annex f appendix i â€“ arrt oil dispersant guidelines

ARRT Oil Dispersant Guidelines/Preauthorization Plan - Draft Revision: 7-30-12

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ANNEX F APPENDIX I – ARRT OIL DISPERSANT GUIDELINES/PREAUTHORIZATION PLAN FOR ALASKA This document is also available on the Alaska Regional Response Team website at:

http://alaskarrt.org/ or at the Alaska Department of Environmental Conservation website at:

http://dec.alaska.gov/spar/perp/plans/uc/Annex%20F%20(Jan%2010).pdf


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Table of Contents

SECTION 1.0 Introduction ......................................................................................................................... 3

SECTION 2.0 Background ......................................................................................................................... 3

SECTION 3.0 Alaska Dispersant Use Policy ............................................................................................. 6

SECTION 4.0 Dispersant Application and Decision Process .................................................................... 7

PART 1.0 Summary of Decision-Making Process for Dispersants Use…………………………...5 PART 2.0 Dispersant Use Application…………………………………………………………….7 PART 3.0 Incident-Specific Resources at Risk…………………………………………………..10 PART 4.0 Procedure for Incident-Specific Collaboration for Dispersant Use Decision-Making..12 PART 5.0 FOSC Dispersant Use Decision Checklist…………………………………………….13 PART 6.0 Agency Dispersant Use Decision Document………………………………………….16

SECTION 5.0 Dispersant Use Zones for Alaska ...................................................................................... 20

SECTION 6.0 Guidelines For Dispersant Use in Cook Inlet ................................................................... 22

SECTION 7.0 Guidelines For Dispersant Use in Prince William Sound ................................................. 28

FIGURES

Figure 1 Conceptual Spill Response Decision Chart ................................................................................ 5 Figure 6.1 Cook Inlet Dispersant Use Zones: Northern Sector ................................................................ 24 Figure 6.2 Cook Inlet Dispersant Use Zones: East Foreland ................................................................... 25 Figure 6.3 Cook Inlet Dispersant Use: Drift River Tanker Loading Terminal ........................................ 26 Figure 6.4 Cook Inlet Dispersant Use: Southern Sector ........................................................................... 27 Figure 7.1 Prince William Sound Dispersant Use Zones: Valdez Port .................................................... 31 Figure 7.2 Prince William Sound Dispersant Use Zones: Main Body ..................................................... 32 Figure 7.3 Prince William Sound Dispersant Use Zones: Copper River Delta ........................................ 33

TABS

TAB A Summary Analysis of Dispersants on the NCP Product Schedule ..............................................

TAB B Special Monitoring of Applied Response TechnologiesProtocols ..............................................

TAB C Dispersant Use After-Action Report ...........................................................................................


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1.0 INTRODUCTION This appendix contains the Oil Dispersant Guidelines/Preauthorization Plan for Alaska and specific guidelines for Cook Inlet and Prince William Sound. The overall (Statewide) guidelines and guidelines specific to Cook Inlet were approved by the Alaska Regional Response Team (ARRT) in April 1986. The specific guidelines for Prince William Sound were approved by the ARRT on March 6, 1989. The current document, which is in effect for all marine waters in Alaska, was approved by the ARRT on ______________________. The guidelines are subject to periodic review and update by the ARRT. This appendix outlines the process to be used in Alaska following an oil discharge when dispersant use is requested. The purpose of this appendix is to streamline and expedite the decision-making process. 2.0 BACKGROUND The capability to adequately respond to an oil spill in Alaska can be hampered by the great distances involved, poorly developed transportation networks, an inadequate labor force, limited mechanical spill cleanup technology, and severe weather conditions. The use of oil dispersing chemicals provides a supplemental response method to existing conventional cleanup techniques, which include mechanical recovery and in-situ burning. See Figure 1 for a conceptual marine spill response decision chart. Dispersants are chemical agents (i.e., surfactants, solvents, and other compounds) that enhance the natural process of dispersion by generating larger numbers of small droplets of oil that are entrained into the water column by wave action. Oil spill dispersants do not actually reduce the total amount of oil entering the environment. Rather, they change the inherent chemical and physical properties of oil, thereby changing the oil’s transport, fate, and potential effects. The objective of dispersant use is to reduce the potential that a surface slick will contaminate shoreline habitats or come into contact with birds, marine mammals, or other organisms that exist on the water surface or shoreline. Decisions to use dispersants involve trade-offs between decreasing the risk to water surface and shoreline habitats while increasing the potential risk to organisms in the water column and on the seafloor. This trade-off reflects the complex interplay of many variables, including (but not limited to) the type of oil spilled, the volume of the spill, sea state and weather, water depth, water temperature, water salinity, degree of turbulence, presence and relative abundance and life stages of potentially-affected wildlife and marine organisms, and the use of those resources. As noted by the National Academy of Sciences1 review of ongoing research on the use of dispersants as an oil spill response technique and the impact of dispersed oil on marine and coastal ecosystems, there are many uncertainties regarding the efficacy and toxicity of dispersant use. Dispersant use is controversial because Alaskan marine waters support valuable commercial, subsistence, and recreational fisheries; large and important populations of birds and marine mammals; and significant oil, transportation, and tourism industries. Key questions to answer during the dispersant use decision-making process: Will the selected dispersant work effectively on the oil spilled and in the given circumstances? Can the dispersant be safely applied to the oil without interfering with other response actions? Do the environmental trade-offs support the use of the dispersant in the given circumstance?

The National Oil and Hazardous Substance Pollution Contingency Plan (NCP) (Section 300.910(a)) provides for Regional Response Teams (RRTs) and Area Committees to prepare, and include in regional and/or area plans, dispersant preauthorization plans, which require the approval of “…the RRT representatives from EPA [U.S. Environmental Protection Agency] and the states with jurisdiction over the waters of the area to which a preauthorization plan applies and the DOC [U.S. Department of

1 Oil Spill Dispersants Efficacy and Effects. 2005. National Academy of Sciences, available at: http://dels.nas.edu/resources/static‐assets/materials‐based‐on‐reports/special‐products/oil_spill_dispersants_key_findings_final.pdf


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Commerce] and DOI [U.S. Department of the Interior] natural resource trustees.” The NCP also states that “...preauthorization plans may address factors such as the potential sources and types of oil that might be spilled, the existence and location of environmentally sensitive resources that might be impacted by spilled oil, available product and storage locations, available equipment and adequately trained operators, and the available means to monitor the product application and effectiveness.” This document constitutes a preauthorization plan agreement adopted by the ARRT, but is not the final decision to apply a dispersant, which will be made by the Federal On-Scene Coordinator (OSC) during an incident. One final note, the Government Accountability Office, in a May 2012 report stated: “Every oil spill is different, and the conditions—such as weather, oil type and volume, currents, and location—surrounding any unanticipated release of oil into the ocean are highly variable. Given this variability, no one study can account for all the potential permutations.”2

2 Oil Dispersants: Additional Research Needed, Particularly on Subsurface and Arctic Applications. 2012. U.S. Government Accountability Office. A Report to Congressional Requestors. GAO-12-585.


