Ocean Pollution EPA Regulations Regarding Incineration Over 6,000 people attended a U.S, Environmental Protection Agency public hearing held in Brownsville, Texas, in 1983. The hearing, which concerned whether a permit should be granted for Incineration of PCB- and DDT-containing wastes in the Gulf of Mexico, was the largest public hearing in EPA history and reflected intense public concern about the technology. Appendix I Overview of In-situ Burning as an Oil Spill Response Tool Appendix II In-situ Burning Plan this Appendix is an example of the information pertinent to in-situ Burning; it was developed for Oceania and must be adapted for the area off the California Coast Appendix III In-situ Burning Monitoring Plan [this is an example from Oceania, and it must be adapted for the area off the California Coast] Appendix IV Site Safety Plan for In-situ Burning - [Oceania Site Safety Plan included as example; some language has been adapted for the area off the California Coast] Appendix V In-situ Burn Boom Operations Procedures [Oceania version included as example. LA-LB Sector ACP Section 3000 March 30, 2006 OVERVIEW OF IN-SITU BURNING AS AN OIL SPILL RESPONSE TOOL Burning has distinct advantages over other spill response tools. First, it offers the potential to remove large quantities of oil rapidly from the environment. In-situ burning could potentially remove as much oil in one day as mechanical methods could in one month. In addition, in-situ burning could prevent a large amount of shoreline contamination and injury to biota by removing oil before it spreads and moves to other areas. Second, in-situ burning requires less equipment and personnel than do other response tools. It can be used in areas where other methods cannot because of distances and lack of infrastructure. Third, burning significantly reduces the volume of material requiring disposal - compared to mechanical recovery. Mechanically -recovered oil must still be transported, stored, and properly disposed. This involves equipment, personnel, time, money, and an approved Resource Conservation and Recovery Act (RCRA) disposal site. Often, these resources are not available in sufficient quantities when large spills occur. Burning also has disadvantages. The most obvious are the large black smoke plume that is produced by burning oil and concerns about potential associated health effects. Additionally, oil must be a minimum thickness of 2 to 3 millimeters (mm) to burn efficiently; thin slicks will not burn. This can be partially countered with the use of fire booms to concentrate oils into thicker slicks before burning. However, as oil spreading and dispersion take place over time, the ability to achieve this minimum thickness becomes increasingly difficult. In-situ burning is considered a trade-off between the ability to remove large amounts of spilled oil from the water surface in a short period of time and the human health effects and ecological impacts of burn by-products. Preliminary data from recent test burns indicate that airborne emissions are not a serious concern at distances greater than a few miles, given the proper atmospheric conditions. ECOLOGICAL EFFECTS Potential ecological impacts resulting from the use of in-situ burning have not been extensively studied. Whether in-situ burning does result in ecological impacts cannot be directly determined based on existing information. Potential biological impacts are the subject of planned field and laboratory tests. The surface area affected by burning oil is usually small relative to the total surface area of a given body of water, relative to the total depth of the water body, and is less than the area impacted by the oil slick. This does not preclude adverse ecological effects. The possibility remains that contamination at the sea surface could affect certain unique populations as well as organisms that use surface layers of the water column at certain times to spawn or feed. However, because the distribution of these populations is patchy, these impacts would most likely be localized. The same populations would also be adversely affected to some degree by an oil slick. The plume or heat from the burn will not result in greater impact to populations. Burn residues could be ingested by fish, birds, mammals, etc. and could be a source of fouling of wildlife; however, it should be noted that the water surface is already adversely affected by oil, and any additional adverse effects from burning would be comparatively small. The extent of these spatial and temporal effects would be expected to be much less severe than those from a large oil spill contained by traditional mechanical methods. The residual material should be removed as soon as possible, and this could be accomplished using traditional spill containment and cleanup equipment and techniques. Measurements conducted during test burns show that water temperature is not raised significantly, even in shallow confined test tanks. Thermal transfer to the water is limited by the insulating oil layer and is actually the mechanism by which the combustion of oil slicks is extinguished. Except where conditions of pre-approval are met, the appropriate State and the Federal trustees (e.g., NOAA, DOI) are to be consulted before using in-situ burning on oil spills. They can identify resources of concern in the area that could be potentially adversely affected by burning in situ.. Interests include but are not limited to: 1) the proximity of occurrence of the proposed burn in coastal marshes and estuaries and inland marsh/wetland environments; 2) the occurrence and location of threatened and endangered species in relation to the proposed burn site; 3) the occurrence and location of sensitive/critical habitat or resources (e.g., land) in relation to the proposed burn site; and 4) the benefits to sensitive habitats of burning versus the effects resulting from the land fall of oil.