
the Administrator for oil spill response, acting at the direction of the Governor, to
ensure the State fully and adequately responds to all oil spills in state waters and to
represent the State in any coordinated response efforts with the federal government.
The goal and purpose of the Act is for the Administrator to provide for the best
achievable protection of waters of the state from oil spills. This includes establishing
and periodically revising a California Oil Spill Contingency Plan that provides
integrated and effective coordination for state agencies to address the results of
major oil spills.

The Administrator must implement activities relating to oil spill response, such as
emergency drills for preparedness, oil spill containment and cleanup, and financial
responsibility. This also specifically includes adopting and implementing regulations
governing the adequacy of oil spill contingency plans that must be prepared and
implemented by vessels and facilities that could spill oil into state waters.

The Administrator has the primary authority to direct prevention, removal, abatement,
response, containment, and cleanup efforts with regard to all aspects of any oil spill
in waters of the state. This includes authority over the use of all response methods,
such as in situ burning, dispersants, and other oil spill cleanup agents in connection
with an oil discharge. The Administrator must cooperate with any federal on-scene
coordinator, as specified in the National Contingency Plan.

The Administrator is required to establish a network of rescue and rehabilitation

stations for wildlife injured by oil spills in waters of the state, including sea otters and
other marine mammals. This network is known as the Oiled Wildlife Care Network
(OWCN), and is administered through the Wildlife Health Center at the University of
California, Davis. If a plan holder has a spill that injures wildlife, plan holders are
encouraged to use a local OWCN facility if there is one in the area.

Owners or operators of facilities that have the potential to spill oil into state waters
are required to prepare and submit an oil spill contingency plan (C-plan) to the Office
of Spill Prevention and Response (OSPR) for approval. [Ref. CA Government Code
§§8670.28, 8670.28.5, 8670.29, 8670.30.5, and 8670.31] Contingency plans are
prepared and used for response activities in the event of an oil spill or threatened
spill into waters of the state. The Act authorizes the Administrator to require that
contingency plans provide for best achievable protection taken and that sufficient
response resources are capable of arriving on-scene and equipment deployed within
a certain timeframe for effective containment and response.

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DISCLAIMER

The purpose of the guidance document is to assist owner/operators in complying with

the oil spill contingency plan (C-plan), drills and exercises, financial responsibility and
other requirements established by the Office of Spill Prevention and Response. C-
plans are mandated for certain vessels and facilities by the Lempert-Keene-
Seastrand Oil Spill Prevention & Response Act (the Act; Gov. C. §8670.1 et seq.),
which was significantly amended in 2014 by Senate Bill 861 (SB 861).

This document does not contain specific requirements, nor does it replace any
statutory requirements established by the Act, SB 861 amendments, or regulations
promulgated to implement the Act and SB 861 amendments. This guidance
document helps explain how to comply with the Act and the implementing
regulations. However, all applicable laws and regulations should be read before
using this guidance document for the preparation of C-plans.

All guidance documents can be obtained by visiting our website at

http://www.wildlife.ca.gov/OSPR/Preparedness/Inland-Facilities-Contingency-Plan.
Guidance documents may be updated periodically without notice, as necessary, to
reflect any changes in applicable laws or regulations. Comments or questions
regarding a guidance document should be addressed to the OSPR Branch listed on
the specific guidance document.

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Regulation
Title 14, CCR Section 817.04(l) Risk and Hazard, and Oil Spill Consequences
Analyses

Purpose

The goal of contingency planning is to provide information and resources necessary

for a quick and efficient response to oil spills. A comprehensive contingency plan will
identify and map ecologically sensitive areas, which could be adversely affected by
an oil spill and identify protective strategies to protect those resources. This section is
intended to support compliance with the requirements for identification of response
strategies for ecological resources at risk.

General Strategy for Addressing Oil Spills

A Contingency Plan spill response strategy should address steps from point of
release through release into water body and final extent, based upon worst case
trajectory. Typically, the following concerns must be addressed, in priority order:

 SAFETY AND PUBLIC HEALTH

o Ensure the safety of responders as well as maximize the protection of
public health and safety.
 SOURCE CONTROL
o Ensure actions are underway to control the source and minimize the total
volume released. Respond as close to the source as possible.
 ENVIRONMENTAL PROTECTION
o Use all appropriate tools to keep oil out of water and ensure all necessary
actions have been taken to protect environmentally sensitive areas and
minimize wildlife impacts.
 CONTAINMENT AND RECOVERY
o If oil enters the water body, use key strategies of collection, diversion or
exclusion booming to contain and recover the oil and ensure effective
cleanup, recovery, and disposal of spilled product.