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3.0 ALASKA DISPERSANT USE POLICY The primary method for cleaning up oil shall be the mechanical removal of oil from the water

surface. The use of dispersants is intended to augment mechanical response rather than substitute for it. However, no single response method will be 100 percent effective, thereby establishing a need to consider the use of all available methods from the start of the spill response. Initially, the assumption should be that all three methods (mechanical recovery, in-situ burning, and dispersant use) may be appropriate and then adjustments made as information concerning the spill is received by the UC and appropriate approvals are granted.

Dispersant use zones shall be established for certain parts of the marine waters of Alaska, as appropriate. At this time pre-identified zones have been established for Cook Inlet and Prince William Sound. See sections 5.0 and 6.0 for a description of these zones.

The use of dispersants shall be based on an incident-specific evaluation of the operational feasibility and the trade-offs between the likely impacts of dispersants and dispersed oil and non-dispersed oil on the environment and human-use areas.

All requests for dispersant use shall follow the process defined in Section 4.0.

Depending on the timing and need to move quickly, as soon as the Applicant notifies the Federal OSC of their intention to prepare and submit a completed Part 2: Dispersant Use Application (Application), the Applicant shall begin mobilizing equipment, materials, and personnel to implement the dispersant use plan to be proposed in the Application.

Input on the decision to use dispersants shall be provided to the Federal OSC within the timeframe requested by the Federal OSC.

Dispersant delivery platforms shall not be used in such a manner that interferes with other response operations.

A field test(s) to determine the operational, chemical, and hydrodynamic effectiveness of oil dispersion under existing conditions shall be conducted and evaluated prior to any continued application of dispersants. At a minimum, the field test shall include Special Monitoring of Applied Response Technologies (SMART) Tier 1 and Tier 2 protocols (see TAB B).

For every dispersant application, the Federal OSC (in cooperation with the UC) shall ensure that monitoring is conducted to determine the operational, chemical, and hydrodynamic effectiveness of dispersant use. The resulting information shall be analyzed and used on a daily basis to determine whether dispersant application(s) shall continue, be modified, or cease.

Monitoring for operational, chemical, and hydrodynamic effectiveness of dispersant use shall be conducted by agency representatives or an independent third party acceptable to the UC and the natural resources trustees.

N N


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4.0 DISPERSANT APPLICATION AND DECISION PROCESS

Part 1: Summary of Decision-Making Process for Dispersant Use The following information outlines the incident-specific process to be followed when the application of dispersants on the surface of marine waters is being proposed as a response option for an oil spill:

1. The Applicant notifies the Federal On-Scene Coordinator (OSC) of their intention to prepare and submit an Application (see Part 2). Depending on the timing and need to move quickly, the Applicant begins mobilizing equipment, materials, and personnel to implement the dispersant use plan to be proposed.

2. The Federal OSC immediately notifies the following entities of the Applicant’s intent to submit an Application:

State OSC

U.S. Environmental Protection Agency (EPA) Alaska Regional Response Team (ARRT) representative

U.S. Department of the Interior (DOI) ARRT representative

U.S. Department of Commerce (DOC) ARRT representative

Representative of appropriate Federally-recognized tribes

Representatives of appropriate stakeholder groups (e.g., local government, Native corporation, regional citizens’ advisory councils)

USCG Strike Team/ Special Monitoring of Applied Response Technologies (SMART) Team

3. Depending on the timing and need to move quickly, the Federal OSC mobilizes the Strike Team/ SMART Team (or notifies the other agreed-upon team) who will conduct dispersant effectiveness monitoring.

4. The National Oceanic and Atmospheric Administration (NOAA) Scientific Support Coordinator (SSC) and Environmental Unit staff (in coordination with the Operations Section) provide any necessary supporting information (e.g., ADIOS model runs and information on dispersibility, currents, water temperature, and fish and wildlife observations) required in the Application.

5. The completed Application is submitted by the Applicant to the Federal OSC and any other members of the Unified Command.

6. Once the Federal OSC (in cooperation with the UC) deems the Application to be complete, the completed Application is immediately disseminated by the USCG ARRT Co-Chair to any remaining entities identified in #2 above.

7. The Federal OSC contacts the U.S. Fish and Wildlife Service (FWS) and/or National Marine Fisheries Service (NMFS) Endangered Species Act (ESA) experts to initiate Section 7 consultation(s), as appropriate, in accordance with the ESA Memorandum of Agreement (see Annex G of the Unified Plan.)

8. The Federal OSC contacts a NMFS Essential Fish Habitat (EFH) expert to initiate, as appropriate, EFH consultation.

9. Natural resource trustees review the Application and identify incident-specific resources at risk (see Part 3).

10. The EPA ARRT representative reviews the Application and NCP Product Schedule for the dispersant proposed for use.


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Part 1: Decision-Making Process for Use of Dispersants, Cont.

11. The NOAA SSC coordinates a meeting/teleconference date/time with the USCG ARRT Co-Chair, who convenes a meeting/teleconference with Unified Command representatives, the EPA ARRT representative, and natural resource trustees (including the DOI and DOC ARRT representatives) (see Part 4, Procedure for Incident-Specific Collaboration for Dispersant Use Decision-Making) to discuss the Application and Incident-Specific Resources at Risk (see Part 5).

12. The Federal OSC (in cooperation with the UC) completes the FOSC Dispersant Use Decision Checklist (Checklist) (see Part 5).

13. The Agency Dispersant Use Decision Document is completed by the appropriate parties (see Part 6).

14. The Applicant advises the Federal OSC and the UC that dispersant application personnel (including the Dispersant Controller), equipment, and supplies are staged and ready to deploy an initial dispersant application field test.

15. The Federal OSC (in cooperation with the UC) ensures all required monitoring capabilities (e.g. SMART team) are in place and will be conducting the appropriate monitoring when dispersants are applied.

16. The Applicant conducts an initial dispersant application field test to determine if the additional applications should be approved. Based on feedback from the monitoring teams, the Federal OSC (in cooperation with the UC) determines whether or not to continue and/or modify the dispersant operations. An additional meeting/conference call(s) will be convened by the NOAA SSC (see Part 5) to review any substantive modifications to any approved dispersant plan.

17. After the response for this incident has been completed, the Federal OSC will ensure that a Dispersant Use After-Action Report (see Tab C) is completed and submitted to other members of the Unified Command, all ARRT members, and the National Response Team (NRT). The report will also be posted on the ARRT public web site.

