Oil and Hazardous Substances Integrated Contingency Plan


To Report Spills Call the National Response Center
24-hour phone: (800) 424-8802
National Response Center
United States Coast Guard Headquarters
Washington, DC

Regional Response Centers & Emergency Response 24-Hour Emergency Numbers
(312) 353-2318
U.S. Environmental Protection Agency
Region 5
Waste Management Division
Office of Superfund
Emergency and Enforcement Response Branch
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
(216) 522-3984
United States Coast Guard
Ninth Coast Guard District Office
1240 East Ninth Street
Cleveland, Ohio 44199-2060
(504) 589-6225
United States Coast Guard
Eighth Coast Guard District Office
Director of Western Rivers Operations
501 Magazine Street
New Orleans, Louisiana 70130-3396
U.S. Environmental Protection Agency

Oil and Hazardous Substances Pollution/
Area Contingency Plan



 

Table of Contents

i. LETTER OF PROMULGATION
ii. DEFINITIONS
iii. NCP CROSSWALK

Section 1: Introduction

Section 2: Command

Section 3: Operations

Setion 4: Planning

Section 5: Logistics/p>

Section 6: Finance

APPENDIX I: JURISDICTIONS IN REGION 5
APPENDIX II: FEDERALLY RECOGNIZED NATIVE AMERICAN TRIBES IN REGION 5
APPENDIX III: CURRENT MEMBERS OF STANDING RRT
APPENDIX IV: WORST-CASE DISCHARGES IN REGION 5
APPENDIX V: SHORELINE CLEANUP GUIDELINE MATRICES
APPENDIX VI: OPTIONS FOR MINIMIZING ENVIRONMENTAL IMPACTS OF FRESHWATER SPILL RESPONSE ACTIONS
APPENDIX VII: CHEMICAL USE CHECKLIST
APPENDIX VIII: IN SITU BURNING OF OIL
APPENDIX IX: FISH AND WILDLIFE ANNEX
APPENDIX X: STATE HISTORIC PRESERVATION OFFICERS IN REGION 5
APPENDIX XI: ECONOMICALLY AND ENVIRONMENTALLY SENSITIVE AREA INDICES
APPENDIX XII: CONTINGENCY PLANNING
APPENDIX XIII: STATE EMERGENCY INFORMATION
APPENDIX XIV: ALTERNATIVE RESPONSE TOOL EVALUATION SYSTEM (ARTES)
APPENDIX XV: ACRONYMS

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LETTER OF PROMULGATION

In accordance with the provisions of the Federal Water Pollution Control Act of 1972 as amended by the Clean Water Act of 1977, and Section 105 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, a National Oil and Hazardous Substances Contingency Plan was developed by the United States Environmental Protection Agency (U.S. EPA). Section 300.41 of the National Contingency Plan states that Regional Contingency Plans shall be prepared for each standard Federal region. The Region 5 Oil and Hazardous Materials Contingency Plan has been developed with cooperation of all designated Federal Agencies and State governments. This plan provides a mechanism for coordinating responses to releases of oil or hazardous materials within the States of Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin, and within the Tribal lands of the 31 Federally recognized Native American Tribes in Region 5.

This plan is effective upon receipt and supersedes the previous plans* in their entirety. Changes to this plan will be noted and consecutively numbered. Comments and recommendations regarding this plan should be addressed to U.S. EPA Region 5. Requests for amendments and changes will be addressed during regularly scheduled RRT meetings.

Copies of this plan may be obtained from:

U.S. Environmental Protection Agency
Office of Superfund (HSE-5J)
77 West Jackson Boulevard
Chicago, IL 60604

Richard Karl, Chief Captain Thomas Daley
Emergency Response Branch Chief, Marine Safety Division
U.S. Environmental Protection Agency U.S. Coast Guard
Region 5 Ninth Coast Guard District
Co-Chair, Region 5 RRT Co-Chair, Region 5 RRT

* Note: This plan incorporates and supersedes US EPA Region 5 Inland Plan.

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iii. DEFINITIONS

Area Committee: As provided for by Sections 311(a)(18) and (j)(4) of the Clean Water Act (CWA), means the entity appointed by the President consisting of members from qualified personnel of Federal, State, and local agencies with responsibilities that include preparing an Area Contingency Plan for the area designated by the President. The Area Committee may include ex-officio (i.e., non-voting) members (e.g., industry and local interest groups).

Area Contingency Plan: As provided for by Sections 311(a)(19) and (j)(4) of CWA, means the plan prepared by an Area Committee that is developed to be implemented in conjunction with the NCP and RCP, in part to address removal of a worst case discharge and to mitigate or prevent a substantial threat of such a discharge from a vessel, offshore facility, or onshore facility operating in or near an Area designated by the President.

coastal waters: As defined in the NCP, for the purposes of classifying the size of discharges, the waters of the coastal zone except for the Great Lakes and specified ports and harbors on inland rivers. Precise boundaries are identified in U.S. Coast Guard/U.S. Environmental Protection Agency agreements, Federal Regional Contingency Plans and Area Contingency Plans.

coastal zone: As defined in the NCP, all United States waters subject to the tide, United States waters of the Great Lakes, specified ports and harbors on inland rivers, waters of the contiguous zone, other waters of the high seas subject to the NCP, and the land surface or land substrata, ground waters, and ambient air proximal to those waters. The term coastal zone delineates an area of Federal responsibility for response action. Precise boundaries are determined by U.S. EPA/USCG agreements and identified in Federal Regional Contingency Plans. No ports or harbors are designated in Region 5.

discharge: As defined by Section 311(a)(2) of CWA, includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil, but excludes discharges in compliance with a permit under Section 402 of the CWA, discharges resulting from circumstances identified and reviewed and made a part of the public record with respect to a permit issued or modified under Section 402 of the CWA, and subject to a condition in such permit, or continuous or anticipated intermittent discharges from a point source, identified in a permit or permit application under Section 402 of the CWA, that are caused by events occurring within the scope of relevant operating or treatment systems. For purposes of the NCP, discharge also means substantial threat of discharge.

drinking water supply: As defined by Section 101(7) of CERCLA, means any raw or finished water source that is or may be used by a public water system (as defined in the Safe Drinking Water Act, 42 U.S.C. et seq.) or as drinking water by one or more individuals.

economically sensitive areas: Those areas of explicit economic importance to the public that due to their proximity to potential spill sources may require special protection and include, but are not limited to: public water supplies, publicly managed use areas, and Tribal use areas.

Emergency Planning and Community Right-to-Know Act (EPCRA): Title III Section 300. of SARA; created a system of State and local planning agencies for chemical emergencies and provided a way for communities to gain information about potential chemical hazards. EPCRA's mandates cover three main topics: emergency planning, emergency notification requirements, and requirements for reporting hazardous chemical inventories.

environmentally sensitive areas: Areas identified as a priority for protection and special attention during cleanup in the event of a pollution incident. Designations of types of areas considered to be sensitive can be found in 1) the U.S. Fish and Wildlife Annex (Appendix IX) and 2) the Guidance for Facility and Vessel Response Plans Fish and Wildlife and Sensitive Environments, published by Department of Commerce/National Oceanic and Atmospheric Administration. In addition to this definition, Area Committees may include any additional areas determined to be "sensitive." These areas are mapped in Region 5 and are available on paper and CD-ROM as a companion to this Plan. 4202.(a)(4)(B)(ii)

hazardous substance: As defined by section 101(14) of CERCLA, any substance designated pursuant to section 311(b)(2)(A) of the CWA; any element, compound, mixture, solution, or substance designated pursuant to section 102 of CERCLA; any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (but not including any waste the regulation of which under the Solid Waste Disposal Act [42 U.S. C. 6901 et seq.] has been suspended by Act of Congress); any toxic pollutant listed under section 307(a) of the CWA; any hazardous air pollutant listed under section 112 of the Clean Air Act; and any imminently hazardous chemical substance or mixture with respect to which the U.S. EPA Administrator has taken action pursuant to section 7 of the Toxic Substances Control Act (TSCA). This term does not include petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance in the first sentence of this paragraph, and does not include natural gas, natural gas liquids, liquified natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and synthetic gas).

inland waters: As defined in the NCP, for the purposes of classifying the size of discharges, means those waters of the United States in the inland zone, waters of the Great Lakes, and specified ports and harbors on inland rivers.

inland zone: As defined in the NCP, means the environment inland of the coastal zone excluding the Great Lakes and specified ports and harbors on inland rivers. The term inland zone delineates an area of Federal responsibility for response action. Precise boundaries are determined by U.S. EPA/USCG agreements and identified in Federal regional contingency plans.

Local Emergency Planning Committee (LEPC): A group of local representatives appointed by the State Emergency Response Commission (SERC) to prepare a comprehensive emergency plan for the local emergency planning district, as required by the Emergency Planning and Community Right-to-know Act (EPCRA), Title III Section 301(c) of SARA.

National Oil and Hazardous Substances Pollution Contingency Plan (NCP): As required by section 105 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. 9605, as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), Pub. L. 99-499, collectively called (CERCLA), and by section 311(d) of the Clean Water Act (CWA), 33 U.S.C. 1321(d), as amended by the Oil Pollution Act of 1990 (OPA), Pub. L. 101-380, the NCP provides nationwide organizational structure and procedures for responding to discharges of oil and releases of hazardous substances, pollutants and contaminants. In Executive Order (E.O.) 12777 (56 FR 54757, October 1991), the President delegated to the Environmental Protection Agency (EPA) the responsibility for the amendment of the NCP in coordination with members of the National Response Team (NRT) as well as the Federal Emergency Management Agency (FEMA) and the Nuclear Regulatory Commission to avoid inconsistent or duplicative requirements in the emergency planning responsibilities of those agencies.

National Pollution Fund Center (NPFC): As defined by Section 7 of Executive Order 12777, the NPFC is the entity established by the Secretary of the Department of Transportation whose function is the administration of the Oil Spill Liability Trust Fund (OSLTF). This includes access to the OSLTF by Federal Agencies, States, and designated trustees for removal actions and initiation of natural resource damage assessments, as well as claims for removal costs and damages.

Natural Resource Trustees: Officials representing State, Tribal, Federal, and foreign governments who are authorized to act pursuant to section 107(f) of CERCLA, section 311(f)(5) of the CWA, or section 10006 of the OPA when there is injury or threat to natural resources, including their supporting ecosystems, as a result of a release of a hazardous substance or a discharge of oil. Natural resources means land, fish, wildlife, biota, air, water, ground water, drinking water supplies, and other such resources.

navigable waters: As defined by 40 CFR 110.1, the term navigable waters includes: (a) All waters that are currently used, were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters that are subject to the ebb and flow of the tide; (b) Interstate waters, including interstate wetlands; (c) All other waters such as intrastate lakes, rivers, streams, mudflats, sandflats, and wetlands, the use, degradation, or destruction of which would affect or could affect interstate or foreign commerce including any such waters: (1) That are or could be used by interstate or foreign travelers for recreational or other purposes; (2) From which fish or shellfish are or could be taken and sold in interstate or foreign commerce; (3) That are used or could be used for industrial purposes by industries in interstate commerce; (d) All impoundments of waters otherwise defined as navigable waters under this Section; (e) Tributaries of waters identified in (a) through (d) of this definition, including adjacent wetlands; and (f) Wetlands adjacent to waters identified in (a) through (e) of this definition: Provided, that waste treatment systems (other than cooling ponds meeting the criteria of this paragraph) are not waters of the United States. Water of the United States do not include prior converted cropland. Notwithstanding the determination of an area's status as prior converted cropland by any other Federal Agency, for the purposes of the CWA, the final authority regarding CWA jurisdiction remains with U.S. EPA.

oil: As defined by Section 311(a)(1) of CWA, means oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil. Oil, as defined by Section 1001 of OPA means oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged oil, but does not include petroleum, including crude oil or any fraction thereof, which is specifically listed or designated as a hazardous substance under paragraphs (A) through (F) of Section 101(14) of CERCLA (42 U.S.C. 9601) and which is subject to the provisions of that Act.

Oil Spill Liability Trust Fund (OSLTF): As defined by the NCP, means the fund established under Section 9509 of the Internal Revenue Code of 1986 (26 U.S.C. Section 9509).

On-Scene Coordinator (OSC): As defined by the NCP, means the Federal official predesignated by U.S. EPA or USCG to coordinate and direct responses, or the government official designated by the lead agency to coordinate and direct removal actions under the NCP. In certain site-specific situations, DOD or DOE may also act as OSC.

Region 5 Integrated Contingency Plan (ICP): Developed to fulfill the requirements of the NCP for both the RCP and Area Contingency Plans (ACP), as well as relevant portions of the Federal Response Plan (FRP), particularly Emergency Support Function #10 for Hazardous Materials (ESF #10)

Regional Oil and Hazardous Substances Pollution Contingency Plan (RCP): As provided for by Section 300.210 (b) of the NCP, and under the auspices of the Regional Response Team (RRT), the RCP is the mechanism for planning and coordinating regional preparedness and response actions for discharges of oil and releases of hazardous substances.

Regional Response Team (RRT): As defined in the NCP, the regional response organization (consisting of a representative from each State in the region and representatives from 15 Federal Agencies) which acts as a regional body responsible for regional planning and coordination of preparedness and response actions involving oil and hazardous materials. The RRT coordinates assistance and advice to the OSC in the event of a major or substantial spill. State Emergency Response Commission (SERC): As provided in SARA Section 301.(a), an individual or group of officials appointed by the State governor to implement the provisions of EPCRA (see above). The SERC coordinates and supervises the work of the Local Emergency Planning Committees and reviews local emergency plans annually.

Tribal Emergency Response Commission (TERC): A group of officials appointed by Native American governing bodies to implement the provisions of Title III of SARA.

used oil: Any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities.

waste oil: For the purposes of this Plan waste oil is any oil that has been refined from crude oil, or any synthetic oil, that has been physically or chemically contaminated as a result of a spill.

wetlands: Those areas that are inundated or saturated by surface or groundwater at a frequency or duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include playa lakes, swamps, marshes, bogs, and similar areas such as sloughs, prairie potholes, wet meadows, prairie river overflows, mudflats, and natural ponds (40 CFR 112.2[y]).

worst case discharge: As defined by section 311(a)(24) of the CWA, means, in the case of a vessel, a discharge in adverse weather conditions of its entire cargo and, in the case of an offshore facility or onshore facility, the largest foreseeable discharge in adverse weather conditions.

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NCP Crosswalk


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SECTION 1: INTRODUCTION

1.1: Introduction
1.2: Purpose and Objective
1.3: Authority
1.4: Scope and Provisions
1.5: Updating
1.6: Consistency with state, federal, and tribal statutues

1.1. INTRODUCTION

This Region 5 Oil and Hazardous Substances Integrated Contingency Plan (ICP) is intended for use by local, Tribal, State, and Federal emergency response personnel as a tool for procuring resources to respond to an oil or hazardous materials incident. It outlines the response mechanisms that would be activated among the various levels of the response community in the event of an emergency situation. It is not intended to displace local emergency response plans, but rather it is intended to coordinate with local plans and build on the mechanisms set forth in State plans.

The Federal On-Scene Coordinator (OSC) is the link between local and State emergency response communities and Federal response efforts.

This ICP outlines:

(a) the types of assistance available to Federal OSCs from Regional Response Team (RRT) member agencies during response actions, and

(b) the cooperative response that should be carried out by OSCs during response actions.

The plan also includes resource information from governmental, commercial, and other sources that may be utilized during a response.

This plan has been organized to follow the structure of the Incident Command System (ICS), as outlined in the Integrated Contingency Plan guidance developed by the National Response Team (NRT), but this will be appended by reference in this plan.

This plan combines the response authorities relevant for both oil and hazardous materials. Although these releases and the related contingency planning are regulated separately under the Oil Pollution Act of 1990 (OPA) and the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), there is significant overlap in the type and scope of relevant information. In order to minimize confusion and maximize resources, the two plans are combined herein. In order to meet some of the requirements of OPA, subarea plans are being developed separately, but will be referenced in this ICP.

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1.2. PURPOSE AND OBJECTIVE

The purpose of this combined ICP is to fulfill the requirements of Sections 300.210(b) and (c), of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), and Section 311(j)(4) of the Clean Water Act (CWA) as well as relevant portions of the Federal Response Plan (FRP), particularly Emergency Support Function #10 Hazardous Materials (ESF #10). The ICP is designed to coordinate timely and effective response among
· local, Tribal, and State officials;
· private industry;
· OSCs;
· Remedial Project Managers (RPMs);
· various Federal Agencies; and
· other organizations
to minimize damage resulting from releases of oil or hazardous substances, pollutants, or contaminants.

The objective of this plan is to describe response protocols and assist in providing a coordinated response capability in the event of a release or spill that poses a threat to the environment or to human health and welfare. The initial actions taken by the OSC and/or other appropriate personnel should be to determine whether proper response actions have already been initiated.

In general, if the party or parties responsible for the release or spill do not take appropriate actions, or if the party or parties responsible for the release or spill are unknown, the local response community or State agencies will become involved. If Federal assistance is requested or required, the OSC shall respond, implement provisions of the NCP and applicable agency guidance, and coordinate activities as outlined in this ICP.

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1.3. AUTHORITY

The RCP is developed pursuant to Section 300.210 of the NCP. The NCP is required by Section 105 of CERCLA, as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), by Section 311(d) of CWA, as amended by OPA. The ESF 10 components of this plan are required by the Robert T. Stafford Disaster Relief and Emergency Act (Public Law 93-288), as amended. The RCP is applicable to response actions taken pursuant to the authorities under CERCLA, Section 311 of CWA, and OPA. The NCP requires establishment of RRTs, which are responsible for Regional planning and preparedness activities before response actions, and for providing advice and support to the RRT when activated during a response.

The ACP is required by Section 311(j)(4) of CWA, and is written in conjunction with the NCP and CERCLA.

To accomplish the coordinated planning structure envisioned under OPA, Section 4202(a) of OPA requires the President to designate specific Areas for which Area Committees are established. Each Area Committee, under the direction of an OSC, must prepare and submit to the President for approval an ACP that, in conjunction with the NCP, is adequate to remove a worst case discharge from a vessel or facility operating in or near that Area.

Through Executive Order 12777, the President delegated to the Administrator of the United States Environmental Protection Agency (U.S. EPA) responsibility for designating the Areas and appointing the committees for the inland zone as designated in the NCP. The Administrator further delegated this authority to the U.S. EPA Regional Administrators, and designated the 10 pre-existing RRT areas as the Areas for OPA planning purposes. U.S. EPA Region 5, which consists of Illinois, Indiana, Minnesota, Michigan, Ohio, and Wisconsin, is one Area. Establishment of the Area Committee is required by Section 311(j)(4) of CWA.

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1.4. SCOPE AND PROVISIONS

This ICP:
(a) expands upon planning and response requirements set forth in the NCP,
(b) augments coordination with local and State authorities, and
(c) integrates existing local, Tribal, State, and private sector plans for the Area.

The U.S. EPA Region 5 RCP/ACP has been developed in coordination with the NCP and the United States Coast Guard (USCG) area plans. The Ninth Coast Guard District is covered by eight area contingency plans, seven of which are in Region 5. Each plan covers the coastal zone of the corresponding Marine Safety Office (MSO). Each USCG area contingency plan is developed by an area committee chaired by the respective Coast Guard Captain-of-the-Port.

USCG's eight area contingency plans cover, in part, how to respond to an oil or hazardous substance spill in the coastal zone of the Great Lakes and the connecting channels. This includes the identification, prioritization, and cleanup strategies for sensitive areas; and identification of contractors and equipment.

While U.S. EPA has chosen to combine its Area Contingency Plan for Region 5 into the existing Regional Contingency Plan to produce this joint document, the USCG's seven area contingency plans are separate documents, which are compatible with and may be used in conjunction with this ICP for spills which impact both the inland and coastal zones.

The ACP referred to in this Plan is the U.S. EPA Inland Plan unless otherwise stated. This plan applies to the Region 5 RRT (RRT5) member agencies and covers:

(a) discharge or threats of discharge of oil into or upon navigable waters of the United States and adjoining shorelines or which may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the United States;

(b) releases or substantial threats of release of hazardous substances into the environment; and

(c) releases or substantial threats of release of pollutants or contaminants that may present an imminent and substantial danger to public health or welfare in the States of Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin, and in the lands of the Federally recognized Native American Tribes in Region 5.

The ICP, when implemented in conjunction with other provisions of the NCP, shall be adequate to remove a worst case discharge and to mitigate or prevent a substantial threat of such a discharge.

The RCP portion of this plan covers response for all of Region 5. The ACP portion of this plan covers the inland portion only. Thus, when reading the plan, if the jurisdiction falls in the coastal zone, the spill will fall under the responsibility of the Coast Guard and will only be subject to the RCP components of this plan. If a jurisdiction is in the inland zone, both ACP and RCP components of this plan apply.

Certain groups of counties have been or will be designated as sub areas of the ACP and will be appended to the plan. They are chosen based on criteria for threat (proximity to large bodies of fresh water, number of facilities) and need for greater jurisdictional coordination. They may also contain portions of other adjacent areas to provide for a coordinated plan for spills affecting certain boundary locations.

See Appendix I for coastal zone boundaries.
See Appendix I for the jurisdictions in Region 5.

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1.5. UPDATING

Section 311(j)(4)(C)(viii) of CWA requires that the ACP be updated periodically by the Area Committee. For national consistency, it has been determined that the ACP will be updated annually for 5 years, starting January 1, 1995, and once every 5 years thereafter. The document may be updated more frequently, as policy changes require.

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1.6. CONSISTENCY WITH STATE, TRIBAL, AND FEDERAL STATUTES

Planning and response protocols and decisions may be subject to existing statutes (e.g., radiological emergencies that involve response by various agencies; disposal restrictions for oiled debris; compliance with the Endangered Species Act; State, Tribal, and Federal authorities to protect cultural and historic resources). RRT representatives will assist the OSC by involving the appropriate regulatory staffs.

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SECTION 2: COMMAND

2.1: Introduction
2.2: Incident Command Protocal/Liaison
2.3: Local Response
2.4: State Response
2.5: Native American Response
2.6: Federal Response
2.7: Multiregional Responses
2.8: National Response
2.9: International Response
2.10: Communications
2.11: Safety

2.1. INTRODUCTION

It is the policy of the RRT that response actions on non-Federal lands should be monitored or implemented by the most immediate level of government with authority and capability to conduct such activities. The first level of response will generally be the responsible party (RP), followed by local government agencies, followed by State agencies when local capabilities are exceeded. When incident response is beyond the capability of the State response, U.S. EPA or USCG is authorized to take response measures deemed necessary to protect the public health or welfare or the environment from discharges of oil or releases of hazardous substances, pollutants, or contaminants. The need for Federal response is based on evaluation by the Federal OSC.

2.1.1. Response to Public Safety and Property Threats Caused by Spills

When a spill poses public safety and property threats via potential fires, explosions, toxic clouds, or other means, local officials are usually in command of the incident. The party responsible for the incident is required to cooperate with and aid the local police and fire agencies. At some facilities, the responsible party conducts the response; at other facilities and in transportation incidents where the responsible party may not have the specialized capability to address an incident, public agencies direct the response. If highly specialized activities such as off-loading tank cars or repackaging hazardous chemicals are required, the responsible party may implement the actions under the general direction of the local public safety commander.

In most States, the role of State agencies in public safety response during the early stages of an incident is to provide technical advice to local commanders as soon as possible. During major incidents, State and Federal authorities may be able to provide additional assistance to the local commander at the spill scene by:
· conducting sampling and analysis of chemicals,
· providing specialized contractors or equipment, or
· providing detailed advice or other supporting functions.

Seldom will State or Federal authorities assume command from a local fire or police commander for short-term, on-site, public-safety-related issues.

2.1.2. Response to Environmental and Health Threats Caused by Spills

A number of State and Federal programs require parties who are responsible for a spill to investigate and remedy all related environmental and health threats. Often these actions include activities on properties owned by third parties or public agencies. The actions usually begin somewhat later than the public safety protection response, but can continue for a much longer period. The actions may include, but are not limited to:
· placing containment and recovery booms and pads,
· sampling runoff and rivers,
· excavating soil,
· sampling smoke,
· performing hydrogeological investigations,
· wildlife rescue and rehabilitation,
· closing drinking water intakes, and
· providing an alternate water supply.

Sometimes a responsible party is unable or unwilling to undertake adequately or quickly the environmental and health protection actions required by State or Federal authorities. In those cases, State or Federal authorities can assume a more direct role. Usually this is done through investigation or cleanup contractors using governmental funds, such as State or Federal Superfunds or the Oil Spill Liability Trust Fund (OSLTF). The costs of these direct government actions will usually be recovered later from the responsible party. The decision to assume governmental control of environmental and health followup of an incident is dependent on:
· the ability and willingness of the responsible party to respond effectively,
· the severity of the incident,
· the cost and duration of required actions, and
· the resources available to the various levels of government.

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2.2. INCIDENT COMMAND PROTOCOL/LIAISON

Federal law requires implementation of a site-specific incident command system by the senior emergency response official at all emergencies involving hazardous substances (29 CFR 1910.120 (q) and 40 CFR 311). The specific regulatory language suggests a seniority hierarchy increasing from local to State to Federal levels. Often the senior local or State official assumes command because they are most familiar with the resources immediately available. At the same time, it must be recognized that local, Tribal, State, and Federal responders are charged by law with specific authorities and responsibilities in certain emergency situations that cannot be subsumed. This protocol does not commit any parties adopting it to do anything not already required by Federal law.

An Incident Command System (ICS) shall be established at all incidents involving spills of oil or hazardous

substances1 by the senior on-scene official of the first response organization to arrive at an incident. The ICS should be based on the organization, terminology, and procedures recommended by the National Fire Academy2 and applied in a broad sense to include all hazard control and mitigation response organizations, including responsible parties; private responders; and local, Tribal, State, and Federal Agencies. Each participating entity is required by Federal law to implement an intra-organizational ICS and integrate it with the overall ICS (29 CFR 1910.120, 40 CFR 311, or 30 CFR 154).

A Unified Command System (UCS) consisting of the responsible party and senior competent local, Tribal, State, and Federal emergency response officials at the site may be the preferred approach to integrating several levels of government into an ICS. A UCS is a type of ICS in which parties with jurisdiction command by agreeing on objective priorities and response strategies.

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2.2.1. Single Jurisdictional Area Affected

When an incident involves and affects only a single geographical jurisdiction (e.g., within the boundaries of a city or county), the organizational structure of the ICS will be determined by the established local contingency plan. It may involve one or more agencies. In all situations, one person shall act as either Incident Commander (IC) in sole charge of the ICS, or as Operations Chief to implement the action plan of a Unified Command.

In such instances, responding State and Federal officials who might otherwise be considered the senior competent emergency response official at the site shall:

(1) identify themselves to the IC and integrate themselves into the established ICS per the IC's direction, usually as a technical specialist to an operations group supervisor or as an operations group supervisor; or

(2) join the existing Unified Command or request that the IC establish a Unified Command; or

(3)assume the Incident Commander role:
· when required by Federal or State law, or
· when an existing IC agrees to such a transition, or
· when no ICS has been established.

The protocols for ICS transfer of command or initial assumption of command shall be used.

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2.2.2. Multiple Jurisdictional Areas Affected

When the incident involves and affects multiple local geographical jurisdictions or areas not covered by local emergency response organizations, the State or Federal competent senior official at the site shall:

(1) preferably join an existing Incident Command or Unified Command as in subsection 2.2.1 (above); or

(2) establish a Unified Command as an encompassing ICS if none exists; or

(3) assume Incident Command and establish an ICS incorporating existing local efforts as operations section branches or as otherwise appropriate.

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2.2.3. Local, Tribal, State, and Federal Interaction

When not specifically prescribed, a Unified Command consisting of senior competent local, Tribal, State, and Federal emergency response officials at the site shall be the preferred approach to integrating several levels of government into an ICS. Where State law specifies incident command assignment, it shall take precedence over this protocol with respect to those State and local organizations to which it applies. Federal jurisdiction specified in CERCLA, OPA, or other sections of this RCP/ACP shall take precedence over this protocol.

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2.2.4. Seniority

For purposes of this plan, Seniority, as discussed in 29 CFR 1910.120(q)(3)(i)3, is ranked according to competency and breadth of responsibility.

Competency will be determined by meeting the requirements of 29 CFR 1910.120 (q)(6)(v).4 All officials meeting the competency criteria are senior to those who do not, unless specifically assigned overriding authority applicable to the specific incident situation by State or Federal law.

Breadth of responsibility will be considered to increase from the local to the State to the Federal level. However, this protocol encourages the establishment of the ICS at the most local level practicable to assure the earliest implementation of a unified response strategy.

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2.2.5. Post-Emergency Operations

This protocol is intended to apply only during the emergency phase of a response to which 29 CFR 1910.120(q) applies. However, use of an ICS throughout a response and cleanup is encouraged.

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1 The definition of hazardous substances used by the Occupational Safety and Health Administration (OSHA) is broader than the CERCLA definition used throughout this document.

2One set of common terminology and procedures is vital to the efficient functioning of an ICS in an emergency. The response management system recommended for use in the National Response Team (NRT) Integrated Contingency Plan (ICP) is the ICS of the National Interagency Incident Management System (NIIMS). NIIMS ICS is a nationally recognized system currently in use by numerous local, State, and Federal organizations. USCG has adopted this Unified Command System (UCS) protocol.

329 CFR 1910.120 (q)(3)(i): "The senior emergency response official responding to an emergency shall become the individual in charge of a site-specific Incident Command System (ICS). All emergency responders and their communications shall be coordinated and controlled through the individual in charge of the ICS assisted by the senior official present for each employer.

"NOTE to (q)(3)(i): The `senior official' at an emergency response is the most senior official on the site who has the responsibility for controlling the operations at the site. Initially it is the senior officer on the first-due piece of responding emergency apparatus to arrive on the scene. As more senior officials arrive (e.g., battalion chief, fire chief, State law enforcement official, site coordinator), the position is passed up the line of authority which has been previously established.

4 29 CFR 1910.120 (q)(6)(v): "On-scene incident commander. Incident commanders, who will assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder awareness level and in addition have competency in the following areas and the employer shall so certify:
(a) Know and be able to implement the employer's incident response system.
(b) Know how to implement the employer's incident response system.
(c) Know and understand the hazards and risks associated with employees working in chemical protective clothing.
(d) Know how to implement the local emergency response plan.
(e) Know of the State emergency response plan and of the Federal Regional Response Team.
(f) Know and understand the importance of decontamination procedures."

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2.3. LOCAL RESPONSE

The focus of local responders is usually directed toward abating immediate public safety threats. The degree of local response will depend upon the training and capabilities of local responders relative to the needs of the specific emergency. In some cases this may be using hazard awareness training knowledge to identify the nature and scope of the hazard. This information is then passed on to State and Federal responders who are activated to address the situation with specific expertise and/or capabilities. Often local agencies take mitigating actions of a defensive nature to contain the incident and protect the public. In many instances, responsible parties or local agencies are capable of aggressive response and quick abatement of immediate hazards. Usually in these cases, local authorities rely on State and Federal responders to assure that cleanup is complete and remediation is technically sufficient.

A major role of local organizations during all emergency incidents is providing security for onscene forces and equipment. For large incidents, help is often requested through State emergency management agencies. This includes establishing local liaison with hospital, emergency services, and police personnel, as well as restricting entrance to hazardous areas to only essential personnel.

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2.4. STATE RESPONSE

The Governor of each State in Region 5 is requested to designate a lead agencythat will direct State-lead response operations. This agency is responsible for designating the lead State response actions and coordinating/communicating with any other State agencies,as appropriate (NCP 300.180). Each Governor will also designate a representative for the State on the RRT. Each State representative may participate fully in all activities of the RRT. The State RRT representatives are expected to coordinate with the State Emergency Response Commissions (SERCs¾in Wisconsin, the State Emergency Response Board, or SERB) in their States in order to communicate and coordinate preparedness and preresponse planning activities between the State and the RRT. State and local government agencies are encouraged to coordinate with:
· State contingency planning efforts for response to oil and hazardous material events,
· this plan, and
· requirements of SARA Title III.

Section 311(j)(4) of CWA calls for inclusion of local, Tribal, and State representatives on the Area Committee. In U.S. EPA Region 5, this has been only partially accomplished through the designation of the RRT as the Area Committee.

Each State in Region 5 has a State disaster plan and laws that specify that State's authority and organization for a technical response to environmental emergencies. All States can provide technical expertise to assess environmental and public health threats and damage, as well as to advise local responders. In specific circumstances, States may provide additional response capabilities in the form of contractors and funding.

The following are summaries of emergency preparedness measures for lead agencies for each State in Region 5.

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2.4.1. ILLINOIS

2.4.1.1. Emergency Response to Oil Spills and Hazardous Materials Incidents

The Illinois Environmental Protection Agency (IEPA) provides the designated RRT member for Illinois. To prevent and abate environmental pollution, IEPA has various responsibilities for responding to environmental emergencies within the State or its adjoining waters. IEPA is the State's lead agency for developing plans and coordinating action before, during, and after certain emergency situations, including:
· emergencies involving waste management;
· emergencies involving public water supplies;
· spills of oil or hazardous materials upon waters or lands of the State; and
· releases of harmful quantities of toxic substances to the atmosphere.

Within IEPA, the Emergency Response Unit (ERU) of the Office of Chemical Safety has the responsibility for coordinating the agency's response and ensuring appropriate cleanup of any subsequent environmental contamination. ERU collects information about environmental emergencies and responds directly and/or notifies other divisions within IEPA of needed action. Technical expertise is provided to first responders and public officials, addressing such issues as:
· the physical, chemical, and toxicological characteristics of the materials involved;
· effective response and treatment actions; and
· precautions to be taken to prevent further injury or damage to public health or the environment.

2.4.1.2. Other Agencies' Responsibilities and Requirements

(a) Illinois Emergency Management Agency (IEMA): coordination and communications center for Illinois State agencies and is in overall command of emergency government efforts during major multijurisdictional disaster responses. IEMA is also the SERC designated pursuant to SARA Title III.

(b) Illinois Department of Nuclear Safety: incidents involving radioactivity, whether in transport or at nuclear power plants or other facilities.

(c) Illinois Department of Mines and Minerals: initial investigation of incidents involving crude oil and natural gas production sites, unless waters of the state are being impacted (then IEPA).

(d) Illinois State Fire Marshal: incidents involving underground storage tanks (USTs); this responsibility is shared with IEPA. Has the authority to require equipment inspection and testing.

(e) Illinois Commerce Commission: incidents involving railroad transport with respect to authority over the use, movement, and compliance of railroad equipment with U.S. Department of Transportation (DOT) regulations.

The llinois 24-hour spill notification number is to the Illinois Emergency Management Agency 217-782-7860 (800-782-7860 in Illinois). The office hours phone is 217-782-3637. After office hours call IEMA to get our Duty Officer.

(f) Illinois State Police: transportation incidents involving DOT Hazardous Materials, enforcement of DOT shipping regulations, traffic control, and security.

(g) Illinois Department of Conservation: assessment of natural resource damage in incidents involving serious environmental injury, such as fish kills and oiled waterfowl.

Other agencies serve a secondary role and provide technical support and resources as needed; however, they do not generally maintain an emergency response capability for onscene response: the Departments of Agriculture, Public Health, and Energy and Natural Resources; the Office of the Attorney General; and other human service agencies that might be involved with evacuees, should a prolonged incident occur requiring relocation of the general public.

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2.4.2. INDIANA

2.4.2.1. Emergency Response to Oil Spills and Hazardous Materials Incidents

The Indiana Department of Environmental Management (IDEM) provides the designated member of the RRT for Indiana and is the lead agency for the State in addressing spills, providing a 24hour response capability. IDEM must provide technical assistance to the responsible party and the responding personnel and ensure compliance with the Indiana spill regulation and other pertinent State and Federal rules and regulations. Technical assistance takes the form of:
· chemical identification, handling, and hazard information;
· evaluation of the threat to environmental and public safety;
· personal protection recommendations;
· containment and cleanup methods; and
· resource identification and location.

On large spills, or where the spiller fails to respond adequately, IDEM staff respond onsite to assist in the response effort, assuming the role of State OSC if necessary.

During a response, staff of the Emergency Response Section (ERS) of IDEM assume the role of technical advisors and provide onscene assistance to the responsible party, and to individuals or agencies involved in the response. On occasion, ERS staff have assumed a role that would appropriately be called OSC. However, if a structure (e.g., ICS) exists within a local or County jurisdiction that provides an OSC and that OSC is being utilized, ERS staff will provide assistance to that OSC.

Once the immediate threat to public health and the environment has been relieved, the incident is further stabilized and cleaned up under ERS supervision. Rule 327 IAC 26.1, Spills: Reporting, Containment, and Response, requires that the spiller report to IDEM and perform a spill response. A spill response means that a spill is contained and free material is removed or neutralized. Disposal of recovered material that is classified as waste is referred by ERS staff to appropriate personnel in the Office of Solid and Hazardous Waste Management. ERS staff may then conduct a followup investigation to ensure that material has been disposed of properly and the cleanup is acceptable.

Spills can be reported 24-hours-a-day at 888-233-7745.

2.4.2.2. Other Agencies' Responsibilities and Requirements

The role of liaison between a spiller and the different program areas of IDEM is perhaps the greatest benefit that ERS can provide to those involved in a spill. This role can also extend to other State agencies and other response organizations. State agencies include:

(a) State Emergency Management Agency (SEMA): SEMA is the lead planning agency for coordinating man-made and natural disasters. SEMA also provides an alternate member for the RRT.

(b) Office of the State Fire Marshal (OSFM): OSFM responds to fire and explosion hazards from hazardous materials incidents.

(c) Office of the Indiana State Chemist (OISC): OISC provides technical guidance regarding agricultural chemical incidents including fertilizers and pesticides. It also conducts investigations of improper application of regulated agricultural chemicals.

(d) Department of Natural Resources (DNR), Fish and Wildlife Division: DNR Conservation Officers conduct investigations to assess damages to natural resources such as fish kills.

(e) DNR, Oil and Gas Division (O & G): DNR O & G regulates oil production facilities, including operation, maintenance, construction, and abandonment of oil wells and associated equipment.

(f) Indiana State Police (ISP): ISP investigates transportation incidents involving DOT hazardous materials, enforces DOT shipping regulations, and provides traffic control and site security.

(g) Indiana State Department of Health (ISDH): ISDH is the lead agency for releases of radiological and etiological materials. They also provide technical guidance to IDEM regarding health issues and advisories.

(h) Indiana Department of Transportation (INDOT): INDOT usually provides traffic control for major transportation incidents involving releases of petroleum and hazardous materials. ERS also coordinates with other program areas within IDEM as well as local response agencies such as fire departments, hazardous materials teams, sheriffs' departments, local emergency planning committees (LEPCs), emergency management agencies, county health departments, and county highway departments.

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2.4.3. MICHIGAN

2.4.3.1. Emergency Response to Oil Spills and Hazardous Materials Incidents

Michigan's representation on RRT5 comes from the Michigan Department of Environmental Quality (MDEQ). MDEQ is the primary environmental emergency response agency in the State in all non-agricultural-related spills. Recent legislation has designated the Michigan Department of Agriculture (MDA) as the primary response organization, in close association with MDEQ, in spills involving agricultural chemicals.

Staff of MDEQ can be notified of oil and hazardous materials incidents via the Pollution Emergency Alert System (PEAS) at (800) 292-4706 (in-state) or (517) 373-7660.

