Hazardous Substance Proposal

Tuesday, August 17, 1999
A recent article mentioned the USCG's March 22, 1999, Notice of Proposed RuleMaking (NPRM) concerning Tank Vessel Response Plans for Hazardous Substances. Since that time I've spent a good deal of time thinking about this NPRM. I feel it appropriate to address some additional aspects of the proposal. There are many issues seemingly unresolved within the proposal. Is it the USCG's intent to establish a new industry for hazardous substance response recovery, developing techniques and recovery equipment not widely in use? If one takes seriously what the USCG has written, such would seem to be the case. It would seem the USCG is taking the experience gained from many years of working with oil recovery and attempting to apply it to chemical responses. Is that possible? Many think it isn't. The issues with chemicals are far more complicated and at times very dangerous. The Comprehensive Environmental Response Compensation and Liability Act (CERCLA) has been around for about 20 years. The strategies needed to clean up chemical releases under this Act are sometimes fairly straightforward and simple. At other times the remediation is extremely complex and involves very sophisticated engineering solutions sometimes only relevant to the one specific spill site. Such responses do not equate to oil spill clean-up mentality. I have often heard it said jokingly the USCG's position toward pollution response is one of rigid flexibility. Rigid in whatever they wish to stand firm on and flexible about issues not important to them. The hard thing to determine is which issues they intend to stand firm on and which ones will allow flexibility. Their perceived view toward personnel safety will probably drive many of their actions; however, there will be no clear consistency. We envision the possibility the USCG will establish such a conservative response doctrine that everyone will be safe because everyone within the hot zone will always be protected by breathing apparatus and encapsulated suits. Rumors persist about the USCG requiring entry personnel to don SCBA's with "Level A" (breathing apparatus & encapsulated suits) entry equipment, while personnel from other USCG commands are inside the hot zone without designated equipment. How can this be? It probably means the entry doctrine was too conservative and some of the Coasties knew it and would not allow the inappropriate doctrine and equipment to get in their way. I don't think the USCG knows as much about chemical transport as it thinks. There are experts in chemical engineering at various levels within the USCG, but rarely is there a consistent body of knowledge concerning chemical response at the field level. Changes in personnel still occur too rapidly to adequately develop and maintain the needed expertise. Chemical responses are highly complex and dangerous. Often, there is no viable doctrine for short-term removal. It ain't oil. The best doctrine for removal is to isolate the spill as much as possible and let nature take its course. Nature can be augmented with engineering solutions. Short-term recovery normally just doesn't work. Maybe the best focus of the spill should be on the salvage of the vessel, containment of the cargo and the elimination of further potential for spill. There is no question many chemical and oil spills have been seriously exacerbated by not giving salvage the highest priority. An example might be the grounding of M/V New Carissa off Coos Bay, Ore. where the emphasis was on destroying the bunker tank tops and burning the oil. Would things have worked better if more emphasis had been placed on salvage and less toward destroying the fuel carried on board? Many persons consider the New Carissa incident to be a showcase of how government should respond to spill incidents. There are many of us who disagree with that judgement. Material compatibility issues during a chemical response effort are issues of major concern. There is a great deal of difference between mucking oil and recovering spilled sulfuric acid or for that matter, many of the chemicals included. As an example, let us address ethylene dichloride (EDC). Direct contact with liquid or vapors presents a serious health hazard. EDC is a suspected carcinogen. With a specific gravity of 1.26, it is clearly a sinker. Not soluble in water, it might be concluded, with added protection for personnel, it can be cleaned up in a manner similar to asphalt. The problem is, EDC is also solvent to many industrial materials used to make the equipment that might be used to clean it up. EDC is carried in stainless steel tanks because it tends to dissolve everything else. Does this mean we have to manufacture all equipment used to clean up an EDC spill out of stainless steel? And have the equipment available to every navigating vessel all the time? It should also be remembered there have been very few - if any - successful recoveries of submerged asphalt, let alone recovery of a highly solvent material. Is it theoretically possible? Yes. Has it ever been done? Probably. Does it use a technology or methodology that can be widely duplicated? Doubtful. Does all this knowledge concerning how to do this reside with the transporter? No. This is only one example of an extremely complex set of variables. Every chemical has its own characteristics and associated problems. The clean-up strategies and efforts will generally have to be designed based upon the specific waters and conditions of the incident. It is curious these rules are applicable only to the transporters of chemicals. Proposed rules for facilities are yet to be forthcoming. It would seem high levels of expertise are required to resolve issues raised in the proposal. Chemical transporters are very knowledgeable about their trade, but it would seem manufacturers should have more expertise concerning spill incidents than transporters. Professional transporters only carry product because someone else manufactured the product and some third party wants to use it. Shouldn't those parties manufacturing and storing chemicals be the ones to provide the resolutions of contentious issues concerning spill clean-up and remediation. Charley Havnen is a Commander USCG Ret. His organization can help with vessel construction projects, regulatory problems, vessel manning issues, procedure manuals, accident analysis or expert witness. He can be reached by contacting the Havnen Group 800-493-3883 