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A. Circumstances of Hazardous Materials (HM) incidents vary so
widely, it is impossible to establish specific guidelines to
cover all incidents.
B. The goal is to remove the threat to public health or welfare,
safety, and property which may result from a hazardous
materials incident.
C. Do not compound the existing problem by creating a disaster
out of an emergency.
D. The senior f^ire ground commander of the jurisdiction is
commonly the ON-SCENE Commander (OSC). As such he makes all
the decisions and should be advised and consulted by all
response personnel to promote a coordinated response official
ON-SCENE Commander. ;
E. Until the fire ground commander is on-scene, you must tak
-------
HAZARDOUS MATERIALS ACCIDENT
1ST ON-SCENE - CHECK LIST
I. REPORT THE INCIDENT AS A POSSIBLE H/M ACCIDENT. GIVE EXACT
LOCATION AND REQUEST ASSISTANCE.
2." STAY UP-WIND AND UP-GRADE.
3. ISOLATE THE AREA OF NON ESSENTIAL PERSONNEL.
4. AVOID CONTACT WITH LIQUID OR FUMES.
5. ELIMINATE IGNITION SOURCES -
(Smoking - flares - combustible engines)
6. RESCUE INJURED ONLY IF PRUDENT.
7. IDENTIFY MATERIALS AND DETERMINE CONDITIONS
(Spill - fire - leak - solid - liquid - vapor; single or
mixed load; waybills - bills of lading. Shipper-owner -
manufacturer and carrier) . .> >•
8. initiate evacuation - Downwind first - if necessary
9. ESTABLISH COMMAND POST LOCATION - UPWIND A SAFE DISTANCE.
REPORT EXACT LOCATION AND GIVE APPROACH ROUTE TO DISPATCHER.
FIRE:
POLICE:
EMERGENCY MEDICAL SERVICE:
HEALTH DEPT.:
CIVIL PREPAREDNESS:
REPORT
OIL OR HAZARDOUS MATERIALS SPILLS/RELEASES
TOLL FREE DAY OR NIGHT
1-800-424-8802
ASSISTANCE
OIL OR HAZARDOUS MATERIALS SPILL/RELEASES
DAY OR NIGHT
REGION VII EPA 913/236-3778
IOWA DEPT. OF ENVIRONMENTAL QUALITY
KANSAS DEPT. OF HEALTH & ENVIRONMENT
MISSOURI DEPT. OF NATURAL RESOURCES
NEBRASKA DEPT. OF ENVIRONMENTAL CONTROL
CHEMTREC
515/281-8694
913/296-1500
314/634-2436
402/471-4545
800/424-9300
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TABLE OF CONTEMTS (cont)
Section
7.2.8 Oxidation
7.2.9 Dilution and Dispersal . .
7.3 Control of Land and Air Spills
7.3.1 Land SpilIs
7.3.2 Air Spills
8. DISPOSAL PROCEDURES
9. SPECIAL CONSIDERATIONS •
9.1 Safety . . .
9.1.1 General Considerations
9.1.2 Site Control
9.1.3 Equipment and Clothing '
9.1.4 Medical f
9.1.5 Training <
9.2 Waterfowl Conservation r
9.3 Environmental Damage Assessment (
10. SAMPLING AND DOCUMENTATION .' ''./'. . . . I
10.1 Sampling Procedures ,f /• t
10.1.1 Method of Sampling '...... i
10.1.2 Type of Samples i
10.1.3 Sample Containers Jfc i
10.1.4 Sample Preservation f (
10.1.5 Sample Identification ..... i (
10.1.6 Chain of Custody . . . -i 6
10.2 Documentation ^ P
i
APPENDICES *. '. i
Is
A. Spill Information f (
A.I Information Contacts (
A.2 Information Sources ' . . . i
B. Cleanup Contractors
C. Oil Sheen Reference
D. Standard Terms and Conversion Table
E. Telephone Directory
H. Frequently Called Narv-s and Telephone Numbers
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TABLE OF CONTENTS
Section
1.0 INTRODUCTION 1
2.0 Preparedness/Prevention -. . . . 1
"'""" . **••-.. ,. if-- - 3iQ FEDERAL LAWS/REGULATIONS 4
3.1 Federal Water Pollution Control Act 4
'**** 3.2 Spill Prevention Control and Countermeasures
Plan (SPCC) 4
3.3 Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA) 5
3.4 Resource Conservation and Recovery Act (RCRA). . 6
4.0 NATIONAL AND REGIONAL OIL AND HAZARDOUS SUBSTANCES
POLLUTION CONTINGENCY PLANS 6
4.1 On-Scene Coordinator , *5
4.2 Regional Response Team • " * 7
4.3 Spill Response Phases • 7
4.3.1 Phase I - Discovery and Notification . . '. /. 7
4.3.2 Phase II - Evaluation and Initiation of Action 7
4.3.3 Phase III - Containment and Cguntermeasure . 8
. * 4.3.5 Phase V - Documentation and Cost Recovery, . 8
5.0 SUMMARY OF ACTION TO BE TAKEN BY THE SPILIJER .... 8
5.1 Report It > 8
5.2 Contain It
7.2.1 Carbon Adsorption "•'<
7.2.2 Filtration •f.r>
7.2.3 Ion Exchange 3d
7.2.4 Gravity Separation 3(>
7.2.5 Neutralisation 37
7.2.6 Coagulation Precipitation 37
7.2.7 Reduction 38
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1.0 INTRODUCTION
The Congress has declared that it Is the policy of the United
States that there should be no discharge of oil or hazardous sub-
stances into or upon the navigable waters of the United States,
adjoining shorelines or into or upon waters of the contiguous
zones (Sec. 311 (b) (1) of the Federal Water Pollution Control
Act).
This policy is carried out.through a coordinated effort by
Federal, State, Local departments* and agencies, as outlined in the
"Region 7 Oil and Hazardous Substances Pollution Contingenty Plan"
for the waters of Iowa, Kansas, Nebraska, and Missouri. This
Response Manual is a sub-part of the overall Region 7 Contingency
Plan. Its purpose is to give the responding Federal and State
officials a convenient "quick" reference guide of duties, cleanup
techniques, and resources that may be called upon to mitigate and
control the effects of ah oil or hazardous substance spill.
The Comprehensive Environmental Response Compensation a.n1
Liability Act of 1980 (CERCLA) significantly broadens the scope o.r
spill reporting and response. Specially, the Act requires that
the National Response Center be notified of any releases tff'-'a
reportable quantity of a hazardous substance to the environment.
Requirements for spill clean up and the responsibilities 6V the
Dn-Scene Coordinator are similar to those under Section 311 of the
FWPCA. ^
2 • 0 PREPAREDNESS/PR EVENT ION }
Organization and operator of a hazardous materials response
system requires more than a rapid delivery system jffor personnel to
reach the scene of an incident. Careful planning, organization
ind training of personnel of diverse backgrounds are necessary to
orepare for effective and safe on-scene operations at a hazardous
naterials release. Preparedness is the general term for these
ictivities which result in an adequate state of awareness of the
mzards involved combined with the capability to effectively
respond to the emergency.
Preparedness ranks very high in the order of importance with
sther elements of oil/hazardous materials spill control. It is
preventive in nature and from this viewpoint is regarded as most
:ffective. It relates to both before and after-the-fact
ictivities in that it can help avoid the spill/releases, or it can
-educe the total impact of the spill on the environment.
The responsibility to develop a sound readiness lies with in-
lividual companies, agency, department, whether moral or le^al
>bligations are involved, or simply appreciation of esthetic
/alues. One step further - each employee should bfe aware of his
•esponsibilities to his company agency, department, and be willing
:o participate in maintaining and improving preparedness efforts.
-1-
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There are many variables in developing an adequat
preparedness plan, and there is no stereotyped checklist t
follow. While it is true many good plans have been worked out
the fact is they are tailored to accomodate specific hazards, i
specific geographic areas, using the available, manpower
organizational structures, equipment and supplies.
These things relate to planning and organization, wherea
training of personnel, maintaining and improving the program mu;
also be considered. Training of personnel, for example, migt
include:
1. How to deploy special equipment (booms and skimmers,
etc. ).
2. Improvising equipment in emergencies.
3. Arranging denonstrations by vendor/supplier of
equi p~ient.
4. Arranging conferences with local, state and federal
environmentalists. f .• )•
5. Discussing and studying new techniques and/keeping
current with developments in related subje'cts.
Maintaining readiness is extreme^ important, because chanc-
in personnel, corporate organization, equipment availability, prc
cess changes and additions, product flow,4etc. , could render tt
plan ineffective or completely inadequate.' Readiness is a neve
ending process and must be periodically reviewed to keep tl
system current. jf
Regardless of the best efforts/ that might have been mad-
certain improvements are always possible. All contingencies a;
not likely to be anticipated.
RESPONSE ACTIVITIES
Response activities associated with each specific incidc:
are unique- however, there are criteria, principles, and oper:
tions that are common to all incidents. The incident must i
evaluated to determine its hazard or potential hazard. Vario
types of environmental samples or measurements may be needed
initially determine the hazard or to provide additional or contu
ual information for assessment. Personnel workers involved in t
many activities will need to be protected appropriate to the ha:
ards involved. Efforts will be needed to prevent or ri-du.
potentially harmful substances from migrating from the site due .
natural or man-made activities. Containment, cleanup, and di
posal activities may be conducted.
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P-1SPOSAL/_R ECOVERY
After cleanup operations have removed the spilled materials
and contaminated dobris from the water or ground," the OSC's
responsibilities are not over. Improper shipping and'-disposal of
spilled cleanup waste can cause serious safety problems as well
as result in secondary pollution as bad as, if not worse than the
original spill. Therefore, the OSC nust be assured that all chem-
ical disposal is carried out in a safe and proper manner.
Disposal/recovery operations may involve the shipping of the
waste materials to a state approved land disposal site, U-eattm-nt
by a reliable disposal or recycling to the spiller's company or to
a company that can use the material in its operation.
In all cases involving the disposal/recovery of oil and ha?-
ardous substances, contact and coordination should be made with
all affected parties. EPA looks to the State pollution control
agencies to obtain disposal sites and act as disposal sites, air
pollution control agencies, sewage treatment plants, etc. :
Extremely toxic materials nay require special on-site-'freat-
ment, or as in the case of PCB's either incineration or shipment
to an EPA/State approved disposal site. EPA, Edison, N6* Jersey,
has specialised equipment that nay be available to treat these
very toxic materials. Coordination of this^activity will be con-
tacted by the EPA Emergency Response Team.
Generators (spillers) and transporters ofj hazardous waste
materials must obtain the appropriate EPA identification numbers
as required by RCRA (See Section 4.4).
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-.0 FEDERAL LAES/REGULATIONS
3.1 FEDERAL WATER POLLUTION CONTROL ACT
The Federal Water Pollution Control Act, as anmended
(also called the Clean Water Act), represents the latest
wa£er pollution control legislation a"nd contains several
elements relative to pollution by oil and hazardous sub-
stances. The basic authority for spill prevention and re-
sponse programs originates from Section 311 of the Act.
Section 311 provides the overall framework for spills of oil
and designated hazardous substances, including national
policy and responsibilities. Section 311(b)(5) provides
that: "Any person in charge of a vessel or of an on-shore
facility shall, as soon as he has knowledge of any discharge
of oil or a hazardous substance from such vessel or facility
...immediately notify the appropriate agency of the United
States Government of such discharge. Any such person who...
fails to notify immediately such agency of such discharge
shall, upon conviction, be fined not more than $10,000 or
imprisoned for not more than one year or both." The appro-
priate "agency" is indicated in Section 6.1 of this •manual.
It is the policy of the; United States Envirorfraental Pro-
tection Agency and the U.S. Coast Guard that the spiller
assumes complete financial respoj^ibility for removal
actions. If the Federal On-Scene Coordinator (,OSC) deter-
mines that timely and/or adequate removal actions are not
being carried out, then the Federal Government will initiate
cleanup. The Government nay then bring action against the
responsible party to recover all clelfhup costs up to the
liabilities set by Federal Law. A spil| cleanup must be done
to the satisfaction of the Federal OSC.T
3.2 SPILL PREVENTION CONTROL AND COTJNTEKMEASURES
PLAN (SPCC PLAN)
The Environmental Protection Agency Oil Pollution Pre-
vention Regulation, published in the Federal Register on
December 11, 1973, is addressed to non-transportation related
facilities and is further identified as Title 40, Code of
Federal Regulations, Part 112. The main requirement of
facilities subject to the regulation is the preparation and
implementation of a plan to prevent any discharge of oil into
waters of the United States. The plan is referred to as a
Spill Prevention Control and Countermoasure Plan (SPCC Plan).