MDEQ has approximately 19 full-time equivalent field positions available to respond to complaints and environmental emergencies. Most of these positions are located in the nine Field Operations Districts operated by MDEQ, which are situated throughout the State. The primary response role of MDEQ is one of technical advisor. These personnel are responsible for complaint investigation and emergency spill response and generally oversee the environmental aspects of spill containment, control, and mitigation. Appropriately trained staff within MDEQ can provide hands-on response with absorbents and skirt boom if the situation requires this type of response. It is anticipated, however, that all "first responder" response will be conducted by local units of government and the various Hazardous Material Response Teams located throughout the State, although predominantly in the lower third of the peninsula.

Environmental mitigation associated with material spills will generally be conducted by the RP. If the RP cannot be identified or is reluctant to adequately address mitigation needs, the State can hire contractors to perform the mitigation. A limited amount of money is available through funds administered by the MDEQ Environmental Response Division. The State can also access the Federal fund administered under OPA in accordance with Federal guidelines and regulations.

Michigan has a responder immunity act.

MDEQ, in conjunction with the Department of Attorney General, is the designated Natural Resources Trustee for the State.

2.4.3.2. Other Agencies' Responsibilities and Requirements

(a) Michigan State Police (MSP): The MSP Emergency Management Division (EMD) serves as the designated emergency/disaster response coordination agency for the State and as the primary State contact point in the event of a declared disaster resulting in the activation of the State Emergency Management Plan.

(b) Michigan Department of Agriculture (MDA): MDA is the lead agency in spill responses involving agricultural chemicals and/or fertilizers.

(c) Michigan Emergency Response Commission (MERC): MERC is the primary coordination agency and liaison with the local Emergency Planning Commissions throughout the state. MERC is co-chaired by MSP-EMD and MDEQ.

(d) Michigan Department of Natural Resources (MDNR): MDNR is the lead agency for the State in decisions involving fish and wildlife issues during a spill response working cooperatively with the MDEQ State OSC.

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2.4.4. MINNESOTA

2.4.4.1. Emergency Response to Oil Spills and Hazardous Materials Incidents

The Minnesota Pollution Control Agency (MPCA) provides the designated member of RRT5 for Minnesota. MPCA is the primary State responder to spills and other emergencies involving hazardous materials (with the exception of incidents involving pesticides and fertilizers, which are under the jurisdiction of the Minnesota Department of Agriculture). All of the following information describing State emergency response therefore assumes MPCA actions for general hazardous materials incidents, but applies to the Department of Agriculture for all pesticide and fertilizer incidents.

Spills can be reported through the following telephone numbers: 651-649-5451 and 800-422-0798 (in-State long distance).

MPCA's Emergency Response Team (ERT) includes eight full-time ERT members whose primary duty is to monitor the cleanup of spills and other emergency situations that pollute or threaten to pollute surface or ground water. By default, they also respond to reports of other environmental emergencies (e.g., air releases, illegal hazardous waste disposal, tire dump fires). In addition to receiving release reports, the ERT may perform field inspections at spill sites, provide technical assistance to responsible parties, or carry out enforcement actions for violation of State laws and rules.

If necessary, ERT staff will proceed to the site to provide coordination and assistance in handling the emergency. This may include taking charge of the response if the responsible party is unknown or unavailable. In situations where public safety is the primary consideration, the ERT member does not take charge of the incident, but assists the fire chief or other public safety officials at the scene. This assistance may include emergency waiver or suspension of State laws and rules (e.g., allowing emergency wastewater discharges or burning of a spilled product in order to minimize overall environmental damage). The assistance may also include activation of contractors using State funds.

Minnesota Statute Chapter 115E requires companies handling oil and hazardous substances to act to prevent releases and to be prepared for releases they may have. Chapter 115E requirements are similar to OPA but cover protection of the public's safety and the environment, and pollution of the land, air, and waters of the State. A facility operator is to notify the Emergency Response Commission when their plan is completed, and must supply a copy upon request. ERT staff actively inspect the prevention capabilities and preparedness of major facilities, and will assist facility owners if requested. They conduct enforcement if the preparedness of a facility is found to be inadequate, especially if it contributed to a release or poor response.

Both Minnesota Statute Chapter 115E and State Superfund Chapter 115B contain language providing immunity to those responding to oil or hazardous substance discharges.

2.4.4.2. Other Agencies' Responsibilities and Requirements

The Department of Public Safety Division of Emergency Management (DEM) operates the 24-hour-per-day Duty Officer System to take incident reports for all State agencies. DEM also coordinates the actions of State agencies, including MPCA, Natural Resources, Transportation, Public Safety, and Health. DEM conducts training for State and local responders, and reviews County emergency plans. DEM and the State Fire Marshal contract with a number of local jurisdictions to provide hazardous materials assessment and response teams to the various regions of the State. The Emergency Response Commission conducts the Right-to-Know programs in the State.

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2.4.5. OHIO

2.4.5.1. Emergency Response to Oil Spills and Hazardous Materials Incidents

The Ohio Environmental Protection Agency (OEPA) is the designated representative of RRT5 for Ohio. OEPA is also the State agency charged with investigating releases of oil and hazardous substances from both fixed and mobile facilities. Ohio's spill response program is housed in the Emergency Response Unit (ERU), which is a part of the Division of Emergency and Remedial Response. This unit, which is responsible for receiving reports of releases to all environmental media, uses 15 spill responders to aid in chemical identification, containment, cleanup, public safety, and the identification of responsible parties. If a responsible party cannot be identified or is recalcitrant, the ERU can activate a level-of-effort contractor to initiate actions to contain or clean up the spill.

Spills can be reported 24-hours-a-day at 800-282-9378.

Ohio has enacted no laws specifically related to responder immunity in environmental emergencies but it has enacted both a Good Samaritan Statute and a "General Duty Clause" that applies to State employees.

2.4.5.2. Other Agencies' Responsibilities and Requirements

Several different State agencies have areas of expertise to contribute during a spill, and in the case of such an event, operate under a cooperative agreement that outlines the activities of the signatory agencies when a spill occurs. These agencies are:
· the Ohio Emergency Management Agency,
· the State Fire Marshal,
· the Department of Highway Safety,
· the Public Utilities Commission,
· the Department of Transportation,
· the Department of Health,
· the Department of Agriculture,
· the Department of Natural Resources, and
· OEPA.

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2.4.6. WISCONSIN

2.4.6.1. Emergency Response to Oil Spills and Hazardous Materials Incidents

The primary agency representative to the RRT for Wisconsin is the Wisconsin Department of Natural Resources (WDNR) and alternate representative agency is from Wisconsin Emergency Management (WEM). WDNR is responsible for developing and updating a State Contingency Plan addressing spill response. The agency is responsible for: receiving notifications of releases; identifying the responsible party; and ensuring that appropriate measures are being taken by the responsible party to address public safety; and contain, clean up, and remediate a release. When a responsible party is unknown, or unable or unwilling to take appropriate actions, a WDNR representative may activate a Zone Contractor to take necessary actions.

WEM administers the Emergency Planning and Community Right-To-Know Act (EPCRA) in the State, and also administers eight Level A Regional Hazardous Materials Response Teams. This agency also coordinates resources for overall emergency management and provides hazardous materials training classes for all levels of responders. WEM operates a 24-hour emergency hotline that has a voice prompt directing spill calls to WDNR. WEM also serves as the lead State agency for consequence management of terrorism events.

2.4.6.2. Other Agencies' Responsibilities and Requirements

(a) The Department of Health and Family Services (DHFS) is responsible for monitoring the effects of chemical spills on public health and for providing assistance to local public health authorities.

Spills can be reported to the WEM 24-hour emergency hotline at 1-800-943-0003

(b) The Department of Agriculture, Trade, and Consumer Protection (DATCP) responds to spills of agrichemicals and coordinates with WDNR on remediation issues.

(c) The Wisconsin State Patrol (WSP) enforces State hazardous materials transportation regulations and can be involved in the initial response to transportation-related spills.

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2.5. NATIVE AMERICAN RESPONSE

The Tribe is the designated natural resource trustee for Native American communities. Response capabilities of Tribes in Region 5 vary. When a Tribal representative is not available or if it is unclear if there are any potential Tribal impacts, the Bureau of Indian Affairs (BIA) should be consulted. Contact with BIA can be facilitated by notifying the DOI RRT representative.

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2.6. FEDERAL RESPONSE

2.6.1. Statutory Authority

Section 104 of CERCLA as amended by SARA gives the Federal government the authority to respond to any hazardous substance released or to a substantial threat of a release into the environment or any pollutant or contaminant which may present an imminent and substantial danger to the public health or welfare and to remove or arrange to remove the hazardous substance, pollutant or contaminant or take any other response measure consistent with the NCP which is necessary.

Section 311 of CWA, 33 U.S.C. 1321, gives the Federal Government the authority to respond to a discharge or substantial threat of discharge of oil or a hazardous substance into or upon the navigable waters of the United States, adjoining shorelines, or the waters of the contiguous zone. It gives the President the authority to:
· remove or arrange for removal of a discharge and mitigate or prevent a substantial threat of a discharge at any time;
· direct or monitor all private, local, State, and Federal actions to remove a discharge; and
· if necessary, destroy by whatever means are available a vessel discharging, or threatening to discharge.

This authority is delegated to the Administrator of U.S. EPA, who has delegated it to the Regional Administrators of U.S. EPA, who then delegate that authority to OSCs. If a discharge or threat of discharge poses a substantial threat to public health or the welfare of the United States, the OSC shall direct all private, local, State, and Federal actions to remove the discharge or to mitigate or prevent the threat of discharge.

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2.6.2. Federal OSC Responsibilities

The Federal OSC directs Federal response efforts and coordinates all other Federal efforts at the scene of a discharge or release. The OSC may monitor local, Tribal, State, or private actions to remove a discharge, and may provide technical assistance to local, Tribal, State, or responsible party response personnel.

If a response action is being conducted through local, Tribal, State, or responsible party efforts, the OSC will ensure adequate oversight. If local, Tribal, or State agencies or the responsible party cannot or will not initiate action to eliminate the threat, or if the removal is not being conducted properly, the OSC should advise the government agency or responsible party and take appropriate actions to mitigate or remove the threat or discharge.

When the OSC has determined that a discharge poses or may present a substantial threat to public health or welfare, he/she is authorized by the NCP to direct all private, State, or Federal actions to remove the discharge or to mitigate or prevent the threat of such a discharge. In addition, the OSC may remove or arrange for the removal of the discharge or mitigate or prevent the substantial threat of the discharge; and may remove and, if necessary, destroy by whatever means available a vessel discharging, or threatening to discharge, without regard for any other provision of law governing contracting procedures or employment of personnel by the Federal Government (40 CFR 300.322).

Upon receipt of notification of a discharge or release, the OSC is responsible for conducting a preliminary assessment to determine:
(a) threat to human health and the environment;
(b) the responsible party and its capability to conduct the removal; and
(c) feasibility of removal or the mitigation of impact.

OSC responsibilities in the event of a discharge or release include the following:

(a) Coordinate with appropriate Federal Agencies.

(b) Notify the appropriate State and Federal Agencies. OSC notification responsibilities are discussed in further detail in subsection 2.10 of this plan (p. 31).

(c) Determine whether proper response actions have been initiated. If the party responsible for the release or spill does not act promptly in accordance with the directions of the OSC or does not take appropriate actions, or if the party is unknown, the OSC shall respond in accordance with provisions of the NCP and agency guidance, and coordinate activities as outlined in this ICP.

(d)Collect information concerning the discharge or release:
· its source and cause;
· potentially responsible parties;
· the nature, amount, location, direction, and time of discharge;
· pathways to human and environmental exposure;
· potential impact on human health, welfare, and safety, and the environment;
· possible impact on natural resources and property;
· priorities for protecting human health and welfare and the environment; and
· estimated cost for the response.

(e) Coordinate his/her efforts with other appropriate Federal, State, and local agencies.

(f) Consult with and inform the RRT members of reported discharges and releases through Pollution Reports in Message Format (POLREPs). (See Figure 2-1, p. 34)

(g) Consult with the appropriate Regional or District office regarding situations potentially requiring temporary or permanent relocation. In the event of a declared Federal disaster, coordinate with the Federal Emergency Management Agency (FEMA) Federal Coordinating Officer (FCO) as appropriate.

(h) Implement appropriate community relations activities.

(i) Address worker health and safety issues prior to and during a response operation, and comply with all worker health and safety regulations.

(j) Coordinate with the Agency for Toxic Substances and Disease Registry (ATSDR), as deemed necessary, regarding possible public health threats.

(k) Coordinate with the U.S. EPA Office of Radiation and Indoor Air (ORIA) and the Department of Energy (DOE) in emergencies involving radiological hazards.

As requested by the NRT or RRT, the OSC shall submit to the RRT a complete report on the removal operation and the actions taken. The report shall record:
· the situation as it develops,
· the actions taken,
· the resources committed, and
· the problems encountered.

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2.6.3. Regional Response Team (RRT)

The RRT is reponsible for regional planning and preparedness activities, as well as for coordination of assistance and advice to the OSC during site-specific incidents. The Co-Chairs of the Region 5 RRT are the Chief of the Emergency Response Branch, U.S. EPA Region 5; and the Chief of the Marine Safety Division, Ninth Coast Guard District. The RRT membership includes representatives from each State appointed by the Governor, and the designated regional representatives of the following Federal Agencies:
· the Department of Agriculture (USDA),
· the Department of Commerce (DOC),
· the Department of Defense (DOD),
· DOE,
· FEMA,
· the General Services Administration (GSA),
· the Department of Health and Human Services (HHS),
· the Department of the Interior (DOI),
· the Department of Justice (DOJ),
· the Department of Labor (DOL),
· the Nuclear Regulatory Commission,
· the Department of State (DOS),
· the Department of Transportation (DOT),
· USCG, and
· U.S. EPA.

Federal RRT member agencies have duties established by Statute or Executive Order that may apply to Federal response actions following or in prevention of a discharge of oil or a release or threat of release of a hazardous substance, pollutant, or contaminant. The RRT also functions as the Area Committee for Inland Region 5.

The principal components of the RRT are a standing RRT and incident-specific RRTs. The standing RRT consists of designated representatives from each participating Federal Agency listed above and each State. Each incident-specific RRT is formed from the standing team when the RRT is activated for a response, and consists of representatives of appropriate local governments, State agencies, and Federal Agencies.

Each member agency should designate one member and at least one alternate member to the standing RRT. Agencies whose regional subdivisions do not correspond to the standard Federal Regions may designate additional representatives to the standing RRT to ensure appropriate coverage of the standard Federal Region. Federally recognized Native American Tribal governments may arrange for representation on the RRT. Other interested parties may attend and observe RRT meetings. The usual process by which the RRT reaches its decisions is by consensus. However, in instances where a decision is reached by means of a vote, the voting capacity of each Federal member agency and other RRT member organizations is limited to one vote per member agency or organization.

The first Federal official affiliated with an RRT agency to arrive at the scene of a discharge or release, provided they have the proper training, should coordinate activities under the NCP, this RCP/ACP, and agency guidance until the predesignated OSC is available. That Federal official should consult directly with the predesignated OSC regarding any necessary initial actions. Fund-financed operations must be authorized by the OSC prior to implementation.

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2.6.3.1. STANDING RRT

The role of the standing RRT includes communications and procedures planning, coordination, training, evaluation of responses, preparedness, and related activities on a Region- and Area-wide basis. These activities include, but are not limited to the following:

(a) Providing resources, upon request, for response to major discharges or releases inside the Region or outside the Region;

(b) Providing technical assistance for preparedness and conducting and participating in as necessary training and exercises to encourage preparedness activities of the response community within the Region (Region 5 will participate in one exercise per year);

(c) Reviewing and updating the ICP;

(d) Discussing, modifying, and adopting procedures to enhance the various aspects of response coordination between local, Tribal, State, Regional, and Federal response efforts;

(e) Reviewing and commenting, where practicable, on local emergency response plans (required by SARA, Title III). Such reviews are conducted upon the request of a Local Emergency Planning Commission (LEPC), forwarded to the RRT by a SERC. The standing RRT may also review and comment on other issues concerning the preparation or implementation of related response plans;

(f) Providing guidance to Area Committees, as appropriate, to ensure interarea consistency and consistency of individual ACPs with the RCP and NCP;

(g) Reviewing, evaluating, and commenting on Regional and local responses to discharges or releases, and recommending improvements, as appropriate;

(h) Encouraging the State and local response communities to improve preparedness for response;

(i) Planning for use of dispersants, surface collection agents, burning agents, biological additives, or other chemical agents, as appropriate; and, upon request, approving chemicals and techniques for response, following established procedures;

(j) Meeting three times annually, rotating meetings among States, to review response actions, address preparedness and pre-response activities, and consider changes to the RCP;

(k) Providing reports on RRT activities to the NRT twice a year, no later than January 31 and July 31;

(l) Integrating, to the extent possible, ongoing planning and preparedness activities with RRT preparedness initiatives, and all RRT agencies;

(m) Recommending revisions of the NCP to the NRT, based on observations of response operations;

(n) Evaluating the preparedness of the participating agencies and the effectiveness of Federal response to discharges and releases;

(o) Preparing an annual work plan to coordinate emergency response and preparedness activities; and

(p) Coordinating planning and preparedness with RRTs in adjacent Regions.

To carry out the preparedness and planning charge of the RRT, a steering committee, with representatives of Co-Chairs and volunteers from member agencies and States, has been established to identify and facilitate implementation of preparedness and pre-response responsibilities. Work groups will be established as projects and particular work efforts are identified. The necessity of the work groups shall be reevaluated annually.

A list of the current members of the Region 5 standing RRT is provided in Appendix III.

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2.6.3.2 INCIDENT-SPECIFIC RRT

An incident-specific RRT is formed from the standing team each time the RRT is activated for a response. It consists of representatives of local and Tribal governments and the appropriate State and Federal Agencies described in subsection 2.6.3.

Appendix I contains a discussion of the U.S. EPA and USCG jurisdictions in Region 5.

An incident-specific RRT has one Chair, the Regional Co-Chair from the agency providing the Federal OSC/RPM for the response to the incident. The standing RRT Co-Chairs may designate other U.S. EPA and USCG employees to act as Co-Chair. The role of the incident-specific team is determined by the operational requirements of the response to a specific discharge or release. Participation is relative to the technical nature and geographic location of the discharge or release.

The incident-specific RRT Chair coordinates with the RRT membership and the OSC/RPM for the incident to determine the appropriate level of RRT member activation. Member agencies and States participating with the RRT must ensure that designated representatives or alternates can function as resource personnel for the OSC/RPM during incident-specific events.

When activated, members of an incident-specific RRT may:

(a) Provide resources and special or technical expertise;

(b) Provide advice and recommend courses of action for consideration by the OSC;

(c) Advise the OSC/RPM on the duration and extent of Federal response and recommend to the OSC/RPM specific actions to respond to a discharge or release;

(d) Request other Federal, State, or local government or private agencies to provide resources under their existing authorities to respond to a discharge or release or to monitor response operations;

(e) Recommend a change of OSC/RPM to the RRT Co-Chairs, if circumstances warrant (e.g., substantial movement of the pollution into the predesignated area of another OSC lead agency);

(f) Ensure continual communication with the National Response Center (NRC) as significant developments occur; and

(g) Monitor and evaluate reports from the OSC/RPM.

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2.6.3.3. ACTIVATION OF THE INCIDENT-SPECIFIC RRT

An incident-specific RRT will be activated during any discharge or release upon a request from the OSC or from any RRT representative to a Co-Chair of the RRT when a discharge or release:

(a) exceeds the response capabilities available to the OSC in the place where it occurs;

(b) transects State, Regional, or international boundaries;

(c) poses a substantial threat to public health, welfare, or to the environment, or to Regionally significant amounts of property; or

(d) is a worst case discharge.

Requests for RRT activation shall subsequently be confirmed in writing. Local requests for RRT activation must be made through the State RRT member. The various levels of activation can be found in the NCP. An incident-specific RRT activation may take place by telephone or by assembly.

Levels of activation are:

(1) Alert: Notification of RRT members that an incident has occurred.

(2) Standby: Notice to some or all RRT members that their services may be needed and that they are to assume a readiness posture and await further instructions. Notice may be given by phone.

(3) Partial: Notice to selected RRT members that their services are required in response to a pollution incident. The activation notice will specify the services requested and the services that will be required. The initial activation notice may be provided by telephone.

(4) Full: Notice to all RRT members (with the exception of representatives of nonaffected States) that their services are requested in response to a pollution incident. The activation notice will specify the services being requested from each RRT member. The services of some members may be limited to advising the OSC on general matters. The initial activation notice may be provided by telephone.

The RRT can be deactivated by the Chair, when the Chair determines that the OSC no longer requires RRT assistance. The time of deactivation shall be included in a POLREP.

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2.6.4. Federal Agency Responsibilities

The Federal Agencies listed in this section have duties established by statute, executive order, or Presidential directive which may apply to Federal response actions following, or in prevention of, the discharge of oil or release of a hazardous substance, pollutant, or contaminant. Some of these agencies also have duties relating to the rehabilitation, restoration, or replacement of natural resources injured or lost as a result of such discharge or release. It is recognized that Native American authorities, responders, and communities are entitled to the same cooperation and protection arrangements as the States.

Federal Agencies should plan for emergencies and develop procedures for addressing oil discharges and releases of hazardous substances, pollutants, or contaminants from vessels and facilities under their jurisdiction, custody, or control. Appropriate Federal RRT members or their representatives should provide OSCs/RPMs with assistance from their respective agencies, commensurate with agency responsibilities, resources, and capabilities within the Region. During a response action, the members of the RRT should seek to make available the resources of their agencies to the OSC/RPM. Specifically, member Federal Agency responsibilities include the following:

(a) Informing the RRT of changes in the availability of their response resources;

(b) Reporting discharges and releases from facilities or vessels under their jurisdiction or control;

(c) Making necessary information available to the RRT and OSCs; and

(d) Providing representatives to the RRT and otherwise assisting RRT and OSCs in formulating RCPs.

Following is a list of Federal Agencies and their responsibilities and functions.

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2.6.4.1. DEPARTMENT OF AGRICULTURE

The U.S. Forest Service is the designated USDA representative to the RRT. USDA maintains a Regional Emergency Team in each of the 10 Standard Federal Regions to provide liaison and coordination with Federal Agencies operating on a Regional basis. Regional Emergency Teams are composed of representatives of USDA agencies having essential emergency functions at the Regional level. These are:

Forest Services (FS): Responsible for prevention and control of fires in rural areas, in cooperation with State Foresters and appropriate Federal Agencies; and emergency production, availability, and utilization of timber and timber products in cooperation with the Department of Commerce. The agency has capabilities to provide emergency communications systems, specialized aircraft, and human support facilities for large groups of people, and has specially trained incident management teams.

Food and Nutrition Service (FNS): Through the Food Distribution Program, provides food as emergency assistance to disaster victims. In appropriate emergency situations, FNS will authorize State agencies to issue food stamps based on emergency procedure.

Food Safety and Inspection Service (FSIS): Tests meat and poultry products for the presence of violative drugs, chemical residues, and other adulterants.

Agricultural Stabilization and Conservation Service (ASCS): In cooperation with the Forest Service, Soil Conservation Service, and the U.S. Army Corps of Engineers, is responsible for emergency plans and preparedness programs for food processing, storage, and distribution through the wholesale level.

Animal and Plant Health Inspection Service (APHIS): Provides expertise on plant and animal diseases and health.

National Agricultural Statistics Service: Serves as a source of data on crops, livestock, poultry, dairy products, and labor. State Statistical Offices collect and publish local information on these topics.

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2.6.4.2. DEPARTMENT OF COMMERCE

DOC, through the National Oceanic and Atmospheric Administration (NOAA), has three roles within Region 5:

Scientific Support Coordinator (SSC): In accordance with the NCP, the SSC provides scientific advice to support the Federal OSC in operational decisions that will protect the environment effectively, mitigate collateral harm, and facilitate environmental recovery. The SSC advises on other technical issues (as requested by the OSC) after consulting with the appropriate NOAA hazardous materials (HAZMAT) resources or other Federal, State, or academic networks. This includes considering advice from the trustee agencies (including the NOAA HAZMAT RRT member), and any divergent opinions.

National Resource Trustee: The Secretary of Commerce acts as trustee for natural resources managed or controlled by DOC, including their supporting ecosystems. 40 CFR 300.600(b), (b)(1). Pursuant to the Great Lakes Critical Programs Act of 1990, 33 USC 1268 (Great Lakes Act), and the Great Lakes Water Quality Agreement of 1978, as amended by the Water Quality Agreement of 1987 (Great Lakes Water Quality Agreement), the United States, in part through DOC, manages and/or controls the water and sediments of the Great Lakes System.

The Secretary of Commerce also acts as trustee for natural resources managed or controlled by other federal agencies that are found in, under, or using waters navigable by deep draft vessels, tidally influenced waters, or waters of the contiguous zone, the exclusive economic zone, and the outer continental shelf. Therefore, all federally managed or controlled resources that are found in those waters, such as water and sediments that form navigation channels and that are managed, controlled, and maintained by the Army Corps of Engineers, and the fisheries that are controlled by the Food and Drug Administration through derivation of action levels, fall within DOC trusteeship. Similarly, the water and sediment of the Great Lakes System are within the administrative jurisdiction of the United States, and are federally managed or controlled pursuant to the Great Lakes Act and the Great Lakes Water Quality Agreement.

The Secretary has delegated his authority to act as trustee to the Administrator of NOAA. Pursuant to these delegations, NOAA has trusteeship for the water, sediment, and the biological resources, of the Great Lakes and their supporting ecosystems. The NCP also cites as examples of DOC trusteeship the following natural resources and their supporting ecosystems: migratory birds, anadromous fish, and endangered species and marine mammals. 40 CFR 300.600(b)(1), (b)(2).

Under OPA and the NCP, NOAA has specific responsibilities as a natural resource trustee that include:

(a) Receiving notification of potential or actual spills threatening NOAA resources;

(b) Being consulted on the preparation of the fish and wildlife and sensitive environments annex (this includes concurring on specific countermeasures or removal actions during the contingency planning phase);

(c) Being consulted on removal actions during an incident; and

(d) Implementing damage assessment activities.

All of these activities are intended to minimize impacts and to restore the environment.

RRT Member: Has the primary goal to support the appropriate RRT Co-Chair who supports the Federal OSC by providing advice and resources that will protect the environment effectively, mitigate collateral harm, and facilitate environmental recovery. Carries out this goal by:

(a) serving as an access point to other DOC resources and expertise, usually outside NOAA HAZMAT, that have primary roles in carrying out NOAA's trusteeship role during spills;

(b) representing DOC in carrying out its policy responsibilities (such as trusteeship);

(c) helping the NOAA SSC provide technical assistance, if needed; and

(d) representing NOAA HAZMAT at meetings where the SSC cannot be present.

This member can provide:

· scientific expertise on living aquatic resources for which DOC is responsible;

· current and predicted meteorological, hydrologic, ice, and limnologic conditions;

· charts and maps; and

· communication services to the general public, various levels of government, and the media via its NOAA weather wire and NOAA weather radio systems.

These roles are the responsibility of all DOC representatives, whether from NOAA HAZMAT, NOAA National Marine Fisheries Service (NMFS), or NOAA National Weather Service (NWS).

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2.6.4.3. DEPARTMENT OF DEFENSE

DOD, consistent with its operational requirements, may provide assistance in critical oil and hazardous materials incidents, in the maintenance of navigation channels, and in removal and salvage of navigation obstructions. DOD will provide the OSC and RRT Chair for releases occurring on DOD property or facilities.

U.S. Army Corps of Engineers (USACE): Has specialized equipment and personnel for maintaining navigation channels, for removing navigational obstructions, for accomplishing structural repairs, and for performing maintenance to hydropower electric generating equipment. USACE can also provide design services, perform construction, and provide contract writing and contract administration services for other Federal Agencies.

U.S. Navy Supervisor of Salvage (SUPSALV): Is knowledgeable and experienced in ship salvage, shipboard damage control, diving, and has equipment for salvage-related and open-sea pollution incidents.

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2.6.4.4. DEPARTMENT OF ENERGY

DOE provides the designated OSC/RPM for responses to releases on or from any facility or vessel under its jurisdiction. DOE administers, implements, and coordinates the Federal Radiological Monitoring and Assessment Center (FRMAC). Under the Federal Radiological Emergency Response Plan (FRERP), DOE provides advice and assistance to the RRT regarding the identification of the source and extent of radioactive contamination, and removal and disposal of radioactive releases.

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2.6.4.5. FEDERAL EMERGENCY MANAGEMENT AGENCY

FEMA requires the development, evaluation, and exercise of all-hazard contingency plans for all FEMA-funded jurisdictions at the State and local levels. SARA Title III plans are often annexes of the all-hazard plan. FEMA monitors and provides technical assistance regarding public sector emergency response training and planning for incidents involving hazardous materials. In a response, FEMA provides advice and assistance to the lead agency on coordinating relocation assistance and mitigation efforts with other Federal Agencies, State and local governments, and the private sector.

If the President declares a disaster or emergency, FEMA coordinates all Federal assistance, including temporary housing. The OSC coordinates with the Federal Coordinating Officer in situations where both authorities are active.

FEMA's National Emergency Support Team and Regional Emergency Response Teams provide coordination of Federal response in situations of unique national significance, such as commercial nuclear power plant or nuclear weapons accidents and catastrophic natural disasters.

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2.6.4.6. GENERAL SERVICES ADMINISTRATION

GSA, upon request, provides expedited logistical and telecommunications support to Federal Agencies that are members of the NRT. The support includes, but is not limited to,
· provision of space,
· transportation,
· telecommunications,
· supplies, and
· procurement-related services.

Services may be furnished through GSA personnel who are located at the scene of the oil or hazardous material release, or at their regular duty stations, depending on the specific requirements of the Federal OSC or the emergency situation. Expenses incurred by GSA in providing requested assistance to other agencies must be reimbursed.

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2.6.4.7. DEPARTMENT OF HEALTH AND HUMAN SERVICES

HHS assists with the assessment, preservation, and protection of human health and helps ensure the availability of essential human services. HHS provides technical and nontechnical assistance in the form of advice, guidance, and resources to other Federal Agencies, as well as to State and local governments.

The principal HHS response comes from the U.S. Public Health Service (PHS). Within PHS, the primary response to hazardous materials emergencies comes from ATSDR and the Centers for Disease Control (CDC). Both ATSDR and CDC have 24-hour emergency response capability whereby scientific and technical personnel are available to provide technical assistance to the lead Federal Agency and State and local response agencies on human health threat assessment and analysis, and exposure prevention and mitigation. Such assistance is used in situations requiring evacuation of affected areas, dealing with human exposure to hazardous materials, or advice on mitigation and prevention.

Agency for Toxic Substances and Disease Registry: ATSDR is the lead Federal public health agency for hazardous material incidents under CERCLA. Two ATSDR representatives are assigned to each U.S. EPA Region to assist in U.S. EPA/ATSDR communications. Regional representatives can also assist in emergency response events that involve RRT issues by coordinating with ATSDR headquarters Emergency Response and Consultation Branch and with the CDC RRT representative. Under CERCLA Section 104(i), ATSDR is required to:

(a) establish appropriate disease/exposure registries;

(b) provide medical care and testing of exposed individuals in public emergencies;

(c) develop, maintain, and provide information on health effects of toxic substances;

(d) conduct research to determine relationships between exposure to toxic substances and illness;

(e) develop guidelines, with U.S. EPA, for toxicological profiles for hazardous substances; and

(f) develop educational materials for health professionals related to health effects of toxic substances.

Additionally, ATSDR operates a 24-hour phone line to address public health issues.

Centers for Disease Control and Prevention: CDC takes the lead during oil releases regulated under CWA and OPA. PHS has designated the CDC representative to the RRT. This person is responsible for coordinating all public health responses on the Federal level and for coordinating all responses with State and local health agencies.

Other PHS agencies involved in support during hazardous materials incidents, either directly or through ATSDR/CDC, include the Food and Drug Administration (FDA), the Health Resources and Services Administration, the Indian Health Service, and the National Institutes of Health (NIH).

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2.6.4.8. DEPARTMENT OF THE INTERIOR

DOI can provide information concerning the lands and resources specifically under DOI jurisdiction, as well as offer technical expertise related to geology, hydrology, minerals, fish and wildlife, cultural resources, and recreation resources. Under Executive Order 12580, DOI is designated by the NCP as a Federal Trustee for Natural Resources.

DOI has direct jurisdiction for protection of resources on its own lands, as well as trustee responsibilities for certain natural resources, regardless of location. The DOI natural resource trusteeship that extends beyond DOI site boundaries includes migratory birds, anadromous fish, and endangered/threatened species and their critical habitat.

Bureaus may provide assistance in investigations to evaluate the magnitude and severity of discharges on or affecting facilities or resources under their jurisdiction, and may conduct activities as natural resource trustees as set forth in Subpart G of the NCP.

Bureaus may also provide:

· advice to the OSC/RPM when response operations are being performed that affect land, facilities, or natural resources under their management authority;

· technical assistance in disposal activities; however, lands under the jurisdiction of DOI (including certain municipal landfills) may not be utilized as disposal sites; or

· air and ground transportation support, and maintainenance of communications support.

Within the Department, individual bureaus and offices have specific responsibilities and capabilities as follows:

Office of Environmental Policy and Compliance (OEPC): The Regional Environmental Officer (REO) represents DOI on the RRT, and is responsible for coordinating RRT/DOI activities. The Regional Environmental Assistant (REA) provides support to the REO in planning and emergency response and acts for the REO when unavailable. The Regional Coordinator (RC) provides planning and natural resource damage assessment (NRDA) coordination. OEPC provides a number of services, including:

· presenting the DOI position on chemical countermeasure and in situ burn decisions,

· facilitating technical assistance requests from the OSC,

· supplying administrative details to secure response cost reimbursement approval from the OSC,

· initiation of natural resource damage assessments (NRDAs), and

· coordinating response between DOI Bureaus.

U.S. Fish and Wildlife Service (USFWS): Can provide responders with information concerning migratory birds, Federally listed threatened and endangered species and their designated critical habitat, certain anadromous fish, and certain Federal lands (National Wildlife Refuges, Waterfowl Production Areas, and National Fish Hatcheries), as well as technical assistance concerning the effects of oil on these resources. In addition, it will help coordinate wildlife rescue and rehabilitation efforts in conjunction with State natural resource trustee(s). The Service is responsible for assessing damages to natural resources as a result of releases of oil or hazardous substances into the environment, and issues Federal Migratory Bird and Eagle Permits to qualified individuals and/or organizations conducting wildlife collection, rescue, and rehabilitation operations related to oil spill incidents.

National Park Service (NPS): Provides expertise on historic, cultural, archeological, architectural, and recreational resources and sites on the National Register of Historic Places. NPS can also provide information on National Parks, National Recreation Areas, National Historic Sites,

DOI Bureaus can be contacted through the Regional Environmental Officer.

National Trails, Lake Shores, National Monuments, and Wild and Scenic Rivers listed on the Nationwide Rivers Inventory (NRI).

U.S. Geological Survey (USGS): Provides advice and information concerning geohydrologic, geologic, and geochemical data; ground and surface water data; and maps. USGS maintains stream flow gauges in every State and can provide historical stream flow information, assist in predicting the time/travel/trajectory of spills, and can collect and analyze surface and groundwater samples.

The Biological Resources Division performs research in support of biological resource management; inventories, monitors, and reports on the status and trends in the nation's biologic resources; and transfers the information gained to resource managers and others concerned with the care, use, and conservation of the nation's natural resources.

Bureau of Indian Affairs (BIA): Responsible for protecting and improving the trust resources of Native American Tribes and facilitating an active role in planning and response for Tribal governments as requested. BIA coordinates activities affecting Native American Tribal lands, and can provide assistance to the OSC in identifying Native American Tribal government officials. BIA can also assist in obtaining access to Tribal land areas as needed for response action and will coordinate with the incident Public Information Office Director to ensure pertinent information is made available to appropriate Tribal authorities on a timely basis.

Bureau of Land Management (BLM): Has expertise in minerals, soils, vegetation, archeology, and wildlife habitat, and may provide advice on response affecting lands or minerals administered by BLM. May also provide advice in the field of oil and gas drilling, production, handling, and transportation by pipeline.

All bureaus of the Department of the Interior may be contacted through the Regional Environmental Officer, the designated member of the RRT.

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2.6.4.9. DEPARTMENT OF JUSTICE

DOJ members of the RRT serve as representatives of the Department of Justice and not as legal counsel to the RRT or its member agencies. Although the DOJ representative to the RRT is not a substitute for member agencies' in-house counsel, the DOJ representative will be able to offer the advice, views, and expertise of the Department with respect to RRT's long-term planning and incident-specific functions.

As a consequence of DOJ's primary role as litigation counsel for the Federal Government and as legal counsel on enforcement and interagency matters, its participation in RRT activities will ordinarily focus on litigation concerns regarding response activities and interagency coordination. The DOJ representative might provide:

· general legal advice;

· review and comment on regional planning and procedural documents; and

· incident-specific assistance, including assigning staff attorneys when an incident may result in litigation or raise difficult issues of interagency coordination.

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2.6.4.10. DEPARTMENT OF LABOR

DOL, through the Occupational Safety and Health Administration (OSHA):

(a) conducts safety and health inspections at hazardous waste sites and during emergencies to ensure that employees are being protected and to determine compliance with its regulations, and

(b) provides the OSC/RPM with advice, guidance, and assistance regarding hazards to persons involved in removal or control of oil or chemical spills, and the precautions necessary to protect such persons' health and safety.

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2.6.4.11. NUCLEAR REGULATORY COMMISSION

The Nuclear Regulatory Commission (NRC) will:

(a) respond, as appropriate, to releases of radioactive materials by its licensees, in accordance with the NRC Incident Response Plan to monitor the actions of those licensees and assure that the public health and environment are protected and adequate recovery operations are instituted;

(b) keep U.S. EPA informed of any significant actual or potential releases in accordance with procedural agreements; and

(c) provide advice to the OSC/RPM when assistance is required in identifying the source or character of other hazardous substance releases where the NRC has licensing authority for activities utilizing radioactive materials.

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2.6.4.12. DEPARTMENT OF STATE

DOS will:

(a) lead in developing joint international contingency plans;

(b) provide assistance in coordination when a pollution release crosses international boundaries or involves foreign flag vessels; and

(c) coordinate requests for assistance from the Government of Canada and U.S. proposals for conducting research at incidents that occur in Canadian waters.

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2.6.4.13. DEPARTMENT OF TRANSPORTATION

DOT, through USCG, provides the Co-Chair of RRT5 and predesignated OSCs for the Great Lakes Coastal Zone and specified ports and harbors in Region 5. DOT also provides expertise regarding transportation of oil or hazardous materials. Through USCG, DOT:

(a) supplies expertise in the domestic/international fields of

· port safety and security;

· marine law enforcement, navigation, and construction; and

· manning, operation, and safety of vessels and marine facilities;

(b) maintains continuously manned facilities that are capable of command, control, and surveillance for oil or hazardous substances releases occurring on the waters of the United States, and may provide these services to the OSC.

DOT, through the Research and Special Programs Administration (RSPA), establishes oil discharge contingency planning requirements for pipelines, transport by rail and containers, or bulk transport of oil.

