crew: u.s. coast guard (uscg): regarding bp oil spill: 1/26/11 - dispersant monitoring an4...

8/7/2019 CREW: U.S. Coast Guard (USCG): Regarding BP Oil Spill: 1/26/11 - Dispersant Monitoring an4 Assessment Directive

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DispersantMonitoring an4 AssessmentDirective

L PlumeMonitoring and Assessment Plan fpr Subsurface Dispersant ApplicationBP shall implementthe approvedDispersed Pl9me Characterization Plan for SubsurfaceDispersant Application. Part I of the plan is a ~ ' P r o o f ofConcept' to determine ifsubsurface dispersant operation is chemically c(ispersing the oil plume. Once the "Proofof Concept" test is complete; the results will be. reviewed by theRRT for a decision toproceed or not proceed with Part2 of the plan. Part 2 of the plan involves robustsamplingto detect and delineate the dispersed ~ l u m e Part3, entitled "SubsurfaceInjection ofDispersant", outlines the o p e r a t i o n ~ procedures. Additional guidancewillbe provided by the RRT coordination group onjspecific implementation of this directiveand that guidance will be considered an a d d e n ~ u m to this directive.At least 24 hours prior to the testing; use and/or applicationof any subsurface dispersants,BP shall provide aDispersant ApplicaJion P l a ~ that identifies the dispersants to be used,describes themethods and equipmentused to i ~ j e c t the dispersant. plume model to assurerepresentative sampling, proposedmethod of v)sual observation, process for determiningthe effectiveness of subsurface injection, the s ~ i f l c injection rate (i.e., gallons/minute),the total amount to be used for the duration of the test, the total length of time thatdispersant is injected, and the plan for s a m p ! i n ~ and monitoring, as approved by theUnified C o ~ m a n d Environmental Unit. Dispe7sants must be on the approved productschedule an;d suitable for this use.AU data shalt be provided to theUnited StatesGoast Guard (USCG) Federal On-SceneCoordinator, .and the Environmental P r o t e c t i o ~ Agency (EPA) Regional Response Team(RRT) representative within 24 hours of the information being received. This dataincludes real time monitorltlg. laboratory a n a l ~ s i s , documented observations,photographs, video, and any other infonnationlrelated to subsurface dispersantapplication.BP shall conduct Part 1monitoringand o o J 1 e c ~ the data outlined below to determinedispersed plume concentration and transport. shall conduct Part 2monitoring andcollect the data outlined below, which win be *ustained and more comprehensive, toaddress plume fate and effects on ~ i f e trom the dispersed plume and chemical 'IGdispersants based on the resultsOfPrm I and i ~ r a t i v e hydrodynamicmodeling output.Timing: BP shall commencePart t monitoringwhen subsurface applicationof dispersantis initiated. BP shall ensure that theRJV BrooJi,s McCall or equivalent on location isoutfitted. and manned before subsurface appli


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DItPfu:r ijl r.&V'rLsampling should determine the factors to predi4t buoyancy; namelyjJubt5fe sizes, density il t l /f(or speific gravity) along the thennal gradientlofthewarer column, and kinematic !f-viscosity.Part 1IF ~ 4 - T I I,!. . s . v l U S S S ~ V I . . ..f,..Jt. l c e > l . i n ~ $ . dl tBP shall design and implementa Part 2 monito)'ing plan to collect and report, on a dailybasis, the data and information described belo\y. BP shall submit this plan to the FOSCand EPA RRT Co Chair for approval and shalilbegin implementation upon notice fromthe CoastGuard and EPA. BP shall continue itnplementation of this plan until furthernotification from the Coast Guard and EPA. I

BP's monitoring plan shall include amore thorpugh oil analysis. to enable EPA todetermine whether the dispersed plume is toxiq to aquatic life. This plan shall bedesigned and implemented to determine whether the dispersed oil will hang in the watercolumn and eventually come in contact with thp benthos as it approaches land. BP hasthe option ofconducting this particularmotlitoting and analysis as part of Part 1 if sodesired.PART 1- ProofofConcept- Data Collection ~ e q u i r e m e n t

Towed Fluorometer at 1meter ussrParticleAnalysis at various intetvals from surface to 550 meters Dissolved Oxygen at various intervals trom surface to 550 meters CTD - Conductivity. Temperature, a n ~ n e p t h at various intervals from surface to550 meters Water sampling from surface to 550 m ~ t e r s f0t,PAH analysis 1HI Aerial Visual Observation - t J ~ ~ Ift:tt.I..'f "mN4 AJ].JPART 2 - Characterization Plan - Data Coltec);ion Requirement Cast Fluorometer - surface to sea floorl LISST Particle Analysis at various intervals from surface to sea floor Dissolved Oxygen at various intervals from surface to sea floor CTD - Conductivity. Temperature, an4Depth at various intervals from surface tosea floor Water sampling from surface to 550 m ~ t e r s for PAH analysis Aerial Visual Observation Rototox toxicity testing UV -Fluorescence testing to meet objectives in Appendix A

PART 3- Subsurface Injection ofDispersant + Parameter Requirements Type of dispersant to be used

, See Appendix Afor further background

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Rate of dispersant injection Process for monitoring pumping rate Procedures for FOSe to start and stop i ~ j e c t i o n

Evaluation Criteria to Determine Operation)tJ Shut-Down of SubsurfaceSeaDispersant Application: ,.The Federal On-Scene Coordinatorwill immediately convene the Regional ResponseTeam (RRT) when either of the following cond,itions is reported:

J. Ifthere is a significant reduction in PO from background to below 2 mglL; or2. IfEPA's interpretation of the toxici;.y test reveals excessive exertionof a toxicresponse. To determine a measurable toxic response, BP must first perform arangefinder test since the collectionjof the sample will be directly from thetoxic plume, and any sample from the plume wi1llikely kill 100% of the testpopulation. Therefore, the rangefin4ermust first be conducted to determine anorder ofmagnitude dilution that givies a measurable response. Then, a morerefined dilution proceduremust be ~ o n e to get the final LC50 answer. Thisresult will be compared to aNOAAj plume model thatwould predictwhenorwhere exertion of that toxic r e s p o n ~ e would take place. EPA and NOAA willinterpretthe results of the toxicity t ~ s t s to infonn determination of a shutdowndecision.

The RRT will evaluate the conditions above, it}. addition to all relevant factors includingshoreline. surface water, and other human health and ecological impacts, to determinewhether subsurface dispersant application shoqld be shut down.Limitations to AddressBP shall include in its monitoring plan p r o v i s i ~ n s to address and minimize the 'impactthe following challenges:

1. Timely transport of samples to labs whre necessary, which may be subjecttoweather and/or operational delays.2. Sampling in the deep sea environment tnay posechallenges due to equipmentlimitations and malfunctions.Quality Assurance and SamplingPlanReqqirementsBP's plan shall include sample collection meW,odology, handling, chainofcustody anddecontamination procedures to ensurethe higt(est quality will be collected. Discrete 1 h , I u ~samples shall be tested at an approved lab(s). 1 I " r ~ samples shall be tested. All tJt,r Itx.f. /ttUsamples (or as practicably possible) shall be atpffived for potential future analysis. WherebtJl'ul.A-t\S'technically possible, all samples shaH be at leaj>t 100 ml. UN

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BP shall include the following oomlionents and criteria in its Sampling Plan:1. An Introduction, to include woject objective and project staff2. A brief sitedescription and I1ackground3. A description of the Sampliri% Approach and Procedures, to encompass:a. A briefoverview of ~ p l i n g activities, data quality objectives, and healthand s a f ~ i m p l e m e n ~ o n strategies (frequently, this references anotherspecific dOOument, b(itmust be included).b. The actual sampling ~ d l o r monitoring approach, to ensure repeatabilityand consistent Pt0ce4ures. Describe sampling, monitoring, sampling andfield QC procedures,!spoil orwaste disposal procedures resulting from thiseffort, as well as spe4imen/data handling issues.c. Samplemanagementi- how the samplewill beprocured, bandIed, anddeliveredd. Sample instroctions-- preservation. containers, and hold times4. The analytical approach - w ~ a t lab tests will be ron, any special instructions, howthe data will be verified, andlhow datawm be reported.5. Quality Assurance- custody PJ:


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BP shall include the following components an4 criteria in its SamplingPlan:t. An Introduction, to include project objl:jctive and project staff2. A brief site description and backgroun43. A description of the Sampling A p p r o a c ~ and Procedures, to encompass:a. A briefoverviewof sampling aqtivities, data quality objectives, and healthand safety implementation s t r a t ~ g i e s (frequently, this references anotherspecific document, butmust be Jncluded).b. The actual sampling and/or m o ~ i t o r i n g approach, to ensure repeatabilityand consistent procedures. Desqribe sampling, monitoring, sampling andfield QC procedures, spoil orw,ste disposal procedures resulting from thiseffort, as well as specimen/data\handling issues.c. Samplemanagement - how the ~ a m p l e wilt be procured, handled, anddeliveredd. Sample instructions- preservatiqn, containers, and hold times4. The analytical approach - what lab t e s t ~ will be rwl, any special instructions; howthe data will be verified, and bow data will be reported.5. Quality Assurance- custody p r o c e d u r e s ~ field records including logs, chainofcustody, qualitative data handling inclu,iiing photographs.

