'JEL*  WATER POLLUTION PREVENTION AND CONTROL
.3B°
OIL AND HAZARDOUS MATERIALS PROGRAM SERIES OHM 74-03-001
           U.S. ENVIRONMENTAL PROTECTION AGENCY

           OFFICE OF WATER PROGRAM OPERATIONS

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                     SCHUYLKILL OIL SPILL  II
                        JUNE-OCTOBER 1972
                   POTTSTOWN,  PENNSYLVANIA AREA
                   ON-SCENE  COORDINATOR'S  REPORT
              Division of  Oil  and Hazardous Materials
                Office of  Water Program Operations
               U.S. Environmental Protection  Agency
                      Washington, D.C. 20460

                                and

                              Region III
               U.S. Environmental Protection  Agency
                 Philadelphia, Pennsylvania 19106
                             March 1974
                                  U.S.  Environmental Protection
                                  Region V, Library
                                  230  South Dearborn Street
                                  Chicago, Illinois  60604
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 - Price $1.30

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                EPA Review Notice

This report has been reviewed by the Office of
Water Programs, EPA, and approved for publica-
tion.  Approval does not signify that the con-
tents necessarily reflect the views and policies
of the Environmental Protection Agency, nor does
mention of trade names or commercial products
constitute endorsement or recommendation for use
                      11

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             TABLE   OF   CONTENTS



           TITLE                                         PAGE


INTRODUCTION	    1

     (Purpose of This Report)	    1

THE SCHUYLKILL SPILL OF NOVEMBER 13, 1970	    5

HURRICANE AGNES:  JUNE, 1972	    7

REACTION TO THE OIL SPILL	   13

ACTIVITIES OF THE REGIONAL RESPONSE TEAM	   20

ACTIVATION OF THE NATIONAL STRIKE FORCE	   25

NARRATIVE:  28 June - 8 July 1972	   37

NARRATIVE:  10 July - 29 Sept.  1972	   60

PREPAREDNESS FOR OIL SPILL EMERGENCIES	   64

EVALUATION OF THE NATIONAL CONTINGENCY PLAN
AND POTENTIAL SPILLS	   66

RELATIONS WITH BERKS ASSOCIATES	   69

USE OF INDEPENDENT CONTRACTORS	   70

SURVEYS AND RESEARCH	   72

PERSONNEL	   77

INTER-AGENCY COOPERATION	   79

CLEAN-UP ACTIVITIES OF THE U.  S.  ARMY CORPS
OF ENGINEERS	   80

EQUIPMENT AND MATERIALS	   82

THE DIVERSION BOOM AT PENNHURST	   84

ESTIMATE OF OIL VOLUME RECOVERED	   86

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               LIST   OF   EXHIBITS

Exhibit Number          Title and Credit          Page Number
     1.           Flood Rescue Mission, Local
                  Police *                            9
     2.           Rescue, Navy 21 *                   10
     3.           SITREP ONE - Base Gloucester        11
     4.           Berks Associates - flooded *        14
     5.           Oil High-Water mark - NSF           16
     6.           After the flood - NSF               16
     7.           Heavy oil on river *                18
     8.           Fast current flow *                 19
     9.           Pollution                           21
    10.           Official records - by date          27
    11.           Work load as measured by            29
                  problems reported
    12.           "Special Events" form               30
    13.           Major Problems Identified on
                  28 June 1972                        31
    14.           Administrative Problems             32
    15.           Special Operation Problems
                  28 June - 8 July (inc.)             34
    16.           Technical Problems                  35
    17.           Free Oil in Streams                 36
    18.           Lagoons repaired after spill        36
    19.           Boom, barge and Vac-Truck           38
    20.           Diversion Boom - North bank         38
    21.           Diversion Boom - South bank         4-1
    22.           Polluted Foliage was not
                  removed                             41
    23.           Penn. National Guard Helicopter     43
    24.           Oil Soaked Foliage                  43

    *  Credit Pottstown Mercury (Staff Photo)
  NSF  Credit National Strike Force

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Exhibit Number           Title and Credit          Page Number
     25.           "There's No Substitute for
                   Manpower"                           49
     26.           Diversion Boom at Hanover St.
                   Bridge                              50
     27.           Diversion Boom at Pennhurst         55
     28.           Settling Tank and Boom              55
     29.           Schematic of Skim-Separate-
                   Pump Equipment at Pennhurst         56
     30.           Major Problems, 9 July - 25
                   Sept.                               59
     31.           Oil, Sludge and Debris re-
                   covered                             87
     32.           Gallons of Oil Recovered for
                   temporary Storage at Lagoons        88
                         V1T

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                  INTRODUCTION


                  PURPOSE OF THIS REPORT
The Schuylkill flood and oil spill of 22 June 1972 was unique
in several respects:

     1.  It was the second major oil spill to originate from
         a group of oil storage lagoons on the banks of the
         Schuylkill River at Douglassville, Pennsylvania,
         four miles West of Pottstown.  (The first - Schuyl-
         kill I - took place on 13 November 1970.)

     2.  The spill clean-up process had to be performed
         against the background of the "Agnes" disaster, the
         worst inland flood on record in the United States.

     3.  Several key personnel of the United States Coast
         Guard and Environmental Protection Agency were in-
         volved in the clean-up of both spills.

     4.  Clean-up activities on the Schuylkill I spill had
         been reported in some detail by a documentation team.
         Their report entitled "Oil on the Schuylkill" was
         published by the Environmental Protection Agency,
         Division of Oil and Hazardous materials.  The same
         documentation team has now been employed by the On-
         Scene Coordinator to report on the second spill,
         Schuylkill II.

Consequently, the situation offers an unusual opportunity to
compare performances on both spills and to evaluate the read-
iness of all concerned groups to respond to a major emergency.

Any major disaster requires fast and effective response if
life and property are to be protected and losses kept at a
minimum.  In many instances, the resources of Federal, State
and Civic Governments must be coordinated with those of bus-
iness, industry and the private sector.

Wherever the spillage of oil or other hazardous materials is
involved, special technical knowledge, equipment and skills
are required.  Skillful administration is required while
working under conditions of extreme emergency.

The 91st Congress of the United States directed preparation of
a National Contingency Plan to deal with major oil spill emer-
gencies.  PL 91-224 provides a mechanism whereby Federal re-
sources can be marshalled to deal with the unusual problems
created by oil spills.
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The plan was activated in June 1970.  It included the organ-
ization of an oil spill "Strike Force" on a national level.

The National "Strike Force" has responded to several spill
emergencies, and the Schuylkill River Spill of November,
1970 was the first.

As might be expected, experience gained in one emergency
situation can be valuable in dealing with subsequent in-
cidents.  Consequently, accurate records of each oil spill
clean-up are essential to the learning process.

This report is intended to document the activities of the
National Strike Force, the Coast Guard, the Environmental
Protection Agency and nearly a score of the other agencies
which responded to the Schuylkill II emergency.

The flood and oil spill in 1972 involved an estimated 5,000,000
gallons of oily sludge from all the lagoons as compared with 3
million gallons or less from 2 lagoons in the 1970 spill.

The oil contained a high residue of lead and other potent-
ially dangerous metals and hydrocarbons.  Because the oil
was carried on flood waters far beyond the banks of the
Schuylkill River, the resulting contamination covered hun-
dreds of acres of land.  Obviously, this spread the pollu-
tion into homes, farms, industrial plants, public recreation
areas and other terrain untouched by the first spill.

Farm animals, birds and thousands of people were exposed to
the oil.  Hydrocarbon vapors, toxic metals and chemicals re-
presented potentially dangerous situations by exposing people
and wildlife through direct contact, inhalation and drinking
water.  The extent of the danger was not known immediately
and maximum precautions had to be taken until laboratory
analysis of the waste oil and water could be completed.

Once the threat of an oil spill became known, intensive activ-
ity was generated at:

     1.  United States Coast Guard, Gloucester City, New
         Jersey:  (Base Gloucester)

     2.  National Strike Force Headquarters (Strike Force)
         of United States Coast Guard, Governors Island,
         New York

     3.  Division of Oil and Hazardous Materials,(DOHM) En-
         vironmental Protection Agency, (EPA) Washington, B.C.

     4.  Philadelphia Regional Office of Environmental Prot-
         ection Agency (EPA-Phila)

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     5.  Edison Laboratories of Environmental Protection
         Agency, Edison, New Jersey  (Edison Laboratories)

     6.  United States Corps of Engineers  (USC of E)

     7.  Department of Environmental Resources of Pennsyl-
         vania, Harrisburg, Pennsylvania  (DER-Pa.)

     8.  Civil Defense Agencies in cities and counties in
         the Schuylkill River Valley.

Official records of the oil spill clean-up operations include
the following daily reports issued by several agencies as in-
dicated:

     1.  Situation Reports, (SITREPS) from Base Gloucester
         from 22 June through 26 June, 1972.

     2.  Pollution Reports (POLREPS) from the Regional Re-
         sponse Team (RRT), EPA - Phila from 23 June through
         28 June.

     3.  POLREPS from USCG Base Gloucester from 23 June
         through 28 June.

     4.  Information reports from USCG Base Gloucester from
         27 June through 1 July 1972.

     5.  USCG POLREPS from Office of the On-Scene Coordin-
         ator, (OSC) from 28 June through 29 September.

     6.  A Daily Log from the Office of the OSC from 28 June
         through 25 September 1972.

Daily Newspapers in Schuylkill River Valley provided broad
coverage of the flood disaster together with many details of
the oil spill situation and related information.

Members of the documentation team conducted personal inter-
views on the site or by telephone with key personnel assoc-
iated with the oil spill response.  Documentation personnel
kept comprehensive notes on activities which they observed
personally during intermittent visits to the site from 3
July through 18 October 1972.

Based on the information from above sources, this report
attempts to describe the cause of the spill, the means used
to protect the public from the pollution hazard, the oil con-
trol and clean-up methods, final disposal of the polluted oil
and debris, restoration of the polluted areas, the short-
range effects and the probable long-term effects on the ecol-
ogy.  The Division of Oil and Hazardous Materials, through
                          -3-

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Ocean Science and Engineering,  is conducting continuing
studies of the effects on the ecology.

The report will make special observations on many of the
problems which persisted throughout the period.   It will
also suggest opportunities for improvement of the response
to a major oil spill and it will discuss a list of special
subjects which confront the on-scene commander in dealing
with oil spill control and clean-up.

Most of the statements of fact in this report have been
verified from one or more of the sources listed above.
Where substantiation is not available,  statements believed
to be true were identified with the phrase, "it was reported
that	"

Opinions and judgements expressed by the authors of this
report are readily identified as such and are based on
nearly five years of experience in oil spill control work
including five major oil spills.
                           -4-

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            THE SCHUYLKILL SPILL OF NOVEMBER 13, 1970

         i   was described in the report "Oil on the Schuyl-
kill."  It may not be available to all readers of this report,
so a brief summary of that spill is submitted herewith.

Berks Associates at Douglassville, Pennsylvania have been re-
claiming used crank-case oil for about 20 years.  Their pro-
cess extracted useable crank-case oil from dirty oil drained
from automobiles.  By so doing, they provided a satisfactory
disposal method for many thousands of gallons of used oil
which might otherwise have been poured into sewer systems.

The process re-claimed approximately 95% of its feed stocks,
but a heavy residue of sludge oil remained.  For many years
there was no use for this sludge, and it was stored in lag-
oons behind the Berks Associates plant on the banks of the
Schuylkill River.  Some of the lagoons were within 50 ft of
the river.

Obviously,  the location chosen for those lagoons proved to
be most unfortunate.  The hazard was recognized by the Pen-
nsylvania Dept. of Environmental Resources and a safety dike
was constructed between the lagoons and the river a few weeks
before Schuylkill I took place.

In early November 1970, 10 days of heavy rain flooded the
lagoons.  Two of them over-flowed their dikes.  The safety
dike was breached and the oil sludge poured onto the sur-
face of the Schuylkill River which was in flood but not over
its banks.

A large portion of the spilled oil flowed from the Schuyl-
kill River into the Delaware River and finally disappeared
at sea.  Substantial quantities of oil and oil-soaked debris
were intercepted and recovered in the Philadelphia Area and
trucked to land-fill disposal sites in New Jersey.

The disaster forced Berks Associates into bankruptcy and a
federal judge decreed that no more residual oil was to be
stored in the lagoons.  Berks Associates consented to the
decree, and their compliance was monitored by the Phila-
delphia Office of E.P.A.

During that period, Berks Associates was reactivated and
some industrial customers were found who could use the res-
idual oil from the lagoons.  Several shipments of sludge oil
were made to customers in the United States and Canada.  Con-
sequently,  the content of the lagoons had been reduced meas-
ureably before Hurricane Agnes became a threat.

Experience  in this case and in other major spills such as
                          -5-

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Kodiak Naval Station (1970) and Indiana Harbor, Indiana (1970)
has indicated that oil in storage is a continuing hazard unless
the tanks or pipelines or lagoons are protected against unusual
hazards to an extent never before considered necessary.
                         -6-

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                HURRICANE AGNES:  JUNE, 1972


As Hurricane Agnes moved slowly from the Gulf of Mexico toward
western Pennsylvania, it accumulated record quantities of water
in its system and spread its storm clouds over an area reaching
from Virginia to upper New York.  At that point, the storm  sys-
tem remained stationary for days and released its torrents  of
rain.  By the middle of June it was obvious that a major flood
threat was building up.  Disaster relief organizations began
to prepare for action.

Any flood has the potential to wreck warehouses or break tanks
or pipelines where oil or other pollutants may be stored.   In
Washington, B.C. the EPA Division of Oil and Hazardous Mater-
ials was aware of the possibility.  Mr. Kenneth Biglane, Dir-
ector o" the Division of Oil and Hazardous Material, estab-
lished a flood watch at strategic locations in the threatened
area.

Oil and Hazardous Material regional offices were alerted and
special observers were assigned to flood duty at Richmond,
Virginia; Harrisburg, Wilkes-Barre and Philadelphia, Pa.; and
at Elmira, New York.  Dr. Allen L. Jennings of the Division of
Oil and Hazardous Materials, Washington, D. C. was assigned to
the Philadelphia Regional Office of Oil and Hazardous Materials.

