TABLE OF OONl'Em'8

1. INTRODUCTION 1-1

2. REGULATORY SUMMARY 2-1

3. TRAINING FOR QUALIFIED INDNIDUALS 3-1

3.A... Suggested training elements

for qualified lni:lividuals 3-2

4, TRAINING FOR SPILL MANAGEMENT TEAMS 4-1

4.A...Suggested training elements

for spill management team members 4-2

5. TRAINING FOR VESSEL PERSONNEL 5-1

5.A... Suggested training requirements for

vessel response plans to comply with 33 CFR
155.1035, 155.1040, and 155.1055 5-2

5.6... Suggested training requirements for

vessel response plans to comply with 33 CFR
155.1045 5-3

5.C ... Suggested training elements for

members of the vessel crew having
responsibilities under the plan 5-4
5.D ... Sugpested training elements for other
personne as described In 33 CFR 155.1040
(unmanned tankbarges) with speclijc responsl-
bllitles under the plan 5-7

6. TRAINING FOR FACILITY PERSONNEL 6-1

6A ..Suggested training elements for

facility personnel 6-2

7. TRAINING FOR OIL SPILL REMOVAL ORGANIZATIONS 7-1

8. tRAINING FOR WORKER HEALTH AND SAFETY 8-1

8A ..Outllne of general requirements for

emergency phase and po~-emergency response
operations "- 8-2

8.6...Declslon guide for on-site training

requirements 8-6
APPENDICES

A. OIL SPILL RESPONSE COURSES A-1

A-1 ... Level 1 course for oil spill response A-2
A-2... Level 2 course for oil spill response A-14
B. TRAINING RESOURCES B-1
C. SAMPLE LESSON PLANS
TAB A ... Containment and recovery equipment and
techniques C-1
TAB B... Shoreline cleanup and disposal C-22
TAB C ... Physical, chemical and toxicological
properties of oil C-53
~ 1: ~

The Oil Pollution Act of 1990 (OPA) amended the Federal Water Pollution Control Act
(FWPCA) to require tank vessel and facility response plans. The plans are intended to
prepare the owner of a vessel or facility to respond to an oil or hazardous substance
discharge. Response plans must describe the training of persons on a tank vessel
which carries oil or hazardous substances in bulk as cargo or cargo residue, at an
offshore facility, or at an onshore facility where its location could reasonably be
expected to cause substantial harm to the environment by discharging oil or hazardous
substances into the navigable waters, adjoining shoreline, or exclusive economic zone.
The training is required to ensure the safety of the vessel or facility and to mitigate or
prevent a discharge of oil or a hazardous substance. The definition of a facility is very
broad under OPA and includes any offshore facility, onshore facility, motor vehicle,
rolling stock, or pipeline used for oil exploration, production, storing, handling,
transferring, processing, or transporting oil.

In addition to OPA-required response training, there are other federal and state
response training requirements. Vessel and facility owners or operators are responsible
for ensuring that all private response personnel which they employ are trained to meet
the Occupational Safety and Health Administration (OSHA) Hazardous Waste
Operations Standard (29 CFR 1910.120.) These requirements, commonly referred to as
the HAZWOPER regulations, were established to ensure the health and safety of
personnel employed in hazardous substance response and clean-up operations.
Personnel employed at facilities which transfer or store products in bulk, classified as
hazardous substances by OSHA, must also comply with HAZWOPER regulations.
Crude oil, petroleum oil, and petroleum distillates are considered hazardous substances
by OSHA. In addition to the HAZWOPER regulations, employers must comply with
federal requirements contained in 49 CFR Parts 172 and 176 to train employees
handling hazardous materials.

There are four federal agencies with responsibilities under OPA to require vessel and
facility response plans: the U.S. Coast Guard (USCG), the U.S. Environmental
Protection Agency (EPA), the Department of Transportation's Research and Special
Programs Administration (RSPA), and the Minerals Management Service (MMS). These
agencies recognize that pollution response training should be directly related to the
duties and responsibilities of the workers in the response organization. Workers with a
limited role in a response need to be trained to protect their health and to perform their
normal duties in a safe manner. They must also be trained to conduct the proper
notifications to the National Response Center and to immediately intervene to mitigate a
spill once it has occurred. Workers with spill clean-up responsibilities will need to be
trained to deploy and operate the equipment they will actually use in the response.
Other personnel with a more active role in the response organization or w"ith supervisory
responsibilities may need additional training in such subjects as response or clean-up
technology, spill trajectory forecasting or response management strategies.

In order to assist companies in meeting their regulatory responsibilities to develop

training programs for their personnel, the four federal agencies have developed this
training reference manual for oil spill response. The contents provide a foundation of
suggested subject material for training personnel with responsibilities Identified In
response plans. Subject material is provided for each of the key individuals or groups of
people required to be identified in response plans as well as for worker health and
safety as follows:

1-1
 " Qualified Individual (Section 3)

" Spill Management Team (Section 4)

" Vessel Personnel (Section 5)

" Facility Personnel (Section 6)

>< Oil Spill Removal Organizations (Section 7)

>< Worker Health and Safety (Section 8)
The training elements included are not intended to be a "cookbook" providing a
complete training program of lesson plans to cover all subject areas. Rather, they are
intended to be a foundation upon which individual companies may build training to suit
their needs. Some of the material may not be applicable to the needs of the company
or roles of the company personnel in the company's response organization. In order to
assist industry and governmental response organizations, we have included some
lesson plans used to train USCG personnel in pollution response. We expect that some
modifications or enhancements to the lesson plans may be required to meet the training
needs of your organization. The lesson plans also do not cover all of the technical
subjects, (i.e., vessel salvage,) required to be addressed by individual plan holders.
Although initially intended as information for vessel and facility owners or operators, we
have determined that the training elements may prove useful to any industry which
handles, stores, or transports oil, regardless of location. The training elements may also
prove useful to state agencies or governmental response organizations. The training
elements are intended to be strictly voluntary and non-regulatory. Any conflict with
existing federal or state regulations in this document is unintentional and does not
relieve owners or operators of facilities or vessels from compliance with federal or state
laws or regulations.

The International Maritime Organization (IMO), based in London, England, has been
developing training courses for oil spill response. Resolution seven of the International
Convention on Oil Pollution Preparedness, Response and Cooperation, 1990 (OPRC),
committed IMO to the "development and implementation of a training program for oil
pollution preparedness and response." After analyzing responses to major oil spills,
IMO recognized that the capability of a nation to respond to an oil spill is dependent on
both the availability of adequate equipment and trained response personnel to operate
the equipment. A special need was identified to assist developing countries by
providing training to their response personnel. As a result, IMO invited interested
member governments to help develop training programs in preparedness and
response. IMO working groups then identified three levels of training for oil spill
response:

" Level 1 - First responder level (or operational staff).

~ Level 2 - Middle management level (supervisors or on-scene commanders).

" Level 3 - Senior management level (decision makers at

the upper level)

The Canadian Coast Guard agreed to act as lead country of a correspondence group in
the design work for these IMO courses. Drawing upon its own expertise and that of
member nations, the Canadian Coast Guard has actively pursued course development.

1-2
 Design work on the first two courses has been completed. The subsequent stages of
course development, testing, implementation, and evaluation are expected to follow.

The course design material for the first two IMO courses has been modified slightly to
make it more relevant to the oil spill training needs of the United States. The design
material, presented in the form of a job task analysis, is included in the appendix
sections of this document for your information only. The IMO courses were never
intended to be promulgated as standards or regulations and should not be used as
such. Please consider the material as a menu of training elements from which to select
relevant material that may be incorporated into your own training program on an as­
needed basis .•

1-3
On February 5, 1993, the USCG published interim final rules requiring vessel and facility
owners to identify the training to be provided to each individual who has responsibilities
as described in company response plans [58 FR 7424 (vessels); and 58 FR 7352
(facilities)]. The USCG regulates and is required to review and approve all deepwater
port, vessel, and marine transportation-related facility response plans. Rather than
develop highly prescriptive regulatory requirements, the USCG has allowed vessel and
marine transportation-related facility owners and operators the flexibility to choose the
manner in which they describe training in their response plans. USCG regulations are
found in 33 CFR parts 150, 154 and 155.
EPA regulates non-transportation related onshore facilities and certain offshore facilities
located landward of the coastline under the oil pollution prevention regulations (40 CFR
part 112). EPA published a final rule in the Federal Register on July 1, 1994. to amend
these regulations to include response plan requirements under OPA [50 FR 34097).
The final rule requires the owner or operator of a substantial harm facility to develop and
implement a facility response plan, which includes a training program for those
personnel involved in oil spill response activities. The rule recommends that the training
program be based on this reference manual. as applicable to facility operations. An
alternative training program can also be acceptable, subject to approval by the Regional
Administrator.
Under OPA, the MMS regulates offshore facilities, including associated pipelines, other
than deepwater ports subject to the Deepwater Port Act. Under a Memorandum of
Understanding among the Department of the Interior, the Department of Transportation,
and the EPA, MMS only regulates those offshore facilities located seaward of the
coastline. The MMS published an interim final rule (IFR) on February 8, 1993, requiring
spill response plans from offshore facilities [58 FR 7490). The IFR will expire on February
18, 1995, or when superseded by a final rule. The MMS is currently preparing a notice
of proposed rulemaking (NPRM) for the final rule on spill response plans.

RSPA's Office of Pipeline Safety regulates onshore transportation-related natural gas,

hazardous liquid (including oil and refined products), and carbon dioxide pipelines.
RSPA plans to issue regulations establishing training qualifications for pipeline personnel
involved in operations, maintenance, and emergency response functions. A notice of
proposed rulemaking is expected in late summer of 1994.■

2-1
Industry response plan holders must identify a qualified individual who will act as the
point of contact between the federal government and the owner or Operator of the
vessel or facility. This individual is also referred to as the emergency response
coordinator by EPA regulations. The responsibilities of the qualified individual go far
beyond that of a mere intermediary. As defined in OPA, the qualified individual is that
person identified in a response plan having "full authority to implement removal actions"
on behalf of the plan holder. The qualified individual must have the authority to commit
the financial resources of the company to prevent or clean up a spill.
One of the primary responsibilities of the qualified Individual is, upon learning of a spill or
potential spill of an oil or hazardous substance, to immediately communicate with the
appropriate federal official and the persons providing personnel and equipment for the
spill response. This procedure will ensure timely notification of federal officials so that
they may activate Area Contingency Plans notify other federal, state, and local agencies
ensure adequate measures are taken by the responsible party and activate
governmental response resources when necessary. It also ensures that response
resources identified by the plan holder will commence appropriate response actions in a
timely manner.
Federal regulations require response plan holders to identify the type of training the
qualified individual will receive. The goal is to ensure that the qualified individual is fully
capable to perform his or her duties. Although the qualified individual is not expected to
be a technical expert in vessel salvage, clean-up technology, or pipeline repair, the
qualified individual must be familiar enough with the company's response plan to know
what measures must be taken under the circumstances. The qualified individual must
ensure adequate steps.are taken to mitigate the situation and should know the
capabilities of any oi! spill removal organization (OSRO) which is contracted to respond
on behalf of the company. The qualified individual should be thoroughly familiar with
procedures to activate and contract with the company's OSRO.
The following TAB provides suggested elements which could be incorporated into the
training program for a qualified individual. The material should not be considered as
mandatory training nor should it be considered all-inclusive. A training program which
provided all of the suggested training elements would certainly be very comprehensive.
An individual receiving this training would have an excellent educational foundation to
help him or her play a highly pro active role in the plan holder's response organization.
Plan holders must decide the actual role of the qualified individual in their organizations
and customize their training programs accordingly.

3-1
 TABA
Suggested training elements for qualified individuals:
Demonstrate knowledge ofthe following:

• Captain of the Port (COTP) Zones or Environmental Protection Agency (EPA)

Regions in which the vessel will operate or facility is located.

• Notification procedures and requirements for vessel or facility owners or operators;

Internal response organizations; federal and state agencies; and contracted oil spill
removal organizations (OSROs) and the information required for those organizations.

• Communication system used for the notifications.

• Information on the cargoes carried by the vessel or transferred, stored, or used by

the facility, including familiarity with the material safety data sheets, special handling
procedures, health and safety hazards, spill and fire fighting procedures.

• Procedures the crew or facility personnel may use to mitigate or prevent any
discharge or a substantial threat of a discharge of oil resulting from shipboard or facility
· operational activities associated with internal or external cargo transfers, storage, or
.use.
• Procedures the vessel's crew may use to mitigate or prevent any discharge or a
substantial threat of a discharge of oil in the event of --

• Grounding or stranding;
• Collision;
• Explosion or fire;
• Hull failure;
• Excessive list; or
• Equipment failure.

• Procedures for both the Internal and ship-to-ship transfers of car99 in an emergency.

• Procedures and arrangements for emergency towing, including the rigging and
operation of any emergency towing equipment aboard the vessel.

• Vessel crew or facility personnel responsibilities, and procedures to, use of shipboard
or facility equipment which may be carried to mitigate an oil discharge.

• The vessel crew's responsibilities, if any, to initiate a response and supervise shore­
based response resources.

• Operational capabilities of the contracted OSROs to respond to the following:

• Average most probable discharge (small discharge);

• Maximum most probable discharge (medium discharge); and
• Worst case discharge.

3-2
• Responsibilities and authorities of the qualified individual as described In the vessel or
facility response plan and company response organization.

• Procedures, if applicable, for transferring responsibility for direction of response

activities from vessel personnel to the shore-based spill management team.

• The organizational structure that will be used to manage the response actions,
including --

0 Command and control;

0
Public information;
0
Safety;
0
Liaison with government agencies;
Spill response operations;
0

Planning;
0

Logistics support; and

0

° Finance.

• The responsibilities and duties of each oil spill management team member within the
organizational structure.
• The drill and exercise program to meet federal and state regulations as required
underOPA.

• The role of the qualified individual in the post discharge review of the plan to evaluate
and validate its effectiveness.

• Area Contingency Plans (ACPs) for the areas in which the vessel operates or the
facility is located.

• The National Contingency Plan (NCP).

• Roles and responsibilities of federal and state agencies in pollution response.

• Available response resources identified in response plan.

• Contracting and ordering procedures to acquire oil spill removal organization

resources identified in the response plan.

• Occupational Safety and Health Administration (OSHA) requirements for worker

health and safety (29 CFR 1910.120).

• Incident Command System/Unified Command System.

• Public affairs.

• Crisis management.

• Procedures for the plan holder's ship salvage arrangements.

• Procedures for obtaining approval for dispersant use or in-situ burnin~ of the spill.

• Oil spill trajectory analyses.

• Sensitive biological areas.•

3-3
A spill management team is also required to be designated by USCG regulations. The
function of the team is to assist or relieve the companys qualified individual in the actual
response to an oil or hazardous substance spill. The team staffs the organizational
structure the company has identified to manage response plan implementation. The
team may also provide the operational oversight of field response personnel.

Although the size and qualifications of the spill management team have not been
federally mandated, the team must be adequately staffed to ensure a credible response
depending on the size of the spill. The number of members will be expected to grow if
the situation warrants 24 hour per day operations and a cast of several thousand clean­
up personnel. A well-structured response organization will be able to accommodate
changes in the size of the spill management team and rapidly integrate additional
members.

Many private companies have chosen response organizations based on the Incident
Command System (!CS) model which was developed in the early 1970's in California by
federal, state, and local officials to fight major forest fires. There are many systems that
are used throughout the United States for the direction and control of resources in
emergencies. The National Fire Academy and the National lnteragency Incident
Management System have both developed popular models for !CS-based response
organizations. However, regardless of the specifics of the systems, all !CS systems are
based on the same basic business management principles. In a business or
government environment, managers and leaders perform the basic daily tasks of
planning, directing, organizing, coordinating, communicating, delegating, and
evaluating. The same is true for emergency response management.

OSHA requires the senior emergency response official of hazardous substance

emergency response organizations to use a site-specific !CS. The response
management organization is built around five major management activities:

):( Command;
" Operations;
" Planning;
" Logistics; and
):( Administration and Finance.

OPA requires the On-Scene Coordinator (OSC) to work with state and local officials in
the development of ACPs, to ensure pre-planning of joint response efforts, and to
expedite decisions for the use of dispersants and other mitigating substances. The
Federal Government, through its NCP, uses a Unified Command Structure (UCS). This
structure is intended to bring the OSC, state official, and the responsible party together
to facilitate the decision making processes and optimize the combined response efforts
of all participants. The UCS structure can easily integrate members of the spill
management team who will be most likely invited to participate.

The key to training spill management team members is to train them according to their
functional role within the response organization. Members staffing an operations center
need to be trained differently from members whose primary function is logistics. Many
of the company's personnel will be able to draw upon skills they use and training they

4-1
have obtained in the company's everyday activities of running the facility or vessel
operation. Personnel designated to administer the financial duties of spill response and
cost documentation are especially likely to have such experience. Other personnel will
be asked to fill roles which they may only perform in a crisis situation: therefore, due to
the infrequency of an actual crisis, these personnel would need extra periodic training to
perform crisis functions.

If the individual will always fill the same spill management team function, training
requirements will be narrowed in scope. If a company desires greater flexibility in use of
their personnel and redundancy in available knowledge in case key personnel are
unavailable, it may choose to add to the curricula presented to team members. The
goal is to train these personnel so that the team can function as a coordinated unit and
direct the clean-up activities or preventative measures in an efficient and timely manner.

4-A provides suggested elements which could be incorporated Into the training program
for the spill manageITlent team. The material should not be considered as mandatory
training nor should it be considered all-inclusive. A training program which provided all
of the suggested training elements would certainly be very comprehensive. Team
members receiving this training would have an excellent educational foundation to help
them play a highly pro active role in the plan holder's response organization. Plan
holders must decide the actual role of their spill management team members in their
organizations and customize their training programs accordingly.
4.A. Suggested training elements for Spill Management Team members:

Demonstrate knowledge of the following:

♦ The Captain of the Port (COTP) Zones or EPA Regions in which the vessel will
operate or facility is located.

• Notification procedures and requirements for vessel or facility owners or operators,

internal response organizations, federal and state agencies; and contracted oil spill
removal organizations and information required for those organizations.

• Communication systems used for-the notifications.

• Information on the cargoes carried by the vessel or transferred, stored, or used by
the facility, including familiarity with the material safety data sheets, special handling
procedures, health and safety hazards, spill and firefighting procedures.

• Procedures the vessel's crew may use to mitigate or prevent any discharge or a
substantial threat of a discharge of oil in the event of --

• Grounding or stranding;
° Collision;
• Explosion or fire;
• Hull failure;
• Excessive list; or
• Equipment failure.

• Vessel crew or facility personnel responsibilities, and procedures for use of shipboard
or facility equipment which may be carried to mitigate an oil discharge.

♦ Vessel crew's responsibilities, if any, to initiate a response and supervise shore­

based response resources.

4-2
• The operational capabilities of the contracted oil spill removal organizations (OSROs)
to respond to the --

0 Average most probable discharge (small discharge);

0
Maximum most probable discharge (medium discharge); and
0
Worst case discharge.

• Responsibilities and authority of the qualified individual as described in the vessel or

facility response plan and company response organization.

• Procedures, if applicable, for transferring responsibility for direction of response

activities from vessel personnel to the shore-based spill management team.

+ The organizational structure that will be used to manage the response actions,
including --

0 Command and control;

0
Public information;
0
Safety;
Liaison with government agencies;
0

Spill response operations;

0

Planning;
0

Logistics support; and

0

° Finance.

• The responsibilities and duties of the oil spill management team member within the
organizational structure, in accordance with designated job responsibilities.

+ The training procedures as described in the response plan for members of the spill
management team.

+ The drill and exercise program to meet the federal and state regulations as required
byOPA.

• Procedures for the post discharge review of the plan to evaluate and validate its
effectiveness.

+ The Area Contingency Plans (ACPs) for the areas in which the vessel operates or the
facility is located.

+ The National Contingency Plan.

+ Roles and responsibilities of federal and state agencies in pollution response.

+ Available response resources.
+ Contracting and ordering procedures to acquire OSRO resources, in accordance
with designated job responsibilities.

• Basic information on spill operations and oil spill clean-up technology including --

0 Oil containment;
0
Oil recovery methods and devices;
0
Equipmsi1t limitations and uses;

4-3
 • Shoreline clean-up and protection;
• Spill trajectory analysis;
• Use of dispersants, in-situ burning, bioremediation; and
• Waste storage and disposal considerations.

• Hazard recognition and evaluation.

• Site safety and security procedures.

• OSHA requirements for worker health and safety (29 CFR 1910.120).

• Incident Command System and Unified Command System.

• Public affairs, as applicable to designated job responsibilities.

• Crisis managemePt, as applicable to designated job responsibilities.

• Personnel management, as applicable to designated job responsibilities.

• Ship salvage procedures, vessel damage stability and hull stress considerations
when perfonming shipboard mitigation procedures, as applicable to designated job
responsibilities.

