The Exxon Valdez Oil Spill
         A Report to the President
from
Samuel K. Skinner
Secretary, Department of Transportation
and
William K. Reilly
Administrator, Environmental Protection Agency
Prepared by

The National Response Team
May 1989

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                      CONTENTS
    EXECUTIVE SUMMARY

    I. INTRODUCTION AND BACKGROUND	    1

    II. THE INCIDENT 	    3

    III. PREPAREDNESS AND PREVENTION	    5
       Preparedness 	    5
         National Response System  	    5
         Contingency Plans	    6
         Contingency Plan Findings	    8
         Early Lessons Learned/          1?
           Recommendations:  Preparedness	   10
       Prevention	   10
    IV. THE RESPONSE  	   12
       Assessment And Initial Response  	   12
       Response	   12
         Strategy	   12
         Logistics 	   13
         Exxon Actions	   13
         OSC Actions And Activities In
           Support Of The OSC	   15
         State of Alaska Actions 	   16
         Clean-up Methods	   17
         Shoreline Cleanup  	   20
       Response Organization	   21
       Public Information	 .   22
       Early Lessons Learned/Recommendations ...   22
    V. THE EFFECTS  . 1	   24
       Environmental Effects  	   24
         Background	   24
         Effects On Birds And Marine Mammals  . .   27
         Effects On Fisheries and
           Other Marine Resources	   27
         Federal And State Action
           To Address Environmental Impact	   28
         Early Lessons Learned/Recommendations .   29
       Energy Effects	   29
         Importance Of Alaska North Slope Oil ...   29
         Market Impact Analysis	   29
         Early Lessons Learned/Recommendations .   30
       Effects On The Alaskan Economy	   31
         Commercial Fisheries	   31
         Recreation	   31
         Native Villages  	   32
         Timber  	   32
         Early Lessons Learned/Recommendations .   32
       Health Effects	   32
         Food Safety	   32
         Mental Health	   32
         Occupational Health And Safety	   33
         Early Lessons Learned/Recommendations .   33
    VI. LIABILITY AND COMPENSATION	   34
       Description Of Compensation And Liability
         Provisions	   34
       Early Lessons Learned/Recommendations ...   35
    VII. GENERAL LESSONS LEARNED/
       RECOMMENDATIONS  	   36
Contents-1

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APPENDICES
   A. Chronology  	   1
   B. Response Forces On Scene  	  20
   C. Glossary For Key Equipment On Scene ...  21
   D. Dispersants	  23
   E. State Of Alaska Dispersant Use
       Decision Matrix	  25
   F. National Response Team Members	  26
   G. Acronym Glossary  	  27
   H. Shoreline Impacts	  28
FIGURES
1.  Exxon Valdez   	   3
2.  Schematic Of Exxon Valdez
     Showing Damaged Tanks 	   4
3.  Prince William Sound	   4
4.  Total Number Of Vessels On Scene  	  13
5.  Air Freight Delivered By Exxon	  14
6.  Exxon Equipment On Scene	  14
7.  Exxon Personnel On Scene	  14
8.  Federal Equipment On Scene	  15
9.  Federal Personnel On Scene	  15
10. Zones Of Dispersant Use
     In Prince William Sound	  18
11. Number Of Skimmers On Scene	  20
12. Number Of Skimmers In Operation  	  20
13. Estimated Cumulative And Daily
     Volumes Of Oil Recovered	  20
14. Representation Of Oil Behavior
     In Prince William Sound	  24
15. Environmentally Sensitive Areas	  25
16. Leading Edge Of Oil Spill
     (through April 23)	  26
17. Alaskan Oil Pipeline Throughput	  30
                                        Contents-2

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                                  EXECUTIVE SUMMARY
   Shortly after midnight on March 24, 1989, the
987-foot tank vessel  Exxon Valdez struck Bligh
Reef in Prince William Sound,  Alaska.  What fol-
lowed was the largest  oil  spill in U.S. history. The
oil slick has spread over 3,000 square miles and onto
over 350 miles of beaches in Prince William Sound,
one of the most pristine and magnificent natural
areas in the country.  Experts still are assessing the
environmental and economic  implications of the
incident. The job of  cleaning up the spill is under
way, and although the initial response proceeded
slowly, major steps have  been taken.
    The very large spill  size, the remote location,
and the character of the oil all tested spill prepared-
ness and response  capabilities.   Government and
industry plans, individually and collectively, proved
to be wholly insufficient to control an oil spill  of
the magnitude of the Exxon  Valdez incident. Initial
industry efforts to get equipment on scene were
unreasonably  slow, and  once deployed the equip-
ment could not cope  with the spill. Moreover, the
various contingency  plans  did not refer  to each
other or establish  a  workable  response command
hierarchy. This resulted in confusion  and delayed
the cleanup.
    Prepared by the National Response Team, this
report was requested by the President and under-
taken  by Secretary of Transportation Samuel  K.
Skinner and Environmental  Protection  Agency
Administrator William K.  Reilly.  The report ad-
dresses the preparedness for, the response to, and
early lessons learned  from the  Exxon  Valdez inci-
dent.  The President  has also asked Secretary Skin-
 ner to coordinate the efforts of all federal agencies
 involved in the cleanup and Administrator Reilly to
 coordinate the long-term recovery of the affected
 areas of the Alaskan environment. These efforts  are
 ongoing.
     While it remains too early to draw final con-
 clusions about many  spill effects, the report addres-
 ses a number of important environmental, energy,
 economic, and health implications of the incident.
     The lack of necessary preparedness for oil spills
 in Prince William Sound and  the inadequate  re-
 sponse actions that resulted mandate improvements
 in the way  the  nation  plans for and reacts to oil
 spills of national significance.
     This report starts the  critical process of docu-
 menting these  lessons and recommending needed
 changes to restore public confidence and improve
our ability to plan for and respond to oil spills.  The
following points deserve special emphasis:
1. Prevention is the  first line of defense.  Avoid-
ance of accidents remains the best way to assure the
quality and health of our environment.  We must
continue to take steps to minimize the probability of
oil spills.
2. Preparedness must be strengthened. Exxon was
not prepared for a spill of this magnitude—nor were
Alyeska, the State of Alaska, or the federal govern-
ment.  It is clear that the planning for and response
to the Exxon  Valdez incident  was unequal to the
task.  Contingency planning in the  future needs  to
incorporate realistic worst-case scenarios  and  to
include adequate equipment and personnel to handle
major spills.  Adequate training in the techniques
and limitations of oil spill removal is critical to the
success of contingency planning.  Organizational
responsibilities must be clear, and personnel must be
knowledgeable about their roles. Realistic exercises
that fully test the  response system must be under-
taken regularly.  The National Response Team is
conducting a study of the adequacy of  oil  spill
contingency plans throughout the country under the
leadership of  the Coast Guard.
3. Response capabilities must be enhanced to reduce
environmental risk. Oil spills—even small ones—
are difficult to clean up. Oil recovery rates are low.
Both  public  and  private  research are  needed  to
 improve cleanup technology. Research should focus
on mechanical, chemical,  and biological means of
 combating oil spills. Decision-making processes  for
 determining  what  technology  to  use  should  be
 streamlined,  and  strategies  for the  protection  of
 natural  resources need to be rethought.
 4.  Some oil spills may be inevitable.  Oil is a vital
 resource that is inherently dangerous to  use and
 transport. We therefore must balance environmental
 risks  with  the nation's energy requirements. The
 nation  must  recognize that there  is no  fail-safe
 prevention,  preparedness,  or  response   system.
 Technology and human organization can reduce the
 chance  of accidents and mitigate their effects,  but
  may not stop them from happening. This awareness
  makes it imperative that we work harder to establish
  environmental safeguards that reduce  the risks
  associated  with oil production and transportation.
  The infrequency  of major oil spills in recent years
  contributed to the complacency that exacerbated the
  effect of the Exxon Valdez spill.
                                                 ES-1

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5. Legislation on liability  and  compensation  is
needed. The Exxon Valdez incident has highlighted
many problems associated with liability and com-
pensation when an oil spill occurs. Comprehensive
U.S. oil spill liability and compensation legislation
is necessary as soon as  possible to address these
concerns.
6. The United States should ratify the International
Maritime Organization  (IMO)  1984  Protocols.
Domestic legislation on compensation and liability
is needed to implement two IMO protocols related
to compensation  and liability.  The United States
should ratify the 1984 Protocols to the 1969 Civil
Liability  and the 1971  Fund Conventions.   Ex-
peditious ratification is essential to ensure interna-
tional agreement on responsibilities  associated with
oil spills around the  world.
7. Federal planning for oil spills must be improved.
The National Contingency Plan (NCP) has helped to
minimize environmental harm and  health impacts
from accidents.   The NCP should,  however, con-
tinue to be  reviewed and improved in order  to
ensure that it activates the most effective response
structure for releases or spills, particularly of great
magnitude.  Moreover, to assure expeditious and
well-coordinated  response actions, it is critical that
top officials—local, state, and federal—fully under-
stand and be prepared to implement the contingency
plans that are in place.
8. Studies of the long—term environmental and
health effects  must be  undertaken expeditiously
and carefully. Broad gauge and carefully structured
environmental recovery efforts, including damage
assessments, are critical to assure the eventual full
restoration  of  Prince William  Sound  and  other
affected areas.
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                        I. INTRODUCTION AND  BACKGROUND
   At 0004 on March 24, 1989, the 987-foot tank
vessel Exxon Valdez struck Bligh Reef in Prince
William Sound,  Alaska.   What  followed  was the
largest oil spill in U.S. history:  over ten million
gallons of crude oil flooded one of the nation's most
sensitive ecosystems in less than five hours. The oil
slick has scattered over 3,000 square miles  and onto
over 350 miles of shoreline in Prince William Sound
alone.  The initial response  was slow and insuffi-
cient. Major steps have now been taken to clean up
the spill, and these efforts will continue throughout
the summer.
   The  purpose of this report by the  National
Response Team (NRT) is to address preparedness
for,  the  response to, and the early lessons learned
from the Exxon Valdez oil spill.  It was requested
by the President and has been undertaken at  the
direction of Secretary of Transportation Samuel K.
Skinner  and Administrator of the Environmental
Protection   Agency William K.  Reilly.  The 14
agencies comprising  the NRT  worked  together
closely in  preparing this report.  Except where
otherwise stated, the report covers the period from
the incident through April 26.
    The report describes the status of preparedness
and response  actions taken in the month after the
 incident.   Preliminary  environmental,  energy,
economic,  and health effects of the  spill are dis-
 cussed.  Preliminary  recommendations for follow-
 up steps to prevent similar spills are identified. The
 report represents an important first step in examin-
 ing  the  spill and improving both preparedness and
 response capabilities  in  the  future through steps
 such as research and enhancement of liability and
 compensation provisions.
     Concurrently, other studies of the Exxon Valdez
 incident are  being undertaken, and other reports
 will follow.   The National Transportation Safety
 Board,  Coast Guard,  State of Alaska, and other
 authorities are looking into the spill.  This report
 complements these efforts.  Together, they will help
 to  provide a complete  picture  of the  oil spill's
 causes, its effects, and needed follow-up actions.
     In his statement of March 30,  the President
 described the Exxon Valdez oil spill as "an environ-
 mental tragedy."  The incident has both short-term
 and long-term implications.  Prince William Sound
 is a region rich in biological diversity, and the oil
 spill  has  caused ecological  harm.   The spill  has
 affected directly the livelihoods of many Alaskans.
 It also has impaired the beauty of a spectacular wild
area that has provided inspiration not only to those
persons who live and work along its shores, but also
to the growing numbers of people from the rest of
Alaska and elsewhere  who  enjoy its recreational
opportunities.  Alaska represents a last unspoiled
frontier in the eyes of many Americans.  That an
incident like this oil spill can cause such damage in
such a short time is a frightening realization.
    Another reality is the fact that both Alaska and
the rest of the United States depend on Alaskan oil.
Although the reduction in oil pipeline throughput
resulting  from  the  spill  was  of relatively  short
duration, the interruption  of Alaskan crude  oil
created serious  concern regarding future supply
curtailments. Americans consume about 700 million
gallons of oil daily.  Alaskan oil  helps to limit the
country's balance of trade deficit, and its steady
supply also  plays  a role in  protecting  national
security.  In addition, oil revenues account for over
80 percent of Alaska's state income.  The oil in-
dustry provides many Alaskans with jobs.
    The .Exxon  Valdez incident therefore dramatizes
the difficult decisions that must be made in balanc-
ing environmental protection and economic growth
in Alaska.  In  the words of former Governor  of
Alaska Jay S.  Hammond, "We are called upon at
once to be oil barrel for America and national park
 for the world."  On one hand, the Alaska National
 Interest  Lands  Conservation Act of  1980  demon-
 strates the priority given  to  preserving Alaska's
 natural  beauty by setting aside over 100 million
 acres as national conservation units.  On the other
 hand, the U.S. Government  has taken steps  to
 develop Alaska's vast energy reserves.  The Trans-
 Alaska  Pipeline Authorization  Act  provided the
 means by which oil could be transported to the Port
 of Valdez for shipment to the lower 48 states. The
 truth brought to bear by the Exxon Valdez incident
 is that accidents can occur that threaten the coexist-
 ence of conservation and energy interests.
     Actions  have been taken to decrease the proba-
 bility of such accidents, to prepare for them, and to
 mitigate their impacts if they occur. More, how-
 ever, can and  must be done.  The  many possible
  causes  of an  accident make  prevention difficult.
  These causes   include:  mechanical  or  structural
  failure,  human error, acts  of God,  inadequate or
  inappropriate design, and sabotage.

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    Once the Exxon Valdez spill occurred, a number
of circumstances combined to complicate the  re-
sponse action. That the spill took place in a remote
location complicated an expeditious and effective
response.  The sheer size of the spill, which was
larger than contingency planning had anticipated,
posed particular problems.  The magnitude  of  the
spill was beyond the physical capability of skimmers
and  booms  currently  being used  in the United
States. Moreover, the first equipment to control  the
spill arrived on scene over ten hours  after  the
incident after more than 10 million gallons of oil
already were in the water.
    A number of contingency plans were in place.
Alyeska had a contingency plan. National, regional,
and local plans mandated by federal regulation all
had  been developed.    These contingency plans
served as the basis for  response actions.
    In the absence  of realistic worst-case scenarios
and without adequate booms and barges on hand to
contain the spill, however, these plans had an unreal
quality and arguably served to reinforce a dangerous
complacency.
    It also is important to remember that the isolated
location minimized human health impacts.   With
respect to environmental impacts, nature's remark-
able resilience has  enabled eventual recovery from
large oil spills in other areas in the past.
    The next step is to evaluate the adequacy of
these contingency plans, both with respect to their
specific requirements and their implementation. In
the aftermath of the Exxon Valdez incident, ques-
tions have been raised  about contingency planning
requirements for oil  spills in  general  and  about
appropriate spill liability and compensation provi-
sions.   More  study of long-term  environmental
effects associated with persistence of oil in Prince
William Sound and its implications for the food
chain are needed.  Research and development to
improve response capabilities should be fostered.
This report begins the task of  investigating  these
and  other issues  raised by the Exxon  Valdez oil
spill.
    Alaska has been called upon to be both a source
of energy for  America and  a seemingly endless
frontier where  nature  is preserved.  The difficult
job ahead is to  maintain this delicate balance.

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                                     II. THE INCIDENT
   The American-registered motor tankship Exxon
Valdez departed  the Alyeska marine terminal in
Valdez, Alaska, on the evening of March 23, 1989.
The vessel was under the control of its captain, the
guidance of an Alaska state pilot, and monitored by
the U.S. Coast Guard Vessel Traffic Service (VTS).
The  VTS monitors  moving vessels by  radar  from
Valdez and Potato Point.  The ship was enroute to
Los  Angeles/Long Beach and  was loaded  with
53,094,510 gallons  of Prudhoe Bay (North Slope)
crude oil.
   The Exxon Valdez is a two-year-old tankship of
single skin, high-strength steel construction.   It is
987 feet long, 166 feet wide and 88 feet deep.  The
ship weighs  213,755 deadweight tons  and has 11
cargo tanks.  In lieu of double bottoms, the ship has
seven protectively-located segregated ballast  tanks
(see  Figure 2).
    At 2325, the  captain advised the VTS that the
pilot had departed. He further stated that the ship
probably would leave the outbound traffic lane and
cross the separation zone into the inbound lane in
order to avoid ice. The next call from the ship
stated that it  was reducing speed to 12 knots to wind
its way through some ice and  that the VTS would be
advised after the ice had been cleared.
    The  Exxon Valdez ran aground on Bligh  Reef,
Prince William Sound,  Alaska, four minutes after
midnight on Good Friday morning, March 24, 1989
(see Figure 3).  At the time  of the grounding, the
Exxon Valdez was loaded to a draft of 56 feet. The
 charted  depth  where the vessel  grounded was 30
 feet at low tide.  The severity of the grounding  is"
 attributed to the sound's rocky bottom, coupled with
 the vessel's momentum. Subsequent damage surveys
 showed  that eight of the 11 cargo tanks, extending
 the full  length of the vessel, were torn open.  Three
 salt-water ballast tanks also  were pierced. A total
 of 11 tanks  on the center and starboard side of the
 vessel were  damaged.
     The enormous damage caused a rapid loss  of
 cargo.  Within five hours, 10.1 million gallons had
 been spilled. About 80 percent of the ship's cargo
 remained on board, however, and the vessel came to
 rest in a very unstable position. The Exxon Valdez
 was in danger of capsizing if it floated off the reef.
 Both oil spill response and removal of the remaining
 oil  from the ship became top priorities.
FIGURE 1
Exxon Valdez
*•*?/ -/  ;;' '
Source: EPA, 1989.

    This report is not  intended  to  replace  any
investigations concerning the Exxon Valdez oil spill
currently being conducted under existing federal or
state statutes.  Certain aspects of  the incident
therefore  are the responsibility of the following
parties:
o The National Transportation Safety Board (NTSB)
    is conducting  a fact-finding investigation that
    can be expected to identify responsibility  for
    the Exxon Valdez oil spill, as well  as to make
    recommendations for avoiding such accidents in
    the future.  An NTSB report typically requires
    eight to 12 months to prepare.
 o The U.S. Coast Guard is investigating the role of
    the VTS and will address any circumstances that
    may have played a part in the spill.
 o The U.S. Coast Guard also is conducting a marine
     casualty   investigation  that  will  examine  any
     evidence  of wrongdoing on  the part  of  the
     captain, officers, or crew of the Exxon Valdez.
     This investigation will  determine if the Coast
     Guard will initiate suspension and revocation
     proceedings against the licenses or documents of
     personnel aboard the ship.
 o The Federal Bureau of Investigation is investigat-
     ing whether there  were criminal violations of
     the Clean Water Act and other applicable federal
     statutes.
 o The  Attorney General for  the State  of Alaska is
     investigating issues of  negligence and liability
     resulting from violations of state laws.
     Appendix A contains a chronology of events.

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FIGURE 2

Schematic of Exxon Valdez Showing Damaged Tanks
                           Starboard
                      Protectively located segregated salt water ballast tanks
                      Flooded (due to grounding)
FIGURE 3
Prince William Sound
                                 PRINCE WILLIAM SOUND

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                       III.  PREPAREDNESS AND PREVENTION
            A.  PREPAREDNESS
   When the tanker Exxon Valdez ran aground on
Bligh Reef, six  contingency plans were in place,
ranging from the National Contingency Plan (NCP)
to site-specific  plans for Prince William Sound.
They were designed to bring about an effective and
coordinated national, regional,  state, local,  and
industry oil spill response effort. The NCP and the
Alaska Regional Oil and  Hazardous Substances
Pollution  Contingency   Plan  (RCP)   established
federal responsibilities for response and identified
the Coast  Guard as On-Scene Coordinator (OSC).
The  Alaska State  Oil and Hazardous Substances
Pollution Contingency Plan outlined the state role.
    Initial  responses  were  identified  in  both the
local Coast Guard Marine Safety Office (MSO) plan
for the Port  of Valdez  and industry's  Alyeska
Contingency Plan  for Prince William  Sound.  The
Alyeska plan  guided the Exxon Valdez spill re-
sponse before the  Exxon Company took respons-
ibility on March 25 for the incident and put its own
plans into effect.
    Oil spill preparedness is a constantly evolving
process of incorporating  lessons  learned  from
simulated spills  and actual incidents.  Contingency
planning grows  from this continuing distillation of
experience, shaping new requirements for response
training, drills and exercises, equipment, and other
resources.

1. National Response System
    Composed of 14 federal agencies, the National
Response Team (NRT) has broad responsibilities for
the coordination of federal planning and prepared-
ness.  The  NRT provides  national  support for
response actions related to oil discharges and haz-
ardous substance releases.  Primarily through Re-
gional Response Teams (RRT),  the NRT supports
emergency responders  at  all levels  by  means of
technical expertise, equipment, and other resources.
 It also assists in the development of training, coor-
 dinates responses  with  neighboring countries, and
 manages the National Response  System (NRS).
     The umbrella NRS includes key elements of any
 federal response effort. Legally, the NRS functions
 under the NCP which,  in turn,  was created by the
 Clean Water Act (CWA).   The  Comprehensive
 Environmental   Response,  Compensation,  and
 Liability Act (CERCLA/Superfund)  also  is imple-
 mented  through the NCP.   Section  311(k) of the
CWA provides a fund for federal responses to oil
spills.
    Persons involved in  a spill or release of more
than a "reportable  quantity" of oil or  hazardous
substance (as defined by Superfund) are required by
law to notify the National Response Center (NRC)
in Washington, D.C. immediately.  Staffed by Coast
Guard personnel and funded by the Department of
Transportation  and the  Environmental  Protection
Agency (EPA), the NRC provides a central location
for reporting spills of oil and hazardous substances.
    When not convened for a specific incident, the
RRT is a standing body responsible for maintaining
up-to-date  regional planning  and preparedness.
The 13 standing RRTs  (one  for each  of the 10
federal regions, plus one each for the Pacific Basin,
Caribbean, and Alaska) under the NRT are essential
to effective  federal-state coordination  in  any oil
spill response.  Working closely with state govern-
ments and federal OSCs in its region,  the RRT
ensures that  appropriate federal agencies provide
assistance at spill  scenes when federal help is re-
quested.
    Typically, the "incident-specific" RRT consists
of selected federal agency and state  representatives
who have technical expertise or contacts needed by
the OSC for a  particular incident.  Depending on
OSC  needs, incident-specific  RRT members may
provide technical advice or actual resources such as
equipment or manpower needed on scene.  The
RRT also serves as an information conduit  for
federal agency field offices and state staffs. Each
RRT develops a Regional Contingency Plan (RCP)
to delineate clearly roles and responsibilities at all
levels of government during a response.
    An RRT will review OSC spill reports to iden-
tify problems in regional response capabilities and
help OSCs develop contingency plans for specific
 areas in its region.  Also, RRT  member agencies
 may provide training for contingency planners and
 conduct simulation exercises of regional  and OSC
 contingency plans to test federal response capabili-
 ties.
    A detailed  report  on the National Response
 System is provided in the NRT's 1988 annual report.

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2.  Contingency Plans
    The  following  section  describes contingency
plans identifying  the  responsibilities of response
personnel in the event of  an oil  spill  in  Prince
William Sound.

a.The Alyeska Plan
    The Alyeska Pipeline Service Company's oil spill
contingency plan  for  the pipeline, terminal and
Prince William Sound is an  industry plan required
under  state law.   The plan  incorporates federal
requirements applicable to the terminal  and pipe-
line.  For tankers, the plan includes "General Pro-
visions" covering Alyeska's oil spill response capa-
bility for terminal  and tanker operations, a more
detailed  "Port of  Valdez" section, and  a "Prince
William  Sound" section  which  addresses  tanker
operations from the  terminal  to Hinchenbrook
Entrance. The Alyeska plan incorporates a Prince
William Sound plan developed specifically for rapid
and  effective responses to  spills from  vessels  in
trade with Alyeska's Valdez Terminal.
    The plan states that Alyeska will "direct cleanup
operations of spills" from tankers carrying Trans-
Alaska Pipeline System (TAPS) oil through Prince
William Sound in such a way as to make  federal or
state  intervention  or  takeovers  unnecessary.   It
describes equipment and lays out procedures for oil
spill detection and assessment, emergency notifica-
tion and coordination, and control actions covering
cleanup, disposal, and restoration.
    The Alyeska plan gives priority to containment
and cleanup of oil spills to prevent or minimize the
amount of oil reaching sensitive areas.  The plan
lists 136  sensitive  areas  to  be protected in and
around Prince  William  Sound.  The Alyeska plan
addresses response actions, reconnaissance, exclusion
booming sites, response times (including a five-hour
objective for initial spill response), oil transfer
activities, spill trajectories, climate, oceanography,
and fish and wildlife resources.
    The plan covers scenarios for three spill sizes,
including an 8.4 million gallon spill in Prince Wil-
liam Sound remarkably similar  to  what actually
occurred on March 24. This scenario estimates that
approximately  50  percent  of the oil  would  be
recovered at sea either directly after the spill or at
a later time.   The Alyeska plan also  establishes
public relations guidance and sets forth  a training
program and an annual full-scale, company-wide
field exercise.
    Chain of command responsibilities in the Alyes-
ka plan generally parallel the NCP. The Alyeska Oil
Spill Coordinator (AOSC) heads the Oil Spill Task
Force responsible  for providing response and fol-
low-up activities  for all oil spills.  The terminal
superintendent heads  reconnaissance  and directs
response supervisors. The immediate response teams
'evaluate a spill and begin cleanup. If, at that stage,
the spill cannot be contained, additional resources
are requested from the AOSC, who can activate any
or all remaining task force resources.
    In addition  to other  response strategies,  the
Alyeska plan addresses use of dispersants, con-
forming with the  NCP restrictions.  The plan ac-
knowledges the need to receive approval from state
and federal governments before dispersants can be
applied to a  spill.  However,  the Alyeska  plan
concludes that, "it  would be difficult to effectively
apply dispersants..."  because of the need to bring
equipment in from  Arizona and because  of  the
approval process. Nevertheless, the plan emphasizes
the use of dispersants as an option for spill manage-
ment.

b. Captain of the Port (COTP) Prince William Sound
        Pollution Action Plan (OSC Plan)
    This plan implements provisions of the NCP and
the Alaska Regional  Oil and Hazardous Substances
Pollution  Contingency Plan (RCP).  It takes into
account the Alyeska  plan for Prince William Sound
and the Port  of Valdez.
    The plan provides  information on  port  area
geography, including a general description of Prince
William Sound and a more detailed discussion of the
Port of Valdez and Orca Inlet.  It provides a listing
and brief  description of waterfront facilities in the
Captain of the Port .(COTP) zone.  Procedures for
notifying  local, state, and  federal agencies, includ-
ing  the  Alaska  Department  of  Environmental
Conservation and other RRT members, are address-
ed. The plan discusses planned response actions for
oil spills in five areas of  the port:  Hinchinbrook
Entrance, Central Prince William  Sound,  Valdez
Arm and Narrows  to Middle Rock, Middle Rock to
Port Valdez, and  the remainder  of the sound.  A
COTP Valdez response organization with a descrip-
tion of duties for each billet  is provided, and proce-
dures  for gaining access  to  response   resources
(including special  forces)  are addressed.  A list of
federal, state, and local response resources extends
from the  NRT and Strike Teams to the  Homer
Harbor Master. The plan cites access to a computer
listing of  clean-up equipment in Alaska.

