Oil Spill Response. 15 th Annual OSC Readiness Training Program.
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1 Oil Spill Response 15 th Annual OSC Readiness Training Program
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 predesignated safe location 15 th Annual OSC Readiness Training Program 2
3 Classroom Courtesy Turn off Blackberrys, iphones, pagers, and/or other similar electronic equipment Break schedule Restrooms Questions are encouraged 15 th Annual OSC Readiness Training Program 3
4 Introductions Instructors Names Work experience Participants Names Position/Region Work experience Course expectations 15 th Annual OSC Readiness Training Program 4
5 Course Overview I. Gain an awareness of the environmental and human factors affecting cleanup decisions II. III. IV. Gain an awareness of the statutory and regulatory thresholds for response to Oil Spills Identify the main tasks an OSC is responsible for during an oil spill response 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 15 th Annual OSC Readiness Training Program 5
6 I. Factors Affecting Response and Cleanup Decisions 15 th Annual OSC Readiness Training Program 6
7 Environmental Source and type of oil spilled Lighter oils tend to evaporate and degrade very quickly Heavier oils tend to form thick oil-and-water mixture which clings to rocks and sand Climate 15 th Annual OSC Readiness Training Program 7
8 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 15 th Annual OSC Readiness Training Program 8
9 Environmental (continued) Type and sensitivity of biological communities likely to be affected Physical properties Food chain Habitat 15 th Annual OSC Readiness Training Program 9
10 Human Industry Need to keep production and cleanup activities from interfering with each other Management of response operations Organizational context and design and learning Cost 15 th Annual OSC Readiness Training Program 10
11 Human (continued) Political Legal constraints Multi-agency, multi-jurisdiction Public opinion Non-governmental interest groups 15 th Annual OSC Readiness Training Program 11
12 Socio-economic Human (continued) Amount spilled, spill location, and rate of spillage Aesthetic appeal and amenity use of the shoreline and beaches Media Primary and secondary economic impacts 15 th Annual OSC Readiness Training Program 12
13 Questions? 15 th Annual OSC Readiness Training Program 13
14 II. Statutory and Regulatory Thresholds for Response to Oil Spills 15 th Annual OSC Readiness Training Program 14
15 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] 15 th Annual OSC Readiness Training Program 15
16 Statutory and Regulatory Authority Clean Water Act Section 311 (c) Executive Order National Response Framework National Oil and Hazardous Substances Pollution Contingency Plan Subparts B and D Appendix E to Subpart D 15 th Annual OSC Readiness Training Program 16
17 Decision to Initiate Action Federal Removal Authority: Is the substance involved an oil? [CWA 311(a)(1)] Is there a discharge or substantial threat of a discharge? [CWA 311(c)(1)] Is the discharge or substantial threat of discharge into navigable waters or adjoining shorelines? [CWA 311(c)(1)] Are removal actions consistent with the NCP? [CWA 311(c)(3)]: 15 th Annual OSC Readiness Training Program 17
18 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 15 th Annual OSC Readiness Training Program 18
19 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 nonnavigable tributaries that are not relatively permanent Wetlands adjacent to but that do not directly abut a relatively permanent non-navigable tributary 15 th Annual OSC Readiness Training Program 19
20 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 15 th Annual OSC Readiness Training Program 20
21 Character of Discharge Discharge or Substantial Threat NCP Worst Case Discharges NCP Spills Of National Significance NCP th Annual OSC Readiness Training Program 21
22 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. 15 th Annual OSC Readiness Training Program 22
23 Limitations Oil Spill Liability Trust Fund (continued) 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 15 th Annual OSC Readiness Training Program 23
24 Questions? 15 th Annual OSC Readiness Training Program 24
25 IV. Oil Spill Management 15 th Annual OSC Readiness Training Program 25