• Emergency cargo transfer procedures, as applicable to designated job

responsibilities.

• Procedures for both the internal and ship-to-ship transfers of cargo in an emergency,
as applicable to designated job responsibilities.

• Procedures and arrangements for emergency towing, including the rigging and
operation of any emergency towing equipment aboard the vessel, as applicable to
designated job responsibilities.

• Sensitive biological areas, as applicable to designated job responsibilities.

• Procedures for directing the deployment and use of spill response equipment, as
applicable to designated job responsibilities.

4-4
~ I A : 031 ~60 ~ ~

The USCG has worked closely with IMO and the Canadian Coast Guard in the
development of course curricula for oil spill response. In August 1993, the USCG
distributed two sets cf draft voluntary training guidelines for oil pollution response. The
guidelines were modifications of training material which IMO will be using to train
members of the international community. The guidelines provided industry with an
outline of recommended subject areas in which personnel involved in oil spill response
and clean-up could be trained in. They were presented in the form of a job task analysis
for two separate training courses. One course was designed for non-supervisory
operational personnel, while the other course was designed for supervisory operational
personnel. The guidelines were intended to assist owners and operators of vessels,
marine transportation-related (MTR) facilities, and deepwater ports in developing or
choosing training programs for oil spill response for their operational personnel.

A job task analysis (JTA) can be considered a job performance outline. Job
requirements are broken into specific performance elements referred to as tasks and
sub-tasks. For instance, task number 13, "Transfer oily wastes,• is subdivided into three
sub-tasks:

>< 13.1 Categorize and quantify collected materials;

>< 13.2 Select pump, conveyors, and other equipment; and

>< 13.3 Safely operate transfer equipment.

The knowledge which must be communicated to teach each sub-task and the resulting
skills which the student must demonstrate after training is completed are also provided.
Because of the different job responsibilities of each employee and their intended role in
the vessel or facility plan, the JTA should be customized by the trainer. Trainers may
use the guidelines as a menu of subject areas from which to select relevant topics
depending on the duties and responsibilities of the individual employee. This procedure
ensures a direct correlation between the job which is performed and the training which
is provided to perform that job. Specific lesson plans must be developed by the
instructor to actually deliver the subject material to the student .•

A-1
OPA clearly requires vessel response plans include information on training and
response actions of vessel crews to ensure the safety of their vessel and to mitigate or
prevent an oil or haz:,rdous substance discharge. Therefore, the basic training
elements which should be addressed include both --

a. Prevention training to prevent a spill from occurring and the tank ship or tank
barge from endangering its cargo, and

b. Response training so that each crew member knows what his or her role is in
a marine emergency, and how to respond if the crew has failed in its effonts to
prevent a discharge of cargo onto the deck or into the surrounding water.

Prevention training is used to hone the normal operational skills of the mariner. It
ensures the safe operation of the vessel during transit and during cargo transfer
operations. Theoretically, if a comprehensive prevention training program is
implemented by the vessel owners and employees, it will substantially reduce the
number and severity of oil and hazardous substance spills. Unfortunately, many factors
combine to cause pollution incidents: these factors include but are not limited to minor
errors in judgment, equipment failure, crew fatigue, and severe weather conditions.
Response training will ensure the preparedness of the vessel's crew to respond if
prevention training has failed. A response plan training program which does not include
elements of both prevention and response is not a complete program.

The USCG has issued interim final rules in codified at 33 CFR part 155 which require
tank vessels and offshore tank barges to carry appropriate equipment and supplies for
the containment and removal of on-deck oil cargo spills. The amount of oil which the
vessel's crew must be able to contain Is dependent upon the size of the vessel. Inland
oil barges must have appropriate equipment and supplies ready for immediate use to
control and remove on-deck oil spills of at least one barrel. The Coast Guard
recognizes that the use of vessel crews in the control and clean-up of oil spills, once the
spill hits the surrounding water, is inefficient given the present state of technology and
endangers the vessel, crew, and the remainder of the cargo on board. Control and
clean-up of oil on the water is more appropriately handled by shore-based response
resources. Owners or operators of tank vessels or facilities must ensure the availability
of, through contract or other approved means, the resources to respond to an oil
discharge from a tank vessel or facility.

5-A provides suggested elements which could be incorporated into the training program
for vessel personnel. The material should not be considered as mandatory training nor
should it be considered all-inclusive. A training program which provided all of the
suggested training elements would certainly be very comprehensive. Vessel crews
receiving this training would have an excellent educational foundation to help them play
a highly proactive role in the plan holder's response organization. Plan holders must
decide the actual role of their vessel crews in their organizations and customize their
training programs accordingly.

5-1
5.A. Suggested training requirements for vessel response plans to comply with
33 CFR 155.1035, 155.1040, and 155.1055 {Vessels carrying oil as primary cargo:
unmanned tank barges).

• A response plan submitted to meet the requirements of 33 CFR 155.1035 (manned

vessels carrying oil as a primary cargo) must identify the training to be provided to
members of the vessel crew having responsibilities under the plan, the qualified
individual, and the spill management team.
• A response plan submitted to meet the requirements of 33 CFR 155.1040 (unmanned
tank barges carrying oil as a primary cargo) must identify the training to be provided to
the spill management team, the qualified individual, and other personnel in 33 CFR
155.1040 with specific responsibilities under the plan.

• The alternate qualified individual, designated to meet the requirements of 33 CFR

155.1026, should complete the same training program as the primary qualified
individual.
• The training program must differentiate between that training provided to vessel
personnel and that training provided to shore-based personnel.

• A vessel owner or operator may identify equivalent work experience which fulfills
specific training requirements.
• The training program for manned vessels and unmanned tankbarges carrying oil as a
primary cargo should include participation in periodic announced and unannounced
drills or exercises conducted in compliance of 33 CFR 155.1060. Participation in drills or
exercises should approximate the actual roles and responsibilities of individuals as
specified in the vessel response plan.
• Training should be conducted periodically to reinforce the required knowledge and to
ensure an adequate degree of preparedness by individuals with responsibilities under
the vessel response plan.
• Training may be delivered via classroom sessions, group discussions, videotapes,
self-study workbooks, resident training courses, on-the-job training, or other means as
deemed appropriate to ensure proper instruction.

• New employees should complete the training program prior to being assigned job
responsibilities which require participation in emergency response situations.

5.B. Suggested training reguirements for vessel response plans to comply with
33 CFR 155.1045 (Oil carried as secondary cargo).

• A response plan submitted to meet the requirements of33 CFR 155.1045 (vessels
carrying oil as a secondary cargo) must identify the training to be provided to all
personnel with responsibilities under the plan.
• The alternate qualified individual, designated to meet the requirements of 33 CFR
155.1026, should complete the same training program as the primary qualified
individual.

5-2
• A vessel owner or operator may identify equivalent work experience which fulfills
specific training requirements.

♦ The training program for vessels carrying oil as a secondary cargo should include
participation in periodic drills or exercises conducted in compliance of 33 CFR
155.1045(h). Participation in drills or exercises should approximate the actual roles and
responsibilities of individuals as specified In the vess_el response plan.

• Training should be conducted periodically to reinforce the required knowledge and to

ensure an adequate degree of preparedness by individuals with responsibilities under
the vessel response plan.

♦ Training may be delivered via classroom sessions, group discussions, videotapes,

self-study workbooks, resident training courses, on-the-job training, or other means as
deemed appropriate to ensure proper instruction.

♦ New employees should complete the training program prior to being assigned job
responsibilities which require participation in emergency response situations.

5-3
5.C. Suggested training elements for members of the vessel crew having
responsibilities under the plan:

1) Training elements for ship's officers:

Demonstrate knowledge ofthe following:

• The Captain of the Port (COTP) Zones in which the vessel will operate.

+ Notification procedures and requirements for vessel owners or operators, internal

response organizations; federal and state agencies; and contracted oil spill removal
organizations (OSROs) and the information required for those organizations.

• Primary and secondary (if applicable) communication systems used for the
notifications.

• Information on the cargoes carried by the vessel, including familiarity with the cargo
material safety data sheets, chemical characteristics, special handling procedures,
health and safety hazards, and spill and firefighting procedures.

• Procedures the craw may use to mitigate or prevent any discharge or a substantial
threat of a discharge of oil resulting from shipboard operational activities associated with
internal or external cargo transfers.

• Personnel actions to take in the event of a transfer system leak, tank overflow, or
suspected cargo tank or hull leak.

• Procedures the crew may use to mitigate or prevent any discharge or a substantial
threat of a discharge of oil in the event of --
0 Grounding or stranding;
° Collision;
0
Explosion or fire;
0
Hull failure;
0
Excessive list; or
Equipment failure.
0

• Ship salvage procedures, damage stability, and hull stress considerations when
performing shipboard mitigation measures.

• Familiarity with the vessel's --

0 General arrangement plan;

0
Midship section plan;
0
Lines plan;
Tank tables;
0

Load line assignment; and

0

Light ship characteristics.

0

• Procedures for both the internal and ship-to-ship transfers of cargo in an emergency.

+ Procedures and response resources necessary to carry out cargo transfers

involving -~

5-4
 ° Fendering equipment;
0
Transfer hoses and connection equipment;
0
Portable pumps and ancillary equipment;
0
Lightering and mooring masters; and
Vessel and barge brokers.
0

• Procedures and arrangements for emergency towing, including the rigging and
operation of any emergency towing equipment aboard the vessel.

• Crew's responsibilities, and procedures for use of shipboard equipment which may
be carried to mitigate an oil discharge.

• Crew's responsibilities, if any, for recordkeeping, sampling of spilled oil, and

applicable worker safety procedures.

• Crew's responsibilities, if any, to initiate a response and supervise shore.-based

response resources.

• Operational capabilities of the contracted OSROs to respond to the --

0 Average most probable discharge;

0
Maximum most probable discharge; and
0
Worst case discharge.

• Procedures, if applicable, for transferring responsibility for direction of response

activities from vessel personnel to the shore-based spill management team.

+ Training procedures as described in the vessel response plan for members of the
vessel's crew.
• Drill and exercise program to meet the requirements of 33 CFR 155.1060.

• The role of the vessel's crew in the post discharge review of the plan to evaluate and
validate its effectiveness.

♦ Available response resources identified in response plan.

• OSHA requirements for worker health and safety (29 CFR 1910.120).

• Name of the qualified individual and how to contact him or her.

• General responsib;lities and authority of the qualified individual as described in the

vessel response plan and company response organization.
• Area Contingency Plans for the areas in which the vessel operates.

• The National Contingency Plan.

• Roles and responsibilities of federal and state agencies in pollution response.

5-5
2) Training elements for ship's crew members with responsibilities under the plan.

Demonstrate knowledge o f -

• Information on the cargos carried by the vessel, including familiarity with the cargo
material safety data sheets, special handling procedures, health and safety hazards,
spill and fire fighting procedures.

+ Procedures, in accordance with designated job responsibilities, to mitigate or prevent

any discharge or a substantial threat of a discharge of oil resulting from shipboard
operational activities associated with internal or external cargo transfers.

+ Actions to take, in accordance with designated job responsibilities, in the event of a

transfer system leak, tank overflow, or suspected cargo tank or hull leak.

+ Procedures, in accordance with designated job responsibilities, to mitigate or prevent

any discharge or a substantial threat of a discharge of oil in the event of --

0 Grounding or stranding;
° Collision;
0
Explosion or fire;
0
Hull failure;
0
Excessive list; or
Equipment failure.
0

+ Procedures, in accordance with designated job responsibilities, to perform ship

salvage while performing shipboard mitigation measures.

+ Procedures, in accordance with designated job responsibilities, for both the internal
and ship-to-ship transfers of cargo in an emergency.

+ Individual duties, In accordance with designated job responsibilities, to carry out

cargo transfers involving --

0 Fendering equipment;
0
Transfer hoses and connection equipment; and
0
Portable pumps and ancillary equipment.

+ Individual duties, in accordance with designated job responsibil'lties, to conduct

emergency towing, including the rigging and operation of any emergency towing
equipment aboard the vessel.

+ Individual duties, in accordance with designated job responsibilities, for use of

shipboard equipment which may be carried to mitigate an oil discharge.

+ OSHA requirements for worker health and safety (29 CFR 1910.120).

+ Notification procedures and requirements for vessel owners or operators; internal

response organizations; federal and state agencies; and contracted OSROs and the
'information required for those organizations.

+ Primary and secondary (if applicable) communication systems used for the
notifications.

5-6
5.D Suggested training elements for other personnel as described In 33 CFR
155.1040 (unmanned tank barges) with specific responsibilities under the plan:

Demonstrate knowledge o f -

• Notification procedures in the event of a discharge of oil or substantial threat of a

discharge of oil for the towing vessel, for the vessel owner or operator, or for the
qualified individual.

+ Notification procedures to contact the vessel's owner or operator, qualified individual,

National Response Center, and state agencies, and the information required to be
provided in the initial and any follow-up notifications.

+ Information on the cargoes carried by the barge including familiarity with the cargo
material safety data sheets, special handling procedures, health and safety hazards,
and spill and firefighting procedures.

+ Procedures, in accordance with designated job responsibilities, to mitigate or prevent

any discharge or a substantial threat of a discharge of oil resulting from barge
operational activities '3.nd casualties.

+ Actions to take, in accordance with designated job responsibilities, in the event of a

transfer system leak, tank overflow, or suspected cargo tank or hull leak.

+ Procedures, in accordance with designated job responsibilities, to mitigate or prevent

any discharge or a substantial threat of a discharge of oil in the event of --
• Grounding or stranding;
° Collision;
• Explosion or fire;
• Hull failure: or
0
Excessive list.

+ Damage stability and hull stress considerations when performing shipboard mitigation
measures in accordance with designated job responsibilities.

+ Procedures, in accordance with designated job responsibilities, for both the internal
and barge-to-barge transfers of cargo in an emergency.

+ Procedures and arrangements to conduct emergency towing, including the rigging

and operation of any emergency towing equipment aboard the barge.
+ Procedures for use of barge equipment which may be carried to mitigate an oil
discharge.
+ The responsibilities, if any, of the towing vessel crew, or facility or fleeting area
personnel to initiate a response and supervise shore-based response resources.

+ OSHA requirements for worker health and safety (29 CFR 1910.120).
+ Name of the qualified individual and how to contact him or her.

• General responsibilities and authority of the qualified individual as described in the

vessel response plan and company response organization.

5-7
• Primary and secondary (if applicable) communication system used for the
notifications.

• Organizational structure that will be used to manage the response actions,

including --

• Command and control;

• Safety; and
• Spill response operations.

+ Available response resources.

+ The Captain of the Port Zones (COTP) in which the tank barges covered by the
response plan will operate.

+ Procedures for the post discharge review of the plan to evaluate and validate its
effectiveness.•

5-8
Facility owners and operators are required to explain in detail how to implement the
facility's emergency response plan by describing response actions to be carried out
under the plan to ensure the safety of the facility and to mitigate or prevent discharges.
They must identify the response resources for worst case discharges and identify facility
personnel responsible for performing specific procedures to mitigate or prevent a
discharge or potential discharge.

Prevention Training Requirements: EPA's current oil pollution prevention

regulations (40 CFR part 112), also known as the Spill Prevention, Control and
Countermeasures (SPCC) rule, states that training exercises should be conducted at
least yearly for all personnel. Training should be given to new employees within one
week of beginning work, and spill prevention briefings should be scheduled and
conducted for the facility's operating personnel at least once a year. Prevention training
must include, but is not limited to, the following subjects:

)::( Operations and maintenance of equipment

" Applicable pollution control laws;
" Contents of facility's SPCC plan; and
:a: General facility operations.

EPA has proposed, but not finalized, several additional prevention training requirements
as follows: (1) the training previously described is proposed as a requirement, and (2)
personnel involved in oil-handling activities at facilities with certain operations are
proposed to receive at least 8 hours of training initially and at least 4 hours of refresher
training per year.

Response Training Requirements: EPA's final facility response plan rule

requires the owner or operator of a substantial harm facility to have a training program
for those personnel involved in oil spill response activities [59 FR 34097; July 1, 1994].
The rule recommends that the training program be based on this reference manual, as
applicable to facility operations, or a facility can develop its own response training
program subject to approval by the appropriate EPA Regional Administrator.

MMS regulations require that personnel who respond to spills through deployment and
operation of oil spill response equipment be provided with hands-on training classes at
least annually [30 CFR 250.43]. In addition, future MMS regulations may require a
description of the training to be carried out under the plan.

Coast Guard regulations require the owner or operator of marine-transportation-related

(MTR) facilities to identify the training to be provided to each individual with
responsibilities in the response plan.

If the individual will always fill the same function in the facility response plan, training
requirements will be narrowed in scope. If a company desires greater flexibility in use of
Its personnel and redundancy in available knowledge in case key personnel are
unavailable, it may_ choose to add to the curricu_la presented_to facility op~rators. Th_e.
following 6-A provides suggested elements which could be incorporated into the training
program for facility personnel. The material should not be considered as mandatory
training nor should it be considered all-inclusive. A training program which provided all

6-1
of the suggested training elements would certainly be very comprehensive. Facility
personnel receiving t~is training would have an excellent educational foundation to help
them play a highly proactive role in the plan holder's response organization. Plan
holders must decide the actual role of their facility personnel in their organizations and
customize their training programs accordingly.

6.A. Suggested training elements for Facility Personnel:

Demonstrate knowledge o f -

• The Captain of the Port (COTP) Zone or EPA Region in which the facility is located.

• Notification procedures and requirements for facility owners or operators, internal

response organizations, federal and state agencies; and contracted oil spill response
organizations (OSROs), and the information required for those organizations.

• Communication system used for the notifications.

• Information on the products stored, used, or transferred by the facility, including

familiarity with the material safety data sheets, special handling procedures, health and
safety hazards, and spill and firefighting procedures.

• Facility personnel responsibilities, and procedures for use of facility equipment which
may be available to mitigate or prevent an oil discharge.

• Specific procedures to shut down affected operations.

• Procedures to follow in the event of discharge, potential discharge, or emergency
in\iolving the following equipment or scenarios:
0
Tank overfill;
0
Tank rupture;
0
Piping or pipeline rupture;
Piping or pipeline leak, both under pressure and
0

not under pressure, if applicable;

Explosion or fire;
0

Equipment failure; and

0

° Failure of secondary containment system.

• The operational capabilities of the contracted OSROs to respond to the -- .

0
Average most probable discharge (small discharge);
0
Maximum most probable discharge (medium discharge); and
0
Worst case discharge.

• Name of the qualified individual and how to contact him or her.

• General responsibilities and authorities of the qualified individual· as described in the

facility response plan and company response organization.

• The organizational structure that will be used to manage the response actions,
including --

0 Command and control;

6-2
 • Public information;
• Safety;
• Liaison with government agencies;
• Spill response operations;
• Planning;
• Logistics support; and
• Finance.

• The drill and exercise program to meet the federal requirements.

• The Area Contingency Plan for the area in which the facility is located.

• The National Contingency Plan.

• Roles and responsibilities of federal and state agencies in pollution response.

• OSHA requirements for worker heallh and safety (29 CFR 1910.120) ..

6-3
Federal regulations require owners and operators of tank vessels and facilities to
ensure, through contracts or other approved means, sufficient private resources to
remove specific volumes of oil. A USCG-classified oil spill removal organization (OSRO)
may be identified in the response plan instead of providing a detailed list of equipment
and personnel resources. USCG regulations require marine transportation-related
(MTR) facility or vessel owners or operators to ensure that an OSRO identified in the
facility or vessel response plan maintains records to document training of the OSRO's
personnel. These training records must be available for inspection by the vessel or
facility management personnel, qualified individual, or federal inspectors. OSRO
personnel must also be trained to meet OSHA regulations in 29 CFR 1910.120.

OSROs may provide the contracted resources for oil and hazardous substance
response and clean-up. In some response plans, the OSRO may be contracted to
provide the spill management team, all of the response equipment, and the operational
personnel needed to deploy, operate and maintain the equipment. In other response
plans, the OSRO is merely contracted to provide the bulk of the response equipment
on- scene. The equipment may then be deployed and operated by responsible party
personnel. As an alternative to contracting with an OSRO, facilities are allowed to own,
operate, or have under their direct control the personnel and equipment necessary for
timely response. Active membership in a local or regional OSRO commonly referred to
as a cooperative is another means of compliance.
OSRO personnel are involved in the direct operational functions of oil spill clean-up.
Personnel should be trained in hazard recognition, worker health and safety issues, oil
containment, oil recovery methods and devices, equipment operation, shoreline clean­
up, and waste storage and disposal considerations. Specialized training may involve
such topics as the use of dispersants, slick trajectory forecasting, in-situ burning,
bioremediation, or ship salvage. Training methods may include a variety of techniques
but an emphasis should .be placed on hands-on equipment deployment and operations.

