Response to Hazardous Substances Releases
When a hazardous substance release is reported in the United States, the Environmental Protection Agency's (EPA) Emergency Response Program sets its response procedures into motion. Many steps and safety precautions must be followed to ensure a swift and effective response to the emergency.
|Regional Response Team (RRT) responding to hazardous substance release in Massachusetts. Credit: Mass.gov|
The first step in any response action is to investigate the site. When a release is first reported, responders may not know all the necessary information such as how the release occured, the extent of the damage, or even what hazardous substances are involved. All this information must be learned before any effective response effort can be carried out. Site investigation also allows responders to determine the appropriate safety measures to take during the response effort.
Response actions fall into three main categories, depending on the urgency of the situation. Once information has been gatherered about the release, responders can determine what type of response action should be taken. A clean-up effort may be long-term or short-term. Depending on the circumstances, responders may employ some or all of these methods:
- Removing hazardous substances in soil or in containers
- Burning or otherwise treating hazardous substances
- Draining waste ponds or repairing leaky waste disposal pits so that hazardous substances do not seep into the ground
- Using chemicals to stop the spread of the hazardous substance release
- Encasing hazardous substances in place or otherwise ensuring that winds or rain do not move them around
- Providing a safe supply of drinking water to people affected by hazardous substance contamination
- Temporarily moving residents affected by hazardous substance contamination while cleanup activities take place
- Installing fences to prevent direct contact with hazardous substances
EPA has conducted several thousand response actions since the Emergency Response program began in 1980, and has directed and monitored many other actions carried out by those responsible for the contamination. The threats confronted by the EPA Emergency Response program vary greatly in size, nature, and location, and have involved EPA in incidents requiring unusual or complex emergency response actions.
Experience has demonstrated that not all emergency response or removal actions classified under the National Contingency Plan (NCP) are equally urgent. For example, situations involving fire or explosions or imminent, catastrophic contamination of a reservoir may require prompt and expeditious attention, while certain situations involving abandoned hazardous waste drums or cleanup of abandoned industrial facilities may not. Based on the NCP, EPA defines the following types of removal actions:
- Classic Emergencies: Those actions where the release requires that on-site activities be initiated within minutes or hours of the determination that a removal action is appropriate.
- Long-term clean-up efforts may respond to less urgent recent releases, or may involve clean-up at long-term Superfund sites:
- Time-Critical Actions: Those actions where, based on an evaluation of the site, EPA determines that less than six months is available before site activities must be initiated.
- Non-Time-Critical Actions: Those actions where, based on an evaluation of the site, EPA determines that more than six months is available before on-site activities must begin.
Responding to Oil Spills
National Response System Flowchart. Source: EPA
Despite the nation's best efforts to prevent spills, almost 14,000 oil spills are reported each year, mobilizing thousands of specially trained emergency response personnel and challenging the best-laid contingency plans. Although many spills are contained and cleaned up by the party responsible for the spill, some spills require assistance from local and state agencies, and occasionally, the federal government. Under the National Contingency Plan, EPA is the lead federal response agency for oil spills occurring in inland waters, and the U.S. Coast Guard is the lead response agency for spills in coastal waters and deepwater ports.
Whether or not it manages the response, EPA tracks all reports of oil spills. EPA usually learns about a spill from the responsible party, who is required by law to report the spill to the federal government, or from state and local responders. Once the federal government receives the report, either through the National Response Center, EPA, or another agency, it is recorded in the Emergency Response Notification System, or ERNS. ERNS contains historical spill information for the entire country dating from 1986, and is currently available for downloading.
National Response Center (NRC)
|EPA responding to a hazardous substance release. Credit: EPA|
The National Response Center (NRC) is the federal government's national communications center, which is staffed 24 hours a day by U.S. Coast Guard officers and marine science technicians. The NRC is the sole federal point of contact for reporting all hazardous substances and oil spills. The NRC receives all reports of releases involving hazardous substances and oil that trigger the federal notification requirements under several laws.
Reports to the NRC activate the National Contingency Plan and the federal government's response capabilities. It is the responsibility of the NRC staff to notify the pre-designated On-Scene Coordinator (OSC) assigned to the area of the incident and to collect available information on the size and nature of the release, the facility or vessel involved, and the party(ies) responsible for the release. The NRC maintains reports of all releases and spills in a national database.
Once EPA learns of a potential hazardous substance release, an established set of procedures is followed to investigate the site, evaluate the threat, and determine the best course of action. First, EPA designates an On-Scene Coordinator (OSC) to evaluate the incident and determine the appropriate response agency. If the OSC determines that EPA will take the lead in responding to the incident, the OSC will evaluate the urgency of the situation to determine the appropriate response alternative.