II. SpecialMonitoring ofApplied Response/Technologies ("SMART") Protocol forSurface Application ofDispersantsBP shall immediately implement the Special Monitoring ofApplied ResponseTechnologies ("SMART') Protocol (attached Appendix B) at the Tier III level forsurface application of dispersants. Results ftot;.1 Tier TIlmonitoringmust be shared withthe Area Command Environmental Unit. I f T i ~ r II I is not deemed to be sufficient, furtherdirection will be provided.

D ~ t e : ~Mary E. Landry RearAdmiral, U COFederal O n ~ S c e n e CoordinatorDirectorSuperfundDivisionU.S. EPA Region 6Dallas, TX75202

D)d;e: _


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Appendix A -Background forPart 2 MeVtodology for Informational PurposesThe-fact thatmany organic compounds fluoresPe at specific excitation and emissionwavelengths is the basis for identifying many the components of crude oil in seawater.When subject to excitation at 245-280 run, polycyclicaromatic hydrocarbons (PAH)fluoresce overwavelengths of 310 to> 400 nni. dependingon thenumberof aromaticrings in the structure. Only one group has e x ~ i n e d the 2D UV FluorescenceSpectrosCopy (UVFS) spectraof oil treated with chemical dispersants. the Ken Lee groupat Fisheries and Oceans Canada (DFO). They 1Pund that a fixed excitation wavelength of280 om works best for fluorescence of PAHs i,n crudeoil, and two different emissionwavelengths, one at 340 nm for 1~ a n d 2 ~ r i n g pjt>.Hs and the other at 445 nm for 3 ~ r i n g andhigher PAHS, provide an excellent fingerprint differentiating chemically dispersed oilfrom n o n ~ d i s p e r s e d oil. As oil gets dispersed to the action of a chemical dispersant,the peak heightat 445 nm becomes highly proljlounced relative to the peak height at 340run. Thus, computing the ratio ofpeak. height 1\1: 340 to the peak. height at 44S gives adirectmeasurement of the degree of d i s p e r s i o ~ that has taken place as a result of applyinga dispersant to an oil.The effect ofoil dispersion on UVFS spectra cpn be expressed in terms of an emissionratio, so that dispersion can be trackedwithoutlhaving to measure oil concentration. Thespectral changes associated with the applicatiop of dispersant can also be calibrated toquantify increasing oil or oil plus dispersant. 1)lefact thatUVFS and UVA data arecomparable at an emission intensity of 445 nm)or over the whole spectrum of intensities(from 300 500 nm) indicates that the fate ofl1igher molecular weight (> 3 ~ r i n g ) PAHfractions - the more "dispersiblell fraction of aJll oil slick will provide a good idea of thefate of the oil as awhole during the dispersion!process. Given that higher molecularweight PAHs may be associated withmany o f ~ e persistent (or chronic) toxic effects ofcrude oils on marine organisms. the ability ofl!JVFS to track"dispersible" fractionswould make it a particularly useful tool in stud!ies ofthe longvterm toxic effects ofdispersed oil.

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DispersantMonitoring and Assessment Directive ....Addendum 1this Is an addendum (Addendum 1) to the DispersantMonItoring and Assessment Ofl1!ctive Issued on May 10.. 2010,by the U.S. Coast Guard (USCG) and the Environmental protection Agency (EPA) to gP. The requirements In thisAddendUll'll apply to Part 2of theMav 10,2010DIrective and are in additIon to the requirements of thatDirective.BPshall commence P a r t ~ r e g 4 i r ~ m e n t s b E # f o . r ~ s ~ ! ; ) ! i l . l r f a c e ~ p p l l ~ t 1 o n ofdlspersanUs h"!!tieted ~ m d ~ n t l n u e the P ~ r t2 requirements and this AddendumlilritIl c ~ n c e l l ~ d o r m o d f f l ~ d by the USCG and ~ P A . if vJA ,,, r0 f.!- to f " . ~ ' f, " t l m ~ ' < ' ( j l ; Addfttonal Requfremelrts: 01';0 , ~ { f l r l T ;) .0

\ . . : t ~ f : . . ~1. Sampling of dispersant/oil :ind Qll-only waters must be continued perthe Directive, IJnd 1M adaftlol'1, baselinedata ofwaterswithout dIrect application ofdispersant or 011 shall also be collected by BP.

2. BP shall aI/ow EPA/NOAA stlentlsts flexibility within the sampling plan to d l ~ c t the collectfon ofaddltlonaldata based on fTetd observations (at times and focattons of their choIce) .For example, EPA may request torecast the stat1an If the eDOM fluorometer IndIcatesa large lncre;,ise in signal after data review. EPA/NOMstaff mustbe qllowed to be In constant communication with staffon shore.

3. ap shall use Turner Oeslgru C3 fluorometer (e.g., SMART protocol) to distinguish betWeen ollimpadedsurfaee waters and those not Impacted by 011.4. 8P shall use a CTO rosette package equipped with COOM fluorometer and a 2 ~ w a y communication wire toensure that EPA/NOM scIentists can vfew profile data as the rosette package Is d e p J ~ d to 1500 m e t e ~ s . Inaddition, theCOT rosette package must be capable of collecttng dIscrete samples In thewater column usIng

the live feed data stream. The requIrement must be metwlthln 7 days for the RV Brooks Mccall. All othervessels must Immedlatelv meet this requIrementBP shalfdeploy ussr from the v ~ e l for continuous sampling of surface waters during transits, in order toprovide particle slle(Ounts Information whIch potentiallydistingUishes between dispersed and n o n ~dispersed oil.

6. Discrete water samples shall b& taken by liP at predetermined depths as spacJfled or directed by EPA/NOAAscientists for UV fluorescences.7 .B f ~ ~ a l l p ~ o y i d , e 4 8 hour advanced notice f q r d ~ p a r t u r e and trip duration tlmellnes to the rose and the EPA;ftRTc.o-chalr." t . J t \ W ~ 4M.(: L.- ()/"JO,8. Data reporting shall be conducted by BP on adally basis. This reporting shallindude a sample. tracking ~ b l e ' . ; L -Data reporting shall be proVided by BP to the FOSC and the EPA RRT Co-chalr. ! c;"rl't y t>

Date: 5'Ii t.{ 1-,- 0 L 0t IDate: 5jJL/:LufO, ,

'DirectorSuperfundOMslonU.S. EPA Region 6Dallas, TX 75202


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Dispersant Monitoring and Assessment Directive - AddendumThis is an addendum (Addendum 2) to the Dispersant Monitoring and Assessment Directive Issued on May 10,2010, andAddendum 1 issued on May 14, 2010 by the U.S. Coast Guard (USCG) and the Environmental Protection Agency (EPA) to BP.The requirements in this Addendum 2 apply to Parts 1 and 2 of the May 10, 2010 Directive and are In addition to therequirements of that Directive. BP shall commence Parts 1 and 2 requirements before subsurface application of dispersantis Initiated and continues the Parts 1 and 2 requirements, Addendum 1, and this Addendum 2 untll cancelled or modified bythe USCG and EPA.Alternative Dispersant additional Requirements:

1. Sampling of dispersant/oil and oil..-only waters must be continued per the Directive, and In addition, baseline data ofwaters without direct application of dispersant or oil shall also be collected by BP. Monitoring of subsurfacedispersantapplication by BP shall be performed from a vessel capable of performing all requirements of the May la ,2010, Dispersant Monitoring and Assessment Directive and Addendum 1 on each day that dispersant is applied. Asused in this Addendum 2, a "day" shall mean a calendar day.

2. Within 24 hours of the issuance of this Addendum 2, BP'shall identify to the FOSC and the EPA RRT Co-chair fo r EPA'sand the FOSC's approvat one or more approved dispersant products from the National Contingency Plan ProductSchedule that are available in, sufficient quantities, are as effective at dispersing the oil plume, and have a toxicityvalue less than or equal to 23.00 ppm LC50 toxicityvalue fo rMenidia or 18.00 ppm LC50 for Mysldopsis, as 'indicated on the NCP Product Schedule (http://www.epa.gov!oeml.content/ncp/tox_tables.htm). The less toxic[S$lersant R,rodu 5 shall be used by BP fo r surface ~ p p t i c a t l o n and subsurface application as directed by the FOSC.I fifn 72 hours after submItting e 1st of alternatives, and after receiving EPA approva , BP shall immediate use

only the approved alternative dispersant. Should BP not be able to identify alternative dispersant products, BP shallprOVide the FOSC and EPA RRT CO-Chair a detailed description of the products Investigated, the reason the products, did notmeetthe standards described above. Availability shall be b a s e ~ X i S t i ~ s t o c k p i l e s of dispersants, theestimat 'me to begin and aerial and subsurface application, t ime for manufacturing, shi ping, and warehousing.

