United States
Environmental Protection
Agency

Office of Land and
Emergency Management

July 2021
www.epa.gov/emergency-response

Dispersant Monitoring Provisions Under Subpart J of the
National Contingency Plan - Final Rule

The U.S. Environmental Protection Agency (EPA) is finalizing monitoring requirements under
Subpart J of the National Contingency Plan (NCP) for dispersant use in response to major oil
discharges and certain other atypical dispersant use situations in the navigable waters of the United
States and adjoining shorelines. These provisions will equip the response community with data and
information to authorize and use dispersants in a judicious and effective manner.

In April 2010, the Deepwater Horizon underwater oil well blowout discharged significant
quantities of oil into the Gulf of Mexico. The blowout discharged oil from one mile below the sea
surface. Approximately one million gallons of dispersants were deployed on surface slicks over a
three-month period on thousands of square miles of the Gulf of Mexico. Additionally, approximately
three quarters of a million gallons of dispersants were, for the first time, injected directly into the oil
gushing from the well riser. The Deepwater Horizon incident raised questions about the challenges of
making dispersant use decisions in response operations for certain atypical dispersant use situations.

Summary of Proposed Rule Amendments

On January 22, 2015, EPA published a proposed rule to amend Subpart J of the NCP. The
proposed amendments are a major component of EPA's effort to inform the use of dispersants and
other chemical or biological agents when responding to oil discharges. The proposed amendments
were intended to ensure that On-Scene Coordinators (OSCs), Regional Response Teams (RRTs),
and Area Committees (AC) have relevant information to support response decision-making regarding
dispersant use. They also incorporate lessons learned from the Deepwater Horizon response.

Key areas addressed in the 2015 proposed Subpart J amendments included:

•	Authorization of use requirements for chemical agents;

•	Toxicity and efficacy testing protocols, information requirements, and procedures for listing
products on the Subpart J Product Schedule; and

•	New monitoring requirements for subsurface, major oil discharges, and prolonged
surface application of dispersants.

The Agency received public comment submissions from industry, academia, state and local
governments, environmental groups, and individuals on the 2015 proposal.

The Dispersant Monitoring Provisions Under Subpart J of the National Contingency Plan final
action establishes new dispersant monitoring requirements. The remaining provisions addressed in
the 2015 proposed rule (i.e., authorization of use, testing protocols, and listing) are currently under
consideration.

Office of Emergency Management

History


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Subpart J Monitoring Requirements - Final Rule

July 2021

Final Dispersant Use Monitoring Requirements

Environmental field monitoring data can support decision-making when dispersants are used in
response to an oil discharge. The data provide site-specific information on the overall effectiveness,
including the transport and environmental effects, of the dispersants and the dispersed oil.
Dispersant-use monitoring provides information on the transport of dispersed oil in the water column
to inform sampling as well as potential environmental effects. The monitoring provisions are to ensure
that the OSC and other agencies with responsibility for authorizing dispersant use have relevant
information under certain atypical use situations for decision-making.

These monitoring requirements apply to the responsible party of an oil discharge. The
amendments establish dispersant monitoring requirements when responding to oil discharges as
follows:

•	Subsurface - Any subsurface use of dispersants,

•	Prolonged Surface - Any surface use of dispersant for more than 96 hours after initial
application, and

•	Major Oil Discharges - Any surface use of dispersant in response to oil discharges of more
than 100,000 U.S. gallons occurring within a 24-hour period.

The monitoring elements in the final rule cover several key areas including:

•	Source Characterization and Information on Dispersant Application - Oil discharge flow
rate or volume as applicable, dispersant choice, dispersant-to-oil ratio, application rates, and
total amount of dispersant needed.

•	Water Column Sampling - Background, baseline, and dispersed oil plume water column in-
situ sampling for oil droplet size distribution, fluorometry and fluorescence, total petroleum
hydrocarbons, dissolved oxygen (subsurface only), methane (subsurface only), heavy metals,
turbidity, water temperature, pH, and conductivity.

•	Oil Distribution Analysis - Characterization of dispersant effectiveness and oil distribution.

•	Ecological Characterization - Characterization of potential ecological receptors and
habitats, and their associated exposure pathways.

•	Immediate and Daily Reporting - Reporting to the OSC and RRT immediately for specified
application deviations, and daily for water sampling and data analyses.

For More Information

Read the Proposed Subpart J Rule Amendment:

http://www.epa.gov/emereencv-response/national-contingencv-plan-subpart-i

Visit the EPA Emergency Response Website:

http://www.epa.gov/emergencv-response

Call the National Contingency Plan Product Schedule Information Line

(202) 260-2342 (phone)

To Report an Oil or Chemical Spill

Call the National Response Center:

(800) 424-8802 or (202) 267-2675
TDD (202) 267-4477

Office of Emergency Management


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