Prior to initiating an emergency response action, the OSC will conduct an off-site preliminary assessment of the release and the site's characteristics. The preliminary assessment helps to identify specific hazards and determine the appropriate response measures and safety measures needed to ensure the health and safety of the responders. The OSC may rely on a variety of methods to collect the necessary information, including interviewing witnesses, first responders, and others present at the site; reviewing records and documents at the facility or on the vehicle; analyzing photographs taken at the site; or conducting a visual (off-site) inspection using binoculars. Thanks to the Community Right-to-Know law, important information about the released substances is often easily and quickly obtained.
Once EPA determines the type of emergency response action needed, response personnel take special precautions to ensure that they are protected from the threats posed at the site. When entering the site, response personnel wear personal protective gear to shield or isolate them from the chemical, physical, and biological hazards that may be encountered on the site. The selection of the type or level of personal protective equipment is based on the identification of the hazards or suspected hazards, potential exposure pathways, and the performance of the equipment in providing a barrier to these hazards. Because there is often little known information on specific hazards during the initial phase of an emergency response, the OSC typically directs that the most protective equipment be used at first; as more information about the hazards and conditions become available, the OSC can decide to downgrade the level of protection to match the site hazards.
As response personnel enter the site of the release, they gather additional information and further evaluate the site risks and hazards present. Response personnel use this information to further refine their response activities and the safety measures being taken. Generally, response workers entering the site conduct a visual survey for potential hazards and may perform air monitoring for potential dangers to life and health. For example, a visual survey might note the condition of waste containers (e.g., rusted or other unusual conditions), determine potential exposure pathways, and identify other possible dangers, such as confined space and oxygen-deficient environments, ground subsidence, visible vapor clouds, or areas that contain biological indicators, such as dead vegetation or wildlife. Response personnel use direct-reading instruments and testing equipment when performing air monitoring. One important goal of monitoring during initial site entry is to establish work or safety zones at the site. As the emergency response action continues, response personnel conduct periodic monitoring to ensure that any new hazards are identified promptly and that appropriate controls are implemented to protect the responders and nearby communities.
Site investigations are essential to protect the health and safety of response personnel and others during emergency response actions. The information gathered is absolutely critical to enable responders to proceed confidently and safely, and to ensure that local communities receive accurate information about the potential for adverse health effects.
Oil Spill Response Management
|Fish & Wildlife Service personnel participate as members of an integrated response team, responding to chemical and oil spills. Credit: FWS|
As the federal government's lead agency in responding to oil spills in inland waters, EPA is responsible for monitoring and, if necessary, directing spill response efforts. Under the Oil Pollution Act of 1990, EPA is required to direct the response in cases where the spill "is of such a size or character as to pose a substantial threat to the public health or welfare." EPA may also take the lead in managing the response if requested to do so by state or local response officials, or if EPA determines that the responsible party is incapable of responding adequately to the spill.
The On-Scene Coordinator (OSC) is the federal official responsible for monitoring or managing federal responses to oil spills. If the spill affects inland waters, then an EPA OSC will be designated for the incident; a USCG OSC will be designated for spills to coastal waters and the great lakes. Once notified of an oil spill, the OSC also will conduct an immediate assessment to evaluate several factors, including the size and nature of the spill, the type of oil spilled, its potential hazards, and the resources needed to contain and clean it up. The OSC also will monitor any existing response efforts to determine whether additional technical support or federal involvement is necessary.
If the OSC determines that federal involvement is needed, the OSC will assume control of all spill response operations at the site and will obtain and direct all needed resources, such as cleanup personnel and equipment. If the OSC determines that the personnel and equipment already deployed at the spill site are inadequate, the OSC will employ spill contractors using available federal response funds or, if necessary, funds from the Oil Spill Liability Trust Fund.
For oil spills that require a greater scope of federal support and resources, the OSC may activate the Regional Response Team to provide broader technical advice, equipment, or manpower to assist with a response. In addition, the OSC can request support from EPA's Environmental Response Team , which is available 24 hours-a-day to provide oil spill expertise and special response equipment to the spill responders. The OSC also can access various National Oceanic and Atmospheric Administration (NOAA) Scientific Support Coordinators with expertise in different aspects of oil spills, as well as support from non-governmental organizations that specialize in wildlife rescue and rehabilitation.
