United States
Environmental Protection
Agency
April 1984
HW-2
&EPA
Environmental
Response
learn
JiA
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Environmental
Response
Team
Contents
2 ERT: What we do
4 Operating in the Field
5 Making Environmental
Decisions
7 Developing Data
8 Training Response
Specialists
9 Incident Response Operations
10 ERT in action
10 Throughout the Years
11 Across the United States
12 Case Histories
16 How ERT is activated
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ER1 What we do
Congress enacted the Comprehensive
Environmental Response, Compensation,
and Liability Act (CERCLA) in December
1980 to broaden and strengthen Federal
initiatives in responding to hazardous
waste emergencies. Limited authority to
deal with these emergencies previously
had been based on Section 311 of the
Clean Water Act A new office, the Office
of Solid Waste and Emergency Response
(OSWER), was established within the U.S.
Environmental Protection Agency to ad-
minister CERCLA, Section 311 of the Clean
Water Act and the Resource Conservation
and Recovery Act (RCRA) which had
preceded CERCLA. OSWER has quickly
become the nerve center of a compre-
hensive, well-coordinated nationwide at-
tack upon solid waste problems dealing
with uncontrolled hazardous waste sites
and environmental emergencies.
One of the basic OSWER missions is
provision of technical services to both
National and Regional offices of EPA in
nonenforcement aspects of response ac-
tions. This mission is carried out by the
Hazardous Response Support Division
(HRSD) located in OSWER’s Office of
Emergency and Remedial Response.
HRSD’s responsibilities are to:
• Provide field support and technical
assistance to on-scene emergency
efforts.
• Train personnel involved in response
actions.
• Conduct a comprehensive program of
collecting, processing and disseminat-
ing technical information to National
and Regional offices.
• Serve as the focal point with EPA’S
Office of Research and Development in
identification of new research needs,
evaluation of new technologies, and
their incorporation into EPA’s emer-
gency response and hazardous waste
site program.
The Environmental
Response Team
The focal point of HRSD cleanup efforts
is the Environmental Response Team
(ERT), a group of 12 hazardous waste
experts who provide multidisciplinary
assistance to EPA’s other hazardous
waste response experts located in its 10
Regional offices. Together they can
bring to bear upon a problem nearly 130
years of technical experience in dealing
with hazardous wastes.
The ERT was estahlished in 1978 under
the National Contingency Plan, the ve-
hicle through which the Clean Water Act
directed coordination of Federal hazard-
ous cleanup and response efforts. The
basic ERT function initially was to advise
On-Scene Coordinators and Regional Re-
sponse Teams on environmental issues
dealing with cleaning up oil spills in
navigable waters, and accidents involving
approximately 300 hazardous substances.
When Congress enacted the Comprehen-
sive Environmental Response, Compen-
sation, and Liability Act in 1980 to estab-
lish adequate legal mechanisms for
cleaning up abandoned or uncontrolled
hazardous waste sites, it directed the
National Contingency Plan to broaden its
emergency responses. Thus, CERCLA,
commonly called Superfund, currently is
activated by emergencies at sites as well
as spills, by threats to air, land and
non-navigable as well as navigable wat-
ers, and by accidents involving a much
larger number of hazardous substances.
Local communities are on the receiving
end of all these environmental catas-
trophes, but solutions often are beyond
the communities’ abilities and means.
Through the ERT EPA is able to furnish
around-the-clock support personnel
highly skilled in all aspects of environ-
mental emergencies.
The 12 ERT members represent every
discipline involved in dealing with hazar-
dous substances, including: biology,
ecology; chemistry and chemical en-
gineering; civil and sanitary engineer-
ing; environmental health and science;
and industrial hygiene. The Team is
proficient not only in planning but con-
ducting field operations, with special
emphasis upon application of new
technology and equipment, especially
safety equipment and decontamination
procedures.
Some of the primary functions Team
members are trained to perform include:
chemical, biological and physical treat-
ment and monitoring techniques; control,
restoration, disposal and contingency
planning during emergencies; installa-
tion, operation and evaluation of in-
strumentation and field response sys-
tems; sampling and analysis of air, water
and soil; water pollution biology and
toxicology; environmental radiation train-
ing; occupational health and safet and
computerized gas chromatography/mass
spectrometr i
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The ERT’s major functions are to:
• Maintain an around-the-clock activation
system.
