Overview of In-situ Burning (ISB) and ISB NWACP Taskforce Update In-situ burn (ISB) overview and trade-off discussion Update on In-situ Burn (ISB) Task Force activities to update existing policy and decision process Purpose is to refresh ourselves on the decision process in the plan and discuss some of the specifics of decision parameters Lessons Learned during recent drills--Role of Washington Clean Air Agencies during response In-situ burning may occur on water or inland The NWACP policy is designed to cover both – more on that Inland burns often occur in wetlands where more harm may occur from trying to access the oil Marine burns occur in the open water environment

Why In-situ burning? How? In-situ burning is the controlled burning of oil "in place" Burning quickly removes large quantities of oil (crude – diesel) and minimizes the need for recovery, storage, and disposal Burning requires fire resistant boom in the open water environment because uncontained oil rapidly spreads too thin to sustain combustion. The fire can be extinguished almost immediately, by allowing the collected oil to spread Inland in-situ burns need to consider ability to control the fire (fire breaks) may be preferable in remote locations with difficult access In-situ burning use decisions are scenario driven ISB is planned burning. An incident that results in a fire is not considered ISB it is part of the incident scenario… whereas ISB is a response tactic that is being used to address the scenario if appropriate for the oil type, environment, and In-situ burning may occur on water or inland -- we are talking about this as a response option (not the response to an incident that results in a fire– decision to burn) The current NWACP policy is designed to cover both inland and on water burns – more on that Inland burns often occur in wetlands where more harm may occur from trying to access the oil Marine burns occur in the open water environment

Under the right conditions, may eliminate large volumes of oil quickly and efficiently. Response “window” may be brief, requiring pre-planning & rapid authorization for use.

Preferred Conditions for ISB On-water Inland Oil thickness >2-3mm Fresh oil not emulsified Waves <3 to 5 feet Window of opportunity 24-48 hours Wind < 20 knots Current < 1 knot Oil thickness on soil may be less than on water Fresh oil Standing water at least 2 mm Wind < 12 knots (to better control burn) Conditions similar to mechanical recovery – and our area plan identifies mechanical recovery as our primary response method It is assumed that the type of oil to be burned is crude oil, diesel, or other petroleum product, which can be burned safely. Lighter petroleum products such as gasoline are typically considered too volatile for a safe burn. The condition of the oil, its weathering state and ability to ignite and burn, is key.

In-situ burning Operations We have 3 500 ft fire booms in the state of WA these are water cooled booms. Each boom can do between 50 bbls and a few hundred bbls of oil. Burns are quick but refilling the boom to the needed thickness for ignition can be SLOW. Burns are typically 90-98% effective Encounter rate and oil collection. Requires trained personnel, working with state-of-the-art fire boom & igniters.

Examples of Inland ISB I looked for a good picture of inland insitu burn but couldn’t find anything!!!

Net Environmental Benefit Analysis Air (human vs natural) Usually water column animals vs. birds mammals How is the trade-off discussion held within the EU? Conditions for saying yes / no to the use of herders or accelerants? Burn residue – area plan says monitoring is required, to include visual. Is the picking up of burn residue feasible? Are permits needed? What are the parameters of an approval to burn? Require wildlife observers on vessels/by air? What is the method to terminate a burn?

Trade offs Discussion Not human or natural resources damages To burn does not mean unacceptable exposure to humans it does avoid unacceptable exposures to sensitive natural resources – specifically sensitive threatened and endangered species. Goal is effective response within this balance When considering the air quality impacts of the decision to burn spilled oil, it is important to recognize that we are dealing with emergency response to a very infrequent event. Short-term localized air quality degradation may be a more acceptable price to pay than long-term damage from the oil to ecosystems, animal populations, and shoreline resources.

NWACP ISB Taskforce Objectives Develop a map to represent graphic depiction of ISB Policy. Revise checklist for ISB decision making. Work to streamline the process for decision making.

