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6.0 Impact Considerations Version :27.10.4 Alternative Technologies Applied Response Technologies & Oil Spill Cleanup Agents Approval for the use of Applied Response Technologies (ART) on oil spills to state waters rests exclusively with the OSPR Administrator and the Region IX Regional Response Team (RRT), respectively. Response decision-making is triggered by federal (National Response Center) and state (Cal-Office of Emergency Services) spill reporting and is supported by state and federal ART Technical Specialists. ART includes two categories of response technology: 1) The use of chemical or biologically based oil spill cleanup agents (OSCAs), which can include sorbents, surface washing agents, bioremediants, dispersants, herding agents, solidifying agents, and de-emulsifiers and, 2) The use of in-situ burning of oil on water or land. Not all OSCAs are formulated for use in all situations, so product selection is crucial to determining whether a net environmental benefit can be reasonably expected from the use of any particular product. In some situations oil removal via mechanical means may not remove enough oil in hard-to- reach or sensitive areas, dynamic water environments, or shorelines and other hard surfaces. When appropriate, ARTs are evaluated as response tactics, and tailored to the needs posed by incident. Sorbents Sorbents are materials that soak up liquids. Those used for oil spills should be oliophilic and hydrophobic. Sorbent products are available in many forms, including roll, sheet, pad, blanket, or web; loose; and particulates or foam enclosed in boom, sock, pillow or other similar fabric or web-bound constructions, or strips bound into sorbent pom-poms to act as "sweeps". Criteria for selecting sorbents for a particular use may include consideration of: 1. how oliophilic (oil attracting) and hydrophobic (water rejecting)the product is, 2. rate of sorption, 3. surface area, 4. buoyancy, 5. oil retention, 6. reusability, 7. ease of retrieval, 8. disposal options, 9. storage, and 10. cost. The federal EPA offers a categorical exemption for all sorbents from the NCP Product Schedule, so generally no further federal or RRT approval is required before the use of an exempted sorbent in an oil spill response that affects water. However, both the State and the RRT have policies limiting or prohibiting the use of any sorbent in a loose and/or broadcast form, so additional RRT approval may be required before an otherwise federally exempt sorbent can be used loose. Shell Supply and Distribution 6-54 Stockton Terminal FRP ©2019 Witt 0' Brien's Revision Date:October, 2019