3, The effectiveness of t e Ispersant in subsurface application shall be determined as specified In Directive 1 Part 1,and Part 2. Dispersant application can be applied subsurface if, and only if, daily monitoring is performed.

4. BP shall prOVide 48 hours advanced notice of departure and trip duration time lines of the monito ring vessel to theFOSC and the EPA RRT Co-chair.

5. Monitoring data on the use ofthe less toxic disp!=rsant product(s) shall be reported by BP to the FOSC and the EPARRT Co-ehalr on a daily basis. This reporting shall include a sample tracking table. Daily data reports shallthereafter be prOVided by BP to the FOSC and the EPA RRT Co-ehair as soon as practicable on the day following useof the less toxic dispersant product(s) by BP, but in no event later than 24 hours after use.

Date:

Date:Director, Superfund Divisionu.s. EPA Region 6Dallas, TX 75202


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AppendixSimple parametric dlffustonmodel of 011 dispersed from Injectionof dIspersantS at thewellhead.Conceptual Madel:'rh*" oU ..andgas pllJme is released from the well head and rises in a coherent fashion.whilecntraftllngwater. At the poIntwhere the densityofthe plume apprciache$ the denstty ofthewaterit starts to Jose Its coherence and individual droplet:; start movlngfndependently. Dispersed oildropletsmove with the plume during the coherentstage ofplume rise, butstartmovingIndependently in the transition zone between these two stages ofplume rise. The verticaldistance over wWch this transition occursdefines the vertical dl$tribution ofthe dispersed 011droplets. We are notawareofexperiments or relIablemodels thatcan Inform us regardIng theextentof the transition zone; h9wever,wewould look to sharp gradients in waterdensity in deepwateras a probably location of the zone,We have notyet included any mechanism for dep'osition ofau droplets as the plume moves down ..current Any sink tenn would reduce the resultingconcentrations.Modelassumptions: Dispersed oil travels With the currents with neglIgiblevertical velodty due to bUoyancy Horizontal current is 5em/secat the depth ofthedispersed plume Horizontal (cross current) diffusion Is0.1mYs Vertical diffusion is negllgible (conservative approximation) Along current diffusfon is neglected (conservative approximation) Diffusion process is governed by Flcklan diffusion with constant diffusion constant Droplets are unifonnly dtsbibuted verticallyWithin a: finlte stab o f w a ~ r Droplets start from a singlevertical line source The entire release rate trom thewell (5000 bblJday) contributes to the dispersed QU plume The release duration [s fndefln1tely longModel results:The modelwas run for 2 scenarios: all the oU (s within a 100meter slab atwater; and aU the on iswithlI1 a 50 meter slab ofwater. The plume length is sensitive to the assumptionsmade about thevertical distribution of the dispersed aU droplets. Plume length is ~ l s o sensitive to release rate.For100meter slab: Centerline c o n c e n t r a t f o ~ drops tQ 1ppm (by mass) in44 kilometers.

2 billion cubic meters atwater ha\1e concentrationsabove Ippm Centerline concentration drops to ZOO ppb (bymass) in 432 kilometers (the travel distanceoftbe plume In 100 days)For a SO meter stab CenterUne c o n c e n ~ t l o n drops to 1ppm (by mass) jn172 kilometers. abillion cubfc meters ofwater have concentrations above lppmInternal Use Only Date Prepared: May 13,2010


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u.s. Department ofHomeland SecurityUnIted StatesCoast Guard

CommanderEIghth CoastGuard Ofstrlet H a J e ~ F e d e n a I Bullding.500 Po StreetNew eans. LA 10130Staff Syr:nbol (dOPhone: (504) 671-23315080May 9. 2010

To: Providers of Surfactant Supplies to the Nalco 'CompanyLadies and Gentlemen:We write to you in a time of great national need. Qn April 20, 2010. an incident on themobileoffshore drilling unit DeepwaterHorizon resulted in an oil spill in the Gulf ofMexico which hassince been designated a "spill ofnational significance." The Coast Guard supports the efforts ofBPExploration & Production Inc. (BP EPn to contain and eliminate this oil spill and minimizeand prevent its effects, both at sea and onshore.Given the circumstances of the oil spill. including!its size and proximity to the shoreline of theUnited States. chemical dispersants are essential t the oil spill response and clean-up effort. Atthis time. the supply of dispersant available to BPEPI is extremely limited. The NalcoCompany. a dispersant manufacturer. is manufactu,ring additional dispersant for BP EPI to use intheDeepwater Horizon response but cannot produ,cc at full capacity due to a shortage ofsurfactant supplies and will soon deplete what remaining surfactant supply it has. If BP EPrcannot source additional dispersant very soon. its current supply of dispersant will be exhausted.The consequences of such a dispersant exhaustion':will be widespread. and we write to Y0t! todayto ask for your assistance in helping all of us avoid those consequences.Specifically, we are asking companies that p r o v l d ~ the Nalco Companywith surfactant suppliesto assist by making available, to the greatest e x t e n ~ possible, their surfactant material to thisresponse and clean-up effort. We understand that thismaterial may be in short supply orotherwise already designated for contracts with otber companies. We appreciate the commercialrealities involved and respectfully ask that you m*,e what efforts you can to allot surfactant. sppply to the Nalco Company's production so thaqit can manufacture dispersant for BPEPI's oilspill response, knowing that whatever efforts you !ireundertaking in this regard are of invaluablebenefit to this country. ,.'We ask that you contact Nalco directly to arrange reasonable terms for your surfactant supply.Please do not hesitate to contact us should you have any questions. We thank you for your timeand consideration of this request.

Sincerely,

1 ~ 6 ~MARY E. LANDR.Y "RearAdmiral. U.S. Coast GuardCommander. Eighth CoastGuard District..... .....;. ---


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U.S. DGPSrbn. G n t ~0Homeland SecurityUnited StatesCoast Guard

31 May 2010B!!!gOfficerExploration & ProductionBP America, Inc.501 WestLake Park BoulevardHouston, Texas 77079Re: Dispersant Management Plan

In the wake of the recent failure of the Top Kill procedure, we mustmove forward withadditional plans to secure the Deepwater Horizon oil leak. We understand that BP has developeda LowerMarine Riser Package Cap (Top Cap) procedure which includes cutting portionsof theriser. Before suchan operationmay commence, however, I need from you a hydrocarbon anddispersantmanagement plan. Sucha plan must include detailed infonnation regarding yourintended use of dispersants during the transition from Top Kill to Top Cap, during the Top Capprocedure itself, and immediately following its completion. The plan must also take into accountthe need to minimize surface and subsurface application of dispersants pursuant to Addendum 3of the Dispersant Monitoring andAssessment Directive.

Separate and apart from this requirement, I seek your assurance that you are continuing anaggressive pursuit of alternate dispersants which will lower the risk ofharm to human life andour environment.Sincerely,! /dm"............. : ~ ( ( { ' ~... J\MES A. WATSON.Rear Admiral, U.S. Coast GuardFederal On-Scene Coordinator


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June 5,2010

RobertCOplPland Post2326.0 Shell LaneRobert, LA 70455

The p u r p o s ~ of this letter to outline improvements to theR'Ototox testingbeing conducted on two BPvessels. BP coID.J:ssione


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The implementation ofthe technical details outlined above will help to ensure higher quality Rototoxdata. I fyou have any questiohs. please do not hesitate to contact one of us.Sincerely.

