Industry Guidelines on Requesting Regulatory Concurrence for Subsea Dispersant Use

API BULLETIN 4719

FIRST EDITION, JUNE 2017

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Contents

Page

1. Scope 1

2. Acronyms and Abbreviations 1

3. Overview 2

   1. General 2

   2. National Response Team 3

   3. Responsible Party 3

4. Summary of Core Information Submitted to Regional Response Teams 3

5. Evaluating the Use of Subsea Dispersant Injection 4

6. Use of Modeling to Support Response Decision-making 4

7. Importance of Effective Data Management Techniques 5

8. Use of SIMA to Support Response Decision-Making 5

9. Regional Response Team Concurrence Request Process 6

10. Incident Command System Positions with Significant SSDI Roles 9

    1. General 9

    2. Responsible Party Incident Commander Recommended Tasks 10

    3. Federal On-Scene Coordinator Recommended Tasks 11

    4. Safety Officer Recommended Tasks 11

    5. Planning Section Chief Recommended Tasks 11

    6. Environmental Unit Recommended Tasks 12

    7. Environmental Data Management Unit Recommended Tasks 12

    8. Subsea Monitoring Team Recommended Tasks 13

    9. Source Control Section or Branch Subsea Dispersant Unit Recommended Tasks 13

    10. Subsea Dispersant Operations Operations/Unit Leader Recommended Tasks 13

Annex A (informative) Recommended Submittal Elements for SSDI Approval Requests 15

Annex B (informative) Summary of Primary Response Options 27

Annex C (informative) Example Timeline for Utilizing Subsea Dispersant Injection 32

Annex D (informative) Subsea Dispersant Initial Injection Rate Calculation Example 33

Bibliography 34

Figures

1. Subsea Dispersant Use Decision-making Process 7

2. General Surface and Subsea Dispersant Guide 8

3. Examples of Organization Elements with Significant SSDI Roles 9

4. Examples of Organization Elements with Significant SSDI Roles 10

1. SSDI Approval Signature Page 16

2. Initial Incident Data Sheet 19

3. Recommended Minimum Parameters for Predictive 3-D Modeling 22

4. Example Subsea Dispersant Injection Operational Plan Components 24

5. SIMA Illustration 26

C.1 Subsea Dispersant Operations Process Timeline (hours) 32

Tables

1. SSDI Readiness to Execute 17

   v

   Contents

2. Example Table of Water Column Resources at Risk for the

   Page

   Western Gulf of Mexico Developed by NOAA 20

3. Example of a Subsea Dispersant Monitoring Plan Development and Implementation Checklist 23

4. Example Subsea Dispersant Injection Critical Equipment Checklist 25

vi

Introduction

Subsea dispersant injection (SSDI) was used as a response method during the Deepwater Horizon oil spill of 2010. The Region VI Response Team (RRT VI) had pre-authorization plans for surface dispersant use in place, but concluded that those plans were not applicable to a subsea, relatively continuous application of dispersant. As a result, incident-specific implementation policies were developed during the course of the response. Since 2010, several command-post exercises sponsored by industry have indicated that existing policies and guidance can be enhanced for operational decisions relating to the use of subsea dispersant.

To clarify what type of information may be required by RRTs to support subsea dispersant–use decisions, the API D3 Subsea Dispersants Joint Industry Task Force developed guidelines for industry on recommended procedures for seeking FOSC authorization and RRT concurrence. These guidelines are based on lessons learned from the above- mentioned exercises and valued input from RRT VI agencies, which helped to continually improve the document to simulate the approval and concurrence of using subsea dispersants for exercise scenarios.

Dispersant use in the United States is governed by Subpart J of the National Contingency Plan (NCP), which is found at 40 CFR (Code of Federal Regulations), §300.910. This guidance offers clarification on how API has interpreted requirements of 40 CFR §300.910 as applied specifically to subsea dispersant use, but does not in any way modify the roles, requirements, and procedures contained therein. At the time of preparation of this document, the Environmental Protection Agency (EPA) had issued proposed revisions to Subpart J of the NCP. Some of the proposed revisions may alter recommendations contained in this guidance, and may be revised after publication of the EPA final rules.

vii

Industry Guidelines on Requesting Regulatory Concurrence for Subsea Dispersant Use

1. Scope

   
   

   The purpose of this document is to provide guidelines, forms, and checklists recommended for use by industry. The API guidelines describe the RRT concurrence request process, proposed information submission recommendations that are specific to subsea dispersant injection, and the use of Spill Impact Mitigation Analysis (SIMA) and other forms of tradeoff analyses as decision support tools. Also included are practical flowcharts and checklists specific to Incident Management Team (IMT) positions that are integral to subsea dispersant use, and guidance on the preparation of subsea dispersant operations and monitoring plans. This document provides operational guidelines intended for actual events or exercises and provides a basis for engagement from a range of relevant stakeholders.

   
   

   This document provides guidelines for the regulatory approval in accordance with Subpart J for the use of subsea dispersants in the United States with several U.S. references since subsea dispersants were first used for one incident in the United States. The lessons learned captured by numerous companies, in addition to input from members of IPIECA and IOGP, serve as a baseline for initial guidance to share with other countries and organizations to assist in developing their own guidelines.

   
   

   NOTE The main text of this document provides context, and the annexes represent the work tools and templates that can serve as part of a submission package.

   
   

2. Acronyms and Abbreviations

CERA consensus ecological risk assessment DOC Department of Commerce

DOI Department of Interior

DOR dispersant-to-oil ratio

DWH Deepwater Horizon

EDMU Environmental Data Unit

EPA Environmental Protection Agency

EFH Essential Fish Habitats

ESA Endangered Species Act

EU Environmental Unit

EUL Environmental Unit Leader

FWS Fish and Wildlife Service

FOSC Federal On-Scene Coordinator

GOM Gulf of Mexico

ICS Incident Command System

ISB in-situ burn

IMT Incident Management Team

LEL lower explosive limit

LSC Logistics Section Chief

1

2 API BULLETIN 4719

MV monitoring vessel

NCP National Contingency Plan

NEBA net environmental benefit analysis NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration NRC National Response Center

NRS National Response System

NRT National Response Team

OSC Operations Section Chief

OPS Operations Section

PS Planning Section

PSC Planning Section Chief

QI/IC Qualified Individual/Incident Commander RAR resources at risk

ROV remotely operated vehicle

RP Responsible Party

RRT Region Response Team

SCB Source Control Branch

SCS Source Control Section

SDU Subsea Dispersant Unit

SIMA spill impact mitigation assessment

QAPP Quality Assurance Project Plan SIMOPS simultaneous operations

SO Safety Officer

SSDI subsea dispersant injection

UC Unified Command

USCG United States Coast Guard

VOC volatile organic compounds

WCD worst-case discharge

3 Overview

3.1 General

The National Contingency Plan (NCP) establishes the National Response System (NRS) for oil and hazardous substances response actions. The NCP defines the roles of its major components, which include the National Response Team (NRT), the Regional Response Team (RRT), the Federal On-Scene Coordinator (FOSC), and Unified Command (UC), for managing incident-specific response actions of the federal government, state government, and the responsible party. The following section summarizes the key roles of each in authorizing and implementing subsea dispersant use, and proposes a concurrence process that is specific to subsea dispersant injection.