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API BULL 4719-2017 pdf free download

API BULL 4719-2017 pdf free download.Industry Guidelines on Requesting Regulatory Concurrence for Subsea Dispersant Use.
3.2 National Response Team The National Response Team (NRT) is responsible for providing policy and program direction to the RRTs; evaluating methods of responding to discharges or releases; and recommending any changes needed in the response organization. The Environmental Protection Agency (EPA) chairs the NRT; it is vice chaired by the United States Coast Guard (USCG) and composed of representatives of 1 5 federal agencies. For coastal and offshore incidents, the USCG serves as the chair. The NRT does not ordinarily become involved in response operations, but is involved in preparedness functions, such as publishing information, coordinating planning activities, sponsoring training, and supporting Regional Response Teams (RRTs), which can include activation during a response. At this time, no RRTs have approved preauthorization plans for subsea dispersant use. Each use must be authorized by a FOSC, utilizing their authority to mitigate hazards to human life (40 CFR §300.91 0(d)), or with concurrence from the RRT as described below. The NCP describes specific RRT roles with respect to dispersant use, which includes evaluating the desirability of dispersant use as a response method included in preauthorization plans, or in response to incident-specific FOSC requests. For coastal and offshore incidents, the USCG serves as the lead agency for authorizing the use of dispersants with the required concurrence and consultations with other relevant agencies. If an Area Committee (or the RRT) prepares a preauthorization plan for a specific area, the representatives from USCG and EPA, the affected state(s), Department of Commerce (DOC), and Department of Interior (DOI) must approve, disapprove, or approve the plan “with modifications.” A FOSC can authorize the use of dispersants in response to a specific incident that is not covered by a preauthorization plan, with the concurrence of the representatives to the RRT from the EPA,
3.3 Responsible Party The Responsible Party (RP) will participate in the UC through a Qualified Individual/Incident Commander (QI/IC), and coordinate with the FOSC to assemble a package of pertinent information to assist the RRT with their dispersant authorization decision making. 4 Summary of Core Information Submitted to Regional Response Teams To-date, the following information has been used by RRTs to achieve concurrence on subsea dispersant injection (SSDI) during industry-sponsored exercises: a) signature page for FOSC authorization and other Incident Commanders’ approval; b) summary of SSDI rationale and readiness to execute; c) comprehensive incident data sheet; d) identification of resources at risk; e) site and incident-specific 3-D modeling information used to predict oil and dispersed oil trajectories; f) Subsea Dispersant Operations Plan; g) Subsea Dispersant Monitoring Plan; h) analysis of potential NEBA/SIMA and risk assessment associated with SSDI.
5 Evaluating the Use of Subsea Dispersant Injection The primary goal of dispersant use is to increase the amount of oil that dissipates into the water column and is subject to microbial degradation, thereby reducing the amount of oil remaining on the surface. The use of SSDI offers an available and efficient method of achieving a high encounter rate directly at the source, thereby reducing the potential for floating oil to threaten worker health and safety, and to reach ecologically and economically sensitive shoreline environments. Research and experience has shown that hydrocarbon exposures decline rapidly away from the subsea source and are further mitigated by microbial degradation [24] . This enhanced dispersal of oil is an important factor when using SIMA as a part of the response decision–making process.

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