6 Acute pollution: risk and the preparedness and response system
Acute pollution is defined in the Pollution Control Act as significant pollution that occurs suddenly and that is not permitted under the Act. This chapter deals with acute pollution from shipping and petroleum activities, and with civilian and military activities that pose a risk of acute radioactive pollution.
Like any other human activity, shipping and petroleum activities involve an element of risk. To systematically prevent undesirable events, all stakeholders put a great deal of effort into risk management, including risk treatment.
No common, integrated approach has been established for dealing with accident risk and environmental risk across activities in various sectors. This means that assessments and results for different sectors cannot be compared directly.
The shipping industry involves a large number of stakeholders, and in principle, ships can sail anywhere in the oceans. Risk management in this sector is for the most part based on international conventions and other rules adopted by the International Maritime Organization (IMO). In addition, Norway has as a coastal state introduced a number of preventive measures that reduce the likelihood of accidents. For shipping, the likelihood of accidents is calculated on the basis of previous events involving different types and sizes of vessels and on the distance sailed in a given geographical area. The potential environmental consequences and risks of acute spills can be calculated using oil spill modelling and knowledge about the distribution and vulnerability of various species and habitats.
On the other hand, the petroleum industry is dominated by a small number of stakeholders and by stationary installations within limited geographical areas. Risk management in the petroleum activities are mainly focused on managing risks adequately at individual installations and is related to different types of activities. The stakeholders work extensively on risk.
The petroleum sector in Norway expresses risk in terms of the potential consequences of petroleum activities and the uncertainty associated with them. ‘Consequences’ include all possible outcomes of incidents that could potentially arise during activities. ‘Associated uncertainty’ is uncertainty relating to the potential consequences of incidents during activities and their effects. There may be uncertainty about the types of incidents that may occur, how often they are likely to occur, and the damage or loss that different incidents may cause as regards human life, health, the environment and material assets. Uncertainty also involves a lack of information, understanding or knowledge.
The likelihood of a nuclear accident or another nuclear or radiological event that has significant consequences and results in acute radioactive pollution outside an extremely limited area is generally low. The consequences of an event will depend on the content of radioactive material in the source, the measures taken at the source to reduce consequences, how the release occurs and which substances are released, and the way in which people and environment are exposed to the radioactive material.
Major accidents seldom occur but can have serious environmental consequences. The level of major accident risk is uncertain and depends on what individual stakeholders do to prevent accidents. Ensuring that the risk of accidents remains low is a vital part of reducing the level of environmental risk.
6.1 Environmental vulnerability
Acute pollution can harm organisms in the water column and on the seabed, seabirds and marine mammals, and organisms that live in coastal waters and the shore zone. Every spill is different, and the environmental consequences depend on location, timing, the type of spill and its volume, the species and habitats affected and how vulnerable they are to the pollutant in question, and the emergency response and other measures taken to reduce the consequences. The actual effects of a spill also depend on the state of the species and habitats affected and their importance in the ecosystem, in addition to their vulnerability to the pollutant involved. Major oil spills pose the greatest risk, and the main focus is therefore on improving scientific knowledge about vulnerability to oil pollution, regardless of whether spills are from vessels or petroleum installations.
Vulnerability to oil pollution
In recent years, much new knowledge and data have been obtained that further enhance our understanding of the vulnerability of the marine environment to oil pollution. A substantial body of experience and knowledge has been collected about the ecological impacts of the 2010 blowout in the Gulf of Mexico, for example on the effects of oil sedimentation and marine oil snow. There is a high level of research activity in Norway as well, including research on the tolerance of various organisms in Arctic areas to oil. Although a great deal of knowledge that is relevant to Norwegian conditions has been obtained on possible effects on individual organisms, the level of uncertainty is still high when assessing impacts at population and ecosystem levels.
Knowledge about habitat use by different seabird populations through the year has been considerably improved for the Barents Sea. The SEATRACK mapping project has provided new understanding of seabird distribution in the open sea, particularly in the autumn and winter. As a result, seabirds have been assessed as particularly vulnerable to acute pollution in several areas of open sea in addition to at the major breeding colonies. This assessment applies for example to common guillemots migrating by swimming after breeding, and the areas in the southeastern Barents Sea where they congregate after the swimming migration for the autumn and winter. Species such as puffins, common guillemots, Brünnich‘s guillemots and little auks also use large areas when foraging at sea during the breeding season. These areas extend further out from the breeding colonies than previously thought. Populations in decline are vulnerable to begin with, and new knowledge shows that abrupt reductions in population size will increase pressure on such populations and make them more vulnerable. Brünnich‘s guillemots from colonies on Bjørnøya and puffins from those on Røst stand out as being particularly vulnerable. Kittiwakes from the Vedøy, Hjelmsøya and Hornøya colonies are also particularly vulnerable.
Fish eggs and larvae are more exposed to oil pollution than adult fish because they drift more or less passively with ocean currents and cannot actively avoid oil pollution. In addition, fish eggs and larvae have a larger potential for absorbing oil components due to their high surface-to-volume ratio. These organisms are also particularly vulnerable to pollution in their early developmental stages. A number of Norwegian and international laboratory studies have been carried out to investigate exposure of fish larvae to oil for varying lengths of time in order to establish tolerance to oil and threshold values for developmental abnormalities and mortality. Results from the Institute of Marine Research project EGGTOX indicate that exposure to realistic concentrations of oil causes serious harm to eggs and larvae of haddock, cod, saithe, halibut, herring and polar cod. The thresholds for harmful effects of oil on different fish species are uncertain. As new information and new studies become available, it is important to adapt and adjust the threshold values used by the industry in environmental risk analyses.
