Options for Minimizing Environmental Impacts of Inland Spill Response: New Guide From the American Petroleum Institute

In 1994, the American Petroleum Institute (API) and the National Oceanic and Atmospheric Administration (NOAA) published a guide entitled “Options for Minimizing Environmental Impacts of Freshwater Spill Response” (API, 1993; API and NOAA, 1994). The 1993/4 guides identified response methods for twelve primary freshwater habitats: four water environments and eight shoreline habitats. For each habitat, response methods were given a relative impact score for four general oil types. The 2016 inland guide differs in several ways:

• Information on spill sources and risks is included, to reflect increases in oil transportation by rail, the risks of fire and air quality concerns from spills of very light crude oils from tight shale production areas and diluted bitumen, behavior of diluted bitumen products when spilled to fresh water, and special considerations for inland spill response.

• Five oil groups are used and the guide is organized based on these groups as, in most cases, responders are dealing with a specific oil type that often has a unique set of response options and impacts to various habitats. Thus, this approach helps responders evaluate and select the most appropriate spill containment and recovery, and consequently impact minimization, options for each oil group. Group 5 oils that become submerged in the water column are included in this guide. Response guidance for sunken oil spill detection, containment, and recovery is included in a separate API technical report and operations guide (API, 2016a,b).

• Guidance is provided for two phases of the response: 1) The Control and Contain Phase; and 2) The Cleanup Phase. “Stoplight” matrices indicate the relative impacts of different response techniques for four water environments and seven land habitats.

• Current best management practices are compiled for different types of response actions, with the goal that these can be used in the preparation of treatment recommendations, as another means by which impacts during the emergency response phase can be minimized or avoided.

The 2016 inland guide contains the following sections, which are briefly described. Because they are adequately covered in other documents, the 2016 inland guide does not address the following very important inland response topics: Response during snow and ice conditions; and groundwater contamination or extensive subsurface oil recovery.

This section provides brief summaries of available data and information on inland spill sources (pipelines, rail, tanker truck, tank barge/towing vessel, oil exploration and production facilities, and other regulated facilities), spill types and volumes, and recent trends. Case studies are included to demonstrate successes and challenges of inland oil response to various spill sources and oil types.

This section highlights oil behavior and environmental and human concerns for inland spills that are different from marine spills. Inland oil spills typically have the following behavior characteristics and concerns that are different when compared to marine spills:

• Nearby shorelines on small water bodies can limit spreading, and consequently evaporation, which can prolong air quality concerns for workers and the public, leading to higher air monitoring and safety measure requirements.

• Increased potential for floating oil slicks to break up and form oil-particle aggregates formation in flowing river water, which can change the density of spilled oil to potentially result in oil submergence or sinking.

• Some oils can lose the light fractions and more readily reach the lower density of fresh water, which can result in submergence or sinking.

• Stranded oil can persist longer because of lower energy environments on lake shores or river banks (smaller waves, lack of tidal water motion and currents).

• Less dilution in shallow water bodies and with lower currents.

• Potential to affect larger areas and longer distances because of constantly flowing water, usually in one direction.

This section also describes the different types of sensitive resources of inland environments, outlines consultation requirements under the Endangered Species Act, Magnuson-Stevens Fishery Conservation and Management Act, and the National Historic Preservation Act.

This section defines the oil types by groups 1–5, which are used throughout the guide. Summaries are provided on the properties, typical behaviors, toxicity, and changes in properties as oil weathers.

This section discusses current accepted methods for oil spill detection, delineation, and characterization for inland spills. It includes guidelines for conducting Shoreline Cleanup Assessment Technique (SCAT) surveys of oil on land, both on the surface and in the subsurface, including use of a canine oil detection (K9-SCAT) team (API, 2016c). There are many natural materials that could be mistaken for oil (e.g., algal blooms, suspended sediments, bacterial sheens), thus ground truthing of aerial observations is essential. A nonpetroleum sheen can often be distinguished from a petroleum sheen by disturbing the sheen, which must be done from the ground. When disturbed, a bacterial sheen typically breaks into small platelets or fractures like broken glass. In contrast, a petroleum sheen swirls and quickly reforms after a disturbance. Other techniques to differentiate nonpetroleum sheens include:

1. Hexane test, where the sheen is collected with a sheen net. The net is inserted into a glass vial containing hexane, shaken, and allowed to stabilize. A petroleum sheen dissolves in hexane, causing the hexane to discolor. Biogenic sheens do not dissolve in hexane, thus there is no change in color.

2. Ultraviolet test, where hexane vials are viewed under ultraviolet light. Petroleum oils fluoresce, whereas biogenic sheens do not (USEPA, 2016).

This section includes descriptions of the response techniques and inland environments that are the backbone of the guide. Guidance is provided for options to minimize environmental impacts while achieving response goals, and a “stoplight” matrix indicates the relative impact of each response technique on each inland environment. Table 1 is an example of the information included in the matrices, this one is for spills of Group 2 oils—diesel-like oils and light/very light crude oils. Table 2 is an example of the guidance provided on best practices for spills of Group 2 to water during the contain and control phase of the response. Table 3 is an example of the guidance for spills of Group 2 oils during the cleanup phase of a response on land.

