&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.5-1151
April 1991
Update on Implementation
of the Oil Pollution Act of 1990
Office of Emergency and Remedial Response
Emergency Response Division OS-210
Intermittent Bulletin
Volume 1 Number 2
Inside the Update
Spill Exercise in Baltimore
Spill Planning/Response: Practical Issues
San Diego Oil Spill Conference
The Exxon Valdez: Lessons Learned
The Exxon Valdez: What If?
Oil Spills Reported in the U.S., 1988-1990
Interim Guidelines for Bioremediation
SPILL EXERCISE IN BALTIMORE
On February 21-22, 1991, the U.S. Coast Guard
sponsored an On-Scene Coordinator/Regional
Response Team (OSC/RRT) exercise in Baltimore,
Maryland to test oil spill response plans and
capabilities. Representatives of EPA Headquarters as
well as Region III attended the exercise.
The scenario for the table-top exercise involved
a collision in the Chesapeake Bay between an inbound
tank vessel loaded with 200,000 barrels of oil and an
outbound container vessel. Oil was spilled into the
Bay from ruptured cargo wing tanks. An unknown
number of containers were pushed over the side of the
container vessel; one 5,000-gallon intermodal tank
filled with methyl bromide also was thrown onto the
deck of the tank vessel. Each vessel contacted Coast
Guard Group Baltimore which in turn notified the
Marine Safety Office. That office then notified the
Federal pre-designated On-Scene Coordinator, the 5th
Coast Guard District Operations Center, which got
word to the Region III RRT, and the Maryland
Department of the Environment.
Approximately 500 Federal, state, and local
government personnel as well as representatives from
the private sector participated in and observed the
exercise. As is typical in such exercises, separate rooms
were provided for the OSC and his staff, the RRT, and
the control group running the exercise. Everyone else
was in a large meeting room where closed-circuit
television monitors provided continuous video coverage
of the activities in the three smaller rooms.
The issues addressed during the exercise included:
various provisions of the Oil Pollution Act (OPA) such
as responsible party liability and fund access; differing
state liability limits; the use of a NOAA Scientific
Support Coordinator; wildlife rescue, cleaning, and
rehabilitation; the disposal of oil, oiled debris, and
toxic wastes; the use of state and local resources
(including a "mosquito" fleet of local fishermen); the
OSC's role in directing a large spill cleanup by
responsible parties; the use of dispersants, in-situ
burning, and/or bioremediation; the emergency
capabilities of local medical facilities; communications
among responders and with ship crews; as well as
public and media relations.
The OSC, RRT members, and others took part in
a debriefing session that provided several lessons for
future planning and response efforts. Among the
lessons learned were the following: OSCs and other
response officials could profit from training in stress
management; planners need to include a fish and
wildlife section in Area Contingency Plans; officials
must provide accurate information to the public as
quickly as possible without reaching any snap decisions
about long-term impacts; and local barge and tugboat
operators have developed their own contingency plans
that could be useful to the OSC.
On March 13-14, a follow-up meeting was held in
Rosslyn, Virginia to provide an opportunity for senior
headquarters and regional officials of agencies
represented on the NRT to see how their agencies
might participate in the response to a catastrophic
spill. Additional drills will be held in the future to test
removal capability under Area Contingency Plans and
tank vessel and facility response plans; such drills are
required to be conducted periodically under OPA
section 4202. •
Printed on Recycled Paper
April 1991
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OIL SPILL PLANNING AND RESPONSE:
PRACTICAL ISSUES
Jr reparing Area Contingency Plans or response
plans for vessels and facilities under the new OPA
requirements will not be easy. That's because there are
many complicatingt factors in oil spill response and
contingency planning.
First, "oil" itself may have different physical
properties depending upon where it comes from and
whether it has been processed into a useable end
product. Oil right from the ground is called "crude"
oil. Most people probably know that this crude oil
requires further processing before consumers and
businesses can use it. But what may not be commonly
understood is that there are many types of crude oil,
and these types can vary widely in consistency,
appearance, and environmental persistence. Various
refined oil products have their own physical properties.