On-Scene Coordinators (OSCs)
The On-Scene Coordinator (OSC) is the federal official responsible for monitoring or directing responses to all oil spills and hazardous substance releases reported to the federal government. The OSC coordinates all federal efforts with, and provides support and information to, local, state and regional response communities. The OSC is an agent of either EPA or the U.S. Coast Guard, depending on where the incident occurs. EPA OSCs have primary responsibility for spills and releases to inland areas and waters, while U.S. Coast Guard OSCs have responsibility for coastal waters and the Great Lakes. In general, the OSC has the following key responsibilities during and after a response to a hazardous substance release or an oil spill: (1) assessment; (2) monitoring; (3) response assistance; and (4) evaluation.
The OSC typically conducts assessment activities at the beginning of a response. Assessment involves evaluating the size and nature of a release or spill, its potential hazards, the resources needed to contain and clean it up, and the ability of the responsible party or local authorities to handle the incident. The results of the assessment are used to determine the need for personnel, equipment, and other resources to promptly and effectively combat the release.
Most releases or spills are small and are cleaned up by the responsible party or local response agencies. Monitoring comprises those activities taken to ensure that the actions taken to control and clean up a chemical release or oil spill are appropriate. Monitoring can be conducted from the site when necessary, or from an agency office if the situation appears to be under control. In the case of oil spills, the OSC is legally required to monitor the response if the spill poses a substantial threat to the health and welfare of the public due to its size or characteristics.
Once a release or spill has been assessed, the OSC determines whether federal assistance will be http://www.eoearth.org/articles/edit/158425/necessary to help control and contain it. If the OSC decides that federal assistance is required, the OSC will obtain needed resources such as personnel and equipment. If sufficient resources are not available for an incident, the OSC decides who pays and can secure federal funding either from the Superfund trust fund for hazardous substance releases or the Oil Spill Liability Trust Fund for oil spills. This assistance ensures that cleanup will not be hindered by a lack in availability of personnel or equipment on behalf of the local or state or responsible party resources.
Evaluating response actions provides information that is useful for designing or improving spill response plans. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) requires that the OSC report all activities that take place during and after an incident. For example, following an oil spill, the OSC is required to file a summary report that outlines the actions taken to remedy the spill and the level of assistance provided by local, state, and federal agencies. These reports can be used to identify problem areas and can be shared with other agencies who may make recommendations for improvement.
National Response System
The National Response System (NRS) routinely and effectively responds to a wide range of oil and hazardous substance releases. It is a multi-layered system of individuals and teams from local, state, and federal agencies, industry, and other organizations that share expertise and resources to ensure that oil spill control and cleanup activities are timely and efficient, and that they minimize threats to human health and the environment.
At the heart of the system is the National Contingency Plan (NCP), which ensures that the resources and expertise of the federal government are available immediately for oil or hazardous substance releases that are beyond the capabilities of local and state responders. The NCP provides the framework for the NRS and establishes how it works.
When releases are serious enough to be considered "Nationally Significant Incidents," the National Response Framework (NRF) is activated, and works in conjunction with the NRS and NCP. The NRF is the federal government's comprehensive, all-hazard approach to crisis management, and provides a mechanism for coordinating federal assistance to state governments and localities.
Maintaining Response Readiness
Because a hazardous substance release or an oil spill could occur virtually anywhere and at any time, EPA and a network of federal, state, and local responders stand ready 24 hours a day to contain and clean-up the discharged oil and released chemicals. EPA's Emergency Response program has a leadership role in this National Response System that promotes coordinated emergency response actions and guarantees the availability of resources to cover all possible release scenarios. This coordination allows federal, state, and local agencies to work together to respond to all emergencies efficiently. EPA also provides other financial and technical support as needed to assist local communities in responding to the broad range of emergency response incidents that may occur.
One of EPA's major tasks is to coordinate contingency planning efforts with other agencies to ensure that emergency responses are carried out quickly and with maximum effectiveness. To further ensure the readiness of its response teams, EPA provides training to emergency responders so that they have the necessary skills and use appropriate precautions when undertaking emergency response measures.
Contingency plans describe the information and processes for responding to hazardous substance emergencies, including the roles and responsibilities of the different responding agencies, the location and availability of response resources, the process for conducting the response, and other actions necessary to ensure a safe and effective cleanup. When used properly by trained personnel, a well-designed contingency plan enables response efforts to proceed smoothly and effectively, minimizes danger to cleanup personnel, reduces overall costs of cleanup by avoiding unnecessary effort, and ensures the protection of human health and the environment. Because the approaches and methods for responding to releases are constantly evolving, contingency plans also are constantly evolving and improving.