Reasonable Worst Case Spill Trajectory Planning

 Calculate the distance that discharged oil could travel from your facility before it
is contained.
o If oil can impact a water body, knowing the water flow will allow prediction
of how far downstream oil will flow under given time and flow condition.

 Determine locations of sensitive resources and strategic points to divert, collect

and/or recover oil within the potentially effected waterway. These may include
bridge and culvert crossings.

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  Provide a map indicating waterways, sensitive areas and specific locations of
booming strategies. These maps are designed to help the responder visualize
response strategies. Details of each booming strategy should be listed in
corresponding matrix tables. Each table should indicate the exact location, intent
and implementation of the strategy indicated on the map.

Examples

A. Site Map and Table: Locate response strategies and sensitive areas potentially
affected by a spill from the facility, with cross-references to their locations as
shown on Site map. Show protection strategy points for a spill into a waterbody
from this facility. Insert Response Strategy Table with strategy location
coordinates.

Site Name Strategy Location

BBS1 Diversion/Collection. 400’ 36.4655 122.3425
boom
BBS2 Deflection/Protection of 36.4534 122.4982
Wetlands. 600’ boom
BBS3 Diversion/Collection. 36.5678 122.4728
400’boom

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B. Figure showing booming tactics.

C. Response Actions

If the oil has not yet reached water:

Actions
Contain or control oil leak at source. Assess character of oil & its trajectory
Contact cleanup contractor(s).

Control oil flow on the ground by constructing physical barriers and/or using
sorbent materials (e.g., sandbags, earthen berm, trenches) across the oil
flow path.
Deploy berms or barriers downgradient from the oil, to contain and prevent
the oil from spreading.

Implement land based response actions (countermeasures) such as digging

temporary trenches, containment pits, storage tanks, or curbs to prevent the
flow of oil into the waterbody*.
Deploy boom and sorbent materials along the waterbody shoreline to
prevent oil from entering waters or leaving immediate area.
* Physical barriers or excavations can cause significant impacts to the
environment and may require appropriate permits. If time allows, the facility
should consult with the lead Environmental Agency (DFW OSPR) before
authorizing the construction of any dike, berm or dam in a waterway.

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If the oil has reached water:

Actions
Deploy floating booms immediately downstream from the release point to
contain oil at water entry.
Deploy additional floating booms to divert oil to collection pockets for recovery
and to prevent further downstream spread of oil.
Deploy additional booms at appropriate diversion and collection points
downstream of release point. Access points and staging areas along the
shoreline should be identified in the Contingency Plan.
Deploy protective booming measures for downstream receptors that may be
impacted by the spill. Sensitive sites/areas designated for protection should be
identified in the Contingency Plan. As responders and planners adjust
strategies to meet the needs presented by prevailing conditions, they should,
as much as possible, do so with the prior advisement of the on-scene DFW
Office of Spill Prevention and Response Resources at Risk Technical
Specialist and with the approval of the Unified Command.

Mechanical Recovery and Protection Strategies: Waterways

The key strategies are the use of collection, diversion, or exclusion booming to
contain and recover the oil, and prevent it from entering areas with sensitive wildlife
and fisheries resources. Booming and other recovery and protection options are
described in detail in Appendix A. In general, immediate cleanup objectives are to:

 Contain oil and control source as soon as possible, mobilize resources to the spill
location, and collect.

 Intercept oil flowing downstream to prevent further contamination, while

protecting resources at risk

 Identify strategic locations to collect, divert and/or recover oil within the
potentially affected waterway. .

Determining the priority or order of Area Contingency Plan or Geographic Response

Plan strategies should be based on the location of the spill or area affected. In
establishing waterway response priorities, the downstream movement of spilled oil
and the time it takes to mobilize and deploy response resources must always be
considered. Oil can be rapidly transported by moving water, following the direction of
currents, winds and tidally influenced waters. Generally, waterway response plan
strategies should first be implemented downstream, well beyond the furthest extent
of the spill, and then continued upstream towards the spill source. As response
resources become available, implement additional Area Contingency or Geographic
Response Plan strategies in order of priority.