Chemical additives further alter the character of
refined oil products.
These physical and chemical differences mean
that teams planning for or responding to a release of
oil must use the approach that is specifically tailored to
the particular properties of the kind of oil released.
For example, some types of spilled oil may respond
well to the introduction of nutrients to stimulate
biodegradation by indigenous microorganisms; other
spilled products may require the introduction of new
biodegrading species.
A second complicating factor is the
environmental circumstance (weather conditions and
affected areas) of the spill. For example, vessels
outfitted with equipment to skim oil from the surface
of the water are relatively ineffective in rough seas. A
particular oil spill dispersant may be effective in
treating a given type of crude oil but toxic to organisms
in the environment where the spill occurred.
Mechanical cleanup methods may be able to remove oil
from a marsh but may do more harm than good to the
marsh in the process. The challenge in planning for an
oil spill response is that every spill is different and
requires a unique approach to response.
In future editions of the Update, we will present
articles on some critical issues affecting oil spill
response and contingency planning, such as the types
of oil and constituent chemicals in oil spills and
technologies (new and existing) for combating oil
pollution. n
SAN DIEGO OIL SPILL CONFERENCE
I he tradition of government and industry oil
experts convening to discuss common concerns and to
share information continued this year at the 12th
Biennial International Oil Spill Conference.
The Conference, sponsored by EPA, the U.S.
Coast Guard (USCG), and the American Petroleum
Institute (API), was held in San Diego, California, on
March 4-7, and had an unprecedented attendance of
2,400 people. This high attendance was a consequence
of concern over the impact of two recent major events
-- the 1989 oil spill in Prince William Sound, Alaska,
and promulgation of the OPA -- on government
organizations, industry, and the environment. The
conference featured technical sessions, poster
presentations, and films on oil pollution prevention
schemes, the need to establish and implement
comprehensive response and management plans, and
the effect of increasing public concern and involvement
in oil pollution. About 190 exhibitors provided
displays and hands-on demonstrations of oil spill
prevention and response products available from U.S.
and foreign companies, institutions, and government
agencies.
Events began with a plenary session in which
representatives from EPA, the USCG, state agencies,
and industry discussed the effects of the OPA and
similar state legislation on the oil industry, cleanup
contractors, and Federal and State enforcement
agencies. After the opening plenary session,
participants elected to attend any of 28 sessions on
such topics as contingency planning, cleanup
operations, response policy, case histories, damage
assessment, dispersants, fate and effects,
bioremediation, and modeling.
Four special panel discussions (on research and
development issues, scientific/litigation conflicts in oil
spill damage assessment and operational spill response,
crisis communications, and oil spill management and
decision-making) had lively audience participation.
The 1989 oil spill in Prince William Sound has
undeniably stimulated new public interest and
involvement in oil pollution issues. During discussions
of the spill, representatives of citizen groups often
provided first-hand accounts and differing perspectives
from the statements and opinions presented by EPA,
the USCG, API, the National Oceanic and
Atmospheric Administration, and others.
Off-site and conference demonstrations were well-
attended additions to the Conference and offered
Continued on next page
April 1991
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San Diego Conference (Continued)...
valuable educational opportunities to attendees.
Approximately 500 people attended a demonstration of
state-of-the-art oil containment and recover}'
equipment and response systems, including dedicated
oil spill response vessels, rapid response boats,
skimmers, booms, and dispersant application
techniques. Capping the week's events was a discussion
of the new, industry-created, non-profit Marine Spill
Response Corporation. •
THE EXXON VALDEZ: LESSONS LEARNED
I wo years ago, the 987-foot tank vessel Exxon
Valdez struck Bligh Reef in Prince William Sound,
Alaska. What followed was the largest oil spill in U.S.
history. The oil slick spread over 3,000 square miles
and onto 350 miles of beaches in Prince William
Sound, one of the most -pristine and magnificent
natural areas of the country. Soon after the Exxon
Valdez spill, the National Response Team (NRT), at
the request of the President, began preparing a report
to address the preparedness for, the response to, and
early lessons learned from the incident. The Report
was published two months after the spill, in May 1989.
