Oil Spill Response

www.oscreadiness.org

15th Annual OSC Readiness Training Program

Oil Spill Response

15th Annual OSC Readiness Training Program www.oscreadiness.org 2

Emergency Evacuation of Training Center

Be prepared in case of the need to immediately evacuate the training center

Instructors will lead the entire class to a pre-designated safe location

Classroom Courtesy

Turn off Blackberrys, iPhones, pagers, and/or other similar electronic equipment

Break schedule

Restrooms

Questions are encouraged

Introductions

Instructors Names Work experience

Participants Names Position/Region Work experience Course expectations

Course Overview

I. Gain an awareness of the environmental and human factors affecting cleanup decisions

II. Gain an awareness of the statutory and regulatory thresholds for response to Oil Spills

III. Identify the main tasks an OSC is responsible for during an oil spill response

IV. Gain an awareness of Oil Spill Response Techniques

V. Better Understand How to Dispose of Oil and Oily Debris

VI. Gain an awareness of certain supplemental topics involved with oil spill response, including natural resource trustees, safety, and use of volunteers

I. Factors Affecting Response and Cleanup Decisions

Environmental(continued)

Geology of the shoreline and rate of flow

Oil tends to stick to sediments and surfaces of cobbles and pebbles

Standing or slow-moving water is more likely to incur severe impacts that flowing water

Environmental

Source and type of oil spilled

Lighter oils tend to evaporateand degrade very quickly

Heavier oils tend to formthick oil-and-water mixturewhich clings to rocksand sand

Climate

Environmental(continued)

Type and sensitivity of biological communities likely to be affected

Physical properties Food chain Habitat

Industry

Need to keep production and cleanup activities from interfering with each other

Management of response operations

Organizational context and design and learning

Human(continued)

Political

Legal constraints

Multi-agency, multi-jurisdiction

Public opinion

Non-governmental interest groups

Human(continued)

Socio-economic

Amount spilled, spill location, and rate of spillage

Aesthetic appeal and amenity use of the shoreline and beaches

Primary and secondary economic impacts

II. Statutory and Regulatory Thresholds for Response to Oil Spills

Definitions

Oil [CWA § 311(a)(1) & NCP § 300.5]

Coastal Zone v. Inland Zone [NCP § 300.5]

Discharge [NCP § 300.5]

Reportable Quantity – Oil [40 CFR § 110.3]

Statutory and Regulatory Authority

Clean Water Act Section 311 (c)

Executive Order 12777

National Response Framework

National Oil and Hazardous Substances Pollution Contingency Plan Subparts B and D Appendix E to Subpart D

Decision to Initiate Action[CWA § 311(c)(1)]

General Removal Requirement:

Is the substance involved an oil?

Is there a discharge or substantial threat of a discharge?

Is the discharge or substantial threat of discharge into navigable waters or adjoining shorelines?

Are removal actions consistent with the NCP?

Summary of Waters of the U.S.

Traditional navigable waters

Wetlands adjacent to traditional navigable waters

Non-navigable tributaries of traditional navigable waters that are relatively permanent where the tributaries typically flow year-round or have continuous flow at least seasonally

Wetlands that directly abut such tributaries

Summary of Waters of the U.S.(continued)

The following waters based on a fact-specific analysis to determine whether they have a significant nexus with a traditional navigable water:

Non-navigable tributaries that are not relatively permanent

Wetlands adjacent to non-navigable tributaries that are not relatively permanent

Wetlands adjacent to but that do not directly abut a relatively permanent non-navigable tributary

Summary of Waters of the U.S.(continued)

The following features are not generally considered:

Swales or erosional features

Ditches excavated wholly in and draining only uplands and that do not carry a relatively permanent flow

Character of Discharge

Spills Of National SignificanceNCP § 300.3232

Worst Case DischargesNCP § 300.324

Discharge or Substantial ThreatNCP § 300.322

Oil Spill Liability Trust Fund

National Pollution Funds Center oversees and manages the OSTLF

Access:

If you answer Yes to both of these questions, then OSTLF applies:

Was there a discharge of oil, or a substantial threat of a discharge of oil, (i) into navigable waters ; (ii) onto adjoining shorelines; (iii) into the waters of the economic exclusive zone; or (iv) it may affect natural resources under the exclusive management authority of the US?

Are further actions necessary to ensure effective and immediate removal, mitigation, or prevention of the substantial threat?

Use Ceiling and Number Assignment Processing System (CANAPs) a Federal Project Number (FPN) and initial ceiling amount.