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Boom is a common type of oil spill response equipment for oil spills to water. Boom is
a containment barrier typically comprised of a PVC coated material that encloses a
foam tube to float it and a PVC skirt or curtain that extends below to prevent oil from
entraining beneath it. Boom serves as a floating, physical barrier placed on the water
surface. Boom is used in many ways during an oil spill response, including the
following: to contain, exclude, deflect, or divert oil. Boom is used to protect
shorelines or sensitive areas such as marshes or other wildlife and fish habitat by
acting as a barrier.

Containment boom may work well in water with little or no current and can be placed
around a vessel or tank that is leaking oil or trapping oil in a slough or eddy adjacent
to fast water until it can be recovered. The boom confines the oil within a small
space, minimizing spread, so it can be collected with oil recovery devices such as a
skimmer – equipment that efficiently and effectively separates oil from water for
recovery.

River booming strategies:

 Diversion booming moves oil from fast flow areas in the center of the river to
calm water to enable collection in slower water or pockets along the bank. This
approach allows the use of conventional containment and recovery
techniques. The boom can be deployed in a single long section as shown in in
the example above, or as multiple booms staggered across a river or harbor.

 Deflection booming is used to keep oil away from water intakes and
ecologically sensitive areas. Can be used in conjunction with
recovery/collection tactics. Fewer booms may be required than those used for
containment, but the oil may be directed to another sensitive area.

 Exclusion booming is used to completely boom off an area such as a sensitive

site, forming a protective barrier. Conventional oil boom, tidal-seal boom, or a
combination of each can be used to exclude spilled oil from a sensitive area.
This technique is most effective in no or low current areas.

Small Streams/Arroyos/Washes/Creeks/Culverts:
Shallow streams and other small waterways are susceptible to spills from pipelines,
storage facilities, highway accidents and storm drains. Boom is generally ineffective
in very shallow water where the draft of the boom is greater than about one-third of
the water depth. The restricted flow under the skirt increases the flow, which
increases oil entrainment. For very low flow rates or small spills, floating boom,
including sorbent types, can be used but care must be taken to minimize
entrainment. A rule of thumb for a low flow rate is a flow of less than 10 cubic feet per
second (cfs). A flow of one cfs is approximately equal to 450 gallons per minute.
Above this flow rate, underflow dams, overflow dams, weir and sorbent barriers can
be used. Under very low flow conditions or no flow conditions, a temporary berm or

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dam can be built that completely stops the oil and water flow for immediate
containment but if there is water, flow will have to be quickly dealt with before the
dam is overwhelmed. In measuring the speed of drift or stream flow, an easy rule of
thumb to remember is that an object that moves 100ft in 1 minute is traveling at a
speed of ~1 knot. Changing weather conditions can drastically alter the flow so
caution should be taken during severe weather. In some conditions, a combination of
techniques can be used such as deploying a sorbent barrier backed by an underflow
dam.

Dams can be built in shallow streams, culverts and inlets using hand tools or heavy
equipment, as available. Pipes are used to form an underflow dam to allow water
passage through while oil stays behind. Pipes must be inclined, with the elevated end
on the downstream side. Make sure that the upstream end of the pipe is submerged
and remains below the oil/water interface. This technique is effective for water bodies
less than two feet deep where flow volume can be accommodated by pipe flow. This
method can also be used in deep, narrow culverts (see “Oil Spill Response in Fast
Currents: A Field Guide.” U.S. Coast Guard, October 2001).

Facilities in inland areas need to be aware that sometimes the classification of boom
for an Oil Spill Response Organization (OSRO) in rivers/canals includes boom sizes
up to 18” (overall). This can be far too large for many of the fast moving (over 2 miles
an hour) streams and rivers found in California. Besides the velocity of the current,
many streams and rivers are often shallow, resulting in the larger boom dragging on
the bottom or creating difficulty in placement near to the river bank. Boom that is
large requires more people to deploy, the skirt may fill and sink, and smaller angles
must be used which requires more boom. Boom that is 10” (overall) or 12” (overall)
works better in fast water as well as in smaller, shallow water bodies.

Do not assume 100% efficiency with one boom system.

Position collection areas where there are natural collection points, or where water
movement is slowest, such as the inside of the river bend, or where access allows.
Deploy booms to deflect oil from the fast side to the slow side of the river and into the
collection areas.

Currents are highest in the deep channels of the river and diminish as depth
decreases near shore, due to bottom friction effects. Oil will generally follow the
higher current flow downriver. It will be distributed much like river debris in areas
where slow current, eddies and alternate watercourses exist.

