Oil Blowout Contingency Planning and Countermeasures 69 10. OIL BLOWOUT CONTINGENCY PLANNING AND COUNTERMEASURES CONTINGENCY PLANNING An oil spill contingenc y plan is an action plan for responding to oil released by a blowout. It describes actions that would be taken to avoid or reduce the impacts of an oil blowout. The Canada Oil and Gas Lands Administration requires a site-s pecifi c o il blowout contingency plan before it wil l approve a drilling program. The plan is prepared by industry operators, in cooperation with gover nment agencies, at the time they apply for specific drilling permits. The contents of a contingency plan are described in Canad a Oil and Gas Lands Administration’s Guide- lines and Procedures for Drilling for Oil and Gas on Minist ry of Energy, Mines and Petroleum Resource s also requires contingency plans in its draft Dril ling and Production Regulations. This s ection considers some of the requirements that should be included in contingency planning, such as sens itivity mapping, organization and countermeasure operations. SENSITIVITY MAPPING FOR CONTINGENCY PLANNING For effective contingency planning, information on important resourc es at risk to an oil blowout must be sufficien tly detailed to provide a basis for determining how and where various countermeasures should be deployed. Many participants argued that information for identifying important resourc es vulnerable to oil on the British Columbia north coa st is inadequate to meet this requirement. These resources include fisherie s, bird or marine mammal concentrations, sensitive nearshore areas and estuaries, recreation and heritage sites and ecological reserves. In responding to an oil slic k’s movement, the on-scene commander needs information identifying the most important areas, rather than detailed descriptions of the resource s at each site. This information is best provided on sens itivity maps. which highlight priority-a reas and their sensitivity to oil at various times and seasons. They should also include informa tion on the best measures for protecting those areas and for cleaning up oil should it reach the shore. The Initial Environmental Evaluatio ns prepared by Chevron and Petro-Canada identified important coastal resource areas. Further information, including further research needs, was provided by government and Chevron in response to the Requirements for Addition al Informa- tion. This information provides a starting point for mapping prio rity resource areas for contingency planning. A resource mappi ng program sponsored under the Environme ntal Studies Revolving Fund is underway for the Queen Charlotte Islands, and Chevron stated it would conduct further programs to obtain the information needed to meet requirements for obtaining a drillin g permit. Information is also n eeded on the domestic use of marine resources, particu larly the native food fishery. Because local residents have concerns about the confidentia lity of this information, it is important to involve them in identifying priorit y areas for protection. This ensures that local knowledge and interests are recognized in the mapping process. Final ly, inventorie s are needed of the large number of archaeolog ical sites along the shoreline s and intertidal areas of the north coast. M any of these sites could be exposed to oil stranded on the beach and could be furt her disturbed by inappropriate cleanup activit ies. To ensure that it contains the latest and most complete information, the Panel believes that sensitivit y mapping must be updated regula rly by resource agencies and industry. Clear respon sibility must be assigned for updating. Agen cies involv ed in updating should also be involved in the original data collectio n so that they understand the methods and limitations of the data base. The Panel recommends that, before exploratory drilling is approved, the regulatory authority ensure that: 1. 2. 3. coastal sen sitiv ity mapping begun under the Eaviromaeotal Studies Revolving Fund is expanded to corer areas that are oow ioade- quately mapped; the native food fishery aod resource harvesting activity are iocluded within this mapping. with native people involv ed in acquirin g nod develop ing this information; arrangements are ia place to ensure that sens itivi ty mapping i s maintained and updated jointly by the British Colombi a Ministry of Environment, Environment Canada, the Department of Fishe ries aod Oceans and industry; and
Oil Blowout Contingency Planning and Countermeasures 69
10. OIL BLOWOUT
CONTINGENCY PLANNING
AND COUNTERMEASURES
CONTINGENCY PLANNING
An oil spill contingency plan is an action plan forresponding to oil released by a blowout. It describesactions that would be taken to avoid or reduce theimpacts of an oil blowout.
The Canada Oil and Gas Lands Administration requiresa site-specifi c o il blowout contingency plan before it wil lapprove a drilling program. The plan is prepared byindustry operators, in cooperation with governmentagencies, at the time they apply for specific drillingpermits. The contents of a contingency plan are describedin Canada Oil and Gas Lands Administration’s Guide-
lines and Procedures for D rilling for Oil and Gas onCanada Lands (September 1984). The British ColumbiaMinist ry of Energy, Mines and Petroleum Resources alsorequires contingency plans in its draft Drilling andProduction Regulations.