To develop better tools for assessing the impacts of oil spills on fish stocks, the modelling system SYMBIOSES was developed as a collaborative project between the petroleum industry and a number of research institutions, including the Institute of Marine Research. So far, simulations have been run for spills in the spawning grounds for Northeast Arctic cod off the Lofoten Islands. The simulation showed that in the worst-case scenario that was simulated, up to 43 % of a year class of eggs and larvae could be exposed to lethal levels of oil. Further modelling indicates that such losses of eggs and larvae would have a limited effect on the Northeast Arctic cod stock (12 % loss of adult biomass). No simulations have been run for other species as yet, so these results cannot be directly transferred to other fish stocks. Uncertainty about the effects on species other than cod, particularly in the most important spawning areas, is therefore still high. In autumn 2019, the Institute of Marine Research published a study supporting these conclusions.
There are several areas of the Barents Sea that support a high diversity of important species and habitats that could be harmed by exposure to oil. However, there is a lack of knowledge about the vulnerability of these ecosystems and potential effects at ecosystem level. Several of the particularly valuable and vulnerable areas stand out as being nutrient-rich and with high biodiversity, and may be especially vulnerable to ecosystem effects in the event of acute pollution all year round or at certain times of year. In the Barents Sea–Lofoten area, this applies particularly to Lofoten–Tromsøflaket, the Tromsøflaket bank area, the marginal ice zone and the polar tidal front, and the sea areas surrounding Svalbard (including Bjørnøya). It is important to take a particularly cautious approach in these areas to avoid oil pollution and associated damage. In the Norwegian Sea and the North Sea–Skagerrak, the particularly valuable and vulnerable areas and also coastal waters and seabird breeding colonies are especially vulnerable to oil pollution.
The marginal ice zone is a highly productive area where a number of vulnerable resources could be affected simultaneously, and oil pollution in the area could have major impacts. An oil spill in the marginal ice zone could affect large congregations of seabirds and marine mammals (including polar bears), and also the plankton, ice algae and fish larvae in the water column and under the ice. The scale of the impacts on an oil spill will depend on its magnitude, where the spill occurs, the type of spill and the time of year.
Oil that is frozen into the ice can be transported with the ice as it drifts, and will be a source of pollution in areas where the ice melts. Because of the high biological production and diversity in the marginal ice zone, oil pollution in this area could affect the habitats of a large number of species and species groups.
There are still major gaps in our knowledge of the damage oil pollution could do to the ecosystem in the marginal ice zone, but its vulnerability is considered to be high. The impacts could be particularly severe in the event of a major oil spill across a large area of the marginal ice zone in spring or summer, when production in the water column is very high and large numbers of seabirds and marine mammals may be concentrated in limited areas.
Vulnerability to radioactive pollution
Ionising radiation from radioactive substances can affect organisms through both external exposure and internal exposure. Exposure types must be included in assessments of harmful effects. Different radioactive substances emit different types of radiation with varying ranges and potential to cause harm. The harmful effects of radiation and radiation-induced free radicals often involve DNA damage and cellular reactions which may cause biological damage.
Vulnerability to other acute pollution
Acute effects of chemical spills will primarily involve toxic substances. Assuming that the scale of such spills is limited in both volume and time, rapid dilution in coastal waters and particularly in the open sea will limit the exposure of living organisms to concentrations exceeding threshold levels for toxicity. These thresholds are known for organisms that have been tested against various substances, but not for all relevant organisms that may be exposed to pollutants.
Vessel casualties, including groundings, collisions, structural failure and fire or explosion, occur at irregular intervals and can result in acute pollution.
In 2017, the Norwegian Maritime Authority registered 204 personal injuries and 244 vessel casualties. Figures for 2018 were 199 personal injuries and 240 vessel casualties. In the last five-year period, the combined total averaged 462 per year.
The overall number of injuries and accidents is trending downwards. The number of incidents involving fire, contact damage and occupational accidents is declining. Although fatalities do unfortunately occur on Norwegian vessels, the trend over time indicates a clear reduction of the most serious accidents.
A vessel casualty may involve personal injuries or fatalities as well as damage to or loss of the vessel itself. The Norwegian Maritime Authority recorded 1 241 vessel casualties in the most recent five-year period (2014–2018). The annual number of groundings was quite stable during the five-year period, while the number of accidents involving contact damage (collisions with piers, bridges, etc.), dropped from 58 in 2014 to 34 in 2018.
The probability of accidents is influenced by a number of factors, including the volume of transport, the traffic situation, the technical standard and equipment of vessels, crew qualifications and the preventive measures that have been introduced. The forecast frequency of accidents is highest in the North Sea–Skagerrak area and lowest in the Barents Sea–Lofoten area. This corresponds to the share of total distance sailed in each of the management plan areas and also the shares of total distance sailed that are close to the coast.