In the Report, the NRT concluded the following:
• Preparedness was not adequate to address the
spill. Neither Exxon, nor the State of Alaska,
nor the Federal government was adequately
prepared for the spill. The various contingency
plans in place at the time of the spill did not
reference each other or establish a workable
response command hierarchy.
• Response efforts were slow and often insufficient.
The quantity of oil released in such a short time
overwhelmed recovery and containment efforts.
The isolation of the spill area hampered the
movement of response and worker support
equipment.
• Compensation and liability provisions of existing
statutes may have been insufficient. If Exxon
had not voluntarily assumed financial
responsibility for cleaning up the spill, the Clean
Water Act section 311(k) Trust Fund would have
been rapidly depleted. (At the time of the spill,
there was $6.7 million in the Trust Fund.)
The Report also noted that the NRT was
conducting a related study of the adequacy of oil spill
contingency plans throughout the country under the
leadership of the Coast Guard. This study resulted in
publication of the October 1990 Oil Spill Contingency
Planning Report to the President.
The October 1990 Report looks at the Exxon
Valdez incident several months into the cleanup and
also analyzes the National Response System as a whole,
including: the NRT; Regional Response Teams; the
National Oil and Hazardous Substances Pollution
Contingency Plan; Federal On-Scene Coordinators;
Regional, State, and local personnel; and industry
personnel. It examines the ability of the Nation's oil
spill response system to address worst-case spills on the
order of the Exxon Valdez incident. It also reviews the
adequacy of response equipment and personnel,
assesses the effectiveness of response training and
exercises throughout the Regions, and reports on the
organizational effectiveness of the National Response
System. Topics and findings in the report include:
• Prevention. The best defense against spills is to
prevent them from occurring in the first place.
Unfortunately, budget restrictions in recent years
have placed constraints on many prevention
programs, both in the government and in
industry.
• Planning and Coordination. The network of
Federal, state, local, and industry organizations
that participate in oil spill response cannot
operate to maximum effectiveness without better
coordination among the participants. This is
particularly true of government and private sector
coordination.
• Catastrophic Spills. According to the review of
contingency planning conducted for the October
1990 Report, the ability of Federal, state, and
local governments as well as the ability of
industry to respond to a catastrophic spill is
inadequate. The Exxon Valdez incident provided
a graphic example of how the concern over one
catastrophic spill, such as the Amoco Cadiz
incident in 1978, can turn to complacency in the
years following the spill, with the result that
response capabilities are ineffective when the next
catastrophic spill occurs.
• Cumulative Effect of Responses. During a single
week in June 1989, Federal, state, local, and
industry organizations and agencies responded
effectively to three demanding oil spills across the
country, all at a time when the Exxon Valdez
response also was underway. However, those
involved in responding to these major spills
pointed out that these incidents pushed the
response system to its limits. If the spills had
Continued on next page
April 1991
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The Exxon Valdez (Continued)...
occurred under less favorable circumstances, or if
the response actions had gone on longer, some
parts of the system might not have had the
backup capability to perform a timely and
adequate cleanup.
The OPA incorporates many of the
recommendations of the two NRT studies. For
example, the OPA provision requiring the
establishment of Area Committees and Area
Contingency Plans stems from the finding in both
studies that increased planning and coordination are
essential to improving the National Response
System, n
THE EXXON VALDEZ INCIDENT: WHAT IF
THE OPA HAD EXISTED?
1 he Exxon Valdcz oil spill predated enactment of
the OPA by a year and a half. In fact, the Exxon
Valdez incident is widely regarded as the primary event
behind the development of many provisions of the
OPA, its unanimous passage in Congress, and its
eventual signing into law. But suppose the OPA had
already been in effect as the Exxon Valdez pulled out of
the Alyeska marine terminal on the evening of
March 23, 1989 and made its way down Valdez Arm
toward the more open waters of Prince William Sound.