At the same time, the Department of Housing and Urban Develop-
ment, The Department of Health and Welfare and the Federal
Small Business Agency were sending representatives to Potts-
town.  On 26 June, Pottstown Mayor Brower B. Yerger made the
Washington Elementary School available to these agencies.  The
OSC, with the cooperation of Mayor Yerger, established the
office of the On-Scene Coordinator in the Washington Elementary
School on 28 June.

The lagoons at Berks Associates gave concern to personnel who
had been associated with the Schuylkill Spill of 1970.  Per-
sonnel at OHM-Offices, EPA, Oil and Hazardous Materials Offices
at Coast Guard Base, Gloucester, New Jersey, at EPA Edison Lab-
oratories, New Jersey and at the National Strike Force head-
quarters in New York watched developments.  They realized that
heavy rains might over-flow the dikes for a second time.  Break-
age of the dikes was not expected because they had been repaired
and strengthened after the first spill.

Flash flooding in the river was a known hazard,  but there was
no reason to expect that the Schuylkill River would go 20 feet
over its banks,  and no forecasts of such flooding were published
until 21 June.   (It has been suggested that massive embankments
on the Route 422 Bypass accentuated the effect of the flood in
                          -7-

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the Pottstown area.  Pottstown Mercury, 29 July)

Meanwhile, areas from Richmond, Virginia to Elmira, New York
and all of Western Pennsylvania became flooded.  The magnitude
of the disaster was not understood even while it was taking
place, but, as information came from devastated areas to Gov-
ernment Agencies and as news media released stories of the
flood, disaster relief was summoned from available sources
on the Central East Coast.

By 21 June, many of the resources available to a disaster
emergency had been totally committed to the flood relief
effort.  Civil Defence Organizations, National Guard, Red
Cross, Coast Guard, Navy, Army and a long list of federal
agencies had sent their top personnel.  Whole warehouses
of materials had been shipped to stricken areas.  Skilled
manpower resources and emergency funds were becoming de-
pleted.

Saving lives and the protection of property received top
priority.  (Exhibit l)

Late at night on 21 June, severe flooding had reached Cen-
tral Pennsylvania and by 04:30 hours on the morning of 22
June, Coast Guard auxiliaries in Lebanon were mobilizing
for flood patrol and relief activities, local commanders
phoned Coast Guard Base Gloucester asking for orders.  At
09:30 hours the Civil Defense Director of Columbia County
requested mobilization of the Coast Guard Auxiliary at
Bloomsburg.  Capt. R.I. Price, the Commanding Officer at
Base Gloucester issued the necessary orders, assigned per-
sonnel to coordinate activities and dispatched mobile equip-
ment to the flooded areas for rescue work.

Mobilization of resources was spreading.  The Governor of
Pennsylvania declared a state of emergency in the Central
Pennsylvania area.  The Naval Air Force dispatched rescue
helicopters from Lakehurst, New Jersey and Willow Grove,
Pennsylvania  (See Exhibit 2.)

The first warning that flash flooding might be expected on
the Schuylkill was received at Base Gloucester at 04:30
hours on 22 June.  (Exhibit 3.  SITREP ONE)

The first notice that oils and hazardous materials were
present in the flood came from areas where rising waters
washed out factories and warehouses along the banks of the
Schuylkill River and huge inventories of industrial mat-
erials were swept into the flood.

Drums filled with many kinds of industrial chemicals floated
away from shipping docks and storage warehouses.  If these
containers were not securely closed, their contents were
spilled into the flood.  Spilled materials included harmless

                          -8-

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                  EXHIBIT # 2




                RESCUE,  NAVY  21
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TH DE GL

P 23 1553Z JUN 72
FM COGARD BASE GLOU
70 CGGDTHREE
ST
UNCLAS
TO 0
SITREP ONE:  CENTRAL AND EASTERN PENNA. FLOODING

I.  SITUATION
    A.  RECEIVED CALL VIA L/L AT 04300 FROM MR. STRETLER,
        COGARD AUXILLIARY, (717 838-3007) REQUESTING
        TRAVEL ORDER NUMBERS FOR COGARD AUX. ASSISTANCE
        IN LEBANON, PA. AREA.  HE HAD BEEN NOTIFIED BY
        PA. CIVIL DEFENSE OF HEAVY FLOODING.
    B.  RECEIVED REQUEST AT 0930Q FROM MR. CARL HUNSICKER;
        CIVIL DEFENSE DIRECTOR FOR COLUMBIA COUNTY, PA.
        (717 784-3012) REQUESTING COGARD AUXILLIARY ASSIS-
        TANCE IN AREA OF BLOOMSBURG, PA. TO RESCUE STRAND-
        ED FLOOD VICTIMS.
    C.  GOVERNOR OF PA. HAS DECLARED STATE OF EMERGENCY
        IN THE AREA.
2.  ACTION TAKEN
    A.  ISSUED FIVE (05) TRAVEL ORDER NUMBERS TO STRETLER
    B.  ISSUED ONE (01) TRAVEL ORDER NUMBER  TO MR. RUSS
        KRESSLER, FLOTILLA COMMANDER, AUX. PLOT. 5-10,
        DIV. 5 FOR RESCUE WORK IN BLOOMSBURG, PA. AREA.
    C.  HAVE CO-ORDINATED WITH LCDR. H. PINTER, DIR. AUX.
        SA, REGARDING COGARD AUXILLIARY ASSISTANCE.  ASST
        DIR. OF AUXL, SA, LT. J. TAMALONIS, HAS BEEN DE-
        SIGNATED AS AREA COGARD CO-ORDINATOR.
3.  FUTURE PLANS
    A.  TWO (02) PIECES OF TRANSPORTABLE EQUIPMENT WILL
        BE RETAINED AT BASE GLOUCESTER FOR POSSIBLE USE
        IN DELAWARE RIVER WATER SHED WHICH HAS FLASH
        FLOOD WARNINGS NOW IN EFFECT.
    B.  CONTINUE TO CO-ORDINATE COGARD AUXILLIARY ACTIV-
        ITIES.
4.  CASE PENDS.

BT

TOD  22/1650Z RH K
DE TH R DR AR
              SITREP  ONE  -  Base  Gloucester

                       EXHIBIT # 3

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liquids, poisonous or toxic compounds and acids.   Even if the
drums were secure, there was always the chance that they might
be opened by children or by others who did not realize the
danger.

Hundreds of drums were reported floating on the Schuylkill
River and were beginning to reach the Philadelphia area and
the Delaware River.  There was a report that 600 barrels of
lacquer and un-known quantities of other hazardous materials
were involved.

Captain R. I. Price, Commanding Officer at Base Gloucester
and Captain of the Port of Philadelphia, organized Coast
Guard resources and requested assistance from industries on
the Delaware River to gather these floating drums for tem-
porary storage pending identification and return to the
owners or for other disposal.  He also obtained assistance
from the Corps of Engineers at Fort. Miflin, Pa.,  who continued
to recover drums and other debris from the river bank and river
bottom throughout the clean-up period.

Consequently, when flood waters finally entered the lagoons
at Berks Associates late on 22nd of June and the contents
of the lagoons poured out onto the flood, the Schuylkill
River Flood and Oil Spill became a localized oil spill dis-
aster, literally piled on top of the far greater disaster
of a major flood.

Because so many resources had already been committed to the
saving of lives and other flood relief problems in Western
Pennsylvania, remaining resources capable of dealing with
an oil spill did not have their usual reserves of personnel
and materials to draw upon.

The fact that the Coast Guard, its National Strike Force and
the EPA were able to mount a major oil control and clean-up
campaign under those circumstances is a tribute to the plan-
ning and organization which had been done in advance and to
the dedicated efforts of the personnel concerned.
                         -12-

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                  REACTION TO THE OIL SPILL


It should be noted that all official action through 22 June
had been based on the general flood situation and on the spec-
ific problem of hazardous materials in drums or barrels.  Oil
spills were not yet a reality, and the action taken before
18:00 hours on 22 June had been directed only to the hazards
identified up to that time.

At 13:00 on 22 June, power failure caused shut-down of the
plant at Berks Associates (Pottstown Mercury, 23 June) and
at 15:00 EDT the flood waters overflowed the dike and the
spill began.  (Exhibit 4)

The flood crested at approximately 22:00 hours in the Potts-
town area and waters began to recede slowly.  By that time
most of the contents of the lagoons had flowed into the river.
The major spillage took place during hours of darkness.

The very beginnings of the spill may not have been observed
because of darkness and because all residents of the Schuyl-
kill Valley were concerned with evacuation of threatened homes,
rescue of stranded personnel, saving of property and all the
other high-priority activities associated with a flash flood
of such magnitude.  There is no evidence that wor4  of the oil
spill reached the Coast Guard or the EPA on the afternoon or
evening of 22 June.

Fortunately, Base Gloucester was planning a helicopter over-
flight early on 23 June "for survey or assistance.  '  (B. G.
SITREPS TWO)  Early on that day, Captain Price and Commander
Dash of Base Gloucester and Mr. Malcolm Castor of EPA-Phila
surveyed the area.  There were hundreds of drums and barrels
in the lower Schuylkill River.  As their flight approached
the Pottstown area, patches of black oil were sighted.  The
river was over its banks on both sides and the oil was spread-
ing over the country side.  It was obvious that a new dimen-
sion had been added to this major flood catastrophe and that
specialists in oil spill clean-up technology should be brought
into action as quickly as possible.

Captain Price took action as intended by the National Con-
tingency Plan.  He recommended that the Regional Response
Team be activated immediately and that Base Gloucester, which
was already involved with flood activities, could provide
space and logistical support for a Regional Response Center.

Developments followed rapidly.  The Regional Response Team,
as provided for in the Regional Contingency Plan for Inland
Waters, of EPA, Region III was activated, a Regional Response
                          -13-

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Center was established in the headquarters office at Base
Gloucester and Mr. Castor was designated to serve as On-
Scene Coordinator.  Authorization was obtained to use the
National Contingency Plan revolving fund and personnel from
EPA-Phila joined with Coast Guard personnel from Base Glou-
cester to form the first cadre for the RRT activities.
(Details of the day by day activities of the RRT are contained
in the following section of this report).

The first recorded notice of the oil spill was included in
Base Gloucester's SITREPS FOUR of 23 June, quoting Mr. Cas-
tor that the dikes at Douglassville had been overrun by the
flood "late 22 June."  That report was on the teletype at
16:55 hours Z (12;55 local time).  It was followed at about
01:04 hours Z (21:40 hours local time) by the POLREP ONE of
the Regional Response Team which listed the actions taken up
to that time.

Information about the spill spread rapidly through designated
official channels and through the news media and the oil spill
began to assume increasing importance among the many emerg-
encies of the Hurrican Agnes Disaster.

From 23 June through 28 June activities of the RRT at Coast
Guard Base Gloucester became inter-mingled with the mobil-
ization efforts of a host of Federal Agencies and Departments,
their Regional Offices, State,  County and Civic agencies.  Bus-
iness, industry and volunteer groups were organizing, and their
efforts had to be directed toward definite objectives and co-
ordinated with other activities.

As the flood waters began to recede, continued over-flights
and surface observations began to reveal the extent of the
oil pollution and several of its unusual characteristics.

     1.   When the flood waters  over-flowed the dikes, a sub-
         stantial portion of the sludge oil spread over the
         flooded area downstream for about 15 miles.

     2.   The river had gone over its banks, and in many areas
         the oil was carried nearly a mile inland on both sides
         of the river.

     3.   The sludge oil was very sticky and heavy coatings of
         the oil covered much of the foliage,  farmlands,  roads
         and structures in the  area.  (Exhibit 5.)

     4.   Pools of oil came to rest in ditches,  on low-lying
         fields and on islands  in the river.

     5.   The oil/water mixture  flowing out of the lagoons
         made channels in the dikes and the out-flow continued
                          -15-

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Exhibit #5   OIL HIGH-WATER MARK-(NSF Photo)
                  '^
















                      ' ""'*?
Exhibit #6   AFTER THE FLOOD - (NSF Photo)
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         to feed oil into the flooded areas.  (Exhibit 6.)

     6.  The worst pollution was concentrated in the area
         from Berks Associates at Douglassville to Pennhurst,
         a distance of about 15 miles.

     7.  The river continued to carry an oil slick further
         downstream as oil from the banks drained into the
         river or was washed into it by rains.  (Exhibit 7)

Two contractors had been placed on standby basis to assist in
cleaning up the oil pollution "When feasible", but fast cur-
rents in the river and continued rains delayed positive action
on the oil pollution front.  (Exhibit 8)  There was general
agreement that a major clean-up operation would have to be
organized and that the National Strike Force should be called
into action.  Personnel from that organization had worked on
Schuylkill I.

POLREP FIVE published by the RRT covering events of 27 June
recorded a meeting with contractors "on a no-fee" basis to
discuss a program for combating the oil spill situation.  An
on-site survey was conducted by a group from EPA, Coast Guard,
and interested contractors, and the findings of that group led
to the activation of the National Strike Force and change of
the base of operations from Base Gloucester to Pottstown on
28  June.
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                       EXHIBIT #  7
                  HEAVY OIL ON RIVER
-IB-

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          ACTIVITIES OF THE REGIONAL RESPONSE TEAM
23 June through 28 June, 1972

The Regional Response Team realized very promptly on 23
June that it was faced with a complicated problem far
greater than Schuylkill I.

It would have to deal not only with oil floating on the
River, but also with a major oil pollution of river banks,
farmland, roads, dwellings and structures of all kinds.

Furthermore, its operations would have to be coordinated
with Base Gloucester's on-going program of flood rescue
work, recovery of barrels, drums and floating debris on
the lower Schuylkill and Delaware River areas.

Note:  The Regional Response Team was made up of personnel
from USCG, (Base Gloucester) and from EPA-Philadelphia
(Environmental Emergency Branch).  The National Contingency
Plan directed that the OSC be supplied by EPA because the
source of the spill on inland waters was in EPA's jurisdic-
tion.

In the 6 days of its operation, the RRT took action on a
host of problems.  The POLREPS issued by the RRT included
these items:

     23 June  Overflight of Schuylkill area
              Evaluation of Oil Spill Disaster
              Activation of Regional Response Team with RRC
              at Base Gloucester.
              Two contractors alerted for emergency action.
              Plans to boom New Jersey Creeks to prevent
              encroachment of oil pollution.