Because of the large number of OSRO personnel involved in major pollution incidents
and the fact that many of these people are hired as temporary employees, it is expected
that only senior supervisory personnel will receive broad-based training or experience in
oil spill removal technology. The majority of the OSRO's personnel may, as appropriate,
receive training to enable them to safely and efficiently perform the specific duties
assigned to them within the organization. For example, someone who will only perform
beach clean-up operations should not be expected to know how to operate, repair, or
maintain a weir skimmer.
The Level 1 and Level 2 courses for oil spill response described in Appendix A to this
document provide suggested training elements in the form of tasks and sub-tasks.
Some of these elements could be incorporated into the training program for personnel
employed by an OSRO. The material should not be considered as mandatory training
nor should it be considered all-inclusive. A training program which provided all of the
suggested training elements would certainly be very comprehensive. Personnel
employed by an OSRO receiving this training would have an excellent educational
foundation to help them play a highly proactive role in all aspects of the organization's
clean-up efforts. Each OSRO must decide the actual role of its personnel in their own
organization and customize its company's training program accordingly.•

7-1
Vessel and facility owners or operators must ensure that all private response personnel,
volunteers, or casual laborers, which they employ are trained to meet the OSHA
standards for emergency response operations promulgated in 29 CFR 1910.120. These
requirements, commonly referred to as the HAZWOPER regulations, were established
to ensure the health and safety of personnel employed in hazardous substance
response and cleanup operations. OSHA has defined hazardous substances as any
substance "exposure to which results or may result in adverse affects on health or
safety of employees."[29 CFR 1919.120] This includes substances defined under
101(14) of the Comp•ehensive Environmental Response, Compensation and Liability
Act (CERCLA), as amended, those listed by the Department of Transporation (DOT) as
designated hazardous substances under 49 CFR Part 172.101, hazardous wastes, end
biological agents. DOT regulations designate petroleum crude oil, petroleum distillates,
end petroleum oil (DOT hazard class 3, flammable liquids) as hazardous substances.

Responding to oil spills is typically different from other hazardous material emergencies
in that worker safety issues are often a more significent concern than is protection from
toxic chemicals. This focus on worker safety does not mean that we are not concerned
with the potential affects of toxic chemicals to the worker. The danger to the responder,
however, from a large variety of oils is more probable to occur from common hazards
such as slipping or tripping while trying to cleen up a highly slippery substance.
Relatively minor health problems such as dermatitis can be prevented by wearing
proper gloves, boots and protective clothing. However, there are also oils, such as high
sulfur crude oils or oils with a high benzene content, which may cause life threatening
health concerns. Proper personal protective equipment, including respiratory
protection, must be worn by the responder when responding to incidents involving
these oils or other hazardous substances with a respiratory hazard.

In general, personnel must be provided with adequate training to do their jobs safely.
This includes the fundamentals of site safety which apply generally to personnel working
at hazardous waste sites. It further includes safety conscious operational training for the
particular job (e.g., methods of deploying boom safely by boat). An ongoing training
program to reinforce and build upon previous training is also required (i.e., annual
refresher training). It is not necessary to conduct all training in one block of time, or
restrict it to a single training event.

OSHA's Hazardous Waste Operations Standard (29 CFR 1910.120) sets basic
requirements for training of personnel. These requirements are dependent on the
operations (e.g., general site operations, emergency response operations, and post­
emergency response operations); on the individual's duties (e.g., first responders,
general site workers, supervisors, special short term operations, technicians, etc.); and
on the degree of exposure (e.g., minimal exposure, unknown exposures, etc.). It Is
important to recognize that these requirements may change as the operations progress
from emergency phase to post-emergency phase. At the same time, the degree of
exposure risk is also changing with time. For example, as high vapor pressure products
which might pose an inhalation hazard evaporate from the weathering oil, or as the
hazards become better characterized the amount of potential danger is also altered.
6-A and 6-B provide more specific information on OSHA requirements and training
qualifications.

8-1
8.A. Outline of General Requirements for Emergency Phase and
Post-emergency Response Operations.

1.-General requirements for emergency phase response operations (e.g., spill control
measures conducted prior to recovery). Specific competencies are listed in 29 CFR
1910.120(q)(6).

a. LEVEL 1--First Responder (awareness).

This level is characterized as personnel that might discover a release and

who are simply expected to report the incident.

(1) Sufficient training OR proven experience in specific competencies; AND

(2) Annual refresher training.

b. LEVEL 2--First Responder (operations).

This level is characterized by responding to a release in a DEFENSIVE

manner and generally without being exposed to risk (e.g., no attempts to
stop leaks).

(1) Level 1 competency;

(2) Eight hours initial training OR proven experience in specific

competencies; AND

(3) Annual refresher training.

c. LEVEL 3--Hazourdous Material (HAZMAT) Technician.

This level is characterized by responding AGGRESSIVELY to stop a

release (e.g., expecting some risk of exposure).

{1) Twenty-four hours of Level 2 training;

(2) Proven experience in specific competencies; and

(3) Annual refresher training.

d. LEVEL 4-- HAZMAT Specialist.

This level is characterized by responding with and in support of

technicians but haveing specialty knowledge and competence.

(1) Twenty-four hours of Level 3 training;

(2) Proven experience in specific competencies; AND

(3) Annual refresher training.

e. LEVEL 5--On-Scene Incident Commander.

8-2
 This level is for personnel that may be called upon to assume supervisory
(incident command) responsibilities on-scene.

(1) Twenty-four hours of Level 2 training;

(2) Proven experience in specific competencies; AND

(3) Annual refresher training.

2. General requirements for post-emergency response operations are described in 29

CFR 1910.120(q)(11) which simply refers to the training requirements for general
hazardous waste operations at 29 CFR 1910.120(e). The regulations require initial
training; management and supervisory training; and annual refresher training.

a. The general subjects to be covered by this training

include --

(1) Key personnel responsible for site safety and

health;

(2) Hazards present on site;

(3) Use of personal protective equipment;

(4) Safe work practices;

(5) Safe use of engineering controls and other

equipment on site;

(6) Medical surveillance requirements and recognition of signs and

symptoms of overexposure; and

(7) The contents of site specific safety and health plans (e.g.,
decontamination procedures, emergency procedures, confined space
entry procedures, and spill containment program in particular).

b. Initial training. There are three categories of initial training depending on

the degree of exposure and the amount of time expected to be spent on site.

(1) General site workers. General site workers (e.g., general laborers or
equipment operators) must have the following:

> 40 hours off-site training.

> 24 hours supervised field experience.
> 8 hours annual refresher training.

(2) Minimal hazard workers. Routine site workers who work in areas
that have been monitored and fully characterized such that exposures are
within permissible limits (and published limits or other hazards),

OR ............. .

8-3
 non-routine site employees who are on site only occasionally for a specific
limited task, and who are unlikely to be exposed over permissible
exposure limits (or published limits) may be trained as follows:

> 24 hours off-site training.

> 8 hours supervised field experience.
> 8 hours annual refresher training.

c. Management and supervisory training. On-site management and

supervisors directly responsible for, or who supervise employees engaged in,
hazardous waste operations shall have the same initial training as the personnel
they supervise. They then must receive at least another 8 hours of training in
hazardous waste operations management as follows:

> 40 hours off-site training, which may be reduced to 24 hrs if all

employees supervised are permitted to be trained at this level;

> 24 hours supervised field experience, which may be reduced to 8 hrs if

all employees supervised are permitted to be trained at this level; and

> 8 hours annual refresher training; PLUS

> 8 hours of hazardous waste operation management training,

d. Refresher training. Refresher training may include incident debriefs, or

response drills and exercises. OSHA officials have indicated that those workers
involved in the post-emergency phase of a spill response whose job duties and
responsibilities have a low magnitude of risk may be allowed to have fewer than 24
hours of training. Specifically, OSHA has issued an instruction stating that a
minimum of 4 hours of training is appropriate in most situations involving post­
emergency clean-up workers (See "Inspection Guidelines for Post-Emergency
Operations Under 29 CFR 1910.120," OSHA Instruction CPL 2-2.41, Nov. 5, 1990).
Under OSHA instruction, OSHA Regional Response :ream.representa!iv.e is__ _ - • •·
responsible for making determinations of when fewer than 24 hours of training is
required. ·

e. Certain oil spill response personnel. Guidelines have been published by

OSHA with regards to the training requirements for post-emergency response to
oil spills. OSHA recognizes that reduced training for certain categories of
personnel involved in oil spill operations may be necessary, and may not constitute
a serious violation of the regulations (i.e., a "de minimis" violation). In general, 4
hours of training is expected to be adequate to meet the "de minimis" criteria. This
requirement may change based on the specific state requirements, response
circumstances, or both. Other requirements must also be met (e.g., adequate
characterization of minimal hazards, and adequate supervision by fully trained
personnel)·•

8-4
6.B. Decision Guide for On-site Training Requirements.

I
______v____ _
Supervisor in ~he yes Must be fully qualified in
operational chain --> accordance with A.l.e. (Inci­
of command? dent Commander) and/or A.2.b
(Management and Supervisory).
EXAMPLE: Operations control
no team leaders

______v_____
May be expected to yes Awareness level training
perform emergency --> per A.l.a. and
phase operations? annual refresher training.
EXAMPLE: Local police and fire
smallboat stations
no
I(continue)
--~---~v_________
Performs advanced emergency
Go to next response operations such as:
page [POST­ no containment from safe distance,
(1)<- EMERGENCY <-- entering hot zones, or
OPERATIONS] supporting hot zone entrants.

I yes
_________v_________
V
Go to next Further training in accordance
page [POST- no with -­
(l)<- EMERGENCY <-.­ A.l.b: operations level
OPERATIONS] A.l.c: technician level
A.l.d: specialist level
I
v__________
Performs unexpected, yes Site safety and ha~ard
special limited risk --> awareness briefing per A.l.f.
operations support­ EXAMPLES: Crane operators
ing emergency phase Longshoremen
response operations? Buoy tender for VOSS

nol NOTE: Ops at the same site may

V include emergency phase and post­
emergency phase work. IN GENERAL,
ops intended to control a
continuing release should be
treated as emergency phase, while
ops intended to recover product,
V should be treated as post­
( 2) emergency. Operations at a
remedial site should be treated as
routineand post-emergency phase
operations.

8-5
(continued):
( 2) (1)
I I
._____v_____ ~ - - - - - - - - - v_ _ _ _ _ _ _ __
POST-EMERGENCY Emergency response personnel that
OPERATIONS also perform post-emergency ops may
<-- require both A.l & A.2. or hybrid
training that is consistent with
both requirements.

____v______ .
Performs minimal yes 4 hours of training in accordance
exposure risk ops --> with A.2.c. Must be supervised
for post-emergency by a qualified supervisor.
response to oil EXAMPLE: (a) Temporary hire for
spills ONLY? a large oil spill
(b) Bird rehab volunteer
May be combined with A.l.a
training.

--------~_v________
I
For prolonged operations
continue training to meet the
minimal risk requirements.
______v_______
Performs minimal yes 24-hour training in accordance
exposure risk ops --> with A.2.a.(2)
for post-e111ergency EXAMPLE: Ground water monitors
response to HAZMAT Geophysical surveyist
incidents?
May be combined with A.1.
training.

______v_______
Regular response pers yes 40-hour training in accordance
and/or site workers --> with A.2.a.(1).
for post-emergency EXAMPLE:
operations at HAZMAT Cleanup contractor personnel
oil spills? Gov't pollution response pers
May be combined with A.l.
training.

_____v__________
For special cases contact
the site safety and health
officer for a specific
determination.

8-6
The USCG has worked closely with IMO and the Canadian Coast Guard in the
development of course curricula for oil spill response. In August 1993, the USCG
distributed two sets of draft voluntary training guidelines for oil pollution response. The
guidelines were modifications of training material which IMO will be using to train
members of the international community. The guidelines provided industry with an
outline of recommended subject areas in which personnel involved in oil spill response
and clean-up could be trained in. They were presented in the form of a job task analysis
for two separate training courses. One course was designed for non-supervisory
operational personnel, while the other course was designed for supervisory operational
personnel. The guidelines were intended to assist owners and operators of vessels,
marine transportation-related (MTR) facilities, and deepwater ports in developing or
choosing training programs for oil spill response for their operational personnel.

A job task analysis (JTA) can be considered a job performance outline. Job
requirements are broken into specific performance elements referred to as tasks and
sub-tasks. For instance, task number 13, "Transfer oily wastes," is subdivided into three
sub-tasks:
" 13.1 Categorize and quantify collected materials;

" 13.2 Select pump, conveyors, and other equipment; and

>< 13.3 Safely operate transfer equipment.

The knowledge which must be communicated to teach each sub-task and the resulting
skills which the student must demonstrate after training is completed are also provided.
Because of the different job responsibilities of each employee and their intended role in
the vessel or facility plan, the JTA should be customized by the trainer. Trainers may
use the guidelines as a menu of subject areas from which to select relevant topics
depending on the duties and responsibilities of the individual employee. This procedure
ensures a direct correlation between the job which is performed and the training which
is provided to perform that job. Specific lesson plans must be developed by the
instructor to actually deliver the subject material to the student.■

A-1
 LEVEL 1 COURSE FOR OIL SPILL RESPONSE
----------------------------------------------------------------------------------------------------------]
[----------------------------------------------------------------------------------------------------------
TASK 1: ASSESS SPILL AND RESPONSE OPERATION.

[ _________ sui-tASK ________ I__________ KNOWLEDGE___________ I___________________ sK111 ________________________ ]

1.1 Assist tn initial · Type and volume of spill Recognize oil type, behavior and properties.
assessment of spill source sources: e.g., tankers, Detennine slick trajectory.
and potential impacts. barges, pipelines, etc. Predict fate and consequences.
· General description of
causes of spills: e.g.,
collisions; breakups;
groundings; mechanical,
human, and environmental
factors.
· S~ill volume
· Oi.1 types: e.g., crude,
bunker fuels, gasoline,
diesel, and non-petroleum.
• Proximity to shoreline.
· Potential impacts on
resources and amenities.
· Effects on flora and
fauna.
· Persistence of oil on
shorelines.
1.2 Hazard recognition. · Awareness of physical · Identify hazards associated with spilled oil
chemistry of oil and or product.
product.
· Awareness of oil
toxicology.
· Material safety data
sheet.
• Fire and explosion
hazards.
· Potential hazards to
human health.

A· I
1.3 Assess water and · Influence of water and Recognize limitations of response equipment.
weather conditions. weather conditions on oil Use data to predict speed and direction of
properties and slick slick transport, fate, and behavior.
behavior.
• Boating safety
· Implications of water
conditions and wind speed
on response operations.
1.4 Identify and stop Causes of spills. · Assist in selecting control measures.
pollution source, if Options tor.top oil flow.
continuing.
1.5 Identify response · Description of clean-up • Prioritize sensitivity, identify protection
priorities and select phases and hardware zones.
countermeasures. alternatives. · Review merits and disadvantages of spill
· Response steps: stopping, control alternatives.
monitoring, containment, · Assist in determining best response
deflection, removal, methodology.
storage, disposal.
· Planning and logistics:
timing, resource
utilization, safety,
incident command structure.
Protection priorities.
Spill control o~tions.
Deployment requirements.
1.6 Reassess cleanu~ Operational efficiency of • Apply changing data to the selection of
requirements on ongoing equipment and alternative cleanup gear and to the choice of response
basis. resources. effort locations to optimize operations
· Changing oil properties
and environmental factors.
New information.
1.7 Perform administrative Accounting of personnel, · Reep records and conduct assigned tasks.
duties. expenditures, and
equipment.
· Recording of impacts,
response actions and
locations.
· Recording of sampling,
legal statements and/or
discussions.
• Organization of personnel
and task assignments,

A-2
 -
1.8 Take sam~les from · Legal sampling methods. • Take samples from water and source admissible
source and slicks. · Storage and chain of as court evidence.
custody requirements. · Process samples so that the accuracy of test
results is ensured.

[----------------------------------------------------------------------------------------------------------
TASK 2: ASSESS THE EFFECTS OF OIL MOVEMENT AND WEATHERING ON RESPONSE OPERATIONS
----------------------------------------------------------------------------------------------------------
l
[ _________ SUB·TASK ---- ·___ I__________ KNOWLEDGE___________ I___________________ SKILL________________________ ]
2.1 Identify oil types · Types of oil: crude, Demonstrate general knowledge of oil types,
and their properties. gasoline, diesel, bunker, grades, physical, and chemical properties.
non-petroleum.
· Properties: e.g.,
specific gravity,
viscosity, pour point,
flash point, and
solubility.

2.2 Forecast slick · Effect of oil properties, · Estimate spill volume and direction of
transport and spreading. sea state, and water and movement.
weather conditions on
spread rate and transport.
· Spill volume as a
function of slick area,
thickness and appearance.
· Trajectory modeling.
· Interaction with ice
(where appropriate).
2.3 Identify the effect of · Weathering processes: · Assess effect of environmental conditions on
weathering on response e.$., evaporation, oil and product.
operations, hazards and oxidation, dissolution,
impacts. sinking, emulsification,
biodegradation, and
sedimentation.
• Effect of weather, sea
state and oil type on
weathering.
· Fire hazards
· Implications to
countermeasures operations.

A-3
 ----------------------------------------------------------------------------------------------------------]
[----------------------------------------------------------------------------------------------------------
TASK 3: DETERMINE AND IMPLEMENT SAFETY PROCEDURES
--------- SUE-TASK --------r----------KNoWLEDGE___________I___________________ SKILL________________________ l
[
-------------------------- ------------------------------ ------------------------------------------------
3.1 Ensure provision of · Safety risks of petroleum Attend or facilitate attendance to injured.
first aid and access to and non-petroleum oils: Prevent self·injury.
medical facilities. e.g., fire, and explosion.
· Effects of exposure:
e.g., inhalation, dermal,
and ingestion.
· Safety risks and handling
guidance of mechanical, and
electrical equipment.
· Safe boating practices
and guidelines.
· First aid.
· Marine safety data
sheets.
3,2 Implement safety · Safety checklist for • Recognize need for and properly use personal
procedures. response operations. protective clothing and equipment.
· Safe work practices: • Use safety equipment.
e.g., clean-up equipment, · Prevent unsafe worker performance,
petroleum products, and
site.
· Personal protective
clothin~ and equipment.
• Capability of personnel:
e.g., length of shift, and
level of training,
· Decontamination
procedures.
3.3 Take appropriate · Site security and access · Ensure security of work site.
site security measures. procedures,

A-4
[----------------------------------------------------------------------------------------------------------
__________________________________________________________________________________________________________
TASK 4: SELECT AND OPERATE MEANS OF TRANSPORT ]
---------SUB•TASK --------1----------KNOWLEDGE-----------1-------------------SKILL________________________l
[__________________________ ------------------------------ ------------------------------------------------
4.1 Assess transport needs. · Ongoing transportation needs · Determine transportation requirements.
of ALL cleanup phases.
4.2 Choose appropriate • Capabilities of available Select appropriate means of trans~ort.
response vessels or mobile small boats. Operate vessels safety and effectively.
response equipmen'.:. · Safe deployment and
operation of boats.
· Navigation: aids, areas
of operation.
· Effects of environmental
factors an operation of
vessels or mobile response
equipment.

---------------------------------------------------------------------------------------------------------- ]
[__________________________________________________________________________________________________________
TASK 5: ESTABLISH AND MAINTAIN COMMUNICATIONS

[_________ su»-TAsK -_______!__________ KNOWLEDGE __________ r_-______-____ ---_ --sKit~----_------::---:~:~~:~:]

5.1 Use • Response information and · Communicate effectively to facilitate

communications equipment. communication needs. response.
· Portable UHF/VHF radios
cellular telephones.
· Capabilities and limits
of available systems.
· Radio operations
protocols and use.

A· 5
[----------------------------------------------------------------------------------------------------------
TAS~ 6: CONTAIN SPILLED OIL
----------------------------------------------------------------------------------------------------------
]
---------su»:rAsi---------r----------;;owtEDGi-----------r-------------------;iiii________________________ l
[
-------------------------- ------------------------------ ------------------------------------------------
6.1 Select appropriate · Main uses of boom: · Select boom upon consideration of location,
boom. e.g., containment, oil type, and environmental factors.
deflection, and protection.
• Boom components and
structure.
• Types of commercial and
improvised booms: skirt,
fence, sorbent, others.
• Selection criteria for
offshore, near-shore use.
• Boom failure mechanisms
and solutions: entrainment,
drainage, splashover, boom
submergence and planning.
· Response time.
· Safety warning for spills
of gasoline or other
explosive products.
· ~ i te specific
considerations: wetland
damage at low tide, mooring
to existing structure,,
location of nearby
amenities or sensitive
areas.
6.2 Deploy b~oms. • Deployment equipment and • Deploy and moor booms to safely and
safety requirements. effectively concentrate oil for recovery,
Slick behavior. to protect resources, and to deflect slicks.
· Selecting booms·for
response, which would
depend upon sea state and
application.
• Typical deployment
configurations for
contairunent and deflection.
• Determination of boom
angle.

