USE OF DISPERSANTS - U.S. National Response Team (NRT)

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CommanderSeventh Coast Guard DistrictBrickell PlazaFederal Building909 SE First AvenueMiami, Florida 33131-3050Staff Symbol: (m)Phone: (305) 536-5651Mr. Charles OravetzProtected Species Management BranchNational Marine Fisheries Service9721 Executive Center Drive NorthSt. Petersburg, Florida 337021646522 Jan 97Dear Mr. Oravetz:In accordance with the requirements of the Endangered Species Act and 50 CFR 402.12, I am enclosing for youreview and concurrence our “Biological Assessment of Effects on Listed Species of Caribbean Regional ResponseTeam Letters of Agreement on Limited Use of Oil Spill Dispersants.”These Letters of Agreement (LOA) pre-authorize the limited use of dispersants by the pre-designated U.S. CoastGuard Federal On-Scene Coordinator on oil discharges impacting the waters of the Commonwealth of Puerto Ricoand the Territory of the U.S. Virgin Islands. These LOAs implement Subpart J of the National Oil and HazardousSubstances Contingency Plan (NCP) and are signed by the U. S. Coast Guard, U.S. Environmental ProtectionAgency, the U.S. Department of the Interior, the U.S. Department of Commerce, and the Commonwealth of PuertoRico, and Territory of the U.S. Virgin Islands. It is understood that this may constitute a federal action in areaswhere endangered and threatened species are known to occur and consultation under Section 7 of the EndangeredSpecies Act may be required.Our biological assessment indicates that the listed species are not likely to be adversely affected by this action. Theuse of dispsersants offers strong potential for net environmental benefit during an oil spill by allowing for increasedprotection of nearshore, shoreline, and down-current biological resources and habitat and provides for a more rapidremoval of oil from the environment thus subjecting fewer resources to potential impact.Commander Bradford Benggio, National Oceanic and Atmospheric Administration (NOAA) Scientific SupportCoordinator to the Seventh Coast Guard District has discussed this matter with LT David Bernlardt of your staff andwith Commander Gary Petrae, U.S. Department of Commerce trustee representative to the Caribbean RegionalResponse Team.Thank you for your efforts in this review. With your concurrence, a formal consultation should not be necessary. Ifyou have any questions or desire further information, please contact Mr. Eric Wolfe at (305) 536-3060.Sincerely,Encl: (1) Biological Assessment(2) LOA Puerto Rico(3) LOA U.S. Virgin Islands//s//R. C. WIGGERCaptain, U.S. Coast GuardChief, Marine Safety DivisionSeventh Coast Guard DistrictBy direction of the District Commander
Biological Assessment of Effects on Listed Species of Caribbean Regional Response TeamLetters of Agreement on limited Use of Oil Spill DispersantsDescription of Proposed ActionThe proposed actions are two Caribbean Regional Response Team (Caribbean RRT/CRRT) Letters of Agreementpre-authorizing limited use of dispersants by the pre-designated United States Coast Guard (USCG) On-SceneCoordinator (OSC) on oil discharges impacting the waters of the Commonwealth of Puerto Rico and the Territory ofthe U.S. Virgin Islands. The Letters of Agreement implement Subpart J of the National Oil and HazardousSubstances Contingency Plan (NCP) and are signed by the USCG, U.S. Environmental Protection Agency (USEPA),U.S. Department of Interior (USDOI), the U.S. Department of Commerce (USDOC), and the Commonwealth ofPuerto Rico, and the Territory of the U.S. Virgin Islands.The Caribbean RRT agrees that the primary method of controlling discharged oil shall be physical removal for theenvironment. The Caribbean RRT recognizes, however, that in certain instances physical containment, collection,and removal of oil may not be possible and the use of dispersants must be considered in order to prevent substantialthreat to public health or serious environmental damage. By breaking a cohesive surface oil slick into small dropletsthat disperse into the water column, dispersants can prevent an offshore oil spill from contaminating wildlife andcritical habitat in nearshore and shoreline areas.The Caribbean RRT strongly recommends that, to be effective, application of dispersants should be targeted to beginnot later than six hours after an oil spill. Accordingly, employment of dispresants usually requires that authorizationfor use be given prior to a spill incident. Within areas pre-authorized for use of dispersants by the Letters ofAgreement, further consultation by the USCG OSC is not required, provided the appropriate CRRT agencies areimmediately notified and applicable protocols are followed. Pre-authorization allows the USCG OSC to order theuse of dispersants, as defined in the National Contingency Plan (NCP) and listed on the USEPA NCP ProductSchedule, when in the judgment of the USCG OSC their use is necessary to prevent substantial threat to publichealth or welfare or to minimize serious environmental damage. The Letters of Agreement are not intended toexclude or replace the use of mechanical, in-situ burning, or other open-water cleanup methods but to enable andencourage the use of all appropriate techniques in the strategy to remove oil from the water surface and, thereby,minimize environmental impacts of a spill.If a decision to use dispersants is made, the USCG OSC will immediately notify the USEPA, USDOC, USDOI, theCommonwealth of Puerto Rico, and the Territory of the U.S. Virgin Islands through CRRT representatives. A