A network of contingency plans with different levels of geographical scope form the backbone of our country's efforts to prepare for and coordinate responses to emergency incidents:
- The National Contingency Plan Overview (National Oil and Hazardous Substances Pollution Contingency Plan - 40 CFR Part 300) is the federal government's primary plan for preparing for, and coordinating with, other emergency responders. The National Contingency Plan establishes the principles and structure of the unified command system and identifies the roles and responsibilities of the key players within the system.
- The federal government also prepares Regional and Area Contingency Plans that coordinate effective responses within each of the 10 standard federal regions and other designated Areas covering Alaska, the Caribbean, and several islands in the Pacific. These plans include preparedness information on a regional level and identify useful response facilities and resources available from government, commercial, academic, and other sources.
- At the local level, Local Contingency Plans are developed to prepare and organize local resources in the event of the accidental release of hazardous substances. Under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), state governors are required to establish State Emergency Response Commissions, which in turn establish Local Emergency Planning Committees (LEPCs) for districts within the state. These emergency planning organizations are responsible for developing local contingency plans using chemical inventory information collected as part of the law's community right-to-know provisions.
- Federal on-scene coordinators, who are the federal government's frontline staff during an incident, may develop an On-Scene Coordinator (OSC) Contingency Plan for responses in the OSC's area of responsibility. These plans identify probable locations of releases, the availability and location of emergency response resources, and the local structure for responding to release incidents.
Taken together, these activities and resources form the cornerstone of our country's ability to respond to hazardous substance emergencies regardless of their nature, size, or location.
Federal, State, and Local Cooperation
Together, EPA and state and local governments form an effective partnership at all points in the emergency response process as part of our country's National Response System, a multi-layered network of individuals and teams from local, state, and federal agencies, industry, and other response organizations.
Federal Response Actions
The Superfund law grants the Emergency Response program and the Superfund program the authority to respond to hazardous substance emergencies. On the national level, the Superfund law distinguishes between short-term and long-term responses to threats posed by hazardous substances. Short-term responses address immediate threats to public health and the environment. These short-term national responses are primarily coordinated by the Emergency Response program. EPA differentiates among three types of emergency response alternatives according to the urgency of the situation, and the Emergency Response program ensures that all elements of the response system are ready to respond immediately to any hazardous substance emergency, wherever it occurs. Since its inception in 1980, the program has compiled an impressive record of accomplishments.
The Superfund Response program is primarily responsible for long-term responses, which involve complex and highly contaminated sites where it often requires several years to fully study the problem, develop a permanent remedy, and clean up the hazardous waste. As of August 1996, there were over 1200 Superfund sites undergoing some form of long-term cleanup. Together, the Superfund and the Emergency Response programs coordinate safe and effective response techniques for any type of hazardous substance emergency.
Response Teams and the National Response System
Sometimes, when an EPA On-Scene Coordinator (OSC) or other emergency responder comes to the scene of a hazardous substance release, he or she immediately knows that extra technical help will be needed. In these cases, additional support may come from several response teams established under the National Contingency Plan:
|Members of EPA's Radiological Emergency Response Team (RERT) inspecting a potentially hazardous site. Credit: EPA|
Environmental Response Team: The Environmental Response Team (ERT) is a group of EPA technical experts who provide around-the-clock assistance at the scene of hazardous substance releases, offering expertise in such areas as treatment, biology, chemistry, hydrology, geology, and engineering. The ERT can provide support to the full range of emergency response actions, including unusual or complex emergency incidents such as underwater releases.
National Response Team: The National Response Team (NRT) is an inter-agency group that provides guidance prior to an incident and, when requested, technical and financial assistance during an incident.
Regional Response Teams: Regional Response Teams (RRTs) also are interagency groups that consist of representatives from federal, state, and local governments. They conduct pre-response planning and preparedness activities, as well as coordinate and provide advice during response actions. The two principal components of the RRT are thirteen regional standing teams that provide region-wide support on communications, planning, coordination, training, evaluation, and preparedness, as well as incident-specific teams for which participation depends on the technical nature and location of the incident.
State and Local Responders
Individual states are members in their respective Regional Response Teams, which are established and maintained in the National Response System to provide On-Scene Coordinator (OSCs) with support and assistance in responses to release incidents at the Regional level. Prior to emergency incidents, EPA coordinates with states to ensure that state contingency plans are consistent with what was accomplished through national and regional contingency planning.
Local responders have, perhaps, the most vital role in the National Response System. Because firefighters and local police are usually the first responders at the scene of an incident, they are the first to assess the situation, identify the hazards, and take emergency measures, such as fighting a fire, securing the area, or re-routing traffic. Their assessment and initial activities help the EPA OSC determine what EPA actions are necessary.