In the event that response activities are continued for one or more months, the Federal OSC will ensure the completion of an Interim Dispersant Use After-Action Report (see Tab C) for submittal to other members of the Unified Command, all ARRT members, and the NRT at the end of every month, if dispersants have been used during the previous time period(s). The report(s) will also be posted on the ARRT public web site.


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Part 2: Dispersant Use Application INCIDENT NAME Date Prepared:

Time Prepared:

INCIDENT LOCATION APPLICANT INFORMATION

Latitude: Name:

Longitude: Affiliation:

Description: Address:

Phone:

Cell Phone:

Incident Date: Fax:

Incident Time: Email:

Zones dispersants to be applied in:

Zone 1 Zone 2 Zone 3

BASIC DATA

Type of Incident (check one): Did source burn? Yes No Grounding Is source still burning? Yes No Transfer Operations Is product easily emulsified? Yes No Explosion Collision RESPONSE CONSIDERATIONS Blowout Why is mechanical recovery inadequate?

___________________________________________________ Explosion ___________________________________________________ Other ______________________________ ___________________________________________________

___________________________________________________ Product Released (check one): API: ___________________________________________________

North Slope Crude ___________________________________________________

Cook Inlet Crude

Residuals Will in-situ burning also be used? Yes No

Diesel #2 Will mechanical recovery also be used? Yes No

JP4 Will dispersant use impede mechanical recovery?

Yes No

Other If yes, explain how this will be resolved: ___________________________________________________ Estimated Volume of Released Product: ___________________________________________________ gallons / barrels ___________________________________________________

___________________________________________________ Potential Release Volume Estimate:

gallons/ barrels ADIOS MODEL Has ADIOS been run by a qualified person? Yes NoRelease Status (check one): Identify individual and affiliation: ________________________

Continuous If yes, the please fill out the following ADIOS Input parameters: Intermittent Wind Speed ___________ Water Temp ___________ One time only, now stopped ADIOS Output Parameters to be Specified:

Percentage Evaporation Current Estimate of Water Surface Covered as of: Viscosity Change

Water Percentage or Emulsification over a 5-day period Date/Time: Area: sq. mi.


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BASIC DATA, Continued

WEATHER AND SEA CONDITIONS DISPERSANT USE PLAN

Check boxes and enter wind values in the following table: Proposed date and time for application of dispersants:

Present Condition

12-hour Forecast

24-hour Forecast

Date: ______________ Time: ________________

Clear Distance to nearest staging area (airport/facility): __________ mi

Partly Cloudy Overcast What is the dispersant proposed for use?

Rain Corexit 9500 Corexit 9527

Snow Other: ___________________________________________

Fog

Wind Speed (knots) Material Safety Data Sheet (MSDS) attached? Yes No

Wind Direction (from)

Visibility (nm): _____________________________________ What is the proposed dispersant to oil ratio? ______:_______

Tidal State at __________________ o’clock (check one):

Slack Tide Incoming (flood) Outgoing (ebb) How much total dispersant per acre is proposed?

Attachment 1: Graph with tidal information for 3 tidal cycles. gallons

Dominant current (net drift): What is the estimated percentage of spill slick to be treated?

______________________% Speed (knots): __________ Direction (to): ______________ Who will apply the dispersants? Sea State (check one): Individual/Affiliation: ___________________________________

Calm Choppy Swell APPLICATION

METHOD

EST. DISPERSANT CAPACITY PER

SORTIE

EST. NUMBER OF SORTIES:

Waves (height estimate): _______________ feet

Depth of water at slick: _______________ feet Boat

Water temperature: ___________________ degrees C and F C-130

Water salinity: _______________________parts/thousand CASA

If ice is present, describe: _______________________________ Helicopter

____________________________________________________ Other:

____________________________________________________ Sunrise: __________________ Sunset: _________________ Distance from source: miles

Distance from nearest shoreline: miles

WILDLIFE INFORMATION

Have fish swarms, birds, and/or marine mammals been observed near the oil slick?

Attachment 2: Provide a chart with a distance scale. Chart must include: 1) estimated spill trajectory and landfalls with time; 2) location and distance of proposed dispersant application relative to zone boundaries, proposed field test location, and other response activities; 3) dispersant tactic summary and how it will augment the mechanical response; and 4) fish and wildlife locations relative to the oil slick.

Yes No

If yes, please answer the following:

Type observed (e.g., birds, sea otters, seals, whales, fish)

Estimated Number

SAFETY PLAN FOR DISPERSANTS Does your health and safety plan cover the dispersant use plan?

Yes No

(The proximity of the above observed fish and wildlife should be included in the chart being submitted as Attachment 2)

Attachment 3: Relevant portion of Safety Plan, including MSDS.


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Part 2: Dispersant Use Application, Cont.

DISPERSANT SYSTEM ANALYSIS SIGNATURES Application System Design Has Been:

Specifically designed for this purpose: Yes No

Previously used for this purpose: Yes No Applicant’s Printed Name and Signature

Anticipated to be effective and safe: Yes No Applicant contact cell phone: ______________________________

Meets manufactures recommendations: Yes No Date and time submitted to FOSC and SOSC:

Application personnel are trained and/or experienced in the use of dispersants and this application system? Yes No

Date Time

Aerial Application System: Received by:

A qualified Dispersant Controller will be in a separate aircraft over the spray zone(s)? Yes No

The Dispersant Controller will be able to direct operations and avoidance of fish and wildlife?

Yes No

Federal OSC Printed Name and Signature Date/Time Boat Application System:

A qualified Dispersant Controller will oversee operations? Yes No

The system components meets relevant ASTM standards? Yes No

State OSC Printed Name and Signature Date/Time Attachment 4: Description of dispersant application system and application team personnel qualifications.

COMMUNICATIONS PLAN

Describe the communications plan to be used for communications between and among the Unified Command, Dispersant Controller, SMART Team, and dispersant applications platform(s):

DISPERSANT MONITORING

Indicate the SMART monitoring tier to be used:

Tier 1: Yes No

Tier 2: Yes No

Tier 3: Yes No Describe the monitoring platform that will be used: Identify (name, title, affiliation) monitoring team members:


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Part 3: Incident-Specific Resources at Risk A. Information Considered

Sensitive Areas information in the Subarea Contingency Plan(s) (SCPs) for this incident. Relevant Geographic Response Strategies in appropriate SCPs for this incident. Incident-specific information from on-scene observations. Others: ___________________________________________________________

B. Biological Species (may not be a complete list of species present) Present/Absent/

or Unknown Other Relevant

Information Used for

Subsistence?

