US ENVIRONMENTAL PROTECTION AGENCY REGION 4 EMERGENCY RESPONSE AND REMOVAL BRANCH * 1 WEPA REGION IV & pHnfTzARDO^sHmN^S ^ iHHi <5> 4^l PR0f$^ GUIDANCE ON THE USE OF CHEMICAL COUNTERMEASURES ON ROADSIDE FUEL SPILLS INFORMATION GOVERNMENT RESPONDERS ------- Introduction. The US Environmental Protection Agency Region IV (EPA) office recognizes the major role of local government responders as the first line of defense for mitigating threats to public health and the environment from spills of oil and hazardous substances. In recognition of this role, EPA tries to provide local responders with the tools necessary to safely and effectively mitigate such incidents. Chemical countermeasures are one of the tools available to local responders. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) at Subpart J requires the On-Scene Coordinator (OSC) approve the use of chemical countermeasures on spills not threatening human life. In some situations, this approval process places delays on local responders and hampers their ability to properly address roadside spills. The EPA therefore recognizes and authorizes, through this guidance, that under certain conditions, local responders will be allowed to use chemical countermeasures to mitigate small roadside fuel spills. What are Chemical Countermeasures? Any element, compound, or mixture that coagulates, disperses, dissolves, emulsifies, foams, neutralizes, precipitates, reduces, solubilizes, oxidizes, concentrates, congeals, entraps, fixes, makes the oil more rigid or viscous, reduces the harmful effects or otherwise helps remove the oil from the environment. This includes biological additives, dispersants, surface washing agents, surface collecting agents and any other miscellaneous oil spill control agents. When can Countermeasures be used? The EPA authorizes the use of certain chemical countermeasures ONLY for mitigating small roadside fuel spills, primarily to reduce the slickness of the highway or roadway preventing secondary accidents and to preserve and maintain the integrity of the pavement surface which may be degraded by the solvent action of the spilled fuel. ------- Local responders, or their contractors, must first remove the majority of the spilled fuel by conventional physical or mechanical means (i.e! granular absorbents or absorbent pads). When the amount of fuel present has been reduced to a visible sheen, chemical countermeasures may be applied per manufacturers instructions. What countermeasures can be used? For spills that have the potential to reach surface water or groundwater, either by runoff or through a storm drain, the chemical countermeasure must be listed on the NCP Product Schedule. Chemical countermeasures listed on the Product Schedule have not been approved for use by the EPA, merely they have met the testing criteria set forth in the NCP. ARE THERE ANY RESTRICTIONS??? YES! Chemical countermeasures CANNOT be applied to spills on inland surface waters or to spills that may reach a waterway, through storms drains or nearby creeks, without permission of the EPA and the Region IV Regional Response Team (RRT). Refer to the next section for further information on surface water applications. Also, chemical countermeasures CANNOT be applied in areas where there is a concern with groundwater contamination (i.e. shallow aquifers, karst geology). Local response authorities should consult with their State environmental department when groundwater contamination may be of concern. Caution must be used when applying chemical countermeasures into a closed conduit, such as a sanitary sewer or a storm sewer. Many countermeasures, especially dispersants, break the fuel into smaller parts and increase vaporization. Be sure to only use products specifically designed for vapor suppression. Many States have their own policy regarding the use of chemical countermeasures. Local response authorities should consult with their State's environmental agency before using any product. ------- Authorization to use chemical countermeasures for fuel slick reduction applies only to local government responders. Contractors may use countermeasures as long as a local government representative is on-scene to provide oversight. Nothing in this policy is intended to allow pre-authorization of use to private concerns. When is approval necessary? In general, EPA strongly discourages the use of chemical countermeasures on inland waterways. However, if chemical countermeasures are being considered for use on a spill that does not meet the authorization criteria discussed earlier (i.e. small roadside fuel spill), then EPA, in coordination with the Region 4 Regional Response Team (RRT), must grant approval prior to any application of the desired countermeasure. The only exception is when a local government responder determines the use of a product will prevent or substantially reduce an immediate hazard to human life. How to obtain approval when necessary. During a spill event, the EPA, in coordination with the Region 4 Regional Response Team (RRT), may verbally authorize the use of a chemical countermeasure provided it is listed on the NCP Product Schedule. EPA's 24-hour number is (404) 347-4062. An answer should be available within one hour of the request. Information needed to grant approval. * Exact location of spill * Type of material spilled * Amount spilled or potentially spilled * Name of product * MSDS on product * Rate and method of application * Nearest surface water * Forecasted weather conditions * Monitoring strategy ------- Additional Sources of Information. 1. National Oil and Hazardous Substances Pollution Contingency Plan (NCP); 40 CFR Part 300 Subpart J. 2. NCP Product Schedule may be obtained from the Emergency Response Division (5202-G), U.S. Environmental Protection Agency, 401 M Street, SW, Washington, DC, 20460. The telephone number is 1-202-260-2342. 3. "The Behavior of Dispersed and Nondispersed Fuels in a Sewer System", M.F. Fingas, K.A. Hughes, and A.M. Bobra in Oil Dispersants: New Ecological Approaches, ASTM STP 1018, 1989, pp. 274-289. Any More Questions? For additional information that is not addressed in this phamphlet, please call (404) 347-3931. Or write to Mary Jo Bragan, US Environmental Protection Agency (4WD-ERRB), Emergency Response and Removal Branch, 345 Courtland Street, Atlanta, GA, 30365. LIBRARY US EPA Region 4 Atlanta Federal Center 100 Alabama St., SW Atlanta, GA 30303-3104 DATE DU Rtrck IHS y ------- 24-HOUR NUMBERS USEPA Region 4 (404) 347-4062 NATIONAL RESPONSE CENTER 1-800-424-8802 ALABAMA (205) 242-4378 In-State 1-800-843-0699 FLORIDA (904) 413-9911 In-State 1-800-342-5367 GEORGIA (404) 656-4300 KENTUCY 1-800-928-2380 MISSISSIPPI (601) 352-9100 NORTH CAROLINA (919) 733-5083 After hours (919) 899-4500 SOUTH CAROLINA (803) 253-6488 TENNESSEE 1-800-258-3300 ' In-State 1-800-262-3300 ^ EPA Library Region A 006569 ------- |