.A. WatsOllRearA,dmiral.U. S. CoastGuardFederal On-SceneCoordinator

DirectorSuperfund DivisionU.S. EPA Region 6

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U.S. DepartmentHomeland SecurityUnited StatesCoast GuardMEMORANDUM

CommanderEighth Coast Guard District 500 Poydras StreetNew Orleans, LA 7013()..3310StaffSymbol; (drm)Phone: (504) 6712231Fax: (504) 671-2005

1660007 June 10Mr. Bill Goetzee, USCG504-671-2234From:

To:Subj:

J. E. Hanzalik. CAPT Reply toCGDEIGHT (dnn) Attn of:RRTVI CONSENSUSNETWORKPARTICIPANTSRRT CALL TO DISCUSS PROCEEDINGWITHADAY OF TRAGETEDAERIALDISPERSANTACTIVITYDUETO INABILITY TO SKIMORIN-SITUBURN

1. A request for a 15th overall Incident Specific convening of the RRT VI consensus trusteeswas made on behalfofRADM JamesA. Watson, the USCG FOSC for the on-going oil spillassociated with theTRANS-OCEANDEEP WATERHORIZON) incident thatbegan on 20APR 2010, where aMobile Off-Shore DrillingUnit (MOHU) located approximately 45-miles SEofVenice, Louisiana in the GulfofMexico suffered an uncontrolled blow-out, explosion, loss oflife, and subsequent sinking of the MODU. Thepurpose of this Incident Specific Convening ofthe RRT VI trustee agencies was to gain consensus to perform a one-day targeted application ofaerial dispersants in the ICP HoumaAOR, sinceweather conditions hadprecluded surface oilremoval my either mechanical skimming, or in-situ burning. A one-daywaiver to the cessation ofaerial dispersants was requested to gain back some lost ground that the gap in both skimming andin-situ burning has created with the goal to prevent shore-line impact created by the largerquantity of surface oil now presenting based on 06 JUN over-flight observations. The followingtrustees, RRTVImember agency representatives, consensus network participants, were presenton the Incident Specific Telephone Conference that began at 1030amL Central Time, Monday07 June 2010, but not limited to the following list:


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Subj: RRT CALL TO DISCUSS PROCEEDINGWITH ADAYOFTRAGETED AERIAL DISPERSANTACTIVITY DUE TO INABILITYTO SKJM OR IN-SITU BURN1660007 June 10

2. perfonned a role call and introduced the purpose of the incident specificconvemng ofthe RRT VI Trustee network and applicable stakeholders. Amemo for AdmiralWatson (FOSC) to sign approving a one-daywaiver to the currently discontinued surface aerialdispersantuse was submitted to RRT VI consensus trustees for concurrence (Enel. 1).As stated above, aerial over-flights on 06 June indicated a presence of dark high concentration oilthat had accumulated due to the (adverse weather caused gap) in conducting either surfaceskimming ops or in-situ burning. This requested one-day targeted aerial application is meant togain back the ground lost by inability to convene surface ops, and to prevent a greater shore-lineimpact that would result if surface application of dispersants to mitigate multiple reported slicksof fresh oil is not temporarily resumed for a requested one day period. The amountof surfaceapplication requested would not exceed 32,000 gallons for a period not to exceed 12 hours.3. LADEQ acknowledged that the greater accumulationof surface oil was caused by adverseweather creating a gap that precluded both surface skimming operations and in-situ burning.EPA stated concerns regarding if the weather wouldpreclude the required SMARTmonitoring,if aerial dispersant use was resumed. TIER I visualmonitoring, at a minimum would beavailable, but if consensus was achieved to conduct the orie-day targeted application, Tier i l lwould be requested and mandated as co-requisite. Additionally, in accordancewith previoussampling and monitoring directive, TIER i l l is required for surface dispersant application periods(Encl. 2). Note also (Encl. 3) Addendumm, that later directed the cessationof surface dispersantuse, unless on rare occasions it was deemed by FOSC as being required.4. Amotion was made byUSCGCo-Chair to solicit consensus for the one-day targeted aerialdisperSant application to reduce the larger surface oil footprint causedby the weather inducedgap in surfacemechanical recovery and in-situ burning. USCG Concurred with the use of aerial for one day, with required TIER i l lmonitoringimplemented as co-requisite. DOl concurredprovided thatmonitoringwas co-requisite. DOC concurred provided that monitoring was co-requisite. State (LOSCO and DEQ) abstained EPA would further vet the issue with their chain of command and return reply to CAPTHanzalik (USCGRRTVI Co-Chair via off-line phone call).

5. EPAimmediately following the RRT call submitted the following e-mail statement fromEPA Co-Chair to USCGCo-Chair: The justification identified as (Encl 1) for this RRT call #15.. . ''was received in accordance with the DispersantMonitoring andAssessment Directive Addendum 3. The Directive refers to "rare cases where there may have to be an exemption.!!BP is now requesting the exemption on a somewhat regular basis. Furthermore the writtenrequests being presented are becoming less and less specific, and do not include the specific

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Subj: RRT CALL TO DISCUSS PROCEEDINGWITH ADAY OFTRAGETED AERlAL DISPERSANTACTIVITY DUE TO INABILITYTO SKIM OR IN-SITU BURN1660007 June 10

requirements in theAddendum. As you know, there is a strong preference to mechanicalremoval technology. From the documents we are seeing, EPA cannot tell the extent to whichthese methods are considered, why they are not being used., and whenyou anticipate theywill beavailable. In short, the approval process appears to be somewhat pro forma, and not as rigorousas EPA desires. The Agency believes BP must provide much more robust explanations, andmust be put on notice that the request for exemptions cannot be presumed to be approved at thepoint they are submitted.Per our phone call justnow, dispersant application can proceed per the directive. EPA requestdocumentation thatmore clearly demonstrates the need for this exemption. While there is goodinformation in the current request, additional information is relevant to support compliance withthe directive. Specifically, the request should also cover:* Operational conditions thatmerit - e.g. weather, VOC levels in and around rig and supportingdata* Capacity issues that require it - e.g. lack of spotters, lack of skinuning vessels* Subsurface dispersant injection issues that contribute - e.g. stopped due to c ~ p p i n g of BOPtherefore increased oil was released to surface.* Tactical issues that require it - e.g. slick cannot be reached in time by sldm/burn vesselsbefore it weathers too much* Rational for why particular slicks were prioritized for dispersion rather thanmechanicalrecovery.* Monitoring - e.g. Type ofmonitoring thatwill be conducted; date/time SMART data whichdemonstrates effectiveness of applicationwill be provided."6. The above statement from EPA received via e-mail at 1303L Central 07 JUNE f r o ~_to CAPT James Hanzalik provides the conditional items marked by asterisk that fuci 'Iagency requires prior to consensus to proceed with the targeted aerial dispersant application.Other than State of Louisiana abstaining to an official decision, all other applicable resourcetrustee agencies concurredwith the conditional dispersant application via the requestedexemption based on weather precluding both skimrn.iilg operations and in-situ burning. Again,EPA requested that comprehensive details be provided to them for the asterisked items aboveprior to a decision ofconsensus or not byEPAto the requested exemption.7. The USCGCo-Chair has noted concerns regarding the process bywhich expeditedexemptions can be made in a time criticalmanner at the RRT level for an ongoing emergencyresponse. This will allow for mitigation of larger quantities of fresh dispensable surface oil whenweather precludes othermechanical or surface oil mitigation techniques. It should also be notedthat there is pre-approvallpreauthorization for the use of dispersants in this region lll1d thatsubsequent calls are not needed or required. Although the use ofdispersants for this event andthe amount of oil spilled is unprecedented, unprecedentedmeans to affect the outcome of thisresponse is needed to meet the unprecedented emergency spill response we are endeavoring to

3


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Subj; RRTCALL TODISCUSS PROCEEDINGWITII A DAY OFTRAGETEDAERIALDISPERSANTACTIVITYDUETO INABILITYTO SKIM OR INwsrru BURN1660007 June 10

mitigate. TheCo-Chair recommends that the FOSC "takewhatever additional response actionsare deemed appropriate to mitigate the substantial threat the public and the e n v i r o n m e n t . ~ ~

Encl (1) .MEMO to FOSC by BP requesting SurfaceDispersant Exception 07 JUNE 2010Encl (2) Dispersant Monitoring and Assessment Directive 09MAY 2010Encl (3) DispersantMonitoring and AssessmentDirectiveAddendum 3 (MAY 2010)

4


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U.S.08PBnxnentoo.Homeland SecurityUnited StatesCoast Guard

ChiefOperating OfficerExploration & ProductionBP America Inc.501 WestLake Park BoulevardHouston, Texas 77079

Federal On-Scene CoordinatorUnified Area COOlmand Unified Area CommandShell on Training center23260 Shell LaneRobert, LA 70455

16480June 8, 2010

I am in receipt of the document entitled GoM Drilling,Completions, and InterventionsMC252: Guidance on SubseaDispersant ApplicationOPS Note #3 whichaddresses your planfor use of subsea dispersants. As you know, under the third addendum to the DispersantMonitoring and Assessment Directive, use of subseadispersant in volumes greater than 15,000gallons per day requires my or the current Federal On-Scene Coordinator's approval. It is myunderstanding that your plan seeks to maximize the efficacyof subsea dispersant and allow forreductions in their use as the oil flow is reduced. With this in mind, your plan is approvedeffective immediately, subject to the following conditions unless otherwise directed:1. Continue to conduct requiredmonitoring and provide daily updates as to the results of theoperation.2. This approval shall continue through June 30, 2010.3. Submit a new plan for subsea dispersant use not later than three days prior to theexpiration of this approval.My Incident Commanders have suggested that the current dispersant use limitations presentsignificant and growing operational challenges to themanagement of this emergency response.Please provide me, within 48 hours, with any additional information that youhave regarding thisconcern including your assessment of dispersant toxicity, availability ofmechanical recoveryequipment (e.g., offshore and near shore skimmers) to keep pace with the current andpotentialrelease, and total insitu-burn capacity. Once I receive this information, I intend to consultwiththe Regional Response Team and my Incident Commanders to develop an effective operationalplan for use of surface and s u b ~ s u r f a c e dispersant while minimizing any environmental impact.


