Oil Spill Removal Organizations

1. Oil Spill Removal Organizations What are your Roles and Responsibilities as an OSRO Contractor? U.S. EPA Region III Office of Enforcement, Oil and Prevention Branch (3HS61) 1650 Arch Street Philadelphia PA 19103-2029

2. Purpose of OSRO’s • Their primary purpose is to serve as an emergency spill response resource to their customers. • So what exactly are their responsibilities to the customer? • To respond to emergency situations concerning the release of oil.

3. National Preparedness for Response Exercise Program • PREP • Establishes a workable exercise program • Meets the intent of section 4202(a) of the Oil Pollution Act (OPA 90) • Provides a mechanism for compliance

4. PREP Cont. • Unified Federal Effort • Coast Guard • Environmental Protection Agency • Research and Special Programs Administration • Office of Pipeline Safety • Minerals Management Service • Satisfies all OPA 90 mandated federal oil pollution response exercise requirements

5. PREP Cont. • What does PREP Represent? • The minimum guidelines for ensuring adequate response and preparedness. • Exercises provide an opportunity for continuous improvement.

6. Internal Unannounced Exercises • Internal Unannounced Exercises • Must be completed! • Can be in the form of: • Emergency Procedures exercises for facilities • Spill management team tabletop exercises • Equipment deployment exercise • It is necessary to have both announced and unannounced exercises • Actual spill response

7. Equipment Deployment Exercises • As defined in the PREP • As a general rule, the equipment should be: • A representative of the total equipment • In good working condition and appropriate to the working environment. • The OSRO should try to develop a rotation of equipment and personnel in order to maximize response effectiveness. • Personnel Used • Representative sample • Must be included in some type of comprehensive training

8. Equipment Deployment (Responsibilities of OSRO’s with Field Facilities) • Larger facilities, with smaller regional field response facilities, are required to have at least one equipment deployment exercise annually. • Must also coordinate personnel from each field facility to participate in the drill • Equipment may be taken from one or more facilities. • For a facility to take credit • Equipment deployment must occur in a similar environment

9. Equipment Deployment Exercises • OSRO should provide documentation of completion to plan holders. • Plan holder is responsible for ensuring the OSRO has completed deployment exercises and obtained documentation.

10. Government Initiated Unannounced Exercises • Give regulators the opportunity to evaluate response preparedness • After a successful completion plan holders are not required to participate in another exercise for 36 months. • Unsuccessful may lead: • Additional exercises • Changes in plan • Should respond with same intensity as a release

11. EPA Regulations • 40 CFR Part 112 Appendix E 3.3 • Shall include: • 1000 ft of containment boom • or for complexes double the length of the largest vessel that conducts transfers (where applicable) • Means of deploying it within 1 hr of discovery • For exercise situations and small discharge • Means of deploying it within 1 hour of the discovery of a spill • Recovery devices • Effective for recovering capacity equal to the amount discharged in a small discharge or greater. • Available at the facility within 2 hours

12. Coast Guard Regulations • 33 CFR 154.1045 • OSRO (if relied upon) must supply the facility with at least 1000’ of boom. • Means of deploying and anchoring boom • Recovery devices capable of being at the facility within 2 hrs

13. Contractor Expectations During Exercises and Response • Exercise their best efforts for all clean up related processes. • Safety comes first, even with a spill response exercise. • All PPE should be used • Take a look at chemical specific safety • Regulations must be followed. • Should be able to contact 3rd party for additional resources

14. Contractor Expectations During Exercises and Response cont. • The OSRO is also expected to supply the facility with the required materials and labor to contain the spill until long term remediation strategies are being implemented. • General needs • Site specific needs

15. Special Considerations • Need to be assessed. • Certain situations may require special training and/or equipment. • Evaluate your capabilities • Know your limitations • Consider your personnel • Have site specific strategies

16. Fast Current/Shallow Water • Different strategy and equipment needed • Things to be considered: • Booming techniques • Anchor Points • Equipment • Training • Limited timeframe • Timely access to equipment • Deflection boom • Focus on sensitive areas

17. Response to Oil Spills on Land • Response Strategy • Stop the source • Equipment • Loaders, backhoe • Training • Know the topography and overland drainage pathways. • Must understand the hydro

18. Sinking Oil Response • Sampling and Tracking • Grab sampling • Water core sampling • Certified divers • Response Techniques • Determine: • Location • Depth • Extent • Response Equipment • If suspended • Silt Curtains, nets • If on bottom • Seabed depressions • Training • Diver certification, coast guard and National Response Council websites.

19. Extreme Weather • Cold • Frigid wind chills • Ice cover • Personnel Safety • High Priority Due to: • Risks associated with the site • Risks associated with frigid conditions

20. Extreme Heat • May enhance volatilization of VOC’s • Will require being familiar with and monitoring exposure limits • Monitor Lower Explosive Limits (LEL) • Other Safety Issues • Heat stroke • Dehydration

21. Remote Spill Areas • Remote areas are considered to be any area where access is limited. • Strategies? • Pre-stage Equipment • Possibly transfer pumps?

22. Key Points • Consider the site • Examine what is unique • Use drills to determine weaknesses/strengths • Know you capabilities • Review response contract