In the period 2014–2017, the number of vessel casualties in the Barents Sea–Lofoten area was relatively low compared to the numbers for the Norwegian Sea and the North Sea–Skagerrak. The number of accidents was highest in near-coastal areas. In all, 428 incidents were recorded in the Barents Sea–Lofoten area, of which 126 involved spills totalling 15 062 litres of various substances. There was an increase in the number of incidents during this period, but the time frame is too short, and there are too few incidents, to draw any conclusions about trends. Most registered spills were small, but the total spill volume was noticeably higher in 2015 than in 2014, 2016 and 2017. The largest single spill (1 500 litres) was a release of marine diesel from a fishing vessel in 2015. In 2018, 106 vessel casualties involving spills were reported, with a total spill volume of 52 m3 to Norwegian waters. Over the last three years, there has been little variation in spill volume.
In the period 2011–2017, there was an increase in the volume of both transit traffic and high-risk traffic in the Barents Sea. With the higher volumes of high-risk cargo and bunker oil, there is also a higher discharge potential and a possibility of more severe environmental impacts. Data from the Vardø Vessel Traffic Service (VTS) Centre show that the vessels transporting petroleum products from northwestern Russia are relatively new. In addition, serious accidents involving large tankers are very rare. Thus, the growth in the volume of traffic and in the volume of petroleum products transported do not result in much increase in the likelihood of accidents.
Maritime safety measures
The Polar Code lays down globally binding rules for ships operating in polar waters, i.e. Arctic and Antarctic waters. Its rules apply in addition to those of already existing conventions and codes on maritime safety and pollution from shipping (SOLAS, MARPOL, the STCW Convention, etc). The Polar Code consists of two parts, one on safety and one on environment-related matters. It sets specific requirements for ships operating in polar waters, for example on ship design, equipment, operations, environmental protection, navigation and crew qualifications. The most important environment-related provisions deal with pollution by oil, chemicals, sewage and garbage released from ships. The Polar Code is considered to be one of the most important developments for improving maritime safety in polar waters. The Polar Code entered into force on 1 January 2017.
The prohibition against carrying heavy bunker oil in the protected areas around Svalbard was introduced in 2007, and its scope was expanded from 1 January 2015. Ships are not permitted to use or carry heavy bunker oil when sailing into Nordaust- and Søraust-Svalbard nature reserves on the east coast of Svalbard or the three large national parks Sør-Spitsbergen, Forlandet and Nordvest-Spitsbergen in the western part of the archipelago. Instead, they must use light marine diesel, which causes less serious pollution in the event of a spill. The Government is considering extending this ban to other parts of Svalbard‘s territorial waters. Negotiations under IMO are underway to establish an international ban on heavy fuel oil in the Arctic.
Traffic separation schemes and recommended routes have been introduced between Vardø and Røst (in 2007), between Runde and Utsira and between Egersund and Risør (in 2011). These measures have helped to move shipping further out from the coast, separate traffic streams in opposite directions and establish a fixed sailing pattern. The traffic separation schemes reduce the risk of collisions, simplify traffic monitoring and give the maritime traffic control centres more time to come to the assistance of vessels when necessary.
The government emergency tugboat capability is designed to prevent or reduce the risk of acute pollution during towing operations or when assisting vessels in other ways. From 1 January 2020, operational responsibility for providing this capability has been transferred to the Coast Guard, under the administration of the Norwegian Coastal Administration. The Coast Guard will shortly have two new vessels in service, and will then have six vessels that provide tugboat capability. The Coastal Administration coordinates the use of government tugboat capability from the Vardø VTS Centre. The VTS Centre deploys tugboat capability in cooperation with the Coast Guard command centre at Sortland.
Vessel monitoring systems in Norwegian waters provide a detailed picture of maritime traffic and make it possible to provide assistance or take steps to limit damage at the right time. These systems also make it easier for the authorities to deal with accidents and run search and rescue operations. Further development of the infrastructure for receiving Automatic Identification System (AIS) signals from vessels has significantly enhanced vessel monitoring in recent years. A network of AIS base stations along the entire mainland coast and for the most heavily trafficked waters off Svalbard has been established. Satellites equipped with AIS receivers have also greatly enhanced monitoring in the open sea. The Vardø VTS Centre monitors shipping throughout Norway‘s exclusive economic zone and the waters around Svalbard, focusing particularly on tankers and other large vessels. The Vardø VTS also monitors compliance with the rules for the traffic separation schemes and recommended routes off the coast, and issues navigational warnings.
Fairway measures, such as dredging and blasting to remove shallows, improve safety and navigation in narrow coastal channels. Some fairway measures also reduce distance and time sailed. In many cases, fairway measures involve the removal of contaminated sediments, which improves environmental status in the ports and fairways where this is done.
The white paper on cooperation to improve maritime safety (Meld. St. 30 (2018–2019)) gives an account of maritime safety measures implemented in recent years. Together, these measures have enhanced maritime safety in Norway‘s marine and coastal waters.
Integrated environmental risk and preparedness analyses were carried out for the mainland coast in 2011 and for Svalbard and Jan Mayen in 2014. The analysis of the likelihood of vessel casualties leading to acute pollution was updated in 2018, and shows only small changes in accident likelihood. The Norwegian Coastal Administration has developed new tools to calculate the likelihood of accidents and environmental risks associated with shipping, and will regularly assess trends in risk level once these tools are taken into use. If there are substantial changes in the level of environmental risk, it may be appropriate to adjust the capabilities of the governmental preparedness and response system for acute pollution.