National Response Team
Response planning and coordination is accomplished at the federal level through the U.S. National Response Team (NRT), an interagency group co-chaired by the EPA and the U.S. Coast Guard. Although the NRT does not respond directly to incidents, it is responsible for three major activities related to managing responses: (1) distributing information; (2) planning for emergencies; and (3) training for emergencies. The NRT also supports the Regional Response Teams.
The NRT is responsible for distributing technical, financial, and operational information about hazardous substance releases and oil spills to all members of the team. This information is collected primarily by NRT committees whose purpose is to focus attention on specific issues, then collect and disseminate information on those issues to other members of the team. Standing committees of the NRT and the topics that are addressed include:
- Response Committee, chaired by EPA, addresses issues such as response operations, technology employment during response, operational safety, and interagency facilitation of response issues (e.g., customs on transboundary issues). Response specific national policy/program coordination and capacity building also reside in this committee.
- Preparedness Committee, chaired by the U.S. Coast Guard, addresses issues such as preparedness training, monitoring exercises/drills, planning guidance, planning interoperability, and planning consistency issues. Preparedness specific national policy/program coordination and capacity building also reside in this committee.
- Science and Technology Committee, chaired by EPA and the National Oceanic and Atmospheric Administration in alternating years, provides national coordination on issues that parallel those addressed by the Scientific Support Coordinator on an incident by incident basis. The focus of this committee is on identifying developed technology and mechanisms for applying those technologies to enhance operational response. The committee monitors research and development of response technologies and provides relevant information to the RRTs and other members of the National Response System to assist in the use of such technologies.
Planning for Emergencies
|EPA inspectors look for hazardous spills in obvious places such as chemical plants and factories, but also visit sites like this high school chemistry lab to ensure no materials are creating a danger for students. Credit: EPA|
The NRT ensures that the roles of federal agencies in the NRT for emergency response are clearly outlined in the National Contingency Plan (see the National Oil and Hazardous Substances Pollution Contingency Plan Overview). After a major incident, the effectiveness of the response is carefully assessed by the NRT. The NRT may use information gathered from the assessment to make recommendations for improving the National Contingency Plan and the National Response System. The NRT may be asked to help Regional Response Teams (RRTs) develop Regional Contingency Plans. The NRT also reviews these plans to determine whether they comply with federal policies on emergency response.
Training for Emergencies
Training is the key to the federal strategy for preparing for oil spills or hazardous substance releases. Although most training is performed by state and local personnel, the NRT develops training courses and programs, coordinates federal training efforts, and provides information to regional, state, and local officials about training needs and courses.
Supporting Regional Response Teams
The NRT supports Regional Response Teams (RRTs) by reviewing Regional or Area Contingency Plans to maintain consistency with national policies on emergency response. The NRT also supports RRTs by monitoring and assessing RRT effectiveness during an incident. The NRT may ask an RRT to focus on specific lessons learned from a particular incident and to share those lessons with other members of the National Response System. In this way, the RRTs can improve their own regional contingency plans while helping to solve problems that might be occurring elsewhere within the National Response System.
National Response Team (NRT) Member Roles and Responsibilities
EPA personnel chair the National Response Team and cochair all Regional Response Teams (RRTs). The agency provides On-Scene Coordinators (OSCs), scientific support coordinators for inland spills, and Remedial Project Managers for hazardous waste remedial actions under Superfund. EPA funds the Environmental Response Team (ERT), which is dispatched at the OSC's request to any response episode exceeding available regional resources. The ERT can provide support for site assessments, health and safety issues, action plan development, and contamination monitoring. Legal expertise is also available from EPA to interpret environmental statutes.
- U.S. Coast Guard: An agency of the U.S. Department of Transportation, the U.S. Coast Guard serves as ViceChair for the National Response Team. U.S. Coast Guard provides OSCs for coastal zones and cochairs all RRTs. Twenty four hour-a-day staffed facilities in 46 "Captain of the Port Zones" are maintained by the U.S. Coast Guard, for command, control, and surveillance of releases in coastal waters. The U.S. Coast Guard manages the National Response Center and maintains a National Strike Force, specially trained and equipped to respond to major marine pollution incidents. The U.S. Coast Guard's Strike Teams are based on the Pacific and Gulf Coasts. The U.S. Commandant of the Coast Guard also serves as fund manager for the Oil Pollution Liability Trust Fund set up under the Clean Water Act.
- Federal Emergency Management Agency (FEMA): During a response effort, FEMA advises and aids lead agencies in coordinating relocation assistance. The agency provides guidance, policy, and technical assistance in emergency preparedness planning, training, and exercising activities for state and local governments.