Because the API Technical Report 1154-1 (API, 2016a) and Operational Guide 1154-2 (API, 2016b) cover sunken oil detection, containment, and recovery techniques, the 2016 inland guide addresses only oils that either immediately submerge or suspend in the water column after release or become submerged after weathering and/or uptake of sediment and/or organic matter. These oils can be heavier or become heavier than the receiving water, but do not sink at or near the release site because of strong currents or turbulence in the water body. In April 2016, the U.S. Coast Guard updated the Oil Spill Removal Organization (OSRO) Guidelines to include a classification for nonfloating oils. The Nonfloating Oil Classification meets regulatory requirements of Group 5 oils in accordance with criteria set forth by 33 CFR§154.1047 and 33 CFR§155.1052 and the inherent risk of other heavy oil types that can submerge or sink. The information in both API guides (sunken oil and inland guide) can assist OSROs in selection of appropriate equipment and techniques to comply with these regulations.

Potential techniques for submerged oil detection, containment, and recovery are described, and the advantages and considerations for their use are summarized. Table 4 shows the relative effectiveness of response techniques for detection and quantification, containment, and recovery of submerged oil in the water column for different water habitats.

Effectiveness is a function of the following considerations:

Detection and Quantification:

• Minimum depth and width of a water body for deployment of the system. For example, induced polarization systems require water depths of at least 1.5 meters and the unit has two strings of electrodes that have to be towed in the water column.

• Ability to quantify amount of oil present. All of the sensors have the potential to quantify the extent and relative concentration of submerged oil plumes. Sorbents, nets, and visual methods have the potential to detect submerged oil presence but lack the ability to synoptically quantify the extent and amount of submerged oil present.

• Ability to detect oiled area, rather than at point locations that have to be interpolated to generate maps. Rivers and streams are likely to have rapidly changing submerged oil locations and be more difficult to survey, so acoustic systems are expected to be most effective.

Containment:

• Effects of water currents on performance. Most types of curtains or barriers that extend to any appropriate depth or height can fail in large rivers because currents are too strong. Air curtains might be effective for containment or for protection of sensitive resources in areas of lower flow. Curtains and barriers in streams might be effective because they are shallower and smaller, meaning more of the water column could be affected, and oil could be diverted to low-flow areas for containment and recovery.

• Presence/absence of natural depositional areas in the habitat. For lakes and impoundments, these areas would include where rivers or streams enter them. For rivers, these areas would include side channels or man-made diversion dikes. Ponds and streams are not likely to have such natural depositional areas of any significant size.

Recovery:

• Expected efficiency of oil removal. No current option is likely to remove a significant amount of the submerged oil from the water column; most efforts focus on removal from accumulation areas.

• Effective depth of the water body for deployment. Pneumatic barriers are likely to be even less effective in small streams because of shallow water depth and stronger currents.

This section provides guidance on selecting appropriate cleanup endpoints for inland spills. The goal of any spill response is to select the appropriate treatment methods and cleanup endpoints that would minimize the overall impacts to, and result in the most rapid recovery of, the environment. For inland spills, an agreement with all stakeholders may be problematic if a scientific assessment indicates that it would be appropriate to leave some oil for natural attenuation where continued treatment or cleanup will exacerbate potential habitat or natural resource damage. Often, there are two perspectives that have to be resolved:

1. Remove all of the spilled oil from the environment, and

2. Remove as much oil as possible without damaging or slowing overall habitat/resource recovery.

Stakeholders and the public often are unfamiliar with cleanup methods and how those methods, and associated operational activities, can result in potential damage due to trampling, road building, vegetation removal, excavation, etc. Stakeholders often also are unaware that natural attenuation can be very effective in the final phase of a spill response. It is important to develop cleanup endpoints early in a response and at the same time realize that they can be different for different phases of a response operation over time, particularly as oil weathers and becomes more difficult to remove. Guidelines for selecting cleanup methods and endpoints for inland habitats are derived primarily from Whelan et al. (2014).

This section provides guidance on some issues of special concern for inland spills, including:

1. Protection of water intakes

2. Response to spills of ethanol-blended fuels

3. Air quality monitoring and levels of concern

4. Release of oil field produced waters

5. Treatment of oiled debris

6. Guidelines for dealing with intermittent sheens

7. Successful fast-water booming strategies

There are four appendices: A) Properties of Nonconventional Oils: Provides summaries on the categories and environmental behavior and effects for light shale oils, diluted bitumen products, biodiesel, and non-petroleum oils; B) Best Management Practices: Includes current best management practices for different response actions to minimize collateral impacts during implementation of approved response operations; C) Firefighting Foam: Describes the current types of firefighting foam, how they can be used to combat oil fires, and guidelines for management of firefighting foam wastewater; and D) Responding to Spills of Very Light Crude Oils that Ignite: Provides guidance to responders for spills of these volatile oils when they ignite.

Inland spills have unique characteristics and behavior, may have the potential to pose greater risks to the public, and often necessitate more intensive removal methods, compared to coastal and marine spills. Therefore, choosing the best response options and implementing these in the most environmentally appropriate manner can minimize adverse impacts of a response. The API inland guide will support contingency planners and emergency responders in evaluating response techniques and selecting those techniques that will most effectively prevent or minimize adverse environmental impacts from inland spills.

Early drafts of the inland guide were improved by technical reviews by Lt. Brandon Aten, Josie Clark, Mary Cramer, Adam Davis, Eric DeMicco, Ralph Dollhopf, David Fritz, Kurt Hansen, Ed Owens, Alexis Steen, Elliott Taylor, Richard Tatner, and Ann Whelan. Their time and knowledge are greatly appreciated. Funding was provided by the American Petroleum Institute, with Ray Bradley as the contract manager.