RRT VI Structure• Standing RRT

• Standing Committees– Preparedness– Response– S & T Committee

– Industry

• Incident Specific RRT

2

Regional Response Teams(RRTs)

• 13 RRTs comprised of 15 Federal agencies plus State representatives

• Co-chaired by EPA and USCG

• Engage in planning and training activities year-round

• Coordinate decision making process for alternative cleanup operations

AlaskaAlaska

XVIII

IX VII

VI

V

IV

III

III

CaribbeanCaribbean

• Provide technical expertise and resources to the OSC during a response

OceaniaOceania

RRT STANDING AGENCY BODY

Alternate Response TechnologiesEvaluated at RRT Level

• Dispersants• In Situ Burns• Surface Washing Agents• Bioremediation Agents

– Bioremediation Agents– Natural Sorbents

• Solidifiers

ESA, EFH Consultations

Historic Properties

Specialist

(Reports Directly to FOSC at UAC)

Historic PropertiesSpecialist’s Rep.

Historic PropertiesSpecialist’s Rep.

ICP

Historic PropertiesSpecialist’ Rep.

ICP

Tribal Consultation Coordinator

ICP

Structure of Section 106 Response Approved 6/24/2010

Houma Mobile Miami

Tribal Liaison

GIS Data Tech

Tribal Liaison

GIS Data Tech

Traditional CulturalProperties Ethnographer

Traditional CulturalProperties Ethnographer

Tribal Liaison

SHPO Liaison (2)

GIS Data Tech

Traditional CulturalProperties Ethnographer

Archeology Crew Chief (3)

Federal or Federal Contracted (20)Responsible Party Contracted (78)

Archeology Crew Members (15)

Archeology Crew Members (23)

Archeology Crew Members (18)

Archeology Crew Chief (4)

Archeology Crew Chief (5)

SHPO Liaison (2) SHPO Liaison (2)

Administrative Support (1) Administrative Support (2) Administrative Support (1)

Historic Architect

Architectural Conservator

Historic Architect

Architectural Conservator

Historic Architect

Architectural Conservator

Historic Properties Specialist

Archeology Crew Chief

1 per 5 Crew Members

Archeology Crew Members

Cultural Resource Management Structure for Each ICP

Incident: Deepwater Horizon Accepted Structure of Section 106 Response

Tribal Liaison

SHPO Liaison

SHPO Liaison

TCP Ethnographer

GIS Data Tech

Admin. Asst. Historic Architect

Architectural Conservator

Administrative Support

Federal or Federal Contracted

Responsible Party Contracted

Louisiana SOSC Authority for Oil Related Coastal Spill Response Issues

Louisiana SOSC Authority

Office of Coastal Protection And RestorationLouisiana Oil Spill Coordinators OfficeDepartment of Natural ResourcesDepartment of Environmental QualityDepartment of Wildlife and Fisheries

Louisiana NRDA Trustees

• 40 CFR 300.180 - State and local participation in response.• • (a) Each state governor is requested to designate one state

office/representative to represent the state on the appropriate RRT. The state's office/representative may participate fully in all activities of the appropriate RRT. Each state governor is also requested to designate a lead state agency that will direct state-lead response operations.

• • This agency is responsible for designating the lead state

response official for federal and/or state-lead response actions, and coordinating/communicating with any other state agencies, as appropriate...

Inter-Regional RRT Coordination of Alternate Response Technologies

Jurisdictional Boundaries- Region VI

EPA

SECTORCORPUS CHRISTI

SECTORNEW

ORLEANS

SECTORHOUS-GALV

MSUMORGAN

CITY

MSUPORT ARTHUR

SECTOR

HOUSTON-GALV

Jurisdictional Boundaries - Region IV

SECTORMOBILE

SECTORNEW ORLEANS

EPA

SECTORMIAMI

SECTORST. PETE

SECTORJACKSONVILLE

Cross –Regional CoordinationAlternate Response Technology

RRT VI RRT IV

Dispersant Pre-Auth Zone Yes – Pre Auth Plan

Yes – Pre Auth Plan

In Sutu Burn Policy Yes – Pre Auth Plan Yes – Pre Auth Plan

Surface Washing Agents Policy-Yes: But No Pre-Auth Zones identified in Region VI ACPs

Incident Specific RRT Decision

Solidifiers Policy Draft Limited Pre-Auth Yes: Limited Pre-Auth provided all recovered similar to sorbent requirements

Bioremediation Policy Guidance Document Yes

RPFOSC

Responsible Party

ACTIVATE GST & SMART PROTOCOL

Dispersant Asset on STBY

Original Dispersant Pre-Auth Consults

Request

Targetsproposed

TargetsJustified?