This section considers some of the requirements thatshould be included in contingency planning, such assens itivity mapping, organization and countermeasureoperations.
SENSITIVITY MAPPING FOR CONTINGENCYPLANNING
For effective contingency planning, information onimportant resources at risk to an oil blowout must besufficien tly detailed to provide a basis for determininghow and where various countermeasures should bedeployed. Many participants argued that information foridentifying important resources vulnerable to oil on theBrit ish Co lumbia north coast is inadequate to meet thisrequirement. These resources include fisheries, bird ormarine mammal concentrations, sensit ive nearshore areasand estuaries, recreation and heritage sites and ecolog icalreserves.
In responding to an oil slick’s movement, the on-scenecommander needs information identifying the mostimportant areas, rather than detailed descriptions of the
resources at each site. This information is best providedon sensitivity maps. which highlight priority-areas andtheir sensitivity to oil at various times and seasons. Theyshould also include information on the best measures forprotecting those areas and for cleaning up oil should itreach the shore.
The Initial Environmental Evaluations prepared byChevron and Petro-Canada identified important coastalresource areas. Further information, including furtherresearch needs, was provided by government and Chevronin response to the Requirements for Additional Informa-tion. This information provides a starting point for
mapping prio rity resource areas for contingency planning.A resource mapping program sponsored under theEnvironmental Studies Revolving Fund is underway forthe Queen Charlotte Islands, and Chevron stated it wouldconduct further programs to obtain the informationneeded to meet requirements for obtaining a drillingpermit.
Information is also needed on the domestic use of marineresources, particu larly the native food fishery. Becauselocal residents have concerns about the confidentia lity ofthis information, it is important to involve them inidentifying priorit y areas for protection. This ensures thatlocal knowledge and interests are recognized in the
mapping process.
Final ly, inventories are needed of the large number ofarchaeolog ical sites along the shorelines and intertidalareas of the north coast. Many of these sites could beexposed to oil stranded on the beach and could be furtherdisturbed by inappropriate cleanup activit ies.
To ensure that it contains the latest and most completeinformation, the Panel believes that sensitivit y mappingmust be updated regula rly by resource agencies andindustry. Clear responsibility must be assigned forupdating. Agencies involved in updating should also beinvolved in the original data collection so that theyunderstand the methods and limitations of the data base.
The Panel recommends that, before exploratorydrilling is approved, the regulatory authority ensurethat:
1.
2.
3.
coastal sensitiv ity mapping begun under theEaviromaeotal Studies Revolving Fund isexpanded to corer areas that are oow ioade-quately mapped;
the native food fishery aod resource harvestingactivity are iocluded within this mapping. withnative people involved in acquiring nod developing this information;
arrangements are ia place to ensure thatsens itivi ty mapping is maintained and updatedjointly by the British Colombia Ministry ofEnvironment, Environment Canada, theDepartment of Fisheries aod Oceans andindustry; and
70 Oil Blowout Contingency Planning and Countermeasures
4. the Heritage Conservation Branch of theGovernment of Brit ish Colombia completes aninventory of arcbaeoiogical and cultural sitesvulnerable to oil and ensures tbat measureS toprotect these sites from inappropriate cleanupprocedures are included in contingency plans.
ORGANIZATION
Effective implementation of a contingency plan requires awell trained response team. This is particularly true if theteam includes several government agencies, local com-munities, contractors and operators, as would be the caseon the west coast.
Under present arrangements, the polluter has initialresponsibility for cleanup of an oil spill. If the polluter isunable to clean up B spil l, government agencies may stepin to complete the cleanup and bill the polluter for thecosts.
Several agencies are responsibile for responding to oilspi lls on the west coast. The Canadian Coast Guard hasprimary responsibility for spills from ships. EnvironmentCanada is the lead agency for spi lls from land into marinewaters and mystery spills. The Provincia l EmergencyProgram of the British Columbia Ministry of Environ-ment deals with spills on land and spills into fresh waters.The Canada O il and Gas Lands Administration is thelead agency for spill s from offshore drilling operations,including oil blowouts.