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c. National And Regional Contingency Plans
    Both the Alyeska and COTP Prince  William
Sound plans spell out a multitude of site-specific
response recommendations and directives.  They
operate in the context of  national  and  regional
response policies established  through the NCP and
RCP.  The principal task of the NRT  is to  coor-
dinate all  federal  oil spill  response actions and
policies.   Through federal  regulation, the  NCP
provides guidance  for the more site-specific RCP
and OSC contingency plans.
    The RCP  is the  region-specific plan  that es-
tablishes a regional  response team. It predesignates
federal OSCs and outlines all regional mechanisms
for coordinated response activities involving federal
and state personnel. The OSC monitors  the spiiler's
(the  responsible  party's) activities to terminate,
contain, and remove an  oil  discharge.  The OSC
manages a response action when the spiller  is un-
known or unable to provide a response.
    The RCP, revised in 1988, establishes a RRT
for the area that includes Prince  William Sound.
The plan outlines the regional response system that
establishes mechanical oil removal as a primary spill
response  strategy.   In one  of the first planning
efforts of its  kind, the RCP includes  chemical
dispersant preauthorization  procedures for  use  in
Prince William Sound.   Preauthorization by the
RRT, which is provided for in the NCP, is meant to
assist the  OSC in  making  timely  dispersant-use
decisions by providing him with authority to allow
dispersant use  in  specified areas without RRT
concurrence. Where preauthorization is  not granted,
the OSC  must first obtain the concurrence  of the
RRT.  The RCP also contains wildlife protection
guidelines for an oil spill.
    Like  most regional plans, the  RCP provides a
mechanism for coordination of state  and  federal
assistance after  a  spill  in support of  the  federal
OSC's basic  responsibility  to either  monitor the
 cleanup or conduct a response.  In either case, the
 OSC is provided technical assistance by the  special
 forces and teams listed in the RCP.  The RRT also
 furnishes equipment and other resources. When not
 convened for a specific incident, the RRT is a
 standing body responsible for maintaining  up-to-
 date regional planning and preparedness.
     The  RRT's  Fiscal Year (FY) 1989  work and
 training  plans establish  a priority listing of tasks
 designed to improve Alaskan regional preparedness.
 In  FY 1989, the  RRT had planned to prepare
 guidance to  help  local planners  effectively  use
 federal oil  spill  response  resources.   The RRT
completed planning guidelines for the rehabilitation
of oiled wildlife.

d. State of Alaska Contingency Plan
       And  Response Program
    The Alaska oil spill response program, in place
since 1977 to address rapid gas and oil development
in the state, is administered by the Alaska Depart-
ment of Environmental Conservation (ADEC). The
state response program serves a number of  func-
tions: review and approval of all oil spill contingen-
cy plans; maintenance of the state's Oil and Haz-
ardous  Substances  Pollution  Contingency  Plan;
inspection  of state oil  facilities;  prevention and
cleanup of underground spills; response and clean-
up or oversight  of  responsible party cleanup of oil
spills; and enforcement of many other authorities.
The ADEC  approves oil spill contingency plans for
over 450  tankers,  barges, onshore terminals,  and
offshore facilities.   The ADEC does not maintain
full-time oil spill response teams or large clean-up
equipment inventories.
    The plan lists the U.S. Coast  Guard as having
"basic investigative and enforcement responsibilities
for oil spills that occur on coastal  waters bordering
Alaska." It  adds that the U.S. Coast Guard Captain
of the Port of Valdez  "is the federal OSC for the
coastal waters of Prince William Sound from Cape
Puget to Castle Island near  Cordova."   The plan
establishes ADEC as the lead state agency respons-
ible for oil  spill emergencies within Alaska and its
coastal waters.
    Under  the  state plan,  responses to moderate
(1,000 to 100,000 gallons in coastal waters) or large
(over  100,000  gallons) oil  spills  fall  under  the
province of the U.S. Coast Guard or Environmental
Protection  Agency OSC.  In these cases,  the state
OSC will  act  as an  advisor  to  the  federal OSC
 regarding such state issues  as availability of state
 and local resources, assignment of priority areas for
 cleanup and protection, response  equipment and
 manpower  staging areas, potential disposal areas,
 threats to humans and wildlife habitats, adequacy of
 cleanup, activation of the RRT, and activation of a
 state-funded response.

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    In response to a large spill, the state QSC func-
tions as the state representative to the RRT. In this
situation,  response jurisdiction is assumed by the
federal government once the federal OSC arrives on
scene. The state then provides the federal OSC with
appropriate assistance. Specifically, Annex XVII to
the state plan gives ADEC authority to respond to
catastrophic oil discharges which constitute a dis-
aster  emergency under Alaska Statute 26.23.010-
230. Under Alaska Statute 46/04.010, ADEC also is
authorized to seek reimbursement of clean-up or
containment  expenses.   Spillers  are  responsible
under state law to  contain and clean up any  oil
discharge  except in cases where  containment and
cleanup is not technically feasible or will cause more
damage than the spill  itself.
    Other  state agencies also share oil spill  response
responsibilities.  For example, the Alaska Depart-
ment of Fish and Wildlife provides for protection of
fish, game, and aquatic plant resources. Other state
and local  agencies regulate operations that affect
health and safety.

e. The Exxon Plan
    The Exxon Shipping  Company Headquarters
Casualty Response Plan, a voluntary document not
required by^federal law or regulation, establishes a
company Casualty Management Team and a Head-
quarters Oil Spill Assistance Team.  The plan made
available by Exxon for purposes of developing this
report defines the organization and responsibilities
of each team during a marine incident, but it is not
specific to any location.  The Exxon plan has no
specific details.  It includes no explanation of any
interaction with the NCP, RCP, Alyeska, state or
Coast Guard plans.  The  Exxon  plan  contains no
information specific to the Prince William Sound or
Valdez Terminal and  no equipment list other than
mention of  a van and sampling equipment.  The
plan also does not prescribe uses of booms, skim-
mers,  and dispersants.  The Exxon Plan required no
approval by federal or state government.

3. Contingency Plan Findings
Contingency planning coordination:
o Government and industry plans, except the Aly-
    eska plan, did not assume a spill of the mag-
    nitude of the Exxon Valdez spill and the Alyes-
    ka Plan did not provide sufficient detail to guide
    the response.  The Alyeska plan, approved by
    the state, was the  primary plan for purposes of
    direct  spill  cleanup  involving  oil from the
    Trans-Alaska Pipeline  in the  Valdez  Ter-
    minal/Prince William  Sound area.  The Exxon
    plan states that the Exxon Shipping Company is
    responsible   for  containment,  cleanup,  and
    claims settlements related to spills in the waters
  .  of the U.S. from Exxon vessels. These plans do
    not refer to each other or establish a response
  ,  command hierarchy that would take precedence
    in the event  of  a  spill  either at  the  Valdez
    Terminal or in Prince William Sound.
 Responsibility for response:
' o For the Port'of Valdez, all of these plans assumed
    that the  spiller will be the responder initially.
    The plans assumed that the supporting OSC,
    state, and RRT would evaluate response actions,
    providing approvals when necessary unless the
    spiller cannot be found.  There appears to have
    been  insufficient planning, however, to assure
    that either the responsible party would be able
   .to respond effectively or, if necessary, gov.ern-
 , ,  .ment parties could respond  to a spill of this
    magnitude.
 Exercises:
 o Although several exercises required by the Aly-
    eska plan already have been conducted, Alyeska
    did not utilize critiques of these exercises ade-
    quately.   A  critique advanced by the State of
    Alaska had recommended revisions  to the plan.
   .One critique had pointed out that the Alyeska
    on-scene coordinator is needed at the spill  site
    to direct  and supervise clean-up operations, and
    to interact with on-scene government  agency
.  ,  personnel.  The Alyeska on-scene  coordinator
    did not go with the Coast Guard to  the site.
 Training:
 o Because planners could not anticipate the man-
    power needed to respond to a very large, very
    widespread  spill; there was a lack of personnel
    skilled in oil spill response techniques. Valuable
    time was used to train inexperienced workers.
    In addition,  some response personnel and gover-
    nment representatives did not fully  understand
    the NRT/RRT structure and how it  works,
    reducing the effectiveness of available on-scene
    organizations and resources through unrelated or
    overlapping efforts and management chains.
 Spills of national significance:
 o The National Oil andHazardous Substances Pollu-
    tion Contingency Plan (40 CFR 300) is adequate
    for handling almost all oil spills. It should be
    reviewed and amended, as needed, however, to
    ensure that  it activates the  most effective re-
    sponse structure for releases or spills of national
    significance.

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COTP (OSC) plan:
o The COTP Prince William Sound Plan considers
   the Alyeska plan but not the Exxon plan.  Lack
   of coordination between the Alyeska and Exxon
   plans  appears to have caused  confusion in
   structuring  the response to the Exxon Valdez
   incident. For example, the State of Alaska was
   not notified by Alyeska as required when Exxon
   assumed responsibility for the spill response. In
   addition, there was no provision for review by
   the federal  OSC, who establishes priorities for
   response actions.  Therefore, coordination was
   further limited.  As it turned out, the Alyeska
   plan was used for- immediate response and the
   COTP Prince William Sound plan served as a
   basis for guiding the actions of the OSC.
Alyeska contingency plan:
o Alyeska did  not carry out the objectives  of its
   plan to direct the spill response in a manner that
   ensured a rapid response and the availability of
   adequate and usable  equipment.  Nor  did it
   provide the State of Alaska with timely infor-
    mation  on  when  Alyeska had turned over its
    responsibility to  Exxon.   Alyeska  was not
    prepared to respond to this spill.
Equipment:
o Equipment adequate to contain and clean up the
    spilled oil was  not available during  the  initial
    days of the incident.  This is because  of the
    magnitude of the spill, the fact that the oil barge
    was not certified to receive oil and was dam-
    aged, and because equipment  that would have
    been useful was not in the inventory.  A large
    self-contained  oil skimmer would have been
    useful during the spill response, notwithstanding
    the magnitude of the event.
 Response strategies:
 o All  the  basic  contingency plans—the Alyeska,
    Exxon, Prince William Sound, Alaska RRT and
    state—appear to agree that the principal re-
    sponse  strategy  is physical containment and
    removal,  along  with diversion  booming  to
    protect sensitive ecosystems.  They agree that
    other such response strategies as chemical dis-
    persion and in-situ burning will be employed to
    supplement this strategy.
o Except for the Alaska  RRT  plan, criteria for
    requesting employment of additional technol-
    ogies are absent from these plans. The Alaska
    RRT plan contains specific  criteria and a de-
    tailed checklist containing evaluation factors for
    determining whether  to  approve the  use of
    dispersants. No similar criteria, however, have
    been developed  for in-situ burning.  Early use
    of dispersants in most major oil spills in coastal
    waters is a controversial OSC.and RRT decision.
o Dispersant-use  decisions, can be critical to re-
    sponses. Detailed and thoughtful dispersant-use
    preplanning can greatly improve the technical
    quality of such decisions.
Response implementation:
o Although the basic response strategy  is outlined
    clearly in the Alyeska plan, guidance  to  help
    responders  implement this strategy was inade-
    quate in the Exxon Valdez spill. For example,
    the plan identifies sensitive habitats in detail
    and ranks them  in order of response priority. It
    even calculates the amount of diversion booming
    needed to protect these habitats.  The Alyeska
    plan does not provide clear guidelines, however,
    on the manpower or equipment needed to de-
    ploy this booming or the time it would take. As
    a  result, the amount of equipment actually
    stockpiled at the Valdez Terminal and elsewhere
    in the  state was not known before the response
    was undertaken. Several  of the plans also men-
    tion the difficulty of planning for, and respond-
    ing to, spills in remote areas, but they do not
    identify specific measures to address this prob-
    lem.
 o It  appears that the Alaska  RRT  and State of
    Alaska plans  did  not  adequately consider
    equipment, manpower, and the logistical prob-
    lems associated with such a large spill.

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4.  Early Lessons Learned/
       Recommendations:  Preparedness
Contingency planning:
o Planning for a large self-contained oil skimmer
    and other necessary response equipment was
    inadequate.
o The National Oil and Hazardous Substances Pollu-
    tion Contingency Plan (40 CFR 300) should be
    reviewed and amended as needed, to ensure that
    it activates the most effective response structure
    for releases or spills of national  significance.
    Such releases or spills should be defined, thres-
    hold criteria should be formulated to establish
    when  this  condition exists,  and a  pre-es-
    tablished,  integrated  command  and  control
    mechanism should be identified to address them.
    This mechanism is necessary in order to utilize
    effectively the resources of the parties respons-
    ible for the spill, the 14  federal agencies in the
    NRT/RRT structure, and the affected state or
    states and local governments.
0 The  federal  government should  consider the
    extent to which contingency planning should be
    implemented under the CWA and other appro-
    priate  authorities in major port areas.  Title 33
    of the  Federal Code, that addresses oil pollution
    prevention regulations for marine oil transfer
    facilities, provides  a starting point  for  this
    effort.  At this time, there is no specific re-
    quirement for the operators of major oil  ter-
    minal  facilities to  develop oil spill contingency
    plans.  The EPA and the Coast Guard do require
    spill prevention plans. That Alyeska is required
    by the State of Alaska to have such  a plan is
    atypical.  Many other states leave contingency
    planning to industry on a voluntary basis.
o The Exxon Valdez spill and analyses of the con-
    tingency plans for Prince William Sound  raise
    concerns about  the adequacy of contingency
    planning in other major port areas. The Presi-
    dent has ordered a nationwide review of contin-
    gency  planning in major ports to be completed
    within six months.  The review will  be  con-
    ducted by the National  Response Team.   The
    Vice Chair of the NRT, the Coast Guard repre-
    sentative to the NRT,  will direct the  review.
    With support from the other 13 federal agencies
    represented on the NRT, the Coast Guard will
    be the lead agency conducting the study.   Re-
    gional  Response Teams and  Coast Guard COTP
    will assist in review of port plans. Key issues
    will include ensuring that plans in other  port
    areas address maximum probable spill assump-
    tions and  associated  levels of manpower  and
    equipment. Another issue is the reinstatement
    of the spills inventory system, which identified
    the  location of oil spill response equipment
    world-wide.
Training:
o Training programs in oil spill clean-up techniques
    and responsibilities of agencies under the NCP
    should be reviewed and expanded to include all
    persons who would be relied on for response to
    a major oil spill. Adequate training, both in the
    techniques and limitations of oil spill  removal
    and in the roles  and  responsibilities  of  the
    various  response  and  support  organizations
    under the NRT/RRT structure, is critical to the
    success of industry and government contingency
    plans.  In a spill  of national or  region-wide
    significance,  persons and  organizations  not
    normally involved in oil spill  response may be
    required to function in  key roles.
o There should be adequately trained personnel on
    hand in the event of a spill.
Exercises:
o Contingency plans are important.   It is equally
    important to test the plans in a realistic manner
    to ensure  an  effective  response.   Computer-
    aided table-top exercises and field exercises  that
    put  stress  on the response system should be
    expanded  by  the  National Oceanic  and  At-
    mospheric Administration, EPA, and the Coast
    Guard. RRTs should ensure as a part of their
    planning process that contingency plans  are in
    place for areas  in which major oil spills rea-
    sonably can be  expected.   In addition,  unan-
    nounced drills should be conducted to ensure
    that plans and organizations can deliver respons-
    es as planned. RRTs need to ensure that train-
    ing is current, that realistic evaluations of drills
    are  conducted,  and  that formal  revisions of
    plans are required based on the results of exer-
    cises.

              B.  PREVENTION

    Prevention is  the principal  defense against oil
spills. The old adage that an ounce of prevention is
worth a pound of cure remains  valid:  the best  way
to protect the environment is to prevent spills from
occurring in the first place.  This truth is vividly
evident in the enormous costs of the Exxon Valdez
oil spill.
                                                10

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    Although both government and industry have
critical roles to play, prevention of oil spills cannot
be accomplished  without industry  action to safe-
guard oil transport.  Industry immediately should
review all  elements  of the oil transportation and
distribution system  for  vulnerabilities that could
lead to serious oil spills.  It is industry's respons-
ibility to ensure that facilities and equipment are
properly designed,  safely operated, and correctly
maintained.
    Industry already  has taken steps in an attempt to
reduce the risks of  oil spills.  The American Pe-
troleum Institute has undertaken a review of in-
dustry operations and will report a recommended
program in three months. The review will examine
manning of  ships,  as  well  as preparedness and
response issues. The major owner companies of the
Alyeska  Pipeline  also  have announced plans  to
improve the industry's ability to prevent oil spills in
Alaskan waters.
                                  Subject
    Human error is a major factor in many types of
accidents. Any comprehensive prevention program
must address human error through better training
and equipping of  personnel, safety programs, and
steps to ensure that constant vigilance is exercised
by management.  For example, legislation, regula-
tion, and studies under consideration address ways
to prevent drug and substance abuse in the work-
place. Prevention of such abuse is especially impor-
tant for vital transportation services.
    Government also must take steps to help prevent
oil spills.  Federal and state agencies currently are
conducting investigations to address the cause of the
accident. These investigations will examine whether
navigation controls were adequate.  They will look
into licensing of the captain and crew and issues of
negligence, liability, and criminal violation. Results
from  these  investigations  can have  an  important
impact on preventing future oil spills.
    Prevention is  a complex  area, and  actions to
address concerns  about  prevention will require
examination in the  near  future of key issues  by
appropriate authorities. Several areas for follow-up
action appropriate  by federal, state,  and  local
agencies and by  industry deserve special mention
here-  Following  is an initial list of the prevention
areas that should be considered and the agencies re-
sponsible for addressing them:

            Party  Responsible
              Ship design and construction (e.g., double hulls,
              smaller tankers)

              Manning of ships (e.g., licensing of officers and
              crew, alcohol/drug testing)

              Ship movement (e.g., piloting, vessel traffic con-
              trol, speed limitations, navigational hazard mark-
              ing)

              Spill prevention plans and operations manuals
              (terminals and transfer facilities, on-board re-
              sponse capabilities)

              Training of government workers in prevention
              responsibilities

              Safety programs and training for operators
              (management oversight)
            USCG, industry


            USCG, industry


            USCG, industry
            EPA and USCG,
            state/local agencies,
            industry

            Federal/state/local
            agencies

            Industry
                                                  11

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                                    IV.  THE RESPONSE
A.  ASSESSMENT AND INITIAL RESPONSE
    Upon notification by the Exxon Valdez to the
Vessel Traffic Service (VTS) of the incident at 0028,
the Commanding  Officer, Marine Safety Office
(MSO) Valdez, in his capacity as the predesignated
federal On-Scene Coordinator (OSC), immediately
closed the Port of Valdez to  all  traffic. The OSC
notified the National Response Center (NRC), the
state, and Alyeska of the spill. By 0100, a pilot boat
with  a  Coast Guard  investigator  and  an  Alaska
Department of Environmental Conservation (ADEC)
representative aboard was enroute to the vessel.
    At 0330, the Coast Guard investigator reported
that approximately 5.8 million gallons  of oil  had
been  lost from the damaged tanks.  By 0530, an
estimated 10.1 million  gallons  of  crude oil  had
spilled into Prince William Sound.
    Alyeska accepted responsibility  for the cleanup
and activated  its  emergency  operations  center
45 minutes after receiving word of the spill.  A
second operations  center in Anchorage  was estab-
lished 15 minutes later.   By 0500,  70 people had
been  called,  and 28 people  were  working at the
terminal.
    By 0730, Alyeska had a helicopter aloft with a
Coast Guard investigator aboard.  Videotape record-
ed during this overflight showed a slick 1,000 feet
wide by about four miles long.

                B. RESPONSE

1. Strategy
    Several goals were developed by the  responsible
party and the OSC in structuring the response.  Of
primary importance were steps to prevent the spill
of additional oil. The Exxon Valdez was unstable.
Genuine concern was expressed that the vessel could
capsize and spill the 43  million gallons of oil re-
maining on board (80 percent of the total load) into
the water.
    Environmentally sensitive areas needed protec-
tion.   The National Oceanic  and  Atmospheric
Administration (NOAA) had identified these areas
prior to the incident.  This information was used to
set priorities for sensitive areas, such as fish hatch-
eries.   Four  fish hatcheries  were singled out  as
priorities, and equipment was deployed to protect
them.  The OSC  faced  the  decision  to  use  the
limited available booms and  skimmers  to protect
other sensitive areas or to contain the oil, because
not enough equipment was on hand to do both tasks.
    Personnel safety  was. another major concern.
Flammable, toxic  fumes  made  response actions
dangerous. To address this danger, Exxon establish-
ed  a nine-member health and  safety  task force,
developed a safety plan, and trained all personnel on
scene.  No one was seriously injured  in this case.
Finally, strategies were developed for the contain-
ment and recovery of the 10.1 million gallons of oil
that had entered the environment.
    The response began on several fronts.  The OSC
mobilized the National Strike Force to assist with
controlling the release of additional  oil  from  the
Exxon Valdez.   Personnel  from the  MSO were
recalled and the pre-arranged  response organization
put in place.  Exxon activated its emergency center
in Houston and mobilized equipment to stabilize the
stranded  vessel.   The  Exxon  Baton  Rouge was
directed to the scene to offload the remaining cargo.
Within 24  hours  of  the incident, the oil on  the
Exxon Valdez was being pumped off.
    Major problems began to arise, however, within
three hours of  the  incident.   Alyeska response
equipment shortages  and casualties  delayed any
opportunity to contain the spilled oil  early on.  A
barge specified by Alyeska in its contingency plan
to provide containment equipment at the scene of
an  oil  spill within five hours of notification had
been stripped of its equipment for repairs.  Reload-
ing the  barge was time  consuming  and further
delayed when the cranes loading the equipment on
the barge were redirected by Alyeska to load trans-
fer equipment aboard a tug.  The barge left for the
vessel ten hours after the spill and arrived on scene
two hours later.,
                                                •12

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2. Logistics
    The spill occurred in a remote location of the
country, and,  as the oil spread, it moved to even
more difficult and remote areas.  The town closest
to the spill site  is Valdez,  which has  less than
4,000 residents. The small airstrip in Valdez norm-
ally handles about 10  flights a day, but this  figure
jumped to between 750 and 1000 flights  a day
during the spill response.  The  Federal Aviation
Administration set up and manned a temporary air
traffic control tower to manage this  increase in
traffic.  The largest plane Valdez can accommodate
is a C-130 with  load  restrictions.  Larger planes
carrying clean-up equipment were forced to fly into
Anchorage.  The drive from Anchorage can take up
to nine hours by,truck, and the roads sometimes are
closed due to bad weather and avalanches. The only
other town close to the oil spill is Cordova,  which
can be reached only by boat or plane. Its only ferry
has been used  as part  of the response action.
    Valdez has limited accommodations and  could
not handle the number of spill response personnel,
government officials,  and reporters who descended
on the  town  in  the  spill's  wake.  Because of a
limited phone system, during the first week after
the spill several thousand calls into or out of Valdez
were not connected.   This  lack of  phone lines
initially delayed  responders  from  requesting the
resources they needed to handle the spill. Only the
Coast Guard OSC had a direct line out of Valdez.
The phone problem was alleviated somewhat during
the second week when the phone company increased
the number of lines into town.
    Even when equipment and clean-up personnel
arrived in Valdez, the spill site still was  two hours
distant by boat. By April 13, the oil covered 1,000
square  miles  and  reached  80 to  90  miles from
Valdez.  It took eight to  10 hours  by boat,  at
 10 knots, to go from one end of the spill  to the
other.  It took 14 hours to tow a skimmer 35 miles
across the width of Prince William Sound. It was an
hour flight by helicopter to reach affected beaches.
Staging had to be done on scene  from  mobile plat-
 forms,  requiring  that equipment  be air-dropped or
delivered by boat.  All of these factors exacerbated
 the slow delivery of clean-up equipment.
     Radio transmissions cannot travel great distances
 without repeaters in mountainous terrain. The large
 number of boats involved in clean-up activity (see
 Figure 4) resulted in multiple, simultaneous trans-
 missions  and  led to many radio channel violations.
 This problem was eliminated when the Coast Guard
 cutter Rush arrived on scene and began enforcing
 proper radio procedures.
FIGURE 4
Total  Number of Vessels On Scene
 200-
 250
 200
 150
 100
  50
    24 25 26 27 28 29 30 31 1 2 3 4 5 6  7 8  9 10 11 12 13
              March                  April
 Source: U.S. Coast Guard, 1989.

3. Exxon Actions
    Exxon Shipping Company assumed financial and
clean-up responsibility from Alyeska on the second
day after the spill;  part of  the  normal response
process and not unanticipated.  Exxon designed a
plan to transfer the remaining 43 million gallons of
oil and salvage the vessel with the assistance of the
National Strike  Team.  The oil was removed  by
April  4 without  further  damage to  the vessel,
additional  spillage, or injuries.   The  vessel  was
refloated and towed to a sheltered harbor for dam-
age assessment and temporary repairs the next day.
    Exxon also initiated a communications network.
Exxon built a remote transmitter by day four of the
spill, and on day six sent a communications trailer
out on a boat. Eventually,  a complete communica-
tions network was established.  It consisted of four
 repeater stations: one on a mountain, one on Knight
 Island, and two on vessels.
    The weather changes quickly and  varies from
one part of the sound to another. Clean-up person-
nel had to be placed on and removed from steep
rocky shores which experience  10- to  12-foot tide
changes twice a day.  Bad  weather grounded heli-
copters used to transport these personnel.  Vessels
needed warning to move equipment to safe harbors
during rough seas.  The Bureau of Land Manage-
ment  had portable  weather stations  for remote
locations  that  could  relay  weather  information
through a satellite link. Because weather forecast-
 ing was critical to the response operation, Exxon
worked with NOAA to set  up five weather stations
around Prince William Sound.
                                                 13

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    Fuel required for transit from Valdez to clean-
up sites left helicopters with only about 25 minutes'
worth of fuel to remain on scene.  Exxon set up a
refueling station in Seward  to  increase on-scene
time for helicopters.  Questions were raised con-
cerning the spill's effect on  water quality and  on
the fishing industry.  Exxon developed a  water
sampling plan and selected 25 sites to monitor on a
regular basis.
    The Exxon emergency center in Houston opened
shortly after receiving word of the incident.  By the
end of the fourth day after the spill, a total  of
274 tons  of  booms,  skimmers,  dispersant, and
dispersant application equipment had arrived. This
equipment  was flown in from around the world (see
Figure 5).
    Exxon also mobilized a fleet of vessels.  By the
second day after the spill, Exxon had contracted for
52 vessels.   This steady build up continued until
April 13  when the number of vessels hired leveled
off at about 110. As of April 13, Exxon had 248-
 vessels contracted (see Figure 6). Eighteen contract
aircraft were on site by April  13.   By April 13,
aircraft had delivered 1,767 tons of equipment, and
twenty-five aircraft were contracted for use on site.
As of April 10, the response staff totaled 1,470 and
included 130 Exxon employees,  962 contract per-
sonnel, and 378  fishermen  (see Figure 7).


