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 OSROs

• 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 OSROs
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 VOCs
• 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