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Subpart H to the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) authorizes the On-Scene Coordinator (OSC) to use dispersants on oil discharges if certain conditions have been met. Primary among these is the requirement that the U.S. Environmental Protection Agency (EPA) representative to the Regional Response Team (RRT) and the affected state concur regarding dispersant use. However, obtaining concurrence after a spill can be so time-consuming that optimal dispersant use is no longer possible.
Since the effectiveness of dispersants is time-critical, the sooner that concurrence can be obtained and the dispersant applied, the more effective such application should be. Thus, planning can significantly increase the performance of dispersants.
One way to expedite the decision making process is in agreements that preauthorize the OSC to use dispersants. The NCP encourages RRTs to plan for such use and to have preauthorizations in place. The Region IV RRT has developed an agreement for the use of dispersants in Florida. Two similar agreements have been developed by the Caribbean RRT for Puerto Rico and the U.S. Virgin Islands. While none of these agreements allows the unrestricted use of dispersants, each specifies areas where the OSC can use dispersants and areas where dispersants cannot be used without further discussion with the EPA and the state. The Caribbean RRT has also included provisions in the agreements for a monitoring strategy to assess the effectiveness of dispersants when they are used.
The key to an effective and successful response is having an organization and contingency plan in place. Such arrangements are an integral part of the Region IV and Caribbean RRTs' contingency plans and will result in a more timely and informed decision on whether dispersants will be used.
dispersants, letters of agreement, contingency plans, oil spills
Commanderchief, U.S. Coast GuardMarine Environmental Protection Branch, Miami, FL