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2.6.4.14. U.S. ENVIRONMENTAL PROTECTION AGENCY

U.S. EPA provides the Co-Chair of RRT5 and provides OSCs for all inland areas for which an ACP is required under CWA Section 311(j) and for discharges and releases occurring in the inland zone. It also provides RPMs for remedial actions except as otherwise provided, and generally provides the Scientific Support Center for responses in the inland zone.

U.S. EPA is responsible for providing expertise regarding environmental effects of pollution and environmental pollution control techniques. U.S. EPA will also:

· assist USCG in hazardous materials incidents,

· advise the RRT and the OSC of the degree of hazard a particular release poses to public health and safety, and

· coordinate scientific support, including environmental assessment, in inland regions.

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2.7. MULTIREGIONAL RESPONSES

The Federal OSC for a given incident is determined by the point of origin of the release. However, if a discharge or release affects areas covered by two or more RCPs/ACPs, the response mechanisms of both may be affected. In this case, response actions of all Regions concerned shall be fully coordinated as detailed in the RCPs.

There shall be only one OSC at any time during the course of a specific response operation. Should a discharge or release affect two or more areas, U.S. EPA, USCG, DOD, DOE, or other lead agency, as appropriate, shall give prime consideration to the area vulnerable to the greatest threat, in determining which agency should provide the OSC. The RRT shall designate the OSC if the RRT member agencies who have response authority within the affected area are unable to agree on the designation. The NRT shall designate the OSC if members of one RRT or two adjacent RRTs are unable to agree on the designation.

Where USCG has initially provided the OSC for response to a release from hazardous waste management facilities located in the coastal zone, responsibility for response shall shift to U.S. EPA or another Federal Agency, as appropriate.

The OSC/RPM shall be provided by the Region within which the release occurs, or according to preestablished protocols described in the interregional contingency plans and Section 3 of this ICP.

Several interregional agencies have been established that have interests within Region 5 and have roles in response and planning. The agencies vary considerably in their concerns and capabilities. The following is a list of these interregional organizations.

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2.7.1. The Great Lakes Commission

The Great Lakes Commission (GLC) is an interstate compact commission consisting of gubernatorially appointed and legislatively mandated representatives of the eight Great Lakes States (Minnesota, Wisconsin, Illinois, Michigan, Indiana, Ohio, Pennsylvania, and New York). The Commission was formed to promote the informed use, development, and protection of Great Lakes Basin land and water resources through regional coordination, policy development, and advocacy.

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2.7.2. Ohio River Valley Water Sanitation Commission

The Ohio River Valley Water Sanitation Commission (ORSANCO) is an interstate water pollution control agency established in 1948, with membership consisting of representatives from the eight States in the Ohio River Valley (Illinois, Indiana, Kentucky, New York, Ohio, Pennsylvania, Virginia, and West Virginia), and a representative from U.S. EPA. The Commission is responsible for operating several programs:

· water quality monitoring of the Ohio River and its major tributaries;

· regulation of wastewater discharge to the Ohio River; and

· investigation of particular water pollution problems.

In addition, ORSANCO assists State environmental agencies, U.S. EPA, and USCG in emergency spill response and notification. ORSANCO maintains a spill notification database on the Ohio River and its tributaries. Specifically, in the event of a spill on the Ohio River or a major tributary, ORSANCO's role is to serve as an interstate communications center, assisting in emergency notification procedures and to coordinate emergency stream monitoring.

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2.7.3. Upper Mississippi River Basin Association

The Upper Mississippi River Basin Association (UMRBA) is an interstate organization formed by the Governors of Illinois, Iowa, Minnesota, Missouri, and Wisconsin to maintain communication and cooperation among the States on matters related to water resources planning and management in the Upper Mississippi Basin. The five States are represented through gubernatorial appointees, and five Federal Agencies have advisory status. As part of its efforts to facilitate cooperative planning, the Association provides support to an ad-hoc Upper Mississippi Spills Coordination Group, which includes representatives of the five State response agencies, as well as U.S. EPA Regions 5 and 7, USCG, USFWS, NOAA, and USACE. The group meets periodically to discuss common problems and coordinate activities to respond to spills on the Upper Mississippi.

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2.8. NATIONAL RESPONSE

2.8.1. National Response Team

The NRT is responsible for oil and hazardous materials spill planning and coordination on the national level. The NRT is made up of representatives of each of 15 Federal Agencies, chaired by U.S. EPA and vice-chaired by USCG. The NRT's responsibilities include:

· evaluating methods of responding to discharges,

· maintaining national preparedness to respond to a major oil discharge, and

· developing procedures, in coordination with the National Strike Force Coordination Center (NSFCC), to ensure the coordination of Federal, State, and local governments.

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2.8.2. Federal Radiological Emergency Response Plan

Response to radiological emergencies is coordinated under the FRERP.

ORSANCO has developed a spill notification and response plan, which should be used as the operative plan for spills on the Ohio River, and the ORSANCO Emergency Response Resource Manual.

UMRBA and the member State and Federal Agencies of the Upper Mississippi Rivers Hazardous Spills Coordination Group have produced the Upper Mississippi River Spills Response Plan and Resource Manual. The manual functions as a working contingency plan, to supplement the appropriate State emergency response plans, RCPs, and the NCP. As such, themanual is consistent with the U.S. EPA Region 5 ICP and Region 7 RCP, is in compliance with requirements of the NCP, and should be used as the operative plan for spills on the Mississippi River.

This interagency agreement coordinates the response of various agencies, under a variety of statutes, to a large radiological accident. The lead Federal Agency, defined by the FRERP, activates the FRERP for any peacetime radiological emergency that, based upon the agency's professional judgment, is expected to have a significant radiological effect within the United States, its territories, possessions, or territorial waters; and that could require a response by several Federal Agencies.

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2.8.3. Federal Response Plan

In the event of a declaration of a major disaster by the President, FEMA may activate the Federal Response Plan. An FCO, designated by the President, may implement the Federal Response Plan and coordinate and direct emergency assistance and disaster relief of impacted individuals, businesses, and public services under the Stafford Disaster Relief Act. Planning for disasters is coordinated by FEMA under the Federal Response Plan. The RCP is Emergency Support Function #10 under the Federal Response Plan, along with the FRMAP.

The Federal Response Plan was developed under the Disaster Relief Act of 1974, as amended by the Stafford Disaster Relief Act of 1988. The Federal Response Plan established a foundation for coordinating Federal assistance to supplement State and local response efforts to save lives, protect public health and safety, and protect property in the event of a natural disaster, catastrophic earthquake, or other incident declared a major disaster by the President.

The delivery of Federal assistance is facilitated through twelve annexes, or Emergency Support Functions (ESFs), which describe a single functional area of response activity: Transportation, Communications, Public Works and Engineering, Fire Fighting, Information and Planning, Mass Care, Resource Support, Health and Medical Services, Urban Search and Rescue, Hazardous Materials, Food, and Energy. The Hazardous Materials annex, ESF #10, addresses releases of oil and hazardous substances that occur as a result of a natural disaster or catastrophic event and incorporates preparedness and response actions carried out under the NCP. U.S. EPA serves as the Chair of ESF #10 and is responsible for oversight of all preparedness and response actions associated with ESF #10 activities, only if assigned it by FEMA. All NRT/RRT departments and agencies serve as support agencies to ESF #10.

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2.9. INTERNATIONAL RESPONSE

2.9.1. International Joint Commission

The International Joint Commission (IJC) is a binational organization that was created under the Boundary Waters Treaty of 1909 to advise the governments of the United States and Canada on issues concerning water quality and quantity in the boundary waters between the two nations. The IJC monitors and assesses cleanup progress under the Treaty and advises governments on matters related to the quality of the boundary waters of the Great Lakes system. The Commission consists of six members, three appointed by the President of the United States, and three appointed by the Prime Minister of Canada.

In the event of releases that impact or threaten the international border, the following Canadian government agencies should be notified:

Canadian Coast Guard | (519) 337-6360
Environment Canada | (416) 518-3221
Emergency Preparedness Canada | (613) 991-7000

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2.9.2. Joint Contingency Plan

A Joint Contingency Plan is being developed with Canada for releases of oil and hazardous substances. Several plans will cover the Great Lakes and the inland area.

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2.10. COMMUNICATIONS

2.10.1. Discovery

It is the spiller's responsibility to report all spills. The spiller or responsible party is required to immediately report all releases of oil and hazardous substances into or on navigable water, adjoining shorelines, or the contiguous zone, to the National Response Center (NRC). The NRC will notify the appropriate OSC. If NRC notification is not practicable, the responsible party should notify the U.S. EPA or USCG predesignated OSC and the appropriate State environmental agency.

If U.S. EPA or USCG is the first to be notified of a release or discharge, U.S. EPA or USCG will notify the State and the NRC, the appropriate trustees for natural resources and other RRT members, as stated in Subsection 2.10.2 of this plan. OSC notification of trustees is accomplished through protocols developed via trustee-specific agreements. For spills of significance, if the State or other agency is the first to be notified, they shall notify the appropriate Federal Agencies.

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2.10.2. OSC Notification Responsibilities

As used in this section, "notification" refers to the actions taken by the predesignated Federal OSC to immediately alert appropriate Federal and State agencies of a release. The purpose of this notification is to provide the best available summary of OSC observations and operations, and to allow the notified agency an opportunity to perform some on-scene program function. Usually, the OSC will notify agencies by telephone.

Upon notification from the NRC, the OSC may investigate the report to determine the threat posed to the public health or welfare or to the environment. Notifications are based on the actual or potential size of the spill and the threat posed as outlined in Table 2-1.

OSCs should also ensure that all appropriate public and private interests are kept informed and their concerns considered.

If radioactive substances are present in a release, the U.S. EPA Region 5 Emergency Response Branch should be notified for evaluation and assistance, either directly or through the National Response Center.

2.10.3. Pollution Report Messages (POLREPs)

When conducting Federal removal actions, the OSC will submit POLREPs to the above-mentioned agencies, and include local entities as necessary. As changing conditions warrant, POLREP distribution may be expanded to include additional entities. In the case of an oil release, the OSC will submit a POLREP to the National Pollution Fund Center (NPFC).

Except as noted below, the designated OSC prepares POLREPs for each release occurring within the OSC's area of responsibility. The OSC submits POLREPs to the RRT as significant developments occur. For medium and major releases, these submittals will occur on a daily basis until, in the judgment of the OSC, the response operation and the impact of the release have stabilized. The standard POLREP format is presented as Figure 2-1.

Notification should be made to the NRC duty officer at (800) 424-8802 or (202) 267-2675.

The U.S. EPA Region 5 predesignated OSC can be reached 24 hours a day at (312) 353-2318. The USCG predesignated OSC can be reached at (216) 522-3984 (Ninth District) or (504) 589-6225 (Eighth District).

Appendix III provides communication information (including FAX numbers) for RRT members, OSCs, and other government entities that routinely participate in Federal response activities in Region 5.

FIGURE 2-1: Model Initial POLREP

U.S. ENVIRONMENTAL PROTECTION AGENCY POLLUTION REPORT

I. HEADING

Date:

Subject:

From:

To: , U.S. EPA, OSWER FAX: _____________ , U.S. EPA ERB FAX: _____________

, Chief, U.S. EPA Response Section __ FAX: _____________

, Chief, U.S. EPA ESS FAX: _____________

, U.S. EPA Office of Public Affairs FAX: _____________

, U.S. EPA ORC FAX: _____________

, U.S. EPA Enforcement Specialist FAX: _____________

, State agency FAX: _____________

, USCG, District __ FAX: _____________

, U.S. DOI FAX: 215-597-9845

, County official FAX: _____________

POLREP No.:

II. BACKGROUND

Site No.:

Delivery Order No.:

Response Authority:

ERNS No.:

CERCLIS No.:

NPL Status:

State Notification:

Action Memorandum Status:

Start Date:

Demobilization Date:

Completion Date:

III. SITE INFORMATION

A. Incident Category

B. Site Description

1. Site location

2. Description of threat

FIGURE 3-1: Model Initial POLREP (cont.)

C. Preliminary Assessment/Site Inspection Results

IV. RESPONSE INFORMATION

A. Situation

1. Current situation

2. Removal activities to date

3. Enforcement

B. Planned Removal Activities

C. Next Steps

D. Key Issues

V. COST INFORMATION

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.

VI. DISPOSITION OF WASTES

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2.10.3.1. Special Cases

Fund Manager: In the event of a Federally funded oil cleanup, the OSC will submit a POLREP to the NPFC.

Worker Safety: If the pollutant is a hazardous substance and Federal or private sector personnel are participating in a "hands-on" removal, the OSC will include the Department of Labor RRT representative in the distribution of POLREPs. (Note: this provision does not extend to the activities of State and local government employees.)

Federal Land Manager: Consistent with spill notification guidelines, when a release impacts Federal lands, the OSC will include the RRT representative of the managing agency in the distribution of POLREPs.

Intrastate Distribution: The State office designated to receive POLREPs from Federal OSCs will perform any further distribution to other elements of government within that State.

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2.10.3.2. Means of Transmission

Facsimile (FAX) is the standard method of transmitting messages between member agencies of RRT5. However, individual agencies and a lead agency may agree to use other means of communication (e.g., E-mail, AUTODIN, TELEX). It is incumbent upon each agency to identify a reliable 24-hour means of receiving POLREPs. Where this has not been done, distribution will be by regular mail.

Where an incident generates substantial interest in the response community and the lead agency experiences a demand for POLREPs beyond the normal RRT distribution, the lead agency may elect to post POLREPs on a commonly accessible computer bulletin board in lieu of direct transmission to individual offices. In such an event, the Ninth Coast Guard District will employ the NOAA RRT System discussed in

subsection 5.4.5 of this plan.

2.10.4. Public Information

In accordance with 40 CFR 300.415(n), the lead agency shall designate a spokesperson who shall:
· inform the community of actions taken,
· respond to inquiries, and
· provide information concerning the response action.

All news releases or statements made by participating agencies shall be jointly coordinated and released through a public information office. The spokesperson shall notify, at a minimum, immediately affected citizens, local and State officials and, when appropriate, emergency management agencies. OSCs may consider use of the RRT to assist in media relations and other community involvement activities. Also, responsible parties may implement community involvement activities.

For response actions lasting less than 30 days, the following apply:

(a) The administrative record file must be maintained at the U.S. EPA Regional Office;

(b) The administrative record must be made available to the public no later than 60 days after initiation of activity at the site, and U.S. EPA must inform the public that it is available for public inspection by placing a notice in a major newspaper; and

(c) No public comment period on the administrative record is required when on-site activity lasts less than 30 days.

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2.11. SAFETY

2.11.1. Worker Health and Safety

U.S. EPA Worker Protection Standards apply to employers of State and local governments whose employees are engaged in hazardous waste operations and emergency response. OSHA regulations apply directly to private and Federal employees and to those State and local government employees in States having OSHA-approved plans. OSHA and U.S. EPA worker protection standards (29 CFR 1910.120 and 40 CFR 11) implement Section 126 of SARA. U.S. EPA's worker protection regulations cover State and local government employees without OSHA-approved plans (reference 300.150 of the NCP).

An employer conducting a cleanup must comply with all the requirements in (b) through (o) of the OSHA standard. The requirements of (b) through (o) of the standard specify a minimum of 24 hours of off-site training. During emergency responses under 29 CFR 1910.120, the employer must comply with 1910.120 (q). If a post-emergency-response cleanup is done on plant property using plant or workplace employees, the employer must comply with the training requirements of 29 CFR 1910.38(a), 1910.134, 1910.120, and other appropriate training made necessary by the tasks they are expected to perform.

Based on experience with the standard (29 CFR 1910.120 [q][11][i]) during oil spills off the coasts of Texas, Alaska, and California, the hazards to employees vary widely in severity of potential injury or illness. For job duties and responsibilities with a low magnitude of risk, fewer than 24 hours of training may be appropriate for post-emergency cleanup workers. It is the expectation of OSHA that though the number of hours of training may vary, a minimum of 4 hours would be appropriate in most situations. Moreover, petroleum spills are unique in that many people who assist in the cleanup may not engage in this activity on a recurring basis. In addition, for maximum protection of the environment, petroleum spills dictate that cleanup must be completed as soon as possible (OSHA Instruction CPL 2-2.251). The DOL RRT representative is responsible for determining site-specific training requirements.

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2.11.2. Safety and Environmental Health Officer

The Ninth and the Eighth Coast Guard District Offices each maintain a billet for a Safety and Environmental Health Officer (SEHO); District Industrial Hygienist). Primary responsibility of the incumbent is to provide occupational safety and health support for USCG Marine Safety personnel. This includes pollution response operations. The SEHO can provide USCG OSCs advice on safety and health matters and can assist on-scene in environmental and medical monitoring activities. Outside normal working hours, OSCs may request the SEHO's services through the District Operations Center.

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2.11.3. Emotional Health Services

Emergency workers often experience delayed reactions to the death and destruction caused by explosion, fire, or oil and chemical releases. No one is immune to the tragedy and mental stress. Responders should be debriefed within 1 week of their return home. It is each member agency's responsibility to ensure that its employees have this type of training. Contact FEMA for materials that address this aspect of emergency response.

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SECTION 3: Operations

3.1: Assessment/Classification of Discharge
3.2: Operational Response Objectives
3.3: Discharge or Release Control
3.4: Decontamination
3.5: Nonresponder Medical Needs
3.6: Wildlife Conservation
3.7: Evidence for Cost Recovery Actions
3.8: Waste Management

3.1. ASSESSMENT/CLASSIFICATION OF DISCHARGE

When the OSC receives a report of a discharge, initial actions include investigating the report to determine the threat posed to human health or welfare of the United States or the environment, the type and quantity of polluting material, and the source of the discharge. The OSC then officially classifies the size (i.e., minor, medium, major) and type (i.e., substantial threat, worst case discharge) of the discharge and determines the course of action to be followed. (See Table 2-1, p. 33)

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3.1.1. Spill of National Significance

A Spill of National Significance (SONS) is a spill that due to:
· severity,
· size,
· location,
· actual or potential impact on the public health and welfare or the environment, or
· the necessary response effort, is so complex that it requires extraordinary coordination of Federal, State, local, Tribal, and responsible party resources to contain and clean up the discharge.

A discharge may be classified as a SONS by the Administrator of U.S. EPA for discharges occurring in the inland zone and the Commandant of the USCG for discharges occurring in the coastal zone. For a SONS in the inland zone, the U.S. EPA Administrator may name a senior Agency official to assist the OSC in communicating with the affected parties and the public and coordinating Federal, State, local, Tribal, and international resources at the national level. This strategic coordination will involve, as appropriate, the NRT, RRT(s), the Governor(s) of affected State(s), and the mayor(s) or other chief executive(s) of local government(s).

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3.1.2. Worst Case Discharge

CWA Section 311(d)(2)(J) requires the ACP to include procedures and standards for removing a worst case discharge of oil, and for mitigating or preventing a substantial threat of such a discharge. A "worst case" discharge for the purposes of this plan will be the catastrophic release as identified in Facility Response Plans (FRPs) submitted to U.S. EPA. Since this is a requirement of OPA, only oil scenarios will be listed.

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3.2. OPERATIONAL RESPONSE OBJECTIVES

The priority response objective is protection of public health and safety, which includes response worker health and safety. Protection of the environment and public welfare (infrastructure) are also important response objectives, but are subordinate to public and worker safety.

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3.3. DISCHARGE OR RELEASE CONTROL

3.3.1. Actions To Lessen Impact

Defensive actions should begin as soon as possible to prevent, minimize, or mitigate the threat to the public health or welfare or to the environment. Actions may include the following:

(a) Analysis of water samples to determine the source and spread of the contaminants;

(b) Control of the source of the discharge;

(c) Measurements and sampling;

(d) Placement of physical barriers to deter the spread of the oil or to protect sensitive environmental resources through coordination with resource agency specialists;

(e) Control of the water discharged from upstream impoundments; and

(f) If approved, the use of chemicals and other materials to restrain the spread of the oil and mitigate its effects, in accordance with the NCP. Use of chemical agents is not pre-approved in Region 5.

Appendix IV presents a list of facilities by State, city, and name, and the worst case discharge and the water body threatened. Facilities are also cited on the Inland Sensitivity Maps.

Appropriate actions should be taken to recover the oil or mitigate its effects. Of the numerous chemical or physical methods that may be used, the chosen methods should be the most consistent with protecting the public health and welfare and the environment. Sinking agents shall not be used.

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3.3.1.1. General Guidelines for Oil Spills

Shoreline Cleanup Guideline Matrices have been developed for the U.S. EPA Region 5 Area by the RRT. These guidelines address the use of specific countermeasures on various shoreline habitats for four oil types. The shoreline types are listed in relative order of sensitivity. Habitat sensitivity is a function of a range of factors, including:
· degree of exposure to natural removal processes,
· biological productivity and ability to recover following oil exposure,
· human use of the habitat, and
· ease of oil removal.

These correlate directly with the rankings used in the Environmental Sensitivity Index (ESI) atlases published for the U.S. Great Lakes by NOAA.

The classifications developed for these matrices indicate the relative environmental impact expected as a result of implementing the response techniques on a specific shoreline. The relative effectiveness of the technique also has been incorporated into the matrices, especially where use of the technique would result in longer application and thus greater ecological impacts, or leave higher oil residues in the habitat.

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3.3.1.2. Oil Removal Actions

Selection of appropriate oil spill protection, recovery, and cleanup techniques prior to and following an oil spill is a critical element affecting the spill's environmental impact. To choose techniques that most effectively prevent or minimize adverse ecological impact, it is important to identify techniques that have minimal intrinsic ecological impacts and also are effective in minimizing the impact of the oil. Furthermore, it is important that these response techniques be pre-planned so that in the event of a spill, minimal time be spent preparing for the response.

Shoreline Cleanup Guideline Matrices are included in electronic form in Appendix V.

See Options for Minimizing Environmental Impacts of Freshwater Spill Response Actions (American Petroleum Institute [API]/NOAA, 1994), included in electronic form in Appendix VI.

Refer to Section 3.8 of this plan for details on disposal of recovered oil and contaminated materials.

As stated previously, the OSC directs response efforts and coordinates all other efforts at the scene of a discharge. As part of this effort, and following the required notifications, the OSC should:

(a) collect information about the discharge including source and cause;

(b) identify responsible parties;

(c) obtain technical data including amount, exposure pathways, and time of travel;

(d) determine potential impact on human health and the environment;

(e) determine whether spill poses a substantial threat;

(f) assess impact on natural resources and other property;

(g) determine protection priorities; and

(h) document costs.

OSCs shall consult with the natural resource trustees and appropriate local, Tribal, State, and Federal response agencies on all removal actions. OSCs may designate capable persons from local, State, or Federal agencies to act as their on-scene representatives. FEMA should be notified of all potential major disaster situations.

Properly trained volunteers can be used for such duties during an incident as beach surveillance, logistical support, and bird and wildlife rehabilitation. Such use of volunteers must, however, be approved by the appropriate State, Federal, and Native American fish and wildlife officials. Unless specifically requested by the OSC, these volunteers generally should not be used for physical removal or mitigative activities. If, in the judgement of the OSC, dangerous conditions exist, these volunteers shall be restricted from on-scene operations.

All response actions shall be conducted in accordance with the NCP. Oil recovered in cleanup operations and contaminated materials shall be disposed of in accordance with this ICP and local contingency plans.

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3.3.2. Use of Chemical Agents

The OSC must choose the best method from the available response tools in any incident. The physical recovery and removal of oil is the preferred cleanup technique. Under certain conditions, however, chemical agents can be an effective tool. There are no pre-approved uses of chemical agents in Region 5. If chemical use is considered, the guidelines below are intended to aid the OSC in making a decision.

U.S. EPA has compiled the NCP Product Schedule, a list of dispersants and other chemicals which the OSC and/or PRP may consider for use during a spill emergency. The Product Schedule does not authorize or pre-approve use of any of the listed products. The OSC may not authorize use of a product that is not listed on the Product Schedule.

The notifications required by the OSC are described in Section 2.10.2.

The USFWS must approve responsible party or OSC requests to allow trained volunteers to capture oiled birds. Federally and State-licensed bird rehabilitators with USFWS oversight may employ properly trained volunteers for bird cleaning activities. Bird handlers should have current tetanus shots.

Physical recovery and removal of oil is preferred.

Sinking agents shall not be used in U.S. EPA Region 5. U.S. EPA Region 5 does not promote the use of dispersants or other oil emulsifiers. The use of:
· surface collecting agents,
· biological additives,
· burning agents, or
· miscellaneous oil spill control agents
on surface waters, particularly near sensitive wetland or water supplies (fresh water systems) must be approved by State and/or Federal Agencies. Such use adds to the potential for serious impact of already released petroleum products. This stance is necessary to protect subsurface water intakes (potable and non-potable).

The Region does recognize, however, that as a last resort, such agents may have some limited applicability. An example of a situation in which chemical use might be considered for reasons other than protection of human life is during the migratory season, when significant migratory bird or endangered species populations are in danger of becoming oiled.

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3.3.2.1. Application Steps for Use of Chemical Spill Control Agent

The OSC may authorize or is authorized to use any chemical product without requesting permission if its use is necessary to prevent or substantially reduce a hazard to human life. The RRT should be notified as soon as practicable. In situations where a human hazard is not present, the OSC must receive the concurrence of:

(a) the RRT Co-Chair, and

(b) the RRT representative(s) of the affected State(s), in consultation with

(c) the DOI RRT member (and, where the Great Lakes are affected, the DOC RRT member, where practicable) before authorizing use of a listed product.

The OSC may consult with the NOAA or EPA Scientific Support Coordinator (SSC) prior to chemical agent application in U.S. EPA Region 5. The NOAA and EPA SSCs provide:
· oil spill modeling results,
· interpretation of ESI maps,
· location of sensitive areas,
· chemical effects, and
· environmental risks.

The OSC will request approval from the RRT to use chemicals on behalf of the spiller. Use of chemicals on a Regional boundary should include the appropriate RRT members of the bordering Region. The RRT shall be notified of any chemical use as soon as practicable.

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3.3.2.2. Chemical Use Checklist

The OSC/RPM will supply the appropriate members of the RRT with the information contained in the checklist. The checklist provides information concerning the circumstances of the spill, trajectories, environmental resources at risk, and available decision makers with the information necessary to make a decision on the use of chemical agents.

Refer to Appendix VII for the Chemical Use Checklist.

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3.3.3. Use of In Situ Burning in U.S. EPA Region 5

In order to minimize the environmental impacts and facilitate effective cleanup of an oil spill, responders have a limited number of techniques available to them. These include mechanical methods, the use of certain chemical countermeasures, and in situ burning. Under certain specific conditions, in situ burning may offer a logistically simple, rapid, inexpensive, and relatively safe means for reducing the shoreline impacts of an oil spill. Moreover, because a large portion of the oil is converted to gaseous combustion products, the need for collection, storage, transport, and disposal of recovered material can be substantially reduced. In situ burning may be able to remove a large amount of spilled oil before spreading and drifting of the spill fouls shorelines and threatens wildlife. In certain circumstances, such as oil spilled in ice conditions, burning may be the only viable response technique. Authorization of in-situ burning is subject to consultation and concurrence from the State and DOI. Considerations for use should include an analysis of oil location and the potential impact of smoke on downwind populations.

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3.4. DECONTAMINATION

Personnel responding to hazardous substance incidents may become contaminated in a number of ways, including: · contacting vapors, gases, or particulates in the air;
· being splashed by materials while sampling or opening containers;
· walking through puddles of liquids or on contaminated soil; or
· using contaminated instruments or equipment.

Decontamination consists of physically removing contaminants or changing their chemical nature to innocuous substances. The extent of decontamination depends on a number of factors, the most important being the type of contaminants involved.

A decontamination plan should be developed as part of the safety plan for an emergency response. The initial decontamination plan is based on a worst-case situation or assumes no information is available about the incident. Specific conditions (e.g., type of contaminant, amount of contamination, levels of protection required, type of protective clothing worn) are then evaluated, and the initial decontamination plan is modified to adapt as new information about site conditions becomes available. All materials and equipment used for decontamination must be disposed of properly.

In addition to routine decontamination procedures, emergency decontamination procedures must be established. In an emergency, the primary concern is to prevent the loss of life or severe injury to site personnel. If immediate medical treatment is required to save a life, decontamination should be delayed until the victim is stabilized. If decontamination can be performed without interfering with essential lifesaving techniques or first aid, or if a worker has been contaminated with an extremely toxic or corrosive material that could cause severe injury or loss of life, decontamination must be performed immediately. During an emergency, provision must also be made for protecting medical personnel and disposing of contaminated clothing and equipment.

The complete text of In Situ Burning of Oil as a Response Tool in Region 5, Parts I and II (January 1996) is presented as Appendix VIII of this Plan.

The OSC is responsible for addressing worker health and safety concerns at a response scene in accordance with 40 CFR Section 300.150.

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3.5. NONRESPONDER MEDICAL NEEDS

3.5.1. Population Protective Actions

Protective actions for human populations are shelter in place, evacuation, or some combination of the two (e.g., evacuate the general population but shelter bedridden patients, jail populations). Guidance is currently being developed by FEMA in conjunction with other Federal Agencies on the decision-making process between evacuation and in-place sheltering. Until that guidance is available, it should be noted that if no decision is made, by default people will be sheltered in place, albeit not as effectively.

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3.5.2. Treatment of Exposed Population

The first priority of response personnel is to assess the health and welfare of individuals involved in the emergency incident. Immediate medical attention is given to seriously injured persons; the hospital is alerted and transportation is requested as necessary.

(a) An initial survey of the area should be performed to determine radiologically contaminated areas and, if possible, to identify an uncontaminated area to which any injured persons can be removed.

(b) Contamination monitoring of all injured persons should be performed in the clean area and appropriate decontamination performed, if necessary.

(c) Seriously injured individuals who cannot be completely decontaminated should be wrapped in blankets to prevent the spread of contamination during transport.

(d) Individuals not completely decontaminated should be tagged to alert medical personnel to their contaminated status. Each tag should include the name of the individual, the injuries identified, the date and time of the incident, suspected contaminants, and the locations and levels of contamination.

(e) Provisions for appropriate testing should be made in all cases of suspected internal contamination of affected individuals or response personnel.

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3.6. WILDLIFE CONSERVATION

The contamination of wildlife by oil has a high public impact which must be recognized by the OSC and members of the RRT. Public interest, inquiries, criticism, and demands for the cleaning of affected wildlife can seriously hamper the OSC's ability to proceed with mitigation of the spill. Early inspection of impacted or potentially impacted areas known to be wildlife habitat should be made by the OSC, and at the first sign of wildlife involvement, the OSC/RPM should contact the DOI representative to RRT5 to request organization and supervision of the wildlife protection efforts. Funding for these efforts will be required either from a responsible party or the pollution fund.

During response to a discharge or release, natural resource trustees and managers may provide technical assistance and expertise on potential effects on fish and wildlife and their habitats, or other sensitive environments that can be found in the affected area. They are familiar with the area or habitats affected and may be able to provide recommendations on the best locations for staging areas, access points, or anchorage. The natural resource trustees and managers may recommend specific habitats where protective measures should be taken and offer advice on response actions. They may assist in the development of a response monitoring plan and subsequent collection of data. Finally, the USFWS and the state wildlife agency can be expected to direct or provide oversight for the protection, rescue, and/or rehabilitation of fish and wildlife.

Additional Information on shelter in place can be found at the following web sites:
http://www.fema.gov/library/hazmatf.htm;
http://www.fema.gov/pte/talkdiz/chemical.htm

Protective measures may include one or more of the following:

· Preventing oil from reaching areas where migratory birds and other wildlife are located by either containing or recovering the oil, or

· Deterring birds or other wildlife from entering areas affected by oil by using wildlife hazing devices or other methods.

If exposure of birds and other wildlife to oil cannot be prevented, an immediate decision will need to be made regarding whether to capture and rehabilitate oiled birds and other wildlife. The DOI has statutory responsibilities for protecting migratory birds and Federally-listed threatened and endangered species. These responsibilities are delegated to the USFWS. If animals other than migratory birds or Federally-listed threatened or endangered species are found injured, the responsible agency would typically be the state wildlife agency. The decision to rescue and rehabilitate oiled wildlife must be made in consultation with the applicable state and Federal natural resource management agencies, since state and Federal permits are required by law. Any wildlife rescue and rehabilitation will be directed or overseen by the USFWS.

Detailed information on procedures, permit requirements, and appropriate contacts is provided in Appendix IX, Fish and Wildlife Annex to the U.S. EPA Region 5 Integrated Contingency Plan.

Tri-State Bird Rescue and Research, Inc., of Wilmington, DE, and International Bird Research and Rehabilitation Center of Berkeley, CA, are the two nationally recognized centers that can assist in planned or emergency training and organization of wildlife conservation efforts. Several regional centers have experience with oiled wildlife. USFWS Regional Pollution Response Coordinators are sources of these and other contacts in the Region.

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3.7. EVIDENCE FOR COST RECOVERY ACTIONS

3.7.1. Sample Collection Procedures

The OSC must observe precautions when collecting and handling liquid samples for analyses, as the character of the sample may be affected by a number of common conditions. Standard agency protocols are to be followed in the collection and shipment of all samples. Reports of laboratory analyses will be forwarded to the appropriate RRT Co-Chair for transmittal to counsel.

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3.7.2. Photographic Records

Conditions should be photographed to show the source and the extent of oil or hazardous material, if possible using both color and black-and-white film. The following information should be recorded on the back of each photographic print:
(a) name and location of vessel or facility;
(b) date and time the photo was taken;
(c) names of the photographer and witnesses;
(d) shutter speed and lens opening; and
(e) type of film used and details of film processing.

A reference manual Oiled Bird Rehabilitation: A Guide for Establishing and Operating a Treatment Facility for Oiled Birds has been prepared by Tri-State Bird Rescue and Research, Inc., and is a valuable resource for learning more about all aspects of wildlife conservation. Contact Tri-State Bird Rescue and Research, Inc., at (302) 737-7241.

See Appendix IX for USFWS Regional Pollution Response Coordinator contact information.

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3.7.3. Chain-of-Custody Record

All samples and other tangible evidence must be maintained in proper custody until orders have been received from competent authority directing their disposition. Precautions should be taken to protect the samples from breakage, fire, altering, and tampering. It is important that a chainofcustody of the samples be properly maintained and recorded from the time the samples are collected until ultimate use at the trial of the case. In this regard, a record of time, place, and name and title of the person collecting the sample, and each person handling same thereafter, must be maintained and forwarded with the sample. Form No. lEPA350051 may be used. U.S. EPA Regional procedures for sample collection, transport and custody are to be used for all samples submitted to the Central Regional Laboratory.

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3.8. WASTE MANAGEMENT

3.8.1. State Disposal and Management

Although the 1992 40 CFR Part 279 rules are not all immediately applicable Region-wide, individual States can enforce the rules as a matter of State law. Illinois, for example, has already promulgated equivalent regulations to 40 CFR Part 279. In addition, some States (e.g., Wisconsin) may prohibit the land disposal of oils.

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3.8.1.1. ILLINOIS

The Illinois Environmental Protection Agency (IEPA) expedites spill residue disposal permitting through its Emergency Action Center in Springfield. Permits are required for open burning and may be prescribed in some cases. Spill residues are considered Special Wastes in Illinois and require permit authorization numbers from IEPA for acceptance for disposal in a landfill. The procedural aspects of such permits can be expedited by IEPA but the technical requirements must be met (i.e., characterizations of the waste and its suitability for acceptance by a particular facility). IEPA maintains a current list of hazardous materials remediation contractors and disposal/treatment facilities, as well as a list of licensed waste haulers.

During office hours, IEPA can issue emergency generator identification numbers (both State and Federal). During non-office hours, IEPA may issue exemptions for procedural requirements when necessary to prevent additional damage to the environment. Out-of-state wastes may require additional review time.

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3.8.1.2. INDIANA

The Indiana Department of Environmental Management (IDEM) Emergency Response Section (ERS) facilitates issues related to waste management and disposal. The Indiana Code under Title 13 and Indiana Administrative Code includes laws related to these issues.

Contact the IEPA Duty Officer at: (217) 782-3637 (office) or (217) 782-7860 (both 24-hour numbers).


3.8.1.3. MICHIGAN

To be written.

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3.8.1.4. MINNESOTA

In Minnesota, disposal options for waste generated from a spill vary, depending on the contaminant and waste media. The Minnesota Pollution Control Agency (MPCA) Emergency Response Team members can assist the responsible party and expedite the necessary approvals for disposal of wastes generated from spills. In some emergency situations, the Team members may grant approval directly. Waste generated from oil spills can be disposed as follows:

(a) Oil-contaminated Water. After removal of free oil, the contaminated water can be stored for later treatment or disposed by discharge with approval to a local wastewater treatment plant, surface water, or on land. In some cases, the water may require carbon filtration and/or air stripping before discharge.

(b) Oil-contaminated Soil. There are several options—land applying or land farming, composting, and thermal treatment. The MPCA has developed guidance for these options.

(c) Oil-contaminated Debris. Possible options are co-incineration with municipal or industrial solid waste, open burning (permit required), or landfill deposition, depending on the volume, level of contamination, and location of the waste.

(d) Oil-contaminated Sorbent. For heavily saturated sorbent, incineration at a permitted solid waste facility is the only option. In some cases where little waste is generated and the sorbent has little contamination, the material can be wrung out, dried, and landfilled.

(e) Burning Oil Spills. The MPCA ERT is authorized to approve the burning of oil spills with the concurrence of local authorities and the Department of Natural Resources.

All disposal options must be approved by MPCA staff prior to disposal.

General information regarding open burning can be obtained from the Office of Air Management at (317) 233-0178.

During normal business hours, OSHWM phone number is (317) 615-7956. General information can be obtained at (317) 615-7373. General information can be obtained at (317) 615-8670.

The 24-hour contact numbers for the MPCA Emergency Response Team are (612) 649-5451 and (800) 442-0798.

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3.8.1.5. OHIO

The Division of Emergency and Remedial Response OSCs facilitate disposal of soils, spilled product, and contaminated water with the appropriate staff of other Ohio Environmental Protection Agency (OEPA) divisions. The Ohio Revised Code and Administrative Code provide emergency permitting for open burning, recovery, and injection wells, and assigns explosives and hazardous waste emergency generator identification numbers.

(a) Explosives. Under emergency conditions, the OEPA Emergency Response Duty Officer or OSC may grant verbal approval to local officials to detonate explosives. During business hours the responsible party must complete an application with the Central Office Division of Hazardous Waste Management.

(b) Open Burning. The OSC may authorize open burning of hydrocarbons and associated debris if the material and spill site meet established criteria. Any open burning is corrdinated with the local fire department, local health departments (air), and the OEPA Division of Air Pollution Control through the district offices. Requests are handled on a case-by-case basis.

(c) Hazardous Waste Generator Identification Numbers. Emergency Hazardous Waste Generator Identification Numbers are now assigned by the OEPA Division of Hazardous Waste Management during business hours. The Duty Officer and OSC may facilitate this process and help identify possible sites for waste storage and disposal.

(d) Hazardous Material Transporters. The Public Utilities Commission of Ohio (PUCO) registers Hazardous Material Transporters for OEPA. Over 500 companies are registered by the State of Ohio. The PUCO Transportation Division also enforces U.S. DOT's motor carrier safety laws.

(e) Groundwater/Wastewater Discharges. The Division of Public Drinking Water oversees the construction standards for wells. Enhanced recovery, involving shallow injection wells, requires a permit. Recovery wells, which result in a discharge to waters of the State, require best available treatment standards to be met. Recovery systems may require the owner/operator to apply for a permit to install. Typically, activated carbon is used on oil/water separation recovery systems before discharge to waters of the State is allowed. Permit applications are handled by the district office staff.