Endangered/Threatened/Candidate Species: Migratory birds (specify) Sea otters (southwest Distinct Population Segment)

Polar bears Seals (specify) Toothed whales (specify) Baleen whales (specify) Sea Lions

Other Species: Seabirds Diving birds (unlisted populations) Waterfowl (unlisted populations) Shorebirds Raptors (unlisted populations) Sea Otters (unlisted populations) Walruses Fur seals Other seals (unlisted populations) Toothed whales (unlisted populations) Baleen whales (unlisted populations) Ungulates Bears (brown & black) Furbearers Fish: Pelagic and larval Bottomfish Intertidal mullusks Crustacea Plankton (including larval species)


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Part 3: Incident-Specific Resources at Risk, Cont.

C. Habitat Types

D. Special Designations

Present/Absent/Unknown Other Relevant Information ESA designated critical habitats Essential Fish Habitat Legislatively-designated areas Native allotments Others:

E. Historic Properties

Present/Absent/Unknown Other Relevant Information Historic Resources Archaeological Resources Others:

F. Other Considerations

Present/Absent/Unknown Other Relevant Information Commercial harvest areas Subsistence harvest areas Recreational use areas Mariculture facilities Others:

Present/Absent/Unknown Other Relevant Information

Salt/brackish-water marshes Eelgrass beds/kelp beds Tidal mudflats Sheltered rocky shores/shallow reefs

Gravel beaches Mixed sand and gravel beaches Coarse-grained sand beaches Marshes Peat shorelines Inundated low-lying tundra Ice (seasonal, multi-year) Marine mammal haul-outs/rookeries

Migratory bird nesting colonies Fish spawning grounds Others:


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Part 4: Procedure for Incident-Specific Collaboration for Dispersant Use Decision-Making

This procedure facilitates input to the Federal On-Scene Coordinator (OSC) by the State OSC and U.S. Environmental Protection Agency (EPA),U.S. Department of the Interior ( DOI), and U.S. Department of Commerce (DOC) Alaska Regional Response Team (ARRT) representatives following their receipt of a completed Dispersant Use Application (Application) (see Part 2). National Oceanic and Atmospheric Administration Scientific Support Coordinator Responsibilities: Provides to the U.S. Coast Guard (USCG) ARRT Co-Chair, the Application as soon as it has

been “deemed complete” by the Federal OSC, and a copy of the Incident-Specific Resources at Risk (see Part 3) form as completed by the natural resource trustees.

Confirms with the USCG ARRT Co-Chair when (i.e., date and time) the Federal OSC needs input

from the State OSC and the EPA, DOI, and DOC ARRT representatives on the dispersant request and when (date/time) Unified Command representatives are available for a meeting/conference call to discuss the request.

USCG ARRT Co-Chair Responsibilities:

Provides to State OSC and the EPA, DOI, and DOC ARRT representatives, a completed

Application (see Part 2) and information on meeting/conference call date/time and logistics. [The State OSC and DOI and DOC ARRT representatives are responsible for distributing the Application and meeting/conference call date/time and logistics to their respective natural resource trustee contacts.]

Chairs the meeting/conference call and: (1) conducts roll call, recording names, titles, and

affiliations of meeting/conference call participants; (2) requests (from the Applicant) a summary/overview of the dispersant use plan; (3) directs questions regarding the dispersant use plan to the appropriate Unified Command representative(s); (4) queries the State OSC and EPA, DOI, and DOC ARRT representatives for input on the proposed plan; (5) facilitates development of a consensus recommendation by the State OSC and EPA, DOI, and DOC ARRT representatives on the dispersant request[1]; (6) documents any State OSC and EPA, DOI, and/or DOC-related special considerations, constraints, permit requirements, and/or special authorizations; (7) queries the State OSC and the EPA, DOI, and DOC ARRT representatives for their summary input on the dispersant request; and (8) reviews verbally the meeting/conference call results.

Prepares and provides as soon as possible to the State OSC and EPA, DOI, and DOC ARRT

representatives, a draft written summary of the meeting results along with the names, titles, and affiliations of conference call/meeting participants. Incorporates as soon as possible, any corrections to the summary provided by the State OSC and EPA, DOI, and/or DOC ARRT representatives, and immediately provides the final summary to the Unified Command with a copy to each meeting participant.

[1] State OSC and EPA, DOI, and DOC input will be based on existing published and unpublished information, incident-specific on-site observations, and best professional judgment and best available science.


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Part 5: FOSC Dispersant Use Decision Checklist YES NO CONSIDERATIONS

1. Dispersant Use Application Received: The Applicant has submitted a completed Dispersant Use Application (see Part 2).

Notifications: The following entities have been notified of the potential dispersant use for this incident: 2a. 2b.

a. State On-Scene Coordinator (OSC) b. U.S. Environmental Protection Agency (EPA) Alaska Regional Response Team (ARRT) representative

2c. c. U.S. Department of the Interior (DOI) ARRT representative 2d. d. U.S. Department of Commerce (DOC) ARRT representative 2e. e. Appropriate Federally-recognized tribes (specify: _________________________) 2f. f. Appropriate stakeholders (e.g., local governments, Native corporations, regional citizens’ advisory

councils) (specify: ___________________________________________) 2g. g. USCG Strike Team/ Special Monitoring of Applied Response Technologies (SMART) Team and/or

other agreed-upon monitoring team(s).

3. Endangered Species Act (ESA) Consultations: U.S. Fish and Wildlife Service (FWS) and/or National Marine Fisheries Service (NMFS) ESA expert(s) have been notified and, if appropriate, Section 7 consultation(s) have begun per the ESA MOA.

4. Essential Fish Habitat (EFH) Consultations: NMFS EFH expert has been notified and, if appropriate, EFH consultations have begun.

5. Dispersibility: Available technical and scientific information or experience suggests that the spilled product is dispersible and will be dispersible in the time frame of anticipated application of dispersants. Identify source(s) relied upon: _______________________________________________________

6. NCP Listed Dispersant: The dispersant to be used is listed on the current NCP Product Schedule and is considered appropriate for the existing environmental and physical conditions. Identify source(s) relied upon: ____________________________________________________________________________

7a. Response Considerations: a) Has mechanical response been deemed to be inadequate? If yes, specify reason(s) (e.g., availability,

effectiveness, timeliness, sea state, spatial coverage, weather conditions): ______________________. 7b. b) Is dispersant application being used to augment mechanical recovery? 7c. c) Is in-situ burning being considered to augment mechanical recovery and dispersant use? 7d. d) Is a map illustrating timing, tactics, and proximity of each response option to each other attached?

Dispersant availability and timeliness: Sufficient dispersant and application equipment has been confirmed to be available:

8a. a) to make a significant impact on the spilled product, and 8b. b) to be deployable within the proposed time frame.

