Please bear with me as I swim through the multi-layered clouds of this Dispersant story, like so many underwater plumes. Its twist and turns, go on for miles it seems, but each is relevant to the bigger picture ... (and skimming through it, is OK too. Or just look at the Pictures.)

[The ProPublica investigation

by Marian Wang, ProPublica - May 18, 2010 continues ...]

Given that the dispersants are EPA-approved, the choice of which ones to use was left to BP, which had stockpiled large amounts of Corexit and is now ordering more.

[...]

BP has defended its choice to use Corexit. A BP spokesman called the product [5] "pretty effective," and said it had been "rigorously tested." It is not testing other dispersants, he said, [5] because it’s focusing on stopping the spill. Mani Ramesh, the chief technology officer for Nalco, which makes Corexit, disputed claims that the product is harmful to the environment [10], telling Reuters that Corexit’s active ingredient is "an emulsifier also found in ice cream."



Don't you love it when Company spokesmen assure us "everything's fine" -- while at the same time refusing to disclosure all those "secret ingredients" in their "wonder product".

We can't violate those 'sacred' Copyrights now, can we?



Oil cleanup chemicals worry environment watchdogs

By Deborah Zabarenko, Environment Correspondent, Reuters -- May 4, 2010

The use of dispersants could be a trade-off between potential short-term harm to offshore wildlife and possible long-term damage to coastal wildlife habitat if the oil slick were to reach land.

[...]

So-called dispersants work on an oil spill as dishwashing detergent works on a greasy skillet: they break up oil into tiny droplets that sink below the water's surface where naturally occurring bacteria consume them. Without dispersants, oil stays on the water's surface, where bacteria can't get at them, Ramesh said. The problem, according to Jackie Savitz, a senior scientist at the marine environmental group Oceana, is that the dispersants themselves can be toxic to wildlife. Dispersants can also enhance oil's toxicity in the dispersion process.

"Dishsoap" may be perfectly safe for doing dishes -- but that doesn't mean I want to drink the stuff, with every meal!



"Dispersants can also enhance oil's toxicity in the dispersion process."

I wonder if the EPA knew about this "magnifier" effect? (The sum is greater than its parts, idea?)

I wonder if they knew about it, and approved it anyways -- it's an Emergency situation afterall. Drastic times, call for drastic measures, sometimes.



This is funny, the EPA recently updated their Dispersant Product list. Hmmm ... I wonder why?



EPA: PRODUCT SCHEDULE Revision (pdf)

ENVIRONMENTAL PROTECTION AGENCY

NATIONAL CONTINGENCY PLAN

PRODUCT SCHEDULE

MAY 2010 -- (5/11/2010) Prepared by:

U.S. Environmental Protection Agency

[So what changed in this schedule, in May of this year?]

[...]



PRODUCT NAME/BULLETIN NUMBER: COREXIT® EC7664A (SW-1)

PRODUCT TYPE: Surface Washing Agent

DATE LISTED: 11/01/78

RELISTED*: 05/02/10*

[...]



PRODUCT NAME/BULLETIN NUMBER: NOKOMIS 5-W (SW-38)

PRODUCT TYPE: Surface Washing Agent

DATE LISTED: 05/11/10



Blogger, raises Eyebrows, scratches Noggin ... that's odd.

Somebody just gave Corexit the "Official stamp of Approval" again. I wonder Who, and more importantly, Why?



OK, that's a story for another day ...

What about the Toxicity Specifics on Corexit 9500 -- the dispersant that BP has boat-loads of? The one that marine biologists are so worried about?

OK, Here's the Beef:

TECHNICAL PRODUCT BULLETIN: COREXIT® EC9500A

EPA Home - Emergency Management TECHNICAL PRODUCT BULLETIN #D-4

COREXIT® EC9500A -- (formerly COREXIT 9500)

