ABSTRACT The Regional Response Teams for Region 4 and the Caribbean developed pre-authorization documents to allow the use of solidifiers as listed on the National Product Schedule for mitigation of oil spills. Solidifiers are considered an alternative to sorbents or mechanical recovery for removal of small amounts of oil or thin sheens from the water surface. Throughout the process of developing the pre-authorization documents, a number of questions arose which were identified as key issues to a successful outcome, such as: What are sorbents? What are solidifiers? What are appropriate criteria for classification of solidifiers? What are the mechanisms of action for solidifiers? What is the typical composition of solidifiers? What are the environmental concerns associated with solidifiers? What are the benefits, shortcomings, and comparisons of using solidifiers versus sorbents? What are application and monitoring issues associated with use of solidifiers? What are the solidifier products currently listed on the NC? Product Schedule? The questions, while simple in nature, were complex in terms of the answers. There are conflicting and confusing criteria that exist when attempting to determine the nature of product designation as a sorbent or solidifier. Review of the ASTM criteria and Product Schedule in Subchapter J of the National Contingency Plan did little to clear the confusion. Despite this challenge, guidelines were developed for conditions where solidifiers could be pre-authorized for use including types of oil, use in loose form on any oil type under 500 gallons (treatment volume), no more than 1,000 pounds of solidifier loose product applied in response to a spill event, complete containment and recovery of all material, and monitoring requirements. A lesson learned from this exercise was that there needs to be a review and clarification of existing criteria for determining the difference between a sorbent and solidifier. This clarification will greatly assist in product classification under the Product Schedule during the projected upcoming regulatory project to rewrite Subchapter J of the NCP. That effort, in turn, will eliminate perceived discrepancies in product classification and allow the pre-authorization document to be a more lucid product for use by On Scene Coordinators.
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