or 504-394-8933. A recent article mentioned the USCG's March 22, 1999, Notice of Proposed RuleMaking (NPRM) concerning Tank Vessel Response Plans for Hazardous Substances. Since that time I've spent a good deal of time thinking about this NPRM. I feel it appropriate to address some additional aspects of the proposal. There are many issues seemingly unresolved within the proposal. Is it the USCG's intent to establish a new industry for hazardous substance response recovery, developing techniques and recovery equipment not widely in use? If one takes seriously what the USCG has written, such would seem to be the case. It would seem the USCG is taking the experience gained from many years of working with oil recovery and attempting to apply it to chemical responses. Is that possible? Many think it isn't. The issues with chemicals are far more complicated and at times very dangerous. The Comprehensive Environmental Response Compensation and Liability Act (CERCLA) has been around for about 20 years. The strategies needed to clean up chemical releases under this Act are sometimes fairly straightforward and simple. At other times the remediation is extremely complex and involves very sophisticated engineering solutions sometimes only relevant to the one specific spill site. Such responses do not equate to oil spill clean-up mentality. I have often heard it said jokingly the USCG's position toward pollution response is one of rigid flexibility. Rigid in whatever they wish to stand firm on and flexible about issues not important to them. The hard thing to determine is which issues they intend to stand firm on and which ones will allow flexibility. Their perceived view toward personnel safety will probably drive many of their actions; however, there will be no clear consistency. We envision the possibility the USCG will establish such a conservative response doctrine that everyone will be safe because everyone within the hot zone will always be protected by breathing apparatus and encapsulated suits. Rumors persist about the USCG requiring entry personnel to don SCBA's with "Level A" (breathing apparatus & encapsulated suits) entry equipment, while personnel from other USCG commands are inside the hot zone without designated equipment. How can this be? It probably means the entry doctrine was too conservative and some of the Coasties knew it and would not allow the inappropriate doctrine and equipment to get in their way. I don't think the USCG knows as much about chemical transport as it thinks. There are experts in chemical engineering at various levels within the USCG, but rarely is there a consistent body of knowledge concerning chemical response at the field level. Changes in personnel still occur too rapidly to adequately develop and maintain the needed expertise. Chemical responses are highly complex and dangerous. Often, there is no viable doctrine for short-term removal. It ain't oil. The best doctrine for removal is to isolate the spill as much as possible and let nature take its course. Nature can be augmented with engineering solutions. Short-term recovery normally just doesn't work. Maybe the best focus of the spill should be on the salvage of the vessel, containment of the cargo and the elimination of further potential for spill. There is no question many chemical and oil spills have been seriously exacerbated by not giving salvage the highest priority. An example might be the grounding of M/V New Carissa off Coos Bay, Ore. where the emphasis was on destroying the bunker tank tops and burning the oil. Would things have worked better if more emphasis had been placed on salvage and less toward destroying the fuel carried on board? Many persons consider the New Carissa incident to be a showcase of how government should respond to spill incidents. There are many of us who disagree with that judgement. Material compatibility issues during a chemical response effort are issues of major concern. There is a great deal of difference between mucking oil and recovering spilled sulfuric acid or for that matter, many of the chemicals included. As an example, let us address ethylene dichloride (EDC). Direct contact with liquid or vapors presents a serious health hazard. EDC is a suspected carcinogen. With a specific gravity of 1.26, it is clearly a sinker. Not soluble in water, it might be concluded, with added protection for personnel, it can be cleaned up in a manner similar to asphalt. The problem is, EDC is also solvent to many industrial materials used to make the equipment that might be used to clean it up. EDC is carried in stainless steel tanks because it tends to dissolve everything else. Does this mean we have to manufacture all equipment used to clean up an EDC spill out of stainless steel? And have the equipment available to every navigating vessel all the time? It should also be remembered there have been very few - if any - successful recoveries of submerged asphalt, let alone recovery of a highly solvent material. Is it theoretically possible? Yes. Has it ever been done? Probably. Does it use a technology or methodology that can be widely duplicated? Doubtful. Does all this knowledge concerning how to do this reside with the transporter? No. This is only one example of an extremely complex set of variables. Every chemical has its own characteristics and associated problems. The clean-up strategies and efforts will generally have to be designed based upon the specific waters and conditions of the incident. It is curious these rules are applicable only to the transporters of chemicals. Proposed rules for facilities are yet to be forthcoming. It would seem high levels of expertise are required to resolve issues raised in the proposal. Chemical transporters are very knowledgeable about their trade, but it would seem manufacturers should have more expertise concerning spill incidents than transporters. Professional transporters only carry product because someone else manufactured the product and some third party wants to use it. Shouldn't those parties manufacturing and storing chemicals be the ones to provide the resolutions of contentious issues concerning spill clean-up and remediation. Charley Havnen is a Commander USCG Ret. His organization can help with vessel construction projects, regulatory problems, vessel manning issues, procedure manuals, accident analysis or expert witness. He can be reached by contacting the Havnen Group 800-493-3883 or 504-394-8933. A recent article