VI. RECOMMENDED APPLICATION PROCEDURE 1 ) Application Method: COREXIT® EC9500A contains the same surfactants present in COREXIT® EC9500A and a new improved oleophilic [strong affinity for oils] solvent delivery system. Aerial Spraying - Aircraft provide the most rapid method of applying dispersants to an oil spill and a variety of aircraft can be used for spraying. For aerial spraying, COREXIT® EC9500A is applied undiluted. Typical application altitudes of 30 to 50 feet have been used, although higher altitudes may be effective under certain conditions. [...] Boat Spraying - COREXIT® EC9500A may also be applied by workboats equipped with spray booms mounted ahead of the bow wake or as far forward as possible. The preferred and most effective method of application from a workboat is to use a low-volume, low-pressure pump so the chemical can be applied undiluted. Spray equipment designed to provide a five to ten percent diluted dispersant solution to the spray booms can also be used. COREXIT® EC9500A 9500 should be applied as droplets, not fogged or atomized. Natural wave or boat wake action usually provides adequate mixing energy to disperse the oil. [...] 2 ) Concentration/Application Rate: A treatment rate of about 2 to 10 U.S. gallons per acre, or a dispersant to oil ratio of 1:50 to 1:10 is recommended. This rate varies depending on the type of oil, degree of weathering, temperature, and thickness of the slick. 3 ) Conditions for Use: As with all dispersants, timely application ensures the highest degree of success. Early treatment with COREXIT® EC9500A, even at reduced treat rates, can also counter the "mousse" forming tendencies of the spilled oil. COREXIT® EC9500A is useful on oil spills in salt water.

II. TOXICITY AND EFFECTIVENESS a. Toxicity [Diarist Note: parts per million indicated, which causes 50% Lethality, in test species, during the test period; see FAQ below.] Material Tested COREXIT® EC9500A Species LC50 (ppm)

Menidia beryllina 25.20 96-hr [about 3x less toxic than Reference]

Mysidopsis bahia 32.23 48-hr No. 2 Fuel Oil Menidia beryllina 10.72 96-hr

Mysidopsis bahia 16.12 48-hr COREXIT® EC9500A & No. 2 Fuel Oil (1:10) [Dispersant to Oil ratio] Menidia beryllina 2.61 96-hr [about 3x MORE toxic than Reference]

Mysidopsis bahia 3.40 48-hr

Reference Toxicant (SDS) [This looks like the baseline for Toxicity] Menidia beryllina 7.07 96-hr [Reference Toxicity level]

Mysidopsis bahia 9.82 48-hr

NOTE: This toxicity data was derived using the concentrated product. See Section VI of this bulletin for information regarding the manufacturer's recommendations for concentrations and application rates for field use.

[...]

VIII. PHYSICAL PROPERTIES 1 ) Flash Point: 181.4ºF

2 ) Pour Point: Less than -71ºF

3 ) Viscosity: 22.5 cst at 104ºF

4 ) Specific Gravity: 0.949 at 60ºF

5 ) pH: 6.2

6 ) Chemical Name and Percentage by Weight of the Total Formulation: CONFIDENTIAL

7 ) Surface Active Agents: CONFIDENTIAL

8 ) Solvents: CONFIDENTIAL

9 ) Additives: None

10 ) Solubility: Miscible

IX. ANALYSIS FOR HEAVY METALS, CYANIDE, AND CHLORINATED HYDROCARBONS

Compound Concentration (ppm)

Arsenic 0.16

Cadmium N/D

Chromium 0.03

Copper 0.10

[...]

Oy Veh! ... there's that "jargony math wall" I warned you about.

This time however I was able to "decipher the jargon" using some very incisive Q&A from an EPA FAQ page.

My explanations, as best I understand it (now), are shown in square brackets [ah hah!], in both the next, and previous blocks.



EPA Toxicity tests: FAQ

EPA Toxicity tests Question) What is a toxicity test? Answer) Toxicity tests are methods for determining the impact of a chemical or an effluent on living organisms and measure the degree of response using commonly tested species. Many different kinds of tests can be used to identify potential toxic effects but since toxic effects differ, comparing the toxicity of one to another may not be appropriate.

Question) There is toxicity test data available for the dispersants on the NCP Product Schedule (http://www.epa.gov/...) and it talks about LC50s. What is an LC50 ? Answer) In environmental studies, LC stands for "Lethal Concentration" and

is the concentration of the chemical, given all at once, in the water that causes the death of 50% of a group of test animals

in a given time (for example, during a 96-hour period). [ LC50 means "what it took" for 50% of the test species to die, when exposed to toxic level (in ppm), for the stated time.]

In general, the smaller the LC50 value [in ppm], the more toxic the chemical. The opposite is also true: the larger the LC50 value [in ppm], the lower the toxicity.