A·6
 • Vessel or deployment
vehicle selection.
• Preparation and
inspection.
• Towing: e.g., tow line
length attachment to tow
post.
· Mooring: e.g., anchor
size and number, length of
mooring line, and mooring
arrangement.
· Safety checklist for
operations.
6.3 Assess water and · Influence of water, wind, · Monitor and assess boom performance.
weather conditions. and currents on ability to • Redeploy booms as tides, currents, and oil
contain oil. volumes dictate.
· Safety implications.
6 .4 Retrieve booms • Recovery, cleaning, · Safely recover booms without damage, clean and
disassembly, and storage of store.
equipment.
----------------------------------------------------------------------------------------------------------]
[----------------------------------------------------------------------------------------------------------
TASK 7: OPERATE OIL RECOVERY EQUIPMENT

--------------------------r-----------------------------·r--·---------------------------------------------1
[_________ SUB·TASK ________ ----------~OWLED:E______________________________ SKILL-----------------------
7.1 Select appropriate • Skimming principles and · Select appropriate skimmer for intended
skimmer, types: i.e.,weir, application.
oleophilic,suction and
other.
· Common nomenclature of
skimmers and hardware.
7.2 Operate skimmers. • Basic engine types; fuel • Start, operate and shut down skimmer.
needs; control, lube and · Monitor for optimum performance and reselect
hydraulic srstems; fittings skimmer, if needed.
and connect1ons. • Troubleshoot minor problems.
· Operational difficulties:
e.g., breakdown and debris.
· Safety considerations.

A· 7
7.3 Equipment maintenance. • Cleaning, disassembly, Remove oil and debris, repair broken or worn
and storage. parts and store skimmer in ready to use
· Check and repair condition.
equipment.

[ TASK 8: REMOVE- OIL USING SORRENTS - - - - - ]

- - -- ------------------- -------------------------------------------------------------------------------
[_________ su»•TAsK ________ I__________ KNOWLEDGE___________ I___________________ sKILL _______________________}
8.1 Select sorbents. • Characteristics. · Select effective sorbents.
· Sorbent types and
effectiveness.
8.2 Use sorbents. · Application of effective · Apply, recover, and reuse sorbents
sorbent to spill conditions effectively.
(e.g., water or land)

[----------------------------------------------------------------------------------------------------------]
TASK 9; ASSIST IN APPLICATION OF RIOREKEDIATION PROCESS/SYSTEMS
----------------------------------------------------------------------------------------------------------
[:::::::::su»•TASK :::::_::r::::::::::KNOWLEDG~ ::::::::::1:::::::::::::::::::SKILL::::::::::::::_::_______)
9.1 Identify appropriate · Principle of ~recess, • Determine applicability of bioremediation to
conditions for conducting agents and application oil clean·up.
bioremediation. methods.
• Limitations and
advanta$es: .
· Restrictions governing
application and pre·
approval.

9.2 Assist in applying • Application methods · Assist in implementation.

bioremediation techniques. strategies and safety
concerns.

A-8
[ TASK 10: ASSIST IN APPLICATION OF-CHEMICAL DISPERSION SYSTEMS ---------------------------------11
---------------------------------------------------------------------------------------------------------J
--------------------------1------------------------------r-----------------------------------------------
[--------~~~~~~~~~--------- ----------~~~=~~:~----------- -------------------~~~::_______________________]
10. l Identify aJ?propriate · Action of dis'persant: · Determine whether or not dispersants are
conditions for dispersing e.g., surface tension, potentially applicable,
oil. emulsion formation, and
water column distribution.
· Effective application
conditions: e.g., oil type,
slick thickness, mixing
energy, and water
temJ?e:atu:e,
· L1.m1tat1on: e.g.,
ineffective(calm)
conditions, interference
with mechanical
countermeasures, and
overall effectiveness.
· Toxicity of chemical and
dispersed hydrocarbon
in water column.
• Advantages: i.e., oil
degradation rate, tar
residue formation,
hydrocarbon flammability,
and reduction in impacts to
shoreline and water fowl.
· Restrictions governing
application and pre·
approval.
10.2 Assist in chemical • Choice and effectiveness Assist in the safe use and monitoring
dispersion of oil. of a$ents, and dosage, dispersants.
application equipment and
methods.
· Safety considerations.

A·9
 ------------------------------------------------------ --------------------------------------------------1 I
[ TASK II: ASSIST IN CONDUCTING IN-SITU BURNING
---------------------------------------------------------------------------------------------------------J
[ _________ SUB-TASK ________ I__________ ~?~LEDGE__- ________ I___________________ SKILL_______________ - _______ ]

11.l Identify appropriate · Conditions conducive to Determine whether or not combustion will be
conditions for conducting combustion: e.g., slick successful and appropriate.
in-situ buring. thickness, oil type and
weathering, weather and sea
state and pro~er timing.
· Safety considerations:
e.g., highly trained
personnel, air quality,
fire hazard to nearby
facilities, ecological and
wildlife, and nearby
populations.
· Advantages: e.g., removal
rates, shoreline impacts,
storage, and disposal.
· Restrictions governing
use and pre-approval.

11.2 Assist in conducting · Principles of process or · Assess impact of combustion by-products to

in-situ burning. operation. public and worker safety.
· Equipment: e.g., fire • Assist in their safe use and monitoring.
containment boom, ignition
system, and residue clean­
up.
• Equipment requirements
and constraints.

[
TASK 12: CLEANUP SHORELINE - - - - -- 11
---------------------------------------------------------------------------------------------------------J
[ _________ SUB-TASK_________ !__________
KNOWLEDGE _- ________ I____________:_____ :~i1tL ----------------------J l

12.1 Assist in selection • Methods and required • Assess factors dictating shoreline response.
of approprl•t• toohniqY••· tqYipment; @,g,, nitural1 · Aa&i&t in selection of appropriate cleanup
mechanical, manual, and methods.
flushing.

A•IO
 Clean-up alternatives vs.
environmental sensitivities.
· Habitat disturbance from
clean -ue ope.rations.
· Changing conditions:
e.g., seasonal, diurnal
and tidal.
· Practical considerations:
e.g., access and disposal.
12.2 Clean up shoreline. · Safety considerations: · Safely conduct and organize shoreline
tides, equipment, animals, cleanup activities.
o Careful and efficient Minimize disturbance to shoreline.
execution of response. · Minimize amount of non-oily wastes-collected.

[---------------------------------------------------------------------------------------------------------
TASK 13: TRANSFER OIL WATERS
---------------------------------------------------------------------------------------------------------J
l I

[
--------------------------r------------------------------1-----------------------------------------------
SUB·TASK KNOWLEDGE SKILL
-------------------------- ------------------------------ -----------------------------------------------
l
13.1 Categorize and · Oily liquids and solids · Determine factors affecting operation of
quantify collected generated during clean-up. transfer equipment.
materials.
13.2 Select pumps, · Transfer options and · Determine suitable means to transfer
conveyors and other mechanical principles: materials.
equipment. e.g., pumps (centrifu$al,
lobe, gear, intermesh1ng
screw vane, flexible
impeller, screw auger,
progressing cavity, piston,
and diaphragm).
Other: aire conveyor,
vacuum truck, portable
vacuum unit.
· Capabilities of transfer
equipm~nt: e.g., o~l
v1scos1ty, pour point,
debris, abrasives,
portability,
emulsification, cold
weather operation and ease
of repair and handling.
· Lightering operations

A·ll
13.3 Safely operate Pre~aration, operation Safely operate pumps, conveyors, and other
transfer equipment. and disconnection of equipment.
equipment. • Troubleshoot minor problems.
· Use of controls.
· Safety considerations.

[----------------------------------------------------------------------------------------------------------
__________________________________________________________________________________________________________
TASK 14 STORE AND DISPOSE OF OILY WASTES ]
( _________ sUR·TASK __ - _____ r__________ KNOWLEDGE___________ r___________________ SKILL_____________ - __ -- __ ---:1
14.1 Store materials by · Land-based and-water· · Assist in the selection of storage sites
cleanup. based storage options: and options.
e.g., pit; prefabricated · Set up and use storage facilities.
kit; towable tank; drum;
trucks (tank, vacuum, dump,
pickup), barges
(tank, deck, and hooper);
vessels (workboat, skimmer,
supply boat, and tanker),
plastic bag and tubing; and
spent boom.
· Factors re: selection of
storage sites(envirorunental
regulatory).
Permit requirements.
14.2 Segregate and · Segregation of materials. · Sort materials to facilitate storage and
minimize waste. · Waste reduction, disposal.
practices: e.g., re· · Separate and recycle waste.
use; oiland water
separation; minimal
collection of non-oiled
material; and minimal
formation of waste water,
14.3 Facilitate disposal · Disposal options: · Assist in the selection of disposal sites and
of collected materials. e.g., reprocessing, options.
recycling, landfilling, Operate on-site disposal methods.
stabilization, burning, Provide feedstock for disposal units.
incineration,
bioremediation, and
landfarming.
· Capabilities of equipment
and techniques.

A·l2
 · Factors re: selection of
dis~osal options: e.g.,
environmental, re~ulatory,
access, and security
factors.
· On·site disposal for
remote locations.
· Safety: e.g., fire
control equipment.
· Permit requirements.

[---------------------------------------------------------------------------------------------------------
TASK 15: PERFORM POST-SPILL ACTIVITIES
---------------------------------------------------------------------------------------------------------J
l [

[_: _______ SUB-TASK _- ______ I__________ KNOWLEDGE __________ I___________________ SKILL __________________ - __ -)
15.1 Ensure · Health and safety · Set u~ and use personnel decontamination
decontamination of guidelines. facilities.
personnel. · Facility set·up.
15.2 Restore equipment · Equipment decontamination · Perform equipment restoration
to pre·spill condition. procedures. activities.
· Cleaning requirements and
method,
• Waste water collection.
· Equipment maintenance and
storage.

15.3 Participate in · Technical problems and · Suggest improved response methods.

debriefing. solutions.

A-13
 Ll;VEL__2___COURSE FOR OIL SPILL RESPONSE

[----------------------------------------------------------------------------------------------------------
TASK 1: ASSESS SITUATION
----------------------------------------------------------------------------------------------------------
]

[ _________ SUE·T~SK ____ - __ :1________ -_KNO~LED~E_: ______ : __ r_____-________-__ -_sK11i________-__ --_-----::-::1

1.1 Receive incicT.ent · Standard spill reporting · £nsure accuracy of report and document on
report. forms and procedure for standard report forms.
use.
1.2 Gather and verify • Knowledge of construction Demonstrate ability to gather enough
additional information. and operation of various supporting data to facilitate an appropriate
pollution sources such response.
as - -
vessels and damage
assessment of vessels;
pipeline;
storage tanks;
oil r1gs and platforms;
and terminals.
Plotting skills.
Use of charts and tide
tables.
Introductory meteorology.
Local sensitivities.
1.3 Assess size, product, Metric and US measurement Estimate spill size.
source, and magnitude of conversion. Determine spill source.
spill. · Methods to estimate spill Convert metric to US.
volume. • Assess potential political and economic
· Physical oil types and significance.
API ratings. · Identify spilled product.
· Awareness of oil physical
chemistry.
1.4 Hazard recognition. · Awareness of oil and · Identify potential threat to people and the
product physical chemistry. environment.
· Marine Safety Data
Sheets.

A· 14
 · Awareness of oil and
product toxicology.
· Fire and explosion
hazards.
· Potential hazards to
human health,
· Recovery capabilities of
coastal and inland areas.
· Effects on flora and
faWla.
Sensitivity mapp~_ng.
1.5 Hazard evaluation · Sampling techniques • Prevent accidental injury to personnel.
· Sampling instruments
(e.g., CG/02 meter,
Draeger, etc,),
' Monitoring techniques.
· Site characterization and
analysis.

[----------------------------------------------------------------------------------------------------------]
TASK 2: ACTIVATE RESPONSE PLAN
----------------------------------------------------------------------------------------------------------
[---------suB:TASi_________ I__________ KNOWLED~~--:--------I-------------------siiLL::---------:------------J
2.1 Notify appropriate · Vessel and facility · Demonstrate practical activation of plan
authorities and alert key plans. through drills and exercises.
personnel according to · Notification of
plan. authorities.
• Clean-up resources.
· How and when to mobilize
resources.
2.2 Initiate response. • Base line survey · Identify and coordinate immediate response
techniques and activities.
requirements.
· Contracting procedures.
Salvage/mitigation.
• Liability issues.
· Equipment uses and
limitations.
· Funding sources.

A•l5
 • Natural resource damage
assessment, including
assaessement of statutory
and regulatory
requirements.

[----------------------------------------------------------------------------------------------------------
__________________________________________________________________________________________________________
TASK 3: PREPAKE A RESPONSE ACTION PLAN (STRATEGY) ]
--------------------------1------------------------------i------------------------------------------------i
[_________ su»-TAsx_________ ----------~OWL~DGE ---------- ___________________ s~IL: -----------------------
3.1 Identify and • Shoreline and inland Identify protection J?riorities.
prioritize resources at types. Identify clean-up priorities.
risk. · ielative sensitivity of
coastal ty1;>es,
· Sensitiv1ty mapping.
Local geography.
Local oceano~raphy.
Critical hab1tats. ·
Use of tide and tidal
current tables.
3.2 Spill trajectory · Influence of water and • Use data to predict speed and direction of oil
forecasting. weather conditions on oil movement.
properties and slick
behavior and spread rate.
Estimating spill size.
Trajectory modeling.
3.3 Identify resources Use and limitations of • Selection of proper equipment for the given
required. dispersants; circumstance.
tracking systems; Determine personnel requirements.
booms; · Determine surveillance requirements.
skimmers; • Determine fWldin~ required,
pumps; • Determine logistical needs; i.e., food,
portable storage; shelter, hygiene.
chemical barriers;
sorbents;
bioremediation;
communication
equipment;
· shoreline cleanup;

A· 16

~
 equiJ?ment; and
in·situ burning.
Logistics
FW1ding sources
Permits and other
approvals required.
3.4 Identify addit+onal · Location of additional · Locat,e and acquire additional resources.
resources, resources.
· Means to obtain
resources.
Regional agreements.
International agreements.
Negotiations.
Contract procedures.
3.5 Maintain records as Contract agreements, · Establish log keeping procedures for the
required. Market rates. following:
Purchase order systems. contractors.
Change order agreements. subcontractors.
Accounting procedures. hired equipment.
consumables used.
personnel hired.
3.6 Prepare response • Elements of a viable Prepare and brief appropriate members of
action plan. response plan including response community.
· time available;
resources available;
containment plan;
protection/deflection
plan;
oil recovery plan;
temporary storage and
disposal plan;
application of
chemicals, etc. ;
method of deployment of
e9-uipment;
site safety plan;
personnel protective
equipment;
plan adjustment
mechanisms; and
permits and other
Federal and state approval~
required. ·

A•l7
 ----------------------------------------------------------------------------------------------------------
[----------------------------------------------------------------------------------------------------------
TASK 4i ACTIVATE ORGARIZATIONAL RESPONSE ]

[
--------------------------1------------------------------i------------------------------------------------
SUB·TASK KNOWLEDGE SKILL
-------------------------- ------------------------------ ------------------------------------------------
l
4.1 Define operation team · Typical spill response Organize response structure.
command structure. organization which would Delegate responsibilities.
depend on scale of the
spill (e.g., minor, medium,
or major).
· Typ1cal spill response
command structure.
· Roles and
responsibilities of team
members.
· Incident Command System
and Unified Command System.
Tiered response methods.
4.2 Establish internal and · Log-keeping requirements. Control information flow as follows:
external communication · Standardized report Downwards to operations level; and
procedures. forms. · Upwards to supervisors.
· Common communication
problems.
· Reporting schedules.
4.3 Establish command post • Site selection Select appropriate command post site.
consideration: Provide for logistics.
infrastructure.
· logistics concerns.
· future expansion.
4.4 Implement safety and Reasons for Organize safety/security operations structure.
security procedures. security and safety. Delegate responsibilities.
• Potential problems with
securityand safety.
· Local resources.
· Training requirements and
skill level of personnel.
· Occupational safety and
health requirements.

A-18
 · Environmental monitoring
requirements (e.g., l~wer
explosive limit and
toxicity).
4.5 Establish claims Claims procedures. Organize claims office.
office. Regulatory requirements. Delegate responsibilities.
4.6 Coordinate sub· Contracting procedures. Assess need for subcontracted services.
contracted services. Basic ordering Execute contracts.
agreements. Define role of subcontractors in overall
Market rates. response organization.
· Daily work sheets. • Monitor work.

A•l9
----------------------------------------------------------------------------------------------------------]
[----------------------------------------------------------------------------------------------------------
TASK 5: MANAGE ONGOING OPERATIONAL RESPONSE

[:::::::::suB~TASK ::::::::1::::::::::KNOWLEDGE:::::::::::1___::::::::::::::::sKILL::::::::::::::::::::::::J
5.1 Management of · Use and limitations of Direct & supervise
operational response pollution control. secure source;
activities. equipment and techniques chemical/biological treatment methods;
· Logistics concerns, such containment methods;
as personnel and equipment, protection & deflection procedures; and
recoveryand clean-up procedures.
Monitor adherence to site safety and security
plans.
· Coordinate disposal of pollutants.
Direct and supervise logistical support.
5.2 Conducting briefings. · Briefing techniques. Conduct briefings for --
supervisors;
subordinates;
media;
community; and
public officials.
5.3 Adjusting operations · Methods for changing Revise operation.
or organization as needed. response priorities. Revise organization.
· Methods for monitoring Evaluate changing conditions to modify and
information flow. adjust response considering the following
· Methods for progress factors:
measurement. Safety.
• Methods for monitoring Strategy.
contracted services. Tactics.

5.4 Personnel management. Team leadership. Identify, define and assign tasks and
Time management. expectations.
Stress management, · Monitor results.
Delegation methods.
5.5 Assisting in Methods scientists use to · Assist in sampling for later scientific
scientific monitoring of collect data and document analysis.
affected area. harm to the environment Describe environmental monitoring program.
(e.g., sampling, storage, Describe aerial surveillance.
custody, documentation).

A-20
[----------------------------------------------------------------------------------------------------------]
TASK 6: DEACTIVATE RESPONSE
----------------------------------------------------------------------------------------------------------
[ _________ SUB·TASK _____ - __ l__________ KNOWLEDGE ______--__ 1-________-_________ SKILL ____________ - __________ ]

6.1 Conduct analysis to · Effort and benefit Rank the different criteria.
determine if response analysis as follows: Use effort and benefit analysis method.
should be continued, Effort: manpower, equip­
suspended or terminated ment and time requirements,
with appr~priate agencies. environmental damage, anJ
area use interference
Benefits: aesthetic
benefits, environmental,
economical, and social
water use benefits; and
addressing public pressure.
6.2 Ass~ss eotential for • Location of remainin$ oil · Use spill projection models.
recontam1na ti.on. in the environment or 1n · Determine whether cleanup should be continued
the source. or terminated.
Trajectory modelin~.
Final survey techn1ques.
6.3 Shut ~own field Updated inventory and · Describe how the operations should be
operations, location of equipment and terminated in an orderly manner.
personnel.
· Procedures to terminate
operations.

A.·21
 ----------------------------------------------------------------------------------------------------------]
[_________________________________________________________________________________________________________
TASX 7: CONSOLIDATE COSTS _
---------su;:TASi_________I__________ iiOWLEiGE___________ I___________________ Siiii________________________ l
[-------------------------- ------------------------------ ------------------------------------------------
7. l Verify and certify · Reasons for cost • Present a plan for filing and record
costs. documentation. maintenance.
· Liability, and cost · Consolidate records and produce reports of
recovery, expenditures by category.
Daily log procedures.
Equipment cost report.
• Manpower forms.
· Invoices for contract
services.
· Personnel activity
sheets.
Daily work sheets.
Travel claims.
7.2 Provide final cost Cost\ documentation · Construct a simple coding structure for the
documentation report, procedures response.
and report writing • Produce final cost report.
techniques.
· Coding structure.

A·22
 ----------------------------------------------------------------------------------------------------------1
[----------------------------------------------------------------------------------------------------------
TASK 8: DEBRIEF AlfD REPORT

--------------------------i------------------------------r------------------------------------------------1
[_________ SUB·TASK __________________ KNOWLEDGE______________________________ SKILL-----------------------
B.l Conduct operational Daily report. · Conduct an effective and productive team
review of the response. Purpose of review. review of response.
8.2 Provide information, Daily report and • Consolidate information to produce operations
documentation and evidence chronological report. report.
to final operations · Maps, charts, or
report. diagrams.
• Message traffic, telex,
radio, and fax.
· Shoreline survey
evaluation form.
• Photographic
documentation.
8.3 Make recommendations • Familiarity with existing · Demonstrate the ability to make pertinent
for improved preparedness. contingency plan. recommendations for improvements to the
contingency plan.
demonstrate analytical skills.