postincidentbriefing will be held within 45 days following an application of dispersants to exchange information oneffectiveness of the application and to determine whether changes to the Letters of Agreement are necessary.Description of Pre-authorization AreaPre-authorization Area for the Commonwealth of Puerto Rico:Dispersants are pre-authorized for use only in open waters that are at least 0.5 nautical miles from any shoreline andwhere the water depth if greater than 60 feet.Dispersants are not pre-authorized for use in, on, or over waters containing reefs, waters designated as marinereserves, mangrove areas, fresh or brackish waters or waters in coastal wetlands; except with the prior and expressconcurrence of the Puerto Rico Department of Natural Resources and USEPA, in consultation with USDOC andUSDOI. Coastal wetlands include: submerged algal beds (rocky or unconsolidated bottom), submerged seagrassbeds, and coral reefs.Pre-authorization Area for the Territory of the U.S. Virgin Islands:Use of dispersants is pre-authorized only in open waters that are at least one mile from any shoreline, or at least one
Page 2 and 3: UPDATES AND CHANGESCHANGE OR UPDATE
Page 6 and 7: CARIBBEAN REGIONAL RESPONSE TEAMPOL
Page 9 and 10: SECTION IPurposeThis policy provide
Page 11 and 12: 2. YELLOW ZONE - WATERS REQUIRING C
Page 13 and 14: SECTION IIIProtocolsTHE FOLLOWING R
Page 15 and 16: APPENDICES
Page 17 and 18: Caribbean Regional Response TeamDis
Page 27: Caribbean Regional Response TeamDis
Page 34 and 35: mile from any reef which is less th
Page 36 and 37: high exposure levels, volatile hydr
Page 38 and 39: a few days or weeks, unmetabolized
Page 40 and 41: 1990. Geraci, J.R. and D. J. St. Au
Page 42 and 43: CommanderSeventh Coast Guard Distri
Page 44 and 45: Biological Assessment of Effects on
Page 46 and 47: The dispersed oil droplets, ranging
Page 48 and 49: Sea TurtlesSea turtles can be expos
Page 50 and 51: Most aquatic organisms have the abi
Page 52 and 53: Ernst, C.H., J. Lovich, and R.W. Ba
Page 54 and 55: Appendix IIIDispersant Use Monitori
Page 56 and 57: Dispersant Use Monitoring Program w
Page 58 and 59: APPENDIX IVDispersant Use Decision
Page 60 and 61: - dispersant composition;- water sa
Page 62 and 63: For Puerto Rico:1) the waters are n
Page 64 and 65: DOCUMENTATION/APPLICATION FORM FORD
Page 66 and 67: 2. Type of aircraft used __________
Page 68 and 69: Letter of AgreementCommonwealth of
Page 70 and 71: 300. SCOPE301. The USCG, USEPA, USD
Page 72 and 73: debriefing will gather information
Page 74 and 75: LETTER OF AGREEMENTON LIMITED USE O
Page 76 and 77: LETTER OF AGREEMENTON LIMITED USE O
Page 78 and 79: minimize substantial threat to publ
Page 80 and 81: Appendix VIDispersant Use Operation
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APPENDIX VIDispersant Use Operation
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APPENDIX VI TABLE OF CONTENTSSECTIO
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ICS DISPERSANT USE ORGANIZATIONAL R
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DISPERSANT USE DECISION / IMPLEMENT
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DISPERSANT APPLICATION PLATFORM CAP
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DISPERSANT APPLICATION OPERATIONAL
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DISPERSANT OPERATION PLAN CHECKLIST
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GENERAL:OBSERVATIONS:PHOTOGRAPHY:In
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Incident CommanderOperations Sectio
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DISPERSANT / APPLICATION FORM FROM
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DISPERSANT / APPLICATION FORM FROM
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[This page intentionally blank]
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• Comply with the dispersant use
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• Coordinates and is lead for any
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SPRAYER LOG SHEET(Completed by Spra
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OBSERVATION AIRCRAFT / VESSEL / "OB
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• The visibility of the dispersed
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Duration of FlightPreferred Altitud
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DISPERSANT OBSERVATION FINAL REPORT
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SITE SAFETY PLAN TEMPLATE FOR DISPE
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Adequate protection may be achieved
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(404)639-0615 (24 hr) (voice) 0655
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GENERIC SITE SAFETY PLAN FOR DISPER
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• From a safe distance (at least
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SAFE APPROACH TO A HELICOPTERAPPROA
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c. Optimum storage temperature rang
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X. ANALYSIS FOR HEAVY METALS AND CH
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wear long sleeve shirt, chemical re
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8. Solvents: CONFIDENTIAL9. Additiv
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___ rubber steel toe/shank safety b
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USE OF DISPERSANTS - U.S. National Response Team (NRT)

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