For example, a chemical with an LC50 of 2 parts per million (ppm)

would be more toxic than a chemical with an LC50 of 20 ppm. [Relative Toxicity: 2.0 ppm > 20.0 ppm -- 2 drops is more toxic than 20, if both cause the same "kill rate"]

The LC50 is the measure of the immediate (or acute) toxicity of a chemical for the particular animal species being tested. The LC50 was not designed nor intended to give information on the long-term exposure effects of a chemical.



Here are my Take-Away points:

A) Disperant + Fuel Oil (when combined) is much more Toxic than either alone.

B) Disperant + Fuel Oil (when combined) is about 3x more Toxic than EPA's Reference Level for Toxicity!

[Remember: the smaller the LC50 level, the MORE toxic {potent} the toxin.]



----------

Species LC50 (ppm)



COREXIT® EC9500A & No. 2 Fuel Oil (1:10) [Dispersant to Oil ratio]

Menidia beryllina 2.61 96-hr [about 3x MORE toxic than Reference]

Mysidopsis bahia 3.40 48-hr [about 3x MORE toxic than Reference]



Reference Toxicant (SDS) [This looks like the baseline for Toxicity]

Menidia beryllina 7.07 96-hr [Reference Toxicity level]

Mysidopsis bahia 9.82 48-hr [Reference Toxicity level]

----------



Show your work, my math teachers always said:

7.07 / 2.61 = 2.71 x more potent than reference level (about 3x)

9.82 / 3.40 = 2.89 x more potent than reference level (about 3x)



[Note to self: Find out what sort of Toxicity Reference (SDS) is.]



It's just like those Marine Biologists have been telling us -- Oil and Corexit COMBINED, is much worse, than either one alone. Smart Marine Biologists. They must of learn to read Toxicity Tests, back in their Lab classes. Most likely.







So the EPA runs Toxicity Tests using bacteria and phytoplankton, right, those hyper-sensitive canaries of the sea?



Well NOT Exactly ... these Toxicity "test critters" are a step or two beyond that ...

EPA Test Species Number 1:



Inland silverside (more photos)

Scientific name: Menidia beryllina

Common name: Inland silverside Ecology: Silversides occur in estuaries along the Atlantic, Gulf, and Pacific coasts. Uses in Aquatic Toxicology: Menidia beryllina are the current EPA-approved marine vertebrate used in both acute and chronic toxicity testing. In acute toxicity testing, one to 14 day-olds are used and survival is recorded. In chronic toxicity testing, seven to eleven-day olds are used and survival and growth are recorded. [...] Other Uses: Silversides have been used as a forage species for game fish and as a biological control for reducing gnat and midge populations. They are also often used as a bait fish.



EPA Test Species Number 2:



Mysid shrimp (more photos)

Scientific name: Americamysis bahia

Common name: Opossum shrimp, Mysid shrimp, Mysids Ecology: Mysids are small shrimp-like crustaceans found primarily in the Gulf of Mexico and the eastern coast of Florida. They commonly occur at salinities above 15-ppt and are found in greatest abundance at salinities near 30-ppt. Use in Aquatic Toxicology: Americamysis bahia is currently the primary estuarine species in toxicity testing. It is used in both acute and chronic tests. In acute testing, one to five day old Mysids are used and survival is recorded. In chronic toxicity tests, seven-day old Mysids are used to test survival, growth, and fecundity. [...] Other Uses: Used as a live food source for seahorses, seadragons, and pipefish.



Both of the "test" Species, sound like important "fish food" at the base of the Gulf Food Chain. Must be why they picked them, in the EPA's initial Toxicity Tests. Smart EPA Scientists.



And Smart US Representatives too. Seems this one knows how to listen to the Smart Scientists. Seems like he knows how to ask the right questions, when those Scientists get him up to speed:



Feedcry Archive -> NYT > Home Page [archive of the NYTimes story]

Napolitano Defends Government Response to Spill

In a letter to Lisa P. Jackson, the E.P.A. administrator, [Representative Edward J. Markey, Democrat of Massachusetts] said that some formulations of Corexit had been banned in Britain because of harmful effects on sea life. More than half a million gallons of the dispersants have already been used in the Gulf, and hundreds of thousands more gallons are being prepared for use. He asked E.P.A. to provide information on the effect of water temperature and pressure on the dispersant, a combination of solvents, surfactants and other compounds. He also requested detailed data on the subsea tests that led E.P.A. and the United States Coast Guard to approve its use a mile below the surface . He also asked for information on whether the chemicals accumulate in marine life over time and whether they could affect human health through gulf seafood.