• Upon request, dispatch Team mem-
bers to emergency sites to assist Re-
gional and program offices.
• Provide critical consultation in water
and air quality criteria, toxicology, in-
terpretation and evaluation of analyt-
ical data, and engineering and scientific
studies.
• Develop and conduct site-specific
safety programs.
• Provide technical experts for a Public
Affairs Assist Team (PAAT).
• Supervise the work of contractors.
• Provide specialized equipment to meet
specific site requirements such as
monitoring, analytical support, waste
treatment, containment and control.
• Help to develop technical manuals,
policies, and standard operating pro-
cedures (SOPs).
• Assist in developing new technology
for use at environmental emergencies
and uncontrolled hazardous waste sites.
• Train Federal, State and local govern-
ment officials and industry repre-
sentatives in the latest technology for
environmental emergencies at hazard-
ous waste responses.
For further information about the
ERT:
J. Stephen Dorrler
Chief, Environmental Response Team
U.S. Environmental Protection Agency
Edison, New Jersey 08837
201-321-6740
FTS-340-6740
Organization Chart
3
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ER1 What we do
The Nature of the Response
Each year, EPA answers hundreds of calls
for emergency assistance and cleanup
expertise at spills and hazardous waste
sites. The Agency’s On-Scene Coordina-
tors and Superfund Coordinators are
drawn from more than 100 emergency
response specialists located in EPA’s 10
Regional offices. These coordinators also
are highly trained in such disciplines as
biology, chemistry, engineering and
ground water hydrology. They are experi-
enced in cleaning up and removing spills
or mitigating the adverse environmental
effects of hazardous waste sites. They
review and implement spill prevention
control and countermeasures which must
be prepared by facilities handling oil or
other hazardous materials. If they need
help, they call upon the EAT
The type of ERT response varies. In a
chemical spill into a river, for example, the
ERT provides immediate assistance. (Re-
sponsibility for on-scene coordination
rests with EPA for inland incidents, while
the Coast Guard is responsible for those
in coastal waters and the Great Lakes.)
The assistance might include monitoring
the chemicals, predicting the dispersion
rate, and providing emergency water
treatment technology or alternate water
supplies. In the case of a hazardous waste
site, the Team assists in developing tech-
niques and solutions to minimize the
immediate threat, and then helps identify
long-term solutions.
The Environmental Response Branch,
The Organizational Entity for the ERT,
includes three sections: Operational
Support, Environmental Impact, and
Analytical Support.
Operating in the Field
The OPERA11ONAL SUPPORT SEC11ON,
through the EPA Regional representative,
develops and implements site-specific
strategies for both short-term and long-
term responses at uncontrolled hazard-
ous waste sites and environmental
emergencies. The Section:
• Conducts or assists Regions in conduct-
ing engineering feasibility studies for
containment, cleanup and disposal ac-
tions at hazardous waste sites.
• Develops alternatives for on-site/off-
site disposal of hazardous materials,
toxic wastes and recovered spill mate-
rial, on both temporary and permanent
bases.
• Evaluates existing technical
approaches.
• Develops and implements new techni-
cal approaches as necessary
• Performs cost analyses.
• Ensures that all operations, such as
access control, decontamination, per-
sonnel monitoring and respiratory pro-
tection, incorporate the latest safety
and health preservation techniques.
• Ensures compliance with all appropri-
ate Federal and State regulations, in-
cluding those of the Comprehensive
Environmental Response, Compensa-
tion, and Liability Act, Resource Con-
servation and Recovery Act, Clean
Water Act, Clean Air Act, and Safe
Drinking Water Act.
• Provides and supervises on-site con-
tract support as necessary.
• As required, supports other programs
such as training, ADP and enforcement
activities, both in Headquarters and the
Regional offices.