There is uncertainty concerning potential environmental consequences associated with spills of new fuel types. The Coastal Administration has therefore analysed many of the new fuels that are now being taken into use in Norwegian waters and the Arctic. This builds a stronger basis for decisions about operations to deal with acute pollution, including assessing different response techniques and strategies.
6.3 Petroleum activities
In addition to operational discharges (discussed in Chapter 5), petroleum activities involve a risk of acute pollution. Acute pollution may be caused by events ranging from blowouts, where there is an uncontrolled flow from one or more reservoirs and large volumes of oil may be released to the sea, to small-scale spills of oil or chemicals, for example due to a ruptured hose or overfilled tank. The risk of spills during petroleum activities is also referred to as accident risk in this white paper. The risk of spills causing environmental damage is referred to as environmental risk.
For over 40 years, the Norwegian petroleum industry has been dealing with challenges in new areas, developing necessary knowledge and technology, and building up wide operational experience. Before starting activities in new areas, the industry dedicates substantial resources to knowledge acquisition, assessment and any measures considered to be necessary. The infrequency of accidents must be considered in conjunction with these preparations and with companies’ risk management systems and the improvements they make in subsequent phases of activity. After assessments, the Forum for Integrated Ocean Management concluded that no individual factors had been identified that were previously unknown and that cannot be managed within the framework of the current legislation, and/or are not already being dealt with through technology development.
Management responsibility for the petroleum sector is split between a number of ministries and directorates. From the outset, a key part of the system has been maintaining high health, safety and working environment standards. The Government‘s ambition is for the Norwegian petroleum industry to be world-leading in this field. The industry supports this ambition and is responsible for achieving it.
There have been both large and small spills from oil and gas activities on the Norwegian continental shelf, but they have occurred relatively far from land and under favourable weather conditions, and response measures were implemented, so that the pollution has not reached land or caused environmental damage.
There was a decline in the number incidents involving crude oil spills on the Norwegian continental shelf in the period 2001–2018 (see Figure 6.1). This indicates that barrier failures have been occurring less frequently in recent years. The decline is due to a reduction in the number of incidents and in spill volumes. Incidents involving large spills occur infrequently, and there is insufficient data to identify a trend. Few incidents were registered in the Barents Sea–Lofoten area that resulted or could have resulted in acute pollution in the period 2001–2018.
Chemical spills are the dominant type of incident involving acute pollution from petroleum activities on the Norwegian continental shelf (see Figure 6.2). Roughly 80 % of the incidents involving acute pollution in the period 2001–2018 were chemical spills. Around one-fourth of these involved a spill volume exceeding one cubic metre.
There has been a decline in the number of incidents involving acute pollution in the Norwegian Sea in recent years. The same applies to incidents involving chemical spills. However, total spill volumes from incidents involving chemical spills have been high in recent years both in the Norwegian Sea and in the North Sea–Skagerrak.
The figures for 2001–2018, include too few registered incidents in the Barents Sea–Lofoten area to allow analysis of trends over time or comparison with the other management plan areas. However, both the figures and practical experience indicate that the safety level in the Barents Sea is on a par with that on the rest of the continental shelf. The level of activity in the Barents Sea since 2013 has enabled both the authorities and the operators to learn more about factors specific to particular areas.
A near miss is an event that does not lead to a spill but that could have done so under different circumstances. Such events are analysed and followed up by the operators and the authorities, in particular the Petroleum Safety Authority, so that the experience gained can be used in preventive efforts and risk treatment.
In recent years there has been a tendency for the number of near misses on the Norwegian continental shelf to rise, because the number of well control incidents in the North Sea has risen. Most of these incidents have occurred during production drilling. Relatively large numbers of production wells have been drilled in the North Sea during the same period.
Measures to reduce accident risk
Much safety work involves preventing or mitigating the consequences of incidents. Often, the same mechanisms underlie near misses and more serious incidents, despite differences in the consequences. Small differences in circumstances may be enough to determine whether near misses and accidents result only in financial consequences or whether they also cause personal injuries and/or lead to acute pollution. Reducing accident risk is therefore a vital part of safety work. Whether it is possible in practice to avoid accidents that lead to acute pollution will depend greatly on risk management work by the companies during planning and operations.
Operators are responsible for preventing all incidents, including those that may lead to acute pollution. Accident prevention requires continuous efforts by competent, responsible stakeholders. Before starting activities, the operator must determine whether established procedures can be used, or whether further measures need to be implemented to operate responsibly. The authorities monitor this through supervisory activities and consent procedures. The Petroleum Safety Authority has a particular responsibility for ensuring that operators work systematically to reduce accident risk through targeted risk management, knowledge development, transfer of experience, and development of technology and standards.
The Petroleum Safety Authority has also taken various steps to ensure learning from experience, and has strengthened safety rules, provided information on requirements for risk management, and sought to improve barrier management. Stricter requirements for drilling of relief wells have been introduced, as well as a closer focus on dealing with uncertainty in risk management.
The Petroleum Safety Authority, in cooperation with the operators, has been focusing more on preventing well control incidents during exploration drilling, for instance through special attention to well design and changes to statutory requirements. Well control incidents can lead to major spills, and are therefore given high priority even though the likelihood of such accidents is low.
