NCP

On September 29, 2021, the Environmental Protection Agency (EPA) announced the Greenworld Innovations submission for De-Oil-It to be included in the NCP list (National Contingency Plan) was accepted. CLICK THE LINK to download the letter sent by the EPA stating as such and by Q4 2021 we should be included on the updated EPA online managed NCP Product Schedule.

De-Oil-It Industrial Strength Concentrate (“ISC”) is the formula approved by the EPA for the NCP list under the category of “SURFACE WASHING AGENT”.

The break down of NCP list categories is as follows:

Bioremediation Agents
Biological Additives
Microbiological Cultures
Enzyme Additives
Nutrient Additives
Dispersants
Miscellaneous Oil Spill Control Agents
Solidifiers
Surface Collecting Agents
Surface Washing Agents
There are 4 main categories and 6 sub-categories

The two most prevalent categories are DISPERSANTS and SURFACE WASHING AGENTS

The bioremediation agents have a short shelf life and are usually ordered and then immediately applied to the oil spill clean-up efforts, typically in conjunction with dispersants and surface washing agents therefore described as “accelerants” to help break down oil faster and to promote biodegrading.

Dispersants are harsh chemicals that do quickly break down oil; however, history of large spills like the Gulf of Mexico BP Horizon Oil spill the selection of dispersant resulted in broken down oil reforming (which does not happen with De-Oil-It) and the indigenous bacteria in the water could not safely eat the decomposed oil resulting in digestive waste products more toxic than the original oil spill (De-Oil-It, on the other hand, detoxifies degraded oil allowing bacteria to safely consume the treated oil resulting in a more complete biodegrading process).

De-Oil-It is regarded as a DEGRADER versus a dispersant. Note that dispersants and degreasers are used interchangeably by many either rightly or incorrectly.

A degrader breaks down the hydrocarbon chain (up to 40 carbon levels) in a manner to decompose the oil into smaller simpler chemical compound structures. This is where dispersants, degreasers, and soap/detergent products stop.

De-Oil-It goes an extra step in the decomposition of oil by capping the ends of the smaller simpler chemical structures in nanotechnology referred to in all scientific journals/studies/papers as COLLODIAL MICELLE.

The degraded hydrocarbon chain into smaller simpler chemical elements is capped in a manner that these oil nano-sized droplets DO NOT REJOIN and are rendered LESS TOXIC than the decomposition of dispersants, degreasers, soaps, etc. The capping of degraded oil is a colloidal micelle because a positive charge (“anionic”) completely surrounds the nano-sized degraded oil droplet. This achieves prevention of oil droplets coming back together (so like a magnet like charges repel like charges) and accomplishes a strong affinity to join water molecules – therefore no residue and in the manner of the formation of the micelle bacteria can consume the contents safely.

De-Oil-It also optimizes the conditions suitable for BIODEGRADING which is ONLY PERFORMED BY BACTERIA. The optimal conditions in part are pH balance ranging in practice from 7.2 to 8.3 pH (slightly alkaline); in this pH, range bacteria perform biodegrading by eating the decomposed oil, and the bacteria waste products are soluble carbon, hydrogen, and oxygen. In this way, De-Oil-It has in practice shown to degrade oil in a manner that IN SITU (at the site of the oil spill) to have negligent to non-detect pollution (readings of hydrocarbon content PPM – parts per million).

This is why De-Oil-It is regarded as an environmentally responsible and much safer cleaner because the product leaves NO RESIDUE (oil or product chemicals) and with negligent to non-detect pollution transforms oil contamination to environmentally safe results.

On the NCP categories we originally choose dispersant, and then miscellaneous control agent, finally settling on Surface Washing Agent.

To be qualified as a dispersant the product must decompose a very thin layer of Prudhoe Bay and Louisiana Sweet Crude non-refined oil in 10 minutes. The success used to be changing the color of water below the thin meniscus layer from clear to brackish brown. The EPA labs (there are 8) measure the change of color from clear to 45% murky; however, new standards jump to 65% murky meaning most of the current dispersant if not grandfathered will not pass the test.

De-Oil-It on the other hand even in a super concentrated formula does not change the color of the water until 24-36 hours; therefore failing the dispersant qualification test. However, in 72-92 hours the color of the water changes from murky brackish brown to CLEAR.  De-Oil-It is degrading the oil to the lowest levels possible without bacteria finalizing decomposition via bioremediation (i.e. bacteria eating the remaining decomposed oil content).

We next submitted under the category of Miscellaneous Oil Spill Control Agents and were rejected because De-Oil-It forms an emulsified layer of treated oil on the surface of the water. In contrast, on land oil spills, De-Oil-It acts as a surfactant to drive the degraded oil into the soil to then be biodegraded by indigenous bacteria (some soil content requires added enzymes or introduced bacteria when the soil does not naturally support as much bacteria required to biodegrade).

