I've had the luxury of being able to follow some of the information coming out of the Gulf regarding the Deepwater Horizion disaster response. The response appears to be directed, and rightly so, at cleaning up the surface oil, protecting the beaches, protecting the wetlands and fisheries, and stopping the leak. I won't comment on the surficial response efforts, except to inquire, what happened to all of the response plans that were generated as a requirement of the 1990 Oil Pollution Act
? Shortly after the act became law, I was charged with assisting a major oil company in the development of detailed response plans and scenarios for their terminals in the southeastern US.
[caption id="attachment_1846" align="alignleft" width="300" caption="Oil on Troubled Waters"][/caption]
From the USEPA's own website on the OPA regulations:
Facilities who have the potential for discharging oil into or on navigable waters are required to prepare and submit Facility Response Plans (FRPs). The Oil Pollution Prevention regulation includes two methods by which a facility may be identified as posing substantial harm:
- Through a self-selection process; or
- By a determination of the EPA Regional Administrator.
The EPA Regional Administrator may consider factors similar to the self-selection criteria, as well as other factors, including:
In addition, the EPA Regional Administrator may determine that a facility poses significant and substantial harm.
- Type of transfer operations
- Oil storage capacity
- Lack of secondary containment
- Proximity to fish, wildlife, and sensitive environments or drinking-water intakes
- Spill history
[caption id="attachment_1847" align="alignright" width="300" caption="Bird Covered in Oil"]
I find it incredible that neither the EPA nor BP had followed their own regulations regarding pre-positioning of equipment to respond to an event which could pose "significant and substantial harm" to U.S. navigable waters. It is even more disquieting when one considers that this regulation has been on the books almost 20 years!
May Update from NOAA Regarding Subsurface Ploom
According to a NOAA report, from the end of May, the subsurface plume is as much as 142 miles from the Deepwater Horizon Site. However, there is some mixed, if not good news. The NOAA vessel R/V Weatherbird surveyed the submerged oil plume and found that the dispersant is working fairly well. The reported TPH concentrations were less than 0.5 mg/l in ALL cases.
The report can be viewed and downloaded here
Under the circumstances (see the report page 5 of 14), there's not much that any of us can do attempt to remove additional oil from the Gulf Waters because at less than 0.5 mg/l, we are generally at or below treatment levels achieved by conventional means.
Putting toxicity issues aside for a moment, the levels of concern regarding turning the entire Gulf into a large dead zone without oxygen may be close to moot. I don't know what the Oxygen Demand of Crude is, but with concentrations down in the 0.203 ppm range (median value according to the report), there's not a lot that we can do to capture it except recover it on Carbon and/or clays. Conventional treatment just won't work well as concentrations are too low for most conventional treatment.
This does not mean, however, that there is no problem or need for chemical engineers to take action. It just changes the scope of the problem to one of mitigation of low concentrations of crude in vast quantities of water. This is definitely a time when chemical engineers should be helping and providing expertise and advice on remediation. Our expertise is vitally important to the environment and oceans, as well as to the welfare of the various states bordering the Gulf. I need not remind anyone that as of the first we are in hurricane season and the predictions of an active hurricane season are ominous. I would offer the idea that a hurricane in the Gulf could very easily disturb and displace much of the subsurface oil, dwarfing any quantities which are currently on the surface. If the oil below the surface stays submerged, or if it rises to the surface, it will represent a new level of catastrophe. The DOE has set up a resource—Alternative Technology Response Form—
where solutions can be submitted.
I believe that it is time for chemical engineers to band together and submit recommendations for recovery and treatment of the submerged oil.
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