A-23
The federal government encourages private industry and training institutions to develop
and further refine courses available for oil and hazardous substance spill prevention and
response. While training for pollution response is important, emphasis should be given
to improving the training available for the prevention of all spills. This goal would be best
accomplished by existing in-house training programs developed by companies which
are more familiar with the operational job requirements of their own employees.

Private sources have developed a large number of training courses for the oil and
chemical industries. The International Tanker Owners Pollution Federation, Limited has
published a manual for oil spill response titled Response to Marine Oil Spills and has
also produced accompanying training video tapes. The Texas A & M University offers a
wide variety of courses on oil and hazardous substance prevention and response at its
National Spill Control School in Corpus Christi, Texas, at the Texas Engineering
Extension Service, and at the Center for Marine Training and Safety in Galveston, Texas.
The Paul Hall Training Center in Piney Point, Maryland offers courses in hazardous
materials and oil spill response as well as a wide variety of courses for the professional
mariner. The Massachusetts Maritime Academy has also developed courses for
qualified individuals and supervisory personnel. Other maritime academies either have
existing courses or are in the process of developing courses to better serve the
changing needs of the maritime industry.

Numerous commercial and government sources have developed videotapes and

course booklets designed for hazardous substance response teams and chemical
industry employees. Commercial companies offer training videotapes on all aspects of
hazardous substance response. Interested parties are advised to contact the training
officer for their state emergency management agency for specific recommendations on
commercial or state hazardous substance response courses. Many large companies
within the oil and chemical industries have also developed highly professional in-house
training programs to indoctrinate their personnel in safe work practices and response
techniques.

In the federal government, the Federal Emergency Management Agency (FEMA)

National Fire Academy, and the EPA have developed and now provide courses on
hazardous substance response. These courses are primarily designed for local, state,
and federal agency response personnel. The EPA's Office of Emergency and Remedial
Response (OERR) is responsible for the EPA's Environmental Response Training
Program (ERTP). EPA has developed numerous courses designed for emergency
response personnel and those who investigate and remediate hazardous waste sites.
ERTP courses are offered in each EPA region and at the EPA's Environmental
Response Training Centers located in Cincinnati, Ohio, and Edison, New Jersey.
Although federal, state, and local government employees are given priority for course
attendance, private sector employees are considered on a space available basis.
Inquiries on available course offerings and registration procedures should be directed
to:

B-1
 Training Registrar
U.S. EPA Environmental Response Training Program
3280 River Road
Cincinnati, OH 45204
Tel: (513) 251-7776;FAX: (513) 251-4137.

Under an interagency agreement with the Department of Transportation, FEMA's

Emergency Management Institute has developed a manual on hazardous materials
training. The first edition of the manual titled Guidelines for Public Sector Hazardous
Material Training will be available to the public in 1994. The manual emphasizes
hazardous material course content and the methods used in course evaluations.
Another FEMA office, the National Audiovisual Center, is the central repository for over
8,000 video programs, films, slide sets, and other training material on hazardous
substances and response produced by, or for, the U. S. Government. The courses may
be ordered by contacting:

The National Audiovisual Center

8700 Edgeworth Drive
Capital Heights, MD 30243-3701
Tel: (301) 763-1896.

FEMA also operates the National Emergency Training Center in Emmitsburg, Maryland.
The Center houses the U. S. Fire Administration, the National Fire Academy, and the
Emergency Management Institute. The Center offers a wide variety of resident and
nonresident courses in emergency preparedness and several courses on hazardous
substances. Interested individuals may correspond to the following:

National Emergency Training Center

Office of Admissions
16825 South Seton Ave.
Emmitsburg, MD 21727.•

B-2
Sample Lesson Plans
TAB A OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

OUTLINE In this lesson will be discussing the following topics:

♦ Purpose of containment
♦ Reference material
♦ Boom Selection
♦ Commercial Floating Boom
♦ Improvised Boom
♦ Sorbent Boom
♦ Air or Water Streams
♦ Bubble Barriers
♦ Chemical Barriers

♦ Containment Techniques & Applications

o Exclusion Booming
o Diversion Booming
o Containment Booming
o Sorbent Booming
a Sorbent Barriers

♦ Boom Failures
o Sheet Breakaway [Entrainment]
o Droplet Breakaway [Drainage]
o Splash-over [Submergence/Planing]
a Wave Induced Failure

♦ Recovery
♦ Skimmers
oWe\r
o Suction
o Centrifugal
o Submersion
o Sorbent Surface

♦ Sorbents
o Classes
o Uses

♦ Manual Recovery
♦ Solidifying Agents
♦ Chemical Agents
o Collecting Agents
o Dispersing Agents
o Sinking Agents
o Burning Agents
o Biological Agents
o Gelling Agents
o Neutralizing Agents

C-1
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

PURPOSE ♦ CONTAINMENT of an oil spill is the process of preventing its

spread by confining the oil to the area in which it has been
discharged.

♦ The purpose of containment is not only to localize the spill and

thus minimize pollution BUT to facilitate removal of the oil by
causing it to concentrate in thick layers on the surface of the
water.

♦ In short, EFFECTIVE containment systems:

o COLLECT the pollutant to aid in recovery ops.

o DIVERT the pollutant to areas where cleanup can be
conducted.
o PREVENT the spread of pollutants over a wide area.
o PROTECT specific areas such as entrances to
harbors/rivers and environmentally or economically
sensitive areas.

REFERENCES ♦ You can find information on containment and recovery in the

following references:

o EPA's "Manual of Practice for Protection and Cleanup of

Shorelines"
o "The Basics of Oil Spill Cleanup" by Mervin Fingas
o "Response to Marine Oil Spills" by The International
Tanker Owners Pollution Federation - ITOPF
World Catalog o World Catalog of Oil Spill Response Products - a
6514 Rockburn Hill Rd complete listing of equipment throughout the world.
Elkridge, MD 21227
1-800-937-5078

TYPES OF SYSTEMS ♦ The most common types of containment systems are:

o Commercial floating boom ( curtain & fence)

o Improvised boom and barriers
o Sorbent boom and sorbent barriers
o Air or water streams
o Bubble barriers
o Chemical Barriers

BOOM SELECTION ♦ Boom selection must take into consideration:

o The type of pollutant to be contained.

o The conditions it will be operating in (i.e. wind, wave
height, open or closed water area, current speed and
tides).
o The logistical requirements for deployment and availability

C-2
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

of manpower.
o Its compatibility with other types of booms.
o The location of access points for recovery equipment.
o Deployment areas must have good anchoring locations
for shoreside and waterside ends of the boom.
o Its buoyancy.
o Its roll response in currents.
o Its heave response in waves.
o Does it have adequate freeboard height and skirt depth.
o Is it easily visible in daylight: yellow or international
orange is good.
o Can it be packaged for ease of transportation.
o Is it easy to assemble, deploy and retrieve.
o Are there anchor points at about 50 foot (15m) intervals.
o Are the surfaces smooth to permit laminar (layered) fluid
flow & prevent the collection of debris.
o Is it easy to assemble, deploy and retrieve.

Boom containment devices are generally designed for oil

pollution, but some types are designed for floating hazardous
materials such as acids, bases and solvents. For HAZMAT
especially, the physical and chemical properties of the pollutant
and the compatibility of the pollutant with boom material must be
carefully considered prior to deployment.

COMMERCIAL ♦ There are five basic components of boom:

FLOATING BOOM
COMPONENTS o Means of flotation
Floats may be rigid or flexible. Flotation elements should be
relatively smooth so that they don't trap debris or produce
vortices in moving water causing loss of oil under the boom.
o Freeboard (prevents/reduces splash-over)
The vertical height of a boom above the water line. The
freeboard prevents oil from washing over the top of the boom,
but if it is too high, the boom may be pushed over in high winds.

o Skirt (prevents oil from being swept underneath the boom)

The continuous portion of a boom below the floats. Since the
force of current on a boom is proportional to the skirt area,
increasing skirt depth beyond what is really necessary puts an
unusually high load on tension members of the boom.

o Ballast System
Weight applied to the skirt to improve performance. Ballast may
be a series of weights attached to the skirt along the entire
length, a chain, or metaj rods supported along the bottom of
the skirt.

o Tension line/strength member

Tension members are often cables, chains or lines running along
the skirt of the boom and/or along the freeboard.

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OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ In addition, containment booms may have some or all of the

following auxiliary or support components:

o Anchor points
o End connectors
o Handholds
o Hinge
o Lifting Points
o Stiffeners

♦ There are !l different types of boom connectors:

o Quick
o Universal slide
oSlide
o Slotted tube
o Raised Channel
o Bolt
o Hinged Plate and Pin
o Hinge and Pin

♦ There are two types of booms in general use today: FENCE and
CURTAIN booms.
Fence booms have a rigid or semi-solid material as a vertical
screen against oil floating on the water. Curtain booms have a
flexible skirt that is held down by ballasting weights or separate
tension lines.
Fence booms can be classified according to the type of flotation
used:

o Centerline flotation,
o Outboard flotation, and
o One-sided outboard flotation.

Fence booms are usually easy to deploy, resistant to damage,

but bulky for storage.

Curtain booms have centerline flotation provided by air, inert gas,

solid foam bars, flexible foam roll, or granulated foam contained in
a plastic cylinder. They have flexible skirts which are free to move
independently of the floats.
Several kinds of specialized booms are also available. They are:

o Tidal seal booms (for tidal flats)

0 Fireproof booms
o Ice booms

C-4
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

IMPROVISED BOOM Can be used to contain relatively small spills which occur in
sheltered waters or as a temporary measure until more suitable
boom is brought on-site.

♦ EXAMPLES:
o inflated fire hose
o telephone poles
ologs
o linked railroad ties
o earthen dams

♦ USES:
o As diversion boom to divert oil to area where commercial
boom is already deployed.
o Collection point for river debris to protect main containment
boom.
o GOOD in streams or ditches which are too shallow for
conventional boom.

A major problem with this system is that the oil can readily spill
over the top or in-between sections.

· SORBENT BOOMS AND Specialized containment devices that absorb oil in porous
BARRIERS materials such as straw or synthetic materials [This will be covered
in more detail in the RECOVERY portion of the lesson].
Used when the oil slick is relatively thin because efficiency rapidly
decreases once the porous surface is saturated with oil.

♦ DRAWBACKS:
o Requires considerable additional support to avoid breakage
under the force of wind/current.
o Often requires some method of additional flotation to
prevent sinking when saturated with oil & water.
o A great deal of caution must be used to prevent the
contaminated side of the boom from turning over and
recontaminating the water.

AIR OR WATER Under some circumstances, the force of a water stream from a fire
STREAMS hose or pump can be used to contain or divert an oil slick. A high­
pressure airflow will produce the same results.

♦ USES:
o Keep oil out of a gap between conventional floating booms.
o Temporary containment measure wjllle a boom is being
deployed.
o Direct oil towards a recovery sight.
o Flush oil from beneath a dock.
o Adjust booms that have already been deployed.

C-5
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ DRAWBACKS:
o ONLY effective when current Is less than .5 knots. \
o If current exceeds 1 knot this systems adds to the problem
by causing the oil to form emulsions hindering cleanup.
o Requires continuous use.
o Requires considerable skill to use effectively.
o Requires close coordination between operators and
recovery personnel.

BUBBLE BARRIERS A rising curtain of bubbles can be produced when air is pumped
into a perforated pipe located below the water's surface. This
rising curtain causes the surface water to spread horizontally in
two directions perpendicular to the submerged pipe, thereby
forming a natural barrier.

♦ BASIC PRINCIPLE:

o Oil will not cross the two-way current.

♦ USE/ADVANTAGES:

o Most suited to relatively calm harbors.

o Allows for the passage of vessels.
o Will hold oil against water flows up to .7 knots.

♦ DISADVANTAGES:

o Costly installation and maintenance costs.

o HIGH power output required to produce a sufficient bubble
stream to disrupt the surface of the water.
o Redistribution of bottom silt (shoaling).

There has been success using the system when installed on an

angle to the current providing a diverting action to a shoreline
area.

CHEMICAL BARRIERS Certain chemicals act as surface tension modifiers and inhibit the
spread of oil. These are known as "herders". When relatively
small quantities of these chemicals are placed on the water 1s
surface next to the floating oil, the oil is pushed away as a result of
the stronger spreading force (low surface tension) of the chemical.

♦ HOW DISPERSED:

o Sprayed from a boat, helicopter or plane.

o Sprayed so that the slick is surrounded by the chemical and
corralled/concentrated in thick layers.
o Sprayed so as to divert oil to a recovery area.

C-6
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ DRAWBACKS:

o Acts only on fresh oils - must be used early in spill.

o Effects only last a few hours.
o Recovery must begin immediately after application.
o Approval must be obtained from proper
authorities/regulatory agencies prior to use.
o Public/health issues must be considered before use.
o Impact on environmentally sensitive areas.
o Less effective on viscous oils.
o Don't work well in icy or cold waters.
o Don't work well where wind, current or wave action is
significant.

CONTAINMENT ♦ The five basic containment techniques/applications are:

TECHNIQUES &
APPLICATIONS o Exclusion booming,
o Diversion booming,
o Containment booming,
o Sorbent oooming, and
o Sorbent barriers.

EXCLUSION BOOMING A boom is deployed across or around a sensitive area to 11 exclude11

a pollutant from contaminating the area. The pollutant is either
deflected or contained by the exclusion boom. A good example of
this would be putting a boom around a tank vessel while it is
conducting transfer operations.

In some cases, booms are positioned in a semicircle along a

specific section of shoreline to aid in containing oil which has been
removed from the shore or beach and is awaiting recovery.

DIVERSION BOOMING A boom is deplo'{ed at an angle to the approaching pollutant. The

pollutant is either "diverted" away from a sensitive area or diverted
to a central collection point to ease recovery. This technique is
primarily done in inshore, river or harbor areas.

Primarily used when currents are less then .7 knots and breaking
waves are negligible.

The velocity of water in a stream or river is not equal at all points

across its width; higher velocities are generally·found in the deeper
central parts and along the outside curves. Therefore oil will
naturally be forced into the QUIET areas of the stream or river.

C-7
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ HOW DEPLOYED:

o Chevron pattern - The boom is angled in a chevron

or inverted V pattern so that all floating oil and debris is
deflected to either side of the stream.

o Cascading pattern - Varying lengths of boom are

progressively staggered along the watercourse so that the
oil is directed to one side of the watercourse. - Particularly
effective in rivers which are too wide to allow use of the
more simple chevron pattern - or - where currents are
very strong and single booms fail.

NOTE: There are tremendous forces on any boom in a

diversionary mode, so it MUST be firmly anchored to the shore.
Recommend putting numerous anchors throughout the entire
length of the boom.

CONTAINMENT A boom is deployed in a "U" or "V" shape in front of the

BOOMING approaching pollutant. The ends of the booms are anchored or
secured to work vessels. The pollutant is contained within the "U"
or "V" and prevented from spreading.

♦ Primarily used on the open water with offshore boom.

♦ Often used in combination with skimming vessels or devices. \

♦ When used in relatively sheltered waters, such as estuaries, ports

and harbors, containment barriers are often anchored to the
bottom. Depending on local current and wave conditions, inshore
boom may be used. A major consideration is to ensure the
anchoring system takes into consideration current direction.
velocity and tidal shifts.

SORBENT BOOMING Boom composed of sorbent material. This type of boom is usually
deployed along a shoreline to protect sensitive areas or keep
heavier, emulsified oils from spreading.

Primarily used on quiet waters that are not heavily contaminated.

SORBENT BARRIERS A sorbent barrier is usually constructed of wire mesh, stakes and
loose sorbent materials. It is often deployed across a waterway or
outfall. It allows water to flow through it but retains and absorbs oil
on the water's surface. Primarily used in small, low-velocity
streams, tidal inlets or channels.

C-8
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

•
BOOM FAILURES Oil loss resulting from boom failure may be attributed to one or
more of the following causes:

o Underflow [ENTRAINMENT/DRAINAGE] caused by

currents (Sheet and/or Droplet breakaway).
o Splash-over caused by winds.
o Submergence or rollover [PLANING] caused by
waves/currents
o Mechanical failure of structural members or joint
connections.
o Improper anchoring.
o Improper positioning of the boom with respect to current
direction.
o Failure of cleanup crews to compensate for tidal changes
and/or current force & direction.

SHEET BREAKAWAY ♦ Sheet Breakaway [ENTRAINMENT] is the most common type of

boom failure because:

1. Boom acts as a dam, so ...

2. The surface water is deflected downwards, and
3. The surface water accelerates in an attempt to keep up
with the water normally flowing under the skirt (the depth of
the skirt affects acceleration speed); therefore,
4. Oil is drawn down under the boom (entrainment).

♦ The amount of oil lost in headwave failure depends on the

thickness of the oil in the headwave, which is a combination of
water velocity and specific gravity of the oil. The current velocity
which creates this phenomenon is called "critical velocity" and
varies with:
o Skirt depth,
o Oil viscosity,
o Specific gravity of oil, and
o Thickness of oil film contained in the boom.

GENERAL RULE: Oil will begin to escape beneath the skirt of

most booms when current velocity exceeds .7 knot~. Entrainment
loss determines how fast a boom can be towed or the maximum
current in which it will be effective.

This type of boom failure can be overcome, to a certain degree, by

placing the boom at an angle to the current. Spill containment
performance depends on the angle between the boom and the
current. They can be expected to take some catenary shape.
When the angle with the direction of flow becomes small, the
catenary may be more like a J-shape. The curvature of the "J"
presents a greater angle to the flow and therefore has a lower
speed at which failure occurs. Therefore, one would expect failure

C-9
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

to occur first in that part of the boom curving to cross the direction
of flow ..

When booms fail in fast currents, oil escaping under the boom
tends to collect in the water flowing along the backside of the
boom. This provides a spill response crew with another
opportunity for containment. A second boom can be deployed just
downstream from the boom that is showing failure.

DROPLET BREAKAWAY High velocity currents cause another type of failure (oil loss)
known as DROPLET BREAKAWAY [DRAINAGE) because:
1. Oil mass forms a headwave, and
2. The rear of the headwave becomes unstable, so•..
3. Oil droplets are tom off and entrained in water flow, flowing
under the skirt.

This phenomenon begins to occur at about .3 knots.

The problem is aggravated by having a deeper skirt. Increasing

skirt depth also increases the distance water must travel to stay
with the flow, which causes drainage to occur at a lower critical
velocity.

Both entrainment and drainage failures involve leakage from large

pools of oil that my collect ahead of the boom. Failure can often
be avoided by eliminating the pools that are the source of the
leakage. To prevent leakage, deploy skimmers where oil has
pooled in the area of the headwave.

"SPLASH OVER" Wind is a SECONDARY factor affecting a boom's efficiency when

the current is the dominant factor.

If the boom is not securely anchored on both sides and the wind is
blowing opposite the current, the boom will move back and forth
causing "SPLASH OVER".

If the wind is moving in the same direction as the current, "splash

over'' will also occur. In a worst case, the boom will fail.

WAVE INDUCED ♦ Waves affect the efficiency of booms. Typical failures are:
FAILURE
o Submergence
o Roll over [Planing]

Submergence may occur when a boom is deployed or anchored in

a fast current, or is being towed at a high velocity in still water.
The tendency of a boom to submerge at a given velocity is
determined by its rese,ve buoyancy.

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OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

A strong wind and strong current moving in opposite directions

may cause a boom to heel flat on the water surface. The resulting
loss of oil is called planing failure.

Most booms perform well in gentle swells. If swells are long

(length to height rate is 10:1) with a long period between crests,
and the boom is flexible - there should be LITTLE problems.
Waves with medium swells and significant wave heights (5:1) or
short choppy waves with high winds will cause excessive
turbulence at the apex of the boom and result in splash-over.

RECOVERY After the oil is contained, the next step in the response op.eration is
to recover it from the water. In most instances the containment
and recovery phases proceed simultaneously.

RECOVERY ♦ There are 3 distinct approaches to the physical recovery of oil

APPROACHES from the water. They are:

o Use of mechanical skimmers.

o Use of sorbents.
o Use of manual labor.

In most spills, each approach is used to a certain extent and each

has specific limitations depending on geographic location and
ambient climatic conditions.

FACTS ABOUT A skimmer is a mechanical recovery device designed to remove

SKIMMERS the pollutant from the water's surface without causing major
alterations in its physical or chemical properties. All skimmers
work best in calm waters with little or no wave action. Skimmer
types can be classified according to their basic principles of
operation. They fall into two categories: Suction Skimmers or
Adhesion Skimmers. Viscosity (see special note) of the pollutant
will help determine the most appropriate skimmer and pump types
to be utilized for a particular incident.

SPECIAL NOTE: Viscosity is defined as the measure of a

fluid's internal friction or its resistance to flow; a fluid's
surface tension. Lower viscosity substances are lighter and
when spilled or released into a waterway will spread out over
a greater area. Higher viscosity substances will not spread
out as much. Hence, the product will remain "thicker".