mentioned the USCG's March 22, 1999, Notice of Proposed RuleMaking (NPRM) concerning Tank Vessel Response Plans for Hazardous Substances. Since that time I've spent a good deal of time thinking about this NPRM. I feel it appropriate to address some additional aspects of the proposal. There are many issues seemingly unresolved within the proposal. Is it the USCG's intent to establish a new industry for hazardous substance response recovery, developing techniques and recovery equipment not widely in use? If one takes seriously what the USCG has written, such would seem to be the case. It would seem the USCG is taking the experience gained from many years of working with oil recovery and attempting to apply it to chemical responses. Is that possible? Many think it isn't. The issues with chemicals are far more complicated and at times very dangerous. The Comprehensive Environmental Response Compensation and Liability Act (CERCLA) has been around for about 20 years. The strategies needed to clean up chemical releases under this Act are sometimes fairly straightforward and simple. At other times the remediation is extremely complex and involves very sophisticated engineering solutions sometimes only relevant to the one specific spill site. Such responses do not equate to oil spill clean-up mentality. I have often heard it said jokingly the USCG's position toward pollution response is one of rigid flexibility. Rigid in whatever they wish to stand firm on and flexible about issues not important to them. The hard thing to determine is which issues they intend to stand firm on and which ones will allow flexibility. Their perceived view toward personnel safety will probably drive many of their actions; however, there will be no clear consistency. We envision the possibility the USCG will establish such a conservative response doctrine that everyone will be safe because everyone within the hot zone will always be protected by breathing apparatus and encapsulated suits. Rumors persist about the USCG requiring entry personnel to don SCBA's with "Level A" (breathing apparatus & encapsulated suits) entry equipment, while personnel from other USCG commands are inside the hot zone without designated equipment. How can this be? It probably means the entry doctrine was too conservative and some of the Coasties knew it and would not allow the inappropriate doctrine and equipment to get in their way. I don't think the USCG knows as much about chemical transport as it thinks. There are experts in chemical engineering at various levels within the USCG, but rarely is there a consistent body of knowledge concerning chemical response at the field level. Changes in personnel still occur too rapidly to adequately develop and maintain the needed expertise. Chemical responses are highly complex and dangerous. Often, there is no viable doctrine for short-term removal. It ain't oil. The best doctrine for removal is to isolate the spill as much as possible and let nature take its course. Nature can be augmented with engineering solutions. Short-term recovery normally just doesn't work. Maybe the best focus of the spill should be on the salvage of the vessel, containment of the cargo and the elimination of further potential for spill. There is no question many chemical and oil spills have been seriously exacerbated by not giving salvage the highest priority. An example might be the grounding of M/V New Carissa off Coos Bay, Ore. where the emphasis was on destroying the bunker tank tops and burning the oil. Would things have worked better if more emphasis had been placed on salvage and less toward destroying the fuel carried on board? Many persons consider the New Carissa incident to be a showcase of how government should respond to spill incidents. There are many of us who disagree with that judgement. Material compatibility issues during a chemical response effort are issues of major concern. There is a great deal of difference between mucking oil and recovering spilled sulfuric acid or for that matter, many of the chemicals included. As an example, let us address ethylene dichloride (EDC). Direct contact with liquid or vapors presents a serious health hazard. EDC is a suspected carcinogen. With a specific gravity of 1.26, it is clearly a sinker. Not soluble in water, it might be concluded, with added protection for personnel, it can be cleaned up in a manner similar to asphalt. The problem is, EDC is also solvent to many industrial materials used to make the equipment that might be used to clean it up. EDC is carried in stainless steel tanks because it tends to dissolve everything else. Does this mean we have to manufacture all equipment used to clean up an EDC spill out of stainless steel? And have the equipment available to every navigating vessel all the time? It should also be remembered there have been very few - if any - successful recoveries of submerged asphalt, let alone recovery of a highly solvent material. Is it theoretically possible? Yes. Has it ever been done? Probably. Does it use a technology or methodology that can be widely duplicated? Doubtful. Does all this knowledge concerning how to do this reside with the transporter? No. This is only one example of an extremely complex set of variables. Every chemical has its own characteristics and associated problems. The clean-up strategies and efforts will generally have to be designed based upon the specific waters and conditions of the incident. It is curious these rules are applicable only to the transporters of chemicals. Proposed rules for facilities are yet to be forthcoming. It would seem high levels of expertise are required to resolve issues raised in the proposal. Chemical transporters are very knowledgeable about their trade, but it would seem manufacturers should have more expertise concerning spill incidents than transporters. Professional transporters only carry product because someone else manufactured the product and some third party wants to use it. Shouldn't those parties manufacturing and storing chemicals be the ones to provide the resolutions of contentious issues concerning spill clean-up and remediation. Charley Havnen is a Commander USCG Ret. His organization can help with vessel construction projects, regulatory problems, vessel manning issues, procedure manuals, accident analysis or expert witness. He can be reached by contacting the Havnen Group 800-493-3883 or 504-394-8933.
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