     24 June  Continued overflights
              Conferences with USCG, USC of E and EPA to
              assess possibility of containing spilled oil.
              Agreed that booms not feasible due to high
              current velocities.
              USCG and C of E continuing Barrel and Drum
              recovery program.

     25 June  Continued over-flights
              N J Marine Police assisting in Barrel recovery.
              Planning clean-up of oil contamination.

     26 June  Overflights disclose very heavy accumulation of
              oil on flooded areas.  (Exhibit 9)
              N J National Guard assisting on Barrel recovery,
                           -20-

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EXHIBIT # 9.  POLLUTION
         -21-

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              USCG Cape May alerted on Barrel problem.
              Vehicle survey in Douglassville confirmed
              Berks Assoc. to be source of major oil spill.
              Arranged for deflector booms to protect civic
              water intakes in Phoenixville area.
              Collection areas set up for recovered barrels.

     27 June  Overflights with EPA personnel in flooded area
              Meeting with contractors to discuss techniques
              for:

                   a.  Containing oil still leaking at Berks
                   b.  Protection of civic water intakes
                   c.  Oil removal from river
                   d.  Clean-up of oil-soaked vegetation

              Joint survey by contractors, USCG, EPA groups.
              Delaware Civil Defense group added to Barrel
              recovery program.

Accomplishments of the RRT up to 28 June were considerably
more than those summarized in the POLREPS exerpted above.
Administration of an RRT operation includes problems of
finance, public relations, communications, logistical support
for field operations and billeting of detached duty person-
nel.  Every day saw one or more Government Agencies added to
the co-ordinated effort.

At the same time that the work load was increasing rapidly,
it was obvious  that the oil spill control and clean-up ef-
fort would soon require hundreds of personnel and many more
skills.  The problems of oil spill recovery and restoration
of the polluted land area were assuming top priority.

Flood rescue had been accomplished and need for flood patrol
was diminishing.  The Barrel recovery program was working ef-
fectively and dangers of pollution in the Philadelphia - New
Jersey areas were minimal.

This shift in emphasis was apparent to personnel who had
worked on Schuylkill River I.  They had experienced dif-
ficulties of transportation, logistical support, and comm-
unication when administering work crews in Pottstown from
a Headquarters at Base Gloucester.  Consequently, the ques-
tion arose, and properly so, as to whether response to the
oil spill 40 miles inland should continue to be administered
from Headquarters at Base Gloucester.

It was proposed that the Regional Response Center be moved
from Base Gloucester, and re-established in the Pottstown
area, and that additional personnel from the National Strike
Force be activated.
                           -22-

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After considerable debate, the evidence was clear that the
operation should be transferred to the Pottstown area.  On
28 June the RRT was secured at Base Gloucester and the Nat-
ional Strike Force was activated.

In its 6 days of operation, the RRT did not initiate oil
clean-up and recovery operations to deal with the oil pol-
lution problem in the Pottstown area.  This was due to two
factors.  First, the flood waters receded slowly and ground
travel into the area was difficult until 27 June.  Second,
the magnitude of the oil spill was not immediately recog-
nized as exceeding "the response capability of the region"
on which it occurred, and that "national level involvement"
was required.  (See National Contingency Plan, Annex III,
1302.1 and 1312.1).  Understandably, initial efforts to
cope with the emergency were on a Regional basis, but Re-
gional resources were already strained by the flood emer-
gency.

The RRT did employ contractors to place preventive booms
across some New Jersey creeks as was done in Schuylkill I,
but these soon proved to be unnecessary and tney were removed,

Also, the RRT served as a working force to maintain surveill-
ance of the area, to report developments, to work with the
Coast Guard on barrel and drum recovery, and to conduct pre-
liminary conferences with contractors on methods for attack-
ing the oil pollution problem when the river flow permitted.
The RRT developed a substantial fund of information about con-
ditions in the polluted area, it identified many problems
which would have to be solved as soon as the river went back
into its banks.

All this information was immedately available to the Nat-
ional Strike Force when that group came on the scene offic-
ially on 28 June.  On that date the operation began a new
phase.  Mr.  Thomas Massey, EPA Philadelphia, was appointed
OSC at Pottstown, relieving Mr. Castor, and top priority
was directed to the problems of the oil spill.

Base Gloucester continued its operations on floating drums
on the lower Schuylkill and Delaware Rivers and several Base
Gloucester personnel were assigned to duty at Pottstown.

Later, Coast Guard Auxiliaries were mobilized for traffic
duty at Pottstown.   The close cooperation between Base
Gloucester and the OSC continued effectively.

Available evidence indicates that the decision to change OSC
Headquarters from Base Gloucester to Pottstown was proper.
Its effect was to keep the center of operations close to the
area requiring the most attention,  and to bring to the task


                       -23-

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the special skills and equipment of the National Strike Force.

In summary, the Schuylkill II operations involved three dif-
ferent "game plans" within 9 days, and in the process, changed
its headquarters from Gloucester City, New Jersey to Pottstown,
Pennsylvania.  Three different "field commanders  were involved-
Capt. R.I. Price, Commanding Officer of Base Gloucester and
Captain of the Port of Philadelphia:  Mr. Malcolm Castor of
EPA - Phila;  and Mr. Thomas Massey of EPA - Phila.

While these organizational changes were being made, the
characteristics of the disaster changed markedly, and it
is to the credit of all personnel concerned that effective
action continued at an increasing pace throughout the period
and on a 24 hour basis.
                           -24-

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          ACTIVATION OF THE NATIONAL STRIKE FORCE
Activation of the National Strike Force provided the On-
Scene-Coordinator with additional resources.  The Strike
Force immediately supplied special equipment for commun-
ications and for river operations.  Many of its personnel
had had extensive experience in combating oil spills and
they had been training as a specialized team since its
formation in the Summer of 1970.

The On-Scene-Coordinator assigned the Strike Force oper-
ation to Phase II and Phase III activities as outlined in
the National Contingency Plan, while support operations
were largely carried out by personnel from EPA, Region III.

The National Strike Force had some advance notice of the
problems it would face on 28 June.  Several of its key
personnel were already familiar with the Schuylkill area
and knew the situation at the Berks Lagoons.

Consequently, when word of the oil spill was broadcast on
23 June, Commander Robert Hanson of the National Strike
Force began to plan for later involvement in the spill if
necessary.

On 26 June, the news of the spill became more serious.  OSC
Castor had estimated its volume at 8,000,000 gallons.  Cdr.
Hanson, anticipating a call-up, dispatched CWO Wirt to the
Pottstown area to serve as observer for the National Strike
Force.

On 27 June, Mr.  Wirt accompanied EPA and Coast Guard per-
sonnel on an overflight of the area and on a ground level
inspection trip to the lagoons at Berks Associates as soon
as roads were passable.

At Berks Associates, the lagoons were still pouring their
contents into the flood, and large pools of oil on nearby
fields were a probable source of more pollution.  (Exhibit
17).  The group met with Mr. Lester Schurr, Manager of Berks
Associates.  Mr. Thomas Massey, representing the Environmental
Emergency Branch, EPA-Philadelphia, urged immediate action
to close those two sources of additional spillage.  Mr. Schurr
obtained a bulldozer almost immediately, and Mr. Massey agreed
that costs would be reimbursed by some Federal source, perhaps
the revolving fund.  Repairs of the dikes and a restraining wall
in the fields were completed that afternoon.  (Exhibit 18) This
type of action is highly effective when the opportunity to stop
all or a portion of a spill at its source is so evident.
                         -25-

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Reports from all observers confirmed that the size of the
spill and the widespread pollution would require the com-
bined efforts of the National Strike Force, other Coast
Guard Commands, the EPA, the Corps of Engineers and many
other groups.

Appointment of Mr. Massey as OSC, transfer of the RRC to
Pottstown and activation of the Strike Force took place
on the following day, 28 June.

Fortunately, many of the administrative problems and some
of the operations problems which confronted the OSC could
be anticipated as a result of previous experience.  For
example, the report on Schuylkill One had identified sev-
eral tasks which could be prepared for in advance of activ-
ation of an RRT or of the National Strike Force.  Some of
those recommendations have obviously been followed.  The
National Strike Force arrived at Pottstown on 28 June more
thoroughly equipped for immediate action than had been the
cast in Schuylkill One.  Experience on other major spills,
additional manpower and knowledge of the area gained in
Schuylkill One enabled the Strike Force to fit into the
OSC's organization with a minimum of wasted effort.

However, it is axiomatic that no two oil spills are alike
and in spite of the benefits of advance planning the OSC
and his staff were faced with many new situations which
required prompt action.

While the National Strike Force was assigned primarily to
clean-up operations, it assisted the OSC in other activ-
ities as requested and coordinated its efforts with the
several support groups which had been set up.

For example, accurate records, on a day to day basis, are
essential to a successful operation.  The Strike Force
started immediately to issue daily POLREPS, emphasing
clean-up activities and technical matters.  This supple-
mented the Daily Log of Events prepared by the OSC; and the
two series of reports, plus the POLREPS, SITREPS and Com-
munication files issued from Base Gloucester, have provided
a continuing document of the combined operation. (Exhibit 10)

They demonstrate the vast amount of detail work required
to combat a major oil spill.  The National Strike Force
or any other organization dealing with such a spill can
expect new problems to develop every day while the oper-
ation is in its "emergency" stage.  Those problems must
be identified, solutions must be found and effective action
must be taken if the whole operation is to succeed.
                           -26-

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-27-

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The DAILY LOGS and POLREPS are very effective in listing
the problems, actions and results.  Exhibit 11 shows, for
example, that in the period 28 June through 8 July there
were nearly 475 items recorded in the POLREPS and DAILY
LOGS.

In order to eliminate a mass of detail and to concentrate
on major items for the purposes of this report, selected
items from each DAILY LOG and POLREP have been extracted
and listed on a single "Daily Events" page quite similar
to the POLREP in outline form.  (Exhibit 12)

By working from this "Daily Events" list of major problems,
it has been possible to identify the date on which each new
problem appeared, the time needed to work out a solution and
the additonal time needed to implement the solution so that
the problem could be considered closed.

For example, Exhibit 13 lists 17 major problems which faced
the OSC and his staff on 28 June.  There were 9 problems
identified with Administration.  Most of these were routine,
but recruitment of skilled personnel required a nation-wide
search of Federal agencies, State agencies and industrial
sources.  The personnel problem continued for weeks.

5 problems were related to Oil Control Operations, but each
one was a special case because of the nature of the spill,
the materials spilled, the difficult terrain and the need
for developing   new clean-up methods or adapting old methods
to the needs of this emergency.  Consequently, those prob-
lems required many days of survey and research effort be-
fore satisfactory answers were developed.

3 major technical problems were recognized.  Sampling of the
river bottom was assigned to Ocean Science and Engineering
under an emergency BOA contract.  New clean-up techniques
would be required to handle the polluted foliage and debris.
Detailed survey of the area was needed to identify other
technical problems as quickly as possible.

Some problems were solved almost immediately.  Others re-
mained on the "active" list for weeks, particularly those
related to the development of new technology or disposal
problems which encountered militant opposition from envir-
onmentalists.

Exhibit 14 lists the 9 selected problems of Administration
encountered on 28 June and 3 additional items which showed
up on the 1st, 2nd and 5th.  Of the 12 problems in this
category, only one was still unsolved as of 8 July.
                         -28-

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                                      -29-

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             SCHUYLKILL   TWO

DAILY EVENTS  -                       Thursday, 29 June 1972
OFFICIAL SOURCES;

Situation Reports;

Action Taken:
     1.  Material
     2.  Personnel
     3.  Inter-Agency Support
     4.  Surveys and Research
     5.  Containment Clean-up
         and Disposal

Objectives and Plans

Other Sources of Information
                       EXHIBIT #  12
                  "SPECIAL  EVENTS" Form
                           -30-

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            MAJOR PROBLEMS IDENTIFIED ON
                   28  JUNE  1972
ADMINISTRATION
     Office Space
     Communications
     Lodgings
     Staff Personnel
     Public Relations Contacts
     Contracting and Purchasing
     Legal Assistance
     Visitors
     Disaster Relief

OIL CONTROL OPERATIONS
     Protection of Sensitive Areas
     Filter Fences
     Location of Booms
     Disposal Site for Oily Waste
     Incineration of Oily Debris

TECHNICAL
     Samples of River Bottom
     Plan Clean-Up Operations
     Survey of Polluted Area
                Exhibit  13
                      -31-

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Exhibit 15 lists the 12 selected Operations Problems re-
corded from 28 June through 8 July and 7 of those were
still un-solved on that date.

In the same manner, Exhibit 16 lists 3 major Technical Prob-
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that period.  Some of these problems required intensive sur-
vey and research before workable solutions could be found.

Review of the calendar chart exhibits for this period gives
some idea of the task faced by an OSC in coping with so many
tasks in a short time and while working under the almost un-
believable pressure of an emergency situation.

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factor in freeing the On-Scene-Coordinator from some of the
time-consuming problems of oil control and clean-up so that
he could give adequate attention to the many other broad
responsibilities of his office.
                          -33-

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   EXHIBIT # 17  LIQUID OIL IN STREAMS
EXHIBIT # 18  LAGOONS REPAIRED AFTER SPILL
                -36-

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              NARRATIVE:  28 June - 8 July 1972
On 28 June  Thomas I. Massey was appointed from EPA-Phila
to act as OSC and the National Strike Force was activated.
He made an immediate over-flight of the polluted area in
company with Cdr. Robert Hanson and CWO Wirt of the Nat-
ional Strike Force, and Dr. Allen L. Jennings of EPA-OHM,
Washington.  Pollution on the river and on the flood plain
was appalling.

In the first day of Strike Force action, temporary office
space was found, telephone service was established and a
mobile unit for communications was requested from the Coast
Guard and placed in operation.

Base Gloucester supplied officer personnel who had worked
on Schuylkill One.  Additional personnel were requested
from the Pacific National Strike Force based at San Fran-
cisco, from the U. S. Army Corps of Engineers, and from
EPA-OHM in Washington.