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I fyou have any questions concerning the content of this letter please contact CAPTRayPerry ormy Scientific Support Coordinator (SSC),Mr. Steve Lehmann located at the UAC inRobert, LA.

Sincerely,

~ / t : Y ~f\MES A. WATSONRear Admiral,U.S. CoastGuardFederal On-Scene Coordinator

2


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U.S. Department00.Homeland SecurityUnited StatesCoast Guard

Regional ResponseTeamFedeial Region VIRespected Members,

Federal On-Seene CoordinatorUnified Area Commend Unified Area command1250 Poydras StreetNewOrleans. LA 70113

June 22,2010

I received the attached letter from CAPT LaFerriere, the Houma IncidentCommander, andthe LouisianaOn-Scene Coordinator. I wholeheartedly endorse their letter,and request that you draft andpropose a new Addendum (to supersede Addendum 3) to addressthe dispersant approval process.

The new Addendum should incorporate a number of important principles. First, it should beconsistentwith the National ContingencyPlan, inwhich dispersant use is a response option thattheFOSC controls guidedby the pre-approval ofRegional Response Teams in consultation withthe National Response Team. Second, it should reflect the continued goal ofminimizingdispersantusewhen operationally feasible-I will not tolerate excessive useofdispersants whichprovides no real advantage in fighting this spill. Third, i t should in no way weaken the currentmonitoring and water samplingprogram currently in place. Fourth, it should empower incidentcommanders to make real-time decisions to use appropriate amounts ofdispersants-we cannotafford the delay inherent in seeking approval from above when the window ofopportunity isfrequently short. F,ifth, it should allow the use of dispersants to appropriately control volatileorganic compounds-we must protect the health and safety of the workers at or near the source.Finally, the newDirective should in no way condition the use of dispersants on receipt ofprecisedataregarding the capabilityofmechanical recoverymethods. While recovery by mechanicalmethods does r e d u c ~ the overall need to usedispersants, the success of those methods is subjectto an enormous number of constantly shifting variables-variables that will only increase ashurricane season adds new challenges.While the use ofdispersants in any amount involves a number of unknowns and risktradeoffs, we must keep in mindwhat we do know: that non-dispersed oil continues to damagethe environmentonshore and offshore in the GulfofMexico. Wemust employ all the tools atour disposal to fight it on all fronts.

Sincerely,. .C,.,.", . ' .

. " - ..' :AMES A. WATSON

........ '. Rear Admiral, U.s. CoastGuard.. Federal On-Scene Coordinator


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June 20, 2010

RADM James WatsonFederal On-Scene CoordinatorUnified Area Command1250 Poydras StreetNew Orleans, LA 70113AdmiralWatson:

Webelieve the time is right to reconsider the approval process for the use of surfacedispersants.As you know, on May 26, the EPA and the FOSe concurrently issued Addendum 3 to theDispersantMonitoring and Assessment Directive. That AddendlUll instituted strict limits on theapplication ofdispersants-limits which could be exceeded only by explicitFOSe approval afterconsideration of a number ofspecific factors.At the time Addendum 3was signed, estimates suggested that the oil flow into the Gulfwasapproximately 5,000 barrels per day. Current estimates from the Flow Rate Technical Group,

however, suggest the number is in the rangeof35,000-60,000 barrels perday-roughly 7 to 12times the rate previously thought. In light of the challenges presented by this marked increase inflow rate estimates, we are convinced that the dispersant approval process must be reexamined.In particular, we believe the current process hinders our ability to adequately respond to varyingoperational conditions. Whilewe expect that you will continue to set broad policy guidelines,incident commands mustbe able to exercisediscretion to make real-time decisions as todispersant application.Therefore, we believe theRRT should draft arid propose to you anew Addendum (tosupersedeAddendum 3) to address the dispersant approval process.

Captain, U.S. Coast GuardFederal On-Scene Coordinator's RepresentativeByDirection

oU1S1ana Coastal Protection &Restoration AuthorityState On-Scene Coordinator


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FW: Aerial dispersant target

From:Sent: 28 May 2010 14:06To: _Subject: FW: Aerial dispersant target

Sent with Good (www.good.com)

----Original Message----From: Hanzalik, James CAPTSent: Friday, May 28, 2010 03:02 PM Eastern Standard TimeTo: Landry, Mary RADMCc: Watson, James RADMSubject: Aerial dispersant ta rge tMa'am.FYI I gave BP the go ahead to hit an oil target offshore with dispersants IAW the directive.VIR.JamesSent with Good (www.good.com)

28/05/2010

Page 1 of 1


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DispersantMonitoringand ASsessment D i r e e t i ~ e - Addendum 3

Reduction in Use of Dispersants. BP shall implementmeasures to limit the total amountof surface and subsurfacedispersant appfl!3d each day to the minimum amount possible. BP shall estabrlSh an overall goal of reducingdispersant application by 75% from the maximum daily amount used as follows:

a. Surface Application. BP shall eliminate the surface application ofdispersants. in rare cases when theremay have to be an exemption, BP must make a request in writing to the rose providingjustrflcation which willinclude the volume, weather conditions. mechanical or means for removal that were considered and the reason theywere not used, and otherrelevant information to justify the use of surface application. The rose must approve therequest and volume of dispersant prior to Initiating surface application.

b. SUbsurface APplication. BP shall be limited to a maximum subsurface application of dispersantof notmore than 15,000gallons in a single calendar day.Application of dispersant in amounts greater than specified in thisAddendum 3 shall be in such amounts, on such

day{s) and for such application (surface or subsurface) only as specifically approved in writing by the USCG federalOn-Scene COordinator (FOSC).

Date: G/U /2..01 \?-r I

~ - ~Mary E. landryRear Admiral, USCGIre orSuperfund DivisionU.S. EPA Region 6Dallas, TX 75202

Date: 5:/ /J....'O ( aI I


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Surface dispersant application Approval

Easley, MaxFrom:Sent: 29 May 201010:21To: Easley, MaxCo: Landry, Mary RADM; Watson, James RADMSUbject: Surface dispersant application Approval

Page 1 of 1

Your request to conduct aerial dispersant operations for dispersable oil 30miles off shore is approved. In addition, yourrequest to apply vessel disperant ops for the health andsafety reasons at the source is also approved. These operations havebeenverbally approvedbyRADM Landry.CAPTJamesHanzalik:Robert, UAC

Sent withGood (www.goodcom)

29/05/2010


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Dispersant Monitoring and Assessment Directive- Addendum 3

Reduction in Use of Dispersants. BP shall implement measures to l imit the total amountof surface and subsurfacedispersant applied each day to the minimumamount possible. BP shall establish an overall goal of reducingdispersant application by 75% from the maximum daily amount used as follows:

a. Surface Application. BP shall eliminate the surface application of dispersants. In rare cases when theremay have to be an exemption. BP mustmake a request in writing to the FOSC providingjuStification whichwillinclude the volume, weather conditions, mechanical or means fo r removal that were considered and th e reason theywere no t used, and other relevant information to justify the use of surface application. The FOSC must approve therequest and volume of dispersant prior to lnftiating surface application.

b. SubsurfaceApplication. BP shall be limited to a maximum subsurface application of dispersant of no tmore than 15,000 gallons in a single calendar day.Application of dispersant in amountsgreaterthan specified in this Addendum 3 shall be in such amounts, on suchday(s) and for such application (surface or subsurface) only as specifically approved in writing by the USCG FederalOn-Scene Coordinator (FOSC).