The purpose of the plan is to prevent discharges of oil
into waters of the United States. The main thrust of the
regulation^is "prevention" is opposed to "after-the-fact," or
"reactive" measures commonly described in Spill Contingency
Plans.
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This plan applies to owners or operators of facilities
engaged in drilling, producing, gathering, storing,
processing, refining, transferring, or consuming oil and oil
products, providing -
1. the facility is non-transportation related (see
definition of non-transportation)
2, aboveground storage capacity of single container As in
excess of 660 gallons, or an aggregrate storage
capacity greater than 1320 gallons, or providing that
total belowground storage capacity is greater than
42,000 gallons
3. facilities, which, due to their location could reason-
ably expect spilled oil to reach waters of the United '
States.
3.3 COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION
AND LIABILITY ACT OF 1980 (CERCLA)
This act significantly broadens the scope of spill re-
porting and response. Specifically, the Act requires that
the National Response Center be notified of any releases of a
reportable quantity of a hazardous substance to the envirdh-
nent.
'/
The Act defines the environment to include water,
groundwater, land surface, and subsurface^ The definition of
hazardous substances has been expanded to include: those
already designated under Section 311 of the Federaj. Water
Pollution Control Act (FWPCA); hazardous waste* defined under
Section 3001 of the Solid Waste Disposal Ac.t; toxic pollut-
ants listed under Section 307 of the FWPCJA; hazardous air
pollutants listed under Section 112 of thj£ Clean Air Act;
substances pursued under Section 7 of t^he? Toxic Substances
Control Act; and any substances subsequently designated pur-
suant to Section 102 of Superfund. The' definition does not
include petroleum. A listing of these substances can be con-
piled by obtaining copies of 40 CFR Part 116 and 49 CFR Part
172. The Act sets a reportable quantity of one pound, except
for those substances for which reportable quantities were
previously assigned under Section 311 of the FWPCA.
Petroleum spills to the navigable waters of the United
States continue to be under the jurisdiction of the FWPCA.
Therefore, any substance designated as hazardous
according to the laws cited above, when released to the
environment in quantities of one pound or greater (unless a
different quantity has been designated under Section 311 of
the FWPCA) must be reported to the National Response Center.
Failure to notify could result in a fine or not more than
$10,000 or imprisonment for not more than one year, or both.
Requirements for spill cleanup and the responsibilities
of the On-Scene Coordinator are similar to those under Sec^
tion 311 of the FWPCA.
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3.4 RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
This Act addresses problems related to the generation,
disposal, and management of waste materials in the United States.
In relation to his plan are those portions of the Act dealing with
» hazardous wastes. Regulations have been promulgated b"y EPA which
will serve to identify hazardous waste both by characteristics and
by sources; develop the cradle-to-grave manifest and tracking
systems; and implement a permit system and facility standards for
the treatment, storage, and disposal of hazardous wastes.
>s> _ _ The regulations require that generators, transporters, and
v«.-- , 4..-- - disposers of hazardous waste must obtain EPA identification
numbers. During spill situations where hazardous waste is
recovered and transported to a disposal site, the shipment must be
accompanied by a manifest which includes the EPA characterization
number of the generator and each transporter. These
identification numbers are necessary prior to transporting the
material off site. In order to avoid delay in obtaining these
numbers, EPA has established a special procedure for rapid
issuance of numbers. EPA Region Office will issue provisional
numbers to generators and transporters during emergencies when
necessary for rapid transportation of hazardous waste to an
authorized waste management facility. These identification
numbers and further information concerning the RCRA Act can be
obtained by contacting: U.S. Environmental Protection'Agency,
Region VII, 25 Funston Road, Kansas City, Kansas 66115.
jv
* 4.0 NATIONAL AND RB3IONAL OIL ANP HAZARDOUS *
SUBSTANCES POLLUTION CONTINGENCY {PLANS
The National and Regional Oil and Hazardous Substances Pollu-
tion Contingency Plans have been developed $1 compliance with the
Federal Water Pollution Control Act, Sectiion 311 (c) (2) and
CEHCLA, Section 105. These Plans provide for a coordinated and
integrated response by departments and agencies of the Federal and
State governements to protect the public health and environment
and minimize adverse impacts due to oil and hazardous substance
discharges, including containment, dispersal and removal. The
Plans also promote the coordination of the Federal and State
response systems by developing local government and private capa-
bilities in handling environmental incidents.
4.1 ON-SCENE COORDINATION
The On-Scene Coordinator (OSC) is the Federal official pre-
designated by the EPA or USCG to provide on-scene coordination and
direction of all aspects of a spill and subsequent removal
actions. The OSC is predeslgnated as part of the planning and
preparation for response to pollution incidents. EPA normally
provides OSC's for inland waters and USCG normally provides OCS's
for coastal waters. However, this function may be delegated to
other State and Federal officials where appropriate. The OSC
maintains responsibility to insure that the proper initiation,
containment, countermeasures, cleanup, and disposal actions take
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place. An official from any agency with responsibility under the
Regional Contingency Plan may assume the role of the OSC until the
predesignated OSC arrives. '
4.2 REGIONAL RESPONSE TEAM
The Regional Response Team (RRT) serves as the regional body
for planning and preparedness actions prior to pollution
discharges and for coordination and advice during a pollution
discharge. The RRT is composed of regional representatives of
participating Federal, State, and Local government agencies.
Activation of the RRT will normally occur when a major or
significant discharge of oil or hazardous substance occurs.
During a pollution emergency the RRT members shall insure that the
resources of their respective agencies are made available to the
OSC. Both the National and Regional Plans contain the
responsibilities and the functions of the OSC and RRT and are
available for review at the EPA and USCG offices.
4.3 SPILL RESPONSE PHASES
The actions taken to respond to a pollution release can ^be
separated into five relatively distinct classes or phases. , ,-For
descriptive purposes, these are: Phase I - Discovery and Notifi-
cation; Phase II - Evaluation and Initiation of Action; P,hase LI I
- Containment and Countermeasures; Phase IV - Cleanup, Mitigation
and Disposal; and Phase V - Documentation and Cost Recovery. It
must be recognized that elements of any one-^shase may take place
concurrently with one or more other phases. The OSC initiates and
directs Phases II, III and IVT
4.3.1 Phase I - Discovery and Notification fJ
Identification is the first response action to an oil or haz-
ardous substance spill. The notification ,«and dissemination iaf
information will be in accordance with the applicable regional and
local plans, but should include the necessary steps to safeguard
life and property and the notification of other agencies, i.e.,
fire departments, police departments, etc.
4-3.2 Phase II - Evaluation and Initiation of Action
Identification of the material spilled is of utmost import-
ance during spill incidents (see Section 7.0). If the identity of
a spilled material is not known, it is recommended that the spill
not be approached by the responder until the material can be
properly identified and the hazards and safety precautions known.
Otherwise, the spill should be treated as if it were a highly
toxic substance and should be approached only with full protective
gear employed.
In the case in which the nature of the potential hazard of a
spill is unknown, but no imminent hazard to a populace is sus-
pected, every effort should be made to determine the spill nature
and extent prior to exposure of cleanup personnel. In the long
run, time spent in making such a determination may be more than
compensated for by making swift, concerted and appropriate action
possible when the problem is properly defined.
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Many, if not most, hazardous substances are soluble or
miscible In water. Thus, evaluation of containment/clean up
efforts will be much more difficult than with oil spills. In
addition, the evaluation of the magnitude of the spill and the
potential hazard and environmental impact will be more difficult
and can be expected to require more on-scene response effort than
previously required for oil alone.
4:3.3 phase III - Containment and Countermeasures
This includes actions taken to recover the pollutant from the
water and affected public and private shoreline areas, and monit-
oring activities to determine the scope and effectiveness of
removal actions. Actions that could be taken include the use of
sorbents, skimmers and other collection devices for sunken pollut-
ants; the use of reaeration or other methods to minimize or miti-
gate damage resultant from dissolved, suspended or emulsified pol-
lutants; or special treatment techniques to protect public water
supplies or wildlife resources from continuing damage (see Section
8.0).
Pollutants and contaminated materials that are recovered in
cleanup operations shall be disposed of in accordance with
procedures agreed to at the State or local level (see, ,-Section
9.0).
t /
4.3.5 Phase V - Documentation and Cost Recovery
This includes a variety of activities, depending on the
location of and circumstances surrounding a particular release.
Recovery of Federal removal costs and recovery, for da'mage done to
Federal, State or local government property is included; however,
third party damages are not dealt with,? in this Plan. The
collection of scientific and technical information of value to the
scientific community as a basis for research and development
activities and for the enhancement £>f understanding of the
environment may also be considered in fthis phase. It must be
recognized that the collection of samples and necessary data must
be performed at the proper times during the case to fix liability
and for other purposes (see Section 9).
5.0 SUMMARY OF ACTIONS TO BE TAKEN BY THE SPILLER
When a spill has occured which is in violation of the Act
(see Section 11.0), the responsibile party must take certain
actions which can be classified as follows.
5.1 REPORT IT
The Act requires that any person in charge of a facility
responsible for discharging will notify the appropriate agency of
the United States Government as soon as he has knowledge of any
discharge of oil or hazardous substance. The appropriate agencies
to notify are as follows:
Federal
National Response Center 800-424-8802
USEPA Region VII K.C. 816-374-3778
USCG 2nd District 314-425-4612
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State
Iowa DEQ 515-281-8883
Kansas DUE 913-862-9360
Missouri DNR 314-634-2436
Nebraska DEC 402-4-23-7442
5.2 CONTAIN IT
Containment of the spilled material is of extreme importance
since the effectiveness and cost of cleanup will usually be
directly related to the effectiveness of containment. For this
reason, containment must be undertaken immediately upon discovery
of the spill. The first step is to locate the source and make' an
effort to stop the migration of. material. Containment equipment
should then be established well below the leading edge of the
spilled material to insure ample time for installing the contain-
ment-equipment. In many cases, a series of containment ^eyi-ces
will be required. Whenever possible, containment should be accom-
plished before the naterial reaches water. Once oil or a /hazard-
ous substance release has reached water, recovery is much more
difficult. Most other hazardous substances are nearly impossible
to recover or treat when they have entered abater body.
5.3 CLEAN IT UP j '
I
The Act also requires that the responsible party remove the
spilled material and conduct cleanup to the Satisfaction of the
OSC (see Section 4.1). Therefore, after thej material has been
adequately contained, resources should be assembled to acconplish
a satisfactory cleanup. This may involve using company employees
and equipment or it could require the assistance of a contractor
who specializes in spill cleanup. (See Section 8.0 for specific
techniques related to containment and cleanup).
6.0 IDENTIFICATION AND ASSESSMENT OF SPILLED MATERIALS
In the eyent of a discharge, the spiller should be able to
provide information concerning the identification of the naterial.
However, if the spiller is unknown or not available, then other
clues may be useful in determining the type of material spilled.
These include:
1. Characteristics of the container
o Container shapes
o Markings and colors
o Placards and labels
2. Characteristics of the spilled material
o Physical state
o Type of odor emitted
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o Color
o Turbidity
o Behavior in water
o Irritability to eyes
o Fuming
o Flaming
o Foaming
o Gas emitting
o Reactions
3. Shipping papers for transportation related spills
Every vehicle should be considered to be a hazard because of
the material it may be carrying, even though it is not placarded.
This is because the law does not require vehicles carrying certain
materials be placarded, even though they may be extremely danger-
ous under certain circumstances. (For example, hair spray usually
considered to be relatively harmless, is very flammable and ex-
plodes when subjected to heat). There are numberous other pro-
ducts which when packed under pressure in aerosol cans are potent-
ially dangerous. • '''
In case of an accident or spillage, the first frerson at the
scene should ascertain from the driver of the vehicle, conductor
of train or pilot of plane, the type jpf material being trans-
ported. If the driver, conductor or pilot is unconsicious or
dead, an attempt should be made to retreive the shipping papers
from the location indicated in Table 1 to determine the type of
material aboard. If unable to locate shipping papers, or obtain
the name of the commodity from the containers, contact the carrier
or shipper involved to get this information. The attempt to
retreive the shipping papers or name of,commodity from containers,
should ONLY be attempted it it can be Accomplished without undue
risk to emergency personnel. *
TABLE 1 SHIPPING PAPER IDENTIFICATION CHART
Mode of Title of Location of Responsible
Transportation Shipping Paper Shipping Papers Person
Highway*
Rail**
Water
Air
Bill of la'ding Cab of vehicle
Waybill With Conductor
Consist
Dangerous Cargo Wheelhouse or
Manifest ptpelike con-
tainer on barge
Air Bill with Cockpit
Certification for
Restricted Areas
Driver
Conductor
Capjtain
Master
Pilot
* Manufacturer's data sheets generally available from driver in
addition to bills of lading.
