EVALUATION
OF THE
OIL SPILL
ENFORCEMENT PROGRAM
CHI ASSOCIATES. INC.
SUITE 316
1011 ARLINGTON BLVD.
ARLINGTON, VA. 22209
PHONE: (703)527-8704
527-8705
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Chi associates, inc.
SUITE 316
1011 ARLINGTON BOULEVARD
ARLINGTON, VA. 22209
(703)527-6704
RESEARCH AND DEVELOPMENT CONSULTING ENGINEERS SYSTEMS ANALYSIS
EVALUATION
OF THE
OIL SPILL
ENFORCEMENT PROGRAM
BY
EDDIE NEAL
ANN DALSIMER
SUBMITTED TO
THE ENVIRONMENTAL PROTECTION AGENCY
COMPLIANCE BRANCH, ENFORCEMENT DIVISION
CONTRACT : EPA - 68 - 01 -3918
MAY 25,1978
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ABSTRACT
An evaluation of EPA's oil spill enforcement program was undertaken
to determine the correlation between EPA spill enforcement activities
and the number and volume of oil spills. Spill and enforcement
statistics were analyzed with emphasis on non-transportation related
spills, the prevention of which the Agency has been legally delegated
responsibility under Executive Order 11735.
It was determined in the course of the project that EPA regional
enforcement program activity is not divided strictly along transportation
and non-transportation lines and that, furthermore, only certain non-
transportation facilities are subject to spill prevention regulations.
Nevertheless, examination of available data has revealed that overall
non-transportation related spills, especially those minor in nature,
are decreasing, suggesting that more spills are being averted or
contained due to preventive measures.
In-depth study of four widely different EPA regional enforcement
programs revealed that programs varied greatly regarding implementation
of national guidelines. It was noted that in those regions where the
enforcement and prevention/response components were located within the
same organizational unit, program efficiency was increased.
Five specific recommendations have been made as a result of this
six-month investigation. These deal with elevating prevention as a
national priority, changing the definition of "non-transportation related
facilities" to permit the Agency to establish preventive regulations
for pipelines, achieving optimum administrative organization, improving
methods of record-keeping through computerized files and, finally,
performing cost-effectiveness studies to determine to what degree the
SPCC program may be self-supporting and/or contributing to response
costs.
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ACKNOWLEDGEMENTS
The preparation of this report would not have been possible
without the assistance and encouragement of concerned and conscientious
individuals in Washington and in each of the regions. It is not possible
here to cite the special contributions made by the people listed below.
Each gave of their time and energy to provide useful information and
guidance in the development of the project.
In Washington, D.C., we would especially like to thank:
Teresa Wehner, EPA Office of Enforcement, who as our Project Officer
was consistently helpful, available for consultation, and deeply concerned
about the success of the study. We appreciate her insight and interest in
the project and have tried to the greatest possible extent to follow guide-
lines which she suggested.
Tom Charlton, EPA Office of Oil and Special Materials Control, whose
help was invaluable in the preparation of material and development of
understanding of the problems involved in analyzing the regional programs.
We have profited from his sharing with us his many years of experience in
the oil spill program.
Ensign Mark Ives, Office of Marine Environment and Systems, U.S.
Coast Guard, who over a period of several months, expended a great deal of
time from his already hectic schedule to assist us in the interpretation
and analysis of data from the PIRS File. Without his competent help, it
would have been impossible to have developed the oil spill statistics within
the allotted time.
Others in Washington whose help is deeply appreciated are: Jean
Wright, Richard Smith and John Golueke of EPA; and Walter Dupree, Lulie
Crump and Charles Readling of the Department of Energy.
In the Regions, we are indebted to the following people:
Region I - Jack Conlon, Veronica Harrington, Dave MclntyTe, Bill Torrey,
Wayne Wirtanen.
Region II - ClaTk Price, James Yezzi.
Region III - John Gilbert, Ann-Marvel, Tom Massey, Neil Wise.
Region IV - Ann Asbell, Marcia Glenn, George Moein, Frances Seymour, A1
Smith.
Region V - Eileen Bloom, Charles Castle, Russ Diefenbach, Cindy
Shamburger, Wayne Wilcox.
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Region VI - Tony Anthony, Brenda Christian, Jim Collins, Wally Cooper,
Ralph Corley, Dave Curtis, Richard Hill, Dick Peckham, Barry Reid,
Guanita Reiter, Don Washington.
Region VII - D.H. Frame, Gene Reid, Martha Steincamp, Pat Suhr, David
Tripp.
Region VIII - Virginia Burns, Jerry Cross, Dick Jones, Pete Larsen, John
Lepley, Floyd Nichol, C. Alvin Yorke
Region IX - Harlan Agnew, Ron Clawson, Jim Jaffe, Eilash Metrisian, Dave
Mowday, Mike Sternburg, Jack White, Maria Zapata.
Region X - Mike Garcia, Carl Kitz.
To many others who aided in assembling data, photocopying files, and
other tasks we also owe a debt of gratitude. A special factor in the
preparation of this report has been the spirit of cooperation and
interest which has prevailed during the entire study.
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DEFINITIONS USED IN THE REPORT
Amendment inspection: An inspection conducted under provisions of
C.F.R.§ 112.4 by which EPA may require an amendment to a
facility's SPCC Plan following a triggering spill.
Assessment: An initial monetary penalty prescribed for infractions
of oil spill or spill prevention regulations.
Barrel (bbl): Forty-two United States gallons.
C.F.R.: Code of Federal Regulations.
Coastal waters: Those U.S. waters navigable by deep draft vessels,
the contiguous zone, the high seas and other waters subject to
tidal influence.
Collection: An amount of money received from the owner or operator of
a facility found to be in violation of a given section of the FWCPA.
Compliance inspection: An inspection of a facility to determine the
existence, implementation and certification of an SPCC plan.
Effectiveness: Degree- to which enforcement activity affects oil spills
in decreasing their occurrence and/or severity.
Enforcement Activity: Those actions taken by EPA under the provisions
of particular sections of the FWPCA.
FWPCA: The Federal Water Pollution Control Act
Inland waters: Generally, those waters upstream from coastal waters.
Local program: Any one of the ten EPA regional oil spill enforcement
programs.
Major spill:.. An oil spill amounting to more than 10,000 gallons of oil
discharged into inland waters or more than 100,000 gallons into
coastal waters.
Medium (moderate) spill: An oil spill amounting to 1,000 to 10,000
gallons of oil discharged into inland waters or 10,000 to
100,.000 gallons into coastal waters.
Minor spill: An oil spill amounting to less than 1,000 gallons discharged
into inland waters or less than 10,000 gallons into coastal waters.
Non-transportation related: A characterization applied to onshore and
offshore facilities as defined in the Memorandum of Understanding
between the Secretary of DOT and the Administrator of EPA, dated
November 24, 1971 (36 F.R. 24080).
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NOV: Notice of Violation of subsection 311(j)(2) of the FWPCA as
defined in 40 C.F.R. §. 112.
Oil: Any form of oil including petroleum, fuel oil, sludge, oil refuse
and oil mixed with wastes other than dredged spoil.
Offshore facility: A facility of any kind located in, on, or under the
navigable waters of the United States, other than a vessel or public
vessel.
Oil spill: The discharge of oil into or upon the navigable waters of
the U.S. or adjoining shorelines in harmful quantities as defined
in 40 C.F.R. § 110.
On-Scene Coordinator: The Federal official pre-designated by EPA or
the U.S. Coast Guard to coordinate and direct Federal discharge
removal efforts under Regional Contingency Plans at the scene of an
oil or hazardous substance discharge.
Onshore facility: A facility of any kind located in, on, or under any
land within the United States, other than submerged land.
Resolution time: Time lapse between a spill incident and the termination
of enforcement activity for that particular case.
SPCC: Spill Prevention Control and Countermeasure (plan).
Spill potential: The total amount of oil that may be spilled in a particular
time and place.
Spill rate: Volume of oil spilled per unit of spill potential.
Statistically significant value: A value whose outcome has only a five
percent probability of occurring on the basis of chance alone.
Tendency: A statistically non-significant outcome whose trend may not be
quantifiable.
Transportation-related: A characterization applied to an onshore or
offshore facility, as defined in the Memorandum of Understanding
between the Secretary of DOT and the Administrator of EPA, dated
November 24, 1971 (36 F.R. 24080).
Trend: A series of incidents or outcomes which appear to be developing
some degree of direction or reflecting some statistically
significant connection, so that the next event might be predictable.
Triggering spill: A spill of over 1,000 gallons or the second of two
reportable spills within 12 months at a facility subject to SPCC
regulations.
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Violation: An infraction of provisions of Sections 311(b)(5), 311(b)(6)
or 311(j)(2) of the FWPCA.
"308!' letter" A letter written under authority of Section 308 of the
FWPCA.
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CONTENTS
Abstract i
Acknowledgements ii
Definitions Used in the Report iv
Tables ix
Figures xii
Conclusions xvii
Recommendations xix
1. Introduction 1
1.1 Background 1
1.2 Purpose of the Study 4
1.3 Project Scope 5
1.4 Organization of the Report 6
2. Data Sources for the Study 7
1.1 Spill Data 7
1.2 Enforcement Data 8
3. Spill Trends 10
3.1 National Spill Trends 10
3.2 Comparison of Transportation and Non-Transportation
Related Spill Trends 12
3.3 Spill Rate Trends 16
4. Enforcement Trends 19
4.1 Introduction 19
4.2 National Enforcement Trends 20
5. Enforcement-Spill Correlation 25
5.1 The Correlation Problem 25
5.2 Development of Measures of Effectiveness 25
5.3 Application to Spill-Enforcement Data 29
Enforcement/Spill Ratios 29
Formal Statistical Correlation 29
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6. Analysis of Regional Enforcement Programs 31
6.1 An Overview of the In-Depth Studies 31
6.2 Local Program Selection 31
6.3 The Enforcement Program in Region III 32
Program Organization 33
Enforcement Policy 33
Program Activity 37
Unique Program Features 38
6.4 The Enforcement Program in Region VI 38
Program Organization 39
Enforcement Policy 39
Program Activity 42
Unique Program Features 43
6.5 The Enforcement Program in Region VII 44
Program Organization 44
Enforcement Policy 47
Program Activity 48
Unique Program Features 48
6.6 The Enforcement Program in Region IX 49
Program Organization 49
Enforcement Policy 53
Program Activity 54
Unique Program Features 56
6.7 Assessment of Local Program Effectiveness 57
Relations with the Coast Guard and the States 58
Staffing 58
Record-Keeping 59
The SPCC Computer File 60
B(5) Referrals 62
Cost-Effectiveness Considerations 63
7. Addendum: "An Ounce of Prevention " 65
Bibliography 67
Appendix A: Tables a-1
Appendix B: Figures b-1
Appendix C: Linear Regression Model Used in Data Analysis c-1
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TABLES
Number Title Page Number
1 Total Number of Spills by Region and Year a- 1
2 Total Spill Volume by Region and Year a- 2
3 Average Volume Spilled by Region and Year a- 3
4 Total Number of Transportation Related Spills by
Region and Year a-- 4
5 Total Number of Non-Transportation Related Spills
by Region and Year a~ 5
6 Percentage of Non-Transportation Related Spills
as (Transportation+Non-Transportation) Spills a- 6
7 Total Volume of Transportation Related Spills by
Region and Year a~ 7
8 Total Volume of Non-Transportation Related Spills
by Region and Year a- 8
9 Percent Non-Transportation Related Spill Volume
by Region and Year a- 9
10 Average Volume of Transportation Related Spills
by Region and Year a-10
11 Average Volume of Non-Transportation Related
Spills ; a-11
12 Total Number of Minor Non-Transportation Related
Spills by Region and Year a-12
13 Total Number of Moderate Non-Transportation Related
Spills by Region and Year a-13
14 Total Number of Major Non-Transportation Related
Spills by Region and Year a-14
15 Total Volume of Minor Non-Transportation Related
Spills by Region and Year a-15
16 Total Volume of Moderate Non-Transportation Related
Spills by Region and Year a-16
17 Total Volume of Major Non-Transportation Related
Spills by Region and Year — a"17
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Number Title Page Number
18 Average Volume of Minor Non-Transportation
Related Spills by Region and Year a-18
19 Average Volume of Moderate Non-Transportation
Related Spills by Region and Year a-19
20 Average Volume of Major Non-Transportation
Related Spills by Region and Year a-20
21 Total Oil Spill Potential by Region and Year a-21
22 Spill Rate in Gallons Spilled Per Thousand
Gallons Exposed a-22
23 Total Number of SPCC Violations by .Region
and Year a-23
24 Total Number of SPCC Assessments by Region
and Year a-24
25 Total Amount of SPCC Assessments by Region
and Year a-25
26 Average Amount of SPCC Assessments by Region
and Year a-26
27 Total Number of SPCC Collections by Region
and Year a-27
28 Total Amount of SPCC Collections by Region
and Year a-28
29 Average Amount of SPCC Collection by Region
and Year a-29
30 Proposed Spill Penalties by Year and Region a-30
31 Collected Spill Penalties by Year and Region a-31
32 Percentage Amounts of Spill Penalties Collected a-32
33 Percentage Amounts of Assessed SPCC Penalties
Collected a-33
34 Total Number of 311(b)(5) Violations by
Region and Year a-34
35 Disposition of 311(b)(5) Cases by Region and Year-- a-35
36 Ratio of Number of SPCC Violations to Number of
Non-Transportation Related Spills a-36
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Number Title Page Number
37 Average SPCC Assessment Per Gallon of
Average Spill Volume a-37
38 Amount of SPCC Assessments Per Non-Transportation
Related Spill by Region and Year a-38
39 Average Amount of SPCC Collection Per Average
Volume of Non-Transportation Related Spill a-39
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figures'
Number Titles Page Number
1 National Total Oil Spill Trends by Year ^
2 EPA Regional Total Oil Spill Trends 1973 2
3 EPA Regional Total Oil Spill Trends 1974 3
4 EPA Regional Total Oil Spill Trends, 1975 - 4
5 EPA Regional Total Oil Spill Trends, 1976 b- 5
6 National Transportation Related Oil Spill
Trends by Year b- 6
7 National Non-Transportation Related Oil Spill
Trends by Year b- 7
8 EPA Regional Transportation Related Oil Spill
Trends, 1973 b- 8
9 EPA Regional Transportation Related Oil Spill
Trends, 1974 b- 9
10 EPA Regional Transportation Related Oil Spill
Trends, 1975 b-10
11 EPA Regional Transportation Related Oil Spill
Trends, 1976 b-11
12 EPA Regional Non-Transportation Related Oil
Spill Trends,1973 b-12
13 EPA Regional Non-Transportation Related Oil
Spill Trends, 1974 b-13
14 EPA Regional Non-Transportation Related Oil
Spill Trends, 1975 b-14
15 EPA Regional Non-Transportation Related Oil
Spill Trends,1976 b-IS
16 National Total Minor Transportation Related
Oil Spill Trends by Year b-16
17 National Total Moderate Transportation
Related Oil Spill Trends by Year b-17
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Number Title Page Number
18 National Total Major Transportation Related Oil
Spill Trends by Year b-18
19 National Total Minor Non-Transportation Related
Oil Spill Trends by Year b-19
20 National Total Moderate Non-Transportation Related
Oil Spill Trends by Year b-20
21 National Total Major Non-Transportation Related
Oil Spill Trends by Year b-21
22 Minor Non-Transportation Related Oil Spill Trends
by Year, Region I ¦ b-22
23 Minor Non-Transportation Related Oil Spill Trends
by Year, Region II b-23
24 Minor Non-Transportation Related Oil Spill Trends
by Year, Region III b-24
25 Minor Non-Transportation Related Oil Spill Trends
by Year, Region IV b-25
. 26 Minor Non-Transportation Related Oil Spill Trends
by Year, Region V b-26
27 Minor Non-Transportation Related Oil Spill Trends
by Year, Region VI b-27
28 Minor Non-Transportation Related Oil Spill Trends
by Year, Region VII b-28
29 Minor Non-Transportation Related Oil Spill Trends
by Year, Region VIII b-29
30 Minor Non-Transportation Related Oil Spill Trends
by Year, Region IX b-30
31 Minor Non-Transportation Related Oil Spill Trends
by Year, Region X b-31
32 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region I b-32
33 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region II b-33
34 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region III b-34
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Number Title Page Number
35 Moderate Non-Transportation Related Oil;Spill Trends
by Year, Region IV b-35
36 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region V b-36
37 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region VI b-57
38 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region VII b-38
39 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region VIII b-39
40 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region IX b-40
41 Moderate Non-Transportation Related Oil Spill Trends
by Year, Region X b-41
42 Major Non-Transportation Related Oil Spill Trends
by Year, Region I b-42
43 Major Non-Transportation Related Oil Spill Trends
by Year, Region II b-43
44 Major Non-Transportation Related Oil Spill Trends
by Year, Region III b-44
45 Major Non-Transportation Related Oil Spill Trends
by Year, Region IV b-45
46 Major Non-Transportation Related Oil Spill Trends
by Year, Region V b-46
47 Major Non-Transportation Related Oil Spill Trends
by Year, Region VI b-47
48 Major Non-Transportation Related Oil Spill Trends
by Year, Region VII b-48
49 Major Non-Transportation Related Oil Spill Trends
by Year, Region VIII b-49
50 Major Non-Transportation Related Oil Spill Trends
by Year, Region IX b-50
51 Major Non-Transportation Related Oil Spill Trends
by Year, Region X b-51
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Number Title Page Number
52 EPA Regional Total Minor Non-Transportation
Related Oil Spill Trends, 1973-1976 - b-52
53 EPA Regional Total Moderate Non-Transportation
Related Oil Spill Trends, 1973-1976 - b-53
54 EPA Regional Total Major Non-Transportation
Related Oil Spill Trends, 1973-1976 b-54
55 EPA Regional Total Minor Non-Transportation
Related Oil Spill Trends, 1973 b-55
56 EPA Regional Total Minor Non-Transportation
Related Oil Spill Trends, 1974 b-56
57 EPA Regional Total Minor Non-Transportation
Related Oil Spill Trends, 1975 b-57
58 EPA Regional Total Minor Non-Transportation
Related Oil Spill Trends, 1976 b-58
59 EPA Regional Total Moderate Non-Transportation
Related Oil Spill Trends, 1973 b-59
60 EPA Regional Total Moderate Non-Transportation
Related Oil Spill Trends, 1974 b-60
61 EPA Regional Total Moderate Non-Transportation
Related Oil Spill Trends, 1975 b-61
62 EPA Regional Total Moderate Non-Transportation
Related Oil Spill Trends, 1976 b-62
63 EPA Regional Total Major Non-Transportation
Related Oil Spill Trends, 1973 b-63
64 EPA Regional Total Major Non-Transportation
Related Oil Spill Trends, 1974 b-64
65 EPA Regional Total Major Non-Transportation
Related Oil Spill Trends, 1975 b-65
66 EPA Regional Total Major Non-Transportation
Related Oil Spill Trends, 1976 b-66
67 National Total Minor Unknown Source Related Oil
Spill Trends by Year b-67
68 National Total Moderate Unknown Source Related Oil
Spill Trends by Year b-68
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Number Title Page Number
69 National Total Major Unknown Source Related Oil
Spill Trends by Year b-69
70 National Oil Spill Potential in Billion Gallons per
Year (1960-1975)— b-70
71 Oil Spill Potential for Each Region in Billion Gallons
per Year (1960-1975) b-71
72 National SPCC Assessment Trends, 1974-1977 b-72
73 National SPCC Collection Trends, 1974-1977 b-73
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CONCLUSIONS
The conclusions drawn here are based on data analysis, study o£
program guidelines and direct observations in the field and are the
result of a six month effort which began in EPA/Washington's Office of
Enforcement. We have divided our conclusions into four categories:
• Program Administration. These conclusions were developed,
from on-site visits to EPA/Washington's Office of Enforcement
and to each regional office.