FIGURE 5

Air Freight Delivered by Exxon
Tons
r2000	
FIGURE 6
Exxon Equipment On Scene
 250-
             • — Vessels

             "• Thousands of boom feet
 200
 150
 100
  50
    24 25 26 27 28 29 30 31  1  2  3  4 5 6 7 8  9 10 11 12
             March                  April
Source: U.S. Coast Guard, 1989.
FIGURE 7
Exxon Personnel On Scene
                                                        24 25 26 27 28 29 30 31 1 2  3  4  5  6 7 8 9 10 11 12
                                                                March                  April
                                                    Source: U.S. Coast Guard, 1989.
    24 25 26 27 28 29 30 31  1  2 3 4 5  6  7  8  9 10 11 12
             March                  April
Source: U.S. Coast Guard, 1989.
                                                  14

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4.  OSC Actions And Activities
       In Support Of The OSC
    Within 24 hours  of the spill,  the Coast Guard
had supplemented the 34 personnel assigned to MSO
Valdez. Four members of the Coast Guard's Pacific
Area  Strike Team  (PACAREA)  of the National
Strike Force arrived on scene from  San Francisco,
and the Coast Guard began to mobilize over  1,000
personnel.  The following day, the Coast Guard
mobilized several cutters, aircraft, and other equip-
ment (see Figure 8).  As of April 24, over 250 per-
sonnel were working for either MSO Valdez or MSO
Anchorage,  and 750 were crew  aboard the nine
Coast Guard cutters and  eight aircraft (see Figure
9).

 FIGURE 8
 Federal Equipment On Scene
                                        FIGURE 9
                                        Federal Personnel On Scene
  30
  25
  20
  15
  10
— — - Vessels

—— Skimmers

••••• Aircraft
     24 25 26 27 28 29 30 31  1  2  3  4 5 6 7 8 9 10 11 12
              March                  April
 Source: U.S. Coast Guard, 1989.
    The National Strike Team supervised the off-
 loading of the Exxon Valdez under the direction of
 a salvage  master.  At  any given time during the
 crisis, the Strike Team  has had at least 20 members
 on scene.   Virtually all of the PACAREA Strike
 Team members have participated  in this spill re-
 sponse, as have some Atlantic Area (LANTAREA)
 members.
                                         500-
                                         400
                                         300
                                         200
                                         100
                                            24 25 26 27 28 29 30 31  1  2 3 4 5 6 7  8  9  10 11 12
                                                     March                  April
                                         Source: U.S. Coast Guard, 1989.
   NOAA's Scientific Support Coordinator (SSC) in
Anchorage was called the morning of the incident
and was on scene within hours.  By the end of the
day, NOAA's Hazardous Materials Response Branch
had assembled a team of six people and a  NOAA
helicopter to assist the OSC.  Oil spill trajectory,
weather, and tide forecasts were available to the
OSC within the first 24  hours, and routine  oil spill
overflights  to map  the extent  of contamination
began on March 26. By the middle of April, NOAA
had staff in Valdez, Whittier, Seward, Homer, and
Kodiak to facilitate the coordination of scientific
activities.
    Shortly after the incident, Alyeska contacted the
International Bird Rescue Research Center (IBRRC)
and placed it under contract. IBRRC staff arrived
on scene March  25 and began  to set up a  bird
cleaning  and  rehabilitation  center  in  Valdez.
Department  of the Interior (DOI)  and Fish and
Wildlife Service  (FWS)  representatives arrived in
Valdez the evening  of March  24.  A specialist
arrived in Valdez from the Hubbs Marine Research
Institute in San Diego to set up a sea otter facility.
Exxon hired these animal rescue specialists pursuant
to the wildlife protection guidelines of the Regional
Contingency Plan (RCP).
                                                 •15

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    A sea otter collection program began on March -
29. The sea otter cleaning and rehabilitation center
in Valdez was opened on March 30.  Cleaning and
rehabilitation centers also were established in other
cities.  In addition to sea otter collection by Exxon
contractors, FWS personnel are assisting in capturing
oiled sea otters.
    A bird collection program began on March 29,
and the cleaning and rehabilitation center in Valdez
opened on March 31.  As the oil progressed south-
ward, the IBRRC established centers in other cities.
In addition, Exxon is reviewing an FWS draft spring
migration bird protection plan. The plan focuses on
hazing birds  from  oil-contaminated areas  and
establishing flight patterns to prevent aircraft  from
moving birds from unoiled areas to oiled areas.
    Other military resources have been mobilized to
clean  up the spill.  The Department of Defense,
through the normal RRT/NRT mechanism, provid-
ed U.S. Navy equipment on the second day of the
spill and  increased the level of support throughout
the cleanup. The Army, Navy, and Air Force have
supported the response effort.  (See Appendix B for
Forces On Scene).  Funding for  this support was
provided by Exxon through a previously developed
mechanism using the  §311(k)  Fund established by
the Clean Water Act  (CWA).  The OSC  retained
responsibility for cost accounting.
    Coast  Guard   administrative,  management,
clerical,  and support  personnel from around the
country have been assigned  to the spill.  Coast
Guard public affairs officers and specialists are in
the Valdez area to answer media questions, escort
VIP visitors, and administer a long-term community
relations program.
    In addition to the resources provided by the U.S.
government, state agencies, and  private domestic
companies hired by Exxon, the governments and
private sectors of Canada, Denmark, France,  Nor-
way, and the Soviet Union made generous offers of
assistance.
    The RRT became actively involved in the clean-
up soon after the spill.  The RRT convened for its
first teleconference call at 1200 on Friday, March
24, and  continued to  hold  teleconference  calls
virtually every day thereafter.
    The National Response Team (NRT) was acti-
vated almost immediately.  Less than four hours
after the spill was  reported, the  Coast Guard Vice
Chair,  acting  as NRT Chair  for this  incident,
directed the National Response Center to brief NRT
members. The Coast Guard had  all of its pollution
reports sent directly to individual NRT agencies as
the OSC  released them.  Shortly  after the spill, the
Chair and the Vice Chair  visited the spill site and
returned to brief the NRT.
    The NRT convened five times through April 26
in special session to receive updates on the incident
and discuss the activities  of NRT agencies.   The
NRT members established a communications net-
work for information and  coordination and volun-
teered their resources and expertise, as needed.  The
Coast Guard established  a 24-hour crisis action
center adjacent to the NRC. Additionally, the NRT
sent a group of Coast Guard, EPA, DOI, and  De-
partment of Energy  representatives to Alaska for
firsthand input into this report.

5. State of Alaska Actions

    The State of Alaska's  participation in the re-
sponse to this incident began when the  spill  was
reported. An ADEC official went to the scene with
the Coast Guard investigator less than one-half hour
after notification of the spill.  ADEC  was an inte-
gral part of the contingency planning process before
the incident and an active participant in RRT and
subsequent management organizations  in the early
stages  of the response effort.    It did,  however,
assume a role largely independent of the federal
response organization as  the cleanup proceeded.
For example, Alaska obtained recovery equipment
and a state ferry to use as a mobile operations center
on its own.
    The Governor of Alaska personally  surveyed
the damage by 0600 the  first  day and  remained
involved with the state's  efforts throughout the
response. On March 26, the Governor declared a
state disaster and implemented  the Alaska Emer-
gency  Plan.   The  following day, the Governor
requested a Presidential declaration of an emergency
under Title V of the Stafford Act. Specifically, he
asked for the appointment of a federal coordinator
and  for  technical  and advisory assistance to the
federal, state, and local governments.  On April 11,
the director of the Federal Emergency  Management
Agency advised the Governor that the National Oil
and Hazardous Substances Pollution  Contingency
Plan (NCP) was operating. The  NCP  already pro-
vided the federal coordinator and technical assis-
tance specified in the governor's request.
                                                 16

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6. Clean-up Methods
a. Dispersants
    Dispersant use became a controversial issue in
this response.  The federal OSC is responsible for
ensuring minimal harm to the environment.  The
OSC relies on advice from the Scientific Support
Coordinator, recommendations from the Regional
Response Team (RRT), and his  best professional
judgment.  The Alaska RRT was well  prepared to
address questions of dispersant use (see Appendices
D and E) and had  developed a new dispersant-use
plan in early March 1989 (see Figure 10). The plan
was  incorporated into the RCP and reflected in-
depth study done in the area.
    At the  time of  the  incident,  two different
dispersant  use  strategies  were in  effect.   Each
strategy  applies  within discrete seasonal and geo-
graphic boundaries.   The area of Prince William
Sound from two miles below the grounding site and
extending to the north (including Valdez Harbor) is
designated in the RCP as Zone 2 from March 1st
until October 15th.  In Zone 2, RRT concurrence
with the OSC's recommendations is required prior to
dispersant  use authorization.  (This  area is  desig-
nated Zone 1 from October 16th until  April 30th.)
The area beginning two miles south of  the ground-
ing site, which was  in the  path of the slick, is
designated in the RCP as  Zone 1 all year. In Zone
1, the OSC is preauthorized to use (or allow the
spiller to use) dispersants, with the only condition
that the EPA and state (ADEC) RRT representatives
be notified retroactively—but with minimal delay.
    Approximately 30 minutes after the spill was
reported, the OSC contacted Alyeska to suggest it
consider calling aircraft  to be used  for dispersant
application. About 0430, the OSC discussed disper-
sant use with Exxon and advised that dispersants
were preauthorized by the RRT at the discretion of
the OSC for use in Zone 1.
   The OSC contacted Alyeska at 0630 and advised
Alyeska to start the dispersant-use request process.
About 0830, Alyeska transmitted a 10-page formal
request  to have both fixed-wing aircraft and heli-
copters spread 50,000 gallons of dispersant, beginn-
ing at 1400 that afternoon.   At the time of the
request,  Alyeska had less than 4,000  gallons of
dispersant at its terminal, no dispersant application
equipment, and no aircraft. A total of 8,000 gallons
of dispersant were available in Kenai, and an addi-
tional 8,800 gallons of dispersants were available in
Anchorage.   Alyeska had contacted a  dispersant
application equipment contractor in Kenai and its
contract dispersant aircraft in Arizona.  The RRT
discussed dispersant use during its 1200 conference
call.   At about  1500, by which time the oil had
spread south into Zone 1, the OSC granted permis-
sion  for a trial application to determine the disper-
sant's effectiveness under the existing conditions.
Alyeska conducted the first trial application about
1800  that  first  evening  using  a helicopter and
dispersant bucket. The OSC decided the application
was ineffective because wave action was insufficient
to mix the oil and  dispersant. However, the OSC
authorized additional applications in Zone 1 for the
following morning using a fixed-wing aircraft.
   Exxon's fixed-wing  aircraft arrived in Anchor-
age about 0615 the following  morning,  March 25.
At about 0945, the RRT met and discussed disper-
sant  application in Zone 2 near the spill site.  The
RRT concurred with the OSC that,  despite calm
water and light winds which adversely affected the
dispersant's effectiveness, further trial applications
should  be conducted.  The  OSC announced this
authorization  for  trial  application  at about  1200.
Full  application in Zone 2 would  depend on the
state and EPA RRT representatives' concurrence
with the OSC's recommendation.  The second trial
application was conducted by Exxon using a fixed-
wing aircraft with 2,500 gallons of dispersant. The
aircraft  arrived  at the  spill  site  around  1700.
Dwindling daylight prevented a complete evalua-
tion, but extremely calm seas and winds of less than
15 knots caused very little dispersing action to be
observed by the OSC. The OSC authorized another
trial  application  during  daylight  hours  for the
following day, March 27.
                                                 17

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Figure 10

Zones Of Dispersant Use In Prince William Sound
                                              f Vessel traffic lanes\
                                              • anH spnaratinn ?nnfi ^
and separation zone

                                 PRINCE WILLIAM SOUND
                                                                                      *•••*•••••••
                                                                          ^*

                                                                       Hinchinbrook ^
                                                                               *+*
                                                                     OF ALASKA
                                                      1 —Acceptable and OSC preauthorized

                                                      2 —Conditional, RRT concurrence required

                                                      3 —Not recommended, RRT concurrence required
                                                 •18

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   A third trial application was conducted about
1030 the third morning after the spill using 3,500
gallons of dispersant in a fix-wing aircraft.  Me-
chanically, the test was not satisfactory because the
nozzles did not spray the dispersant evenly.  This
caused some  oil to be completely untreated and
some  oil  to  be overdosed with  the dispersant.
Throughout the day,  the seas were increasing to
about four feet and  the wind was increasing to
about 20  knots.  Exxon conducted a fourth trial
application at approximately 1600 that day using a
different type of fixed-wing aircraft. The increas-
ed wave action created the mixing action needed to
make the dispersant effective.  The OSC authorized
full scale use for the following day.
   During the night,  winds increased to gale force
and  continued through the  following  morning,
grounding all aircraft. When the spotter helicopter
got airborne around noon, the oil  had moved into
Zone 3 where dispersant use is not recommended.
The RRT was contacted and asked  to grant permis-
sion to apply dispersants in this "not recommended"
zone. At 1400, the RRT granted permission for one
plane load of dispersant to be applied in this zone.
At about 1800, the OSC, along with ADEC and EPA
representatives,  was  aboard a spotter  helicopter
awaiting the arrival of the dispersant aircraft. The
OSC cancelled the application around 1850 when the
aircraft had not arrived, daylight was waning, and
there was little oil left  in the area.  It was later
learned that, at the direction of the  Exxon command
post,  the aircraft  had applied dispersant  at about
1500  over an unauthorized location.
b. Burning
   On the first day of the spill,  Exxon requested
an open-burn permit from the State of Alaska. The
state responded the following day by authorizing an
effectiveness test for burning the spilled oil, and the
test was conducted toward evening of that same day.
Approximately 12,000  to  15,000  gallons were
burned.  Disagreements arose between Exxon and
the State of Alaska about the success of this opera-
tion.  Although the oil burned satisfactorily, there
were questions about residual  smoke.  Some resi-
dents several  miles  from the burn site  reported
irritated  eyes  and throats. No further tests were
conducted. The ADEC took the position that it was
not opposed to burning as long as communities were
not harmed and their residents were notified of an
upcoming  burn.   The  weather  changed  by  the
evening  of  the third day, making conditions un-
favorable for another burn.

c.  Mechanical Recovery
   Mechanical recovery was the preferred method
of oil removal because mechanical  recovery removes
oil from  the environment without  possible environ-
mental effects from contaminants,  such as added
chemicals. Necessary recovery equipment  included
various booms, skimmers, and containment vessels.
Equipment assembly was  labor intensive and time
consuming. Booms  required personnel who could
attach sections, set, and tend  them.  Some booms
are inflatable, but one such boom sank on the first
day  of the spill.  The booms had to be towed slowly
to prevent damage.  Since Prince William  Sound is
very large, the time necessary to  relocate booms to
different areas of Prince  William Sound was con-
siderable.
    Skimmers are mechanical  devices that remove
oil from water. They require tending during opera-
tion.  Skimmers  must be directed  to oil  locations
from aircraft to assure  greater efficiency, thereby
increasing  coordination problems.   Few aircraft
were available initially to coordinate the deployment
of skimmers. With limited personnel available to
monitor and repair skimmers operating great dis-
tances from one another,  long periods of inactivity
resulted when they became disabled.  When break-
downs required shop work, they were towed back to
Valdez.  For example, one skimmer with a gear box
problem required 12 hours to be towed  to Valdez
 for  repairs.  The repair shop  was already working
 on two other skimmers and repairs took all night to
 complete.
                                                 19

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    As is graphically shown in Figures 11  and 12,
63 percent to 85 percent of the skimmers on scene
were deployed at any one time after the first day.
For reasons mentioned above, not all of the deploy-
ed skimmers were recovering  oil effectively.  A
skimmer's  efficiency depends  on the  type and
condition of the oil being recovered.  After the oil
weathered  in this spill,  it had  the thick,  viscous
consistency of axle grease.  Skimmer hoses clogged,
and only about 10 percent of the designed recovery
rate could be achieved (see Figure 13). Heavy kelp
concentrations also contributed to clogging.

FIGURE 11
Number of Skimmers On Scene
                                       FIGURE 13
 •70——
 65	
 60	
 55	
 SO	
 45	
 40	
 35	
 30	
 25	
 20	
 15	
 10	
  5	1
Exxon

Government
    24 85 26 37 28 29 30 31 1  2 3 4 5  6  7  8 9 10 11 12
             March                  April
Sourca: U.S. Coast Guard, 1989.
 FIGURE 12
 Number of Skimmers in Operation
    24 25 26 27 28 29 30 31 1  2 3 4  5  6 7 8 15 17 19
           March                  April

 Sourco: U.S. Coast Guard Pollution Reports. 1989.
                                       Estimated Cumulative and Daily Volumes
                                       of Oil Recovered
                                       Thousands of Gallons
                                       •800
                                                   Amount of Oil Recovered
                                                   Each Day
    24 25 26  27 28 29  30 31  1  2  3  45  6   7  8
             March                  April

Source: U.S. Coast Guard Pollution Reports, 1989.
                                           The third component of a mechanical recovery
                                        system is the temporary storage vessel.  A small,
                                        temporary  oil-containment  device  (oil  bladder)
                                        attached to the skimmer must be emptied at a large
                                        oil recovery barge when full.  This procedure  was
                                        slow because the transfer pumps had difficulty
                                        moving the heavy,  grease-like material.  Conse-
                                        quently, vessels would often queue up at the recove-
                                        ry barge.
                                           Weather also affected the pace and effectiveness
                                        of oil recovery.  Severe weather suspended opera-
                                        tions a number  of  times, forcing vessels  to  tow
                                        skimmers and booms to sheltered harbors and coves.

                                        7. Shoreline Cleanup

                                           Appropriate shoreline clean-up techniques vary
                                        according to the type of shoreline, the nature of the
                                        oil,  and the natural  resources present.  One of the
                                        primary selection criteria in choosing a clean-up
                                        method is to ensure that the technique will not cause
                                        greater harm  than  allowing natural processes to
                                        cleanse the environment.  Much of western Prince
                                        William Sound is characterized by  high vertical
                                        cliffs frequently edged with  gravel shorelines.  The
                                        inner sound is laced with fjords and more sheltered
                                        rocky beaches. General recommendations for clean-
                                        up methods for the variety  of shorelines found in
                                        the  sound  are shown in Appendix I-I.
                                                 •20

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   After  the Exxon  Valdez incident,  a multi-
agency group was  tasked  to  advise  the  OSC  by
identifying sensitive environments, delineating the
degree of affected shoreline, and ranking areas to
be cleaned.   Clean-up guidelines  were developed
and presented to the OSC. Exxon, federal, and state
agency personnel conducted field surveys to define
the shoreline, determine the amount of oil present,
identify logistical problems, and investigate other
concerns.   Cleaning  techniques were  identified,
tested, and approved by the OSC.  A streamlined
process was  developed by  Admiral  Yost in mid-
April which requires OSC approval for any particu-
lar beach  segment before actual cleaning  work by
the Exxon teams.  Initially, approval of shoreline
clean-up procedures was time consuming because of
the large number of participants in this process with
varying levels  of  knowledge.   Special clearances
remained  necessary to prevent damage to potential
archaeological  sites commonly  found along the
shores.  Areas  where seal  pupping is expected to
occur around the third week in May received high
priority for cleanup.

      C.  RESPONSE ORGANIZATION

    Under the  National Contingency Plan (NCP),
the  OSC is responsible   for ensuring  a proper
response by continuously assessing and monitoring
all response actions, and by "federalizing" a spill if
the  response activities are unsatisfactory.  In the
context of the Clean Water Act (CWA) and Execu-
tive Order 11735, "federalize" is defined as the use
of federal funds for cleanup under the direction of
the  federal OSC.  If a response is not being carried
out properly, the OSC will  notify the party respons-
ible for the spill of its liability for costs associated
with the  removal under CWA and "federalize" the
response  and cleanup.   Lacking a  finding that  a
responsible party is not conducting a proper clean-
up,  the  NCP envisages  a  cleanup conducted and
paid for by the responsible party.
     The OSC is the focal point in effectively coor-
 dinating the response to an oil spill.  The OSC pulls
 together the various threads of expertise and prov-
 ides oversight  direction for the use of manpower,
 equipment,  and  resources.   In general, the OSC
 classifies the size of the discharge; investigates the
 source, type, and  quantity  of  the  discharge; and
 monitors the response action to  determine  if the
 discharger is carrying out the response properly. In
 this case, the predesignated OSC was the Command-
 ing Officer of the Coast Guard  MSO  in Valdez.
 That office consists of 34  personnel  and is respons-
 ible for marine inspections, casualty investigations,
port safety, environmental response, and the VTS
system for the MSO Valdez area.
    With Alyeska accepting responsibility  for the
cleanup immediately after the spill  occurred, the
OSC established a response organization in con-
formance with the NCP. The lack of preparedness
on the part of Alyeska to have the requisite equip-
ment pre-staged, however, effectively delayed any
meaningful response.
    The spill's  sheer  size and complexity of the
required response taxed the initial OSC organization.
Additionally, public and media concerns over the
spill's potential environmental and economic effects
demanded the  OSC's  attention to  a  far  greater
degree than that previously experienced during any
spill in U.S. history. It was quickly evident that this
spill would require  additional assistance  for the
OSC.
    To alleviate pressure  on the OSC, the Seven-
teenth Coast Guard District Commander was dis-
patched to  the scene on the second day after the
spill.  The presence of  the District Commander at
the scene may have led to initial confusion as  to
who was in charge, because he is the OSC's super-
visor.  In fact,  no  transfer of authority took place,
and the OSC retained his role under the CWA.  It
may be unrealistic to believe that any disaster  of
national proportions such  as this  one will remain
under the full authority of a predesignated OSC for
very long.
    As the response activities increased in intensity,
the response organization grew to accommodate the
increased demands placed on it. By  the fourth day
of  the spill,  a high  level management  steering
committee, consisting  of the Seventeenth  Coast
Guard District Commander, the President of Exxon
Shipping, and the Commissioner of ADEC, evolved
to  coordinate the  response. This elevation of au-
thority was appropriate given the circumstances of
the spill.
    "Federalization"  is a potential response in any
 spill.  By continuously monitoring the responders -
  first  Alyeska, then Exxon -  the OSC determined,
 however, that the responsible party was mounting as
 effective a response as possible.   (See Appendix B
 for Forces On Scene.)  The OSC deemed it inappro-
 priate to "federalize" the  incident as long as Exxon
 continued to cooperate with the federal OSC, fund
 the entire operation, and perform satisfactorily.
                                                 •21

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    On April 7, the President directed the Secretary
of Transportation to  serve as the coordinator of
efforts by all federal agencies involved in the clean-
up, lie also directed the Commandant of the Coast
Guard to return to Alaska and  assume personal
oversight direction of the spill response efforts. A
much larger federal organization, with the Coast
Guard Commander, Pacific  Area, designated as
federal OSC, was established.
    The President directed the Secretary of Defense
to make U.S. military resources available to assist in
the cleanup. The Secretary of the Army was desig-
nated as the executive agent for DOD's involvement
in clean-up activities, and the Director of Military
Support (DOMS) was designated the action agent to
coordinate, manage, and task all DOD support. To
ensure coordination of  requests  for support,  a
DOMS Oil  Spill  Joint Task Force consisting of
Army, Navy, Air Force, Marine Corps, Joint Staff,
and Coast Guard representatives  was activated in
the Army Operations Center, Pentagon. (See Ap-
pendix B for Forces on Scene.)

         D. PUBLIC INFORMATION

    The Coast Guard immediately  activated  its
existing public information plan after being notified
of the spill. A local petty officer acted as  interim
spokesman  until the District Public Affairs  Officer
and a Public Information Assist Team member from
Headquarters arrived on scene. Their first actions
were  to establish a Coast Guard  news office and
request additional public affairs staff.
    The huge  number of media correspondents in
the area strained the Coast Guard's ability  to pro-
vide  information.  Phone lines were jammed as
correspondents held them open to stay in  contact
with their home offices. Media representatives soon
located themselves in a Valdez community building,
where subsequently they were briefed by members
of  the response  organization.   Additional Coast
Guard public affairs staff arrived five days  follow-
ing the spill and have run an integrated and  respon-
sive operation under extremely trying conditions.

      E. EARLY LESSONS LEARNED/
           RECOMMENDATIONS

1. Initial Response
o Mobilizing equipment and personnel in the initial
    stages of an incident is difficult in all major oil
    spill recovery operations. In the Exxon Valdez
    spill, this  problem  was accentuated  by the
    remote location and  the distances involved in
   moving equipment. The time lag in transporting
   and deploying equipment forced the responders
   into catch-up efforts from the onset.
o Equipment staged at the Alyeska terminal was not
   sufficient to cope with a spill of this magnitude.
   The time lag in transporting additional equip-
   ment to the  scene from out-of-state led to  a
   perception of inaction.
o Given the limitation of existing plans and capabil-
   ities, the quantity of oil released in such a short
   period (10.1 million gallons in five hours) over-
   whelmed recovery and containment efforts.
o Alyeska's initial efforts to get its equipment on
   scene were slow because the response barge was
   not ready. The response barge was stripped of
   equipment,  took  ten hours to load,  and took
   another two hours to reach the Exxon Valdez.
   Once  started,  oil  recovery progressed  very
   slowly.
o The quantity and size of booms were insufficient
   to respond to the spill adequately.
o Few skimmers were working on scene during the
   first 24 hours.  Alyeska also lacked a tank barge
   into which  the skimmers could  discharge re-
   covered oil.
o The issue of  dispersant  use remains in dispute.
   Conflicting documentation from Exxon and the
   OSC makes the decision process  unclear. It  is
   clear, however, that neither Alyeska nor Exxon
   had sufficient quantities of dispersant available
   for the magnitude of the spill.  The dispersants
   that were available were not used immediately
   because the OSC determined, as a result of three
   trial applications,  that they were not effective
   due to the lack of wave action required to mix
   dispersants  with   oil, and because they  were
   applied improperly. Dispersant use on catastro-
   phic spills needs further study.
o Burning  the  oil was possible  and was  done.
   Apparently,  it was not  continued because of a
   misunderstanding between Exxon and the State
   of  Alaska over  the conditions  under  which
   burning could proceed.  By the time the misun-
   derstanding  was  worked  out,  the opportunity
   had passed.

2. Wildlife Rescue

o Initial wildlife rehabilitation efforts were slow.
   In light of the magnitude of the spill, all avail-
   able resources should have been brought to the
   scene more quickly.
o An overall  plan should have been  developed
   during the initial  stages of the spill to address
                                                •22

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   bird  and sea otter collection,  cleaning,  and
   rehabilitation programs  that   would  extend
   throughout the entire area potentially affected.
   This  plan is  being developed  now and  will
   include volunteers and effective oversight by
   federal agencies responsible.
o The Alaska regional Oil and Hazardous Substances
   Pollution Contingency Plan's Wildlife Protection
   Guidelines  should  be  expanded  to  include
   information  on dealing  with wildlife impacts
   when the responsible party assumes respon-
   sibility.