C-11
OIL SPILL CONTAINMENT & nECOVERY EQUIPMENT

Skimmer performance varies widely depending on the viscosity of

the oil being recovered. Most skimmers have a range of
viscosities in which they work best: They are

Light Oil Viscosity 3-1 o est, .83-.88 Sp. gravity

Weir, Suction, Submersion belts, Submersion planes.

Medium Oil Viscosity 100-300 Cst, .90-.94 Sp. gravity

Disc, Drum, Rope mop, Floating head belt, Sorbent lifting belt,
Sorbent submersion belt, Submersion belt, Drum brush, Chain
brush, submersion planes, boom-skimmer, Vortex.

Heavy Oil Viscosity 500-2000 Cst, .94-.97 Sp. gravity

Paddle belt, Sorbent lifting belt, Rope Mop, Drum brush, chain
brush, Oil head weir.

Waves and currents have a significant effect on skimmer

performance. Waves affect performance because rough seas
move the skimmer away from the oil floating on the water surface.
Currents affect the performance of skimmers because fast
currents generally cause oil to escape under collection booms.

♦ There are generally five different types of skimmers:

oWeir,
o Suction,
o Centrifugal,
o Submersion, and
o Sorbent surface.

WEIR This type of skimmer takes advantage of gravity to drain the oil off
the water's surface. It consists of a weir or dam, a holding tank
and an attachment which is connected to external pumping
equipment.

Two types of weir skimmers are:

1. Sweeping arm weir.

2. Oil head weir.

♦ OPERATION:

o The top edge is positioned at a certain level with respect to

the oil/water interface, then
o Floating oil falls over weir or is forced over it by currents
where ...
o Oil is continually removed by pumps.

C-12
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ ADVANTAGES:

o Simple, reliable, most available of all skimmers.

o Given a thick layer of oil the weir can recover large volumes
of product at high rates with a recovery efficiency of about
50%.
♦ DISADVANTAGES:

o Efficiency is reduced in cold weather.

o Tends to draw too much water relative to oil which requires
constant adjustment of the pumping rate.
o Presence of debris reduces efficiency.
o EXTREMELY susceptible to wave action.
o Tendency to turn over in rough water.
o Intake of air can cause the pumps to lose prime, causing
the skimmer to stop operating.
o Will turn over in rough water.

Best when used in calm, protected waters. Rarely used in open

ocean incidents.

SUCTION Suction skimmers are similar in many respects to weir-type

devices. These skimmers also sit on the water surface, generally
use an external vacuum pump system and are adjusted to float at
the oil-water interface. Due to their compactness and shallow
draft, suction skimmers are particularly useful in shallow water and
in confined areas such as under docks.

♦ ADVANTAGES:

o Simple to operate.
o Have a shallow draft.
o Can be used nearly everywhere, even under piers.
o Require little or no adjustment.
o Efficiently recovers a wide range of different viscosity oils.

♦ DISADVANTAGES:
o Susceptible to clogging.
o Doesn't work well in choppy waves.
o Loses suction (planing) if current exceeds .6 knots.
o Must be tended with lines from ashore or a boat.
o Susceptible to clogging.

These skimmers work well in calm waters when containment

barriers are used to direct the flow of oil toward the skimmer's
floating head.

Another form of suction recovery is the use of a vacuum truck.

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OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

CENTRIFUGAL

This skimmer operates by the creation of a water vortex or

whirlpool, which draws the oil into a collection area where it is
pumped to an oil~water separator.

♦ ADVANTAGE:
o Not susceptible to clogging with debris (debris screen).

♦ DISADVANTAGES:
o Currents and waves limit its effectiveness.
o Does not work well when current exceeds .6 knots.

The most common centrifugal skimmer is the VORTEX skimmer.

SUBMERSION This type of skimmer is usually mounted on or incorporated within

a powered vessel. Oil in the path of the skimmer is forced beneath
the water's surface by a moving belt inclined at an angle to the
surface. The belt forces the oil downward toward the mouth of a
collection well where it rises to the surface. Water collected with
the oil simply passes under the collection well and out a discharge
port. Oil adheres to the belt and is removed by a mechanical
scraping device. The oil is then pumped to an onboard or
adjacent storage facility.

The most common of these skimmers are:

1. Solid belt,
2. Sorbent belt.

♦ ADVANTAGES:

o Efficient with low viscosity oils and when slick is thin.

o Will work. but not as well, with high viscosity oil.
o Not seriously hampered by debris.
o Not seriously hampered by waves.
o Good for uncontained slicks.
o Rate of recovery and amount of recovered oil is
HIGHER than other skimmers.

♦ DISADVANTAGES:

o Large and must be in motion to recover oil.

o Not well suited for confined areas or adjacent to
containment boom.

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OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

SORBENT SURFACE This type t>f skimmer incorporates a surface to which oil can
(OLEOPHILIC) adhere in order to facilitate its recovery from the water. The
sorbent, or Holeophilic", surface can be in the form of a drum, disc,
belt or rope which is continuously moved through the oil film. The
collected oil is removed by a wiper blade or pressure roller and is
then deposited in an onboard container or pumped to a storage
facility.

The most common types are:

1. Rope mop,
2. Disc,
3. Drum.
4. Paddle belt,
5. Sorbent lifting belt, and
6. Brush (drum or chain).
♦ ADVANTAGES:

o Of all the types of skimmers, this one is least affected by

waves. Wave action can enhance oil recovery in some
models by increasing the surface area of the sorbent
component.
o Can be operated from a stationary location and is most
suited for use within containment booms and adjacent
docks.

♦ DISADVANTAGES:

o Rotating surface tends to drive oil away from skimmer

where it enters the water, especially when the skimmer is
moving.
o Debris can damage rollers, wringers and wiper assemblies.

SORBENTS ♦ A sorbent is a material which will recover oil through either

absorption or adsorption.

♦ In "absorption", the oil actually penetrates the surface of the

sorbent.

♦ In "adsorption", the oil is attracted to and adheres to the sorbent

♦ Sorbents should be hydrophobic or water repellant.

♦ The ideal sorbent absorbs oil quickly with retention. It also
absorbs large amounts of oil per its unit weight with very little
water.

C-15
 OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ The sorbent should be easy to apply and non-toxic to both

handlers and the environment.

♦ Those to be used on water will be able to take on large amounts

of oil without sinking.

♦ They should be easy to recover and be strong enough to be

handled without tearing.

CLASSES ♦ The three basic classes of sorbents are:

o Natural organic:
' - peat moss,
I - straw,
-hay,
I, - sawdust,
- ground corn cobs,
- chicken feathers,
- cork, wool, clay.
- snow.

They can pick up from 5 to 15 times their weight in oil.

o Inorganic/Mineral Based:
- vermiculite (silicates),
- perlite (natural volcanic glass),
- volcanic ash,
- glass wool,
- volcanic ash/rock.
They usually sorb about four to eight times their weight in oil.
Some of these are difficult to apply because they blow in the wind.
Others are hazardous and require operators to wear breathing
apparatus (respirators).

o Synthetic Organic:
- rubber,
- polyester foam,
- polyurethane,
- polystyrene,
- nylon fibers.

These are highly oleophilic and hydrophobic and are ideal for
recovering oil floating on water. They are generally strong enough
to be used several times.

C-16
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

Sorbents are available in a great many forms:

o Rolls, sheets, blankets, web, loose particulates, pillows or
sorbent booms.
Sawdust, peat moss and cotton will soak up oil but tend to sink
once water saturated - this will intensify the cleanup problem.
Recovery of large amounts of natural sorbents required lots of
manpower.

MANUAL RECOVERY -Where access is difficult, oil may have to be removed using a
bucket.
Manual recovery can be manpower intensive and expensive.

SOLIDIFYING AGENTS Although not an oil recovery technique in its own right, chemicals
have been developed that convert liquid oil into solid mats, thereby
facilitating recovery by manual means or nets. While such
chemicals have been demonstrated successfully in the laboratory,
difficulties in achieving the required intensive mixing into the oil
and their high cost are likely to preclude their use except for small
pockets of oil in restricted locations.

CHEMICAL AGENTS ♦ A chemical agent is a substance or chemical used in pollution

cleanup/recovery and mitigation. Some chemical agents are
designed specifically for oil products (hydrocarbons), while others
are designed for classes of hazardous materials (acids, bases and
solvents).

Types of agents are:

o Collecting,
o Dispersing,
o Sinking,
o Burning,
o Biological,
o Gelling,
o Neutralizing.

COLLECTING AGENTS ♦ Cause the oil to herd to a collection point. Works by affecting the
surface tension of the oil.

DISPERSING AGENTS ♦ Dispersants contain chemicals which reduce the surface tension
between oil and water and therefore result in the breakup and
dispersal of the slick throughout the water column in the form of an

C-17
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

oil-in-water emulsion. However, the oil IS NOT removed from the

water. •

♦ The basic argument in favor of their use is that dispersion of the

oil will increase the opportunity for oxidation, biodegradation and
other weathering processes and reduce immediate damage to
waterfowl or other wildlife which could be adversely affected by a
surface slick. Dispersants are also used to prevent oil from
adhering to solid surfaces such as piers.

♦ Older dispersants contained a large proportion of inherently toxic

hydrocarbon-based solvents such as kerosene, mineral spirits
and naphtha, which, when applied to an oil slick, increased the
volume of hydrocarbon pollutants present in the water. The major
organic solvents contained in modern dispersants are alchohols,
glycols and glycol ethers. These substances tend to be somewhat
less toxic than the older components.

♦ A variety of equipment such as spray applicators and portable

pumps may be used to apply dispersants to the oil slick. And,
even in the presence of waves, it is often necessary to agitate the
water to facilitate formation of oil-in-water emulsions. Application
of these chemicals without thorough mixing in the surface water is
a waste of time, manpower and cleanup funds.

♦ Dispersants are most effective on unweathered oils with low

viscosities and low pour points in relatively warm water.

♦ Their use is usually considered a last resort in most cleanup

programs since dispersion of oil throughout the water column may
harm a far greater number and variety of organisms than are
affected when the oil is concentrated on the surface.

♦ Advantages:

o Increased oil degradation,

o Less tendency for the oil to form tarry residues,
o Reduced fire hazard with some petroleum products,
o Decreased impact on waterfowl.

♦ Disadvantages:

o Potential toxic effects on aquatic life,

o Increased exposure of organisms to toxic hydrocarbons,
o Lack of knowledge regarding the fate of dispersed oil.

ALL DECISIONS REGARDING THE USE OF DISPERSANTS

ARE MADE AFTER CAREFUL EVALUATION OF THE
SITUATION AND CONSULTATION WITH REGULATORY
AGENCIES.

C-18
 OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

SINKING AGENTS ♦ Special materials can be applied to the oil slick which adsorb the
oil to their surface. The combination of the oil and the sinking
agent is heavier than water, therefore it sinks.

'
C-19
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ Common sinking agents are:

o treated sand
o brick dust
a cement
o silicone-treated materials
o chalk

♦ Large quantities of sinking agents are required in relation to the

size of the slick and it is often difficult to wet the surface of these
materials with oil. Once the oil has adsorbed to the material and
has sunk, there is no guarantee that it will not resurface, perhaps
in other areas which are environmentally more sensitive.

♦ Sinking agents are not particularly effective with low viscosity oils
or when the oil slick is relatively thick.

♦ Like dlspersants, sinking agents may cause considerable damage

to bottom-dwelling organisms, so their use is generally prohibited
by regulatory agencies.

BURNING AGENTS ♦ A substance that will make it possible to ignite the oil on the
surface of the water or upon a shoreline. It creates a buffer
Facilitates "In-Situ" between the oil and the water's surface, which allows for ignition.
burning. Most oils will burn on water or land provided that the oil is thick,
sufficiently emulsified and heated to its ignition temperature.

♦ However, despite the fact that many hydrocarbons are

flammable, this is often difficult since the fire must be kept hot
enough to continually support combustion and must be supplied
with sufficient oxygen. It is virtually impossible to ignite a thin layer
of oil on water because it is cooled by the water beneath it.

♦ Typical agents are:

a Gasoline.
o Light crude oils.

BIOLOGICAL AGENTS ♦ A combination of enzymes, natural organisms and nutrients which

increase the rate of natural degradation of oil. Since it works as a
"natural" process, this method's effectiveness is measured over a
period of many months and years. It is a LONG TERM technique.

GELLING AGENTS ♦ Gelling agents are chemicals which increase the viscosity of the
oil slick and thereby reduce its rate of spread over the water's
surface. Some gelling agents change the oil into cellular-like
foam, while others actually coat the oil with a material having the
consistency of plastic thread.

C-20
OIL SPILL CONTAINMENT & RECOVERY EQUIPMENT

♦ These chemicals are rarely used since the quantities required to

gel an oil are extremely high in relation to the volume of oil, and it
takes at least eight hours before the gel is sufficiently strong to
allow recovery.

Gelling agents are used as a first step for other cleanup methods
(i.e. gelling agent is used on a light oil to thicken it so a skimmer
can remove it from the water's surface).

NEUTRALIZING ♦ Some hazardous materials can be neutralized by applying other

AGENTS materials, neutralizing agents, to the spill, which will react
chemically to form less harmful substances.

For example: Acids neutralized by bases such as sodium

bicarbonate and soda ash.

The neutralization process is also known as CHEMICAL

INACTIVATION.

APPROVAL FOR USE ♦ The OSC has the authority to deploy chemical agents only under
the following circumstances:

- The EPA and state agree to such use, and

- The chemical is listed in the National Contingency Plan
Product Schedule (means the product is approved) - OR -
- The OSC determines that the use of an agent is necessary
when the spill poses is a threat to human life - OR -
- There are previously approved plans authorizing such use.

C-21
TABB OVERVIEW

Introduction When there is an oil pollution incident, cleanup efforts should be

implemented as rapidly as possible to reduce or minimize the
harmful effects of the pollution. Shoreline cleanup or
countermeasures following an oil spill are a critical element in
determining the ultimate environmental impact and cost resulting
from a spill. As with most aspects of spill response, careful
planning can significantly increase the effectiveness of treatment
operations.

Outline This lesson is designed to provide you the information needed to

plan a effective treatment operation and discusses:
Types of Shorelines
♦ Introduction
♦ Seawalls and piers
♦ Exposed wave-cut platforms
♦ Fine~grained saAd·beaches
♦ Coarse-grained sand beaches
♦ Mixed sand gravel (or shell) beaches
♦ Gravel beaches and riprap structures
♦ Exposed tidal flats
♦ Sheltered rocky shores
♦ Sheltered tidal flats
♦ Fringing and extensive salt marshes
Environmental Concerns
♦ Introduction
♦ Human life
Wildlife Resources and Habitats
♦ Introduction
♦ Seawalls and piers
♦ Exposed wave-cut platforms
♦ Fine-grained sand beaches
♦ Coarse-grained sand beaches
♦ Mixed sand gravel (or shell) beaches
♦ Gravel beaches and riprap structures
♦ Exposed tidal flats
♦ Sheltered rocky shores
♦ Sheltered tidal flats
♦ Fringing and extensive salt marshes

C-22
OVERVIEW (cont)

Outline Economical Impact

(cont)
♦ Introduction
♦ Public access
♦ Commercial harvest
♦ Other trades
Commonly Used Cleanup Methods
♦ Introduction
♦ Rocks
♦ Cobble Stone
♦ Sand beaches
♦ Marshes
Recommended Response Activity
♦ Introduction
♦ Seawalls and piers
♦ Exposed wave-cut platforms
♦ Fine-grained sand beaches
♦ Coarse-grained sand beaches
♦ Mixed sand gravel (or shell) beaches
♦ Gravel beaches and riprap structures
♦ Exposed tidal flats
♦ Sheltered rocky shores
♦ Sheltered tidal flats
♦ Fringing and extensive salt marshes
RCRA
♦ Background
♦ Solid Waste Definition
♦ Hazardous Waste Definition
Disposal of Oil
♦ Background
♦ Recycling
♦ In-situ Burning
♦ Incineration
♦ Landfills
♦ Land Farming
♦ State Law

C-23
OVERVIEW (cont)

Outline Hazardous Waste Handlers

(cont)
♦ Generator Definition
♦ Generator Requirements
♦ Hazardous Waste Manifests
♦ Transporter Definition
♦ Transporter Requirements
♦ Accidental Releases
♦ Treatment, Storage, and Disposal Facilities
RCRA Penalties
♦ Civil
♦ Criminal
♦ Federal Facilities

C-24
 TYPES OF SHORELINES

Introduction Before cleanup operations may begin, the area to be cleaned must
be evaluated. This is done by determining:
♦ the type of shoreline,
♦ the degree of exposure to waves and currents,
♦ the associated biological sensitivity, and
♦ the ease of cleanup.
All of these factors are used to determine an Environmental
Sensitivity Index (ESI), which ranks shoreline environments on a
scale of 1 to 10. Generally speaking, areas exposed to high levels
of physical energy such as wave action and tidal currents and have
low biological activity rank low on the scale (1 ); while sheltered
areas associated with high b"1ological activity have the highest
ranking (10). The shoreline ranking system provides a useful first
step in the evaluation process because it identifies the priority
areas that require maximum effort for protection and cleanup. The
ESl is prioritized as follows with 1 being the lowest concern and 10
being the highest concern:
1. Seawalls and piers,
2. Exposed wave-cut platforms,
3. Fine-grained sand beaches,
4. Coarse-grained sand beaches,
5. Mixed sand and gravel (or shell) beaches,
6. Gravel beaches and riprap structures,
7. Exposed tidal flats,
8. Sheltered rocky shores,
9. Sheltered tidal flats,
10. Fringing and extensive slat marshes.

Seawalls Seawalls and piers are divided into two categories:

and Piers
♦ Exposed Wave-Cut Cliffs (1 a)
n The intertidal zone is steep (greater than 30 degrees
slope), with very little width.
n Sediment accumulations are uncommon and usually
ephemeral (lasting a short time), since waves remove the
debris that has slumped from the eroding cliffs.
n They are often found interspersed with other shoreline
types.

,I

C-25
TYPES OF SHORELINES (cont)

Seawalls ♦ Seawalls and Piers (1 b)

and Piers " Are particularly common in developed areas, providing
(cont) protection to residential and industrial developments.
JJ: They are also common along inlets, urbanized areas and
developed beach front sites.
JJ: They are composed of concrete and stone, wooden or metal
bulkheads and wooden pilings.

Exposed ♦ The intertidal zone consists of a flat rock bench of highly

Wave-Cut variable width.
Platforms
♦ The shoreline may be backed by a steep scarp or low bluff.
♦ There may be a narrow, perched beach or gravel to boulder
sized sediments at the base of the scarp.
♦ The platform surface is irregular and tidal pools are common.
♦ Small accumulations of gravel can be found in the tidal pools
and crevices in the platform.
♦ Pockets of sandy "tidal flats" can occur on the platform in less
exposed settings.

Fine- ♦ These beaches are generally flat, wide and hard packed.
Grained
Sand ♦ They are commonly backed by dunes or seawalls along
Beaches exposed outer coasts.
♦ Along sheltered bays, they are narrower, often fronted by tidal
flats.

C-26
; TYPES OF SHORELINES (cont)

Coarse­ ♦ These beaches are moderate to steep, of variable width, and

Grained have soft sediment.
Sand
Beaches ♦ They are commonly backed by dunes or seawalls along
exposed outer coasts.

Mixed Sand ♦ Moderately sloping beach composed of a mixture of sand

and Gravel (greater than 20 percent) and gravel (greater than 25 percent).
(or Shell)
Beaches ♦ The high tide berm area is usually composed of sand or fine
gravel (pebbles to cobbles), whereas the lower part of the
beach is coarser, with cobbles to boulders.
♦ Because of the mixed sediment sizes, there may be zones of
sand, pebbles or cobbles.

Gravel ♦ Gravel beaches are composed of sediment ranging in size from

Beaches pebbles to boulders.
and Riprap
Structures ♦ They can be very steep, with multiple wave built berms forming
the upper beach.
♦ Attached animals and plants are usually restricted to the lowest
parts of the beach, where the sediment are less mobile.
♦ Riprap structures are composed of cobble to boulder size
rocks.
♦ Riprap structures are placed for shoreline protection and inlet
stabilization.

C-27
TYPES OF SHORELINES (cont)

Exposed ♦ Are composed primarily of sand and mud.

Tidal
Flats ♦ The presence of sand indicates that the tidal or wind currents
and waves are strong enough to mobilize the sediment.
♦ They are always associated with another shoreline type on the
landward side of the flat.
♦ The sediments are water saturated, with only the
topographically higher ridges drying out during low tide.

Sheltered ♦ They consist of bedrock shores of variable slope (from vertical

Rocky cliffs to wide rocky ledges) that are sheltered from exposure to
Shores most wave and tidal energy.

♦ The wider shores may have some surface sediment, but the
bedrock is the dominant substrate type.