9. Weather Conditions: Weather and sea conditions are conducive to dispersant application by the chosen system or platform. (Generally, for aerial application, wind ≤ 25 kts, visibility ≥ 3 nm, and ceiling ≥1,000 ft. Generally for boat application, a sea state that will allow the vessel to be used to conduct an effective and safe spray operation.) Identify conditions (if different than Application) _______________________________

10. PPE: Personal protective equipment for all personnel involved in, or impacted by, dispersant application conforms to the site-specific and health and safety plan.

General Adequacy of Dispersant Spray System and Personnel Competency: Note: The general criteria for evaluating the suitability for use of any dispersant system is the ability of the Applicant to demonstrate to the satisfaction of the OSCs, the following:

11a. 11b. 11c.

Has the application system been: a) Specifically designed for its intended purpose, or b) Used previously and deemed to be effective and appropriate (if not specifically designed for dispersant

use), and will it be used again in a similar manner, or c) Deemed to be effective and appropriate by some other specific means; if so, identify specific means:

___________________________________


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YES NO CONSIDERATIONS

11d. d) Is the design and operation of the application system such that it can reasonably be expected to apply the chemical dispersant in a manner consistent with the dispersant manufacturer’s recommendation, especially with regards to dosage rates, and concentrations?

11e. e) Will the dispersant application be supervised by personnel that have experience, knowledge, specific training, and/or recognized competence with chemical dispersants and the type of system to be used?

Aerial Application Operational and Technical Issues: In the case of aerial application of dispersants: 12a. 12b.

a) Is there a Dispersant Controller who will be over the spray zone(s) in separate aircraft from the dispersant aircraft?

b) Is the Dispersant Controller qualified and able to direct the dispersant aircraft in carrying out dispersant application, including avoiding spraying dispersants on swarming fish, birds, and/or marine mammals that may be in the area adjacent to the oil slick?

12c. c) Is the aircraft spray system capable of producing dispersant droplet sizes that provide for optimal dispersant effectiveness (generally 250-500 µm), but following manufacturer and ASTM guidance)?

13a. 13b. 13c.

Boat Application Operational Technical Issues: If the system involves spray arms or booms that extend over the edge of a boat and has fan type nozzles that spray a fixed pattern of dispersant, has the Applicant confirmed that the dispersant application will comply with all of the following ASTM standards?

a) ASTM F 1413-92 Standard Guide for Oil Spill Dispersant Application Equipment : Boom and Nozzle Systems

b) ASTM F 1460-93 Standard Practice for Calibrating Oil Spill Dispersant Application Equipment Boom and Nozzle Systems

c) ASTM F 1737-96 Standard Guide for Use of Oil Spill Dispersant Application Equipment during Spill Response: Boom and Nozzle Systems

14a. 14b. 14c.

SMART Protocols/Deployment: a) Has the USCG Strike Team SMART Team (or other agreed-upon monitoring team(s)) been activated? b) Are they prepared to be flying over the response zone to conduct Tier 1 (visual) monitoring during

every dispersant application to visually assess the effectiveness of the dispersant application(s) and to watch for swarming fish, birds, and marine mammals?

c) Are they prepared to implement the Tier 2 and/or Tier 3 on-water monitoring component of the SMART monitoring protocols for every dispersant application?

15. Communications: Has a communications plan been developed that will allow communications between and among the Unified Command, Dispersant Controller, SMART Team(s), and dispersant applications platform(s)?

16. Natural Resource Trustee Input: Have the Federal OSC received input from natural resource trustees on incident-specific resources at risk (see Part 3)?

17. State OSC, EPA, DOI, and DOC Input: Has the Federal OSC received input from the State OSC and the EPA, DOI, and DOC ARRT representatives on the dispersant request? (see Part 4)

18. Federally-Recognized Tribes: Has the Federal OSC received input from appropriate Federally-recognized tribes on the dispersant request?

19. Stakeholder Input: Have the Federal OSC (in cooperation with the UC) received input from appropriate stakeholders on the dispersant request?

Conditions/Stipulations: Will the following application conditions and stipulations be included in any initial and/or subsequent approval(s) of dispersant use:

a) An initial dispersant application field test will be conducted on a representative portion of the slick.

b) Dispersant application will be in accordance with the approved dispersant application plan. c) Dispersants will only be applied in areas where the water depth is ≥ 10 fathoms (20 meters) (with the

exception of special 5 fathom contour in certain locations in Cook Inlet).

20a.

20b.

20c.


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YES NO CONSIDERATIONS

20d. 20e. 20f. 20g 20h

d) If the dispersant platform is an aircraft, spray aircraft will maintain a minimum 500 meters horizontal separation from swarming fish, rafting flocks of birds, and sea lion haul outs. Dispersants will not be sprayed over swarming fish, birds, or marine mammals or their haulouts.

e) Dispersant application will only be carried out in daylight conditions. f) DOI and/or DOC will provide a specialist in aerial surveying of marine mammals and/or pelagic birds

to accompany the SMART observer. g) Monitoring protocols required by natural resource trustees (e.g., ESA compliance) will occur. h) SMART Tier 1 and Tier 2 monitoring will occur during any dispersant application.

21. Has the Dispersant Decision Document been completed?


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Part 6: Agency Dispersant Use Decision Document Incident: ______________________________________________________________________

U.S. Department of the Interior Consultation by DOI ARRT Representative:

o ______Does not support the use of dispersants (reasons attached) o ______Agrees with dispersants use in the selected areas under noted conditions

(attached) o ______Agrees with dispersant use as requested in the application form

_______________________________ _______________________________ ___________ Signature Printed Name Time/Date U.S. Department of Commence Consultation by DOC ARRT Representative:

o ______Does not support the use of dispersants (reasons attached) o ______Agrees with dispersants use in the selected areas under noted conditions

(attached) o ______Agrees with dispersant use as requested in the application form

_______________________________ _______________________________ ___________ Signature Printed Name Time/Date U.S. Environmental Protection Agency Concurrence by EPA ARRT Representative:

o ______No dispersants may be applied (reasons attached) o ______Dispersants may be used in the selected areas under noted conditions (attached) o ______Dispersants may be applied as requested in the application form

_______________________________ _______________________________ ___________ Signature Printed Name Time/Date State of Alaska Concurrence by State On-Scene Coordinator:


_______________________________ _______________________________ ___________ Signature Printed Name Time/Date Federal On-Scene Coordinator Approval:


_______________________________ _______________________________ ___________ Signature Printed Name Time/Date


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Part 6: Agency Dispersant Use Decision Document, Cont. Conditions/Stipulations: The following conditions and stipulations shall be included in any initial and/or subsequent approval of the surface application of dispersants: 1) An initial dispersant application field test will be conducted on a representative portion of the

oil slick. 2) Dispersant application will be conducted in accordance with the approved dispersant

application plan. 3) Dispersants will only be applied in areas where the water depth is ≥ 10 fathoms (20 meters)

(with the exception of special 5 fathom contour in certain locations in Cook Inlet). 4) If the dispersant platform is an aircraft, spray aircraft will maintain a minimum 500 meters

horizontal separation from swarming fish, rafting flocks of birds, and sea lion haul outs. Dispersants will not be sprayed on swarming fish, birds, marine mammals or marine mammal haul outs.