~ - ~Mary E. LandryRear Admiral, USCGFlrector

Superfund DivisionU.S. EPA Region 6Dallas, TX 75202

Date: / , : ) 1 J - ~ / 2 . .0 ( 0

Date: G/U/ZOIt::Jr J


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*0 Daily Dispersant Application (Gallons)Q.lfitQ.l ..... tv W .po. 01 0> "-J co(J) p 0 0 , 0 0 0 0 0S- o 0 a 0 0 0 0 '001. 0 0 0 0 0 0 0 00 0 0 0 0 0 0 0 0"N I00 4/21tvtv CJ0 Q) 4/230 -


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James A. WatsonRear Admiral, USCGFederal On-Scene CoordinatorJune 8,2010

DearAdmiral Watson:In compliance with the May 26, 2010; Dispersant Monitoring and Assessment Directive Addendum 3 (the "Directive"), the Houma Unified Command has eliminated the surfaceapplication of dispersants, except in cases where an exemption is requested andjustified, and approved by the Federal On-Scene Coordinator.Houma Unified Command has six (6) spotter visual reports from 7 June of multiple slicksof dispersible oil (Attachment 1) and the NOAA Surface Oil Forecast for 8 June showsextensive areas of heavy and medium oil (Attachment 2). Weather forecast indicatesexcellent flying weather with Winds of 5-8 knots, ceilings unlimited and visibility 10 nm.Houma Unified Command anticipates that, due to the weather, location, distribution(5,400 sqmi) and size of the mUltiple oil slicks identified (290 sqmi), the use of mechanicalrecovery and ISB to' recover or remove the oil in the target area will be insufficient toremove the spill volume on June 8, 2010. Prior to spray operations the spotter aircraftwill identify the highest value targeted slicks and will direct spray aircraft to the heaviestportions of the slick.Further data to underpin this request is as follows: The physical dimensions of identified targets proposed are included in Table A andgiven in approximate acreage and average length and width perimeterdimensions. The use of mechanical recovery to recover or remove the oil in the identifiedtarget areas will be insufficient to remove the estimated dispersible oil volumesthat we have estimated for June 8, 2010. The targeted oil herein is dispersible oiland dispersible oil is not the only oil demanding mechanical recovery assets. Thegeographic area of the spill site contains a combination of dispersible oil, heavysheens and emulsified oil. Mechanical recovery devices are required elsewherein the entire geographic area to address aU areas and all oils that can be recoveredmechanically and not just the dispersible oils. The amount of oil located today andshown herein, will require alternative response methods to be employed in orderto minimize potential shoreline and wildlife impact.


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Rear Admiral James A. WatsonJune 8, 2010Page 2

A daily summation of skimmers in the source area and outside the source will beprovided to the Aerial Dispersant Group for insertion in this report. Skimmingresources outside of the source area are not available for this request but will bemade available for any future requests.Skimming Resources within the source area.

It is our understanding that it has been agreed within the RRT that going forwardwith SMART Tier II & III will no longer be required. What has been accepted inlieu of these' activities is the Surface Water Sampling Plan for DispersantApplication M o n i t o r i n g ~ ; Version 1, approved on June 3, 2010 by _ _Environmental Unit Leader; _ _ BP IC,Captain Merideth, FOSC. T ~ t h i s p l a n ~ n t and OSRpersonnel who will be onboard our vessel as our science team. Accommodationswill be available for two Federal representatives who will act as observers whilethe science team implements the aforementioned plan. The intended vessel willbe the International Peace OP}. It is not anticipated that the IP will be performingsampling/monitoring for each application of dispersant nor for the full track of thespray applied, but a representative sampling will be accomplished. Please notethe IP is currently in dry dock for repairs. We anticipate her returning to service onJune 9th to recommence her science duties.

Accordingly, in accordance with the Directive, Houma Unified Command respectfullyrequests an exemption to apply EC9500A in volumes on oil slicks located today shown inTable 1 not to exceed 32,000 gallons for a period not to exceed 12 hours.Sincerely,

Houma Unified Command


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Exemption approved subject to the above:

ames A. WatsonRear Admiral, USCGFederal On-Scene Coordinator

Date: 8: .jUn. 10


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Rear Admiral James A. WatsonJune 8,20'0Page 4 IAttachment 1

for 8 June 2010 with Oil Ta

TABLE 1DISPERSffiLEOIL REPORT

(June 7, 2010)Targeted Estimated Estimated Dispersant Dispersant DifferenceOil Slick Dimensions Area (sq.mi) Needed Requestedin Miles (1120 DOR)Priority 1 1 10X5 50 80,000 6,000 74,000Priority 2 2 20X6 120 192,000 26,000 166,000Priority 3 3 12X3 36 90,000 90,000Priority 4 4 14X6 84 134,000 134,000Total NA 290 496,000 32,000 464,000

Note: The above Table 1 shows our intentions based upon our observations the day before theseactions take place. Size and location of slicks will change. Activities within slicks, e.g.,skimming operations, i n ~ s i t u burning, etc., or weather conditions may require revisions to theactual operational plan implemented.


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James A. Watson L/Rear Admiral, USCGFederal On-Scene O:il Inatortv /J U ~ 0 1 0

\0 .

Dear Admiral Watson:In compliance with the May 26, 2010, Dispersant Monitoring and Assessment Directive Addendum 3 (the "Directive"), Houma Unified Command has eliminated the surfaceapplication of dispersants, except in cases where an exemption is requested andjustified, and approved by the Federal On-Scene Coordinator.Houma Unified Command has ten (10) spotter visual reports from 9 June of mUltipleslicks of dispersible oil (Attachment 1) and the NOAA Surface Oil Forecast for 10 Juneshows e>


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. Rear Admiral James A. vv'atsonJune 9,2010Page 2

Tabulation of number of assets (skimmers, etc.) in service today and how manyassets are available yet not in service: A daily summation of skimmers in the


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Rear Admiral James A WatsonJune 9, 2010Page 3

Offshore Federal Skimming Resources

.....- --.. . . , ;;, "'"""-I : : ~ ~ - ..........ap . . . . , 1. . . . , , ;_ .. _ _ _........... """... --- - lam.......n::,:,=:.:--- .......... 1-"",,_ ......._-"'-'_ ........a ~ . . . - : A m ...... _O P .... ....- 1-...r"""-.;,;,l2'IIl1lP*'- ........,...-:.._-_ _ IW : 1.........- - ......_-eq...,-- . . . . . . . . .G>""'" ---- ___


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Rear Admiral James A vv'atsonJune 9,2010Page 4

sampling will be accomplished. The IP commenced operations this date and is currentlyengaged in near shore activities.Accordingly, in accordance with the Directive, Houma Unified Command respectfullyrequests an e x e m p t i ~ ~ ! o ~ p l y EC9500A in volumes on oil slicks located today shown inTable 1 not to e x c e e d ~ u O gallons for a period not to exceed 12 hours.Sincerely, '2,..' I t7 It 0'



, ames A. WatsonRear Admiral. USCGFederal On-Scene Coordinator

Date:


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RearAdmirat James A WatsonJune 9, 2010Page 5 I~ t t a C h m . e n t 1

Dispersant Zone Map for 9 June 2010 with Oil Targets fromS otterOerations this Date

TABLEtDISPERSffiLEOIL REPORT(June 9, 2OIG)

Targeted Estimated Estimated Dispersant Dispersant DifferenceOil Slick Dimensions Area (sq.m.i) Needed Requestedin Miles (1/20 DOR)Priority 1 1 21X3 16 133,000 6,000 127,000Priority 2 2 7X2 14 2,000 2,000 Priority3 3 17X4 24 28,000 24,000 4,0.00

Prioritv4 4 21X6 126 200,000 0 200,000Total NA 180 363,000 32,000 332,000Note: The above Table 1 shows our intentions based upon our observations the day before theseactions take place. Size and location of slicks will change. Activities within slicks, e.g.,skimming operations, in-situ burning, etc., or weather conditions may require revisions to theactual operational plan implemented.


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James A. WatsonRear Admiral, USCGFederal OnwScene CoordinatorJune 10, 2010

Dear Admiral Watson:In compliance with the May 26, 2010, Dispersant Monitoring and Assessment Directive Addendum 3 (the "Directive"), Houma Unified Command has eliminated the surfaceapplication of dispersants, except in cases where an exemption is requested andjustified. and approved by the Federal On-Scene Coordinator.Houma Unified Command has twelve (12) spotter visual reports from 10 June of multipleslicks of dispersible oil (Attachment 1) and the NOAA Surface Oil Forecast for 11 Juneshows extensive areas of heavy and medium oil (Attachment 2). Weather forecastindicates excellent flying weather with winds of 8--10 knots, wave height 1.5'-2.5',ceilings unlimited and visibility 10 nm.Houma Unified Command anticipates that, due to the weather, location, distribution(7,200 sqmi) and size of the multiple oil slicks'identified (42 sqmi), the use of mechanicalrecovery and ISB to recover or remove the oil in the target area will be insufficient toremove the spill volume on June 11, 2010. Prior to spray operations the spotter aircraftwill identify the highest value targeted slicks and will direct seray aircraft to the heaviestportions of the slick.Pursuant to a request this date from Unified Area Command, the following information isprovided.

Include physical dimensions of identified targets proposed: this information isincluded in Table 1 and given in approximate acreage and average length andwidth perimeter dimensions. Explicit justification for why these targets can't be skimmed or addressed byother mechanical means: The use of mechanical recovery to recover or removethe oil in the identified target areas will be insufficient to remove the estimated

dispersible oil volumes that we have estimated for tomorrow. The targeted oilherein is dispersible oil and. dispersible oil is not the only oil demandingmechanical recovery assets. The geographic area of the spill site contains acombination of dispersible oil, heavy sheens and emulsified oil. Mechanicalrecovery devices are required elsewhere in the entire geographic area to addressall areas and all oils that can be recovered mechanically and not just thedispersible oils and are therefore otherwise engaged.