• Enforcement Program Statistics. These conclusions were
developed from analysis of data obtained during the National
Overview phase of the project.
• Enforcement-Spill Correlation. These conclusions were
developed from analysis of data obtained during the National
Overview phase of the project.
•- Enforcement Program Effectiveness. These conclusions were
developed, using the first three categories as input and
through direct observation in the field during the in-depth
study phase of the project.
Program Administration
1. The oil spill enforcement program has always been a low priority
program in EPA.
2. National program guidelines have shown declining emphasis on the
spill prevention program.
3. Regional Administrators exercise wide latitude in implementing
the oil spill enforcement program.
4. Regional programs vary widely in the level of support given to oil
spill enforcement.
Enforcement Program Statistics
1. Available enforcement statistics are generally of poor quality due
to the absence of systematic record-keeping at both the
national and regional levels.
2. Enforcement program statistics often fail to distinguish non-
transportation related spills from transportation related spills.
3. It is impossible to identify from available statistics which non-
transportation- related spills occurred at facilities subject to
SPCC plans.
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4. Available program statistics cannot identify facilities whose
SPCC plans have succeeded in containing spills.
5. The SPCC computer file has not realized its potential in documenting
and maintaining oil spill program statistics.
Enforcement-Spill Correlation
1. Non-transportation related spills indicate a decreasing trend over
the study period.
2. The number and amount of SPCC assessments and collections indicate an
increasing trend over the study period.
3. Transportation related spills indicate an increasing trend over the
study period.
4. The number and amount of proposed and collected spill penalties
indicate a statistically significant decrease over the study period.
5. SPCC enforcement activity is most strongly correlated with minor
non-transportation related spills.
6. The decreasing trend in national non-transportation related spill
statistics can be reasonably assumed to have resulted from increased
SPCC activity.
Enforcement Program Effectiveness
1. The oil spill enforcement program is generally effective in responding
to national guidelines.
2. The SPCC program is an excellent preventive concept. Adequate
resources, however, have not been allocated in any region to realize
its full potential.
3. The most systematic enforcement programs are those in which Enforce-
ment and Surveillance and Analysis staff work in a close partnership.
This permits implementation of a balanced program involving prevention,
response and enforcement aspects.
4. Enforcement program efficiency is enhanced in those regions where
inspection/response staff members and their legal counterparts are
located within the same division.
5. Regional enforcement program effectiveness is often hampered by the
rapid turnover of legal personnel.
6. Remarkable levels of effective enforcement program activity have
been achieved in most regions in relation to the available
resources. This attests to the high degree of personal dedication
on the part of program staff and line managers in these programs.
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RECOMMENDATIONS
Based on the conclusions reached and detailed in the preceding
section, we recommend the following:
® that EPA raise the priority of oil spill and SPCC enforcement
within its Water Quality Enforcement Program. Sufficient
additional resources should be allocated to the SPCC
enforcement program to permit a system of comprehensive
initial and follow-up inspection procedures combined
with a continuous and vigorous spill enforcement effort.
Limited data available on the spill prevention program
indicate that, when properly implemented, the SPCC
program is effective in reducing the incidence and
severity of spills. A substantial increase in EPA's
commitment to prevention through SPCC enforcement is
required if maximal benefit is to be derived from th6
program.
• that EPA enter into negotiations with the Department
of Transportation to amend the definition of non-
transportation facilities to include onshore pipelines.
A significant number of all onshore spills are from
pipelines and several of these have been identified as
chronic violators. Preventive measures on pipelines,
such as mandatory pressure testing, would serve to reduce
both the incidence and severity of such spills and
lessen the need for EPA on-scene response actions.
• that EPA adopt as national policy a procedure that is
being applied in several regions to combine the
prevention/response and legal components of the oil
spill enforcement program into common organizational
units. This would increase program efficiency by
reducing the amount of inter-office coordination
required in the enforcement process and provide a higher
level of program continuity, especially during periods
of personnel changes. Experience indicates a rapid
turnover of legal personnel whereas prevention/response
staffing has remained more stable.
• that a standardized system of record-keeping be
established on a national basis. In order to achieve
this goal, it will be necessary for representatives of
Headquarters and the regions to decide the extent of
information needed to monitor program activity and to
further evaluate its effectiveness. Ideally, a
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computerized data file should be implemented for
easy access by both Headquarters and the regions. As
a first step, we recommend that the SPCC computer file
be investigated to determine how it can be made into a
useful tool. If corrective modifications can be made,
it will then be necessary to allocate resources in
Headquarters to maintain and operate the system and
provide user service. Personnel assigned this task
must be sufficiently knowledgeable about the oil spill
enforcement program to communicate with staff in the
field.
that EPA undertake a cost-effectiveness analysis of the
SPCC program. The outcome of the study would provide
guidance in resource allocation for all facets of the
oil spill enforcement program. The study should
establish the cost of response/enforcement activity and
determine to what extent such costs are being reimbursed
through regional input to the revolving fund through
SPCC fines. The relative merits of alternative methods
of program implementation, such as contracted inspections,
could also be investigated.
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SECTION 1
INTRODUCTION
1.1 BACKGROUND
Following several massive oil spills in the late 1960's, Congress
established a policy that there should be no discharges of oil into or
upon the navigable waters of the U. S. This policy was first declared
in the 1970 Amendments (also known as the Federal Water Quality Improve-
ment Act) to the Federal Water Pollution Control Act (FWPCA) and was
later refined and extended in the 1972 and 1977 Amendments (also known
as Clean Water Act) to FWPCA. Responsibility and authority for en-
forcing this policy was split by Executive Order between the Administra-
tor of the Environmental Protection Agency (EPA) and the Commandant,
U. S. Coast Guard.
Since the FWPCA, as amended, provides the basis for the present
oil enforcement program, it seems appropriate to review some of its
most pertinent provisions.
Subsection 311(b)(3) states that, penalties may be imposed for
discharging oil in "harmful quantities" into the waters of the U. S.
Waters of the U. S. include, for example, the streams, creeks, lakes
and ponds which are tributaries of navigable waters or waters used in
interstate commerce.
"Harmful quantities" of oil are defined in 40 C.F.R. § 110.3 as
those sufficient in amount to "violate applicable water quality standards"
or "cause a film or sheen upon or discoloration of the surface of the
water or adjoining shorelines or cause a sludge or emulsion to be deposited be-
neath the surface of the water or upon the adjoining shorelines." The
latter, because of the obvious visual simplicity of determination, has
come to be a standard gauge of pollution detection and has been upheld
in court (U. S. v. Boyd, 491 F.2d 1163 or 3 E.L.R. 10434 (9th Cir., 1973)).
Subsection 311(b)(5) states that:
Any person in charge of a vessel or of an onshore
facility or an offshore facility shall, as soon as he~
has knowledge of any discharge of oil or a hazardous
substance from such vessel or facility in violation of
paragraph (3) of this subsection, immediately notify the
appropriate agency of the United States Government of
such discharge.
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Failure to immediately notify the appropriate agency of such
discharge may result in criminal penalties of $10,000 and/or 1 year
in prison, as sought by the U. S. Attorney.
Any owner, operator, or person in charge of any onshore or off-
shore facility or vessel, from which oil is discharged in harmful
quantities, shall be liable for civil penalties of up to $5,000 per
offense under subsection 311(b)(6). The Coast Guard is mandated to
assess these civil penalties after providing notice and opportunity
for- a hearing to the owner or operator. The statute imposing liabi-
lity for discharging harmful quantities is absolute. Proof of negli-
gence or intention to discharge is not required.
A National Contingency Plan (40 C.F.R. § 1510) for removal or
control of spills has been developed pursuant to subsection 311(c)(2)
and has assigned responsibilities for handling spills. Subsections
311(f) and 311(g) authorize the U. S. Government to try to secure
reimbursement from the responsible parties for the costs incurred in
the cleanup. A revolving fund was established by subsection 311(k)
to provide capital for cleanups. The reimbursements from parties
held liable for spills, as well as penalty assessments, are deposited
in this fund which the Coast Guard administers.
To prevent spills, subsection 311(j) authorizes regulations
establishing, among other things, procedures, methods and equipment
to prevent and control discharges of oil. Penalties of up to $5,000
may be imposed on persons failing to comply with the regulations.
Executive Order 11735 assigns responsibility for transporta-
tion-related facilities to the Department of Transportation (DOT) and
non-transportation related facilities to the Environmental Protection
Agency (EPA). A Memorandum of Understanding (MOU) was developed be-
tween EPA and DOT defining specifically what is meant by transporta-
tion related and non-transportation related (NTR) with respect to the
prevention of oil discharges.
As a consequence of the Executive Orders, MOU and Spill Contin-
gency Plans, EPA is responsible for regulating the prevention of oil
spills from NTR facilities and for responding to oil spills from any
source occurring within specified geographical or inland locations.
The Coast Guard acts as the lead for the spill response program.
EPA responds to inland spills that are defined in Regional contingency
plans and boundary agreements as being within its jurisdiction. EPA
gathers evidence for the spills and transmits case files to the Coast
Guard, which handles spill enforcement for civil penalties and for
cost reimbursement. Those spills for which the Coast Guard is respon-
sible are handled entirely by the Coast Guard.
In those instances where there may be evidence of failure to
notify by an oil spiller within its jurisdiction, EPA may prepare a
referral to the U.S. Attorney for enforcement under subsection 311(b)(5).
2
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Under the prevention provisions of 311(j), the Spill Prevention
Control and Countermeasure (SPCC) Plan was introduced into the lexicon
of oil spill enforcement in the early 1970's when "prevention" first
started to be emphasized and studied. The ideas of many experienced
professionals culminated in a proposed regulation in the Federal
Register of July 19, 1973 that defined the requirements for prepara-
tion, implementation and maintenance of SPCC plans for the NTR onshore
and offshore facilities that could reasonably be expected to discharge
oil into U. S. waters. This, added to EPA's responsibility to respond
to spills and monitor and coordinate cleanup operations, has provided
a new dimension of enforcement for EPA.
The prevention regulation (40 C.F.R. § 112) was published on
December 11, 1973 and became effective on January 10, 1974. Briefly,
it required that SPCC Plans be prepared by non-transportation facili-
ties with buried storage in excess of 42,000 gallons or above ground
storage capacities in excess of 660 gallons in a single tank or 1,320
gallons in aggregate if these facilities could be reasonably expected to
discharge oil into navigable waters. Specific requirements of the Plan were:
(1) For existing facilities, the Plan had to be
prepared by July 11, 1974, in accordance
with guidelines contained in the regulations.
(2) The Plan had to be certified by a Registered
Professional Engineer.
(3) The Plan had to be implemented by January 10,
1975.
(4) The Plan must be maintained at the facility
and available for EPA inspection during normal
working hours.
(5) The Plan must be submitted for review and possible
amendment by EPA if the facility experiences:
(a) A single spill of more than 1,000
gallons,
(b) Any two reportable spills within
one year.
(6) •' The Plan must be reviewed and evaluated every three
years by the owner or operator.
New facilities were accorded one year to prepare ana implement plans.
Civil penalty procedures for violations of the prevention
regulations were published August 29, 1974 as an interim regulation
(40 C.F.R. I 114). This defined violations and established procedures
for issuing notices of violation and conducting hearings.
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Much autonomy was given by the regulations to the Regional Admini-
strators to work out program policy and implementation. In this way,
each region developed its own inspection program, its own methodology
for issuing notices of violations, its own policies regarding assess-
ment and collection of penalties, and its own degree of formality in
the settlement of cases within the format of Parts 112 and 114. Thus,
while the enforcement guidelines are standardized, the implementation
policies vary wide - partly, of course, due to the geographic, industrial,
demographic, social and economic differences which exist among regions.
To consider the effectiveness of the SPCC Program in reducing the
number of non-transportation spills, it is important to realize the
program's limitations. Of special note is that the regulations are
based on the storage capacity of facilities - namely, those with buried
storage of greater than 42,000 gallons or above ground storage of
greater than 660 gallons in a single tank or 1,320 gallons in aggregate.
These limitations were purposely incorporated into the regulations to
exclude urban service stations, individual residences and similar
facilities. However, in many rural areas, gas stations may be
few and far between and as a result, many small installations or even
farms may have storage capacities in excess of the stipulated amounts.
In addition, there are peripheral industries that are not specifically
oil producing or oil handling which are subject to SPCC regulations.
A major problem for EPA inspectors has been the identification of these
facilities, which are likely to be outside the mainstream of the oil
industry itself. In general, therefore, it is not a problem for EPA
inspectors to detect facilities of major oil companies, but difficult
for them to locate small, independent operators, and other facilities
not clearly identifiable.
1.2 PURPOSE OF THE STUDY
In October of 1977, CHI ASSOCIATES, INC. (CAI) was tasked with
carrying out for the Environmental Protection Agency an evaluation of
its oil spill enforcement program. The objective was to determine
whether spills, for which EPA had been accorded prevention, cleanup
and monitoring responsibilities in 1972, had declined following enforce-
ment of the Spill Prevention Control and Countermeasure Plan provisions
which took effect in 1974. Specifically, the contract called for
statistical analyses to be performed in order to identify and quantify
relationships between enforcement activity and oil spill incidence.
Should such correlations exist, the study would then attempt to iden-
tify the most effective methodology employed in the regions to reduce
oil spills and thus provide guidance to EPA in establishing program
priorities.
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1.3 PROJECT SCOPE
This study was initially undertaken as a correlation analysis of oil
spill and SPCC enforcement statistics. As the project progressed, it
became increasingly clear that:
Ca) available statistics were inadequate
to fully assess the effectiveness of
the national enforcement program;
(b) the enforcement program could not be
evaluated without a detailed under-
standing of the mutual relationship
between it and the oil spill preven-
tion and response program.
It would not be possible to overcome the lack of complete enforce-
ment program data within the time and resource constraints of the
pro j ect.
It was, therefore, decided to adopt an alternative approach in
which readily available program statistics could be analyzed to deter-
mine national and regional spill and enforcement trends in order to
assess the current status of the national program. In addition, by
analysis and comparison of several regional program approaches, an
effort would be made to identify program features which seem to result
in an efficient and productive operational approach to the spill en-
forcement programs.
