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API Bull 4719 Industry Guidelines on Requesting Regulatory Concurrence for Subsea Dispersant Use, FIrst Edition
standard by American Petroleum Institute, 06/01/2017
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API BULLETIN 4719
FIRST EDITION, JUNE 2017
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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.
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Industry Guidelines on Requesting Regulatory Concurrence for Subsea Dispersant Use
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.
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
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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
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.