1. 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

2. 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

3. 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.

4. Preferred Conditions for ISB
On-water
Inland
Oil thickness >2-3mm
Fresh oil not emulsified
Waves <3 to 5 feet
Window of opportunity 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.

5. In-situ burning Operations
We have 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.

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

7. 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?

8. 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.

9. 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.

10. 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.
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
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

11. Map Continued – Pre-Authorization

12. Case – By Case – Population & Inland
In-Situ Map Development Methods:
Population data source 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

13. 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.

15. 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.

16. 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?

17. 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.

18. Questions