Case Study 2 - Trainex Transp_Liverman...Case Study 2 Earl Liverman, OSC Region 10 15th Annual OSC Readiness Training Program 1 Keller Transportation Diesel Spill September 2010

www.oscreadiness.org

15th Annual OSC Readiness Training Program

Case Study 2

Earl Liverman, OSC Region 10

15th Annual OSC Readiness Training Program www.oscreadiness.org 1

Keller TransportationDiesel Spill

September 2010


Background

• On 29/09/10, a tanker truck pulling a trailer overturned on US Highway 12 causing a discharge of about 7550 gallons of red-dyed diesel

• Diesel was discharged into upslope roadside ditch, and migrated downward and laterally through the subsurface materials beneath the highway

• Site is located on public land administered by US Forest Service and within the Idaho Transportation Department right-of-way, and is adjacent to the Lochsa River


Background

• Lochsa River is a federally designated Wild and Scenic River that contains bull trout, chinooksalmon, and steelhead trout listed as threatened under the Endangered Species Act

• Site is within the Nez Perce Tribe treaty area









What are the criteria for determining whether to exercise federal removal authority for oil

spill response?


Decision to Initiate Action

General Removal Requirement:

Is the substance an oil?

Is there a discharge or substantial threat of discharge?

Is the discharge or substantial threat of discharge into navigable waters or adjoining shorelines?

Are removal actions consistent with the NCP?


Are there national response priorities for an oil spill response?


There are National Response Priorities?

First: Safety of human life, including any search and rescue efforts in the general proximity of the discharge and safety of response personnel

Second: Stabilizing the situation to prevent the event from worsening

Third: Use all necessary containment and removal tactics in a coordinated manner to ensure a timely, effective response that minimizes adverse impact to the environment

Fourth: Other priorities on a site-specific basis


Is there a general pattern of response?


There a General Pattern of Response

Discovery or Notification [NCP § 300.300]

Preliminary Assessment [NCP § 300.305]

Containment, countermeasures, cleanup, and disposal [NCP § 300.310]

Documentation and Cost Recovery [NCP § 300.315]


Are there other significant responsibilities?


There Are Other Significant Responsibilities

Keeping the EPA chain-of-command informed

Coordinate efforts with other agencies and third parties [NCP 300.155(a)]

Public Information and Community Relations [NCP § 300.155(b)]

Worker Health and Safety [NCP § 300.150 , §300.185(c), § 300.317]


How do you determine when the response is complete?


Discharges of oil that:

Violate applicable water quality standards

or

Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines

or

Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines


How do you use to determine when the response is complete?


Examples of Qualitative Endpoints

There is no longer any detectable oil present on the water, adjoining shorelines, or places where it is likely to reach the water again

Oil no longer releases thick rainbow sheen that will affect wildlife, sensitive areas, or human health

Further removal operations would cause more environmental harm than the oil to be removed

Cleanup measures would be excessively costly in view of their insignificant contribution to minimizing a threat to the public health or welfare, or the environment


Examples of Quantitative Endpoints

Oil on surface water, groundwater, soil or sediment does not exceed background concentrations for the constituents or compounds of concern

Oil on surface water, groundwater, soil, or sediment does not exceed predetermined concentrations for the constituents or compounds of concern


What are some practical considerations for achieving

cleanup?


Practical Considerations for Achieving Cleanup

Consultation

Long-term deployment of absorbent materials

Widely varying cleanup standards


Practical Considerations for Achieving Cleanup(continued)

Natural Attenuation

Not all spilled oil will be recovered

Weather


What Are Some Practical Considerations for Determining When the Cleanup is Complete

When Not All Spilled Oil is Recoverable?


Some Practical Considerations for Determining When the Cleanup is Complete When Not All Spilled

Oil is Recoverable

Technical and operational feasibility of investigation and cleanup

Is there a balance between cost in relation to the added degree of protection or reduction of risk afforded by additional cleanup?

Is there a state or other entity that has the capability to assume responsibility for the cleanup action?


What Are Some Practical Considerations for Determining When the Cleanup is Complete When

Not All Spilled Oil is Recoverable(continued)

Anticipated rate of natural attenuation processes

Institutional Constraints/Pressures

Is the remaining oil likely to damage environmentally sensitive resources?


What Are Some Practical Considerations for Determining When the Cleanup is Complete When

Not All Spilled Oil is Recoverable(continued)

Does it interfere with the aesthetic appeal and amenity use of the shoreline?

Is the oil detrimental to economic resources or disrupting economic activities?


Current Situation

The steep mountain sideslope is overlain at varying depths by backfill material and/or colluvium followed by weathered granitic bedrock which grades into competent bedrock

There are no alternate subsurface investigation techniques or cleanup techniques considered reliable for the Site conditions

Dissolved BTEX and Napthalene appear to be naturally attenuating

The rate of liquid fuel removed from the subsurface recovery system has diminished over time


Current Situation(continued)

Analytical results from 11 upstream surface water samples and 25 downstream surface water samples show that the contaminants of concern were non-detect

Analytical results for 28 groundwater samples show only one benzene, ethyl-benzene, and naphthalene above State standards

The last time any free product or sheen was observed along the riverbank was in November 2010 and a few days in October 2011


What Would You Do?

Documents

Case Study 2 - Trainex Transp_Liverman...Case Study 2 Earl Liverman, OSC Region 10 15th Annual OSC Readiness Training Program 1 Keller Transportation Diesel Spill September 2010