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Rear Admiral James A. WatsonJune 10,2010Page 2

Tabulation of number of assets (skimmers, etc.) in service today and how manyassets are available yet not in service: A daily summation of skimmers in thesource area and outside the source is now being provided daily to the AerialDispersant Group for insertion in this report. Our review of the assets listedbelow reveal that they are engaged in skimming operations with some out ofservice for various reasons.Offshore Skimming Resources

c....nR.....,. I"L.tts t-"l"IHP.. s. 'lHItuBro raM huttl.i& s. .. .,.; 8 JI ' J.. P.r, St.... t l u ~ .. s. An I0 Oa,tr,.S"hct.. ,\ lolA. s. I A.. Y....ic.B ...l .\i.1. lit! b.ioIl:tI S. . V,+JoU:

" IV ...... HM;CR....," s. y " MW ttrW tot CR ..,u S - 11.111; '" ... 1! 80 e.....c .... I"."" .", I R ... i SOl'1"'4.'S." , .. ,


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EOr 0'" '.",e . r.- m.l'l"

It is planned to conduct multiple Tier 1 helicopter overflights to observe dispersantoperations. Additionally the MN International Peace will conduct water chemistry andtoxicology sampling. All depending upon approval to apply dispersants.

Accordingly, in accordance with Directive, Houma Unified Command respectfullyrequests an exemption to apply EC9500A in volumes on oil slicks located today shown inTable 1 not to exceed 15,300 gallons for a period not to exceed 12 hours.Sincerely,



ames A. WatsonRear Admiral, USCGFederal On-Scene Coordinator

Date: -.J


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Rear Admiral James A. WatsonJune 10,2010Page 4 IAttachment 1I A

Dispersant ZoneMap for 11 June 2010witbOil Targets from Spotter Operations 10 June! ". :

TABLE 1" ...Dispersable Oil ReportJune 10, 2010Estimated Estimated Dispersant Dispersant DifferenceDimensions Area (sq.mi) Needed RequestedinMiles (1/20 DOR)Priority 1 4x6 24 38,400 21,000 17,400 .Priority 2 4x4 16 25,600 12,000 13,600Priority 3 2x1 2 3,200 3,200 0

Total 42 67,200 36,200 31,000.. ..

Note: Table 1 shows our intentions based upon our observations the day before these actionstake place. Size and location of slicks will change. Activities within slicks, e.g., skimmingoperations, in-situ burning, etc., or weather conditions may require revisions to the actualoperational plan implemented.


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James A. WatsonRear Admirat USCGFederal On-Scene CoordinatorJune 11, 2010

DearAdmiralWatson:In compliance with the May 26,2010, DispersantMonitoring and Assessment Directive HAddendum 3 (the " D i r e c t i v e ~ ' ) , Houma Unified Command has eliminated the surfaceapplication of dispersants. except in cases where an exemption is requested and justified;and approved by the Federal On-Scene Coordinator.Houma UnifiedCommaIid requests that theMN International Peace be permitted to spraydispersantwith its boat spray application systemon targeted oil slicks. The purpose of thisdispersant application program is to: Collect samples pre and post d i ~ r s a n t application to assess dispersanteffectiveness. subsurface dispeisant plume characteristics and to generate

data which can be used to assess environmental and safety issues. Conduct toxicity testing at multiple depths according to the Surface WaterSampling Plan for DispersantApplicationMonitoring approved by HoumaUC on June 3,2010. Evaluate the effectiveness ofapplYing dispersants to emulsified oil asrecommended by SINTEF.

Conducting a sampling and monitoring plan to assess the extentof the 3D area aftermultiple applications of dispersant at the sur.fuce was recommended by the assembledeXPerts in theDeepwaterHorizon Dispersant Use Meeting Report datedMay 26-27, 2010.In conducting this vitalmonitoring e f f o ~ theMN International Peace will work closelywith spotteraircraft to identify appropriate spill targets for application by the boat spraysystem. The MN International Peace will alsoworkwith aerial spray assets for theacquisition of data following aerial application.Two federal observers were requested. by theNOAASSC (at request ofRR.1) to be onboard(twoUSCGStrikeTeammembers are currently assigned to thevessel).Accordingly. in accordance with the Directive. Houma Unified Command respectfullyrequests an exemption to apply EC9500A on targeted oil slicks using the boat spray systemin volumes of approximately 50 gallons per test for a total amountnot to exceed 500 gallonsfor a period not to exceed 14 days.


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Sincerely,



l es A. WatsonJ ear Admiral,. USCG/ Federal On-Scene Coordinator


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James A. WatsonRear Admiral, USCGFederal On-Scene CoordinatorJune11,2010

DearAdmiral Watson:In compliance with the May 26, 2010, Dispersant Monitoring and Assessment Directive Addendum 3 (the "Directive"), Houma Unified Command has eliminated the surfaceapplication of dispersants, except in cases where an exemption is requested and justified,and approved by the Federal On-Scene Coordinator. .HoumaUnified Command requests that theMN InternationalPeace bepermitted to spraydispersant with its boat spray application system on targeted oil slicks. The purpose of thisdispersant application program is to: Collect samples pre and post dispersant application to asSess dispersanteffectiveness, subsurface dispersant plumecharacteristics and to generatedata which can be usedto assess environmental and safety issues. Conduct toxicity testing at multiple depths according to theSurface WaterSampling Plan for DispersantApplicationMonitoring approved byHoumaUC on June 3, 2010. Evaluate the effectiveness of applying dispersants to emulsified oil asrecommended by SINTE;F.

Conducting a sampling and monitoring plan to assess the extent of the 3D area aftermultiple applications of dispersant at the surface was recommended by the assembledexperts in the Deepwater Horizon Dispersant Use Meeting Report dated May 26-27, 2010.In conducting this vital monitoring effort, the MIV InternationalPeace willwork closelywith spotter aircraft to identify appropriate spill targets for application by theboat spraysystem. TheMN International Peace will alsoworkwith aerial spray assets for theacquisition of data following aerial application.Two federal observers were requested by the NOAA SSC (at request ofRRT) to be onboard(twoUSCG Strike Team members are currently assigned to the vessel).Accordingly, in accordance with the Directive, Houma Unified Command respectfullyrequests an exemption to apply EC9500A on targeted oil slicks using tlle boat spray systemin volumes of approximately 50 gallons per test for a total amount not to exceed 500 gallonsfor a period not to exceed 14 days.


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Sincerely,HoumaUnified Conunand


James A. WatsonRearAdmiral, USCGFederal On-Scene Coordinator

Date: (;, ..... IS- v I ()


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James A WatsonRear Admiral, USCGFederal On-Scene CoordinatorJune 11 2010

Dear Admiral Watson:In compliance with the May 26, 2010, Dispersant Monitoring and Assessment Directive Addendum 3 (the "Directive"), Houma Unified Command has eliminated the surfaceapplication of dispersants, except in cases where an exemption is requested andjustified, and approved by the Federal On-Scene Coordinator.Houma Unified Command has eleven (11) spotter visual reports from 11 June of multipleslicks of dispersible oil (Attachment 1) and the NOAA Surface Oil Forecast for 12 Juneshows extensive areas of heavy and medium oil (Attachment 2). Weather forecastindicates excellent flying weather with winds of 5-13 knots, wave height 2-3 feet, ceilingsunlimited and visibility 10 nm.Houma Unified Command anticipates that, due to the weather, location, distribution(2,700 sqmi) and size of the multiple oil slicks identified (34 sqmi), the use of mechanicalrecovery and IS8 to recover or remove the oil in the target area will be insufficient toremove tne spill volume on June 12, 2010. Prior to sprayoperations the spotter aircraftwifl identify the highest value targeted slicks and will direct spray aircraft to the heaviestportions of the slick.Pursuant to a request this date from Unified Command, the following information isprovided.

Include physical dimensions of identified targets proposed: this information isincluded in Table 1 and given in approximate acreage and average length andwidth perimeter dimensions:

Explicit justification fo r why these targets can't be skimmed or addressed byother mechanical,means: The use of mechanical recovery to recover or removethe oil in the identified target areas will be insufficient to remove the estimateddispersible oil volumes that we have estimated for tomorrow. The targeted oilherein is dispersible oil and dispersible oil is not the only oil demandingmechanical recovery assets. The geographic area of the spill site contains acombination of dispersible oil, heavy sheens and emulsified oil. Mechanicalrecovery devices are required elsewhere in the entire geographic area to addressall areas and all oils that can be recovered mechanically and not just thedispersible oils and are therefore otherwise engaged.


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Sincerely,


Tabulation of number of assets (skimmers, etc.l in service today and how manyassets are avaifable yet not in service: A daily summation of skimmers in thesource area and outside the source is now being provided daily to the AerialDispersant Group for insertion in this report (Attachment 3). Our review of theassets listed below reveal that they are engaged in skimming operations withsome out of service for various reasons. It is planned to conduct multiple Tier 1 helicopter overflights to observe dispersantoperations. Additionally the MN Intemational Peace will conduct water chemistryand toxicology sampling. All depending upon approval to apply dispersants.