Subsea installations may also be a source of acute pollution. The industry and the authorities are cooperating on developing methods to prevent and detect such incidents. The development of technology for early detection of spills is a key part of these efforts.
The same health, safety and working environment legislation for petroleum activities applies to the entire Norwegian continental shelf. It includes requirements for risk management and to take local factors into account. The companies must therefore assess local conditions and take appropriate measures to deal with them. This makes it important to build up knowledge and information about local conditions. Experience has shown that there are certain local factors in the Barents Sea that require special measures to be taken. In recent years, the operators and the authorities have worked to develop knowledge and standards to deal with this. The companies dedicate substantial resources to knowledge acquisition, assessments and the necessary measures. They also cooperate on solutions to improve accident prevention and response, such as the oil spill preparedness and response system. Another priority area is development of technical and operational solutions adapted to conditions when icing is likely.
The Petroleum Safety Authority has been following and contributing to the development of knowledge and standards specifically related to these matters. The Authority has also taken a number of initiatives to consider how to foster closer cooperation between companies involved in petroleum activities in the Barents Sea.
The environmental risk associated with petroleum activities is primarily related to oil spills. Releases of natural gas emissions and chemicals are not associated with a high level of environmental risk. Environmental risk is defined as the potential for environmental consequences from acute pollution.
The health, safety and working environment regulations require operators to conduct risk analyses of their own activities to support decisions when assessing risk-reducing measures, in keeping with requirements to minimise risk. The regulations also require operators to set their own acceptance criteria for environmental risk and apply these in managing their activities.
The operators’ analyses and assessments of environmental consequences and environmental risk, together with other available knowledge about potential environmental consequences, are used as a basis for determining requirements for acute pollution preparedness and response, as well as for assessing whether the risk level for activities described in an application is acceptable. The legislation requires analyses and assessments to be based on the best available underlying data and reasonable assumptions.
The environmental authorities need information on the potential for environmental consequences, the severity of the potential consequences and the associated uncertainty when assessing levels of environmental risk. Environmental risk is an important part of overall risk assessment, and risk management must include both preventive measures and measures to reduce consequences. The Petroleum Safety Authority and the Norwegian Environment Agency are seeking to enhance integrated risk management across different fields.
There is a substantial body of experience relating to spill scenarios, oil spill modelling and potential environmental consequences, environmental risk and challenges relating to preparedness and response in the Barents Sea. This experience, together with new knowledge about species and habitats, is important for understanding environmental risk in the management plan area.
The potential consequences will be greatest if a spill could affect areas where there are high concentrations of vulnerable species and habitats, such as the marginal ice zone and areas close to seabird colonies.
Seabirds stand out as being at high environmental risk in the Barents Sea. Although the discharge potential here, particularly in northern parts of the Barents Sea South, is considerably lower than elsewhere on the Norwegian continental shelf, the environmental risk for seabirds in the open sea is generally higher in the Barents Sea–Lofoten area than in the North Sea–Skagerrak and the Norwegian Sea, because larger numbers of seabirds are present for much of the year.
There is no reason to believe that environmental risk to fish is high, as long as there is no significant overlap between the presence of fish eggs and larvae and harmful concentrations of oil. The level of risk also depends on how vulnerable a particular stock is to the loss of a year class of recruits to the mature stock.
The level of environmental risk associated with most drilling and other field activity in the Norwegian Sea and the North Sea is within the range expected for these activities in these management plan areas. This is mainly because the likelihood of serious accidents is considered low and because, for many activities, there is a limited potential for environmental consequences in the most vulnerable areas. However, certain activities in the Norwegian Sea and the North Sea are associated with a high level of environmental risk because they have a potential for serious environmental consequences. Some wells are considered to pose a high environmental risk because of their potential for very high blowout rates and/or their location near the coast. New knowledge about the potential for oil sedimentation from spills is also of relevance for environmental risk assessments for the Norwegian Sea, where there are large, important cold-water coral reef complexes. Oil drift simulation for wells near the Viking Bank indicates that in the event of a spill, oil concentrations in much of the water column in the area could exceed the estimated threshold for harmful effects on fish larvae, including sandeels. Data on the specific oil concentrations that are harmful to sandeel eggs and larvae is not available, and will be needed to improve assessments of the environmental risk to sandeels.
Important measures for reducing environmental risk
The most important ways of reducing environmental risk are to take preventive action to reduce the likelihood of accidents involving spills and to avoid accidents in areas that are particularly vulnerable to acute pollution. Such measures may include robust well design, good standards of maintenance, measures to reduce potential spill volumes, and scheduling activities during periods when the environmental consequences of acute pollution would be smaller. In certain areas and at certain times of year, it will be difficult to reduce environmental risk sufficiently through preparedness measures. Scheduling activities outside the areas and times associated with highest environmental risk is one of the measures that can give the greatest reductions in the consequences of spills.
6.4 Activities involving nuclear and radioactive material
Large-scale nuclear accidents can have very serious consequences in nearby areas. In addition, radioactive pollution can be spread widely by winds and ocean currents and affect large geographical areas. Shortly after a nuclear accident, organisms may suffer external exposure to radiation or may ingest radioactive material. In the longer term, exposure will primarily be internal, through the uptake of radioactive substances in organisms and food chains. In recent years, environmental risk assessments have been conducted for accident scenarios involving nuclear-powered vessels, maritime transport of radioactive material, leaks from sunken nuclear submarines, and long-range transport of radioactivity released from reprocessing plants. These assessments indicate that for a number of accident scenarios, there is a potential for levels of radioactive substances to exceed thresholds set by the authorities.