----- Some pretty good questions from Rep Markey's Letter to the EPA Director, May 17, 2010, for instance:

1 ) d. Was the toxicity to other subsurface aquatic life evaluated? If so, please provide details, and if not, why not? 2 ) How is EPA tracking the volume of dispersants being used both in both surface and subsurface applications? How does EPA plan to determine whether their use causes harm to the aquatic ecosystem they come into contact with? 3 ) Is EPA fully aware of all chemical constituents contained within the two formulations of Corexit dispersants currently being used? If so, please provide a list of each such constituent. 4 ) Did EPA ensure that tests were conducted to evaluate the efficacy and toxicity of the 18 dispersants it has approved for use? What were the results of the tests?

Isn't it something -- what can happen when Representatives step up for the People's interests. And say Hey wait a minute, BUT ...



AND just 3 days later ... how's that for a coincidence?

Timeline of Events in BP Oil Spill: Day by Day, April 20 to May 26

BeforeItsNews.com

Day: May 20, 2010 The EPA also issued a directive requiring BP to identify and use a less toxic and more effective dispersant from the list of EPA-authorized dispersants. The directive required BP to identify a less toxic alternative – to be used both on the surface and under the water at the source of the oil leak – within 24 hours, and to begin using the less toxic dispersant within 72 hours of submitting the alternative.

That was probably easier for the EPA Director, than finding all that "other" paperwork Representative Markey, was after.

(Is this what they used to call, Congressional "Checks and Balances" over the Executive branch?)



What's that you say, Director Jackson?

BP really doesn't like to take orders from the U.S. Government Officials.

Well imagine that!

BP really doesn't have to answer to the "Checks and Balances" built into our 3 Branch system (that is, unless you start counting Lobbyists as the 4th branch of Government, or something?)



Well this is really turning into a bit of "a sticky wicket" now, isn't it Guvner?



Secret Formulas, Data Shortages Fuel Arguments Over Dispersants Used for Gulf Spill

By PAUL QUINLAN of Greenwire, NYTimes -- May 24, 2010

As the quantity of dispersant that BP has sprayed on the spill surpassed 800,000 gallons last weekend, experts say the secret formulas, combined with the sparse water-quality data released by U.S. EPA, make an independent assessment of the dispersant strategy next to impossible . Some scientists are calling for all dispersant use to be halted until the ingredients and effects are better understood. "The data is horrible," said Carys Mitchelmore, an environmental chemist and toxicologist at the University of Maryland's Center for Environmental Science. A co-author of a 2005 National Academy of Sciences report on dispersants, she has testified repeatedly on Capitol Hill over the gaping holes in the scientific knowledge regarding the chemicals.

[...]

The company responsible for containing the spill, BP PLC, continued to spar with EPA over the company's decision to rely on two types of Corexit -- proprietary dispersant formulas manufactured by Nalco Holding Co., which has close ties to both BP and Exxon Mobil Corp.

[...] On Saturday, BP rejected the order, citing an ingredient in a potential alternative formula, called Sea Brat #4, that could degrade into a nonylphenol, a class of chemicals believed to be disruptive to hormone systems. BP's letter and accompanying analysis, which included numerous redactions, also said the company was unable to identify ingredients in other proprietary oil dispersants, concluding that Corexit remained the safest and most abundant option available. "We're still using it because, as of today, it's still the best product available," said Doug Suttles, chief operating officer for BP, on CNN today. "It is on the approved list. It is safe to use. It is the most widely used."



AND 4 more days later ... and BP's still stone-walling?

you don't say!



And what's the final result of BP stalling and waffling? ... well that's NOT exactly CLEAR yet ... just who's zooming who.



And the Corexit(c) final results on the many Ecosystems of the Gulf, well only time will tell, and perhaps a few intrepid Reporters ... and some of those dogged Scientists too.

Swimming Through the Spill...