3. Response Organization
o In general, most spills are managed using a "team"
   concept.  This approach involves the spiller, the
   OSC, other federal agencies, and the state. This
   team  concept appeared  to break  down  into
   adversarial relationships that may have caused a
   lack  of  communication  and ineffectiveness in
   the cleanup.
o The OSC  spill-response organization  outlined in
   the NCP was not  followed  in this case.  Public
   and media interest required a disproportionate
   amount of the OSC's  time.  Three different
   organizations eventually evolved  to deal  with
   this spill:  the NCP-specified organization, the
   steering committee, and Presidentially-directed
   oversight  by the  Commandant of  the Coast
   Guard.   An initial perception persisted  that
    strong oversight direction was not being exer-
    cised.
o The NCP should be  reviewed to determine the
    most appropriate organizational structure for
    catastrophic spills.
o The Commandant of the Coast Guard reestablish-
    ed federal oversight of the response, clarified
    lines of authority and  management, and put
    response actions back on course.
o "Federalization" of  the  spill  was not considered
    necessary because the OSC determined Exxon
    was  taking proper action to remove the spilled
    oil and effective action to eliminate its threat to
    the environment.  Exxon assumed responsibility
    for the spill quickly and showed the willingness
    and  capacity to  acquire  the  equipment  and
    personnel necessary to carry out the response.

 4. Response  Policies
 o When  tested by a massive, open-water oil  spill,
    current response  equipment is still inadequate
    under less than ideal conditions.  With existing
    technology, booms and skimmers alone cannot
   handle a 10-million gallon spill. Improvements
   in response technology are needed.
o As in many previous incidents, open-water clean-
   up attempts evolved into a decision to protect
   sensitive areas by booming while awaiting shore
   impacts.  Final oil recovery strategies then are
   based on shoreline cleanup. Significant oppor-
   tunities to  skim oil  off the water  in Prince
   William Sound were lost due to the conflicting
   priorities of protection.
o Use of dispersants and skimmers in cold-water oil
   spill  responses needs further study. The results
   need to be shared with industry and incorporat-
   ed into national plans.
o Beach-cleaning  techniques for  the  conditions
   found in Prince William Sound are labor- and
   resource-intensive and not efficient.  Further
   lessons from this experience need to  be shared
   with all concerned.

5. On-Scene Communications

o Communications were a problem, given the large
   area, the mountainous terrain, and the varied
   armada of  vessels involved. A hodgepodge of
    radio equipment made communications difficult.
    Voids in radio coverage were aggravated by
    distances  and geography  inherent  to  Prince
    William Sound. Exxon is to be commended for
    putting together,  with Coast Guard  and DOD
    assistance, an effective communications system
    in short order.

6. Public Information

o The Coast Guard did  not initially foresee  the
    magnitude of the public and media  interest in
    this  incident.  Consequently, the small number
    of public affairs personnel assigned were over-
    whelmed.  This  adversely affected the  OSC
    organization and its ability to carry out opera-
    tional responsibilities.  Future spills must in-
    clude prompt, aggressive  public information
    support, including  both the means  to control
    misinformation and rumors and  the means to
    coordinate with all relevant agencies, in order
    to assist the OSC and give the public  a more ac-
    curate picture of the response.
 o A public information program is necessary to deal
    specifically with the collection,  cleaning,  and
     rehabilitation of injured wildlife.
                                                 •23

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                                      V.  THE EFFECTS
    It still is much too early to know the full extent
of the environmental, economic, and health effects
of the oil that spilled from the  Exxon  Valdez into
the waters off Alaska's south-central  coast.  The
discussion  below, which  describes these effects,
should be regarded as preliminary.

      A.  ENVIRONMENTAL EFFECTS

1. Background

    The severity of oil spill effects on the environ-
ment varies greatly, depending on the conditions of
the spill.  The type and amount of oil involved, its
degree of weathering, geographic location, seasonal
timing,  types of habitat affected,  sensitivity of the
affected organism's life stage, and adequacy of the
response all influence the severity of environmental
effects (see  Figure 14).  Many of  the conditions
present during  the Exxon  Valdez  spill increased,
rather than diminished,  the severity of its impacts
relative to other large spills. The spill occurred at
a high latitude in a semi-enclosed body of water at
the beginning of spring.  The 10.1 million gallons of
oil spilled from the Exxon  Valdez are known to
have oiled over 350 miles  of  shoreline in Prince
William Sound  alone.  The figure will  increase as
other affected areas are  surveyed.
FIGURE 14
Representation Of Oil Behavior In Prince William Sound
                Stranding and Weathering
                                  Water-in-Oil Emulsion
                                     (mousse)*
                                           Ingestion and Egestion by Animals
"Mousse is the name given to the thick emulsion of water and oil (50-60% water) caused by the wind and waves.
                                                •24

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FIGURE 15
Environmentally Sensitive Areas
                                      PRINCE WILLIAM SOUND
                                   Knight
                                   Island
                                                                            Salmon Hatchery
                                                                            Marine bird concentration area
                                                                            Combined bird and otter area
                                                                            Sea otter concentration area
                                                                            Herring spawning area
     In contrast, only 240  miles of  coastline  were
  affected by the Amoco Cadiz oil spill in 1978. The
  Amoco Cadiz released 68 million gallons of oil when
  it broke up on  the rocks in stormy seas off France's
  Brittany coast.  Most of the elements of Brittany's
  temperate  zone  environment  largely  recovered
  within three to eight years from the effects of the
  oil spill  and ensuing  clean-up  operations.  The
  habitats of the south-central Alaskan coast generally
  are more vulnerable to spilled oil than those of more
  temperate climates because the lower temperatures
and resulting slower rates  of physical weathering
and biodegradation allow the oil to persist.  This
persistence provides the potential  for long-term
exposures and sub-lethal chronic effects, as well as
short-term exposures and acute effects. In addition,
the remoteness of the affected Alaskan area and the
physical features of its coastline make cleanup more
difficult than it was in Brittany.  Great  care must
be taken in the Exxon  Valdez cleanup to minimize
harm to sensitive environments.
                                                  •25

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r
              Prince William Sound,  the  site of the Exxon
           Valdez spill, is one of the largest tidal estuarine
           systems on the North American continent. In terms
           of water surface alone, it is about as large as Chesa-
           peake Bay.  Its many islands, bays, and fjords give
           it a shoreline totalling more than 2,000 miles, nearly
           one-quarter of Chesapeake Bay's total shoreline.
           Prince William Sound is within the boundaries of
           the Chugach National Forest. The western half of
           the sound, the area most affected by the oil spill, is
           within the  Nellie Juan-College Fjord Wilderness
           study area.  This area is highly sensitive environ-
           mentally.

           FIGURE 16
           Leading Edge Of Oil Spill (through April 23)
    Patches  of  oil  or  oil-and-water emulsion
(mousse) now have moved with the prevailing winds
and currents in a southwesterly direction more than
250 miles from the accident site on Bligh Reef (see
Figure 16).  The oil has moved  out of Prince Wil-
liam Sound into  the Gulf of Alaska and along the
Kenai Peninsula and the Kenai Fjords National Park
to the islands of  Lower Cook Inlet and  the Kodiak
Archipelago.  There is no evidence to date that large
quantities of oil  have entered the water column or
sunk to the bottom in Prince William Sound.
                                                                                    Tanker aground
                                                                                    March 24, 1989
                                                                                  PRINCE WILLIAM SOUND
                                                                                     «
                                                    GULF OF ALASKA
                                                           •26

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    Much  of this entire  area  was largely pristine
 until the Exxon Valdez incident.  It is an area of
 great natural beauty, and its rich natural resources
 form the basis  for major commercial fisheries for
 pink and chum salmon and Pacific herring.  There
 are smaller  fisheries for halibut,  sablefish,  king,
 Tanner  and Dungeness crabs, and shrimp.  The
 Chugach National Forest in Prince William  Sound
 and  Kenai  Fjords  National  Park are  relatively
 accessible  by air and  boat from  Anchorage, the
 major population center in Alaska, making the area
 a favorite location for recreational users. The sound
 is the major food source for  the Alaskan Native
 villages  on its shore.

 2.  Effects On Birds  And Marine Mammals

    Immediate spill effects were most visible  on
 marine  birds and  sea  otters.   These  effects are
 becoming much less severe as the oil breaks up into
 smaller  patches and,  finally,  into weathered tar
 balls.
    The bird population  of Prince  William  Sound
 and the Kenai/Kodiak area is diverse and abundant.
 The Fish and Wildlife Service (FWS) counted more
 than   91,000 waterbirds  (mostly  diving  ducks,
 grebes, and  loons) in the sound immediately after
 the spill. About half of these birds were in or near
 areas affected by floating oil. As .the spring migra-
 tion gets underway, large numbers of waterfowl and
 shorebirds that stop to feed in the  Prince William
 Sound area  potentially could  be  exposed to the
 spilled oil.  Many of these birds may.be affected
 either directly by oil or indirectly through the loss
 of  food  sources.
    As the oil moves along the  Kenai Peninsula and
 the Kodiak Archipelago,,it will continue to  affect
 shorebirds and  waterfowl.. The  severity of the
 impact will depend on the amount of oil that reach-
. es these areas, its degree of  weathering and emulsi-
 fication, .and how long it persists near the seabird
 colonies.  Seabirds are just beginning to occupy
 colonies for this year's breeding season.  The success
 of  this breeding season also could be diminished
 because of habitat loss, loss of food resources, and
 mortality of chicks and eggs. Oil transferred from
 the feathers of brooding  birds is  toxic to embryos
 within the eggs.  For the reasons discussed  above
 and because of the difficulty in recovering bodies,
 the 4,463 dead birds collected  do not represent the
 full toll.
    Twenty-three species of marine mammals live
 in  the sound and the Gulf of  Alaska either year-
 round or  during the summer.   These mammals
 include gray, humpback, and killer whales, various
porpoises and dolphins, harbor seals, sea lions, and
sea otters.  Of these animals, the sea otters are by
far the most sensitive and vulnerable to spilled oil.
Because they are dependent upon fur for insulation,
they die of hypothermia and stress when it comes in
contact with  oil.  -Fumes from the floating oil also
may have contributed to their deaths.  As many as
2,500 of Prince William Sound's estimated pre-spill
population of 8,000 to 10,000 sea otters  are in the
western portions  of the sound where they may be
exposed to oil from the Exxon Valdez. The number
of dead, currently at  479,  is not regarded as an
accurate  measure of the spill's impact on sea otters
because of the difficulty in recovering their bodies.
No estimates  of total mortality yet have been made.
    Other sea otter populations potentially at risk as
the oil moves through the Gulf of Alaska off the
Kenai Peninsula  and the  Kodiak Archipelago are
the estimated 2,500 to 3,500 otters along the penin-
sula and the estimated 4,000 to 6,000 around Kodiak
and other nearby  islands. No other marine mammal
(e.g., dolphin, seal, or whale) mortality yet has been
attributed to  the oil spill, but harbor seals will start
pupping  in May.  There is concern that oil remain-
ing in harbor seal pupping areas could injure or kill
the pups. Priority is being given to cleanup of these
areas, but the work must proceed cautiously in order
to minimize stress on the pregnant females at this
critical time.   Terrestrial  animals,  such as river
otters, mink,  bald eagles, bear, and deer, that, utilize
intertidal areas, also may be  affected through scav-
enging of oiled carcasses on the beaches or browsing
on oiled kelp.         .     .     .

3. Effects On Fisheries
       And  Other Marine Resources

   Oil can affeqt microscopic plants and animals
(phytoplankton and  zooplankton)  adversely.'  The
latter include the floating eggs and  larvae of fish
that  form the base of the marine food chain. In the
open waters  of the sound  and gulf,  this impact
probably will be  short-liyed and local because of
the quick replacement of plankton by the §ame or-
ganisms from unaffected areas.  For some species,
however, mortality'of planktoriic  eggs  and larvae
may be reflected in long-term population effects.
Intertidal animals such as barnacles and mussels,
which live in a highly variable and stressful en-
vironment, have little or no mobility. Oil in many
intertidal areas within  Prince William Sound and
elsewhere will  result  in  severe mortality among
these animals.  Recovery of their populations  may
take several years.
                                                 •27

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    As the oil from the Exxon Valdez moves into
the deeply indented coast by means of tidal  and
wind  action, it will affect increasingly sensitive
environments. Higher-risk, lower-energy environ-
ments are located deeper in fjords and bays.  In
high-energy  environments, such  as the headlands
along the Kenai Peninsula, wave action tends to
remove what oil is stranded rather quickly. In low-
energy environments,  such as shallow  bays  and
marshes, oil  may remain for years with  only slow
chemical and biological processes to degrade it.  The
stranded oil will serve as a reservoir for the chronic
input of oil  into the subtidal sediments, where it
may affect  bottom  dwelling  (benthic) organisms
over the long  term.  The potential exists for oil
released in the Exxon Valdez spill to persist in and
on parts of this coastline for many years.
    Long-term effects to the area's rich biota  may
result  from  food chain and habitat disruption as
well as from  decreased survivability and reproduc-
tive capability of animals directly  exposed to oil.
Determining these impacts will require study of the
species of concern throughout their life cycle or
longer. For example, pink salmon have the shortest
life cycle among the five different salmon found in
the area.  These salmon return to spawn two years
after their eggs are laid.  Prince  William Sound
alone  accounts for 50 percent  of  Alaska's  total
commercial harvest of the species.
    A series  of state and private hatcheries, two of
which are the world's largest,  support the  pink
salmon fishery.  Hatchery-raised fry normally are
 released in early April and spend up to three months
 feeding  and growing  in  the  shallow,  near-shore
 areas of the sound before migrating into the Gulf of
 Alaska.   The  fate of  this year's fry, estimated to
 exceed 650 million, is a cause for concern.  The fry
 may be killed by hydrocarbons in their nursery
 areas (they are sensitive to very low concentrations
 in the water column).  Their growth rate may be
 slower this year due to stress from hydrocarbons or
 a decrease in the amount of available food.  Because
 smaller fish are more susceptible to predation, fewer
 adult fish may return in 1991.
     Another economically  significant  long-term
 effect could be the possible loss of this year's young
 herring from the affected areas.  Pacific herring are
 second  in importance only to salmon  among the
 fishery  resources  of  the area.  Their roe (eggs)
 provide one of the state's most valuable fish prod-
 ucts per unit of weight. The herring and roe fishery
 in Prince William Sound has been closed this year,
 and restrictions have  been placed  on the herring
 fishery off Kodiak because of the spill. Herring are
spring (April-May) intertidal and subtidal spawners.
They do not spawn until they are at least three years
old and return each year thereafter during their life
span to spawn in their natal areas.
   Herring eggs can  cover many  miles  of the
intertidal  zone.   They are both vulnerable  and
sensitive to oil. The eggs may be smothered and die
outright, or oil may cause developmental  abnor-
malities in the growing embryos. The persistence of
stranded oil in herring spawning  areas may affect
not just the 1989-year class but  also subsequent-
year classes.  This impact can be determined  best
by examining the spawning adults  at areas of impact
in 1992, 1993, and  1994  for the percentage of the
population recruited from spawn in 1989 through
1991.

4. Federal And State Action
       To Address Environmental Impact

    Section 311(f) of the Clean Water Act (CWA)
authorizes the President and state officials to act on
behalf of  the public as Trustees for natural re-
sources seeking recovery from  Exxon for the costs
of  restoring,  rehabilitating,  or  acquiring  the
equivalent of the injured resources.  The State of
Alaska and the  U.S. Departments of Agriculture,
Commerce, and  the Interior have  primary  trust
resources affected by the spill.
     Representatives of the Trustee agencies are
working together in Alaska to develop a plan for
assessing  the short- and long-term  effects of the
spill on their Trust  resources, the extent of the
 injury, the resulting economic damages,  and the
probable cost of restoration. This plan is scheduled
 tentatively for completion in early June.
     Exxon has agreed to make up  to $15 million
 available  initially  to  the  Trustees  to  fund  these
 damage assessments, but Trustees believe that addi-
 tional funding will be needed.  Because some of the
 potentially affected resources, such as salmon, have
 two- to seven-year life cycles, estimating the extent
 of their injury will require long-term studies.   It
 may be difficult therefore to assess fully all injuries
 and economic damages  for  a  number of  years.
 Where necessary  and  possible, restoration will
 require even more time.
                                                 •28-

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    The need for information about the environ-
mental aspects of the Exxon Valdez spill extends
beyond what will be learned as a result  of assessing
injury and economic damages to natural resources.
The President has asked Environmental Protection
Agency (EPA)  Administrator  William Reilly to
coordinate the long-range planning to restore the
environment of the sound. The expertise of leading
governmental and private  scientists and  oil spill
experts will be used in this work.  To the  extent
feasible, existing coordinating groups  such  as the
National Ocean  Pollution Policy  Board, an  inter-
agency group established  by  Congress  for the
coordination of marine pollution research develop-
ment  and  monitoring,  will  be  included.   Other
existing federal scientific advisory and coordinating
bodies will participate if possible.

5. Early Lessons Learned/
       Recommendations

o The Departments of Agriculture, Commerce, and
    the Interior, as federal Trustees for the affected
    natural resources, should work closely with the
    state trustee agency, the Alaska Department of
    Fish and Game, to plan and implement natural
    resource damage assessments as quickly as pos-
    sible.  In doing so, they should coordinate their
    activities with  response  authorities  to  avoid
    interfering with the cleanup.
o The Trustees, together with EPA, should work in
    coordination with the parties assessing  long-
    term environmental effects to avoid duplication
    and develop the  best possible scientific basis for
    restoration of Prince William Sound and other
    affected areas.
o Where applicable,  results of past studies should be
    used.  New research should be used to confirm
    earlier preliminary findings or to fill gaps.
o In future spills, damage assessment and restoration
    should begin immediately and funding options
    should be identified quickly.
o To facilitate response to future incidents, federal
    Trustee agencies should develop an automatic
    mechanism to resolve in advance such issues as
    identification of lead Trustee, management of
    assessment funding, delineation of restoration
    responsibilities,  and the allocation  of restored
    funds  recovered from joint  claims.
o Federal  agency  damage  assessment  capabilities
    should be strengthened  so that a small cadre of
    trained and experienced personnel will be able
    to go immediately to the scene of major spills in
    the future.
o States that have not  yet  done so  should be en-
    couraged to designate Trustee agencies as pro-
    vided under §107(f)(2)(B) of the Comprehensive
    Environmental Response,  Compensation,  and
    Liability Act, and §311(f)(S) of the CWA.
o Wildlife rescue efforts need to be implemented
    immediately after a spill is reported.  In addi-
    tion, research procedures should be established
    quickly to  allow data  collection required to
    develop improved rescue efforts in the future.

           B.  ENERGY  EFFECTS

1. Importance Of Alaska North Slope Oil

    Alaskan North Slope (ANS) crude oil is produc-
ed in the Prudhoe Bay area of Alaska in  the nor-
thern part of the state.  During 1988, ANS crude oil
production made  up about one-quarter  of U.S.
crude production  and about  12 percent of U.S.
petroleum consumption. Approximately two million
barrels of ANS oil per day  is transported by a 48-
inch pipeline 800 miles to the Port of Valdez.
    All ANS crude oil remains within the United
States and U.S. territories.  During 1988, about
70 percent of ANS crude oil was transported to the
west coast, and slightly over 15 percent  was trans-
ported to  the Gulf coast.   The remainder went to
the east coast, the midwest,  and the U.S. territories.

2. Market Impact Analysis

    The Department of Energy (DOE) intensified its
monitoring of available energy  supplies and fuel
prices  immediately after the  Exxon  Valdez spill
interrupted Alaskan  crude  oil shipments.  In the
three weeks following the spill, gasoline prices rose,
but this increase was only temporary. Los Angeles
spot gasoline prices  rose by 50 cents to $1.18 per
gallon at their peak on March  31. Nationally, un-
leaded regular gasoline prices increased, on average,
about 10  cents per gallon  at  both  wholesale and
retail levels. Complete data for a thorough analysis
of market responses to  this  event are not yet avail-
able.  Nonetheless, some observations and prelimi-
nary conclusions can be made.
                                                •29

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    Over the 13-day period before the Exxon  Val-
dez was refloated, the reduction of Alaskan crude
oil production was approximately 13 million barrels
(see Figure 17,  which shows pipeline throughput
quantities that are roughly equivalent to production
quantities). This amount is small by national stand-
ards.  It represents the equivalent of about 17 hours
of total national petroleum consumption and less
than two  percent of total annual production  from
the ANS which eventually leaves the Port of Valdez.
Approximately  10 million  of these 13 million bar-
rels,  however,  had  been destined for west  coast
refiners,  and that region suffered  a temporary,
disproportionate increase in retail gasoline prices.
The interruption of Alaskan crude oil  also may have
contributed to price increases by creating serious
concern regarding future supply  curtailments in
product oil markets.
 RGURE 17
 Alaskan OH Pipeline Throughput
 Millions of Gallons Per Day
 100
             Expected First Quarter Average
      24' 25" 2P 2r 28
               March
  Source: U.S. Department of Energy. Energy Information Administration, 1989.
  • No tanker transport on these days.
     In the two weeks following the spill, crude oil
  from other producing regions offset west coast
  crude oil losses by drawdown of refinery crude oil
  stocks, by drawdown of product stocks, and by
  product imports. Three weeks after the spill, other
  crude  supplies and crude oil accumulated at the
  Valdez terminal nearly  had  compensated for the
  earlier supply loss.  The  temporary  reduction in
  production should have no lasting or  permanent
  effect on gasoline prices.
     Observed west coast retail gasoline price in-
  creases, which began in February long  before the
  spill, can be attributed to several causes.  Crude oil
  prices (West Texas Intermediate)  rose from a two-
  year low of $12.58 per  barrel in  early October of
1988 to slightly above $20 by the day before  the
Exxon Valdez incident. This price increase of $7.50
per barrel translates into an equivalent increase in
product prices of 18 cents per gallon.
    Both average U.S. wholesale and retail prices of
gasoline, however, lagged behind the crude oil price
increase by about  four months.   Wholesale price
increases due to the crude oil increase had begun to
rise before the Exxon Valdez incident. Yet average
U.S. gasoline retail prices for the nation as a whole
had remained essentially unchanged over the period
from early October 1988 to mid-March of 1989.
Other factors also  may have contributed to the  rise
in west coast gasoline prices since February.  These
factors include: strong seasonal gasoline demand,
lower  refinery gasoline inventories due to routine
seasonal refinery  maintenance,  and  new gasoline
specifications  that  reduce  vapor emissions  but
increase refining costs.
    Fortunately, shortages have not occurred. Prices
in California have fallen from their reported peaks.
In  the week ending April 17,  Los  Angeles spot
gasoline prices fell from $1.18 per gallon to $0.79
per gallon. Market forces have operated to provide
California markets with energy following the brief
interruption of Alaskan crude oil.

3.  Early Lessons Learned/
        Recommendations

o A variety of factors contributed to product price
    increases observed following the Exxon  Valdez
    spill.  Among  these factors may have  been
    concerns regarding future supply curtailments in
    product  markets.  Overall,  however,  market
    forces appeared to have operated efficiently to
    meet energy demands.
 o Despite the tanker transportation safety record out
    of Valdez,  an incident like the Exxon  Valdez
    accident can  crystallize public opinion against
     the petroleum industry almost instantaneously.
 o Conflicts need to be resolved on issues such as the
     use of dispersants, the risk of fire, and the state
     of readiness.
 o Workable oil spill contingency plans and suffi-
     ciently trained response personnel, along  with
     policies and  practices to police the industry
     workforce, must be in place.   Industry  must
     operate at all times with a clear recognition of
     the importance of environmental safeguards and
     adequate  responsiveness.    Most important,
     environmental  protection should  not  be  just
     another regulatory burden, but the watchword
     of every aspect of operations.
                                                  •30

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C.  EFFECTS ON THE ALASKAN ECONOMY
    The natural resources of the areas affected by
the Exxon Valdez spill are important to Alaska's
local and statewide economy.  While it is too early
to know the full  extent of the economic conse-
quences of the spill, the local  and state economies
are likely to suffer economic losses in the following
categories.

1. Commercial Fisheries
    Prince William Sound possesses rich commercial
fisheries for Pacific herring and salmon, along with
smaller halibut, sablefish, crab, and shrimp fisher-
ies.  These fisheries are used on a permit basis by
commercial fishermen from as far away as Anchor-
age and Seattle.  The Alaskan  fishing ports nearest
the  sound  are  Cordova,  Seward,  Homer,  and
Kodiak.  Cordova, probably the  most affected of
the fishing ports, is the third largest in Alaska and
the ninth largest in the United States in terms of the
dollar  value  of  commercial  fishery  landings.
Kodiak is the largest Alaskan  fishing port and the
second largest in the United States.
    Together,  these two ports  had  commercial
fishery landings of all species valued at $174 million
in 1987.  This catch represented over  18 percent of
the total for Alaska and nearly six percent for the
United States in that year. An estimated one-third
of Alaska's nearly  12,000 full- or part-time fisher-
men in  1987 worked in the area now affected by
the spill.
    Prince William Sound's herring and herring roe
fishery (valued at $14 million in 1988) usually opens
in early April. Out of concern for additional harm
to the stocks and possible  contamination of the
product, the Alaska Department of Fish and Game
closed the herring fishery after the spill and recent-
ly restricted part of the herring fishery off Kodiak.
It is unknown at this time whether or not the $33-
million  pink salmon fishery in  the sound, which
reaches its peak in July and August, will be closed
or restricted for similar reasons.
    Closings  or restrictions  will  harm  not only
fishermen but also the area's important fish process-
ing industry.  This industry employs an estimated
3,000 to  4,000 people annually.   The  State of
Alaska, with technical assistance from the Food and
Drug Administration (FDA), is taking precautions
to assure that oil-tainted fish products do not reach
the market.  The state is assigning 40 extra inspec-
tors to the processing  plants serving the affected
area and will continue to close fisheries, if neces-
sary, to protect the public (see  Section D below).
If, despite these measures, consumers avoid Alaskan
fish products, the national prices for those products
may be depressed temporarily.
    With the spill still spreading, the full economic
impact on commercial fishermen is unknown.  The
immediate economic losses of many local fishermen
are being mitigated by their employment in Exxon's
clean-up efforts.  Fishermen in the affected area
remain deeply concerned not only about their long-
term economic prospects, but also about possible
changes in their way of life.

