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 Valdtz: Lessons Learned
    The Exxon Valdez: What If?
    Oil Spills Reported in the U.S., 1988-1990
    Interim Guidelines for Bioreraedialion
  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 111  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  biorernediation;   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
      Preparing 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. •
  SAN DIEGO OIL SPILL CONFERENCE
     T. 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-siteand conference demonstrations were well-
attended  additions  to  the Conference  and  offered
                                 Continued on next page
                                                                                                   April 1991

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                                                                            54OF91OO3
 San Diego Conference (Continued)...

 valuable  educational  opportunities   to  attendees.
 Approximately 500 people attended a demonstration of
 state-of-the-art   oil   containment   and   recovery
 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
     Two 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 Eocon
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 31 l(k) Trust Fund would have
     been rapidly depleted.  (At the time of the spill,
     there was S6.7 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 noa page
                                                                                                   April 1991

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  INTERIM GUIDELINES FOR
  BIOREMEDIAT1ON SPILL RESPONSE PLANS
     The 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.  Bioremediation --  the use of
microorganisms to degrade chemical substances (such
as petroleum products and other hydrocarbons) - is a
technology that the Agency believes offers significani
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  Bioremediation  Action
Committee  (BAC)  was  created  last year  at  the
direction of EPA Administrator William K. Reilly to
foster the development of bioremediation as a safe and
effective solution to environmental problems.  Within
the BAC, six subcommittees have been established:
Data Identification and Collection, Education, National
Bioremediation Spill Response, Pollution Prevention,
Research, and Treatability Protocol.

     The Subcommittee on  National Bioremediation
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
ihc guidelines are being used to develop a site-specific
hioremediation  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. •
         COMMENTS ON THE UPDATE

       Youi 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-21Q), U.S.
  Environmental Protection Agency, 401 M Street,
  S.W., Washington, D.C 20460.
x>EPA
United States
Environmental Protection
Agency (OS-120)
Washington, DC 20460

Official Business
Penalty tor Private Use
$300
                              First-Class Mail
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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. •
  THE EXXON VALDEZ INCIDENT: WHAT IF
  THE OPA HAD EXISTED?
     The Exxon Valdez 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 faiigue after cargo loading
have  been  identified  as   factors  that may  have
contributed 10 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  51/* 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 lor the
best available spill removal equipment  to he 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 thai she Federal
government  direct responses  to  spills thai  pose  a
"substantial  threat to the public health or  \seliare"
might have improved the initial response to ihe -.pill hy
clarifying the chain of command  for  spill reNp*Ti>c
activities.

     Because most of the provisions described here are,
not limited  to  any single area, their poienual  lor
preventing or mitigating the effects of another Luun
Valdez incident also applies to any major U.S. >-pill that
might occur after the OPA is fully implemented. Thus,
this brief look at "what might have been" bode* well lor
what might  occur -- or be  prevented  - in  years to
come. •
                                                                                                  Apnl 1091

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                 OIL SPILL STATISTICS:  RELEASE NOTIFICATIONS BY REGION, 1988-1990
                                                                                               r\
                                                                                                19881189
                                                                                                19891097
                                                                                                19901030
                        19881179
                        1989 1162
                        1990 1040
                                                                                    1988 1471
                                                                                    1989 1769
                                                                                    1990 2260
    TOTAL RELEASE NOTIFICATIONS
     Year       Number"  % Change
     1988        15,799      -2%
     1989        16.819        6%
     1990        19,526       14%
*  Total numbers include notifications where the Region was not provided.
Source: Emergency Response Notification System (ERNS); February 21,1991.
       The 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. Joes
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 ,md
more extensive  analyses than that presented  .iho\c.
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 orgam/.num.v
Data  may  be  provided  in various forms, incluJmc
computerized copies, printouts, or summari/ed tek.ivc
totals.  General information and specific daia ma\ 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 Oiiice
(A-101),  401   M Street, S.W.,   Washington.  D.C
20460. •
                                                                                                  Apnl

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