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RRT Roles and Responsibilities for Subpart J Response

RRT Roles and Responsibilities for Subpart J Response. Session Purpose – what are we doing?. Review background of issue – GTI spill Review RRT authorities/responsibilities Review applicability of Annex IX and subpart J regulations Outline EPA/USCG proposal

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RRT Roles and Responsibilities for Subpart J Response

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  1. RRT Roles and Responsibilities for Subpart J Response

  2. Session Purpose – what are we doing? Review background of issue – GTI spill Review RRT authorities/responsibilities Review applicability of Annex IX and subpart J regulations Outline EPA/USCG proposal Form subcommittee to continue with next steps/action items.

  3. Background – GTI spill Tank truck rollover results in release of diesel fuel OSC responds, initiates bioremediation annex under RCP Numerous questions arose, no action taken Request to review RCP annex

  4. RRT activities per NCP Preparedness planning and coordination for response to a discharge of oil or release of hazardous substance; Notification and communications; and Response operations at the scene of a discharge or release. 300.105(b)

  5. RRT activities per NCP 300.900 (aka Subpart J) As part of planning activities, RRTs shall address the desirability of using chemical agents (300.910(a))

  6. Applicability of Subpart J Chemical agents – definition Chemical agent use regulated by Subpart J (300.900(c)) – for Oil! CERCLA response is different Agent use, landfarming, etc regulated by 300.400(e) and (g)(1-2) Subpart J only applies for agents in water Thus, somewhat limited scope

  7. Bioremediation R8 and beyond Annex IX in RCP details bioremediation requirements Lengthy – approx 50 pages Separate from other chemical countermeasures Other approaches (R7, R9, etc)

  8. Proposal Eliminate separate bioremediation annex Combine bio with other chemical agents annex and policy New annex to include: RRT policy/planning for chemical agent use Separate from other chemical countermeasures Streamlined process for FOSC use Collect supporting documents in another place Next steps – volunteers?

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