** STCC (Standard Transportation Commodity Code) Number is usc>d
extensively on rail transportation shipping papers.
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When identifying hazardous substances, great care must be
taken in copying names of materials since even minor spelling
errors can have serious consequences in determining the hazardous
properties of the spilled material.
Unidentified materials must be approached as though they are
highly toxic and full protective gear should be used.
Table 2 provides a general classification of hazardous mater-
ials commonly transported.
The following format will be of assistance in establishing
the identity of the material and the magnitude of the spill: >
Establish the type of spill - The first step is to determine what
type of spill is involved by identifying the source of the spill.
The following types of spills are possible:
1. Trains
Tank car
Box car;
Trucks
Tank
Trailer
6.
7. Pipeline '
o Offshore
^ o On shore
8. Storfcge Tank
~q| Offshore
tj On shore
f
Things to look for at spill
sit*:
1. Are hazardous placards
or labels visible on
vehicle or container?
2. If so, what are contents
identification or
warnings relating to
dangers (poisonous,
explosives)?
3. Identification numbers
on tank cars, trucks,
etc.?
4. Is shipping paper avail-
able?
Record easily visible physical properties - Observation of the
following properties of the spilled material can confirm an ident-
ification or possible identify the specific chemical involved.
However, the OSC must approach the spill cautiously and not en-
danger himself and others in determining the characteristics. If
a certain physical property cannot be readily identified, gather
other information that can safely be obtained.
3.
4.
5.
Bus
Aircraft
o
o
Shii
o
0
o
o
o
o
o
o
Cargo
Passenger
3
"Dry Cargo
Tank Ship
Com. Pass
. Vessel
Fishing Vessel
CG Vessel
Pleasure
Tugboat
Craft
Uniden ti f ied
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!. Vihat Is the spill state?
o Solid (powder, pellet
granular)
o Liquid
o Gas
2. Is there a noticeable odor
from a safe distance?
(pleasant, almond, ammonia
benzene, fragrant, lysol,
vinegar, sweet)
3. What color is it?
4. Is it turbid?
o Opaque
o Clear
o Cloudy
o Other
If it is in water, does it
o Float
o Sink
o Mix (soluble)
Does it cause your eyes
to water?
Is it
o Fuming
o Flaming
o Foaming
o Is a gas being given
off
o Is another noticeable
reaction occurring?
Magnitude of Spill - The OSC can establish the magnitude, of the
spill by considering the following. * •'
1. What number, type and size of individual containers have
spilled the material?
o Metal drums
Fiber drums
approx. height
approx.
diameter
height
o
Carboys
approx. -height
diameter
o
o
o
o
2.
Bags
Paper
Polyethlcne
Cylinders
Boxes Type
Other
If largs tank
Length Width
Length
Length
Length
Dimensions:
trucks, cars, or
Width
Width
Width
barge and
Height
Height
Height
Height
ship holds are in
volved, the approximate size can be estimated by pacing off
a similar distance at a remote location.
size: x x
Often the tank cars and trains are labeled so the capacity
should be recorded: gallons.
-12-
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6.1 CHEMICAL COMPATIBILITY
, If two or more hazardous materials can remain in contact
indefinitely without changing structure or resulting in a chenical
reaction then they are compatible. Incompatibility does not
necessarily indicate a hazard.
Many operations on waste or accident sites involve mixing or
unavoidable contact between different hazardous materials. It is
•""*"• '. '/••''•'-'•: \,'•.-.f.~.-• *•' important to know ahead of time if such materials are compatible.
If they are not, then any number of chemical reactions could ,oc-
..*««* cur. The results of a reaction could range from the formation of
an innocuous gas to a violent explosion. Table 2 gives the
results of incompatible mixtures.
The identity of the reactants and their nature must be deter-
mined in order to establish compatibility of the reactants are un-
known, then it must be determined by chemical analysis.
Once the identity is known then a chemist should be able to
determine the compatibility or the chemical reaction resulting
from mixing the reactants. Judging the compatibility of more than
two reactants is very difficult. If more than two reaatants are
to be combined, then compatibility is judged on a one to .one
basis.
For response personnel who are required to deterrain/e compati-
bilities there is an EPA R&D publication which lean be' utilized.
It is called "A Method for Determining the 'Compatibility of
Hazardous Wastes" EPA 600/2-80-076. 1>
Sometimes the identity of a waste is impossible to ascertain
due to money and time constraints. In tt£s event, simple tests
must be performed to determine the nature ,pf the material or mix-
ture. Tests such as pH , oxidation-reduction potential, and flash-
point determinations are used to characterize the waste. Other
tests such as combining very small amounts of the reactants may be
carefully employed to determine compatibility.
Practical Considerations:
If materials are compatible they must be stored together in
bulk tanks or transferred to tank trucks for ultimate disposal.
Bulk containment of wastes for transport requires only one chemi-
cal analysis whereas one is required for each drum or container
transported.
Compatibility information is also very important when evalua-
ting a situation resulting from an accident involving several dif-
ferent hazardous materials. The ultimate handling and treatment
of the materials may be partially based on such information.
-13-
-------
3.
4.
5.
6.
7.
8.
9.
10.
11.
TABLE 2
Generation heat - e.g., acid and water
Fire - e.g., hydrogen sulfide and calcium hypochlorite
Explosion - e.g., picric acid and sodium hydroxide
Toxic gas or vapor production - e.g., sulfuric acid and
plastic
Flammable gas or vapor production - e.g., acid and metal
Formation of a substance with a greater toxicity than the
reactants - e.g. , chlorine and ammonia
Formation of shock or friction sensitive compounds
Pressurization of closed vessels - fire extinguisher.
Solubilization of toxic substances - e.g., hydrochloric acid
and chromium ' .'
Dispersal of toxic dusts and mistsj*.
Violent polymerization - e.g., ammonia and acrylonitrile'
i
-14-
-------
Available technical data:
A. CHRIS Manuals - U.S. Coast Guard
B. OHMTADS - EPA
C- chemtrec
D. NIOSH/OSHA - Guide to Chemical Hazards
E. Merck Index
F. Sax, Irving - Dangerous Properties of Industrial
Materials
G. Fire Protection Guide or Hazardous Materials - NFPA
H. Hazardous Materials - Emergency Action Guide , ••
U.S. Department of Transportation
/ /
I. Bureau of Explosives
Association of American Railroads
Emergency Handling of Hazardous Materials
in Surface Transportation
i
3. Additional Notes: '
!>
-15-
-------
TABLE 3
CLASSIFYING HAZARDOUS MATERIALS
General category
DOT Classifications
Explosives
Class A Explosive
Class B Explosive
Class C Explosive
Blasting Agents
Cowpressea oases
Flanmble Gas
Nonflammable Gas
Special Forms
Liquified
Cryogenic
Gas in solution
Flarmaftle Liquids
Pyrophoric Liquids
Flanmable Liquids
Combustible Liquid
Flammtile solias
Flamrable Solid
Water Reactive
Spontaneously
Combustible
uxirli7.ing Materials
Oxidi7,er
Organic Peroxide
poisonous Materials • "
Class A Poison
Class B Poison
Irritant
Etlologic Agent
KadioactiV6 Materials
Radioactive I
Radioactive II
Radioactive III
COi'i'Osive Materials
Corrosive
otner
CRM A
ORM B
OHM C
CRM D
Examples
Dynanito, TNT, Black Powder
Propel Ian t Powders, Rocket
Motors
Comon Fireworks, Snail
Arms
Nitro Carbo Nitrate
Acetylene, Butane, Hydrogen
Carbon Dioxide, Nitrogen
Sulfur Dioxide
Butane, LNG, Nitrogen,
Propane
Ethylene, Hydrogen, Nitroge
Acetylene
Aluminum Alkyls, Alkyl
ESoranes
Acetone, Gasoline, Methyl
Alcohol
Fuel Oil, Stoddard Solvent
Magnesium, Titanium
«^*
Calcium Carbide, Sodium
Hydride
Phosphorus, Sodium, J
Potassium '
Lithium Peroxide *f
Benzoyl Peroxide, Peracetic
Acid ,t '
f
Arsine, Hydrocyanic Acid,
Phosgene
Aniline, Arsenic, Methyl
Bromide
Tear Gas, Xylyl Etromide
Anthrax, Botulism, Rabies,
Tetnus
Plutonium, Cobalt, uranium
Uranium Hexafluoride
Acids - Hydrocyanic. Acid,
Sulfuric Acid
Bases - Caustic Soda,
Caustic Potash
Dry Ice, Carbon Tetrachlori
Quick! une, Metallic Mercury
Battery Parts, Bleaching
Powder
Disinfectants
<.ienerai naz&ruous
Properties
Sensitive to heat &
Contamination could cause
explosion
Thermal and Mechanical
impact
BLEVE potential
FlaimabiUty hazard
Highly mobile vapors
Toxicity, oorroslvity
potentials
Liquified gases - cold
temperatures - frostbite
i expansion ratio high
Flamnability
Explosion potential
BLEVE • •' ''
Vapor /air
Potentially corrosive,
toxic thermally unstable
Readily ignite & burn
explosively, some
spontaneously
Water reactive potentials
Toxic & corrosive potenti
Supply oxygen to support
conbustion of normally
nonflamrable materials
Explosively sensitive to
heat, shock, friction
Potentially toxic
Harm from inhalation ,
ingestion , absorption
Effect on environment
Flammability potential
Harm - internal 5 externa
Contaminates -
In-mediate area
Smoke, clothing, water
Harm - disintegration of
tissues, internal &
external
Oxidizing effect
Splatter pottential
ie Noxious
Corrosive
-16-
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7.0 CONTAINMENT AND CLEANUP TECHNIQUES
Upon arriving at a spill scene the investigator should
observe the physical situation and take appropriate safety pre-
cautions if necessary. It is preferable to know the materials
spilled before leaving the office. This will allow time to check
the hazards of the materials involved in the spill, arhd what pre-
cautions and actions would be required during the cleanup opera-
tions.
Once the identity and danger of the spilled material has been
assessed, various methods of containment and/or cleanup may be
appropriate. It is the policy of EPA that mechanical containment
and removal methods be used whenever possible unless they would
endanger life of property or another more effective and readily
available method is more feasible.
While it is recognized that there are many adequate methods
available to mitigate the effects of an oil or hazardous substance
spill, the methods presented here are offered as a guide to assist
the Federal and other responding personnel in carrying out'-'their
responsibilities. For purposes of discussion, the techniques
-------
Weirs
TABLE 4
CONTROL METHODS PCR SPILLS IN WATER
FLOAT IH3 SPILLS
METHOD
Booms
APPLICATION CR
CONSTRUCTION
MATERIALS
Varies; need de-
ployment device
USE
Not too
much
ADVANTAGES
Used on largo
area; many
knotcurrent
DISADVANTAGES
1. Only in wave <2-4 feet
2. Current speed <0.7
varieties
Weir & boat
Calm
Not easily
clogged;
collects &
contains
Not used in rough water
Pneumatic
Barriers
Spill
Herding
Methods
Air compressor
diffuser
deployment
method
Chemicals on
water ; spray
or prop, wash
Only in
shallow
water
Protect
shore &
facilities
Do not create
a physical
barrier to
vessels
Useful in
rough water
1.
2.
3.
1.
2.
Not in rough water
Only shallow water
Only thin layers of
materials
.» >*
Not eastlty obtainable
Not 10Q& effective
7.1.1. Booms
Booms are used to contain spills of floatable{materials, and
to facilitate cleanup operations. Booms can be, used to keep the
oil and hazardous materials in a small area »6r to keep these
materials out of a particular area. This lattej1 approach is used
to protect vulnerable natural resources and priyate property such
as a marina. M
Generally, booms as a containnent device are good in clam
waters. However, they will loose their effectiveness in currents
above 1 MPH. (See Figures 1 and 2). In situations where the
current is above the 1 MPH figure, the boora should be used as a
deflection device, moving the oil to a quiet collection area.
This is done by placing the boom at an angle to the movement of
the floating material, this angle being less than 90° and usually
smaller than 45°. The faster the current, the smaller the angle
and the longer length of boon is required.
Boons are usually susceptible to two kinds of failure while
they are deployed: (1) entrainment and (2) splashover.