Accordingly, in accordance with the Directive, the Houma Unified Command respectfuUyrequests an exemption to apply EC9500A in volumes on oil slicks located today shown inTable 1 not to e x c e e d ~ g a n 6 n s for a period not to exceed 12 hours.7,(900



J mes A. WatsonearAdmiral, USCGFederal On-Scene Coordinator


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James A. WatsonRear Admiral, USCGFederal On-Scene CoordinatorJune 12, 2010

Dear Admiral Watson:In compliance with the May 26, 2010, Dispersant Monitoring and AssessmentDirectiveAddendum 3 (the "Directive"), Houma Unified Command has eliminated the surfaceapplication of dispersants, except in cases where an exemption is requested andjustified, and approved by the Federal OrrScene Coordinator.Houma Unified Command has ten (10) spotter visual reports from 12 June of multipleslicks of dispersible oil (Attachment 1) and the NOAA Surface Oil Forecast for 13Juneshows extensive areas of heavy and medium oil (Attachment 2). Weather forecastindicates excellent flying weather with winds of 5-9 knots, wave height 2 feet, ceilingsunlimited and visibility 100m.Houma Unified Command anticipates that, due to the weather, location, distribution(3,600 sqmi) and size of the multiple oil slicks identified the use of mechanical recoveryand IS8 to recover or remove the oil in the target area will be insufficient to remove thespill volume on June 13, 2010. Prior to spray operations the spotter aircraft will identifythe highest value targeted slicks and will direct spray aircraft to the heaviest portions ofthe slick.Pursuant to a request this date from Unified Command, the following information isprovided.

Estimated size of identified dispersible oil slick targets proposed in designatedzones: this information is included in Table 1with the estimate of the amount ofdispersant needed to treat these slicks. Explicit justification for why these targets can't be skimmed or addressed byother mechanical means; The use of mechanical recovery to recover or removethe oil in the identified target areas will be insufficient to remove the estimated

dispersible oil volumes that we have estimated for tomorrow. The targeted oilherein is dispersible oil and dispersible oil is not the only oil demandingmechanical recovery assets, The geographic area of the spill site contains acombination of dispersible oil, heavy sheens and emulsified oil. Mechanicalrecovery devices are required elsewhere throughout the entire geographic area toaddress all a re as and all oils that can be recovered mechanically and not just thedispersible o ils an d are therefore otherwise engaged. Generally the skimmingvessels are concentrated near the source site so that they can remain in the


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Rear Admiral James A WatsonJune 12. 2010Page 2

heaviest oil and collect the highest volume of oil. Other skimming assets aredeployed nearshore to recover oil before it comes ashore.

Tabulation of number of assets. (skimmers, etc.) in service today and how manyassets are available yet not in service: A daily summation of skimmers in thesource area and outside the source is now being provided daily to the AerialDispersant Group for insertion in this report (Attachment 3). Our review of theassets l isted below reveal that they are engaged in skimming operations withsome out of service for various reasons. It is planned to conduct multiple Tier 1 helicopter SMART overflights to observedispersant operations. Additionally, the MN International Peace is planned toconduct water chemistry and toxicology sampling. These operations dependupon approval to apply dispersants either aerial or with boat spray systems

onboard the MN International Peace.Accordingly, in accordance with the Directive, the Houma Unified Command respectfullyrequests an exemption to apply EC9500A in volumes on oil slicks located today shown inTable 1 not to exceed 36,000 gallons for a period not to exceed 12 hours.Sincerely,



Date: ( , LI :$ /1 0ames A WatsonRear Admiral, USCGFederal On-Scene Coordinator


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Rear Admiral James A WatsonJune 12,2010Page 3 IAttachment 1

Dispersant ZoneMap for 13 June 2010with Oil Targets from Spotter Operations 12 June

'NVSN Ao.

.

TABLE 1 Dispersible Oil Report June 11, 2010Zone EstimatedArea Estimated percentage Dispersant Needed(sq.mi) dispersible oil (1/20DOR)Priority l- AC 900 1 28.800Priority 2 AM 900 0.2 5.760Priority 3 AB 900 0.05 1,440

Total 36.000Note: Table 1 shows our intentions based upon our observations the day before these actionstake place. Size and location of slicks will change. Activities within slick areas e.g., skimmingoperations, in-situ burning, etc., or weather conditions may require revisions to the actualoperational plan implemented.


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RearAdmiral James A. WatsonJune 12, 2010Page 5

Offshore Skimming ResourcesIAttachment 3


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Rear Admiral James A WatsonJune 12, 2010Page 6


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James A. WatsonRear Admiral, USCGFederal On-Scene CoordinatorJune 13, 2010

Dear Admira! Watson:In compliance with the May 26, 2010, Dispersant Monitoring and Assessment Directive-Addendum ,3 (the "Directive"), Houma Unified Command has eliminated the surfaceapplication of dispersants, except in cases where an exemption is requested andjustified, and approved by the Federal On-Scene Coordinator.Houma Unified Command has ten (10) spotter visual reports from 13 June of multipleslicks of dispersible oil (Attachment 1) and the NOAA Surface Oil F o r e c a ~ t for 14 Juneshows extensive areas of heavy and medium oil (Attachment 2). Weather forecastindicates excellent flying weather with winds pf 5-10 knots, wave height 1-2 feet, ceilingsunlimited and visibility 10 nm.Houma Unified Command anticipates that, due to the weather, location, distribution{3 t600 sqmi} 'and size of the multiple oil slicks identified the use of mechanical recoveryand IS8 to recover or remove the oil in the target area will be insufficient to remove thespirt volume on June 14, 2010. Prior to spray operations the spotter aircraft will identifythe highest value targeted slicks and will direct spray aircraft to the heaviest portions ofthe slick.Pursuant to a request this date from Unified Command, the fol lowing information isprovided.

Estimated size of identif ied dispersible oil slick targets proposed in designatedzones: this information is included in Table 1 with the estimate of the amount ofdispersant needed to treat these slicks. ' Explicit justification for why these targets can't be skimmed or addressed byother mechanical means: The use of mechanical recovery to recover or removethe oil in the identified target areas will be insufficient to remove the estimated

dispersible oil volumes that we have estimated for tomorrow. The targeted oilherein is dispersible oil and dispersible oil is not the only 'oil demandingmechanical recovery assets. The geographic area of the spill site contains acombination of dispersible oil, heavy sheens and emulsif ied oil. Mechanicalrecovery devices are required elsewhere throughout the entire geographic area toaddress all areas and an oils that can be recovered mechanically and not just thedispersible oils and are therefore otherwise engaged. Generally the skimmingvessels are concentrated near the source site so that they can remain in the


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Sincerely,

Rear Admiral James A WatsonJune 13, 2010Page 2heaviest oil and coHect the highest volume of oil. Other skimming assets aredeployed nearshore to recover oil before it comes ashore.

Tabulation of number of assets (skimmers, etc.) in service today and how manyassets are available yet not in service: A daily summation of skimmers in thesource area and outside the source is now being provided daily to the AerialDispersant Group for insertion in this report (Attachment 3). Our review of theassets listed below reveal that they are engaged in skimming operations withsome out of service for various reasons.- It is planned to 'conduct multiple Tier 1 helicopter SMART overflights to observedispersant operations. Additionally, the MN International Peace is planned toconduct water chemistry and toxicology sampling. These operations dependupon approval to apply dispersants either aerial or with boat spray systems

onboard the MN International Peace.Accordingly, in accordance with the Directive, the Houma Unified Command respectfullyrequests an exemption to apply EC9500A in volumes on oil slicks located today shown inTable 1 not to exceed ~ g a l l o n s for a period not to exceed 12 hours.\1 feet>I



ames A WatsonRear Admiral, USCGFederal On-Scene Coordinator


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Rear Admiral James A. WatsonJune 13,2010Page 3 IAttachment 1

Dispersant Zone Map for 14 June 2010with Oil Targets from Spotter Operations 13 Junew ..Jeans

29NMe x

13 2010TABLE 1'bI 0'1 R JD'lspersl e 1 eport une ,Zone Estimated Area Estimated percentage DispersantNeeded(sq.mi) dispersible oil (1120 DOR)Priority 1 AC 900 1 28,800Priority 2 AM 900 0.3 8,640Priority 3 AB 900 0.05 1,440Total 2,700 38,880

Note: Table 1 shows our intentions based upon our observations the day before these actionstake place. Size and location of slicks will change. Activities within slick areas e.g., skimmingoperations, in-situ burning, etc., or weather conditions may require revisions to the actualoperational plan implemented.


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Offshore Skimming ResourcesIAttachment 3

crew: u.s. coast guard (uscg): regarding bp oil spill: 1/26/11 - dispersant monitoring an4...

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