Oil Spill Liability Trust Fund(continued)

Limitations

The pollutant must be oil

Removal funding comes from the Emergency Fund subset of the OSLTF

A maximum of $500,000,000 per case is available to remediate natural resource damage assessments

A maximum of $1,000,000,000 is available to pay for certain costs and damages associated with oil spills

IV. Oil Spill Management

National Response Priorities[NCP § 300.317]

Safety of human life

Stabilize situation

Ensure timely effective response

General Pattern of Response [NCP § 300.320]

OSCs are responsible for directing response actions and coordinating all other efforts at the scene of a discharge or spill

OSCs work in partnership with other federal, state, local, and private response agencies, as well as Tribes

OSCs main tasks include assessment, determining response management framework, operational administration, monitoring, determining need for response assistance, determining when response is complete, and documenting and reporting

Phases of Response Four phases of response:

Discovery or Notification [NCP § 300.300] Preliminary Assessment [NCP § 300.305] Containment, countermeasures, cleanup, and disposal [NCP §

300.310] Documentation and Cost Recovery [NCP § 300.315]

In addition to running the incident, FOSC also has other significant responsibilities such as:

Keeping the EPA chain-of-command informed Coordinate efforts with other agencies and third parties [NCP

300.155(a)] Public Information and Community Relations [NCP § 300.155(b)] Worker Health and Safety [NCP § 300.150, .185(c), .317]

Assessment

Evaluate the size and nature of spill and potential hazards [NCP § 300.305 & § 300.320]

Determine the need for personnel, equipment, and other resources to promptly and effectively respond to the spill

Response Management Framework

NRF mandates the use of ICS for responses to all hazards including response to oil spills.

Establishing an effective response management strategy early and using the ICS planning process is pivotal to a unified and effective response

Determine the framework for the response management structure [NCP § 300.305(c)]

Operational Administration

Identification of Potentially Responsible Party

Administrative Orders CWA § 311(c) CWA § 311(e)

Comparison of CWA § 311(c) and § 311(e)

Operational Administration(continued)

Notice of Federal Interest (NOFI)

Notice of Federal Assumption (NOFA)

Operational Administration(continued)

Access Private Public (administering agency)

Contracts START ERRS PRFAs

Monitoring

Monitor actions taken to control and cleanup a spill to make sure they are appropriate [NCP § 300.320(a)(2)(iii)]

Monitoring can be conducted from the Site when necessary, or from an agency if the situation appears to be under control

Response Assistance

Determine whether federal assistance will be necessary to help control and contain spill

If federal resources are required: Oil Spill Liability Trust Fund [NCP § 300.335] National & Regional Response Teams [NCP §

300.145] Special Forces/Teams [NCP § 300.145] Federal agencies [NCP § 300.175]

Response Assistance(continued)

State and local participation [NCP § 300.180]

Nongovernmental participation [NCP §300.185]

Public Information and Community Relations[NCP § 300.155(a)]

Ensure that all appropriate public and private are kept informed and that their concerns are considered throughout a response

Worker Health & Safety

Safety of human life is paramount during all response efforts at the scene of a discharge as well as the safety of all response personnel

FOSC primarily responsible for addressing worker health and safety at a response scene [NCP § 300.150 and 29 CFR 1910.120

FOSC shall restrict volunteers from on-scene operations if dangerous conditions exist [NCP § 300.185(c)]

Documentation & Reporting

Must document and report all activities that take place during and after a spill [§ 300.315]

POLREPS/SITREPS [§ 300.135(m)]

Federal Cleanup Standard Discharges of oil that:

Violate applicable water quality standards

Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines

Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines

Cleanup Endpoints

Cleanup endpoints can be:

Qualitative which are based primarily on visual, olfactory, or tactile observations and do not necessarily require collection of analytical chemistry data

Quantitative which rely on measurements or quantitative data, as opposed to qualitative data such as categorical observations (e.g., sheen or no sheen)

Examples ofQualitative Cleanup Endpoints

There is no longer any detectable oil present on the water, adjoining shorelines, or places where it is likely to reach the water again

Oil visible but no more than background

Oil no longer releases thick rainbow sheen that will affect wildlife, sensitive areas, or human health

Further removal operations would cause more environmental harm than the oil to be removed

Cleanup measures would be excessively costly in view of their insignificant contribution to minimizing a threat to the public health or welfare, or the environment

Examples of Quantitative Cleanup Endpoints

Oil on surface water, groundwater, soil, or sediment does not exceed background concentrations for the constituents or compounds of concern

Oil on surface water, groundwater, soil, or sediment does not exceed predetermined concentrations for the constituents or compounds of concern