What might have been different?
Although it is impossible to say for sure, the
OPA's many provisions specifically related to Prince
William Sound (such as the requirement that pilots of
tankers in Prince William Sound not be tanker crew
members) might well have prevented the spill from
occurring in the first place. However, even without
these Prince William Sound provisions (which probably
would not have been included in the OPA but for the
Exxon Valdez spill), there are a number of more
generally applicable OPA requirements that might have
prevented the spill or at least diminished its size and
the resulting damage.
Prevention
Several OPA provisions might lead to measures
that, had they been in place, would have prevented the
accident altogether. The forthcoming study on vessel
traffic service systems required by OPA section 4107
might lead to improvements in vessel traffic operations
that would have prevented the incident by keeping the
Exxon Valdez away from Bligh Reef and other
dangerous areas. Similarly, the study on tanker
navigation safety standards mandated by section 4111
might lead to the establishment of new standards on
the size of and rest periods for tanker crews that could
have prevented the incident. The small size of the
Exxon Valdez crew and its fatigue after cargo loading
have been identified as factors that may have
contributed to the incident.
The OPA section 4115 requirement that most
tankers be equipped with double hulls might have
prevented the spill or resulted in a smaller spill. The
USCG has estimated that a double hull on the Exxon
Valdez would have reduced the size of the spill by
50 percent, or 5'/2 million gallons. Although this
phased-in requirement would not have prohibited the
use of a single hull on the Exxon Valdez until more
than 19 years after OPA enactment, the tanker might
have been built with a double hull in anticipation of
the requirement. If the Exxon Valdez were still a
single-hull tanker, the section 4116 requirement that it
be escorted by at least two towing vessels and piloted
by a person who is not a crew member might have
prevented the incident by keeping the tanker away
from dangerous areas.
Response
Even if the Exxon Valdez had spilled oil, certain
OPA provisions designed to improve spill response
actions might have reduced the size and environmental
impact of the spill. The OPA section 4202
requirements for an Area Contingency Plan and a tank
vessel response plan designed to handle a worst-case
spill (worse than the Exxon Valdez spill), and for the
best available spill removal equipment to be kept on
board on the tanker, might have resulted in quicker
and more effective spill response.
Other section 4202 provisions requiring periodic
inspection of removal equipment and unannounced
drills of removal capability might have revealed
inadequacies in response planning that could have been
addressed before the Exxon Valdez spill occurred. In
addition, the section 4201 requirement that the Federal
government direct responses to spills that pose a
"substantial threat to the public health or welfare"
might have improved the initial response to the spill by
clarifying the chain of command for spill response
activities.
Because most of the provisions described here are
not limited to any single area, their potential for
preventing or mitigating the effects of another Exxon
Valdez incident also applies to any major U.S. spill that
might occur after the OPA is fully implemented. Thus,
this brief look at "what might have been" bodes well for
what might occur -- or be prevented - in years to
come, n
April 1991
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OIL SPILL STATISTICS: RELEASE NOTIFICATIONS BY REGION, 1988-1990
TOTAL RELEASE NOTIFICATIONS
Year Number* % Change
1988 15,799 -2%
1989 16,819 6%
1990 19,526 14%
Region 1
19881189
19891097
19901030
Regions
1988 1471
1989 1769
1990 2260
cr*.-*
0
* Total numbers include notifications where the Region was not provided.
Source: Emergency Response Notification System (ERNS); February 21,1991.
1 he information presented in the map above is
from the Emergency Response Notification System
(ERNS), a national computer data base and retrieval
system used to store information on releases of oil and
hazardous substances. ERNS contains preliminary
information on the date, cause, and size of a release;
the response actions taken; the environmental media
affected; and several other data items. The map shows
the number of oil spills that have been reported to
EPA Regions, the National Response Center, and the
U.S. Coast Guard during the past three years. ERNS
is continually updated as new reports are received and
information is verified.
