Identification of Nontoxic Methods for Contingency Plans
The establishment and enactment of new contingency plans associated with remediation of oil spills (including those response plans submitted by oil companies requesting permits) is urgently needed, using methodologies other than intensive application of chemical dispersants. The commencement and acceleration of new deep-water drilling in the Gulf of Mexico and the Beaufort Sea in Alaska, for instance, particularly in the absence of updated contingency plans in the event of a spill, is quite concerning. In other words, hundreds of permits have been issued since September 2010 with no signifcant change in spill contingency planning—other than more advanced deep-water dispersant injection systems that have been added to plans, which would produce a repeat of the Deepwater Horizon toxic response.
The information presented here is for distribution to Regional/Area Committees and all stakeholders responsible for maintaining up- to-date contingency plans for safeguarding our aquatic, marine, and terrestrial environments. The article included regarding bioremediation category definitions and their modes of action, along with further information below, should over- write previous guidance on bioremediation because it clarifies use of the Bioremediation Agent EA Type as a FIRST-RESPONSE agent.
Bioremediation Agent Enzyme Additive Type can clearly serve as a first-response alternative to the use of chemical dispersants, which no longer have a place in modern-day oil spill cleanup in US navigable waters.
NCP-Listed Bioremediation Agent (EA Type) as a Solution and Alternative to Chemical Dispersants
We encourage independent investigation of EA Type as a promising potential solution to oil spill response in deep-water drilling and diffcult access environments, particularly as a first-response method for open-water oil spills, in lieu of chemical dispersants of any kind.
It is the position of the Science & Technology Advisory Board of the Lawrence Anthony Earth Organization that Bioremediation Agent Enzyme Additive Type can clearly serve as a first-response alternative to the use of chemical dispersants, which no longer have a place in modern-day oil spill cleanup in US navigable waters.
The EPA is now being pressed to find safer response agents to replace these outdated modes, which, when combined with oil pollutants, are more toxic than the oil itself and therefore contrary to the intent of the US Clean Water Act (CWA).29 To reiterate, the CWA stipulates that, for a response method to be utilized, it must REMOVE oil from the environment. Dispersants do not fulfill this requirement; in fact, studies have shown that use of dispersants prolongs the time that oil plus chemical dispersants remain in the environment, resulting in adverse impacts to fora and fauna for up to five years or longer.30 31
The good news is that there are developed protocols for identifying and assessing the degree of usefulness of spill-response products, and they are not complicated.
How Oil Spill Cleanup Products Should Be Assessed and Prioritized
The LAEO has conducted nearly three years of research to find methods for remediating oil spills that are more effective and less toxic than those currently used. We have also been working to gain the necessary authorizations for utilizing these more effective techniques to clean up the waters of the Gulf and its shorelines still impacted by the Macondo spill.
Our frst step was to vet the applicable products on the EPA NCP Product Schedule. We developed a set of guidelines by which to review products and determine their eligibility for use in US
navigable waters. We were not looking for any given product but merely those that fell under our criteria for desired effectiveness, as follows:
- On the NCP list.
- Swift and effective removal of the oil, not just dispersal of it by solubilizing or dis- solving it into the water column.
- Nontoxic with no destructive “trade-offs” associated with its application.
- Able to also detoxify chemical dispersants, e.g., the two types of Corexit that have been broadly used domestically and internationally.
- Using neither nonindigenous microbes nor genetically modified organisms.
- Complete scientific documentation substantiating the product’s efficacy.
- A track record of success in the field.
- Pretested and screened as usable any- where—open water, sandy beaches, marshes, etc., as a first-response method (i.e., predetermined as applicable in all environments to enable rapid response without the need for assessment during an emergency).
- The manufacturer has suffcient quantities in stock and immediate production capabilities to handle a spill of signifcance.
- Its use and application must be economically reasonable and within acceptable ranges of expected remediation costs.
- Eliminates or significantly reduces the necessity for secondary cleanup, such as cleaning up tar mats formed by sinking the oil using dispersants, disposal of hydrocarbon-based material in landfills, or other methods of disposal.
Our extensive search revealed only one product that fulflled all of these requirements—one under the Bioremediation subcategory EA on the NCP list: Oil Spill Eater II (OSE II). We continue to look for other products that fulfill these criteria, but in the meantime, at least there is one bioremediation category that could effectively lead response methods into the twenty-first century; and as of the writing of this paper, the only product that has been able to meet our guidelines has been OSE II.
