From: Don Steck [mailto:donsteck@gmail.com] Sent: Tuesday, June 15, 2010 9:11 PM To: Mimi Snyder Cc: ccomerford@nrcc.

com; iocdo@nrcc.com; Probinson@resolvemarine.com; Billyji1@aol.com Subject: Re: USDA BioPreferred P.O.L. Sorb Peat Moss Products

Dear Sirs; My name is Don Steck, I work for USDA in DC as a hazardous waste program manager. Our main contractor, who cleans up our hazardous waste sites and oil spills nationwide, has for years been using a pure shagnum peat moss product to clean up oil spills on land and water. The product we use is called POLSORB http://www.arkent.com. This natural shagnum peat moss product is listed as a USDA Biopreferred material to clean up oil spills. It is also approved as a sorbent for use in cleaning up oil spills under the National Oil and Hazardous Substances Pollution Contingency Plan, more commonly called the National Contingency Plan or NCP (see EPA letter). We have sent this idea to everyone (ie. DOI, State Governments, BP, the Coast Guard, EPA etc.) and no one appears to be listening or feels that peat moss won't work because it is not hydrophobic (will not float on water) and not approved on the NCP. Ironically the product we use is approved by the NCP, as referenced above. The heat treated activated sphagnum peat moss product that USDA, uses at our oil spill sites, is hydrophobic and is the only peat moss product, of this nature, on the USDA biopreferred products list (P.O.L.Sorb http://www.arkent.com/). Attached please find a copy of the approval letter from EPA, dated 7/28/04, stating that this product meets the definition of 'sorbent' under the NCP guidelines. I am sure there are other companies out there that produce a similar product and has EPA approval under the NCP. There is no chemical treatment. The naturally occurring sphagnum peat moss is heat treated to less than 10% moisture and screened of debris thus rendering it hydrophobic. It can absorb about 8-10 lbs(>1 gallon) of oil per 1 lb of activated peat moss and still float on water. Once saturated with oil it is considered biodegradable. The cellular structure of the peat moss encapsulates the oil long enough for microbes to naturally break it down to innocuous byproducts (water, carbon dioxide and harmless hydrocarbons). While I can't advocate a product or a contractor I can say that this technique has worked effectively for USDA time and again on a smaller scale. One of our contractors, who lives on the Gulf coast, Ken Davis, has the logistics planned out to get this on the water within 48 hrs on a small or large scale. The peat would be sprayed through ship mounted mulch or spray insulation blowers. If sprayed in combination with the boom deployments it could turn the oil into a solid that would be much easier to skim off the water or if the booms wash ashore or fail, due to high swell, it could be raked up like seaweed. It can also be recycled as a fuel source or land farmed. Whatever was not picked up would not be harmful to the environment and would slowly biodegrade. Even if birds got in it the oil has more affinity to the peat moss then feathers. This is a proven technology, augmenting everything else, could significantly reduce the amount of environmental damage from this tragedy and help to mitigate the damage to beaches, fragile bayous and tidal marsh areas. It has worked successfully on large scale coastal oil spills in South Africa and Norway. If you have got proven tools in your tool box why not use them or at least try them instead of outright dismissing them because of some perceived bureaucratic hurdle that doesn't even really exist. I've also included some research links below. Thanks for any help you can give to get this idea on the water before it's too late. If nothing else just try it on a small scale and see how well it works in the Gulf. EPA already approved the dispersants that they just recently disapproved and this approach appears to be approved by EPA under the NCP. I have much more information on this and similar products and would be glad to provide them or assist you in any way you would find useful. V/R Don Steck Natural Resource Program Manager USDA Farm Service Agency Conservation and Environmental Program Division

Advantages of applying Processed Peat Moss as an absorbent media to surface water oil releases: As processed peat moss is applied to oil on surface waters, the petroleum is absorbed by the peat moss. When the oil/peat moss reaches the shorelines or marsh areas the oil is contained in the peat moss and can be handled as a solid which can be removed from the environment with less effort than a liquid. Reduced removal efforts will reduce impacts to the affected areas. Removal tools and materials from shoreline areas are common grass rakes, shovels, and trash bags. Transportation and disposal of the waste oil are also more easily managed in a solid as opposed to a liquid. Once absorbed by the peat moss, the oil is locked in and does not adhere to other surfaces such as sand or vegetation. The peat moss can also be utilized to absorb and solidify oil along the shorelines and marsh areas reducing the spread of oil and speeding cleanup efforts thereby alleviating impacts to areas. Oil absorbed by the peat moss which escapes capture and removal will have a lesser impact on the aquatic environment as it is degraded by natural occurring bacteria. The waste oil/peat moss could be disposed in a landfill permitted to accept petroleum waste or could be used as a supplemental fuel for industries such as paper mills. This procedure has been utilized in the past on crude oil cleanup projects with great success. In June 2000, the M/V Treasure sank off the coast of South Africa spilling 1300 tons of bunker oil. Processed peat moss was utilized in the shoreline cleanup which is home to the largest population of African Penguins. The products are available in the Federal Supply System (GSA and DOD). Peat moss oil absorbent products are a USDA BioPreferred Sorbent. MSDS on this product are available upon request. Application methods would be through blower equipment which is readily available and easily operated with minimal training. Blower application equipment can be vessel mounted or trailer mounted. PPE for application personnel are dust masks and goggles. I have located personnel, vessels, application equipment, and materials for utilizing this procedure on the Deep Water Horizon incident with a response of less than 48 hours. Ken Davis 850-380-2131