Two contractors were authorized to start clean-up operations
immediately  each in a specified area.  One concentrated on
the installation of filter fences near Douglassville.  An-
other started planning for deployment of booms and vacuum
trucks for oil containment and recovery operations.  (Exhibit
19)

It was immediately recognized that the spilled oil contained
high concentrations of toxic metals and potentially toxic
chemicals.  Dr. Jennings took action to collect samples of
the oil and of the river bottom for analysis by Ocean Science
and Engineering.

At this point the impact of the total flood disaster became
very evident.   The need for help in all areas was critical,
and many agencies which  could normally supply clerical per-
sonnel or technical personnel had already been stripped of
their staffs while the disaster was only a flood and not yet
an oil spill.   Nevertheless,  a staff was assembled, and al-
though personnel were in very short supply the paper work
system did begin to function.

During this very hectic period,  personnel who had previous
oil spill experience proved invaluable in meeting the emer-
gency problems.  Captain Price assigned Lt.  Kangeter and RD
2 Gill from Base Gloucester.   Commander Hanson and CWO Wirt
from the National Strike Force were already familiar with
the area and had worked on Schuylkill One.   Dr.  Jennings of
EPA-OHM provided technological assistance on chemical and
biological matters.   Mr.  Thomas  Massey,  newly appointed OSC,
                           -37-

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EXHIBIT # 19  BOOM BARGE AND VAC-TRUCK(South Bank)
   f  *
   EXHIBIT # 20  DIVERSION BOOM (North Bank)
                  -38-

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had recently attended an OSC training course conducted by
the EPA in Athens, Georgia.

These personnel were resourceful, they had a background of
oil spill experience to draw upon and they were dedicated
to solving the problems encountered.  Such people can work
together effectively without organization charts or specific
guide lines under emergency conditions.  And at the end of
the first day's activities, the ground work had been laid
for mobilizing an effective operation.

On 29 June progress was made on administrative matters and
on assembling the materials and experienced personnel needed
for an expanding effort.  Cdr. Hanson requested immediate
orders to transfer Chief Don Alberts from USCG Base Yorktown
to temporary duty with the National Strike Force at Potts-
town.  Chief Alberts was experienced in many phases of oil
spill operations and was appointed Technical Assistant to
the OSC.

Additional office space was an urgent requirement.  Through
Mayor Yerger the OSC obtained space at the Washington Elem-
entary School in Pottstown.  The quarters were suitable for
the OSC Staff and the National Strike Force and were used
until the entire operation was terminated at the end of
September.

By the end of the day, testing equipment for river bottom
samples had arrived, 16 Coast Guard Personnel were on the
scene including a cadre from the Pacific Strike Force at
San Francisco.  The Pennsylvania Department of Environmental
Resources was asked to supply a staff man for liason pur-
poses but the flood effort had taken precedence and they
were unable to comply.

Several surveys of the area were conducted by air and by
ground transportation.  Reporters from the news media trav-
eled throughout the area,  usually accompanied by the OSC
or Coast Guard personnel.   Mr. Furia,   Regional Administrator
of EPA-Phila took part in surveys and outlined legal problems.

Top priority in combating the oil spill was to reduce leach-
ing of oil from the lagoons and to protect the water intakes
of cities down stream of Douglassville.   Deflection booms
were installed around the water supply intakes at Pottstown
and at Pennhurst,  at Black Rock Dam, and Kenilworth, but
other clean-up operations could not be effective at this
early date because rains had raised the level of the river
again and this secondary flood did not crest until late on
the 29th.   Ground travel was restricted in many areas,  and
                           -39-

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air survey was restricted because of much of the polluted
area was shielded from view by foliage.

Nevertheless, the contractors were set to work on oil re-
covery operations.  Clean Water, Inc. began installation of
a filter fence at Douglassville Bridge duplicating a fence
which had been at that point in the later stages of Schuyl-
kill One.

Under Water Technics, Inc., began the placing of diversion
booms at various sites where heavy concentrations of oil on
the river could be guided into quiet coves or back waters
for skimming operations.  (Exhibit 20,21)

The Corps of Engineers had taken emergency measures to
protect the Phoenixville Water Supply inlet.  A deflection
boom had been installed.  The Strike Force, now on hand with
contractor crews working on the river, assumed the respons-
ibility for maintaining that protection.

Air and ground transport were planned for news media, Mr.
Furia, Mr. Massey and Cdr. Hanson.  Briefing sessions were
provided.

On 30 June the rain had stopped and there was welcome news
that the water was no longer rising.  Oil continued to flow
into the river as a result of the rain and a heavy sheen of
oil was visable.

A third contractor had been employed.  Nepco, Inc. from
Connecticut arrived on the site with two trucks, equipment
and five men.  They were assigned to a third area of oper-
ations.

Additional personnel from the Pacific Strike Force arrived
bringing the Coast Guard total to 29 and to 10 from the EPA-
Philadelphia.

The problem of cleaning or removing polluted foliage was
pressing.  (Exhibit 22)  Joint discussion with the Penn-
sylvania Bureau of Sanitation engineers and the USC of E
brought promise of additional manpower on that project.  In
addition, state and county agriculture specialists expressed
the belief that oil covered branches and leaves need not be
stripped from trees.  It was felt that such action would be
more likely to kill the trees than would the coating of pol-
luted oil.  Mr. W. R. Ruckelshaus, Administrator of EPA,
arrived for a survey, briefing and a description of problems.
Disposal of polluted materials was high on the list and the
possibility of incineration was discussed.
                          -40-

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 EXHIBIT #21  DIVERSION BOOM (South Bank)
EXHIBIT # 22  POLLUTED FOLIAGE WAS NOT REMOVED
                     -41-

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Contractors completed work on two filter fences and started
spreading absorbents on the river banks.  The value of fil-
ter fences was questioned and a survey of their effectiveness
was planned.

Fiscal arrangements with contractors began to emerge as a
difficult problem.  Contracting officers understandably
hoped for firm estimates of the work to be accomplished, but
such estimates could not be supplied at this date.

Every day brought its list of new areas to be cleaned, un-
foreseen problems of transportation and collection of oil
soaked debris.  The problems seemed likely to continue in-
definitely.  (See special reports section)

On 1 July  the water level was definitely receding and the
oil sheen was still visable on the river surface.

Equipment deployment and clean-up operations gathered momen-
tum.  The Strike Force received three boats and a truck and
built one raft on the site.  The Pennsylvania National Guard
provided a helicopter and capable pilots throughout daylight
hours (Exhibit 23).  Pennsylvania C. of E. provided a work
barge and contractors ordered more vacuum trucks.

Special problems required more intensive investigation and
the OSC arranged a conference with the C. of E. in Pottstown
to discuss the removal of oil soaked foliage. (Exhibit 24)
Special over-flights were planned to locate areas which re-
quired priority action and Ocean Science and Engineering,
Inc. personnel arrived to begin a program of water sampling
and technical field support.

The Pilot Research and Development Corp. employed to consult
on chemical problems suggested the possibility that contam-
ination might be present in the river bottom area due to the
concentration of poisonous materials in the oil sludge.

After three days operations, it became evident that the filter
fences were not as effective on this spill as had been hoped.
They required excessive maintenance, the sorbents had to be
replaced frequently, the sorbents were expensive and their
capacity to clean-up the oil sheen was not sufficient.  A
decision was made that no more filter fences would be in-
stalled.

On 2 July  the f]ood waters were at normal level within the
river banks and the river was flowing at about 2.5 to 3 knots
in Pottstown at the Hanover Street Bridge.
                         -42-

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EXHIBIT # 23  PENNSYLVANIA NATIONAL GUARD HELICOPTER
   EXHIBIT #  24   OIL  SOAKED FOLIAGE
                  -43-

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Hot weather accelerated the evaporation of oil from ground
and foliage.  There was a possibility that fumes could be-
come explosive and generate a fire hazard.  Local and State
fire officials were asked to investigate.

Ocean Science and Engineering reported that the sludge con-
tained 16,500 parts per million of lead.  This is an unus-
ually high lead content.  It is considered dangerously toxic
and it suggested the need for immediate analysis of its pot-
ential for poisoning by contact and drinking water used by
animals.

Reaction to that report resulted in the following:

     1.  All land-fill disposal plans were halted.

     2.  The City of Philadelphia started checking its water
         supply for lead content.

     3.  The State of New Jersey was notified and the OSC
         agreed to take back 10,000 gallons of waste already
         dumped in a New Jersey land-fill.

     4.  Pennsylvania Soil and Conservation Services notified
         farmers and dairy men.

     5.  The water sampling program was expanded.  The Penn-
         sylvania State emergency office in Reading agreed
         to assist this effort.

     6.  Decision made to use railroad tank cars and hopper
         cars for temporary storage of oily waste.

     7.  The news media warned the public of the dangers of
         any contact with the oil sludge.

     8.  The search for suitable disposal sites was continued.

Ocean Science and Engineering and the Pennsylvania Dept. of
Agriculture predicted that most trees would survive the oil
coating on their leaves.

On 3 July  the danger of any future flooding was past but,
the oil sheen continued on the river and was expected to
increase, because rain showers and hot sun caused additional
leaching of oil into the river.

The search for temporary storage produced five railroad tank
cars in North Carolina.  Delivery of the cars  across Vir-
ginia and Pennsylvania on five railroad systems required in-
tensive expediting.
                          -44-

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Cdr. Hanson handled this problem and worked with railroad
offices in Pottstown and Reading, with Mr. Iverson of the
Interstate Commerce Commission and Major O'Leary of the
Department of Defense Transportation Office in Brooklyn.
After cars were located and needed repairs were planned,
Lt.  William Mueller of the Pacific Strike Force was as-
signed to follow through on the details.  Continued pres-
sure brought results and the project eventually dispatched
more than 10 loaded cars per day to a disposal site recom-
mended by the Pennsylvania Department of Environmental Re-
sources .

The  presence of lead poisoning in the polluted area offered
such a threat to residents of the area that the Pennsylvania
Dept. of Environmental Resources found necessary manpower to
coordinate with Strike Force activities.  All local water
companies, civic officials, EPA-Phila and the DER met in
conference with Mr. Kenneth Biglane of EPA, OHM-Wash., D. C.

It was finally decided to discontinue the filter fence at
the  Douglassville Bridge.

Commander Robert Hanson of the Strike Force and Mr. Thomas
Massey, OSC, agreed that additional help was needed to pro-
vide a documentary record of the Schuylkill Two and the op-
erations of the Strike Force.  The authors of this report
received telephone notice of this decision at 15:00 hours
local time on this date.  Mr. Altenburg and Mr. Kirk of
the  documentation team departed from Portland, Maine that
evening and arrived in Pottstown on 4 July 1972.

On 4 July the flood waters had subsided and the river was
inside its banks.  A heavy oil sheen was apparent on the
river surface.

Members of the documentation team arrived early on 4 July
and  signed in.  The receptionist's desk found good motel
accomendations promptly and arranged for a helicopter over-
flight of the area and for a briefing session with Thomas
Massey, OSC, and Cdr. Hanson of the Strike Force.

It was immediately evident that the operations room for
Schuylkill II was functioning far better after 5 days
occupancy than had been the case on Schuylkill I.  The room
was  larger, maps of the area were adequate, the communications
system included recorders, video tape equipment and copying
machines.

Sections of the room were adequately marked:

     1.  OSC desk                   5.  Legal

     2.  Reception area             6.  Public Affairs

     3.  Coast Guard Operations     7.  EPA

     4.  Contracts                  8.  Office Services
                          -45-

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There was also a large conference room for briefing sessions
and projection of video tapes.

Each section was staffed with at least one specialist plus
assistants, had its own phone and was functioning with some
effectiveness.  The administrative groups were handling most
of the routine contacts and house-keeping chores and the OSC
and Coast Guard Strike Force personnel could concentrate on
the problems of the flood and spill.

By this time the clean-up operation, was spread over an area
of 15 miles on both sides of the river.  After a first re-
connaissance of the area on 4 July, it was evident that a
lot of work was being done, but there were several problem
areas which would require better direction and more super-
vision.

There were:

     1.  Planning and Supervision of Contractor Operations

         This included the assignment or work areas, com-
         munications problems, clean-up techniques, addit-
         ional manpower requirements, sources of materials
         and supplies, fiscal arrangements, deployment and
         use of equipment, scheduling of daily briefing
         sessions with contractors.

     2.  Disposal Problems

         These included methods for picking up and collecting
         oil soaked foliage and debris, pools of free oil and
         topsoil covered with oily sludge.

         Temporary storage for large quantities of the polluted
         materials was an intermediate operation to be followed
         by transport to a final disposal site.  No adequate
         disposal sites were available.  Being considered were
         land fill sites, refineries for the processing of free
         oil and an incineration process for burning foliage
         and branches.

     3.  Health Problems

         The public, workers and livestock in the area were
         exposed to poisoneous hazards.  Public health officers
         were alerted to the problem and asked to  set up a
         safety 'program.

     4.  Support for the Labor Force

         It was evident that the labor force would reach
         several hundred people before the job was finished.


                          -46-

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          Many of these were transient workers who required
          housing and food in addition to protective clothing
          and transportation.

At this point the daily roster listed 24 EPA personnel and
nearly 30 from the Coast Guard.  The problem of keeping Key
Personnel advised of the day to day developments prompted
OSC Massey to initiate a series of daily briefings, usually
in late afternoon to review the major problems and to receive
suggestions for their solutions.  In many cases, decisions
could be made on the spot after hearing from various depart-
ment heads concerned.  It became necessary to schedule these
early enough in the afternoon to give contractors time to in-
corporate the decisions into their work schedules for the fol-
lowing day.

Typical of the sessions were the items discussed in the fol-
lowing paragraphs:

Lt. John Spreter of the Strike Force pointed out that vacuum
trucks in the Berks area were full of liquid oil and sludge
and had no place to dispose of their contents.  He suggested
that these trucks be permitted to unload their contents into
one of the Berks lagoons for temporary storage until a per-
manent disposal site could be found.

Search for a disposal site was not successful and showed no
promise of being completed within the next 48 hours.  So per-
mission was requested and obtained from EPA-Philadelphia to
repair one of the lagoons at Berks, and to use it for tem-
porary storage.  It was agreed that the lagoon would be emp-
tied permanently just as soon as the disposal problem could
be solved.