Controlling and recovering oil spills in fast moving water above one knot is difficult to
accomplish because oil entrains under booms and skimmers in swift currents. Fast
water accelerates many spill processes, necessitating quicker and more efficient
responses compared to stagnant water or slow-moving current conditions.

The angle of the boom to the current flow is of critical importance. Correct boom
deployment is a key factor in on-water oil control and containment. The maximum
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deflection angle as possible from the current must be maintained to prevent oil
entrainment.

For inland waterways with current, it is better to limit the boom draft for diversion/
deflection applications. Boom with draft greater than six inches is not recommended
for currents above 1.5 knots. For currents of three knots and greater, boom with only
a short chain pocket and no more than three inches draft is recommended to
maintain a shallow deflection angle to the current. The requirements for anchoring
will depend upon the situation. Details about anchoring methods are contained in Oil
Spill Response in Fast Currents: A Field Guide.” U.S. Coast Guard, October 2001,
Chapter 8.

Geographic Response Plans (GRPs)

In some geographic areas, Geographic Response Plans (GRPs) have been

developed and are available for consideration (see
https://www.wildlife.ca.gov/OSPR).

GRPs are geographic-specific response plans for oil spills to particular waterbodies
or areas. They include response strategies tailored to a specific beach, shore, or
waterway and are meant to minimize impacts on sensitive resources threatened by
the spill. GRPs include map-based strategies that can save time during the critical
first few hours of an oil spill response. They indicate where sensitive areas are
located and where to place oil spill protection resources. Each GRP has two main
priorities:
 To identify sensitive natural, cultural or significant economic resources.
 To describe and prioritize response strategies in an effort to minimize injury to
sensitive natural, cultural, and certain economic resources at risk from oil spills.

Each plan covers a specific geographic area and contains information meant to aid
the response community in managing the incident through, and as necessary
beyond, the initial phase of the response. Information contained in the plans include:
site descriptions, reference maps, recommended response strategies, shoreline
information, resources at risk details, and logistical information. These plans can be
useful to reference in Contingency Plans, however GRP coverage is currently limited
in California.

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References

Alaska Department of Environmental Conservation. 2002. “Alaska

Incident Management System Guide for Oil and Hazardous
Substance Response, Revision 1.” http://www.akrrt.org/aim/
aim_toc.shtml

ExxonMobil Research and Engineering Company. 2002. “Oil Spill

Response Field Manual.”

Hansen, Kurt and Thomas J. Coe. October 2001. “Oil Spill

Response in Fast Currents – A Field Guide.” U.S.Coast Guard,
Research and Development Center, 1082 Shennescossett Road,
Groton, CT 06340-6096. http://www.epa.gov/oilspill/pdfs/
hansenpaper.pd

Michel, Jacqueline; Christopherson, Sharon; Whipple, Frank.

1994. “Mechanical Protection Guidelines.” National Oceanic &
Atmospheric Administration, Hazardous Materials Response &
Assessment Division. http://response.restoration.noaa.gov/
oilaids/Mechanical.pdf

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Appendix A
Mechanical Protection and Recovery Techniques

Primary Logistical
Protection Techniques Description Limitations
Requirements

LAND

A berm is a low barrier  Bulldozer/Road grader

 Accessibility
constructed of available  Personnel – equipment
 Implementation time
material (earth, gravel, operator & worker(s)
Berms  Environmental damage
sandbags etc.) to contain,  Misc. - plastic or geotextile
inflicted by berm material
stop or divert the flow of sheeting to prevent
excavation or deposition
oil. penetration of oil thru berm.

 Impenetrable subsurface
 Bulldozer/Road grader/
Excavated trenches are  High water table
Excavator
used to intercept or divert  Accessibility
Interception trench  Personnel - equipment
surface or subsurface  Implementation time
operator & 1 worker
flows of oil.  Environmental damage
caused by excavation

Boards, sandbags,  Available material to block

 Strong flowing water
sheetmetal used to block flow
Culvert blocks  Culvert size
flow from entering culverts  Accessibility
and contain oil flow..