2. Recreation

    Recreation and tourism have been increasing
rapidly  in Prince  William Sound over the  last 10
years. In the late  1970's, cruise ships did not visit
the sound, but, by 1987, ship visits had reached 88
per  season.   In the same  year,  an estimated  1.8
million  people visited Prince William Sound  for
recreation purposes.  Much of the recreation and
tourism in Prince William  Sound  and the Kenai
Fjords National Park is related to the outstanding
scenic beauty of the area and its pristine wilderness
character.   The  Alaska National  Interest Lands
Conservation Act (ANILCA) created a 2.3-million
acre wilderness study area in Prince William Sound.
    The oil spill can be expected to affect tourism
and recreation in the affected region of Alaska at
least through the approaching summer season.  The
tourist industry already is  reporting  higher than
normal cancellations on bookings for this summer.
The  magnitude and duration  of these  adverse
consequences will  depend in part on the speed and
effectiveness of the cleanup  and  in  part  on  the
public's perception of its effectiveness in restoring
the  wildlife  and  scenic areas  to  their  pre-spill
condition. The spill is not expected to have a major
detrimental impact on travel and tourism in the rest
of Alaska.
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3. Native Villages
    Native villages such as Tatitlek and Chenega on
the shores of Prince William Sound depend on the
animals,  birds, fish, and plants of the sound and
surrounding lands  for their food. The existence of
their traditional culture depends on the continuation
of this subsistence economy.  Losses or reductions
in the availability of wild food sources cannot be
measured adequately  in  dollars.   Although the
Natives are gaining some employment opportunities
from  Exxon's clean-up efforts, they remain deeply
concerned about the long-term effects of the spill
on their subsistence culture.  There also is concern
that beached oil and its cleanup may either destroy
cultural  resources   or   affect   the  ability  of
archaeologists to carbon date early sites.  No single
mechanism  is in place at this time through which
Alaska Natives can provide inputs on their par-
ticular concerns,  or receive  assistance  for their
claims and subsistence needs.

4. Timber
    Neither the oil spill nor its cleanup is expected
to affect timber harvesting on national forest lands
around Prince William Sound and on the Kenai
Peninsula, and economic losses are unlikely.  Some
delay, however, in harvesting on Native Corporation
and national forest lands on Montague Island may
result from the spill.  The U.S. Forest Service has
had to extend the review period for the draft En-
vironmental Impacts Statement because of oil spill
response activities.

5. Early Lessons Learned/
        Recommendations
 o The Department of the Interior, working with the
    State of Alaska and local  Native leadership,
    should  assist  individual  Alaska Natives  and
    Native organizations in providing  input into
    clean-up planning and filing claims  for econo-
    mic losses.  This assistance should include the
    emergency provision of subsistence needs wher-
    ever required as a direct result of the spill.
 o There is no existing legislation that allows im-
    mediate aid to the local population affected by
    the spill. In this incident, Exxon mitigated some
    of the economic losses to fishermen, Alaskan
    Natives, and  other Alaskans  through employ-
     ment in the clean-up effort. Had there not been
     a responsible party who willingly assumed this
     financial burden, there would have been no
     immediate  financial  relief  available  to the
     affected population.
           D.  HEALTH EFFECTS

   Potential human health impacts from the Exxon
Valdez oil spill include those associated  with  ex-
posure to contaminants either directly or through
the food chain; stress associated with loss of lifestyle
and possible economic impacts; and hazards workers
may encounter during clean-up operations.

1. Food Safety
    It is important to keep dead fish and  mammals
out of the food chain and allow harvesting of sea-
food only when its safety has been assured. Cur-
rently, organoleptic (sensory) testing is being used
to determine whether fish and shellfish should be
consumed.   This testing method  can  be used to
determine  freshness and  presence of  volatile oil
components.  The FDA is now training state sani-
tarians in organoleptic techniques.
    To ensure food safety properly over the  long
term, however, a system involving both organoleptic
and chemical analytic testing needs to be developed.
FDA and other agencies and experts are  obtaining
information  on the characteristics of crude oil,
accumulation and dissipation of oil components in
fish and shellfish, analytical methodology, organo-
leptic detection in fish and shellfish, and toxicity
data relative to long-term consumption of oil com-
ponents. Information developed from these sources
will be evaluated, particularly in terms of the  type
of food safety program needed.

2. Mental Health
    With  the assistance of  a contracted  disaster
psychologist, the State of Alaska is now assessing
the nature and extent of mental health  problems
 resulting from the spill among emergency workers,
 fishermen,  and others and  present capabilities to
 address these problems. The state plans to enhance
 the service capabilities of its system based  on this
 assessment.   The  state will seek payment  from
 Exxon for short-term supplemental assistance to the
 mental health system.  U.S. Health  and Human
 Services agencies such as the Alcohol, Drug Abuse,
 and Mental Health Administration (ADAMHA) are
 prepared to  offer technical  and other support.
                                                 •32

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3. Occupational Health And Safety

   Since the spill, Exxon has employed boat owners
to assist in skimming  and  booming  operations.
Exxon estimates the company will  hire between
2,000 and  5,000  people to clean up oil-covered
shoreline.  This cleanup  is expected to continue
through the summer.   The potential for worker
injury and  other problems exists.
   Workers have expressed concern to  both state
and federal authorities about safety and health risks
in performing  clean-up operations.  These risks
include: inhalation exposure to volatile, and dermal
exposure to non-volatile, components of crude oil;
exposure to chemical dispersants; stress  from long
hours; possible physical injury and hypothermia;
and lack of available information about  the  health
effects of materials being  used.
   Regulations that address these concerns  are in
place.  Alaska's Department of Labor is providing
advice to Exxon on personal protective equipment
and  required training  in  hazard recognition  and
prevention. The state  also has established a field
headquarters in Valdez to improve communications
and monitor events. In accordance with the regula-
tions, a  field  headquarters for  the Occupational
Safety and Health Administration (OSHA) has been
established in  Valdez,  and Exxon  has set up  a
training  program  for  the clean-up crews.   The
program covers areas  such as   proper  clothing,
hazard recognition, and first aid  and injury proto-
cols.
4. Early Lessons Learned/
       Recommendations
Short—term
o FDA and  the State of Alaska should undertake
    biological monitoring of potentially affected fish
    and mammals in the spill area on a continuing
    basis.  Strict guidelines for reporting and com-
    paring analytic data should  be  determined in
    collaboration  with  the  Centers for  Disease
    Control (CDC) and the Agency for  Toxic Sub-
    stances and Disease  Registry (ATSDR).  All
    relevant information  should be disseminated
    centrally within the State of Alaska.
o The mental  health system should be  monitored
    continually by the State of Alaska, supported by
    ADAMHA, to  ensure  its adequacy to meet the
    mental health needs of the  population.
o Worker training,  appropriate  protective  equip-
    ment, and occupational safety and  health sur-
    veillance should continue to  be emphasized  by
    Exxon and coordinated with OSHA, organized
    labor,  the  Alaska State Department  of Health,
    and  the National  Institute  for Occupational
    Safety and Health.
o The State of Alaska's  Health Department  has
    relayed concerns from workers and the com-
    munity regarding long-term effects of exposure
    to oil  chemicals and clean-up chemicals, and
    long-term effects of consuming food possibly
    contaminated  by  these  chemicals.   The U.S.
    Department of Health  and Human Services
    (primarily through ATSDR, CDC,  and  FDA)
    should continue to provide any needed technical
    assistance  to the state to assess the long-term
    health effects of exposure  to the spill of crude
    oil, its degradation products, and  dispersants
    used in the clean—up effort.
                                                •33

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                         VI.  LIABILITY AND COMPENSATION
  A.  DESCRIPTION OF COMPENSATION
        AND LIABILITY PROVISIONS
   Exxon's exposure to liability for the grounding
of the Exxon  Valdez stems from  the Clean Water
Act (CWA), the Trans-Alaska Pipeline Authoriza-
tion  Act  (TAPAA), general maritime  law, and
Alaska state law.
   Although aspects of both §311 of the CWA and
TAPAA  apply to the Exxon Valdez  spill, it is
unclear to what extent they may both be applicable
or how they will interrelate. As indicated, state and
general maritime tort laws also apply, but the legal
complexities of the incident ultimately may require
resolution in the courts.
   Under the CWA, an owner of a vessel is liable
for both clean-up costs that may be incurred by the
federal  government and  for damage  to natural
resources under the trusteeship of the federal and
state  governments.  Absent a successful defense,
Exxon has approximately a $14.3  million liability
cap.  If "willful  negligence or willful misconduct"
can be proven, however, Exxon's liability under the
CWA is unlimited. Without proof of willful negli-
gence or misconduct, §311(f)(l) of the CWA limits
Exxon's liability to $150 per gross ton of the vessel
($14.3 million). Each natural resource damage claim
is prepared by the Trustees:  the Department of the
Interior,  the  National Oceanic  and Atmospheric
Administration  (NOAA)  of the  Department  of
Commerce, the Department of Agriculture, and the
State of Alaska.
    Section 311(k) of the CWA authorizes creation
of a revolving fund to finance, among other things,
the removal of oil and hazardous substances spilled
 from vessels.  The §31 l(k) Fund has been used since
the first day of the spill.  It has not been used to
 finance federal removal costs; rather, it has served
as authorized by the CWA to facilitate Exxon's use
 of federal resources.   As of  April 14,  $13  million
 had  been spent or obligated  from this fund in
 connection  with the use  of  those   resources.
 Through that date,  Exxon had reimbursed the
 §311(k) Fund a total of nearly $10 million.
    The Trans-Alaska Pipeline Liability Fund (the
 TAP Fund)  is available  to pay  damage  claims
 resulting from spills of oil that has been transported
 through the Trans-Alaska Pipeline and loaded on a
 vessel to be carried to another U.S. port. The TAP
 Fund was created as  part of the statute in which
 Congress authorized the construction and operation
of the Trans-Alaska Pipeline  in  1974.   Money
charged on each barrel of pipeline oil loaded on a
vessel financed the fund. The amount of money
currently in the fund is approximately $250 million.
   Under the statute and the regulations promul-
gated by the Secretary of the Interior to govern the
TAP Fund's administration, the owner and operator
of the vessel from which the oil is spilled are each
strictly liable for the first $14 million in damages
resulting from the oil spill. Owners and operators
of vessels are required  to furnish proof of their
financial responsibility for this liability.  Owners
must present the proof before their tankers may be
loaded with North Slope  crude oil at the pipeline's
terminal in Valdez.
    Accordingly,  under the statute and regulations
Exxon is liable for the first $14 million in claims.
Once that amount is paid, the industry-supported
TAP  Fund provides an  additional  $86 million for
claims.  The TAP Fund has the right to recover
money it has paid on claims if it can be shown that
Exxon was negligent or that the Exxon Valdez was
unseaworthy.  Under those circumstances, Exxon's
total liability under the TAP Fund could reach $ 100
million.   TAPAA  specifically  does not preclude
recovery under state or other federal law.
    TAPAA covers  all  damages, including either
public or private clean-up costs sustained by any
person or entity.  It also covers claims by Canadian
residents.  If total claims exceed $100 million, each
claim for TAPAA funds is reduced proportionately.
In such a case, the TAP Fund considers claims after
the  response  is  completed and  total claims are
known.  The TAP Fund is not designed to support
ongoing response actions.
    When spills of oil from tankers carrying North
Slope crude  oil  occur,  the  owner and operator
designate a single contact person who coordinates
 with the TAP Fund the resolution of claims arising
 from the spill. For spills exceeding a projected $14
 million in damages, the TAP Fund advertises avail-
 ability of the Fund and the person to whom claims
 should be directed.
    Exxon has designated a contact person to coor-
 dinate actions with the TAP Fund and is processing
 claims.  The TAP Fund will publish an advertise-
 ment in the very near future specifying that claims
 should be presented to Exxon.  The advertisement
 will  set forth addresses and telephone numbers for
 presentation of claims.
                                                •34

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   The §311(k) Fund had only $6.7 million avail-
able  when the spill  occurred.   The fund has an
authorized ceiling of $35 million, but its highest
end-of-year  balance  was $24.8 million in 1985.
Since fiscal year  1986,  the  balance has been less
than $12 million.  In part, this situation was due to
the anticipated passage of proposed, comprehensive
oil spill legislation.
   There  is no  corresponding fund  to   finance
natural  resource damage assessments.  Money for
natural resource damage assessments can be placed
in the §31 l(k) Fund by the discharger for the use of
Trustees.   Initially, the natural resource  Trustees
funded a preliminary assessment by diverting funds
from other programs.  The federal and state natural
resource trustees, working in conjunction  with the
Department of Justice, approached Exxon and were
able  to obtain a $15 million commitment for initial
funds to begin natural resource damage assessments.
   If Exxon had not voluntarily assumed financial
and clean-up responsibility for the spill, the §31 l(k)
Fund probably would have been rapidly expended.
Furthermore, there might not have been adequate
money available  for  resource damage assessment
and  restoration.  Legislation under  consideration
would create a new  fee-based  fund with a sig-
nificantly higher balance than in the §311(k) Fund
and  liability regime.   This  new fund  would  be
available not only for cleanup, but also for  resource
damage assessment and third party damage recovery.
      B.  EARLY LESSONS LEARNED/
           RECOMMENDATIONS
o Congress should enact comprehensive oil  spill
   liability and compensation provisions along the
   lines of the legislation proposed by the Admini-
   stration.  It should include implementation of:
   (1) the 1984  Protocols  to  the  International
   Convention on Civil Liability for Oil Pollution
   Damage, 1969 and (2) the International Conven-
   tion on the Establishment of an International
   Fund for Compensation for Oil Pollution Dam-
   age, 1971.  Enactment of such legislation would
   make  available means in  all  cases to address
   adequately oil tanker spills that could extensive-
   ly damage our coast.
o The  relationship between  liability requirements
   under the Clean Water Act and other statutes is
   undefined and could result in costly and exten-
   sive litigation. Both total liability and necessary
   compensation in the case of the Exxon  Valdez
   spill remain  undetermined.  Cleanup,  natural
   resource restoration, and third-party damages
   will be enormous.  Had  Exxon not  made vast
   sums of money available rather quickly, or had
   the discharger been unreachable, foreign, or less
   solvent, the patchwork of  existing federal and
   state law  applicable to a pollution  incident of
   this magnitude would have been inadequate.
o Laws and regulations on  handling the §311(k)
   Fund need to be analyzed. Money  to finance
   natural resource damage assessments currently
   is being placed in the pollution fund by Exxon
   to  be  disbursed  to natural resource Trustees.
   The Coast Guard is responsible  for  receiving
   and disbursing that money to the Trustees. The
   responsibility of the Coast  Guard, vis-a-vis the
   Trustees,  however, is  undefined and requires
   further review.
o The Clean Water Act needs analysis in relation to
   other existing law to determine whether other
   issues associated  with major marine disasters
   resulting in large spills are addressed adequately.
   In  particular, the need for additional criminal
   sanctions,  civil  penalties, and  judicial and
   administrative order authority should  be ex-
   amined.
                                                •35

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           VII.  GENERAL LESSONS LEARNED/RECOMMENDATIONS
   The Exxon  Valdez oil spill severely tested this
country's existing oil spill preparedness and response
capabilities.  It revealed shortcomings that require
immediate attention.  While definitive  conclusions
about many aspects of the incident remain prema-
ture, a number of important lessons and recommen-
dations  have emerged  in the course of developing
this report.  Significant actions to prevent or miti-
gate the impacts of similar tragedies  already are
underway.   Certain  steps  that  warrant careful
attention in the near future can be identified.

Steps that Already Have Been Initiated
o Several  investigations,  independent of this NRT
    report, are underway to investigate the cause of
    the  spill.  The National Transportation  Safety
    Board, Coast Guard, State of Alaska, and other
    authorities concurrently are looking into  dif-
    ferent aspects of the spill. These investigations
    will create a more complete picture of its causes
    and suggest strategies for strengthening preven-
    tion.
o The President has asked the Environmental Pro-
    tection  Agency  Administrator to  coordinate
    long-range planning to restore the environment
    of Prince William Sound. The Administrator is
    establishing a task force to this end. This task
    force will bring together the expertise of leading
    government and  private  scientists and the
    interest of the public in an advisory capacity.
    This  work will yield important  information
    particular to Prince William Sound and will
    advance our general state of knowledge con-
    cerning  both  the long-range environmental
    impacts of oil spills and ways of ameliorating
    their  impacts.
 o Comprehensive oil spill liability and compensation
    legislation  is pending.   Such legislation is  a
    necessary prerequisite  to  ratifying the  1984
    Protocols to the 1969 Civil Liability and  1971
    Fund Conventions.  These steps will address a
    number of troubling questions about the extent
    of corporate liability for oil spillers world-wide.
o A number of  federal agencies  are coordinating
   closely with  the State of Alaska to undertake
   natural resource  damage assessments to learn
   about  the short- and long-term environmental
   effects of the spill, resulting economic damages,
   and the probable cost of recovery. These stud-
   ies will pave  the way for further steps to reduce
   adverse environmental and economic effects.
o Under  the leadership of  the Coast  Guard, the
   National Response Team (NRT) is conducting a
   six-month  study  of  contingency planning.
   Preparedness must be improved. The study will
   examine the use of  worst-case scenarios to
   ensure realistic  planning and the need  for
   thorough testing  of plans with exercises.   The
   study  will address questions associated with the
   adequacy of equipment and  personnel for an
   effective response, and the importance of well-
   defined organizational responsibilities.
o A  panel of scientists has been established to
    review the feasibility of using bioremediation
   techniques to clean up oil spills and to design
   demonstration projects to evaluate these tech-
    niques for use after oil spills.

Long—term Goals
o Improved response coordination between federal,
    state,  and local authorities can facilitate rapid
    clean-up actions. Complications associated  with
    the Exxon  Valdez oil  spill response highlight
    the importance  of smooth  coordination.   A
    better way  of incorporating  the  concerns of
    states into the National Response System (NRS)
    should be developed. The NRT also will under-
    take a program to improve understanding of the
    National  Response System  among top local,
    state, and federal  officials.   Improved under-
    standing is an essential basis for smooth coor-
    dination.
 o The NRT must initiate a study of ways to improve
    the National Contingency Plan (NCP). The NCP
    has been effective  in minimizing environmental
    and health  impacts from accidents for over 18
    years, but changes that ensure the optimum re-
    sponse structure for releases or spills of national
    significance require study.
                                                 •36

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o Attention should  be paid  to  Native Alaskans
    whose livelihoods  have been affected by  the
    spill and whose cultural practices may have been
    threatened. Short-term and long-term  steps to
    mitigate economic and mental health  impacts
    may be required. The Department of Interior,
    working with  the State  of Alaska and local
    Native leadership, will work together to  provide
    assistance.
o Steps must be taken  to improve overall planning
    for, and care of, wildlife affected by oil spills.
    Contingency planning should be expanded to
    prepare properly for wildlife impacts.  Signifi-
    cant  actions  to prevent  or  mitigate  similar
    tragedies already are underway.
o The Exxon Valdez incident emphasized the need
    for greatly improved public and private research
    and development capabilities.  Current response
    equipment is still inadequate in less than ideal
    conditions. Better mechanical, chemical, and
    biological  strategies for  cleanup are  needed.
    The incident revealed how little we know about
    cold-water oil  spill responses.   The  oil spill
    showed  the need  to  develop beach-cleaning
    techniques  that  are more effective and less
    labor-intensive.
o Possibilities  to strengthen existing international
    ties should be  explored.   Working  through
    federal agencies involved in established organi-
    zations, agreements addressing available equip-
    ment and personnel for spills of this magnitude
    should be pursued.  Better coordination  of joint
    efforts  to transport and stage equipment from
    other countries would enhance response capabil-
    ities.   Joint  research and development and
    information sharing agreements between nations
    also warrant consideration.
                                                •37

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                                 APPENDIX A.  CHRONOLOGY
                (Derived from U.S. Coast Guard Pollution Reports.  All times are local.
                          Hours of daylight are roughly from 0600 to 2200.)

MARCH 24, 1989  (FIRST DAY)

                     0028 Marine Safety Office (MSO) Valdez receives notification from Exxon Valdez
                           reporting that the vessel was hard aground on  Bligh Reef.  The vessel was
                           loaded with 1,264,155 barrels (53,094,510 gallons) of North Slope crude oil.
                           While maneuvering to avoid  glacial ice, the vessel left the tanker lanes and
                           struck bottom on a 30-foot charted shoal  on Bligh Reef.  The vessel's draft
                           fore and aft was 56 feet. Approximately 510,000 gallons of crude oil released.
                           Initial assessment of pollution extent and shoreline impact could not be made
                           with any degree of accuracy due to darkness.

                     0030 Captain of the Port (COTP) at MSO Valdez closes Port of Valdez to all traffic.
                           The tug Stalwart is dispatched from Alyeska Marine Terminal to assist Exxon
                           Valdez.

                     0100 Pilot  boat is  made  available to  transport Coast  Guard  (CG) and  Alaska
                           Department of Environmental Conservation (ADEC) pollution personnel to
                           the scene.

                     0105 Alaska RRT Chairman for this incident is notified.

                     0148 MSO Valdez contacts Air Station Kodiak  requesting helicopter overflight at
                           first light.

                     0206 Attempt to refloat Exxon Valdez at high tide unsuccessful.

                     0227 Motor vessel (M/V) Shelikoff reports oil slick to half mile south of Exxon
                           Valdez.

                     0249 Pacific Area (PACAREA) Strike Team assistance requested.

                     0323 CG personnel now aboard Exxon  Valdez.  Tanks gauged:  about  138,000
                           barrels (5.8 million gallons) lost from  wing tanks 1, 3, 5 starboard, starboard
                           slop tanks, and number 5  center tanks.

                     0330 Initial response efforts at the Port of  Valdez  under Alyeska's  control are
                           hampered  by  equipment casualties and  holiday personnel shortages.  As
                           response personnel arrive at the Alyeska Terminal, however, Alyeska is unable
                           to comply  with the response timeliness provision in its own contingency plan
                           that calls  for initial  response  at the vessel  within  five hours  of  first
                           notification.
                                Alyeska's only containment barge is tied up at Valdez Terminal, stripped
                           for repairs. Barge was not  certified  by the CG to receive oil, but  it could
                           carry recovery bladders. Alaska's state contingency plan requires Alyeska to
                           notify the state when response equipment is taken out of service. Satisfied the
                           barge was  seaworthy without repairs,  Alyeska had not done so.
                                Before barge could be used, pollution gear had to be loaded.  Crane
                           riggers called at 0330.  By this time, CG estimates 5.8 million gallons already
                           discharged from the tanks.
                                          1 Appendices-1

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0400  Stability of Exxon Valdez is CG's highest priority.  The biggest concern is
      that the vessel  might capsize and break up, spilling  the entire 53 million
      gallons of oil. Word is passed to Alyeska to assemble oil transfer (lightering)
      equipment (six-inch hoses and fenders to transfer oil  from Exxon Valdez to
      recovery vessels, bladders or other containers).

0414  Tank vessel (T/V) Exxon Baton Rouge contacted and is enroute to initiate oil
      transfer operations.

0500  CG small boat dispatched to survey the area.

0727  Alyeska Marine Terminal  security helicopter aloft for overflight with CG
      investigator aboard. Analysis of videotape taken by the investigator showed
      the slick to  be  1,000 feet wide by  four miles  long.  Sheen  extends in a
      southerly direction with minimal contact with shoreline.
1115




1140


1145


1200


1230
1310


1510


1645


1700


1800



1820

2010

2030

2154
The Federal  Aviation  Administration (FAA)  imposes  temporary  flight
restriction around Exxon Valdez.  Rate of discharge from Exxon Valdez is
slowing. Exxon Baton Rouge arrives at location of grounding and begins to
rig fenders for coming alongside to begin oil transfer operation

H-3 helicopter overflight observes extremely heavy oil 20 to 30 feet from the
side of the vessel.  Calm sea is slowing the movement of the oil.       ;

COTP imposes 500-yard safety zone  around grounded vessel.   Notice to
Mariners broadcast begins.
Regional  Response Team  (RRT) teleconference commences.
includes use of dispersants and in-situ burning.
Discussion
Alyeska barge arrives at Bligh Reef, seven hours after the five-hour initial
response time required by Alyeska's contingency plan.  Oil slick is already
1,000 feet wide and four to five miles long.   The barge arrives with two
skimmers in tow, two 1,000-gallon bladders, and 8,000 feet of containment
boom for a spill of 10 million gallons.  The two on-scene skimmers begin
recovering oil near the Exxon Valdez.

MSO Valdez estimates quantity released is now 250,000 barrels (10.5 million
gallons).

On-Scene Coordinator (OSC) grants permission for dispersant test on leading
edge of sheen.

CG 32323 underway with State of Alaska Governor Cowper and assistants on-
board.

CG  32323 drops off Governor Cowper and assistants.  They board Exxon
Valdez.

Dispersant trial application  is conducted with less than satisfactory results,
due to lack of mixing energy. Use of dispersants is deemed inappropriate at
this time.

PACAREA Strike Team members arrive in Cordova, Alaska.

Exxon Baton Rouge alongside Exxon  Valdez, port-to-port.

Contract divers arrive on scene.

Exxon Baton Rouge made fast alongside Exxon Valdez.
                     Appendices-2

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                     2215  First oil transfer hose connected.

                     2338  Second oil transfer hose connected between the two vessels.
MARCH 25, 1989  (SECOND DAY)
                     0015  Tug Jeffrey Foss on scene with 30,000-barrel tank barge to receive recovered
                           oil.

                     0736  Oil transfer operations begin, with cargo transferred to Exxon Baton Rouge.

                     0745  OSC reports that loss of additional oil has ceased.

                     0750  Commercial divers complete underwater hull survey showing holes in 11 tanks.
                           Exxon Valdez  had been grounded from the number two tank aft to  the
                           number four tank. The vessel's designer advises CG that ship is not floatable
                           and that a major salvage operation will be required.  Meanwhile, oil transfer
                           to the Exxon Baton Rouge continues at a rate of 10,000 to 12,000 gallons  per
                           hour. Water replaces cargo to maintain ballast.

                     0830  Alyeska pipeline representative advises that pipeline flow has been slowed to
                           768,000 barrels per day.  At this rate,  Alyeska has seven days of storage
                           capacity.

                     0833  USCGC Rush is ordered to put CG personnel aboard T/V Oriental Crane and
                           to proceed with all haste to Exxon Valdez site and establish a command and
                           control platform.  USCGC Sedge is ordered to Prince William Sound to assist
                           OSC.

                     0845  Oil transfer operations suspended as on-scene crews reevaluate the situation.

                     0930  Ms. Alice Berkner of International Bird Rescue and Research Center arrives
                           in Valdez to set up facilities for treating oiled animals.

                     0945  On—Scene RRT agency representatives hold a meeting at MSO  Valdez with
                           teleconference following at 1110.  Dispersant trial application planned utilizing
                           C-130 cargo aircraft. Exxon Shipping Company assumes management of spill
                           and financial responsibility.

                     1100  Exxon Valdez surrounded by containment boom.  USCGC Rush on scene to
                           assume air traffic control functions.

                     1145  CG Commander  of  the  Pacific Area (PACAREA) requests   AIREYE
                           surveillance from the Atlantic Area Commander.

                     1200  Second hull survey conducted with video cameras by dive team.

                     1230  Some oil released as transfer operations begin again.  Oil transfer had been
                           delayed due to  piping damage.

                     1330  FAA in Anchorage is mobilizing air traffic  control team to set up temporary
                           control tower (seven personnel) at Valdez Airport.

                     1900  RADM Nelson, Commander Seventeenth CG District,  arrives on scene.

                     1930  Clean-up crews report 1,200 barrels of oil recovered.

                     2000  Dispersant trial application conducted  by C-130 with inconclusive results.
                           Another test to be conducted on  March 26 under optimal light conditions
                                          1 Appendices-3

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                     2010 Exxon Valdez had transferred 11,000 barrels of oil to Exxon Baton Rouge
                           before suspending oil transfer operations. Second test of ships cargo transfer
                           system will be conducted on the morning of March 26.