Cdr. Hanson reported that 20 railroad tank cars had been
started toward Douglassville but their arrival was indefin-
ite.  Also, the hopper cars being procured required repair-
ing and sealing of the bottoms so that oily debris would not
leak out in transit.  It was estimated that upwards of 50,000
cubic yards of oil soaked debris would have to be transported
in those cars to some as yet unknown site.

It was reported that contractors were frequently delayed in
their operations pending receipt of specific instructions or
permissions on environmental problems.  Chief Alberts sugg-
ested that a Coast Guard officer and an EPA man should be
assigned to work with each contractor in the field and to
make decisions on operations and environmental matters in
the area served by the contractor.  This procedure was put
into effect and later proved to be very successful in avoid-
ing delays pending a decision from the OSC.
                           -47-

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Groups working on clean-up had reported that wide  spread
use of absorbent was not working as well as expected and
that  its continued use  should be reviewed and evaluated.

Islands began to appear in the river as the level  of the
water dropped.  Pools of free oil were apparent on many of
these islands.  This raised the problem of transporting that
oil to the mainland for collection and disposal.   Manpower
seemed to be the only immediate answer and bucket  brigades
were  formed.  This proved to be time-consuming and back-
breaking work, but it did move a large volume of oil.
(Exhibit 25)

Warm  muggy weather was  releasing fumes from the oil in low
lying areas along the river bottom and this raised the pos-
sibility that toxic fumes were being breathed by the workers.
It was agreed that no workers would stay in such an area  for
longer than six hours and that supervisors would watch care-
fully for any symptom of distress.  It was also agreed that
more  help and medical expertise should be requested to mon-
itor  this problem.

'Contractors had been requisitioning additional personnel  and
at the close of business on 4 July, Clean-Water, Inc. was
using 60 laborers, Nepco had 35 to 40, and Underwater Tech-
nichs had employed 20 in their respective areas.

The clean-up and collection of polluted debris had not yet
reached an effective stage.  Each contractor was confronted
with  a series of different problems in his own area and he
tended to use his own equipment in the manner that seemed
the best to his own group.  There was no uniformity in clean-
up methods and it was very evident that the clean-up process
as presently operated was expensive, slow and not  always  the
best  method for the environment.

The one common denominator which would help resolve this
problem was to find a satisfactory disposal site for pol-
luted waste.  Efforts were going forward on many fronts to
solve this problem.  Unfortunately, in the time interval
between Schuylkill One  and Schuylkill Two, the general public
had become very "gun-shy" of any material contaminated by
oil.  And public resistance to normal land-fill disposal
was encountered in nearly every area that was investigated.

Nevertheless the investigation was continued and the fact
that  it was ultimately  solved was another indication of the
determination with which the OSC, the EPA and the  Strike
Force staffs attacked these new and difficult problems for
which there was no precedent.

The problem of cleaning oil off the surface of the river  was

                           -48-

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EXHIBIT # 25  "THERE'S NO SUBSTITUTE FOR MANPOWER."
EXHIBIT # 26  DIVERSION BOOM AT HANOVER ST. BRIDGE
Note:  RIVER FLOW IS FROM BOTTOM TO TOP.  SHEEN TO
       LEFT OF BOOM IS COLLECTED INTO A SLICK OF
       HEAVY OIL ALONG BOOM, LEAVING SURFACE OF
       RIVER CLEAN DOWN-STREAM OF BOOM.
                     -49-

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not receiving sufficient attention.  Oil sheen on the river
was a hazy light blue in color.  Coverage was spotty.

Consequently, it looked relatively harmless.  And priority
was being given to the heavy accumulation on the river banks
and the pools of free oil.

Nevertheless, a great deal of free oil was still showing on
the surface of the river.  The only attempt to attack that
problem had been the initial installations of filter-fences
which proved ineffective because of high currents and high
volume of oil earlier in the spill.

Fortunately, no one wasted time by trying to put a boom dir-
ectly across the river to contain the sheen.  All the con-
tractors, on the job had learned from previous experience
that such a boom would have been ineffective.  They did bring
to this operation some knowledge of diversion boom techniques
and such booms were installed at several points where heavy
leaching of black or brown oil was flowing from the river
banks.  (Exhibit 26)

Here again, however, there was no uniform method for clean-
ing up the pools of oil which collected in the downstream end
of these diversion booms.  At one point, vacuum trucks were
used;  at another a bucket brigade was used to clean out the
pools and still other cases where diversion booms were used,
it was reported that the booms were left unattended and the
oil eventually underflowed the boom when the capacity of the
boom was exceeded.

The situation was not surprising.  Very few people have had
experience with diversion boom  techniques and the recovery
of oil from the pool created by those booms.

The OSC, Mr. Massey, had not had direct experience with that
problem and he depended on Strike Force personnel for solu-
tions to it.  They, in turn, were primarily concerned with
starting an effective clean-up along the river banks and
with coaching the operations of the contractors.  Conseq-
uently, the problem of cleaning oily sheen from the surface
of the river remained on the research and survey agenda for
several days.

In summary, Schuylkill Two had generated many problems which
had never been encountered before.  Some problems were quickly
solved, others were being researched carefully and methodi-
cally and still others were baffling to all concerned and
would require continuing effort in order to arrive at a work-
able solution.
                           -50-

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On July 5  the official records indicated that clean-up
operations were beginning to gain momentum.  It was estim-
ated that 24,700 gallons of liquid oil and sludge had been
collected on that date.

Progress was evident on several fronts and the OSC planned
a comprehensive review of the operations for late afternoon.
This type of daily meeting with staff and key personnel was
proving to be very effective in keeping all phases of oper-
ations on target.  All participants at the meeting had an
opportunity to express opinions, report new problems, and
recommend solutions.  The following minutes of the meeting
(compiled by documentation team) are indicative of the many
subjects covered on this date:

     1.  Health Problem.  It had been recommended that per-
         sonnel who experienced long exposure to polluted
         air should be given blood tests.  There was also a
         continuing sampling program utilizing hydrocarbon
         air samplers of samples by Air Emergency Episode
         Office in Research, Triangle Park, North Carolina
         to detect the presence of any hydrocarbons in the
         air.  Preliminary tests indicated that no danger -
         ous concentrations of fumes were present, but con-
         tinued monitoring of the problem was planned.  (Air
         pollution never did become dangerous.)

     2.  Drinking Water Supplies in the area were being
         sampled periodically.  No dangerous conditions
         developed.

     3.  Liquid Oil removed from pools was being stored in
         the lagoons at Berks Assoc.  on a temporary basis
         as authorized.

     4.  More booms were deployed to control leaching from
         the river banks into the water.  Continued rain
         was expected to accelerate the leaching process.

     5.  Bucket brigades were working effectively to re-
         cover oil from pools in remote areas and on the
         islands.

     6.  The drum removal program was going forward sat-
         isfactorily.  The Corps of Engineers was supply-
         ing a Land-Rover to haul drums to a storage site
         set up in Pottstown where local police provided
         security for the storage area.

     7.  Liquid oil recovered was being stored separately
         from recovered sludge.  It was hoped that a refin-
         ery could be found to process liquid oil while
         sludge was expected to go to a land-fill disposal site.


                          -51-

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 8.   The rail car procurement program was making progress.
     20 tank cars were on order and the first one was ex-
     pected on 7 July.  10 hopper cars were available and
     holes in their flooring were being sealed.

 9.   The state of New Jersey again emphasized that there
     should be no more dumping of oil waste within its
     boundaries.

10.   County Commissioners of the three counties  in the
     polluted area passed resolutions confirming that
     the clean-up operations by the Federal Government
     were necessary and legal and should be continued.

11.   Plans to incinerate polluted waste and debris and
     to monitor lead emissions were continuing.   A test
     pit was being prepared on the grounds of Berks Asso-
     ciates and the first test was planned for 7 July.

12.   Extra labor was required.  Originally 500 people were
     requisitioned.  But the logistics of housing, sleep-
     ing and feeding so many caused a reconsideration.
     Local Red Cross and Salavation Army facilities had
     already exhausted their resources and were  unable to
     provide further assistance.  Personnel needs were
     revised to a level which could be administered by the
     contractors.

13.   Ocean Science and Engineering, Inc. personnel re-
     ported that open pit burning of polluted materials
     would probably be unacceptable because of excessive
     air pollution.

14.   Mr. Van Cleave of EPA and Chief Alberts of the Strike
     Force reported good progress on stationing a Strike
     Force officer, plus an EPA representative to act as
     a supervisory team with each contractor.

15.   Operational areas for each of the three contractors
     were reviewed and assignments were revised.

16.   Lt. Kangeter of Base Gloucester asked about possib-
     ilities of a final check point to prevent surface
     oil from flowing downstream beyond Black Rock Dam.

17.   Mr. Van Cleave reported in detail on operational
     progress for this date.  At the Berks Associates
     area, clean-up in the fields was moving forward.
     Pools of oil in the Hanover Street area were being
     cleaned up by hand on the islands in the river, and
     additional diversion booms had been placed around the
     island.
                          -52-

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     18.  Opinion was expressed that  substantial  increase
         would be needed  in the  labor force and  the poss-
         ibility of using the National Guard was discussed.

     19.  Additional tank  trucks  were needed, and the Gov-
         ernor of Pennsylvania authorized un-licensed tank
         trucks to operate on highways during the emergency.
         State Police were notified.

It was evident that the efforts  of the OSC and his staff were
beginning to whittle away at the problems, but the major prob-
lems of disposal, efficient clean-up operations, health situ-
ation, contract administration and fiscal problems remained.

On 6 July  a report was received that the State of Pennsyl-
vania had located a possible land-fill site.  This was most
encouraging.  It indicated that  a break through in the dis-
posal problem might be imminent.

Continued sampling of air, water and the materials in the
polluted area indicated that there were no dangerous con-
ditions.  Recovery of liquid oil from swampy areas along
the  river was accelerated by the use of mule and horse
power.

The  first railroad car arrived and was loaded with sludge.

Mr.  Furia,  the EPA Regional Administrator made an on-scene
inspection.  Mr. Kenneth  Biglane of Washington EPA, OHM, was
present for an extended visit, and for survey of overall
activities.

Pick up of liquid oil and polluted debris was accelerating.

The Corps of Engineers unit stationed at Pottstown reported
that it had completed its plans for cleaning up of foliage
and debris OP the river banks and would be ready to start
operations on a small scale within a few days.

On 7 July  occasional rain showers persisted, and an oily
sheen was still apparent  on the river surface but the clean-
up operation on the banks was accelerating.

Contractors needed additional supervisory personnel because
more manual laborers were employed.

Berks Associates prepared to resume oil reclaiming operations
but they planned no further use of the lagoons.  Everyone con-
cerned with the operation was agreed that as soon as the tem-
porary storage program at the lagoons came to an end,  the lag-
oons should be eliminated.
                          -53-

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The collection of oil pools and polluted debris on the river
banks and adjacent areas was progressing satisfactorily al-
though there were many areas where mechanical equipment could
not be used, and nothing but manual labor or horse power was
effective.

On the surface of the river, however, it was apparent that a
lot of oil was still present and visible in the form of a
mottled sheen which was occasionally quite heavy.

The possibility of setting up a positive barrier to this oil
was discussed.  Members of the documentation team observed
that diversion booms in use near the Hanover Street Bridge
were proving very effective in collecting sheen from the
surface of the river, concentrating it and then delivering
It to locations at the river banks where it could be re-
moved by skimmers or vacuum trucks.  (Exhibit 26)

The situation was called to Cdr. Hanson's attention and he
agreed that a diversion boom might be extended clear across
the river at some locations where river current was not be-
yond operable limits.

A suitable location was found near the Pennhurst facilities
of the Home Water Company and the placing of a diversion
boom, a shore side settling tank and a skimming operation
was suggested by a member of the documentation team.  Such
a boom would be about 1,300 feet in length.  Additional boom
material would be needed before it could be installed.
(Exhibit 27)

On 8 July  the situation on the river continued much the same.
Local showers were falling on the polluted area, some oil was
leaching into the river and the oil sheen on the surface of
the river was still visible.  Clean-up operations were con-
tinuing.

On this date, major progress was noted on the most trouble-
some problems, which had been confronting this operation.

     1.  Oil Sheen on River Surface

         The OSC obtained permission to install a diversion
         boom across the Schuylkill River with its downstream
         end secured at the Home Water Company at Pennhurst.
         The installation was successful in collecting both
         the oil sheen and floating debris.  It was left in
         position until the entire operation was secured.
         (Exhibits 28 & 29)

     2.  Drum Identification and Disposal

         On the same day, a team of experts arrived from the
         Manufacturing Chemistry Association of the United

                           -54-

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 EXHIBIT #27   DIVERSION BOOM AT PENNHURST



''Note:   RIVER  FLOWS LEFT TO RIGHT
 EXHIBIT #  28.   SETTLING  TANK & BOOM AT PENNHURST
                    -55-

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                                           CN
                                           =«=
                                           H
                                           ffi
                                           X
                                           w
-56-

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         States to assist in identifying the contents of the
         many drums stored in the drum holding area in Potts-
         town.  This promised success in identifying the con-
         tents and returning them to their owners or sending
         them to final disposal destinations.

      3.  Temporary Storage of Recovered Oil

         The use of one of the lagoons at Berks Associates as
         a temporary holding pool for liquid oil was contin-
         uing satisfactorily and it was being monitored by
         the Pennsylvania Department of Environmental Resources
         and personnel from the EPA-Phila.

      4.  Disposal of Oily Waste

         A breakthrough was scored in the disposal problem.
         Montgomery County Commissioners agreed to accept
         sludge and debris at a land-fill site at West Con-
         shohocken, Pennsylvania.  The land-fill site was in
         an abandoned quarry.

         Successive layers of debris were covered with layers
         of earth.  This operation provided much needed cap-
         acity for disposal of the polluted debris.

      5.  Clean-up Methods

         Research was continuing on methods of cleaning up
         fallen trees and other oil polluted debris along
         the river course.  This had been the subject of
         numerous discussions with the Corps of Engineers
         personnel stationed at Pottstown.  It was finally
         agreed that much of the debris on the islands in
         the river and on the lower edges of the river banks
         would gradually clean itself and that complete re-
         moval was not necessary.  Some removal of under-
         brush was necessary so that ground clean-up crews
         could work effectively.   This decision to limit the
         removal of trees and foliage wherever possible, went
         a long way towards standardizing the clean-up oper-
         ation.   It was in accordance with the later decision
         that the oiled underbrush need not be removed just
         for ecological considerations.   (See special report
         section)

As of 8 July operations of the OSC had developed into a
reasonable stable and effective effort.   Production by all
three contractor groups had picked up appreciably,  most of
the major problems were under control or well on their way
to solution and the entire picture took on the aspects of
a job which had finite boundaries.   It was reasonable to

                          -57-

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expect that no major problems would develop in the fore-
seeable future and that the entire operation could look
forward to completion in late summer or early fall.