LAEO produced a documentary film to educate the public on bioremediation and to encourage researchers and companies with products that meet the above criteria to step forward.32 Several products have since been submitted to us for our advocacy, and some, although promoted as “nontoxic,” were found to be at least as toxic as crude oil.
New and innovative solutions utilizing all available technology are needed for the situation in the Gulf of Mexico, as well as future hydrocarbon-based spills that will continue to occur in all the waters of the world. If we stay on the same track, we run the risk of having fsheries collapse, a chemically stressed ecosystem worldwide, and progres- sively worsening human health issues.33
Characteristics of an Effective Solution—Feasibility Assessment Criteria
The protection of human health should be the foremost concern of any oil spill cleanup decision-making process. Human health is dependent upon the relative health of the surrounding environment; hence it is important to understand the criteria by which cleanup methods must be gauged as to their value and effectiveness. To reiterate, the primary reason to clean up an oil spill or hazardous materials is to rapidly reduce the impact of their toxicity so that all living organisms can survive. And again, if even the smallest organisms can survive, then the ecosystem will be able to sustain itself.
Thus, our recommended standards for the ideal technology or agent for use in cleaning up a hazardous spill would be these:
1. Must swiftly and thoroughly detoxify the oil or hazardous substances as a frst step in order to protect the indigenous microbial
populations and all life forms.
2. Must nullify the oil’s adhesive qualities so that it does not stick to marine life, wildlife, marsh grass, rocky shorelines, sandy beaches, or seabed sediment.
3. Must keep the oil on the surface so that it can most rapidly be digested by indigenous microbes, utilizing existing airborne oxygen and protecting the 60 percent of marine life that resides in the subsurface area. (Note: This also makes it accessible for physical removal methods working in tandem with nontoxic agents.)
4. Understanding that nature uses surfactants xiii in the natural process of cleaning up an oil spill, an effective product would have no toxic surfactants such as are contained in both Corexit 9527 and 9500. (For instance, Bioremediation EA Type OSE II contains no toxic surfactants and is fully tested and validated as nontoxic. Comparing toxicity levels using established EPA standards cited earlier, Corexit 9500 had a high toxicity level of 0.065 to 0.354 ppm compared to OSE II, which had a reading of 10,000 ppm for one of the most sensitive marine species tested [the higher the number, the lower the toxicity level]. This means that Corexit is as much as 150,000 times more toxic than the bioremediation alternative. See Toxicity Values chart below.)
5. Must have a scientifically substantiated and predictable end point that could be standardly achieved from its proper application. This end point would be that within a matter of days to, maximally, a few weeks, close to 100 percent of the oil would have been converted into CO2 and water— two benign substances—without any adverse side effects, or “trade-offs” related to its application, thereby protecting the responders, wildlife, and marine life.
6. Its application must be economically viable—for example, comparable in cost to current methods and, ideally, significantly less.
Our research found that an EA Type bioremediation technology that meets the above criteria exists today and is being used in over 30 countries. Its results contrast strongly with those derived from dispersants predominantly used in US navigable waters. Additionally, it costs a fraction of the other methods and would therefore represent an economic boon, not only to the responsible parties, who could avoid damage claims and heavy fines, but also to those living in the environment, reducing business disruptions with rapid cleanup, bringing a quick return to their livelihoods. In other words, in addition to preserving the health and safety of the waters, there would be little impact on tourism, coastal businesses, and fisheries.
The value of a product could be rated and characterized by how rapidly and thoroughly it meets the above criteria while introducing no additional toxicity to the scene already created by the hazardous spill.
Due to the many common misconceptions about bioremediation, and especially the subcategory EA Type on the NCP list, LAEO’s Science & Technology Advisory Board has provided the above summary of our vetting process of spill-response methods for use by all interested parties.
We encourage independent investigation of EA Type as a promising potential solution to oil spill response in deep-water drilling and difficult access environments, particularly as a first-response method for open-water oil spills, in lieu of chemical dispersants of any kind. … To reiterate, the primary reason to clean up an oil spill or hazardous materials is to rapidly reduce the impact of their toxicity so that all living organisms can survive. And again, if even the smallest organisms can survive, then the ecosystem will be able to sustain itself.
xiii. surfactant. A substance that lowers the surface tension of water, making it easier for organic compounds to be dissolved in the water. There are toxic and nontoxic surfactants; i.e., chemical based with various degrees of toxicity, and plant/living-organism based = nontoxic.