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4
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En vfronmenta! Emergency
Response Unit
Here is an example of how the Opera-
tional Support Section responds: The
Section is called upon to assist a Regional
office in lowering the liquid level in a
hazardous waste lagoon which is
threatening to overflow. Within 24 hours,
a Mobile Activated Carbon Treatment
Trailer is at the site to pump and treat the
contaminated water, thus minimizing the
environmental emergency. A Mobile Ana-
lytical Laboratory arrives to ensure that
the discharge from the carbon treatment
unit meets State water quality standards.
These pieces of equipment are part of the
arsenal which makes up the Environmen-
tal Emergency Response Unit (EERU).
The EERU is a cooperative effort between
the EAT, the Oil and Hazardous Materials
Spills Branch (OHMSB) of EPA’S Office of
Research and Development, and contrac-
tor personnel. The Unit provides the most
effective use of methodology and equip-
ment under development or already
field-tested. This technology, available for
operational response through the ER1
includes proven and prototype spill con-
trol and cleanup equipment, treatability
studies and laboratory consultation
services.
The ERT is responsible for activating
EERU when the latter’s capabilities are
required. Upon such activation, the ERT
assumes operational control for EERU
and provides overall coordinating ca-
pacity during the incident.
Equipment available through the EAT!
EERU includes:
• Mobile Activated Carbon Treatment
Trailers (2).
• Mobile Analytical Laboratory (GC/MS,
GC, IR, AA, Compatability Studies).
• Mobile Flocculation/Sedimentation
System.
• Mobile Stream Diversion System.
• Pilot Plant Treatability Unit
Other special mobile equipment, includ-
ing a unique mobile incinerator now
undergoing final testing, will be added to
the Team’s arsenal in the future.
For further information on Operational
Support Section services, contact:
Making Environmental
Decisions
The ENVIRONMENTAL IMPACT SEC-
TiON, through the Regional representat-
ive, develops and implements new ap-
proaches to risk assessment, determining
the extent of contamination, the degree of
cleanup necessary and restoration re-
quirements at uncontrolled hazardous
waste sites and environmental emergen-
cies. The Section:
• Rapidly assesses the toxicity of
leachates, treatment system effluents
and environmental samples.
• Develops and implements priority sys-
tems to ensure that all corrective ac-
tions are directed to the most sensitive
and vulnerable environmental, social
and economic areas.
• Coordinates human health studies
conducted by the Communicable Dis-
ease Center of the Public Health Serv-
ice and/or State health officials to
identify impacts and remedial activities
on specific population segments.
• Prepares, evaluates and reviews En-
vironmental Assessments to ensure
that response actions produce the
fewest possible complications for the
environment and local population.
• Develops data and evaluates informa-
tion to ensure that the effective cleanup
and restoration activities are carried
out.
• Provides input to other programs as
required.
John Gilbert
Chief, Operational Support Section,
ERT
U.S. Environmental Protection Agency
26 West St. Clair
Cincinnati, Ohio 45268
513-684-7537
FTS-684-7537
- 7- -:
‘ ,
4
5
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ER1 What we do
HazaidAssessment
One of the first steps the Environmental
Impact Section takes in formulating a
hazardous substance strategy is to de-
termine the degree of risk to people and
the environment Since the hazard may
affect its target population in several
ways, it is essential that the assessment
consider all environmental media — air,
surface water, ground water, soil, and
biomass.
The Section has been conducting hazard-
ous assessments at a variety of spills and
waste sites; each operation produces an
increasingly refined hazard assessment
technique. This increased sophistication
has resulted in improved documentation
of the extent of contamination, a logical
approach for defining “when clean is
clean enough7 and the extent of cleanup
ultimately recommended.
The Section’s approach is first to consider
the hazard itself, then to determine its
probable pathways. Identification of the
actual pathway or pathways and the
speed of the contaminant’s migration will
dictate selection of the most cost-effective
remedial actions. These findings are then
used to develop engineering options for
containing and removing contaminants,
and restoring the site.
Toxicity Testing
In its field activities the Environmental
Impact Section employs a new instru-
ment which rapidly assesses the toxicity
of leachates, treatment system effluents
and ambient water. The portable instru-
ment has been used successfully at a
number of hazardous waste sites and
spills for toxicity screening of waterborne
contaminants, as well as for substantia-
tion of other aquatic bioassay tests. The
instrument operates on the fact that toxic
chemicals in water inhibit the light-
emitting capacity of certain marine bac-
teria. The degree of light inhibition is
directly proportional to the concentration
of the chemicals.
