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:

• degree of exposure to natural removal processes
• biological productivity and ability to recover following oil exposure
• human use of the habitat
• ease of oil removal

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:

• Analysis of water samples to determine the source and spread of the contaminants
• Control of the source of the discharge
• Measurements and sampling
• Placement of physical barriers to deter the spread of the oil or to protect sensitive environmental resources through coordination with resource agency specialists
• Control of the water discharged from upstream impoundments
• If approved, the use of chemicals and other materials to restrain the spread of the oil and mitigate its effects, in accordance with the NCP. Use of chemical agents is not pre-approved in Region 5.

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.

3.2.3. Use of Chemical Agents

Click here for Chemical Use Checklist

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. 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 is 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

• surface collecting agents
• biological additives
• burning agents
• miscellaneous oil spill control agents

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

• the RRT Co-Chair, and
• the RRT representative(s) of the affected State(s), in consultation with
• the DOI RRT member (and, where the Great Lakes are affected, the DOC RRT member, where practicable)

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

• oil spill modeling results,
• interpretation of ESI maps,
• location of sensitive areas,
• chemical effects, and
• environmental risks.

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.

Under the NCP, the RRT may authorize the use of oil spill control agents that are on the NCP Product Schedule. The Region 5 RRT has preapproved the use, in Region 5, of socks, booms, pads, pillows or other devices which completely surround and contain one of the solidifier products listed: ALSOCUP, Aqua N-CAP Polymer, CIAgent, WASTE-SET #3200, WASTE-SET #3400, as long as they remain on the NCP Product Schedule and subject to the following conditions:

1. Application of the solidifier product must be done in a manner that does not allow the solidifier product to be released from the sock, boom, pad or pillow; and
2. The sock, boom, pad or pillow is not left in the environment for more than one week after contact with the oil; and
3. The sock, boom, pad or pillow must be recovered from the water within one week of contact with oil or depletion of solidifying capacity and properly disposed of.
4. This preapproval does not include preapproved use in Tribal or Department of Interior managed lands.

Solidifier preapproval documents can be found in Appendix VIII.

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.