(f) Other. Treatment options such as on-site treatment or vapor recovery are handled on a case-by-case basis by the OSC.

The Central Office Division of Hazardous Waste Management can be contacted at (614) 644-2917.

The OEPA Division of Hazardous Waste Management can be reached during normal business hours at (614) 728-3778.

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3.8.1.6. WISCONSIN

The Wisconsin Department of Natural Resources rule series, "Investigation and Remediation of Environmental Contamination," includes specific rules on immediate and interim actions (NR 708); management of solid wastes excavated during response actions (NR 718); soil cleanup standards (NR 720); standards for selecting remedial actions (NR 722); remedial and interim action design, implementation, operation, maintenance and monitoring requirements (NR 724); and case closure (NR 726). The cleanup program is decentralized making staff available in the five regional offices for technical assistance. Each regional office has a Spill Coordinator to assist in spill-related technical issues.

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3.8.2. Federal Disposal—Hazardous Materials

In order to ensure proper treatment and disposal of hazardous substances recovered from CERCLA emergency response or removal sites, Section 300.65 of the NCP requires that off-site transport of hazardous substances use only facilities operating under appropriate Federal or State permits or authorization. Hazardous substances removed from such sites may be transferred only to facilities that are operating in compliance with RCRA, TSCA, and all applicable State requirements. These requirements also preclude the use of disposal units that have releases of hazardous wastes or hazardous constituents, or of disposal facilities that have releases which have not been addressed by corrective action.

U.S. EPA issued policies and procedures related to these requirements on November 13, 1987, entitled Revised Procedures for Implementing Off-site Response Actions (Office of Solid Waste and Emergency Response [OSWER] Directive 9834.11). Specific OSC roles and responsibilities for implementing the requirements can be found in Section IV of the Superfund Removal Procedures Manual, dated February 1988 (OSWER Directive 9360.03B).

The PUCO Transportation Division can be contacted at (614) 466-0351.

The OSC should coordinate closely with the Regional RCRA Off-site Coordinator (RROC), and/or TSCA personnel and the State, as appropriate.

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3.8.3. Federal Management—Oil

The NCP, Appendix E to Part 300, Oil Spill Response, Section 5.4, states that oil recovered in cleanup operations shall be disposed of in accordance with the RCP, ACP, and any applicable laws, regulations, or requirements. RRT and ACP guidelines may identify the disposal plans to be followed during an oil spill response and may address:

· sampling, testing, and classifying of recovered oil and oiled debris;

· segregation and stockpiling of recovered oil and oiled debris

· prior State disposal approvals and permits; and

· routes, methods (e.g., recycle/reuse, on-site burning, incineration, landfilling, etc.), and sites for the disposal of collected oil, oiled debris, and animal carcasses.

The Solid Waste Disposal Act as amended by the Used Oil Recycling Act (1980) and the Hazardous and Solid Waste Amendments (1984) provide the statutory authority for RCRA, as amended regulations applying to recovered oils and oily wastes. In 1992, U.S. EPA promulgated new used oil regulations at 40 CFR Part 279; these regulations incorporate the old used oil fuel requirements formerly codified at 40 CFR 266, Subpart E (1986_1992 CFRs).

The new used oil management standards at 40 CFR Part 279 apply only to "used oil," defined as any oil that has been refined from crude oil, used, and, as a result of such use, contaminated by physical and chemical impurities. If used oil is destined for disposal, the 40 CFR Part 279 regulations reference the RCRA hazardous waste management standards. Mixtures of waste oil (i.e., spilled, unused product oils) and used oil are regulated as used oil.

Waste oil and oily wastes are subject to the hazardous waste management regulations at 40 CFR Parts 124, 260-266, 268, and 270. Non-hazardous used oil may be disposed of in an industrial or a municipal solid waste landfill (each State may have additional, more stringent requirements), in accordance with 40 CFR 257 and 258.

It is Federal policy to recycle waste and used oils rather than dispose of them. Under the pre-1992 used oil regulations, used oil destined for recycling (in any way other than burning for energy recovery) is exempt from regulation as hazardous waste. The 1992 used oil management standards do address all recycling activities. Recycling waste oils and oily wastes is addressed by applicable hazardous waste management regulations.

Determining which used oil regulations apply to a particular spill is complicated by U.S. EPA's use of different statutory authority for the pre-1992 used oil fuel regulations than for the September 10, 1992, used oil management standards. The pre-1992 used oil regulations are Federally enforceable requirements in all U.S. EPA Region 5 States. The 1992 used oil management standards will become Federally enforceable requirements as the individual States promulgate regulations and become authorized for them. The relationship between 40 CFR 266 Subpart E and 40 CFR Part 279 was clarified in a May 3, 1993 Federal Register final rule (58 FR 26420-26426).

For answers to spill cleanup questions, call the RCRA Hotline at (800) 424-9346.

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SECTION 4: PLANNING

4.1: Resource Protection
4.2: Trustees For Natural Resources
4.3: Field Survey Techniques
4.4: Weather Information
4.5: Models

SECTION 4: PLANNING

4.1. RESOURCE PROTECTION

Mitigation and cleanup of spills requires a knowledge of resources at risk. Because many source locations and pollution paths are possible, strict prioritization of protection strategies is difficult. However, identification of resources potentially at risk before an incident and discussion of their relative importance are useful processes, both technically and from communications and human standpoints.

Sources of resource information are provided in this section. Planning is the preferred means to identify protection strategies as it reduces time required to implement effective protective measures and improves coordination through prior personal contact between responsible agencies. Where planning has not been completed, early notification and coordination with the appropriate agencies is critical. This section identifies types of resources to be considered for protection.

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4.1.1. Cultural Sites

Identification of culturally sensitive sites in the vicinity of a spill can be accomplished by contacting the State Historic Preservation Officer (SHPO). This individual is generally associated with the State Historical Preservation Office or Society, which may or may not be within a department of State government. Additionally, NPS has responsibility for sites located on Federal lands within the Region and can serve as a liaison to request NPS assistance concerning these resources. Specific procedures and Federal OSC responsibilities are set forth in the Programmatic Agreement on Protection of Historic Properties During Emergency Response Under the National Oil and Hazardous Substances Contingency Plan.

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4.1.2. Drinking Water Intakes

One of the major differences between coastal marine spills and freshwater spills (to Great Lakes and inland surface waters) is the potential impact on drinking water supplies. In many cases, users of surface waters do not have an alternate source of supply, nor do they have treatment or monitoring facilities for oil or chemical contamination.

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4.1.3. Environmentally and Economically Sensitive Areas

Environmentally and Economically Sensitive Areas are identified in the Inland Sensitivity Atlases. Information mapped includes:

· species data including Federal and State threatened and endangered species,
· Federal, State, Regional, and privately-owned and managed natural resource areas,
· Tribal Lands,
· Federal, State, Regional, and private designations of natural resource areas (no ownership),
· drinking water intakes,
· industrial water intakes,
· locks and dams,
· marinas and boat accesses, and
· oil storage above 42,000 gallons and oil pipelines.

Owners/operators, in the preparation of their FRPs, should also incorporate locally managed environmentally and economically sensitive area information for inclusion in the FRP.

Additional contacts for resource information are provided in Appendix IX.

A list of cultural site preservation contacts for U.S. EPA Region 5 is provided in Appendix X. These contacts are generally available during business hours only.

Identification of drinking water intakes may be found in the Inland Sensitivity Maps, USCG local Contingency Plans, State Health Departments, and locally in Emergency Management Plans.

Appendix IX, the Fish and Wildlife Annex to the U.S. EPA Region 5 ICP, dentifies and establishes priorities for fish and wildlife resources and their habitats and other important sensitive areas requiring protection from discharges. It provides mechanisms for timely identification of protection priorities during a spill response.

4.1.3.1. FISH, WILDLIFE, AND PLANTS

USFWS Field Response Coordinators are the primary Federal contact for information about migratory birds, endangered and threatened species, and fish and wildlife at risk as a result of spills in the inland and coastal zones.

Each State has fisheries and wildlife biologists, who may be assigned to a Department of Natural Resources or other State agency. These personnel are assigned to geographic areas within a State (district or region) and are listed in Appendix IX. They can also be identified through State emergency response agencies or USFWS Pollution Response Coordinators.

Each State has a Natural Heritage or Natural Features Inventory in computer format. These databases were initiated by The Nature Conservancy and have been turned over to States for management. These inventories incorporate observations of endangered, threatened, and otherwise specially designated species of fish, wildlife, and plants. Some inventories are in computer format; others are hard copy only. Data can be faxed in an emergency. The inventory is generally housed in the State Department of Natural Resources.

In Illinois, the Illinois Department of Natural Resources maintains a natural heritage inventory system. At present, the location information consists of hand-labeled topographical maps. Efforts are underway to input this information to a GIS system so that publication-quality maps can be more readily reproduced. Emergency contact: IEPA (217) 782-3637.

The Great Lakes Indian Fish and Wildlife Commission (GLIFWC) can be a source of technical assistance in understanding Native American fish and wildlife management and cultural values. Another source of valuable information is the National Animal Poison Control Center.

Sea Grant Universities and Extension Agents may be a source of local knowledge outside the public sector. These agents have contact with local scientists, fishermen, environmental groups, and other sources that may supplement information provided by regulatory agencies. They can be contacted through the NOAA SSC.

4.1.3.2. PROTECTED HABITAT

Updated information on protected habitat and economically and environmentally sensitive environments is provided in this plan in three separate indices, one for each of the three drainage basins in

Region 5: the Great Lakes Basin, the Mississippi River Basin, and the Ohio River Basin. Each index contains detailed information, in digital format, regarding the environmentally and economically sensitive areas, and Tribal interests. Descriptive information, maps, and emergency contact lists are also included. The text in the indices provides further instructions on accessing the data available on the disks.

A variety of protected areas such as forests, parks, preserves, reserves, and management areas are managed by public or private organizations such as The Nature Conservancy/Heritage Foundation. Additional sources of this information include Federal or State land management agencies, which include the Departments of the Interior, Agriculture, and Commerce at the Federal level and their counterparts at the State and local levels.

The list of current USFWS personnel and their geographic areas of expertise and/or responsibility is provided in Appendix IX.

Following is a list of locations of Nature Conservancy-sponsored inventories of "species of concern." The staff are not response personnel and are available during business hours only:

The National Animal Poison Control Center can be contacted at: 888-426-4435

The Great Lakes Basin, the Mississippi River Basin, and the Ohio River Basin indices are contained in Appendix XI.

See Appendix IX for listings of protected areas.

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4.2. TRUSTEES FOR NATURAL RESOURCES

CERCLA, CWA, and OPA require the designation of certain Federal, State, and Native American Tribal officials to act on behalf of the public as trustees for natural resources that they manage or protect. Natural resources, as defined in CERCLA Section 101(16) and OPA 1001(20) means land, fish, wildlife, biota, air, water, groundwater, drinking water supplies, and other such resources belonging to, managed by, held in trust by, appertaining to, or otherwise controlled by the United States, any state or local government, or Indian Tribe.

Natural resource(s) trustees are responsible for assessing damages to resources under their jurisdictions resulting from oil spills or release of hazardous substances. Also, agencies are responsible for seeking recovery for losses from responsible parties and for devising and carrying out rehabilitation, restoration, and replacement of injured natural resources. Where more than one natural resource(s) trustee has jurisdiction over a resource, agencies will coordinate and cooperate in carrying out the activities described above (reference NCP 300.600). Damage assessment is controlled by the designated natural resource(s) trustees and not response; however, it is important for natural resource(s) trustees to work with the OSC/RPM to coordinate activities as necessary.

To minimize impacts to natural resources and assist trustees in carrying out their responsibilities, the OSC is required to:

(1) Promptly report actual or potential discharges or releases to those federal, state, and tribal agencies designated as trustees for natural resources;

(2) Consult with trustees and other natural resource managers in determining such impacts and appropriate protective actions;

(3) Coordinate all response activities with trustees and other natural resource managers;

(4) Make available to trustees, documentation and information that can assist the trustees in determining actual or potential natural resource injuries; and

(5) Consult with USFWS on all incidents and response activities that may affect federally-listed threatened or endangered species, or their habitats.

The trustees and other natural resource managers, consistent with procedures specified in the Fish and Wildlife Annex (Appendix IX), may provide timely advice on recommended actions concerning resources that are potentially affected by a discharge of oil or release of hazardous substances. This could include providing assistance to the OSC/RPM in identifying and recommending pre-approved response techniques and in predesignating shoreline types and areas.

For U.S. EPA Region 5, the DOI Office of Environmental Policy and Compliance contact is located in Philadelphia, PA, at (215) 597-5378.

See Appendix IX for detailed discussion of trustee responsibilities.

Contact U.S. EPA Emergency Response Team (ERT) at (908) 906-6825 (business hours).

The trustees are authorized to assess monetary damages for resources injured, lost, or destroyed as a result of discharge of oil or releases of hazardous substances. In addition, the trustees are authorized to seek damages from the responsible person(s), and to devise and carry out restoration, rehabilitation and replacement of natural resources. Where more than one trustee has jurisdiction over a resource, these agencies should coordinate and cooperate in carrying out their activities. RRT representatives from trustee agencies serve as contact points.

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4.2.1. Federal Trustees

Unless delegated to an Authorized Official, the Secretary of the Interior is the natural resource trustee for the natural resources managed or controlled by the following DOI Bureaus:

NPS: National parks, national monuments, national historic sites, national recreation areas, and wild and scenic rivers;

USFWS: National wildlife refuges, national fish hatcheries, waterfowl production areas, migratory birds, threatened and endangered species, and anadromous fish.

BLM: Public lands and federally owned minerals (underlying private as well as public lands).

BIA: In cases where the United States acts on behalf of a Native American Tribe, the Secretary of the Interior also acts as trustee for natural resources for which the tribe would otherwise act as trustee, i.e., reservations and other lands or natural resources held in trust for the tribe including off-reservation natural resources).

The Secretary of Agriculture is trustee for the national forests and national grasslands.

The Secretary of Commerce, through the National Oceanic and Atmospheric Administration (NOAA), is trustee for lands under their administration; certain federally listed species; marine mammals; and marine, anadromous, and some Great Lakes fishes.

The Secretary of Defense is trustee for military lands and USACE project lands.

The Secretary of Energy is trustee for DOE lands and facilities.

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4.2.2. State Trustees

The governor of each state has designated state officials to act on behalf of the public as trustees for natural resources. Natural resources under state jurisdiction include all fish, wildlife, and biota including a shared trusteeship with the federal government for certain plants and animals, air, surface water, groundwater, and land.

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4.2.3. Native American Tribal Trustees

The tribal chairman or head of the tribal governing body, or person designated by tribal officials, acts as trustee of natural resources under Native American tribal trusteeship including lands and other natural resources belonging to, managed by, controlled by, or otherwise appertaining to the tribe; or held in trust for the tribe; or belonging to a member of the tribe if subject to a trust restriction on alienation.

State trustees for natural resources within Region 5 are listed in Annex 1 to Appendix IX.

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4.2.4. Functions of Trustees

The DOI Office of Environmental Policy and Compliance manages oil spills,and releases of hazardous substances. This includes supervision of DOI's participation in contingency planning, response activities, technical assistance, and training exercises. In this regard it represents the Department in the NCP, the FRERP, and other Federal response plans for natural and technological hazards on national and regional response teams.

The DOI Office of Environmental Policy and Compliance is the initial contact for notification and for overall coordination of its trustee activities. USFWS is the program manager for endangered species, anadromous fish, and the lands in the National Wildlife Refuge system, and will be among those involved for DOI in spill incidents because of its responsibility for these resources. The Department of the Interior, Department of Defense, Department of Energy, Department of Agriculture, U.S. National Forest Service, National Oceanic and Atmospheric Administration, and Native American Tribes may serve as trustees or co-trustees.

At the time of a spill, the Federal trustees and trustees of affected Stateand Tribal communities will meet and select one agency to act as Lead Administrative Trustee (LAT). They will convene a trustee group to ensure the best possible coordination of natural resource trustee activities such as data gathering, damage assessment, and negotiations with responsible parties.

The trustees may initiate a natural resource damage assessment. The Federal damage assessment regulations for oil discharges mandated under OPA were developed by NOAA and are now final. The regulations developed by DOI under CERCLA and CWA authorities apply to releases of hazardous substances and are in effect and available for trustee guidance and use. The NOAA SSC can serve as the liaison between the OSC and the trustees conducting damage assessment data collection efforts.

Specific natural resource trustee activities which may be expected to begin during a response include, but are not limited to:

(a) convening the trustee group;

(b) developing and implementing initial sampling plans;

(c) establishing the lead administrative trustee;

(d) developing NRDA initiation requests to the OSLTF;

(e) selecting appropriate assessment strategies;

(f) implementing longer-term assessment studies; and

(g) planning and implementing natural resource restoration.

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4.3. FIELD SURVEY TECHNIQUES

4.3.1. Remote Sensing

A variety of land-based remote sensing methods exist which have been successfully used and are commercially available through contractors. Contact U.S. EPA for details and access its contracted resources.

Aerial remote sensing, primarily used for locating pollutants in water, is in its early stages of development. Technologies are similar to land-based systems; however, data acquisition and interpretation are costly and of limited value. The agencies listed below have capabilities and experts that can be consulted regarding the use of these techniques.

EPA Environmental Photographic Interpretation Center (EPIC)
Reston, Virginia | (703) 648-4284; fax: (708) 648-4290
NOAA Satellite Services Division | (301) 7638051 (business hours); (301) 763-8142, x 124
Environment Canada (Emergency Science Division) | (613) 9989622

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4.3.2. Underwater Response

4.3.2.1. UNDERWATER SURVEY EQUIPMENT

The following underwater survey equipment is available to the Region through the U.S. EPA Emergency Response Team (ERT):

Remote-Operated Vehicle (ROV): For use in observing underwater objects from shore or boat (1,000-foot depth limit).

Mesotech Sonar: Mounted on ROV to locate any object above bottom sediments. ROV directed to potential drums by sonar.

Proton Magnetometer: Locates metal objects underwater. Towed behind a boat.

Sediment and Water Sampling Equipment: Provides ability to sample water and sediments at any depth. Analyses performed at ERT's laboratory facilities, Edison, NJ.

20-foot Boston Whaler: Trailerable boat specially designed for underwater electronic surveys and diving operations.

Side-Scan Sonar Survey Equipment: Accurately maps bottom.

4.3.2.2. DIVING CAPABILITIES

ERT Diving Team: Three U.S. EPA-certified divers with Level B-equivalent diving gear.

Commercial (Contract) Divers: For long-term underwater removals, Region 5 uses private diving firms that comply with U.S. EPA's Chapter 10 Diving Safety Regulations.

Various Diving Equipment: Available from any of U.S. EPA's five diving units.

Contact ERT's Unit Dive Officer: 908-906-6825 (business hours). For a list of qualified diving contractors and required equipment modifications, contact Unit Dive Officer, U.S. EPA Region 5 (312-886-4466).

4.3.3. Field Services Section

The Field Services Section, Superfund Division, Region 5, has the ability to perform limited field surveys at hazardous waste sites. The Section has staff and equipment to provide the following services using various techniques and field equipment:

(a) Surface geophysical surveys: using ground-penetrating radar, electromagnetic surveys, magnetometers, seismic refraction, and resistivity measures.

(b) Subsurface geophysical surveys: using seismic tomography, electromagnetic surveys, natural gamma detection, single-point resistivity, spontaneous potential measures, fluid resistivity, and various borehole measures.

(c) Soil/Groundwater samples: using a Geoprobe or similar equipment.

(d) Aerial photography: using a remote control helicopter for low level flights.

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4.4. WEATHER INFORMATION

NOAA's NWS forecast offices are operated 24 hours a day and primarily provide weather forecasts and warnings. In addition, many can provide hydrological information.

The NWS Forecast Office in Cleveland houses a computer weather product database called DMWDS. A password that can be obtained through the Cleveland office allows access to forecasts for all the Great Lakes and raw data (e.g., wind speed and direction) from many reporting stations, including NOAA data buoys throughout the Great Lakes. The NWS offices on the inland rivers provide river velocity information, as well as weather forecasts, warnings, and observations.

The offices listed below are Forecast Offices at which forecasts are prepared. Other NWS offices located throughout the region have access to the same data and can be useful resources.
Cleveland, OH -- (216) 265-2374
Pittsburgh, PA -- (412) 262-1988
Charleston, WV -- (304) 746-0188/89
Romeoville, IL -- (815) 834-0651
Detroit/Pontiac, MI -- (810) 625-4139
Minneapolis, MN -- (612) 361-6671
Milwaukee, WI -- (414) 965-5063
Indianapolis, IN -- (317) 856-0360
Marquette, MI -- (906) 475-5213
Duluth, MN -- (218) 729-6572
Green Bay, WI -- (414) 497-9177

The Field Services Section, Superfund Division, Region 5 can be contacted at (312) 886-3011.

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4.5. MODELS

4.5.1. Water

4.5.1.1. NOAA GREAT LAKES ENVIRONMENTAL RESEARCH LABORATORY (Great Lakes open water)

Surface water models exist for the Great Lakes and interconnecting channels. The open water model for all of the Lakes was produced by NOAA's Great Lakes Environmental Research Laboratory (GLERL) and is housed on their VAX.

Models of near-shore areas and tributaries to the Great Lakes have various levels of detail. Contact with Sea Grant Institutions or USGS is suggested.

4.5.1.2. ReachScan Model

A model for the Mississippi River or Illinois Waterway was developed for U.S. EPA by Versar, Inc., in 1986. The model is called ReachScan, and is also on PC GEMS, a widely used U.S. EPA modeling program. Contact SSC for 24-hour information on pollutant movement in surface waters.

4.5.1.3. NOAA HAZMAT MODELING AND SIMULATION STUDIES BRANCH (MASS)

MASS can provide spill trajectories and information on
· weather,
· currents,
· water levels, and
· oil fate and behavior.

MASS maintains and operates the On-Scene Spill Model (OSSM) for marine spills and can run other available models (such as GLERL's) for the Great Lakes and Inland Rivers.

4.5.1.4. USACE COLD REGIONS RESEARCH ENGINEERING LABORATORY (CRREL) (RIVERS: GENERAL, AND ST. MARY'S, DETROIT—ST. CLAIR, AND OHIO RIVERS SPECIFICALLY); AND ST. LAWRENCE SEAWAY DEVELOPMENT CORPORATION (SLSDC)

Interconnecting channel models have been produced by the USACE CRREL. SLSDC also has a model for the St. Lawrence River. These models are available through USACE and operate on an MSDOS PC. Noncomputerized hydraulic information, which can be used to calculate travel times along the Great Lakes interconnecting channels, is provided in CANUSLAK.

4.5.1.5.ORSANCO (OHIO RIVER, MAIN STEM ONLY)

Time-of-travel estimations for the main stem of the Ohio River have been modeled by ORSANCO (model does not include the Monongahela and Allegheny tributaries). The model can be run on a MSDOS PC and is available through ORSANCO.

4.5.1.6. USACE DISTRICTS

USACE Districts are a source of information concerning water levels and velocities on the interconnecting channels to the Great Lakes and on the inland rivers.

The open water model for all of the Lakes is accessible to anyone with a modem by contacting (313) 741-2244.

Contact MASS at (206) 526-6317 or via the NOAA SSC for the Great Lakes and Inland Rivers (216) 522-7760).

The contact number for ORSANCO is (513) 231-7719.

(a) USACE's Detroit Office is capable of running trajectory models for the St. Mary's and the Detroit-St. Clair River Systems.

(b) USACE's Buffalo office houses the St. Lawrence River model.

(c) The Rock Island District and the St. Louis District can provide projections of flow on the Mississippi River from Minneapolis to St. Louis and the Illinois Waterway.

(d) The Pittsburgh Office and the Cincinnati Division can provide river flow data and river stage data for the Ohio River.

(e) The Chicago Office can provide river flow information for waterways in the Chicago Metropolitan area: the Chicago, Fox, DuPage, Little Calumet, and Kankakee Rivers.

(f) The St. Paul District's Riverine Emergency Management Model (REMM) can compute travel time between any two points on a river system and optionally can compute the fate of a chemical spill on the system. REMM is a generic program whose data set has been modeled on the Mississippi River headwaters.

4.5.1.7. NWS FORECAST OFFICES

These are secondary sources of river flow information, which can convert flows to velocities at select locations along rivers.

Ohio River—Cincinnati, OH (513) 383-0527

Lower Mississippi River—Slidell, LA (504) 641-4343

North Central—Minneapolis, MN (612) 361-6660

National Ocean Service (NOS), Silver Spring, MD (Water Levels) (301) 713-2902; (301) 713-2902 (business hours)

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4.5.2. Air Dispersion

A variety of air dispersion models are available, some of which are personal-computer-based and some of which require a mainframe computer. Computer-based models are quite useful in response planning; however, their results should be applied with caution. Discussion of output with experts is critical to correct interpretation and limitations. ARCHIE (developed by FEMA, U.S. EPA, and DOT), and NOAA's ALOHA (part of CAMEO), are examples of simple, computer-based planning models.

Detroit (Detroit River/Lake St. Clair/St. Mary's River) (313) 226-6413

Buffalo (St. Lawrence Riv.) (716) 879-4200

Rock Island (Upper Mississippi River, and the Illinois River) (309) 794-5272; (319) 627-4138 (24 hours).

St. Louis (St. Louis to Cairo and lower Illinois) (314) 331-8000

Chicago (Illinois River, defer to Rock Island) (312) 353-8884

REMM (612) 290-5402

Agencies that can run air dispersion models, interpret the output, and provide expert advice during a response include:
NOAA MASS (206) 526-6317;
U.S. EPA ERT (908) 321-6660;
ATSDR (404) 639-0615;
Environment Canada (416) 3461971;

Ontario Ministry of the Environment, Spills Action Center (416) 3253000.

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SECTION 5: LOGISTICS

5.1: Site Security
5.2: Communications
5.3: Transportation
5.4: Special Teams and Other Assistance Available to OSCS/RPMS
5.5: Non-Federal Chemical Expertise
5.6: State Organizations
5.7: Basic Ordering Agreement (BOA) Contractors

5.1. SITE SECURITY

Generally, local law enforcement or the responsible party provide site security at the scene of a response. However, the OSC has the authority to provide for site security as necessary.

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5.2. COMMUNICATIONS

5.2.1. Computer Bulletin Boards

Access by other staff to the computer bulletin boards listed below may be arranged through the appropriate RRT member.

5.2.1.1. FIRSTCLASS E-MAIL(NOAA RRT SYSTEM)

NOAA's FirstClass E-mail is an electronic communication network. Through this system, e-mail can be exchanged between RRT and NRT members, contractors, and State and Federal spill response agencies with accounts on the system. Although the capability exists, the effort has been directed at establishing support for the NRT members and the RRT Co-chairs. NRT members and RRT Co-chairs can contact the NRT FirstClass Administrator for information on obtaining an account.

5.2.1.2. ORSANCO

ORSANCO operates an electronic bulletin board, which is available to provide water quality information during spill events in the Ohio River basin. The system is resident on a personal computer and employs Mustang's Wildcat Bulletin Board software. In addition to spillrelated information, ORSANCO posts daily flow data and seasonal water quality data on the Board. There is no charge or formal registration procedure to use the system. Anyone can call and obtain immediate access to whatever is on file.

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5.2.2. NRC Teleconference Service

The National Response Center is capable of establishing a teleconference of up to 60 participants. The system is intended for use in support of emergency response operations, but can be made available on a limited basis for routine matters.

Federal OSCs and RRT chairmen may request a teleconference by contacting the NRC Duty Officer. They may request emergency conferences at any time, but should provide 1-day advance notice whenever possible.

In addition, both FEMA and GSA has a dedicated teleconference system capable of handling 10 participants.

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5.3. TRANSPORTATION (AIR, LAND, WATER)

Generally, government and/or personal vehicles or commercial airlines are utilized as transportation during response incidents. If necessary, charter services may be contracted.

For further information, see the NOAA HAZMAT FirstClass User's Manual, dated June 1994, or contact (202) 267-4497.

For information concerning procedures for logging onto the system and for reading reports, contact ORSANCO at (513) 231-7719.

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5.4. SPECIAL TEAMS AND OTHER ASSISTANCE AVAILABLE TO OSCS/RPMS

Different Federal Agencies can provide special forces that an OSC/RPM can call upon for assistance during an oil spill or hazardous substance release. These special forces are described below. They can be requested through the agency's RRT member.

5.4.1. National Strike Team

The National Strike Team consists of the three USCG Strike Teams, the Public Information Assist Team (PIAT), and the NSFCC, and is available to assist OSCs in both preparedness and response. The Strike Team provides trained personnel and specialized equipment to assist the OSC in training, spill stabilization and containment, and monitoring or directing response actions. The NSFCC can provide coordination support to the OSC and assist in locating spill response resources.

5.4.1.1. ATLANTIC STRIKE TEAM (AST)

AST is a pollution control team equipped and trained to assist in the response to oil or chemical incidents. The AST has personnel on standby to respond to incidents occurring in the Great Lakes and eastern United States. Services available from the AST include:
· technical expertise;
· supervisory assistance;
· cost documentation;
· deployment of salvage and pollution control equipment; and
· training in pollution response techniques.

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5.4.2. U.S. EPA Scientific Support Center

5.4.2.1. U.S. EPA ENVIRONMENTAL RESPONSE TEAM (ERT)

The ERT provides access to special response equipment including decontamination, sampling,, and air monitoring equipment. The ERT has expertise in treatment technology, biology, chemistry, hydrology, geology, and engineering, and can advise the OSC in:
· hazard evaluation and risk assessment,
· multimedia sampling and analysis,
· water supply decontamination and protection,
· safety,
· cleanup techniques and priorities,
· dispersant application, and
· training.

5.4.2.2. RADIOLOGICAL EMERGENCY RESPONSE TEAMS (RERTS) have been established by U.S. EPA ORIA to provide response and support for incidents or sites containing radiological hazards. Expertise is available in:
· radiation monitoring,
· radionuclide analysis,
· radiation health physics, and
· risk assessment.

RERTs can provide on-site support, including mobile monitoring laboratories for radiochemical sampling and analysis. Requests for support may be made 24 hours a day via the National Response Center or directly to the Regional U.S. EPA Radiation Program Manager in the Air and Radiation Division. Assistance is also available from the Nuclear Regulatory Commission, DOE, and other Federal Agencies.

The NSFCC's contact number is (919) 331-6000.

The Atlantic Strike Team's contact number is (609) 7240008.

The ERT's contact number is (908) 321-6740.

The contact number for the NRC's Radiological Emergency Response Team is (800) 424-8802.

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5.4.3. ATSDR/CDC

ATSDR, the lead Federal Agency for hazardous materials incidents, can provide the following experts for consultation and advice:

(1) Within 10 minutes: an emergency response coordinator;

(2) Within 20 minutes: a preliminary assessment team consisting of a toxicologist, chemist, environmental health scientist, physician, and other health personnel as required;

(3) Within 8 hours: an on-site response team (if the incident warrants).

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5.4.4. Navy Supervisor of Salvage

The Navy Supervisor of Salvage and Diving, Office of the Director of Ocean Engineering (SUPSALV), maintains special equipment and trained teams for response to salvage-related oil and hazardous substance incidents. SUPSALV maintains an extensive inventory of oil pollution abatement equipment located primarily at Williamsburg, VA, and Stockton, CA, which is containerized for immediate deployment by air or truck.

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5.4.5. NOAA Scientific Support Coordinator

The NOAA SSC provides scientific support in
· environmental chemistry,
· oil spill trajectories,
· natural resources at risk,
· environmental tradeoffs of countermeasures and cleanup, and
· information management.

OSC requests for SSC support can be made directly to the assigned area SSC, the NOAA HAZMAT program office in Seattle, or the DOC RRT representative.

The SSC may, at the request of the OSC, lead the scientific team and be responsible for providing scientific support for operational decisions and for coordinating on-scene scientific activity. The SSC may also facilitate the OSC's work with the lead administrative trustee for natural resources to ensure coordination between damage assessment data collection efforts and data collected in support of response operations. The SSC can also support RRTs and Area Committees in preparing Regional and area contingency plans and in conducting spill training.

The NOAA SSC serving the Ninth Coast Guard District is located at District Headquarters in Cleveland, Ohio. The NOAA SSC can provide:
· weather forecasts, water levels, and currents;
· spill trajectory forecasts;
· oil observations and overflight maps;
· information management;
· natural resources at risk;
· coordination of the natural resource trustee agencies;
· environmental tradeoffs of countermeasures and cleanup;
· environmental chemistry, including oil fingerprinting;
· health and safety;
· support to RRTs and Area Committees in preparing regional and area contingency plans and conducting spill training and exercises.

The ATSDR/CDC contact number is (404) 639-0615.

NOAA SSC contact numbers are:
usiness hours: (216) 522-7760
24-hour: (206) 526-6317 FAX: (216) 522-7759

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5.4.6. USCG District Response Group

The USCG District Response Groups (DRGs) provide the OSC with technical assistance, personnel, and equipment. The DRG comprises USCG personnel and equipment in the district, and an advisory team that coordinates movement of USCG resources.

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5.4.7. Office of Pipeline Safety

The DOT Office of Pipeline Safety is another resource available to OSCs.

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5.5. NON-FEDERAL CHEMICAL EXPERTISE

Technical and scientific information generated by the local community, along with information from Federal, State, and local governments, should be used to assist the OSC in devising response strategies where effective standard techniques are unavailable. Additional support is available from the organizations listed below.

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5.5.1. Chemical Transportation Emergency Center

The Chemical Transportation Emergency Center (CHEMTREC), a service of the Chemical Manufacturers' Association, provides technical data, coordination of chemical manufacturers, and emergency response information on chemical spills.

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5.5.2. American Petroleum Institute

The American Petroleum Institute (API), 2100 L Street, NW, Washington, DC 20037, is an organization consisting of representatives of the petroleum industry. Technical and operational expertise is available.

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5.5.3. National Pesticide Telecommunication Network

The National Pesticide Telecommunication Network provides information on pesticide-related health/toxicity/minor cleanup to physicians, veterinarians, fire departments, government agencies, and the general public.

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5.5.4. Canadian Transport Emergency Center

For dealing with Canadian shipments, the Canadian Transport Emergency Center (CANUTEC) has technical experts on duty 24 hours for chemical guidance.

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5.5.5. Association of Railroads, Bureau of Explosives

The Bureau of Explosives of the Association of Railroads, Washington, DC, can provide assistance in:
· accident assessment,
· classification of materials,
· environmental impacts,
· methods of cleanup, and
· mechanical evaluations
for incidents involving railroad trains.

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5.6. STATE ORGANIZATIONS

For services listed in this section, contact the appropriate State representative to the RRT.

District 9 Marine Safety Office contact number is (216) 902-6047/8.

District 8 Marine Safety Division contact number is (504) 589-6225.

The Office of Pipeline Safety contact number is (202) 366-4595.

The CHEMTREC 24-hour emergency number is (800) 4249300.

The contact number for API is (202) 682-8000 (business hours only).

The 24-hour number for CANUTEC is (613) 996-6666.

The Bureau of Explosives can be contacted at (202) 639-2222 during normal business hours; 24-hour response is available through CHEMTREC/Bureau of Explosives at (800) 424-9300.

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5.6.1. Illinois

IEPA has six chemists on its emergency response staff and immediate access to four toxicologists and one certified industrial hygienist. Explosive disposal expertise is available commercially in the Chicago area or through the Illinois Secretary of State's Police Bomb Squad, based in Springfield.

IEPA and the Indiana Department of Public Health (IDPH) have human and environmental toxicologists. The University of Illinois supports a 24hour veterinary toxicology hotline. Computer databases for physical, chemical, toxicological, and environmental data are available through government and commercial sources to both IEPA and IDPH.

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5.6.2. Indiana

IDEM has access to the Chemistry Section Chief 24 hours per day for technical advice about hazardous materials releases. In addition, IDEM has access to ISDH staff toxicologists to provide toxicological information and to assess the impact of spills on ingestion, inhalation, or direct contact, and to make recommendations on human health advisories 24 hours per day.

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5.6.3. Michigan

To be written.

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5.6.4. Minnesota

The on-call staff of MPCA are trained in chemical emergency hazards. MPCA toxicologist and Health Risk Assessment staff of the Department of Health can consult on hazards, but are not on call. The State's Duty Officer can reach and activate several local bomb squads throughout the State. MPCA's emergency contractor has staff trained in chemical hazards and industrial hygiene.

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5.6.5. Ohio

In consultation with the Ohio Department of Health Epidemiology Section, toxicological information can be provided and recommendations can be made on human health advisories concerning spills that may impact water supplies, the food chain, or result in public exposure.

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5.6.6. Wisconsin

The Department of Health and Family Services provides coordination of emergency public health and human services. Emergency public health activities includes technical assistance for hazardous material releases, disease outbreaks, radiological monitoring, natural disasters, and other health emergencies. The Division of Health employs a large number of environmental health professionals, including physicians, toxicologists, environmental health specialists, epidemiologists, public health nurses and public health educators who can be involved as a situation and their expertise warrants.

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5.7. BASIC ORDERING AGREEMENT (BOA) CONTRACTORS

USCG has established Basic Ordering Agreements with a number of commercial environmental remediation contractors. The list of current contractors is available on the following web sites:
· http://www.uscg.mil/mlclant/fdiv/8thdistrict.htm
· http://www.uscg.mil/mlclant/fdiv/9thdistrict.htm

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SECTION 6: FINANCE

6.1: General
6.2: CERCLA-Funded Responses
6.3: OPA-Funded Responses
6.4: Reimbursement to Local Governments For Emergency Response to Substance Releases
6.5: Documentation for Enforcement and Cost Recovery

6.1. GENERAL

The person or persons responsible for discharges or releases are liable for costs of cleanup. The OSC shall attempt to have the party responsible for the discharge or release voluntarily assume responsibility for containment, removal, and disposal operations. If the OSC determines that the responsible party has caused the discharge of oil or release of hazardous substances, he/she may initiate appropriate response actions established by OPA, CWA, or CERCLA. Action will be initiated by the agency administering the funding mechanism to recover such expenditures from the party responsible for the discharge, if known. The OSC may also issue an Administrative Order, either by consent or unilaterally, to require financially viable responsible parties to conduct the removal action.

Until new guidance is published, all incidents requiring funding must be screened by category:

(a) CWA Section 311(k) for oil only, and

(b) CERCLA for any release or threat of release of a hazardous material as defined by CERCLA.

A U.S. EPA and USCG Headquarters agreement states that response to any potentially hazardous oil and hazardous materials mixture shall be CERCLA-funded. This section addresses U.S. EPA and State access to OPA and CERCLA funding. USCG procedures can be found in USCG ACPs.

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6.2. CERCLA-FUNDED RESPONSES

Two mechanisms exist for funding a response and response-related activities of another Federal Agency other than U.S. EPA:

(a) an agency's Superfund budget, and

(b) an interagency agreement (IAG) authorizing access to the CERCLA Superfund account.