5) Dispersant application will only be carried out in daylight conditions. 6) DOI and/or DOC will provide a specialist in aerial surveying of marine mammals and/or

pelagic birds to accompany the SMART observer. 7) Monitoring protocols required by natural resource trustees (e.g., for ESA compliance) will be

conducted. 8) SMART Tier 1 (visual) and Tier 2 (water column) monitoring shall occur during any

dispersant application. 8) Other(s) as specified: _________________________________________________________


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5.0 GENERAL DISPERSANT USE ZONES FOR ALASKA All marine waters in Alaska are designated as Zone 2, with the exception of Cook Inlet and Prince William Sound. These two areas include three zone designations as shown in Section 6.0 and Section 7.0, respectively. The dispersant use criteria developed for Alaska classify coastal waters into three dispersant use zones. In all cases, the use of dispersants will be based on the determination that the impact of dispersants or dispersed oil will be less harmful than non-dispersed oil. These zones are defined by: 1) physical parameters such as bathymetry and currents; 2) biological parameters such as sensitive habitats or fish and wildlife concentration areas; 3) nearshore human use activities; and 4) time required to respond.

2.1 Zone 1:

Zone 1 is defined as an area in which dispersant use should be evaluated as a means to prevent or reduce the amount of oil reaching the shoreline or other sensitive resources. Each Zone 1 will be defined in map format, and will include a description of: 1) minimum depth of water; 2) minimum distance from shoreline; 3) seasonal timeframes, if any; 4) the maximum allowable amount of dispersant that may be used without further consultations; 5) the maximum duration for dispersant use without further consultations; and 6) the type and amount of petroleum product suitable for dispersal within the zone. The application and decision-making process and forms presented in Section 4.0 are to be followed.

2.2 Zone 2:

The application of dispersants is conditional in Zone 2, but generally acceptable due to water depth for good mixing and dilution of dispersed oil, however, the presence of sensitive wildlife and other resources needs to be evaluated at the time of the incident. All marine waters not specifically identified as Zone 1 or Zone 3 are defined as being in Zone 2. The application and decision-making process and forms presented in Section 4.0 are to be followed.

2.3 Zone 3:

The application of dispersants in Zone 3 is generally not recommended due to the frequent or constant presence of sensitive wildlife, and/or other biological resources. Each Zone 3 will be defined in map format, and will include a rationale for its designation. Prior to dispersant use, the application and decision-making process and forms presented in Section 4.0 are to be followed. 2.4 General Dispersant Zone Factors

The following factors were considered in developing the dispersant use zones:

Bathymetry - it is generally recognized that adequate mixing and dilution of dispersants

should occur if applied in waters greater than 10 fathoms (or 60 feet) depth if there is sufficient energy. The 10 fathom contour is a standard line on NOAA marine charts.

Distance from shore - generally a buffer of one-half to one nautical mile, depending on water depth, is established from shorelines to reduce the chances of applying dispersants to sensitive shorelines or adversely affecting intertidal and benthic biota due to poor mixing.

Wind and currents - areas where there is generally little movement of water would not provide sufficient mixing energy for successful dispersant use.


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Salinity - most dispersants are made for use in saltwater and are not effective in fresh water, e.g., less than 15 parts per thousand.

Shoreline types - certain shoreline types, such as gravel, mixed sand and gravel, and coarse-grained sand beaches, and marshes may trap oil for long periods.

Sensitive habitats - certain habitats where biota breed, rear young, feed, or congregate, such as eelgrass beds, kelp beds, and saltwater marshes, may be adversely affected by oil and/or dispersed oil.

Threatened or endangered species and/or their designated critical habitats - these species and/or their habitats may be adversely affected by oil and/or dispersed oil.

Other areas designated for special use or protection - e.g., national and state parks and wildlife refuges may be adversely affected by oil and/or dispersed oil.

Historic properties - e.g. archeological and historic resources may be adversely affected by oil and/or dispersed oil.

Human use activities - e.g., subsistence, fishing, and boating may be adversely affected by oil and/or dispersed oil.

Public and private facilities (e.g., fish hatcheries, aquaculture and mariculture facilities, public water intakes, and docks may be adversely affected by oil and/or dispersed oil).

Response equipment - the availability and time to mobilize response equipment may affect whether dispersants can be used.

Locations of vessels carrying significant quantities of crude oil.


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6.0 SPECIFIC GUIDELINES FOR THE USE OF DISPERSANTS IN COOK INLET3 Because of the presence of large numbers of commercially valuable adult salmon, that section of Cook Inlet north of a line drawn along the latitude at Anchor Point north of Kachemak Bay is considered to be Zone 3 during the period from July 1 to August 15. The general rationale is presented below and illustrated in figures 6.1 through 6.3.

6.1 Upper Cook Inlet (North of Point Possession and North Foreland) - Figures 6.1

Upper Cook Inlet is unique because the extreme upper portion contains two Zone 3 designations (dispersant use not recommended) which are based upon tidal stages. During the first three hours of an ebb tide, the Zone 3 boundary is roughly defined by the five-fathom isobath. For periods outside this time window, Zone 3 is defined as the area north of a line between Point Possession and North Foreland.

A dual Zone 3 designation is needed because dispersant use during a flood tide could result in relatively high concentrations of dispersed oil impacting shallow waters or intertidal habitats. Restricting dispersant use in this area to the ebb tide period eliminates these concerns while still allowing dispersant use in the northern portion of Upper Cook Inlet. Providing the option for dispersant use in this area is deemed desirable due to:

the high spill potential; the difficulty in mechanically containing spills; the extreme tidal fluctuations which rapidly transport spilled oil; and sensitive coastal habitats requiring protection from potential oil contamination.

6.1.1 Zone 3 - Ebb Tide.

The Ebb Tide Zone 3, which exists only during the first 3 hours of an ebb tide, occurs shoreward of the five-fathom isobath. This shallower isobath is used because: 1) the ebb tide will rapidly transport the dispersed oil to deeper waters; 2) benthic communities in Upper Cook Inlet exhibit relatively low productivity; and 3) increased water depths from the high tide stage will enhance dilution capabilities.