- Department of Defense (DoD): DoD acts when oil or hazardous substances are released from a facility or vessel under its jurisdiction. Upon request, DoD will provide U.S. Navy oil spill containment and recovery equipment and manpower, as well as equipment for ship salvaging, shipboard damage control, and diving. DoD may also make U.S. Army Corp of Engineer equipment and expertise available for removing navigational obstructions and performing ship structural repairs.
- Department of Energy (DOE): This agency provides OSCs when hazardous substances are released from DOE facilities, or when materials being transported under DOE's control are spilled. DOE staff aids in the control of immediate radiological hazards.
- Department of Agriculture (USDA): USDA measures, evaluates, and monitors situations where natural resources, including soil, water, wildlife, and vegetation have been affected by hazardous substances. USDA contributes expertise from the following organizations:
- Forest Service
- Agriculture Research Service
- Natural Resources Conservation Service (formerly Soil Conservation Service)
- Food Safety and Inspection Service
- Animal and Plant Health Inspection Service
- Department of Commerce (DOC): This department, through the National Oceanic and Atmospheric Administration (NOAA), provides scientific support for resources and contingency planning in coastal and marine areas including hazard assessment and spill trajectory (direction) monitoring to predict movement and dispersion of oil and other hazardous substances. NOAA contributes information about sensitive coastal environments, and furnishes data about actual and predicted meteorological, hydrological, ice, and oceanographic conditions. NOAA also serves as the natural resource trustee for the living marine resources it manages and protects.
- Department of Health and Human Services (HHS): Health hazards at a response are assessed by HHS. Agencies within HHS that maintain and provide information on health effects include the Agency for Toxic Substances and Disease Registry (ATSDR) and the National Institutes for Environmental Health Sciences (NIEHS). NIEHS also offers training on the health effects of oil spills.
- Department of Interior (DOI): This department contributes expertise on natural resources, endangered species, and Federal lands and waters, and is responsible for native Americans and U.S. territories. Regional Environmental Officers (REO) of DOI are designated members of RRTs DOI serves as a natural resource trustee for the resources it manages or protects. Bureaus within the department with expertise include:
- Fish and Wildlife Service
- Geological Survey Bureau of Indian Affairs
- Bureau of Land Management
- Minerals Management Service
- Bureau of Mines
- National Park Service
- Bureau of Reclamation
- Office of Surface Mining and Reclamation Enforcement
- Office of Territorial Affairs
- Department of Justice (DOJ): Expert advice on legal questions arising from discharges or releases, and Federal agency responses, can be obtained from this agency. DOJ represents the Federal government in litigation relating to discharges or releases.
- Department of Labor (DOL): Through the Occupational Safety and Health Administration (OSHA), DOL conducts safety and health inspections of hazardous waste sites to ensure that onsite employees are protected from hazards and to determine if a site is in compliance with safety and health standards and regulations.
- Department of Transportation (DOT): In addition to the activities of the U.S. Coast Guard, response expertise is provided by DOT pertaining to transportation of oil or hazardous substances through the Research and Special Programs Administration (RSPA). RSPA offers specialized advice on requirements of packaging, handling, and transporting regulated hazardous materials. RSPA serves other functions, including promulgating and enforcing hazardous materials regulations (49 CFR Part 100199), producing emergency response guidebooks, and supporting protective action decision strategies and exercise scenarios.
- Nuclear Regulatory Commission (NRC): When radioactive materials by its licensees are released, this agency responds in accordance with the its incident response plan.
- Department of State: This agency takes the lead in developing international contingency plans. It helps coordinate international response efforts, when discharges or releases cross international boundaries or involve foreign flag vessels. The agency also coordinates requests for aid from foreign governments.
- General Services Administration (GSA)
- Treasury Department
Regional Response Teams
There are thirteen Regional Response Teams (RRTs) in the U.S., each representing a particular geographic region (including the Caribbean and the Pacific Basin). RRTs are composed of representatives from field offices of the federal agencies that make up the National Response Team, as well as state representatives. The four major responsibilities of RRTs are: (1) response; (2) planning; (3) training; and (4) coordination.
RRTs provide a forum for federal agency field offices and state agencies to exchange information about their abilities to respond to On-Scene Coordinator's (OSC's) requests for assistance. As with the National Response Team (NRT), RRT members do not respond directly to releases or spills, but may be called upon to provide technical advice, equipment, or manpower to assist with a response.
Each RRT develops a Regional Contingency Plan to ensure that the roles of federal and state agencies during an actual incident are clear. Following an incident, the RRT reviews the OSC's reports to identify problems with the Region's response to the incident and improves the plan as necessary.