Entrainroent is the loss of oil under the skirt, due normally
to a combination of increased headwave thickness and water cur-
rent. Figure 2 illustrates what happens to cause this undesirable
effect.
-18-
-------
TENSION
MEMBER
<•• --SKIRT
1 BALLAST
1* WEIGHT
-»n r.i u
n
n
END VIEW SIDE VIE'*
Figure 1. The basic components of an oil contaminant boom.
WATER FLOW
OIL SURFACING
BEHIND BOOM
OIL DROPLETS
BREAKING OFF
Firure 2. Heavy waves and current; -,ay v-sh Drilled oil under
the booms; this type of failure is known as "entrainrent."
19
-------
tntrainment can be accelerated by either of two separate
events or a combination of external inputs. One event is the
im-rease of water current velocity. This event has a tenriincy
to push the skirt off the vertical and to increase the amount
of entrained oil (Figure 3). The second event is high winds,
which can cause a similar loss of vortical integrity, if suf-
ficient freeboard is present, by pushing the top of the boom
toward the water surface. Sometimes, the boom may actually lie
flat on the water with a subsequent loss of previously contained
oil (Figure 4).
WIND
Figure 3. Entrainment increased due to fast current.
WIND
Figure 1. Entrainment increased due to high wind with normal
current.
The problems associated with entrainment can be partially
countered by decreasing the angle of the boom to the bank.
Problems associated with the effect of wind on boom integrity
are completely situational and require individual analysis and
deployment of "trade-offs" to maximize containment of the
spilled product.
20
-------
The wind and the sea state are primary influences on the
second type of failure, which stems from the splashover of the
boom. Splashover is directly affected by boom design, freeboard
height, angle of approach of wavts to the boom, and the size:and
interval of the waves. Any combination of these factors causes
the oil to go over the top of the boom. The solution, again, is
site-specific, and the amount and direction of movement of the
boom to minimize this splashover should be determined on a
case-by-case basis. In choppy sea conditions, some oil will'spill
over, but there is no need for alarm unless large quantities are
being lost.
Regardless of the type used, booms can be effective only if
positioned or deployed in a manner consistent with local conditions.
The most valuable element in boom deployment is a sound work-
ing knowledge of local waterways. Knowledge of currents, tides
natural catch areas, water depth, etc., is invaluable in effecting
a more rapid response. A second element necessary for timely, ef-
fective deployment is the availability of ready support equipment.
If the water body is large enough to require a boat for boom 'de-
ployment, it is important to have available some sort of towing
bridle that will place the strain on the tension member.
The following examples demonstrate various technique's'that
are widely used to contain oil with booms under different stream
conditions (Figures 5, 6, and 7). The illustrated solution is
not always effective. In the case of most rivers, currents
usually subside at or near the banks. Because of reduced flow
in these areas, some containment can normally be expected near-
shore. As can be seen, all of these deployment!techniques re-
quire the securing of an anchor on the leading edge of the boom.
A recommended method for anchoring the boom (Is shown in Figure 8.
COLLECTION
POINT
Figure 5. Small river with moderate depth of 15 to 20 ft (1).6 to
6.1 m) and slow current of 1.0 to 1.5 kn (1.8 to 2.8 km/h).
21
-------
ANCHOR
.>««*
COLLECTION PIT
Figure 6. Small river with moderate depth of 15 to 20 ft. (1.6 to
6.1 m) and moderate to fast current of 3 to M kn (5.6 to 7.1 km/h).
Figure 7. River of moderate to deep depth and fast current.
BOOM
ANCHOR BUOY
ANCHOR LINE
(RECOMMENDED iCOPE
7x WATER DEPTH)
= 6-8 FT
ANCHOR CHAIN
OANFORTH ANCHOR
Figure 8. Normal configuration for anchoring booms.
22
-------
7.1 . 2 Earthen Dams
x ^.-.
Earthen dims arc a second type of barrier. This moasure is
used most frequently on small creeks or tributaries, but could be
effectively used on slightly larger water bodies if the flow rate
^s slow J<0.5 knots (kn)]. Earthen dams are very easy to con-
struct, using a bulldozer, dragline, or backhoe. The primary ob-
jective is to allow the water to pass downstream while containing
•the oil. Water passes through an inverted siph'on or inclined
pipe, which is placed below the water surface (Figure 10-12).
Barriers of straw and/or peat can also be constructed easily.
The type barriers or dams may be constructed in a variety of
means. Typically chicken wire or something similar is strung
across the stream/creek and the straw or peat is placed on the up
stream side of the wire. It maybe desirable to use a second
string of wire to contain the straw or peat should the stream or
creek be prone to directional current changes. Natural debris
such as a log jam may also be used to the responders advantage.
In summary, it should be remembered that physical barriers.
whether booms or dams, are intended to restrict the spread of
oil/hazardous materials and decrease contamination. , -Inr all oil
spill situations, rapid response is the key to an effective oper-
ation, and containment must be accomplished as score As possible,
using the best available resources.
Figure 9. Back moored boom technique for containing spilled oil in tidal-
influenced estuaries and bays.
23
-------
DRY DITCH OR RAVINE
BLOCKED TO FORM HOLDING POND
ss& DRY
DITCH '>
FILL
• FILL SHOULD BE COMPACTED
BY ANY AVAILABLE MEANS DURING
CONSTRUCTION
FIGURE 10
-------
WATER BY-PASS DAM
(VALVED PIPE)
VALVED PIPEtS- OF
AOOUATE CAPACITY
TO BY-PASS WATER
WATER FLOW OF STREAM OR SURFACE WATER DRAINAGE
IS BY PASbfcD TO MAINTAIN RESERVOIR LEVEL. SOIL IS
SKIMMED OFF OR ADSORBED AS CONDITION1.DIC7T ATE
CREST OF DAM SHOULD BE SUFFICIENT WIDTH TO
ACCOMODATE COMPACTION VEHICLE. HEIGHT OF FILL
2 TO 3 FEET ABOVF FLUID LEVEL. NORMAL FALL ANGLE
OF FILL WILL SUFFICE FOR SLOPING.
FIGURE 11
25
-------
WATER BY-PASS DAM
(INCLINED TUBE)
ELEVATE DISCHARGE END OF TUBE(S) TO
DESIRED RESERVOIRjUEVEL.
/OIR
-------
SUSPENDED BARRIER
Straw Layer(6"min. thick)
Width of Barrier
10-15 Feet Upstream
Anchor at 6-8 Feet t
Intervals Along Bottorn
of Wire Mesh
•STAGE BARRIERS IN SERIES
OF TWO OR MORE
•SELECT QUIESCENT AREA OF
STRFAM TO LOCATE BARRIERS
FIGURE 13
27
-------
7.1.3 Skimmers
Assumingthat efforts to contain the discharged oil have
J proved successful, recovery of the spilled oil is then begun.
Removal is usually accomplished with the use of mechanical devices
called "skimmers".
Skimmers, as the name implies, are designed to-collect, or
skim, the floating product from the surface of the water. Skim-
mers' can be grouped' into four basic categories: (12) vacuum or
„. suction type, (2) weirs, (3) dynamic inclined plane, and (4) oleo-
. v "••.».•• ." philic belts, drums, and disks.
7.1.3.1 Vacuum or Suction-Type Skimmers
The suction-type skimmer is a simple device in terms of both
design and operation. A suction head and pump are involved, and
these devices simply vacuum the oil from the surface of the water.
One sample of a suction-type skimmer head is called a "duck bill"
(Figure 14). The primary advantages of using this device are its
adaptability to most environmental situations, its ability to
handle almost all types of oils, and the simplicity of ^.operation
in most water depth. Its disadvantages include a • tendency to
become clogged with debris and the need for continual maintenance
during recovery operations to prevent clogging and al-low efficient
skimming. „,„*.„„„
Figure 14. Illustration
7.1.3.2 Weir Skimmers Of a suction-type skinner heM fprQ removing
Weir skimmers are probably the most widely recognized type of
recovery device available today. In addition, they are the most
widely available type of skimmer for pollution recovery
operations.
Weir skimmers consist of four primary components: (1) a
flotation device to suspend the skimmer in water, (2) a reservoir
to collect the oil, (3) a device to adjust the skimming level to
minimize the quantity of water entering the reservoir, and (4)
some method to empty the reservoir, either by positive displace-
ment pumps or suction (Figure 15) .
The idea behind this device is commonly referred to as the
"waterfall" priniciple. The collecting reservoir is submerged to
the level of the oil/water interface, at which point, gravity
forces the oil into the reservoir, creating a "waterfall" effect.
The advantages of this type of skimmer include its high mobility
and good recovery efficiency in relatively calm water. The wier
is susceptible to being clogged with debris, but a screen can be
placed around the unit to minimize this problem.
-28-
-------
OIL SLICK
- WATER
COLLECTION RESERVOIR
SUCTION DISCHARGE HOSE . •< /
Figure 15. Vertical and lateral views of the components of the»vyfeir
skimmer.
8.1.3.3 Dynamic Inclined Plane Skimmers , '
Dynamic inclined plane skimmers use an inverted, continuous
belt; that is, a belt that runs from high ,$o low, as opposed to
normal conveyors which run from low to 'higii (Figure 16 ). The
belt takes the oil below the surface of thp water. The' oil
leaves the belt and floats upward to a J-eservoir, where it is
collected and pumped to a storage container. Like oleophilic
skimmers, which are discussed later, dynamic inclined plane
skimmers have good recovery efficiency and are available in a
variety of sizes. Both types have restrictions on maneuver-
ability and loss of efficiency when trash or debris is present.
Figure 16. An illustration of the dynamic inclined plane skimmer in
operation.
29
-------
? 7.1.3.4 Oleophilic Skimmers
Oleophilic skimmers are operated on the principles of oil
absorption. The term "oleophilic" means a strong affinity for
oil. Almost all of the oleophilic components of this type of
skimmer have the characteristic of being hydrophobia,, or water-
VL, jj-. ~ resistant. The common denominator of all oleophiVic recovery
- '•*" devices is the passing of the "absorbing1 material continuously
through the spilled oil. The oil adheres to the surface and is
removed from the water. At this point, the oleophilic member is
wiped or squeezed by rollers or blades and the oil is deposited in
a reservoir. the product in the reservoir is then pumped into
some type of holding container.
Oleophilic skimmers are the most sophisticated recovery
devices available today, usually employing several different
mechanical systems, which require varying levels of preventive
maintenance and highly trained operators for use.
The rotating disk, or drum systems, as shown in Fig-ure 17,
are noted for very efficient recovery of oil in deeper water where
little or no debris is present. Available in various sizes, the
large models normally require extensive logistic support.
* * i
<• The most widely used oleophilic skimmers are of thfe belt and
rope type. These devices operate very efficiently in both thick
and thin slicks, and are usually capable of» recovering sheens.
Their ability to remove oil mixed with smaH amounts of debris
remains almost as efficient as debris-free environments.
-------
FIXED WIPER
COII.ECT10N TROUGH
Figure 17. Oleophilic drum skinner.
COLLECTION RESERVOIR
Figure 18. A continuous-belt oleophilic skimmer for recovering
spilled oil on the surface of the water.
31
-------
TABLE 5
EPA ACCEPTANCE LIST
DISPFRSANTS COLLECTING AGENTS, BIOLOGICAL ADDITIVES
C.ompany
Product Name
Chemical Agent Date of Acceptance
Shell Oil Company
Two Shpl' Plaza
P.O. Box 2105
Houston, TX
Natural Hydrocarbon
Elimination Co
5400 Memorial Drive
Suite 812, Houston, TX
Whale Chemical Co.
58 Winant St.
State Is., N.Y.
Ara-Chen, Inc.
808 Gable «ay
El Cajon, CA
GFC Gnomical Co.
2539 Old Okeechobee Rd
West Pain Beach, FL
Adair Equipnent Co.
P.O. Box 19333
Houston, TX
Oil Herder
NOSCUM
Seanaster
NS-555
Surface
Collector
Biological
Additive
Dispersant
Gold Crew Dispersant
Dispersant
JVk
Atlantic-Pacific Dispersant
. Oil Dispersant '
Cold Clean Dispersan
BP North Anerica,
620 Fifth Ave.
New York, N.Y.
Exxon Chenical Co.
1333 W. Loop South
Houston, TX
Continental Chenical
270 Clifton Blvd.
Clinton, N.J.
BP North America,Inc.
620 Fifth Ave.
New York, N.Y.
U.S. Navy
Naval Ship Engin.
Center, Washington, D
Inc. BP-1100X
Dispersant
Corexit 9527 Dispersant
Conco Dispersant
Dispersant K
CP-1100 WD Dispersant
Oil Spill
Romover
.C.