Of Norway‘s three management plan areas, the Barents Sea–Lofoten area has the highest volume of traffic involving nuclear-powered vessels and vessels carrying nuclear weapons. This is also the area nearest sources and activities in northwestern Russia, including military facilities and activities, civilian nuclear reactors, civilian nuclear-powered vessels and transport of radioactive material, and floating nuclear power plants. There are also a number of sunken nuclear submarines and sites where radioactive waste has been dumped in the Barents Sea and the adjoining Kara Sea. There is also risk associated with a possible future increase in military activity and greater use of the Northern Sea Route, which may include the use of floating nuclear power plants and small modular reactors in connection with the anticipated rise in commercial activity.
Proximity to the Sellafield (UK) and La Hague (France) reprocessing plants entail shorter transport time and less dilution of radioactive material before reaching Norway‘s management plan areas of the North Sea–Skagerrak and the Norwegian Sea.
6.5 Preparedness and response to acute pollution: reducing the consequences of accidents
The Pollution Control Act distinguishes between private, municipal and governmental levels of the preparedness and response system for acute pollution. A basic principle of the Act is that anyone who is engaged in any activity that may result in acute pollution must ensure that the necessary preparedness and response system is in place to prevent, detect, stop, remove and limit the impacts of pollution. A municipality where there is a pollution incident has an obligation to take action if those responsible for the pollution are unable to deal with it. The central government is the supervisory authority for private and municipal acute pollution response operations, and can assume on-scene command if the situation is not being adequately handled by the polluter or municipality. At operational level, the overall preparedness and response system involves cooperation between the three levels described here.
The Norwegian Coastal Administration, under the Ministry of Transport, is responsible for the governmental preparedness and response system for acute pollution, and for supervision of the response of those responsible in the event of acute pollution. The Coastal Administration is also responsible for coordinating governmental, municipal and private resources to provide a national preparedness and response system for acute pollution.
The Norwegian Environment Agency, under the Ministry of Climate and Environment, is responsible for setting requirements for private and municipal preparedness and response systems, further developing preparedness and response legislation, and supervising private and municipal preparedness and response systems. The Petroleum Safety Authority, under the Ministry of Labour and Social Affairs, is responsible for technical and operational safety and for preventing acute pollution from petroleum activities.
The Government has decided to establish test facilities for oil spill response equipment at Fiskebøl, Nordland county, as part of the Norwegian Centre for Oil Spill Preparedness and Marine Environment. This will provide opportunities for testing equipment over long periods in cold conditions will and strengthen research and development of technology for operations in icy waters. In the longer term, this will improve Norway‘s oil spill preparedness. In addition, the Coastal Administration has launched a number of research projects on new methods for dispersion and in-situ burning of different types of fuel in cold waters.
The Pollution Control Act and Norway‘s national plan for the emergency preparedness and response system for acute pollution clarify roles and responsibilities, which also apply in the Barents Sea–Lofoten area. Exercises are held several times a year. The Coastal Administration takes part in large-scale exercises with the oil companies every year, and at least one exercise a year involves the governmental preparedness and response system assuming on-scene command. The Coastal Administration also participates in search and rescue (SAR) exercises and, together with the Joint Rescue Coordination Centre, conducts annual SAR and oil response exercises with Russian authorities in the Barents Sea. The Coastal Administration also carries out annual exercises with the governmental action control group and the Governor of Svalbard. In recent years, the Coastal Administration has carried out shoreline clean-up exercises in eastern Finnmark together with Russian partners and the intermunicipal acute pollution control committees. To define roles and responsibilities for preparedness and response even more clearly, the Coastal Administration will revise the national plan for the emergency preparedness and response system for acute pollution in 2020.
The Office of the Auditor General has investigated the authorities’ efforts to safeguard the environment and fisheries in connection with petroleum activities in the Arctic. The Storting has considered the Auditor General‘s report and responded to a number of its recommendations. The Auditor General concluded that the oil spill preparedness and response system is not properly adapted to the specific conditions in the Arctic. The report therefore recommends that the competent authorities should consider ways of strengthening research on new methods for oil spill response in icy conditions, obtain better information about the operators’ preparedness and response plans, and conduct emergency preparedness analyses and exercises in cooperation with other authorities and the industry in order to assess overall preparedness and response in the Arctic. Closer follow-up of municipal preparedness and response systems is also recommended. Steps have been taken to follow up the Auditor General‘s recommendations.
The Coastal Administration and the Norwegian Environment Agency are seeking closer collaboration to ensure the right preparedness and response requirements for the petroleum industry, and effective coordination of national preparedness and response. To ensure better access to information, it may be appropriate to establish a joint database for operators’ preparedness and response plans.
