Is BP complying with the Directive to reduce dispersant use in the Gulf?

Richard Denison, Ph.D., is a Senior Scientist.

[Note added 6/22:  I have corrected one of the figures below, which was based on a misunderstanding of the EPA/Coast Guard Directive.  Please see this correction for the updated information and a statement from EPA.]

As of yesterday, BP’s use of dispersants to address the ongoing Deepwater Horizon spill has topped 1.4 million gallons.

On May 26, 2010, EPA and the Coast Guard issued a Directive to BP calling for significant reductions in BP’s use of dispersants.  That directive set out three requirements:

• Eliminate surface application of dispersant except in rare cases where exemptions are requested in writing and granted by the Coast Guard’s Federal On-Scene Coordinator (FOSC).
• Limit subsurface application of dispersant to a maximum of 15,000 gallons per day.
• Overall goal of reducing dispersant use by 75%.

Has BP complied?  The short answer is not even close.  The details follow. 

BP’s use of dispersants is tracked and reported daily by the Deepwater Horizon Unified Command on its website.  The first report of dispersant use was on April 23, three days after the explosion that initiated leakage of oil.  Subsurface application of dispersant was approved by EPA and the Coast Guard and initiated on or about May 17.

Here’s a graph I compiled from the Unified Command’s daily reports that shows the cumulative amounts of dispersants applied through yesterday at the surface and subsea by BP:

So, is BP complying?  Let’s take the requirements one at a time:

• Eliminate surface application of dispersant except in rare cases where exemptions are requested in writing and granted by the Coast Guard’s Federal On-Scene Coordinator (FOSC).

Clearly, BP has not come close to ceasing surface application of dispersant.  Before the directive date of May 26, BP’s surface application daily average was 20,600 gallons.  Since May 26, the daily average has fallen to just under 10,000 gallons, a 52% reduction.

• Limit subsurface application of dispersant to a maximum of 15,000 gallons per day.

BP has done somewhat better here, but has exceeded the daily maximum on four occasions since the date of the directive:

            On May 28:    20,000 gallons were applied subsurface

            On May 30:    20,000 gallons were applied subsurface

            On June 6:      33,000 gallons were applied subsurface

            On June 20:    18,000 gallons were applied subsurface

•  Overall goal of reducing dispersant use by 75%.

Before the directive, BP’s total application of dispersant averaged 24,700 gallons per day.  Since the directive, that average has fallen only slightly, to 22,600 gallons per day – a decrease of only 9%.

[Note added 6/22:  While the figures in the preceding sentence are accurate, they were based on a misunderstanding of the EPA/Coast Guard Directive.  The Directive stated that the reduction goal was to measured against a baseline of the “maximum daily amount” specified in the Directive, rather than against the daily average, which is what I used; against that baseline, the reduction is 68%.  Please see this post providing the correction and a statement from EPA for details.]

(One note:  Since June 3, the daily numbers are reported as “more than X gallons,” whereas before that date the reported numbers were simply “X gallons.”  The calculations I used to derive the figures above assumed no more than the stated gallon values were applied.  Hence, they may be underestimates of actual dispersant usage by BP.)

I may have missed it, but I haven’t been able to find on the Unified Command’s or EPA’s website any indication that BP applied for and received exemptions to allow it to exceed the volume limits imposed by the Directive.