The instrument’s effectiveness is derived
from its portability, its compactness and
its dependence upon regular household
electric current. Requiring only four feet of
table top or laboratory bench space, it can
be setup in a command post or a motel
room. Individual samples can be assayed
in 5-15 minutes. This type of speed can be
particularly valuable if the sample is from
stored, treated wastewaters that must be
discharged only after toxicity tests are
completed. The instrument also reveals
the synergistic effects of toxic mixtures,
which cannot be predicted by interpreting
data from chemical analysis.
The data produced by the instrument are
the result of toxic chemicals acting on
various physiological systems of the
marine bacteria. As such, the data do not
have as much ecological relevance as a
bioassay of fresh water fish or macroin-
vertebrates. However, the instrument has
been used enough on certain fish/macro-
invertebrate bioassays to make correla-
tions with specific toxic chemicals.
The Environmental Impact Section is also
developing a portable unit using fresh
water fish and Daphnia (a small crusta-
cean) to generate toxicity information.
This unit will soon be combined with the
rapid assessment instrument to provide a
complete system for defining toxicity in
aqueous hazardous materials.
This new unit consists of modules that
can be transported as baggage on most
airlines and set up in a trailer. Its own
temperature control unit maintains ap-
prop nate temperatures for test
organisms.
While the unit’s diluter system is espe-
cially designed to produce the concen-
trations of pollutant required for generat-
ing standard U data, it can be easily
modified to perform special tests using
more than one pollutant at a time.
The information generated from these
two new instruments can be used to
determine:
• The most environmentally acceptable
means of counteracting effects of
hazardous material discharges.
• The environmental acceptability of the
effluent from various treatment
processes.
• The biological “zone of influence” re-
sulting from the discharges of hazard-
ous materials.
For further information on Environmental
Impact Section services, contact:
Dr. Royal Nadeau
Chief, Environmental Impact Section,
ERT
U.S. Environmental Protection Agency
Edison, New Jersey 08837
201-321-6743
FTS-340-6743
6
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Developing Data
The ANALY11CAL SUPPORT SECTiON,
through the Regional representative, de-
velops and implements sampling and
analytical programs to handle particular
problems associated with environmental
emergency and uncontrolled hazardous
waste sites. The Section:
• Ensures that collected samples are
representative of the problem at hand.
• Provides mobile laboratory equipment
operation and support personnel.
• Provides nonroutine analytical support
on or off site, either through in-house or
contract laboratories.
• Interprets data and provides informa-
tion in a format that can be readily
used by operational personnel.
• Provides remote sensing services for
multimedia episodes through aerial
reconnaissance, fixed-position monitor-
ing equipment and portable
instruments.
• Provides and ensures quality control so
that data generated on a case-by-case
basis can be used with confidence by
those making technical remedial
decisions.
• Prepares site-specific safely plans, in-
cluding the levels of protection re-
quired by workers onsite, control of
access to the site, and decontamination
procedures.
Site-Specific Analytical Plans
The Analytical Support Section has
pioneered the development and im-
plementation of analytical plans tailored
to the needs of individual sites. At uncon-
trolled hazardous waste sites, for in-
stance, the Section developed and im-
plemented compatibility testing protocols
(CW) to allow the safe bulking of barrel-
led wastes. The basic protocol, modified
for each site, consists of spot tests for pH,
oxidation-reduction potential, radiation,
flammability volatile gases, and water
reactivity At sites where disposal re-
quirements demand testing for specific
materials, such as PCBS, cyanides and
organic chlorine, the Section adds rapid
analytical procedures to screen each bar-
rel. Custom compatibility schemes have
been developed and used successfully at
several sites, including those in Kingston,
New Hampshire; Coventry, Rhode Island;
Baltimore, Maryland; Rock Creek, Ohio;
Ellisville, Missouri; and Lock Haven,
Pennsylvania. Compatibility testing is
very economical because it avoids the
necessity of separately and completely
characterizing the contents of each of the
thousands of drums found on most sites.