The present system for responding to spil ls on the westcoast, involving the Canadian Coast Guard, EnvironmentCanada and the Provincial Emergency Program, has
evolved over several years. It is utilized frequently in themany minor accidents that occur in British Columbiawaters every year. The Panel believes that this systemshould be the basis for a government oil blowout responseoo the west coast. Given i ts responsibi lity for the morecornmoo offshore spi lls, the Caoadian Coast Guardshould also be the lead ageacy for responding to oil spil lsresulting from blowouts. The Canada Oi l and Gas LandsAdministration and the British Columbia Ministry ofEnergy, Mines and Petroleum Resources should be thelead agencies for rig-related actions necessary to cootrola blowout.
The Panel recommends that, in the event of ablowout,
1. the Canadian Coast Guard coordinate govern-ment involvement in responses to an oil sp illresulting from a blowout; and
2. .‘t& Canada Oi l and Gas Lands Admiai&atioaand the British Columbia Ministry of Energy,Min.& and Petroleum Resources coordinate
government responsibilities ‘for. rig-relatedactions to control blowouts.
Typically, residents volunteer to help clean up shorelinesin an area where slicks come ashore. The participation oflocal residents would be valuable given their knowledge of
local environmental conditions and especially of subsist-ence food resources. The Panel believes that localresidents, who have P large economic and social stake inthe protection of marine resources, should be included incleanup planning. To enable these residents to participatesafely and effectively in a blowout response, they shouldbe trained for their roles.
Tbe Panel recommends that the regulatory author-ity ensure tbe establishment of programs to train,orgaaize and equip local residents for participationin oil spill countermeasures and cleanup.
“I wonder if i f isn’t more reasonable to
make the people in the area w here the oil
might spil l . awm e of what has to be done
and in (1 minimal way coordinate a type
of emergen cy response capabil ity that
would be there if anything did go wrong.”
(Kevin O’Neil l, Central Coa st Fisher-
men’s Protective Association. Be//a
Coola. September 1985)
PREPARATION AND UPDATING
Although practice exercises can identify weaknesses in acontingency plan, a plan is only properly tested in anemergency situation. A “paper plan” may be rendereduseless by unforeseen problems such as adverse weather,logistical constraints, or human error. To prepare forthese unforeseen factors, contingency plans must bethorough, detailed, flexible, and real istic. Adequateresources must also be available at all times to carry outthese plans.
Because good logis tical support is vital to the effectivenessof contingency plans, these plans should provide detai ls onhow this support is to be mobilized and maintained.Equipment for countermeasures, cleanup and logistica lsupport should be catalogued, along with its location and
how quickly it can be mobilized. Detailed arrangementsshould be made for field headquarter facil ities, accommo-dation and catering, communication systems, and air andwater transportation. Advance arrangements are particu-larly important on the west coast due to the remoteness ofthe region, limited transportation facil ities, and the highincidence of fog and poor vnhdlty.
Oil Blowout Contingency Planning and Countermeasures 71
Once a contingency plan is prepared and tested, it mustbe kept current. A plan which contains outdated informa-tion is no longer functional. The location and availabilityof countermeasure equipment, air and sea transportationservices, accommodation facilities, communication
systems and key personnel must be checked and updated
frequently.
The Pa&i recommends tlmt, before ex&r&ydri lli ig ie approved, the regulatory authority ensurethat arrangements we in pli<e to r&gularly test andevaluate operator end government ~cootiageacypleas.
TRAINING AND EXERCISES
Company and government personnel m”st receiveadequate training for their ass igned roles in a blowoutresponse. Training programs should take place jointlybetween industry and government so participants meetface to face with their counterparts in a setting conduc iveto cooperative effort. Local residents with major roles in aresponse must be included. Training programs areavailable, such as those sponsored by Transport Canadaat Cornwall, Ontario, that review Canadian spill situa-tions and responses.
Frequent oil spill training exercises in which responseoperations are practised are important for ensuringequipment deployment plans function properly, equip-ment is serviceable and logistical support is adequate.They are also important for ensuring that the responseteam is well organ&d and ready. Exercises shouldinvolve all phases of an oil spill response including thespill reporting and notifications systems, logistics and
cleanup equipment mobiliza tion.
Exercises should be held in realistic conditions, andshould not necessarily be scheduled on a weekday orduring good weather in summer. They should test theabilit y of the operator and government to initiate counter-mea~um on short notice.