A dam is constructed  Bulldozer/ Frontend loader/  Inadequate storage

across a low flow or no Excavator capacity behind dam
Dams (over flow, flow ditch, streambed or  Too much water flow
underflow or no flow) dry drainage course.  Personnel - equipment exceeding outflow
Contain oil and stop operator & 1 worker or capacity
spread. several workers w/shovels

 Labor-intensive nature of
the operation
Adsorbents are used to
 Logistics of applying and  Relative high cost
recover small amounts of Relative low recovery
Sorbent pads, booms retrieving sorbents on wide-
oil through absorption and
spread slicks rates
adsorption
 Large amount of solid
waste generated

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 Primary Logistical
Protection Techniques Description Limitations
Requirements

LAND, CONT.

 Per 30 meters of barrier

A barrier is constructed by  Wire mesh - 70 m x 2 m
installing two parallel lines  Stakes - 20
of stakes across a  Sorbents – Synthetic  Waves > 25 cm
Sorbent barriers, filter (polypropylene rolls, sheets 
channel, fastening wire Currents > 0.5 m/s
fences snare, Organic (straw bales
mesh to the stakes & filling etc.)  Tidal range > 1 m
the space between with  Personnel - 2
sorbents.  Misc. - fasteners, support,
lines, additional stakes, etc.

 If sufficient underflow
A dam is constructed
across the channel using  Loader - 1 cannot be maintained, or
Inlet Dams local soil or beach  Personnel - equipment if excessive overflow
operator & 1 worker or occurs, additional dams
sediments to exclude several workers w/shovels downstream may be
oil from entering channel.
required.

WATER

Boom  Currents less than 2 knots,  Current < 2 knots use

Adequate angle of deflection boom skirt > 10 inches
Single Diversion necessary to prevent
Rivers/Streams/Lakes
Boom entrainment  Current > 2 knots use
(Depth is greater than
 Currents greater than 2 boom skirt 6 inches or
boom skirt depth) knots, entrainment can less
occur if angle too steep

 Currents over 2 knots  Use of multiple anchors

Boom  Use short skirts, shorts or ropes is difficult in fast
Rivers/Streams/Lakes Cascading Diversion boom lengths and sufficient currents over 2 knots so
(Depth is greater than Boom overlap. Requires anchors
planning and training are
boom skirt depth and boats to deploy them or
ropes and pulleys required.

Boom  Single Diversion Boom

Rivers/Streams/Lakes Currents less than 2 knots  Exclusion Boom for
Sensitive Areas  Breaking waves
(Depth is greater than and river is wide
 Encircle & Divert to
boom skirt depth Collection Area

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 Primary Logistical
Protection Techniques Description Limitations
Requirements

 Boom is used in little or

Boom is deployed in a "U"  For 150 meters Slick:
 Boom - 280 m no current to isolate a
shape in front of the
oncoming slick. The oil is  Boats - 2 spill, to control spreading,
Containment booming  Personnel - boat crews & 4 to concentrate the oil, and
contained within the "U" &
boom tenders to facilitate its recovery by
prevented from reaching
 Misc. - tow lines, drogues, skimmers
the shore. connectors, etc.

Boom is deployed across  Per 300 meters of Boom

or around sensitive areas  Boats - 1  Currents > 0.5 m/s
& anchored in place.  Personnel - boat crew &  Breaking waves >
Exclusion booming
Approaching oil is 3boom tenders 50 cm
deflected or contained by  Misc.- 6 anchors, anchor  Water depth > 20 m
boom. line, buoys, etc.

 Single Boom, 0.75m/s

Boom is deployed at an <1knot/current
angle from the shoreline  Boom - 100 m  Currents > 1.0 m/s
Deflection booming away from the  Boats - 1  Breaking waves >
approaching slick to  Personnel - boat crew + 3 50 cm
deflect oil from sensitive  Misc. - 5 anchors, line,
shoreline or to a collection buoys, recovery unit
point.

Boom is deployed from the

 Single Boom, 0.75 m/s
shoreline at an angle <1knot current
towards the approaching
 Boom – per 60 m  Currents > 1.0 m/s
slick & anchored or held in
Diversion booming  boats - 1  Breaking waves >
place with blocks and
 Personnel - boat crew + 3 50 cm
tackle. Oil is diverted
 Misc. - 3 anchors, line,
towards the shoreline for
buoys, recovery unit
recovery.

 Portable  High winds

Portable skimmers are  Hoses  Swells > 2 m
placed within  Oil storage  Breaking waves >
containment booms in the  Self-propelled 50 cm
area of heaviest oil  Towed  Currents > 1.0 m/s
Skimming
concentration. or used in  Boom
conjunction with  Boats
diversion/deflection  Personnel - boat crews &
collection booming boom tenders

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