On 9 July it was evident that the OSC and staff and devel-
oped a vastly improved capability to solve a problem once
it had been properly identified,  and the activities of the
Strike Force were becoming increasingly of a routine nature.
At this point the policy was adopted of phasing out the Nat-
ional Strike Force operation as soon as possible.

Exhibit 30 shows the problems which still required careful
supervision.  The OSC s office would continue its careful
supervision of contractors operations and a new OSC was
scheduled to relieve Mr. Massey.   Planning was needed by
OSC and his staff to provide for final phase-out of the
emergency effort by EPA and the Strike Force and to phase-
in the program for final removal of polluted soil and foliage
by the Corps of Engineers.

Research was continuing on the possible use of incineration
as part of the disposal problem.   Clean-up of debris in diff-
icult locations along the river continued to present material
handling problems.
                            -58-

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-59-

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               NARRATIVE  -  10 July - 29 Sept.
On 10 July Mr. Robert Kaiser, EPA, Philadelphia, head of
the Environmental Emergency Branch for Region III, arrived
on the scene and relieved Thomas Massey as OSC.

Mr. Kaiser's initial actions were to re-evaluate the cap-
abilities of the contractors, to revise their specific
assignments and to start a program of releasing equipment
and reducing the force of emergency personnel as rapidly
as circumstances would permit.

On that same date, a summary of information on drum recovery,
identification, and disposal was delivered formally to the
Corps of Engineers office at Pottstown.  (See summary in
special subjects section.)

On 11 July all booms were removed from the river except for
the diversion boom at the Pennhurst site, a total of 132,000
gallons of oil had been stored temporarily at Berks Assoc-
iates, and plans were being made to release Coast Guard re-
serve personnel on 14 July.  On 13 July, the Pacific Strike
Force Team was released except for 3 men.

On 14 July the shipment of hopper cars to the land-fill
site was increasing.  A definite decision was made by EPA-
Phila. that no open air burning of debris would be conducted
in the Pottstown area or in the Norristown area.

As the activities of the three clean-up contractors were re-
duced and their work forces became smaller, the OSC required
contractors to submit written requisitions for additonal
equipment or manpower for specific situations.  This brought
the expenditure of funds under more direct and tighter control

On about 14 July, Mr. R. E. Hess summarized the current in-
structions on removal of oily sludge from land in the pol-
luted area.  (See special subjects section.;

On 17 July some additional pools of heavy oil were found in
the area between Hanover Street Bridge and Royersford.  This
posed a difficult problem in transporting the oil from the
islands to the mainland.

As the area began to recover from the impact of the flood,
both upstream and downstream of Pottstown, there were in-
creasing reports of pollution from the industrial plants
in the neighborhood.  Each of these was responded to and
investigated by personnel from the OSC office.  Some pol-
lution was caused as a result of cutting oil discharge from
                           -60-

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a steel plant and chemical discharge from a die-casting plant.
Corrective action was obtained from the owners in each case.

On 18 July it was decided to submit POLREPS every other day
instead of every day.   This was another indication that the
clean-up operation was under control and it was becoming
routine, although, there were still about 300 contractor
personnel on the job.

On 19 July che identification of recovered drums was proving
effective.  Some were being returned to their owners.  Others
were being returned to people who could safely use the cont-
ents (owners unknown) and those which could not be so dis-
posed of were scheduled for long term storage at Fort Miflin.

On 20 July the evaluation of the use of chipping machines
proved that the chipping operation permitted a high degree
of compaction in the land-fill and consequently was valuable
because of the space which was saved.  The chips also acted
as a blotter of liquid oil and thereby facilitated the un-
loading operation.

Heavy duty, vacuum primed pumps were working successfully
to pump oil from islands to the shore for distances of up
to 200 feet.  (See Special Section)

On 22 July the National Strike Force Team was released from
its responsibilities and the OSC, Region  III of EPA con-
tinued the clean-up operations without their services.

On 28 July there was some indication of a growing problem
in the field of contract administration.

Reports were filtering down to the OSC from various sources
that the Federal Government had placed a limitation on the
funds to be spent on the Schuylkill Two operation and that
the limit had already been exceeded.  This raised the prob-
lem of honoring contracts made in good faith by the OSC
before such a limit had been imposed.

The problem may have been triggered because of some questions
about engineering contracts set up early in the emergency. At
any rate, on 28 July a communication from the office of the
OSC stated that the matter had been discussed at headquarters
of EPA and at headquarters of USCG and that it had been agreed
that any requests certified by the OSC to be essential in the
performance of his function under phase II and III (of the
National Contingency Plan) would be honored by the revolving
fund.

It is fortunate for the future of the On-Scene-Coordinator
activities and the success of the National Contingency Plan
that the decision was made to honor these committments.  They
were obviously made in good faith and in times of great stress.

                          -61-

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Any action by the federal government to disavow such commit-
ments would have made it very difficult in the future to ob-
tain whole hearted cooperation on an emergency basis from
contractors and others who could assist in emergency  operations.

On 31 July there was an indication that the  Corps of Engineers
was slowing down its recovery, storage and identification of
drums for fiscal reasons.  At that time there were approximat-
ely 1,000 drums estimated to be loose in the area and conseq-
uently, they were a hazard.  This is another example of the
need for adequate funds to do a complete and an effective job
on these major disasters.

On 2 August Mr. Malcolm Castor summarized the entire drum
clean-up situation in EPA, Region III, and listed 1,000
drums at Reading, Pa. nearly 300 at Norristown, hundreds of
barrels and drums reported below the dam on  the Potomac River
near Martinsburg, West Virginia and other drums submerged and
half submerged in the Delaware River below Philadelphia.

On the same day, the approaching school term made it necessary
that the OSC office restrict its activities  to a single room
in the Washington Elementary School at Pottstown, Pennsylvania.

On 8 August the job of pumping out the lagoons at Berks Asso.
was commenced.  A fleet of trucks had been assembled for this
purpose.

Through the later part of August, Contract Administration and
cleaning up the loose ends of contracts was  a major activity
in the office of the OSC.

On 17 August the Corps of Engineers picked up activity on
drum removal.

On 1 September  the OSC's office estimated that 211 hopper
cars had been loaded with debris.

On 20  September operations of Clean-Water, Inc. and of New
England Pollution Control  (Nepco) were terminated.  The office
of the OSC started to prepare an inventory of equipment and
materials purchased by the revolving  fund and used on this
spill  situation.  Underwater Technics ,  Inc. was still active
cleaning hopper and tank  cars and returning  them to the rail-
roads .

On 29  September  the office of the OSC issued POLREP 43,  its
final  POLREP on the Schuylkill River  Flood-Oil  Spill.

The POLREP indicated that  there  was no visable  sheen on the
river, a total of 220 hopper cars had been unloaded at the

                           -62-

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disposal site containing a total of 13,957 tons of oil soaked
debris.  103 cars had been completely cleaned and returned to
the railroads.

Operations of Underwater Technics,  Inc.  were terminated as of
30 Deptember 1972.  All operations  had been completed and the
emergency phase of the case was considered closed.
                          -63-

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           PREPAREDNESS FOR OIL SPILL EMERGENCIES
The Schuylkill One emergency took place only four months after
the National Contingency Plan was published.  Mobilizing to
meet that emergency was "a first time" experience for all con-
cerned.

In Schuylkill Two, the initial flood emergency found Base
Gloucester alert to the requirements of the occasion.   Base
personnel had made progress toward developing a Contingency
Plan for the Delaware Basin Area.  Some contact had been made
with oil terminal operators on both sides of the river and the
beginning of an oil clean-up association had been made.  Plans
had been drawn up for establishing a Regional Response Center
at Base Gloucester to serve any emergency.

Consequently, when the Schuylkill River flooded, the search
and rescue mission, the surveillance mission and the barrel
and drum recovery program were handled with a minimum of
delay.

When the Regional Response Team was activated on 23 June, the
Regional Response Center was set up over night.  Facilities
for the OSC and his staff were immediately available and far
more complete than in Schuylkill One.

The National Strike Force, as reported in the narrative, was
alerted to the possibility of an oil spill and several of the
personnel, obviously, "had their bags all packed" by the time
it was decided to activate the group.  The National Strike
Force traveled to the Pottstown area with a good nucleus of
equipment for assisting the On-Scene-Coordinator.  Emergency
service was nothing new to Strike Force personnel and they
showed a commendable ability to work on priority items immed-
iately.  They lost no time in requesting assistance and in
many cases recognized the need for help before the need became
acute.

Direction and supervision of independent contractors was very
difficult in the initial stage of the emergency because of
the flood conditions and the unforeseen problems due to a
coating of dirty oil over 15 miles of the Schuylkill River
Valley.

The OSC, Mr. Thomas Massey, had attended OSC training courses,
but he had not experienced the oil clean-up problems that con-
fronted him on the Schuylkill.  Under the circumstances, his
reaction was to lean heavily on Strike Force personnel for
technical assistance while he organized and directed the ad-
ministrative staff.  This turned out to be a good division of
responsibility and the emergence of an effective team effort
                           -64-

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was apparent as early as 4 July.  In a very few days, the
Strike Force demonstrated its ability to identify problems,
to act upon them immediately if necessary and to research
them carefully when time permitted a search for the best
solution.

All personnel learned a great deal from this experience and
it is safe to predict that experience so gained will show to
good advantage when and if the Strike Force is confronted
with another oil spill emergency.

Various aspects of this operation are reported in more detail
in the discussions of special subjects which follows.
                           -65-

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         EVALUATION OF THE NATIONAL CONTINGENCY PLAN

         	AND POTENTIAL SPILLS	


The National Contingency Plan of June, 1970, emphasizes the
problem of responding to an oil spill, and makes reference
to "potential" spills in Paragraphs 306.1, 505.1, 506.2-4 and
506.2-5.  Paragraph 506.1 directs that "when the OSC receives
a report of a spill, or of a potential spill, the report should
be evaluated."

If a potential spill is reported or if a potentially dangerous
situation is known to exist, the evaluation would probably be-
come the responsibility of a pre-designated Regional OSC who
might or might not have the experience to evaluate a potential
hazard of major importance.

Evaluation of a potential spill should be performed by a per-
son trained and experienced in oil pollution control and clean-
up operations.  Fast action is always imperative.  Discovery of
the Schuylkill Two oil spill on June 23 resulted in immediate
activation of the Regional Response Team and the Regional Re-
sponse Center, but assistance from the National Strike Force
was not initiated until June 28.  Reports concerning other pol-
lution incidents have indicated similar delays.  (For example,
the USNS Towle Spill in New York Harbor in 197L) Until such
time as there are trained and experienced oil control and clean-
up personnel in all of the several EPA regions and Coast Guard
Districts, those regions should be encouraged, or even directed,
to call on the National Strike Force or  more experienced EPA
personnel for an independent evaluation of any hazard which
might become a major spill.  (As defined in paragraph 105.8)

It is recognized that immediate activation of the National
Strike Force on every potential spill is not in accord with
the intent of the National Contingency Plan, but use of NSF
personnel to evaluate is suggested as a stop gap measure until
trained and experienced personnel are available at all Regional
Response Centers to deal with moderate or major pollution in-
cidents.
                           -66-

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The National  Strike Force  seems  to  be  the  logical  group
with knowledge and operations  caoabilitv to  permit effec-
tive preventive action an emergency such  as this, but there
seems to be no specific  provision in the National  Contin-
gency Plan for taking preventive measures  of such  scope
unless the forecasts of  danger are  specific  and immediately
threatening.

On the basis  of present  authorizations,  any  major  strike
force operations which eventually prove  unnecessary would
certainly be  criticised  as too costly.   In this instance,
hind-sight suggests that such  expenditures would have  paid
for themselves several hundred times over.

It might be well to review the provisions  of the National
Contingency Plan with a  view toward incorporating  author-
ization for preventive measures  and providing guidelines
for the Strike Force Commander so that he  could act instant-
ly on his own responsibility.

It is our recommendation that  the sections of the  National
Contingency Plan which call for  immediate  response to  an
alert should  be reviewed and perhaps revised to insure that
personnel from the National Strike  Force are available to
assist the pre-designated OSC in evaluating the  threat of a  major oil
spill.

Such evaluation should not be  delayed  pending identification
of "the responsible party" and pending that  party's own dec-
ision as to its ability  to control  the potential spill.   Such
determinations inevitably require valuable time and they may
be unduly influenced by  the responsible  party's financial
status, sense of public  relations,  and knowledge or lack of
knowledge of  oil spill clean-up  technology.  An  early evaluation
of a hazardous situation by the  pre-designated  OSC assisted by
experienced personnel from the National  Strike  Force  could
                           -67-

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provide hard information which would give immediate dir-
ection to control and clean-up activities if they should
eventually become necessary.

In the case of Schuylkill Two, the initial response to the
flood and to the oil spill which followed it, was in accord-
ance with the National Contingency Plan.

In retrospect, how effective was the Plan in the first few
days of the disaster?

Generally, it was a source of considerable strength because
it made money, equipment and personnel available on a scale
never before possible in an oil spill situation.

Specifically, it did not seem to provide for the flexibility
of organization and the instant availability of trained per-
sonnel that this very complicated situation required.

The following items are suggested for review and possible
change in the next up-dating of the Contingency Plan.

     1.  The OSC for a major pollution incident should be
         chosen for his ability to handle the situation at
         hand, even if this means bringing in an OSC from
         another region.  In other words, if an experienced
         OSC is not available in the region of a spill, there
         should be no hesitation in bringing in a specialist
         from another region, from the Strike Force Team, or
         from any other source available.  The pre-designated
         OSC in the spill region could then serve on his staff,
         gain valuable experience and be better prepared for
         the next emergency.