Because of the enforcement emphasis of the project, detailed
study of the prevention/response aspects of the program has of neces-
sity been limited. For instance, since inspections were not specified
in the original list of study parameters, no attempt was made to collect
inspection data during the regional visits conducted early in the study.
However, this omission was corrected to some extent later in the study
and the final product attempts to reflect both the response and preven-
tion aspects of enforcement.
Discussion of policy matters was also outside the scope of the
project, yet it soon became evident that priorities set at both the
national and regional levels had direct bearing on program activities.
To exclude mention of policy would result in a failure to explain
statistics. We have sought to correct this situation by presenting
views expressed by responsible working level officials in the regions
who are directly involved in the enforcement program. In so doing, we
have attempted to avoid making judgmental statements of our own.
5
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Finally, we regret that the scope of the project was
limited to a six-month time frame and that it did not include in-
depth evaluation of all regional programs. Nevertheless, we have
tried to present as accurate and complete an evaluation of the oil
spill enforcement program as was possible within the project constraints.
1.4 ORGANIZATION OF THE REPORT
Section 2 details the data sources employed in the study and
delineates some of the limitations of the available data.
An analysis of national and regional spill trends over the period
1973-1976 is provided in Section 3. Results are presented on the
number, volume and average volume of spills for the nation as a whole
and separately for transportation and non-transportation related
sources. A spill rate trend is also established and reported for
annual spill data.
An analysis of enforcement trends is provided in Section 4. Re-
sults are provided for SPCC and spill enforcement activity. Statis-
tical tests are applied to determine the significance of changes in
enforcement levels over time.
Section 5 contains an analysis and interpretation of the en-
forcement spill correlation. It also documents the effort undertaken
in the study to develop measures of effectiveness for assessing oil
spill enforcement performance.
Section 6 focuses on in-depth studies conducted in Regions III,
VI, VII and IX. The reasons for the studies are outlined and the
rationale for selection of these regions detailed. Local program
organization, policy and activities are described and unique features
of each region highlighted. Certain factors of regional programs or
impacts of external factors upon them are extrapolated to be appli-
cable nationally. These regional visits provided a wealth of infor-
mation which, coupled with the statistical data analysis already
described, formed the basis for the specific recommendations we have
made in this report.
Finally, Section 7 hypothesizes as to the likely consequences
of failing to accord to prevention a higher priority in the
EPA national guidelines.
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SECTION 2
DATA SOURCES FOR THE STUDY
In order to assemble the vast amount of data required in the
study within the bTief time available, it was necessary to make maxi-
mum use of available data bases. The principal known data bases for
oil spill data were the Pollution Incident Report System (PIRS) of
the U. S. Coast Guard and the Spill Prevention, Control and Counter-
measure (SPCC) File of the Environmental Protection Agency. These
files contain information on spill and enforcement activity as re-
ported by local agency units throughout the country and maintained
in headquarters' offices of the two agencies. It was known that the
Bureau of Mines has maintained data on oil production, storage, and
consumption since 1970. This data source was proposed for use in
defining the potential amounts of spilled oil by region and year.
All spill data in the report represent only those spills that have
been reported to a responsible agency. This section describes how
the final selection of data for the study was made and enumerates
the major limitations of these data. The discussion is organized
into spill/enforcement groupings.
2.1 SPILL DATA
Spill data were obtained from several sources, each of which had
to be carefully examined and rated for reliability and completeness.
As chronologically received, these data bases consisted first of
information contained in EPA Headquarters' Office of Enforcement in the
form of logs which are updated semi-annually from regional reports. The
Oil and Hazardous Materials SPCC Data System, located in EPA's Oil and
Special Materials Control Division, was analyzed by interactive computer
facilities to provide data on individual regional spill and prevention
programs. Following on-site visits to each of the regions in November-
December 1977, additional logs and data were received from the regional
offices. Finally, the comprehensive national data base contained in the
U.S. Coast Guard's PIRS (Pollution Incident Reporting System) File was
made available for analysis.
Upon preliminary overall analysis and random comparison of
specific data, incidents and logs from all sources, it was determined
that the PIRS File contained the most complete spill data and that
this file should be analyzed specifically for the 10 EPA regions.
It was found that discrepancies sometimes existed between PIRS
File data and that from EPA regional sources. However, in each region
the PIRS data appeared overall more complete and consistent than any
other. Hence, the PIRS File was adopted as representing an accurate
qualitative description of reported oil spills throughout the EPA
regional system. The file would appear further to represent an
accurate quantitative description of oil spill trends within the
the usual error constraints of nationwide data bases.
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PIRS is an enormous and complex file. Its entries come from
the Coast Guard districts and are broken down into 60 possible speci-
fic sources and 270 possible specific causes of pollution incidents.
In order to apply the PIRS File to the EPA regional programs, it was
necessary to restructure the existing PIRS computerized reporting
format. Previous analysis of PIRS had been based solely on national
statistics or on results from the 17 Coast Guard districts. To
adapt the file for use in the present study, it was necessary to
classify each spill by the state in which it occurred and then group
state data to form data bases for each of the 10 EPA regional programs.
It was also necessary to group the many categories of sources and
causes of spills into those applicable to the needs of this project.
This restructured data base thus became the primary source of the
spill data analysis herewith presented.
With regards to the breakdown of national data into state and
then EPA regional data, it was natural that practical problems would
arise in obtaining completely accurate results from a file as large as
PIRS. It was, for example, not always possible to identify the
location (state), or source of a particular spill. Hence, when
regional results are given, their summation does not provide the
total number of incidents for a given year. Also, when transportation
and non-transportation related spills are separated and analyzed, their
sum will not provide the total number of spills for a region or a time
period. In the case of location data, relatively few spills are uniden-
tified so that the regional totals will provide a very good approximation
of the national totals. Problems, however, arise for source data. In
many instances, as many as one-third of the incidents were of unknown
origin and results for transportation and non-transportation spills
may reflect only about seventy percent of the total amount of spills.
Nevertheless, since the emphasis of this study is on relative compari-
sons between transportation and non-transportation spills and among
regional results as opposed to the total national figures published
annually by the Coast Guard, it was considered reasonable to use the
given relative figures as a basis of evaluation, comparison and analysis.
2.2 ENFORCEMENT DATA
SPCC data were obtained mainly from logs and other records fur-
nished by regional offices and information on cases referred to the
U.S. Attorney for criminal action was taken from logs in EPA's Office
of Enforcement in Washington, D.C.
8
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Certain problems are inherent in the tabulation of SPCC data.
The most obvious is that such categories as notices of violation,
assessments and collections frequently do not fall neatly within a
given calendar year. Region IV, for example, provided only totals
of annual violations, assessments and collections. To delineate the
problem, a region issues a notice of violation in 1974, a hearing is
set in 1975, this results in a lowered assessment which is appealed
by the company, and the case is finally settled in 1976. For regional
office purposes, this is settlement of a 1974 case. For purposes of
this study, however, the case was opened in 1974, assessed in 1975
and collected in 1976. This distinction is necessary for the
national overview, since it is not concerned with the outcomes of
individual cases, but with recording the activity levels of the regions
and relating these to the national goals in an annual time frame.
The time factor is important also in how each region handles
cases. In general, the processing of violations may involve several
offices within each region, including staff responsibility in the
Surveillance and Analysis and Enforcement Divisions. Responsibilities,
however, vary widely among the regions. Different logs at times had to
be used to correlate information thoroughly.
Another problem which arose is that not only different logs
had to be studied, but in some cases, information was only complete
in dossier form, which could not be reproduced for centralized analysis.
In general, therefore, it can be said that, while information at the
regional level appears complete and up-to-date, it is rarely readily
available in any standardized format for purposes of analysis.
In addition, it should be pointed out that, due to the timing of
the study, the 1977 data are incomplete. This is important in considering
the development of trend information. Although the SPCC program offi-
cially began in 1974, it did not become nationally effective until
January 1975. It is, therefore, administratively still in its infancy
and is not settled enough to admit a comprehensive evaluation.
9
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10
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SECTION 3
SPILL TRENDS
Spill trends were obtained by determining spill statistics
(incidence, volume, rate) for each year between 1973 and 1975 and
analyzing changes in the statistics over the time period. Overall
(total) trends were determined by summing the regional statistics
for each year to obtain national values. Overall and regional trends
were analyzed, using statistical methods outlined in Appendix C.
3.1 NATIONAL SPILL TRENDS
Tables 1, 2 and 3 respectively indicate the national trends in
spill incidence, volume and average volume over the study period.
These results are shown graphically in Figure 1.
Table 1 shows the distribution of the number of spills by
year and region. It is seen that the total number of spills ranges _
between 12,000-13,000 for each of the four years, 1973-1976, covered
by the study. The variations among regions are, as might be expected,
related to the amount of oil activity in various parts of the country.
Region VIII, a low spill activity region, has consistently no more
than 100 spills per year whereas the active regions, such as Region VI,
report 1000 to 4000 spills annually.
Table 2 presents spill volume data for the period of the study.
The results are broken down by region and by year. The total spill
volumes shown in Table 2 indicate that nearly 100 million gallons
of oil were spilled over the period 1973-1976. The total amount of
oil spilled is fairly consistent by year from 1973 to 1975 and may be
said to show even a small decline over that period. However, the 1976
figures are .up markedl , representing an approximate doubling of the
1975 figures. Over half the 1976 volumes resulted from major
spills which occurred in Region V and which accounted for 22 million
gallons.V Apart from the apparent influence of major spills, most
regions indicate a reduction in spill volume over the study period.
V This figure was reported in the PIRS data base, but its authenticity
has been questioned by EPA officials in Region V. Region VIII has also
questioned the validity of PIRS data as related to their region.
11
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Table 3 presents average spill volume by region and year. It
is seen that the average spill volume is relatively constant over
the period 1973-1975, averaging some 1600 gallons per spill. The
average volumes by region are more variable, especially due to the
incidence of large spills in Regions V and VII and vary from some
500 gallons per spill in Region X to 5000 per spill in Region VII.
Figure 1 graphically depicts total spill trends for the four
year period, 1973-1976. The national total is comprised of the sum
of transportation, non-transportation and unknown sources. Figures
2-5 project the corresponding trend results by year for the ten
regional programs.
Statistical methods were applied to the spill incidence, volume
and average volume data in order to determine whether any significant
trends exist in the data. The results from this analysis are
summarized in the respective tables. In general, the regional program
trends do not change significantly over the study period. However,
the following findings result:
Nationally, spill reporting incidence shows an
increasing tendency over the study period. The
increase is not statistically significant.
Regions I, II, III, IX and X indicate a de-
creasing tendency in spill incidence over the
study period.
Regions I, II, VI, VII, XI and X indicate a
decreasing tendency in spill volume over the
study period.
Region I indicates a significant decrease in
spill volume of approximately 50% over the
study period.
Data for the year 1977 were not available during the data collec-
tion phase of the study. However, by application of the statistical
analysis models used to test significance of the regional trend
it was possible to predict 1977 regional outcomes. These predicted
values may be used in the future to test whether actual 1977 regional
outcomes show additional program improvement by comparing whether
actual values fall below the predicted values.
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3.2 COMPARISON OF TRANSPORTATION AND NON-TRANSPORTATION
RELATED SPILL TRENDS
Tables 4 and 5, respectively, contain the number of transpor-
tation related vs. non-transportation related spills by region and
year. The number of transportation related spills remains fairly
constant at some 5000 per year. The number of non-transportation
related spills is smaller at some 3000 per year. The remaining have
unknown sources.
Table 6 breaks down non-transportation related spills as a
percentage of the total of transportation and non-transportation
related spills. Overall, the data indicate that non-transportation
related spills form slightly more than one-third of these spills,
with Region IX having the lowest number, followed by Regions IV
and X, and Region VI having significantly more NTR spills than
the others.
Tables 7 and 8 show a breakdown of spill volumes by transpor-
tation and non-transportation related causes. Again, the large
spill volume occurring in Region V in both transportation and non-
transportation spills during 1975-1976 is seen.
Table 9 shows the percentage of non-transportation spill
volume computed using the sum of transportation and non-transpor-
tation volumes as the base. These results show that non-transpor-
tation related spills make up about 35 percent of the combined
spill volume. The variable percentages of non-transportation related
spills in the regions reflect the obvious regional geography and
the nature of oil handling operations in varous parts of the country.
It is seen that non-transportation related spills represent only 15
percent of the spill volume in Region X, but approximately SO percent
of the spill volume in Regions I, IV and V. In Region VIII, a com-
pletely inland region, two-thirds of the total spill volume is attri-
butable to non-transportation related spills.
Tables 10 and 11 show breakdowns- of average volume by trans-
portation and non-transportation related sources. It should be noted
that average spill volumes for annual totals are always lower than those
for either transportation or non-transportation spills. This is due
to the many spills of small volume whose sources are not identified
in the PIRS data base.
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Figures 6 and 7, respectively, indicate the national spill trends
for transportation and non-transportation related spills. Trie cor-
responding transportation and non-transportation related spill trend
results computed on a regional basis for each of the four study
years are shown in Figures 8-11. The non-transportation related
regional trends for each year are depicted in Figures 12-15.
Tables 12-14 show the distribution of non-transportation re-
lated spills by spill size. The spill size categories used are those
for inland spills; namely, minor spills are 1000 gallons or less,
moderate spills are 1000 to 10,000 gallons and major spills are more
than 10,000 gallons. It is seen that the majority of non-transpor-
tation related spills fall into the minor category and that the
distribution over time of both minor and moderate spills generally follows
national trends by region. There are very few major spills and their
distribution is more erratic over the regions, indicating a random
occurrence of such major spills.
Tables 15-17 indicate that the minor spills increased in volume
over the first three years of the study and decreased in 1976. Volumes
increased over the first two years of the study and decreased markedly
in the second half of the study. The major spill volume shows con-
siderable fluctuation from year to year with no apparent trends.
Tables 18-20 indicate that the average volumes of minor and
moderate spills remain reasonably constant at approximately 70 and
3000 gallons, respectively. The major spill averages are more variable
and show no apparent trends.
By eliminating the major non-transportation related spills and
considering only the minor and moderate categories, it can be reasonably
concluded that the incidence and volume of NTR spills remained fairly
constant over the study period and actually decreased in some regions.
The reasons for these trends are not obvious; however, such results
cannot be expected on the basis of chance and probably reflect EPA
Enforcement Program activity. The correlation of enforcement and
spill program activity is addressed in Section 5 of this report.
Figures 16, 17 and 18 respectively depict graphically national
trends for minor, moderate and major categories of transportation
related spills. It is seen that minor and moderate spills represent
a nearly constant trend over the study period, whereas the major
transportation related spills in Figure 18 show a slight decrease in
spill incidence, but a significant increase in spill volume.
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Figures 19, 20 and 21 display corresponding minor, moderate
and major trends for non-transportation related spills. Quantita-
tively, these results have trends similar to the transportation
related spills.
The next category of figures shows the breakdown of minor,
moderate and major non-transportation related spills by year and
separately for each region. Figures 22-31 show the separate trends
in minor non-transportation related spills for Regions I-X. Figures
32-41 display the moderate non-transportation spill results, and
figures 42-51 indicate the results for major spills.
Figures 52, 53 and 54 show the oil spill trends for the minor,
moderate and major non-transportation related spills where data have
been combined for the four-year period, 1973-1976. Figures 55-58
show the regional breakdowns of minor non-transportation related
spills for each of the four years studied. Figures 59-62 show simi-
lar results for moderate spills. Finally, Figures 63-66 show the
regional breakdowns for the major non-transportation related spills
over the four-year period.
Because up to one-third of the spills occurring over the study
period were of unknown origin, it was decided to perform a trend
analysis on the unknown source data. The results are presented
graphically in Figures 67-69 for minor, moderate and major spill
categories. It is seen that these spills are generally of small
volume and indicate a decreasing trend, especially in spill volume,
over the study period. This decrease suggests a probable increase
in spill reporting and consequent decline in spills whose origins
remain a mystery.
By applying formal statistical testing as discussed in Appendix
C, the following findings result relative to the analysis of spill
data by transportation or non-transportation sources over the study
period: (1973-1976)
The incidence of transportation related spills
indicates an increasing tendency.
Region IV indicates a statistically significant
increase of 46% in the incidence of transportation
related spills.
The incidence of non-transportation related
spills indicates a decreasing tendency.
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Regions I, II, IX and X indicate a decreasing
tendency in the incidence of transportation
and non-transportation related spills.
Region VI indicates a decreasing tendency in
non-transportation related spills.
Region V indicates a statistically significant
increase of nearly 100% in the number of moderate
non-transportation related spills between 1973
and 1975.
Nationally, both transportation related and
non-transportation related spill volume indi-
cates an increasing tendency over the study
period.
Regions I, II, III and VII indicate a decreasing
tendency in spill volume.
Regions I, II, III and VI indicate a decreasing
tendency in minor non-transportation related
spill volume over the study period.
Regions I, II, VI and X indicate a decreasing
tendency in moderate non-transportation related
spill volume.
