oversight

Oil Dispersants: Additional Research Needed, Particularly on Subsurface and Arctic Applications

Published by the Government Accountability Office on 2012-05-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to Congressional Requesters




May 2012
             OIL DISPERSANTS

             Additional Research
             Needed, Particularly
             on Subsurface and
             Arctic Applications




GAO-12-585
                                                May 2012

                                                OIL DISPERSANTS
                                                Additional Research Needed, Particularly on
                                                Subsurface and Arctic Applications
Highlights of GAO-12-585, a report to
congressional requesters




Why GAO Did This Study                          What GAO Found
In April 2010, an explosion onboard the         According to experts, agency officials, and specialists, much is known about the
Deepwater Horizon drilling rig in the           use of chemical dispersants on the surface of the water, but gaps remain in
Gulf of Mexico led to a release of              several research areas. For example, experts generally agreed that there is a
approximately 206 million gallons of oil.       basic understanding of the processes that influence where and how oil travels
When an oil spill occurs, responders            through the water, but that more research was needed to quantify the actual rate
have several options for managing the           at which dispersants biodegrade. In addition, all the experts GAO spoke with said
environmental impacts, including using          that little is known about the application and effects of dispersants applied
chemical dispersants to break the oil           subsurface, noting that specific environmental conditions, such as higher
into smaller droplets, which can
                                                pressures, may influence dispersants’ effectiveness. Knowledge about the use
promote biodegradation and help
                                                and effectiveness of dispersants in the Arctic is also limited, with less research
prevent oil from coming on shore. GAO
was asked to review (1) what is known
                                                conducted on dispersant use there than in temperate or tropical climates. For
about the use of chemical dispersants           example, one expert noted that more research is needed on biodegradation rates
and their effects, and any knowledge            for oil in the Arctic because the cold temperature may slow the process down.
gaps or limitations; (2) the extent to          Federal agencies have funded over $15.5 million of dispersant-related research
which federal agencies and other                since fiscal year 2000, with more than half of the total funding occurring since the
entities have taken steps to enhance            Deepwater Horizon incident. Most of these 106 projects were funded by the
knowledge on dispersant use and its             Department of the Interior’s Bureau of Safety and Environmental Enforcement
effects; and (3) challenges, if any, that
                                                (BSEE), the National Science Foundation (NSF), and the Environmental
researchers and federal agencies face
                                                Protection Agency (EPA). Over 40 percent of the research projects were focused
in their attempts to enhance
knowledge. GAO collaborated with the            at least in part on testing dispersant effectiveness. For example, BSEE funded 28
National Academy of Sciences to                 projects on the efficacy of dispersants on different types of oil and under different
identify and recruit experts on                 ocean conditions. In contrast, relatively few projects were focused on applying
dispersant use and conducted                    dispersants subsurface or in the Arctic. Specifically, NSF funded three projects
interviews with these experts, agency           looking at the use and effects of subsurface dispersant application, and BSEE
officials, and other specialists, and           and EPA funded the eight projects related to the use of chemical dispersants in
reviewed key documents and reports.             Arctic or cold water environments.
                                                Researchers face resource, scientific, and communication challenges related to
What GAO Recommends                             dispersant research. Agency officials, experts, and specialists identified
GAO recommends, among other                     inconsistent and limited levels of funding as a challenge to developing research
things, that the Interagency                    on the use and effects of chemical dispersants. For example, because support
Coordinating Committee on Oil                   for dispersant research fluctuates, with temporary increases following a major
Pollution Research periodically provide         spill, it is difficult for federal agencies to fund longer term studies, such as those
updated information on key dispersant           needed to understand chronic toxicological effects of dispersants. In addition,
research by nonfederal sources. Also,           researchers face scientific challenges with respect to dispersants, including being
the Interagency Committee should                able to conduct research that replicates realistic oil spill conditions. Conducting
ensure that subsurface and Arctic               research in the open ocean faces several logistical barriers, and laboratory
applications are among the future               experiments are unable to fully approximate the scale and complexity of ocean
priority research areas. The                    conditions. Lastly, agency officials, experts, and specialists told GAO that it can
Departments of the Interior,                    be a challenge to communicate and track research. Although some organizations
Commerce, and Homeland Security,                have attempted to compile lists of dispersant-related research, currently there is
and the EPA generally concurred with            no mechanism that tracks dispersant research across all sources and highlights
the recommendations made to them.               past and ongoing research projects. For example, the Interagency Coordinating
                                                Committee on Oil Pollution Research—a multi-agency committee chaired by the
                                                Coast Guard—maintains a list of federally sponsored oil spill related research,
View GAO-12-585. For more information,
contact David C. Trimble at (202) 512-3841 or   but does not track or cross-reference related research that has been funded
trimbled@gao.gov.                               solely by industry or nongovernmental sources.

                                                                                          United States Government Accountability Office
Contents


Letter                                                                                   1
               Background                                                                4
               Much Is Known about Surface Use of Chemical Dispersants, but
                 Gaps Remain, Particularly about Subsurface and Arctic Use             13
               Federal Agencies, Industry, States, and Other Groups Have Funded
                 Research to Enhance Knowledge on the Use and Effects of
                 Dispersants                                                           25
               Dispersant Research Faces Resource, Scientific, and
                 Communication Challenges                                              39
               Conclusions                                                             44
               Recommendations for Executive Action                                    46
               Agency Comments                                                         47

Appendix I     Objectives, Scope, and Methodology                                      49



Appendix II    List of Experts Selected by the National Academy of Sciences            52



Appendix III   Listing of Federally Sponsored Research on Dispersants since
               Fiscal Year 2000, by Research Category and Agency                       53



Appendix IV    Comments from the Department of Commerce                                59



Appendix V     Comments from the Department of Homeland Security                       61



Appendix VI    Comments from the Department of the Interior                            63



Appendix VII   Comments from the Environmental Protection Agency                       65




               Page i                                            GAO-12-585 Oil Dispersants
Appendix VIII   GAO Contact and Staff Acknowledgments                                   67



Tables
                Table 1: Description of Weathering and Migration Processes That
                         Act on Spilled Oil                                               6
                Table 2: Federal Agencies’ Dispersant Research Funding since
                         Fiscal Year 2000                                               26
                Table 3: Federally Funded Dispersant Research Projects by
                         Research Area since Fiscal Year 2000                           30
                Table 4: Federally Sponsored Research on Dispersants since Fiscal
                         Year 2000, by Research Category and Agency                     53


Figure
                Figure 1: Ways in Which Spilled Oil Weathers and Migrates                 5




                Page ii                                           GAO-12-585 Oil Dispersants
Abbreviations
BSEE         Bureau of Safety and Environmental Enforcement
CEDRE        Centre of Documentation, Research and Experimentation on
             Accidental Water Pollution
CDC          Centers for Disease Control and Prevention
CRRC         Coastal Response Research Center
DHS          Department of Homeland Security
EPA          Environmental Protection Agency
HHS          Department of Health and Human Services
MSDS         Material Safety Data Sheet
NAS          National Academy of Sciences
NIH          National Institutes of Health
NIEHS        National Institute of Environmental Health Sciences
NIOSH        National Institute for Occupational Safety and Health
NOAA         National Oceanic and Atmospheric Administration
NSF          National Science Foundation
SMART        Special Monitoring of Applied Response Technologies

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Page iii                                                       GAO-12-585 Oil Dispersants
United States Government Accountability Office
Washington, DC 20548




                                   May 30, 2012

                                   The Honorable Brad Miller
                                   Ranking Member
                                   Subcommittee on Energy and Environment
                                   Committee on Science, Space, and Technology
                                   House of Representatives

                                   The Honorable Edward J. Markey
                                   House of Representatives

                                   On April 20, 2010, an explosion and fire onboard the Deepwater Horizon
                                   drilling rig in the Gulf of Mexico led to the largest oil spill in U.S. history,
                                   releasing approximately 206 million gallons of oil into the Gulf over a
                                   period of nearly 3 months. When an oil spill occurs in coastal waters of
                                   the United States, responders have several options for managing the
                                   environmental impacts of the spill, including the use of chemical
                                   dispersants. Dispersants do not reduce the total amount of oil entering
                                   the environment; rather, they help break down oil into small droplets that
                                   can more easily mix into the water below the surface, increasing
                                   biodegradation rates and potentially decreasing the impact of spilled oil
                                   on the shoreline. However, because chemical dispersants promote the
                                   movement of oil below the surface, their use exposes the underwater
                                   environment and the ocean floor to more of the spilled oil, where it may
                                   also have harmful effects. Therefore, decisions about whether to use
                                   dispersants involve trade-offs between the risks that untreated oil poses
                                   to the water surface and shoreline habitats and the risks that chemically
                                   dispersed oil poses to underwater environments, as well as the feasibility
                                   and limitations of alternative response options.

                                   To help inform oil spill response efforts and decision making, government,
                                   industry, and academic scientists have conducted research on the use
                                   and effects of chemical dispersants. Research on dispersants involves a
                                   range of interdisciplinary areas, including the effectiveness of such
                                   chemicals in dispersing oil; the fate and transport of dispersants and
                                   chemically dispersed oil––that is, where they ultimately go and how they
                                   travel with the water; aquatic toxicity and other environmental effects of
                                   dispersants and chemically dispersed oil; the modeling and monitoring of
                                   dispersant use; and human health effects.

                                   Oil spill responders have been using chemical dispersants since the
                                   1960s. No entity precisely tracks dispersant use, but according to federal


                                   Page 1                                                  GAO-12-585 Oil Dispersants
officials, dispersants have been used about 11 times in response to spill
events in U.S. waters. According to a study from the 2008 International
Oil Spill Conference, dispersants were applied over 200 times globally
from 1968 through 2007, though many of these applications involved
small amounts of dispersant. 1 During the Deepwater Horizon incident,
responders applied over 1.8 million gallons of chemical dispersants to the
spilled oil––an unprecedented volume in the United States. 2
Approximately 42 percent of this total was applied directly at the wellhead
more than 5,000 feet below the ocean’s surface—a method that had not
previously been used or planned. According to a presidential commission
that investigated the Deepwater Horizon incident, the future of domestic
oil production relies to a substantial extent on producing oil from current
offshore wells and expanding development into progressively deeper,
more distant waters, perhaps including challenging environments such as
the Alaskan Arctic, which will require response options that are viable in
such conditions. 3

In this context, you asked us to review chemical dispersant use and
research. Specifically, our objectives were to examine (1) what is known
about the use of chemical dispersants and their effects, and knowledge
gaps about or limitations to their use, if any; (2) the extent to which
federal agencies and other entities have taken steps to enhance
knowledge on chemical dispersant use and its effects; and (3) challenges,
if any, that researchers and federal agencies face in their attempts to
enhance knowledge on chemical dispersant use and its effects.

To determine what is known about the use and effects of chemical
dispersants and identify any knowledge gaps or limitations, we reviewed
documents and literature, including federal regulations, government oil
spill planning documents, scientific studies, and key reports on dispersant


1
 A. Findlay and A. Steen, “Frequency of Dispersant Use Worldwide,” International Oil Spill
Conference (2008). The International Oil Spill Conference provides a forum for
professionals from the international community, the private sector, government, and non-
governmental organizations to highlight and discuss innovations and best practices across
the spectrum of prevention, preparedness, response, and restoration.
2
 In response to the Ixtoc spill, which occurred in 1979-1980 off the coast of Mexico,
responders applied 2.7 million gallons of dispersants to the surface of the water.
3
 National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, Deep
Water: The Gulf Oil Disaster and the Future of Offshore Drilling (Washington, D.C.:
January 2011).




Page 2                                                          GAO-12-585 Oil Dispersants
use to determine areas of research that inform planning and decision
making regarding the use of chemical dispersants. In addition, we
collaborated with the National Academy of Sciences (NAS) to identify 11
academic, industry, and other researchers recognized as experts in their
respective scientific fields and capable of advising us on chemical
dispersant use and research; hereafter, these scientists and researchers
will be referred to as “experts.” A list of these experts can be found in
appendix II. NAS staff selected these experts based on their knowledge
of one or more of the following topic areas: dispersant effectiveness,
toxicity of dispersants and dispersed oil, fate and transport of dispersants
and dispersed oil, and monitoring actual dispersant use, among others.
We conducted semi-structured interviews with these experts to discuss
the state of knowledge, including gaps, regarding dispersant research.
We supplemented our semi-structured expert interviews with interviews of
federal officials and other oil spill or dispersant specialists, including state
officials who have been involved in past response actions, human health
researchers, oil spill response organizations with expertise in applying
chemical dispersants, industry representatives with experience in
researching oil dispersants and responding to oil spills, and other relevant
non-governmental organizations, such as a regional advisory group
focused on environmental protection as it relates to oil production and
transportation. Statements from these groups will be identified as being
from “specialists.”

To determine the extent to which federal agencies and other entities have
taken steps to enhance knowledge on chemical dispersant use and its
effects, and what challenges, if any, researchers have faced, we analyzed
information supplied by and conducted interviews with officials from
federal agencies conducting research on dispersant use and effects: the
Department of the Interior’s Bureau of Safety and Environmental
Enforcement (BSEE), the Department of Homeland Security’s (DHS)
United States Coast Guard (Coast Guard), the Environmental Protection
Agency (EPA), the Department of Health and Human Services’ (HHS)
National Institutes of Health (NIH) and Centers for Disease Control and
Prevention (CDC), the Department of Commerce’s National Oceanic and
Atmospheric Administration (NOAA), and the National Science
Foundation (NSF). We also analyzed information supplied by and
conducted interviews with specialists, as identified above. In addition, we
attended a NOAA-funded workshop on the future of dispersant use to
gather information on both the state of knowledge and ongoing research
and an industry-funded workshop of key federal, state, and local
responders, academic researchers, and other stakeholders who could
potentially be affected by an accidental offshore oil spill along the Eastern


Page 3                                                 GAO-12-585 Oil Dispersants
             seaboard of the United States. Appendix I provides a more detailed
             description of our scope and methodology.

             We conducted this performance audit from March 2011 through May
             2012, in accordance with generally accepted government auditing
             standards. Those standards require that we plan and perform the audit to
             obtain sufficient, appropriate evidence to provide a reasonable basis for
             our findings and conclusions based on our audit objectives. We believe
             that the evidence obtained provides a reasonable basis for our findings
             and conclusions based on our audit objectives.


             Crude oil is a naturally occurring substance generated by geological and
Background   geochemical processes. A variety of petroleum products, such as
             gasoline, diesel fuel, and heavy fuel oil are derived from this natural
             resource. Crude oil and petroleum products can vary greatly depending
             on where and how they were extracted and refined, and their unique
             characteristics influence how they will behave when released into water
             and how they will affect animals, plants, and their habitats. Because oil is
             typically less dense than water, oil spills on or near the surface of water
             will float and form slicks. An untreated slick will remain at the surface until
             it evaporates, disperses naturally into the water column, washes onto the
             shoreline, breaks up into smaller collections of oil—known as tarballs—or
             is recovered or removed from the water.

             Oil or petroleum products spilled on water undergo a series of physical
             and chemical processes that may cause the oil to change––known as
             weathering––or migrate. Some processes cause oil to be removed from
             the water’s surface, while others change its form on the surface. Figure 1
             depicts these processes, which are further described and defined in
             table 1.




             Page 4                                                 GAO-12-585 Oil Dispersants
Figure 1: Ways in Which Spilled Oil Weathers and Migrates




                                        Page 5              GAO-12-585 Oil Dispersants
Table 1: Description of Weathering and Migration Processes That Act on Spilled Oil

 Process                                      Description of action on spilled oil
 Drifting                                     Physical movement of surface oil from one location to
                                              another due to the combined effects of wind, waves,
                                              currents, and tides
 Spreading                                    Expansion of oil on the sea surface
 Evaporation                                  Physical-chemical process resulting in transfer of
                                              hydrocarbons from the sea surface to the atmosphere
 Emulsification and mousse                    Formation of water in oil emulsions that can contain as
 formation                                    much as 75 to 80 percent water
 Dispersion                                   Transport of oil from the sea surface into the water
                                              column due to wave action
 Dissolution                                  Physical-chemical process resulting in dissolution of
                                              hydrocarbons in the water column
 Sinking/Sedimentation                        Increase in density of oil due to weathering and
                                              interaction with suspended sediments or material of
                                              biological origin; deposition of material to the sea floor
 Atmospheric transport                        Transport of evaporated hydrocarbons in the atmosphere
 Biodegradation                               Biological-chemical process altering or transforming
                                              petroleum hydrocarbons through microbial action
 Photo-oxidation                              Transformation of petroleum hydrocarbons through
                                              interaction with sunlight
Source: ExxonMobil Oil Spill Response Field Manual.