                     2015 Exxon completes initial mapping of the area to determine the extent of the
                           oil spread and impact.  Bird rescue operation instituted by Exxon.

                     2045 Burn test conducted near Goose Island with approximately 100 square feet of
                           tar left as a residue. An estimated 15,000 gallons of oil were consumed.

MARCH 26, 1989  (THIRD DAY)
                     0530 CG Strike Team members join responders on Exxon Valdez.  Earlier they had
                           staged an Open Water Oil Containment and Recovery System (OWOCRS) for
                           loading onboard USCGC Sedge.

                     0900 Exxon has assigned over 100 people including Exxon, Alyeska, and contract
                           personnel to clean-up operation.  Another 200 people are on standby.

                     0643 CG reports shipment of one MARCO skimmer from Elmendorf Air Force
                           Base, Alaska.   Twenty people transported to Bligh Island to survey beach
                           cleanup and bird and wildlife impact.  75  oiled birds reported sighted  by
                           Department of the Interior (DOI) personnel.  Birds include White Wing
                           Scoters, Old Squaw, and Golden Eye ducks.  Most oiled birds sighted on west
                           side of Bligh Island.  Two oiled sea otters sighted.  DOI estimates that 3,000
                           seabirds and several hundred sea otters live in area of Knowles Head to Galena
                           Bay.

                     1045 Three CG personnel arrive from MSO Anchorage to assist.

                     1115 CG personnel  and  members from ADEC and Exxon confer on state efforts
                           for protecting  sensitive areas on north side of Bligh Island.

                1123-1510 USCGC  Sedge arrives on  scene north of Bligh  Reef.   USCGC Sedge
                           dispatches small boat to recheck proper positioning of navigational equipment
                           within the sound, maintaining navigation safety levels.

                     1400 Skimmers have recovered 2,275 barrels of oil from the water.

                     1500 National  Transportation Safety Board (NTSB) representatives board Exxon
                           Valdez.

                     1600 Dispersant application  conducted  with  C-130, equipped with Beigart Air
                           Deliverable Dispersant  System (ADDS) system.  Results are satisfactory.

                     1700 46,256 barrels of oil transferred to Exxon Baton Rouge.

                     1800 Skimmers recover 3,004 barrels of oil.

                     1830 Governor Cowper declares a state of emergency.

                     1900 51,064 barrels  transferred to Exxon Baton Rouge. Commercial divers conduct
                           survey with the use of  video equipment.

                     2000 Additional survey by divers reveals port tanks intact.  Some distortion is
                           evident.
                                          1 Appendices-4

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MARCH 27, 1989  (FOURTH DAY)
                           High winds seriously impair response operations. Overnight, gusts clocked as
                           high as 73 miles per hour have driven the spill nearly 40 miles into Prince
                           William Sound, coating beaches at Little Smith, Naked, and Knight Islands.
                           Skimmer systems, booms, and other equipment had to be moved to sheltered
                           water for protection.

                      0542 USCGC Rush launches HH-65 helicopter to provide OSC and key response
                           personnel an overflight view of the spill. USCGC Rush continues to enforce
                           air space restrictions.
                      1100 90,599 barrels of oil have been transferred to Exxon Baton Rouge.

                      1245 CG overflight reveals that  oil pooled up southwest  of  Exxon  Valdez has
                           formed dark, emulsified ribbons.  Entire north and northeast side of Smith
                           Island is heavily affected by thick oil.   Some oil  reaching Seal Island.  Oil
                           glancing eastern end of Naked Island is a lighter  sheen, containing smaller
                           ribbons.  No recovery of oil since 1800, March 26.

                      1330 RRT assembles for a  teleconference.  The staging of sorbent materials at
                           sensitive beaches is planned for areas in the path  of the oil spill trajectory.
                           Exxon is informed of the need for beach clean-up crews.

                      1900 124,299 barrels of oil  have  been  transferred from Exxon Valdez to Exxon
                           Baton Rouge.
                                CG overflight reports heavy shoreline contamination on northeastern end
                           of Knight Island.   Large pools of oil appear in the bays and  inlets of the
                           island. Oil heavily affects Eleanor Island moving  west around north end of
                           island.  High winds move spill beyond sites initially selected for recovery
                           operations
                                At  the  RRT  teleconference,  permission  is  given  for  dispersant
                           application.  Scheduled dispersant application did not  take place, because
                           aircraft did not arrive at authorized site.  Virtually all mechanical recovery
                           operations have ceased.
                      2100 3,000 barrels of oil recovered.

MARCH 28, 1989  (FIFTH DAY)
                      1000 Additional PACAREA Strike Team equipment arrives in Valdez.

                      1010 Exxon requests use of dispersants and in-situ burning around Eleanor Island
                           (Zone 3). RRT considers dispersant use in this area inappropriate.

                      1030 USCGC  Sedge informs OSC that no oil is in Main or Eshamay Bay.  Work
                           crews are setting booms in both areas.

                      1120 ADEC approves  in-situ burning  permit for area around  Eleanor Island.
                           PACAREA Strike  Team reports 226,874 barrels transferred  from Exxon
                           Valdez to Exxon Baton Rouge.

                      1200 CG overflight  from 0800 to 1130 indicates oil has reached beaches  on all
                           islands from northeastern side of Storey Island, Naked  Island, Eleanor Island,
                           Ingot Island, and  Knight Island down to the Bay of Isles  area on Knight
                           Island.   Heavy oil slicks are  found  between Naked and Eleanor Islands,
                           extending in a westerly direction out into  Knight  Island passage.
                                Heavy oil impact on Smith and  Little Smith Islands, with  moderate
                           contamination  on the eastern  side of Green  Island.  A major  clean-up
                           mobilization is initiated to protect critical  fishery  resources in Eshamay Bay,
                           Main Bay,  Port  San Juan, and  Esther  Bay.   Response  management  is
                           reorganized formally as a steering committee consisting of CG, ADEC, and
                           Exxon.

                     •————•——— Appendices-5          	                    —•

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r
                                1230
          Major operation mobilized to protect fishery resources in Eshamay Bay,
      Main Bay, Port San Juan, and Esther Bay.

      Exxon-chartered C-130 applies dispersants in areas of heavily concentrated
      oil.  Minor discharge of oil from  Exxon Valdez.  OSC  authorizes use of
      dispersants.
                          1300-1530 Exxon dispersant operation conducted near vicinity of Exxon Valdez.  Exxon
                                     reports excellent results.  Dispersant operation also conducted off eastern end
                                     of South Island.

                                1400 OSC opens Port of Valdez to vessel traffic.  Vessels subject to Vessel Traffic
                                     Service (VTS)  regulations will make  daylight transits only.  A 1,000-yard
                                     safety zone around the Exxon Valdez is imposed.  Tank vessels inbound or
                                     outbound will be required to have a two-tug escort to or  from Bligh Reef.
                                     Vessels directed to avoid any clean-up operations by 500 yards.

                                1600 OSC holds teleconference with Alaska State Legislature.

                                1730 Secretary of Transportation Skinner, Environmental Protection Agency (EPA)
                                     Administrator  Reilly, and CG Commandant Admiral Yost arrive to assess
                                     clean-up and oil transfer operations.

                                1800 274,000 barrels of oil transferred from the vessel at a transfer rate of 3,624
                                     barrels per hour. Soundings indicate vessel is still hard aground between the
                                     number two and three starboard tank areas.
          MARCH 29, 1989  (SIXTH DAY)
                                0845
      Secretary  of  Transportation  Skinner,  EPA  Administrator  Reilly,  CG
      Commandant Yost, Senator Murkowski, and Congressional staffers view spill
      area from CG overflight. They arrive in Valdez after having reviewed clean-
      up and oil transfer operations.  They meet with OSC.

1200  At Valdez  site,  two dispersant  aircraft stand ready for operations.  An
      Aerostar aircraft augments command and control.  Five landing craft (LCM)
      arrive for beach cleanup.   Seven skimmers operate around  Knight Island.
      Over 8,000 feet of additional boom is enroute.  Skimmers remove over 5,000
      barrels of oil.
          Over  390,000 barrels  of  oil transferred off Exxon  Valdez.  Present
      pumping rate is 9,000 barrels per hour.

2000  Total  of 442,988  barrels of oil—45 percent of cargo—now  removed from
      Exxon Valdez.  National Oceanic and Atmospheric Administration (NOAA)
      review of recent overflights indicates oil beginning counterclockwise rotation,
      moving  from Naked Island, down western side  of  Knight Island, and up
      eastern side of Knight Island and western side of  Green Island.
                                2130 Exxon  Baton Rouge ceases taking on  Exxon
                                     Francisco is enroute to resume operations.
                                                  Valdez  cargo.  Exxon  San
          MARCH 30, 1989  (SEVENTH DAY)

                                     Three separate beach clean-up work groups established.  Priority Assessment
                                     Team to rank most critically affected areas for cleanup. Clean-up Assessment
                                     Team will determine use of best clean-up techniques. Shoreline Assessment
                                     Team will make final assessments of clean-up work.
                                          Exxon reports that 7,537 barrels of oil recovered. NOAA estimates that
                                     30 to 40 percent of the spilled oil has  evaporated.
                                          The oil has  passed  Montague  Island  and  Latouche  Island  and is
                                     proceeding  westerly into Gulf of Alaska.
                                                    1 Appendices-6

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                      0800 Oil concentrations have moved south seven to eight miles overnight, extending
                           to the Montague Strait area near southern tip of Montague Island and eastern
                           side of Latouche Island.  Oil remains concentrated in center of  Montague
                           Strait.  Green Island surrounded by oil. Heavy concentrations of oil remain
                           in the  area southeast of Naked  Island, through the Eleanor and Ingot Island
                           areas, and down western side of Knight Island. Vessel Crystal Star (130 feet)
                           set up  as Exxon floating command center.

                      0900 OSC authorizes three EPA members to assist Exxon in planning  for beach
                           cleanup.

                      0915 CG transportable communications center arrives from Sacramento, CA,  to
                           handle Coast Guard air  traffic communications.

                      1000 Oil transfer from Exxon Valdez totals over 447,000 barrels.

                      1100 Exxon San Francisco takes over transfer operations from Exxon Baton Rouge.
                           Divers in the water conduct additional surveys.

                      1300 VADM Robbins,  Commander CG Pacarea, and Senator Lautenberg arrive in
                           Valdez.

                      2300 Exxon Baton Rouge departs.  Estimated 668,000 barrels of oil left on Exxon
                           Valdez at conclusion of transfer operations.
MARCH 31, 1989  (EIGHTH DAY)
                           Due to low visibility, CG using its own AIREYE and Exxon infrared tracking
                           equipment to monitor spill migration.  NOAA projections using AIREYE
                           surveillance shows large crossover effect. Oil slick appears to be turning back
                           on  itself,  moving into Knight Island  Passage.  Oil emulsifying with water
                           increases volume of liquid to be recovered.  Responders replace weir-type
                           skimmers  with rope-mop units.
                               Green  Island surrounded by thickening oil.   Large patch of thick oil
                           reaches northwestern side of Knight Island past Herring Bay area.  Latouche
                           Island  touched  by lighter patches.  No signs yet  of  beach  contamination.
                           Exxon reports 7,537 barrels of oil recovered.  Preliminary  DOI survey of
                           Green Island indicates 1,000 oiled birds.

                     1000  Senator Stevens arrives and is briefed by the OSC.

                     1143  USCGC Sedge  in Sawmill Bay operating OWOCRS.  Personnel are issued
                           respiratory equipment to avoid irritating fumes from oil.  Three dead sea
                           otters removed from the sea.

                     1200  Nearly 80,000 feet of sorbent boom transferred from USCGC Rush to contract
                           vessels in southern part of Prince William Sound. The Rush acts as command
                           and control platform in this area. Operating OWOCRS from USCGC Sedge,
                           Strike Force recovers 679 barrels of oil.  Meanwhile, Exxon Valdez shows
                           signs of buoyancy after 500,000 barrels off-loaded to Exxon Baton Rouge and
                           Exxon San Francisco.

                     1400  Alaska Air National Guard air drops sorbent materials to contractor boat crews
                           in Hawkins Island area.

                     1700  Ten sea otters received by the wildlife cleaning facility.

                     1800  220,952 barrels of oil transferred from Exxon Valdez to Exxon San Francisco.

                     1930  USCGC Sedge departs for Sawmill Bay area by way  of Knight Island passage.
                                         1 Appendices-7

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APRIL 1,1989 (NINTH DAY)
                           Heavy weathered oil continues to wrap around Knight Island. Emulsified oil
                           reported from Squire Point south to Prince of Wales Passage opposite Port San
                           Juan. Heavy oil also reported on west side of Latouche Island.
                                By April 1, a substantial accumulation of response equipment has been
                           deployed throughout affected areas of the sound.  For example, the amount
                           of boom positioned by Exxon  from March 24 to April 1 has grown from
                           12,500 feet to over 84,000 feet.
                                Galena Bay is protected by 1,000 feet of deflection boom; Head Main
                           Bay by 5,000 feet, with a recovery vessel attending; Hatchery Island of Main
                           Bay by 2,000 feet; and Herring Bay, Knight Island by 3,000 feet of sorbent
                           boom and 6,000 feet of recovery boom used by five vessels for later pickup
                           by skimmers.
                                Sawmill Bay, Evans Island protected by 50,000 feet of boom deployed
                           with  15  vessels and much other equipment;  Point Helens, Knight  Island
                           shielded by 1,200 feet of recovery boom; Snug Harbor, Knight Island by 1,000
                           feet; Bay of Isles, Knight Island by 500 feet of boom; and Bushby Island by
                           5,000 feet of recovery boom. Applegate Rock protected  by CG skimming
                           barriers with an attending 35,000-barrel recovery barge. Crippled  Exxon
                           Valdez is surrounded by 6,000 feet of boom.
                                The federal presence also has increased significantly. Employed in the
                           response on April 1 are 391 CG personnel, 23 from DOI, 14 from NOAA, six
                           from EPA, and four  from the  Department  of  Agriculture.   On-scene
                           equipment marshalled  by federal  agencies includes 8,000 feet of sea boom,
                           2,000 feet of flexi-boom, 1,200 feet of harbor boom,  over 100,000 feet of
                           sorbent boom, two CG Strike Force skimming OWOCRS, two Navy MARCO
                           Class V skimmers, a PACAREA tow vehicle, eight boats, three CG cutters,
                           four fixed wing aircraft, and four helicopters.

                      0650 295,645 barrels of oil transferred to Exxon  San Francisco.

                      1000 State officials mobilizing resources to conduct water sampling in areas of
                           hatchery and spawning activities.

                      1130 Wildlife recovery centers treating 28 oiled birds and 12 otters.

                      1215 Notice to mariners broadcast:  all  vessels not involved in response operations
                           are to stay well clear of any observed oil.

                      1300 Secretary of Transportation  Skinner and  CG Commandant Admiral  Yost
                           briefed by OSC on cleanup status and adequacy.
APRIL 2, 1989 (TENTH DAY)
                            Using CG AIREYE, NOAA reports the leading edge of spill is approximately
                            nine miles south of Cape Resurrection, progressing south west ward.
                                Beach cleanup at Naked, Peak, and Smith Islands begin as response teams
                            gather growing clean-up manpower and pool special skills. Exxon team totals
                            160 persons now,  including experts from the U.S., Canada, and the United
                            Kingdom.  The company has hired  over 350 additional clean-up workers.
                            Nearly 100 vessels are actively participating in the response.
                                336,853 barrels of oil have been transferred from the Exxon Valdez to
                            Exxon San Francisco.
                                Exxon reports total quantity of oil recovered exceeds 10,000 barrels.
                                Exxon visual overflight indicates lighter sheens of oil are flowing into
                            Gulf of Alaska. Large concentrations of oil remain in Knight Island Passage
                            and in bays and sounds on north end of Knight Island.
                                ADEC beach surveys on Eleanor Island, Ingot Island, and northern end
                            of Knight Island show heavy contamination.
                                          1 Appendices-8

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                      0900 At wildlife cleaning  centers,  28 oiled otters and 49 oiled birds are being
                           treated.   Approximately 140  oiled birds per  square  mile are found  in
                           Gibbons/Anchorage area. DOI estimates very high wildlife mortality rates.

                      1300 Exxon San Francisco  loaded to its capacity of 452,533 barrels.
                                 OSC grants Exxon request to apply dispersant to the slick sighted south
                           of Point 'Erlington, but results  not satisfactory on the main body of the oil.
                           Dispersants moderately effective in breaking up  surrounding oil sheen.

                      1400 Exxon reports 943,000 barrels of oil transferred from Exxon Valdez to Exxon
                           Baton Rouge and Exxon San Francisco.

                      1530 Exxon Baytown alongside Exxon Valdez for continuation of oil transfer.

                      1600 150  birds treated and 30  sea  otters recovered.  Once  treated,  otters are
                           transported to various aquariums.
                                By evening, southern extent of the spill progresses further south and is
                           now 12 miles southwest of southern tip of Montague Island.  Small stringers
                           of oil sighted in the Bainbridge and Prince of Wales Passages.  Light sheen
                           remains in all passages. Three  main streams of oil are flowing into Gulf of
                           Alaska and are currently four to five miles offshore.
                                NOAA weather stations set up at northwest corner of Sawmill Bay and
                           southern tip of Latouche Island.
APRIL 3, 1989 (ELEVENTH DAY)
                           Alaska Department of Fish and Game cancels all herring fishing in Prince
                           William Sound based on damage to spawning areas.

                      1400 New remote weather stations established at northeast point of Sawmill  Bay,
                           Dangerous Island, and Perry Island.

                      1941 USCGC Sedge reports 8,949 barrels of oil recovered by  CG OWOCRS.

                      2000 Skimming operations progress with oil recovery rates approaching 90 percent.

                      2100 Appearance of oil not yet sighted on shorelines west of Cape Puget, which
                           serves as boundary between Valdez and Anchorage OSCs.  Anchorage  OSC
                           sends representative to Prince William Sound. Preparations start to protect
                           against possible movement of oil into Gulf of Alaska.
APRIL 4, 1989 (TWELFTH DAY)
                                Shoreline crews continue to operate at Smith and Naked Island. Housing
                           for work crews provided by the  barge Exxon II,  located in Mummy Bay,
                           Knight Island and by the M/V Bartlett (to be relieved later by M/V Aurora)
                           in Sawmill Bay.
                                Exxon has established a boat cleaning station  in  Valdez.   Cordova
                           Fisheries Union are setting up another cleaning station in Cordova.
                                USCGC Rush  works 329 aircraft  and  processed 1,867  radio contacts
                           between  0700 and 2130.
                                Health and safety training classes  set up by Exxon contractors to provide
                           mandatory training  for all clean-up personnel.
                                Oil  transfer from  Exxon Valdez  completed by Exxon Baytown; Exxon
                           Baytown underway.
APRIL 5, 1989 (THIRTEENTH DAY)
                           Over 66,000 feet of boom deployed  in  Sawmill Bay.  This represents 65
                           percent of total boom  deployed.  OSC had decided to deploy a significant
                           amount of booming and skimmers in defensive positions to protect hatcheries,
                           removing capacity to fight the spill  itself.
                                          Appendices-9

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                               Air Force Military Airlift Command (MAC) airlifts U.S. Navy, CG, and
                           Exxon skimmer boats, drums of dispersant, mooring systems, boom vans,
                           barrier material,  and assorted  vehicles from California, Oregon,  Texas,
                           Virginia, Denmark, and Finland to spill site.  Exxon will pay airlift cost.
                               Sawmill Bay fishermen now expressing confidence that  hatcheries will
                           be protected. Clean-up crews at a number of beach locations begin to mop up
                           oil in  tidal pools.
                               Primary concentration of oil in Prince William Sound extends almost in
                           a continuous sheen from Smith Island, between Knight  and  Green Islands,
                           and down Montague Strait out into Gulf of Alaska.  Oil remains in passages
                           between Bainbridge and Latouche Passages. Large slick has moved into Gulf
                           of Alaska, extending from southern outlets of the  passages across Montague
                           Strait. Slick has moved approximately 50 miles into the gulf.
                               Skimming rates continually reduced due to oil weathering.
                               OSC permits transit of two vessels during daylight hours,
                           provided they are heading in the same direction.  Each vessel must have two-
                           tug escort.
                               USCGC Rush works 127 air contacts and processes 550 radio contacts as
                           part of air traffic control operations.

                     1035  Exxon Valdez refloated after oil transfer operations and is holding position
                           on Bligh Reef. About 16,445 barrels of oil remain in the vessel. 1,000-yard
                           safety zone established around the tanker.  Two MARCO skimmers and a
                           vacuum truck are aboard  Exxon  Valdez and attended by  workboats and
                           standby dispersant-loaded aircraft to respond to any additional spill.  Transit
                           of Exxon Valdez  to Naked Island area begins.

                     1420  USCGC Sedge reports recovery of  oil is becoming extremely difficult due to
                           formation of a water-and-oil emulsion or "mousse."

                     1935  Exxon Valdez anchored in Outside Bay near Naked Island.

                     2201  Canadian and U.S. Region Joint Contingency Plan activated.  Co-chairs are
                           Captain G.E. Haines, the Commander of the Coast Guard District 17 Marine
                           Safety Program, and Mr. G.R. Stewart, Director General, Western Region,
                           Canadian Coast Guard.

APRIL 6, 1989 (FOURTEENTH DAY)
                           Twenty-one additional skimmers, including  15 Navy units transported by the
                           Department of Defense (DOD), enroute to spill scene.
                                Variety of response equipment being assembled at Mummy Bay and Point
                           Helens, Knight Island to protect environmentally sensitive areas there.  Also,
                           joint  U.S. - Canadian response plan invoked to speed delivery of more clean-
                           up equipment and operators.
                                USCGCs Midgett, Yocoa, Sweetbriar, Iris, and Planetree  directed to join
                           cutters Rush, Ironwood, and Sedge in clean-up area.
                                Mandatory health and safety classes for all clean-up crews begin while
                           contractors work with NOAA to develop detailed maps of oiled beach areas.
                                Exxon Valdez remains anchored off Naked Island.
                                NOAA overflight reveals oil  is thinning and heading out to sea.  Heavy
                           oil contamination reported at Smith Island, Main Bay, Falls Bay, Eshamay Bay,
                           eastern side of Chenega Island, and  northern parts of Bainbridge, Evans, and
                           Latouche Islands.   Eastern and  western shores  of  Knight Island also
                           contaminated.  Oil with light concentrations of emulsified  ribbons spotted
                           north of Main Bay near Port Nellie Juan.
                                Mortality rate of otters turned into rehabilitation centers is approximately
                           50 percent.  Leading edge of oil slick 22 miles south of Nuka Bay in Gulf of
                           Alaska.  Impact  observed on the  Chiswell Islands.   Oil mousse  surrounds
                           Barwell  Island,  and  some oil has been trapped on eastern side of Cape
                           Resurrection.
                                           Appendices-10 '

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                                Oil observed approximately 20 miles off coast from Gore Point, varying
                            in width from 10 to 20 miles. Oil forming wind rows. Oil in Prince William
                            Sound continues to flush into the gulf.
                                Rear Admiral Nelson (USCG) assumes OSC responsibility to  facilitate
                            strategic control of response.
                                Oil  volume in Bainbridge  and Latouche Passages diminishes with
                            migration of spill into the gulf.
                                USCGC Rush maintaining air traffic control.
                                Oil affects areas within Anchorage OSC jurisdiction. Oil slick reaches
                            Barwell Island at entrance of Resurrection Bay.

                      1500  Overflights indicate difficulties encountered in positioning skimmers in areas
                            of  heavily  concentrated oil.  Emulsified  patches  of oil  clinging  to some
                            shoreline areas inaccessible to larger skimmers.
APRIL 7, 1989 (FIFTEENTH DAY)
                            At direction of President Bush, DOD establishes Director of Military Support
                            Joint Task Force (DOMS JTF) to assist OSC in cleanup. DOD assessment team
                            will determine best way to apply military support.  Joint Task Force begins
                            daily oversight meetings in Pentagon Army Operations Center.
                                Emergency order tightening  operations at Valdez Terminal signed by
                            Governor Cowper.
                                Spill  area  enlarged  to approximately 2,600  square nautical  miles,
                            according to NOAA analysis of recent overflights.  Heavy  concentrations of
                            oil sighted on eastern side of Knight Island.  Sheen remaining in most passage
                            areas forms streams and stringers.
                                Approximately 300 dead  birds and 76 sea otters collected.  The  new
                            Valdez rehabilitation center begins operations.

                      0930  Divers survey tank  number  1C beneath Exxon  Valdez -and  begin drilling
                            operations to prevent further spread of main crack.

                      1830  Sheen with streaks of mousse reported extending from the northern part of
                            Naked Island down eastern shore of Knight Island, through Latouche Passage,
                            and into Gulf of Alaska.  Northern part of Montague Island and Green Island
                            affected. Extensive sheen observed in and  around Snug Harbor. Light sheen
                            with stringers ranges from Port Nellie Juan to Main Bay and down Knight
                            Island Passage into Latouche Passage. Some sheen observed in Prince of Wales
                            Passage.
                                USCGC Rush maintains  air  traffic  control.   USCGC  Sedge  passes
                            OWOCRS towline to Theresa Marie.
APRIL 8, 1989 (SIXTEENTH DAY)
                           Skimming operations continue in Main, Eshamay, Herring, and Sawmill Bays
                           and begin between Knight and Green Islands.  While GT-185 skimmers are
                           very effective, CG reports that oil recovery rates are reduced to 200 barrels
                           per day due to increasing oil viscosity.
                                Morning overflight shows occasional light sheen in Perry Passage north
                           of Port Nellie Juan. No oil found in Wells Passage or McClure Island. Light
                           sheen at Port Nellie Juan, Main Bay, and Crofton Island where some beach
                           impact observed. Less than 10 percent of Eshamay Bay covered with sheen,
                           but heavy oil concentrations contained by booms.
                                Mixture of sheen and mousse observed in northern, eastern, and southern
                           areas of  Knight Passage. Sheen and mousse streaks noted in Prince of Wales
                           Passage.  Shorelines abutting Latouche Passage show oiling with mousse and
                           sheen offshore.  Sheen with patches of heavy oil  observed off southern
                           Montague Island. Trajectory of spill curving into Anchorage OSC jurisdiction.
                           Valdez and Anchorage OSCs deploy MARCO Class V skimmers in defensive
                           positions in Gulf of Alaska.
                                           Appendices-11

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                               DOI reports that 529 birds and 94 sea otters have died. The Fish and
                           Wildlife Service (FWS) has prepared a list of wildlife areas believed to be at
                           risk from the oil spill.
                               USCGC Rush maintains air traffic control,  works  303 aircraft, and
                           processes over 2,126 radio contacts.  USCGC Ironwood continues installation
                           of mooring systems in Sawmill Bay.
                               CG Boating Safety Team enroute to Whittier to conduct safety boardings
                           on volunteer recreational boats used for retrieval of dead wildlife.
                               In Whittier, DOI is setting up  a wildlife collection station and Exxon
                           establishes a boat-cleaning station.