ICC developsbriefing package

for FOSCNLT: 1800 CDT

FOSCEPA-6/RA

STOP

Justification NO

NO

YES

WeatherSkimmer availabilityISB not practical

MonitoringJustificationLocationTrajectory

YES

AdvanceDeploymentNMT 48 Hours in advance

ICC/Houma

Re-Justify?

STOP

NO

YES

AM TargetingFlight

06:00-07:00

SignificantChanges

08:00

ChangesCan bejustified

FOSCEPA/Robert

NOAA08:30

DEPLOY

STOPYES

NO

YES

YES

NO

STOP NO

Morning of Deployment

Who gets the intel?

40 CFR 300.915 (d)

The OSC may authorize the use of any dispersant, surface washing agent, surface collecting agent, other chemical agent, burning agent, or miscellaneous oil spill control agent, including products not listed on the NCP Product Schedule, WITHOUT obtaining the concurrence of the EPA representative to the RRT and, as appropriate, the RRT representatives from the states with jurisdiction over the navigable waters threatened by the release or discharge when, in the judgment of the OSC, the use of the product is

necessary to prevent or substantially reduce a hazard to human life.

Surface Dispersant for Health and Safety FOSC Issues

Approval for Surface Dispersant

Vessels Follow Existing H&S Plans for Dispersant Use

Nightly Report Correlating VOCs and Dispersant

Applications

Does the Data Justify the use of

Dispersants

If 2 consecutive Days, Re-Evaluate the use of Dispersants for Health

and Safety

Does the Revisited H&S Plan Involve the Use of

Dispersants

STOP USE OF SURFACE DISPERSANTS FOR

HEALTH AND SAFETY

Yes

Yes

No

No

Cross –Regional CoordinationAlternate Response Technology

RRT VI RRT IV

Dispersant Pre-Auth Zone Yes – Pre Auth Plan Yes – Pre Auth Plan

In Sutu Burn Policy Yes – Pre Auth Plan Yes – Pre Auth Plan

Surface Washing Agents Policy-Yes: But No Pre-Auth Zones identified in Region VI ACPs

Incident Specific RRT Decision

Solidifiers Policy Draft Limited Pre-Auth Yes: Limited Pre-Auth provided all recovered similar to sorbent requirements

Bioremediation Policy Guidance Document Yes

NRT Authorized In-Situ Burns via R6 Pre-Auth

Cross –Regional CoordinationAlternate Response Technology

RRT VI RRT IV

Dispersant Pre-Auth Zone Yes – Pre Auth Plan Yes – Pre Auth Plan

In Sutu Burn Policy Yes – Pre Auth Plan Yes – Pre Auth Plan

Surface Washing Agents Policy-Yes: But No Pre-Auth Zones identified in Region VI ACPs

Incident Specific RRT Decision

Solidifiers Policy Draft Limited Pre-Auth Yes: Limited Pre-Auth provided all recovered similar to sorbent requirements

Bioremediation Policy Guidance Document Yes

RRT IV Incident Specific

Approval of SWA off

MS, AL, & FL

Cross –Regional CoordinationAlternate Response Technology

RRT VI RRT IV

Dispersant Pre-Auth Zone Yes – Pre Auth Plan Yes – Pre Auth Plan

In Sutu Burn Policy Yes – Pre Auth Plan Yes – Pre Auth Plan

Surface Washing Agents Policy-Yes: But No Pre-Auth Zones identified in Region VI ACPs

Incident Specific RRT Decision

Solidifiers Policy Draft Limited Pre Auth Yes: Limited Pre Auth provided all recovered similar to sorbent requirements

Bioremediation Policy Guidance Document Yes

Note that the listing of “XXXX” on the NCP Product Schedule does not constitute approval, certification, authorization, licensing or promotion of the product; nor does it imply compliance with any criteria or minimum standards for such agents. Failure to comply with these restrictions or the making of any improper reference to EPA in an attempt to demonstrate approval or acceptance of the product will constitute grounds for removal of the product from the schedule.

What is the Product Schedule?• Required by Section 311(d)(2)(G) of the CWA

– Compiles chemicals and other agents that may be used to carry out the NCP, waters they may be used in, and quantities that may be used.

• Listing in the schedule gives:– The RRT the power to pre-approve usage under certain conditions and in

specific locations with “preauthorization plans” – 300.910(a)– The OSC the power, with concurrence/consultation of select RRT members,

to approve the use “on the fly”. – 300.910(b)• EPA co-chair and State reps of States with jurisdiction over the effected

or threatened waters: concurrence• US DOI and US DOC trustees: consultation

• Not listed on the schedule? No approval can be granted…– Except by an OSC to prevent or “remove a hazard to human life.”

