RRT Roles and Responsibilities for Subpart J Response. Session Purpose – what are we doing?. Review background of issue – GTI spill Review RRT authorities/responsibilities Review applicability of Annex IX and subpart J regulations Outline EPA/USCG proposal
Review background of issue – GTI spill
Review RRT authorities/responsibilities
Review applicability of Annex IX and subpart J regulations
Outline EPA/USCG proposal
Form subcommittee to continue with next steps/action items.
Tank truck rollover results in release of diesel fuel
OSC responds, initiates bioremediation annex under RCP
Numerous questions arose, no action taken
Request to review RCP annex
Preparedness planning and coordination for response to a discharge of oil or release of hazardous substance;
Notification and communications; and
Response operations at the scene of a discharge or release.
As part of planning activities, RRTs shall address the desirability of using chemical agents (300.910(a))
Chemical agents – definition
Chemical agent use regulated by Subpart J (300.900(c)) – for Oil!
CERCLA response is different
Agent use, landfarming, etc regulated by 300.400(e) and (g)(1-2)
Subpart J only applies for agents in water
Thus, somewhat limited scope
Annex IX in RCP details bioremediation requirements
Lengthy – approx 50 pages
Separate from other chemical countermeasures
Other approaches (R7, R9, etc)
Eliminate separate bioremediation annex
Combine bio with other chemical agents annex and policy
New annex to include:
RRT policy/planning for chemical agent use Separate from other chemical countermeasures
Streamlined process for FOSC use
Collect supporting documents in another place
Next steps – volunteers?