Under section 43 of the Pollution Control Act, municipalities are required to provide for the necessary emergency preparedness and response system to deal with minor acute pollution incidents. The Norwegian Environment Agency is the supervisory authority for municipal preparedness and response and is authorised to set further requirements for the municipalities, while the Coastal Administration is responsible for coordinating the national preparedness and response system. To ensure closer coordination of municipal and governmental preparedness and response, the possibility of transferring responsibility for supervision and follow up of municipal preparedness and response from the Norwegian Environment Agency to the Coastal Administration will be considered. This could ensure seamless integration between municipal and governmental preparedness and response systems.
The Barents Sea–Lofoten area
Over the past decade, both the governmental and private preparedness and response systems for acute pollution have been built up. The white paper on cooperation to improve maritime safety (Meld. St. 30 (2018–2019)) reviewed ways of strengthening governmental preparedness and response. Based on the difficulties identified in the 2014 environmental risk and emergency preparedness analysis for Svalbard and Jan Mayen, the Government has implemented a number of measures to strengthen the preparedness and response system for acute pollution in the area. Service vessels under the Governor of Svalbard have been outfitted with additional oil spill response equipment and crews are trained to use it. Several new vessels have been included in the coastal preparedness and response system for Svalbard. The Coast Guard vessel KV Svalbard has been equipped with a heavy-duty oil containment boom reinforced for icy conditions. In cooperation with the Governor of Svalbard and the company Telenor, the Coastal Administration has developed a maritime broadband radio network for key areas of Svalbard‘s west coast.
The Coastal Administration has analysed many of the new fuels that are now being taken into use in Norwegian waters and the Arctic. These have been tested under Arctic conditions for persistence, evaporation rates, dissolution rates in water, dispersibility and toxicity. The Coastal Administration has also investigated releases of gases and particulate matter from the combustion of different fuels. This is important background information for environmental assessments of measures to deal with acute pollution.
The northernmost sea areas have little infrastructure and limited telecommunications coverage and capacity. The availability of oil spill response equipment and personnel is also limited, there is a lack of sites where recovered oil and waste can be deposited, and distances are long, meaning that response times are also long if there is an incident.
Natural conditions will also affect oil spill recovery operations – for instance the very limited daylight for part of the year, low temperatures and the risk of icing on equipment, and the often rapid shifts in weather conditions. The presence of ice makes it considerably more difficult to deal effectively with acute pollution. Finding efficient logistics solutions will be a major challenge for all types of operations in Arctic waters. Personnel and material will need to be transported to and from the area affected during an oil spill operation, and recovered oil will have to be transported out of the area unless it is burned off in situ. Operational platforms including ships, aircraft and drones must be robust and meet adequate safety standards. It is essential to comply with health, safety and working environment requirements for response personnel during all types of activities.
An oil spill response operation near Bjørnøya would be particularly challenging. Access to the island from both land and sea is difficult for response teams and equipment due to its exposed coastline and steep coastal cliffs. Even much of the more low-lying northern part of the island ends in a steep drop of 10–30 metres, making boat landings difficult. There are a few sandy bays and beaches, but even these are not protected from winds and rough seas. The exposed coastline and wave conditions akin to the open sea mean that standard oil recovery systems designed for fjord and coastal operations are not robust enough. Larger systems have the drawback of being difficult to manoeuvre near the coast. Access from land is extremely difficult because of a lack of infrastructure in addition to the terrain.
It would also be very demanding to carry out a large-scale shoreline-cleaning operation in Svalbard because of the long distances involved and the lack of resources and infrastructure on land. Dealing with waste would be particularly difficult, and it will be necessary to focus on techniques for reducing waste quantities.
Technology development has resulted in improvements of conventional methods for spill containment and recovery in open seas and coastal waters, but the cold, presence of ice and long distances still make response operations in both coastal waters and the shore zone a challenging task.
There are challenges relating to wave height, currents and operations in coastal waters and the shore zone in all three management plan areas. It is particularly demanding to carry out large-scale response operations in vulnerable coastal waters.
Both public- and private-sector studies have been carried out to assess the suitability of available oil spill response methods and equipment in the Barents Sea–Lofoten area, and how their suitability may vary from season to season. Based on knowledge about limitations relating to wave height, ice, wind and light conditions, the studies indicate that conditions for mechanical recovery of oil will seldom be favourable in winter but will often be favourable in the summer. Unfavourable conditions can significantly reduce operational effectiveness. Actual recovery effectiveness, which has not been assessed, will depend on the type of oil and degree of weathering.
The use of dispersants is not restricted to the same extent by the prevailing weather conditions, and weather statistics indicate that they will be suitable for use for more of the year. Since seabirds are considered to be the group at the highest environmental risk from oil spills in the Barents Sea, using dispersants may be an important part of a preparedness and response strategy for the area. However, dispersant delivery capacity for the Barents Sea is currently limited.
Subsea injection of dispersants was an important part of the response during the Gulf of Mexico blowout in 2010. Studies by the oil and gas industry indicate that water depths in the Barents Sea, the Norwegian Sea and northern North Sea are sufficient for subsea injection of dispersants to be effective, provided that the gas content of the oil is not excessive. However, more knowledge is needed about sedimentation of dispersed oil and possible formation of marine oil snow before dispersants are used in areas with a vulnerable benthic fauna.
Both mechanical recovery and dispersion can function satisfactorily in areas with some ice. Recent field trials have shown that mechanical equipment can be operated in areas with up to 10 % ice cover. However, the reduction in recovery effectiveness caused by the recovery of large quantities of ice with the oil has not been assessed. Both governmental and private response equipment has been tested, and steps have been taken to strengthen equipment to withstand the additional load of ice.