• 300.910(d) – the only place the NCP states “human life”

Subpart J applies only to water, right?

• No – 300.900(b)– “…adjoining shorelines…activities that may effect

natural resources belonging to, appertaining to, or under exclusive management of the United States…”

What are defined “natural resources”??

• Natural resources – 300.5– Land, fish, wildlife, biota, water, groundwater

drinking water supplies, and other such resources belonging to, managed by, held in trust by, appertaining to, or otherwise controlled by the United States…any state or local government, any Indian Tribe, or if such resources are subject to a trust restriction on alienation, any member of an Indian Tribe.

Use in Headwaters vs Main Streams

• NCP and CWA 311 do not distinguish between them.

• RRT’s responsibility to approve, or not, per 40 CFR 300.910

• 40 CFR § 300.910 Authorization of use. • (b) For spill situations that are not addressed by the

preauthorization plans developed pursuant to paragraph (a) of this section, the OSC, with the concurrence of the EPA representative to the RRT and, as appropriate, the concurrence of the RRT representatives from the states with jurisdiction over the navigable waters threatened by the release or discharge, and in consultation with the DOC and DOI natural resource trustees, when practicable, may authorize the use of dispersants, surface washing agents, surface collecting agents, bioremediation agents, or miscellaneous oil spill control agents on the oil discharge, provided that the products are listed on the NCP Product Schedule.

Senate Hearings and Congressional Inquiries:

Example of Political Pressure being exercised by vendors whose products were not being purchased for the spill response

Cross –Regional CoordinationAlternate Response Technology

RRT VI RRT IV

Dispersant Pre-Auth Zone Yes – Pre Auth Plan Yes – Pre Auth Plan

In Sutu Burn Policy Yes – Pre Auth Plan Yes – Pre Auth Plan

Surface Washing Agents Policy-Yes: But No Pre-Auth Zones identified in Region VI ACPs

Incident Specific RRT Decision

Solidifiers Policy Draft Limited Pre-Auth Yes: Limited Pre- Auth provided all recovered similar to sorbent requirements

Bioremediation Policy Guidance Document Yes

Request to the FOSC for

alternative spill product use

Source of request is of

a political nature?

no

Yes

Product on NCP product schedule?

no

Yes

Is the request for operational

use?

no

yes

Is the request for

pre –operational

test?

Forward request to EPA

Reg & Policy Division

UAC EU Replies to sender that

request has been

forwarded to EPA

Request /assist the originator in completing RRT 6 Small-Scale Alternative Shoreline Testing Checklist

UAC EU forwards to CG RDC ARTES

- Houma for testing

yes

Houma EU provides strategies list to

FOSC /R & Ops sections for potential use

Request the sender provide idea to

DWH IATAP website

RDC ARTES prioritizes request &

conducts test

Test sucessful

?

yes

no

RDC notifies BP of successful

test

RDC notifies Requestor of unsuccessful

test

Houma EU & RDC develop strategies for potential use

Was the product

tested using RRT6 small

scale checklist?

yes

no

Awaits operationa

l need from

FOSC/R

Go to

next page

DWH Process for Alternative Spill Product Use Flowchart

Source of

request is of a

political nature?

no

Yes

Is the product RRT pre-authorized for use?

no

Is plan consistent with RRT 6/4 guidelines?

FOSC/R executes plan & provides report

as required

Request /assist the originator in completing operational plan for the

product within RRT Guidelines

FOSC/R requests RRT

approval

yes yes

yes

Notify requestor a

product awaits operational need from

FOSC/R

Approval

granted?

FOSC/R determine

d operationa

l need?

RRT provides

explanation of denial

no

no

Requestor ensures plan meets RRT guidelines

RRT or FOSC

provides explanation

of denial

FOSC/R executes plan

& provides report as required

LT 400 Acres of LA Marsh Impacted

Strategy Presidential Directives

National Incident Management

System (NIMS)

National Preparedness

Guidance

Capabilities-Based Planning Tools

(Scenarios, UTL, TCL)

National Preparedness Goal

National Response Plan (NRP)The National The National

Strategy for Strategy for Homeland Homeland SecuritySecurity Homeland Homeland

Security Security Presidential Presidential Directive 7Directive 7

Homeland Security Grant Program

Guidance

Homeland Homeland Security Security

Presidential Presidential Directive 5Directive 5

Common approach to

national incident management:

Prevention

Protection

Response

Recovery

Preparedness

National Initiatives

Homeland Homeland Security Security

Presidential Presidential Directive 8Directive 8

National Infrastructure

Protection Plan (NIPP)