Regions I, II, III and VII indicate a decreasing
tendency in major non-transportation related
spill volume.
It was the opinion of Region III personnel that non-transportation
spills, especially those of small volume, have shown a sharp decline in
the past few years. To check this hypothesis, data on non-transportation
spills were provided by the Region from its SPCC computer file for ana-
lysis by CAI staff. The following results were obtained for onshore
non-transportation spills:
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1975
1976
1977
Number of Spills
Under 100 Gallons
369
456
385
Number of Spills
Under 1000 Gallons
536
534
469
Total Volume Spills
Under 100 Gallons
5181
4762
3105
Total Volume Spills
Under 1000 Gallons
54,480
27,150
27,034
These results indicate that while the number of minor spills
(under 1000 gallons) has declined somewhat over the study period,
the total volume of minor spills dropped sharply in 1976 while the
volume of spills under 100 gallons has been declining steadily since
1975. This indicates that less oil is being discharged into water
and implies that more is probably being contained under SPCC regulated
structural controls.
3.3 SPILL RATE TRENDS
Figures on oil production, importation, storage and consumption
have; been kept by the Bureau of Mines since 1970 with responsibility
recently being transferred to the Department of Energy. These data
provided a basis for deriving an oil handling figure to be used in the
definition of spill rate. Data on a state-by-state basis available up
to 1975 were provided by the Department of Energy. These data required
further analysis to arrive at an appropriate oil handling base defini-
tion. Statistics given, for example, relating to oil production had no
statistics for those states which did not produce. Movement data
skewed information into coastal states concerned with refueling and
heavily into those states involved with refining; it also created some
confusion in that oil moved into a state, refined there and then re-
moved elsewhere risked becoming intermingled. It was, therefore, de-
cided to use actual consumption figures which indicate oil actually
consumed and replenished annually in each state.
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Categories of oil include gasoline,' jet fuel, kerosene, distil-
late fuel oil, residual fuel oil, liquified petroleum gases and
asphalt. It has not been possible, according to officials in the
Department of Energy, to trace such oils as lubricating oil,
crankcase oil, and animal and vegetable oils. Since these products,
compared to petroleum, could be expected to be lower in volume
and largely unreported, their omission is not considered signifi-
cant to this study.
Figure 70 depicts graphically an historical overview of oil
consumption in the United States since 1960. Figure 71 provides
a regional breakdown. It is seen from these figures that at the
national level, oil consumption rose steadily over a 13-year period,
and peaked in 1973. Then, due probably to the "energy crisis," oil
consumption declined reaching its lowest point in 1975 at some 15
billion gallons less than those consumed in 1973. Although no
statistics are available for 1976 on a state-by-state basis, unpublished
Department of Energy data on national consumption indicate that con-
sumption jumped by 15 billion gallons from 1975 to 1976 with the jump
in the transportation industry alone rising by almost 5 billion
gallons. Although preliminary estimates were not available for 1977
consumption figures, the Department of Energy has unofficially projected
that 1977 figures meet or exceed the 1976 figures.
Table 21 shows the oil spill potential by region and year from
1972 to 1976. Spill potential (S.P.) for a given region is defined as
the total amount of oil consumed for that region as defined above in
a given year and is reported in units of 10 billion gallons of oil.
It is seen that the spill potential remains fairly constant over the
period of 1972-1975. The regional differences in spill potential
generally follow the distribution of spill incidence and volumes dis-
cussed earlier except that some changes are evident. Region V is shown
to have the largest amount of oil handled in each year of the period
of the study. Regions II, III, and IV all show proportionally large
amounts of oil handled over the period while Regions VII, VIII and X
indicate a relatively small amount of oil handled. Because oil con-
sumption figures were not available for 1976, as stated earlier, the
projected figures given for that year in Table 21 were computed as
follows:
From Department of Energy data, the ratio of petroleum
products consumed in 1976 to those consumed in 1975 was
1.191. This value was defined as a projection factor
(PF) and applied to the 1975 spill potential data for
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each region to arrive at the 1976 totals. That is:
S.P.,„ = PF x S.P..
1976 197S
» 1.191 S.P.
1975
Table 22 shows spill rate data for each year and region from
1973-1976. These rates represent totals, as no method was availa-
ble to estimate spill potential by spill source. The re-
sults show a steadily declining total spill rate between 1973 and
1975 with a sharp rise for rate in 1976. However, further inspec-
tion reveals that the major reason for the increased trend in 1976
was due to a small number of massive spills in Region V during that
year (see footnote on page 10). If those spills were deleted from
the table, the total spill rate for the remaining nine regions would
be 0.064, which represents an actual reduction over the 1975 spill
data. It is further seen that in several of the regions, the spill
rate is actually reduced over the period of the study.
Formal statistical tests applied to the spill rate data in
Table 22 lead to the following findings:
Region I indicates a statistically significant
reduction in spill rate of 50% over the study period.
Regions II, VI, VII, IX and X indicate a de-
creasing tendency in spill rate over the study
period.
18 a
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SECTION 4
ENFORCEMENT TRENDS
4.1 INTRODUCTION
The Spill Prevention Control and Countermeasure Plan (SPCC)
was introduced into the lexicon of oil spill enforcement in the early
1970's when "prevention" first started to be emphasized and studied.
The ideas of many experienced professionals culminated in proposed
regulations in the Federal Register of July 19, 1973 using EPA's
legal authority to inspect oil storage facilities, to issue
notices of violation and to assess and collect penalties from those
NTR facilities where the possibility of a spill existed. This, added
to EPA's responsibilities to respond to spills and monitor and co-
ordinate clean-up operations, was a new dimension of enforcement.
The regulation itself became effective in January 1974. Briefly,
it required that SPCC Plans be prepared by non-transportation facili-
ties with above ground storage capacities in excess of 660 gallons in
a single tank or 1,320 gallons in aggregate or buried storage in excess
of 42,000 gallons, if these facilities could be reasonably expected to
discharge oil into navigable waters. Specific requirements for the
Plan were:
(1) The Plan had to be prepared by July 11, 1974.
(2) The Plan had to be certified by a Registered
Professional Engineer.
(3) The Plan had to be implemented by January 10,
1975.
(4) A copy of the Plan had to be maintained at the
facility and available for EPA inspection during
normal working hours.
A Plan must also be submitted for review by EPA if the facility
experiences:
(1) A single spill of more than 1000 gallons.
(2) Any two reportable spills within one year.
19
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Considerable autonomy was given by the regulations (40 C.F.R.
§ 112 and 114) to the Regional Administrators to implement program
policy. In this way, each region developed its own individual in-
spection programs, its own methodology for issuing notices of vio-
lations, its own policies regarding assessment and collection of
penalties, and its own degree of formality in the settlement of cases.
Thus, while the enforcement guidelines are standardized, the imple-
mentation policies vary widely. This is due partly to the demographic,
geographic and industrial differences among regions and to variability
in administrative procedures within regions.
It is the purpose of this section of the report to give an over-
view of results of EPA's national oil spill enforcement program. Em-
phasis has been placed on the SPCC Program which is the only aspect of
oil enforcement that EPA controls from inspection through collection.
The approach will be to summarize the collected data on enforcement
program activity for use in assessing the amount of enforcement activity
over time and over the ten EPA regions and in developing the spill-en-
forcement correlation in Section 5.
4.2 NATIONAL ENFORCEMENT TRENDS
Enforcement trends were obtained by determining enforcement
statistics (311(b)(5), 311 (b)(6) and 311 (j)(2) violations) for each
year in which data were available. Spill data were available over
the period 1973-1976. However, because the SPCC Program did not come
into existence until late 1974, SPCC statistics are provided for the
period 1974-1976. Partial data are also provided for 1977.
Table 23 shows the total number of SPCC Notices of Violation by
region and year for the period 1974-1977. It is seen that nearly 4000
NOV's were documented over this time period. Regions IV and VI are the
most active SPCC violation regions. However, the number of NOV's for
Regions I, II, and IX lag by only a small amount. The results show
that an increasing number of NOV's are being issued in most of the
regions; exceptions are Regions II, III and X. Application of the
statistical procedure outlined in Appendix C indicated the fol-
lowing:
Regions I, II, V, VI, VII, VIII and IX indicate
an increasing tendency in issuing NOV's over
the study period.
Regions III, IV and'X indicate a decreasing
tendency..
20
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Region IV indicates a statistically signi-
ficant decrease of nearly 50% in SPCC
NOV's over the study period.
Tables 24, 25 and 26 show, respectively, the number, amount
and average amount of SPCC assessments over the period 1974-1977.
These results indicate that assessments have been made for some
3,300 NOV's amounting to an assessed value of over $6 million. The
average assessed amount per NOV amounts to approximately $1,800.
Application of the statistical test to Table 24 indicated the
following:
Overall numbers of assessments are generally
increasing.
Region IV's number of assessments is de-
creasing from the 1974 level.
Application of the statistical test to Table 25 indicated the
following:
Overall amounts of assessments are generally
increasing.
Regions I, IV, V, VI, VII, VIII., IX and X in-
dicate increasing tendency in amounts assessed
for the study period.
Region VI indicates a statistically significant
increase (from $3600 in 1974 to $1.2 million
in 1977) in amounts of SPCC assessments over
the study period.
Region II indicates a decreasing tendency in
amounts of SPCC assessments over the study
period.
Application of the statistical test to Table 26 indicated the
following:
Regions I, V, VI, VII, VIII and X indicate an
increasing tendency in average SPCC amounts as-
sessed over the study period.
21
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Region I indicates a statistically signi-
ficant increase in average SPCC amounts
assessed over the study period (from
$356 in 1974 to $2,823 in 1977).
Regions II and IX indicate a decreasing
tendency in average SPCC amounts assessed
over the study period.
The overall trend in average amounts of
assessment indicates a statistically signi-
ficant increase over the study period (from
$881 in 1974 to $2,747 in 1977).
Figure 72 summarizes SPCC assessment activity over the period
1974-1977.
Tables 27, 28 and 29 contain, respectively, the number, amount
and average amount of SPCC collections by region and year over the
period 1974-77. It is seen from these tables that nearly three
quarters of a million dollars in fines have been collected based on
some 2,000 collection instances. The average amount collected is
$350 per NOV over the study period and the average amount collected
has increased steadily since 1974. Formal statistical tests
applied to these tables lead to the following findings:
The annual number of SPCC collections peaked
in 1975 and has shown a decreasing tendency
since that year.
Contrary to the general trend, Regions III, V,
VI, VII, VIII, IX and X indicate an increasing
tendency in number of collections for the
study period.
Regions I and IV indicate a decreasing tendency
in amounts collected over the study period.
The collection penalty trends are heavily weighted
by the relatively large number of collections re-
ported by Region IV.
22
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All regions except II and IV indicate an increasing
tendency in amounts of SPCC collections for the
study period.
Region VI indicates a decreasing tendency in
the average amount of SPCC collections for the
study period.
All regions except Region VI indicate an
increasing tendency in average amounts of
SPCC collections over the study period.
The overall national trend shows a statisti-
cally significant increase from $170 to $459
in the average amount of SPCC collections over
the study period.
Figure 73- graphically summarizes the SPCC collection process over the
study period.
Tables 30 and 31 contain, respectively, the amount of proposed
and collected spill penalties over the period 1973-1976. It is seen
that nationally the Coast Guard proposed penalties amount to a total
of some $11 million and indicate a decreasing trend over the study
period. A similar trend is indicated by the collected penalties.
These two tables lead to the following findings, based on formal
statistical analysis of their contents:
There has been a statistically significant
nationwide reduction (from $3.6 million in *
1973 to $1.8 million in 1976) in proposed
spill penalties over the study period.
Regions I, II, III, IV, V, IX and X indi-
cate a decreasing tendency in proposed
spill penalties over the study period.
Region II indicates a statistically signi-
ficant decrease in proposed spill penalties
over the study period (from $715 in 1973 to
$150 in 1976).
23
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Nationwide, the amount of collected spill
penalties shows a statistically significant
decrease over the study period (from nearly
$2 million in 1973- to $1 million in 1976) .
Specifically, Regions I, II, III, IV, V, VI,
IX and X show a decreasing tendency over the
study period.
Regions II and IX show a statistically signi-
ficant decrease in collected spill penalties
over the study period.
Regions VII and VIII indicate an increasing
tendency in the collected spill penalties
over the study period.
Table 32 shows spill penalties collected as a percentage of
proposed penalties by region over the study period. It is seen that
nationally 55 percent of the proposed penalty amounts were collected
over the study period. Regions III and VII indicate the highest
percentages of collected penalties. Regions V and IX indicate the
smallest percentage collections, although both of these regions have
recently increased their percentages.
Table 33 shows the percentage of assessed SPCC penalties col-
lected. This value averages about 12 percent over the study period.
Table 34 shows the number of 311(b)(5) (failure to notify)
referrals by region and year over the study period. It is seen that
the number of referrals has decreased significantly since 1973; such
that in 1976, only three regions referred any cases to the U. S.
Attorney under 311(b)(5) violations and the total number of cases re
ferred nationally amounted to only ten. Table 35 indicates the dis-
position of.311(b)(5) for each region and year.
24
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SECTION 5
ENFORCEMENT-SPILL CORRELATION
S.l THE CORRELATION PROBLEM
Correlation in the context of enforcement and oil spill trends
suggests the existence of a cause-effect relationship between enforce-
ment activity and spill reduction. In general, the inference of cause
and effect is a difficult task which depends essentially upon the
nature of the phenomenon under consideration, but which must be care-
fully investigated in order to avoid erroneous conclusions on the
basis of usually limited statistics. The oil spill program is no
exception. Due to the shared program authority between EPA and the
Coast Guard, it is necessary to establish which spills could reasona-
bly be expected to have been affected by EPA enforcement actions. Once
this has been ascertained, there remains the problem of obtaining data
relating the change in pertinent spill and enforcement activity over
time to establish the significance of any correlation.
Problems arise both in the determination of appropriate spill
and enforcement data to enter the correlation and in obtaining the
required data. It was assumed early in the study that SPCC enforce-
ment activity was the only component of EPA enforcement which could be
expected to lead to a reduction in non-transportation related spills.
However, several categories of non-transportation related spills are
not covered in the SPCC program. Also, the SPCC program has been in
existence only a short period (since 1974) so that its;impact has
probably not been fully realized. In addition, enforcement program
statistics presently contain no information on spills which may have
been contained by SPCC control measures.
In spite of these factors, an attempt was made to correlate
spill-enforcement data in the hope of establishing some significant
trend. At the same time, an effort was undertaken to establish
measures of effectiveness to independently compare and assess
enforcement performance.
5.2 DEVELOPMENT OF MEASURES OF EFFECTIVENESS
The approach to the assessment of program effectiveness can be
defined as a systems analysis. It will consist of the initial as-
sumption that sufficient resources have been provided within EPA for
2S
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for the purpose of administering an effective enforcement program.
Based on these resources, certain enforcement activities have been
planned and implemented with the objective of obtaining a timely
response to oil spill incidents and ultimately of preventing or re-
ducing such incidents. From the systems perspective, the allocated
resources may be considered as program inputs which have been de-
signated in the form of funds and subsequently have been translated
into human and other physical resources for the operation of the
enforcement program. Based on the available enforcement program
inputs or resources, each regional program develops certain opera-
tional functions in concert with national enforcement and operational
procedures. The results of applying these functions may be termed
outputs of the system. The system outputs are designed to achieve
certain tangible program outcomes. Such outcomes would hopefully
take the form of overall spill reduction.
Enforcement program outputs are related either to spill response
or spill prevention. Spill response consists of all actions taken to
assure1 an adequate response to spills, including on-site documentation
' of the spill, assuring its prompt clean-up, identifying the spiller
and processing the file through to the Coast Guard for penalty action.
Spill prevention procedures consist of inspections, spill plan evalua-
tion, notices of SPCC plan violations, possible holding of hearings,
and establishment and collection of final penalties.
In general, the components of program outputs are the same in all
regional programs. However, it is assumed that the exact manner in
which program components are manipulated within the regions will provide
an indication of specific regional enforcement policy. For instance,
if a regional program is heavily response-oriented as opposed to pre-
vention-oriented, one would expect that the output would indicate a
large number of on-site spill investigations as opposed to SPCC acti-
vities. On the other hand, a region which de-emphasizes spill response
might show a preponderance of SPCC inspections, violations and fines as
opposed to on-site incident investigations.
Finally, it is assumed that the relative emphasis that a partic-
ular region gives to the spill prevention aspects of its program
will be reflected ultimately in the incidence of NTR spills - that is
it is assumed that occurrence of NTR spills may be predicted as a
function of enforcement program ouputs.
26
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. Inherent in any oil spill enforcement program is the assumption
that program outputs can be manipulated in a manner to produce
tangible change in oil spill outcomes. Based on this assumption, it is
then desirable to develop effectiveness measures to serve as criteria
for assessing program improvement.
The present investigation has developed measures of effective-
ness corresponding to the components of an enforcement system as dis-
cussed above - that is, the effectiveness measures are categorized as
(1) Output Measures, (2) Outcome Measures and (3) Outcome/Output
Ratios. It should be noticed that the indicated effectiveness measures
avoid any reference to cost-effectiveness, primarily because cost-
effectiveness considerations are beyond the scope of this study.