The use of in-situ burning has been considered as a way of dealing with oil trapped in ice and oil-polluted sediments in areas lacking the infrastructure needed to handle large quantities of waste. Burning trials have shown that significant amounts of viscous oil residue remain and must later be recovered. Further development work is needed to find a suitable recovery method for use during response operations.
Design and capabilities of the preparedness and response systems
Governmental preparedness and response
Governmental preparedness and response capability and the locations where equipment and other resources are available are determined on the basis of knowledge of environmental risk associated with oil spills from shipping in Norwegian waters. The Coastal Administration carried out environmental risk and emergency preparedness analyses for the mainland coast in 2011 and for Svalbard and Jan Mayen in 2014. These analyses are used in the work of optimising the design of the governmental preparedness and response system.
The petroleum industry‘s preparedness and response system
There is no clear-cut solution for how the preparedness and response system for petroleum activities on the Norwegian continental shelf should be designed. The system must be in reasonable proportion to risk, rather than based on worst-case scenarios. Nonetheless, the system is designed to deal with blowouts of relatively long duration, even though their likelihood is low.
The Office of the Auditor General has raised questions about whether certain weaknesses in the operators’ analyses, their presentation of results, and insufficient cooperation between the relevant authorities have resulted in an inadequate basis for making decisions about requirements for risk-reducing measures. There is a need to review the assumptions on which preparedness and response capability is based and how the response equipment and techniques available and their limitations are taken into account. The operators are now reviewing their guidelines for environmental preparedness analyses, and the Norwegian Environment Agency is considering amending the requirements set out in regulations and individual decisions.
Restrictions on when drilling is permitted can considerably reduce the environmental risk associated with exploration drilling. By the time production drilling starts, there is much more information about reservoir conditions and types of oil, and the likelihood of a blowout is lower than during exploration drilling. A gas blowout is primarily associated with a risk of fire or explosion. Oil spill response measures can reduce the consequences of a spill. There is always a possibility of oil spills and discharges of chemicals during oil production or drilling in oil-bearing formations. It is therefore vital that the industry maintains high safety standards and continues its efforts to reduce the risk of spills.
The oil spill preparedness and response system at private, municipal and governmental level is risk-based. Uncertainties regarding risk levels and which types of incidents may occur make it difficult to assess whether the design and capabilities of the preparedness and response system are appropriate. Measures have been introduced to strengthen the preparedness and response system both at governmental level and by the petroleum industry. However, it is difficult to verify how much these measures will reduce the consequences of spills, and the extent to which the goal for acute pollution has been achieved is uncertain.
Emergency preparedness system for nuclear accidents and acute radioactive pollution
Norway‘s nuclear emergency preparedness system involves authorities at the national, regional and local levels. The system is designed to rapidly establish an effective, science-based, coordinated response to nuclear accidents and ensure the rapid implementation of measures to protect lives, health, the environment and other important public interests. Norway‘s nuclear emergency preparedness system is led by the Crisis Committee for Nuclear and Radiological Preparedness.
In the event of a nuclear accident, the Crisis Committee will coordinate the responses of various authorities in different sectors, and can also implement measures itself. The spread of the radioactive pollution and its anticipated scale and severity will be modelled. Measurements and other information will also need to be obtained to feed into the models in order to characterise the type and amount of radioactive pollution. Life-saving efforts at the accident site/vessel will be given top priority. This work will be coordinated by one of the Joint Rescue Coordination Centres with expert assistance from the Crisis Committee and the Norwegian Radiation and Nuclear Safety Authority. Important action may include issuing advisories to and redirecting people in the vicinity, measures to deal with the vessel, and halting other nearby activities that are affected by the accident. Even minor incidents that do not involve a risk that radioactive material will be released could have serious impacts on Norwegian commercial interests such as seafood exports. The Crisis Committee and others involved in the system are engaged in continuous efforts to improve preparedness, for instance by following up the Crisis Committee‘s updated threat assessments.
The Ministry of Climate and Environment is in the process of extending the applicability of certain provisions of the Pollution Control Act to acute radioactive pollution. These concern the municipal and governmental preparedness and response system, preparedness and response plans, governmental on-scene command of operations, and the duty to provide assistance. This will make the Norwegian Radiation and Nuclear Safety Authority responsible for setting requirements for private and municipal preparedness and response systems, further developing preparedness and response legislation and supervising private and municipal preparedness and response for acute radioactive pollution. In addition, the Authority will assume governmental on-scene command if required during acute radioactive pollution incidents. This corresponds to the role the Coastal Administration has in dealing with other forms of acute pollution, which will facilitate the development of cooperation between the two bodies in administering the same legislation for different types of acute pollution, and will enable them to deal with complex pollution situations together.
Since the 1990s, Norway‘s nuclear emergency preparedness system has been built up through work under the Government‘s Nuclear Action Plan. Nuclear safety cooperation with Russia has been a particularly high priority, and formal and informal cooperation has been established between relevant Norwegian and Russian authorities. Norway‘s focus areas in the years ahead include dealing with sunken and dumped submarines and other radioactive objects, and cooperation on notification and preparedness and response, for example within the framework of the Norwegian-Russian Commission for Nuclear Safety.