Regardless of their physical and chemical properties, all oils will weather
once spilled. The rate of weathering depends on the conditions at the
time of the spill and the nature of the spilled oil. Most weathering
processes are highly temperature dependent, however, and will often
slow considerably as the temperature approaches freezing
temperatures. 4

When an oil spill occurs underwater, such as during a well blowout or
pipeline rupture, 5 it forms underwater plumes of oil droplets that billow
and drift beneath the ocean’s surface. Water temperature and salinity, the
depth of the leak, the density of the oil, and the pressure with which it is
flowing, among other things, can affect plume formation. Because oil is


4
 National Research Council, Oil in the Sea III: Inputs, Fates, and Effects (Washington,
D.C.: 2003).
5
 A blowout is an uncontrolled release of oil or gas from a well.




Page 6                                                                         GAO-12-585 Oil Dispersants
less dense than water, it will float toward the surface. The speed at which
it rises is based on the oil’s droplet size—the larger the droplet the faster
the oil rises. Once it reaches the surface, the oil forms a slick thinner than
those that result from surface spills, in part because of the diffusion and
dispersal of oil droplets as they rise. 6

When an oil spill occurs, responders have several techniques for
responding, including the following: 7

•   Chemical dispersants—applying chemicals to help break up the oil
    into smaller droplets to facilitate the movement of the oil off the
    surface and into the water column and enhance microbial breakdown
    of the oil.

•   Mechanical containment and recovery—using booms, skimmers,
    sorbents, and other techniques to trap and remove the oil. 8

•   In-situ burning—burning spilled oil on the surface of the water.

•   Shoreline clean-up—physically picking up oil and washing or
    chemically treating shorelines, or deploying bioremediation, which
    involves the addition of nutrients to enhance the ability of
    microorganisms to degrade the oil more rapidly.

•   No action—taking no active response to the spill.

Each response technique has its own operational requirements, benefits,
limitations, and potential adverse impacts. Responders must evaluate
which method or combination of methods to use depending on the
circumstances and conditions of the oil spill, such as the weather, sea



6
 National Research Council, Oil in the Sea III: Inputs, Fates, and Effects (Washington,
D.C.: 2003).
7
 Well containment and source control are other response options taken after an event
such as a blowout or spill to regain control of the well and capture any released oil. This
response option was outside the scope of this review. See GAO, Oil and Gas: Interior Has
Strengthened Its Oversight of Subsea Well Containment, but Should Improve Its
Documentation, GAO-12-244 (Washington, D.C.: Feb. 2012) for related report.
8
 Booms are floating barriers that serve to contain an oil spill; oil skimmers are devices that
remove oil floating on the surface of a body of water, and sorbents are sponges used to
absorb oil.




Page 7                                                           GAO-12-585 Oil Dispersants
state, type and amount of oil spilled, distance of spill from shore, and
potentially affected natural resources. In the United States, mechanical
containment and recovery is the primary response option, since it
physically removes oil from the environment. However, experience has
shown that mechanical containment and recovery in open waters can be
limited depending on sea conditions. Specifically, for such operations to
be conducted most effectively, seas need to be relatively calm, with
waves under about 3 feet, according to documents we reviewed and
specialists with whom we spoke.

Oil spills inevitably have environmental impacts, and response actions
may only reduce these impacts or shift them. In determining which
response options are best for an individual spill, agency officials said that
decision makers weigh the ecological risks and consequences with the
goal of minimizing adverse effects as much as possible. 9 For example,
when considering the use of chemical dispersants as a response option,
the essential question asked is whether dispersing the oil into the water
column offers more benefits (i.e., causes less harm) than leaving the oil
on the surface if it cannot be adequately removed by mechanical means
or burned. Decision makers would collect as much information as
possible to assess, for example, whether the potential harm to wetlands
or waterfowl that could occur if dispersants were not applied is greater
than the potential harm to marine species from chemically dispersed oil
entering the water column. This evaluation of these trade-offs is
sometimes called a net environmental benefit analysis.

Chemical dispersants function by reducing the surface tension between
oil and water—similar to the way that dish detergents break up cooking oil
on a skillet—and enhancing the natural process of dispersion by
generating larger numbers of small droplets of oil that are mixed into the
water column by wave energy. Thus, rather than having a surface slick of
oil, one will have an underwater plume of chemically dispersed oil.
Throughout this report we use the term “chemically dispersed oil” to
discuss the mixture that results when chemical dispersants are applied to
oil and facilitate the formation of oil droplets. A typical commercial
dispersant contains a mixture of three types of chemicals: surfactants,
solvents, and additives. Surfactants are the active agents that reduce oil-


9
 According to agency officials, it is important to note that there is not an expectation that
any response option will be 100 percent effective. Spill responses generally involve an
integrated combination of response options.




Page 8                                                            GAO-12-585 Oil Dispersants
water surface tension. Surfactant compounds contain both oil-compatible
and water-compatible groups on the same molecule, with the oil-
compatible group interacting with oil and the water-compatible group
interacting with water to make the interaction between the two easier.
Solvents are added to promote the dissolution of the surfactants and
additives into the dispersant mixture and then, during application, into the
oil slick. Additives may be present for a number of purposes, such as
improving the dissolution of the surfactants and increasing the long term
stability of the dispersant formulation.

Federal statutes required the development of a National Oil and
Hazardous Substances Pollution Contingency Plan that, among other
things, delineates the procedures for preparing for and responding to oil
spills and details the roles and responsibilities of federal agencies and
others involved in dispersant decision making. 10 Specifically, the National
Contingency Plan is based on a framework that brings together the
functions of the federal government, the affected state governments, and
the party responsible for a spill under a unified command to achieve an
effective and efficient response. In response to an oil spill, the National
Contingency Plan calls for a Federal On-Scene Coordinator to direct and
coordinate response efforts. In the case of oil spills in the coastal zone, 11
such as in the Deepwater Horizon incident, a representative from the
Coast Guard serves as the Federal On-Scene Coordinator. EPA provides
the Federal On-Scene Coordinator for spills occurring in the inland zone,
and the designation of these zones is documented in the Regional
Contingency Plans.

As part of the National Contingency Plan, EPA maintains the National Oil
and Hazardous Substances Pollution Contingency Plan Product
Schedule, which lists chemical dispersants that may be authorized for use



10
 Development of a National Contingency Plan is required by the Comprehensive
Environmental Response, Compensation, and Liability Act, as amended, and the Clean
Water Act, as amended.
11
  As defined for the purpose of the National Contingency Plan, the coastal zone means all
U.S. waters subject to the tide, U.S. waters of the Great Lakes, specified ports and
harbors on inland rivers, waters of the contiguous zone, other waters of the high seas
subject to the National Contingency Plan, and the land surface or land substrata, ground
waters, and ambient air proximal to those waters. The term coastal zone delineates an
area of federal responsibility for response action. Precise boundaries are determined by
EPA/Coast Guard agreements and specified in federal Regional Contingency Plans.




Page 9                                                        GAO-12-585 Oil Dispersants
on oil discharges. 12 Inclusion on the Product Schedule does not mean
that EPA recommends the product for use; rather, it only means that
certain data have been submitted to EPA and that the dispersant has a
certain effectiveness. The data that a manufacturer must submit to EPA
includes effectiveness and toxicity data, special handling and worker
precautions for storage and application, recommended application
procedures and conditions for use, and shelf life. An appendix to the
regulations implementing the National Contingency Plan describes the
test methods a manufacturer is to follow for measuring effectiveness and
toxicity of dispersants. In terms of effectiveness, the manufacturer must
demonstrate that the dispersant can disperse at least 45 percent of oil in
testing. To assess toxicity, the appendix specifies the standard test for a
chemical dispersant, which involves exposing two species––silverside
fish (Menidia beryllina) and mysid shrimp (Mysidopsis bahia)—to varying
concentrations of the dispersant, oil, and a mixture of the two, to
determine mortality rates at the end of 96 hours for silversides and 48
hours for mysid shrimp. Chemical dispersant manufacturers must submit
the results of effectiveness and toxicity testing to EPA, which may request
further documentation or verify test results in determining whether the
dispersant meets listing criteria. Both the presidential commission that
investigated the Deepwater Horizon incident and the EPA Inspector
General have recommended that EPA update the Product Schedule’s
testing protocols and requirements for listing. 13 In addition, the EPA
Inspector General recommended, among other things, that EPA modify
the Product Schedule and contingency plans to include additional
information learned from the Deepwater Horizon oil spill response, such
as subsurface dispersant application in deep water. EPA anticipates
issuing a proposed rule in winter 2012 that would revise the requirements
for listing a product on the Product Schedule and is considering changes
to effectiveness and toxicity testing protocols.

A National Response Team and Regional Response Teams serve as
preparedness and planning organizations prior to a response and may
serve as incident-specific response teams to provide support and advice
to the Federal On-Scene Coordinator during a response. The National



12
 33 U.S.C. § 1321(d)(G)(i) (2006); 40 C.F.R. § 300.5 (2011).
13
  EPA, Office of Inspector General, Revisions Needed to National Contingency Plan
Based on Deepwater Horizon Oil Spill, Report No. 11-P-0534 (Washington, D.C.: Aug. 25,
2011).




Page 10                                                        GAO-12-585 Oil Dispersants
Response Team includes 20 federal departments and agencies
responsible for national response and preparedness planning, for
coordinating regional planning, and for providing policy guidance and
support to Regional Response Teams. 14 Regional Response Teams are
composed of representatives of each National Response Team agency
and representatives from relevant state and local governments (as
agreed upon by the states) and may also include tribal governments.
There are 13 Regional Response Teams corresponding to the 10
standard federal regions, plus separate teams for Alaska, Oceania in the
Pacific, and the Caribbean. The Regional Response Teams develop
Regional Contingency Plans establishing procedures for preparing for
and responding to oil spills in the region. Within the regions, area
committees composed of officials from federal, state, and local agencies
have been designated to develop Area Contingency Plans.

Regional and Area Contingency Plans may address the specific situations
in which chemical dispersants should and should not be used and may
preauthorize their use by the Federal On-Scene Coordinator.
Preauthorization plans may address factors such as the potential sources
and types of oil that might be spilled, the existence and location of
environmentally sensitive resources that could be affected, available
dispersant stockpiles, available equipment and adequately trained
operators, and means to monitor product application and effectiveness.
The details and procedures for preauthorized use vary by region;
however, plans generally preauthorize use of dispersants for areas at
least 3 nautical miles from shore with water at least 10 meters deep, and
the chemical dispersant must be listed on EPA’s Product Schedule. If
dispersants are not preauthorized, the Federal On-Scene Coordinator
may authorize use of dispersants on the Product Schedule with the
concurrence of EPA and appropriate state representatives and in
consultation with the Department of Commerce and Department of the


14
  The 20 members include EPA; the Coast Guard; the Department of Commerce’s NOAA,
National Ocean Service and Office of Response and Restoration; the Department of
Energy’s Office of Health, Safety and Security and National Nuclear Security
Administration; the Department of Health and Human Services’ Centers for Disease
Control and Prevention and National Institute for Occupational Safety and Health; the
Department of the Interior’s Office of Environmental Policy and Compliance and Minerals
Management Service (now reorganized into the Bureau of Safety and Environmental
Enforcement, the Bureau of Ocean Energy Management, and the Office of Natural
Resources Revenue); the Departments of Agriculture, Defense, Justice, Labor,
Transportation, and State; the Federal Emergency Management Agency; the General
Services Administration; and the Nuclear Regulatory Commission.




Page 11                                                     GAO-12-585 Oil Dispersants
Interior. The Federal On-Scene Coordinator may authorize the use of any
dispersant, including products not listed on the Product Schedule, without
obtaining concurrence, when, in the judgment of the coordinator, the use
of the product is necessary to prevent or substantially reduce a hazard to
human life. Currently, most Regional Contingency Plans include
preauthorization for application of dispersants on the surface in certain
areas; however, none of the plans include preauthorization for subsurface
application of dispersants in deep water. 15

During the Deepwater Horizon incident, chemical dispersants were used
with and without preauthorization and were applied at various times
throughout the response by airplane, boat, and deep water, subsurface
injection at the wellhead. The aerial and boat applications were
preauthorized, but subsurface injection of dispersants, which had never
previously been used, was guided by a directive and a series of addenda
to that directive. This directive and its addenda were established jointly by
the Coast Guard and EPA as the spill was occurring, and these
documents placed certain restrictions on dispersant use. Because of
complications and uncertainties related to real time authorization of
chemical dispersant use in this novel manner, the EPA Inspector General
recommended in its 2011 report that EPA develop policies and
procedures to govern subsurface dispersant use and to modify
preauthorization plans to specifically address subsurface application of
dispersants. According to agency officials, the National Response Team
has drafted guidelines for subsurface dispersant monitoring and
application and expects to finalize them by winter 2012.




15
  Four Regional Contingency Plans do not currently contain preauthorized use of
chemical dispersants—Alaska, and the three regions that are inland and without access to
oceans. In addition, dispersants are typically not preauthorized or used inland or in fresh
water.




Page 12                                                        GAO-12-585 Oil Dispersants
                              According to experts we spoke with, there is a significant body of
Much Is Known about           research on the use of chemical dispersants on the surface of the water,
Surface Use of                but some gaps remain in several research areas. Moreover, experts
                              highlighted two additional areas in which knowledge is limited and more
Chemical Dispersants,         research is needed—the subsurface application and effects of
but Gaps Remain,              dispersants in deep water environments and the use of dispersants in
Particularly about            Arctic and other cold water environments.

Subsurface and Arctic
Use

Surface Use of Dispersants    According to experts, agency officials, and specialists we spoke with,
Reflects a Significant Body   much is known about the use of dispersants on the surface of the water;
of Research, but Gaps         however, they said that gaps remain in several research areas.
                              Specifically, experts, agency officials, and specialists described the state
Remain                        of knowledge and gaps in the following six research areas:

                              •   effectiveness in dispersing oil,

                              •   fate and transport of chemically dispersed oil,

                              •   aquatic toxicity and environmental effects of chemically dispersed oil,

                              •   modeling of chemically dispersed oil,

                              •   monitoring of chemically dispersed oil, and

                              •   human health effects.

                              Effectiveness in dispersing oil. Most of the 11 experts we interviewed
                              agreed that there is a large body of research on the effectiveness of
                              chemical dispersants, and many said that there is a solid understanding
                              of the factors that may influence the effectiveness of such dispersants
                              when used on the surface. For a dispersant to be effective, the oil must
                              be dispersible, and there must be sufficient mixing energy––the energy
                              generated by movement of the water from wind and wave action—to
                              allow formation of smaller oil droplets and to disperse these droplets into
                              the water column. Whether these two conditions are satisfied relies on a
                              complex set of factors, including the type of oil spilled, how the long the
                              oil has been exposed to the environment, and sea and weather
                              conditions. One of the primary factors in the dispersability of oil is its



                              Page 13                                               GAO-12-585 Oil Dispersants
viscosity––the resistance of a liquid to flow. Oils that do not flow easily
have a high viscosity and are more difficult to disperse; oils that flow
easily have a low viscosity and tend to be more dispersible. Oil viscosity
is influenced by its type and the amount of change or weathering it has
undergone. For example, many experts stated that chemical dispersants
are more effective in dispersing light to medium crude oils, which have a
lower viscosity, than heavy oils, which have a higher viscosity. In addition,
the longer oil weathers, the more viscous––and thus less dispersible––it
becomes. This means chemical dispersants need to be used quickly after
a spill––typically within hours to 1 to 2 days after a spill, depending on
conditions––before the oil has weathered substantially. At a certain level
of viscosity, dispersants are no longer effective. Many experts also told us
that chemical dispersants are more effective in dispersing oil in
moderately wavy seas than in calm seas because of the mixing energy
such sea states provide, and dispersants would likely not be used in very
stormy, wavy seas because such conditions would disperse the oil
naturally and present operational difficulties. In addition, the effectiveness
of a chemical dispersant depends on the ratio of chemical dispersant to
oil. Planning guidelines generally recommend a ratio of 1 part dispersant
to 20 parts oil. However, some experts and specialists told us that the
minimum effective dispersant-to-oil ratio can also vary greatly based on
the type of oil and degree of weathering. Thus, some light oils, if fresh,
may only require ratios of 1:40 or less, whereas weathered or more
viscous oils may require ratios above 1:20.

While there is a large body of research on the effectiveness of chemical
dispersant use on the surface of the water, experts identified a number of
areas in which they believe additional study is needed. Specifically, some
experts told us that research on effectiveness should more closely
resemble real world conditions, rather than the artificial conditions often
experienced in a laboratory. For example, one expert said that some
laboratory effectiveness tests involve less mixing energy than real world
conditions found in the ocean, and therefore, dispersant effectiveness
rates may be understated. In addition, the properties of oil can vary
greatly depending on the source, and some experts said that more
research should be conducted on the effectiveness of different dispersant
formulations on different types of oil. Because there are hundreds of
types of oil, specific dispersants may work better on certain types of oil
than others. Some experts also said that more research is needed to
better understand the effectiveness of dispersants on heavily weathered
and emulsified oil, noting that dispersants are typically applied on the
surface just once; however, applying dispersants twice may increase their
effectiveness on emulsified oil.


