Monday, May 17, 2010

EPA Subsurface Dispersant Protocols

Dispersant Monitoring and Assessment Directive for Subsurface Dispersant Application
May 10, 2010
Plume Monitoring and Assessment Plan for Subsurface Dispersant Application

Part 1: “Proof of Concept” to determine if subsurface dispersant operation is chemically dispersing the oil plume.

Part 2: Robust sampling to detect and delineate the dispersed plume.

Part 3: “Subsurface Injection of Dispersant” outlines the operational procedures.


BP shall provide a Dispersant Application Plan that identifies the dispersants to be used, describes the methods and equipment used to inject the dispersant, plume model to assure
representative sampling, proposed method of visual observation, process for determining the effectiveness of subsurface injection, the specific injection rate (i.e., gallons/minute), the total amount to be used for the duration of the test, the total length of time that dispersant is injected, and the plan for sampling and monitoring, as approved by the Unified Command

Environmental Unit. Dispersants must be on the approved product schedule and suitable for this use.

All data shall be provided to the United States Coast Guard (USCG) Federal On‐Scene
Coordinator, and the Environmental Protection Agency (EPA) Regional Response Team (RRT) representative within 24 hours of the information being received. This data includes real time monitoring, laboratory analysis, documented observations, photographs, video, and any other information related to subsurface dispersant application.

BP’s monitoring plan shall include a more thorough oil analysis, to enable EPA to determine whether the dispersed plume is toxic to aquatic life. This plan shall be designed and implemented to determine whether the dispersed oil will hang in the water column and eventually come in contact with the benthos as it approaches land.

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