Site-Specific Safety Plans
At the request of the On-Scene Coor-
dinator, the Section develops and imple-
ments site-safety plans incorporating the
unique requirements of each site. Using
“Interim Standard Operating Safety Pro-
cedures” issued by the Office of Emer-
gency and Remedial Response, the Sec-
tion determines the zones of contamina-
tion, the type of personal protective
equipment required for each operation
being conducted in a given zone, the
method and frequency of workplace air
monitoring for each zone and type of
operation, and the method and location of
personnel and equipment decontamina-
tion. Custom safety plans have been used
at several sites, including Stroudsburg,
Pennsylvania; Ellisville, Missouri;
Elizabeth, New Jersey; Lock Haven,
Pennsylvania; Baltimore, Maryland; Ep-
ping, New Hampshire; Tacoma, Washing-
ton; Fresno, California; and Nampa, In-
diana.
For further information on Analytical
Support Section services contact:
Dr. Joseph Lafornara
Chief, Analytical Support Section, ERT
U.S. Environmental Protection Agency
Edison, New Jersey 08837
201-321-6741
FTS-340-6741
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Training Response Specialists
Item: An abandoned storage warehouse
catches fire. Local volunteer firemen ex-
tinguish the blaze but find many drums,
containers and cartons whose labels indi-
cate they contain a variety of chemicals.
Pungent odors also are obvious. Realizing
their lack of expertise in dealing with
chemicals could present a serious threat
to themselves and local inhabitants, the
firemen seal off the warehouse and re-
quest outside help.
Item: A fiat-bed tractor trailer rig,
placarded with diamond-shaped signs
reading “DANGEROUS,” spills its load at
an intersection off a freeway exit during
the morning rush hour. A number of
55-gallon drums and boxes of various
sizes litter the site. A deputy sheriff arrives
on the scene, reroutes traffic and radios
his office that a serious situation involving
hazardous materials could exist. He re-
quests expert assistance immediately to
assess the situation and advise on
cleanup.
If uncontrolled, release of hazardous sub-
stances in these two incidents could have
adversely affected public health or the
environment The incidents, however,
were not real but simulated. Staged
periodically by the ERT at EPA’S Region II
facility in Edison, New Jersey, they are
designed to approximate real events as
closely as possible. “Assistance” is pro-
vided by participants in a training course
entitled “Hazardous Materials Incident
Response Operations.” Following a week
of instruction, the truck incident provides
a mock crisis to which the class responds
as a team.
8
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Incident Response Operations
To improve EPA’s readiness to manage
environmental episodes involving
hazardous materials, EPA’s Office of
Emergency and Remedial Response di-
rected the ERT to plan, organize and
conduct a training program. As a result,
courses were developed to train emer-
gency response personnel from Federa’,
State and local levels in five areas of
hazardous environmental response: a
general introduction, monitoring and
sampling, hazard evaluation, mitigation
and treatment, and personnel protection.
The program’s goal is to provide practical
knowledge about response activities dur-
ing the initial phase of hazardous sub-
stance incidents. Focusing on team func-
tions, methods, procedures, organization
and safety in responding to hazardous
episodes, the courses emphasize the fol-
lowing considerations:
• Recognizing the hazards associated
with specific materials.
• Determining the risks to the public and
the environment.
• Developing methods of reducing or
preventing hazardous effects.
• Protecting response personnel.
Although each release of a hazardous
substance presents a unique situation,
corrective principles remain the same;
they must merely be adapted to meet
specific incidents.
The course on Hazardous Materials Inci-
dent Response Operations is a unique
course within EPA because it emphasizes
field exercises. Each course presentation
is limited to 18 participants who come
from EPA, Coast Guard, State and local
emergency response offices, other Fed-
eral agencies and private organizations.
During the work and field sessIons, parti-
cipants are divided into small groups
which operate independently. The first
part of the instruction covers problem-
solving and decision-making, evaluation
of hazards, determination of risks and
selection of appropriate personnel protec-
tive equipment and methods.