As the map shows, oil release notifications vary
substantially from one EPA Region to another. In
1990, the number of these reports ranged from 477 in
Region 8 to 6,726 in Region 6. Emergency responders
use this type of information to determine where to
concentrate emergency response efforts. For example,
the highest number of notifications are consistently
received in Region 6, which includes the States of
Texas, Oklahoma, and Louisiana. These states also
account for the greatest number of oil production
facilities.
An overall increase in the number of notifications
each year is apparent. The number of notifications
increased six percent in 1989 and more than twice as
much, 14 percent, in 1990. This rise, however, does
not necessarily indicate an increase in the number of
oil spills. More diligent reporting, greater awareness of
Federal reporting requirements, and improved
notification and data collection processes may account
for at least part of the increase.
ERNS information can be used for different and
more extensive analyses than that presented above.
Data in ERNS are available to anyone interested in
release notifications, such as emergency response
personnel, government officials, the public, the media,
educational institutions, and scientific organizations.
Data may be provided in various forms, including
computerized copies, printouts, or summarized release
totals. General information and specific data may be
obtained by calling the ERNS Project Manager at
(202) 382-2342 or by writing to the U.S. Environmental
Protection Agency, Freedom of Information Act Office
(A-101), 401 M Street, S.W., Washington, D.C.
20460. •
April 1991
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INTERIM GUIDELINES FOR
BIOREMEDIATION SI'ILL RESPONSE PLANS
I he identification and development of promising
new technologies for the prevention and reduction of
oil pollution are important parts of EPA's effort to
implement the OPA. Biorcmediation -- the use of
microorganisms to degrade chemical substances (such
as petroleum products and other hydrocarbons) -- is a
technology that the Agency believes offers significant
potential for addressing not only oil spills, but releases
of hazardous substances as well. Given an appropriate
environment and sufficient time, microorganisms have
exhibited the ability to degrade a wide variety of
chemical substances. The Bioremcdiation Action
Committee (BAG) was created last year at the
direction of EPA Administrator William K. Reilly to
foster the development of biorcmcdiation as a safe and
effective solution to environmental problems. Within
the BAG, six subcommittees have been established:
Data Identification and Collection, Education, National
Bioremediation Spill Response, Pollution Prevention,
Research, and Treatability Protocol.
The Subcommittee on National Bioremcdiation
Spill Response recently took the first steps toward its
long-term goal of developing a national bioremediation
response capability for oil spills. It has prepared
interim guidelines to address the urgent need for
guidance on the use of promising but not widely
established bioremediation spill response measures,
including the use of bioremediation agents listed on
the Product Schedule under Subpart J of the National
Oil and Hazardous Substances Pollution Contingency
Plan (NCP). (The Subpart J regulations are among
those EPA is in the process of revising based on the
OPA.) In preparing the guidelines, Royal Nadeau, of
EPA's Environmental Response Team in Edison, New
Jersey, who headed up the effort, drew on the expertise
of Subcommittee members involved in bioremediation
projects in Alaska's Prince William Sound and on
research being conducted at the Agency's Office of
Research and Development laboratories.
The new guidelines provide a general model on
how to craft site-specific plans for using bioremediation
agents that reflect the particular needs and
characteristics of a given location. As the first major
product of its kind, the interim guidelines have been
forwarded to U.S. personnel in Saudi Arabia to assist
in response to the Kuwaiti oil spill. In addition, the
Subcommittee is conducting a pilot project in which
the guidelines are being used to develop a site-specific
bioremediation response plan for a particular area.
For more information, please write to: Pamela
Russell-Harris, Emergency Response Division
(OS-210), U.S. Environmental Protection Agency,
401 M Street, S.W., Washington, D.C. 20460. a
COMMENTS ON THE UPDATE
Your comments on this new series of
bulletins are welcome. Please contact the editor,
Phyllis Anderson, at (202) 382-5614 or write to
the Emergency Response Division (OS-210), U.S.
Environmental Protection Agency, 401 M Street,
S.W., Washington, D.C. 20460.
&EPA
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