ISB Interactive Map Preauthorization Area The In Situ Burning Preauthorization Area is described as follows: Any area that is more than 3 miles from human population. Human population is defined as 100 people per square mile.   9407.1.7 Case-By-Case Areas The In Situ Burning Case-by-Case areas are described as follows: Any areas within 3 miles of human population. Human population is defined as 100 people per square mile. All areas in the EPA jurisdiction will be treated as case – by case ISB Web MAP http://waecy.maps.arcgis.com/apps/webappviewer/index.html?id=13a6c63a1f9a438583726292e0adb816 The decision must consider impacts to air quality, benefit of rapid oil removal, safety of response workers and the public, and risk of secondary fires The Northwest Area Contingency Plan has a policy for the use of in-situ burning Burning is pre-authorized in areas > 3 miles from human population centers (defined as 100 people) – UC approves Burning is considered case by case in areas < 3 miles from human population centers – RRT must approve The area plan policy seeks to get regional air authorities input on case –by –case in-situ burn decisions http://waecy.maps.arcgis.com/apps/webappviewer/index.html?id=13a6c63a1f9a438583726292e0adb816

Map Continued – Pre-Authorization

Case – By Case – Population & Inland In-Situ Map Development Methods: Population data source -2010 Census blocks(this is the smallest geographical area delineated by the US census) Blocks > Block Groups > Tracts Then to much larger geographical areas - County Division, County, Combined statistical area, etc In Urban areas a “Block” –is generally a city block(but it can vary widely in shape and size) in rural or sparely populates areas they can be much larger US Census - occurs every 10 years next one is 2020   Per the policy a population center is > 100 people. For our purposes human population = total population/block area (square miles) greater than or equal to a 100 people per square mile Buffer units – 3 miles

Proposed burn location and oil type, amount and condition (affecting ignition and fire control) Environmental conditions (wind, waves, visibility, currents, water depth, etc.) Proximity issues (population centers, shorelines, other response activity, natural resources, etc.) Personnel, equipment & tactics (vessels, aircraft, fire boom, igniters, & deployment options) Monitoring & Sampling (oil slicks, weather, vessels, performance, combustion byproducts, etc.) Timing (mobilization, access of oil, public notices, authorization, etc.) The thicknesses required to ignite and sustain combustion depend upon the volatility of an oil, its emulsification (or water content), and wind and sea state conditions. Ignition of spilled oil is especially dependent upon these conditions because of the limited size and intensity of most ignition devices.

Role of Regional Air Authorities in Case – By Case Use Decisions Lessons learned from drill Modeling not an option Time Oil types Weather conditions Smoke Forecasting is an option Weather Terrain Population centers Chris cover this slide Once ignited, spilled oil will tend to burn down to a thickness of about 1 mm on water. On soil, the oil soaks in to varying extents, and there is often combustible organic material (vegetation), which contributes fuel for a more complete burn. • For a burn to be ignited and sustained on water, the spilled oil must be at least 1/10 in., or 2–3 mm, in thickness. For heavier and emulsified oils up to 10 mm in thickness may be necessary to generate burnable vapor concentrations.

Air Monitoring & Action Levels In the smoke plume carbon particulates are of highest concern to public health Monitoring teams are activated with real-time particulate monitors to address the Level of Concern (LOC) Upper limit of 35 micrograms of particulates 2.5 microns in diameter (or smaller) per cubic meter of air, averaged over one hour. Challenge is the short duration of burns Chris cover this slide Local Air officials (located in the Environmental Unit) will review monitoring data with the Safety Officer and have the authority to stop operations based on monitoring results RRT monitoring levels defined in NWACP How will the results be managed in the UC?

Next Steps Map is complete! Will go out for public review and comments this Fall along with other products underdevelopment: Taskforce will finalize an updated Pre-Authorization Area Checklist and Case-by–case checklist Overview of decision process and roles will be streamlined Development of “Appendix A” Update to the policy to reflect role of regional air authorities in case-by-case decisions Goal to be able to contact the Executive Director 24 hours per day Agency to provide subject matter expert information to support spill response decision making Air authorities may fill roles during spills and drills within ICP or virtual – expected roles Environmental Unit or Liaison Section Opportunity to review the policy, monitoring guidelines, action levels ahead of spills and provide feedback that supports updates to our plan.

Questions