The next block of instruction provides
detailed direction in the use of protective
clothing and breathing equipment, the
body’s first line of defense against hostile,
toxic environments. All students receive a
self-contained breathing apparatus and
full-face air purifying mask. After thor-
ough instruction in its uses, limitations
and inspection procedures, the equip-
ment is worn by the students in a
smoke-filled environment, on obstacle
courses and while operating field instru-
ments. The participants also practice
wearing various types of fully encapsulat-
ing suits over the breathing apparatus.
Both laboratory and outdoor exercises
provide students with a basic understand-
ing of the fundamental instruments avail-
able for initially assessing the hazards and
characterizing the site. While learning
how to work under adverse conditions,
the students also establish a series of
decontamination lines to demonstrate the
correct procedures for removing chemi-
cals from protective clothing during re-
sponse operations.
As they move through their exercises, the
students begin to develop an awareness
of the complexities involved in hazardous
substance incidents. Each situation in-
volves specific factors which must be
evaluated and managed, based upon the
information available. The class learns to
organize, develop and mount a team
effort that effectively reduces the en-
vironmental impact of the incident
The final exercises are designed to test
the participants’ ability to use their
newly-acquired knowledge in a full-scale
environmental episode. Although simu-
lated, the incidents represent events that
have actually happened. Throughout the
course, emergency response principles
and procedures are discussed in detail;
the final test is their application to the
simulated environmental episode.
Plans call for at least one training presen-
tation per month for the next fIscal year.
For more information about this course
and the other technical courses, contact:
Thomas Sell
Training Coordinator, ERT
U .S. Environmental Protection
Agency
26 West St .Clair Street
Cincinnati , Ohio 45268
513-684-7537
FTS-684-7537
9
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I j
ERT in action
Since its founding in 1978, the ERT
has responded to more than 400
emergency incidents and hazardous
waste sites; it has provided direct
technical assistance in another 500 +
incidents. Responses have been pro-
vided for alt 10 EPA Regions, includ-
ing Alaska, Puerto Rico, and the Com-
monwealth of the Northern Marianna
Islands (Saipan). In addition, the ERT
has been requested to assist the Gov-
ernment of Mexico on two separate
occasions, the Governments of Can-
ada, the United Arab Emirates, Qatar,
Venezuela, Brazil and Italy.
The type of support the EAT provides
has changed since 1978 from strict
“emergency” response, typically
short in duration, to “quick” response
invotving more Team members over
a longer period. For example, during
its first year of operation, the ERT
responded to 42 incidents, approx-
imately half of which were oil
(Continued on Page 12)
ON SITE RESPONSES
BY MONTH
20
FISCAL YEAR 1981
TOTAL RESPONSES 49
15
10
20
15
10
5
20 ______________________- _____________- ____________
FISCAL YEAR 1980
TOTAL RESPONSES = 53
15 — -
FISCAL YEAR 1983
TOTAL RESPONSES
= 113
20
FISCAL YEAR 1982
TOTAL RESPONSES = 65
15
10 — -
hhd
9
13
11
11
.
2
(2
2
-------
ON SITE RESPONSES
BY REGION
I II
j
III IV V VI VII VIII IX X
40—— - — — _________
FISCAL YEAR 1980
TOTAL RESPONSES = 53
30 —-
20
FISCAL YEAR 1981
TOTAL RESPONSES = 49
30
20
10
iL
J4 1 2
I II III IV V VI VII VIII IX X
I II III IV V VI VII VIII IX X
II
40-
40— - _______
FISCAL YEAR 1979
TOTAL RESPONSES = 42
30——- - —
20——————-—
10
11
I II III IV V VI VII VIII IX X
40
40
FISCAL YEAR 1982
TOTAL RESPONSES = 65
30
— 21
20- - -—
10
3I
FISCAL YEAR 1984
TOTAL RESPONSES = 89
(as of 3 3184)
30 -—-- -—- --- —- -
— 26
20 - ___________________________
15
14
13
iii ;
11
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ERT in action
spills. Oil can be handled by a single
individual with little or no respiratory
protection. The present responses,
however, require a minimum of two
people operating on the “buddy sys-
tem” and generally utilizing sophisti-
cated personnel protection equipment.
Average duration of responses has in-
creased from 4.5 days in 1978 to eleven
days. Some responses have entailed in-
termittent actions over several months.