15 National Planning ScenariosScenario 1: Nuclear Detonation – Improvised Nuclear Device

Scenario 2: Biological Attack – Aerosol Anthrax

Scenario 3: Biological Disease Outbreak – Pandemic Influenza

Scenario 4: Biological Attack – Pneumonic Plague

Scenario 5: Chemical Attack – Blister Agent

Scenario 6: Chemical Attack – Toxic Industrial Chemicals

Scenario 7: Chemical Attack – Nerve Agent

Scenario 8: Chemical Attack – Chlorine Tank Explosion

Scenario 9: Natural Disaster – Major Earthquake

Scenario 10: Natural Disaster – Major Hurricane

Scenario 11: Radiological Attack – Radiological Dispersal Devices

Scenario 12: Explosives Attack – Bombing Using Improvised Explosive Devices

Scenario 13: Biological Attack – Food Contamination

Scenario 14: Biological Attack – Foreign Animal Disease

Scenario 15: Cyber Attack

#1 NuclearDetonation

#2 Anthrax #3 Pandemic #4 Plague

#5 Blister #8 Chlorine

#10 Hurricane

#6 Toxic Industrial #7 Nerve Agent

#9 EarthQuake

#15 Cyber

#11 RadiologicalAttack (RDD)

#12 ExplosivesAttack (IED)

#13 Food #14 Animal

15 NATIONAL PLANNING SCENARIOS

Natural Disaster

Chemical Attack

Biological Attack /Disease

Rad/Nuc/ExplosiveAttack

Cyber Attack

Target Capabilities List• 1. Animal Health Emergency Support

• 2. CBRNE Detection

• 3. Citizen Preparedness and Participation

• 4. Citizen Protection: Evacuation and/or In-Place Protection

• 5. Critical Infrastructure Protection

• 6. Critical Resource Logistics and Distribution

• 7. Economic and Community Recovery

• 8. Emergency Operations Center Management

• 9. Emergency Public Information and Warning

• 10. Environmental Health and Vector Control

• 11. Explosive Device Response Operations

• 12. Fatality Management

• 13. Firefighting Operations/Support

• 14. Food and Agriculture Safety and Defense

• 15. Information Collection and Threat Recognition

• 16. Information Sharing and Collaboration

• 17. Intelligence Fusion and Analysis

• 18. Interoperable Communications

19. Isolation and Quarantine

20. Mass Care (Sheltering, Feeding, and Related Services)

21. Mass Prophylaxis

22. Medical Supplies Management and Distribution

23. Medical Surge

24. On-Site Incident Management

25. Planning

26. Public Health Epidemiological Investigation and Laboratory Testing

27. Public Safety and Security Response

28. Restoration of Lifelines

29. Risk Analysis

30. Search and Rescue

31. Structural Damage Assessment and Mitigation

32. Terrorism Investigation and Intervention

33. Triage and Pre-Hospital Treatment

34. Volunteer Management and Donations

35. WMD/Hazardous Materials Response and Decontamination

36. Worker Health and Safety

55

Unified Area CmdFOSC State RP

UCGFCO DCO SCO(JFO) (EOC)

NIC

NCP = Federal Command/Control

STATE EOC

PARISH AND COUNTY EOC

FEMA Administrator

STATE EOC

PARISH AND COUNTY EOC

National Contingency Plan

National Response Framework

Governor Governor

UICHouston, TX

UIC Houma, LA

UIC Mobile, AL

UICMiami, FL

ESF 1-15

ESF 9

EPA COORDUSCG-D8/7USCG-DWH

ESF 10

FEMA COORDFEMA-R4/6USCG-D8/7NPSDOD

NRF = Federal Support to State/Local

Secretary DHS

WHITE HOUSE

EmergencyAnd Disaster Declaration s

56

Barge, Train or Truck?

1 Barge =

100 16 Rail Cars =

60 Trucks

Recommendations

• A web-site and dial-in line as established for DWH event was an invaluable tool to acquire and filter the thousands of ideas coming from the public

• SONS type events require immediate IASG/ARTES establishment to vet high visibility, or response strategies having either a high media, political and/or senate/congressional query associated. Although adequate procedures already exist that document RRT –level approvals of Sub Part-J (NPL) listed chemical countermeasures, an elevated level of feedback to originator is sometimes necessary based on the politics associated with the requestor. FOSC level or NRT/HQ level work-group such as IASG is needed in some cases.

• Work toward consistency in Policies across regions for approval or pre-authorization plans involving alternate response technologies and sub-part J listed products.