Surface
Collector
Sept. IP. 1976
Sept. 16, 1976
June 6, 1977
Aug'' 31, 1977
sJpt. 19, 1977
Oct. 7.1977
Oct. 20, 1977
March :o. 1978
April 05. 1978
May I1. . 1978
Aug. ~>1 , 1978
-32-
-------
Company
Product Name Chenlcal Agent Date of Acceptance
Exxon Chemical Co.
1333 W. Loop South
Houston, TX
Exxon Chemical Co.
1333 W. Loop South
Houston, TX
Bioteknika Intl., Inc.
7835 Greeley Blvd.
Springfield, VA
Proform Products Corp.
230 California Ave.
Palo Alto, CA
Drew Chemical Corp.
One Drew Chemical PI.
Polybac Corp.
1251 S. Cedar Crest
Blvd., Suite 304A
All en town, PA
Arco Chemical Co.
P.O. Box 370
Sand Springs, OK
Aspra, Inc.
4401 23rd Ave.
Seattle, WA
American Petrofina
P.O. Box 2159
Dallas, TX
Petrocon Marine &
Industrial Chemical
243 44th St.
Brooklyn, N.Y.
Polybac Corp.
4 West 58th St.
New York, N'.Y.
Corexit 8667 Dispersant
Corexit OC-5 Surface
Petrodeg 100 Biological
Additive
Proform-
Pollution
Control Agent
Dispersant
Aneroid Oil Spill Dispersant
Dispersant/LT
Petrobac R
Biological
Additive
ArcoChern D-609 Dispersant
BC.O Allan ' tol Dispersan
AT7 »
Finasol Osr 8 Dispersant
Oil Spill
Eliminator
N/T No. 4
Hydrobac
Dispersant
Biological
Nov. 1 , 1978
Nov. 1 , ]978
Dec. 15 ,, 1978
May 9, 1979
^JL^ 1979
« /'
Aug. 4, 1979
if
Aug. 20, 1979
Nov. 13,, 1979
May jl , iPSO
Hay 21, 15)80
-33-
-------
7.1.4. Chemicals for Oil Spill Cleanup
t The uso o£ chemicals must he In accordance with Annex X of
the National Oil and Hazardous Substances Contingency, Plan. The
list of accepted chemicals is shown in Table 5.
7.1.4.1 Dispersants
„« The Federal OSC, on a case-by-case basis, can approve the use
..v -r- Qf chemlcal dispersants on any spills if it is determined they
will prevent or substantially reduce the hazard to human life or
substantially reduce explosion or fire hazard to property. All
other cases must be approved by the EPA RRT representative after
consultation with appropriate Federal and State agencies. In all
cases, appropriate application rates and methods must be used.
7.1.4.2 Collecting Agents
The OSC may authorize use of the surface collecting agents on
minor, medium and major discharges on a case-by-case^ ,ppis if
their use will result in the least overall environmental damage or
interference with water uses, and greatly enhance' removal
actions.
7.1.4.3 Burning Agents •**
'
% The use of burning agents may be authorized on a -case-by-case
basis by the OSC with approval from the RRT, State, and local air
pollution control agency. However, it mxidt be recognized that
burning off is potentially one of the most dangerous treatment
operations. It should only be considered when it can be
determined that the risks to people wou.ld 'be greater if burning
were not attempted. f
7.1.4.4 Biological Additives
Biological additives, such as bacteria cultures, have proven
successful in degrading a variety of chemical wastes. The success
of this method is dependent upon many factors; therefore, each
case must be evaluated individually.
-34-
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7,2 CLEANUP TECHNIQUES FOR HAZARDOUS SUBSTANCES
Methods for controlling spills of hazardous substances are
shown in Tables 6 and 7. Techniques discussed in Section 8.1 may
t also be applicable for hazardous substances which float.
Candidate schemes for the treatment and disposal -of hazardous
substances include: 1) Carbon Adsorption, 2) Filtration, 3) Ion
Exchange, 4) Gravity Separation, 5) Neutralization, 6) Coagulation
Precipitation, 7) Reduction, 8) Oxidation and, 9) Dilution and
., ,A '.._.*.. Dispersion. These treatment schemes can be achieved either in a
...>. r.v-.--^ batch mode depending on the hazardous materials containment or In
' a flow through process. Consideration should also be given
whether the material can be discharged to a municipal treatment
plant without creating a major upset. This may be prior to or
following treatment of hazardous materials on site. Also, due to
the high solubility of most hazardous substances, success of any
treatment scheme is dependent on quick containment of the spilled
materials.
7.2.1 Carbon Adsorption
Carbon adsorption is a physical phenomena which , wano'vps
organic matter and some inorganic chemicals from water. These
chemicals are physically adsorbed on the large surface arete of the
carbon (500-1000 m^ per gram). Activated carbon is produced
from many materials including wood, coal, lignite, etc. The
." adsorption process and its effectivenesses dependent on the
- •- nature of the material being adsorbed and on the type t-'of carbon
used. In general, concentrations of greater than 1000 'mg/I of a
contaminant requires excessive detention time's and excessive
quantities of carbon. The amount of carbonjJneeded to adsorb a
given chemical must be established by field^testing. .When the
capacity of the carbon has been exhausted fthe carbon must be
replaced and the spent carbon disposed of.jj Table 7 gives general
guidelines for the adsorbability of various organics on activated
carbon. In situ use of carbon would generally consider the addit-
ion of powered activated carbon directly to the spill site.
Effective mixing of the carbon with the contaminated water in
question is essential for effective adsorption to occur. Off-site
treatment would involve pumping the contaminated water through a
granular carbon column (See Table 8).
7.2.2. Filtration
Filtration is designed to remove particulate natter by pass-
ing the contaminated water through a layer of porous media such as
sand. The treatment may be employed as a pre-treatment prior to
passing the water through a carbon column or ion exchange system
or as a polishing step for removal of a particulate after' a
chemical reaction. While various types of media are used in
-35-
a
-------
iH. if— •
filtration a simplified mode for field application would generally
consider a gravity or pressure flow dual media filter column.
During a filter run, the head loss will gradually increase due to
accumulation of solids within the filter media. When the hr>a.1
loss roaches the limit set by the hydraulic conditions of the
filter design the filter run will stop and the- filter is
backwabhed. In some cases the effluent quality from the filter
may control the termination of the filter run. Filters may be
backwashed with sorted filter effluent, in which case the backwash
waste after removal of a suspended solid Is retreated an.i
refiltered. In situ filtration may involve permitting water ..o
pass by gravity through a built-up sand or coal bed. Continuous
filtration will usually involve bringing in a portable filter tor
direct application at the site.
7.2.3 Ion Exchange
Ion exchange is a process in which ions held by electrostatic-
forces to functional groups on the surface of a. solid are ex-
changed for ions of a different species in solution. The process
takes place on a resin which is usually made of synthetic mat-
erial. Various kinds of resin are available including weakly
acidic and strongly acidic ion exchange resins depending on the
application involved. The ions are exchanged until ttjre resin is
exhausted and then the resin is regenerated with a concentrated
solution of ions flowing in a reverse direction or replaced with
new resin. The amount of resin required must be established b>
chemical tests done on the wastewater for the ion' content of
interest. The best type of resin is established mainly by the
specific contaminant to be removed, the .amount of wastewater
involved and other ionic demands on theljresin. Ion exchange
treatment can be accomplished by of f-sitejfpumping of the waste-
water in question through an ion exchangp column with the ability
to either regenerate or replace the rfrsin when it becomes ex-
hausted. In situ treatment in a manned similar to carbon would
involve mixing the resin with the wastewater in question in a
suitable containment area.
7.2.4 Gravity Separation
Gravity separation involves removal of suspended solids with
a specific gravity greater than water by the process of sediment-
ation or particles with a specific gravity less than water bj
flotation. Sedimentation is removal of solid particles from a
suspension through gravity settling. The process may be used as a
pretreatment and concentration step to reduce the load subsequent
to other processes, thereby utilizing a natural concentration
procedure. Various factors affect the rate of settling including
particle size and shape, density and viscosity of water, and the
presence of other materials in the water. The rate of settling
while predictable using theoretical equations, should eroploj a
field testing procedure. While sedimentation may involve the
-36-
-------
removal of hazardous solid materials, it is most often associated
with the coagulation process. Flotation is used to separate tho
materials with a specific gravity less than water. Thp
contaminant rises to the top and is skimmed off periodically.
7.. 2. 5 Neutralization
Neutralization is a process in which hydroxyl or hy1rofeen
ions are added to a solution to produce an approximately equal
concentration or pH . 7. Acidic wastes can bo neutralized' usine
caustic soda (NaOH) , lime (Ca[OH],), or soda ash OJaCo-,)?
Alkaline wastewaters are neutralized by tho addition of
hydrochloric acid (HCL) or sulfuric acid (H2S04). Stronglv
basic NaOH, strongly acidic H2S04 and HC1 must be added very
carefully, to., avoid creating a violent reaction. These chemicals
may need to be diluted or nixed with sand prior to use - in order to
avoid a violent reaction. Complete nixing of the contents is
especially important to avoid pockets of strong chemicals in th-
in the liquid. T,he other agents are considered weaker acids and
bases and react slower than the strong acids and bases.. The
amount of neutralizing chemical required should be determ-is^d bv a
bench scale test.
» /
7.2.6 Coagulation Precipitation /
Coagulation precipitation is a process which removes pbllut-
ants b->' reacting these materials to form an insoluajjle product
Thls- process results in a reaction rather thfen physical
adsorbtion. There is a series of steps «to allow effective
precipitation; (1) chemical addition, (2) limpid mix, (3) addition
of coagulant, (4) f locculation. (5) sedimentation and in some
cases (6) filtration. Each precipitation reactions may not
require a11 of these steps. Precipitation 'is used to remove many
types °f metal cations and some anionjl such as fluorides and
sulfides. The agents involved in precipitation reaction include
calcium, sodium hydroxide, sodium bicarbonate, sulfate and
sul fide. These chemicals are added at a certain pH . The anount
of chenicals required to precipitate a particular constituent are
determined by running a bench scale test. Coagulation involves
the addition of a coagulant such as ferric chloride, aluminum
sulfate or organic polyelectrolytes in order to precipitate
specific wastewater constituents.
Ferric Chloride As Coagulation Aid
This compound is effective in clarifying both organic and in-
organic suspensions. The final pH should be above 6 for the best
results or caustic soda may be needed to control pH. Large sus-
pensions require dosages of approximately 50-500 mg/1, although
larger doses may be needed for very high waste concentration or
-37-
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TABLE 7
INFLUENCE OF MOLECULAR STRUCTURE
AND OTHER FACTORS ON ABSORBABILITY
U An Increasing solubility of the solute in the liould carrier
decreases its adsorbabillty. *-«" ner
2. Branched chains are usually more adsorbable than straieht
chains. An increasing length of the chain decreases solu-
3. Substituent groups affect adsorbability:
Substituent Group Nature of Influence
Hydroxyl Generally reduces adsorbability;
extent of decrease depends on
structure of host molecule.
Aclino Effect similar to that of hydroxyl
but somewhat greater. Many amino
acids are not adsorbed to any
appreciable extent. . •' /'
Carbonyl Effect varies accorfli'ng to host
molecule; glyoxylic is more
adsorbable^than acetic but similar
increase does not .occur when
introduced into higher fatty
acids. i
Double Bonds Variable effect as with carbonyl.
Halogens Variable effect.
Sulfonic Usually decreases adsorbability.
Ni-tro Often increases adsorbability.
4. Generally, strong ionized solutions are not as adsorbable as
weakly ionized ones; i.e. , undissociated molecules are in
general preferentially adsorbed.
5. The amount of hydrolytic adsorbtion depends on the ability of
the hydrolysis to form an adsorbable acid or base.
6. Unless the screening action of the carbon pores intervene
large molecules are more sorbable than small molecules of
similar chemical nature. This is attributed to more solute
carbon chemical bonds being formed, making desorption more
difficult.
