Case Study 2. Earl Liverman, OSC Region th Annual OSC Readiness Training Program.

Transcription

1 Case Study 2 Earl Liverman, OSC Region th Annual OSC Readiness Training Program

2 Keller Transportation Diesel Spill September th Annual OSC Readiness Training Program 1

3 Background On 29/09/10, a tanker truck pulling a trailer overturned on US Highway 12 causing a discharge of about 7550 gallons of red-dyed diesel Diesel was discharged into upslope roadside ditch, and migrated downward and laterally through the subsurface materials beneath the highway Site is located on public land administered by US Forest Service and within the Idaho Transportation Department right-of-way, and is adjacent to the Lochsa River 15 th Annual OSC Readiness Training Program 2

4 Background Lochsa River is a federally designated Wild and Scenic River that contains bull trout, chinook salmon, and steelhead trout listed as threatened under the Endangered Species Act Site is within the Nez Perce Tribe treaty area 15 th Annual OSC Readiness Training Program 3

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12 What are the criteria for determining whether to exercise federal removal authority for oil spill response? 15 th Annual OSC Readiness Training Program 11

13 Decision to Initiate Action General Removal Requirement: Is the substance an oil? Is there a discharge or substantial threat of discharge? Is the discharge or substantial threat of discharge into navigable waters or adjoining shorelines? Are removal actions consistent with the NCP? 15 th Annual OSC Readiness Training Program 12

14 Are there national response priorities for an oil spill response? 15 th Annual OSC Readiness Training Program 13

15 There are National Response Priorities? First: Safety of human life, including any search and rescue efforts in the general proximity of the discharge and safety of response personnel Second: Stabilizing the situation to prevent the event from worsening Third: Use all necessary containment and removal tactics in a coordinated manner to ensure a timely, effective response that minimizes adverse impact to the environment Fourth: Other priorities on a site-specific basis 15 th Annual OSC Readiness Training Program 14

16 Is there a general pattern of response? 15 th Annual OSC Readiness Training Program 15

17 There a General Pattern of Response Discovery or Notification [NCP ] Preliminary Assessment [NCP ] Containment, countermeasures, cleanup, and disposal [NCP ] Documentation and Cost Recovery [NCP ] 15 th Annual OSC Readiness Training Program 16

18 Are there other significant responsibilities? 15 th Annual OSC Readiness Training Program 17

19 There Are Other Significant Responsibilities Keeping the EPA chain-of-command informed Coordinate efforts with other agencies and third parties [NCP (a)] Public Information and Community Relations [NCP (b)] Worker Health and Safety [NCP , (c), ] 15 th Annual OSC Readiness Training Program 18

20 How do you determine when the response is complete? 15 th Annual OSC Readiness Training Program 19

21 Discharges of oil that: Violate applicable water quality standards or Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines 15 th Annual OSC Readiness Training Program 20

22 How do you use to determine when the response is complete? 15 th Annual OSC Readiness Training Program 21

23 Examples of Qualitative Endpoints There is no longer any detectable oil present on the water, adjoining shorelines, or places where it is likely to reach the water again Oil no longer releases thick rainbow sheen that will affect wildlife, sensitive areas, or human health Further removal operations would cause more environmental harm than the oil to be removed Cleanup measures would be excessively costly in view of their insignificant contribution to minimizing a threat to the public health or welfare, or the environment 15 th Annual OSC Readiness Training Program 22

24 Examples of Quantitative Endpoints Oil on surface water, groundwater, soil or sediment does not exceed background concentrations for the constituents or compounds of concern Oil on surface water, groundwater, soil, or sediment does not exceed predetermined concentrations for the constituents or compounds of concern 15 th Annual OSC Readiness Training Program 23

25 What are some practical considerations for achieving cleanup? 15 th Annual OSC Readiness Training Program 24

26 Practical Considerations for Achieving Cleanup Consultation Long-term deployment of absorbent materials Widely varying cleanup standards 15 th Annual OSC Readiness Training Program 25

27 Practical Considerations for Achieving Cleanup (continued) Natural Attenuation Not all spilled oil will be recovered Weather 15 th Annual OSC Readiness Training Program 26

28 What Are Some Practical Considerations for Determining When the Cleanup is Complete When Not All Spilled Oil is Recoverable? 15 th Annual OSC Readiness Training Program 27

29 Some Practical Considerations for Determining When the Cleanup is Complete When Not All Spilled Oil is Recoverable Technical and operational feasibility of investigation and cleanup Is there a balance between cost in relation to the added degree of protection or reduction of risk afforded by additional cleanup? Is there a state or other entity that has the capability to assume responsibility for the cleanup action? 15 th Annual OSC Readiness Training Program 28

30 What Are Some Practical Considerations for Determining When the Cleanup is Complete When Not All Spilled Oil is Recoverable (continued) Anticipated rate of natural attenuation processes Institutional Constraints/Pressures Is the remaining oil likely to damage environmentally sensitive resources? 15 th Annual OSC Readiness Training Program 29

31 What Are Some Practical Considerations for Determining When the Cleanup is Complete When Not All Spilled Oil is Recoverable (continued) Does it interfere with the aesthetic appeal and amenity use of the shoreline? Is the oil detrimental to economic resources or disrupting economic activities? 15 th Annual OSC Readiness Training Program 30

32 Current Situation The steep mountain sideslope is overlain at varying depths by backfill material and/or colluvium followed by weathered granitic bedrock which grades into competent bedrock There are no alternate subsurface investigation techniques or cleanup techniques considered reliable for the Site conditions Dissolved BTEX and Napthalene appear to be naturally attenuating The rate of liquid fuel removed from the subsurface recovery system has diminished over time 15 th Annual OSC Readiness Training Program 31

33 Current Situation (continued) Analytical results from 11 upstream surface water samples and 25 downstream surface water samples show that the contaminants of concern were non-detect Analytical results for 28 groundwater samples show only one benzene, ethyl-benzene, and naphthalene above State standards The last time any free product or sheen was observed along the riverbank was in November 2010 and a few days in October th Annual OSC Readiness Training Program 32

34 What Would You Do? 15 th Annual OSC Readiness Training Program 33