Section 3. OPERATIONS
3.2 Discharge or Release Control
3.2.1 General Guidelines for Oil Spills
Shoreline Cleanup Guideline Matrices have been developed for the US EPA Region 5 Area by the RRT5. These guidelines address the use of specific countermeasures on various shoreline habitats for four oil types. The shoreline types are listed in relative order of sensitivity. Habitat sensitivity is a function of a range of factors, including:
These correlate directly with the rankings used in the Environmental Sensitivity Index (ESI) atlases published for the U.S. Great Lakes by NOAA.
The classifications developed for these matrices indicate the relative environmental impact expected as a result of implementing the response techniques on a specific shoreline. The relative effectiveness of the technique also has been incorporated into the matrices, especially where use of the technique would result in longer application and thus greater ecological impacts, or leave higher oil residues in the habitat.
3.2.2 Actions to Lessen Impact
Defensive actions should begin as soon as possible to prevent, minimize, or mitigate the threat to the public health or welfare or to the environment. Actions may include the following:
Appropriate actions should be taken to recover the oil or mitigate its effects. Of the numerous chemical or physical methods that may be used, the chosen methods should be the most consistent with protecting the public health and welfare and the environment. Sinking agents shall not be used.
The OSC must choose the best method from the available response tools in any incident. The physical recovery and removal of oil is the preferred cleanup technique. Under certain conditions, however, chemical agents can be an effective tool. There are no pre-approved uses of chemical agents in Region 5. If chemical use is considered, the guidelines below are intended to aid the OSC in making a decision.
US EPA has compiled the NCP Product Schedule, a list of dispersants and other chemicals which the OSC and/or PRP may consider for use during a spill emergency. The Product Schedule does not authorize or pre- approve use of any of the listed products. Use of dispersants or other oil emulsifiers in not pre-approved anywhere in Region 5 and is not likely to be allowed because of the limited dilution available in fresh waters, the use of freshwaters as a water supply, the limited toxicology information available for dispersants in fresh water, and the limited information available as to fresh water effectiveness of dispersants. The OSC may not authorize use of a product that is not listed on the Product Schedule.
Sinking agents shall not be used in US EPA Region 5. US EPA Region 5 does not promote the use of dispersants or other oil emulsifiers as they do not work in fresh water.
The use of
on surface waters, particularly near sensitive wetland or water supplies (fresh water systems) must be approved by State and/or Federal Agencies. Such use adds to the potential for serious impact of already released petroleum products. This stance is necessary to protect subsurface water intakes (potable and non-potable).
The Region does recognize, however, that as a last resort, such agents may have some limited applicability. An example of a situation in which chemical use might be considered for reasons other than protection of human life is during the migratory season, when significant migratory bird or endangered species populations are in danger of becoming oiled.
3.2.3.1. Application Steps for Use of Chemical Spill Control Agent
The OSC may authorize or is authorized to use any chemical product without requesting permission if its use is necessary to prevent or substantially reduce a hazard to human life. The RRT should be notified as soon as practicable. In situations where a human hazard is not present, the OSC must receive the concurrence of
before authorizing use of a listed product.
The OSC may consult with the NOAA or US EPA Scientific Support Coordinator (SSC) prior to chemical agent application in US EPA Region 5. The NOAA and US EPA SSCs provide
The OSC will request approval from the RRT to use chemicals on behalf of the spiller. Use of chemicals on a Regional boundary should include the appropriate RRT members of the bordering Region. The RRT shall be notified of any chemical use as soon as practicable.
3.2.3.2 Chemical Use Checklist
The OSC/RPM will supply the appropriate members of the RRT with the information contained in the Chemical Use Checklist. The checklist provides information concerning the circumstances of the spill, trajectories, environmental resources at risk, and available decision makers with the information necessary to make a decision on the use of chemical agents.
3.2.4. Use of In Situ Burning in US EPA Region 5
In order to minimize environmental impacts and facilitate effective cleanup of an oil spill, responders have a limited number of techniques available to them. These include mechanical methods, the use of certain chemical countermeasures, and in situ burning. Under certain specific conditions, in situ burning may offer a logistically simple, rapid, inexpensive, and relatively safe means for reducing the shoreline impacts of an oil spill. Moreover, because a large portion of the oil is converted to gaseous combustion products, the need for collection, storage, transport, and disposal of recovered material can be substantially reduced. In situ burning may be able to remove a large amount of spilled oil before spreading and drifting of the spill fouls shorelines and threatens wildlife. In certain circumstances, such as oil spilled in ice conditions, burning may be the only viable response technique. Authorization of in-situ burning is subject to consultation and concurrence from the State and DOI. Considerations for use should include an analysis of oil location and the potential impact of smoke on downwind populations.