-41-
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TABLE 8
CARBON ADSORPTION
PRIORITY POLLUTANTS
EFFECTIVELY REMOVED BY
ACTIVITATED CARBON
Acrolein
Aldrin
Aroclor 1254
Arochlor 1260
Benzene
Chlorobenzene
,3 Dichlorobenzene
1,4 Dichlorobenzene
Hexachlorobenzene
Nitrobenzene
Bis(2 chloroethyl) ether
Carbon Tetrachloride
Chlordano
ODD
DDE
DDT
Dichloromethane
Dieldrin
n-Dibutyl Phthalate
1,2 Dichloroethane
Endrin
Heptachlor
Hexachlorobutadiene
Hexachlorocyclopentadiene
Lindane
Naphthalene
Phenol
0-Chlorophenol
2,4 Dichlorophenol
,6 Trichlorophenol
4, Nitrophenol
1,1,2,2 Tetrachloroethane
Tetrachloroethylene
Toluene
2,6 Dinitrotoluene
Trichloroethylene
ORGANICS OF DIFFERENT TYPES
EFFECITVELY REMOVED BY
ACTtVIATED CARBON
Acetic acid
Acetone
Aniline
Benzole acid
P-Cresol
0-Cresol
Dlethyl Ether
Dimethyl Malonic acid
Heptanoic acid
Hydroquinone
Isopropyl alcohol
Methylene blue
Methyl Parathion., ,.
B-Naphthol '
Parathion, •
PE01-400
PEG^-IOOO
•* 0'0-Biphenol
2-6 Dimethylphenol
Phenylacetic'acid
Propylamine
j^Resorcinol
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TABLE 10
GENERAL SOURCES FOR VARIOUS TREATMENT CHEMICALS
Chemical
Sources
.«>•*».
Acetic acid
Alum
Ammonium salts
Anion exchangers
Bottom pumps
Calcium carbonate
(limestone, practically
insoluble in water)
Carbon
Cation exchangers
Charcoal
CO2
Epsom salts
Ferric (or iron; salt
(Fe C13)
Lime
Peat mos>
Sodium bicarbonate
(baking t,.-r!a)
Sodian carbonate (soda ash)
Sodluri chl >nde (table salt)
Sodium sultate
Sorti.,-1 thiosulfate
Plastic or electronic"industries ,
grocery distributors (vinegar)
Water treatment plants
Hospitals, dye manufacturers
(must specify pollutant)
water softener suppliers
Fire departments, EPA Regional
offices, Coast Guard
, •' f
Cement plants
Water treatment plants , .sugar
refineries '
(must specify »poll utant)
water softene*^ suppliers
Hardware s^orfcs, grocery
distributors
Soft drink dealers, compressed
gas dealers
Drug stores, groceries
Water treat- «nt plants, pbuti
graphy shops
Cement plants
Nurseries, florists
Grocery d x^trLbutori; , bakeries
Grocery di-s t r ibuti rs , bakeries
Grocery d i,'5trih,;tors
Dye nanuta ~ t ur'.-s
m 1 1 1 1
stops, tanneries,
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-45-
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7.3 CONTROL OF LAND AND AIR SPILLS
7.3.1 Land Spills
Whenever possible, spills should be contained on-land as long
as a greater risk to life and property is not created ;by doing so.
Successful cleanup and treatment is much more likely and consider-
ably less expensive when the material is contained before it
reaches water. Table 11 presents several methods for controlling
spills on land.
In cases where the soil is particularly porous, materials
spilled on land may mi6rate down to the water table. If this
occurs, recovery is very difficult and may require the digging of
wells for purposes of monitoring movement or recovery of the
material. In such cases the technical assistance of a groundwater
hydrologist or other appropriately trained individuals will be
required.
7.3.2 Air Spills
Air spills (vapors, mists, etc.) are extremely dif-ffc'ult to
control. Evacuation of the affected area is often the only pract-
ical choice. However, Table 12 shows several methods w*Mch may be
considered in specific cases. When using a spray mist, consider-
ation must be given to the possible creation of a water pollution
problem. ,'
,f
-46-
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8'° DISPOSAL/RECOVERY PROCEDURES
After cleanup operations have removed the spilled material(s)
and contaminated debris from the water or ground, the OSC's re-
sponsibilities are not over. Improper shipping andrdisposal of
spilled cleanup waste can cause serious safety problems, as well
as result in secondary pollution as bad as, if not worse than, the
original spill. Therefore, the OSC must be assured that all chem-
lcal disposal is carried out in a safe and proper manner.
Disposal/recovery operations may involve the shipping of the
waste materials to a state approved land disposal site, treatment
by a reliable disposal or recycling company, or sending the
material to a sewage treatment plant, etc. The preferred method
of disposal would be to recycle to the spiller's company or to a
company that can use the material in its operation.
In all cases involving the disposal/recovery of oil and
hazardous substances, contact and coordination should be made with
all affected parties. EPA looks to the State pollution coalwol
agencies to obtain disposal sites and act as liaison between 'the
Federal government and local.agencies such as disposal sites, air
pollution control agencies, sewage treatment plants, etc. '
Extremely toxic materials may require special on-site treat-
raent, or as in the case of PCB's either incineration or .shipment
to an EPA/State approved disposal site. EPA, Edison, New Jersey,
has specialized equipment that may be available 'to treat these
very toxic materials. Coordination of this activity will be con-
ducted by the EPA Emergency Response Team. y
Generators (spillers) and transporters.* o*t hazardous waste
materials must obtain the appropriate EPA identification numbers
as required by RCRA (see Section 4.4).
9-° SPECIAL CONSIDERATIONS
9.1 SAFETY/DECONTAMINATION
9.1.1 General Considerations
The safety of the people who arrive on the scene of an oil or
hazardous material spill is critical to consider before any action
is taken. All spills are considered extremely dangerous.
Safety considerations should receive priority during the
decision-making process. Persons responding to spills are not
expected to risk personal Injury or contamination through intimate
physical contact with spilled materials, vapors, etc. Team
members should assess the situation and coordinate activities from
outside the high risk area and should enter such areas only in the
-47-
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event of inninent hazard to life and then only " P™P«r ^
is available, the individual has been thoroughly trained in its
uL. and two additional trained and properly equipped persons are
standing by to provide assistance.
Although the response organization utilized for
tne discharge of a hazardous chemical incident >* sl.n ohvs
for responding to an oil discharge, the state-°f-thVar
-------
have serious side effects. For example, materials which come into
contact with your pants leg may not cause illness or discomfort to
?*K *l ' r ln the home> a sma11 child coming into contact
with the contaminated clothing could be made seriously ill or
*£ , ,°\ thKS ,r«ason' U ls IMPHUTAIVE that you rfind out how
, , K ,' r ou ow
material should be treated. You may have to . remove your
Sl°« g °utslde so that y°ur vehicle, home or offfce does, not
become contaminated and cause unnecessary illness or death. If in
doubt, remove contaminated clothing before entering a building and
shower as quickly as possible to remove any contamination that may
be on the skin or in the hair.
n < though manv spilled materials will be in a solid or
liquid form, the greatest danger to personnel is from inhalation
or exposure to airborne gases, dusts, vapors, or fumes. The dan-
gers from vaporization, sublimation, or secondary reactions which
produce toxic airborne materials cannot be overemphasized.-' /'
Common sense and alertness will prevent most accidents- con-
irHur overconfidence and ignorance are the leading causes of
• *•
9.1.2 Site Control
t
Traffic and spectators should be kept aw,ay from the accident.
Do not let vehicles stop in, or pass thrttiigh, the area of the
spilled materials. »'
r
If hazardous or toxic vapors are escaping from a spill, it is
Dest to take action to evacuate people frbm the area downwind1 from
the spill until the spill has been cleaned up.
In the event that the evacuation of civilian personnel be-
comes necessary, the procedure should be coordinated through local
officials. Although the OSC may determine that evacuation may be
advisable in any given situation, the responsibility to make,such
a decision rests with local civilian officials. Close liaison
with local police and fire officials is a necessity.
Access to the control site is limited to essential personnel.
The designated control site consists of the command post (upwind
and outside the contamination control site), contamination reduct-
ion area, and exclusion area.
The complexity and size of the controlled site is dependent
upon the actual site conditions and decontamination requirements.
Figure 18 illustrates a controlled site situation.
-49-
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WIND DIRECTION
\
EXCLUSION AREA
(CONTROL AREA)
"HOT"
\
20°
20°
\ CONTAMINATION
HOT LINE—»\ CONTROL LINE
\
COMMAND POST
ACCESS
CONTROL-
POINTS
PERSONNEL DECON STATION)
= 40 K ZHH
HOT LINE-*/ CONTAMINATION-
/ CONTROL LINE
1
FIGURE 19 FIELD CONTROL SITE
50
-------
9.1.3 Equipment and Clothing
.' Spills of toxic materials can drastically alter the ambient
environment. Consequently, an accurate assessment of hidden
dangers is an integral part of safety considerations. Field
n monitoring equipment for oxygen deficiency, combustible gases and
vapors, and radiation are necessary in atmospheres 4where these
problems could be found.
It is important that personnel protective equipment and
safety requirements be appropriate to protect against the poten-
tial or known hazards at an incident. Protective equipment should
_#*.%»:•;» li'i*?-- *•• be selected based on the type(s), concentration(s) , possibilities,
and route(s) of personnel exposure from the substance(s) at a
site. In situations where the type of materials and possibilities
of contact are unknown or the hazards are not clearly identifi-
able, a more subjective determination must be made of the per-
sonnel protection equipment required for initial safety.
The appropriate level of protection should be determined
prior to the initial entry on-site based on best available inforra-
-ation. Subsequent information may suggest changes in the original
level selected. '
. •' r
Levels of Protection
* /
When response activities are conducted where atmospheric con-
tamination is known or suspected to exist; there is a potential
f for the generation of vapors or gases^ or direct contact with
' ^ toxic substances may occur, equipment to protect personnel must be
worn. Personnel protective equipment is designed to prevent or
reduce skin and eye contact as well as inhalrftion or ingestion of
the chemical substance. Respirators cfljn protect the ,lungs,
gastro-intestinal tract, and eyes againat atmospheric hazards.
• The surfaces of the body can be protected Against contact with and
possible adsorption of chemicals by chferoical-resistant clothing.
Good personal hygiene practices presents ingestion of toxic
materials.
Personnel equipment to protect the body against contact with
, . known or anticipated chemical hazards has been divided into four
categories commensurate with the degree of protection afforded.
LEVEL A - protection should be worn when the highest level of
respiratory, skin, eye and mucous membrane proteciton is needed.
LEVEL B - protection should be selected when the highest level of
respiratory protection is needed, but a lesser level of skin and
eye protection. Level B protection is the minimum level recom-
mended on initial site entries until the hazards have been further
identified and defined by monitoring, sampling, and other reliable
methods of analysis, and personnel protection corresponding with
those findings utilized.
-51-
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absorbed by the- skin, Level A protection should be worn, until
more definitive information can be obtained.
An upper valve of 1000 ppm total organic vapors/gases has
been established for the use of Level A Protection. Ail indication
of 1000 ppm or greater should not be misinterpreted- as a level
that will exceed the protection afforded by a fully-eSicapsulating
suit, but as a check point for evaluating the need for more
extensive qualitative and quantitative analysis before entry
continues.
LEVEL B PERSONAL PROTECTIVE EQUIPMENT
- Pressure-Demand, Self-Contained Breathing Apparatus
(OSHA/NIOSH approved)
- Chemical resistant clothing (overalls and long sleeved
jacket; coveralls; hooded, two-piece chemical-splash suit;
disposable chemical resistant coveralls)
- Coveralls (under splash suit)*
- Gloves, outer, chemical resistant
- Gloves, inner, chemical resistant , .* r
- Boots, outer, chemical resistant, steel toe and shank
- Boots, outer chemical resistant (disposable)*/'
- 2-way radio communications (intrinsically safe)
- Hard Hat*
- Face Shield* *
•'
CRITERIA FOR SELECTION OF LEVEL B PROTECTION!
When the type(s) and atmospheric o^ncentration(s) of toxic
substances are known and require the highest degree of respiratory
protection, but a lower level of skin an
-------
GUIDANCE ON SELECTION CRITERIA FOR LEVEL B PROTECTION
Level B personnel protective equipment provides a high degree
of protection to the respiratory tract, but a somewhat. lower level
of protection to the skin and eyes. The chemical resistant
clothing required in Level B is available in a wide variety of
styles, materials, construction detail, permeability , -retc. these
factors all effect the degree of protection afforded. Therefore,
the selection of the most effective chemical resistant clothing
(and fully-encapsulating suit) should be done by a qualified
individual based on the known or anticipated hazards and/or job
function required.
The selection of Level B rather than Level A is generally
based on the protection needed against known or anticipated toxic
hazards affecting the skin. The determination is based on:
1. Comparison of air concentrations of identified
substances with criteria for protection for skin. .