Response operations for hazardous substances or mixture of hazardous materials and oil may be funded from the CERCLA Superfund account. Removal actions shall not continue after $2 million has been obligated or twelve months have elapsed from the date of the initial response, unless U.S. EPA grants an exemption in accordance with Section 104(c)(1) CERCLA, as amended. Additionally, CERCLA-funded action may not be taken in response to a release or threat of a release:

(a) Of a naturally occurring substance in its unaltered form or altered solely through naturally occurring processes or phenomena, from a location where it is naturally found;

(b) From products which are part of the structure of, and result in exposure within, residential buildings or business or community structures;

(c) Into public or private drinking water supplies as a result of system deterioration through ordinary use.

However, U.S. EPA may respond to any release or threat of release if it is determined that it constitutes a public health or environmental emergency and no other person with the authority and capability to respond to the emergency will do so in a timely manner.

The U.S. EPA Superfund Division has been delegated authority to approve actions costing up to $2 million. State and local governments are not authorized to take actions that involve expenditure of CERCLA funds, unless an appropriate contract or cooperative agreement has been established.

The OSC is responsible for identifying whether technical assistance from another agency is necessary, and for making arrangements for that assistance. In addition, OSCs are responsible for initiating and processing any site-specific IAGs necessary for reimbursing Federal Agency participation.

U.S. EPA OSCs may develop, negotiate terms, and award IAGs for site-specific, U.S. EPA-led actions. For these IAGs, the OSC:

(a) defines the scope of work to be performed;

(b) outlines the responsibilities of each agency;

(c) determines the performance period;

(d) identifies primary contacts in each agency;

(e) names contractors and the dollar amounts of any contracts, if applicable;

(f) determines the overall reporting, invoicing, and amendment requirements

(g) prepares four copies of the Interagency Agreement/Amendment (EPA Form 1610-1), and

(h) prepares the commitment notice and the transmittal/decision memorandum.

The OSC then monitors accomplishment of work in accordance with the IAG scope of work.

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6.3. OPA-FUNDED RESPONSES

6.3.1. National Pollution Fund Center (NPFC)

OPA established the Oil Spill Liability Trust Fund (OSLTF) to pay for oil spill cleanups and damages in cases where the responsible party cannot or will not pay for the cleanup. The NPFC currently administers the disbursement of OSLTF money. The NPFC has several responsibilities, including:

(a) providing funding to permit timely removal actions;

(b) initiating Natural Resource Damage Assessments for oil spills;

(c) compensating claimants for damages caused by oil pollution;

(d) recovering costs owed by the responsible parties for oil pollution damages; and

(e) certifying the financial responsibility of vessel owners and operators.

OPA effectively permits other Federal Agencies, the States and Native American Tribes access to the OSLTF for a variety of purposes. The OSLTF can be used following an incident for removal actions and actions necessary to minimize or mitigate damage to the public health or welfare, and natural resources. Access to the OSLTF is partially governed by Section 6002 of OPA, 33 U.S.C. Section 2753. Federal, State, local, or Tribal agencies may get funding for removal costs through the OSC or by submitting a claim to the NPFC.

The NPFC can be contacted at (703) 235-4700. Its mailing address is 4200 Wilson Blvd., Ste. 1000 Arlington, VA 22203-1804

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6.3.2. U.S. EPA Access to OSLTF

Following spill notification, the OSC should:

(a) Contact the appropriate USCG District Office to obtain a Federal Project Number (FPN) for the response;

(b) Obtain approval for the project expenditure ceiling from USCG;

(c) Contact U.S. EPA Region 5 Budget Office in Cincinnati and obtain an account number;

(d) If necessary, initiate proper contracting mechanisms (such as ERCS, BOA, START) to assist in the cleanup effort; and

(e) If necessary, utilize Federal support structure as defined in the NCP. An OSC may obtain assistance from USCG/Strike Teams, NOAA, ERT, etc.

During the actual response, the OSC should:

(a) Document progress through POLREPs, including costs (copies to NPFC, Marine Logistics Command [MLC], District); and

(b) Track costs using U.S. EPA Removal Cost Management System or USCG paperwork.

In the case of a cleanup that lasts 30 days or less, the OSC must submit a cost documentation package within 30 days of cleanup completion.

For cleanups that extend beyond 30 days, the OSC must submit a cost documentation package every 45 days.

The documents to be included in cost documentation package are listed below:
(a) Summary letter,
(b) Personnel costs,
(c) Personnel travel costs,
(d) Other U.S. EPA costs, including U.S. EPA vehicles and equipment,
(e) U.S. EPA contractor costs,
(f) USCG Basic Ordering Agreements (BOAs), and
(g) Other government agency costs (local, State, or Federal).

When the cleanup has been completed, the OSC should write a completion report, which should be sent to the NPFC and to the ERD Division Director. The report should be similar to the OSC report developed at the end of a CERCLA response. The final POLREP for the response can serve as the completion report, unless the RRT requests a formal report. The report should include:

(a) a summary of the response events, including:
· spill location,
· cause,
· responsible party actions, and
· beginning and ending dates;

(b) an appraisal of the effectiveness of the removal actions taken by:
· the responsible parties,
· Federal Agencies,
· contractors,
· private groups, and
· volunteers; and

(c) recommendations for prevention of future incidents.

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6.3.3. State Access to OSLTF

States can access the OSLTF in three ways:

(a) Direct Access. States must request direct access through the FOSC. State access must be approved by the FOSC. The request must come only from the official designated by the Governor.

A proposal must be submitted to the FOSC and include anticipated funding and scope of work to be taken at the site. Ceiling increases and changes in the scope of work must be approved by the FOSC.

(b) Pollution Removal Funding Authorization (PRFA). The State acts as a contractor to the FOSC on site and can oversee site activities. The State can oversee Federal contractors under a PRFA.

The FOSC will prepare cost documentation and submit to the NPFC. State and other agency rates can be developed in conjunction with the NPFC.

Each agency involved in the spill must have a separate PRFA.

(c) Claims. Costs for spill cleanup can be submitted to the NPFC after the incident if direct access or a PRFA was not used. An FOSC is not involved in the claims process.

The NPFC will determine whether all actions taken at the site were consistent with the NCP.

In accordance with regulations promulgated under Section 1012(d)(1) of OPA, the President, upon the request of a Governor of a State or the individual designated by the Governor, may obligate the OSLTF through the NPFC for payment in an amount not to exceed $250,000 for removal costs consistent with the NCP required for the immediate removal of a discharge, or the mitigation or prevention of a substantial threat of a discharge, of oil. Requests for access to the OSLTF must be made to the OSC by telephone or other rapid means.

The list of current State designees to request OSLTF funds is contained in Appendix XIII, Section 7.

In making a request to access the OSLTF, the person making the request must do the following:

(a) Indicate that the request is a State access request under

33 CFR Part 133;

(b) Give their name, title, department, and State;

(c) Describe the incident in sufficient detail to allow a determination of jurisdiction, including at a minimum:
· the date of the occurrence,
· type of product discharged,
· estimated quantity of the discharge,
· body of water involved, and
· proposed removal actions for which funds are being requested under this part; and

(d) Indicate the amount of funds being requested.

For further information, refer to the USCG Technical Operating Procedures (TOPs) for State Access Under Section 1012 (d)(1) of OPA (NPFC Instruction 16451.1, November 1992), and the Flow Chart, State Access to OSLTF Under Section 1012(d)(1) of OPA, 33 U.S.C. Section 2712. These documents are available through the NPFC.

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6.3.4. Trustee Access to OSLTF

Trustees must obtain OSC approval prior to obtaining reimbursement of removal costs incurred while responding to an oil and/or hazardous substance discharge under the direction of the OSC. If a trustee believes that a Federal response action is necessary to protect natural resources, whether or not the response action has been Federalized, the trustee must notify the OSC in order to assure that any response action taken is authorized and in accordance with the requirements of the NCP, located at 40 CFR Part 300. If natural resource trustees wish to access the OSLTF in order to initiate a natural resource damages assessment, they must work directly with the NPFC, through the Federal Lead Administrative Trustee. In addition, the trustees may submit claims for natural resource damages to the NPFC for payment from the OSLTF.

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6.3.5. Reimbursable Expenses

OPA authorizes payment of "Removal Costs, including the costs of monitoring removal actions, consistent with the National Contingency Plan." This allows payment of incident-specific costs authorized by a Federal OSC, including costs of monitoring a responsible party's cleanup, as well as actual Federal cleanup activities. The fund may pay:

(a) costs of containment and removal of oil from water and shorelines;

(b) costs to prevent, minimize, or mitigate oil pollution where there is a substantial threat of discharge of oil; and

(c) costs of taking other related actions necessary to minimize or mitigate damage to the public health or welfare, including, but not limited to, damage to:
· fish,
· shellfish,
· wildlife,
· public and private property,
· shorelines, and
· beaches.

Examples of incident-specific Federal removal costs payable from the fund include:

· out-of-pocket expenses (e.g. per diem, travel, vehicle mileage costs; replication, transmission, and delivery of reports; rental cars; and field consumable costs),

· contracted costs,

· costs of U.S. EPA technical assistance teams,

· specific salary costs for temporary government employees hired or activated for the duration of the spill response, and

· specific salary costs for Federal employees not ordinarily available for oil spill response.

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6.3.6. Procedures for Reimbursement

To seek reimbursement from the Federal Pollution Fund:

(1) Federal Agencies must submit their reimbursable expenses on Form SF 1080, "Voucher for Transfer between Appropriations and/or Funds," to the OSC for certification.

(2) The OSC will submit certified requests for reimbursements to NPFC within 60 days after completion of the cleanup action (33 CFR 153.417).

(3) The USCG will effect transfer of funds to the agency requesting reimbursement, and prepare a billing for the discharger from information on recoverable expenditures on the USCG form, "Personnel Vehicle and Miscellaneous Cost Accounting Sheet" (available from USCG).

State agencies that do not have a formal agreement must submit a letter to the OSC requesting reimbursement. This letter must include a detailed itemized statement of reimbursable expenditures. Refer to the USCG Marine Safety Manual for additional information.

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6.3.7. Cost Recovery Action

All agencies participating in a Federal response must submit an itemized account of all recoverable costs to the OSC within 60 days of the completion of a cleanup operation.

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6.3.8. Recoverable Costs

The discharger incurs liability up to the discharger's legal limit of liability for all actual costs associated with Federal removal following Federal assumption of response activities. Recoverable costs include:

(a) direct expenditures from the fund (i.e., payment of contractors or vendors);

(b) all reimbursable agency expenses;

(c) all personnel costs, including salaries of response personnel;

(d) equipment costs, including depreciation and maintenance;

(e) administrative overhead; and

(f) pollution removal damage claims.

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6.3.9. Liability Limits

OPA sets limits of liability which apply to all removal costs and damages sought under the act. The limits may be adjusted for inflation every 3 years, based upon the consumer price index. The limits set by OPA are as follows:

(a) Tank vessels: $1,200 per gross ton; $10 million if 3,000 gross tons or greater; $2 million if less than 3,000 gross tons.

(b) Any other vessel: $600 per gross ton or $500,000.

(c) Offshore facility except Deep Water Ports: $75,000,000.

(d) Onshore facility and Deep Water Port: $350,000,000.

There are certain exceptions to these liability limits. The limits do not apply:

(a) if the incident was caused by gross negligence or willful misconduct;

(b) if the incident was a result of a violation of applicable Federal safety, construction, or operating regulations; or

(c) if the responsible party fails to report the incident, provide all reasonable cooperation and assistance required by a response official, or comply with an order issued by the Federal OSC.

In addition, OPA does not preempt State laws regarding liability, so in areas where State law places a higher limit, compensation for damages up to the liability limit established by the State law may be pursued.

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6.4. REIMBURSEMENT TO LOCAL GOVERNMENTS FOR EMERGENCY RESPONSE TO SUBSTANCE RELEASES

Section 123 of CERCLA and Section 1002 (b)(2)(F) of OPA authorize U.S. EPA to reimburse local governments for some and (in rare cases) possibly all of the expenses incurred in carrying out temporary emergency measures in response to hazardous substance threats or releases. These measures or operations are necessary to prevent or mitigate injury to human health or the environment.

The intent of the CERCLA reimbursement provision is to reduce any significant financial burden that may have been incurred by a local government (city, county, municipality, parish, township, town, Federally recognized Native American Tribe, or other official political subdivisions designated by a particular State) that takes the above measures in response to hazardous substance threats. Traditional local responsibilities, such as routine fire fighting, are not eligible for reimbursement. States are not eligible for this program and may not request reimbursement on their own behalf or on the behalf of a political subdivision within a given State (40 CFR Parts 310.20 and 310.30).

An application package can be obtained by contacting the RCRA/Superfund Hotline at U.S. EPA Headquarters at (800) 424-9346. The application package contains detailed, line-by-line instructions for completing the application.

The following criteria must be met before a request for reimbursement is to be considered:

(a) local government must have had a Title III plan by October 1, 1988.

(b) Response occurred after the effective date of this rule (October 17, 1986).

(c) local government informed U.S. EPA or the NRC as soon as possible, but not more than 24 hours after initiating response.

(d) Response actions were consistent with CERCLA, the NCP, and EPCRA.

(e) The request contains assurances that the response reimbursement does not supplant local funds normally provided for such activities.

(f) The applicant must have first attempted to recover the costs from all known potentially responsible parties (PRPs) and any other possible sources of reimbursement (State funds, insurance companies, etc.). Sixty (60) days must be allowed for the above responsible party to respond by making payment, expressing an intent to pay, or demonstrating willingness to negotiate payment.

CERCLA limits the amount of reimbursement to $25,000 per single response. If several agencies or departments are involved in a response, they must determine among themselves which agency will submit the request for reimbursement. Any request must be received by U.S. EPA within 6 months of the related response action.

Some of the allowable costs may include, but are not limited to, the following:

(a) Disposable materials and supplies acquired and used specifically for the related response.

(b) Employee compensation for response work that is not provided in the applicant's operating budget.

(c) Rental or leasing of equipment.

(d) Replacement costs of equipment contaminated to the extent that it is beyond reuse or repair.

(e) Decontamination of equipment.

(f) Special technical services needed for the response, such as those provided by experts or specialists.

(g) Other special services, such as utilities.

(h) Laboratory analysis costs related to the response.

(i) Costs associated with supplies, services, and equipment procured for a specific evaluation.

A review panel will evaluate each request and will rank the requests on the basis of financial burden. Financial burden is based on the ratio of eligible response costs to the locality's per capita income adjusted for population. If a request is not reimbursed during the review period for which it is submitted, the U.S. EPA reimbursement official has the discretion to hold the request open for a 1-year reconsideration.

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6.5. DOCUMENTATION FOR ENFORCEMENT AND COST RECOVERY

6.5.1. Introduction

The OSC in charge at the scene of a release may be from any one of several agencies. It is necessary, therefore, to establish uniform procedures for notification of counsel and for collection of samples and information consistent with the several phases in Federal response situations. Necessary information and sample collection must be performed at the proper times during Federal involvement in a spill for the purpose of later use in identifying the party responsible for cost recovery.

Time is of great importance, as wind, tide, and current may disperse or remove the evidence and witnesses may no longer be available. Thus, during the response phases, the OSC must take the necessary action to ensure that information, records, and samples adequate for legal and research purposes are obtained and safeguarded for future use.

Section 300.335 of the NCP outlines the types of funds which may be available to address certain oil and hazardous substances discharges. For releases of oil or a hazardous substance, pollutant, or contaminant, the following provisions apply:

(a) During all phases of response, the lead agency shall complete and maintain documentation to support all actions taken under the ACP and to form the basis for cost recovery. In general, documentation shall be sufficient to provide the source and circumstances of release; identity of responsible parties; response action taken; accurate accounting of Federal, State, or private party costs incurred for response actions; and impacts and potential impacts to public health and welfare and the environment. Where applicable, documentation shall state when the NRC received notification of release of a reportable quantity.

(b) The information and reports obtained by the lead agency for OSLTFfinanced response actions shall, as appropriate, be transmitted to the NPFC. Copies can then be forwarded to the NRT, members of the RRT, and others as appropriate.

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6.5.2. Notification

The OSC is responsible for coordinating with counsel in his/her agency. Counsel for the RRT member furnishing the OSC is responsible for notifying other RRT member counsel, as appropriate, of potential enforcement or cost recovery matters related to an incident. The OSC and his/her counsel are responsible, following review and consultation with other RRT members involved in an incident, for notifying a responsible party of any determination under the CWA or CERCLA that the party is not properly accomplishing any response action.

The information and reports obtained by the OSC are to be transmitted to the applicable RRT Co-chair. Copies will then be forwarded to members of the RRT and others, as appropriate. The representative of the agency on the RRT having cost recovery authority will then refer copies of the oil or hazardous materials reports to that agency's respective counsel.

Detailed guidance on preferred procedures can be found in

Enforcement Considerations for Evaluations of Uncontrolled Hazardous Waste Disposal Sites by Contractors, U.S. EPA, National Enforcement Investigation Center, April 1980.

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6.5.3. Legal Notice to Suspected Releaser

The owner, operator, or other appropriate responsible person shall be notified of Federal interest and potential action in an oil or hazardous materials release by the agency furnishing the OSC. This notice shall include:

(a) advice of the owner or operator's potential liability for proper response to the release;

(b) the need to perform removal in accordance with existing Federal and State statutes and regulations, this Plan, and the NCP; and

(c) identification of the OSC.

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6.5.4. Oil or Hazardous Materials Release Report

The appropriate information for each oil or hazardous material release should be obtained by the OSC and reported in the appropriate format established by the Emergency Response Division, Washington, DC. The OSC will retain:
· statements of witnesses,
· photographs,
· analyses of samples, and
· related documentation for possible use in enforcement actions. In all major spills, the oil or hazardous material incident report should be completed and forwarded to the RRT Chair.

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APPENDIX I: JURISDICTIONS IN REGION 5


1. REGIONAL AREAS

Region 5 has been divided into two operational areas, inland and coastal, which correspond to the areas in which U.S. EPA and USCG are responsible respectively for providing OSCs. The coastal operational area consists of the open waters of the Great Lakes, including Lake St. Clair, the interconnecting rivers, major bays, ports, and harbors of the Region 5 States; and the land surface, land substrata, ground water, and ambient air proximal to those waters. The inland operational area includes all other land territory of the six States of Region 5, including each State's inland lakes and rivers. Numerous Native American community reservations and treaty rights areas are also delineated within Region 5.

Two Coast Guard Districts share Federal Region 5. The Ninth Coast Guard District, headquartered in Cleveland, serves the Great Lakes drainage basin. The Eighth Coast Guard District, headquartered in New Orleans, serves the drainage basins of the upper Mississippi and the Ohio Rivers.

Within the Great Lakes coastal zone, the appropriate Captain of the Port (COTP) functions as the predesignated OSC for all oil and hazardous substance releases, subject to a DOT/U.S. EPA redelegation of certain CERCLA response authorities. U.S. EPA performs the following two categories of response actions within the coastal zone: 1) remedial actions for releases originating from facilities, and 2) all response actions for releases originating from hazardous waste management facilities.

The scope of the Eighth Coast Guard District response role is defined by a revised Memorandum of Understanding (MOU), between that District and U.S. EPA Region 5, signed by the Regional Administrator on April 12, 1993. The revised MOU assigned U.S. EPA as the predesignated OSC for the entire inland zone, including the inland river system within the Eighth Coast Guard District for responding to all discharges of oil and hazardous substances. The USCG would respond for spills from commercial vessels only.

DOD or DOE provides OSCs for all response actions for releases of hazardous substances, pollutants, or contaminants which originate on any facility or vessel under the jurisdiction, custody, or control of DOD or DOE. In the case of a Federal agency other than U.S. EPA, USCG, DOD, or DOE, such agency shall provide OSCs for all removal actions necessitated by releases originating on any facility or vessel under its jurisdiction that are not emergencies.

U.S. EPA or USCG OSCs may be requested to provide technical assistance to the lead agency OSC who is responding to the release or threatened release. In the event of an emergency on Federal agency property, other than DOD or DOE, U.S. EPA or USCG retains response authority and U.S. EPA OSCs may respond and later initiate cost recovery actions against the potentially responsible party.

Definitions of the boundaries of OSC jurisdictions for Region 5 are provided in the following subsections. Where highways are used to delineate the boundary, the roadbed right-of-ways of the highway are included in the inland (U.S. EPA) zone.

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2. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OSC BOUNDARIES

2.1. U.S. EPA Region 3 OSC Boundaries

U.S. EPA Region 3 will provide OSCs for investigating and responding to releases to the main stem of the Ohio River from the Ohio-Pennsylvania boundary, mile 40.1, to the Kentucky-West Virginia boundary, mile 317.2.

All releases in the above-named stretch of the Ohio River emanating from sources in West Virginia will be handled by U.S. EPA Region 3 personnel; those from sources in Region 5 will be handled by personnel from Region 5.

If either RRT is activated, the Eighth USCG District would be involved along the entire stretch of the Ohio River.

2.2. U.S. EPA Region 4 OSC Boundaries

U.S. EPA Region 4 will provide OSCs for investigating and responding to releases of oil or hazardous materials to the main stem of the Ohio River from the Kentucky-West Virginia boundary, mile 317.2, to its junction with the Mississippi River, mile 981.2.

Releases in the above-named stretch of the Ohio River emanating from shoreline sources in U.S. EPA Region 4 will be handled by personnel of Region 4; those spills from shoreline sources in Ohio, Indiana, and Illinois will be handled by personnel from Region 5.

Region 4 will have the responsibility for ensuring notification of water users downstream of the location of the release, including coordination with ORSANCO, the USCG Eighth District, and COE when a release occurs on the south shoreline or in the main stream of the Ohio River;

Region 5 has a like responsibility, including coordination with ORSANCO, the USCG Eighth District, and COE when a release occurs on the north shoreline of the river.

Either Region, when requested by the other, may assume the functional OSC role for a particular incident. The decision to accept this responsibility will rest with the Region being requested on an incident-specific basis. Boundary lines do not preclude mutual assistance between the two agencies.

2.3. U.S. EPA Region 7 OSC Boundaries

U.S. EPA Region 7 will provide OSCs for investigating and responding to releases to the main stem of the Upper Mississippi River (UMR) when either Iowa or Missouri is the principal first responding State.

U.S. EPA Region 5 will have jurisdiction for such releases within the State of Minnesota and where Minnesota, Wisconsin, or Illinois is the first principal responding State.

When releases to the UMR main stem will result in significant response by more than one State, or when there is uncertainty as to the responding States, Region 7 will provide OSCs for such releases occurring between Cairo, Illinois, and Keokuk, Iowa (miles 0.0 to 354.5), and Region 5 above that point.

For spills from shore facilities and non-waterborne sources, OSCs will be provided by the Region in which the source is located.

2.4. U.S. EPA Region 8 OSC Boundaries

U.S. EPA Region 5 will provide OSCs for investigating and responding to releases to the main stem of the Red River of the North from its origin in Lake Traverse near Browns Valley, Minnesota, to the Canadian border. All spills to the above-named stretch of the Red River emanating from sources in North Dakota and South Dakota will be handled by Region 8 personnel.

South of the Browns Valley area, the boundary between South Dakota and Minnesota involves the headwaters of the Minnesota River flowing southward. Region 5 Spill Response personnel will respond to releases to the main stem of the Little Minnesota River and Big Stone Lake southward to Ortonville, Minnesota.

All releases to the above-named headwaters of the Minnesota River emanating from sources in South Dakota will be handled by Region 8 personnel; releases from sources in Minnesota will be handled by Region 5 personnel.

U.S. EPA Region 8 will provide communications as necessary with the Canadian Province of Manitoba concerning all releases occurring in waters flowing into Canada, including those emanating from Region 5.

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3. NINTH COAST GUARD DISTRICT OSC BOUNDARIES

Eight USCG units provide OSCs for releases occurring within the coastal zone, each serving a specific geographic area. These geographic areas are defined as: the international boundary with Canada, the boundaries between the units (described at 33 CFR 3.45), and the boundary between the inland zone and the coastal zone. In most locations, the boundary between inland and coastal zones follows the near shore areas adjoining the Great Lakes and the interconnecting rivers.

The following subsections detail, for each of the eight units, which tributaries fall within the coastal zone and where a geographic feature, such as a highway, serves as the boundary.

3.1. Marine Safety Office, Chicago, IL

1. Lake Michigan: within limits of COTP Chicago.

2. North Point Marina (Winthrop Harbor, Illinois): Entire marina.

3. Waukegan Harbor: Entire harbor.

4. Wilmette Harbor: From the entrance to the sluice gate.

5. Montrose Harbor (Chicago, Illinois): Entire harbor.

6. Belmont Harbor (Chicago, Illinois): Entire harbor.

7. Diversey Harbor (Chicago, Illinois): Entire harbor.

8. Chicago River: The outer harbor, limited to the waters outside the Chicago Lock and retaining walls, including the waters inside the lock gates.

9. Burnham Park Harbor (Chicago, Illinois): Entire harbor.

10. 59th Street Harbor (Chicago, Illinois): Entire harbor.

11. Jackson Park Harbor (Chicago, Illinois): Entire harbor.

12. Calumet Harbor and River (Chicago, Illinois): From the mouth of the Calumet River south to the north side of O'Brien Lock and Dam, including the waters inside the lock gates. From "The Forks" west to the temporary dike at the south boundary of Lake Calumet.

13. Hammond Marina: Entire marina.

14. Indiana Harbor (East Chicago, Indiana): Upstream to Conrail Railroad Bridge.

15. Pastrick Marina (East Chicago, Indiana): Entire marina.

16. Buffington Harbor (Gary, Indiana): Entire harbor.

17. Gary Harbor (Gary, Indiana): Entire harbor.

18. Burns Harbor (Burns Harbor, Indiana): From the entrance to the south end of deep draft slip.

19. Michigan City Harbor: Entrance to Bascule Bridge.

20. Betsie Lake (Frankfort): Entire lake throughout up to and including the mouth of the Betsie River to Highway M-22 bridge.

21. Arcadia Lake: Entire lake.

22. Portage Lake: Entire lake.

23. Manistee Lake (Manistee): Entire lake throughout up to and including the mouth of the Manistee River to Highway M-55 bridge.

24. Pere Marquette Lake (Ludington): Entire lake throughout up to and including the mouth of the Pere Marquette River to Old U.S. 31 bridge.

25. Pentwater Lake: Entire lake.

26. White Lake: Entire lake.

27. Muskegon/Bear Lake (Muskegon, Michigan): Entire lake throughout up to and including the Muskegon River to the U.S. 31 bridges.

28. Mona Lake: Entire lake.

29. Spring Lake: Entire lake.

30. Grand River: From the mouth to the end of the dredged channel at Buoy #78 (in Ottawa County approximately 17 miles upstream).

31. Pigeon Lake: Entire lake up to the fixed bridge in the intake channel of the J.H. Campbell power plant and on the eastern end up to the fixed bridge of Lakeshore Avenue.

32. Lake Macatawa: Entire lake to the end of the dredged channel marked by buoys #25 and #26 (eastern end of the lake in Holland).

33. Kalamazoo Lake (Douglas/Saugatuck): Entire lake up to and including the Kalamazoo River to the CSX Railroad bridge, approximately 11 miles upstream.

34. Black River (South Haven): From the mouth to the U.S. 31 bridge, approximately 2.6 miles upstream.

35. St. Joseph River (St. Joseph): From the mouth to the Somerleyton bridge, approximately 6.6 miles upstream.

36. Paw Paw River (Benton Harbor): From the mouth to the CSX Railroad bridge, approximately 3.2 miles upstream.

37. Galien River: from the mouth to the Highway 12 bridge, approximately 2 miles upstream.

3.2. Marine Safety Office, Cleveland, OH

1. Ashtabula River (Ashtabula, Ohio): Upstream to East 5th Street.

2. Black River (Lorain, Ohio): Upstream to the turning basin at the National Tube Division of U.S. Steel (river mile 3.0).

3. Conneaut River (Conneaut, Ohio): Upstream to the Bessemer and Lake Erie Railroad Swing Bridge at Pittsburg & Conneaut Dock Comp. (river mile 0.75).

4. Cuyahoga River (Cleveland, Ohio): Upstream to the mouth of Big Creek in the Metropolitan Parks (river mile 7.5).

5. Grand River (Fairport Harbor, Ohio): Upstream to the turning basin at Osborn Concrete and Tank Company.

In addition to the river miles mentioned above, the coastal/inland zone demarcation shall be defined by the boundary on the highway created by State Route 2 from Vermilion to North Perry and then U.S. Route 20 from North Perry to the Ohio/Pennsylvania border. The costal zone being all waters and adjacent shoreline north of this boundary, any incident on the above-mentioned highways will be the responsibility of U.S. EPA but it should be noted that the COTP may be requested to respond as First Federal Official on scene until a U.S. EPA OSC can respond.

3.3. Marine Safety Office, Detroit, MI

1. Lake Huron: From Latitude 44-43' south and east to international boundary.

2. Saginaw Bay: The entire Saginaw Bay.

3. St. Clair River: East to international boundary.

4. Lake St. Clair: East to international boundary.

5. Detroit River: South to Detroit River Light and east to international boundary.

6. Au Gres River (Au Gres, Michigan): Upstream to U.S. 23 Bridge.

7. Au Sable River (Oscoda, Michigan): Upstream to Mill Street Bridge.

8. Bird Creek (Port Austin, Michigan): Upstream to Spring Street Bridge.

9. Belle River (Port Huron, Michigan): Upstream to M-29 Broadway Bridge.

10. Black River (Port Huron, Michigan): Upstream to and including Black River Canal.

11. Clinton River (Harrison Township, Michigan): Up to and including Clinton River Spillway.

12. Ecorse River (Ecorse, Michigan): Upstream to Jefferson Avenue Bridge.

13. Huron River (Rockwood, Michigan): Dixie Highway Bridge 1.8 miles above mouth of rive.

14. Milk River (St. Clair Shores, Michigan): Up to Jefferson Avenue Bridge.

15. Pigeon River (Caseville, Michigan): Upstream to M-25 Bridge.

16. Pine River (St. Clair, Michigan): Upstream to CSX Railroad Bridge.

17. River Rouge (Saginaw and Bay City, Michigan): Upstream to .5 mile above Center Street Bridge in Saginaw.

18. Salt River (Chesterfield Township, Michigan): Upstream to Callens Road Bridge.

19. Sebewaing River (Sebewaing, Michigan): Upstream to M-25 Bridge.

3.4. Marine Safety Office, Duluth, MN

Within Duluth/Superior Harbor, COTP Duluth will assume the responsibility for providing FOSCs in Duluth/Superior Harbor to the mouths of all small tributary rivers and creeks entering into the harbor, plus the St. Louis River serviced by existing patrols and aids to navigation up to the Highway Bridge on Route 23 at Fond du Lac, Minnesota, and the waters of Lake Superior within COTP Duluth.

3.5. Marine Safety Office, Milwaukee, WI

1. All waters of Lake Michigan within COTP Milwaukee's zone.

2. Pike Creek (Kenosha): To the Sixth Avenue Bridge.

3. Root River (Racine): To the Main Street Bridge.

4. Oak Creek (Milwaukee): To its mouth.

5. Kinnickkinnic River (Milwaukee): To the South Kinnickkinnic Avenue Bridge.

6. Menominee River (Milwaukee): To mile 2 (25th Street Bridge)

7. Milwaukee River (Milwaukee): To the North Humboldt Avenue Bridge.

8. Sauk Creek (Port Washingtom ): To the Wisconsin Street Bridge.

9. Sheboygan River (Sheboygan): To the Pennsylvania Avenue Bridge.

10. Manitowac River (Manitowac): To the C&NW Railroad Bridge.

11. West Twin River (Two Rivers): To the 16th and Madison Streets Bridge.

12. East Twin River (Two Rivers): To the 22nd Street Bridge.

13. Kewaunee River (Kewaunee): To the Park Street Bridge.

14. Ahnapee River (Algoma): To the 2nd Street Bridge.

15. Fox River (Green Bay): To the State Route 172 Bridge.

16. East River (Green Bay): To the Monroe Avenue Bridge.

17. Oconto River (Oconto): To the turning basin.

18. Menominee River (Marinette, Wisconsin to Menominee, Michigan): To the Dunlap Avenue (Highway 41) Bridge.

3.6. Marine Safety Office, Sault Ste. Marie, MI

1. Lake Superior: The waters, bays, tributaries, and adjoining shoreline of Lake Superior within U.S. territory, eastward from the westernmost boundary of the Area of Operations (AOR) to a line between Point Iroquois running northeast to Gros Cap Reef Light on the International Boundary.

2. St. Mary's River: The waters, bays, tributaries, and adjoining shoreline of the St. Mary's River within U.S. territory, from a line between Point Iroquois and Gros Cap Reef Light southward to a line between Detour Reef Light and Crab Island Shoal Light, including the waters of Potagannissing Bay.

3. Lake Huron: The waters, bays, tributaries, and adjoining shoreline of Lake Huron within U.S. territory, northward from the southernmost boundary of the AOR, west to the Straits of Mackinaw Bridge.

4. Lake Michigan: The waters, bays, tributaries, and adjoining shoreline of Lake Michigan, eastward from the westernmost boundary of the AOR, to the Straits of Mackinaw Bridge.

3.7. Marine Safety Office, Toledo, OH

1. River Raisin (Monroe, Michigan): Upstream to the turning basin (river mile 1.5).

2. Maumee River (Toledo, Ohio): Upstream to the I-75 Bridge.

3. Portage River (Port Clinton, Ohio): Upstream to Highway 163.

4. Sandusky Bay (Sandusky, Ohio): Upstream to Highway 2.

5. Huron River (Huron, Ohio): Upstream to turning basin (mile .5).

6. Lake Erie: The open waters, bays, harbors, and mouths of tributaries within the COTP Toledo zone.

3.8. Ninth Coast Guard District Responses in the Inland Zone

Ordinarily, the Ninth Coast Guard District will not provide the OSC for a release occurring in the inland zone. However, where a Marine Safety Officer responds in the inland zone to a marine casualty or other incident pursuant to USCG port safety and commercial vessel safety responsibilities, that officer will serve as the First Federal Official On Scene, pending arrival of the predesignated U.S. EPA OSC. In this capacity, that officer will manage any cleanup actions performed by the responsible party and, if necessary, will initiate a Federal removal.

The U.S. EPA Region 5 office may request that the Ninth Coast Guard District provide the OSC for a release in the inland zone, regardless of source, because of the particular circumstances of the incident.

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4. EIGHTH COAST GUARD DISTRICT OSC BOUNDARIES

Agency responsibilities have been reassigned to more clearly reflect the inland and coastal zone delineation. The revised MOU assigns the U.S. EPA as the predesignated OSC for the entire inland zone, including the inland river system within the Eighth District. The previous agreement designating specified ports and harbors as portions of the Coastal Zone is no longer applicable.

If the incident involves a commercial vessel, a transfer operation, or a marine transportation related facility, the USCG will provide the OSC. The Eighth District will assist the predesignated U.S. EPA OSC where there is a discharge or release of oil or hazardous substances, or a threat of such a discharge or release, into or on navigable waters. Upon request by the U.S. EPA OSC, the USCG may act on behalf of U.S. EPA, assuming the functional role and responsibilities of the OSC. If the USCG is the first Federal official on-scene, the USCG will notify the U.S. EPA OSC and act as the OSC until such time as the U.S. EPA OSC arrives.

