rrt roles and responsibilities for subpart j response n.
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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

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Presentation Transcript
session purpose what are we doing

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

Form subcommittee to continue with next steps/action items.

background gti spill

Background – GTI spill

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

rrt activities per ncp

RRT activities per NCP

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.

300.105(b)

rrt activities per ncp 300 900 aka subpart j

RRT activities per NCP 300.900 (aka Subpart J)

As part of planning activities, RRTs shall address the desirability of using chemical agents (300.910(a))

applicability of subpart j

Applicability of Subpart J

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

bioremediation r8 and beyond

Bioremediation R8 and beyond

Annex IX in RCP details bioremediation requirements

Lengthy – approx 50 pages

Separate from other chemical countermeasures

Other approaches (R7, R9, etc)

proposal

Proposal

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?