2. A lesser potential for splash, vapor generation,, ,or
contact with substances because of job functions-' and/or
the substances encountered are judged to present a
lesser degree of hazard to the ski«k
3. The absence of toxic substances affecting the skin;, or
substances that are not amenable »to rapid field
analysis or monitoring. j
For initial site entry and reconnaissance at an open site,
approaching whenever possible from the upwind direction, Level B
Protection (with good quality, hooded, chemical resistant cloth-
ing) should protect response personnel providing the conditions
described in selecting Level A Protection are known or judged to
be absent.
An upper value of 500 ppm total vapor/gas concentration for
wearing Level B was selected as a concentration above which; up-
grading to Level A protection may be warranted. A major factor
for reevaluation is the identification and potential for the
vapor/gases to be skin hazards requiring a higher degree of pro-
tection.
In situations where extensive personnel decontamination may
be required, the exposed self-contained breathing apparatus (SCBA)
presents a decontamination problem. To prevent or reduce iSuch
difficulties, Level A protection which is less difficult to decon-
taminate could be worn, or a modified Level B using a chemical
resistant apron (smock), or a disposable, encapsulasting garment
worn over the chemical resistant suit.
-55-
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LEVEL C PERSONAL PROTECTIVE EQUIPMENT
? - Full-face, air-purifying respirator (OSHA/NIOSH approved)
- Chemical resistant clothing (one-piece coverall; hooded,
two piece chemical splash suit; chemical resistant hood
and apron; disposable chemical resistant covera-lls)
- Gloves, outer, chemical resistant ':
- Gloves, inner, chemical resistant*
, V^'H. **" ** ~ B00*6- steel toe and shank, chemical resistant.
- Cloth coveralls* (inside chemical protective clothing)
- Hard Hat (face shield)*
- Boots, outer, chemical resistant (disposable)*
- 2-way radio communications (intrinsically safe)
- Escape mask
CRITERIA FOR SELECTION OF LEVEL C PROTECTION
Measured air concentrations will be reduced by the respirator
to or below the substance's protection guideline and the concen-
tration is below the service limit of the canister.
Atmospheric contaminant concentrations do not exceed the IDLH
levels. '/
Contaminant exposure to unprotected ajeas (head and neck) are
• * within skin exposure guidelines, or derraa^hazards do not exist.
Job functions and potential for high exposures have been
Judged not to require a higher Level of Protection.
Total vapor readings register between $ ppm and 5 ppm above
background on OSHA/NIOSH approved portable air monitoring
instruments. i,
Periodic air monitoring must occur.
GUIDANCE ON SELECTION CRITERIA FOR LEVEL C PROTBCITON
Level C protection is distinguished from Level B in the
equipment used to protect the respiratory system, assuming the
same type of chemical resistant clothing is used. The main
selection criteria for Level C is that conditions are such that
air-purifying devices may be worn.
The air-purifying device must be a full-face mask
(OSHA/NIOSH approved), equipped with a chin or harness suspended
canister. Canister/cartridges must be appropriate to remove the
substances encountered. Quarter or half-masks or cheek cartridge
full-face masks, should not be used on a routine basis for
response activities and only when their use is approved by a
qualified individual.
*0ptlonal
-56-
-------
In addition, a full-face, air-purifying mask shall be used
only under the following conditions:
1. Oxygen content of the atmosphere is at least 19.5% by
volume.
2. Substance(s) is identified and it's concentration^) '
measured.
3. Substance(s) has adequate warning properties. ;
4. Individual is successfully qualitative fit-tested to
the mask.
5. Appropriate cartridge/canister is used and its service
limit concentration is not exceeded.
Whenever Level C is used, an air monitoring•program must be
instituted to detect any changes in atmospheric concentrations.
An air monitoring program is required during all longer-term site
operations where atmospheric contamination may occur.
Total unidentified vapor/gas concentrations of 5 ppm above
background concentrations require that Level B protection be used.
The selection of Level C (air-purifying respirators) protection
for use in an unidentified vapor/gas concentration from Or5 ppm
above background should only be done by a qualified indiviaual'.
flhen using the cannister-type mask for known contaminants,, Level B
protection should be used when readings over 1000 ppm. are
detected.
LEVEL D PERSONAL PROTECTIVE EQUIPMENT
- Coveralls >
- Boots/shoes, safety or chemical resistant steel toe and
shank 1
- Boots, outer (chemical resistant disposables)*
- Safety glasses or chemical splash goggles*
- Hard Hat (face shield)* ~
- Escape Mask*
- Gloves*
CRITERIA FOR SELECTION OF LEVEL D PROTECTION
No idication of any atmospheric hazards.
Work function precludes splashes, immersion, or potential for
exposure to any chemicals. '.
GUIDANCE ON SELECTION CRITERIA FOR LEVEL D PROTECTION
Level D protection is primarily a work uniform and should not
be worn in any area where the potential for contanination exists.
In situations where respiratory protection is not necessary
but site activies are needed, chemical resistant garments - high
quality or disposable - must be worn.
-57-
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the Interior) representatives and the State liaison to the RRT
will arrange for and coordinate actions of professional and
? volunteer groups that wish to establish bird collection, cleaning,-
and recovery centers.
9.3 ENVIRONMENTAL DAMAGE ASSESSMENT
Even though initial response to an environment.*! emergency
does not include a formal damage assessment, the field investi-
"-*«« , yi.v~v i*~* *'• gator should be alert to the obvious signs of environmental harm.
This could include indications of a fish kill, oiled and dying
.v«9» birds, contamination of beaches and marshlands, etc. Any signs of
environmental damage should be reported to the EPA Emergency
Response Team who will, in conjunction with the appropriate
resource agencies, coordinate any necessary damage assessment.
10.0 SAMPLING AND DOCUMENTATION
10.1 SAMPLING PROCEDURES
The collection and subsequent analyses of samples.,/s im~
portant in evaluating the progress of spill clean-up, the exposure
levels of clean-up personnel and exposed general population and
the damages to natural resources. Therefore, it is also" important
to collect samples as soon as possible after the spill occurs for
„ spill identification and assessment and for* later use as evidence.
* Likewise, it is important to collect samples at the beginning of
and during the cleanup operation to document tyie progress of the
cleanup. Proper sample collection involves a 'variety of factors
relating to container material, quantity of ^anples, preservation,
hazards to sampling personnel and others which are most properly
addressed by having a sample collection SOP brepared in advance of
response activities and having sampling dt>n<* by professional per-
sonnel operating in concert with the selected analytical labor-
atory.
10.1.1 Method of Sampling
Sample collection during the early phases of response actions
will generally be discrete grab samples collected manually.
Samples should not be collected without adequate for thought as to
the desired data outputs and the hazard of the material involved.
There are certain objectives of sampling during hazardous
materials incidents which occur frequently enough to list as
generally applicable to all incidents.
1) releases material - a sample (generally 1 pt or less in
glass) of the undiluted spilled material may be collected
by hand with adequate safety precautions to document the
hazard, identify responsible parties and evaluate
treatment and disposal options.
2) reaction products - released material mixed in some envi-
ronmental matrix (soil or water) may be sampled (generally
for more of the same containers as the pure spilled pro-
duct) to assist with evaluations of removal and recovery
options.
-60-
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, ' . . 3) exposure of personnel - sampling of atmospheric or potable
water supply contamination is generally performed by an
experienced team with specialized materials.
In summary, sampling at the scene of a spill will usually be
performed manually because of the emergency and temporary nature
of the situation. Also, the presence of personnel oji the scene
-v ws.v!..ViiM«-— *-• raay make it convenient and economical to take manual field
."'" • samples. Guidance on selection and use of automatic samplers
analytical devices can be found in other publications. The
following discussion will assume manual sample collection although
the theory could also apply to the use of an automatic sampler.
10.1.2 Type of Samples
There are two types of samples which can be collected for
analysis: 1. Grab (discrete samples) and 2. Composite-samples.
Grab or discrete samples characterize the material,, .being
sampled at a particular instant in time. The purpode' of a
composite sample is to mix discrete samples in such ,a/ way to
represent the1average characteristic over a period of tim4 or over
an extensive area. In addition to generating an average value,
composition is often done to reduce the analytical load placed on
** the laboratory.
The choice of the type of sample should deptend on the objec-
tive of the sampling and the variability of ttye material or area.
If the variability of the parameter of Interest is low (that !is,
if the concentration of the parameter of interest changes little
over time) , then a grab sample may characterize the quality
adequately. On the other hand, if the variability is high, then a
composite should be formed from grab samples taken at short
intervals, or the grab samples themselves should be collected :and
analyzed. If nothing is known about the variability of the
material, then grab samples should be collected and analyzed
initially to determine the variability. Judgement will have to be
exercised in terms of the allowed variability.
10.1.3 Sample Containers
Samples must be taken in appropriate sample containers to
reduce the possibility of contamination or adsorption which will
yield incorrect results. The container must be completely clean
and equipped with a tightly fitting cap. Organic hazardous mater-
ials must be contained in a glass jar or bottle to reduce adsorp-
tion to the container walls. Specifically, oils and grease, pest-
icides, or even short chain organic compounds should be placed
into glass containers. Other materials such as metallic salts,
can be stored in plastic containers with no adverse effect.
-61-
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A SPILL
A-l INFORMATION CONTACTS
Information
Source
OHMTADS-EPA Oil and
Hazardous Materials
Technical Assistance
Data System
INFORMATION
Type of
Assistance
2,4
Access
Telephone
EPA Regional
OEf ice
913/236-3778
CHEMTREC - Chemical
Transportation
Emergency Center
CHLORBP - Chlorine
Emergency Plan
Chevron
Shell
Pesticides Safety
Team Network
Posion Control Centers:
CHRIS - Coast Guard Chemical
Hazards Response Information
System
EPA ERT - Environmental
Response Team
Coast Guard National
Strike Force
2,3
1,2,3
2-Chevron
Products
2-Shell Chem^als
1,2,3
2,4
1,2
.r
800/424-9300
Through CHEMTREC
(see above)
415/233-3737
618/254-7331
Through CHEMTRBC
{ (see above)
See local
directory
Natl. Response
Center
800/424-8802
EPA Regional
Office (above)
Natl. Response
Center of Gulf
Strike Team
601-683-2330
-66-
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Information
Source
Type of
Assistance
Access
Telephone
U.S. Army Technical
Escort Center, Chemical
Emergency Response Team
.EPA Regional
Office or
J03/521-2185
'Key: 1. Respond to scene with trained personnel if required
2. Provide information on identify, hazards, or what
to do
3. Refer to knowledgeable contact
4. On-line computer available
A-2
INFORMATION SOURCES
American Institute of Chemical Engineers, Control of Hazardous
Material Spills. Proceedings of the 1974 National Cof-
fer ence. New York. •' '
American National Red Cross. American Red Cross Standard First
Aid and Personal Safety. 1973. Garden City, New York:
Doubleday and Company. .jy
American Public Health Association. Standard Methods for Ex-
amination of Water and Wastewater. i
Association of American Railroads, Bureau of'.Explosives.
Emergency Handling of Hazardous Materialjs in Surface
Transportation. Washington, D.C. s T
Is
Best Company. Best's Environmental and Safety Directory.
Morristown, New Jersey: A.M. Best Company.
Biosciences Information Service.
of Environmental Pollutants.
Chemical Index Guide.
Abstracts on Health Effects
1975. Philadelphia:
Christensen, H.E. and Luginbybl, T.L. NIOSH Registry of toxic
Effects of Chemical Substances. Rockville, MD; U.S.
Department of Health, Education and Welfare.
Dow Chemical U.S.A. Chlorinated Solvents - Toxicity, Handling
Precautions, First Aid. Form No. 100-54490-76. Midland,
Michigan.
Hawley, G.G. Condensed Chemical Dictionary.
Nostrand Reinhold Co.
New York: Van
Little, Arthur D. Company. Spill Prevention Techniques for
Hazardous Polluting Substances. Washington, DC: U.S.
Environmental Protection Agency.
-67-
-------
j Heidi, James H. Hazardous Materials Handbook. 1972. Beverly
Hills: Glenco Press.
Mellan Ibert. Industrial Solvents Handbook. 1977. Park
Ridge, New Jersey: Noyes Data Corporation.
Meyer, E. Chemistry of Hazardous Materials. Englewood Cliffs,
'•-*" , vw*n.-STT-•*•• New Jersey Prentice Hall.
•1**a* National Association of Mutual Casualty Companies. Handbook
of Organic Industrial Solvents. 2nd Ed. 1961. Chicago.
National Fire Protection Association. Fire Officers Guide to
Dangerous Chemicals. Boston.
Fire Protection Guide on Hazardous Materials. Boston.
Hazardous Chemicals Data 1976. NFPA No. 49. Boston.
