Notice of Availability for GENWEST EDRC Study and the National Academy of Sciences Letter Report (on the GENWEST Study); Comment Request

The Bureau of Safety and Environmental Enforcement (BSEE) is inviting you to provide comments on the GENWEST Systems, Inc., Effective Daily Recovery Capacity (EDRC) Study, National Academy of Sciences (NAS) Letter Report summarizing its peer review of the GENWEST Study, and comments provided by BSEE regarding each document. Background: EDRC is a calculation method established within BSEE's and the United States Coast Guard's (USCG) regulations to assign an oil recovery capability value to oil skimming equipment. Although the EDRC methodology was finalized in the early 1990's and has been an integral component of industry response planning and readiness for the past 20 years, the methodology came under heavy scrutiny in the wake of the 2010 Deepwater Horizon oil spill. This spurred an open debate and ongoing dialogue on how to best improve the EDRC planning standard. In late 2011, BSEE contracted with GENWEST Systems Inc. to evaluate the EDRC methodology and to develop recommendations for improving the planning standard for the mechanical recovery of oil on water. GENWEST's final report produced the concept of Estimated Recovery System Potential (ERSP), an oil encounter rate- based calculator that evaluates mechanical recovery equipment as a complete system as opposed to focusing on an individual component such as a skimmer or an intake pump. Shortly thereafter, BSEE contracted the National Research Council's Ocean Studies Board to conduct an independent, third party peer review of the ERSP methodology. The resulting National Academy of Sciences (NAS) Peer Review Letter Report validated the ERSP standard as a sound methodology and a significant improvement over EDRC. The peer review also identified a number of areas for further consideration where ERSP might be improved. BSEE is continuing to develop and refine the ERSP methodology, with the intent of evaluating ERSP as a potential revision to BSEE's oil spill response plan (OSRP) regulations. This notice provides a high level summary of some of the key elements of both documents, as well as BSEE comments regarding each document. It also includes BSEE's response to recommendations in the NAS Letter Report. While the development of a new planning standard for calculating the mechanical recovery of spills continues to undergo additional research and refinement, this notice provides an early opportunity for public viewing and comment on the GENWEST EDRC Study and NAS Letter Report documents which are available in the regulations.gov docket ID: BSEE-2014-0006 and on the BSEE Web site at http://www.bsee.gov/Research-and-Training/Oil-Spill-Response- Research/Projects/Project-673/, as well as an opportunity to comment on the BSEE's responses to the findings and recommendations contained in each document.