To be effective for testing and training, exercises shouldbe conducted with all participants, including governmentpersonnel, actively involved rather than observing. Afterthe exercise, participants should be debriefed and contin-gency plans rewritten where necessary.
The Panel recommends that tde &&tory autbor-ity ensute that et Ieeet one full scak, oil blow?utresponsq practice exercise b ear&d out during tkeiaitiel exploration period,, end if en, e3eodedexploration program tekes place, that et kast oneexe+i$&&ed out each yeer.
COUNTERMEASURE OPERATIONS
Countermeasures are procedures and technolog iesavailable to respond to spills. These include measures fortracking slic k movements, containing and recoveringslicks , dispersing s licks, and cleaning up shorelines. These
measures vary in effectiveness.
TRACKING AND MODELLING OF OIL SLICKMOVEMENTS
Information on the actual location of sli cks and theirprobable movement is needed so that countermeasurescan be deployed where they will protect the highestpribrity resources. This information can cane fromtracking and modelling.
Tracking
Various methods have been devised for tracking themovement of slicks . Aircraft are normally used once ortwice a day to observe their location. This i s effective onlyduring daylight and periods of good visibility .
Radio-transmitting buoys or drifters, which drift with theslic k and report their location, are also used. These buoysare helpful in most weather conditions, but are effectiveonly over certain ranges.
Remote sensing technology can also be used. Equipmentavailable in Canada for operation from aircraft includeshighly sophisticated equipment such as side-lookingairborne radar, infrared/ultraviolet scanners and low-lightlevel television. Adverse weather conditions and darkness
could interfere with the remote sensing capabilities ofsome of this equipment.
The Panel concludes that existing technology and on-going research should provide an ever-improving capabil-ity to track the location of slicks. However, it is impor-tant that the types and quantities of equipment needed bereadily available at the time drilling begins.
Tke PewI recommends that, before exploratorydril ling is approved, the regulatory outkorityrequire operators to provide detailed description%?Of:
.,
1. the monitoring and survei llance procedures nodequipment that would be used to monitor thelocation of sl icks from a blowout;
2. tbe location nod availabili ty of equipment andhow it would be deployed; and
72 Oil Blowout Con tingency Planning and Coun termeasu res
3. the adeqoacy of these procedures and equip.meat for use ia tracking slick s from a blowoutat the specific d rilling site.
Trajectory Models
Oil spill trajectory models are computerized simulationsof the behaviour of oil from a blowout or a spi ll site. Theyattempt to predict the movement, spread and condition ofthe oil at various times as it moves over the sea. In orderto do this with confidence, knowledge of the type of oiland amount being ejected at the spill site, along with dataon winds, currents , sea state and sea and air temperaturesalong the spill trajectory is needed. Such models are usedfor two purposes, contingency planning and tracking o ilslick s on the sea from a blowout or a spill.
The Canada Oil and Gas Lands Administration requirescontingency plans to contain a prediction of where oilmight go from a hypothetica l blowout at a drilli ng site.Predicted tracks and destinations, computed at intervalsthroughout a year, are used to assess risks to vulnerablemarine resources both in and on the sea and at coastlines.For these predictions, historical climate records of windsare custom arily used, and at times are supplemented byavailable surface current data.
Technical experts and the Department of Fisheries andOceans believed that this use of trajectory modelling wasuseful for contingency planning but stressed that surfacecurrents must be considered along with winds in comput-ing trajectories. The Department of Fisheries and Oceanssuggested at least one year’s data on surface currents inthe vicinity of a proposed drilling location is needed.While the Panel does not accept the overall u tility of
trajectory models as a key element of tracking oil spills,it does accept their usefulness in cootiogency planning.The Panel believes present information oo surfacecurrents in the regioo to be inadequate.
The Panel recommeods tlmt a; least one year beforeexplora tory drilling beglao, the Dep+tment ofFisberles aud Oceam, in cooperation with industry.implemeut a swfoce current measuriog program inthe region of the drilling site, end that iodos tryiuclude sur face current effects for the purpose ofdeveloping coatiogewy plans.
A trajectory model is theoretically a very useful tool in oil
spill countermeasure operations. Models would allowsome predictions of the likely track of oil during darknessand inclement weather. However, any model is limited bythe quality and ava ilabil ity of input data.