At the present rate of response, the EAT
will be on-site at more than 130 inci-
dents during Fiscal Year 1984.
The ERT’s responses have historically
been concentrated in the Eastern half of
the United States, primarily because of
the area’s large concentration of indus-
trial operations.
In the ERT’s early years, when its re-
sponses were primarily to oil spills, acti-
vities peaked in the early spring when
the annual thaw brought increased
movement of petroleum products on
waterways and through pipelines. This
response pattern has predominantly
shifted to hazardous waste sites.
Overall, preventable incidents such as
housekeeping-type oil spills, which
formerly comprised approximately 90%
of all reported hazardous substance epi-
sodes, have decreased steadily in recent
years. Credit for this welcome trend is
due to a growing sense of responsibility
by industry, to rapidly-advancing waste
disposal technology, and to the Spill
Prevention Control and Countermeasure
Program which is a part of Section 311
of the Clean Water Act.
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Case Histories
Emergency Response
International
At the urgent request from the Govern-
ment of the United Arab Emirates, the
ERT, as part of a US Team, went to the
Middle East (Abu Dhabi) to provide
technical counsel on controlling a
spreading oil slick in the Persian Gulf.
The oil spill was a result of Iraqi military
action against offshore oil wells owned
by Iran. The Team advised the United
Arab Emirates on the best means of
mitigating the worst effects of the oil
spill should it threaten the Gulf Coast.
In response to a request for assistance
from the Venezuela Ministry of Health,
ERT recommended disposal methods of
toluenediisocyanate-contaminated cot-
tonseed oil. These recommendations
consisted of incinerating the contamin-
ated oil in a power plant boiler with con-
tinuous air monitoring for residual TDI
and HCN. Information on portable, real-
time air monitors capable of detecting
these compounds, together with safe
handling procedures in the field, were
also provided.
At the request of the World Health Orga-
nization of the United Nations, ERT rep-
resented EPA in Rome, Italy, with the
development of a guideline document
on Rehabilitation Following Chemical
Accidents. The document will be used
by Nations to design and implement
programs to assist populations affected
by releases of hazardous chemicals.
At the request of Environment Canada,
ERT provided its expertise in the evalua-
tion of the Canadian Government’s sys-
tem for providing analytical data follow-
ing hazardous materials incidents.
When assistance was requested by a
Regional OSC with the hazard assess-
ment at the site of the reported disposal
of etiological (biohazard) wastes, the
ERT developed a site safety plan and
organized and supervised the complete
biological and chemical characterization
of the “lab-packed” materials. A Level A
(fully-encapsulated) entry party, consist-
ing of ERT and contractor personnel
(complete with the ERT-Decon trailer),
used a remote television transmitter sys-
tem supplied by EPA-ORD to document
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ERT in action
the conditions at the site of the “burial
mound.” This allowed off-site govern-
ment and industry experts to assess the
nature of the materials. With the OSC,
the ERT developed the plan to excavate
and recontainerize the bottles in ques-
tion, and directed and participated in the
selection and packaging of representa-
tive containers for complete biological
and chemical characterization. EAT then
supervised and interpreted the analyses,
which led to the determination that dis-
posal of the wastes, at a site approved
for “lab pack” chemicals, was in order.
Air Monitoring
ERT also provided assistance to the U.S.
Attorney’s Office, State Health and En-
vironmental Departments at a hazar-
dous waste disposal facility. The ERT
was not only instrumental in conducting
an on-site air monitoring program and
safety protocol evaluation, but also was
the primary developer/implementor of
the long term air monitoring program.
In addition, ERT assisted with the plan-
ning and review of the responsible
party’s risk-assessment for various re-
medial options. Because of ERT’s in-
volvement in the Site Assessment, Air
Monitoring and Safety protocols, ERT
was requested to serve as the technical
focal point for similar assistance at a
different site involving the same re-
sponsible party.
Operational Support
ERT’s assistance was requested in the
removal clean-up activity of a recycling
facility involving hazardous substances.