Page 14                                               GAO-12-585 Oil Dispersants
Fate and transport of chemically dispersed oil. Many of the experts we
spoke with indicated that there is a basic understanding of the processes
that influence the fate and transport of chemically dispersed oil, but that
fate and transport of oil are subject to many complex processes, some of
which are better understood than others. Specifically, most experts whom
we spoke with agreed that the use of chemical dispersants increases
biodegradation rates, as dispersants help reduce the size of oil droplets,
making them more accessible to microbes that feed on them. Experts
differed in their views with regard to the extent to which factors such as
evaporation, photo-oxidation, and dissolution influence the fate of
chemically dispersed oil. For example, some experts said that
dissolution—the chemical stabilization of oil components in water—
increases with dispersant use; whereas, other experts said that more
research is needed to understand the relationship between dispersant
use and dissolution. Chemically dispersed oil is transported both vertically
and horizontally through the water by wind, waves, and currents. Once
droplets are dispersed vertically into the water column, most oil droplets
will be positively buoyant and will rise toward the surface. The speed at
which the droplets will rise depends on their diameter, with the smallest
droplets rising very slowly. For example, according to a 2005 National
Academy of Sciences report on chemical dispersants, a droplet with a
diameter of 300 micrometers (0.3 millimeters) would take less than 8
minutes to rise 3 meters, while a droplet with the diameter of 30
micrometers (0.03 millimeters) would take over 12 hours to rise the same
distance. 16 Once the oil is dispersed below the surface, subsurface
currents move the location of the oil droplets horizontally. In some cases,
the direction the oil will travel below the surface will be different than it
traveled on the surface because the direction of the currents may be
different than the direction of the wind. When currents are non-uniform,
mixing is produced that further dilutes and disperses oil droplets
throughout the water. Many experts also told us that chemically dispersed
oil, as compared with oil that is naturally dispersed, reduces the likelihood
of oil droplets reforming into slicks because of the smaller droplet size—
which allow for greater dispersion and slower rise rates.

The experts we spoke with also identified several research gaps related
to the fate and transport of chemically dispersed oil. For example, most



16
  National Research Council, Oil Spill Dispersants: Efficacy and Effects (Washington,
D.C.: 2005).




Page 15                                                       GAO-12-585 Oil Dispersants
experts told us that the use of chemical dispersants increases
biodegradation rates, but many told us that more research was needed to
quantify the actual rate at which biodegradation occurs. Additionally,
many experts said that more research is needed to understand the
specifics of transport within the water column and oil droplet size, since
they are important factors for determining whether the chemically
dispersed oil will remain in the water column or float back to the surface.
Many experts also said that more research is needed on chemically
dispersed oil’s interactions with suspended particulate material,
interactions that occur when oil droplets attach to small particles such as
sediment. Such oil-particle combinations could influence fate and
transport in various ways, such as preventing the oil from recoalescing.
Also, some combinations may potentially sink to the bottom, and others
may remain suspended in the water column. According to a 2005
National Academy of Sciences report, gaps related to understanding the
fate of chemically dispersed oil and the interaction of the dispersed oil
with sediments could be addressed through the use of actual spill events
to conduct research and collect data.

Aquatic toxicity and environmental effects of chemically dispersed oil.
Most of the experts we interviewed agreed that there is a large amount of
research on the acute toxicity of chemically dispersed oil but that less
research has been done on its possible chronic effects. According to a
2005 National Academy of Sciences report, the toxicity of chemically
dispersed oil typically results primarily from compounds within the oil
itself––not the dispersant—as numerous studies have found dispersants
to be significantly less toxic than oil or dispersed oil. Most experts we
spoke with told us a large number of the completed toxicity studies have
focused on the acute––rather than chronic––effects of certain aquatic
species’ exposure to chemically dispersed oil. Tests have shown that
acute toxicity levels and sensitivity to chemically dispersed oil vary by
species and life stage. For example, crustaceans, such as crabs, and
mollusks, such as clams, appear to be more sensitive than fish, and larval
stages of fish appear to be more sensitive than adults. 17 Most of the
toxicity tests have focused on a chemical dispersant product line called




17
  These acute toxicity tests generally measure the concentration that would cause death
in 50 percent of the test population—known as LC50.




Page 16                                                       GAO-12-585 Oil Dispersants
COREXIT®, 18 which is the most widely stockpiled dispersant in the United
States. Additionally, most experts said that chemically dispersed oil can
increase oil’s bioavailability—how easily an organism can take up a
particular contaminant from the environment—which can have varying
harmful effects. For example, many experts said that chemical dispersion
will alter the bioavailability of oil. Exposure to shoreline and surface oil
may decrease for wildlife, such as birds or marine mammals, but
exposure may increase for species living in the water column, such as
certain fish or plankton.

Experts also identified several knowledge gaps and limitations in regard
to information on the toxicity of chemically dispersed oil. In particular,
most experts told us that research on the chronic effects of exposure has
been more limited, and many identified this as an area in which more
research is needed. Lack of research on chronic effects limits the
understanding of how marine communities and populations—including
corals, fish, and marine mammals—are affected by dispersant use over
the long term. In addition, many experts said that more research is
needed to understand the impact of chemically dispersed oil on marine
communities and populations. For example, one expert noted that the
rate of recovery for species is a key aspect for determining the trade-offs
of using chemical dispersants. Furthermore, some experts questioned the
usefulness of some toxicity research, noting that this research was
generally not conducted using consistent methodological approaches,
which limits its comparability. For example, one expert said that early
toxicity research did not include chemical analysis, which limits the
comparability of older studies to more recent ones that contain such
analysis. Additionally, some experts noted that while there are many
studies on COREXIT®, there are few studies on the toxicity of the other
dispersants on the Product Schedule. In addition, some experts and
specialists we spoke with questioned the applicability of the research to
real world spill scenarios. Specifically, one expert said that the
concentrations and durations of exposure to chemically dispersed oil
often used in the laboratory do not reflect oil exposure concentrations and
durations during an actual spill. Many laboratory tests use a constant



18
  COREXIT® EC9500A and COREXIT® EC9527A were the two dispersants used during
the Deepwater Horizon incident. Of the approximately 973,000 gallons of aerial
dispersants sprayed by responders, nearly 215,000 gallons were COREXIT® EC9527A,
and the remaining 758,000 gallons were COREXIT® EC9500A. All 771,000 gallons of
dispersant used for subsurface injection were COREXIT® EC9500A.




Page 17                                                 GAO-12-585 Oil Dispersants
exposure level over a period of 96 hours (4 days), while during a
dispersant application on a real spill, the concentration of chemically
dispersed oil could be very high when first applied but will decline quickly
over a matter of hours, particularly in the open ocean. Thus, some
experts noted the need for more studies using realistic exposure
scenarios and consistent methodologies.

Further, many experts said that research should be conducted on a
broader range of species, as the majority of research has been conducted
on a small number of species. For example, one expert said that it is not
always possible to extrapolate from the standard test species––silverside
fish and mysid shrimp—to other species, particularly from different
regions or climates. Another expert noted that since it is not practical to
test every species, those that are tested need to be ones that can be
extrapolated to the key species in each region. In addition, according to
EPA researchers, additional research is needed to better understand
photoenhanced toxicity—the increase in toxic effects resulting from the
synergistic interaction of components of oil accumulated by aquatic
organisms and the ultraviolet radiation in natural sunlight. Recent studies
demonstrate that chemically dispersed oil was substantially more toxic to
early life stages of fish and invertebrates under the light wavelengths and
intensity present in aquatic habitats than under the light systems used to
generate toxicity data in the laboratory, but additional research is needed
according to EPA researchers.

Modeling of chemically dispersed oil. Models that are used to predict how
spilled oil will behave in the environment rely upon a number of inputs,
but according to most experts we spoke with, modeling efforts are limited
by the accuracy of inputs to the model, and the experts said that they
believe that more research is needed to improve these inputs.
Specifically, fate and transport models rely on a variety of inputs,
including dispersant effectiveness, wind speed, and ocean currents.
Some experts we spoke with questioned the accuracy of some of these
inputs, which has implications for the predictive value of the model and
may result in greater uncertainty with regard to the ultimate fate and
transport of the dispersed oil. For example, some experts noted that more
research is needed to more quantitatively measure dispersant
effectiveness, including the amount of oil dispersed below the surface as
droplets and the resulting droplet size distribution.

Monitoring of chemically dispersed oil. Some experts told us the
monitoring protocols currently used are generally sufficient for their
intended purpose of determining whether oil is dispersing. The primary


Page 18                                              GAO-12-585 Oil Dispersants
tool used to monitor this is the Special Monitoring of Applied Response
Technologies (SMART) protocols, 19 which were established by a multi-
agency group—including Coast Guard, NOAA, EPA, CDC, and BSEE—
and are implemented by the Coast Guard in spill response. These
protocols establish a system for rapid collection of real-time, scientifically
based data to assist in decision making related to whether additional
chemical dispersants should be applied to break up remaining oil on the
surface of the water. These protocols rely heavily on trained personnel to
visually observe dispersed oil, collect water samples, and measure the
amount of oil in the water using a fluorometer—a device that detects the
presence of oil in the water column by measuring the light emitted when
certain oil compounds are exposed to ultraviolet light—which helps
indicate that the dispersant is having its desired effect. Some experts
stated that the fluorometry equipment used for the SMART protocols is
useful for determining the initial effectiveness of dispersants—that is,
whether or not oil is being broken up and distributed through the water
column during an oil spill response. Additionally, one expert said that the
SMART protocols are simple, well defined, and standardized and are able
to quickly provide information to decision makers during emergency
response operations.

Many experts and a NOAA review of SMART protocol implementation
also said that the protocols and the equipment used could be enhanced
to provide some in-depth information to help inform research efforts to
address gaps or to further assess the effectiveness of chemical
dispersants. For example, some experts told us that the protocols do not
provide an analysis of oil composition to determine whether and how long
the dispersant remains present in the water and continues to break up the
oil, making it difficult to assess the true effectiveness. Additionally, the
SMART protocols were focused on providing operational guidance on
dispersant effectiveness and were not designed to monitor the fate,
effects, or impacts of chemically dispersed oil, but many experts said that
research should be conducted to integrate monitoring of fate and effects
into the protocols. Doing so would help inform research efforts to better


19
  The SMART protocols involve three levels, or tiers, of assessment. In general, Tier 1
involves observation by a trained observer from an aerial platform. Observations are
documented and supplied to the command center. Tier 2 involves teams on a boat
conducting sampling using a fluorometer and is intended to confirm visual observations
obtained during Tier 1 operations. Sampling is done to determine background, pre-
application, and post-application levels of oil. Tier 3 involves more sample collection and
monitoring at multiple depths with instruments.




Page 19                                                          GAO-12-585 Oil Dispersants
address gaps and help spill responders make better decisions. Some
experts also told us that the fluorometry technology used in SMART is
limited in that it only measures a portion of oil components and that the
standardization and calibration of this equipment could be improved.
Many experts also told us SMART could be enhanced with different,
newer equipment, such as particle size analyzers to measure oil droplet
size, which could better monitor chemically dispersed oil. Moreover, a
February 2012 NOAA review of SMART monitoring protocol
implementation during the Deepwater Horizon incident found that the
SMART protocols were not sufficient to determine the effects of the
dispersant and oil on marine life in the water column. In addition, the
report found that for large spills with information needs beyond the
question of whether the oil is dispersing, the protocols need to be
revamped. This review concluded that the SMART monitoring
methodologies used during the Deepwater Horizon incident lacked rigor
and repeatability.

Human health effects. HHS officials and human health specialists we
spoke with noted that toxicity information is available for the individual
ingredients of some dispersants––particularly COREXIT® EC9500A––
and those individual ingredients are generally believed to be not
particularly toxic to humans. Furthermore, HHS officials and human
health specialists we spoke with noted that there is little likelihood that the
general public will be exposed to dispersants or chemically dispersed oil.
Individuals involved in cleanup operations that directly handled
dispersants or worked in the immediate area of application would likely
have greater potential exposure to dispersants and therefore might have
a greater risk of adverse effects. However, during the Deepwater Horizon
incident, a National Institute for Occupational Safety and Health (NIOSH)
Health Hazard Evaluation looked at the potential exposure of these
highest risk groups and found that indicators of dispersant exposure were
nondetectable or at levels well below applicable occupational exposure
limits. 20 In addition, the Material Safety Data Sheet for COREXIT®
EC9500A—the dispersant most used during the Deepwater Horizon
incident response—states that potential human exposure will be low if
recommended product application procedures and use of personal
protective equipment such as use of hand, skin, and eye


20
  As part of the CDC, NIOSH conducts research and develops guidance and
recommendations for the prevention of work-related illnesses, injuries, disability, and
death.




Page 20                                                          GAO-12-585 Oil Dispersants
protection are followed. 21 In addition, in laboratory tests following the
Deepwater Horizon incident, NIOSH researchers found no long-term
negative health effects due to short-term dermal or inhalation exposure to
COREXIT® EC9500A. However, adverse effects of longer-term exposure
have not been evaluated, according to HHS officials. With regard to
seafood safety, studies indicate that the dispersants used during the
Deepwater Horizon incident did not accumulate in seafood, and therefore
there is no public health concern from them because of seafood
consumption, according to the FDA. To ensure consumers had
confidence in the safety of seafood being harvested from the Gulf, NOAA
and FDA developed a chemical test for the presence of dispersant in
seafood. Most of the seafood samples tested had no detectible oil or
dispersant residue. For the few samples in which some residue was
detected, the levels were far lower than the amounts that would cause a
health concern, even when seafood is eaten on a daily basis.

Agency officials and human health specialists said that less is known
about the ingredients in several other dispersants listed on the Product
Schedule and that they believe more information is needed on the
ingredients in these dispersants. In addition, toxicity information may be
available on many of the individual ingredients in dispersants, but agency
officials and human health specialists told us that there is very little data
regarding the potential human health effects of the mixture of these
ingredients as found in oil dispersant products. For example, the Material
Safety Data Sheet for COREXIT® EC9500A states that no human health
toxicity studies have been conducted on this product. In addition, agency
officials and human health specialists told us that more research is
needed on whether dispersants can alter the toxicological properties of
the chemicals in the oil, which may increase the ability of oil or some of its
constituents to permeate the skin in the event of dermal exposure to
chemically dispersed oil. Agency officials and human health specialists
also told us that currently there are no good biomarkers for dispersant
exposure, making it difficult for researchers to fully measure the extent of
human exposure and any resulting toxicological effects. In addition,


21
  A Material Safety Data Sheet (MSDS) is a detailed information bulletin prepared by the
manufacturer or importer of a chemical that describes the physical and chemical
properties, physical and health hazards, routes of exposure, precautions for safe handling
and use, emergency and first-aid procedures, and control measures. In the United States,
the Occupational Safety and Health Administration requires employers to provide
information to their employees about the hazardous chemicals to which workers are
exposed through a program including MSDS under its Hazard Communication regulation.




Page 21                                                        GAO-12-585 Oil Dispersants
                            results from studies based on human samples or populations are needed
                            to fully inform our understanding of potential health effects, according to
                            agency officials. For example, in order to determine the likelihood of
                            meaningful exposures and the potential for health effects to occur, it
                            would be important to have ongoing environmental and biological
                            monitoring, such as through the collection of blood or urine samples from
                            oil spill response workers before and after they encounter dispersants.


Experts Highlighted Two     Although much is known about the use of dispersants on the surface of
Emerging Areas in Need of   the water, experts highlighted two emerging areas in which additional
Further Research            research is needed—specifically, the subsurface application and effects
                            of dispersants in deep water environments and the use of dispersants in
                            Arctic conditions and other cold water environments. As previously
                            discussed, and according to many experts we spoke with, it will be
                            particularly important to gain a better understanding of these
                            environments since the future of oil production will rely to a substantial
                            extent on producing oil from deep, offshore wells in the Gulf of Mexico
                            and off the Alaskan Coast.

                            Subsurface application of dispersants. All of the 11 experts we spoke with
                            told us that little is known about the use and effects of chemical
                            dispersants applied subsurface in deep water environments—ocean
                            depths of over 1,000 feet—noting that conditions there may influence the
                            effectiveness of dispersants, such as higher pressure, lower water
                            temperatures, and the presence of gas. Most experts characterized the
                            subsurface application of chemical dispersants in the deep water during
                            the Deepwater Horizon incident as surrounded by uncertainties, since it
                            was the first attempt of its kind. Officials and specialists noted that
                            monitoring efforts and visual evidence from the spill indicated subsurface
                            application of dispersants was effective in reducing the amount of oil and
                            volatile organic compound levels that appeared at the surface.