Issues Affecting the Selection Of Endpoints

Type and amount of oil spilled

Type of shoreline

Value of habitat or use of the segment and the timing of that use

Technical and operational feasibility

Anticipated rate of natural attenuation

Environmental influences such as weather

Practical Considerations for Achieving Cleanup

Type and amount of oil spilled

Environmental sensitivities

Consultation

Widely varying cleanup standards

Practical Considerations for Achieving Cleanup(continued)

Long-term deployment of absorbent materials

Not all spilled oil will be recovered

Weather

Natural attenuation

Perceptions of Risk Question is more than a technical or logistical issue:

potentially has profound social and political dimensions

Perceptions of risk can vary depending on whether risk is:

Familiar v. unfamiliar

Visibility of threat

Catastrophic v. non-catastrophic

Character of affected resource

Equal v. unequal affects

How clean is safe?

How and to what extent might people be exposed

Assessment of effects associated

with exposure

RiskCharacterization

Streamlined Risk Evaluation

SocialFactors

Risk ManagementDecision

Statutory and legalConsiderations

Environmental and Public Health

Considerations

RiskManagement

Options

EconomicFactors

PoliticalConsiderations

Risk Management

Practical Considerations for Determining When the Cleanup is Complete When Not All Spilled Oil is Recoverable

Technical and operational feasibility of investigation and cleanup

Is there a balance between cost in relation to the added degree of protection or reduction of risk afforded by additional cleanup?

Is there a state or other entity that has the capability to assume responsibility for the cleanup action?

Anticipated rate of natural removal processes

Practical Considerations for Determining When the Cleanup is Complete When Not All Spilled Oil is Recoverable

(continued)

Institutional constraints/pressures

Is the remaining oil likely to damage environmentally sensitive resources?

Does it interfere with the aesthetic appeal and amenity use of the shoreline?

Is the oil detrimental to economic resources or disrupting economic activities?

IV. Oil Spill Response Techniques

EVAPORATION

SPREADING

EMULSIFICATION

SEDIMENTATION

BIODEGRADATION

SPREADING

DISSOLUTION

OXIDATION

DISPERSION

Cleanup Processes and Methods Natural Processes

Cleanup Processes and Methods(continued)

Physical Methods Wiping with absorbent materials Flushing or pressure washing Raking or bulldozing

Mechanical Containment and Recovery of Oil Following a Spill

Containment: Used to restrict the spread of oil and allow for its recovery, removal, or dispersal Booms Dams Fences

Recovery: Once an oil spill has been contained, efforts to remove the oil from water can begin Booms Skimmers Sorbents

Containment

Booms Commercial Improvised

Dams Under flow Over flow

Fences

Commercial Booms

Internal Flotation

Spring Loaded

Self Inflatable

Fire Boom

Shoreline Boom

Adsorbent

Commercial Booms(continued)

Internal Flotation

Spring Loaded

Self Inflatable

Fire Boom

Shoreline Boom

Adsorbent

Commercial Boom(continued)

Advantage Easy to deploy Quick Deployment Good design Reusable

Disadvantage Storage and

Transportation High winds, waves, fast

current Decontamination Costs Disposal issues

Improvised Boom

Plastic Sheeting & fire hose Telephone Poles

Improvised Boom(continued)

Advantage On site No special training for

deployment No special equipment

Disadvantage Decon issues Waste disposal

issues Temporary in nature

Functions of Boom

Protection Deflection Containment

Functions of Boom

Protection: Shoreline Creeks Wetlands Water intakes

Functions of Boom(continued)

Deflection:

Move oil from one side to the other side

Around an island or object

To a collection point

Functions of Boom

Containment:

Catch or hold oil for collection using various techniques

Under flow Weir

Quikrete dam

Under Flow Dams

Under Flow Dam Under Construction

Stand Pipes used to Regulate Level

Fixed Under Flow Dam

Weir Dams

Gate Valves

Lumber Dam

Straw Log Containment

Straw Bales

Straw Bales in Wire

Fences

Other Techniques

Gabion Snare Capture baskets

Screen capture

Recovery of Oil

Skimmers Portable Boats

Sorbent Materials

Portable Skimmers

Boat Skimmers

Sorbent Materials

Deployment Considerations

Access Natural collection points River speed

Alternative Countermeasures Chemical Dispersants

Biological Agents

In-situ Burning

Natural Attenuation

Response Options to Protect Wildlife Keep the oil away from

the resource

Keep the resource away from the oil

Capture and treat oiled wildlife

VI. Disposal of Oil and Oily Debris

What types of wastes are collected from response and cleanup activities?