The Team assisted the OSC in develop-
ing and implementing: 1) a site safety
plan; 2) on-site mobile laboratory capa-
bilities for heavy metals, PCB’s, and
other organic materials; 3) a field com-
patibility test and computerization of all
data which expedited bulking/shipping
the waste from the site; 4) a site specific
air monitoring program and an overall
air monitoring program for hazardous
waste sites and; 5) the containment!
treatment operations.
Tire Fire
EAT assisted the Regional office in the
response to a fire involving 5-7 million
tires in Frederick County, Virginia. The
fire produced thick black smoke for
several days. For several months after-
ward pyrollysis inside the pile produced
up to 300 gpm of a complex oil-like tar.
Activities encompassed all three ERT
sections and included: a detailed air
monitoring program to identify and
quantify any hazardous vapors and par-
ticulate that might have been present;
an assessment of the environmental im-
pact of the oil on the watershed; recom-
mendations on the design and imple-
mentation of the oil containment and re-
moval system and the accompanying
flow measurement devices and fire
fighting plan; a feasibility study to deter-
mine if the fire could be extinguished
and to develop cost estimates for the
effort; assistance in briefing the press,
EPA, State, local, and Federal officials on
the status of the site and the clean-up;
the establishment of an on-site data pro-
cessing (microcomputer) capability to
track project costs, oil shipments, and
perform word processing (Pollution Re-
ports, Bulletins, Contract SOW’s, Fund
Requests); and the coordination of the
scientific and technical community at
the site.
Missouri Dioxin
EAT has been involved with the Region-
al Office in Missouri Dioxin Sites since
the Denny Farm Site investigation in
1979. As part of this continuing involve-
ment, ERT provided the chairman for a
committee that was tasked with identify-
ing and resolving technical problems
which may be encountered in the re-
moval and transportation of TCDD con-
taminated soils from the confirmed
dioxin sites to the interim storage vault
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planned for Times Beach. Topics of con-
sideration were excavation guidelines,
transportation issues, sampling pro-
tocols, and analytical support. Recom-
mendations developed by the commit-
tee will be used as guidelines for site
specific work plans, which in turn will
evolve into standard procedures for this
type of work.
Extent of Contamination
ERT is often requested to design and
implement “extent of contamination
surveys” to determine the nature and
impact of waste migration from hazar-
dous waste sites. As part of a Superfund
removal effort, the ERT conducted a
comprehensive study to determine the
location of wastes buried in the large fill
area and the migration of solvents in
soils and groundwater. On a rapid turn-
around basis, remote sensing tech-
niques were used to locate buried mate-
rials, a groundwater monitoring system
was installed and sampled, contamina-
tion of the soil profile was examined,
the site was topographically surveyed,
surface water and biota were sampled.
The results of the intensive study were
compiled in a report to the OSC includ-
ing maps of the site, a detailed evalua-
tion of the waste source, contaminant
transport mechanisms and potential
adverse health and environmental im-
pacts associated with the site. ERT re
commended appropriate mitigative ac-
tions to limit any off-site transport of
hazardous wastes. The Regional OSC
and ERT presented this EOC study to in-
terested parties at a public meeting. It
provides a scientific basis for EPA ac-
tions taken regarding the hazardous
waste.
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How the ERT is activated
The ERT maintains a 24-hour response
capability. Once an EPA On-Scene Coor-
dinator (OSC) determines that EAT assist-
ance is required for an effective response,
he may telephone these officials:
• During working hours, Kenneth Big-
lane, Director of the Hazardous Re-
sponse Support Division
(FTS 245-3048).
• During nonworking hours, Steve Dorr-
ler, the EAT leader (or his designee) at
the 24-hour response telephone
(201-321-6660) or FTS (340-6660).
The authority to activate the EAT rests
with the Director of Hazardous Response
Support Division or his designee. Upon
activation, appropriate ERT personnel and
resources are dispatched to operate
under the direct operational control of the
OSC.
In incidents involving an OSC from other
Federal or State agencies, requests for the
EAT should go to the EPA Regional
Emergency Response Coordinator who,
in turn, will contact the appropriate
officials.
In non-emergency situations, such as
providing assistance at hazardous waste
sites, the Director of Hazardous Response
Support Division approves use of the ERT
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* U.S. GOVERNMENT PRINTING OFFICE : 1984 0 - 454-949
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