Implicitly it has been assumed that sufficient economic resources
have been allocated for the effective administration of the national
enforcement program, and further, that each regional program has been
funded at a level sufficient to carry out its program procedures.
The following summary gives measures of effectiveness developed
for this study. Sufficient data were not available to quantify all of
these effectiveness measures. Those measures for which data were
obtained are discussed in Section 6 of the report.
1. OUTPUT MEASURES
a. Number of SPGC inspections per year
b. Number of inspections/number of appli-
cable faculties (if available)
c. Percentage of major non-transportation
spills for which on-site response was
done
d. Percentage of moderate non-transporta-
tion spills for which on-site response
was done
e. The average elapsed time between spill
incidence and EPA referral to the
Coast Guard
2. OUTCOME MEASURES
a. Total number of reported spills
b. Total spill rates
c. Percentage of non-transportation
related spills
27
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d. Number of 311(b)(6) violations/number of reported
spills
e. Number of non-transportation facili-
ties producing spills
f. Number of fines assessed/number of spills
reported
g. Percentage of 311(b)(5) violations referred to
U.S. Attorney
h. Average fine for 311(b)(5) cases referred to
U.S. Attorney
i. Number of chronic spillers (7 or more spills)
which are non-transportation facilities
j. Average volume of spills
k. Number of SPCC NOV's per year
1. Average SPCC penalty
m. Average percentage SPCC penalty based on
maximum allowable penalty
n. Percentage SPCC NOV resulting in hearings
o. Average litigation reduction per SPCC
violation
p. Average resolution time for SPCC violations
q. Number of spills detected through SPCC
inspectons/number of inspections
r. Number of non-transportation spills referred
by EPA/total number reported non-transportation
spills
s. Number of maximum SPCC' penalties/total number of
SPCC penalties.
3. OUTCOME/OUTPUT RATIOS
a. Number of SPCC NOV's/number of spills
b. Number of NOV's obtained/number of inspections
c. Total amount SPCC fines/total number inspections
28
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5.3 APPLICATION TO SPILL-ENFORCEMENT DATA
Enforcement/Spill Ratios
Results from the two approaches to the enforcement-spill
correlation are reported in this section. First, several ratios
of enforcement to spill activity are shown and then the results from
a formal enforcement-spill correlation analysis are presented.
Table 36 shows the ratio of SPCC NOV's to the number of non-
transportation related spills. It is seen that the ratio increased
dramatically between 1974 and 1975 and has continued to increase in
several regions in 1976. Table 37 shows average SPCC assessments
per gallon of average spill volume. Table 38 and Table 39 show the
average amount of SPCC collection per average volume of non-transpor-
tation spill. It is seen from these tables that SPCC activity in-
creased significantly in relation to spill activity between 1974 and
1975 and has shown only a modest change between 1975 and 1976.
Formal Statistical Correlation
Formal statistical correlation techniques were applied to en-
forcement and spill data to test the strength of their association.
The data on spill activity discussed in Section 3 and summarized in
Tables 12-14 show the distribution of non-transportation related spills
by spill size. Similarly, Tables 23-29 contain the SPCC activity
data. These statistics are summarized in Figures 52-54 and 72-73.
It is seen clearly in the figures that SPCC activity (numbers and
amounts of assessment and collections) is increasing over the study
period while non-transportation spill activity has shown a general
decrease. These two sets of results were correlated by applying analysis
to the correlation coefficients relating the time change of each of
the indicated parameters. The following results were obtained:
Non-Transportation Related
Spills
SPCC Correlation
Total
Minor
Moderate
Major
-.302
-.386
+ .128
-.066
29
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These results mean that the non-transportation related spills
tend to decrease as the level of SPCC enforcement increases. The
strongest downward trend is indicated between minor spills and SPCC
assessments. Weaker downward trends are indicated for major and
total spills. Moderate non-transportation related spills indicate
a slight positive correlation with SPCC activity. The exact reason
for this latter trend is uncertain. It may suggest that moderate
spills may tend to occur in facilities which are not covered by
SPCC regulations.
30
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SECTION 6
ANALYSIS OF REGIONAL ENFORCEMENT PROGRAMS
This section deals with the rationale behind conducting in-depth
studies and for choosing specific regions for this purpose. Each
region is described in terms of its progTam organization, enforcement
policy, program activity and uniqueness. Finally, elements of effec-
tiveness are discussed, with specific emphasis on certain program
features which we believe should be considered in achieving maximum
program performance.
6.1 AN OVERVIEW OF THE IN-DEPTH STUDIES
The basic reason for conducting in-depth studies of four selected
regions was to gain insight into enforcement program mechanisms at the
regional level. It was not the purpose of the project to evaluate
EPA policy or procedures at the national level, but rather to visit the
field to determine how, or if, national guidelines are implemented. Only
through a process of thorough familiarization with those techniques
employed in implementation, the philosophy of dealing with internal
and external realities, and regional procedures which enhance or impede
program implementation was it possible for us to make program recommen-
dations. This report is a descriptive narrative of the current state-
of-the-art of the oil spill enforcement program and the numerous
factors in various regions which have caused it to be where it is
today.
6.2 LOCAL PROGRAM SELECTION
One of.the most difficult decisions to make during the project
was the selection of regions for in-depth study. During the national
overview phase, brief visits were made to each regional office in an
attempt to get a general idea of the organization and activity of each.
At this point it became apparent that, while regions shared common
goals, their structures and views of effective program implementation
were vastly different. Therefore, selection was based not only on
geographic distribution but also on the activity parameters of the
regions.
Region III represents the heavily industrialized East. Its
program structure is unique in that oil spill enforcement activity
is concentrated, according to project definition, not in the Enforce-
ment Division, but in the Environmental Emergency Branch of the
Surveillance and Analysis Division. It is a region with heavy urban
31
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concentrations and concomitant pollution problems in addition to
rural pipelines and small well operations. Its centralized loca-
tion on the northeast corridor appeared to make this region a logi-
cal choice for an in-depth study.
From the beginning of the project, it was obvious that Region
VI would have to be included in the in-depth studies simply because
its territory is so vast and so heavily concentrated in the oil
business. Oil production facilities dominate the economy of much
of the region, such as the fields of east Texas, and many facilities
are located on waterways, such as the Louisiana bayou.
Region VII was selected for in-depth evaluation because it is
a truly inland region. It also represents the heartland of the
United States, covering the states of Nebraska, Iowa, Missouri and
Kansas. This is farm country with few urban concentrations and an
ideal representative of the midwest of the United States. Concen-
trations of facilities could be expected to be listed in production
operations in Kansas and in manufacturing plants in St. Louis.
The final choice for an in-depth study was Region IX. Not only
does it represent the west coast of the United States, but more than
any other region, it is completely oriented towards spill prevention
while having minimal response activity. Its territory covers not
only three mainland states but also Hawaii, Guam and American Samoa
so it is, if not the largest region in terms of land area, certainly
the most widespread.
One other region, which could not be included in the in-depth
study, but which was unusual because of its enormous amount of
SPCC inspections and on-site spill response activity is Region IV.
A brief visit was, therefore, made to Atlanta and proved useful in
providing additional background information and perspective on the
enforcement program.
6.3 THE ENFORCEMENT PROGRAM IN REGION III
Region III, with headquarters in Philadelphia, covers the
states of Pennsylvania, Maryland, Delaware, West Virginia, and
Virginia in addition to the District of Columbia. The oil enforce-
ment program is concentrated in the Environmental Emergency Branch
of the Surveillance and Analysis Division. This branch is staffed
by five professionals and two secretaries in Philadelphia, and three
professionals and one secretary in the subsidiary office in Wheeling,
West Virginia. Support services are supplied by a regional labora-
tory in Annapolis, Maryland, though these do not incude inspection,
response or enforcement activities.
32
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ProgTam Organization
Flow charts (a) and (b) indicate the centralized nature of
both the oil spill and SPCC enforcement programs. The procedures for
oil spill response and referral have been in effect since February
1975 and for SPCC actions since February 1976. For the former, a
spill report is received in the Environmental Emergency Branch
(EEB). It is logged both manually and into the SPCC computer system.
Once a spill has been reported, EEB conducts an on-site re-
sponse or sends a letter of inquiry to the responsible company re-
questing complete information on the time, location, nature, cause
and effect of incurred spill in addition to documentation on the size
and type of facility from which the spill emanated. Usually, this
correspondence could be handled through the standardized "308" letter.
In Region Ill's experience, however, use of the "308" designation re-
quires extensive routing and the eventual signature by an authorized
official. To avoid the delays which were encountered in this process,
EEB composed its own format and sends the letter directly from the
branch. Replies received from companies are examined to determine
whether or not the spill reached water. If it did, a referral
package is prepared by EEB and forwarded to the Coast Guard.
Through these replies, facilities not in compliance with SPCC
regulations have also been identified. When this occurs, a Notice
of Violation is prepared. It. is typed in the Legal Branch and signed
by the Director of the Enforcement Division. When the company re-
sponds, its SPCC plan is evaluated in EEB, penalty negotiations are
conducted with the company by EEB, agreement on compliance and pay-
ment is concluded, and finally the company's penalty check is received
by EEB and forwarded to the Coast Guard. Violations discovered
through inspections are handled in an identical manner, except that
the initial information is contained in the inspector's report rather
than garnered from a letter of inquiry.
Enforcement' Policy
The oil spill program has apparently always had very low priority
in Region III. Responsibility for referrals to the Coast Guard was
until February 197S lodged in the Legal Branch, which traditionally
emphasized other environmental programs such as air pollution and
NPDES programs. The low level of referrals can be indicated by
regional statistics: in 1972/73 approximately 50 cases were referred;
in 1974, 30 cases were referred. Following a shift in program
33
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REGIONAL
ADMINISTRATOR
N|
SURVEILLANCE 4
ANALYSIS
OIVISION
ENVIRONMENTS
EMERGENCY
BRANCH
/FT
/\
SPILL ER
¦4)
REGION III
Flow Chart (a): Order of Spill Program Work Flow
1". Spill reported to Environmental Emergency Branch.
2. Letter of inquiry prepared by Environmental Emergency
Branch and sent to spiller.
3. Spiller replies to Environmental Emergency Branch.
4. Environmental Emergency Branch documents case and
transmits file to Coast Guard.
3d
-------
KEuIQNAL
AOH IHfSTRAIOH
SHFQRCEMEHT
¦JlVtSIOH
LEGAL
BRANCH
4^
A.
SURVEILLANCE 5
ANALYSIS
DIVISION
FACILITY
SHVIR0NM6MBI.
SMEftaCf
2RANCH
"7T\"
/v
REGION III
Flow Chart (b): Order of SPCC Program Work c low
L. Violation determined by Environmental Emergency 3rancn.
2. Notice of Violation prepared and transmitted so Legal
Branch.
3. Notice of Violation typed and forwarded to Enforcement
Division.
4. Notice of Violation signed by Director, Enforcement Division
and sent to facility.
3. SPCC Plan prepared and sent to Environmental Emergency
3ranch.
6. SPCC Plan reviewed and penalty negotiations conducted with
facility by Environmental Emergency 3ranch-
7. Penalty check submitted to Environmental Emergency Branch
3. Penalty check forwarded to the Coast Guard.
33
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management in February 1975, the EEB took over responsibility for
referrals and, during the rest of the year, referred to the Coast
Guard all spills for which it had conducted on-site response. Sixty-
four cases were referred that year. A new policy was established
in January 1976 when EEB resolved to refer to the Coast Guard every
spill discharged into water, and 263 cases were handled in this
manner that year with a projected total of close to 300 in 1977.
The precise evolution of the spill program could not be traced
because of personnel changes and because files dealing with the early
part of the program were kept only in chronological order and logs
were non-existent. The system was changed at the end of 1974. Old
files were destroyed and logs have been kept in a systematic manner
from 1975. Information recorded in the logs includes identification
of the spiller, the date of the spill, amount and nature of the spill
(if known), the type of response (EPA on-site, State on-site, or
letter only), date report of spill was received in EEB, date of re-
ferral to the Coast Guard and, when available, final disposition of
case.
According to records, the SPCC program began in 1975, and during
that year 103 Notices of Violation were issued. Only 27 cases were
settled during the year and $15,510 in fines were collected. Twenty-nine
other cases were closed because information was outdated or incomplete.
During 1976, 74 Notices of Violation were issued, 30 assessments were
made, and 71 collections totalling $38,850 were made. Data for 1977
are incomplete at time of this writing, but it is interesting to note
that the penalties collected have risen from an average of $410 in
1975 to an average of $767 during 1977.
The present SPCC penalty policy was established in 1976 when the
program became centralized in EEB. In general, an initial penalty
averaging $3,000 is set. Usually, one-fourth to one-fifth of this
amount is actually collected. Prior to early 1976, initial assessments
had been lower since it was the attitude of 'the Legal Branch that it
was unrealistic to assess very high penalties and then lower them
drastically-. The change in policy reflects EEB's position that an
initial high penalty assures the immediate attention of a company and
induces speedy preparation of a valid SPCC plan. It is the policy in
Region III to emphasize to companies that good faith is a determining
factor in setting the final penalty amount and that good faith in-
cludes the preparation of an adequate plan. An experienced EEB engineer,
therefore, evaluates every plan regardless of whether or not it is
certified.
36
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Program Activity
Response policy incorporates a goal of having on-site investi-
gations of every spill over 3 000 gallons conducted either through
the Philadelphia EEB team or through personnel in the Wheeling office.
The exception to this rule is spills which occur in Virginia. This
state has an excellent response mechanism and consistently submits to
EPA concise and accurate reports.
In EEB's opinion, oil companies are generally most cooperative
about cleaning up spills. A major spill inevitably brings out not
only the State and EPA authorities, but also the media and.a bevy of
company officials. The reason for this is that large oil companies
are extremely conscious of their public image and also they have the
money and resources to conduct effective oil removal. However, the
many potentially hazardous small spills did not until a couple of
years ago receive the attention they should have. Regional program
activity has, therefore, stressed educating the general public about
small spills and impressing upon oil handlers and storers the gravity
of losing any amount of oil into the environment. This was the main
rationale for EEB's adopting the policy of referring every spill
involving oil reaching water to the Coast Guard.
Referral policy is based on EEB's experience that three to six
months is the optimum length of time for a case to be thoroughly studied,
documented and put in a viable legal package for Coast Guard processing.
This goal has been carefully adhered to. Regional records indicate
the following statistics: Of 64 cases in 1975, 61 were referred in
less than six months and only three in over six months. In 1976, 260
of 263 cases were referred in under six months. From available data
in 1977, 181 of 184 cases had been referred within time frames
established by the Region.
For the SPCC program, it is a set policy that, if a member of
the EEB travels, that individual will conduct inspections in the area
visited. This is a random method of inspection and has not been
selectively'implemented against any particular section of the region
or any particular segment of industry. Most violations, however, are
discovered through spill response activities. When EPA officials
perform an on-site response, they invariably comb the vicinity to
detect other possible violators. About 75 percent of violators are
determined in this manner. This fact has created a statistical prob-
lem, since a basic hypothesis in the development of this project is
that inspections could be used as an indicator of program activity.
Within Region III, EEB personnel believed that available data would
not adequately reflect this. Violations detected through letters of
inquiry following a spill are not logged as inspections. In addition,
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no differentiation has been made regarding types of inspections.
On-site inspection, as has been stated, is conducted randomly.
These may take as little as 15 minutes, if it is clear that no
provisions have been made for secondary containment. On the other
hand, an amendment inspection or even an informal evaluation of a
plan submitted to EPA in response to a letter of inquiry will cer-
tainly take several hours. It had been hoped to establish a valid
data base to solve this problem through use of the SPCC file, but
at the time of this writing, no inspection information has been re-
ceived from the Region.
Unique Program Features
The most unique feature of the Region III program is, of
course, the fact that its oil spill enforcement program is physically
and functionally directed from a branch of the Surveillance and Analysis
Division. This unusual situation has developed largely because one of
the EEB Professional Engineers is also an attorney. By vesting coor-
dination of program activities in a single branch with one person able
to provide both engineering and legal input, EEB staff believes that
the Region has given focus to the entire program. Companies are sure
with whom they are dealing, and EEB is charged with the processing
of each case from beginning to end. A negative potential is present,
however. Should the present lawyer-engineer leave, and a similarly
qualified replacement not be found, it is almost inevitable that the
program would encounter a difficult transition period.
At present, the program is essentially divorced from the Enforce-
ment Division, and even those elements which are completely enforcement-
related are conducted in the Surveillance Analysis Division. The ap-
parent pattern in Region III and other Regions indicates a low turn-
over rate in branches like EEB and a correspondingly high rate in
legal branches. This appears to have held true in Region III, despite
the low overall priority accorded to the oil spill program, and is a
significant contributing factor to the program's success.