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APPENDIX II: FEDERALLY RECOGNIZED NATIVE AMERICAN TRIBES IN REGION 5


MICHIGAN TRIBAL CONTACTS

Bay Mills Executive Council
Jeff Parker, Chairman
Route #1
Brimley, MI 49715

Bay Mills Indian Community
Ken Gebhardt, Fisheries Biologist
Route 1
Brimley, MI 49715

Grand Traverse Band of Ottawa & Chippewa
Joseph Raphael, Chairman
2605 NW Bayshore Road
Suttons Bay, MI 49862

Grand Traverse Band of Ottawa & Chippewa
Christine Mitchell, Biological Services Director
Route #1, Box 135
Suttons Bay, MI 49682

Hannahville Indian Community
Jeff Pecotte, Health Administrator
N14911 Hannahville Road
Wilson, MI 49896-7454

Hannahville Tribal Council
Kenneth Meshigaud, Chairman
N14911 Hannahville Bl. Rd.
Wilson, MI 49896-9728

Keweenaw Bay Indian Community
William Beaver, Environmental Specialist
795 Michigan Avenue
Baraga, MI 49908

Keweenaw Bay Tribal Council
Fred Dakota, President
795 Michigan Avenue
Baraga, MI 49908

Lac Vieux Desert Tribal Council
John McGeshick, Chairman
P.O. Box 446
Watersmeet, MI 49969

Lake Superior Chippewa, Lac Vieux Desert Band
George Beck, Environmental Specialist
P.O. Box 446
Watersmeet, MI 49969

Little River Band of Ottawa Indians
Daniel Bailey, Chairman
409 Water Street
Manistee, MI 49660

Little Traverse Band of Odawa Indians
Frank Ettawageshik, Chairman
1345 US Route 31 North
P.O. Box 246
Petosky, MI 49770

Pokaogon Band of Potawatomi
Joseph Winchester, Chairman
714 N. Front Street
Dowagiac, MI 49047

Nottawaseppi Huron Potawatomi Band
221 1/2 Mile Road
Fulton, MI 49052

Saginaw Chippewa Indian Tribe
Bill Mrdeza, Tribal Planner
7070 East Broadway Road
Mt. Pleasant, MI 48858

Saginaw Chippewa Tribal Council
Phil Peters, Chairman
7070 East Broadway Road
Mt. Pleasant, MI 48858

Sault Ste. Marie Tribal Council
Bernard Boushcor, Chairman
206 Greenough Street
Sault Ste. Marie, MI 49783

Sault Ste. Marie Tribe
Dan Tadgerson, Environmental Specialist
206 Greenough Street
Sault Ste. Marie, MI 49783

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MINNESOTA TRIBAL CONTACTS

Bois Forte Band of Chippewa
Darin Steen, Environmental Specialist
P.O. Box 16
Nett Lake, MN 55772

Bois Forte Tribal Council
Gary Donald, Chairman
P.O. Box 16
Nett Lake, MN 55772

Fond du Lac Band of Chippewa
Robert Peacock, Chairman
105 University Road
Cloquet, MN 55720

Fond du Lac Band of Chippewa
Joel Peterson, Environmental Specialist
105 University Road
Cloquet, MN 55720

Grand Portage Band of Chippewa
Norman Deschampe, Chairman
P.O. Box 428
Grand Portage, MN 55605

Grand Portage Band of Chippewa
Kristine Carré, Environmental Specialist
P.O. Box 428
Grand Portage, MN 55605

Leech Lake Band of Chippewa
Alfred Pemberton, Chairman
Route 3, Box 100
Cass Lake, MN 56633

Leech Lake Band of Chippewa
Bev-Nii Anderson, Environmental Specialist
Route 3, Box 100
Cass Lake, MN 56633

Lower Sioux Community Council
Jody Goodthunder, Chairman
Route #1, Box 308
Morton, MN 56270

Mille Lacs Band of Ojibwe
Marge Anderson, Chief Executive
HCR 67, Box 194
Onamia, MN 56359

Mille Lacs Band of Ojibwe
Mike Moilenan, Environmental Specialist
HCR 67, Box 194
Onamia, MN 56359

Minnesota Chippewa Tribe
Gary Frazer, Executive Director
P.O. Box 217
Cass Lake, MN 56633

Prairie Island Dakota Community
Curtis Campbell, Sr., President
5750 Sturgeon Lake Road
Welch, MN 55089

Prairie Island Community Council
Heather Westra, Environmental Specialist
5750 Sturgeon Lake Road
Welch, MN 55089

Red Lake Tribal Council
Bobby Whitefeather, Chairman
PO Box 279
Red Lake, MN 55089

Red Lake Band of Chippewa
Ken McBride, Environmental Specialist
P.O. Box 279
Red Lake, MN 56671

Shakopee Mdewakanton Community
Stanley Crooks, Chairman
2330 Sioux Trail NW
Prior Lake, MN 55372

Shakopee Mdewakanton Community
Stan Ellison, Environmental Specialist
2330 Sioux Trail, NW
Prior Lake, MN 55372

Upper/Lower Sioux
Jeff Besougloff, Environmental Specialist
610 E. Bridge Street
Redwood Falls, MN 56283

Upper Sioux Board of Trustees
Dallas Ross, Chairman
Box 147
Granite Falls, MN 56241

White Earth Band of Chippewa
Jeffrey Wark
RR 2, Box 270
Ponsford, MN 56591

White Earth Tribe
Eugene McArthur, Chairman
P.O. Box 418
White Earth, MN 56591

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WISCONSIN TRIBAL CONTACTS

Bad River Band of Chippewa
John Wilmer, Chairperson
P.O. Box 39
Odanah, WI 54861

Bad River Band of Chippewa
Gerald White, Environmental Specialist
P.O. Box 39
Odanah, WI 54861

Forest County Potawatomi Community
Phil Shopodock, Chairman
P.O. Box 346
Crandon, WI 54520

Forest County Potawatomi Community
Christine Hansen
P.O. Box 346
Crandon, WI 54520

Ho-Chunk Nation
Chloris Lowe, Chairman
P.O. Box 667, Hwy 54 East
Black River Falls, WI 54615

Ho-Chunk Nation
Jim Dunning, Environmental Specialist
Health and Human Services Dept.
P.O. Box 636
Black River Falls, WI 54615

Lac Courte Oreilles Band of Chippewa
Al Trepania, Chairman
Route #2, Box 2700
Hayward, WI 54843

Lac Courte Oreilles Band of Chippewa
Dan Tyrolt, Environmental Specialist
Route #2, Box 2700
Hayward, WI 54843

Lac du Flambeau Band of Chippewa
Tom Maulson, Chairman
P.O. Box 67
Lac du Flambeau, WI 54538

Lac du Flambeau Band of Chippewa
Dee Allen, Environmental Specialist
P. O. Box 67
Lac du Flambeau, WI 54538

Menominee Tribal Legislature
John Teller, Chairman
P.O. Box 397
Keshena, WI 54135

Menominee Indian Tribe
Gary Schuettpelz, Environmental Specialist
P.O. Box 910
Keshena, WI 54135

Oneida Business Committee
Deborah Doxtator, Chairperson
P.O. Box 365
Oneida, WI 54155

Oneida Nation of Wisconsin
Dawn George, Environmental Specialist
P.O. Box 365
Oneida, WI 54155

Red Cliff Tribal Council
Rose Gurnoe, Chairperson
P.O. Box 529
Bayfield, WI 54814

Red Cliff Band of Chippewa Indians
Judy Pratt-Shelley, Environmental Specialist
P.O. Box 529
Bayfield, WI 54814

St. Croix Tribal Council
Lewis Taylor, Chairman
P.O. Box 287
Hertel, WI 54845

St. Croix Band of Chippewa
Michele Schwoch, Environmental Specialist
P.O. Box 287
Hertel, WI 54845

Sokaogon Chippewa Community
Arlyn Ackley, Sr., Chairman
Route #1, P.O. Box 625
Crandon, WI 54520

Sokaogon Chippewa Community
John Griffin, Environmental Specialist
Route #1, P.O. Box 625
Crandon, WI 54520

Stockbridge-Munsee Community
Virgil Murphy, President
Route #1
Bowler, WI 54416

Stockbridge-Munsee Community
Greg Bunker, Environmental Specialist
Route #1
Bowler, WI 54416

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TRIBAL ORGANIZATIONS

Chippewa/Ottawa Treaty Fishery Mgt. Authority
Faith McGruther, Director
186 E. 3 Mile Rd-LeBlanc Bldg.
Sault Ste. Marie, MI 49783

1854 Treaty Resource Management Authority
Ferdinand Martineau, Director
1908 1/2 West Superior
Duluth, MN 55806

Great Lakes Indian Fish and Wildlife Commission
James Schlender, Director
P.O. Box 9
Odanah, WI 54861

Great Lakes Inter-Tribal Council
Joseph Bressette, Executive Director
623 Peace Pipe Road
Lac du Flambeau, WI 54538

Inter-Tribal Council of Michigan
Sylvia Evans, Director
312 Water Tower Drive
Kincheloe, MI 49788

Minnesota Chippewa Tribe
Gary Frazer, Executive Director
P.O. Box 217
Cass Lake, MN 56633

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TRIBAL LIAISONS

Tribal Environmental Liaison
Steve Dodge
P.O. Box 1030
Keshena, Wisconsin 54135

Tribal Environmental Liaison
Ed Fairbanks
c/o Minnesota Chippewa Tribe
P.O. Box 217
Cass Lake, MN 56633

Tribal Environmental Liaison
Jennifer Manville
3601 Mackinaw Trail
Sault Ste. Marie, MI 49783-9479

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APPENDIX III: CURRENT MEMBERS OF STANDING RRT

Department of Agriculture

Primary
Laura Samudio, Center Manager
Fire Operations Aviation and Fire Management
USDA Forest Service, Region 9
310 West Wisconsin Avenue
Milwaukee, WI 53203

Phone: 414-297-3690
24 hour: 414-297-3690
FAX: 414-297-3642
Email:wieac/r9@fs.fed.us

 
Department of Commerce

Primary
Martin McHugh
NOAA, Office of Response & Restoration
77 West Jackson, SR-6J
Chicago, IL 60604-3590

Phone: 312-886-0430
FAX: 312-886-4071
Skypager: 800-759-8888, PIN: 1637623
NOAA Hazmat Duty Officer: 206-526-6317
Email: marty_mchugh@hazmat.noaa.gov

Alternate
LCDR Ken Barton
NOAA/NOS/ORR/HMRD
7600 Sand Point Way, NE
Bin C 15700
Seattle, WA 98115-0070

Phone: 206-526-6326
FAX: 206-526-6329
Skypager: 800-759-7243, PIN: 2168798
NOAA Hazmat Duty Officer: 206-526-6317 Email:

Scientific Support Coordinator
LCDR Jason Maddox
NOAA/HAZMAT
1240 East 9th Street
Cleveland, OH 44199-2060

Phone: 216-522-7760
FAX: 216-522-7759
HAZMAT Duty Officer: 206-526-6317
Email: jason_maddox_lakessc@hazmat.noaa.gov

 
Department of Defense

Primary
Mark Schultz
Director, Environmental Department
Naval Training Center, Great Lakes
Suite 120, Building 1A
201 Decatur Avenue
Great Lakes, IL 60088-5600

Phone: 847-688-5999 ext. 40
FAX: 847-688-2319 or 4845
Pager: 800-759-7243 PIN: 811 3783
Email: schultzmr@pwcgl.navfac.navy.mil

Alternate
Michael A. Hanson
Environmental Department
Naval Training Center, Great Lakes
Suite 120, Building 1A
201 Decatur Avenue
Great Lakes, IL 60088-5600

Phone: 847-688-5999 ext. 48
FAX: 847-688-2319
Email: hansonma@pwcgl.navfac.navy.mil

 
Department of Energy

Primary
Edward Jascewsky
Chief, Health Protection Branch
U.S. Department of Energy
Radiological Coordination Office
9800 South Cass Avenue
Argonne, IL 60439

Phone: 630-252-9660
24 hour: 630-252-4800

FAX: 630-252-2361

Email: edward.jascewsky@ch.doe.gov

Alternate
Julie Beck
U.S. Department of Energy
Radiological Coordination Office
9800 South Cass Avenue
Argonne, IL 60439

Phone: 630-252-2260
24 hour: 630-252-4800
FAX: 630-252-2078
Email: julie.beck@ch.doe.gov

 
Department of Health and Human Services

Primary
Carl Adrianopoli
Office of Emergency Preparedness
U.S. Public Health Service, Region 5
105 West Adams, 17th floor
Chicago, IL 60603

Phone: 312-353-4515
24 hour: 800-SKY-PAGE/Pin: 2376227
FAX: 312-353-0718
Email: CAdrianopoli@hrsa.dhhs.gov

Alternate
Clayton G. Koher
ATSDR
Mail Code: ATSDR-4J
77 West Jackson Blvd.
Chicago, IL 60604

Phone: 312-886-0840
24 hour: 708-352-5566
FAX: 312-886-6066
Pager: 888-336-0727
Email: koher.clayton@epa.gov

 
Department of the Interior

Primary
Michael T. Chezik
U.S. Department of the Interior
Office of Environmental Policy and Compliance
244 Custom House
200 Chestnut Street
Philadelphia, PA 19106

Phone: 215-597-5378
24 hour: 800-759-8352/Mailbox: 1168849
FAX: 215-597-9845
NOAA Mail: R3DOI
Email: michael_chezik@ios.doi.gov

Alternate
Darrell R. Robertson
U.S. Dept. of the Interior
Office of Environmental Policy and Compliance
408 Atlantic Avenue, Room 142
Boston, MA 02210-3334

Phone: 617-223-8565
FAX: 617-223-8569
Pager: 1-888-525-4683
NOAA Mail R1DOI
Email: darrell_robertson@ios.doi.gov

 
Department of Justice

Primary
Steven Ellis
U.S. Department of Justice
Ben Franklin Station
P.O. Box 7611
Washington, DC 20044

Phone: 202-514-3163
24 hour: 202-514-2000
FAX: 202-616-6584
Email: steven.ellis@usdoj.gov

Alternate
Leslie Lehnert
U.S. Department of Justice
P.O. Box 7611
Washington, DC 20044

Phone: 202-514-1761
24 hour: 202-514-2000
FAX: 202-616-6584
Email: leslie.lehnert@usdoj.gov

 
Department of Labor

Primary
William Wiehrdt
Assistant Regional Administrator/Technical Support
U.S. Department of Labor/OSHA
230 South Dearborn, Room 3244
Chicago, IL 60604

Phone: 312-353-5977
24 hour: 312-353-2220
FAX: 312-886-5588
Email: wiehrdt-william@dol.gov

Alternate
Cynthia Weaver
Industrial Hygienist
U.S. Department of Labor /OSHA
230 South Dearborn, Room 3244 Chicago, IL 60604

Phone: 312-886-0906
24 hour: 312-353-2220
FAX: 312-886-5588
Email: weaver-cynthia@dol.gov

 
Department of State (NRT/RRT Representative)

Primary
Robert Blumberg
Marine Pollution Officer
Department of State
Attn: OES/OA, Room 5801
Main State Building
2201 C Street NW
Washington, DC 20520

Phone: 202-647-4971
24 hour: 202-647-1512
FAX: 202-647-9099
Email: blumberg@state.gov

 
Department of Transportation
United States Coast Guard, Ninth District
Primary/Region 5 RRT Co-Chair
Captain Randolph Helland
Chief, Marine Safety Division
Commander (m)
U.S. Coast Guard, Ninth District
1240 East 9th Street
Cleveland, OH 44199-2060
Phone: 216-902-6045
24 hour: 1-800-321-4400
FAX: 216-902-6059
Email:rhelland@d9.uscg.mil
Alternate
Robert Lallier
Marine Safety Division
U.S. Coast Guard Ninth District
1240 East 9th Street
Cleveland, OH 44199-2060
Phone: 216-902-6054
24 hour: 1-800-321-4400
FAX: 216-902-6059
Email: rlallier@d9.uscg.mil

Support
T.J. Mangoni
Marine Safety Division
U.S. Coast Guard, Ninth District
1240 East 9th Street
Cleveland, OH 44199-2060

Voice: 216-902-6053
24 Hour: 1-800-312-4400
FAX: 216-902-6059
Email: amangoni@d9.uscg.mil

 
United States Coast Guard, Eighth District

Primary
CDR Ed Stanton
Marine Safety Division
U.S. Coast Guard, Eighth District
Hale Boggs Federal Building
501 Magazine Street
New Orleans, LA 70130-3396

Phone: 504-589-6271 or 3656
24 hour: 504-589-6225
FAX: 504-589-4999
Email: estanton@d8.uscg.mil

 
United States Environmental Protection Agency, Reg. 5

Primary/Region 5 RRT Co-Chair
Richard Karl, Chief
Emergency Response Branch
U.S. EPA Region 5
77 West Jackson, SE-5J
Chicago, IL 60604

Phone: 312-353-9295
24 hour: 312-353-2318
FAX: 312-353-9176
Email: karl.richard@epamail.epa.gov

Alternate
Mark Horwitz, Chief
Office of Chemical Emergency
Preparedness and Prevention
U.S. EPA Region 5
77 West Jackson, SC-9J
Chicago, IL 60604

Phone: 312-353-9045
24 hour: 312-353-2318
FAX: 312-886-6064
Email: horwitz.mark@epamail.epa.gov

 
Federal Emergency Management Agency

Primary
Mike Dombroski
FEMA Region 5
536 South Clark Street, 6th Floor
Chicago, IL 60605

Phone: 312-408-5516
24 hour: 800-311-7021
FAX: 312-408-5222
Email: mike.dombroski@fema.gov

Alternate
TBA
FEMA Region 5
536 South Clark Street, 6th Floor
Chicago, IL 60605

Phone: 312-408-
24 hour: 202-898-6100
FAX: 312-408-
Email:

 
General Services Administration

Primary
Ronald E. Rennhack
Director, Business Services Office
5 ADC DPN 37-5
General Services Administration
230 South Dearborn, Room 3718
Chicago, IL 60604

Phone: 312-353-7050
24 hour: 312-353-0735
FAX: 312-886-9893
Email: ron.rennhack@gsa.gov

Alternate
James Czysz
Leader, Business Service Center
General Services Administration
230 S. Dearborn St., Room 3718
Chicago, IL 60604

Phone: 312-886-7590
FAX: 312-886-9893
Email: jim.czysz@gsa.gov

 
Nuclear Regulatory Commission

Primary
Thomas Ploski Emergency Response Coordinator
Nuclear Regulatory Commission, Region 3
801 Warrenville Road
Lisle, IL 60532

Phone: 630-829-9812
FAX: 630-515-1259
24 Hour: 301-816-5100
Email: tjp@nrc.gov

Alternate
Roland Lickus
State Liaison Officer
Nuclear Regulatory Commission, Region 3
801 Warrenville Road
Lisle, IL 60532

Phone: 630-829-9960
FAX: 630-515-1096
24 Hour: 301-816-5100
Email: rml2@nrc.gov

 
Illinois

Primary
James O'Brien, Manager
Office of Chemical Safety (MC#29)
Illinois EPA
1021 South Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276

Phone: 217-785-0830
24 hour: 217-782-7860 (IEMA)
FAX: 217-782-1431
Email: epa8539@epa.state.il.us

Alternate
G. Tod Rowe, Managerv Emergency Response Unit (MC#29)
Illinois EPA
1021 South Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276

Phone: 217-782-3637
Pager: 217-467-2221
24 hour: 217-782-7860 (IEMA)
FAX: 217-782-1431
Email: epa8540@epa.state.il.us

 
Indiana

Primary
Max Michael, Section Chief
Emergency Response
Indiana Dept. of Environmental Mgt.
100 North Senate Avenue
P.O. Box 6015
Indianapolis, IN 46206-6015

Phone: 317-308-3049
24 hour: 317-233-7745
Toll Free In State: 888-233-7745
FAX: 317-308-3063
Email:mmichael@dem.state.in.us

Alternate
David Crose, Director
Technological Hazards Division
IN State Emergency Management Agency
Indiana Government Center South
302 West Washington St., Room E-208
Indianapolis, IN 46204-2760

Phone: 317-232-3837
24 hour: 800-669-7362
FAX: 317-233-5006
Email: dcrose@sema.state.in.us

 
Michigan

Primary
Thor Strong
Emergency Mgt. Coordinator
Low Level Radioactive Waste Authority
Michigan Dept. of Environmental Quality
P.O. Box 30473
Lansing, MI 48909

Phone: 517-335-0430
24 Hour: 800-292-4706
FAX: 517-373-0578
Email: strongt@state.mi.us

Alternate
Paul Blakeslee
Surface Water Quality Division
Field Operations
Michigan Dept. of Environmental Quality
P.O. Box 30028
Lansing, MI 48909

Phone: 517-335-6873
24 hour: 800-292-4706
FAX: 517-373-9958
Email: blakeslp@state.mi.us

Alternate
Mitch Adelman, Chief
Site Management Unit #3
Superfund Section
Emergency Response Division
Michigan Dept. of Environmental Quality
P.O. Box 30426
Lansing, MI 48909

Phone: 517-373-8436
24 hour: 800-292-4706
FAX: 517-335-4887
Email: adelmanm@state.mi.us

 
Minnesota

Primary
Stephen J. Lee, Supervisor
Emergency Response Team
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155

Phone: 651-297-8610
24 hour: 651-649-5451
FAX: 651-297-8321
Email: stephen.lee@pca.state.mn.us
Alternate
Kevin C. Leuer
Director
Minnesota Dept. Of Public Safety
Division of Emergency Management
444 Cedar Street, Suite 223
St. Paul, MN 55101
Phone: 651-296-0450
24 hour: 651-296-2233
FAX: 651-296-0459
Email: kevin.leuer@state.mn.us

 
Ohio

Primary
Tim Hickin, Supervisor
Emergency Response Unit
Ohio Environmental Protection Agency
P.O. Box 1049
Columbus, OH 43216-1049

Phone: 614-644-2080
24 hour: 800-282-9378
FAX: 614-644-3250
NOAA Mail: R5OH
Email: tim.hickin@epa.state.oh.us

Alternate
Kevin Clouse
Emergency Response/Special Investigations Section
Ohio Environmental Protection Agency
P.O. Box 1049
Columbus, OH 43216-1049

Phone: 614-644-2083
24 hour: 800-282-9378
FAX: 614-644-3250
NOAA Mail: R5OH
Email: kevin.clouse@epa.state.oh.us

 
Wisconsin

Primary
David Woodbury
Bureau of Law Enforcement
Wisconsin Dept. of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707-7921

Phone: 608-266-2598
24 hour: 800-943-0003
FAX: 608-266-3696
Email: woodbd@dnr.state.wi.us

Alternate
Mr. Jerry Haberl
Wisconsin Dept. of Emergency Management
Department of Military Affairs
2400 Wright Street
P.O. Box 7865
Madison, Wisconsin 53707

Phone: 608-242-3213
24 Hour: 608-275-8029 (pager)
FAX: 608-242-3248
Email: haberj@dma.state.wi.us

 
Interested Parties

Michael Maddock, B.E.S.
Environment Canada
4905 Dufferin Street
Downsview, Ontario M3H 5T4

Phone: 416-739-5911
Fax: 416-739-4953
Email: michael.maddock@ec.gc.ca

Tom Crane
Great Lakes Commission
400 Fourth Street
Ann Arbor, MI 48103-4816

Phone: 734-665-9135
FAX: 734-665-4370
Email: tcrane@glc.org

Jack Bossert
Ohio Emergency Management Agency
2855 West Dublin-Granville Road
Columbus, OH 43235-2206

Phone: 614-889-7178
24Hour: 614-889-7150
FAX: 614-799-3678
Email: jbossert@dps.state.oh.us

David Fritz
BP/Amoco Corporation
28100 Torch Parkway
Suite 500
Warrenville, IL 60555

Phone: 630-836-5867
FAX: 630-836-5699
Email: defritz@amoco.com

John Gustafson
U.S. EPA/NRT
CEPPO, Mail Code: 5104
401 M Street SW
Washington, DC 20406

Phone: 202-260-3315
FAX: 202-260-0154
Email: gogus@aol.com

Ron Kasparski
Wisconsin Emergency Mgt. Agency
2400 Wright Street
P.O. Box 7865
Madison, WI 53707-7865

Phone: 608-242-3228
FAX: 608-242-3249
Email: kasper@dma.state.wi.us

Jonathan A. McSayles
ORSANCO
5735 Kellogg Ave.
Cincinnati, OH 45240

Phone: 513-231-7719
FAX: 513-231-7761
Email: mcsayles@orsanco.org

Barbara Naramore
Upper Mississippi River Basic Assoc.
415 Hamm Building
408 St. Peter Street
St. Paul, MN 55102

Phone: 612-224-2880
FAX: 612-233-5815
Email: umrba@mr.net

Kenneth A. Schultz
Assistant Manager, DERR
Ohio EPA
Central District Office
3232 Alum Creek Drive
Columbus, Ohio 432073461

Phone: 6147283822
Fax: 6147283898
Email: ken.schultz@epa.state.oh.us

James Watts
Chief of Operations
Illinois Emergency Management Agency
110 East Adams Street
Springfield, IL 62701

Phone: 217-782-6598
24 hour: 217-782-7860
FAX: 217-782-2589
Email: jwatts@pop.state.il.us

 
United States Coast Guard, Ninth District, Marine Safety Offices (MSO's)

MSO Buffalo
Commanding Officer
USCG Marine Safety Office
1 Fuhrman Blvd.
Buffalo, NY 14203

Phone: 716-843-9570
FAX: 716-843-9571

MSO Chicago
Commanding Officer
USCG Marine Safety Office
215 West 83rd St., Ste. D
Burr Ridge, IL 60521

Phone: 630-986-2155
FAX: 630-986-2120

MSO Cleveland
Commanding Officer
USCG Marine Safety Office
1055 East 9th Street
Cleveland, OH 44114

Phone: 216-522-4405
FAX: 216-522-3290

MSO Detroit
Commanding Officer
USCG Marine Safety Office
110 Mt. Elliot Ave.
Detroit, MI 48207

Phone: 313-568-9580
FAX: 313-568-9581

MSO Duluth
Commanding Officer
USCG Marine Safety Office
600 S. Lake Street, Canal Park
Duluth, MN 55802

Phone: 218-720-5286
FAX: 218-720-5258

MSO Milwaukee
Commanding Officer
USCG Marine Safety Office
2420 S. Lincoln Memorial Drive
Milwaukee, WI 53207-1997

Phone: 414-747-7155
FAX: 414-747-7890

MSO/Group Sault Ste. Marie
Commanding Officer
USCG Marine Safety Office
337 Water Street
Sault Ste. Marie, MI 49783-9501

Phone: 906-635-3220
FAX: 906-635-3344

MSO Toledo
Commanding Officer
USCG Marine Safety Office
Federal Building, Room 501
234 Summit Street
Toledo, OH 43604

Phone: 419-259-6372
FAX: 419-259-6374

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APPENDIX IV: WORST-CASE DISCHARGES IN U.S.EPA REGION 5



Unknown Location

Facility Name:
City:
State:
FRP ID#: FRP0500216
Worst Case Discharge: 756000


Illinois

Facility Name: Growmark Petroleum Terminal
City: Albany
State: IL
FRP ID#: FRP0500365
Worst Case Discharge: 6900000

Facility Name: Archer Daniels Midland
City: Alton
State: IL
FRP ID#: FRP05A0077
Worst Case Discharge: 398160

Facility Name: Williams Pipe Line Company
City: Amboy
State: IL
FRP ID#: FRP0500193
Worst Case Discharge: 112266

Facility Name: Gatx
City: Argo
State: IL
FRP ID#: FRP0500323
Worst Case Discharge: 5880000

Facility Name: Shell Oil
City: Arlington Heights
State: IL
FRP ID#: FRP0500239
Worst Case Discharge: 5677980

Facility Name: CITGO Petroleum Corporation
City: Arlington Heights
State: IL
FRP ID#: FRP0500183
Worst Case Discharge: 3655113

Facility Name: Arco
City: Arlington Heights
State: IL
FRP ID#: FRP0500188
Worst Case Discharge: 2310000

Facility Name: Mobil
City: Arlington Heights
State: IL
FRP ID#: FRP0500344
Worst Case Discharge: 2867634

Facility Name: Marathon Oil Company
City: Arlington Heights
State: IL
FRP ID#: FRP0500332
Worst Case Discharge: 2167284

Facility Name: Clark Refining & Marketing, Inc.
City: Bartonville
State: IL
FRP ID#: FRP0500190
Worst Case Discharge: 2310000

Facility Name: Shell Oil
City: Bedford Park
State: IL
FRP ID#: FRP0500232
Worst Case Discharge: 4943400

Facility Name: Apex Oil Company
City: Berwyn
State: IL
FRP ID#: FRP0500357
Worst Case Discharge: 3696000

Facility Name: Amoco Oil Company
City: Berwyn
State: IL
FRP ID#: FRP0500161
Worst Case Discharge: 1540476

Facility Name: Clark Refining & Marketing, Inc.
City: Blue Island
State: IL
FRP ID#: FRP0500189
Worst Case Discharge: 0

Facility Name: Martin Oil Marketing, LTD
City: Blue Island
State: IL
FRP ID#: FRP0500361
Worst Case Discharge: 5460000

Facility Name: BTL Industries
City: Blue Island
State: IL
FRP ID#: FRP0500200
Worst Case Discharge: 850000

Facility Name: Bunge Corporation Ca
City: Cairo
State: IL
FRP ID#: FRP05A0411
Worst Case Discharge: 500500

Facility Name: Marathon Oil Company
City: Champaign
State: IL
FRP ID#: FRP0500331
Worst Case Discharge: 3549000

Facility Name: Exxon Company, USA
City: Channahon
State: IL
FRP ID#: FRP0500360
Worst Case Discharge: 1272306

Facility Name: Canal Barge Company, Inc.
City: Channahon
State: IL
FRP ID#: FRP0500187
Worst Case Discharge: 1617000

Facility Name: Great Lakes Terminal
City: Chicago
State: IL
FRP ID#: FRP05A0439
Worst Case Discharge: 1155000

Facility Name: Cargill, Inc. - Oilseeds Div
City: Chicago
State: IL
FRP ID#: FRP05A0402
Worst Case Discharge: 1500

Facility Name: Apex Motor Fuel Company
City: Chicago
State: IL
FRP ID#: FRP0500170
Worst Case Discharge: 61152

Facility Name: Calumet Lubricants Co.
City: Chicago
State: IL
FRP ID#: FRP05A0438
Worst Case Discharge: 462000

Facility Name: Bell Oil Terminal
City: Chicago
State: IL
FRP ID#: FRP05A0090
Worst Case Discharge: 2289569

Facility Name: Stolt-Nielsen
City: Chicago
State: IL
FRP ID#: FRP0500242
Worst Case Discharge: 99624

Facility Name: J.M. Sweeney Co.
City: Chicago
State: IL
FRP ID#: FRP0500369
Worst Case Discharge: 0

Facility Name: Ameropan Tank Terminal
City: Chicago
State: IL
FRP ID#: FRP05A0089
Worst Case Discharge: 2340110

Facility Name: Lockheed
City: Chicago
State: IL
FRP ID#: FRP0500307
Worst Case Discharge: 73700

Facility Name: Support Terminal Services, Inc.
City: Chillicothe
State: IL
FRP ID#: FRP0500275
Worst Case Discharge: 2310000

Facility Name: Olympic Oil, Limited
City: Cicero
State: IL
FRP ID#: FRP0500325
Worst Case Discharge: 1279502

Facility Name: Koppers Ind., Inc.
City: Cicero
State: IL
FRP ID#: FRP05A0397
Worst Case Discharge: 0

Facility Name: Koch Fuels Company, Inc.
City: Cicero
State: IL
FRP ID#: FRP0500335
Worst Case Discharge: 3386880

Facility Name: CITGO Petroleum Corporation
City: Cicero
State: IL
FRP ID#: FRP0500197
Worst Case Discharge: 462000

Facility Name: Chemical Petroleum Exchange, Inc.
City: Cicero
State: IL
FRP ID#: FRP0500184
Worst Case Discharge: 393750

Facility Name: Mobil
City: Cicero
State: IL
FRP ID#: FRP0500347
Worst Case Discharge: 50400

Facility Name: Amoco Oil Company
City: Creve Coeur
State: IL
FRP ID#: FRP0500146
Worst Case Discharge: 1450000

Facility Name: Lauhoff Grain Company
City: Danville
State: IL
FRP ID#: FRP05A0097
Worst Case Discharge: 5510631

Facility Name: Norfolk Southern
City: Decatur
State: IL
FRP ID#: FRP0500301
Worst Case Discharge: 1527000

Facility Name: Amoco Oil Company
City: Des Plaines
State: IL
FRP ID#: FRP0500145
Worst Case Discharge: 4536000

Facility Name: Union Pacific Railroad Company
City: Dolton
State: IL
FRP ID#: FRP05A0409
Worst Case Discharge: 693000

Facility Name: Hicks Oil and Hicksgas, Inc.
City: East Peoria
State: IL
FRP ID#: FRP0500345
Worst Case Discharge: 2418000

Facility Name: Petroleum Fuel & Terminal Company
City: East Saint Louis
State: IL
FRP ID#: FRP0500353
Worst Case Discharge: 4032000

Facility Name: Phillips Pipe Line Company
City: East Saint Louis
State: IL
FRP ID#: FRP0500337
Worst Case Discharge: 8232000

Facility Name: Shell Oil Company
City: Effingham
State: IL
FRP ID#: FRP0500235
Worst Case Discharge: 630000

Facility Name: People Gas Light & Coke Co.
City: Elwood
State: IL
FRP ID#: FRP05A0016
Worst Case Discharge: 6613992

Facility Name: Stepan Co.
City: Elwood
State: IL
FRP ID#: FRP0500269
Worst Case Discharge: 1800000

Facility Name: Phillips Pipe Line Company
City: Forsyth
State: IL
FRP ID#: FRP0500339
Worst Case Discharge: 3360000

Facility Name: Williams Pipeline
City: Franklin Park
State: IL
FRP ID#: FRP0500192
Worst Case Discharge: 152040

Facility Name: Kelly
City: Freeport
State: IL
FRP ID#: FRP0500303
Worst Case Discharge: 800000

Facility Name: Burlington Northern Railroad
City: Galesburg
State: IL
FRP ID#: FRP0500182
Worst Case Discharge: 2622000

Facility Name: National Steel Corporation
City: Granite City
State: IL
FRP ID#: FRP0500302
Worst Case Discharge: 400000

Facility Name: Apex
City: Granite City
State: IL
FRP ID#: FRP0500005
Worst Case Discharge: 6930000

Facility Name: Naval Training Center
City: Great Lakes
State: IL
FRP ID#: FRP0500324
Worst Case Discharge: 1002810

Facility Name: Shell Oil Products Company
City: Harristown
State: IL
FRP ID#: FRP0500240
Worst Case Discharge: 2079000

Facility Name: Clark Refining and Marketing, Inc.
City: Hartford
State: IL
FRP ID#: FRP0500359
Worst Case Discharge: 8477189

Facility Name: Conoco
City: Hartford
State: IL
FRP ID#: FRP05A0407
Worst Case Discharge: 0

Facility Name: Conoco Lubricants
City: Hartford
State: IL
FRP ID#: FRP05A0095
Worst Case Discharge: 0

Facility Name: Illinois Power
City: Havana
State: IL
FRP ID#: FRP0500336
Worst Case Discharge: 20000

Facility Name: Williams Pipeline - N.E.
City: Heyworth
State: IL
FRP ID#: FRP0500191
Worst Case Discharge: 168000

Facility Name: Illinois Central Rr
City: Homestead
State: IL
FRP ID#: FRP0500322
Worst Case Discharge: 1500000

Facility Name: Van Den Bergh Foods
City: Joliet
State: IL
FRP ID#: FRP0500209
Worst Case Discharge: 25000

Facility Name: Mobil
City: Joliet
State: IL
FRP ID#: FRP0500271
Worst Case Discharge: 33390000

Facility Name: Phillips Pipe Line Company
City: Kankakee
State: IL
FRP ID#: FRP0500338
Worst Case Discharge: 2257122

Facility Name: Essex Specialty Products, Inc.
City: Kankakee
State: IL
FRP ID#: FRP0500363
Worst Case Discharge: 22400

Facility Name: Indian Refining Limited Partnership
City: Lawrenceville
State: IL
FRP ID#: FRP0500305
Worst Case Discharge: 89880000

Facility Name: Heritage Environmental Services, Inc.
City: Lemont
State: IL
FRP ID#: FRP0500366
Worst Case Discharge: 402460

Facility Name: Bodie-Hoover Petroleum Corporation
City: Lemont
State: IL
FRP ID#: FRP0500185
Worst Case Discharge: 61600

Facility Name: Uno-Ven
City: Lemont
State: IL
FRP ID#: FRP0500186
Worst Case Discharge: 12474000

Facility Name: Powell Duffryn Terminals, Inc.
City: Lemont
State: IL
FRP ID#: FRP0500299
Worst Case Discharge: 2442000

Facility Name: Korall Corp.
City: Lemont
State: IL
FRP ID#: FRP0500321
Worst Case Discharge: 5308

Facility Name: Texaco
City: Lockport
State: IL
FRP ID#: FRP0500370
Worst Case Discharge: 1050000

Facility Name: Materials Service Corp - Yd 67
City: Lockport
State: IL
FRP ID#: FRP05A0008
Worst Case Discharge: 40000

Facility Name: Sherex Chemical Company, Inc.
City: Mapleton
State: IL
FRP ID#: FRP0500199
Worst Case Discharge: 4000000

Facility Name: Louis Dreyfus Corp
City: Mapleton
State: IL
FRP ID#: FRP0500306
Worst Case Discharge: 29436

Facility Name: Enviropur, Inc.
City: Mccook
State: IL
FRP ID#: FRP05A0437
Worst Case Discharge: 250000

Facility Name: Cnw
City: Melrose Park
State: IL
FRP ID#: FRP0500220
Worst Case Discharge: 1000000

Facility Name: Central Illinois Public Service Company
City: Meredosia
State: IL
FRP ID#: FRP0500171
Worst Case Discharge: 20000

Facility Name: Meredosia Terminal, Inc.
City: Meredosia
State: IL
FRP ID#: FRP0500362
Worst Case Discharge: 1262976

Facility Name: Unocal Pipeline Company
City: Mokena
State: IL
FRP ID#: FRP0500282
Worst Case Discharge: 2100000

Facility Name: Unocal
City: Mokena
State: IL
FRP ID#: FRP0500137
Worst Case Discharge: 672000

Facility Name: Commonwealth Edison Company
City: Morris
State: IL
FRP ID#: FRP0500342
Worst Case Discharge: 23100000

Facility Name: Uno-Ven
City: Mt Prospect
State: IL
FRP ID#: FRP0500281
Worst Case Discharge: 3359160

Facility Name: General Tire Inc.
City: Mt Vernon
State: IL
FRP ID#: FRP05A0070
Worst Case Discharge: 1000000

Facility Name: La Gloria Oil and Gas Company
City: Norris City
State: IL
FRP ID#: FRP0500364
Worst Case Discharge: 2310000

Facility Name: Pekin Energy Com.
City: Pekin
State: IL
FRP ID#: FRP05A0006
Worst Case Discharge: 1386000

Facility Name: Shell Oil
City: Pekin
State: IL
FRP ID#: FRP0500233
Worst Case Discharge: 2711940

Facility Name: International Paper
City: Peoria
State: IL
FRP ID#: FRP0500304
Worst Case Discharge: 55

Facility Name: S.T. Services
City: Peru
State: IL
FRP ID#: FRP0500276
Worst Case Discharge: 2538000

Facility Name: Williams Pipeline
City: Petersburg
State: IL
FRP ID#: FRP0500194
Worst Case Discharge: 170352

Facility Name: Quincy Soybean Co
City: Quincy
State: IL
FRP ID#: FRP05A0096
Worst Case Discharge: 2211000

Facility Name: Pm Ag Products
City: Riverdale
State: IL
FRP ID#: FRP05A0400
Worst Case Discharge: 1320000

Facility Name: Marathon Oil
City: Robinson
State: IL
FRP ID#: FRP0500139
Worst Case Discharge: 10271268

Facility Name: Marathon
City: Robinson
State: IL
FRP ID#: FRP05A0398
Worst Case Discharge: 642054

Facility Name: Marathon Oil Company
City: Robinson
State: IL
FRP ID#: FRP0500333
Worst Case Discharge: 15288

Facility Name: Amoco Oil Company
City: Rochelle
State: IL
FRP ID#: FRP0500147
Worst Case Discharge: 1323000

Facility Name: Clark Refining & Marketing, Inc.
City: Rockford
State: IL
FRP ID#: FRP0500330
Worst Case Discharge: 1470000

Facility Name: Marathon Oil Company
City: Rockford
State: IL
FRP ID#: FRP0500355
Worst Case Discharge: 3705450

Facility Name: Rock Valley Oil & Chemical Co.
City: Rockford
State: IL
FRP ID#: FRP05A0434
Worst Case Discharge: 19000

Facility Name: Shell Oil Company
City: Roxana
State: IL
FRP ID#: FRP0500283
Worst Case Discharge: 12229224

Facility Name: Southern States Asphalt
City: Saint Elmo
State: IL
FRP ID#: FRP0500198
Worst Case Discharge: 1984891

Facility Name: Mobil
City: Sauget
State: IL
FRP ID#: FRP0500343
Worst Case Discharge: 54978000

Facility Name: Owens-Corning Trumbull Asphalt
City: Summit Argo
State: IL
FRP ID#: FRP0500300
Worst Case Discharge: 411600

Facility Name: Emulsicoat, Inc.
City: Urbana
State: IL
FRP ID#: FRP05A0426
Worst Case Discharge: 1015000

Facility Name: Utica Terminal
City: Utica
State: IL
FRP ID#: FRP05A0401
Worst Case Discharge: 4370018

Facility Name: Union Electric
City: Venice
State: IL
FRP ID#: FRP05A0092
Worst Case Discharge: 2767441

Facility Name: Unocal
City: Vernon
State: IL
FRP ID#: FRP0500179
Worst Case Discharge: 1512000

Facility Name: Marathon Oil Company
City: Willow Springs
State: IL
FRP ID#: FRP0500354
Worst Case Discharge: 3224928

Facility Name: Ashland Petroleum Company
City: Willow Springs
State: IL
FRP ID#: FRP0500195
Worst Case Discharge: 2499966

Facility Name: Amoco
City: Wood River
State: IL
FRP ID#: FRP0500144
Worst Case Discharge: 2541651

Facility Name: Amoco Petroleum Products
City: Wood River
State: IL
FRP ID#: FRP0500156
Worst Case Discharge: 31122000

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Indiana

Facility Name: Amoco Oil Company
City: Brookston
State: IN
FRP ID#: FRP0500149
Worst Case Discharge: 756000

Facility Name: Ashland Petroleum Company
City: Clarksville
State: IN
FRP ID#: FRP0500340
Worst Case Discharge: 79254

Facility Name: Phillips Pipe Line Company
City: Clermont
State: IN
FRP ID#: FRP0500049
Worst Case Discharge: 0

Facility Name: Crown
City: Clermont
State: IN
FRP ID#: FRP0500265
Worst Case Discharge: 3074194

Facility Name: Inland Steel/Indiana Harbor Works
City: East Chicago
State: IN
FRP ID#: FRP05A0403
Worst Case Discharge: 1505960

Facility Name: CITGO Petroleum Corporation
City: East Chicago
State: IN
FRP ID#: FRP0500181
Worst Case Discharge: 6172274

Facility Name: Mobil Oil Corporation
City: East Chicago
State: IN
FRP ID#: FRP0500346
Worst Case Discharge: 4747260