Technical experts as well as interveners with modellingexperience were skeptical about the usefulness of modelsduring countermeasures operations, not only because of
the difficu lty of measuring winds at sea and surfacecurrents , but because of the apparent inab ility of avai l-able models to simulate complex and variable physicalpKX.SXS.
Descriptions of the complexities of surface currents in this
region emphasized the fundamental difficu lty of definingoil s lick patterns on the sea as time progresses.
The Panel believes that oil spill trajectory models are nota promising tool for trackiug the movement of oil slicksfrom a blowout on the north coast. Instead, primaryreliance should be placed oo radio-located tracking buoysdeposited at the blowout site aod wherever sli cks aresubsequently found.
The Panel recommeods that during oil spill cooo-termeasure operations, emphasis be placed oo theuse of radio-located tracking buoys as seosors toprovide position updates for oil slic k tracking.
EFFECTIVENESS OF COUNTERMEASURES
The abilit y to minim& damage from an oil blowoutdepends on the effectiveness of the countermeasures usedfor containing and dispersing slicks , and for the cleanupof shorelines. The Panel received information indicatingthat existing countermeasures would have limitedeffectiveness on the west coast.
Contaiuing and Recovering O il Slic ks
The containment, concentration and removal of oil slick sby mechanical means such as booms and skimmers is
obviously the preferred method of handling an oil slickbecause the oil is removed from the sea. Chevron,Environment Canada and the Canadian Coast Guard,however, indicated that the abilit y to do this with presentcontainment and recovery technologies is limited.
“We wouldn’t work in (I sea SUM inexcess of four feel because first we haveto consider rhe saJety of our workers. I’mtalking about attempting to do physicalrecovery. We wouldn’r be able to hold ourbooms in position We don’t work inthe dark. The safety OJ our workerscomes first So offshore recoverywould be limited to working under verygood weather conditions.” (Ian Young,Canadian Coast Guard. Vancouver,November 1985)
Oil Blowout Contingency Planning and Countermeasures 13
Containment boom
Booms and skimmers function only in relatively calm seasand become less effective as wave heights and currentspeeds increase. In addition, the drifting and spreading ofoil as it moves from a blowout site make slick s moredifficult to recover over time. Operational problems alsoresult from fog and darkness, and there are logis ticalproblems in getting equipment in place and in disposingof recovered oil. Equipment is subject to maintenance andother problems, and the effectiveness of equipmentdiminishes as the oil is weathered and becomes more
viscous or emulsified. In their blowout scenarios, govern-ment agencies projected recovery efficiencies at less thanIO percent for oil recovery operations near a blowout.
Although containment and recovery measures alone areof limited effectiveness, they are useful when combinedwith other countermeasures, and in spec ific situations. Asa result. they are an important element in the overa llcontingency plan. The contingency plan should includeprojected equipment and manpower needs for contain-ment and recovery measures for the offshore, nearshore,intertidal and shore zones as well as a general strategy fordeploying these countermeasures.
The Canadian Coast Guard has the lead role in respond-ing to shipping spills. Given the environmental sensitivityof the west coast and the tanker traffic off theroast, thePanel was surprised to learn that the offshore oil spillcountermeasure capab ility of the Canadian Coast Guard
is almost non-ex istent. The Canadian Coast Guard statedit does not currently possess an effective offshore spillresponse capab ility and would encounter significantdifficulties in dealing with oil coming ashore over a broadfront. The Panel concludes that resources of theCanadian Coast Guard for implementing countermeas-
ures must be upgraded.
Tbe Panel r&o& &ns; : th;t before exploratorydrilling is .,8pprov,ed, the Caoadiaa Coast Guardupgrade its resources for responding effectively tooffshore oil spills, including trained personnel,modern equipment, depots, communications sys -tems, and the logis tical capab ility to deploy theseresources quickly.
Using Dispersants to Disperse Oil Slick s
Dispersants are chemicals that physically convert oilslick s to small droplets, which disperse into the watercolumn. Oi l is thereby removed from the surface and theinfluence of winds. This may be advantageous if onshorewinds are blowing. Dispersants work best in moreturbulent seas and are, therefore, an alternative when thesea is too rough for containment and recoveryoperations.The principal concerns associated withdispersants are their tox icity and effectiveness.
