Effective Daily Recovery Capacity (EDRC)

1. Effective Daily Recovery Capacity (EDRC) • Established following the Oil Pollution Act of 1990 (Exxon Valdez incident) • Quantifies the amount of pollution equipment needed by plan holders for an effective response to oil spills, including Worst Case Discharge (WCD) scenarios • Method of calculation (formula) is described in 33 CFR 154 / 155

2. Effective Daily Recovery Capacity (EDRC) R = T x 24 hours x E R = EDRC T = Throughput rate in barrels per hour (nameplate capacity) E = 20 percent Efficiency factor (or lower factor as determined by Coast Guard)

3. Alternate Method • Approved method under regulations • ASTM Standard F631, or Verified actual spill performance data • Calculates lower recovery capacity than EDRC • Not used in calculations by most plan holders

4. What does EDRC account for? • Weather • Sea State • Daily operating period

5. What does EDRC not account for? • Encounter rate • Oil type & thickness • Emulsification • Location of spill (offshore, inshore, inland) • Storage capacity • Skimmer operator proficiency (human factor) • Impact of dispersants on oil recoverability

6. Factors Affecting Skimming Efficiency Human Factors Storage Capacity Weathering Weather, Geography & Ocean Characteristics Weathering Encounter Rates Skimming Efficiency Chemical Dispersion Detection Oil Characteristics Credit: NASA

7. EDRC during Deepwater Horizon • The EDRC on-scene during this incident far exceeded BP’s Oil Spill Response Plan (OSRP) requirements • At height of incident, EDRC on-scene was equivalent to almost 2X the Worst Case Discharge for the Macando Well • Estimated only 3% of total amount of oil released was mechanically recovered

8. DWH Reports on EDRC National Commission report • Coast Guard should revise EDRC to encourage development of more efficient systems ISPR Report • EDRC on-scene far exceeded plan requirements, yet mechanical recovery accounted for small amount • EDRC should incorporate offshore limitations such as encounter rate • Regulations should encourage R&D of more effective skimmer systems

9. EDRC Workshop at IOSC 2011 • Sponsored by USCG, BSEE, & API • Attendance from representatives from the oil spill response community • Presentations followed by facilitated discussion

10. IOSC 2011 – Federal Govt perspective • We need to create incentives that allow the government & industry to find ways to develop more effective systems • We need to better align planning standards with actual performance • We should consider different approaches for different operating environments • Regulations over-emphasize pump capacity & neglect other parts of skimming systems

11. IOSC 2011 – Oil Industry perspective • Statistics from DWH do not represent the whole picture for mechanical recovery • Industry has embraced DWH lessons learned & is looking at ways to improve encounter rate • We need to rely on all our response tools in the offshore environment (dispersants, in-situ burn) • Focus on a systems approach; must include well-maintained equipment & trained personnel

12. IOSC 2011 – Shipping Industry perspective • Public & Congress expects industry to improve every time we respond • OPA 90 is sound; there is no need to make significant changes post-DWH • Big differences between OPA 90 & DWH • We need to embrace our existing regulatory framework & build upon our successes

13. IOSC 2011 - OSRO Community perspective • Planning measure estimate for oil recovery • Fundamentally sound concept but open to enhancement • Fundamental to Response Plan Holders and their contracted OSROs • Drives capital investment and inventory needs • Provides broad framework for comparison and measurement for Plan adequacy • Performance dictated by numerous external factors and not intended to be directly correlated to the planning standard

14. IOSC 2011 - OSRO Community perspective • Safe, Realistic, Achievable, Reliable criteria • Broader “System” approach with oil recovery device EDRC as only part of the solution • ASTM F1780 - 97(2010) Standard Guide for Estimating Oil Spill Recovery System Effectiveness • Enhanced communication and education when we greatly increase EDRC during large incident • More Industry and Government sponsored R&D

15. Potential Courses of Action • Making improvements & adjusting “E” • Identifying different site specific “E”s • Create a new model based on NOAAs mechanical equipment calculation model • Adopt another country’s system (i.e. Norway) • Adopt an improved ASTM standard with a new efficiency factor

16. Way Forward • USCG & BSEE have initiated an independent, 3rd party research contract w/ GENWEST • Agencies will review final report and determine a way forward to address this issue