Facility Name: LTV Steel Company
City: East Chicago
State: IN
FRP ID#: FRP0500031
Worst Case Discharge: 7100

Facility Name: Phillips Pipe Line Company
City: East Chicago
State: IN
FRP ID#: FRP0500048
Worst Case Discharge: 11004000

Facility Name: Safety-Kleen Oil Recovery Company
City: East Chicago
State: IN
FRP ID#: FRP0500050
Worst Case Discharge: 2693502

Facility Name: Consolidated Railroad Corporation
City: Elkhart
State: IN
FRP ID#: FRP0500259
Worst Case Discharge: 0

Facility Name: Ashland Petroleum Company
City: Evansville
State: IN
FRP ID#: FRP0500154
Worst Case Discharge: 1108800

Facility Name: Itapco
City: Evansville
State: IN
FRP ID#: FRP0500027
Worst Case Discharge: 1386000

Facility Name: Gladieux Refinery, Inc.
City: Fort Wayne
State: IN
FRP ID#: FRP05A0415
Worst Case Discharge: 3147210

Facility Name: Norfolk Southern
City: Frankfort
State: IN
FRP ID#: FRP0500046
Worst Case Discharge: 500000

Facility Name: U.S. Steel
City: Gary
State: IN
FRP ID#: FRP0500168
Worst Case Discharge: 4590600

Facility Name: Amoco Petroleum Products
City: Granger
State: IN
FRP ID#: FRP0500196
Worst Case Discharge: 2782000

Facility Name: Wolf Lake Terminals, Inc.
City: Hammond
State: IN
FRP ID#: FRP05A0011
Worst Case Discharge: 420000

Facility Name: Mobil Oil Corporation
City: Hammond
State: IN
FRP ID#: FRP0500043
Worst Case Discharge: 615384

Facility Name: Marathon Oil Company
City: Hammond
State: IN
FRP ID#: FRP0500034
Worst Case Discharge: 9517200

Facility Name: Clark Refining & Marketing, Inc.
City: Hammond
State: IN
FRP ID#: FRP0500327
Worst Case Discharge: 28980000

Facility Name: Ihb Railroad
City: Hammond
State: IN
FRP ID#: FRP0500221
Worst Case Discharge: 1000000

Facility Name: CITGO Petroleum Corporation
City: Huntington
State: IN
FRP ID#: FRP0500162
Worst Case Discharge: 2959850

Facility Name: Ashland Petroleum Company
City: Huntington
State: IN
FRP ID#: FRP0500148
Worst Case Discharge: 1799532

Facility Name: Gladieux Trading & Marketing Co., L.P.
City: Huntington
State: IN
FRP ID#: FRP05A0416
Worst Case Discharge: 2512840

Facility Name: Sun Co.
City: Huntington
State: IN
FRP ID#: FRP0500059
Worst Case Discharge: 1617000

Facility Name: Marathon Oil Company
City: Indianapolis
State: IN
FRP ID#: FRP0500035
Worst Case Discharge: 0

Facility Name: Allison Engine Comany Plant 5
City: Indianapolis
State: IN
FRP ID#: FRP05A0421
Worst Case Discharge: 0

Facility Name: Marathon Oil Company
City: Indianapolis
State: IN
FRP ID#: FRP0500041
Worst Case Discharge: 3525199

Facility Name: General Motors
City: Indianapolis
State: IN
FRP ID#: FRP05A0422
Worst Case Discharge: 0

Facility Name: Indianapolis Power and Light Company
City: Indianapolis
State: IN
FRP ID#: FRP0500025
Worst Case Discharge: 3720000

Facility Name: Clark Refining and Marketing, Inc.
City: Indianapolis
State: IN
FRP ID#: FRP0500341
Worst Case Discharge: 6720000

Facility Name: Asphalt Materials
City: Indianapolis
State: IN
FRP ID#: FRP05A0425
Worst Case Discharge: 4092993

Facility Name: Shell Oil
City: Indianapolis
State: IN
FRP ID#: FRP0500057
Worst Case Discharge: 5052000

Facility Name: Amoco Oil Company
City: Indianapolis
State: IN
FRP ID#: FRP0500155
Worst Case Discharge: 1470000

Facility Name: Sun Company, Inc.
City: Indianapolis
State: IN
FRP ID#: FRP0500058
Worst Case Discharge: 2541000

Facility Name: Central Soya Co.
City: Indianapolis
State: IN
FRP ID#: FRP05A0419
Worst Case Discharge: 428000

Facility Name: Allison Engine Company
City: Indianapolis
State: IN
FRP ID#: FRP05A0418
Worst Case Discharge: 0

Facility Name: S.T. Services
City: Indianapolis
State: IN
FRP ID#: FRP0500274
Worst Case Discharge: 1687900

Facility Name: Ashland Petroleum Company
City: Indianapolis
State: IN
FRP ID#: FRP0500150
Worst Case Discharge: 1108800

Facility Name: Center Terminal Co.
City: Indianapolis
State: IN
FRP ID#: FRP0500093
Worst Case Discharge: 2310000

Facility Name: Colgate Palmolive
City: Jeffersonville
State: IN
FRP ID#: FRP05A0017
Worst Case Discharge: 368500

Facility Name: Chrylser Corp. Kokomo Complex
City: Kokomo
State: IN
FRP ID#: FRP05A0111
Worst Case Discharge: 320000

Facility Name: Cargill Soybean Proc
City: Lafayette
State: IN
FRP ID#: FRP05A0069
Worst Case Discharge: 900000

Facility Name: Laketon Refining Corporation
City: Laketon
State: IN
FRP ID#: FRP0500030
Worst Case Discharge: 4520000

Facility Name: Indiana Michigan Power
City: Lawrenceburg
State: IN
FRP ID#: FRP0500024
Worst Case Discharge: 128000

Facility Name: American Western Refining, Ltd Prtnrshp
City: Mount Vernon
State: IN
FRP ID#: FRP0500293
Worst Case Discharge: 3360000

Facility Name: Marathon Oil Company
City: Mount Vernon
State: IN
FRP ID#: FRP0500038
Worst Case Discharge: 6300000

Facility Name: Countrymark
City: Mt Vernon
State: IN
FRP ID#: FRP0500349
Worst Case Discharge: 5040000

Facility Name: Countrymark
City: Mt Vernon
State: IN
FRP ID#: FRP0500352
Worst Case Discharge: 80640

Facility Name: Shell Oil
City: Muncie
State: IN
FRP ID#: FRP0500055
Worst Case Discharge: 5082000

Facility Name: Itapco
City: New Albany
State: IN
FRP ID#: FRP0500028
Worst Case Discharge: 1155000

Facility Name: Alcoa
City: Newburgh
State: IN
FRP ID#: FRP05A0235
Worst Case Discharge: 6600000

Facility Name: Indianapolis Power & Lt
City: Petersburg
State: IN
FRP ID#: FRP0500026
Worst Case Discharge: 720000

Facility Name: Conrail
City: Plainfield
State: IN
FRP ID#: FRP0500255
Worst Case Discharge: 1000000

Facility Name: Tanco Terminals, Inc.
City: Portage
State: IN
FRP ID#: FRP0500061
Worst Case Discharge: 2730000

Facility Name: Indiana Michigan Power Company
City: Rockport
State: IN
FRP ID#: FRP0500023
Worst Case Discharge: 2200000

Facility Name: Lakehead Pipe Line Company
City: Schererville
State: IN
FRP ID#: FRP05A0088
Worst Case Discharge: 4200000

Facility Name: La Gloria Oil and Gas Company
City: Seymour
State: IN
FRP ID#: FRP0500169
Worst Case Discharge: 462000

Facility Name: Koch Materials
City: Warsaw
State: IN
FRP ID#: FRP0500167
Worst Case Discharge: 500000

Facility Name: Nipsco
City: Wheatfield
State: IN
FRP ID#: FRP05A0086
Worst Case Discharge: 10500000

Facility Name: Amoco Petroleum Products
City: Whiting
State: IN
FRP ID#: FRP0500180
Worst Case Discharge: 23418780

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Michigan

Facility Name: Total Petroleum, Inc., Alma Refinery
City: Alma
State: MI
FRP ID#: FRP0500065
Worst Case Discharge: 5460546

Facility Name: Amoco Oil Company
City: Bay City
State: MI
FRP ID#: FRP0500003
Worst Case Discharge: 43400

Facility Name: Koch Materials
City: Bay City
State: MI
FRP ID#: FRP0500022
Worst Case Discharge: 13403000

Facility Name: Total Petroleum, Inc.
City: Bay City
State: MI
FRP ID#: FRP05A0003
Worst Case Discharge: 4083450

Facility Name: The Uno-Ven Company
City: Bay City
State: MI
FRP ID#: FRP0500067
Worst Case Discharge: 2320080

Facility Name: Amoco
City: Cheboygan
State: MI
FRP ID#: FRP05A0395
Worst Case Discharge: 1986600

Facility Name: Waterfront Petroleum
City: Dearborn
State: MI
FRP ID#: FRP05A0098
Worst Case Discharge: 0

Facility Name: Nw Dtw Fuel Facility
City: Detroit
State: MI
FRP ID#: FRP05A0087
Worst Case Discharge: 880000

Facility Name: General Motors
City: Detroit
State: MI
FRP ID#: FRP05A0420
Worst Case Discharge: 0

Facility Name: Edwards Oil Service
City: Detroit
State: MI
FRP ID#: FRP05A0109
Worst Case Discharge: 1700000

Facility Name: Sun Co.
City: Detroit
State: MI
FRP ID#: FRP0500063
Worst Case Discharge: 1386000

Facility Name: Shell Oil Company
City: Detroit
State: MI
FRP ID#: FRP0500020
Worst Case Discharge: 5313000

Facility Name: Owens-Corning
City: Detroit
State: MI
FRP ID#: FRP0500047
Worst Case Discharge: 33310

Facility Name: Allied Signal
City: Detroit
State: MI
FRP ID#: FRP0500001
Worst Case Discharge: 1000000

Facility Name: Marathon Oil
City: Detroit
State: MI
FRP ID#: FRP0500037
Worst Case Discharge: 10025400

Facility Name: Detroit Edison Company
City: East China
State: MI
FRP ID#: FRP0500019
Worst Case Discharge: 6283200

Facility Name: National Steel Corporation
City: Ecorse
State: MI
FRP ID#: FRP0500045
Worst Case Discharge: 2555000

Facility Name: Koch Materials
City: Elberta
State: MI
FRP ID#: FRP0500029
Worst Case Discharge: 4389000

Facility Name: Mead Publishing Paper Div.
City: Escanaba
State: MI
FRP ID#: FRP05A0432
Worst Case Discharge: 1000000

Facility Name: Consumer Power Co., D E Karn 3 & 4 Plant
City: Essexville
State: MI
FRP ID#: FRP0500011
Worst Case Discharge: 518400

Facility Name: Shell Oil
City: Ferrysburg
State: MI
FRP ID#: FRP0500178
Worst Case Discharge: 806400

Facility Name: CITGO Petroleum Corporation
City: Ferrysburg
State: MI
FRP ID#: FRP0500013
Worst Case Discharge: 2086207

Facility Name: Lockhart Chemical Company
City: Flint
State: MI
FRP ID#: FRP05A0408
Worst Case Discharge: 1800000

Facility Name: Mobil Oil Corporation
City: Flint
State: MI
FRP ID#: FRP0500042
Worst Case Discharge: 2500000

Facility Name: General Motors
City: Flint
State: MI
FRP ID#: FRP05A0001
Worst Case Discharge: 5000

Facility Name: Construction Resource
City: Gladstone
State: MI
FRP ID#: FRP05A0116
Worst Case Discharge: 2340300

Facility Name: Dod
City: Gladstone
State: MI
FRP ID#: FRP0500070
Worst Case Discharge: 3360000

Facility Name: Shell Oil Company
City: Grand Haven
State: MI
FRP ID#: FRP0500053
Worst Case Discharge: 3774540

Facility Name: Natl Park Service
City: Houghton
State: MI
FRP ID#: FRP05A0406
Worst Case Discharge: 0

Facility Name: CITGO Petroleum Corporation
City: Jackson
State: MI
FRP ID#: FRP0500014
Worst Case Discharge: 2494800

Facility Name: Shell Oil Company
City: Jackson
State: MI
FRP ID#: FRP0500054
Worst Case Discharge: 1386000

Facility Name: K I Sawyer Afb
City: K I Sawyer Afb
State: MI
FRP ID#: FRP05A0066
Worst Case Discharge: 1602383

Facility Name: Total Petroleum, Inc., Lansing Terminal
City: Lansing
State: MI
FRP ID#: FRP0500032
Worst Case Discharge: 1073604

Facility Name: General Motors
City: Livonia
State: MI
FRP ID#: FRP05A0417
Worst Case Discharge: 0

Facility Name: Dow Chemical
City: Ludington
State: MI
FRP ID#: FRP0500021
Worst Case Discharge: 0

Facility Name: Marathon Oil
City: Mackinaw City
State: MI
FRP ID#: FRP0500036
Worst Case Discharge: 1562400

Facility Name: Clark Oil
City: Marshall
State: MI
FRP ID#: FRP0500012
Worst Case Discharge: 3360000

Facility Name: Detroit Edison Company
City: Marysville
State: MI
FRP ID#: FRP0500017
Worst Case Discharge: 18700000

Facility Name: General Motors
City: Michigan
State: MI
FRP ID#: FRP05A0412
Worst Case Discharge: 0

Facility Name: Thompson-McCully Oil Company
City: Monroe
State: MI
FRP ID#: FRP0500064
Worst Case Discharge: 88750

Facility Name: Marathon Oil
City: Mt. Morris
State: MI
FRP ID#: FRP0500033
Worst Case Discharge: 2322054

Facility Name: Amoco Oil Company
City: Napoleon
State: MI
FRP ID#: FRP0500004
Worst Case Discharge: 201600

Facility Name: Detroit Edison Company
City: Newport
State: MI
FRP ID#: FRP0500016
Worst Case Discharge: 900000

Facility Name: Shell Oil
City: Niles
State: MI
FRP ID#: FRP0500177
Worst Case Discharge: 420000

Facility Name: Shell Oil Company
City: Niles
State: MI
FRP ID#: FRP0500056
Worst Case Discharge: 3548160

Facility Name: Marathon Oil
City: Niles
State: MI
FRP ID#: FRP0500039
Worst Case Discharge: 4023936

Facility Name: CITGO Petroleum Corporation
City: Niles
State: MI
FRP ID#: FRP0500015
Worst Case Discharge: 5275809

Facility Name: Marathon Oil
City: North Muskegon
State: MI
FRP ID#: FRP0500040
Worst Case Discharge: 3423000

Facility Name: Delta Fuels Of Michigan
City: Novi
State: MI
FRP ID#: FRP05A0435
Worst Case Discharge: 2756922

Facility Name: Sun Co.
City: Owosso
State: MI
FRP ID#: FRP0500060
Worst Case Discharge: 1848000

Facility Name: James River Paper Corp.
City: Parchment
State: MI
FRP ID#: FRP05A0423
Worst Case Discharge: 1100000

Facility Name: General Motors
City: Pontiac
State: MI
FRP ID#: FRP05A0410
Worst Case Discharge: 0

Facility Name: Detroit Edison
City: River Rouge
State: MI
FRP ID#: FRP0500018
Worst Case Discharge: 5775000

Facility Name: Amoco
City: River Rouge
State: MI
FRP ID#: FRP05A0396
Worst Case Discharge: 1663536

Facility Name: Texaco
City: River Rouge
State: MI
FRP ID#: FRP0500062
Worst Case Discharge: 2000000

Facility Name: Usher Oil Company
City: River Rouge
State: MI
FRP ID#: FRP0500211
Worst Case Discharge: 6000000

Facility Name: Total Petroleum, Inc., Romulus Terminal
City: Romulus
State: MI
FRP ID#: FRP0500066
Worst Case Discharge: 2449860

Facility Name: Shell Oil Company
City: Romulus
State: MI
FRP ID#: FRP0500052
Worst Case Discharge: 3095400

Facility Name: Uno-Ven
City: Romulus
State: MI
FRP ID#: FRP0500068
Worst Case Discharge: 5055582

Facility Name: General Motors
City: Saginaw
State: MI
FRP ID#: FRP05A0413
Worst Case Discharge: 0

Facility Name: BP Oil Company
City: Taylor
State: MI
FRP ID#: FRP0500009
Worst Case Discharge: 2259600

Facility Name: Ashland Petroleum Company
City: Taylor
State: MI
FRP ID#: FRP0500007
Worst Case Discharge: 3401290

Facility Name: Clark Oil
City: Taylor
State: MI
FRP ID#: FRP0500010
Worst Case Discharge: 3150000

Facility Name: Koch Refining Co
City: Taylor
State: MI
FRP ID#: FRP05A0103
Worst Case Discharge: 5027000

Facility Name: Amoco Oil Company
City: Taylor
State: MI
FRP ID#: FRP0500002
Worst Case Discharge: 333900

Facility Name: TOTAL Petroleum, Inc.
City: Traverse City
State: MI
FRP ID#: FRP05A0002
Worst Case Discharge: 2283666

Facility Name: Detroit Edison
City: Trenton
State: MI
FRP ID#: FRP05A0073
Worst Case Discharge: 864024

Facility Name: Mobil Oil Corporation
City: Woodhaven
State: MI
FRP ID#: FRP0500044
Worst Case Discharge: 156821

Facility Name: Gm Powertrain
City: Ypsilanti
State: MI
FRP ID#: FRP05A0110
Worst Case Discharge: 1645250

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Minnesota

Facility Name: Williams Pipeline
City: Alexandria
State: MN
FRP ID#: FRP0500073
Worst Case Discharge: 110040

Facility Name: Northern States Power Company
City: Becker
State: MN
FRP ID#: FRP0500158
Worst Case Discharge: 1000000

Facility Name: Bongards Creameries
City: Bongards
State: MN
FRP ID#: FRP05A0079
Worst Case Discharge: 2418600

Facility Name: Murphy Oil
City: Crookston
State: MN
FRP ID#: FRP05A0074
Worst Case Discharge: 4200000

Facility Name: United Power
City: Elk River
State: MN
FRP ID#: FRP0500165
Worst Case Discharge: 924000

Facility Name: Murphy Oil USA, Inc.
City: Esko
State: MN
FRP ID#: FRP0500159
Worst Case Discharge: 2268000

Facility Name: Eveleth Mines
City: Eveleth
State: MN
FRP ID#: FRP05A0405
Worst Case Discharge: 1193975

Facility Name: Williams Pipeline
City: Eyota
State: MN
FRP ID#: FRP0500077
Worst Case Discharge: 84210

Facility Name: Farmers Union Central Exchange Oil Blend
City: Inver Grove Heights
State: MN
FRP ID#: FRP0500089
Worst Case Discharge: 237625

Facility Name: Northern States Power Company
City: Inver Grove Heights
State: MN
FRP ID#: FRP0500157
Worst Case Discharge: 10000000

Facility Name: Honeymead Products Co.
City: Mankato
State: MN
FRP ID#: FRP05A0100
Worst Case Discharge: 4629000

Facility Name: Northern States Power Company
City: Mankato
State: MN
FRP ID#: FRP0500160
Worst Case Discharge: 1000000

Facility Name: Williams Pipeline
City: Mankato
State: MN
FRP ID#: FRP0500074
Worst Case Discharge: 85050

Facility Name: Williams Pipeline
City: Marshall
State: MN
FRP ID#: FRP0500075
Worst Case Discharge: 63210

Facility Name: Koch Materials
City: Marshall
State: MN
FRP ID#: FRP0500096
Worst Case Discharge: 36000

Facility Name: Burlington Northern Railroad
City: Minneapolis
State: MN
FRP ID#: FRP05A0399
Worst Case Discharge: 2000000

Facility Name: Koch Materials Company
City: Minneapolis
State: MN
FRP ID#: FRP0500095
Worst Case Discharge: 446754

Facility Name: Reichhold Chemicals
City: Minneapolis
State: MN
FRP ID#: FRP0500163
Worst Case Discharge: 230883

Facility Name: Amoco Oil Company
City: Moorhead
State: MN
FRP ID#: FRP0500078
Worst Case Discharge: 1892100

Facility Name: United States Steel
City: Mt. Iron
State: MN
FRP ID#: FRP0500071
Worst Case Discharge: 1512795

Facility Name: Newport Terminal Corp.
City: Newport
State: MN
FRP ID#: FRP0500087
Worst Case Discharge: 31500

Facility Name: Barton Enterprises, Inc.
City: Newport
State: MN
FRP ID#: FRP0500051
Worst Case Discharge: 20000

Facility Name: Archer Daniels Midland
City: Red Wing
State: MN
FRP ID#: FRP05A0082
Worst Case Discharge: 2051282

Facility Name: Amoco Oil Company
City: Roseville
State: MN
FRP ID#: FRP0500081
Worst Case Discharge: 1974000

Facility Name: Westway Trading Corporation
City: Saint Paul
State: MN
FRP ID#: FRP0500072
Worst Case Discharge: 848400

Facility Name: 3M Center
City: Saint Paul
State: MN
FRP ID#: FRP0500174
Worst Case Discharge: 285000

Facility Name: Koch Materials Company
City: Saint Paul
State: MN
FRP ID#: FRP0500097
Worst Case Discharge: 243894

Facility Name: Amoco Oil Company
City: Sauk Centre
State: MN
FRP ID#: FRP0500079
Worst Case Discharge: 674100

Facility Name: Richards Asphalt Company
City: Savage
State: MN
FRP ID#: FRP0500164
Worst Case Discharge: 1000000

Facility Name: Nsp
City: Shakopee
State: MN
FRP ID#: FRP0500153
Worst Case Discharge: 2500000

Facility Name: Interstate Power Company
City: Sherburn
State: MN
FRP ID#: FRP0500092
Worst Case Discharge: 2585000

Facility Name: Koch Fuels
City: Silver Bay
State: MN
FRP ID#: FRP0500094
Worst Case Discharge: 14322

Facility Name: Amoco Oil Company
City: Spring Valley
State: MN
FRP ID#: FRP0500080
Worst Case Discharge: 1281000

Facility Name: St Paul Metro Wastewater Treatment Plant
City: St Paul
State: MN
FRP ID#: FRP0500212
Worst Case Discharge: 440000

Facility Name: Koch Refining
City: St Paul
State: MN
FRP ID#: FRP0500172
Worst Case Discharge: 1167600

Facility Name: Koch Refining
City: St Paul
State: MN
FRP ID#: FRP0500173
Worst Case Discharge: 21168000

Facility Name: 3m
City: St Paul
State: MN
FRP ID#: FRP0500175
Worst Case Discharge: 225625

Facility Name: Hawkins Chemical
City: St Paul
State: MN
FRP ID#: FRP0500372
Worst Case Discharge: 0

Facility Name: Hawkins Chemical
City: St Paul
State: MN
FRP ID#: FRP0500373
Worst Case Discharge: 0

Facility Name: Ford
City: St. Paul
State: MN
FRP ID#: FRP05A0078
Worst Case Discharge: 550000

Facility Name: Uno-Ven
City: St. Paul
State: MN
FRP ID#: FRP0500069
Worst Case Discharge: 5772820

Facility Name: Minneapolis
City: St. Paul
State: MN
FRP ID#: FRP05A0102
Worst Case Discharge: 2270000

Facility Name: Westway Terminal Company
City: St. Paul
State: MN
FRP ID#: FRP05A0099
Worst Case Discharge: 1500000

Facility Name: Williams Pipeline
City: St. Paul
State: MN
FRP ID#: FRP0500076
Worst Case Discharge: 170520

Facility Name: Ashland
City: St. Paul Park
State: MN
FRP ID#: FRP0500082
Worst Case Discharge: 220000

Facility Name: Koch Fuels
City: Taconite Harbor
State: MN
FRP ID#: FRP0500142
Worst Case Discharge: 372288

Facility Name: Koch Fuels
City: Two Harbors
State: MN
FRP ID#: FRP0500143
Worst Case Discharge: 46200

Facility Name: Conoco Inc.
City: Wrenshall
State: MN
FRP ID#: FRP0500254
Worst Case Discharge: 4200000

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Ohio

Facility Name: Monsanto Port Plastics Facility
City: Addyston
State: OH
FRP ID#: FRP0500106
Worst Case Discharge: 1000000

Facility Name: Sun Co.
City: Akron
State: OH
FRP ID#: FRP0500113
Worst Case Discharge: 1386000

Facility Name: Uno-Ven
City: Amlin
State: OH
FRP ID#: FRP0500127
Worst Case Discharge: 6639486

Facility Name: Conrail
City: Ashtabula
State: OH
FRP ID#: FRP0500256
Worst Case Discharge: 1000000

Facility Name: Cleveland Electric
City: Ashtabula
State: OH
FRP ID#: FRP0500260
Worst Case Discharge: 34200

Facility Name: Amoco Oil Company
City: Aurora
State: OH
FRP ID#: FRP0500201
Worst Case Discharge: 1241190

Facility Name: Aurora Terminal & Transportation, Inc.
City: Aurora
State: OH
FRP ID#: FRP0500287
Worst Case Discharge: 2100000

Facility Name: Cleveland Electric
City: Avon Lake
State: OH
FRP ID#: FRP0500261
Worst Case Discharge: 3300500

Facility Name: Norfolk Southern
City: Bellevue
State: OH
FRP ID#: FRP0500290
Worst Case Discharge: 0

Facility Name: Degussa Corp.
City: Belpre
State: OH
FRP ID#: FRP0500268
Worst Case Discharge: 3150000

Facility Name: Shell Chemical Company
City: Belpre
State: OH
FRP ID#: FRP0500245
Worst Case Discharge: 1100000

Facility Name: Ohio Power Company
City: Beverly
State: OH
FRP ID#: FRP0500111
Worst Case Discharge: 1000000

Facility Name: Clark Oil
City: Brecksville
State: OH
FRP ID#: FRP0500279
Worst Case Discharge: 3244542

Facility Name: Marathon Oil
City: Brecksville
State: OH
FRP ID#: FRP0500102
Worst Case Discharge: 4032000

Facility Name: Cardinal Operating Company
City: Brilliant
State: OH
FRP ID#: FRP0500296
Worst Case Discharge: 840000

Facility Name: Coz Terminaling, Inc.
City: Bryan
State: OH
FRP ID#: FRP05A0101
Worst Case Discharge: 840000

Facility Name: Ashland Petroleum Company
City: Canton
State: OH
FRP ID#: FRP0500205
Worst Case Discharge: 14208390

Facility Name: BP Oil Company
City: Canton
State: OH
FRP ID#: FRP0500226
Worst Case Discharge: 999600

Facility Name: Ohio Power Company
City: Cheshire
State: OH
FRP ID#: FRP0500110
Worst Case Discharge: 4400000

Facility Name: Department of Defense
City: Cincinnati
State: OH
FRP ID#: FRP0500266
Worst Case Discharge: 700000

Facility Name: Southside River Rail Corp.
City: Cincinnati
State: OH
FRP ID#: FRP0500250
Worst Case Discharge: 70

Facility Name: Queen City Terminals
City: Cincinnati
State: OH
FRP ID#: FRP0500270
Worst Case Discharge: 1800000

Facility Name: Shell Oil
City: Cincinnati
State: OH
FRP ID#: FRP0500251
Worst Case Discharge: 1663200

Facility Name: Ashland Petroleum Company
City: Cincinnati
State: OH
FRP ID#: FRP0500203
Worst Case Discharge: 3819816

Facility Name: Emery Group
City: Cincinnati
State: OH
FRP ID#: FRP0500085
Worst Case Discharge: 635000

Facility Name: Uno-Ven
City: Cincinnati
State: OH
FRP ID#: FRP0500123
Worst Case Discharge: 1369137

Facility Name: Ashland Petroleum Company
City: Cincinnati
State: OH
FRP ID#: FRP0500131
Worst Case Discharge: 2436000

Facility Name: BP Oil Company
City: Cincinnati
State: OH
FRP ID#: FRP0500218
Worst Case Discharge: 840000

Facility Name: Boswell Oil
City: Cincinnati
State: OH
FRP ID#: FRP0500223
Worst Case Discharge: 2224973

Facility Name: Shell Oil
City: Cleveland
State: OH
FRP ID#: FRP0500252
Worst Case Discharge: 1492260

Facility Name: Sun Co. Cleveland Intnl. Airport
City: Cleveland
State: OH
FRP ID#: FRP05A0115
Worst Case Discharge: 234300

Facility Name: Reilly Industries
City: Cleveland
State: OH
FRP ID#: FRP05A0084
Worst Case Discharge: 100000

Facility Name: LTV Steel
City: Cleveland
State: OH
FRP ID#: FRP0500100
Worst Case Discharge: 10100000

Facility Name: Cleveland Electric
City: Cleveland
State: OH
FRP ID#: FRP0500263
Worst Case Discharge: 5500000

Facility Name: Marathon Oil
City: Cleveland
State: OH
FRP ID#: FRP0500103
Worst Case Discharge: 2402022

Facility Name: Fleet Supplies, Inc.
City: Cleveland
State: OH
FRP ID#: FRP0500088
Worst Case Discharge: 4400000

Facility Name: BP Oil Company
City: Cleveland
State: OH
FRP ID#: FRP0500229
Worst Case Discharge: 1718640

Facility Name: Sun Co.
City: Cleveland
State: OH
FRP ID#: FRP0500114
Worst Case Discharge: 1857240

Facility Name: Uno-Ven
City: Cleveland
State: OH
FRP ID#: FRP0500122
Worst Case Discharge: 4645074

Facility Name: Mobil
City: Cleveland
State: OH
FRP ID#: FRP0500104
Worst Case Discharge: 453200

Facility Name: Ashland
City: Columbus
State: OH
FRP ID#: FRP0500151
Worst Case Discharge: 2173626

Facility Name: BP Oil Company
City: Columbus
State: OH
FRP ID#: FRP0500217
Worst Case Discharge: 2011800

Facility Name: Ashland Petroleum Company
City: Columbus
State: OH
FRP ID#: FRP0500204
Worst Case Discharge: 585677

Facility Name: Sun Company, Inc.
City: Columbus
State: OH
FRP ID#: FRP0500115
Worst Case Discharge: 924000

Facility Name: Shell Oil Company
City: Columbus
State: OH
FRP ID#: FRP0500213
Worst Case Discharge: 2457840

Facility Name: Clark Oil
City: Columbus
State: OH
FRP ID#: FRP0500280
Worst Case Discharge: 3263862

Facility Name: Abitec Corporation
City: Columbus
State: OH
FRP ID#: FRP05A0105
Worst Case Discharge: 272000

Facility Name: Eott
City: Columbus
State: OH
FRP ID#: FRP0500086
Worst Case Discharge: 2200000

Facility Name: Marathon Oil
City: Columbus
State: OH
FRP ID#: FRP0500297
Worst Case Discharge: 3575250

Facility Name: CFI Gulf Oil
City: Columbus
State: OH
FRP ID#: FRP05A0430
Worst Case Discharge: 0

Facility Name: Rickenbacker Airport
City: Columbus
State: OH
FRP ID#: FRP0500286
Worst Case Discharge: 50000

Facility Name: Conrail
City: Columbus
State: OH
FRP ID#: FRP0500258
Worst Case Discharge: 1000000

Facility Name: Certified Oil Company
City: Columbus
State: OH
FRP ID#: FRP0500264
Worst Case Discharge: 2310000

Facility Name: Columbus Southern
City: Conesville
State: OH
FRP ID#: FRP0500278
Worst Case Discharge: 35641

Facility Name: Sun Company, Inc.
City: Dayton
State: OH
FRP ID#: FRP0500116
Worst Case Discharge: 2079000

Facility Name: Shell Oil Company
City: Dayton
State: OH
FRP ID#: FRP0500241
Worst Case Discharge: 2462460

Facility Name: BP Oil Company
City: Dayton
State: OH
FRP ID#: FRP0500215
Worst Case Discharge: 2948400

Facility Name: Uno-Ven
City: Dayton
State: OH
FRP ID#: FRP0500124
Worst Case Discharge: 2421888

Facility Name: Itapco
City: East Liverpool
State: OH
FRP ID#: FRP0500292
Worst Case Discharge: 693000

Facility Name: Hays Oil Co.
City: East Liverpool
State: OH
FRP ID#: FRP0500367
Worst Case Discharge: 30000

Facility Name: Ashland
City: Findlay
State: OH
FRP ID#: FRP0500152
Worst Case Discharge: 2696232

Facility Name: BP Oil Company
City: Grafton
State: OH
FRP ID#: FRP0500228
Worst Case Discharge: 1615740

Facility Name: International Paper
City: Hamilton
State: OH
FRP ID#: FRP05A0009
Worst Case Discharge: 2500

Facility Name: Action Terminals
City: Ironton
State: OH
FRP ID#: FRP05A0072
Worst Case Discharge: 1712357

Facility Name: Aristech Chemical
City: Ironton
State: OH
FRP ID#: FRP0500222
Worst Case Discharge: 0

Facility Name: Allied Signal
City: Ironton
State: OH
FRP ID#: FRP0500207
Worst Case Discharge: 1575000

Facility Name: Marathon Oil
City: Lima
State: OH
FRP ID#: FRP0500298
Worst Case Discharge: 10794000

Facility Name: Eott
City: Lima
State: OH
FRP ID#: FRP0500249
Worst Case Discharge: 3350000

Facility Name: BP Oil Company
City: Lima
State: OH
FRP ID#: FRP0500008
Worst Case Discharge: 403200

Facility Name: BP Oil Company
City: Lima
State: OH
FRP ID#: FRP0500230
Worst Case Discharge: 7720692

Facility Name: Hays Oil Co.
City: Lisbon
State: OH
FRP ID#: FRP0500368
Worst Case Discharge: 25000

Facility Name: Uss/Kobe Steel Company
City: Lorain
State: OH
FRP ID#: FRP05A0433
Worst Case Discharge: 0

Facility Name: Sun Co.
City: Mahoning
State: OH
FRP ID#: FRP0500118
Worst Case Discharge: 462000

Facility Name: Dayton Power & Light
City: Manchester
State: OH
FRP ID#: FRP0500277
Worst Case Discharge: 2788445

Facility Name: Ashland Petroleum Company
City: Marietta
State: OH
FRP ID#: FRP0500202
Worst Case Discharge: 104202

Facility Name: Asphalt Materials
City: Marietta
State: OH
FRP ID#: FRP0500099
Worst Case Discharge: 84000

Facility Name: Asphalt Materials
City: Marietta
State: OH
FRP ID#: FRP05A0428
Worst Case Discharge: 1025000

Facility Name: Itapco
City: Marietta
State: OH
FRP ID#: FRP0500291
Worst Case Discharge: 993300

Facility Name: Asphalt Materials
City: Marietta
State: OH
FRP ID#: FRP05A0427
Worst Case Discharge: 630000

Facility Name: Asphalt Materials
City: Marion
State: OH
FRP ID#: FRP05A0424
Worst Case Discharge: 43390

Facility Name: Shell Oil
City: Mogadore
State: OH
FRP ID#: FRP0500253
Worst Case Discharge: 1986600

Facility Name: Cincinnati Gas and Electric Company
City: Moscow
State: OH
FRP ID#: FRP0500236
Worst Case Discharge: 3015000

Facility Name: Cincinnati Gas and Electric Company
City: New Richmond
State: OH
FRP ID#: FRP0500237
Worst Case Discharge: 2115750

Facility Name: Koch Materials
City: Newark
State: OH
FRP ID#: FRP0500098
Worst Case Discharge: 2167200

Facility Name: Ohio Oil Gathering Corporation
City: Newport
State: OH
FRP ID#: FRP0500109
Worst Case Discharge: 2100000

Facility Name: BP Oil Company
City: Niles
State: OH
FRP ID#: FRP0500227
Worst Case Discharge: 1428000

Facility Name: Koch Materials
City: North Bend
State: OH
FRP ID#: FRP0500295
Worst Case Discharge: 420000

Facility Name: Ashland Petroleum Company
City: North Bend
State: OH
FRP ID#: FRP0500141
Worst Case Discharge: 7983360

Facility Name: Cincinnati Gas and Electric Company
City: North Bend
State: OH
FRP ID#: FRP0500238
Worst Case Discharge: 3116000

Facility Name: The Uno-Ven Company
City: Oregon
State: OH
FRP ID#: FRP0500125
Worst Case Discharge: 9240000

Facility Name: BP Oil Company
City: Oregon
State: OH
FRP ID#: FRP0500214
Worst Case Discharge: 7555800

Facility Name: Asphalt Materials
City: Oregon
State: OH
FRP ID#: FRP05A0429
Worst Case Discharge: 2000000

Facility Name: Sun Company, Inc.
City: Oregon
State: OH
FRP ID#: FRP0500117
Worst Case Discharge: 429030

Facility Name: Lubrizol Petroleum Chemicals Company
City: Painesville Township
State: OH
FRP ID#: FRP0500101
Worst Case Discharge: 1000000

Facility Name: Uniroyal Chemical Co., Inc.
City: Painsville
State: OH
FRP ID#: FRP05A0431
Worst Case Discharge: 158000

Facility Name: Doe
City: Piketon
State: OH
FRP ID#: FRP0500248
Worst Case Discharge: 0

Facility Name: Norfolk & Southern Railway Company
City: Portsmouth
State: OH
FRP ID#: FRP0500284
Worst Case Discharge: 2006004

Facility Name: Tri-State Asphalt Corp
City: Rayland
State: OH
FRP ID#: FRP05A0012
Worst Case Discharge: 715000

Facility Name: Eott
City: Richfield
State: OH
FRP ID#: FRP0500247
Worst Case Discharge: 2530000

Facility Name: Goodyear Tire & Rubber Company
City: Saint Marys
State: OH
FRP ID#: FRP0500285
Worst Case Discharge: 500000

Facility Name: BP Oil Company
City: Sciotoville
State: OH
FRP ID#: FRP0500225
Worst Case Discharge: 5171

Facility Name: Cargill Oilseeds Processing
City: Sidney
State: OH
FRP ID#: FRP05A0015
Worst Case Discharge: 800000

Facility Name: South Point Ethanol
City: South Point
State: OH
FRP ID#: FRP0500210
Worst Case Discharge: 0

Facility Name: Marathon Oil
City: Steubenville
State: OH
FRP ID#: FRP0500294
Worst Case Discharge: 1869000

Facility Name: Uno-Ven
City: Tallmadge
State: OH
FRP ID#: FRP0500130
Worst Case Discharge: 1422876

Facility Name: BP Oil Company
City: Tiffin
State: OH
FRP ID#: FRP0500231
Worst Case Discharge: 1096200

Facility Name: Westway Terminal Co.
City: Toledo
State: OH
FRP ID#: FRP05A0091
Worst Case Discharge: 3500000

Facility Name: Delta Fuels Of Ohio
City: Toledo
State: OH
FRP ID#: FRP05A0436
Worst Case Discharge: 1800000

Facility Name: Gm Powertrain
City: Toledo
State: OH
FRP ID#: FRP05A0414
Worst Case Discharge: 0

Facility Name: Sun Co.
City: Toledo
State: OH
FRP ID#: FRP0500246
Worst Case Discharge: 693000

Facility Name: Stoneco
City: Toledo
State: OH
FRP ID#: FRP05A0085
Worst Case Discharge: 4620000

Facility Name: Seneca Petroleum Corporation, Inc.
City: Toledo
State: OH
FRP ID#: FRP0500121
Worst Case Discharge: 4269455

Facility Name: Clark Oil
City: Toledo
State: OH
FRP ID#: FRP0500234
Worst Case Discharge: 2204790