                            Experts agreed that the influence of deep water conditions on subsurface
                            dispersant use requires further research, but they disagreed over the
                            significance of some of the knowledge gaps. For example, some experts
                            felt lack of knowledge about the role of high pressure in the deep water
                            was a big gap, while others felt that, based on the knowledge of chemistry
                            and other existing knowledge about dispersants, pressure was likely to
                            have no influence on effectiveness. Specialists told us scientists are
                            beginning to undertake research to validate the effectiveness of chemical
                            dispersants applied subsurface in deep water environments and better
                            understand how to optimize dispersant formulations, dispersant-to-oil


                            Page 22                                              GAO-12-585 Oil Dispersants
ratios, and application methods for these conditions. Some experts and
specialists told us that since application directly at a spill source in deep
water allows for direct contact with fresh oil and the force of a blowout
creates substantial mixing energy, dispersants designed specifically for
subsurface application could require less or no solvent and be applied at
significantly lower dispersant-to-oil ratios.

Furthermore, with regard to the subsurface use of dispersants, most
experts told us that there are gaps in knowledge related to fate and
transport, toxicity, and monitoring. In terms of the fate and transport of
dispersed oil at depth, while research and models to indicate what
happens to oil released from the ocean floor exist, previous research had
not taken into account the changes the addition of chemical dispersants
could cause. Many experts also cited the need for more research on
issues such as biodegradation, oil droplet size, and interaction with
particulate material in the subsurface, deep water environment. For
example, some experts noted that such research could inform the
adaptation and improvement of models for tracking the fate and transport
of chemically dispersed oil from subsurface dispersant use. One expert
noted a particular need for research on interactions with suspended
particulate material in deep water. This expert noted that there is some
evidence that smaller droplets react differently with suspended particulate
material in deep water and can create a substance, which can entrap
organisms that cannot swim away fast enough.

With regard to toxicity related to the subsurface application of
dispersants, in addition to the gaps in information on chronic effects
discussed above, experts told us that little is known about the species
that reside in deep water environments and how chemically dispersed oil
may affect them. Also, some noted that the difficulties of conducting
toxicity testing on relevant species in realistic exposure scenarios are
amplified for subsurface use of chemical dispersants in deep water
because bringing such species to the surface would likely kill them, and
creating test conditions that would allow them to survive and serve as a
reasonable simulation of that environment would be extremely
challenging. Given the inability in a subsurface, deep water scenario to
implement direct visual observation based monitoring, such as occurs
with the SMART protocols, some experts noted the need for research to
develop scientifically sound monitoring protocols and equipment for deep
water use.

Use of dispersants in Arctic environments. Most experts told us that
knowledge about the use of dispersants in Arctic environments is limited,


Page 23                                               GAO-12-585 Oil Dispersants
and less research has been conducted on dispersant use in the Arctic
and other cold environments than in temperate or tropical climates.
Specifically, some experts stated that additional research is needed to
ensure that dispersant formulations are effective in the Arctic
environment. For example, one expert said that dispersants are currently
designed for temperate or tropical climates, and there is reason to believe
that these formulations will be less effective in the Arctic environment
because of environmental conditions such as cooler temperatures and
the presence of ice. Specifically, sea ice introduces several potential
complicating factors, which require more research. For example, ice
alters the sea’s state, diminishing waves, which could lead to lower
mixing energy. In addition, the presence of ice and broken ice may affect
application methods.

Previously discussed knowledge gaps about fate and transport of
chemically dispersed oil also apply in the Arctic, with one expert noting
that more research is needed on biodegradation rates in the Arctic
because the cold temperatures may slow the process down. Furthermore,
one expert told us that additional research is needed to enhance fate and
transport models for chemically dispersed oil in icy conditions to better
understand the movement of chemically dispersed oil. Some experts also
noted possible differences in the toxicity of chemically dispersed oil for
Arctic species as compared with temperate species. For example, one
expert said that some Arctic species have different metabolism rates than
species in warmer climates, and research is needed to determine how
dispersant use affects Arctic species.




Page 24                                             GAO-12-585 Oil Dispersants
                              Federal agencies and other groups, including industry and states, have
Federal Agencies,             enhanced knowledge on the use of chemical dispersants and its effects
Industry, States, and         by funding research projects. Specifically, six federal agencies have
                              funded over $15.5 million of dispersant-related research projects since
Other Groups Have             fiscal year 2000, 22 with about half of this total federal funding—over $8
Funded Research to            million—occurring since the Deepwater Horizon incident. 23 Over 40
Enhance Knowledge             percent of all federally funded dispersant research projects have focused
                              on testing dispersant effectiveness. Appendix III provides a list of
on the Use and                federally sponsored research projects related to dispersants since fiscal
Effects of Dispersants        year 2000. In addition, industry has a number of past and ongoing
                              research projects focused on the use and effects of dispersants, and
                              states and other groups have also funded dispersant-related research.


Agencies Have Funded          Since fiscal year 2000, six federal agencies—BSEE, 24 Coast Guard, EPA,
Over $15.5 Million for        HHS, NOAA, and NSF—have funded 106 research projects related to
Dispersant Research since     chemical dispersants, at a cost of approximately $15.6 million (see table
                              2). Roughly half of the total federal funding—approximately $8.5 million—
Fiscal Year 2000, Including
                              occurred in fiscal years 2010 or 2011, largely in response to the
Over $8 Million since the     Deepwater Horizon incident. In general, most of the projects funded by
Deepwater Horizon             federal agencies were conducted by nonfederal researchers, including
Incident                      university researchers and independent laboratories. In addition, the
                              federal government has a committee—the Interagency Coordinating
                              Committee on Oil Pollution Research—that helps coordinate research
                              efforts across federal agencies. This committee was established by the
                              Oil Pollution Act of 1990 and is currently composed of 14 federal
                              agencies and chaired by the Coast Guard.


                              22
                                Of the $15.6 million in total funding, approximately $1.3 million was for 7 projects fully or
                              partially conducted by agency staff, as opposed to given out in grants or contracts. For
                              one of these projects, EPA was unable to provide an estimated cost.
                              23
                                This funding and research does not include studies conducted as part of the Natural
                              Resource Damage Assessment for the Deepwater Horizon incident. Under the Clean
                              Water Act, as amended, parties responsible for oil spills are liable for damages to natural
                              resources. NOAA regulations establish a process for developing a plan to restore injured
                              natural resources and services and having such a plan implemented or funded by
                              responsible parties.
                              24
                                BSEE works to promote safety, protect the environment, and conserve resources
                              offshore through regulatory oversight and enforcement. BSEE was created out of the
                              reorganization of the Minerals Management Service into three new bureaus from 2010–
                              2011: BSEE, Bureau of Ocean Energy Management, and the Office of Natural Resources
                              Revenue.




                              Page 25                                                           GAO-12-585 Oil Dispersants
Table 2: Federal Agencies’ Dispersant Research Funding since Fiscal Year 2000

                                                                 Number of agency-specific and
                               Total agency funding for                joint-agency dispersant
    Agency                                 all projectsa                      research projects
    BSEEb                                    $3,978,451                                               39
    NSF                                      $4,395,419                                               29
    EPA                                      $3,118,396                                               27
    NOAA                                     $3,256,894                                               15
          c
    HHS                                        $741,491                                                4
    Coast Guard                                 $64,000                                                2
    Total                                   $15,554,651                                            116d
Source: GAO analysis of agency data.
a
 Research funding data include actual or agency-estimated amounts for completed and ongoing
projects. Each agency’s data include the amount identified for agency staff, grants, or contracts for all
projects funded, whether funded solely by the agency or in a joint project with another agency.
However, the data do not include the costs for agency staff or other technical assistance where direct
funding was not provided. Additionally, the data do not include the cost for one project, for which EPA
was unable to provide funding data, nor do they include funding amounts which may have been
provided by federal agencies outside the scope of our review.
b
Research attributed to BSEE includes research conducted by its predecessor agencies, the Minerals
Management Service and the Bureau of Ocean Energy Management, Regulation, and Enforcement.
c
 Research attributed to HHS includes research conducted by NIH and CDC. One of these projects
focused on analysis of dispersants, as well as oil. The funding included from this project covers both
of these focuses.
d
 The total number of discrete projects is 106, seven of which were collaborative or jointly funded.
Specifically, BSEE and EPA collaborated on three projects—one jointly funded and two funded by
BSEE using EPA contractor support. In addition, projects were jointly funded by BSEE and Coast
Guard, with involvement by EPA and NOAA as technical advisors; by BSEE, Coast Guard, and
NOAA; by EPA and HHS; and by EPA and NOAA. Each agency’s portion of funding for these projects
is included in their agency funding figure above.


Details on dispersant-related research funded by the six federal agencies
since fiscal year 2000 are as follows:

•      BSEE has consistently funded dispersant research projects every
       fiscal year since 2000, and funding for most individual projects has
       ranged from $10,000 to $300,000. According to agency officials,
       BSEE has plans to undertake additional projects and has tentatively
       planned to fund studies on the impact of dispersant use on worker
       safety and studies on subsurface dispersant application. In addition to
       jointly funded projects with other federal agencies, BSEE has also
       funded projects jointly with industry and other groups to conduct
       dispersant research. For example, for one dispersant research
       project, BSEE was one of nine partners, including four oil companies
       and two oil spill response organizations, as well as Canada’s



Page 26                                                                  GAO-12-585 Oil Dispersants
     Department of Fisheries and Oceans, and Texas’ General Land
     Office.

•    NSF has funded the second largest number of projects—29 in all—
     and all but one of its projects were funded as a result of the
     Deepwater Horizon incident. Almost all of NSF’s dispersant research
     funding was distributed to researchers through its rapid response
     grant program––a grant mechanism developed specifically to respond
     to unusual circumstances where a timely response is essential to
     achieving research results, such as in the case of the Deepwater
     Horizon incident. 25 NSF also had the largest total agency funding, with
     individual project funding ranging from $12,878 to $200,000, with an
     average funding level of $151,566. Most of this research is still under
     way. Absent another oil spill, NSF does not have plans to fund further
     dispersant research—other than for projects submitted as individual,
     unsolicited proposals—according to agency officials.

•    EPA, similar to BSEE, has funded at least one project in most years
     since fiscal year 2000. EPA’s total annual funding for dispersant-
     related projects was generally less than $300,000 per year. In fiscal
     year 2010, EPA funding increased, and the agency funded six
     dispersant research projects at a total of $1.3 million. In addition, EPA
     has collaborated with the Canadian government on a wave tank
     facility in Canada, which EPA has used to support some of its
     dispersant-related research projects. 26 EPA, through its STAR grant
     program, 27 also issued a request for proposal on the environmental
     impact and mitigation of oil spills, including the application of
     dispersants as one of the mitigation measures, after the Deepwater
     Horizon incident. This grant program plans to award $2 million to four
     projects by April 2012; an agency official told us that one of the
     projects will focus on the development of new types of dispersants.




25
 NSF focuses on basic scientific questions and not applied research projects. Unlike
many other federal research agencies, NSF does not have its own laboratories. Instead,
NSF advances basic scientific research by providing grants to researchers.
26
  A wave tank mimics ocean conditions and allows for precise measurements of different
types of wave action.
27
  STAR stands for Science to Achieve Results, which funds research grants and graduate
fellowships in numerous environmental science and engineering disciplines through a
competitive solicitation process and independent peer review.




Page 27                                                      GAO-12-585 Oil Dispersants
•   NOAA has funded several projects over the past decade, but has not
    consistently funded dispersant-related research on an annual basis. A
    significant portion of NOAA’s dispersant funding—$1 million out of
    about $3.3 million total—has been for an ongoing project, funded in
    fiscal year 2011, and focused on dispersant use during the Deepwater
    Horizon incident and lessons learned from that event. NOAA funded
    most of its past dispersant research through its partnership with the
    University of New Hampshire’s Coastal Response Research Center
    (CRRC). CRRC projects represent 10 of the 15 NOAA-funded
    dispersant research projects. However, NOAA officials told us that the
    agency’s funding for the CRRC ended in 2007.

•   HHS has funded four research projects, all in fiscal years 2010 or
    2011 and has done so as a result of the Deepwater Horizon incident,
    similar to NSF. Specifically, HHS has funded four research projects,
    ranging in costs from $6,000 to $634,000. 28 One of these projects was
    a jointly funded project with EPA, at a cost of $77,491 to HHS. HHS
    officials told us that the agency currently does not have plans to fund
    any dispersant research in the future.

•   The Coast Guard has the most limited dispersant research program of
    the six key agencies, funding two joint projects since fiscal year 2000,
    at a total cost of $64,000. One of these co-funded projects was the
    2005 National Academy of Sciences report on dispersants. 29 The
    Coast Guard also jointly funded a project with BSEE to analyze
    SMART protocol monitoring data. Coast Guard officials told us that
    the agency has no plans to fund dispersant research projects in the
    future and that the agency has no formal effort under way to update
    the SMART monitoring protocols. In addition, although the agency has
    not funded a large amount of dispersant-related research since fiscal
    year 2000, it has focused its research efforts on other response
    options, such as in situ burning and mechanical recovery, in
    accordance with federal oil pollution research plans, according to
    agency officials.


28
   For the NIH project with a cost of $634,000, this cost represents the first two years of a
five year project that will, in part, analyze the level of dispersant contamination, if any, in
seafood. This project will include other testing that is broader than dispersant testing, but
agency officials could not separate out the dispersant-only costs for this project.
29
  BSEE, NOAA, and the American Petroleum Institute also provided funding for this
report. The American Petroleum Institute is a national trade association that represents
the nation’s oil and natural gas industry.




Page 28                                                            GAO-12-585 Oil Dispersants
The Interagency Coordinating Committee on Oil Pollution Research’s
purpose is to coordinate a comprehensive program of oil pollution
research, technology, development, and demonstration among federal
agencies, in cooperation and coordination with industry, universities,
research institutions, state governments, and other nations as
appropriate, and to foster cost-effective research, including the joint
funding of research. Officials told us that the committee has never
received specific funding to operate as a body. Support for the
Interagency Committee’s activities and responsibilities is currently
subsidized by the budgets of its component member agencies. For
example, the establishment and maintenance of the committee’s website
is being funded by the Coast Guard. The Oil Pollution Act also directed
the committee to develop a comprehensive research and technology plan
to lead federal oil pollution research. Among other things, the plan must
assess the current status of knowledge on oil pollution prevention,
response, and mitigation technologies and effects of oil pollution on the
environment; identify significant oil pollution research gaps; and establish
research priorities. In addition, the chair is required to report every 2
years to Congress on the committee’s past activities and future plans for
oil pollution research. The Interagency Committee first prepared a
research and technology plan in 1992 and subsequently updated it in
1997, but it has not been revised since. According to agency officials, the
plan is currently undergoing revision, and they anticipate releasing the
new plan in 2013; dispersants are to be a focus area in the plan. 30 In
March 2011, we issued a report reviewing the Interagency Committee’s
efforts to facilitate coordination of federal oil pollution research and made
recommendations to improve these efforts. 31 The Department of
Homeland Security concurred with our recommendations and plans to
address them.




30
 Support for the research and technology plan update is also being provided by the
Coast Guard.
31
  GAO, Federal Oil and Gas: Interagency Committee Needs to Better Coordinate
Research on Oil Pollution Prevention and Response, GAO-11-319 (Washington, D.C.:
Mar. 25, 2011).




Page 29                                                      GAO-12-585 Oil Dispersants
Over 40 Percent of                       Over 40 percent of the 106 federally funded research projects on
Federally Funded                         dispersants have focused at least in part on effectiveness, with the
Dispersant Research Has                  remaining projects spread across a broad range of research areas, as
                                         noted in table 3.
Focused on Effectiveness

Table 3: Federally Funded Dispersant Research Projects by Research Area since Fiscal Year 2000

                                               Aquatic                             Subsurface
                                           toxicity and                            Application          Alternative
                                Fate and environmental                      Human     in Deep           Dispersant
Agency           Effectiveness Transport        effects Modeling Monitoring Health       water Arctic Formulations General
BSEE                      28                              2              1       2                                 6                             3
Coast Guard
EPA                       12         4                    3              2                 1                       2
HHS                                                                                        3
NOAA                                 3                    7              4       1                                                               1
NSF                                 14                   11              4                                3                        4             1
BSEE/Coast                                                                       1
Guard/EPA/NOAA
BSEE/Coast                                                                                                                                       1
Guard/NOAA
BSEE/EPA                   3
EPA/HHS                                                                                    1
EPA/NOAA                   1
Total                     44        21                   23             11       4         5              3        8               4             6
                                         Source: GAO analysis of agency data.