                     0630  Overflights conducted by NOAA.

                     0945  USCGC Rush reports heavy concentration of oil from  Bass Harbor to eastern
                           end of Smith Island. Slick apparently one mile wide. Exxon officials notified
                           and a skimmer crew diverted.
                               Response actions stepped up at Sawmill Bay and Snug Harbor, where
                           eight skimmers, five vessels, and an oil  recovery barge are  involved. Over
                           5,000 feet of boom deployed in King Bay.   Fully-boomed Exxon Valdez
                           remains anchored off Naked Island with  a 32-foot water cushion for each of
                           its damaged tanks. Light sheen reported inside the boom.
                               FWS  conducts  aerial  shoreline survey from Prince  William  Sound to
                           Homer.

                     2130  Captain Ryan  of the Canadian Coast  Guard  says Canadian skimming
                           equipment has recovered 666 barrels.

                     2200  USCGC Sedge enroute to Snug Harbor.

                     2205  Summary of clean-up activity provided by Exxon as of this  date:
                                Initial Amount of  Oil Spilled:                          240,000 barrels
                                Amount Recovered:                                   17,000 barrels
                                Amount Evaporated:                                  77,000 barrels
                                Amount Dispersed:                                   11,000 barrels
                                Amount in Prince William Sound:                      45,000 barrels
                                Amount in Gulf of Alaska:                            45,000 barrels
                                Amount on Beaches:                                  45,000 barrels

                                CG AIREYE overflights reveal scattered mousse and sheen from Cape
                           Junken to the southern section of Otter Island. Some oil  apparent around
                           Chiswell Island.  Light sheen with thin strands of mousse apparent north of
                           Hinchinbrook Island. Light beach impacts were observed on the northeastern
                           part of Montague Island.
                                Exxon divers complete drilling eight stopper holes in Exxon  Valdez to
                           arrest fractures.

APRILS, 1989 (SEVENTEENTH DAY)
                           Spill seems  to be stabilizing. CG reports leading edge of the spill has not
                           advanced in two days. Sheen  with streaks  of congealed oil extends from
                           northern Naked Island through the lower passages and into Gulf of Alaska.
                           Heavy sheen reported around Snug Harbor.
                                Sawmill and Herring Bays and Snug  Harbor continue  to hold  highest
                           response priority.  Arriving at Sawmill Bay to join the response effort are a
                           floating hotel (housing 1,000 response personnel), five waste-oil barges, five
                           waste-oil  "doughnuts,"  and 100 small skiffs.
                                USCGC Rush works 320 aircraft and has processed 2,180 radio contacts
                           in the last 24 hours.

                      1430 VADM Robbins, CG PACAREA Commander, returned to Valdez.
                                          1 Appendices-12

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                      1515 Joint NOAA/USCG overflight reports no oil found on Hitchinbrook Island
                           near the Hawkin's Island cut-off.

                      1945 Aerial  reconnaissance reports leading edge of spill is 25  miles southeast of
                           Nuka Island. Slick  runs close to the shore from Cape Junken to the vicinity
                           of Resurrection Bay, where fresh water runoff and fjord winds are pushing
                           the spill offshore.  Major spill impact observed in Chiswell Islands due to
                           combination of steep shoreline and high wave energy.  Offshore slick appears
                           as 20 to 30 mile sheen with widely separated areas of mousse.
                                Weather hinders clean-up  operations.   Many skimmers  operating in
                           exposed areas head  for more protected waters.
                                CG air operations total 38 hours of flight time.
                                In the OSC Anchorage-Gulf of Alaska operational theater, the USCGC
                           Yocona has sailed  from Kodiak to Seward and presently is in Seward. A Navy
                           MARCO skimmer  is  on scene.  An 84-inch boom  at Seward cannot be
                           deployed by USCGC Yocona and Planetree due to adverse weather conditions
                           offshore.  Test using herring nets to break up areas of oil considered partially
                           successful.
                                Two  65,000-gallon  capacity bladders enroute  to Seward for use in
                           skimmer operations.
                                USCGC Morgenthau is stationed at the southeast entrance to lower Cook
                           Inlet monitoring traffic.  Remote weather stations are planned for Harwell
                           Island, Outer Island, Chugach Island, and Marmot Island.
                                14,000 feet of boom deployed at Resurrection  Bay and  Kenai Fjords
                           National Park.

APRIL 10, 1989 (EIGHTEENTH DAY)

                           Leading edge of the slick located 20 miles south of Nuka Sound.
                                USCGC Sedge conducts shoreline survey of Snug Harbor with  a small
                           boat. Only a very light sheen observed approximately one mile offshore. Four
                           foot wide  band of black oil observed at the high water mark on the beach.
                                FWS  personnel continue shoreline aerial survey from Prince William
                           Sound  to Kodiak. On the ground, a survey of deceased wildlife is conducted
                           on the  north end of Knight Island.
                                USCGC Rush  works 324 aircraft, processes 2,192 radio contacts, and
                           then puts  into port for logistic  resupply. USCGC Rush is relieved of air
                           traffic control responsibilities by USCGC Sedge.
                                Poor  visibility  and high variable winds hamper overflight assessments.

                      1400 USCGC Ironwood enroute from Snug Harbor to Valdez and reports every five
                           miles on concentrations of oil.  Ironwood reports light sheen  500 to 1,000
                           yards wide between Sleepy Bay and Point Helen.   Several ribbons of oil
                           approximately 10  by 420 yards reported three miles south of Discovery Point.
                      1845 USCGC Storis loaded with approximately 2,000 feet of membrane-type boom
                           for transport to Kitoi fish hatchery at Afognak Island.
                                At OSC Anchorage-Gulf of Alaska zone, gale force winds and 20-foot
                           seas prevent offshore operations. Exxon establishing an otter cleaning station
                           in Seward. 2,100 feet of boom are deployed at Tutka Bay fish hatchery.
                                Two Navy MARCO skimmers with CG bladder arrive at Homer.
                                Six fishing vessels equipped with herring nets depart Kodiak to join 30
                           other fishing boats at Seward to form mobile response unit in  attempt to break
                           up oil patches off Cape Resurrection.  Additional  10,000 feet of  boom will be
                           deployed with these vessels.

APRIL 11, 1989 (NINETEENTH DAY)

                           Total of  nearly  200,000  feet  of boom  have been deployed to  protect
                           endangered areas in Prince William Sound.   Included are 85,000  feet of
                           containment boom,  98,000 feet of absorbent boom, and 12,000  feet of boom
                           surrounding Exxon  Valdez anchored off Naked Island.
                                          Appendices-13

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                                39 skimming operations shut down by rough seas on April 10 have yet to
                           resume operations in the natural collection area of Snug Harbor, Sawmill Bay,
                           Point Helen, Latouche  Pass, and Herring  Bay.  Over 80  people  are now
                           involved in the cleanup of Naked Island, with 500 more workers expected to
                           join clean-up efforts by April 13.
                                Oil moved westward, forming long, well-defined bands of mousse along
                           eastern shore of Latouche, Knight, and Ingot Islands. Light sheens observed
                           in Main and Eshamay  Bays.   Large patch of sheen/mousse combination
                           approximately six miles long and two miles wide observed west of Eleanor
                           Island, extending nearly into entrance of Main Bay.
                                Small  amounts of  sheen and mousse  observed in Perry  Island  area.
                           Herring Bay still heavily oiled. Large band of  sheen   and mousse parallels
                           southeast end of  Knight Island.  Bay of Isles beaches also heavily  oiled. Wind
                           and wave conditions over past two days have mixed and dispersed the larger
                           concentrations of oil in open waters of Prince William Sound.
                                Exxon  divides Prince William Sound into  four quadrants,  each with a
                           command and control vessel (with PACAREA Strike Team member aboard)
                           to coordinate oil recovery operations. Quadrant zone one represents area
                           north of Knight Island, Quadrant  zone two  represents  areas west,  and
                           Quadrant zone three areas east.  Quadrant zone four represents areas south of
                           island. Areas other than Prince William Sound are designated zone  five.
                                Exxon  Valdez is  subject of diving survey.  Repairs made to fractures in
                           hull of number  four starboard tank.   Vessel engines are checked  and
                           considered  operational.   To date, 19,000 barrels  of oil recovered, but bad
                           weather hinders  future recovery operations.

                     0340 USCGC  Morgenthau ordered to mouth of  Resurrection  Bay to coordinate
                           efforts to break up oil by fishing vessel fleet and Exxon spotter  plane.

                     1445 Potato Point Radar Site becomes inoperative, forcing OSC to close the Valdez
                           Narrows to vessel traffic.

                     1500 Radar site reactivated and port reopened.

APRIL 12,1989 (TWENTIETH DAY)
                           CG helicopter overflight reports leading edge of slick located 30 to 40 miles
                           southeast of Gore Point.
                                Snug Harbor and the Bay of Isles relatively free of oil, but shorelines
                           are extensively oiled.

                     1535 ADM Yost,  Commandant USCG, arrives at  Elmendorf AFB, Anchorage.  He
                           returns as the President's and the Secretary of Transportation's representative
                           to oversee the spill cleanup.  He is met and briefed  by  VADM Robbins and
                           RADM Nelson.

APRIL 13, 1989 (TWENTY-FIRST DAY)
                           CG monitor and vessels assigned to each of  five designated clean-up sectors.
                           Dispersant tests show no effect on mousse and little  effect on sheen.

                     1122 ADM Yost meets with Exxon officials to establish clean-up priorities. Exxon
                           tasked with submitting  a beach clean-up  work  plan.  Exxon temporarily
                           suspends shoreline cleanup pending submission  and approval of  the plan.

                     1330 RRT meeting held.

                     1800 Transfer of oil slops  from  T/S Exxon  Valdez  completed.  Internal survey
                           underway.
                                           Appendices-14

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                      1900 ADM Yost  briefs operations  committee on  his purpose  and function as
                           President's representative.
APRIL 14, 1989 (TWENTY-SECOND DAY)
                      1115  Commandant meets with Governor Cowper and Commissioner of ADEC to
                           discuss  clean-up  progress  and strategies.   Commandant  also  briefed by
                           LT GEN Mclnerney on results of DOD assessment team study.

                      1300  RRT meeting held.

                      1314  ADM Yost provided status  report during telecom with President Bush. The
                           effectiveness of hot water/steam cleaning of shoreline discussed, and a status
                           report provided by ADM Yost.

                      1500  LT GEN Mclnerney, ADM Yost, and VADM Robbins meet.  DOD support
                           resources discussed and additional resources secured, including COE Dredge
                           Essayons and U.S. Navy Ship Juneau.

                      1700  ADM Yost meets  with top Exxon officials.  He presents them with a list of
                           50 beaches requiring cleanup.  ADM Yost is putting pressure on Exxon to
                           provide additional personnel within 10 days.

                      2000  ADM Yost meets  with SSC and operations committee.  The need to protect
                           Seward, Homer, and Kodiak is discussed, as is forthcoming Exxon shoreline
                           clean-up plan.

                      2100  Shoreline Clean-up Committee approves use of wash-vacuum oil cleaning
                           system (VIKOVAK) on  eastern shore of Smith  Island.   Committee also
                           approves test  cleaning using hot/cold/high-pressure  water flushing  with
                           VIKOVAK  applications on northern portion of Smith Island.  Instructions
                           given to avoid all living species, backshore and upper intertidal areas, and use
                           of high-pressure water or steam where invertebrates and seaweed exist.
APRIL 15, 1989 (TWENTY-THIRD DAY)
                     0905  ADM Yost, VADM Robbins, and NOAA rep conduct overflight of Northwest
                           Passage to observe skimming.
                               Concentrated skimming operations  continue in  many  areas.   Ten
                           skimmers and eight CG cutters operating on scene.
                               RADM Nelson departs to resume duties as Commander of Seventeenth
                           CG District.

                     1400  Hydrovac  pumping system transferred to Zone two to speed offloading  of
                           skimmers there. Hydrovac systems considered only  effective pumping system
                           for the viscous, debris-laden oil that is difficult to transfer through integrated
                           skimmer pumping systems.

                     1600  Vice Admiral Robbins (USCG) becomes federal OSC (FOSC).

                     1700  Commandant meets  with representatives of Exxon, ADEC,  and fishermen.
                           Exxon presents shore clean-up execution plan.

                     1900  FOSC approves shoreline clean-up work order for Eleanor Island.

                     1900  ADM  Yost  attends  operations committee briefing  to discuss the  day's
                           developments and clean-up actions to be taken outside Prince William Sound.
                                         1 Appendices-15

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APRIL 16,1989 (TWENTY-FOURTH DAY)
                     0930  Commandant,  FOSC,
                           representatives  attend
                      1800
                                                and  several  federal,  state,  corporate,  and press
                                                shoreline washing  experiment and demonstration
                           conducted by Exxon on southwest Eleanor Island.
                               Exxon submits shoreline clean-up execution plan to FOSC and staff for
                           review.
                               Prince William Sound overflight shows significant change in the path of
                           oil caused by changes in wind direction. Large concentrations of mousse and
                           sheen previously  seen near Eleanor  and Ingot Islands now being driven
                           southwest towards Falls and Main Bay and Lone, Perry, and Culross  Islands.
                           Significant shoreline  impact anticipated there.  Projections indicate  oil will
                           remain in that vicinity and will not migrate into Wells Passage or Port Nellie
                           Juan.  Overflight conducted in the area of Gore Point shows shoreline impacts.
                           Remaining oil in the gulf between Cape Junken and the Chugach Islands may
                           be driven  northward and may reach   shoreline  in that  area  due to
                           predominantly southeast winds.
                               Clean-up operations temporarily stopped due to  reports of exposures to
                           harmful vapors. Air  quality monitoring shows exposure limits  within safety
                           guidelines.

                           ADM Yost meets with operations committee.  Alternate  methods of beach
                           cleanup demonstrated earlier discussed and evaluated. ADM Yost expresses
                           concern over the high number of skimmers that he  observes not operating
                           during his earlier overflight.

APRIL 17, 1989 (TWENTY-FIFTH DAY)

                           Skimmer operations are redirected in order to concentrate on near-shore areas
                           to recover larger amounts of accumulated oil more effectively.
                               Salvage of  Exxon Valdez continues.  Box patches  installed from frame
                           1 to fore and aft bulkhead. All "hangers" (hanging steel pieces) removed from
                           tank numbers 1C, 2C, and 3C.  Divers conduct survey of tank number IS.
                               Joint command communications network established to connect primary
                           command nodes for overall operations coordination.

                     1000  Commandant meets  with lead agencies to  discuss comments  on  Exxon
                           workplan.

                     1300  Commandant approves workplan and presents comments to Exxon officials.

                     1400  Captain Crowe  (USCG) assumes duties as Chief of Operations.

                     1600  Captain Roussel (USCG) designated  assistant OSC for spill outside Prince
                           William Sound.  Vice Admiral Robbins remains FOSC for entire spill.

                     1900  ADM Yost and executive committee meet.  He urges immediate pursuit of
                           shoreline cleanup  using acceptable methods.

APRIL 18, 1989 (TWENTY-SIXTH DAY)
                     1315  ADM Yost, FOSC, and RADM Baker, USN, Commander Third Amphibious
                           Group discuss naval support of cleanup.

                     1330  Visiting Florida DNR personnel discuss cleanup with FOSC,

                     1400  ADM Yost departs Valdez for Anchorage.

                                Skimming  operations center on heavy concentrations of oil near Perry,
                           Long, and Culross Islands.
                                Nine  CG  Cutters operating in  area.  Total of 53  vessels, including
                           33 skimmers on scene.
                                          ' Appendices-16

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                                Prince William Sound overflight reveals heavy patches of oil from Wells
                           Passage to Lone Island. Oil sheen collecting in Port Nellie Juan. Light winds
                           keeping oil basically immobile. New light oil sightings on south side of Lone
                           and Eleanor Islands and south to Smith Island.  Overflights continue to show
                           sheen and mousse patches from Chugach Islands east to Cape Resurrection.
                           Sheen and mousse sighted in vicinity of Shuyak Island.  No oil sighted along
                           beaches of  Katmai National Monument.  Very light tar ball splattering
                           Seward's 2,000-foot beach front. No other evidence detected.
                                Soviet skimmer M/V Vaydagursky receives approval for thirty-day entry
                           into U.S. waters. Approval includes authorization to work within three miles
                           of land from Valdez to Homer and around the Kodiak Archipelago, and to
                           make port calls.
APRIL 19, 1989 (TWENTY-SEVENTH DAY)
                     0700 Two Navy MARCO Class V skimmers, two Class XI skimmers, and two Exxon
                           contract skimming vessels deployed at leading and trailing edge of heavy oil
                           concentration in Perry Passage. Five Navy MARCO Class V skimmers and
                           Exxon contract skimmers are deployed in the bays west of Eleanor Island to
                           collect oil pushed by westerly winds.  Three Navy MARCO Class V skimmers
                           deployed west of Squire Island.

                     1000 USCGC Sweetbrier on scene at Esther Island hatchery to deploy SUPSALV
                           mooring system for protective  booming operations.

                     1100 ADM Yost and FOSC attends luncheon with mayors of affected towns prior
                           to ADM Yost's departure from Anchorage.

                     1200 Soviet M/V   Vaydagursky skimmer  vessel   arrives   at  Seward.    CG
                           representatives board vessel with interpreter, pilot, and VECO representatives
                           (Exxon contractor) to discuss proposed operations. Vessel currently refueling
                           and preparing for skimming operations near mouth of Resurrection Bay.
                                Salvage operations continue.  All tanks except number 4S are inerted.
                           Tank number 4S is opened and safe for work. Three box patches installed in
                           the tank over  the small "repaired" fractures.   Tank number  4S has been
                           repaired temporarily.

                     1300 FOSC meets in Homer with RRT to discuss shoreline cleanup.
APRIL 20, 1989 (TWENTY-EIGHTH DAY)
                      0930 FOSC briefs Secretary of Interior Lujan, and Congressmen Young, Galley
                           and Weldon.

                           Shoreline activities continue on Naked Island.  Over 250 Exxon contractor
                           personnel are supporting clean-up operations in four areas  on north side of
                           Naked and Peak Islands.
                                Nearly 41,062 barrels of oil and water mixture and 14,270 barrels of oil
                           transferred to a barge alongside Exxon Valdez.
                                State of Alaska-funded and constructed Joint Communication Center
                           added to the response communications network.
                                Army  Corps of  Engineers  (ACOE) dredge Yaquina  deployed  as a
                           skimmer, recovers 1,100 barrels  of  oil.  Total of 53 vessels, including 35
                           skimmers, are performing oil recovery operations.
                                           Appendices-17

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APRIL 21, 1989 (TWENTY-NINTH DAY)

                      1300 RRT teleconference updates members and tasks them with investigating use
                           of COREXIT 7664 dispersant for shoreline cleanup.

                           Air Force has transported total of 928 tons of response equipment by 15 C-5
                           missions and 97 tons of equipment by four C-141 missions. Salvage operations
                           to cut hangars from bottom of Exxon Valdez continue.  Draft proposals for
                           tank and hull cleaning presented to CG.
                               High volume/low pressure beach washing applied by 250 Exxon personnel
                           to Naked Island shoreline. CG reports 240  feet of shoreline cleaned.
                               Skimmers move  into  Knight  Island  passage  area for oil  recovery.
                           MARCO skimmer working  in Sawmill Bay in  concert with CG  monitor.
                           OWOCRS and 84-inch boom deployed in Resurrection Bay.
                               M/V Vaydagursky with CG monitor onboard working with two tugs to
                           rig skimming booms in Resurrection Bay. 58 vessels, including 37 skimmers,
                           are operating as recovery or support craft.

APRIL 22, 1989 (THIRTIETH DAY)

                           Divers continue to cut hanging steel pieces from Exxon Valdez hull. Stopper
                           holes  are  drilled at  ends of all transverse fractures.   ADEC personnel
                           scheduled to arrive on M/V Winter King to monitor water quality and observe
                           repairs.  Some oil continues to surface from bilge keels where it is trapped.
                               Shoreline clean-up  plan for Applegate Rock area approved by FOSC.
                           Land  use permit  for clean-up  operations  on all  state-owned  tide and
                           submerged lands  received from State of Alaska for 1989.            :
                               Skimmers in Resurrection Bay unable to pump debris-contaminated,
                           weathered oil. Mr. Clean Class III skimmer recovers oil/mousse off  Gore
                           Point.  USSR  skimmer Vaydagursky shut  down for modifications. It had
                           recovered 12 barrels of oil.

APRIL 23, 1989 (THIRTY-FIRST DAY)

                           Skimming operations continue to maximum  degree possible in Prince William
                           Sound Upper  Passage, Northwest Bay,  Lower Knight Island  Passage, and
                           Eshamay Bay. Exxon estimates 2,990 total barrels recovered on April 22.
                           Adverse weather forces halt of skimming operations.
                               Vessel with  4,800 feet of boom and U.  S. Navy MARCO  skimmer
                           dispatched to Kitoi Hatchery, Izhut Bay.  Eight fishing vessels from Seldowa
                           and Port Graham deployed to Flat Island.  They are towing  herring nets in
                           attempt to collect mousse and tar balls in area.
                               Bird cleaning station opens at National Guard Armory and otter station
                           at National Marine Fisheries  Services site, Gibson Cove.  Alaska Department
                           of Fish and Game closes herring fishery on north and west side of Afognak
                           Island due to sheens in area.  Boat cleaning station  operational at Herman's
                           Harbor.
                               CG and Exxon representatives visit villages on Kodiak Island to gather
                           and disseminate information.

APRIL 24, 1989 (THIRTY-SECOND DAY)

                           Cutting hangers from Exxon  Valdez completed.  Drilling stopper holes at end
                           of fractures continues.   Stripping Forepeak  and number  1C  tank  to  be
                           completed.  Oil in number 1C tank to be boomed to reduce oil leaks. ADEC
                           personnel on M/V Winter King alongside Exxon Valdez.
                               Adverse weather continues to hamper efforts to  skim oil.  ACOE Dredge
                           Yaquina with CG skimming barrier manages to operate in South Night Island
                           Passage and Mummy Bay. Two SUPSALV skimmers work in  Northwest Bay.
                           Remainder of 58  vessels, including 37 skimmers, stay in sheltered waters.
                           Two hundred feet of shoreline cleaned during last two days.
                               CG and Exxon personnel brief Senator Stevens.
                                          Appendices-18

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APRIL 25, 1989 (THIRTY-THIRD DAY)
                           Drilling of stopper holes continues on Exxon Valdez. Booming of oil in tank
                           number 1G in progress.
                               Adverse weather continues to hamper skimming.  All western Alaska
                           skimmers, except for Mister Clean III, attempting to get to Division Bay, Naka
                           Passage to skim oil/mousse concentrated in that area. Approximately 15,000
                           feet of boom arrive in Homer and will be distributed as needed in area by
                           MAC Group. A total of 58 vessels continue to be involved in operation, but
                           42 of these now are skimmers.
                               Joint Communications Center now operational.  Phone patch capability
                           of this system allows total interconnections among all deployed units ashore or
                           afloat.

                     1900  FOSC attends evening operations meeting with Exxon personnel onboard the
                           U.S. Naval Vessel Juneau.
APRIL 26, 1989 (THIRTY-FOURTH DAY)
                           Tank cleaning and repair activities on Exxon Valdez continue. Four major
                           networks  give coverage  to  existence  of Coast  Guard tapes  of radio
                           conversations with Exxon Valdez at time of grounding.
                                Clean-up operations in western Gulf of Alaska continue to be hindered
                           by adverse weather. Due to debris-laden, weathered condition of recovered
                           oil, offloading in both western Gulf of Alaska and Prince William Sound is
                           slow and difficult.  Various super-suction devices have been tried with limited
                           success. The operation has been enhanced by heating the oil with stem coils,
                           but it takes two to two-and-a-half hours to heat approximately 32  barrels.
                                300 feet of shoreline cleaned in Northwest Bay by April 25. Multiagency
                           monitoring program is established to ensure that all shoreline segments will be
                           cleaned in the presence of a federal and state monitor.
                                58 vessels remain in clean-up operation; 42 are skimmers.

                     1730  CAPT  Calhoun, USCG, CO, MSO Portland, OR arrive on scene to survey
                           Exxon  Valdez damage and condition.
                                         1 Appendices-19

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APPENDIX B. RESPONSE FORCES ON SCENE
Exxon arid U.S. Coast Guard Response Forces On Scene , „
MARCH 24
Exxon
10 Landing Craft
(mechanized)
15 Vessels (various)
1 2,500 (t of Boom
3 Skimmers
184 Personnel
Alyeska Marine
Terminal
4 Boats
1 Class V Skimmer
1 Class VII Skimmer
1 Sea Skimmer
1 5,200 ft of Boom
1 Helicopter
3 Sea Pac Barrier
Systems
28 Personnel
U.S. Coast Guard
PACAREA Strike Team
(11 people)
MARCH 25
Exxon
52 Vessels (various)
26,000 ft of Boom
6 Skimmers
237 Personnel
U.S. Coast Guard
1 High Endurance
Cutter
1 Helicopter
1 Buoy Tender
1 32-ftBoat
PACAREA Strike
Team (13 people)
2 Strike Team Air
Deployable Anti-
Pollution Transfer
Systems (ADAPTS)
38 Personnel at
Marine Safety Office
Vatdez
MARCH 28
Exxon
71 Vessels (various)
34,000 ft of Boom
7 Skimmers
340 Personnel
U.S. Coast Guard
1 High Endurance
Cutter
1 Helicopter
1 Buoy Tender
1 32-ft Boat
1 USCGAIREYE
FALCON Plane
1 USCGC-130
Transport Plane
PACAREA Strike Team
(16 people)
5 ADAPTS
1 Strike Team Open
Water Oil
Containment
and Recovery
System (OWOCRS)
APRIL 02
Exxon
107 Vessels (various)
11 0,000 ft of Boom
1 2 Skimmers
817 Personnel
U.S. Coast Guard
1 High Endurance
Cutter
4 Helicopters
2 Buoy Tenders
1 32-ft Boat
1 USCG AIREYE
FALCON Plane
PACAREA Strike Team
(20 people)
6 ADAPTS
2 OWOCRS
11, 200 ft of Boom
96 Personnel at
Marine Safety Office,
Valdez and Anchorage
APRIL 07
Exxon
110 Vessels (various)
158,000 ft of Boom
25 Skimmers
18 Aircraft
1 046 Personnel
U.S. Coast Guard
1 High Endurance
Cutter
6 Helicopters
2 Buoy Tenders
6 Small Boats
3 Rxed Wing Planes
PACAREA Strike
Team (20 people)
6 ADAPTS
2 OWOCRS
11, 200 ft of Boom
118 Personnel at
Marine Safety Office
Valdez and
Anchorage
APRIL 12
Exxon
210 Vessels
(various)
283,000 ft of Boom
41 Skimmers
25 Aircraft
1300 Personnel
U.S. Coast Guard
2 High Endurance
Cutters
2 Medium Endurance
Cutters
4 Buoy Tenders
6 Small Boats
3 Fixed Wing
6 Helicopters
PACAREA Strike
Team (20 people)
6 ADAPTS
6 OWOCRS
15,200 ft of Boom
208 Personnel at
Marine Safety Office
Valdez and
Anchorage
^ .Other Federal Response Forees On Scene




NOAA
1 Helicopter
6 Personnel

Dept. of tha Interior
2 Personnel
Source: U.S. Coast <
U.S. Navy
2 Skimmers
4 Tow Boats
2 Support Vans


NOAA
1 Helicopter
10 Personnel

Dept. of the Interior
2 Personnel
EPA
2 Personnel


U.S. Forest
Service
2 Personnel
NOAA
1 Helicopter
13 Personnel
FAA
7 Personnel
Dept. of the Interior
21 Personnel
EPA
2 Personnel
U.S. Navy
5 Skimmers
6 Tow Boats
8 Support Vans
14 Mooring Systems
U.S. Forest
Service
6 Personnel
NOAA
1 Helicopter
14 Personnel
FAA
7 Personnel
Dept. of the Interior
23 Personnel
EPA
6 Personnel
U.S. Navy
20 Skimmers
2 Barrier Skimming
Systems
10 Tow Boats
20 Mooring Systems
11 Support Vans
94 Personnel
U.S. Forest
Service
23 Personnel
NOAA
1 Helicopter
12 Personnel
FAA
7 Personnel
Dept. of the Interior
23 Personnel
EPA
6 Personnel
3uard, 1989.
U.S. Navy
20 Skimmers
2 Barrier Skimming
Systems
10 Tow Boats
20 Mooring Systems
11 Support Vans
94 Personnel
U.S. Forest
Service
30 Personnel
1 Helicopter
NOAA
1 Helicopter
4 NOAA Data Buoys
22 Personnel
FAA
7 Personnel
Dept. of the Interior
26 Personnel
EPA
7 Personnel
National Guard
93 Personnel
           ' Appendices-20 <

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         APPENDIX C. GLOSSARY FOR KEY EQUIPMENT ON SCENE
           ADAPTS Air Deployable Anti-Pollution Transfer System
                     ADAPTS is a pumping system that is transportable in a variety of ways. It is
                     designed for rapid deployment to dewater, remove oils, or transfer a limited
                     number of liquid hazardous materials.  A Type III Avco Lycoming  diesel
                     prime mover powers the ADAPTS to push oil through a discharge hose for
                     transfer into  a suitable container.  ADAPTS is operated and owned by the
                     Coast Guard.