     2.  Experienced personnel should be requested to make
         an immediate and independent evaluation of the dis-
         aster potential in any major oil pollution incident
         which occurs or which threatens to develop.

     3.  The National Contingency Plan should expand on the
         responsibilities of Strike Force personnel in pre-
         venting oil pollution at locations where known
         hazards exist.

     4.  OSC Training Programs should be set up for all Coast
         Guard or EPA personnel who might be in line for such
         positions.
                             -68-

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                RELATIONS WITH BERKS ASSOCIATES
In Schuylkill One, Berks Associates was very definately the
"Villain".  In Schuylkill Two, Berks Associates was the "Vic-
tim" of an almost unpredictable disaster.  Mr. Ruckelshaus,
Administrator of EPA, called it an "Act of God".

In the period between Schuylkill One and Schuylkill Two, Berks
Associates was bankrupt, but it had resumed operations in ac-
cordance with court orders resulting from legal actions fol-
lowing the first spill.

In Schuylkill Two, there was little that the company could do
to assist the clean-up operations, but to cooperate with the
OSC to the best of its ability.

As might be expected, many individuals were incensed that all
the lagoons had not been emptied permanently after Schuylkill
One and there were news reports of impending legal and polit-
ical moves against the company and proposals to shut down the
plant permanently.

However, there was a realization that Berks Associates per-
forms a very useful service by recylcing waste crank-case
oil and turning it into a useful product.

Furthermore, recent improvements in the process have elimin-
ated the need for storage of waste sludge in lagoons.

As this report is written, the concensus of opinion seems
to favor continuance of operations of the plant, always pro-
vided that the use of the lagoons is never resumed at that
location.
                          -69-

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               USE OF INDEPENDENT CONTRACTORS
Clean-up of Schuylkill Two required the efforts of hundreds
of laborers and many units of powered equipment.  Local con-
tractors are usually the best source for both labor and equip-
ment.  If the contractor has had previous experience on oil
spill work, he may provide valuable skills and special know-
ledge.  Hopefully, he will be resourceful and innovative in
using his equipment to overcome problem situations.

On Schuylkill Two, three contracting firms were hired to per-
form the emergency pick-up of oil and polluted debris.  Each
firm had worked on previous spills, including Schuylkill One,
and was acquainted with the area.

In addition many small contractors were hired on special as-
signments of short duration when extra vacuum trucks, tanker
trucks, pumping equipment, and other items were needed.

Contractors are a valuable resource in emergency situations,
but they can also be the source of fantastic costs for supp-
lies, manpower, standby charges for idle equipment and over-
selling of proprietary items.

Control of the contractor operations should be given special
attention in training potential OSC's because the costs of
such contractor services are usually the most expensive items
in the entire clean-up operations.

In an emergency, for example, contractors may purchase shovels,
protective clothing, life jackets, or buckets in quantity and
issue them to laborers on an "expendable item" basis.  On one
spill of record where about 100 laborers were employed, over
400 life jackets were issued and never recovered.

Some lack of control is to be expected, particularly during
emergency situations in the early days of a clean-up oper-
ation, but someone on the OSC's staff should concentrate
on the control of contractor expenses at the earliest poss-
ible moment.

Cost benefits must also be kept in mind.  For example, the
bull-dozer hired to close leaks in the lagoons on 27 June
prevented the loss of perhaps 1000 barrels of oil waste.
The bulldozer might have cost $1,000. for 10 hours work,
but clean-up could have cost $20,000 or more if the oil
had escaped, necessitating later pick-up by hand method.

The three major contractors hired on Schuylkill Two were
experienced and capable.  They responded promptly when
called and performed many emergency tasks on the basis of

                         -70-

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verbal agreements.  During the first week of the emergency,
many pieces of powered equipment were brought to the area
by these contractors and put into operation or placed on
stand-by status at various locations in the spill area.

Formal contracts, accurate records of equipment and man-
hours under such circumstances are unlikely.  Verbal agree-
ments between the OSC and the contractor are necessary if
action is to be achieved in the time available.

In this spill, contract officers came on the scene after the
fact and did their best to review existing agreements.  Grad-
ually, the contract situation was recorded accurately and eff-
ective follow-up was possible.

Under such circumstances, some waste is inevitable.  It would
be very helpful if regional Contingency Plans contained some
basic guidelines for the use of contractors in an emergency.
Policies on overtime, stand-by charges, subsistence, housing
and rating of personnel as skilled, un-skilled or specialist
could be settled in advance.  Failing that, the OSC or his
contracting officer should have a reference list of equ_p-
ment costs, and labor rates to give some indication of an
acceptable level for such charges.

Obviously, it is highly desirable to have qualified contract-
ing firms available for clean-up in emergency situations.
Any contract matters which can be settled before the fact
should save time and money when emergency action is needed.
Every EPA region should cultivate a good working relationship
with two or more reputable contractors in its district.  The
more people in business, the more reasonable will be the costs
This whole question of contractor - OSC relationship could
well be a subject for special study under the National Cont-
ingency Plan.
                           -71-

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                    SURVEYS AND RESEARCH
In the early stages of Schuylkill Two, several problems were
encountered for which there was no ready answer.  When immed-
iate action was imperative, such action was based on avail-
able knowledge and best judgement of the OSC and NSF person-
nel.

The major problems required days or weeks of study before a
conclusion was reached.  In several cases the investigation
involved many personnel and use of specialized equipment.

In these cases, special projects were identified and the
responsibility for carrying them to completion was assigned
to a member of the staff on an "ad hoc" basis.  He (or she)
coordinated efforts until the solution was reached.

This procedure was used effectively on several problems, in-
cluding:

          Rail Transport or Polluted Debris
          Removal of Oil Sludge from Land
          Incineration of Sludge and Debris
          Water Analysis
          Storage and Disposal of Drums

Sometimes the problem required the efforts of specialists
from  other Federal or State Agencies or from technical con-
sulting firms, laboratories or industries with special know-
ledge.

When a solution was reached, all persons concerned had to be
notified.  This was done in several cases by publishing a
summary report of the findings and the action to be taken.
See following pages.

This method of "passing the word" worked effectively and
provided valuable data for future use.

Recommendation:  This practice or some variation of it should
be adopted in any case where:

     1.  Notification should go to a number of individuals
         or agencies, or

     2.  When some new technique or procedure might be val-
         uable to other OSC's on future emergencies.
                          -72-

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                                           3 July  1972


                       FOR RECORD
Investigation of  Sludge  Incineration.  At the  suggestion  of
Mr. Washoe,Pennsylvania Department of Environmental Resources,
J. Cox~contacted  the City of Hazelton to investigate the  feas-
ibility of using  their Fluidized Bed Incinerator  for burning
the waste oil sludge.  Discussions with Mr. Bunk  (Supt. of
Sewer Authority)  and Mr. Oscar Thomas, P. E. (Chairman of the
Sewer Authority Board) disclosed the fact that the maximum
design temperature of the incinerator is about 1400  F. Since
the expected temperatures from oil sludge incineration is ex-
pected to be much higher, this alternative was not pursued
further.  The City of Scranton has an Open Hearth Incineration
System which (in  Mr. Thomas' opinion) is subject  to t:>e same
limitation.

Investigation of  Sludge Reclamation.  Mr. Rubert  Mahler,  Vice
President of Northeast Oil Service, called to  offer his ser-
vices to remove the sludge.  He reports his firm  is in the re-
refining business (similar to Berks), and that his operation
produces products (fuel oil, dust oils, etc.) within specif-
ications, using processes (blending and distillation) which
violate no regulations.  His price would be 6-12  cents per
gallon depending  on analysis.  A sample of oil sludge was
given to him 4 July, and Mr. Mahler promised analysis and
price figures within 2 days.

This alternative was discussed with Mr. R. Hess,  EPA, Division
of Oil and Hazardous Materials, Washington.  He reports this
firm has been the subject of some criticism since the operation
can pass the heavy metals on into the finished product (i. e.
home fuel oil).   In burning such a product, the metals can coat
the heat exchanger tubes, requiring expensive maintenance.  This
possibility and criticism was discussed frankly with Mr.  Mahler
who replied:  1)  that his finished products were within  spec-
ifications, 2)  that since the heavy metals had to go someplace,
his process avoided the accumulation of millions  of gallons of
sludge in lagoons, which sometimes produces environmental dis-
asters,  3)  that his firm has done business for  some time with
USCS First District (CDR Hanson was asked to verify the latter
point).

Other Incineration Possibilities.
T)It was reported verbally that Rollins-Purle would not ac-
cept the sludge.  However,  an entry in the log (1 July?)  re-
ports they would accept this.  This should be investigated
further.

2)  National Oil Reclamation Corporation, Hook Road & Commerse
St.,  Bayonne,  N. J.  07002,  is under contract with EPA to  dev-
elop a suitable oil re-refining operation.

                           -73-

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                                             7/6/73


TO:        ALLEN JENNINGS

FROM:      EDWARD LEPLEY

SUBJECT:   SAMPLING AND ANALYSIS OF MUNICIPAL PLANT
           PROCESSED WATER FOR TOTAL ORGANIC CARBON;
           TOTAL ORGANIC CARBON:  HEAVY METALS (Pb,
           Zn, Cd, Cu)
The four plants contacted were:  Home Water Co., Norris-
town Water Works, Phoenixville Water Works, and the Potts-
town Water Works.

Facilities for the analysis of TOC, Pb, Zn, Cd, and Cu
were made available to these plants at no charge with a lab
in Cincinnati, Ohio which would run the said test on a freq-
uency of every two (2) or three (3) days.  Instructions were
given for two (2) plastic containers of one (1) liter cap-
acity marked for time and date of sampling and acid added.
In the TOC sample two (2) ml of concentrated H?S04 per liter
sample is to be added in the heavy metal sample three (3) ml
of 1:1 HNO  per liter is to be added.  Shipments were asked
to be sent Air Express at the plant's expense.  The Cincin-
nati address is:

                       Chemical and Radiological
                       Activities Section
                       Room 705
                       5555 Ridge Road
                       Cincinnati, Ohio  45213

                       Attn:  Mr. Richard J. Velton


Facilities at the Northeast Water Pollution Control Plant
were also made available for TOC analysis and facilities
at Tarzydal were available for the metal analysis of Zn,
Pb, Cd, Cu.  Cost and frequency considerations were suf-
ficient to warrant considerable attention to the Cincinnati
Lab for all test.

The Tarzdale lab did agree to report results from a Delaware
River processing plant to be used by E.P.A. as a control.

All sampling was strongly urged but not ordered by E.P.A.
All expense is the plants responsibility except for E.P.A.
Cincinnati analysis.

                                          Thank you,

                                           (signed)

                                          EDWARD LEPLEY
                         -74-

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TO:    Record


FROM:  R. E. Hess
       Chief, Operations Branch
       Division of Hazardous Materials

SUBJECT:  ARS advice on Removal of Oil (sludge) from Land
Dr. D. J. Menzies, Agricultural Research Service, Beltsville,
Md. was contacted by telephone to request his advice on re-
moval of oil waste lost from the Berks Associates facility
from farm and woodland in the Pottstown, Pa. area along the
Schuylkill River.

Dr. Menzies stated that oil pools should be removed from farm
and forest land.  Soil which is oil saturated to a depth of
more than 4 inches should be removed;  soil contaminated to
depth of 4 inches or less should be plowed or disked (if farm
land) or left.

Trees on which the oil waste adhered will suffer contact dam-
age;  however, systemic damage is not expected to occur.  The
opinion was expressed that oiled underbrush could be removed
if it is determined that it constitutes a fire hazard;  it
need not be removed on the basis of ecological considerations.

Vegetable Gardens:  Crops should be thoroughly scrubbed if they
are to be used for human consumption.  This is to reduce the
possibility of ingesting sewage borne pathogenic bacteria
rather than because of heavy metals contamination.  Oil coated
plants should be turned under after removal of oil pools and
heavy oil concentrations on the garden surface.

     1.  OSC instruction on required clean-up issued on July
         11, 1971 be followed;  and

     2.  Farmers whose tillable land was contaminated be ad-
         vised that Federal forces will remove oil and oil
         contaminated soil per the ARS recommendation and
         that fields with light oil residue be plowed or
         disked to a depth of 4 to 6 inches as soon as con-
         ditions permit.

     3.  Home gardners should be advised to scrub vegetables
         thoroughly before table use to remove sewage bacteria
         and residues.  After removal of oil pools and earth
         saturated by oil to more than 4 inches depth, gardens
         should be plowed or spaded to 6 inch depth.


                                       (signed)

                                       R. E. Hess
                           -75-

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              Submitted to COE,  Pottstown  7/10/72
Recommended Safety procedures for chemical drum pick-up and
handling.

     I.  Full Drums  -  Intact

         a)  Contents identified by label

             1)  Use appropriate safety precautions when
                 handling

         b)  Contents unidentified

             1)  Use maximum safety precautions when handling

    II.  Drums with contents, leaking or punctured

         a)  Use safety precautions as above

         b)  Transfer the contents by manual pumps to the clean
             empty drum and label as the original drum

         c)  Do not mix the contents of any one drum with another

         d)  Do not empty drum in an uncontained manner

   III.  Safety equipment

         a)  Acid resistant elbo-length gloves

         b)  Acid resistant gogles and face shields

         c)  (air) pressurized water fire extinguishers

         d)  Have available - Scott air packs.

    IV.  Assistance in any safety or handling procedure can be
         obtained from the EPA or MCA representative at 327/0440



                                          (signed)

                                          Allen L. Jennings
                          -76-

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                         PERSONNEL
In almost every oil spill on record, the need for trained
and experienced personnel is near the top of the priority
list.  In Schuylkill Two the broad scope of the operation
required a wide varity of skills.

The National Contingency Plan implies that the region furn-
ishing the OSC would also provide "trained and experienced"
personnel to staff the OSC office.

When the National Strike Force was activated, Region III
supplied the OSC and was able to supply most of the admin-
istrative personnel for his staff.  Legal affairs, public
relations, contracts, stenographic and office services
were staffed by Region III with people who were trained in
the general aspects of those subjects, but who were not ex-
perienced on oil spill situations.

It seemed to members of the documentation team that most of
these personnel were functioning effectively in their assigned
tasks as early as 4 July.   The individuals were dedicated to
the effort and grew up with their jobs.