                                         Note: The total number of discrete research projects is 106, seven of which were collaborative. The
                                         total number of projects in the research categories will be greater than the total number of projects
                                         overall because a project could have more than one focus.


                                         Specifically, federally funded dispersant research since fiscal year 2000
                                         has included the following areas of study.

                                         Effectiveness in dispersing oil. Of the 106 research projects on
                                         dispersants, the largest number were focused on assessing the
                                         effectiveness of chemical dispersants, and BSEE and EPA have funded
                                         almost all of these. Specifically, BSEE has funded projects on the
                                         effectiveness of dispersants on different types of oil and under specific
                                         environmental conditions. For example, one such project focused on the




                                         Page 30                                                                 GAO-12-585 Oil Dispersants
effectiveness of dispersant use on heavy oil, 32 and another examined
dispersant use in calm waters. BSEE has also conducted research to
mimic at-sea conditions by using the Ohmsett wave tank testing facility in
New Jersey to study the effectiveness of dispersants on light to medium
oils when applied at typical application rates. 33 EPA funded several
projects related to dispersant testing protocols that are used to assess
effectiveness, a key criterion required to list dispersants on the Product
Schedule. For example, EPA funded a study to determine the
effectiveness of eight dispersants on its Product Schedule in dispersing
south Louisiana crude oil. In addition, EPA funded research conducted in
a wave tank in Nova Scotia, Canada, that produced quantitative
estimates of the mixing energy necessary for effective chemical
dispersion under various sea states.

Fate and transport of chemically dispersed oil. Half of the federal
agencies we reviewed have funded projects focused on better
understanding the fate and transport of chemically dispersed oil, with over
half of these studies initiated since the Deepwater Horizon incident. In
particular, fate and transport was the focus of nearly half of the NSF grant
projects. For example, one NSF rapid response grantee studied the oil
plume that resulted from the Deepwater Horizon incident using a specially
designed, portable underwater mass spectrometer, which can measure
minute quantities of chemicals in the ocean to determine the movement of
the oil droplets. Other NSF projects focused on the interaction of oil and
dispersed-oil components with sediments collected in regional sediment
traps during the Deepwater Horizon incident, and on determining the
impacts of dispersants on oil interactions with water column particulates
and sedimentation. In addition, EPA has funded four projects that focus at
least in part on the fate and transport of dispersed oil. For example, one
project examined the impact of waves on the movement of dispersed oil
and resulting oil droplet size. EPA also funded several projects focusing



32
   Heavy oils have a higher viscosity; as such, these oils are more resistant to flow than
lighter oils. As noted earlier, experts stated that dispersants are more effective in
dispersing light to medium crude oils, which have a lower viscosity, than heavy oils.
33
   Ohmsett, the National Oil Spill Response Research & Renewable Energy Test Facility,
is the largest outdoor saltwater wave/tow tank facility in North America and has
capabilities for full-scale oil spill response equipment testing, research, and training in a
marine environment with oil under controlled environmental conditions, such as waves
and different oil types. Ohmsett is operated by BSEE, and is used by the federal
government, as well as industry and other groups, to conduct research.




Page 31                                                           GAO-12-585 Oil Dispersants
on the biodegradation rates of different types of oil and dispersant
mixtures.

Aquatic toxicity and environmental effects of chemically dispersed oil.
NOAA and NSF are the two primary agencies sponsoring research
projects focused on assessing the toxicity and environmental effects of
chemically dispersed oil—funding 18 of the 23 projects in this area.
Specifically, NOAA has funded projects that focus on both the acute and
chronic effects of chemically dispersed oil on certain marine species. For
example, one project examined the acute and chronic effects of crude oil
and chemically dispersed oil on chinook salmon smolts. In addition, NSF
funded a research project examining the potential toxic effects of
chemically dispersed oil on benthic—or sea floor— environments in the
Gulf of Mexico. Another NSF-funded project is investigating the effects of
oil and dispersants on the larval stages of blue crabs and any subsequent
impact the oil and dispersants may have on population dynamics. All of
NSF’s projects in this area were in response to the Deepwater Horizon
incident. EPA and BSEE also funded projects in this category, although
fewer in number. For example, one EPA project focused on how the
dispersion and weathering of dispersed oil affects the exposure of marine
species to dispersed and non-dispersed oil. In response to the Deepwater
Horizon incident, EPA funded a project focused on the toxic effects of (1)
crude oil alone, (2) eight different dispersants alone, and (3) a mixture of
crude oil and each of the dispersants on two Gulf marine species. In
addition, BSEE funded a project completed in 2005 to examine the effects
of oil and chemically dispersed oil on mussels and amphipods—a type of
crustacean.

Modeling of chemically dispersed oil. Most of the agencies supported
research projects focused on modeling chemically dispersed oil. For
example, NOAA funded a project to model the way that chemically
dispersed oil particles may combine with other particulate material in the
ocean. In addition, four of NSF’s grants were awarded to projects to
model the impacts of the Deepwater Horizon incident and dispersant use,
such as the effects on plankton and other offshore marine organisms, and
BSEE funded a project that involved validating two models developed to
predict the window of opportunity for dispersant use in the Gulf of Mexico.
Not specifically focused on modeling chemically dispersed oil, some
projects are under way to improve three-dimensional modeling of ocean
currents, which agency officials told us will be helpful in the event of a




Page 32                                              GAO-12-585 Oil Dispersants
future oil spill. 34 Specifically, NOAA received $1.3 million in supplemental
funding related to the Deepwater Horizon incident to improve its modeling
capabilities to better forecast the subsurface movement and distribution of
oil, taking into account the subsurface currents. According to agency
officials, the three-dimensional modeling will be a significant addition to
the more standard two-dimensional modeling of oil along the surface that
has historically been used to track oil trajectories. Similarly, the
Department of the Interior’s Bureau of Ocean Energy Management
currently has a $989,000 modeling project under way to develop a new
model for ocean currents and oil spills in the Gulf of Mexico. The
enhanced models that both of these projects are developing may be
applied in the future to model chemically dispersed oil and enhance
decision making regarding its efficacy, fate, and transport.

Monitoring of chemically dispersed oil. Research in this area has been
more limited, with four projects funded since fiscal year 2000, primarily by
BSEE. One such project focused on SMART protocol monitoring results
and the effectiveness of dispersants. Specifically, this project involved
applying different ratios of dispersants to oil—ranging from ratios known
to be effective at dispersing oil to ratios that were not effective at
dispersing oil—to compare how well the SMART monitoring protocols
were able to monitor the results of each type of application. The Coast
Guard and BSEE also jointly funded a research project focused on
analyzing SMART protocol monitoring data to verify the reliability of the
protocols and to identify ways in which the protocols could be improved;
NOAA and EPA provided assistance, but not funding, to this project. In
addition, NOAA funded a project to evaluate dispersant application and
monitoring techniques by using oil seeps originating naturally at the
bottom of the ocean as a proxy for an oil spill.

Human health. HHS, through NIH and CDC, is the primary agency that
researches possible human health effects because of the use of
dispersants. For example, CDC’s NIOSH conducted laboratory tests
involving short-term inhalation exposure of rats to the dispersant
COREXIT® EC9500A to study the pulmonary, cardiovascular, and
central-nervous-system responses. NIOSH also studied the dermal
effects of dispersant exposure. In addition, the National Institute of


34
  Because these modeling efforts are more general in nature and not focused on
modeling chemical dispersants specifically, they were not included in the research project
summary or funding summary.




Page 33                                                        GAO-12-585 Oil Dispersants
Environmental Health Sciences (NIEHS) has funded an ongoing project
through an NIH initiative called the Deepwater Horizon Research
Consortia that will, among other things, analyze the contaminant profiles
of seafood fished by subsistence and non-subsistence fishermen in the
Gulf of Mexico and will analyze the seafood samples for dispersant
residues. 35 In addition, NIEHS funded a joint NIH research project with
EPA to evaluate the extent of dispersants’ effects, if any, on endocrine
disruption in human cell lines, among other toxicity markers. In addition,
EPA funded one research project that focused on in vitro testing of eight
oil dispersants to assess four human health toxicity markers. Moreover,
NIEHS launched the Gulf Long-term Follow-up (GuLF) Study to
investigate potential short- and long-term human health effects
associated with clean-up activities following the Deepwater Horizon
incident. 36 The GuLF Study is expected to involve at least 40,000 clean-
up workers and last for at least 10 years, according to agency officials,
and the first 5 years of the study have been funded at $34 million.
Through its interviews with clean-up workers, the GuLF Study will
examine potential exposures and health effects from a variety of
substances and will also try to assess the extent of exposure to
dispersants.

Research on subsurface application of dispersants. Prior to the
Deepwater Horizon incident, federal agencies had not funded research on
the subsurface application of dispersants in deep water. Since then, NSF
has funded three rapid response grant projects that focus on subsurface
application of dispersants and its effects. For example, one project is
using specialty instruments to detect and quantify oil and dispersed oil in
the deep waters of the Gulf of Mexico. Another NSF project is looking at
the acute toxicity effects of oil and chemically dispersed oil on the benthic
communities in the deep water of the Gulf of Mexico. The last project is
studying the impact of chemical dispersants on the aggregation of oil into
oil droplets in the deep water. BSEE has tentative plans to fund research
on subsurface application of dispersants in fiscal year 2012. EPA, NOAA,
and the Coast Guard do not have any current research related to


35
  NIEHS is leading a trans-NIH effort known as the Deepwater Horizon Research
Consortia. The 5-year, $25.2 million grant program will focus on potential acute and long-
term health effects from the Deepwater Horizon incident to the general public.
36
  Because this large scale study is more general in nature, looking at a broad range of
health effects and not focused specifically on dispersants, it was not included in the
research project summary or funding summary.




Page 34                                                        GAO-12-585 Oil Dispersants
subsurface dispersant use in the deep water, according to agency
officials.

Arctic environment dispersant research. Federal research related to the
use of chemical dispersants in an Arctic or cold water environment has
been somewhat limited, with only eight projects undertaken since fiscal
year 2000. For example, one of BSEE’s six funded projects examined the
effectiveness of dispersants in broken-ice conditions, which are fairly
common many months out of the year off the Alaskan coast. Another
project studied dispersant effectiveness in a low mixing energy
environment, which could be caused by the presence of ice cover in the
Arctic. Similarly, an ongoing project is examining new techniques to apply
dispersants in icy environments in which the waves are smaller because
of the presence of ice and, as a result, less mixing generally occurs. In
addition, EPA funded two studies that focused on the fate and transport of
chemically dispersed oil at different temperatures, including in cold water.
EPA is also collaborating with other members of the National Response
Team and the Alaska Regional Response Team to understand the unique
aspects of potential Arctic oil spills with respect to the authorization and
use of dispersants in order to inform and prioritize research needs.

Alternative dispersant formulations. Prior to the Deepwater Horizon
incident, federal agencies had not funded research on alternatives to the
current blends of chemical dispersants used to disperse oil. Since the
Deepwater Horizon incident, NSF has funded four projects in this area.
Specifically, one project is studying natural and synthetic biological
agents as alternatives to chemical dispersants for application in marine oil
spills. Another study is evaluating the potential usefulness of man-made
nanofiber materials as an alternative to chemical dispersants in marine oil
spills. The third study is examining the difference in efficacy of natural and
synthetic surfactants, which may help with the development of less toxic
dispersants. The final project is focusing on the development of bio-
derived, biodegradable oil dispersants.

General. Research in this category includes efforts to synthesize
information and identify broad applications of dispersant knowledge, such
as improving dispersant decision making processes and educational
efforts. For example, three agencies—the Coast Guard, BSEE and
NOAA—provided funding for the 2005 National Academy of Sciences
report. This report provided an expert evaluation of the adequacy of
existing information and ongoing research regarding the effectiveness
and effects of dispersants and recommended steps to be taken to better
support policymakers with dispersant decision making. In addition, BSEE


Page 35                                               GAO-12-585 Oil Dispersants
                            funded three other general projects, including one that focused on
                            developing a training package on the use of chemical dispersants for the
                            Ohmsett wave tank testing facility. Another BSEE project studied the
                            operational and environmental factors associated with the use of
                            chemical dispersants to treat oil spills in California waters, with a goal
                            toward expediting dispersant use decision making and planning for such
                            spills.


Industry Has a Number of    In addition to federally funded dispersant research, the oil industry has
Research Projects Focused   funded a number of past and ongoing research projects related to the use
on Dispersant Use and       and effects of chemical dispersants. These projects have been conducted
                            collaboratively through industry trade associations or across multiple
Effects                     companies, by individual companies, and through an independent
                            research initiative. According to industry representatives, the industry has
                            committed over $20 million to fund American Petroleum Institute and
                            International Association of Oil & Gas Producers’ dispersant programs. 37
                            These projects generally began in 2011 and are anticipated to end by
                            2016. Specifically, the American Petroleum Institute is currently leading a
                            set of dispersant-related projects involving several oil companies and oil
                            spill response organizations, among others. According to industry
                            representatives, a significant part of this research will focus on the
                            subsurface use of dispersants in deep water, ice-free environments. In
                            addition, the International Association of Oil & Gas Producers is pursuing
                            two dispersant research initiatives. One initiative—the Oil Spill Response
                            Joint Industry Project—will focus on the fate and effects of subsurface
                            dispersant use and the tracking and modeling of dispersed oil, among
                            other things. A second initiative—the Arctic Oil Spill Response
                            Technology Joint Industry Programme—includes research on dispersant
                            use in the Arctic. Specifically, the dispersant portion of this project is
                            investigating the fate and transport of chemically dispersed oil under ice
                            and dispersant effectiveness testing in Arctic environments, as well as the
                            environmental impacts of Arctic spills and options for responding to them.
                            Shell representatives told us that there are nine oil companies
                            participating in the Arctic research project, and that this project is building



                            37
                              The International Association of Oil & Gas Producers includes most of the world’s
                            publicly-traded, private and state-owned oil and gas companies, industry associations,
                            and major upstream service companies. Its members produce more than half the world’s
                            oil and about one third of its gas.




                            Page 36                                                      GAO-12-585 Oil Dispersants
                         on earlier Arctic research conducted by a Norwegian research institute
                         called SINTEF. 38

                         Individual oil companies, including ExxonMobil and Shell, have also
                         invested in dispersant research projects together and separately. For
                         example, Shell, ExxonMobil, Statoil, British Petroleum, and
                         ConocoPhillips have funded a project to study the biodegradation of
                         physically and chemically dispersed oil and its toxicity on Arctic species in
                         Alaska. According to Shell representatives, this project started in 2009, in
                         response to concerns from Coast Guard and NOAA officials that the
                         agencies did not have sufficient information to conduct an assessment of
                         potential ecological risk for the North Slope of Alaska. The five oil
                         companies provided funding to NewFields, a private consulting firm, and
                         the University of Alaska at Fairbanks to conduct the research. Federal
                         agencies—including NOAA, EPA, and the Coast Guard—are part of a
                         technical advisory committee overseeing this research project. Shell
                         representatives told us that this project has been funded at a total cost of
                         about $2.5 million. Individual oil companies have also funded chemical
                         dispersant research. For example, industry representatives for Exxon
                         estimated that the company has funded more than $20 million for
                         dispersant research since 2000.

                         In addition to industry-led research efforts, British Petroleum has set up
                         an independent group, the Gulf of Mexico Research Initiative, to disburse
                         $500 million in research funds over 10 years to study the effects of the
                         Deepwater Horizon incident, as well as other oil spills, on the Gulf of
                         Mexico. A portion of this funding will be for dispersant research. For
                         example, Tulane University is leading a consortium of over 40
                         researchers to conduct a roughly $10 million project to examine the
                         science and technology of chemical dispersants as relevant to deep water
                         oil releases.


States and Others Have   States, organizations, and governments have also funded dispersant
Also Funded Dispersant   research. States—including California and Texas—have funded
Research                 dispersant research on topics including the toxicity of dispersed oil on
                         certain species, but they are not currently funding such work because of


                         38
                           SINTEF is an independent research institution based in Norway and the largest
                         research institution in Scandinavia. SINTEF focuses its research on petroleum and energy
                         issues, among other areas.