6.4 THE ENFORCEMENT PROGRAM IN REGION VI
Region VI, with headquarters in Dallas, Texas, covers the states
of Texas, Louisiana, New Mexico, Oklahoma and Arkansas. Enforcement
Program responsibilities are lodged in the Water Section, Legal Branch,
Enforcement Division, where one attorney has been assigned the task of
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dealing with oil spills and SPCC plans, and in the Emergency Response
Branch of the Surveillance and Analysis Division, which is staffed by
five professionals and one secretary. Laboratory facilities are located
in Houston, Texas, and Ada, Oklahoma. Personnel there are sometimes
used for spill response if the discharge occurs in their area.
Program Organization
Flow charts (c) and (d) indicate the procedures for handling oil
spills and SPCC cases, respectively. Spill reports are received by the
Emergency Response Branch (ERB) of the Surveillance and .Analysis Division,
and those reaching water are referred to the Legal Branch of the
Enforcement Division. Reports are reviewed by an attorney in the Water
Section of the Legal Branch, who will mail a "308" letter to the spiller.
In order to avoid delays, a cover form letter signed by the Regional
Administrator is used, while another letter relating specifics of the
case is signed by the Water Section attorney assigned responsibility for
both oil spill and SPCC program enforcement. The spiller responds to the
attorney, who seeks additional information, if necessary. Once it has
been established that oil did indeed reach water, the attorney prepares a
spill referral package which is forwarded to the Coast Guard for action.
Regarding the SPCC program, inspections are made either by ERB
personnel or by a contract engineering firm. Inspection reports and
Notices of Violation are prepared in ERB. These are forwarded to the
Water Section attorney who decides, sometimes in conjunction with the head
of the Water Section, the legal merits of the case. The NOV is mailed to
the company and penalty negotiations are conducted between the attorney
and company officials. When the company's check is received, the
attorney forwards it to the Coast Guard.
During 1976, Legal Branch involvement with both prevention and
response enforcement activities became centralized in a single individual
who was thoroughly familiar with the entire effort and made it a priority
matter. Since his departure last year, his replacement has come and gone
and the attorney currently in charge of the program is new, both to the
program and. to EPA. This personnel turnover has led to a lack of con-
tinuity in the program. In addition, the very centralized nature of
assigned functions means that there is a general lack of awareness among
other members of the Legal Branch of the many intricate elements of the
SPCC program.
Enforcement Policy
Despite the fact that Region VI is oil country in every sense of
the word, the oil program has never had a high regional priority. In
1976, for example, ERB determined that there was a backlog of SPCC
cases extending over a period of six to ten months. Since no NOV's had
ever been mailed by the Enforcement Division, ERB at this point took
over the responsibility of preparing them in-house. As has been men-
tioned, strong individual support came from the Enforcement Division
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REGION VI
Plow Chart (c) : Order of Oil Spill Program Work Flow
1. Spill is reported to Emergency Response Branch.
2. Report is referred to Water Section.
3. Water Section attorney reviews case. A 308 letter
is prepared, signed by the attorney and sent to the
spiller.
4. Spiller replies to Water Section.
5. Legal package is prepared by Water Section and
forwarded to the Coast Guard.
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REGION VI
Flow Chart (d): Order of S?CC Program work Flow
1. Violation determined by Emergency Response 3ranch.
2. Notice of Violation prepared and typed in Emergency
Response 3ranch and forwarded to Water Section.
3. Notice of Violation reviewed in Water Section/ signed by
attorney and sent co facility.
4. 5PCC ?lan submitted to Water Section-
5. SPCC Plan transmitted to Emergency Response 3rancii for
review.
5. Penalty negotiations conducted with facility by Water
Section.
7. Penalty check submitted to Water Section.
3. Penalty check forwarded to the Coast Guard.
il
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at this time, but the departure of this person in 1977 left a void.
ERB tends to be gloomy about future prospects, since historically in
Region VI an attorney who works well on the oil program will be called
to work on other matters and will have less and less time to devote
to oil.
In addition to the problem of oil's low regional priority, the
Enforcement Division appeared to perceive little in the way of guide-
lines from EPA Enforcement, Washington. Of special mention were the
difficulties encountered in arriving at just penalties for large and
small operations. The philosophy of the Region is that SPCC is a
preventive program and is not designed to earn money. If negotiations
ensure that a company is in compliance, the Region will settle for a
nominal amount. On the other hand, large companies should be aware
of regulations through the Federal Register and other publications
and have the financial ability to implement adequate certified plans.
If, however, the region attempts to levy a higher penalty on a major
company facility, it is frequently faced with a time-consuming ap-
peal procedure.
Program Activity
It is the policy of Region VI to send an on-scene investigator
to any spill over 240 bbls (10,000 gallons), to some mystery spills
when the origin and nature of the substance spilled is not identified,
and to hazardous materials spills only when they appear to be extremely
serious.
The bulk of in-house SPCC inspections are conducted in conjunction
with permit inspections under the National Pollutant Discharge Elimina-
tion System (NPDES) which have higher priority in the region. Unfortunately,
these "multi-media" inspections give an incomplete picture since the
NPDES program does not cover oil fields. Other SPCC inspections are
carried out by ERB staff members following an on-site investigation of
a spill. In order to bolster the SPCC program, EPA/Washington granted
funds to Region VI for compliance inspections to be carried out by a
private engineering firm. These contract inspections accounted for
1000 of the total number of 1102 compliance inspections conducted in
1976 and 1977.
The sheer numbers of.facilities in Region VI suggest that greater
emphasis should be placed on prevention, yet ERB can only devote about
10 percent of its resources to the SPCC Program. In ERB's view, rising
spill trends can be only averted by constant vigilance in the field and
constant pressure on companies to implement and maintain preventive
measures. At the time of this writing.,, it was, for example, Regional policy to
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conduct an on-site amendment inspection if a company experienced two
spills within 12 months, and the amount of oil reaching water in the
second spill exceeded 1 bbl (42 gallons).
Reinspections are considered by ERB to be vital to program suc-
cess. A chance inspection in Louisiana, for example, revealed a major
company with certified plans that nevertheless had 30 facilities in
violation. Reasons for this included natural erosion, weather factors
and enlargement of oil handling capacities with no parallel increases
in diking.
ERB believes there should be less emphasis on the necessity of
EPA responding on-scene to major spills. The large oil companies are
generally cooperative and efficient in clean-up operations. Unfortunately,
much of the region's response activity is geared to media pressure.
Large spills receive coverage, train derailments receive coverage, gas
tank explosions receive coverage. The media fail to realize that EPA's
role in being able to avoid these disasters lies only in how much
leverage it is accorded to enforce preventive regulations. Since
spills are not occurring from facilities adequately protected by an
SPCC plan, the latter has never received the sort of appreciation or
publicity it deserves.
Unique Program Features
The obvious unique feature of the oil program in Region VI is
that it operates under a policy of low priority in circumstances which
suggest possibly the greatest regional need for oil spill response and
prevention activity. The production and transfer of oil in Region VI
exceeds that of any other Region and it has at least twice as many
spills as any other Region.
While this may be a reflection of the low level of priority ac-
corded oil on a national level, it is puzzling that more emphasis should
not have been placed on it given the certain flexibility in resource
allocations accorded to regional authorities. Given the vast amount
of oil facilities in a region where oil is news and media pressure
probably more pronounced than elsewhere in the country, it is somewhat
incongruous that the entire spill response and prevention program is
handled in ERB by two geologists, two biologists and a technician in
training.' The degree to which resources are stretched was obvious
during the visit of CAI staff. Four of five professionals were out of
the office on emergency spill response actions - all of which, by the
way, were transportation-related events.
The second feature characterizing Region VI operations is that it
is the only in-depth study in which there was a complete separation of
response/prevention and enforcement responsibilities, both administratively
and physically. Consequently, there was less mutual understanding and
appreciation of the roles played by the Legal Branch and by the Emergency
Response Branch and less evidence of the establishment of an effective
administrative mechanism to assure program continuity in the event of
personnel changes.
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6.5 THE ENFORCEMENT PROGRAM IN REGION VII
Region VII, headquartered in Kansas City, Missouri, covers the
states of Missouri, Kansas, Iowa and Nebraska. The oil spill en-
forcement program is concentrated in the Legal Branch and the Emer-
gency Response Section (EMR) of the Permits and Compliance Branch.
Both branches are part of the Enforcement Division. EMR has five
professionals and one secretary. Legal Branch involvement entails
participation of its chief plus one attorney and of a full-time
legal technician assigned specifically to oil spill cases.
Program Organization
Flowcharts (e) and (f) indicate enforcement mechanisms established
in Region VII. Spill reports are received by EMR and reviewed by EMR
and a Legal Branch attorney. If it is decided that charges appear war-
ranted, a case file is opened and the legal technician is assigned re-
sponsibility of obtaining reports from on-site investigators and along
with maps and other information relative to the spill and its location.
Once these data have been received in the Legal Branch, the legal
technician refers the entire file to an attorney for review and pre-
paration of a "308" letter, if necessary. Following the response of
the spiller and possibly the reception of other material deemed
pertinent to the case, the attorney determines whether there is a
basis for a referral to the Coast Guard. If so, the legal technician
prepares a referral package, and the case is forwarded through the Legal
Branch attorney to the Coast Guard.
For SPCC cases, the EMR transmits to the Legal Branch reports of
oil storage facilities which personnel have inspected and found to be
not in compliance. If the Legal Branch attorney determines that a
violation exists, a Notice of Violation is prepared and signed by the
Director of the Enforcement Division. The facility negotiates with
the Legal Branch attorney. If the case can be settled in an environ-
mentally acceptable manner, a consent decree is drafted by the Legal
Branch attorney and forwarded to the facility for review and signature.
When terms of the settlement are complete, the consent agreement is
signed and returned to the Legal Branch, which in turn transmits it
to the Regional Administrator for approval and signature. The penalty
check receipt is recorded and the check forwarded to the Coast Guard.
It should be stressed in regard to Region VII that flow charts as
such may tend to give an impression of a rigorous, institutionalized
routine. As the situation actually exists, however, there is much
done in the way of informal cooperation and mutual assistance between
the engineers in EMR and the lawyers in the Legal Branch. Region VII,
for example, encounters no delays in sending out the standard "308"
letter, an indicator of the support for the program at all levels.
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3EGICN '/II
?low Cham (a) : Order of S?CC Program Work flow
1. SQncompLian.ee report is prepared by the Emergency Response Section.
2. Report is forwarded -o the Legal 3ranch.
3. Notice of Violation is prepared and transmitted to the
Enforcement Division.
4. Notice of Violation is signed by the Oirsctor Enforcement
Division and sent to the facility.
5. Facility negotiates with Legal 3raxich and emergency Response
Section.
5. If case can be settled in an environmentally acceptable .T.anner,
Legal Branch attorney draft3 a Consent Agreement and forwards it
to the facility for review and signature.
7. Facility signs Consent Agreement and returns <_t to Legal 3rar.ch.
3. Legal 3ranch forwards Consent Agreement to the Regional
Administrator for approval and signature.
9. Check is submitted by the facility to the Legal 3ranc.i.
10. Check receipt is recorded ana check is forvardsd to the Coast C-uard.
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REGION VII
Flow Chart (f): Order of Oil Spill Program Work Tlow
1. Spill is reported to Emergency Response Section.
2. Spill report is reviewed by Emergency Response Section and Legal
Branch. If a file on the case is opened. Legal Branch technician
compiles package, including maps of spill site.
3. Complete file is reviewed by Legal Branch attorney. '303" letter
is prepared and forwarded to the spiller.
4. Legal branch attorney reviews reply from spiller.
5. Case is reviewed and referred to the Coast Guard.
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Enforcement Policy
Region VII staff report that regional philosophy has consistently
been that prevention and control of oil spills have equal priority with
other pressing environmental needs, such as air pollution and waste
management. Since the inception of the SPCC program, efforts were
made to correlate it with the existing spill program and thus to
provide an effective machinery for the speedy handling of <±11 violations.
The Legal Branch has assigned one technician to work full-time on
oil spills and one attorney to work part-time on both spills and
SPCC violations. Under this system, both the attorney and the legal
technician have an intimate knowledge of the oil program and will
inform EMR of the existence of possible violators identified through
replies to "308" letters or subsequent information obtained from
topographic maps, state investigations, and other sources.
The Region can only comment in general about SPCC assessments
and subsequent mitigated penalties because it is currently involved
in a complex law suit with a large company. From the limited amount
of data available for the study, it can be observed that there has
been a somewhat upward trend in collections (Table 27). The policy
in general is to set an SPCC penalty amount based on the gravity of
the violation and the demonstrated good faith effort of the facility
to achieve compliance after reception of the Notice of Violation.
It is the policy of the Region to refer cases to the Coast
Guard within two months of the date of spills. A spot check of the
card files maintained by the legal technician revealed that this
policy has been effectively implemented, except in unusual cases
where a great deal of additional information had to be obtained or a
state was tardy in submitting an investigative report. The Region
attempts to settle SPCC cases within 45 days of the transmission of
the Notice of Violation. Again, spotchecking revealed that this has
been successfully accomplished except in cases involving extensive
litigation or other factors which required extra time to achieve
compliance
Region VII never pressures a company to incorporate certain
features into an SPCC plan. A plan which appears to be constructed
on the basis of sound engineering guidelines and which is certified
by a Professional Engineer is acceptable, since the Agency is not
mandated to check for permeability of dikes, foundation design and
other structural features. Should a plan fail, however, and a trig-
gering spill result, the Region will conduct an on-site inspection
to determine how the plan failed, may require an amendment to the
plan to be prepared and implemented, and will later reinspect
to determine if corrective action has been taken.
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With regard to inspection policy, EMR is opposed in general to
the idea of contracting out compliance inspections to an engineering
firm, since it is felt that the program can be more effective if the
Enforcement Division can exhibit geological, engineering and legal
integrity in defending its reasons for bringing a charge against a
facility.
Program Activity
Since response is a priority matter in this and other regions,
SPCC activity must, therefore, become a second priority. It is
Regional policy to respond to all major spills, most moderate spills
and even minor spills which are unusual in nature. The response
activity of any region based on the number of oil spills for which
it has provided on-site response is, however, a somewhat unrealistic
parameter by which to judge response activity. Most of the truly
serious and urgent response activities conducted in Region VII are
performed under the aegis of Section 504 of the FWPCA, which takes
priority over any other section of the law and directs the Agency to
act in any event which presents "an imminent and substantial endanger-
ment to the health of persons or to the welfare of persons where such
endangerment is to the livelihood of such persons . .
A duty roster has been established for the five professionals
in EMR so that at least one person is on call 24 hours a day seven
days a week. Two people must always be available for response activ-
ities. Ideally, the section would like to perform at least 40
inspections per month and have one professional spend a majority of
his time in the field to inspect and follow-up on compliance. This
has not been possible, but the Region's record is impressive. In
1975 and 1976, respectively, 355 and 464 inspections were carried out.
The number dropped to 250 in 1977 due mainly to heavy response demand
and to time consumed in other matters, such as a lawsuit lodged against
the Region.
Unique Program Features
Region VII is, first of all, geographically unique among the
in-depth study regions in that its location is totally inland. It is,
therefore, concerned only with inland transportation and non-trans-
portation related spills. This fact alone would mean that, if a
detailed statistical study on spill types were to be conducted,
Region VII would be in a good position to break down spills into two
categories with subcategories for non-transportation spills occurring
in facilities covered by SPCC regulations, including those with no
plan and those with plans that failed, and non-transportation facilities
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not covered by SPCC regulations. A comparison of the degrees of
veracity displayed by populations of'various regions can scarcely
be quantified in a formal evaluation of program effectiveness, but
it was interesting to note that this Region believed that one measure
of the effectiveness of the SPCC education program was the number of
facility operators who told inspectors that they had just been negli-
gent in complying with the law.
Personnel in Region VII stressed the support which the oil
spill enforcement receives at- the regional level. They also stated
that they were fortunate in that oil could be given equal priority,
since the Region is not plagued with as many sewage problems and
other pollutants so common, especially in industrialized, urban,
coastal concentrations. These factors have contributed to the high
level of legal support accorded the engineers in EMR. All agreed that
having both program components located within the Enforcement Division
and in one working area has led to a high degree of both formal and
informal cooperation and consequent program effectiveness.
6.6 THE ENFORCEMENT PROGRAM IN REGION IX
Region IX, headquartered in San Francisco, California, covers
the states of California, Arizona, Nevada, Hawaii and American pos-
sessions in the Pacific Ocean, such as Guam and American Samoa. There
are five professionals in the Water Surveillance Section (WSS) , Water
Branch, Surveillance and Analysis Division, all of whom work directly
on oil spill prevention and control. In the Enforcement Division, one
attorney and two paralegal specialists located in the Legal Section
of the Water Branch are assigned spill enforcement responsibilities.
A merger of these two sections within the Enforcement Division was
being contemplated at the time of the in-depth visit, but had not been
implemented at the time of this writing.