Federal agencies that are members of the RRTs provide simulation exercises of Regional plans to test the abilities of federal, state, and local agencies to coordinate their emergency response activities. Any major problems identified as a result of these exercises may be addressed and changed in the Regional Contingency Plan so the same problems do not arise during an actual incident.
The RRTs identify available resources from each federal agency and state within their regions. Such resources include equipment, guidance, training, and technical expertise for dealing with chemical releases or oil spills. When there are too few resources in a region, the RRT can request assistance from federal or state authorities to ensure that sufficient resources will be available during an incident. This coordination by the RRTs assures that resources are used as wisely as possible, and that no Region is lacking what it needs to protect human health and the environment from the effects of a hazardous substance release or oil spill.
Oil Spill Clean-Up Safety Measures
Personal Protective Equipment
|This EPA worker, wearing Level A protection gear, samples this barrel to determine its contents. If the barrel has rusted to the point of degradation, it will be placed in one of the yellow “overpack” barrels to prevent its contents from leaking. Credit: EPA|
Vapors, gases, and particulates from hazardous substance response activities place response personnel at risk. For this reason, response personnel must wear appropriate personal protective clothing and equipment whenever they are near the site. The more that is known about the hazards at a release site, the easier it becomes to select personal protective equipment. There are basically four levels of personal protective equipment:
- Level A protection is required when the greatest potential for exposure to hazards exists, and when the greatest level of skin, respiratory, and eye protection is required. Examples of Level A clothing and equipment include positive-pressure, full face-piece self contained breathing apparatus (SCBA) or positive pressure supplied air respirator with escape SCBA, totally encapsulated chemical- and vapor-protective suit, inner and outer chemical-resistant gloves, and disposable protective suit, gloves, and boots.
- Level B protection is required under circumstances requiring the highest level of respiratory protection, with lesser level of skin protection. At most abandoned outdoor hazardous waste sites, ambient atmospheric vapors or gas levels have not approached sufficiently high concentrations to warrant level A protection -- Level B protection is often adequate. Examples of Level B protection include positive-pressure, full face-piece self contained breathing apparatus (SCBA) or positive pressure supplied air respirator with escape SCBA, inner and outer chemical-resistant gloves, face shield, hooded chemical resistant clothing, coveralls, and outer chemical-resistant boots.
- Level C protection is required when the concentration and type of airborne substances is known and the criteria for using air purifying respirators is met. Typical Level C equipment includes full-face air purifying respirators, inner and outer chemical-resistant gloves, hard hat, escape mask, and disposable chemical-resistant outer boots. The difference between Level C and Level B protection is the type of equipment used to protect the respiratory system, assuming the same type of chemical-resistant clothing is used. The main criterion for Level C is that atmospheric concentrations and other selection criteria permit wearing an air-purifying respirator.
- Level D protection is the minimum protection required. Level D protection may be sufficient when no contaminants are present or work operations preclude splashes, immersion, or the potential for unexpected inhalation or contact with hazardous levels of chemicals. Appropriate Level D protective equipment may include gloves, coveralls, safety glasses, face shield, and chemical-resistant, steel-toe boots or shoes.
While these are general guidelines for typical equipment to be used in certain circumstances, other combinations of protective equipment may be more appropriate, depending upon specific site characteristics.
An essential element of any hazardous substance release site is the establishment of safety or work zones. These zones are established primarily to reduce the accidental spread of hazardous substances by workers or equipment from contaminated areas to clean areas. Safety zones specify the type of operations that will occur in each zone, the degree of hazard at different locations within the release site, and the areas at the site that should be avoided by unauthorized or unprotected employees. The three most frequently identified zones are below:
- The exclusion zone (or hot zone) is the area with actual or potential contamination and the highest potential for exposure to hazardous substances.
- The support zone (or cold zone) is the area of the site that is free from contamination and that may be safely used as a planning and staging area.
- The contamination reduction zone (or warm zone) is the transition area between the exclusion and support zones. This area is where responders enter and exit the exclusion zone and where decontamination activities take place.
Paying for the Clean-Up
By law, the parties responsible for the use, transportation, storage, and disposal of hazardous substances and oil are liable for the cost of containment, cleanup, and damages resulting from a release, or threat of release, related to their own activities. EPA's goal is to identify the responsible parties and ensure that they pay these costs.
Unfortunately, the responsible party sometimes cannot be identified or simply refuses to cooperate with the response effort. In such instances, EPA and other participants in the National Response System will step in without delay to ensure that the emergency is dealt with in a timely and appropriate manner. During and after the cleanup, EPA will continue to search for the responsible party and seek payment for the costs incurred. These efforts do not always result positively; on some occasions, the responsible party is never identified.