It is genera lly agreed that the toxic ity of many of therecently developed dispersants is low for most marine life.However, dispersants would considerably increase theconcentrations of oil in the water column, and there isconcern that this dispersed oil could reach toxic concen-trations for certain important marine species such assalmon and herring.
A second question is whether dispersants reduce thedamage potential of a slic k. Chevron stated that disper-sants are effective in removing the oil from the surfacewithout producing toxic concentrations of oil in the watercolumn. Environment Canada, however. stated that thetested effectiveness of dispersants varied from 0 to 100percent, depending on oil types and prevailing seaconditions. Effectiveness also depends on the specificagents to be applied, the application techniques used, thesea conditions at the time of application, and the logis ticsof the operation. Al l these factors must be consideredcarefully in contingency plans. In addition, because ofconcerns that dispersants may cause toxic concentrationsof oil in the water column, agencies such as the Depart-ment of Fisheries and Oceans, Environment Canada andthe British Columbia Ministry of Environment may bereluctant to permit their use. For these reasons, the roleof dispersants in contingency plans is in question.
74 Oil Blowout Contingency Planning and Countermeasures
“Can oil spil ls be cleaned up? Again. it
comes to a quest ion of performance, and
we have some real information here. Only
about IO to 20 percent of the oil is actu-
ally recovered from a spil l situation. I
can provide you wi th home references on
that, i f necessary, and as much (IS 60
percent of the l ight oil, howe ver, may
evoporote from that particular spil l .”
(J im Steele. Counci l of the Haida Nation.
Victoria, October 1985)
The Panel recommeods, before exploratory dril lingbegins, that:
1.
2.
Environment Canada and the Brit ish ColumbiaMinistry of Environment clarify the eircum-stances under which their respective govern-ments would permit or prohibit tbe use ofdispersants, sad ia cooperation with iodustry,develop a strategy for the use of dispersnats ifthese are not prohibited; and
operators iocorporate this dispenant strategyinto their cootiogency plans.
Cleaning Up Shorelines
Should a blowout occur, oil might come ashore. Changingwinds and currents which could x-oil shorelines may alsobe anticipated. Due to the soc ial and environmentalsensitivities of British Columbia’s coastal resources, it isimportant that the operator demonstrate an adequatecapability to mitigate the effects of oil on shorelines.
Shoreline cleanup usua lly involves manual methods thatcan continue for months following the initia l accident. Inaddition, both oil and debris would have to be contained,mechanically removed, transferred, stored and disposedof. Attempts to intercept slick s may be ineffective as theymove shoreward over relatively broad fronts. The Panelbelieves that to facilitate effective, well planned shorelinecleanup operations, strategies should be detailed iocontiogeocy plans.
The Panel recommends that, before exploratorydrilling is approved, operators include specilicstrategies in their cootingency plats, for cleaningup shorelines that are vulnerable to oil from a
blowout at a proposed drilling site, including detailsoo the types, and availabil ity of equipment thatwould be ww$ manpower requirements, trainingprovisioos, operational logistics and guidelines forekaniag up individual shoreline areas.
APPLYING EXPERIMENTALCOUNTERMEASURES
Considerable research has been underway worldwide.especially over the past decade, to develop newapproaches for controlling and removing oil slicks . Forexample, there are new methods of applying chemicaldispersants, new mechanical containment and recoverysystems, in-situ combustion of oil using laser beams, air-deployable igniters, fire-resistant booms, gelling agents(coagulants), subsea containment devices, portableincinerators and burners and beach cleaners.
While some of these technologies arc almost ready for
commercial use, others are at a research or prototypestage. Advances are being made and important newcmmtermcasure technologies may become availableduring the exploration period. The development of thesenew technologies should be closely monitored andincluded in contingency plans as appropriate.
The Panel believes coagulants arc an especially promisingnew technology. Coagulants are chemicals that arcapplied to oil slick s to cause the oil to solidify. Coagulantscould be especially useful for protecting certain highpriority coastal sites. Coagulated oil would be easier toclean up in sensitive areas because it would be less likelyto penetrate sediments or harm biota. Some problems st ill
need to be resolved, such as the high cost of coagulantsand the logistics of their application. However, the Panelconcludes that the development of coagulants should beclosely monitored for possible ioclusion in contingencyplans.