                         Page 37                                                      GAO-12-585 Oil Dispersants
limited funding or competing research priorities. Specifically, California’s
Office of Spill Prevention and Response funded a number of research
projects from 1993 through 2011 related to the use of chemical
dispersants, at an estimated cost of about $2 million. 39 For example, one
project studied the physical effects on a marine bird or otter diving
through a subsurface plume of chemically dispersed oil. Another funded
research project focused on the acute and chronic toxic effects of
dispersants on salmon larvae, according to agency officials. Texas has
also funded dispersant research projects. According to a state official, the
Texas General Land Office spent several million dollars on dispersant
research from the mid 1990s through the early 2000s. For example, one
project studied the behavior of chemically dispersed oil in a wetland
environment. However, the state official told us that dispersant research
is no longer a priority for Texas because federal agencies, including
BSEE and NOAA, are currently conducting dispersant research and that
his office prefers to spend the state’s limited research funds on other
aspects of oil spill response that need attention, such as improving buoys
to measure waves and ocean currents in order to inform oil spill modeling.

In addition to states, other organizations and governments have funded
some dispersant research projects. For example, the Prince William
Sound Regional Citizens’ Advisory Council has funded research projects
on the effectiveness and toxicity of dispersants in the Alaskan
environment, such as one project that examined the effect of photo-
enhanced toxicity of chemically dispersed oil on Pacific herring eggs and
larvae. 40 Officials with the council noted that not many independent
groups fund dispersant research, due in part to the high costs associated
with this research. In addition, international research organizations and
governments have also funded dispersant research. For example,
SINTEF has done a great deal of oil spill research, as well as dispersant-
related research. In addition, a French organization, the Centre of
Documentation, Research and Experimentation on Accidental Water
Pollution (CEDRE), has worked on enhancing knowledge about the use


39
  California has a separate licensing program for oil spill cleanup agents, including
dispersants, which may be used on state waters. In 2008, California’s Office of Spill
Prevention and Response issued a California Dispersant Plan, which includes information
and tools to guide decision-makers on the use of dispersants.
40
  The Prince William Sound Regional Citizens’ Advisory Council is an independent non-
profit organization established after the Exxon Valdez spill and works to reduce pollution
from crude oil transportation through Prince William Sound and the Gulf of Alaska.




Page 38                                                         GAO-12-585 Oil Dispersants
                      of chemical dispersants, including organizing a conference in March 2011
                      focused on the future of dispersant use, with experts addressing the novel
                      uses of dispersants during the Deepwater Horizon incident. 41 In addition,
                      Canada’s Department of Fisheries and Oceans has also funded
                      dispersant research, such as fish toxicity studies and effectiveness
                      studies. This department also collaborated with EPA and the Bedford
                      Institute of Oceanography to build a 32-meter wave tank, which was
                      completed in 2006. 42 Both countries use this wave tank for research
                      purposes, such as to measure the biological effects of various oil,
                      dispersant, and sea water blends by mimicking different ocean conditions
                      in the lab. Lastly, the United Kingdom has also funded dispersant toxicity
                      research to establish assessment criteria for dispersant approval.


                      According to federal officials, experts, and specialists we spoke with,
Dispersant Research   federal agencies and researchers face resource, scientific, and
Faces Resource,       communication challenges in their attempts to enhance knowledge on
                      chemical dispersant use and its effects.
Scientific, and
Communication         Resource challenges. Agency officials, experts, and specialists identified
Challenges            inconsistent and limited levels of funding as a challenge to developing
                      research related to the use and effects of chemical dispersants.
                      Specifically, according to agency officials, experts, and industry
                      representatives, because support for dispersant research tends to
                      increase in the immediate aftermath of a major oil spill and decrease in
                      the years following a spill, it is difficult for federal agencies, states, and
                      industry to sustain a long term research program. For example, agency
                      officials told us that while there was an increase in research funding
                      specifically related to the Deepwater Horizon incident, this funding is not
                      expected to continue in the future. Some agency officials, as well as
                      some industry representatives and experts, told us that a similar pattern
                      occurred after the 1989 Exxon Valdez oil spill, with a temporary increase
                      in research funding following the spill. However, once those initial


                      41
                        CEDRE is a non-profit organization focused on two key areas—oil spill preparedness
                      and response—and is funded in part by the French government.
                      42
                        The Bedford Institute is a modern oceanographic research facility, established in 1962
                      by the Federal Government of Canada (the former Department of Mines and Technical
                      Surveys, now Natural Resources Canada) and is located on the shores of the Bedford
                      Basin in Dartmouth, Nova Scotia. Over the last 50 years it has grown to become Canada’s
                      largest center for ocean research.




                      Page 39                                                      GAO-12-585 Oil Dispersants
research funds were allocated, very little research funding was available
again until after the Deepwater Horizon oil spill. In addition, some industry
representatives told us that maintaining a long-term focus for dispersant
research can be a challenge for industry groups, as there are many
different oil spill research priorities and responsibilities in addition to
dispersants. According to agency officials and a National Research
Council report, the lack of a consistent research funding stream also
makes it difficult for federal agencies to fund longer term projects. 43 For
example, some agency officials and experts said that to understand the
chronic toxicological effects of dispersants, scientists would need to
design long-term, multiyear studies of the effects of the use of dispersants
on marine species; however, such longer term studies are more
expensive and more complicated to conduct than short-term acute toxicity
tests. Furthermore, although most of the key agencies conducting
research on dispersant use and effects have identified areas in which
additional dispersant-related research would be informative and aid with
decision making, officials from many of these agencies told us their
agencies are unable to fund this research given their limited budgets.
Some state officials we spoke with echoed similar concerns and said that
they have been unable to continue with research in this area.

Scientific challenges. Agency officials, experts, and specialists also
identified scientific challenges, in particular, conducting research that
replicates realistic oil spill conditions and obtaining oil and dispersants for
testing. Every oil spill is different, and the conditions—such as weather,
oil type and volume, currents, and location—surrounding any
unanticipated release of oil into the ocean are highly variable. Given this
variability, no one study can account for all the potential permutations.
Laboratory experiments are useful for determining the chemical
effectiveness of dispersants, but they are unable to approximate ocean
conditions given the difference in scale. Researchers can employ
alternative methods to try to replicate realistic oil spill conditions for the
purposes of conducting dispersant research—use of a wave tank, use of
an existing spill, or the intentional release of oil to create a new spill—but
each of these have their own drawbacks.




43
  National Research Council, Review of the Interagency Oil Pollution Research and
Technology Plan: Final Report of the Committee on Oil Spill Research and Development
(1994).




Page 40                                                    GAO-12-585 Oil Dispersants
•   Wave tanks. As described earlier, two wave tanks are regularly used
    in North America—one in New Jersey and the other in Canada. The
    tanks provide an arena in which oil spills can be created in a body of
    water without risks to the environment; however, unlike the open
    ocean, the size of the tank and presence of walls constrain the
    movement of the oil and water and do not fully account for ocean
    currents. According to EPA researchers, the tank in Canada is able to
    come close in terms of simulating breaking wave action and ocean
    currents, and according to BSEE officials, the tank in New Jersey is
    able to simulate waves up to 1 meter in height. However, neither of
    these wave tanks is equipped to simulate the high pressure and dark
    conditions present in the deep water.

•   Existing spills. An opportunity exists to conduct research on the use of
    chemical dispersants during an oil spill and to obtain real world
    information that can help address some of the identified research
    gaps, but agency officials and experts told us that it is hard to conduct
    rigorous scientific research because of the competing needs of oil spill
    responders. For example, one expert told us that a research team
    may have access to sample and test water in a given spill location but
    may later be restricted from sampling from the same area because of
    actions being taken to respond to the spill. In addition, some agency
    officials told us that it is virtually impossible to conduct scientifically
    sound research during an oil spill emergency because there is not
    enough time to carefully design and execute research projects.

•   Intentional discharges. In the absence of an unexpected spill, another
    option to conduct dispersant-related research could come through the
    intentional discharge of oil for the express purpose of studying how the
    oil responds with or without the application of dispersants. However,
    agency officials, experts, and industry representatives told us that it is
    very difficult to gain approval for an intentional discharge of oil into the
    ocean for research purposes. EPA officials told us that states must first
    approve such a discharge before any applications for a permit to
    discharge come to EPA for review. The few applications attempted did
    not receive state approval. These officials also told us that EPA
    received and granted only one permit, in 1994, for intentional oil
    discharge to a U.S. water for research on a bioremediation agent.
    Because open ocean experiments are generally not conducted in the
    United States, researchers have traveled abroad, including to Norway
    and Canada, to do such testing. According to officials on the
    Interagency Coordinating Committee on Oil Pollution Research, the
    Ocean Energy Safety Advisory Committee, and the American




Page 41                                                 GAO-12-585 Oil Dispersants
     Petroleum Institute, there is growing interest in exploring intentional
     discharges of oil in controlled settings for research purposes.

Another scientific challenge to conducting dispersant-related research is
the accessibility of oil and dispersant samples for testing. Several agency
officials, specialists, and experts told us that it can be difficult and time
consuming to access oil and dispersants to conduct dispersant research.
For example, one expert told us that she has been waiting for several
months to receive the oil she requested from an oil company for her
research, thus delaying her entire project. An industry representative also
told us that access to oil and dispersants could be a challenge for
researchers because of liability concerns from the companies that
produce them, as these companies do not want to be held responsible for
any liability if a research project goes badly or either substance spills into
the environment.

Communication challenges. Agency officials, experts, and specialists told
us that it can be a challenge to communicate research across the
different groups involved in dispersant use and research, including federal
agencies, industry, and academia. Agency officials and industry
representatives noted that the oil spill response research community is
small and that awareness of each others’ work is based on informal
interactions, such as at workshops, meetings, and conferences. Agency
officials and industry representatives we spoke with told us they are
generally aware of each other’s research, but there is additional research
that may not be readily known, such as research undertaken by
academia. Some officials also noted that research across these different
groups can be hard to track, a task that only gets more difficult following
an event like the Deepwater Horizon incident, when there are many new
studies under way at once because of the increased attention and
funding. In addition, according to agency officials, many oil spill research
projects are reported in conference proceedings, such as the Arctic and
Marine Oilspill Program Technical Seminar on Environmental
Contamination and Response and the International Oil Spill Conference, 44
but these proceedings are not covered in commonly used search
engines, such as Web of Science.



44
  The Arctic and Marine Oilspill Program Technical Seminar on Environmental
Contamination and Response is an international forum on preventing, assessing,
containing, and cleaning up spills of hazardous materials in every type of environment. It
also deals with solutions for remediating and rehabilitating contaminated sites.




Page 42                                                         GAO-12-585 Oil Dispersants
Some organizations have attempted to develop lists of dispersant-related
research, but there is no comprehensive mechanism or database that
tracks this research across all sources, includes both past and ongoing
research projects, and is regularly updated. For example, the Interagency
Coordinating Committee on Oil Pollution Research maintains a list of
federally sponsored oil spill related research, including research on
dispersants, from which it publishes biennial reports containing short
summaries of the federal research projects completed during the prior 2
years. However, these reports are intended only to summarize federal
research efforts and do not track or cross-reference related research that
has been funded solely by industry or non-governmental sources. Several
other organizations have gathered dispersant research information in
various types of databases or bibliographies, including those maintained by
the Louisiana Universities Marine Consortium, the Prince William Sound
Regional Citizens’ Advisory Council, and the CRRC, but none of these lists
include the full range of past and current federal, industry, and academic
research on the topic. For example, the Louisiana Universities Marine
Consortium developed a database consisting of citations found in journals,
conference proceedings, and government reports covering published
research on oil spill dispersants from 1960 through June 2008, but the
database has not been updated. In addition, the Prince William Sound
Regional Citizens’ Advisory Council maintains a similar database of
citations of published literature on dispersants; however, this database
does not track ongoing projects. Also, CRRC’s list describes approximately
100 past and current research projects but is limited in that it contains
fewer research projects than the other lists. 45 According to some specialists
we spoke with, a central repository for past and ongoing research would be
helpful to ensure that future research plans will align with current needs
and that new research undertaken will not be duplicative of prior research.
It will also help ensure the transfer of knowledge and experience between
different groups and generations of researchers and responders so that
key lessons and insights do not get lost from one spill to the next,
according to some specialists we spoke with.




45
  As mentioned earlier, NOAA officials told us that the agency’s funding for the CRRC
ended in 2007; as a result, the future of the CRRC is uncertain.




Page 43                                                       GAO-12-585 Oil Dispersants
              Some agency officials, experts, and specialists expressed concerns about
              the independence and quality of dispersant research, which can lead to
              mistrust and misperception about the results. For example, one expert
              told us that industry research may not be fully independent in that industry
              groups would not want to publish research results demonstrating that
              dispersants are harmful in any way. Moreover, some agency officials told
              us there is a concern in the oil spill research community that industry
              researchers do not necessarily use the same peer review process for
              validating their results as is used by government or academia, raising
              concerns about the reliability of the research. Conversely, some
              specialists and one expert noted that because of limited experience in
              actual spill response, many academic researchers do not design and
              conduct studies that reflect realistic spill scenarios, which can skew the
              results or make them less helpful for making decisions during a spill. In
              addition, as previously mentioned, not all dispersant research is
              conducted using consistent methodological approaches, which limits its
              comparability and usefulness in drawing broader conclusions.

              In addition to communication challenges that may exist among the
              different groups involved in dispersant research, some agency officials,
              experts, and specialists we spoke with noted challenges in
              communicating scientific information to the public. According to
              proceedings from a NOAA-sponsored workshop on dispersant use,
              communication to the public—as well as to federal, state, and local
              agencies—was seen as one of the largest issues during the Deepwater
              Horizon incident. For example, a series of local community meetings were
              held during the response at which response specialists were on hand to
              address specific stakeholder questions. From these sessions, it was clear
              to the response specialists that members of the community at these
              sessions had many misconceptions about dispersants, specifically with
              regard to their degradation, toxicity, and application, as well as ways in
              which to monitor them.


              Ocean oil spills can have devastating effects on the environment, coating
Conclusions   coastlines and wetlands and killing marine mammals, birds, fish, and
              other wildlife. Chemical dispersants are one tool that responders have at
              their disposal to try to mitigate the consequences of a spill. Much is
              known about the use of dispersants—particularly on the surface of the
              water and in temperate climates—and federal agencies, industry, states,
              and other groups have taken steps to enhance knowledge on
              dispersants. However, gaps remain, and less is known about the
              application and effects of dispersants applied subsurface to underwater


              Page 44                                              GAO-12-585 Oil Dispersants
spills and to spills in the Arctic or colder environments. Because future
domestic oil production will rely to a substantial extent on developing
additional wells in challenging environments, such as deep waters and
the Arctic Ocean, researching dispersant use in these environments will
be key to improving decision makers’ understanding of the potential
consequences of using dispersants in these situations. Some research
related to application below the surface and in Arctic conditions is under
way, and the Interagency Coordinating Committee on Oil Pollution
Research is currently working to revise its research and technology plan
to address some gaps, including those related to dispersant use.

To make decisions about whether to use dispersants, decision makers
need timely and reliable scientific information on the trade-offs between the
risks that untreated oil poses to the water surface and shoreline habitats
and the risks that chemically dispersed oil poses to underwater
environments. This information must be available before a spill happens
and incorporated into response planning, as the decision to use
dispersants must be made quickly, and an emergency situation provides no
time for designing new research. Because years may pass in between spill
events, information on dispersant use must also be available to responders
and researchers who may have limited experience in using and applying
dispersants as a response option. Some groups, including the Interagency
Coordinating Committee on Oil Pollution Research, have developed lists of
past or ongoing federal research projects related to dispersants, but there
currently is no mechanism that tracks dispersant research across all
sources and highlights key recent and ongoing research projects.
Dissemination of such information would help ensure that new federal
research undertaken will not duplicate prior research and that key
knowledge can more easily transfer from one spill or generation of
researchers and responders to the next. Moreover, the Interagency
Committee is in a prime position to request the sharing of such information
from these non-federal sources in the course of fulfilling its mission to
coordinate a comprehensive program of oil pollution research among
federal agencies, in cooperation and coordination with industry,
universities, research institutions, state governments, and other nations.
Up-to-date information on the findings of key research on dispersant use
and its effects is essential to ensuring that federal research priorities, as
articulated in the research and technology plan currently being revised, are
effectively targeting the most important research needs.




Page 45                                              GAO-12-585 Oil Dispersants
                      Gaining a full understanding of the effectiveness and potential
                      environmental effects of dispersant use is difficult to accomplish in a
                      laboratory setting, not to mention during a spill in light of the competing
                      needs of oil spill responders. However, it is during a spill when the greatest
                      opportunity exists to gather real world data to help address some of the
                      identified research gaps. While some information is currently gathered
                      during response operations, it is primarily limited to whether the oil on the
                      surface is breaking into small droplets and entering the water column.
                      Specifically, the SMART monitoring protocols currently used during a spill
                      response gather information on whether chemical dispersants should
                      continue to be used, but these protocols do not provide robust scientific
                      information on dispersant use and effects. Furthermore, these monitoring
                      protocols are designed for use with surface application of dispersants and
                      do not monitor dispersed oil resulting from deep water dispersant
                      application. NOAA recognized such limitations in its recent review of the
                      SMART data from dispersant monitoring during the Deepwater Horizon
                      incident and has acknowledged improvements could be made.