Unfortunately, there was too much turnover in these admin-
istrative positions and about the time one person became
truly effective, he or she could expect to be replaced by
a new appointee.

Both OSC's, Mr. Massey and Mr. Kaiser, indicated that this
turnover was more frequent than necessary and that it re-
duced the effectiveness of the administrative staff.  On the
other hand, it did expose more personnel to the experience
of working on detached duty and in an emergency situation.

Region III was unable to provide many personnel experienced
in oil spill situations.  Most operations people were re-
cruited by Commander Hanson as Chief of the National Strike
Force.

Immediately, upon activation of the Strike Force, the OSC,
through Commander Hanson, requisitioned personnel from the
Pacific Coast, from Base Yorktown, Base Gloucester and other
areas.  The OSC retained Mr. Malcolm Castor from Region III,
who had served as OSC of the Regional Response Team for a
period of 7 days.  He also requested assistance from EPA in
Washington, D. C., Edison, New Jersey  and other areas where
capable talent was to be found.  By approaching the problem
on a national basis, it was possible to staff most operatins
posts with well qualified personnel.  Many of these personnel
were in Coast Guard Services and the problem of rapid turnover
was thereby avoided in most cases.

                          -77-

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National Contingency Plans makes frequent references to the
"trained personnel" who will be eventually available in each
region, but no date is specified for the completion of such
a program.  Until such a comprehensive training program be-
comes effective, it will probably be necessary to staff major
spill clean-up operation with personnel who are recruited on
a National scale in the manner described above.
                          -78-

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                 INTER - AGENCY COOPERATION
Paragraph 102.1 of the National Contingency Plan "provides
for a pattern of coordinated	•	 responses to poll-
ution spills by departments and agencies of the Federal
Government. "

Schuylkill Two required such cooperation, not only from Fed-
eral Agencies but from all levels of government and from pri-
vate industry.  Fortunately, willing and effective cooperation
was achieved in almost every case when requested.

In the week prior to the oil spill, Base Gloucester requested
assistance in recovering drums and floating debris in the Del-
aware Basin Area.  Immediate and effective response came from
other Coast Guard units, the Corps of Engineers, State Agencies
in Pennsylvania arid New Jersey, Civic Officials and Industrial
Establishments in the Delaware River Basin.

There were occasions when requests were delayed due to short-
age of trained personnel, mis-understanding as to specific
items requested, or provision for funding the costs, but this
is to be expected in an emergency situation.

There were some delays which might have been avoided.  The
National Contingency Plan of June 1970 emphasized response
to an emergency on a regional basis.  Consequently, there
was a tendency for Region III of EPA to provide personnel
or facilities from within its own regional organization even
though better facilities or more experienced personnel might
have been available from other regions.

The Pennsylvania Department of Envinonmental Resources had
its hands full from the very beginning of the flood threat
and was unable to provide liason personnel until early July.
New Jersey Marine Police and others cooperated promptly on
the drum recovery program, but refused emphatically to pro-
vide disposal sites for any oily debris.  On the other hand,
officials of Montgomery County, Pennsylvania, worked dili-
gently and,  finally, successfully to find a suitable dis-
posal site,  thus breaking the biggest bottleneck in the whole
operation.
                          -79-

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     CLEAN UP ACTIVITIES OF THE U. S. ARMY CORPS OF ENGINEERS
The Army Corps of Engineers became involved in the recovery of
oil drums and floating debris even before the oil spill took
place.  Captain Price, Commanding Officer at Base Gloucester
had requested Corps of Engineers assistance from Fort Miflin,
Pennsylvania when floating drums first appeared in the Phila-
delphia Harbor area on or about 22 June.

As flood damage increased it was apparent that the task of
clearing debris from the Schuylkill River Valley was a major
undertaking.  The Office of Emergency Preparedness and the
Corps of Engineers worked out a plan whereby the Corps would
take over responsibility for clean-up of the river-bottom and
adjacent areas as soon as the flood waters receded.  A field
office was established in Pottstown, Pennsylvania and staffed
with Corps of Engineers personnel.

Removal of flood debris was one task, but removal of spilled
oil and of oil soaked debris was a more complicated procedure.
(For example, oil soaked debris could not be burned safely be-
cause of resultant air pollution.)

As early as 4 July, it was evident at the OSC's office that a
substantial increase in manpower would be needed and that spec-
ial treatment would be required for the oil soaked foliage and
sludge.

By 11 July, the OSC's office had worked out satisfactory pro-
cedures for disposing of liquid oil, oily sludge and oil soaked
debris.  The Corps of Engineers was continuing its activities
on drum removal, identification and disposal and was ready to
start on its debris removal assignment.

When Mr. Kaiser assumed the OSC post on 11 July, joint confer-
ences were set up with the Corps of Engineers to discuss the
disposal of oily debris picked up by the Engineers.

It was agreed that the Engineers would segregate oil-soaked
debris and oily sludge from the other debris in such a manner
that the oily wastes could be disposed of through channels set
up by the OSC's office.  This involved the use of trucks for
transportation to the approved disposal site as described
earlier.

Early estimated indicated that $1,600,000. might be needed to
fund the disposal of the oil soaked wastes, but the actual
costs up to the time the OSC's office was closed were sub-
stantially less.
                          -80-

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The Corps of Engineers started land restoration operations by
mid-August, and some of the sub-contractors were at work in
the Pottstown area when Documentation Team personnel made a
final tour of the area on 18 October.

The division of responsibilities between the Corps of Engin-
eers and the OSC's office was logical, with each group handling
tasks for which it was trained.  Final results of the clean-up
program were very encouraging.  By  mid-October there was little
visual evidence of the devastation that was present in July.
                          -81-

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                   EQUIPMENT AND MATERIALS


The clean-up of oil soaked land on the banks of the Schuyl-
kill River was accomplished by the use of manpower, horse-
power, and standard earth moving equipment.  The removal of
top soil which had been mixed with sorbents and the pick-up
of oily foliage and debris was a major exercise for front-
end loaders, bull dozers, and trucks.

There were a few innovations when problems of terrain pre-
vented access of heavy vehicles.

Removal of liquid oil and oily sludge from islands required
the use of high-line cables and trolleys in some cases.  In
other instances Sykes pumps were installed on the islands to
pump oily sludge for as much as 200 feet through a discharge
hose to the river banks.  This pumping operation moved a sub-
stantial quantity of sludge with little difficulty.

Removal of oil from the river surface has been discussed in
the narrative.  The boom and separating system used at Penn-
hurst proved to be a successful installation.  It could prob-
ably have been installed nearly one week earlier at that
location with equal success, but the early emphasis was on
clean-up of the river banks.

Communication between the OSC office and the contractors'
offices in the field was difficult in the early state of
the clean-up.

Walkie-talkies were only partially successful and there were
very few land-lines available to contractors.  National Strike
Force paid special attention to this problem and suggested
that each contractor be equipped with a mobile headquarters
unit.  Small camper trailers were hired for the purpose,
parked at a central location for each contractor and tele-
phones were installed equipped with temporary land-lines.
This gave each contractor a field headquarters with phone,
office equipment and shelter.  These mobile "command posts"
might be considered by other contractors who work on oil
spill clean-up.  In addition to their convenience, they pro-
vided limited storage for items of equipment which could
easily be lost unless safe storage is provided.

Sorbent materials were used extensively in the first six days
of the clean-up effort.  Sorbent granules were spread gener-
ously on oil covered ground and in pools of liquid oil.  They
were used in filter fences and on low bushes and shrubs.  The
results were mixed.
                          -82-

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On oily ground the sorbent granules had a stabilizing effect.
They reduced leaching of oil into the river and made it poss-
ible to walk or even drive vehicles in some spots without be-
coming mired.

The granules had a good "cosmetic" effect.  They concealed
the shiny black on leaves, shrubs or lawns and reduced the
hazard of oil pollution on clothes and equipment.

When spread over oil pools, the granules absorbed some oil,
but thickened the oil to a point that it was difficult to
pump or to collect with vacuum trucks.  Also, liquid oil
could be disposed of at a refinery, but oil and sorbent "mush"
was not as acceptable for that purpose.

Sorbent granules in filter fences had been effective in re-
moving light sheen from the river during the last few days
of Schuylkill One.  In the early stages of Schuylkill Two
there was a heavy sheen on the river and the current was
too fast to allow the sorbents to handle the large volume of
oil.

Other methods of collecting oil and sludge were working effect-
ively and the widespread use of sorbents was discontinued about
7 July.
                          -83-

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              THE DIVERSION BOOM AT PENNHURST
Schuylkill II provided a very good deployment and operation
test for the 'diversion' boom technique.

The the flood waters subsided, a large quantity of oil was
deposited on the flood plains on each side of the river, and
on the islands in the river.  There was continual leaching
of this oil into the river, and the rate of leaching increased
when the oil was warmed by the sun or washed by rain.

The leaching created a sheen on the river which reached from
bank to bank and extended many miles down river from the pol-
luted area.

The oil sheen was difficult to see except  from directly above,
but was quite visable from the bridges spanning the river and
very apparent during helicopter overflights.

Two short sections of boom had been installed as diversion
booms in the heavily polluted areas near the Hanover Street
Bridge.  These booms diverted some of the heaviest leaching
from the mid-stream islands to a small cove where skimmers
removed the oil from the surface of the water.   However,
most of the leaching was escaping down river.

Three requirements had to be met in order to place a diversion
boom to capture the oil sheen.  A location had to be found
where (l)  There was easy access to the river bank for trucks
and equipment;  (2)  The access spot was at a cove or backwater
area of the river;  and (3)  The surface current of the river
was slow.

Study of a topographical map showed that these requirements
would probably be met at Pennhurst, and this was confirmed
by an on-spot inspection.

The diversion boom installed at Pennhurst was about 1300 feet
long and was swung at an angle approximately 30  to the center-
line of the river.  The down stream end of the boom was secured
on the property of Citizens Home Water Company which had a low
bulkhead on the river's edge.

Placing the boom posed some problems because it had to be
launched at the down stream end and towed upstream against
the current.   The preferable deployment method would have
been to launch it from the upstream anchor point - but, there
was no access to the river at that point.  However, by first
towing the boom upstream along the river bank where the current
                          -84-

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 was  minimal,  and  then cutting across  the  river,  the up-stream
 end  of  the  boom was  delivered to  its  anchor point.

 Because of  the length of  the boom and the current  in  the  river,
 several midstream anchors had to  be set.   If  these anchors  had
 been set prior to the deployment  of the boom,  the  operation
 would have  gone more smoothly.  After the anchors were  set,  it
 required many line adjustments  to eliminate  'loops' in  the  boom.

 The  oil sheen was captured by the boom and diverted along the
 boom to the downstream anchor point.   A skimmer  and pump  were
 installed at  this location to remove  the  oil.

 In spite of concentrating the oil sheen in one location the
 oil  film was  still very thin and  oil-water ration passing
 through the skimmer  was very low.  Even when  the skimming
 was  done on an intermittent basis to  allow more  oil to  col-
 lect, large quantities of water were  collected.

 To overcome this  problem  an oil-water separating tank was in-
 stalled.  The separating  tank was an  above-the-ground swimming
 pool which  could  be  easily installed,  and easily removed  and
 stored  for  future use.  The pool  had  a capacity  of some 10,000
 gallons.  (Exhibit 28)

 An automatic  syphon  kept  the pool at  a pre-determined depth in
 spite of the  intermittent skimming operations.   The syphon
.discharged  upstream  of the boom just  in case  any oil  was  dis-
 charged.  Periodically the collected  oil  was  vacuumed from  the
 surface of  the pool  into  a vacuum truck for transport to  a
 disposal site.

 A continuing  problem was  the floating debris  which was  col-
 lected  by the diversion boom.   A  debris fence was  installed
 to keep the debris away from the  skimmer,  but the debris  had
 to be removed manually.   Automatic debris harvesting, using
 a continuous  running open mesh  conveyor belt,  might be  just-
 ified under some  conditions, but  did  not  appear  to be warr-
 anted at Pennhurst.   (Exhibit 29)

 The  OSC and other observers reported  that the diversion boom
 was  fully effective  and that there was no oil sheen on  the
 river below the barrier.

 As the  clean-up operations progressed, the amount  of  leaching
 diminished  and the oil sheen disappeared  except  during  and
 immediately after periods of rain.  The diversion boom  was
 kept in place until  the conclusion of the clean-up operations
 to catch any  oil  run-off  after  rainstorms and as a safety pre-
 caution.  It  should  be noted that there was no water  traffic
 or recreational boating in that stretch of the river  so the
 diversion boom did not pose any navigation problems.
                           -85-

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                ESTIMATE OF OIL VOLUME RECOVERED
About mid-June, 1972, the lagoons at Berks Associates held
approximately 8,000,000 gallons of oil waste and water.
Just how much was oil and how much was water is not known.

The flood on 22 June released most of the contents into the
river.  The oil and water became mixed together by the churn-
ing of the flood waters, so the total volume of polluted liq-
uid must have approximated the 8,000,000 gallon figure.

Clean=up of oil in pools along the river totalled 350,000
gallons of liquid oil-suitable for disposal at a refinery.
(Exhibits 31 & 32)

In addition, an unknown quantity of oil flowed away on the
river, or is still present in the ground or on the branches
or trees and underbrush in the area.

Whatever quantity of oil does still remain is greatly diluted
and worked into the ground.

The clean-up operation has removed all pockets of liquid oil
which could be found.   Ecologically, the area seems to be
recovering rapidly from flood and oil damage.
                          -86-

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                                        -87-

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GALLONS  OF  OIL  RECOVERED   FOR
TEMPORARY   STORAGE  AT  LAGOONS
'72

JULY DAILY
1
2
3
4
5
6
8
12
13
14
15
16
17

10,000
12,000
10,000
10,000
24,700
15,000
55,000
44,640
24,660
16,840
14,800
7,300
15,860
U.S Environmental Protection /
Region V, Library
230 South Dearborn Street ,-
Chicago, Illinois 60604

CUMULATIVE
10,000
22,000
32,000
42,000
66,700
81,700
136,700
181,340
206,000
222,840
237,640
244,940
260,800
* !*>£«&
              Exhibit   32
                  -88-    ftUS. GOVERNMENT PRINTING OFFICE- 1974 546-317/329 1-3

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