Sheltered ♦ They are composed primarily of silt and clay.

Tidal
Flats ♦ They are present in calm water habitats, sheltered from major
wave activity and frequently fronted by marshes.
♦ Wave energy is very low, although there may be strong tidal
currents active on parts of the flat and in channels across the
flat.
♦ The sediments are very soft and cannot support even light foot
traffic.

C-26
TYPES OF SHORELINES (cont)

Fringing ♦ Marshes are intertidal wetlands containing emergent,

& Extensive herbaceous (relating to an herb as distinguished from a woody
plant) vegetation
Salt
Marshes ♦ Width of the marsh can vary widely, from a narrow fringe to
extensive.
♦ They are relatively sheltered from waves and strong tidal
currents.

C-29
ENVIRONMENTAL CONCERNS

Introduction Establishing environmental priorities will determine the allocation of

resources and dictate the actions of cleanup personnel throughout the
response. When determining environmental priorities one must keep
in mind the following hierarchy:
1. Human life
2. Wildlife resources and habitats
3. Economical impact

Human Life Human life concerns can be broken down into two categories:
general population and on-site workers.
♦ General population concerns are factors which will affect the
population in the immediate vicinity of the spill. These factors
include:
" Inhalation hazard, i.e. the pollutant is emitting a toxic plume.
You need to know how large of an area will be affected by the
plume and evaluate the need to evacuate.
" Ingestion hazard, i.e. is there a possibility that the pollutant will
affect water on food supplies.
" Skin contact, i.e. does the pollutant pose a threat of absorption
or corrosivity.
" Flammability, i.e. is the pollutant emitting flammable vapors
which pose a threat of fire.
♦ On-site workers concerns are the same factors listed above, but
also include:
" Threat from wildlife in the area,
" Hazards caused by the terrain, such as steep cliffs, and
" Heat and cold stress.

C-30
WILDLIFE RESOURCES AND HABITATS (cont)

Exposed ♦ Oil will not adhere to the rock platform but rather be
Wave-Cut transported across the platform and accumulate along the high
Platforms tide line.
♦ These habitats can support large populations of encrusting
animals and plants with rich tidal pool communities.
♦ Oil can penetrate and persist in the beach sediments, if
present.
♦ Persistence of oiled sediments is usually short term, except in
wave shadows or larger sediment accumulations.

Fine­ ♦ Light oil accumulations will be deposited as oily swashes or

Grained bands along the upper intertidal zone.
Sand
Beaches ♦ Heavy oil accumulations will cover the entire beach surface,
although the oil will be lifted off the beach with the rising tide.
♦ Maximum penetration of oil into fine-grained sand will be 1O
centimeters (cm).
♦ Burial of oiled layers by clean sands within the nex1 few weeks
will be less than 30 cm along the upper beach.
♦ Upper beach fauna (animals as a whole) are scarce.
♦ Organisms living in the beach sands may be killed either by
smothering or by lethal oil concentrations in the water.
♦ Shore birds may be killed if oiled, though they may shift to
clean sites.
WILDLIFE RESOURCES AND HABITATS (cont)

Coarse­ ♦ Light oil will be deposited primarily as a band along the high-
Grained tide line. •
Sand
Beaches ♦ Under very heavy accumulations, oil may spread across the
entire beach face, though the oil will be lifted off the lower
beach with the rising tide.
♦ Penetration of oil into coarse-grained sand can reach 25
centimeters (cm).
♦ Burial of oiled layers by clean sands can be rapid, and up to 60
cm or more.
♦ Burial over one meter deep is possible if the oil comes ashore
at the start of a depositional period (the change from low to
high tide).
♦ Generally, species density and diversity is low.
♦ Biological impacts include temporary declines in infaunal
(aquatic animals living on the substrate) populations, which can
also affect feeding shore birds.

Mixed Sand ♦ During small spills, oil will be deposited along and above the
and Gravel high tide swash.
(or Shell)
Beaches ♦ Large spills will spread across the entire intertidal area.
♦ Oil penetration into the beach sediment may be up to 50
centimeters (cm); however, the sand fraction can be quite
mobile, and oil behavior is much like on a sand beach if the
sand fraction exceeds about 40 percent.
♦ Burial of oil may be deep at and above the high tide line, where
oil tends to persist, particularly where beaches are only
intermittently exposed to waves.
♦ On sheltered beaches, extensive pavements of asphalted
sediments can form if there is no removal of heavy oil
accumulations, because most of the oil remains on the surface.
♦ Once formed, pavements are very stable and can persist for
many years.
♦ Oil can be stranded in the coarse sediments on the lower part
of the beach, particularly if the oil is weathered or emulsified.

C-33
WILDLIFE RESOURCES AND HABITATS (cont)

Mixed Sand ♦ Because of sediment mobility and desiccation (dry out) on

and Gravel exposed beaches, there are low densities of attached animals
(or Shell} and plants.
Beaches (cont)
♦ The presence of atta.ched algae, mussels and barnacles
indicates beaches that are relatively sheltered, with the more
stable substrate supporting a richer biota (animal and plant life
of a particular region).

Gravel ♦ Deep penetration and rapid burial of stranded oil is likely on

Beaches exposed beaches.
and Riprap
Structures ♦ On exposed beaches, oil can be pushed over the high tide and
storm berms, pooling and persisting above the normal zone of
wave wash.
♦ Long term persistence will be controlled by the depth of
penetration versus the depth of routine reworking by storm
waves.
♦ On relatively sheltered beaches, formation of asphalt
pavements is likely where accumulations are heavy.
♦ On riprap structures, deep penetration of oil between the
boulders is likely.
♦ If oil is left uncleaned, it may become asphaltized.
♦ Biota (animal and plant life of a particular region) on the riprap
may be plentiful and varied.
♦ Resident fauna (animals as a whole) and flora (plants as a
whole) may be killed by the oil.

Exposed ♦ Oil does not usually adhere to the surface of exposed tidal flats,
Tidal but rather moves across the flat and accumulates at the high
Flats tide line.
♦ Deposition of oil on the flat may occur on falling tide if
concentrations are heavy.
♦ Oil does not penetrate the water saturated sediments.

C-34
WILDLIFE RESOURCES AND HABITATS (cont)

Exposed ♦ Biological utilization can be very high, with large numbers of

Tidal infauna (aquatic animals living on the substrate) and heavy use
Flats (cont) by birds for roosting and foraging (rummage through for food).
♦ Biological damage may be severe, primarily to infauna (aquatic
animals living on the substrate), thereby reducing food sources
for birds and other predators.

Sheltered ♦ On rocky shores, oil will adhere readily to the rough rocky
Rocky surface, particularly along the high tid.e line, forming a distinct
Shores oil band.
♦ Fractures in the bedrock will be sites of pooling and oil
persistence.
♦ Even on wide ledges, the lower intertidal zone usually stays
wet (particularly when algae covered), preventing oil from
adhering to the rock surface.
♦ Heavy and weathered oils can cover the upper zone with little
impacts to the rich biological communities of the lower zone.
♦ Where surface sediments are abundant, oil will penetrate into
the crevices formed by the surface rubble and pool at the
contact of the sediments and the surface.
♦ Where the rubble is loosely packed, oil will penetrate deeply,
causing long term contamination of the subsurface sediments.
♦ Species density and diversity vary greatly, but barnacles,
snails, mussels, clams, periwinkles (a small marine snail),
amphipods (beach fleas). polychaetes (marine worm),
rockweed and crabs are often very abundant.
♦ Fresh oil and light refined products have high acute toxicities
that can affect attached organisms after even short exposures.

Sheltered ♦ Oil does not usually adhere to the surface of sheltered tidal
Tidal flats, but rather moves across the flat and accumulates at the
Flats high tide line.
♦ Deposition of oil on the flat may occur on a falling tide if
concentrations are heavy.

C-35
WILDLIFE RESOURCES AND HABITATS (cont)

Sheltered ♦ Oil will not penetrate the water saturated sediments at all.
Tidal
Flats (cont) ♦ In areas of high suspended sediments, sorption of oil can result
in contaminated sediments that can be deposited on the flats.
♦ There are usually large populations of clams, worms and
snails.
♦ Bird life is seasonally abundant.
♦ Biological damage may be severe.

Fringing ♦ Oil adheres readily to marsh vegetation.

& Extensive
Salt · ♦ The band of coating will very widely, depending upon the tidal
Marshes stage at the time oil slicks are in the vegetation. There may be
multiple bands.
♦ Resident flora (plants as a whole) and fauna (animals as a
whole) are abundant and consist of numerous species.
♦ Marshes provide a nursery ground for numerous fish species.
♦ Bird life is seasonally abundant.
♦ Large slicks will persist through multiple tidal cycles and coat
the entire stem from the high tide line to the base.
♦ If the vegetation is thick, heavy oil coating will be restricted to
the outer fringe, with penetration and lighter oiling to the limit of
tidal influence.
♦ Medium to heavy oils do not readily adhere or penetrate the
fine sediments, but they can pool on the surface and in
burrows.
♦ Light oils can penetrate the top few centimeter of sediment and
deeply into burrows and cracks (up to one meter).

C-36
ECONOMICAL IMPACT

Introduction Every oil spill has the potential to effect local economies and can
be categorized into three areas:

♦ Public Access
♦ Commercial Harvest
♦ Other Trades

Public When oil has polluted populated regions or areas of recreational

Access use, priorities and pressure for cleanup differ from remote or
uninhabited coastline areas because of:
♦ Local business or boardwalks,
♦ Seasonal recreation such as water skiing or surfing,
♦ Historical tourist sites, or
♦ Scheduled events in the area.
In these cases, the time required for removal of oil by natural
processes may be unacceptable· and active cleanup action may be
required.

Commercial In some situations, shoreline areas are considered particularly

Harvest sensitive to oil and the priority will be to protect these areas based
on productivity. Such areas include:
♦ Kelp beds,
♦ Coral reefs,
♦ Submerged aquatic vegetation,
♦ Anadromous (migrate up river from the sea to breed) fish
spawning streams,
♦ Shellfish seed beds, and
♦ Crab, shrimp and lobster nursery areas.

Other Sometimes during an oil spill cleanup, it may become necessary to

Trades close off areas close to shore to prevent oil from damaging private
property such as recreational boats or to prevent traffic from
entering the spill site causing further contamination. Other trades
that may be affect by this are:
♦ Marinas,
♦ Marine transport such as freight or tank ships,
♦ Maritime facilities, and
♦ Log storage areas.

C-37
COMMONLY USED CLEANUP METHODS

Introduction Methods of cleanup will greatly depend on the type of shoreline,

access to the area and type of equipment available in the area.
Based on the ESI, we can break down the types of shorelines into
four categories:

♦ Rocks,
♦ Cobble Stone,
♦ Sand Beaches, and
♦ Marshes.

Rocks Methods of cleaning rough or porous surfaces such as rocks,

boulders or man-made structures are:
♦ Steam cleaning or high pressure washing. When using this
method, oil may be flushed down into a boom area at the water
edge and collected by a skimmer or vacuum truck .
.♦ Dispersants can sometimes assist in the removal of oil,
although their use should be restricted to areas were water
movement will allow for rapid dilution to prevent damage to
sensitive marine life. Stains can be removed by brushing
dispersants into the oil or by applying it as a gel and then
hosing off the oil/dispersant mixture.

Cobble Stone Methods of cleaning cobble stone and pebbles are:

♦ High pressure flushing: This can be used to flush surface oil to
the waters edge, but some of the oil will be driven into the
beach. This will cause oil to leak out slowly, producing a sheen
in the area over a period of weeks or longer.
♦ Removal of oily stones: This is rarely practical and will usually
only be possible if tracked front end loaders can be used.
Stone removal should only be used if it is certain that it will not
cause serious erosion.
♦ Masking: This is another approach which might be used in
locations subject to winter storms. Stones from higher up the
beach are used to cover the oiled area, thereby providing a
clean surface during the summer for those using the beach.
This can only be used where the beach is moderately oiled.

C-38
COMMONLY USED CLEANUP METHODS (cont)

Sand Very often, sand beaches are regarded as a valuable resource

Beaches and priority is given to cleaning them. Methods of cleaning sand
beaches are:
♦ Mechanical equipment: Recreation beaches often have good
access, allowing mechanical equipment to be used to remove
bulk oil and sand relatively easy, but a desire to clean them
quickly can lead to difficulties. Coarse sand beaches are
frequently unable to support any vehicle without its wheels or
tracks sinking into the sand, causing oil to be mixed further into
the beach.
♦ Flooding: Oil can be released from coarse grained sand by
passing high volumes of water through sections of the beach.
Sea water is drawn through a high capacity pump and
distributed through a number of hoses at low pressure. By
directing the water into a small area of beach, oil can be floated
out and flushed to the waters edge for collection. This method
is slow and limited to the treatment of small areas at a time.
♦ Dispersants: After most of the contaminated beach material
has been removed, that remaining is likely to be very greasy
and discolored. This is not usually sufficiently cleaned for
recreation beaches. Dispersants can be used by applying the
dispersant to the affected beach area and allowing it to sit for
30 minutes before being washed by the incoming tide or hosing
down with sea water.

Marshes Methods of cleaning marshes are:

♦ Low pressure flushing: This can be used to flush surface oil to
open water where it can be contained in a boom and collected.
♦ If birds are threatened, cutting and removing oiled vegetation
might be considered, but must be balanced against long term
damage
Whenever possible, it is preferable to allow oil on this type of
shoreline to weather naturally, particularly where it has been
washed up into the vegetation. It has often been found that
activities intended to clean pollution causes more damage than the
oil itself.

C-39
RECOMMENDED RESPONSE ACTIVITY

Introduction Once the priorities have been established and all environmental
concerns have been addressed, shoreline cleanup can start.
Shoreline cleanup is usually required in three stages:

♦ Stage I - Removal of heavy contamination and floating oil;

♦ Stage II - Cleanup of moderate contamination, such as,
stranded oil and oiled beach material; and
♦ Stage Ill - Cleanup of lightly contaminated shoreline and
removal of stains.
The recommended response activity will depend on the ES! and
the following types of shorelines:
1. Seawalls and piers
2. Exposed wave-cut platforms
3. Fine-grained sand beaches
4. Coarse-grained sand beaches
5. Mixed sand and gravel (or shell} beaches
6. Gravel beaches
7. Exposed tidal flats
8. Sheltered rocky shores
9. Sheltered tidal flats
10. Fringing and extensive slat marshes

Seawalls Exposed Wave-Cut Cliffs (1 a)

and Piers
♦ Cleanup is usually not required.
♦ Access can be difficult and dangerous.

Seawalls and Piers {1b)

♦ High pressure spraying may be required in order to:

u remove oil;
u prepare substrate for recolonization of barnacles and
oyster communities;
n minimize aesthetic damage; and
" prevent the chronic leaching of oil from the structure.

C-40
RECOMMENDED RESPONSE ACTIVITY (cont)

Exposed ♦ Cleanup is usually not required.

Wave-Cut
Platforms ♦ Where the high tide area is accessible, it may be feasible to
remove heavy oil accumulations and oiled debris.

Fine­ ♦ These beaches are among the easiest beach types to clean.
Grained
Sand ♦ Cleanup should concentrate on the removal of oil from the
Beaches upper swash zone after all oil has come ashore.
♦ Removal of sand from the beach should be minimal to avoid
erosion problems; special caution is necessary in areas backed
by seawalls.
♦ Activity through both oiled and dune areas should be severely
limited to prevent contamination of clean areas.
♦ Manual cleanup, rather than road graders and front-end
loaders, is advised to minimize the volume of sand removed
from the shore and requiring disposal.
♦ All efforts should focus on preventing the mixture of oil being
pushed deeper into the sediments by vehicular and foot traffic.

Coarse- ♦ Remove oil primarily from the upper swash lines.

Grained
Sand ♦ Removal of sediment should be limited to avoid erosion
Beaches problems.
♦ Mechanical reworking of the sediment into the surf zone may
be used to release the oil without removal.
♦ Activity in the oiled sand should be limited to prevent mixing oil
deeper into the beach.
♦ Use of heavy equipment for oil/sand removal may result in the
removal of excessive amounts of sand; manual cleanup may be
more effective.

C-41
RECOMMENDED RESPONSE ACTIVITY (cont)

Mixed Sand ♦ Remove heavy accumulations of pooled oil from the upper
and Gravel beach face.
(or Shell)
Beaches ♦ All oil debris should be removed.
♦ Sediment removal should be limited as much as possible.
♦ Low pressure flushing can be used to float oil away from the
sediment for recovery by skimmers or sorbents.
♦ High pressure spraying should be avoided because of potential
for transporting the finer sediment (sand) to the lower intertidal
or subtidal zones.
♦ Mechanical reworking of oiled sediment from the high tide zone
to the upper intertidal zone can be effective in areas regularly
exposed to wave activity. However, oiled sediment should not
be relocated below the mid tide zone.
♦ In place tilling may be used to reach deeply buried oil layers in
the mid beach on exposed beaches.

Gravel ♦ Heavy accumulations of pooled oil should be quickly removed

Beaches from the upper beach.
and Riprap
Structures ♦ All oiled debris should be removed.
♦ Sediment removal should be limited as much as possible.
♦ Low to high pressure flushing can be used to float oil away from
the sediments for recovery by skimmersClit"UlOl>anlw to high pressure flu
♦ Mechanical reworking of oiled sediment from the high tide zone
to the upper intertidal zone can be effective in areas regularly
exposed to wave activity. However, oiled sediments should not
be relocated below the mid tide zone.
♦ In place tilling may be used to reach deeply buried oil layers in
the mid beach on exposed beaches.
♦ It may be necessary to remove heavy oiled riprap and replace
it.

C-42
RECOMMENDED RESPONSE ACTIVITY (cont)

Exposed ♦ Currents and waves can be very effective in natural removal of

Tidal the oil.
Flats
♦ Cleanup is very difficult (and possible only during low tides).
♦ The use of heavy machinery should be restricted to prevent
mixing of oil into the sediments.
♦ On sand flats, oil will be removed naturally from the flat and
deposited on the adjacent beaches where cleanup is more
feasible.

Sheltered ♦ Low to high pressure spraying at ambient water temperatures

Rocky is most effective when the oil is fresh.
Shores
♦ Extreme care must be taken not to spray in the biological rich
lower intertidal zone or when the tidal level reaches that zone.
♦ Cutting of oiled, attached algae is not recommended; tidal
action will eventually float this oil off, so sorbent boom should
be deployed.

Sheltered ♦ These are high priority areas necessitating the use of spill
Tidal protection devices to limit oil spill impact; deflection or sorbent
Flats booms and open water skimmers should be used.
♦ Cleanup of the flat surface is very difficult because of the soft
substrate and many methods may be restricted.
♦ Manual operations and deployment of sorbents from shallow
draft boats may be helpful.

C-43
RECOMMENDED RESPONSE ACTIVITY (cont)

Fringing ♦ Under light oiling, the best practice is to let the area recover
& Extensive naturally.
Salt
Marshes ♦ Heavy accumulations of pooled oil can be removed by vacuum,
sorbents or low pressure flushing. During flushing, care must
be taken to prevent transporting oil to sensitive areas down
slope or along shore.
♦ Cleanup activities should be carefully supervised to avoid
vegetation damage.
♦ Any cleanup activity must not mix the oil deeper into the
sediments. Trampling of the roots must be minimized.
♦ Cutting of oiled vegetation should be considered when other
resources present are at great risk from leaving the oiled
vegetation in place.

C-44
RCRA

Background RCRA - Resource Conservation and Recovery Act remodeled solid

waste management and added hazardous waste management in
1976. RCRA was expanded significantly in 1984 by the Hazardous
and Solid Waste Amendments. RCRA has basically three goals:
♦ Protect human health and the environment.
♦ Reduce the amount of waste and conserve energy and natural
resources.
♦ Reduce or eliminate generation of hazardous waste as
expeditiously as possible.

RCRA can be divided into four separate, but interrelated, programs.

They are:
♦ Solid Waste Program (Subtitle D)
♦ Hazardous Waste Program (Subtitle C)
♦ Underground Storage Tank Program (Subtitle I)
♦ Medical Waste Program (Subtitle J)
The objectives of Subtitle C (hazardous Waste Programs) are to
control or manage hazardous waste from generation to disposal;
i.e. from "cradle to grave."