The action the EPA wants to see for Dispersants is to sink decomposed oil into the water channel. The thought was as you get down to about 3 fathoms under water where currents would drive the oil droplets away from the spill and the water pressure and particulate matter in oceanic waters would further tear apart the oil droplet; however, as we witnessed in the Gulf of Mexico BP Horizon Oil Spill the dispersant used failed on two fronts. First, oil droplets rejoined others and the tides send oil clumps to the shoreline of Florida. Second, the bacteria that ate the applied dispersant produced toxic waste products from digestion that increased the contamination levels (the bacteria waste product was more toxic than the original oil spill). Of course, De-Oil-It would not have this environmental detrimental consequence (De-Oi-It does not sink oil, it prevents rejoining / reformation into larger compounds, and the degraded oil by De-Oil-It can be safely ingested by indigenous bacteria in the waterways).

The Miscellaneous Oil Control Agent was rejected by the EPA because of the emulsified treated oil produced by De-Oil-It. There are several oil spills outside of USA navigable waters that remediation companies surround the oil slick with De-Oil-It to stop the spread. They also broadcast sprayed De-Oil-It on top of the oil slick and in several days’ time reduced the size of the oil slick dramatically. Final clean-up by vacuum techniques was found to be much easier than conventional methods because De-Oil-It’s nanotechnology completely surrounds the degraded oil droplets, lowering the surface tension so that the collected oil-treated surface emulsified layers DID NOT STICK TO THE VACUUMING APPARATUS used. The EPA strongly prefers for dispersant technology to precede any accelerants (enzyme, bacteria) and control agents, and they are not quite embracing emulsified layers on water (with fuel such as diesel, gasoline, kerosene, racing, and aviation gas De-Oil-It completely breaks down fuels instantly and there are is no emulsification – remember this for Clean Marine product status because one of several line items required for this declaration is NO EMULSIFICATION OF FUELS; De-Oil-It complies with Clean Marine standards as we do not emulsify fuels, instead nauseous odors and flashpoint are IMMEDIATELY ELIMINATED – in this way De-Oil-It also acts as a natural fire retardant/fire extinguisher).

After several years of going back and forth with the EPA, we settled on Surface Washing Agent. Technically this is meant to be restricted oil clean-up mainly by cleaning SURFACES such as beaches, rocks, oil rigs, etc.

While it seems Surface Washing Agent is a limitation on NCP usage note the following. First, the NCP is mainly concerned with NAVIGABLE WATERS of THE UNITED STATES. Therefore many expressed concerns over the years about land, parking lots, industrial/commercial property including the inside of buildings, and government-owned lands/buildings requiring NCP list inclusion is not accurate; there are some Federal regulated and owned properties that do require NCP listed products but overall claims of not being allowed to use non-NCP products for general cleaning is simply not the case; however De-Oil-It is now on the list so that argument is closed. In any regard, De-Oil-It can be selected by the government for any task deemed necessary as per the wide guidelines of 40 CFR section 300.

Any kind of OIL SPILL that is REPORTABLE (generally 500 gallons or more, some government websites state 1000 gallons or more) is regulated by “40 CFR Part 300”.

Under this regulation, the FOSC (“Federal On-Scene Coordinator”) is permitted to SELECT ANY PRODUCT on the NCP LIST and OFF THE NCP LIST. Usually, a product not on the list requires an exception grant. Now that De-Oil-It is on the NCP list it is possible to be selected by the on scene investigators and coordinators which could be Federal, State, or first responders.

The real item of concern by the EPA is citizens and corporate employees trying to mitigate a spill on their own volition. That is a big no no. We encourage any significant spill to be reported and not taken on your own first responder efforts, the legality is not worth the bother. Having said this we are still in position of UNITED STATES COAST GUARD to allow De-Oil-It to be used for emergency on the scene deployment of remediation, and the coast guard allows De-Oil-It to be on maritime vessels recreational and industrial. We used to post this letter on our website but were ordered several years ago because the coast guard regarded posting their letter on our website as marketing and advertising when we were merely presenting the boundaries of “self-help” (immediate reaction to the emergency as it develops and then as you are calling fire departments, state, regional, and federal oil spill numbers that we post on our home page).

It’s been a long journey, we are grateful we have finally obtained inclusion into the NCP list.

Please note: EPA does not constitute product approval, certification, authorization, licensing or promotion of De-Oil-It; nor does the NCP / EPA endorse the product or imply compliance of any sort other than Greenworld Innovations simply adhered to the required EPA lab testing of the product concerning toxicity (LD50 test) and submission of ingredients and other kinds of lab tests. As these tests were reviewed under the category Surface Washing Agent, we SATISFIED requirements of Title 40 CFR section 300.915 of the NCP technical required elements.

We are thankful of the inclusion onto the NCP list. You can call us at any time to get more information as our in house expertise on these matters is well informed on all chemical, technical, legal, and application elements you might be curious to learn more.

ENJOY DE-OIL-IT, a truly superior cleaning product that goes the extra mile in environmental responsibility; we can turn your crisis into a safe non-threat to the ecosystem you are part of.