            AIREYE AIREYE is an aerial surveillance, information gathering, and recording system
                     installed  on  certain Coast Guard  aircraft.   This state-of-the-art  system
                     employs multiple information inputs (visual-photographic, infrared radar) to
                     monitor and track surface objects. AIREYE usually is operated on marine
                     safety and environmental monitoring missions.  It has law enforcement and
                     military applications.

            BOOMS Booms are primarily barriers used to contain or deflect an oil slick, or prevent
                     oil from reaching an environmentally sensitive area.
                     There are two general types of booms: fence booms and curtain booms.  Fence
                     booms are constructed from rigid or semi-rigid material and serve as a vertical
                     barrier against oil floating on water. Curtain booms have a flexible skirt that
                     is held down by ballasting weights or a separate tension line. Booms often are
                     referred  to  in terms of their  combined length below (draft) arid  above
                     (freeboard) the waterline. Therefore, an 18-inch boom would be one that has
                     a total barrier height above and below the waterline of 18  inches.
                            Booms are designed for special purposes.   Fire  booms consist  of
                     fireproof material to contain oil for in-situ burning.  Sorbent booms absorb
                     oil on contact and are disposable.  Ice or cold weather booms can withstand
                     extreme temperatures and ice flows. Some booms have skimming capabilities
                     that trap oil  for recovery.

            GT—185 The GT-185 is a weir skimmer utilizing gravity as a means of collecting oil.
                     With its edge placed at the waterline, the body of the  skimmer below water
                     forces oil into a pump. Oil then is conveyed to a suitable container.  The GT-
                     185's pumping system can deliver up to 440 gallons per minute.

MARCO SKIMMERS The MARCO skimmer  is  a sorbent  lifting-belt skimmer that works on a
                     conveyor belt-type  system. The lifting belt has a high affinity for oil that
                     prevents large volumes of water from being recovered along with the oil. Oil
                     is scraped or wrung from the belt into an appropriate container.  Working in
                     ideal conditions (e.g., calm water, suitable viscosity), the recovery rate is
                     between 42 and 66  gallons per minute, depending on  whether a Class V or
                     Class VII MARCO skimmer is used.

     ODI SKIMMER Towed by two vessels, the  ODI skimmer is a boom system using a barrier to
                     contain oil for recovery.  It features built-in weirs  connected to  discharge
                     hoses enabling the oil to be recovered by a pumping system.

           OWOCRS Open Water Oil Containment And Recovery System
                     Owned and operated by the Coast  Guard, OWOCRS is a  rapidly deployed,
                     very rigid high seas containment barrier that also can be used as a  skimmer.
                     OWOCRS moves in a "U"  configuration,  towed by vessels at each end.  A
                     pump float subsystem is attached to the bend of the "U."  The subsystem
                     pumps oil collected  by skimming weirs inside the "U" at a rate of 825 gallons
                     per minute into a suitable container, usually a tank barge or a towed bladder.
                     OWOCRS can be made stationary by means of a mooring system.
                                   1 Appendices-21

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SEA PAC BARRIER SYSTEM A Sea Pac Barrier System is a 23-foot boat containing 1,475 feet of inflatable
                             boom that is automatically deployed and towed at three to four knots per hour.

               TK-5 PUMPS The TK-5  pump used by the Coast Guard and the ADAPTS system share
                             some of the same components. The TK-S pump functions as a corrosive liquid
                             transfer system that also pumps viscous oils and high-temperature fluids.

  VIKOMA SEA SKIMMERS  Vikoma sea skimmers utilize a rotary disc system to attract oil.  Discs rotate
                             oil toward a centralized pumping system which then pumps it into a suitable
                             container.  In optimal conditions,  the best recovery rates for this unit is 220
                             gallons per minute.

                  VIKOVAK A VIKOVAK is a high-performance vacuum for shoreline cleanup.

            WALOSEP WEIR Walosep Weir Skimmers use gravity to drain oil from the water surface. Using
                  SKIMMER a pump to draw water-separated oil into the  system, this skimmer has an oil
                             recovery  rate of up to 264 gallons per minute.
                                           1 Appendices-22

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                                  APPENDIX D.  DISPERSANTS
    Dispersants  are  chemical solutions used  to
 reduce, the cohesiveness  of oil slicks.  They are
 designed  to  remove  oil  from the surface  of the
 water.  Oil  treated with a dispersant enters the
 water column as  fine droplets  which are  then
 distributed in three dimensions  and subjected to
 natural processes such as  biodegradation.
    When  the   application  of   dispersants  is
 technically feasible,  its  selection as  a  response
 option follows the choice between leaving the spill
 untreated and floating on the surface of the water
 where it may threaten surface resources, or treated
 and distributed in the water column where  it may
 threaten subsurface resources. The threat posed by
 the dispersed oil droplets to  subsurface resources in
 the water  column is moderated by the relatively low
 toxicity of the present generation of dispersants and
 the dilution factor.
    Dispersant use  has been controversial since its
 notable introduction as a response option following
 the sinking of the tanker Torrey Canyon off the
 United Kingdom in  1967.  Various studies since
 then have shown that the dispersants used  in this
 incident caused more  harm than good  because of
 their indiscriminate use and/or highly toxic charac-
 teristics.  Improved dispersants now in use are less
 toxic  and  more effective.
    This response option generally has not been used
 in the United States for oil  spill responses because
 of logistical difficulty, complex decision making or
 uncertain  weather conditions—or because trial ap-
 plications  and evaluation  indicate y lack of  effec-
 tiveness.
    When  an evolving response strategy seems to
 indicate an advantageous  use of dispersants, deci-
 sions  must be based on rigorous technical, biologi-
 cal, and administrative considerations.  The  On-
 Scene  Coordinator (OSC)  initiates t\ie  decision
 process for dispersant use with a "recommendation
 for concurrence" to the Environmental Protection
 Agency (EPA) and state Regional Response Team
 (RRT)  representatives.     The   Department  of
 Commerce and  Department  of  the Interior, as
 natural resource trustees, may also be consulted.
    To get RRT concurrence, a balance of many
 variables must be considered. It must be concluded
that harm from dispersant  use on the  subsurface
environment  is likely to be  less than the potential
harm  of untreated oil. Other factors that must be
considered are spill location,  type, and volume; time
elapsed since the spill;  existing and predicted wea-
 ther; water temperature; salinity and sedimentation.
 The RRT also will take into account tides and tidal
 currents; risks to biological, physical, and economic
 resources; surface and subsurface trajectories; and
 availability of  dispersants, application equipment,
 and trained personnel.
    When they  consider an OSC's "recommendation
 for concurrence" to use dispersants, federal officials
 follow a decision making process established in the
 National Oil and  Hazardous Substances  Pollution
 Contingency Plan (NCP, 40 CFR  300, Subpart H).
 The NCP contains a general authorization-for-use
 policy and an EPA listing of dispersants (the "Pro-
 duct Schedule") that may be authorized for use on
 oil spills.
    The NCP also encourages each RRT to develop
 regional guidelines for preauthorized use of disper-
 sants—allowing  the   OSC   to  forego   RRT
 concurrence under certain circumstances, because it
 had  already been obtained in the planning process.
 Criteria for preauthorization may be a combination
 of geographic, seasonal, biological, or other factors.
 The intent of preplanning and preauthorization is to
 minimize  the interval between the time of  the oil
 spill and the time of dispersant application because
 dispersant effectiveness may decrease dramatically
 relative to the elapsed time.
    Preauthorized  dispersant use decision making
 to reduce  response  time  was  pioneered  by the
 Alaska  RRT.     The  RRT   had  developed  a
 comprehensive  Regional Contingency  Plan  (RCP)
 dispersant use annex ("Dispersant Use Guidelines")
 with  input  from   industry   and   fishermen's
 associations. The Guidelines divide Prince William
 Sound  into three zones,  each with  a  different
 preauthorization process (see Figure 10).
    Zone 1  - The use of dispersants is acceptable
 and  is preauthorized by the RRT at the discretion
 of the OSC.
    Zone 2 - The use of dispersants is conditional to
 protect sensitive resources. Dispersant use is likely
 to cause less harm in this  zone than would result
 from its non-use.  Prior to authorization,  the OSC
 is required to submit a formal proposal to obtain the
 concurrence of  the EPA and Alaska Department of
 Environmental   Conservation  (ADEC)   RRT
 representatives.
   Zone 3 - The use of dispersants is not recom-
 mended.  Dispersant use is likely to  cause more
harm in this zone than would result from its non-
use.  Prior to authorization, the OSC is required to
                                          Appendices-23

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submit a formal proposal to obtain the concurrence
of the EPA and ADEC RRT representatives.
   The evaluation of an incident-specific disper-
sant  application is a  qualitative  and subjective
undertaking.   The retrospective analysis of both
decision making  and operational  effectiveness
should avoid comparisons with earlier case histories
which either cross a generation gap on the disper-
sant development timeline or involve a different set
of incident-specific  variables.   Each RRT post-
incident analysis should evaluate the dispersant
section  of the OSC report  required for major oil
spills, draw conclusions, and offer recommendations
for national, regional, and local improvements.
   National  dispersant use  policy guidance  for
coastal OSCs and RRTs was distributed by the Coast
Guard in October 1987 in a "white paper" entitled
Dispersant  Use Considerations (Commandant (G-
MER),  unpublished).   The text  recognizes  the
importance of regional autonomy  in the  develop-
ment of comprehensive dispersant use contingency
planning at the regional  and local  levels  and is
intended to provide a measure of consistency to the
approach used by RRTs.
   The Interagency  Technical Committee for the
former EPA Oil and Hazardous Materials Simulated
Test Tank (OHMSETT),  whose membership  in-
cludes the Minerals Management Service, the Coast
Guard,  EPA, the U.S. Navy, and  Environment
Canada, commissioned a National Research Council
study entitled Using Oil Spill Dispersants on the
Sea.  The study was published  in February 1989
and addresses the ecological, esthetic, and economic
elements of dispersant use in open water.  It also
includes an  assessment   of the  adequacy   of
dispersant-application technologies  available  for
spill response.  The  study draws  conclusions and
offers recommendations on all aspects of dispersant
use.  The study is currently under consideration by
the Interagency Technical Committee.

References:
Eraser,  John P.  "Methods for Making Dispersant
    Use Decisions,"  Proceedings of the  1989  Oil
    Spill Conference, American Petroleum Institute,
    Washington, D.C.,  1989, pp. 321-330.
Manen, Carol-Ann, (et al.). "Oil Dispersant Guide-
    lines: Alaska," Oil Dispersants - New Ecological
    Approaches, ASTM   STP  1018,  L. Michael
    Flaherty, Ed., American Society for Testing and
    Materials, Philadelphia, 1989, pp. 144-151.
National Research Council (NRC). Using Oil Spill
    Dispersants  on the Sea.  National Academy
    Press, Washington, D.C.,  1989, 335 pp.
U.S. Coast Guard (USCG), Commandant (G-MER).
    Dispersant Use  Considerations.   Washington,
    D.C., 1987, (Unpublished, 18 pp.).
                                         ' Appendices-24

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                 APPENDIX E. STATE OF ALASKA
               DISPERSANT USE DECISION MATRIX
                         OIL MOVING ONSHORE OR
                          INTO CRITICAL AREA(S)
                             YES    NO
  IS PHYSICAL CONTROL
 AND RECOVERY FEASIBLE?
                               -YES-
     YES
              NO
      *	  I
IMPLEMENT
1
F

ARE CONTROL/RECOVERY
ACTIONS ADEQUATE?
     YES
              NO, OR PARTIALLY
                      CAN OIL TYPE AND CONDITION
                      BE CHEMICALLY DISPERSED?
                          YES
                                   NO
     IS A DISPERSION
  OPERATION POSSIBLE?
                                -NO-
         YES
   WILL IMPACTS ASSOCIATED WITH CHEMICAL
  DISPERSION BE LESS THAN THOSE RESULTING
      WITHOUT CHEMICAL DISPERSION?
           -NO-
         YES
   REQUEST APPROVAL FOR
     USE OF DISPERSANTS
 USING ATTACHED PROCEDURE
-YES-
                   IS ACTION REQUIRED
                     OR DESIRED?
                    TREAT
                   ONSHORE
                                                       NO
  WILL VULNERABLE RESOURCES
   OR HABITATS BE ADVERSELY
IMPACTED WITHOUT DISPERSANT USE?
SOURCE: ALASKA REGIONAL CONTINGENCY PLAN
                         1 Appendices-25

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              APPENDIX F.  NATIONAL RESPONSE TEAM MEMBERS
                  Department of Agriculture

           Department of Commerce (NOAA)

                     Department of Defense

                     Department of Energy

            Environmental Protection Agency

      Federal Emergency Management Agency

    Department of Health and Human Services
                                 (ATSDR)

                  Department of the Interior

                      Department of Justice

               Department of Labor (OSHA)

                        Department of State

   Department of Transportation (Coast Guard)

               Department of Transportation
(Research and Special Programs  Administration)
Mr. Bill Opfer

Mr. George Kinter

Mr. Brian Higgins

Mr. Richard Dailey

Mr. Jim Makris, Chair

Mr. Craig Wingo

Ms. Georgi Jones


Ms. Cecil Hoffmann

Ms. Sheila Jones

Mr. Frank Frodyma

Mr. Bob Blumberg

Capt. Richard Larrabee, Vice-Chair

Mr. Alan Roberts
              Nuclear Regulatory Commission    Mr. Bernard Weiss
                                     Appendices-26

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                            APPENDIX G. ACRONYM GLOSSARY
 ACOE:      Army Corps of Engineers
 ADAMHA:  Alcohol, Drug Abuse, and Mental
                Health Administration
 ADAPTS:    Air Deployable Anti-Pollution
                Transfer System
 ADDS:      Air Deliverable Dispersant System
 ADEC:      Alaska Department of
                Environmental Conservation
 AIREYE:    See Appendix C, Equipment
                Glossary
 ANILCA:    Alaska National Interest Lands
                Conservation Act
 ANS:        Alaskan North Slope
 AOSC:       Alyeska Oil Spill Coordinator
 ATSDR:     Agency for Toxic Substances and
                Disease Registry

 CDC:        Centers for Disease Control
 CERCLA:    Comprehensive Environmental
                Response, Compensation, and
                Liability Act (Superfund)
 CG:         U.S. Coast Guard
 COTP:       Captain of the Port
 CWA:        Clean Water Act

 DOD:        Department of Defense
 DOE:        Department of Energy
 DOI:         Department of the  Interior
 DOMS:      Director of Military Support

 EPA:         Environmental Protection Agency

 FAA:        Federal Aviation Administration
 FDA:        Food and Drug Administration
 FOSC:        Federal On-Scene Coordinator
 FWS:         Fish and Wildlife Service
 FY:          Fiscal Year

IBRRC:      International Bird Rescue Research
             Center
IMO:         International Maritime Organization

JTF:         Joint Task Force
 LANTAREA: Atlantic Area (USCG)

 MAC:        Military Airlift Command
 MARCO:     See Appendix C, Equipment
                 Glossary
 MSO:         Marine Safety Office (USCG)
 M/V:         Motor Vessel

 NCP:         National Oil and Hazardous
                 Substances Pollution
                 Contingency Plan (National
                 Contingency Plan)
 NOAA:       National Oceanic and Atmospheric
                 Administration
 NRC:         National Response Center
 NRC:         National Research Council
 NRS:         National Response System
 NRT:         National Response Team
 NTSB:        National Transportation Safety
                 Board

 OSC:         On-Scene Coordinator
 OSHA:        Occupational Safety and Health
                 Administration
 OWOCRS:     Open Water Oil  Containment and
                 Recovery System

 PACAREA:   Pacific Area (USCG)

 RCP:         Regional Contingency Plan
 RRT:         Regional Response Team

 SSC:          Scientific Support Coordinator
 SUPSALV:    Supervisor of Salvage (U.S.  Navy)

 TAPAA:      Trans-Alaska Pipeline
              Authorization Act
 TAPS:         Trans-Alaska Pipeline System
 T/V:          Tank Vessel

USCG:        U.S. Coast Guard

VIKOVAK:   See Appendix C, Equipment
                 Glossary
VTS:          Vessel Traffic Service
                                        1 Appendices-27

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                            APPENDIX H. SHORELINE IMPACTS
          Exposed Rocky Shores
o Common along  open coastal  areas of Prince
   William Sound and the Gulf of Alaska.
o Composed of steeply-dipping to vertical bedrock.
o Exposed to  moderate to high wave action.
o Barnacles, mussels, snails, and various species of
   algae are common in most areas.
Predicted Oil  Impact
o Most  commonly,  oil will  be held  offshore by
   waves reflecting off the steep cliffs.
o On less steep shores, oil may come onshore.
o Oil persistence is related to the incoming wave
   energy; during high-wave conditions, oil persis-
   tence is limited to days.
o Oil trapped in tidal pools will kill  resident or-
   ganisms.
o The damage to the intertidal community is ex-
   pected to be relatively light, with fairly rapid
   recovery.
o Diving birds using these rocky sites may be killed
   if oiled.
Recommended Response Activity
o On most shores, no cleanup is necessary (and may
    be dangerous).
o Access is usually  difficult.
o Cleanup of recreational areas may be necessary;
    high-pressure water spraying is effective while
    oil is still fresh.
       Exposed Wave-Cut Platforms
o Very common along  exposed portions of inner
   Prince William Sound and the Gulf of Alaska.
o Consist of wave-cut or low-lying bedrock.
o May be very wide due to large tidal range.
o Commonly  contain   narrow,   mixed-sediment
   beaches along the high-tide swash zone.
o The lower intertidal zone contains extensive algal
   growth.
o Tide pools and organisms  are  common in the
   lower-to-middle intertidal zone.

Predicted  Oil Impact
o Incoming oil commonly will form a band along
   the high-tide swash line.
o Tide-pool organisms  may be killed.
o Lower intertidal algae may escape damage, de-
   pending on tidal stage and oil type and quantity.
o Oil persistence is limited (days to weeks) in most
   high-energy areas.
Recommended Response Activity
o In most wave-exposed areas, cleanup is not neces-
    sary.
o Removal of organisms should be avoided.
                                                   Source: Adapted from NOAA, 1983. Sensitivity of Central Environ-
                                                   ments and Wildlife to Spilled Oil, Prince William Sound. Alaska.
                                          ' Appendices-28

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      Mixed Sand and Gravel Beaches
o Very common throughout the study site.
o Present in both sheltered and exposed areas.
o Common as a narrow beach or stringer to top of
    bedrock platforms.
o Composed of coarse-grained  sand,  gravels  of
    varying sizes, and possibly shell fragments.
o On active beaches, organisms are scarce due to the
    harshness of the environment.
o In stable habitats, algae may be attached to the
    larger gravel or boulder components.
o The  larger rocks also may provide habitat for
    mussels, crabs, and snails.
Predicted Oil Impact
o Oil will be deposited primarily along  the high-
    tide swash zone.
o Under very heavy accumulations, oil may spread
    across the entire beach face.
o Oil percolation into the beach may be up to 60 cm
    in well-sorted material.
o Burial may be very deep along the berm.
o Biota present  may be killed by the oil, either by
    smothering  or  by  lethal concentrations in the
    water column.
Recommended  Response Activity
o Remove oil primarily from the upper swash lines.
o Removal of sediment should be limited.
o Mechanical reworking of the sediment into the
    wave zone and/or high pressure water spraying
    can remove the oil effectively;  sorbent boom
    may be necessary to capture oil outflow.
               Gravel Beaches
o Fairly common throughout areas dominated by
    bedrock.
o Composed of gravel of varying sizes.
o Shell  fragments and woody debris also are com-
    mon beach components.
o Biomass generally is very low in high-wave areas;
    at calmer sites, the population of fauna and
    attached algae may be fairly great: crabs, snails,
    mussels, barnacles, and attached algae are most
    common.
Predicted Oil Impact
o Under light-to-moderate oil concentrations, oil
    would be deposited  primarily along the  high-
    tide swash zone.
o With heavy oil quantities,  the entire beach face
    may be covered.
o Oil may percolate rapidly and deeply (up to 1 m)
    into the beach face.
o If oil is left to harden, an asphalt/gravel pavement
    may result.
o Resident fauna and flora may be killed by the oil.
Recommended Response Activity
o Removal of sediment should be restricted.
o Pushing gravel into the active surf zone  and use
    of high-pressure water spraying is effective in
    removing oil while it is still fresh.
o Sorbent boom should be used to capture  oil out-
    flowing during the cleansing process described
    above.
                                            Appendices-29

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             Exposed Tidal Flats
o Particularly common in Orca Inlet and in front of
   the Copper River delta.
o Also found on the  very wide uplifted  bedrock
   platform  fronting  Kayak Island.
o Visible only at low tide.
o Exposed to low-to-moderate wave energy and/or
   tidal currents.
o Composition is most  commonly sand or mixed
   sand and  gravel.
o Species density and diversity may be high; soft-
   shelled clams and worms are most important.
o Many millions of migrating birds use these flats as
   a seasonal feeding ground.
Predicted Oil Impact
o Most oil will be pushed across the flat as the tide
   rises.
o Deposition of  oil on the flat  may occur  on a
   falling tide if oil concentrations are heavy.
o Biological damage may be severe.
Recommended Response Activity
o Cleanup is very difficult (and possible only during
   low tides).
o The use of heavy machinery should be restricted
   to prevent mixing oil into the sediments.
o On sand flats, oil will be removed naturally from
   the flat and deposited on the  adjacent beaches
   where cleanup is  more  feasible. In  gravelly
   areas, oil may bind with  the sediment; high-
   pressure water spraying may be necessary.
          Sheltered Rocky Shores
o Composed of bedrock outcrops, ledges, or bould-
   ers.
o Common within the sheltered, interior portions of
   Prince William Sound.
o Species density and diversity vary greatly,  but
   barnacles, mussels, crabs, snails, and rockweed
   often are very abundant.
Predicted Oil Impact
o Oil  will  persist for several years, especially  be-
   tween  rocks.
o Upper intertidal biota and algae will be the most
   severely affected.
o Algae present in the lower intertidal zone are most
   resistant to damage.
Recommended  Response Activity
o These  areas   need  priority protection  using
   deflection booms, sorbent booms, and offshore
   skimmers.
o High- and low-pressure water spraying is effec-
   tive while oil is still  fresh.
o Cutting  of oiled  algae is generally not recom-
   mended.
                                           1 Appendices-30 '

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            Sheltered Tidal Flats
o Very common in the upper portions of Orca Inlet,
    adjacent to marshes of the Copper River delta,
    and in the upper portions of many fjords.
o Present  in  calm water habitats, sheltered from
    major wave activity.
o Composed of muds.
o Usually contain large populations of razor clams,
    worms, and snails; commercial harvesting of
    shell fish occurs on many of these flats.
o Seasonally, bird life is very abundant (millions) in
    the Copper River delta/Orca inlet area.
Predicted Oil Impact
o Oil may persist for many years.
o Incorporation of oil into tidal-flat sediments over
    the long-term is common.
o Oil  deposition  commonly will occur along  the
    upper fringes of the flat.
o Very heavy oil accumulations will cover much of
    the surface of the flat.
o Biological damage may be severe.
Recommended Response Activity
o This is a  high-priority area necessitating the use
    of spill  protection devices to prevent or limit oil
    spill  impact;  open-water  deflection, sorbent
    booms, and open-water skimmers should  be
    used.
o Cleanup of the flat surface  after oiling is very
    difficult because of the soft substrate.
o Manual operations  from shallow draft boats may
    be helpful.
                   Marshes
o Small marshes  common at the head  of many
    fjords; broad  fringing marsh along the Copper
    River delta.
o Very sheltered from wave and tidal activity.
o Composed primarily of Spartina grasses on an rich
    organic mud base.
o The  Copper River delta region supports over 20
    million migratory shorebirds and several hund-
    red thousand waterfowl.
o Marshes are nursery grounds for numerous fish
    species; also, crabs are particularly common.
o The  Copper River delta area is the only nesting
    area of the dusky Canada goose.
Predicted Oil Impact
o Oil  in  heavy  accumulations may  persist   for
    decades.
o Small quantities of oil primarily will be deposited
    along the outer marsh fringe or along the upper
    wrack (debris) swash line.
o Resident biota, including bird life, is likely to be
    oiled and possibly killed.
Recommended Response  Activity
o Under light oiling, the best practice is to let the
    marsh recover naturally.
o Cutting  of  oiled grasses and low-pressure water
    spraying is effective, especially during the early
    part of the spring growing season.
o Heavy  oil accumulations  on the marsh surface
    should be removed manually; access across the
    marsh should be greatly restricted.
o Clean-up activities should be supervised carefully
    to avoid excessive damage to the marsh.
                                           Appendices-31

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