Solid The following are considered to be solid waste:

Waste ♦ Garbage
Definition ♦ Refuse
♦ Sludge
♦ Any other discarded material including solid, semisolid, liquid,
or contained gaseous material. Not all solid waste is actually
solid.
The following materials are not considered to be solid wastes:
♦ Domestic sewage
♦ Industrial wastewater discharges
♦ Irrigation return flows
♦ Nuclear materials

C-45
RCRA (cont)

Hazardous A Hazardous Waste is a solid waste that is not excluded, and

Waste meets one of the following criteria:
Definition ♦ Exhibits any of the following characteristics of a hazardous
waste:
" Corrosivity
" Reactivity
" lgnitability
" Toxicity

♦ Is named and listed as a hazardous waste in regulation:

" Nonspecific Source Waste (40 CFR 261.31) i.e. Dioxin
wastes
o Specific Source Waste (40 CFR 261.32) i.e. Wastewater
treatment sludge from pigment production
" Commercial Chemical Products (40 CFR 261.33) i.e.
Chloroform, DDT
♦ Is a mixture containing a listed hazardous waste and a non-
hazardous solid waste.
Used oil, i.e. recovered oil and oily debris destined for disposal, is
not listed as a hazardous waste. However, if the oil exhibits any of
the characteristics of a hazardous waste, i.e. corrosivity, reactivity,
ignitability, or toxicity, then it meets the definition of a hazardous
waste and full RCRA requirements apply.

C-46
DISPOSAL OF OIL

Background The disposal of recovered oil and oily debris from spill response
operations has traditionally been one of the most difficult aspects of
a response. Disposal options for oil and oily debris should be
researched for your area during the planning process. Various oil
disposal options consist of:
♦ Recycling
♦ In-Situ Burning
♦ Incineration
♦ Landfills
♦ Land Farming

Recycling The recycling of used oil is the preferred method of disposing

waste oil recovered from spill response operations. Recycling
includes using recovered oil to be blended with fuel oils for burning
and for use in asphalt batching. Used oil destined for recycling or
burning for energy recovery should be subject to a system of
management standards, which are somewhat more lenient than full
waste requirements. These standards consist of:
♦ Labeling all used oil storage tanks and containers as "Used Oil";
♦ Clean up any used oil spills or leaks;
♦ Use only transporters with EPA ID numbers when shipping off­
site; and
♦ Track used oil shipments.

In-Situ In-Situ burning is the burning of oil and oily debris on-site in lieu of
Burning attempting recovery. In cases where marshes or other
environmentally sensitive areas have been impacted, in-situ
burning may be the only feasible response option. However, before
in-situ burning can take place, approval, or in some cases even a
permit, must be obtained from the state.

Incineration High temperature incineration can generate the high temperatures

needed for the total combustion of oily waste. This incineration
usually takes place at permitted TSO (Temporary Storage Disposal)
facilities, but portable incinerators have been developed for on-site
use. Incineration can be a costly disposal option, but may be
preferred over landfill disposal.

C-47
DISPOSAL OF OIL (cont)

Landfills Although landfills are still a common disposal method, their use is
becoming increasingly difficult due to many states now regulating
recovered oil and oily debris as a hazardous waste. In any case,
recovered oily debris destined for a landfill site must be free of any
free standing liquids that may separate from the solid debris.

Land Farming Land farming is the spraying of recovered oil in a fine mist over a
large area of land and then tilling the oil into the soil. Although it
may take up to three years for the oil to break down in the soil,
nutrients such as ammonium phosphate can be app\led to enhance
this process. The option is only feasible for small :spills as the
amount of land required is significant. the land should have low
value, and has to be located away from potable water supplies.

State Law In selecting any disposal option, it is important to consult with state
environmental representatives to ensure the disposal option you
wish to use is acceptable and within state law requirements.

C-48
HAZARDOUS WASTE HANDLERS

Introduction RCRA Subtitle C regulates three categories of hazardous waste

handlers. They ar~:
♦ Generators
♦ Transporters
♦ Treatment Storage and Disposal Facilities (TSDFs)

Generator Generators are the first link in the "Cradle to Grave" chain of
Definition hazardous waste management. A generator is any owner.
operator, or person who first creates a hazardous waste or the
person who makes the waste subject to subtitle C regulation.
There are three categories of generators:
♦ Large Quantity - Creates a quantity of waste greater than 1,000
kg per month or greater than 1 kg per month of acutely
hazardous waste.
♦ Small Quantity - Creates a quantity of waste greater than 100
kg per month and less than 1 kg per month of acutely
hazardous waste.
♦ Conditionally Exempt - Creates a quantity of waste less than
100 kg per month and less than 1 kg per month of acutely
hazardous waste.

Generator Large and small generators must comply with the regulations found
Requirements in 40 CFR 262. These regulations require that they:
♦ Determine that a solid waste is hazardous;
♦ Obtain an EPA Identification Number;
♦ Prepare the waste for transportation IAW 49 CFR;
♦ Follow accumulation and storage requirements;
♦ Meet record-keeping and reporting requirements; and
♦ Properly manifest the shipment IAW 40 CFR 262, using a
hazardous waste manifest.

Hazardous Uniform hazardous waste manifesting is the key to managing

Waste hazardous waste "from the cradle to the grave." Through the use of
Manifest manifests, generators can track the movement of the waste from
the point of generation to the point of ultimate treatment, storage, or
disposal. The manifest must contain the following information:

C-49
HAZARDOUS WASTE HANDLERS (cont)

Hazardous ♦ Name and EPA ID number of the generator, transporter, and

Waste TSD facility;

Manifest ♦ The proper DOT shipping description of the waste;

♦ The address of the TSD facility; and

♦ The Hazardous and Solid Waste Amendments certification.

NOTE: If a Federal, state or local official determines that the

immediate removal of a waste is necessary to protect human
health or the environment, the official can authorize waste removal
without the use of the manifest by a transporter lacking an EPA ID
number.

C-50
 HAZARDOUS WASTE HANDLERS (cont)

Transporter ATransporter is any person engaged in the off-site transportation

Definition of manifested hazardous waste by air, rail, highway, or water, and
is the critical link between the generator and the TSD facility.

Transporter Transporters must meet the requirements found in 40 CFR 263.

Requirements These requirements include:
♦ Obtaining an EPA Identification number;
♦ Complying with the manifesting system; and
♦ Handling of accidental hazardous waste discharges.
♦ In addition, all transporters must meet the requirements of each
State that they intend to travel through.

Accidental If an accidental release of a hazardous waste occurs during

, Releases transportation, the transporter must:
♦ Take immediate action to protect health and the environment;
♦ Notify the National Response Center;
♦ Notify the Center for Disease Control if the release involves a
disease causing agent; and
♦ File a report with the DOT within 15 days of the release.

TSO A TSD facility is a permitted facility that accepts hazardous waste

Facilities for treatment, storage, or disposal; i.e. landfills and high­
temperature incinerators. It is the final link in the "cradle to grave"
management system. A TSD facility must meet extensive
requirements under 40 CFR 264 that outline design and operating
criteria as well as performance standards. In addition, a TSD
facility must:
♦ Return the manifest to the generator, completing the manifest
loop;
♦ Ensure that the waste described on the manifest is the waste
actually on the truck; and
♦ Keep operating records, make biennial reports, submit reports
on releases, groundwater monitoring results, and closures.

C-5
RCRA PENALTIES

Civil A generator, transporter or TSD facility found not to be in

compliance with applicable RCRA regulations may be fined up to
$25,000 per day of continued noncompliance.

Criminal Any violator who knowingly generates transports, treats, stores, or

disposes of any hazardous waste in violation of AGRA is subject to
a line of not more than $50.000 for each day of violation to a
maximum of $1,000,000, or imprisonment not to exceed five years-.
or both.

Federal In accordance with the Federal Facilities Compliance Act passed in

Facilities October 1992:
♦ States can fine and penalize federal facilities for violations of
solid and hazardous waste laws.
♦ Federal employees are protected from civil penalties when
acting within scope of their duties.
♦ Federal employees are subiect to criminal penalties for
knowingly violating laws regarding responsible waste handling
practices.

Note In criminal prosecutions, typically the government will not provide

legal representation because conduct which forms the basis for
criminal charges is almost always found to have been committed
outside the scope of duty.

C-52
TAB C OVERVIEW

Introduction You may encounter various types of oils and petroleum products
during pollution response activities. It is imperative that you
become familiar with the physical, chemical, and toxic properties of
oil and how these properties change when oil is released into the
environment. The physical and biological effects of an oil spill as
well as the behavior of the slick and the efficiency of various
cleanup methods are strongly influenced by the type of oil spilled.
The properties of the oil will help you to determine the oil's potential
health hazards along with the most practical cleanup techniques in
order to develop an effective response plan and, more importantly,
to take the proper safety precautions for yourself and the people
that work for you.

Outline This lesson is designed to give you a general overview of:

Sources and Composition of Oil

♦ Chemical composition of Oil
♦ Crude Oils
♦ Sources of spill

Physical and Chemical Properties of Oil

♦ Introduction
♦ Boiling Point
♦ Viscosity
♦ Specific Gravity
♦ Melting point

Toxic Properties of Oil

♦ Introduction
♦ Benzene content
♦ Sulfur content
♦ Skin hazards

Weathering Processes of Oil

♦ Background
♦ Illustration
♦ Spreading
♦ Evaporation
♦ Emulsification
♦ Dispersion

C-53
SOURCES AND COMPOSITION OF OIL

Chemical Petroleum Oil is composed of hydrogen and carbon linked in many

Composition different forms of chains and rings (petroleum hydrocarbons) and
of Oil may also contain small amounts of oxygen, sulfur, nitrogen, and
mineral salts. These complex chains determine the physical,
chemical, and toxic properties of the oil.

Crude Oils Crude oils are the most chemically complex type of petroleum oils.
Hundreds of different chemicals are found in any crude oil and each
oil well produces its own unique blend of these chemicals. Crude
oils are source oils used to produce, through distillation, many other
refined oils and petroleum products including:
So in essence ♦ Gasoline
crude oils contain ♦ Jet fuel (JP4)
the chemical ♦ Naphthas
characteristics ♦ Kerosene
of many oils. ♦ Diesel fuel oils (#2 fuel oil)
♦ Fuel Oils (Bunker C and #6 fuel oil)
♦ Lubricating oils
♦ Residuum (asphalts, tar)

Sources An estimate of the total petroleum oil introduced into the

of Oil Spills environment (land, sea and air) is about 3.2 million metric tons
(25,600,000 barrels) per year. The biggest contribution comes from
land sources such as industrial and municipal wastes. There are
six major ways oil enters the environment:
♦ Industrial discharges and city runoff (37%)
♦ Vessel operations (operational discharges of oily slops) (33%).
These are cargo residues dumped, both legally and illegally,
during tank cleaning and de-ballasting operations, as well as
discharges of oily bilge water and fuel oil sludges. These can be
controlled by strict management practices and regulatory
requirements. That is why we have MARPOL ANNEX I "Vessel
and Facility Requirements". We also need adequate shore
reception facilities for these slops.

C-54
SOURCES AND COMPOSITION OF OIL (cont)

Sources ♦ Tanker accidents during routine operations and

of Oil Spills collisions/groundings (12%) (loading, discharging and bunkering)
(cont)
♦ Atmosphere (9%) The main portion can be linked to exhaust
fumes from road vehicles.
♦ Natural sources (seepage and erosion) (7%) Seeps are
associated with areas of tectonic activity (This is the structural
deformation in the earth's crust caused by the constant shifting
of the earth's plates.)
♦ Offshore oil exploration and production (2%)
" large release (blowouts)
o small release (disposal of oil-based drilling muds)

C-55
PHYSICAL AND CHEMICAL PROPERTIES OF OIL

Introduction Crude oils of different origins have a wide range of physical and
chemica.1 properties, whereas the refined oil products have more
well-defined properties irrespective of the crude oil from which they
are derived. Physical and chemical properties of petroleum oil
defined and discussed below include:
♦ Boiling Point
♦ Viscosity
♦ Specific Gravity
♦ Melting Point

Boiling Boiling Point is the temperature at which a liquid boils. Low boiling
Point point liquids are more volatile and will evaporate faster. Crude oil
can be separated into its chemical components (cuts in a fractional
distillation column based on the boiling points of these
components). As the temperature of the crude oil is raised,
different components reach their boiling point and in turn are
distilled out, with the lower boiling point components rising towards
the top of the column and the higher boiling point components
settling towards the bottom of the column.

Note: The boiling point is what separates the crude into different refined
oils.

C-56
PHYSICAL AND CHEMICAL PROPERTIES OF OIL (cont)

Illustration The illustration below shows a fractional distillation column.

Low bolllng points= light ends

{Gasoline)

High Bolling Pt. = Low Ends

(Asphalt)

lllSIGllUM

<'•UDC STRll',.NO;
STUA>I

Example The hazards of a cleanup can be indicated by the boiling point

of a product. Gasoline has a low boiling point and is more
hazardous then asphalt which has a high boiling point.

Viscosity Viscosity is a measurement of a liquid's resistance to flow. High

viscosity oils flow with difficulty while those with low viscosities are
highly mobile. Viscosity is affected by ambient water and air
temperature. As the temperatures increases, viscosity decreases.
Some examples are:
♦ Water - Low viscosity
♦ Honey - Hi viscosity
♦ Gasoline - Low viscosity
♦ #6 fuel oil - Hi viscosity

C-57
PHYSICAL AND CHEMICAL PROPERTIES OF OIL (cont)

Viscosity Units for viscosity vary based on measurement method, but are
(cont) commonly reported as centistokes (cS1) at 38° C (100.4° F).
Viscosity is an important property for determining appropriate oil
recovery techniques.
Example: What type of sorbent materials would be better to use on a spill?
Absorbents distribute the material taken up throughout the body of
the absorbing material. They work better on light to medium
viscosity oils.
Adsorbents distribute the material on the surface of the adsorbing
material. It is generally considered that adsorbents work better on
high viscosity oils.

Specific Specific Gravity represents a liquid's density in relation to pure

Gravity (S.G.) water and has no unit.
Note The specific gravity of water is 1.0.
♦ S.G. < 1 .0 Oil floats on water
♦ S.G. > 1.0 Oil sinks in water

Melting Melting point represents the temperature below which an oil will not
Point flow due to its paraffin wax content. The greater the wax content,
the higher its Melting point. Melting point reveals the physical state
of the oil. (liquid or solid)
Melting point tells us whether the oil will act as a solid or a liquid.
Melting point is one of the most important properties in terms of
impact to the shoreline and subsequent cleanup techniques.
Note II ambient temperature < Melting point, oil will behave as
solid/semi - solid. This will prevent an oil such as # 6 heating oil
from dispersing and cleanup may consist of using pitchforks and
shovels to remove the product from the water.

Melting point also determines the pumping temperatures needed for

moving the oil through a pipeline or transfer system.
Example Heavy oils with high Melting points such as asphalt need to be
heated via steam lines to be transferred from a ship to a facility.

C-58
TOXIC PROPERTIES OF OIL

Introduction Petroleum oils may pose health hazards through inhalation or skin
contact due to the toxicity of any chemical components within the
oil. This is why we must consider the use of personal protective
equipment (tyvek suits and respirators) for the safety ofcleanup
personnel. The most common toxic properties of petroleum oil
defined and discussed below are:
♦ Benzene content
♦ Sulfur content
♦ Skin hazards

Benzene Different petroleum oils contain varying concentrations of liquid

Content benzene as a chemical component. Benzene is an inhalation
hazard at certain oil spills because it has a high vapor pressure
relative to very low exposure limits and it is a known human
carcinogen. This is another reason we would want to check the
atmosphere we will be working in and wear the appropriate
personal protective equipment to ensure our safety.

Sulfur Sulfur content reveals important toxicity hazards about the oil;
Content specifically, hydrogen sulfide hazards. The amount of sulfur (by
weight percentage) in a crude oil determines whether it is labeled
as "sweee or 11sour" crude oil:
♦ Sweet crude has a Low sulfur content and
♦ Sour crude has a High sulfur content

Sour crude oils pose a serious health hazard because the High
sulfur components generate toxic hydrogen sulfide gas which has
an odor of rotten eggs. A human's nose can become desensitized
after initial inhalation of hydrogen sulfide, making it extremely
hazardous. Once we stop smelling it, we do not realize we are still
being exposed to its toxic effects.

NOTE Measuring devices like a Draeger Multi Gas Detector and detection
tubes that determine the presence of hydrogen sulfide gas are
critically important so we can take the proper safety measures such
as wearing a respirator or other personal protection.

RULE OF >2% SULFUR = SOUR CRUDE

THUMB 5% - 6% SULFUR= HIGH SOUR CRUDE

C-59
TOXIC PROPERTIES OF OIL (CONT)

Skin Crude oils and certain oils (asphalts and tar) contain
Hazards several chemical solvents considered to be "defatting agents."
These chemicals in essence remove the natural oils in our skin and
cause it to dry out , crack and peel. This is a very painful. When
these solvents contact the skin they can cause direct skin irritation
leading to painful damage known as "contact dermatitis." These
oils also contain chemical compounds of hydrocarbons known to
cause skin cancer upon prolonged or repeated (chronic) contact
with the skin. This carcinogenic process may be accelerated
greatly by exposure to ultraviolet rays from the sun, which
underscores the need for workers to have adequate skin protection
on cleanups to prevent exposure to this type of potential cancer
causing agent. This would include the use of tyvec suits and
gloves.
WEATHERING PROCESSES OF OIL

Background Weathering of oil represents the physical and chemical processes

which oil undergoes upon release into the environment. The most
important weathering processes for a responder to understand
during the early stages of an oil spill include:
♦ Spreading .. .
♦ Evaporation - (Most predominant for short term duration)
♦ Emulsification
♦ Dispersion
Oxidation, sedimentation, dissolution, and biodegradation are long­
term weathering processes which determine the ultimate fate of oil.

Illustration The illustration below shows the weathering processes.

EVAPORATION

•. ~ OISSOUJTION
~~:JS ~ A N D 8IOOEGRAOATION
;:,;•:'.?! ,,
._... :

C-61
WEATHERING PROCESSES OF OIL (CONT)

Spreading· Spreading is one of the most significant processes during the early
stages of a spill. It is dependent on the oil's weight, viscosity,
melting point, as well as the weather and sea state. High viscosity
oils spread very slowly and those spilled at temperatures below
their melting point barely spread at all. Low viscosity oils spread
rapidly. After a few hours, the slick begins to break up and form
narrow bands parallel to the wind direction. At this stage, the
fluidity of the oil becomes less important since further spreading is
primarily due to winds, weather and turbulence at the sea surface. It
should be appreciated that except in the case of small spills of low
viscosity oils, spreading is not uniform and large variations of oil
thickness occur within the slick.

Example: A large quantity of oil spilled at a fast rate will spread more rapidly
than a large quantity of oil spilled at a slow rate,

Time is an important factor in cleanup operations. As more time

elapses, the amount of recoverable oil becomes less and less
because of spreading.

Evaporation Evaporation accounts for the largest proportion of volumetric loss of

oil after a spill. It is the single most important weathering process
that affects the oil's characteristics. Toe following are influencing
factors that affect evaporation rates:
♦ Higher API gravity oils have higher evaporation rates due to
higher concentration of low boiling point volatile components
[light endsl(gasolines, kerosenes, benzene).
♦ The greater the oil spread rate, the greater the evaporation rate
due to larger oil surface area.
♦ The greater the seas and wind speeds, the greater the
evaporation rate.
♦ The greater the ambient temperatures, the greater the
evaporation rate.

Note It is estimated that approximately 30% - 80% of spilled product can

be lost to evaporation. A higher% is lost by light crudes, gasolines
etc.. A lower % is lost by heavy crudes and heavy refined oils like
#6 oil, etc..

C-62
WEATHERING PROCESSES OF OIL {CONT)

Emulsification Many oils tend to absorb and mix with water to form emulsions
which can increase the total amount of pollutant by a factor
between 3 and 4. Such emulsions possess a high viscosity and
thus retards the other processes which would dissipate the oil.
Rough sea conditions increase the emulsification process. This
causes a change in the original oil's properties. Absorption of water
usually results in black oil changing color to brown, orange or
yellow. As the amount of water absorbed increases, the density of
the emulsion approaches that of sea water.

Note This can effect the type of cleanup method used to remove the oil
from the water.

Example Sorbents do not work well on emulsified oil because of the oil water
mixture. You would be better off employing skimmers and vacuum
trucks to remove the oil water mixture.

Dispersion Dispersion occurs when waves and turbulence at the sea surface
act on the stick to produce oil droplets with a range of sizes. Small
droplets remain in suspension while the larger ones rise back to the
surface where they reform the stick. Droplets small enough to
remain in suspension become mixed in the water column and the
increased surface area presented by this dispersed oil can enhance
other tong term processes such as biodegradation and
sedimentation. Rough sea conditions (breaking waves) increase
the rate of natural dispersion. High viscosity oils or those that form
stable emulsions tend to form thick tenses on the water surface and
show tittle tendency to disperse. They can persist for several
weeks. Low viscosity oils which remain fluid and can spread
unhindered may disperse completely in moderate sea conditions
within a few days.

Note This effects recovery in that:

♦ If we are dealing with a tow viscosity oil and the cleanup effort is
not immediate, there will be very tittle if any oil to recover.

♦ If it is a high viscosity oil that is spilled even though some time

has elapsed, there may still be a fair amount of oil to recover.

The end result is that dispersion hinders cleanup efforts and makes
time an important factor in cleanup efforts.

*U.S. G.P.0,:1994-301-717:45
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