26 National Response Priorities [NCP ] Safety of human life Stabilize situation Ensure timely effective response 15 th Annual OSC Readiness Training Program 26
27 General Pattern of Response [NCP ] 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 15 th Annual OSC Readiness Training Program 27
28 Phases of Response Four phases of response: Discovery or Notification [NCP ] Preliminary Assessment [NCP ] Containment, countermeasures, cleanup, and disposal [NCP ] Documentation and Cost Recovery [NCP ] 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 (a)] Public Information and Community Relations [NCP (b)] Worker Health and Safety [NCP ,.185(c),.317] 15 th Annual OSC Readiness Training Program 28
29 Assessment Evaluate the size and nature of spill and potential hazards [NCP & ] Determine the need for personnel, equipment, and other resources to promptly and effectively respond to the spill 15 th Annual OSC Readiness Training Program 29
30 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 (c)] 15 th Annual OSC Readiness Training Program 30
31 Operational Administration Identification of Potentially Responsible Party Administrative Orders CWA 311(c) CWA 311(e) 15 th Annual OSC Readiness Training Program 31
32 Comparison of CWA 311(c) and 311(e) 15 th Annual OSC Readiness Training Program 15 th Annual OSC Readiness Training Program 32
33 Operational Administration (continued) Notice of Federal Interest (NOFI) Notice of Federal Assumption (NOFA) 15 th Annual OSC Readiness Training Program 33
34 Operational Administration (continued) Access Private Public (administering agency) Contracts START ERRS PRFAs 15 th Annual OSC Readiness Training Program 34
35 Monitoring Monitor actions taken to control and cleanup a spill to make sure they are appropriate [NCP (a)(2)(iii)] Monitoring can be conducted from the Site when necessary, or from an agency if the situation appears to be under control 15 th Annual OSC Readiness Training Program 35
36 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 ] National & Regional Response Teams [NCP ] Special Forces/Teams [NCP ] Federal agencies [NCP ] 15 th Annual OSC Readiness Training Program 36
37 Response Assistance (continued) State and local participation [NCP ] Nongovernmental participation [NCP ] 15 th Annual OSC Readiness Training Program 37
38 Public Information and Community Relations [NCP (a)] Ensure that all appropriate public and private are kept informed and that their concerns are considered throughout a response 15 th Annual OSC Readiness Training Program 38
39 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 and 29 CFR ] FOSC shall restrict volunteers from on-scene operations if dangerous conditions exist [NCP (c)] 15 th Annual OSC Readiness Training Program 39
40 Documentation & Reporting Must document and report all activities that take place during and after a spill [ ] POLREPS/SITREPS [ (m)] 15 th Annual OSC Readiness Training Program 40
41 Federal Cleanup Standard Discharges of oil that: Violate applicable water quality standards or Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines 15 th Annual OSC Readiness Training Program 41
42 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) 15 th Annual OSC Readiness Training Program 42
43 Examples of Qualitative 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 15 th Annual OSC Readiness Training Program 43
44 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 15 th Annual OSC Readiness Training Program 44
45 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 of cleanup activities Anticipated rate of natural attenuation Environmental influences such as weather Perceptions of risk 15 th Annual OSC Readiness Training Program 45
46 Risk Management Streamlined Risk Evaluation How and to what extent might people and biota be exposed Risk Management Environmental & Public Health Considerations Statutory and legal Considerations Social Factors Background Concentration Risk Characterization Risk Management Decision Economic Factors Assessment of effects associated with exposure Risk Management Options Political Considerations th Annual OSC Readiness Training Program 46
47 Practical Considerations for Achieving Cleanup Type and amount of oil spilled Environmental sensitivities Consultation Widely varying cleanup standards 15 th Annual OSC Readiness Training Program 47