6.1.2 Zone 1 - Ebb Tide.

The Ebb Tide Zone 1, which exists only during the first 3 hours of an ebb tide, extends outward from the five-fathom isobath. Dispersant use is restricted to an ebb tide period to prevent high concentrations of dispersed oil from being transported to shallow nearshore waters. 6.1.3 Zone 3 - Flood Tide.

The Flood Tide Zone 3 is defined as the area north of a line extending from Point Possession to the North Forelands, for all periods outside of the first three hours of an ebb tide. This designation is necessary due to the potential for strong tidal currents to rapidly transport high concentrations of dispersed oil into important shoreline habitats.

3 It should be noted that except for including updated figures and editing figure titles for consistency, text in this section has not been revised.


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6.2 Middle Cook Inlet - South of a Line Between Point Possession and North Foreland to East Foreland and West Foreland - Figures 6.1 and 6.3

6.2.1 Zone 3

Zone 3 occurs inshore of the five-fathom isobath near the northeast shoreline of this section. The five-fathom isobath is used in this area due to a lack of fish and wildlife resources and the presence of strong currents that run parallel to the shoreline. The Zone 3 designation extends out to the 10-fathom isobath along the southeast shoreline to provide protection to the Swanson River estuary area. Along the west shoreline, the Zone 3 boundary follows the 10-fathom isobath.

6.2.2 Zone 1

The remaining waters within this Inlet section are designated as Zone 1. This designation will allow for an immediate dispersant use decision to protect important fish and wildlife resources in Cook Inlet.

6.3 Lower Cook Inlet - South of East and West Forelands.

6.3.1 Zone 3

Zone 3 occurs inshore of the 10-fathom isobath. The 10-fathom isobath provides ample protection to the razor clam beaches and several river estuaries along the east and west shorelines, including Redoubt Bay where large numbers of birds seasonally reside. Around Kalgin Island, a Zone 3 designation is established along the five-fathom isobath due to strong currents that run parallel to the shoreline and the two- to five-mile buffer provided by the five-fathom isobath. Kachemak and Kamishak Bays are given special protection through an expanded Zone 3 area due to the important fishery resources associated with these bays. The shoreline in the extreme southern portions of Cook Inlet drops off rapidly resulting in the 10-fathom isobath being located very near the shoreline. Consequently, Zone 3 is defined as an area extending one nautical mile out from the shoreline for areas exhibiting such shoreline characteristics. The one nautical mile buffer distance will allow for dilution of dispersed oil prior to impacting the shoreline or shallow-water areas. See Figure 5 for dispersant use zones.

6.3.2 Zone 1

Zone 1 is identified as an approximately five-mile wide buffer area extending outside of Zone 3. It is believed that the five-mile wide Zone 1 area will provide adequate time to conduct a dispersant response prior to oil entering the sensitive Zone 3 area.

6.3.3 Zone 2

The remaining waters within this section of Cook Inlet are designated as Zone 2.


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Figure 6.1

Cook Inlet Dispersant Use Zones; Northern Sector

See Notes 3 Below and Figures 6.2 and 6.3 for Dispersant Use in Middle Cook Inlet.


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Figure 6.2 Cook Inlet Dispersant Use Zones: East Foreland


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Figure 6.3 Cook Inlet Dispersant Use Zones:

Drift River Tanker Loading Terminal


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Figure 6.4 Cook Inlet Dispersant Use Zones:

Southern Sector


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7.0 SPECIFIC GUIDELINES FOR THE USE OF DISPERSANTS IN PRINCE WILLIAM SOUND4 The dispersant use guidelines for Prince William Sound focus on the tanker traffic lanes and reflect the remoteness and fjord geomorphology of the Sound. Designation of the tanker lanes primarily as Zone 1 was deemed desirable due to:

the large volume of oil transported through the sound via these lanes; the difficulty in mechanically containing and removing spilled oil; and the likelihood that dispersant use would assist in minimizing the environmental effects of a spill,

particularly oil contamination of sensitive coastal resources and habitats. Most of the area outside the tanker lanes has been designated as Zone 3 due to the variety and abundance of biological resources in Prince William Sound. The general rationale for the guidelines is presented below. The specific zones are illustrated in figures 7.1 through 7.3.

7.1 Port of Valdez and Valdez Arm (North of Latitude 60o 47') - Figure 7.1

7.1.1 Zone 3

Tatitlek Narrows and Columbia Bay are designated as Zone 3.

7.1.2 Zone 2

In general, the areas inshore of the 100-fathom isobath and north of Rocky Point and Point Freemantle are designated as Zone 2.

7.1.3 Seasonal Designation Zone 1/Zone 2

This small portion of Prince William Sound consists almost entirely of tanker traffic lanes and includes the tanker loading berths at the terminus of the Trans-Alaska Pipeline. The Port of Valdez and Valdez Arm also support sensitive fisheries resources, such as out-migrating juvenile salmon, herring spawning and rearing areas, immigrating adult salmon; and commercial fishing activities. Consequently, this portion of the Sound has been designated Zone 1 from October 16 to February 28, when fisheries resources are least abundant; and Zone 2 from March 1 to October 15, when fisheries resources and harvest activities are at a peak. The Zone 2 designation will allow a case-by-case decision on dispersant use. Such a decision will be based on the potential for impact(s) to environmental resources.

7.2 Main Body of Prince William Sound - Figure 7.2

7.2.1 Zone 3

The majority of the waters within this section of Prince William Sound are designated as Zone 3. This provides protection for abundant and diverse biological resources of these areas and eliminates the procedural difficulties of classifying the complicated and extensive shoreline.

4 It should be noted that except for including updated figures and editing figure titles for consistency, text in this section has not been revised.


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7.2.2 Zone 1 The tanker traffic lanes and a variable extending on either side of these lanes are

designated as Zone 1. The width of this zone is determined by the need to minimize adverse effects on sensitive resources and the morphology of the Sound.

7.2.3 Hinchinbrook Entrance Zone 1/Zone 3

Hinchinbrook Entrance, which is included in the tanker traffic lanes is designated Zone 1, with the exception of an area one nautical mile in radius around Seal Rocks. The area around Seal Rocks is designated as Zone 3, reflecting the importance of this area to marine mammals and seabirds.

7.3 Copper River Delta (East of Hinchinbrook Entrance) - Figure 7.3

7.3.1 Zone 3

The area inshore of the three-mile (statute miles) territorial limit along the coast from Cape Hinchinbrook to Kayak Island is designated as Zone 3. This wide Zone 3 designation provides protection for the coastal resources and sensitive marsh and tidal flat habitats of the Copper River Delta area.

7.3.2 Zone 1

Zone 1 is identified as an approximately five nautical-mile wide buffer extending seaward of Zone 3. This width should provide adequate time to conduct a dispersant response to oil entering the sensitive Zone 3.

