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56 Proceedings Spring 2015 www.uscg.mil/proceedings property (the vessel, the cages, the clam storage and sorting facility, and eventually, the refrigerator trucks that were used during transportation). During this clearance phase of operations, EPA respond- ers collected the surface wipe samples from the vessel, the clam sorting facility, the clam cages, and the refrigerator trucks, which were then analyzed at an EPA lab. An EPA subject matter expert provided risk-based "clearance goals" 3 to inform the UC regarding the methods used to determine the presence of sulfur mustard on inanimate surfaces and to estimate if residual contamination had the potential to cause adverse health effects. Fortunately, all sample results were shown to be below the specifed in the clearance goals, so the USCG FOSC released the vessel and the clam cages and cleared the clam sorting facility for reuse. Finally all of the refrigerator trucks returned to New Eng- land for decontamination and clearance, and the last refrig- erator truck was cleared for reuse about six weeks after the initial incident. About the author: Ms. Dana Tulis is the deputy offce director for the EPA Offce of Emergency Management. She has more than 31 years of experience in the environmental feld. She has provided leadership to the agency in determining the approach and supporting responses for chemical, biological, and radiological environ- mental responses since the 9/11 attacks. Bibliography: Visit www.uscg.mil/hq/nsfweb/AST/Site/Welcome%20_fles/Briefng%20Book%20 2012.pdf. Visit www.mass.gov/eea/docs/dep/cleanup/sites/nb610.doc. Endnotes: 1. The National Response Team is an organization comprised of 15 federal depart- ments and agencies responsible for coordinating emergency preparedness and response to oil and hazardous substance pollution incidents. The National Oil and Hazardous Substances Pollution Contingency Plan and the Code of Federal Regu- lations (40 CFR part 300) outline the role of the NRT and Regional Response Teams (RRTs). The NRT also develops procedures, in coordination with the National Strike Force Coordination Center, to ensure the coordination of federal, state, local governments, and private response to oil discharges and releases of haz- ardous substances (40 CFR § 300.110 (h) (5). The response teams are also cited in various federal statutes, including Superfund Amendments and Reauthorization Act (SARA) — Title III and the Hazardous Materials Transportation Act [HMTA]. Responses at this level are typically conducted using the Robert T. Stafford Disas- ter Relief and Emergency Assistance Act (Stafford Act) authorities assigned by the Department of Homeland Security (DHS) whereby agencies are tasked with work orders using mission assignments (MAs) within an appropriate emergency sup- port function (ESF) (e.g., aspects of the incident within their particular expertise). Typically, the EPA and NSF respond to large disasters or incidents with authorities granted to them through the ESF#10 Oil and Hazardous Materials MAs. 2. See www.nrt.org/Production/NRT/RRTHome.nsf/AllPages/othr_rrt.htm? OpenDocument, for more information on these agencies. 3. The methods used to estimate risk-based clearance goals for surfaces contami- nated by sulfur mustard are consistent with those developed by the EPA's Agency for Toxic Substances and Disease Registry, Occupational Safety and Health Administration, the New York State Department of Health, and the New York City Department of Health and Mental Hygiene for calculation of risk-based surface clearance goals subsequent to the World Trade Center collapse. Vessel Decontamination The plan called for applying undiluted household bleach to noncorrosive surfaces and diluted bleach to corrosive sur- faces, followed by a water rinse. The team devised two pro- tocols to decontaminate the hold where the clams had been stored, based upon the ambient temperature. In warmer temperatures, responders rinsed and agitated the hold with sea water, but when the temperatures were colder, employed a decontamination method involving undiluted bleach. The USCG sector and Atlantic Strike Team personnel ensured that the decontamination water was sampled before proper disposal. The sea water used in the hold contained no sodium hypochlorite, and that water was discharged back to the sea. After hold decontamination, teams conducted air monitor- ing and wipe sampling in areas used by the exposed crew members. The Catch To ensure there were no additional munitions in the remain- ing catch, responders temporarily removed the clams from refrigerated storage and scanned them with a U.S. Customs and Border Protection mobile cargo scanner. No muni- tions were found, and the clams were then returned to refrigeration. During the response, the USCG FOSC also tasked EPA per- sonnel with selecting disposal options for the clams. They came up with three options: • disposal at sea; • landfll burial; • incineration at a transfer, storage, and disposal facility. The frst two options were determined to be infeasible, due to a combination of factors, including public acceptance, cost, and an international ban on disposal of chemical muni- tions at sea; the need for analytical data from a source for which there were no existing sampling protocols; and the fact that the clams were already dead and putrefying. Eventually, the UC agreed that the best approach would be to transfer the clams from their cages into lined cubic yard boxes before sending them in refrigerated trucks for incin- eration at a transfer, storage, and disposal facility. Decontaminating the Clam Cages, Storage Facility, Truck As the clams were loaded onto refrigerator trucks for trans- portation to facilities in Texas and Arkansas for incineration, workers implemented the EPA's plans to clear the affected