Program Organization
Flow charts (g) and (h) indicate the manner in which SPCC and
spill cases are handled in Region IX. SPCC violations are identified
by WSS inspections and inspection reports are transmitted to the Legal
Section of the Water Branch in the Enforcement Division. There, a
paralegal specialist prepares a Complaint* which is routed through
*Region IX uses the term "Complaint" against companies which are not
in compliance with SPCC requirements. The rationale for this is that
"Complaint" identifies a specific document used in all litigation pro
cesses while "Notice of Violation" is strictly EPA terminology.
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REGION IX
Flow Chart Cg): Order of SPCC Program work Flow
1. Violation i3 determined by the Water Surveillance Section.
2. Water Surveillance Section (S&A) reports to Legal Section
(Enforcement).
3. Penalty proposal meeting is held among members of the Legal
Section (Enforcement), at which the person who inspected the
facility is present. The case is analyzed and a penalty
proposal figure established.
4. A Complaint is prepared and transmitted to the Director,
Enforcement Division.
5. Complaint is signed by the Director, Enforcement Division,
and sent to the facility.
6. Facility prepares an SPCC plan and forwards it to the Legal
Section.
7. Plan is reviewed by the Water Surveillance Section.
8. Legal Section negotiates penalty with the facility and prepares
a settlement agreement, documenting pertinent facts to explain
the amount of the final penalty.
9. Facility sends penalty check to Legal Section.
10. Complete file is circulated through water Branches of SSA and
Enforcement. Penalty check is forwarded to the Coast Guard.
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RSGION :x
Flow Chart (h): Order of Oil Spill Program Work clow
1. Spill is reported to water Surveillance Section.
2'. 30 8 letter is prepared by water Surveillance Section and
transmitted to Water Branch (Enforcement Division).
3. Legal 3ranch reviews 308 letter and transmits to enforcement
Division.
4. 308 letter is 3igned by Director, Enforcement Division, ar.d
forwarded to spiller.
5". Spiller's reply received by Water Branch.
&. Litigation pacxage prepared by water 3ranch and forwarded to the
Coast Guard.
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the Water Branch and signed by the Director of the Enforcement
Division. Before the Complaint is forwarded to the facility, a
penalty proposal meeting is held and a proposed penalty figure
established. Negotiations are then handled by the paralegal
specialist with aid available from the attorney advisor. Every
attempt is made to complete negotiations by phone. Each telephone
conversation contains a discussion concerning the specific violation,
the necessity of implementing an SPCC plan (especially the require-
ment of secondary containment), the company's right to a formal
hearing, and the establishment of mutually agreeable time frames
for preparation and implementation of the plan. In general, the Region
will settle for 50 percent of the original assessment, but will charge
more if the company is uncooperative. A-Consent Agreement is then
prepared by the paralegal specialist and routed through the Water
Branch. A memo to the file is prepared in support of the settlement
figure, stating all factors which have affected the determination of
the final amount. When the company's check is received, the entire
file is circulated to all interested parties. A penalty receipt is
prepared and the check is forwarded to the Coast Guard.
When an oil spill occurs, it is reported to the Water Sur-
veillance Section's 24-hour hot line. A "308" letter is prepared there
and routed for signature to the Director of the Enforcement Division
through the Legal Section. When the Legal Section receives the re-
sponse, it seeks from the company, the state, or other sources any
additional information required. A law student, who works part-time
for EPA, then prepares a litigation package which is forwarded to the
Coast Guard for action.
It is important to note in Region IX that emphasis has been
placed on program continuity, especially regarding SPCC cases. Every
telephone call or other discussion regarding a case is supposed to
be documented and correctly filed so that information is readily
available to responsible parties, regardless of personnel changes.
In addition, there is a great deal of overlap in the engineering and
legal aspects of the program. Attorneys frequently accompany in-
spectors to the field. Likewise, inspectors sit in on penalty proposal
hearings. In this way, an understanding has developed between
these two very different disciplines. Circulation of files assures
that inspectors are aware of the disposition of each case. The process
is somewhat time-consuming, but personnel agreed that it was indeed
effective. Yet another procedure to ensure communication and
coordination of efforts is a monthly meeting with the Director of
the Enforcement Division attended by legal and technical staff during
which the status of each case is documented for possible discussion.
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Enforcement Policy
Regional philosophy has stressed prevention rather than re-
sponse. In consequence, the SPCC Program has received the greatest
amount of attention. For assessments, the Region relies heavily on
the penalty proposal meeting at which lawyers and inspectors sit down
together to determine all the facts of a case. This conference brings
to light all those variables which ultimately will determine the amount
of the final assessment. Among those factors is the type of oil being
handled. Another factor is the degree of certainty with which the
likelihood of the stored oil reaching water can be predicted. Yet another
consideration is the nature of the waters into which the material will
be discharged. In relatively prsintine environment such as Lake
Tahoe, for example, any kind of oil spill would represent a real
hazard for many years.
The goal of enforcement is, therefore, to get an acceptable
plan suitable for the facility. The bargaining process through which
penalties are mitigated is comparable to a litigation process in court.
At one time, it was believed that penalties should be kept low for
small companies and raised for large corporations. However, the Region
has determined that franchise operators for large companies frequently
need a great deal of time to negotiate through their own corporate
structures, acquire loans, etc., and that an acceptable plan for a
large facility may prove to be extremely complex. Contrary to some
other regions, Region IX is of the opinion that many operators "hang
on until they are caught." Non-implementation, in effect, saves these
recalcitrants construction money. An attorney in Region IX mentioned
that, under the NPDES Program, a company may be fined according to
what is saved through noncompliance. A similar criterion might be
applied to SPCC cases.
Region IX has been informed by some companies that certain in-
surance companies will lower to stabilize rates for implemented spill
prevention plans.
Region IX requires companies to submit their SPCC plans directly
to the inspector who detected the violation. If the plan is not ac-
ceptable in any way, EPA will give advice. However, if the company
enters into a consent agreeement, the second complaint will carry
the maximum penalty.
It should be pointed out here that costs for SPCC compliance in Region
IX may run higher than in other regions because of the ever-present danger
of earthquakes. Many storage facilities are located on the cliffs
around San Francisco, many straddle the San Andreas or Hayward fault,
and preventive measures to protect one million barrels of storage could
cost a company $100,000 or more. Enforcement of prevention is
considered essential, however. EPA officials in Region IX are
S3
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convinced that there will be storms and earthquakes and, as one
stated, "We don't need to add to natural castatrophes by having poor
engineering."
The thrust of the Enforcement Program in Region IX, therefore,
is more and more prevention. The Region is, indeed, fortunate in
having a geographic structure and an unusual cooperative status with
the Coast Guard and the State of California which permits it to func-
tion in optimum fashion to avoid oil spill occurrences instead of
having to clean them up.
Program Activity
Region IX is undoubtedly the least response-oriented operation
in the national EPA program structure. Some reasons for this are
fairly obvious (e.g., quick response to a spill in Guam would require
two days' travel). Possibly because of this time factor, and also
due to Executive Order 11735, the Coast Guard has assumed responsibility
for spills which occur in Hawaii and the Outer Islands. Two other
states under regional jurisdiction, Nevada and Arizona, are essentially
arid and, apart from occasional problems on the Truckee River, there
are few facilities which could discharge a spill into the water. In
addition, spot-checking on those operations where the possibility
existed, such as over a dozen located in Phoenix, revealed 100 per-
cent compliance.
California, however, has lots of spills. Most of these are
coastal and handled by the Coast Guard. For those which are inland,
the State has established a system of rapid response and rapid trans-
mittal of information to EPA and other concerned organizations.
California has established an Office of Emergency Services which noti-
fies EPA and various state organizations of any inland spills which
occur. California's Department of Fish and Game responds to almost
every spill. Spills from oil production facilities are handled by
the California Department of Oil and Gas. The California State Lands
Office has significant input to spill occurrence. In addition, the
California Department of Transportation and its highway patrol are
well-trained and are quickly available to respond to emergency situa-
tions. The view of the State of California appears to be, in the
very basic terms of an analogy, that the State can serve as a Fire
Department for spills if EPA can serve as a Fire Inspector for
prevention.
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Examples of state cooperation are legion. The California De-
partment of Oil and Gas, for example, has regulations for preventive
measures on production wells. The California Water Resources Board
has the authority to issue an abatement order for an imminent pollu-
tion hazard as applied to lack of preventive construction in large
bulk storage plants. Since the State regulations with regard to
designated control requirements are minimal, the Water Resources
Control Board depends on EPA to set a standard for prevention. The
attitude of the State of California can be summarized in that it will
concentrate its resources on monitoring and clean-up but depend on
EPA for inspections and prevention.
EPA program activities have evolved, therefore, since 1975
but have always been focused on prevention. At the beginning of the
program, inspections were concentrated on facilities identified
through industry lists, telephone books and random inspections.
Original inspections were carried out only in major metropolitan
areas and were heavily concentrated in California and Hawaii. The
violation rate was relatively low; 36 violations out of 119 inspec-
tions in 1975 were detected by EPA. The same year, EPA also contracted
with the California Department of Oil and Gas for inspections to be
conducted by engineering students. The system resulted in pinpointing
121 violations in 641 facilities.
By 1976, the Region was considering the introduction of
aerial reconnaissance to identify SPCC violators. A systematic study
by the Region of the 1975 logs, county by county throughout the
Region, determined that Hawaii had been very thoroughly inspected, but
practically no inspections had been carried out in non-coastal areas
on the mainland. Since that determination, the Region has tried to assure
that every county in the Region is inspected at least once a year.
Aerial reconnaissance is also used for areas around San Francisco,
Los Angeles and Bakersfield. Through this method, many operations
with high spill potential have been identified, especially around
Long Beach. The program policy in Region IX has, therefore, been to
conduct on-site inspections and re-inspections and combine this ef-
fort with aerial reconnaissance studies. This policy was designed
to obviate unnecessary inspections of facilities obviously in compliance.
In 1976, of 121 inspections, 69 produced violations. In 1977, 94
violations have been detected mainly through investigations of
structures found through aerial photography. The only trouble with
the latter is that EPA inspectors have occasionally found themselves
examining water tanks rather than oil storage facilities. The
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inspection of an undiked water tank would not be listed on inspection
data. The Region does not believe in writing up Complaints and then
retracting them. The close relationship between the inspectors and
the attorneys has convinced the former that this is a waste of time.
Unique Program Features
Region IX is unique in many ways, mostly because of certain ex-
ternal factors imposed upon it. Regardless of national priorities, it
is difficult to imagine Region IX concentrating its efforts on speedy
response to spills. It is physically impossible in the case of Hawaii
and the Pacific Islands. Arizona and Nevada, which are within its
jurisdiction, rarely have any spills that reach water. Finally, if EPA
were to intervene aggressively in California, the Agency might ruin its
good working relationship with a state which may possibly have the best
spill response network in the country within its boundaries.
Region IX has thus concentrated its efforts on spill prevention
and, of all regions studied, probably devotes more time, professional
talent and overall tenacity to bringing SPCC violators into compliance.
Concomitantly, there is less interest shown in the spill program than in
other regions. Dossiers on spills are compiled and forwarded to the
Coast Guard by a law student who works part-time, and logs indicate cases
dating back over six months on which no action has been taken. The
Region perceived Coast Guard penalties as being consistently low and not
enhancing preventive enforcement. Furthermore, the Region stated that
the Coast Guard had a backlog of cases (later denied by the Coast Guard)
due to massive spills following December 1977 storms. These storms have also
led several Regional officials to believe that immediate program
priority should be accorded to re-inspections of those facilities
whose preventive structures could have been damaged by heavy rains.
The degree of cooperation between field inspectors and attorneys
is marked by their joint on-site inspections and the degree of
importance attached to the penalty proposal discussions in which both
inspectors and attorneys participate. These discussions include the
widest possible scope of factors which could mitigate or increase an
assessed penalty. Another unusual factor is that one attorney is also
an accountant and, if necessary, will examine a company's financial
situation in detail, especially if a company representative states
that they do not have the means to implement SPCC requirements.
The administrative separation of the oil spill enforcement program
between the Surveillance and Analysis and Enforcement Divisions has
apparently never affected either attitude or performance. Personnel
pointed out that this was primarily because, since the inception of the
program, the two offices had been located in close physical proximity
and contact between them had developed in an informal and uncluttered
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manner. It was believed that the discussed merger of the program
under the aegis of the Enforcement Division would not influence
established procedures, unless national priorities force a cut in
the SPCC budget and resultant reduction in program activity levels.
Should this occur, lack of travel funds would limit inspections to
the San Francisco area and massive spills could not be prevented in
Southern California.
6.7 ASSESSMENT OF LOCAL PROGRAM EFFECTIVENESS
Certain hypotheses evolved in the early stages of the project
which were confirmed or negated during the progress of the in-depth
studies. The in-depth studies also provided insight into why there
were gaps and inconsistencies in data. This section deals with
certain factors which impact or might impact local program output.
They were not discussed in the description of each region, for this
would have been repetitive, but are considered important enough to
be included here since many of them were crucial in the determination
of recommendations.
At the outset of the project, we expected that the Headquarters
Office of Enforcement and regional enforcement program officials
would perceive each other's roles somewhat differently and possibly
with some degree of antipathy. This, of course, is normal. Did it
not exist, EPA would be an anomaly among organizations with home and
field offices. From observations during the in-depth studies, it
would appear that the field/home office relationship is more clearly
defined in the regions close to Washington. The farther away the
region, the less interest Washington commands and, in consequence,
the less communication there is with Headquarters Enforcement.
Furthermore, as one moves away from Washington, the less -emphasis
is placed on formal administrative procedures and personnel hierarchies,
at least on the working level. Consider Regions I and II, where the
Surveillance .and Analysis and Enforcement Divisions are actually
located in different municipalities, and Region III, where the basic
philosophies of the two divisions were so markedly different that the
program succeeds only because the established administrative apparatus
has been to a certain extent circumvented. Move out to Region VII,
where all oil spill and SPCC cases are handled within the Enforcement
Division,'or to Region IX, where they are administratively but not
physically separated. To an outside observer, it was apparent that
the administrative structure in these regions was secondary to
functional considerations. Attorneys and engineers were equally
dedicated to the achievement of program goals, and the level of
cooperation and mutual understanding of their respective roles was
impressive.
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Flow charts, which were designed to depict organizational
involvement in the enforcement program, were harder to develop in
the latter two regions since enforcement activities criss-crossed
legal and prevention/response team lines both formally and informally.
It became evident that the success of the oil spill enforcement program
in the field depended to a great degree on the type and amount of
interaction between the two elements. Where they are physically or
philosophically separated, the program is inevitably weakened. Where
they axe closely knit, the program is consistently stronger.
Relations with the Coast Guard and the States
It is also important to note that regions must interact with
both the U.S. Coast Guard and the various states within their juris-
diction. Relations with the Coast Guard are to some degree conditioned
by geography, since the greatest area of Coast Guard concentration
is naturally slanted toward activities in ocean surveillance, ports
and harbors and river estuaries. Region VII, for example, deals with
one Coast Guard district while Region III deals with three. In general,
regions reported harmonious relations with the Coast Guard. A source
of friction was eliminated when the regions ceased recommending
penalty amounts to the Coast Guard. Some regions indicated that the
Coast Guard is at times slow to process cases, though all regions ex-
pressed an understanding of the fact that Coast Guard officials, like
those of EPA, are constantly under pressure to give priority to
response activity.
Little mention was made of relations with states. The degree and
level of relationship between EPA regions and states appears to be a
function of state policy, funding and similar contributory factors.
Staffing
Almost all regions in the in-depth study cited lack of clerical
help as a reason for delays in processing enforcement cases. Region
III appeared to be the most fortunate with five professionals and two
secretaries assigned to oil spill enforcement actions in the
Environmental Emergency Branch and one typist in the Enforcement
Division who provides clerical support in the preparation of NOV's.
The Region IV Environmental Emergency Branch, though not the subject
of an in-depth study, has to be singled out as the least fortunate
with one secretary for eight professionals, although the Legal Branch
performs supportive services like the preparation of NOV's. In Region IX
the problem was slightly different since the Agency there has
established a Word Processing Department. This system, to quote an
attorney, is "great for emergencies, rotten for routine." Lack of
clerical help in the Legal Branch of Region VI was cited as the reason
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for the preparation of NOV's being taken over by the Emergency
Response Branch. Region VII did not find lack of clerical help a
major stumbling block except for backlogs in updating case dis-
positions.
Of all regions studied, it would appear that based on the ratio
of spills to number of people available for inspections and response,
Region VI is the most seriously understaffed in every way. From
limited data available, it would appear that response team personnel
in Region IV spend more work-days on field response activity than
other regions.
Record-Keeping
It appears that regions have received next to nothing in the way
of guidance from Headquarters as to what records should be kept and
what information should be included in these records. The first
material given to CAI consisted of logs from EPA Headquarters' Office
of Enforcement. It was unclear at the outset why information contained
in these logs was incomplete and erratic in certain time periods.
This was soon easily explained. The logs themselves are typed in
Washington from case information received from the regions. They are
then transmitted to the regions every six months so that missing
enforcement data can be supplied. In many instances, cases were still
pending when the logs were returned to Washington and, thus, the logs
in 1977 were still reflecting open cases dating back a year or more.