48 Practical Considerations for Achieving Cleanup (continued) Long-term deployment of absorbent materials Not all spilled oil will be recovered Weather Natural attenuation 15 th Annual OSC Readiness Training Program 48
49 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 15 th Annual OSC Readiness Training Program 49
50 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? 15 th Annual OSC Readiness Training Program 50
51 Questions? 15 th Annual OSC Readiness Training Program 51
52 IV. Oil Spill Response Techniques 15 th Annual OSC Readiness Training Program 52
53 Cleanup Processes and Methods Natural Processes EVAPORATION SPREADING OXIDATION SPREADING EMULSIFICATION DISSOLUTION BIODEGRADATION DISPERSION SEDIMENTATION 15 th Annual OSC Readiness Training Program 15 th Annual OSC Readiness Training Program 53
54 Cleanup Processes and Methods (continued) Physical Methods Wiping with absorbent materials Flushing or pressure washing Raking or bulldozing 15 th Annual OSC Readiness Training Program 54
55 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 15 th Annual OSC Readiness Training Program 55
56 Containment Booms Commercial Improvised Dams Under flow Over flow Fences 15 th Annual OSC Readiness Training Program 56
57 Commercial Booms Internal Flotation Spring Loaded Self Inflatable Fire Boom Shoreline Boom Adsorbent 15 th Annual OSC Readiness Training Program 57
58 Commercial Booms (continued) Internal Flotation 15 th Annual OSC Readiness Training Program 58
59 Commercial Booms (continued) Spring Loaded 15 th Annual OSC Readiness Training Program 59
60 Self Inflatable Commercial Booms (continued) 15 th Annual OSC Readiness Training Program 60
61 Commercial Booms (continued) Fire Boom 15 th Annual OSC Readiness Training Program 61
62 Shoreline Boom Commercial Booms (continued) 15 th Annual OSC Readiness Training Program 62
63 Adsorbent Commercial Booms (continued) 15 th Annual OSC Readiness Training Program 63
64 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 15 th Annual OSC Readiness Training Program 64
65 Improvised Boom Plastic Sheeting & fire hose Telephone Poles 15 th Annual OSC Readiness Training Program 65
66 Improvised Boom (continued) Advantage On site No special training for deployment No special equipment Disadvantage Decon issues Waste disposal issues Temporary in nature 15 th Annual OSC Readiness Training Program 66
67 Protection Deflection Containment Functions of Boom 15 th Annual OSC Readiness Training Program 67
68 Functions of Boom Protection: Shoreline Creeks Wetlands Water intakes 15 th Annual OSC Readiness Training Program 68
69 Deflection: Functions of Boom (continued) Move oil from one side to the other side Around an island or object To a collection point 15 th Annual OSC Readiness Training Program 69
70 Functions of Boom Containment: Catch or hold oil for collection using various techniques 15 th Annual OSC Readiness Training Program 70
71 Dams Under flow Weir 15 th Annual OSC Readiness Training Program 71
72 Quikrete dam 15 th Annual OSC Readiness Training Program 72
73 Under Flow Dams 15 th Annual OSC Readiness Training Program 73
74 Under Flow Dam Under Construction 15 th Annual OSC Readiness Training Program 74
75 Stand Pipes used to Regulate Level 15 th Annual OSC Readiness Training Program 75
76 Fixed Under Flow Dam 15 th Annual OSC Readiness Training Program 76
77 Weir Dams 15 th Annual OSC Readiness Training Program 77
78 Gate Valves 15 th Annual OSC Readiness Training Program 78
79 Weir 15 th Annual OSC Readiness Training Program 79
80 Lumber Dam 15 th Annual OSC Readiness Training Program 80
81 Straw Log Containment 15 th Annual OSC Readiness Training Program 81
82 Straw Bales 15 th Annual OSC Readiness Training Program 82
83 Straw Bales in Wire 15 th Annual OSC Readiness Training Program 83
84 Fences 15 th Annual OSC Readiness Training Program 84
85 Other Techniques Gabion Snare Capture baskets Screen capture 15 th Annual OSC Readiness Training Program 85
86 Recovery of Oil Skimmers Portable Boats Sorbent Materials 15 th Annual OSC Readiness Training Program 86
87 Portable Skimmers 15 th Annual OSC Readiness Training Program 87
88 Boat Skimmers 15 th Annual OSC Readiness Training Program 88
89 Sorbent Materials 15 th Annual OSC Readiness Training Program 89