Facility Name: Emery Air Freight Corporation
City: Vandalia
State: OH
FRP ID#: FRP05A0107
Worst Case Discharge: 4000000

Facility Name: Conrail
City: Walbridge
State: OH
FRP ID#: FRP0500257
Worst Case Discharge: 1000000

Facility Name: Ashland
City: Wellsvelle
State: OH
FRP ID#: FRP0500140
Worst Case Discharge: 4435200

Facility Name: Wellsville Storage And Transport, Inc.
City: Wellsville
State: OH
FRP ID#: FRP0500133
Worst Case Discharge: 12600

Facility Name: Cleveland Electric
City: Willowick
State: OH
FRP ID#: FRP0500262
Worst Case Discharge: 2220000

Facility Name: Dod - Wright
City: Wright-Patterson
State: OH
FRP ID#: FRP05A0018
Worst Case Discharge: 5265000

Facility Name: Marathon Oil
City: Youngstown
State: OH
FRP ID#: FRP0500289
Worst Case Discharge: 2293200

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Wisconsin

Facility Name: Doe
City: Baraboo
State: WI
FRP ID#: FRP0500318
Worst Case Discharge: 824000

Facility Name: Wisconsin Power & Light
City: Beloit
State: WI
FRP ID#: FRP0500136
Worst Case Discharge: 698000

Facility Name: Farmers Union Central
City: Chippewa Falls
State: WI
FRP ID#: FRP0500326
Worst Case Discharge: 2293326

Facility Name: Amoco Oil Company
City: Chippewa Falls
State: WI
FRP ID#: FRP0500308
Worst Case Discharge: 945000

Facility Name: ITAPCO, Inc.
City: Chippewa Falls
State: WI
FRP ID#: FRP0500319
Worst Case Discharge: 1680000

Facility Name: Nicolet Paper Company
City: Depere
State: WI
FRP ID#: FRP0500108
Worst Case Discharge: 0

Facility Name: Wisconsin Power & Light
City: Fond Du Lac
State: WI
FRP ID#: FRP0500138
Worst Case Discharge: 825000

Facility Name: International Paper
City: Fond Du Lac
State: WI
FRP ID#: FRP0500166
Worst Case Discharge: 3750

Facility Name: U.S. Oil Co.
City: Green Bay
State: WI
FRP ID#: FRP05A0093
Worst Case Discharge: 4425667

Facility Name: CITGO Petroleum Corporation
City: Green Bay
State: WI
FRP ID#: FRP0500310
Worst Case Discharge: 3360000

Facility Name: U.S. Oil
City: Green Bay
State: WI
FRP ID#: FRP05A0094
Worst Case Discharge: 2659734

Facility Name: Amoco Oil Company
City: Green Bay
State: WI
FRP ID#: FRP0500309
Worst Case Discharge: 3343200

Facility Name: Mobil
City: Green Bay
State: WI
FRP ID#: FRP0500371
Worst Case Discharge: 4760112

Facility Name: Clark Refining & Marketing, Inc.
City: Green Bay
State: WI
FRP ID#: FRP0500084
Worst Case Discharge: 2310000

Facility Name: Constr. Resource
City: Green Bay
State: WI
FRP ID#: FRP05A0113
Worst Case Discharge: 2300000

Facility Name: Koch Materials/Koch Refining Company
City: Green Bay
State: WI
FRP ID#: FRP0500358
Worst Case Discharge: 2352000

Facility Name: Marathon Oil Company
City: Green Bay
State: WI
FRP ID#: FRP0500314
Worst Case Discharge: 3214134

Facility Name: Koch Refining Company
City: Junction City
State: WI
FRP ID#: FRP0500176
Worst Case Discharge: 1554000

Facility Name: Thilmany
City: Kaukauna
State: WI
FRP ID#: FRP0500091
Worst Case Discharge: 550000

Facility Name: Kohler Company
City: Kohler
State: WI
FRP ID#: FRP05A0076
Worst Case Discharge: 50000

Facility Name: Mobil
City: La Crosse
State: WI
FRP ID#: FRP0500315
Worst Case Discharge: 3511200

Facility Name: Midwest Industrial Fuels, Inc.
City: La Crosse
State: WI
FRP ID#: FRP0500316
Worst Case Discharge: 18270

Facility Name: Northern States Power Company
City: Lacrosse
State: WI
FRP ID#: FRP0500090
Worst Case Discharge: 2000000

Facility Name: Westway Trading Corp
City: Lacrosse
State: WI
FRP ID#: FRP0500134
Worst Case Discharge: 1650000

Facility Name: Van Zeeland Oil
City: Little Chute
State: WI
FRP ID#: FRP0500132
Worst Case Discharge: 331500

Facility Name: Itapco
City: Madison
State: WI
FRP ID#: FRP0500120
Worst Case Discharge: 1848000

Facility Name: Wisconsin Public Service
City: Marinette
State: WI
FRP ID#: FRP05A0062
Worst Case Discharge: 550000

Facility Name: The Uno-Ven Company
City: Mc Farland
State: WI
FRP ID#: FRP0500128
Worst Case Discharge: 3582012

Facility Name: CENEX
City: Mc Farland
State: WI
FRP ID#: FRP0500329
Worst Case Discharge: 2232594

Facility Name: Kerr-McGee Refining Corporation
City: Mc Farland
State: WI
FRP ID#: FRP0500320
Worst Case Discharge: 2310000

Facility Name: CITGO Petroleum Corporation
City: Mc Farland
State: WI
FRP ID#: FRP0500313
Worst Case Discharge: 2310000

Facility Name: U.S. Oil
City: Mcfarland
State: WI
FRP ID#: FRP05A0108
Worst Case Discharge: 3487730

Facility Name: Mobil
City: Mcfarland
State: WI
FRP ID#: FRP0500105
Worst Case Discharge: 2179842

Facility Name: Akrosil
City: Menasha
State: WI
FRP ID#: FRP0500224
Worst Case Discharge: 250

Facility Name: Amoco Oil Company
City: Milwaukee
State: WI
FRP ID#: FRP0500328
Worst Case Discharge: 3834600

Facility Name: Clark Refining & Marketing, Inc.
City: Milwaukee
State: WI
FRP ID#: FRP0500083
Worst Case Discharge: 3360000

Facility Name: Jacobus Petroleum Products, Inc.
City: Milwaukee
State: WI
FRP ID#: FRP05A0013
Worst Case Discharge: 2956000

Facility Name: Constr. Resources
City: Milwaukee
State: WI
FRP ID#: FRP05A0112
Worst Case Discharge: 3053635

Facility Name: CITGO Petroleum Corporation
City: Milwaukee
State: WI
FRP ID#: FRP0500317
Worst Case Discharge: 3276000

Facility Name: Marathon Oil Company
City: Milwaukee
State: WI
FRP ID#: FRP0500311
Worst Case Discharge: 6000708

Facility Name: The Uno-Ven Company
City: Milwaukee
State: WI
FRP ID#: FRP0500129
Worst Case Discharge: 2314704

Facility Name: PTW, Inc.
City: Milwaukee
State: WI
FRP ID#: FRP05A0083
Worst Case Discharge: 3753288

Facility Name: ST Services
City: Milwaukee
State: WI
FRP ID#: FRP0500243
Worst Case Discharge: 3256715

Facility Name: Shell
City: Milwaukee
State: WI
FRP ID#: FRP0500126
Worst Case Discharge: 4620000

Facility Name: U.S. Oil
City: Milwaukee
State: WI
FRP ID#: FRP05A0106
Worst Case Discharge: 3233622

Facility Name: Williams Pipeline
City: Mosinee
State: WI
FRP ID#: FRP0500135
Worst Case Discharge: 140070

Facility Name: Pluswood
City: Oshkosh
State: WI
FRP ID#: FRP0500112
Worst Case Discharge: 3000

Facility Name: Georgia-Pacific Corporation
City: Port Edwards
State: WI
FRP ID#: FRP0500351
Worst Case Discharge: 750000

Facility Name: Acme Die Casting Corp.
City: Racine
State: WI
FRP ID#: FRP0500208
Worst Case Discharge: 7000

Facility Name: Murphy Oil
City: Rhinelander
State: WI
FRP ID#: FRP05A0075
Worst Case Discharge: 2310000

Facility Name: Koch Materials Company
City: Stevens Point
State: WI
FRP ID#: FRP0500348
Worst Case Discharge: 1723355

Facility Name: S.C. Johnson & Son Inc. Waxdale Complex
City: Sturtevant
State: WI
FRP ID#: FRP0500119
Worst Case Discharge: 1142500

Facility Name: Murphy Oil USA, Inc.
City: Superior
State: WI
FRP ID#: FRP0500107
Worst Case Discharge: 10000036

Facility Name: Amoco Oil Company
City: Superior
State: WI
FRP ID#: FRP0500312
Worst Case Discharge: 2814000

Facility Name: Lakehead Pipe Line Company, Inc.
City: Superior
State: WI
FRP ID#: FRP05A0404
Worst Case Discharge: 0

Facility Name: Koch, Marine Fueling Div.
City: Superior
State: WI
FRP ID#: FRP0500350
Worst Case Discharge: 0

Facility Name: Wisconsin Electric Power
City: Union Grove
State: WI
FRP ID#: FRP05A0104
Worst Case Discharge: 1072000

Facility Name: Wisconsin Electric Power Company
City: Watertown
State: WI
FRP ID#: FRP05A0007
Worst Case Discharge: 1500000

Facility Name: Payne & Dolan Waukesha Tank Farm
City: Waukesha
State: WI
FRP ID#: FRP05A0114
Worst Case Discharge: 975042

Facility Name: Wisconsin Public Service
City: Wisconsin Rapids
State: WI
FRP ID#: FRP05A0080
Worst Case Discharge: 515357

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APPENDIX V: SHORELINE CLEANUP GUIDELINE MATRICES


To be included on disk.

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APPENDIX VI: OPTIONS FOR MINIMIZING ENVIRONMENTAL IMPACTS OF FRESHWATER SPILL RESPONSE ACTIONS

by the American Petroleum Institute, and the National Oceanic and Atmospheric Administration


Table of Contents

Abstract

1.0 Introduction

2.0 Summary of Response Methods and Habitats

3.0 Spill Response Methods for Specific Inland Habitats

4.0 Spill Response Methods 5.0 Special Considerations Appendices Tables
  1. Primary freshwater environments and habitats included in this guide
  2. Correlation of the shoreline habitats discussed in this guide with the Environmental Sensitivity Index (ESI) shoreline rankings for the Great Lakes
  3. Relative impact of response methods in the absence of oil
  4. The four types of oil used in this guide and their characteristics
  5. Key to ESI codes
  6. Gasoline Products: Summary of relative environmental impact from response methods for spills in water environments
  7. Gasoline Products: Summary of relative environmental impact from response methods for spills in shoreline habitats
  8. Diesel-like Oils: Summary of relative environmental impact from response methods for spills in water environments
  9. Diesel-like Oils: Summary of relative environmental impact from response methods for spills in shoreline habitats
  10. Medium Oils: Summary of relative environmental impact from response methods for spills in water environments
  11. Medium Oils: Summary of relative environmental impact from response methods for spills in shoreline habitats
  12. Heavy Oils: Summary of relative environmental impact from response methods for spills in water environments
  13. Heavy Oils: Summary of relative environmental impact from response methods for spills in shoreline habitats
  14. Relative environmental impact from response methods for open water environments
  15. Relative environmental impact from response methods for large river environments
  16. Relative environmental impact from response methods for small lake and pond environments
  17. Relative environmental impact from response methods for small river and stream environments
  18. Relative environmental impact from response methods for bedrock habitats
  19. Relative environmental impact from response methods for manmade structures
  20. Relative environmental impact from response methods for sand habitats
  21. Relative environmental impact from response methods for mixed sand and gravel habitats
  22. Relative environmental impact from response methods for gravel habitats
  23. Relative environmental impact from response methods for vegetated shoreline habitats
  24. Relative environmental impact from response methods for mud habitats
  25. Relative environmental impact from response methods for wetland habitats

Abstract

Selecting appropriate protection, response, and cleanup techniques, both before and following an oil spill, affects the ultimate environmental impact and cost resulting from a spill. The American Petroleum Institute (API) and the National Oceanic and Atmospheric Administration (NOAA) jointly developed this guide as a tool for contingency planners and field responders to identify response techniques that have minimal ecological impacts and also minimize the impact of the oil. The guide provides information on 29 response methods and classifies their relative environmental impact for combinations of four oil types and twelve freshwater environments and habitats. Spill topics of special concern in freshwater settings are also discussed, including public health, conditions under which oil might sink in fresh water, oil behavior in ice conditions, permafrost, and use of firefighting foams.

1.0 Introduction

1.1 Scope and Purpose

Selecting appropriate oil spill protection, recovery, and cleanup techniques, before and following an oil spill, is a critical element affecting the ultimate environmental impact and cost resulting from a spill. It is important to identify techniques that in themselves have minimal intrinsic ecological impact and are also effective in reducing the impact of the oil. Furthermore, these response techniques should be considered before a spill, so that little time needs to be spent preparing for the response during a spill.

The American Petroleum Institute (API) and the National Oceanic and Atmospheric Administration (NOAA) jointly developed this guide as a tool to help contingency planners and field responders evaluate response techniques and choose those that will most effectively prevent or minimize adverse ecological impact. Information is provided to help select response techniques for specific combinations of habitat and oil types. Each technique is evaluated individually for a specific habitat; however, during spill response more than one technique may be used at the same time on one or more habitats.

Reducing the overall ecological impact of a spill event is the primary concern of this guide, and it is applicable for inland, freshwater environments and habitats only. This guide does not address land-only, chemical, or marine spills. It also does not discuss legal or regulatory issues; safety considerations; or guidance on planning, organizing, and conducting a spill response effort. The manual may be customized for specific geographic areas to address special priorities and concerns.

The discussions in this guide reflect primarily the assessment of the environmental impact of the response methods. However, the selected techniques should be effective. They must remove a significant amount of oil from the environment or prevent or reduce oil impact, and they must have acceptable impact on the habitat as compared to leaving the oil alone (natural recovery). Prolonged use of an inefficient technique may be more ecologically detrimental than short-term use of a potentially more intrusive approach (e.g., frequent entry into a marsh to replace sorbents rather than vacuuming pooled oil).

Specific spill conditions will often dictate the response techniques used, and selection always involves tradeoffs. For example, a potentially ecologically damaging, but efficient, cleanup technique could be used to meet site-specific response goals. Also, techniques may be used early in response simply because they can be implemented immediately, rather than waiting until ones with lower impact can be mobilized. A method that has a significant short-term ecological impact, such as in-situ burning, may actually produce the lowest long-term ecological impact because it removes the oil quickly.

1.2 Background

Oil spills into inland waters differ from coastal or marine spills from several perspectives. For instance, inland spills are usually in freshwater habitats. Inland spills are also more frequent than marine spills, and they often involve smaller volumes of oil. Refined product spills are more common in freshwater, while crude oil spills comprise the majority of marine spills. Inland spills have a much higher potential to contaminate water supplies (surface as well as groundwater), to affect areas of concentrated populations, and to impact manmade structures and human activities. In coastal and marine environments, wave and tidal action are important mechanisms for dispersion and transport of oil and in removing oil from shorelines. These mechanisms are less important in freshwater habitats, where currents and floods are more important factors.

The knowledge base for response to oil spills reflects the disparity of information available between marine spill response and freshwater response. The lack of literature and guidelines for inland spill response prompted several efforts to improve this shortcoming. Preparation of this guide began with a workshop sponsored by API on Inland Oil Spills, conducted in Dearborn, Michigan from November 19-21, 1991. The objective of the workshop was to bring together the oil spill response community experienced and/or responsible for responding to freshwater crude oil or petroleum product spills, and to develop strategies through consensus for dealing with spills in different freshwater environments and shoreline habitats. The information from that workshop was the basis for development of this guide. However, the final guidelines presented here are based on the educated and experienced opinions of oil spill experts in industry and government.

1.3 Organization of Guidelines

The guide identifies response methods for twelve primary freshwater habitats (Table 1), which represent various waterways and shoreline types. Each habitat is treated separately in the guide, although the spill responder will be confronted with a variety of habitats.

Table 1. Primary freshwater environments and habitats included in this guide.
Water Environments Shoreline Habitats
Open Water Bedrock
Large Rivers Manmade Structures
Small Lakes and Ponds Sand
Small Rivers and Streams Vegetated Shorelines
Mixed Sand and Gravel
Gravel
Mud
Wetlands


Section 2 of the guide includes:

Section 3, arranged by water environment and shoreline habitat, contains:

Section 4 of the guide contains detailed descriptions of the response methods listed in the matrices. The following headings are used:

Section 5 discusses the following special issues of concern in freshwater settings:

1.4 Sensitivity of Environments and Habitats

Habitat sensitivity is a function of several factors, including degree of exposure to natural removal processes, biological productivity and ability to recover following oil exposure, human use of the habitat, and ease of oil removal. These factors are used to rank the overall sensitivity of shoreline habitats to spilled oil as part of the Environmental Sensitivity Index (ESI). This guide focuses on one element of environmental sensitivity, namely the sensitivity of habitats to impacts resulting from oil removal. ESI shorelines are grouped according to the oil removal considerations used in this guide. The correlation between the shoreline habitat groupings in this guide and the shoreline rankings in the ESI atlases published for the U.S. Great Lakes is shown in Table 2, the summary tables, and Chapter 3. It should be noted that some groupings include both low and high sensitivity habitats, particularly where both sheltered and exposed habitats are grouped, such as bedrock and manmade structures.

The differences in oil behavior, persistence, and need for cleanup between sheltered and exposed sites are addressed in the discussion of these habitats.

Sensitivity issues of special concern to inland areas include strong seasonal variations in biological productivity and exposure to physical processes, urban areas with extensive manmade structures along the shoreline, and populated areas that are very near shorelines and bodies of water when human-health concerns can dominate cleanup issues. Important seasonal considerations include presence of ice in winter; variations in water level, which greatly influence habitats likely to be exposed to oil, flooding of stranded oil, and natural removal rates; sensitivity of vegetation to direct oiling impact; and use of habitats by migratory birds.

Table 2. Correlation of the shoreline habitats discussed in this guide with the Environ- mental Sensitivity Index (ESI) shoreline rankings for the Great Lakes.
Shoreline Habitats ESI Ranking and Description
Bedrock ESI = 1A Exposed Rocky Cliffs
ESI = 2 Shelving Bedrock Shores
ESI = 8A Sheltered Rocky Shores
Manmade Structures ESI = 1B Exposed Solid Seawalls
ESI = 6B Riprap Structures
ESI = 8B Sheltered Solid Manmade Structures
Sand ESI = 4 Sand Beaches
Mixed Sand and Gravel ESI = 3 Eroding Scarps in Unconsolidated Sediment
ESI = 5 Mixed Sand and Gravel Beaches
Gravel ESI = 6A Gravel Beaches
Vegetated Shorelines ESI = 9A Sheltered Low Vegetated Banks/Bluffs
Mud ESI = 9B Mud Flats
Wetlands ESI = 10A Fringing Marshes
ESI = 10B Extensive Marshes














1.5 Impact of Response Methods in the Absence of Oil

The following criteria were used to evaluate the relative impact of each technique in the absence of oil, primarily due to physical disturbances of mechanical methods and toxic impacts from chemical and biological methods. The results are shown in Table 3. Impacts from use of individual products and equipment types vary. The information provided to evaluate impacts in the absence of oil addresses generic characteristics of the response techniques and does not consider those variations. Additional information on environmental impacts is provided in the discussions of each technique in Section 4.

Table 3. Relative impact of response methods in the absence of oil.

Water EnvironmentShoreline Habitat
Response
Method
Open
Water
Small
Lakes/Ponds
Large
Rivers
Small
Rivers/
Streams
Bedrock Man-
Made
Sand Sand
and
Gravel
Gravel Vegetated
Shores
Mud Wetlands
Physical Response Methods
Natural
Recovery
- - - - - - - - - - - -
Booming L L L L - - - - - - - -
Skimming L L L L - - - - - - - -
Barriers/
Berms
- - - H - - - - - - - -
Physical
Herding
L L L L - - - - - - - -
Manual Oil
Removal/
Cleaning
L H L M L L L M M H H H
Mechanical
Removal
L H H H - M M M M H H H
Sorbents L L L L L L L L L L M M
Vacuum L L L L L L L L L M H M
Debris
Removal
- L L L L L L L L L M M
Sediment
Reworking
- H - H - - M M M H H H
Vegetation
Removal
L H M H - - - - - H - H
In-Situ
Burning
L M L M L L M M M M H M
Flooding - - - - L L L M L L L L
Low-Pressure,
Cold-Water
Flushing
- - - - L L M L L M H L
High-Pressure,
Cold-Water
Flushing
- - - - L L H H H H H H
Low-Pressure,
Hot-Water
Flushing
- - - - M L H M M H H H
High-Pressure,
Hot-Water
Flushing
- - - - M L H H H H H H
Steam
Cleaning
- - - - M L H M M H H H
Sand
Blasting
- - - - H M - - - - - -
Chemical Response Methods
Dispersants L H L H - - - - - - - -
Demulsifiers L L L M - - - - - - - -
Visco-Elastic
Agents
L L M L - - - - - - - -
Herding
Agents
L M L H - - - - - - - -
Solidifiers L L L L L L M M L M M M
Chemical
Shoreline
Pretreatments
- - - - I I I I I I I I
Shoreline
Cleaners
- - - - M L M M M I M I
Biological Response Methods
Nutrient
Enrichment
L M L L L L L L L L L L
Natural
Microbe
Seeding
I I I I I I I I I I I I
L = Low; M = Moderate; H = High; I = Incomplete; "=" = Not applicable for this oil type


Those techniques that are clearly ineffective or inapplicable for a habitat are indicated with a dash (-). For cases where there is insufficient information to evaluate impact in the absence of oil, an "I" is used.

1.6 Classification of Oil Response Methods

The classifications developed for this guide compare the relative environmental impact of specific response methods for a given environment or habitat and oil type. It should be noted that the methods were compared among themselves, and no one method was used as a standard. The relative effectiveness of a response technique's ability to protect a habitat or remove oil is not explicitly considered. Relative effectiveness is only incorporated into the classification where less effective methods could result in longer application and thus greater ecological impacts, or leave higher oil residues in the habitat.

The classification categories are defined as follows:

A: May cause the least adverse habitat impact
B: May cause some adverse habitat impact
C: May cause significant adverse habitat impact
D: May cause the most adverse habitat impact
I: Insufficient Information - impact or effectiveness of the method could not be evaluated at this time.

Those techniques that are clearly ineffective (e.g., herding agents on heavy oils) or inapplicable for an oil type or habitat (e.g., sand blasting of mud habitats) are indicated with a dash (-).

1.7 Assumptions Used in the Discussion of Methods

This guide was prepared with several assumptions:

Proper Application of Methods

It is assumed that methods will be properly applied by trained personnel. For example, if booms are recommended, these guidelines assume that the booms will be effectively located and correctly deployed. Improper application of almost any technique can render it ineffective or cause additional damage. For general guidance on application, see the publications listed in Appendix A. In cases where instruction for using a protection or cleanup method may be habitat-specific, see Section 4.

Evaluation of Relative Impact of Methods

Each method was evaluated independently for each habitat. In an actual response, however, the methods cannot be evaluated in isolation from each other. Specific spill conditions will often dictate the need for different techniques for the same water environment or shoreline habitat. For example, a high degree of oiling or low exposure to natural removal processes may require a more intrusive technique to accelerate recovery in specific areas. The sensitivity of adjacent habitats may lead to the decision not to use an appropriate method because of the likelihood of secondary impact caused by cleanup of nearby sites. Finally, from an operational perspective, it may be necessary to use available methods early during a spill, rather than waiting for equipment or materials to arrive or teams to be trained in use of a less damaging technique.

Relative Effectiveness of Methods

The relative effectiveness of response methods to protect habitats and remove oil is a key consideration when selecting from various response methods. Although this guide attempts to consider only the environmental impact, effectiveness was incorporated into the discussion of methods in three ways.

First, those methods thought to be totally ineffective or inapplicable for an environment or habitat were not even listed in the habitat-specific matrices. For example, barrier/berms are not listed on the open-water matrices, and mechanical removal is not listed on the bedrock matrices.

Second, those methods that were clearly ineffective or inapplicable for a specific oil type within a habitat matrix were designated with a dash (-). Examples include using solidifiers on heavy oils in open water and emulsion-treating agents on gasoline products.

Third, those methods that are feasible, but likely to leave a significant amount of oil at the end of treatment, are given a lower classification. Often this change in effectiveness is associated with oil type, e.g., low-pressure, cold-water flushing is given a lower classification for heavy oil than medium oil because of its lower efficiency at oil removal. Similarly, methods such as manual and mechanical oil removal and sediment reworking that would have little effect on gasoline, which tends to evaporate quickly, are given lower classifications because the impact of the methods are not balanced by benefits from removing the oil.

Restrictions for Using Response Methods

Restrictions related to safety, weather, spill size, or regulatory constraints cover a wide spectrum of scenarios. It is thus impractical to discuss every possible situation or combination of factors in a set of guidelines. Some of this information, if appropriate, is included in the discussion under each habitat (Section 3) or in the descriptions of each method (Section 4). Many other considerations can come into play, such as worker safety and aesthetic, social, and economic impacts. Specific safety issues dealing with responding to gasoline spills are reflected in the tables. It should be noted that the using chemical methods will require approvals from state and/or Federal regulatory agencies.

1.8 Classification of Oil Types

Inland oil spills can involve a wide range of crude oils and refined products. The type of oil spilled is a key consideration in developing response and cleanup strategies. Oil properties important in characterizing oil types include:

Flash point -- Highly volatile oils, which evaporate rapidly after a release, may pose significant fire risks to responders. Often, the safest option is to allow the product to evaporate. Evaporation is an important mechanism for removing the spill from the water or shore because it lessens the need for cleanup and concern for associated impacts. Highly volatile oils completely evaporate in one to two days.

Specific gravity/API gravity -- Oils with a specific gravity greater than 1.00 (API gravity of less than 10) will sink in fresh water. However, those with a specific gravity of 0.95 or higher (API gravity less than 17.5) are also at risk of sinking once they become mixed with suspended sediments. When these oils have stranded on a shoreline, sediment incorporated from the shoreline can cause sinking if it is eroded from the shoreline.

Viscosity -- Viscosity controls both the rate that oil spreads on water and its likely depth of penetration into thesubstrate once on shore. Low-viscosity oils spread rapidly into thin sheens, increasing the surface area and making recovery difficult. They readily penetrate into sediments and debris. Viscous oils can be so thick that they do not spread, particularly when spilled on cold water. They are more likely to coat rather than penetrate shorelines.

Emulsion formation -- Under certain conditions, oil slicks will form a water-in-oil emulsion often called "chocolate mousse." This material can contain up to 80 percent water and can be many orders of magnitude more viscous than the spilled oil. There is no simple qualitative measure of the tendency to form emulsions. Emulsions are stabilized by natural or added surfactants, or compounds that act like surfactants, in the spilled oil. Gasoline does not emulsify, while diesel can quickly emulsify. Many crude oils can form stable emulsions. When an emulsion is formed, the oil changes in appearance and viscosity, becoming much more difficult to address from a spill-response perspective: the fluid is more viscous and hard to pump, and the volume has increased by a factor of four to five.

Adhesion -- The ease with which spilled oil can be physically removed from surfaces, usually by water flushing or vacuum, is an important factor in planning cleanup operations. The range of response methods needed for shoreline cleanup will depend largely on whether stranded oil adheres to substrate and response equipment. However, adhesion is a poorly defined parameter that is difficult to predict.

We use an oil classification scheme based on these properties to define four categories of oil. Characteristics of the four general types are provided below (Table 4), along with representative oils. Weathering tends to change the physical and chemical properties of oil, usually making it more viscous and cleanup techniques less effective. Methods used during the initial response should be re-evaluated as time elapses and as the oil changes in character. To some extent, this re-evaluation may be achieved by using the four tables for oil types in sequence, thus simulating the weathering process. Extremely heavy oils or those that are solid at ambient temperatures, such as asphalt, are not addressed below but are discussed as a special consideration in Section 5.

Table 4. The four types of oil used in this guide and their characteristics.

Gasoline Products

Diesel-like Products and Light Crude Oils (No. 2 fuel oil, jet fuels, kerosene, West Texas crude, Alberta crude)

Medium-grade Crude Oils and Intermediate Products (North Slope crude, South Louisiana crude, No. 4 fuel oil, IFO 180, lube oils)

Heavy Crude Oils and Residual Products (Venezuela crude, San Joaquin Valley crude, Bunker C, No. 6 fuel oil)

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2.0 Summary of Response Methods and Habitats

Tables 6 through 13 provide overviews of the physical, chemical, and biological response methods for four different oil types as applied to all water environments and shoreline habitats. Detailed information regarding specific habitats is provided in Section 3. Users of this guide should consult the matrices and summaries in Section 3 for descriptions of assumptions and circumstances applicable to the various methods. We encourage you to refer to Section 4 for more information on each response method. Also, the references listed in Appendix A can provide valuable, detailed information on specific topics or applications.

It is important to note that the classifications primarily reflect the likely relative environmental impact resulting from properly implementing a response method within each habitat. However, when there are overriding effectiveness or safety issues associated with a specific oil type or habitat, these methods have been classified as "not applicable" and are denoted with a dash (-) on the matrices. In the case of response to gasoline-type spills, many methods have been classified as "not applicable" because of the fire hazard to the responders. Although responders have used many of these methods at gasoline spills to protect resources or clean up the spill, discussion of the spill-specific circumstances that made their use possible are beyond the scope of this document.

Natural recovery is included in the tables since natural processes can be adequate, on their own, to remediate impact from an oil spill. It also presents no added environmental stress due to human spill response activities. Therefore, natural recovery is often classified as having the least adverse habitat impact in the summary tables.

Since there is little information regarding the environmental impact of in-situ burning, chemical treatment, and biodegradation enhancement in freshwater habitats, the evaluation and discussion are based on the best available knowledge on how they work and any past use. In most cases this knowledge results from past experience with marine spills. Where there is too little information to evaluate a technique (e.g., chemical shoreline pretreatment), an "I", for insufficient information, is used in the tables.

Spill response techniques described in this guide for inland water habitats include protection, recovery, and cleanup methods. The main objective of protection is keeping oil out of a habitat, or reducing the amount of oil that enters. Recovery consists of removal of floating oil from the water surface. Cleanup consists of removal of stranded oil. Frequently, these methods may be used for several response phases, such as deploying boom for protection or for containing oil washed off a river bank during cleanup.

Table 5. Key to ESI codes used in Tables 7, 9, 11, and 13.
ESI No. Shoreline Type
1A Exposed rocky cliffs
1B Exposed solid seawalls
2 Shelving bedrock shores
3 Eroding scarps in unconsolidated sediments
4 Sand beaches
5 Mixed sand and gravel beaches
6A Gravel beaches
6B Riprap structures
7 Exposed tidal flats (not present in Great Lakes)
8A Sheltered rocky shores
8B Sheltered, solid, manmade structures
9A Sheltered vegetated low banks/bluffs
9B Sheltered vegetated low banks/bluffs
10A Sheltered vegetated low banks/bluffs
10B Freshwater swamps (woody vegetation)




Table 6. Gasoline Products: Summary of relative environmental impact from response methods for spills in water environments.
Water Environment
Response Method Water Open RiversLarge Lakes/PondsSmall Lakes/PondsSmall Rivers/Streams
Physical Response Methods
Natural Recovery A A A A
Booming - Containment - - - -
Booming - Deflection/Exclusion A A A A
Skimming - - - A
Barriers/Berms - - - B
Physical Herding B B C B
Manual Oil Removal/Cleaning - - - -
Mechanical Oil Removal - - - -
Sorbents - - - -
Vacuum - - - -
Debris Removal - - - -
Sediment Reworking - - - -
Vegetation Removal - - - -
In-Situ Burning - - B C
Flooding - - - -
Low-Pressure, Cold-Water Flushing - - - -
High-Pressure, Cold-Water Flushing - - - -
Low-Pressure, Hot-Water Flushing - - - -
High-Pressure, Hot-Water Flushing - - - -
Steam Cleaning - - - -
Sand Blasting - - - -
Chemical Response Methods
Dispersants D D D D
Emulsion Treating Agents - - - -
Visco-Elastic Agents - - - B
Herding Agents D D B D
Solidifiers D D D B
Chemical Shoreline Pretreatment - - - -
Shoreline Cleaning Agents - - - -
Biological Response Methods
Nutrient Enrichment - - - -
Natural Microbe Seeding - - - -
The following categories are used to compare the relative environmental impact of each response method for the specific environment or habitat for each oil type, using the following definitions:
A = May cause the least adverse habitat impact.
B = May cause some adverse habitat impact.
C = May cause significant adverse habitat impact.
D = May cause the most adverse habitat impact.
I = Insufficient Information - impact or effectiveness of the method could not be evaluated at this time.
"=" Not applicable for this oil type.




Table 7. Gasoline Products: Summary of relative environmental impact from response methods for spills in shoreline habitats.
Shoreline Habitat
Response Method Bedrock Man-Made Sand Sand and Gravel Vegetated Gravel Shores Mud Wetlands
Equivalent ESI No.* 1A,2,8A 1B,6B,8B 4 3,5 6A 9A 9B 10A,B
Physical Response Methods
Natural RecoveryA AAAAAAA
Booming------ --
Skimming- - - - - - - -
Barriers/Berms- - - - - - - -
Physical Herding- - - - - - - -
Manual Oil Removal/Cleaning- - D D D D D D
Mechanical Oil Removal- D D D D D D
SorbentsB B - - - - B C
Vacuum- - - - - - - -
Debris Removal- - - - - - - -
Sediment Reworking- - D D D D D D
Vegetation Removal- - - - - D - D
In-Situ Burning- - - - - - C B
FloodingB B B A A B B B
Low-Pressure, Cold-Water FlushingB B B B A B D B
High-Pressure, Cold-Water FlushingB B D C C D D D
Low-Pressure, Hot-Water Flushing- - D D D D D D
High-Pressure, Hot-Water Flushing- D D D D D DD
Steam Cleaning- - - - - - - -
Sand Blasting- - - - - - - -
Chemical Response Methods
Dispersants- - - - - - - -
Emulsion Treating Agents- - - - - - - -
Visco-Elastic Agents- - - - - - - -
Herding Agents- - - - - - - -
Solidifiers- B - - - - D D
Chemical Shoreline Pretreatment- - - - - - I I
Shoreline Cleaning Agents- - - - - - - -
Biological Response Methods
Nutrient Enrichment- - - - - - - -
Natural Microbe Seeding- - - - - - - -
*Key to ESI codes in Table 5 on page 14.
The following categories are used to compare the relative environmental impact of each response method for the specific environment or habitat for each oil type, using the following definitions:
A = May cause the least adverse habitat impact.;
B = May cause some adverse habitat impact;
C = May cause significant adverse habitat impact;
D = May cause the most adverse habitat impact;
I = Insufficient Information - impact or effectiveness of the method could not be evaluated at this time; or
"-" = Not applicable for this oil type.



Table 8. Diesel-Like Oils: Summary of relative environmental impact from response methods for spills in water environments.
Water Environment
Response MethodOpen WaterLarge RiversSmall Lakes/PondsSmall Rivers/Streams
Physical Response Methods
Natural RecoveryAABB
BoomingAAAA
SkimmingAABB
Barriers/Berms---A
Physical HerdingBBBB
Manual Oil Removal/Cleaning--CC
Mechanical Oil Removal--CC
SorbentsBBAA
VacuumAAAA
Debris Removal-BBB
Sediment Reworking----
Vegetation RemovalBBBB
In-Situ BurningABBB
Flooding----
Low-Pressure, Cold-Water Flushing----
High-Pressure, Cold-Water Flushing----
Low-Pressure, Hot-Water Flushing----
High-Pressure, Hot-Water Flushing----
Steam Cleaning----
Sand Blasting----
Chemical Response Methods
DispersantsBCDD
Emulsion Treating AgentsBBII
Visco-Elastic AgentsBBBB
Herding AgentsBDBD
SolidifiersBBBB
Chemical Shoreline Pretreatment----
Shoreline Cleaning Agents----
Biological Response Methods
Nutrient Enrichment--II
Natural Microbe Seeding--II
The following categories are used to compare the relative environmental impact of each response method for the specific environment or habitat for each oil type, using the following definitions:
A = May cause the least adverse habitat impact;
B = May cause some adverse habitat impact;
C = May cause significant adverse habitat impact;
D = May cause the most adverse habitat impact;
I = Insufficient Information - impact or effectiveness of the method could not be evaluated at this time; or
"-" = Not applicable for this oil type.



Table 9. Diesel-Like Oils: Summary of relative environmental impact from response methods for spills in shoreline habitats.
Shoreline Habitat
Response Method Bedrock Man-Made Sand Sand and Gravel Vegetated Gravel Shores Mud Wetlands
Equivalent ESI No.* 1A,2,8A 1B,6B,8B 4 3,5 6A 9A 9B 10A,B
Physical Response Methods
Natural RecoveryA AAAAAAA
Booming------ --
Skimming- - - - - - - -
Barriers/Berms- - - - - - - -
Physical Herding- - - - - - - -
Manual Oil Removal/CleaningB A B B B B D D
Mechanical Oil Removal- - B C D CDD
SorbentsA A A A AAAA
VacuumBB B B B B CB
Debris RemovalA A AAA B BB
Sediment Reworking- - B B B D D D
Vegetation Removal- - - - - B - C
In-Situ BurningB B - - - B C B
FloodingA A A A A A A A
Low-Pressure, Cold-Water FlushingA A B A A A C A
High-Pressure, Cold-Water FlushingB A D C B C D D
Low-Pressure, Hot-Water FlushingC B C C C D D D
High-Pressure, Hot-Water FlushingDB D D D D DD
Steam CleaningD C - D D- - -
Sand BlastingD C - - - - - -
Chemical Response Methods
Dispersants- - - - - - - -
Emulsion Treating Agents- - - - - - - -
Visco-Elastic Agents- - - - - - - -
Herding Agents- - - - - - - -
SolidifiersB B B - - D D D
Chemical Shoreline PretreatmentI I I I III I
Shoreline Cleaning Agents- B - - - I D I
Biological Response Methods
Nutrient EnrichmentC C B B B B I I
Natural Microbe SeedingI I I I I I I I
*Key to ESI codes in Table 5 on page 14.
The following categories are used to compare the relative environmental impact of each response method for the specific environment or habitat for each oil type, using the following definitions: A = May cause the least adverse habitat impact.; B = May cause some adverse habitat impact; C = May cause significant adverse habitat impact; D = May cause the most adverse habitat impact; I = Insufficient Information - impact or effectiveness of the method could not be evaluated at this time; or "-" = Not applicable for this oil type.



Table 10. Medium Oils: Summary of relative environmental impact from response methods for spills in water environments.
Water Environment
Response MethodOpen WaterLarge RiversSmall Lakes/PondsSmall Rivers/Streams
Physical Response Methods
Natural RecoveryBBCC
BoomingAAAA
SkimmingAAAA
Barriers/Berms---A
Physical HerdingBBBB
Manual Oil Removal/Cleaning-BCC
Mechanical Oil Removal-BCC
SorbentsBBAA
VacuumAAAA
Debris Removal-BBB
Sediment Reworking----
Vegetation RemovalBBBB
In-Situ BurningA