••* f
National Fire Codes. Vol. 13, Hazardous Materials. Boston.
* /
Patty's Industrial Hygiene and Toxicology. 1978. Mew York:
John Wiley and Sons.
Powers, Philip W. How to Dispose of Toxic Substances and
Industrial Wastes. 1976. Park Ridge,t New Jersey: Noyes
Data Corporation. '
Sax, Irving. Dangerous Properties of Industrial Materials.
New York: Van Nostrand Reinhold Cofnpany.
£
TRW Systems Group. Recommended Methdfts of Reduction, Neutrali-
zation, Recovery or Disposal of Hazardous Waste (Volumes
1-16). Springfield, Virginia: U.S. Department of Commerce.
Ture, R.L. Principles of Fire Protection Chemistry. Boston:
National Fire Protection Association.
U.S. Coast Guard, Department of Transportation. Chemical Data
Guide for Bulk Shipment by Water. Washington, DC: U.S.
Government Printing Office.
U.S. Department of Health, Education, and Welfare. 1974. An
Indentification System for Occupationally Hazardous
Materials. Washington, DC: National Institute for
Occupational Safety and Health.
Registry of Toxic Effects of Chemical Substances, Volumes
I and II. 1977. Washington, DC-
-68-
-------
NIOSH Manual of Analytical Methods. Cincinnati, Ohio: NIOSH
NIOSH Pocket Guide to Chemical Hazards. Farm Chemical Hand-
book. Toxic and Hazardous Industrial Chemicals.
NIOSH Publication Catalog. 1970-1977. Cincinnati, Ohio-
Public Health Service. •=•
Occupational Health Guidelines for Chemical Hazards.
U.S. Department of Transportation. Hazardous Materials Emergency
Action Guide. 1977.
U.S. Environmental Protection Agency. Field Detection and
Damage Assessment Manual for 0:il and Hazardous Material
Spills.. 1977. Washington, DC: Office of Oil and Hazardous
Materials.
Quality Criteria for Water. 1976.
i* f'
Recognition and Management of Pesticide Poisonings.'
Second Edition. 1977. , /'
_Manual for the Control of Hazardous Material Spills: 1977.
Vo1- I - Spill Assessment and Water iRreatment Techniques.
Verschueren, Karel. Handbook of EnvironmentaliData on' Organic
Chemicals. 1977. New York: Van Nostrand Reinhold Co.
*
Walters, Douglas B., Safety Handling of Che&ical Carcinogens,
Mutagens, and Teratogens and Highly Toific Substances.
Volumes 1 and 2. Ann Arbor: Ann Acbor Science Publishers.
?
Windholz. E. , Editor. The Merck Index. 1976. Rahway, New ;
Jersey: Merck and Company.
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APPENDIX B
Clean-up Contractors
Super fund - Approved Contractors
Contractor & Service Pjhone
Amino Brothers Co., Inc. $13/287-4510
8110 Kaw Dr. 913/334-2330
P.O. Box 11277
Kansas City, Kansas 66111
General response service.
Broski Brothers Co., Inc. 816/924-0044
6400 E. 35th St.
Kansas City, MO 64129
Manufacturer, supplier, and
installation of chain link
fence fabric and gates.
Double Check Co. 816/921-5032
4614 Prospect
Kansas City, Missouri 64130 _ ., f
Service station leaks and spills;
related fuel leaks and spills. , >
Environmental Emergency Services Co. 1-800/547-0792
529 Spirit of St. Ixjuis Blvd. •*•
Chesterfield, Missouri 63017
Nationwide oil and hazardous materials ,
contractor-no nukes or explosives. i
Environmental Int'l, Inc. V 913/648-6778
912 Scott |
Kansas City, Kansas 66104 ,» '
Nationwide planning response services ffcr
hazardous was*e. Services include engineering,
laboratory analyses, and professional investigate
services for remedial action design or damage
assessment.
Holland Bros. Cons. Co., Inc. 319/382-2412
Highway 9 West or
Decor&h. Iowa 52101 319/382-4620
Grading, embankment, excavation.
clearing, grubbing and demolition.
J.H. Berre Const. Co.. Inc 218/628-5180
5091 New Baumgartner Road
St. Louis, Missouri 63129
General response service and also
marine transporter. Demolition.
Kehe Const. Co. 319/352-3212
2700 5th Ave. N.W.
?i94rft? ?lwa 50677
General construction service -
Iowa only.
-70-
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Contractor & Service Phone
Lionmark, Inc., & Subsidiaries 314/qqi
1620 Woodson Road J14/991-
St. Louis, Missouri 63114
Land of subsurface excavations, all types
of trucking and hauling, loading and lifting.
314/428-7870
St. Louis, MO 63114
General response services.
Petroleum Maintenance 515/285 877R
Service, Inc. : oia/<285-8778
2431 Dean Ave.
Des Moines, Iowa 50317
Off-shore, inland water, land, and
subsurface for Region VII. Pads
booms, sweeps, skimmers and boat.
1633 S. Marsh
Kansas City, MO 64126
General response services.
x 27310 ' 314/569-0991
St. Louis, MO 63141 l>
Land, inland water, and subsurface for f
Region VII. Hazardous material cleanup I
treatment and disposal capabilities fc
including manpower, equipment and supplies *
and technical engineering services.
Russell a Sons Const. sifi/sR-*
Co. , Inc. 316/583-
P.O. Box 535
Eureka, KS 67045
Kansas only - Full line of heavy
construction equipment, earth moving
and excavation. Environmental aquatic
control capability.
Sajan Construction Corp. T14/79.;
P.O. Box 628 014/725-
Sikeston, MO 63801
Complete line of construction
equipment and specializing in
excavating and hauling.
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Contractor & Service Phone
Shaw & Sons Enviro-pro 816/637-5487
500 Bennington
Kansas City, Missouri 64125
Respond to oil spills in Missouri,
Nebraska, Kansas and Iowa and parts
of Oklahoma.
Thompson Const. Co. , Inc. 316/564-3204
P.O. Box 65
Ellinwood, Kansas 67526
General construction.
Environmental Specialists, Inc. 800/821-5446
3001 East 83rd St.
Kansas City, Missouri 64132
Oil and hazardous waste at any level in
four-state area; Transporter services;
Analytical services.
H. W. Watson, Inc. 91^35-6228
P.O. Box 978
Topeka, Kansas 66601 '/
General construction.
Jlk
Clean-up Contractors <•
Not Superfund Approved Contractors
Amoco Oil Company Terminal jj 515/223-6666
Des Moines, Iowa I
Provide supplies only. Oil clean-up I
supplies, 3m absorbent, containment barri
(available on replacement basis). P
Amoco Oil Company 712/366-9462
829 E. Southbridge Road
Council Bluffs, Iowa
Equipment and personnel for petroleum recovery.
Portable filter pump can recover up to 99% of a
spill. Have absorbent booms, etc. Can provide
service throughout state; Council Bluffs,
Bettendorf, Ottumwa, Dubuque, etc. Prefer to
have companies provide their own personnel. Provide
service to Nebraska also.
Cooper Equipment Co. 402/393-7563
1601 North 84th St.
Omaha, Nebraska
Petroleum products only, personnel and
equipment, sorbents, pump unit, booms, sweeps,
rolls, particulate, SCUBA, remote air masks, rubber
gear. Install tanks, clean tanks.
-72-
iers
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APPENDIX C
OIL SHEEN REFFRENCE
Standard Terms for High Viscosity Oil Films and
Descriptive Appearance of High Viscosity Oil otf Water
Approximate
Standard Film Thickness
Term (millimeters)
Barely
visible
.00004
Approximate
Quantity of
Oil in Film
(Gals, per (Liters per ;
sq. mile) sq. km.) Appearance
25 ~37 Barely visible un
der most favorabl
light conditions
Silvery .00008
Slightly .00015
colored
brightly .0003
colored
Dull
Dark
.001
.002
50
100
200
700
1400
75 Visible as a sil-
very sheon on
water surface.
145 First trace of
color nay be
observed
300 Brlg'ht bands of
color are visible
1025 Colors begin to
tUrn dull brown
207
J Utt
1 bl
Ts"5.61 gal
Colors are much
darker brown or
black
Each one-inch thickness of oil equals'"5. 61 gallons per square
yard or 17,400,000 U.S. gallons |»er square mile.
APPENDIX D
STANDARD TERMS AND^CON\'jRS10N_.
Knowing
Gallon(U.S)
Barrel
Cubic Feet
Litre
Mul
U.S. Gallon
1.0000
42.0000
7.4805
0.2641
tiply by factor
U.S. Barrel
0.02381
,1 . 00000
0.1781
0.00629
to obtain
Cubic Feet
0. 13368
5.6146
1.0000
0.03532
'"" "Litre
3 . 785
' 158.930
28.310
1.000
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Contractors % Service Phones
Ebco Safety Service Co 402/330-4200
« 13326 C Street
Omaha, Nebraska 68144
Sales - Absorbent pads, bales, booms, etc.,
personal safety gear and supplies (clothing,
respirators, etc.).
„ „ Emergency Response Sec. 402/831-0596
-*•' Calgon Activated
Carbon Division
*>"5* 11506 Rock Island Court
Maryland Heights, Missouri 63043
Nationwide response to all types of spills - Primary
expertise in surface and groundwater treatment. Also,
capability for vapor phase toxics.
Hartnett Service Company 816/776-6736
903 East 18th
Kansas City, Missouri 64108
Sells and services service station equipment. . •' f
Has Kentmore testing equipment. Will go as far
as anybody wants to pay. '/
Petroleum Equipment & Service, Inc. _ 319/377-6357
, - 220 35th St.
• Marion, Iowa ',
Have absorbent pads, test underground storage t$.nks
(Kent-Moore system). Main job is installation* »,
service work and cleaning of bulk storage tafejks.
Handle some spills. Work mostly within a 604mile
radius of their offices. f }
Petroleum Maintenance Service, Inc. * 515/285-8778
2431 Dean Ave.
Des Moines, Iowa
Petroleum incidents only - surface and underground
spills. Equipment to be used for spills available.
Will work entire region. Run three trucks 1,000 gallons
of storage carry some booms. Can get additional equipment
from distributors.
Reddi Root'r 515/441-3638
5171 Leavenworth Rd.
Kansas City, Kansas
Primarily plumbing for residences and
business - possibility for oil spills -
work in greater Kansas City area.
United American Minorities 417/732-7976
Box 201
Republic, Missouri 65738
General engineering services.
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APPENDIX E
TELEPHONE DIRECTORY
National Response Center
U.S. Environmental Protection Agency
Regional Office . . . 24-hour number:
EP&R Program
U.S. Coast Guard
2nd District .... Operation Center:
HEP Branch:
MSO Offices . . . St. Louis:
Davenport, Iowa:
Gulf Strike Team
Corps of Engineers •*•
Emergency Operations Manager
Federal Emergency Management Agency (FEMA);
Regional Office Kansas City:
Iowa - Department of Environmental Qualit^F
State Emergency Operations Center:
Kansas - Department of Health and Environment
Missouri - Department of Natural Resources
Nebraska - Department of Environmental Control
Phone
800/424-8802
913/236-3778
314/425-4612
314/425-4567
31,4/425-6297
, ,,601/688-2380
'• 816/426-6320
816/426-6882
515/281-8694
515/281-8752
913/296-1500
314/634-2436
402/471-4545
-75-
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Phone
Oil Spill Co-ops
- Iowa - Bi-State Metropolitan Oil Control 918/743-5311
Coordination Committee
Kansas - Mutual Assistance Pact (Wichita Area) 918/743-5311
Texaco-Cities Service Pipeline
Nebraska - Omaha-Council Bluffs Metropolitan Oil Control 402/342-5476
vt14) 745-3371 or 745-3372
Permit: Missouri Dept. of Natural Resources (Solid Wastes)
Facility: Hazardous Waste Landfill
BFI Liquid Reception Center and Sludge Disposal
Clay County, Missouri
(1/2 mile north of Missouri City, Missouri)
Owner: Lincoln Brothers Land, Inc. Operator. Browning-Ferris Ind.
Westowne, Box 283 Waste Systems Divisior
Liberty, Missouri 64068 3150 N. 7th St.
Kansas City, KS 66115
Contact: Manager, (816) 781-1614
Permit: Missouri Dept. of Natural Resources (Solid Wastes)
Facilities: Liquid solidification, sludge dcwatering and disposal
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FREQUENTLY CALLED NAMES AND TELEPHONE NUMBERS:
.Naroe Telephone Number
-77-
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Name
Telephone Number
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