7.3.3 Zone 2

The waters seaward of Zone 1 are designated as Zone 2.

7.4 Montague Island (West of Hinchinbrook Entrance).

7.4.1 Zone 3

Zone 3 occurs inshore of a line drawn approximately one nautical-mile off the outside

coasts of Montague and Elrington Islands and extending east to Cape Junken. In this area, the water depth increases rapidly with distance offshore. A distance of one nautical mile should provide sufficient depth for adequate mixing and dilution of dispersed oil.

7.4.2 Zone 1

Zone 1 is identified as an approximately five nautical-mile wide buffer area extending seaward of Zone 3. This designation will allow for a rapid decision on dispersant use to minimize adverse effects on the sensitive resources in Zone 3.

7.4.3 Zone 2

The waters seaward of Zone 1 are designated as Zone 2.


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7.4.4 Seasonal Designation Zone 1/Zone 2

The southern end of Montague Strait--south from a line drawn from the northern end of Latouche Island to Point Bazil and to a line drawn between Point Cleare and a point 0.5 nautical-miles south of Point Elrington (59° 55’ latitude and 148° 15’ longitude) is designated as Zone 1 from October 1 to March 31 and as Zone 2 from April 1 to September 30. This dual designation is due to the presence of fisheries resources and commercial harvest activities as well as the potential use of the area by oil tankers.


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Figure 7.1 Prince William Sound Dispersant Use Zones:

Valdez Port


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Figure 7.2 Prince William Sound Dispersant Use Zones:

Main Body


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Figure 7.3

Prince William Sound Dispersant Use Zones: Copper River Delta


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TAB A: SUMMARY ANALYSIS OF DISPERSANTS ON THE NATIONAL CONTINGENCY PLAN PRODUCT SCHEDULE

Dispersant Product Shelf Life

(unopened)

% Effectiveness on Prudhoe Bay

Crude Oil (vendor test)

Toxicity of Dispersant and #2

Fuel Oil (1:10) LC50 (ppm) on

Menidia beryllina

Toxicity of Dispersant and #2

Fuel Oil (1:10) LC50 (ppm) on

Mysidopsis bahia

BIODISPERS Unlimited 51 5.95 96-hr 2.66 48-hr

COREXIT 9500 Unlimited 45.3 2.61 96-hr 3.4 48-hr

COREXIT 9527 Unlimited 37.4 4.49 96-hr 6.6 48-hr

DISPERSIT SPC 1000 Unlimited 40 7.9 96-hr 8.2 48-hr

FINASOL OSR 52 3 years 32.5 5.4 96-hr 2.37 48-hr

JD-109 Unlimited 29 3.84 96-hr 3.51 48-hr

JD-2000 Unlimited 60.4 3.59 96-hr 2.19 48-hr

MARE CLEAN 200 10 years 63.97 42 96-hr 9.84 48-hr

NEOS AB 3000 5 years 19.7 57 96-hr 25 48-hr

NOKOMIS 3-F4 15 years 62.2 100 96-hr 58.4 48-hr

SEA BRAT #4 Indefinite 53.55 23 96-hr 18 48-hr

SAF-RON GOLD Unlimited 84.8 9.25 96-hr 3.04 48-hr

ZI-400 Unlimited 50.1 8.35 96-hr 1.77 48-hr

NOKOMIS 3-AA >24 months 63.2 34.2 96-hr 20.2 48-hr

As of February 2010, for updates, see: http://www.epa.gov/osweroe1/content/ncp/product_schedule.htm


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TAB B: SPECIAL MONITORING OF APPLIED RESPONSE TECHNOLOGIES (SMART) (The latest SMART Protocols approved by USCG and NOAA will be attached in the final document.)


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TAB C: DISPERSANT USE AFTER-ACTION REPORT Guidelines and Requirements The Dispersant Application After-Action Report will focus on the following four elements of the dispersant application: An overview of the incident (prepared by the Federal OSC) A description of how the dispersant application(s) were conducted (prepared by the Applicant) A description of how Tier 1 monitoring was conducted and the results (prepared by the Tier 1

Monitoring Team) A description of how Tier 2 monitoring was conducted and the results (prepared by the Tier 2

Monitoring Team). This report, which will include the elements shown in the box below, should be submitted to the UC and the ARRT and posted on the ARRT public web site within 30 days of completion of the dispersant operations.

Report Outline

I. Incident Overview A. Background information a. Cause of spill b. Type and amount of oil spilled

c. Location of spill d. Anticipated movement of slick, i.e., trajectory e. Anticipated weathering and behavior of oil f. Other pertinent information

B. Response actions taken (e.g., mechanical recovery, protective booming, in-situ burning) C. Summary of decision-making process resulting in the approval of a request for the use of dispersants

II. Description and the Dispersant Application

A. Description of Dispersant Application 1. Type and amount of dispersant applied 2. Type of aircraft or vessel used and dispersant system used 3. Personnel directly involved in dispersant application (e.g., Dispersant Controller) and

summary of their qualifications and experience 4. Location of each application, including Dispersant Use Zone(s) 5. Date and time of application(s) 6. Weather conditions at time(s) of each application, including sea state, water temperature, water

salinity 7. Ratio of dispersant to oil, including amount of dispersant applied and approximate area to which

applied 8. Staging area, distance to region of application, and specifics regarding logistics (including time) involved in supporting the dispersant application. 9. Communications used 10. Interaction between the Incident Management Team and field units carrying out the guidance received 11. Spotter aerial observations 12. Health and Safety plan requirements (including PPE)

B. Lessons Learned 1. What worked well 2. What needed improvement 3. Recommendations


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Report Outline, Cont.

III. Description and Results of Tier 1 (Visual) Monitoring A. How the monitoring was carried out (e.g. method, vehicle, monitors, etc.)

1. Specifics regarding equipment and suitability of the vessel used 2. Describe what was observed regarding the dispersal of oil 3. Communications used and any associated problems 4. Operational support from the staging area, etc. 5. Interaction between the IMT and the field units carrying out guidance received from the IMT

B. Results of Tier 1 Monitoring C. Lessons Learned

1. What worked well 2. What needed improvement 3. Recommendations

IV. Description and Evaluation of Tier 2 (Water Column) Monitoring

A. How the monitoring was carried out (e.g. method, vehicle, monitors, etc.) 1. Specifics regarding equipment and suitability of the vessel used 2. Describe what was observed regarding the dispersal of oil 3. Communications used and any associated problems 4. Operation support from the staging area, etc. 5. Interaction between the IMT and the field units carrying out guidance received from the IMT

B. Results of Tier 2 Monitoring C. Lessons Learned

1. What worked well 2. What needed improvement 3. Recommendations

annex f appendix i â€“ arrt oil dispersant guidelines

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