Congress established two funds to cover the costs of federal cleanup activities when the responsible party does not or cannot pay: the Superfund and the Oil Spill Liability Trust Fund. Both of these funds are financed through taxes on industry, reflecting Congressional recognition of the need for unhesitating response to serious health and environmental hazards and an unwillingness to burden the taxpayer with the sometimes very large costs involved. In a further step, Congress directed that a percentage of the Superfund be used by the Local Governments Reimbursement (LGR) Program to help offset costs involved with the clean up of hazardous substance releases.
Oil Spill Liability Trust Fund
Under the Oil Pollution Act of 1990, the owner or operator of a facility from which oil is discharged (also known as the responsible Party) is liable for the costs associated with the containment or cleanup of the spill and any damages resulting from the spill. The EPA's first priority is to ensure that responsible parties pay to clean up their own oil releases. However, when the responsible party is unknown or refuses to pay, funds from the Oil Spill Liability Trust Fund can be used to cover removal costs or damages resulting from discharges of oil.
The primary source of revenue for the fund is a five-cents per barrel fee on imported and domestic oil. Collection of this fee ceased on December 31, 1994 due to a "sunset" provision in the law. Other revenue sources for the fund include interest on the fund, cost recovery from the parties responsible for the spills, and any fines or civil penalties collected. The Fund is administered by the U.S. Coast Guard's National Pollution Funds Center (NPFC).
The Fund can provide up to $1 billion for any one oil pollution incident, including up to $500 million for the initiation of natural resource damage assessments and claims in connection with any single incident. The main uses of Fund expenditures are:
- State access for removal actions;
- Payments to Federal, state, and Indian tribe trustees to carry out natural resource damage assessments and restorations;
- Payment of claims for uncompensated removal costs and damages; and
- Research and development and other specific appropriations.
Factors that Impact Response Efforts
Different factors affect the ability to contain and clean up an oil spill. Issues concerning geographic isolation, weather conditions, body of water, and type of shoreline are all considered when creating a spill site scenario.
The remote location of an oil spill can present many logistical problems. Lodging, communication resources, and the ability to access an accident scene are all factors for consideration. Small communities may not have adequate facilities to shelter emergency response teams, nor adequate telephone lines and radio transmitters to handle the sudden increase in long distance correspondence. In some cases, cleanup equipment will have to be moved over great distances to reach a spill site. Large planes carrying this equipment may not be able to land at the nearest airstrip.
In addition, most spill response equipment and materials are greatly affected by such factors as shifting tides, water currents, wind, and environmental factors, including water salinity and temperature. (For example, biodegradation and dispersing agents both tend to work best in warm water environments, and moderate wave activity can enhance the effectiveness of gelling agents.) Standing water such as marshes or swamps with little water movement are likely to incur more severe impacts than flowing water because spilled oil tends to "pool" in the water and can remain there for long periods of time. In calm water conditions, the affected habitat may take years to restore. Flowing water is less impacted by oil spills than standing water because the currents provide a natural cleaning mechanism.
Surrounding habitats and type of shoreline must also be considered when determining the best form of response. Biological communities differ in their sensitivity to the effects of oil spills and the physical intrusion that may be associated with various cleanup methods. Spilled oil and cleanup operations can threaten different types of marine habitats, with different results.
Geology of Shorelines
Shorelines can vary dramatically in their forms and compositions. Some shorelines are narrow with beaches formed from rounded or flattened cobbles and pebbles; some are wide and covered in a layer of sand or broken shell fragments; and still others are steep cliffs with no beach at all. The composition and structure of the beach will determine the potential effects of oil on the shoreline.
Oil tends to stick to mud and to the surfaces of cobbles and pebbles. It also flows downward in the spaces between cobbles, pebbles, and sand grains, and accumulates in lower layers of beach sediments. Oil that sticks to mud particles suspended in the water column and to cobbles and pebbles on the beach is exposed to the action of sunlight and waves, which helps it to degrade and makes it less hazardous to organisms that come into contact with it. Oil that sticks to rocks and pebbles can be wiped or washed off. Oil that flows onto sandy beaches, however, can "escape" downward into sand, making it difficult to clean up and reducing its ability to degrade.
Natural processes such as evaporation, oxidation, and biodegradation help to clean the shoreline. Physical methods such as wiping with sorbent materials, pressure washing, raking, and bulldozing can be used to assist these natural processes. Choosing the most effective yet potentially least damaging cleaning methods helps to assure that the natural systems of shorelines will be preserved and protected for future generations.