From shoreline cleanup: Oiled debris, oiled solid materials such as sand, wood,

and vegetation, used personal protective equipment (PPE), disposal equipment

From oil containment and recovery operations: Oil and oily water, oiled debris and solid materials, oiled

sorbent materials, PPE

From vessel or other decontamination operations: Oily water, oiled sorbent materials, PPE

What must be done with wastes resulting from response and cleanup activities?

To the extent practicable, water is separated from the oil, treated and reused, or disposed at permitted facilities

Recovered oil is sent to facilities that recycle or reprocess the oil

Recovered oil that is not suitable for recycling or reprocessing may be disposed of at properly permitted facilities

Oil spill response and cleanup activities may generate small quantities of other wastes such as chemical and solvents and wildlife carcasses

Oil, oily solids, oiled debris, and other wastes must be handled in accordance with all relevant regulations of local/state/federal health and environmental agencies

Is oiled waste considered hazardous?

Petroleum products such as diesel generally do not designate as hazardous waste

If not designated as a hazardous waste they are classified and managed as solid waste

Knowledge of the material spilled can be used to classify all of the released material

Oily waste that cannot be recycled or reprocessed may need to be analyzed for hazardous characteristics before choosing a treatment or disposal option

Waste management “Rules of Thumb”

Waste generation and management begins when the first person shows up on-Site

Segregate wastes at source and label immediately to allow optimal reuse/recycle and disposal

Waste volumes and types will change during the life of a response; every effort should be made to reduce the amount of material for final disposal

VI. Supplemental Topics

Natural Resource Trustees

What is the OSC’s Role and Responsibilities regarding Natural Resource Trustees?

Notify trustees of incidents [§ 300.135(j)(1), 300.305(e), 300.320(a)(5)]

Consult trustees about protection priorities and methods [§ 300.135(j)(2)]

Share non-monetary response resources with trustees conducting Natural Resource Damage Assessment activities so along as this does not hinder response activities [§ 300.305(e) and 615(c)(3)(iii)]

Federal agencies assisting the OSC in response to an oil spill may be reimbursed [§ 300.335(b)]

Natural Resource Trustees(continued)

What are the Natural Resource Trustees Role and Responsibilities regarding the OSC?

Work with OSCs, who are required to coordinate all response activities with the affected natural resource trustees [§ 300.135(j)(2)]

Provide timely advice to the OSC on trustee resources that are potentially affected by a discharge of oil, including identifying/recommending preapproved response techniques [§ 300.305(e) and 615(c)(3)(i)]

Designate a lead administrative trustee to serve as the focal point for coordination between natural resource damage assessment activities and response operations [§ 300.305(e) and 615(c)(3)(ii)]

Who are the Natural Resource Trustees?

Federal - Secretaries of Agriculture, Commerce, Defense, Energy, Interior (§ 300.600)

State - designated by the Governor (§ 300.605)

Tribal - designated by Tribal Chairmen or the Secretary of the Interior may serve as trustee at request of the tribe (§ 300.610)

What are Natural Resources?

Natural resources include land, fish, wildlife, biota, air, water, ground water, drinking water supplies, and other such resources (NCP § 300.5)

Natural resources of concern are held in trust for the public

Trustee Activities in Emergency Response

Identify/prioritize resources at risk

Evaluate protective measures and cleanup strategies

Participate in post-cleanup inspection

Wildlife rehabilitation

Safety

Safety Marine and Shoreline Considerations:

Extremes of weather

Visibility and the ability to communicate

Workers are constantly at risk for getting wet through wave and splash action

Threat of clothing that is often cumbersome, restrictive, and prone to promote heat stress

Water can easily damage mechanical and electrical equipment essential for cleanup activities

Safety(continued)

Marine and Shoreline Considerations (continued):

Conducting work on a moving platform which complicates any movement or procedures

Slippery surfaces

Rough conditions may cause severe pounding and instability which promotes fatigue

An increased likelihood of falls or being struck by falling objects

Use of Volunteers

Volunteer defined [NCP § 300.5]

Nongovernmental participation in response operations [NCP § 300.185]

Use of Volunteers(continued)

Potential use of volunteers during an oil spill Wildlife rehabilitation

Shoreline cleanup support

Public relations & community support

Community liaison social services

Logistics

Transportation

Medical

Personnel support services

Use of Volunteers(continued)

Potential challenges associated with use of volunteers during an oil spill Liability Health & Safety

Congressional interest

Summary Statement

The purpose of this course is to provide an overview of oil emergency response operations.

There is no way to include all possible subjects, references, or guidance for something as complex as incident response in a single course; however it is hoped that this course will assist you when responding to discharges in the inland zone.

Questions?

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