By Susan D. Shaw, NYTimes -- May 28, 2010

[...] What I witnessed was a surreal, sickening scene beyond anything I could have imagined. As the boat entered the slick, I had to cover my nose to block the fumes. There were patches of oil on the gulf’s surface. In some places, the oil has mixed with an orange-brown pudding-like material, some of the 700,000 gallons of a chemical dispersant called Corexit 9500 that BP has sprayed on the spreading oil.

[...] Only a few meters down, the nutrient-rich water became murky, but it was possible to make out tiny wisps of phytoplankton, zooplankton and shrimp enveloped in dark oily droplets. These are essential food sources for fish like the herring I could see feeding with gaping mouths on the oil and dispersant. Dispersants break up the oil into smaller pieces that then sink in the water, forming poisonous droplets — which fish can easily mistake for food. Though all dispersants are potentially dangerous when applied in such volumes, Corexit is particularly toxic. It contains petroleum solvents [oleophilic?] and a chemical that, when ingested, ruptures red blood cells and causes internal bleeding [Lethality?]. It is also bioaccumulative, meaning its concentration intensifies as it moves up the food chain . The timing for exposure to these chemicals could not be worse. Herring and other small fish hatch in the spring, and the larvae are especially vulnerable. As they die, disaster looms for the larger predator fish, as well as dolphins and whales.

Amazing isn't it, just how SO much trouble, can be caused by such a little fish (and tiny shrimp, and their aquatic cousins too) ...



And the Latest Tactical stance of BP with regards to the their "wonder product" that exists with such abundance?

BP reduces use of dispersants amid sea life concerns

By Matthew Tresauge, Houston Chronicle -- May 27, 2010, 7:49PM

BP has scaled back the use of chemical dispersants to combat the massive spill in the Gulf of Mexico amid concerns over the long-term effects on sea life, officials said Thursday. EPA Administrator Lisa Jackson told a House panel that the oil giant has reduced daily use of dispersants to 12,000 gallons from 70,000 gallons at the urging of the agency. BP, which is responsible for the cleanup, has used more than 850,000 gallons of dispersants in an attempt to break up the oil before it reaches Louisiana's fragile coast — a tactic that Jackson described as the lesser of two evils.

[...] [Erik Frywald, president and CEO of Nalco, Dispersant Manufacturer] said Corexit 9500 consists of six chemicals that are in everyday products, such as skin creams and shower cleaners, and should not be a risk to aquatic life, especially in the vast waters of the Gulf. BP, however, has used an unprecedented amount of the chemicals to combat the spill, raising concerns among some government officials and environmental groups. In a letter to BP last week, the EPA gave the company three days to find less toxic and more effective dispersant than Corexit 9500. Federal officials later acknowledged that alternatives are not available in sufficient quantities .



Well that's a NOT-so-fine ending, to a dreadfully Toxic problem ...



"BP rejected the order, citing an ingredient ... "

BP sez: 12,000 gallons of a day of poison 'Approved Surfactants', is MUCH BETTER than 70,000 gallons a day of the stuff.

"Federal officials later acknowledged that" ... BP has a point.



And that, is THAT!

(They'll just pour it out more s.l.o.w.l.y, BUT they WILL keep on pouring ... afterall, it's going to be a long, hot summer ... and who in the world can find a safer substitute, in sufficient quantities? ... sounds like a job for Super-Capitalist!)



And people wonder, Why I'm so snarky!



Here are a few more Dispersant Lessons the EPA should of learned, too, maybe?



When Life gives you an unstoppable Oil Gusher,

Don't mix it with something that makes it EVEN MORE Toxic,

to the ENVIRONMENTAL Food Chain,

that you're suppose to be PROTECTING!



Otherwise those pesky Congress Reps may start asking for some valid reasons,

[Hmmm?... Aren't those inquiries of Markey still on the Table, about now?]

and those pesky Bloggers might start doing their pesky research,

and may even manage to break through that "jargony math wall"

and figure out the sequence of events. Drats!



One other lesson, the EPA and Friends, might of learned:

That we just might need to create another 4th Branch of Govt,

one specially made for those BP-type "persons"

(a branch of Govt 'all to itself', like Dick Cheney wanted),

because sometimes CEO's and COO's

find it extremely difficult "to follow orders" --

without some sort of sufficient Penalties attached ...

except for maybe those 'Orders' of its Shareholders?

(or maybe those of its Customers, too?)

Who knew!