                      To ensure existing and ongoing dispersant research is adequately
Recommendations for   captured and broadly available to different groups and generations of
Executive Action      researchers, to ensure that new research undertaken by the federal
                      government will not duplicate other research efforts, and to ensure that
                      adequate attention is given to better understanding dispersant use in
                      deep water and Arctic environments, we recommend that the
                      Commandant of the Coast Guard direct the Chair of the Interagency
                      Coordinating Committee on Oil Pollution Research to take the following
                      two actions, in coordination with member agencies:

                         Ensure that in the course of revising the Interagency Committee’s
                          research and technology plan, applications of dispersants subsurface
                          and in Arctic conditions are among the areas prioritized for
                          subsequent research.

                         As part of the Interagency Committee’s efforts to help guide federal
                          research, identify information on key ongoing dispersant-related
                          research, including research sponsored by state governments,
                          industry, academia, and other oil pollution research organizations.
                          This information should be provided in the planned and future
                          revisions to the research and technology plan. In addition, periodically
                          update and disseminate this information, for example, as part of the
                          Interagency Committee’s biennial report to Congress on its activities.




                      Page 46                                                GAO-12-585 Oil Dispersants
                  To enhance the knowledge of the effectiveness and potential
                  environmental effects of chemical dispersants, we recommend that the
                  Secretaries of Commerce and the Interior, the Administrator of EPA, and
                  the Commandant of the Coast Guard direct their respective agencies,
                  NOAA, BSEE, EPA, and the Coast Guard, to coordinate and explore
                  ways to better obtain more scientifically robust information during spills
                  without hindering response efforts through enhancement of monitoring
                  protocols and development of new data collection tools.


                  We provided a draft of this report to the Department of Commerce, the
Agency Comments   Department of Health and Human Services, the Department of Homeland
                  Security, the Department of the Interior, the Environmental Protection
                  Agency, and the National Science Foundation for review and comment.
                  DHS concurred with all three recommendations made to it. Commerce and
                  Interior concurred with the recommendation directing them to explore ways
                  to better obtain more scientifically robust information during spills. While
                  EPA did not directly state whether it concurred with that recommendation,
                  the agency generally agreed, noting that it is committed to exploring ways
                  to coordinate with other agencies to better obtain more scientifically robust
                  information during spills, enhance monitoring protocols, and develop new
                  data collection tools. In addition, Commerce, HHS, Interior, EPA, and NSF
                  provided us with technical comments, which we have incorporated as
                  appropriate. See appendixes IV, V, VI, and VII for agency comment letters
                  from Commerce, DHS, Interior, and EPA, respectively.




                  Page 47                                               GAO-12-585 Oil Dispersants
As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies of this report to the
Secretaries of Commerce, Health and Human Services, Homeland
Security, and the Interior; the EPA Administrator; the Director of the
National Science Foundation; the appropriate congressional committees;
and other interested parties. In addition, the report will be available at no
charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please
contact me at (202) 512-3841 or trimbled@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made major contributions to
this report are listed in appendix VIII.




David C. Trimble
Director, Natural Resources
  and Environment




Page 48                                               GAO-12-585 Oil Dispersants
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Our objectives were to examine (1) what is known about the use of
              chemical dispersants and their effects, and knowledge gaps about or
              limitations to their use, if any; (2) the extent to which federal agencies and
              other entities have taken steps to enhance knowledge on chemical
              dispersant use and its effects; and (3) challenges, if any, that researchers
              and federal agencies face in their attempts to enhance knowledge on
              chemical dispersant use and its effects.

              To determine what is known about the use and effects of chemical
              dispersants and identify any knowledge gaps or limitations, we reviewed
              documents and literature, including federal regulations and government
              oil spill planning documents, such as the National Contingency Plan,
              Regional Contingency Plans, and dispersant guidelines. We also
              reviewed scientific studies and key reports on dispersant use, such as the
              2005 National Academy of Sciences (NAS) report on Oil Spill
              Dispersants: Efficacy and Effects, the National Commission on the BP
              Deepwater Horizon Oil Spill and Offshore Drilling report to the President,
              and several Coast Guard and National Oceanic and Atmospheric
              Administration (NOAA) reports on response actions during the Deepwater
              Horizon incident. We used these documents to determine areas of
              research that inform planning and decision making regarding the use of
              chemical dispersants. In addition, we collaborated with the NAS to identify
              11 academic, industry, and other researchers recognized as experts in
              their respective scientific fields and capable of advising us on chemical
              dispersant use and research. In the report, these scientists and
              researchers are referred to as “experts.” NAS staff selected these experts
              based on their knowledge of one or more of the following topic areas:
              dispersant effectiveness, toxicity of dispersants and dispersed oil, fate
              and transport of dispersants and dispersed oil, monitoring actual
              dispersant use, risk assessment of dispersant use, other environmental
              effects of dispersant use, and challenges to dispersant research. In
              addition, NAS staff sought experts representing a wide range of
              viewpoints, including some experts who had experience with the
              Deepwater Horizon incident. In developing the list of experts, NAS staff
              consulted with NAS Ocean Studies Board members and volunteers from
              past and ongoing NAS studies on relevant topics to identify potential
              experts. NAS staff also performed literature reviews and targeted Internet
              searches based on the topic areas and questions identified by GAO. NAS
              staff composed the list of experts by identifying a range of expertise
              among prospective experts and then performing short interviews with
              them to discuss potential biases and any possible conflicts of interest,
              ensure that viewpoints were balanced, and confirm that some of the
              experts had experience with the Deepwater Horizon incident.


              Page 49                                               GAO-12-585 Oil Dispersants
Appendix I: Objectives, Scope, and
Methodology




GAO conducted semi-structured interviews with these experts to discuss
the state of knowledge, including gaps, regarding dispersant research.
We used a standard set of questions, asking the same questions in the
same order to each expert. We carefully documented and analyzed
expert responses to address our objectives and establish common
themes. We used the following categories to quantify the responses of
experts: “some” refers to responses from 2 to 4 experts, “many” refers to
responses from 5 to 7 experts, “most” refers to responses from 8 to 10
experts, and “all” refers to responses from all 11 experts. We
supplemented our semi-structured expert interviews with interviews of
federal officials and other oil spill or dispersant specialists, including state
officials who have been involved in past response actions, human health
researchers, oil spill response organizations with expertise in applying
chemical dispersants, industry representatives with experience in
researching oil dispersants and responding to oil spills, and other relevant
non-governmental organizations, such as a regional advisory group
focused on environmental protection as it relates to oil production and
transportation. Statements from these groups are identified as being from
“specialists.” During the course of our review, we spoke with 37
specialists. For the purposes of our interview analysis, in cases where
multiple specialists were present during one interview but each provided
their own views, we counted each specialist separately. We used the
following categories to quantify the responses of specialists: “some”
refers to responses from 2 to 4 specialists, “several” refers to responses
from 5 to 8 specialists, and “many” refers to responses from 9 or more
specialists.

To determine the extent to which federal agencies and other entities have
taken steps to enhance knowledge on chemical dispersant use and its
effects, and what challenges, if any, researchers have faced, we analyzed
information on federal research efforts since fiscal year 2000 supplied by
the key federal agencies conducting research on dispersant use and
effects: the Department of the Interior’s Bureau of Safety and
Environmental Enforcement (BSEE), the Department of Homeland
Security’s United States Coast Guard, the Environmental Protection
Agency (EPA), the Department of Health and Human Services’ (HHS)
National Institutes of Health (NIH) and Centers for Disease Control and
Prevention (CDC), the Department of Commerce’s NOAA, and the
National Science Foundation (NSF). This information included titles,
funding levels, and a brief description of agency research projects. To
assess the reliability of agency-supplied data, we asked the agencies to
describe how they gathered this information, including their data reliability
controls; we also checked the lists that the agencies provided to us


Page 50                                                 GAO-12-585 Oil Dispersants
Appendix I: Objectives, Scope, and
Methodology




against other publicly available lists of dispersant research projects to
help ensure consistency and completeness. We then categorized each of
the dispersant research projects into one or two research areas and sent
these categorizations back to the agencies for their concurrence. We also
conducted interviews with federal officials from these agencies to obtain
their perspectives on the extent and focus of their research efforts and
what challenges, if any, they have faced. In addition, we analyzed
information supplied by, and conducted interviews with, specialists to
obtain their perspectives on dispersant research efforts and potential
associated challenges. In addition, we attended a NOAA-funded
workshop on the future of dispersant use to gather information on both
the state of knowledge and ongoing research. We also attended an
industry-funded workshop of key federal, state, and local responders,
academic researchers, and other stakeholders who could potentially be
affected by an accidental offshore oil spill along the Eastern seaboard of
the United States. At these workshops we collected written materials,
listened to presentations, and spoke with specialists in attendance.

We conducted this performance audit from March 2011 through May
2012, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




Page 51                                            GAO-12-585 Oil Dispersants
Appendix II: List of Experts Selected by the
               Appendix II: List of Experts Selected by the
               National Academy of Sciences



National Academy of Sciences

               Michel Boufadel, Temple University

               James Clark, Independent Consultant (retired - ExxonMobil Research
               and Engineering)

               Cortis Cooper, Chevron Energy Technology Company

               Sara Edge, Harbor Branch Oceanographic Institute

               Merv Fingas, Independent Consultant (retired - Environment Canada)

               Kenneth Lee, Fisheries and Oceans Canada

               Judith McDowell, Woods Hole Oceanographic Institution

               Francois Merlin, Centre of Documentation, Research and
               Experimentation on Accidental Water Pollution (CEDRE)

               Jacqueline Michel, Research Planning, Inc.

               Chris Reddy, Woods Hole Oceanographic Institution

               Ronald Tjeerdema, University of California, Davis




               Page 52                                             GAO-12-585 Oil Dispersants
Appendix III: Listing of Federally Sponsored
                                            Appendix III: Listing of Federally Sponsored
                                            Research on Dispersants since Fiscal Year
                                            2000, by Research Category and Agency


Research on Dispersants since Fiscal Year
2000, by Research Category and Agency
                                            The following is a listing of federally sponsored research projects related
                                            to dispersants. The title and initial funding year for each dispersant project
                                            was supplied by the respective agency. 1 We asked for this information
                                            from the following agencies: the Department of the Interior’s Bureau of
                                            Safety and Environmental Enforcement (BSEE), the Department of
                                            Homeland Security’s United States Coast Guard (Coast Guard), the
                                            Environmental Protection Agency (EPA), the Department of Health and
                                            Human Services’ (HHS) National Institutes of Health (NIH) and Centers
                                            for Disease Control and Prevention (CDC), the Department of
                                            Commerce’s National Oceanic and Atmospheric Administration (NOAA),
                                            and the National Science Foundation (NSF).

Table 4: Federally Sponsored Research on Dispersants since Fiscal Year 2000, by Research Category and Agency

Effectiveness
Agency     Title of dispersant project                                                                                        Fiscal year
BSEE       TAR 350: Laboratory Study to Compare the Effectiveness of Chemical Dispersants when Applied Dilute                       2000
           versus Neat
BSEE       TAR 375: Feasibility of Using Ohmsett for Dispersant Testing and Research                                                2000
BSEE       TAR 160: Study of Oil Spill Chemical Treating Agents                                                                     2000
BSEE       TAR 436: Chemical Characteristics of an Oil and the Relationship to Dispersant Effectiveness                             2002
BSEE       TAR 450: Dispersant Effectiveness Testing in Cold Water                                                                  2002
BSEE       TAR 476: Ohmsett 2003 Cold Water Dispersant Effectiveness Experiments                                                    2003
BSEE       TAR 506: Analysis of IFO-180 and IFO-380 Oil Properties for Dispersant Window of Opportunity                             2004
BSEE       TAR 507: Correlating Results of Ohmsett Dispersant Test with At-Sea Trials: Workshop to Coordinate                       2004
           Publications and Prioritize Follow-up Research
BSEE       TAR 477: Correlating Results of Dispersants Effectiveness at Ohmsett with Identical At-Sea trial: Effects of Oil         2003
           Viscosity and Dispersant to Oil Ratios
BSEE       TAR 513: Laboratory Testing to Determine Dispersant Predictability of the Baffle Flask Test (BFT) and                    2004
           Swirling Flask Test (SWT)
BSEE       TAR 514: Dispersant Effectiveness testing on Heavy OCS Crude Oils a Ohmsett                                              2004
BSEE       TAR 526: Correlate Ohmsett Dispersant Tests with At Sea Trials; Supplemental Tests to Complete Test                      2005
           Matrix
BSEE       TAR 563: Understanding the Effects of Time and Energy on the Effectiveness of Dispersants                                2005




                                            1
                                              The year listed represents the first year in which the project was funded. Joint or
                                            collaborative projects are entered under each relevant agency as supplied by that agency.
                                            If a project had more than one research focus, it appears under each of the applicable
                                            section’s headers.




                                            Page 53                                                         GAO-12-585 Oil Dispersants
                                           Appendix III: Listing of Federally Sponsored
                                           Research on Dispersants since Fiscal Year
                                           2000, by Research Category and Agency




Effectiveness
Agency    Title of dispersant project                                                                                       Fiscal year
BSEE      TAR 529: Analysis of Dispersant Effectiveness of Heavy Fuel Oils and Weathered Crude Oils at Two Different              2005
          Temperatures Using the Baffled Flask Test
BSEE      TAR 527: The Effect of Warming Viscous Oils Prior to Discharge on Dispersant Performance                                2005
BSEE      TAR 542: Dispersant Effectiveness Testing on Realistic Emulsions at Ohmsett                                             2005
BSEE      TAR 545: Calm Sea Application of Dispersants                                                                            2005
BSEE      TAR 568: Research at Ohmsett on the Effectiveness of Chemical Dispersants on Alaskan Oils in Cold Water                 2006
BSEE      TAR 595: Identification of Window of Opportunity for Chemical Dispersants on Gulf of Mexico Crude Oils                  2007
BSEE      TAR 546: Chemical Dispersibility of OCS Crude Oils in Non-Breaking Waves, Part 1 Determining the Limiting               2005
          Oil Viscosity for Dispersion in Non-Breaking Waves
BSEE      TAR 590: Changes with Dispersant Effectiveness with Extended Exposure in Calm Seas                                      2007
BSEE      TAR 589: Investigation of the Ability to Effectively Recover Oil Following Dispersant Application                       2007
BSEE      TAR 615: Chemical Dispersant Research at Ohmsett                                                                        2008
BSEE      TAR: 635 Literature Review on Chemical Treating Agents in Fresh and Brackish Water                                      2009
BSEE      TAR 637: Validation of the Two Models Developed to Predict the Window of Opportunity for Dispersant Use in              2009
          the Gulf of Mexico
BSEE      TAR 663: Heavy Oil Dispersion Research                                                                                  2010
BSEE      TAR 638: Chemical Dispersant Research at Ohmsett: Phase 2                                                               2009
BSEE      TAR 666: Baffled Flask Dispersant Effectiveness Testing                                                                 2010
BSEE      TAR 685: Operational Chemical Dispersant Research at Ohmsett                                                            2011
BSEE      TAR 681: Laboratory-Scale Investigation of a Method for Enhancing the Effectiveness of Oil Dispersants in               2011
          Destabilizing Water-in-Oil Emulsions
BSEE      TAR 427: Dispersant Effectiveness Test Protocol Development for Ohmsett                                                 2000
EPA       Oil Spill Dispersant Effectiveness Protocol                                                                            1998a
EPA       The Baffled Flask Test for Dispersant Effectiveness: A Round Robin Evaluation of Reproducibility and                    2001
          Repeatability
EPA       Evaluation of Energy Dissipation Rates in Laboratory Flasks Simulating Various Sea States                               2001
EPA       Testing the Dispersant Effectiveness of a New Dispersant Using the Swirling Flask Test                                  2002
EPA       Evaluation of Dispersant Effectiveness in a Wave Tank                                                                   2003
EPA       Evaluation of Dispersant Effectiveness in a Wave Tank                                                                   2004
EPA       Dispersant Effectiveness of Commercial Dispersants on Two Heavy Fuel Oils                                               2004
EPA       Laboratory Testing to Determine Dispersant Predictability of the Baffle Flask Test (BFT) and Swirling Flask             2004
          Test (SWT)
EPA       Dispersion Effectiveness as a Function of Turbulence and Particle Size                                                  2005
EPA       Dispersant Effectiveness as a Function of Turbulence                                                                    2005
EPA       Dispersion of Crude Oil and Petroleum Products in Freshwater                                                            2006
EPA       Dispersant Effectiveness as a Function of Turbulence Under Continuous Flow Conditions                                   2007
EPA       Dispersant effectiveness of 20 crude and fuel oils by Corexit 9500 in lab                                               2010