90 Deployment Considerations Access Natural collection points River speed 15 th Annual OSC Readiness Training Program 90
91 Alternative Countermeasures Chemical Dispersants Biological Agents In-situ Burning Natural Attenuation 15 th Annual OSC Readiness Training Program 91
92 Response Options to Protect Wildlife Keep the oil away from the resource Keep the resource away from the oil Capture and treat oiled wildlife 15 th Annual OSC Readiness Training Program 92
93 Questions? 15 th Annual OSC Readiness Training Program 93
94 VI. Disposal of Oil and Oily Debris 15 th Annual OSC Readiness Training Program 94
95 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 15 th Annual OSC Readiness Training Program 95
96 15 th Annual OSC Readiness Training Program 96
97 15 th Annual OSC Readiness Training Program 97
98 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 15 th Annual OSC Readiness Training Program 98
99 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 15 th Annual OSC Readiness Training Program 99
100 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 15 th Annual OSC Readiness Training Program 100
101 Questions? 15 th Annual OSC Readiness Training Program 101
102 VI. Supplemental Topics 15 th Annual OSC Readiness Training Program 102
103 Natural Resource Trustees 15 th Annual OSC Readiness Training Program 103
104 Natural Resource Trustees What is the OSC s Role and Responsibilities regarding Natural Resource Trustees? Notify trustees of incidents [ (j)(1), (e), (a)(5)] Consult trustees about protection priorities and methods [ (j)(2)] Share non-monetary response resources with trustees conducting Natural Resource Damage Assessment activities so along as this does not hinder response activities [ (e) and 615(c)(3)(iii)] Federal agencies assisting the OSC in response to an oil spill may be reimbursed [ (b)] 15 th Annual OSC Readiness Training Program 104
105 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 [ (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 [ (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 [ (e) and 615(c)(3)(ii)] 15 th Annual OSC Readiness Training Program 105
106 Natural Resource Trustees (continued) Who are the Natural Resource Trustees? Federal - Secretaries of Agriculture, Commerce, Defense, Energy, Interior ( ) th Annual OSC Readiness Training Program 106
107 Natural Resource Trustees (continued) Who are the Natural Resource Trustees? State - designated by the Governor ( ) th Annual OSC Readiness Training Program 107
108 Natural Resource Trustees (continued) Who are the Natural Resource Trustees? Tribal - designated by Tribal Chairmen or the Secretary of the Interior may serve as trustee at request of the tribe ( ) th Annual OSC Readiness Training Program 108
109 Natural Resource Trustees (continued) 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 15 th Annual OSC Readiness Training Program 109
110 Trustee Activities in Emergency Response Identify/prioritize resources at risk Evaluate protective measures and cleanup strategies Participate in post-cleanup inspection Wildlife rehabilitation th Annual OSC Readiness Training Program 110
111 Trustee Participation in ICS/UC in Support of Response Command Logistics Operations Finance/Administration Planning 15 th Annual OSC Readiness Training Program 111
112 Safety 15 th Annual OSC Readiness Training Program 112
113 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 15 th Annual OSC Readiness Training Program 113
114 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 15 th Annual OSC Readiness Training Program 114
115 Use of Volunteers 15 th Annual OSC Readiness Training Program 115
116 Use of Volunteers Volunteer defined [NCP 300.5] Nongovernmental participation in response operations [NCP ] 15 th Annual OSC Readiness Training Program 116
117 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 15 th Annual OSC Readiness Training Program 117
118 Use of Volunteers (continued) Potential challenges associated with use of volunteers during an oil spill Liability Health & Safety Congressional interest 15 th Annual OSC Readiness Training Program 118
119 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. 15 th Annual OSC Readiness Training Program 119
120 Questions? 15 th Annual OSC Readiness Training Program 120
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