                                           Page 54                                                            GAO-12-585 Oil Dispersants
                                          Appendix III: Listing of Federally Sponsored
                                          Research on Dispersants since Fiscal Year
                                          2000, by Research Category and Agency




Effectiveness
Agency    Title of dispersant project                                                                                   Fiscal year
EPA       Use of the Baffled Flask Test to Determine the Dispersant Effectiveness of the Eight NCP Product Schedule           2010
          Dispersants on S. Louisiana Crude Oil at Two Temperatures
EPA       Dispersant Effectiveness Data                                                                                       2001
EPA       Develop Extended Dispersant Data on for a Suite of Environmental Conditions                                         2006
NOAA      Wave Tank Studies on Dispersant Effectiveness as a Function of Energy Dissipation Rate and Particle Size            2006
          Distribution
Fate and transport
EPA       Biodegradability of Dispersed Oil                                                                                   2004
EPA       Biodegradability of Dispersed Oil at 2 Temperatures                                                                 2005
EPA       Biodegradability of Dispersants and Dispersed Oil at Two Temperatures                                               2010
EPA       Impact of Waves on Oil and Dispersed Oil                                                                            2001
NOAA      Effects of Dispersants on Oil-SPM Aggregation and Fate in US Coastal Waters                                         2006
NOAA      Measurements and Modeling of Size Distributions, Settling and Dispersions Rates of Oil Droplets in                  2007
          Turbulent Flows
NOAA      Field Verification of SIMAP Oil Spill Fate and Transport Modeling and Linking CODAR Observation                     2006
          Systems Data with SIMAP Predictions
NSF       Development of a Pyrolysis GC/MS Facility for Characterizing Oil-Contaminated Water, Sediment and                   2010
          Seafood Samples
NSF       MRI RAPID: Acquisition of Two Cavity Ringdown Spectrometers to Quantify Hydrocarbon Conversion in                   2010
          Deep Waters of the Gulf of Mexico
NSF       MRI RAPID: Deepwater Oil/Gas Well Blowout Simulator to Study Oil/Gas Dispersion and Mitigate Gas                    2010
          Hydrate Formation in the Gulf Oil Spill
NSF       RAPID for Gulf of Mexico Oil Spill: Interactions of Crude Oil with Dispersants and Naturally Occurring              2010
          Particles
NSF       RAPID Response in Gulf of Mexico: Sediment Trap Investigations                                                      2010
NSF       RAPID/MRI: Acquisition of a Triple-Quad Mass Spectrometer for Quantitative Identification of Dispersants            2010
          and Water-Soluble Oil in the Gulf of Mexico
NSF       RAPID: Hydrocarbon Dissolution Fluxes from the Deepwater Horizon Oil Plume: GCxGC Chemical                          2010
          Analysis and Mass Transfer Modeling
NSF       RAPID: Multi-phase Buoyant Plumes in Stratified Water Study relevant to Oil Spill Implications for the Gulf         2010
          oil spill distribution
NSF       RAPID: Self Assembly of Chemical Dispersant Systems in the Treatment of Deep Water Hydrocarbon                      2010
          Releases
NSF       RAPID: 3-D Model Forecast of the Vertical and Horizontal Distributions of the Oil Plumes Arising From the           2010
          Deepwater Horizon Spill
NSF       RAPID: Assessing the Impact of Chemical Dispersants on the Microbial Biodegradation of Oil Immediately              2010
          following a Massive Spill
NSF       RAPID: Collaborative Research: Deepwater Horizon Oil Spill, Marine Snow and Sedimentation                           2010
NSF       RAPID: Evaluation of the near term impact of the Deepwater Horizon blowout to the South Florida coast               2010
NSF       RAPID: Photochemical Fate of Oil Dispersants Used in the Gulf Oil Spill Clean-up                                    2010




                                          Page 55                                                         GAO-12-585 Oil Dispersants
                                            Appendix III: Listing of Federally Sponsored
                                            Research on Dispersants since Fiscal Year
                                            2000, by Research Category and Agency




Effectiveness
Agency     Title of dispersant project                                                                                      Fiscal year
Aquatic toxicity and environmental effects
BSEE       TAR 449: Effects of Chemically Dispersed and Biodegraded Oils                                                          2002
BSEE       TAR 662: Combining Mineral Fines with Chemical Dispersants to Disperse Oil in Low Temperature and Low                  2010
           Mixing Energy Environments
EPA        In vitro Testing of Eight Oil Dispersants for In Vitro Assessment of Estogenicity, Androgenicity, Anti-                2010
           Androgenicity and Cytotoxicity
EPA        Toxicity of Eight Oil Dipsersants, Louisiana Crude Oil (LSC), and Dispersed LSC to Two Gulf Species                    2010
EPA        Toxicity of Dispersed Oil to Marine Organisms                                                                          2008
NOAA       Effects of Dispersed Oil on Ecologically Relevant Aquatic Organisms using a Salt-Marsh Mesocosm                        2011
NOAA       Acute and Chronic Effects of Crude Oil and Dispersed Oil on Chinook Salmon Smolts (Oncorhynchus                        2003
           tshawytscha)
NOAA       Acute and Chronic Effects of Oil, Dispersant and Dispersed Oil to Symbiotic Cnidarian Species                          2005
NOAA       Dispersants as an Oil Spill Countermeasure for Remediation and Restoration in Sensitive Coastal Habitats               2003
NOAA       Guidance for Dispersant Decision Making: Potential for Impacts on Aquatic Biota                                        2008
NOAA       The Relationship Between Acute and Population Level Effects of Exposure to Dispersed Oil, and the                      2006
           Influence of Exposure Conditions using Multiple Life History Stages of an Estuarine Copepod, Eurytemora
           affinis, as Model Planktonic Organisms.
NOAA       Lack of Biological Effects of Water Accommodated Fractions of Chemically-and Physically-Dispersed Oil on               2005
           Molecular, Physiological, and Behavioral Traits of Juvenile Snapping Turtles following Embryonic Exposure.
NSF        RAPID: Collaborative Proposal: Spatially-explicit, High-resolution Mapping and Modeling to Quantify Hypoxia            2010
           and Oil Effects on the Living Resources of the Northern Gulf of Mexico
NSF        RAPID: Deepwater Horizon Oil Spill: Impacts on Blue Crab Population Dynamics and Connectivity.                         2010
NSF        RAPID: Collaborative Research: Nematostella as an Estuarine Indicator Species for Assessing Molecular and              2010
           Physiological Impacts of the Deepwater Horizon oil spill.
NSF        RAPID: Assessing the Impact of Chemical Dispersents on the Microbial Biodegradation of Oil Immediately                 2010
           Following a Massive Spill
NSF        RAPID: Assessment of the Impacts of the Deep Horizon Oil Spill on Bluecrab, Callinectes Sapidus, Spawning              2010
           and Recruitment in the Northcentral Gulf of Mexico.
NSF        RAPID: Collaborative Proposal: Acute Response of Benthic Hardbottom Communities to Oil Exposure in the                 2010
           Deep Gulf of Mexico
NSF        RAPID: Collaborative Research: Genetic Impact of the Deepwater Horizon Oil Release                                     2010
NSF        RAPID: Community-level Wetland Stressors, Northern Gulf of Mexico                                                      2010
NSF        RAPID: Rapid Assessment of Extent and Photophysiological Effects of the Deepwater Horizon Oil Spill                    2010
NSF        RAPID: Resolving Higher Trophic-level Change within the Northern Gulf of Mexico Ecosystem as a                         2010
           Consequence of the Deepwater Horizon Oil Spill
NSF        RAPID-Attachment of Crude Oil and Washability of Sand Beaches and Marsh Lands: Effects of Berms and                    2010
           Dispersants




                                            Page 56                                                           GAO-12-585 Oil Dispersants
                                              Appendix III: Listing of Federally Sponsored
                                              Research on Dispersants since Fiscal Year
                                              2000, by Research Category and Agency




Effectiveness
Agency       Title of dispersant project                                                                                     Fiscal year
Modeling
BSEE         TAR 637: Validation of the Two Models Developed to Predict the Window of Opportunity for Dispersant                   2009
             Use in the Gulf of Mexico
EPA          Wave Modeling of Oil Slicks                                                                                           2006
EPA          Development of ERO3S Model                                                                                            2001
NOAA         Guidance for Dispersant Decision Making: Potential for Impacts on Aquatic Biota                                       2008
NOAA         Effects of Dispersants on Oil-SPM Aggregation and Fate in US Coastal Waters                                           2006
NOAA         Measurements and Modeling of Size Distributions, Settling and Dispersions Rates of Oil Droplets in                    2007
             Turbulent Flows
NOAA         Field Verification of SIMAP Oil Spill Fate and Transport Modeling and Linking CODAR Observation                       2006
             Systems Data with SIMAP Predictions
NSF          RAPID Collaborative Proposal: Spatially-explicit, High-resolution Mapping and Modeling to Quantify                    2010
             Hypoxia and Oil Effects on the Living Resources of the Northern Gulf of Mexico
NSF          RAPID: Multi-phase Buoyant Plumes in Stratified Water Study relevant to Oil Spill Implications for the Gulf           2010
             oil spill distribution
NSF          RAPID: 3-D Model Forecast of the Vertical and Horizontal Distributions of the Oil Plumes Arising From the             2010
             Deepwater Horizon Spill
NSF          RAPID: Evaluation of the Near Term Impact of the Deepwater Horizon Blowout to the South Florida Coast                 2010
Monitoring
BSEE         TAR 477: Correlating Results of Dispersants Effectiveness at Ohmsett with Identical At-Sea trial: Effects             2003
             of Oil Viscosity and Dispersant to Oil Ratios
BSEE         TAR 598: Upgrade of SMART Dispersant Effectiveness Monitoring Protocol                                                2007
BSEE         TAR 697: Assessment of Dispersant Effectiveness using Ultrasound to Measure Oil Droplet Particle Size                 2011
             Distributions
Coast        Updating Special Monitoring of Alternative Response Technologies (SMART) Protocol                                     2007
Guard
EPA          Upgrade of SMART Dispersant Effectiveness Monitoring Protocol                                                         2007
NOAA         Use of Natural Oil Seeps for Evaluation of Dispersant Application and Monitoring Techniques                           2002
NOAA         Upgrade of SMART Dispersant Effectiveness Monitoring Protocol                                                         2007
Human Health
EPA          In Vitro High Throughput Screening of Eight Oil Dispersants in ToxCast Assays for Estrogenicity,                      2010
             Androgenicity, Anti-Androgenicity, Other Endocrine Related Endpoints, and Cytotoxicity
EPA          In Vitro Testing of Eight Oil Dispersants for In Vitro Assessment of Estogenicity, Androgenicity, Anti-               2010
             Androgenicity and Cytotoxicity
HHS          NIOSH Emergency Preparedness and Response Office-Technical Assistance and Advancing Research—                         2010
             Research on Airborne Concentrations of Corexit 9500A
HHS          NIOSH Emergency Preparedness and Response Office-Technical Assistance and Advancing Research –                        2010
             Dermal Exposure Studies to Assess Immune Responses in Lab Rats to Exposure to Dispersant (Corexit
             9500A)
HHS          In Vitro High Throughput Screening of Eight Oil Dispersants in ToxCast Assays for Estrogenicity,                      2010
             Androgenicity, Anti-Androgenicity, Other Endocrine Related Endpoints, and Cytotoxicity




                                              Page 57                                                          GAO-12-585 Oil Dispersants
                                          Appendix III: Listing of Federally Sponsored
                                          Research on Dispersants since Fiscal Year
                                          2000, by Research Category and Agency




Effectiveness
Agency    Title of dispersant project                                                                                     Fiscal year
HHS       Human Health Impact of Deepwater Horizon Spill in Eastern Gulf Coast Communities. Sub-project title—                  2011
          Seafood Hydrocarbon Residues and Coastal Community Health Risks.
Subsurface/Deep water applications
NSF       MRI RAPID: Acquisition of Two Cavity Ringdown Spectrometers to Quantify Hydrocarbon Conversion in                     2010
          Deep Waters of the Gulf of Mexico
NSF       RAPID: Self Assembly of Chemical Dispersant Systems in the Treatment of Deep Water Hydrocarbon                        2010
          Releases
NSF       RAPID: Collaborative Proposal: Acute Response of Benthic Hardbottom Communities to Oil Exposure in                    2010
          the Deep Gulf of Mexico
Arctic
BSEE      TAR 450: Dispersant Effectiveness Testing in Cold Water                                                               2002
BSEE      TAR 476: Ohmsett 2003 Cold Water Dispersant Effectiveness Experiments                                                 2003
BSEE      TAR 563: Understanding the Effects of Time and Energy on the Effectiveness of Dispersants                             2005
BSEE      TAR 527: The Effect of Warming Viscous Oils Prior to Discharge on Dispersant Performance                              2005
BSEE      TAR 568: Research at Ohmsett on the Effectiveness of Chemical Dispersants on Alaskan Oils in Cold Water               2006
BSEE      TAR 662: Combining Mineral Fines with Chemical Dispersants to Disperse Oil in Low Temperature and                     2010
          Low Mixing Energy Environments
EPA       Biodegradability of Dispersed Oil at 2 Temperatures                                                                   2005
EPA       Biodegradability of Dispersants and Dispersed Oil at Two Temperatures                                                 2010
Alternative Dispersant Formulations
NSF       Collaborative Research: Characterization of Lipo-peptides for Use as Bio-dispersants to Clean-up Oil                  2010
          Spills
NSF       MRI RAPID: Acquisition of High-Rate Nanomanufacturing System for Accelerated Development of Novel                     2010
          Materials and Processes for Oil Spill Remediation
NSF       RAPID: Water-based, Natural Polymer Surfactants: Implications for Deepwater Horizon Oil Spill Dispersions             2010
NSF       Air: First Stage Commercialization of Oil Anti-Deposition Dispersant Technology for Spilled Oil                       2011
General Research
BSEE      TAR 349: Technology Assessment of the Use of Dispersants on Spills from MMS-Regulated OCS                             2000
          Facilities
BSEE      TAR 413: Assessment of the Use of Dispersants on Marine Oil Spills in California                                      2001
BSEE      TAR 493: Understanding Oil Spill Dispersants: Efficacy and Effects                                                    2003
BSEE      TAR 613: Development of a Training Package on the Use of Chemical Dispersants for Ohmsett—The                         2008
          National Oil Spill Response Test Facility
Coast     Report: National Research Council’s Committee on Understanding Oil Spill Dispersants: Efficacy and Effects            2004
Guard
NOAA      Future of Dispersant Use in Spill Response                                                                            2011
NOAA      NOAA’s Support for 2005 NRC Report on Dispersants                                                                     2003
NSF       RAPID: Responsive Oil Spill Outreach Based in Science                                                                 2010
                                          Source: Project listings supplied by each agency.
                                          a
                                           This project began in 1998, and continued past 2000.



                                          Page 58                                                           GAO-12-585 Oil Dispersants
Appendix IV: Comments from the
             Appendix IV: Comments from the Department
             of Commerce



Department of Commerce




             Page 59                                     GAO-12-585 Oil Dispersants
Appendix IV: Comments from the Department
of Commerce




Page 60                                     GAO-12-585 Oil Dispersants
Appendix V: Comments from the Department
             Appendix V: Comments from the Department
             of Homeland Security



of Homeland Security




             Page 61                                    GAO-12-585 Oil Dispersants
Appendix V: Comments from the Department
of Homeland Security




Page 62                                    GAO-12-585 Oil Dispersants
Appendix VI: Comments from the
             Appendix VI: Comments from the Department
             of the Interior



Department of the Interior




             Page 63                                     GAO-12-585 Oil Dispersants
Appendix VI: Comments from the Department
of the Interior




Page 64                                     GAO-12-585 Oil Dispersants
Appendix VII: Comments from the
             Appendix VII: Comments from the
             Environmental Protection Agency



Environmental Protection Agency




             Page 65                           GAO-12-585 Oil Dispersants
Appendix VII: Comments from the
Environmental Protection Agency




Page 66                           GAO-12-585 Oil Dispersants
Appendix VIII: GAO Contact and Staff
                  Appendix VIII: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  David C. Trimble, (202) 512-3841 or trimbled@gao.gov
GAO Contacts
                  In addition to the individual named above, Elizabeth Erdmann (Assistant
Staff             Director), Antoinette Capaccio, Margaret Childs, Cindy Gilbert, Ryan
Acknowledgments   Gottschall, Rebecca Makar, Alison O’Neill, and Jena Sinkfield made key
                  contributions to this report.




(361265)
                  Page 67                                           GAO-12-585 Oil Dispersants
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