In the regions there did not seem to be a precise comprehension of
the purpose of these logs or, sometimes, even knowledge of their
existence on the part of regional enforcement officials. In fact, the
general assumption was that regions forward reports or copies of
pertinent correspondence to Washington and that this completes their
reporting requirements.
Gaps in data can frequently be explained by personnel shifts,
which have left positions unstaffed for significant periods of time.
An example of this is Region I, where the slot allocated in the Enforce-
ment Division to the oil spill enforcement program was vacant for nine
months. CAI staff made a special trip to Boston to gather data from
the files. No logs had been kept until a new paralegal specialist
recently filled the position. Her work was hampered in that, not only
was she dealing with an almost insurmountable backlog in oil spill
enforcement cases, but was also assigned to spend SO percent of her
time on NPDES work.
It was a pattern generally applicable throughout the regions that
data on response and monitoring actions were more complete than the
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enforcement data. This may be a reflection of the high personnel
turnover rate in enforcement and the comparatively stable staffing
patterns of the response teams. In addition, with regards to the
SPCC program, the fact that it is of relatively recent origin and
because national guidelines on record-keeping were not given to the
regions at its inception, some "floundering around" occurred
regionally before a system was established. In some regions, there-
fore, such as Region IV, an overwhelming amount of statistical data
was readily available on spills, response activities and inspections,
yet gathering SPCC assessment and collection data would have required
manual retrieval from a docket card system, which serves its purpose
in the regional context. This reflects an attitude which has prevailed
in this extraordinarily dynamic region, and which is shared by others,
that the program is goal-oriented. How much is assessed and how much
is finally paid by a company are relatively unimportant. The enforce-
ment processes are merely tools to ensure that companies understand
the gravity of oil spills and the necessity of instituting measures
to prevent them.
The SPCC Computer File
Original perusal of SPCC computer output for EPA Headquarters
puzzled CAI personnel because of its voids and inconsistencies. The
in-depth study phase of the program included questioning regions about
their reactions to and use of the computerized data base.
Region III was enthusiastic about the computer and reported that
details on each spill and each SPCC violation were conscientiously
logged into it and used to correlate spill and SPCC data. CAI requested
the following breakdowns through use of the computer file.
1. Yearly number of spills from:
a. Pipelines
b. Railroad accidents
c. Truck accidents.
2. For all categories, the total and average volumes spilled.
3. The yearly number and volume of major, moderate and minor spills.
4. The number of chronic spillers.
5. Number of SPCC inspections/violations detected through
computerized correlation.
6. Total and average amounts of assessments by year.
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Realizing that time constraints create great difficulties when
regions attempt to supply statistical data, it was nevertheless hoped
that the computer could easily and quickly sort out these data for the
Region III program. Unfortunately, all that was received from the
Region was a printout listing the spills more or less in the order in
which they occurred, their identification as being onshore transportation
or onshore non-transportation, the date of the spill and the amount of
oil reaching water. These data had to be manually sorted by CAI over a
period of several days in order to obtain detailed information.
Regions VII and IX stated that they had attempted to use the com-
puter system but that they had failed to understand its purpose or how
to make it operate effectively to meet regional needs. Region VII
personnel expressed particular disappointment that it had not been
possible to employ computerized techniques to identify correlations
between inspections and non-transportation related spills. This, they
believed, would show statistically that in regions with active
inspection programs, non-transportation related spills were going down,
while the opposite would hold true for regions where inspections were
deemphasized. It would be helpful to both Washington and the regions
if these could appear as measurable trends rather than be based only on
the personal knowledge of those staff involved in the program.
Region IV offered the most detailed criticism of the computer
system. Although this region was not the subject of an in-depth study,
it was the only region visited which expressed a firm conviction that
the oil spill enforcement program could be substantially improved through
use of appropriate computerized techniques. The computer analyst in
Region IV stated that the basic problem with the system is that the
program over-edits for SPCC data while, for spill data, there are not
enough codes. There is, for example, no way to sort out such constant
sources of spills as transformers, power plants, railroad leaching, etc.,
to identify spills which are significant but for some reason did not
reach water, or to enter hazardous materials spills. Another example of
the program's inadequacy is that there is no way to report how much oil
is recovered. This is an important factor since, in general, a high
percentage of viscous oil is always recovered in major spills, but
practically none is recovered from small spills of highly volatile oil.
Statistics such as these from the computer would be a worthwhile
indicator of the dangers inherent in small spills.
Region IV is using an interactive mini-computer to submit data to
the computer file in order to minimize the error rate of up to 50 per
cent experienced when data were keypunched in Washington. Problems ,
remain, however,and the region consistently leaves blank such
categories as "Man-Days Spent on Inspections." The reason for this is
that there is no way to define the type of inspection being logged.
An initial compliance inspection might take 15 minutes. An amendment
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inspection might take a half day, a day or even longer. For problems
such as these, the Region's policy has been to omit information
rather than provide invalid and misleading statistics.
Region VI, which like Regions VII and IX, has given up attempts
to use the present computer system, did have suggestions as to how
computerized communication could be vastly improved. There is a
definite need for a 24-hour system at the National Response Center,
since the present OHMTADS (Oil and Hazardous Materials Technical
Assistance Data System) as it stands is ineffective. The present re-
quirement is for an EPA response team member to carry a terminal on-site
along with a gas mask, tape recorder, camera and other necessary equip-
ment. Then an electrical outlet must be found to plug in the terminal
and this, especially in the case of rural spills, is frequently im-
practical. If all the above can be accomplished, it may still take 30
minutes or more to put the system into operation. The suggestion of
Region VI is that an investigator should be able to connect with the
system through a simple telephone call. This would permit the investi-
gator to determine what was needed, call the National Response Center,
access the system and obtain immediate information. The result would be
a measurable improvement in response capability, especially for hazardous
materials. The Region considers the current OHMTADS as a hindrance to
response efforts; therefore, it has not been used for some time in VI.
In summary, the regions are not currently making efficient use of
the SPCC computer file. On one hand, it appears that regional staff do
not possess adequate knowledge of the software system to gain full ad-
vantage of the computer's potential. On the other hand, the computer
file appears cumbersome to use and does not adequately address
program issues of concern to regions.
B(5) Referrals
The National Overview phase of the project revealed a downward
trend in referrals in all regions.
Across the regions studied, this trend was confirmed and there was
complete agreement that b(5) referrals to the U.S. Attorney, which are
already negligible in quantity, will continue to decline. The overall
reason stated for this was that the system consumes too many resources
for results produced. Over the past two years, for example, Region III
devoted much time and energy to the preparation of three cases which it
believed had involved definite criminal liabilities. Of the three, one
was dismissed and the other two resulted in nominal fines of $200 and
$300 respectively. It is also true that U.S. Attorneys have railed to
take any action on cases referred, and many have been pending for a
period of several years.
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Cost-Effectiveness Considerations
The prevailing view that EPA should concentrate on obtaining
plans rather than emphasize the amount of penalty collected is now
being reconsidered as the SPCC program becomes more mature.
Region IX, for example, has suggested that, like the
NPDES program, fines in future may be geared to savings accrued by
the company through noncompliance. The Region has also started ex-
plaining to facilities the costs of clean-up operations and has
reported that some insurance companies are cutting costs to facilities
in compliance, so that it is actually cost-effective for those facil-
ities to have their plans implemented and maintained.
In Region IV, a plan is crystallizing to tie SPCC penalties to
the clean-up costs which come out of the revolving fund. EPA. has
access to this fund for travel, overtime and other administrative ex-
penses involved in performing on-scene response activities. Matching
their reimbursable figures with fines collected through SPCC penalties
appears to indicate that the SPCC program covers between 50 and 60
percent of costs incurred by personnel performing on-scene responses.
No technical correlation study has been attempted, but it would appear
that the SPCC program is contributing materially not only to preventing
spills but to cleaning up those which do occur by keeping the fund semi-
solvent.
Region VI contracted out for SPCC field inspections. It was the
general view of the regions that this was going to be more and more a
trend, though certain regions were vehemently opposed to the idea.
The actual cost breakdown is not available although the statistically-minded
Region IV has estimated that if SPCC field inspections are conducted in
conjunction with other field activities, the cost of each inspection is
slightly over $8.00. Apparently, Region VI obtained some 1,000
inspections at a cost of approximately $100,000. However, no attempt
is made here to judge the relative quality of inspections under either
of these systems.
A fundamental assumption used in the current study was that the
amount of resources available was adequate for the accomplishment of
the program's mission and that regional effectiveness could be assessed
on the basis of program activity. During the study it became apparent
that adequate resources are usually not available to implement the
complete water enforcement program at a desirable level. To optimize
program procedures so that the greatest benefit is obtained for
application of available resources, it may be necessary to compare
program implementation costs with those pollution costs resulting from
lack of spill enforcement activity. For instance, a cost/effectiveness
analysis may be performed to correlate regional input to the revolving
fund through SPCC fines with regional output for spill and hazardous
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substances response and determine what percentage of the latter is
reimbursable from the revolving fund. In addition, the cost of
inspections could be determined and correlated with estimated clean-up
costs should a spill from a facility occur. Measurements could also
be made to determine if SPCC money remained in the fund to be used in
monitoring or cleaning up transportation-related spills.
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SECTION 7
ADDENDUM
"An Ounce o£ Prevention
, A trend in policy pronouncements from EPA Headquarters starting
in FY 1977/1978 appears to confirm the overriding concern of every
region that prevention is being accorded less and less importance in
national program goals. Since the beginning of the present fiscal
year (1978), the regions have been operating under national guidelines which
removed from the list of "Activity Indicators" any preventive actions.
Since these indicators are supposedly used by Washington to judge the
level of local program effectiveness, the future for increased pre-
vention resources looked bleak.
During the final half hour of CAI's visit to the third in-depth
study Region, we were presented with a copy of the Planning and Budget
Guidance for FY 1979/1980, dated March 1978, which had been received
in the Region earlier that day. Page 174 of this document includes
the following paragraph:
"Although some Regional comments recommended
a higher priority be given to the spill
prevention program, political realities and
public concern require that spill response
be of the highest priority, and given the
resource levels during FY 1979, the oil
spill prevention compliance inspections must
be given a lower priority. Inspections will
be limited to those non-transportation
related facilities where an EPA directed
removal action or on-scene monitoring action
was required."
The document continues (p. 175) to state:
"When the EPA Regional Office receives notice
that a severe oil or hazardous substance has
spilled into the waters. . . . , it is
essential that the Region provide an OSC to
monitor tte removal/mitigation actions..."
and (p. 176):
"Whenever a Regional On-Scene Coordinator (OSC)
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either directs or monitors the removal/
mitigation actions at a spill from a non-
transportation related facility, a concurrent
inspection of that facility's Spill Prevention
Control and Countermeasure Plan will be con-
ducted."
There is an implication in these paragraphs which confirms
regional fears, namely that preventive activity will be drastically
curtailed, permitting compliance inspections only after serious
spills have occurred. We have seen photographs of facilities which
were not in compliance and, while they may have represented the worst
of the worst, it did not require engineering experience to accept
visual evidence that corrosion on tanks, leakages from barrels and
absence of diking near storage tanks on the flowpath to a waterway
would certainly lead to eruptions and discharges in the near future.
Only a preventive program could avert such occurrences.
There is no indication that additional resources will be provided
for prevention activities. It is now time, we believe, that the
Enforcement Office and the Oil and Special Materials Control Office
join forces in Washington, just as they have in successful field
operations, to bring to the attention of policy-makers and the public at
large that the "ounce of prevention" is worth more than the resources
required to remove the pounds of pollutants that will undoubtedly be
spewed into the environment if prevention measures are deemphasized.
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BIBLIOGRAPHY
1. Beyaert, Bruce, "Analysis of Oil Spill Accidents for Environmental
Impact Statements." Marine Technology, October 1974. pp. 365-382.
2. Biglane, K.E., "A History of Major Oil Spill Incidents." In:
Proceedings of Joint Conference on Prevention and Control of Oil
Spills. New York, New York, 1969. pp. 5-6.
3. Charlton, Thomas J., "Spill Prevention: The SPCC Approach." In:
Proceedings of Joint Conference on Prevention and Control of Oil
Spills. San Francisco, California, 1975. pp. 187-188.
4. Devanney, J.W. and Robert J. Stewart, "Bayesian .Analysis of Oil
Spill Statistics." Research paper, 1974.
3. Folger, Frank C., "Prevention - The Best Method of Controlling
Pollution." In: Proceedings of Joint Conference on Prevention and
Control of Oil Spills. Washington, D.C., 1973. pp. 65-68.
6. Hemmen, G.H., "Prevention is Best." In: Proceedings of Joint
Conference on Prevention and Control of Oil Spills. Washington, D.C.,
1973. pp. 69-72.
7. Hyland, John R., "Federal Research and Development Program for
Oil Spills." In: Proceedings of Joint Conference on Prevention and
Control of Oil Spills. New York, New York, 1969. pp. 15-22.
8. Leotta, J., "The U.S. Coast Guard's Pollution Incident Reporting
System, Its Use in Program Management." In: Proceedings of Joint
Conference on Prevention and Control of Oil Spills. San Francisco,
California, 1975. pp. 201-204.
9. Silberman, Henry and Elwin C. Weber, "Maryland's Experience in Oil
Spill Prevention and Control." In: Proceedings of Joint Conference
on Prevention and Control of Oil Spills. San Francisco, California,
1975. pp. 51-58.
10. Snyder, Harold J., "Federal Regulatory Control of Oil Spill Removal
Methods." In: Proceedings of Joint Conference on Prevention and
Control of Oil Spills. San Francisco, California, 1975. pp. 35-38.
11. U.S. Congress, "An Act to Amend the Federal Water Pollution Control
Act" (P.L. 92-500), October 19, 1972.
12. U.S. Department of Interior, "Mineral Industry Surveys." Bureau of
Mines: 1974, 1975, 1976, 1977.
13. U.S. Department of Interior, "Fuels and Energy Data: U.S. by States
and Census Divisions, 1973, 1974, 1975." Bureau of Mines Circulars:
8722, 1976; 8739, 1977; unpublished, 1978.
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14. U.S. Department of Interior, "Historical Fuels and Energy
Consumption Data, 1960-72, United States by States and Census
Districts East of the Mississippi." Bureau of Mines Circular
8704, 1976.
15. U.S. Department of Transportation, "Marine Environmental
Protection Program - An Analysis of Mission Performance." U.S.
Coast Guard, 1977.
16. U.S. Department of Transportation, "Marine Environmental Protection
Program - Measures of Program Effectiveness." U.S. Coast Guard, 1976.
17. U.S. Department of Transportation, "Polluting Incidents In and
Around U.S. Waters." U.S. Coast Guard, 1971, 1972, 1973, 1974, 1975.
18. U.S. Department of Transportation, "Spill Risk Analysis Program:
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Reporting System." U.S. Coast Guard, 1977.
19. U.S. Department of Transportation, "Spill Risk Analysis Program:
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20. U.S. Department of Transportation, "Pollution Incident Reporting
System." U.S. Coast Guard, 1976.
21. U.S. Environmental Protection Agency, "Inland Oil Spills." Kansas
City, Missouri (Region VII), 1976.
22. U.S. Environmental Protection Agency, "Information on SPCC Plans."
Kansas City, Missouri (Region VII), 1976.
22. U.S. Environmental Protection Agency, "Planning and Budget Guidance
for FY 1979/1980." Washington, D.C., March 1978 (draft).
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March 1975.
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27. U.S. Environmental Protection Agency, "User's Manual for the Spill
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Congress, 1973, 1974.
29. U.S. Federal Register, "Council on Environmental Quality: National
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Amendments." Senate Committee on Environment and Public Works,
1977.
33. Van Cleave, Henry D., "Spill Prevention - Phase II." In:
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Pipeline System." In: Proceedings of Joint Conference on Prevention
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Trends, 1976." Report to the Council on Environmental Quality, 1976.
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APPENDIX A
TABLES
-------
TABI.E 1 TOTAL NUMBER OF SPILLS BY REGION AND YEAR (1973-1976)
YliAl! > OF SCI LIS REGION
REGION
II
REGION
III
RECIO.:
IV
REGION
V
REGION RliGlON REGION
VI VII VIII
REGION
IX
REGION ALL
X REGIONS
1977 t) or SPILLS (547) (1048) (H26) (1716) (1517) (3771) (192) (136) (1434)
1976 I OF SPILLS 018 989 1422 1612 1440 3888 184 126 1581
(983) (12,769)
1266 13,126
Iii7? « or SPTLIS 523 1431 1523 1269 1013 3385 149 53 1593 906 11,895
1974 0 or SI'1 LIS 601 1672
1666
1216 901 3766 177 78 1916 1258 13,251
1973 » 0I: SPILLS 665 1363
1515
1062 859 3619 134
34 1887 1472 12,610
All 4 0I-1 SI'II.LS 2107
YEARS
5505
ol 26
5159 4213 14658 644 291 6977 4902 S3,802
Correlation -.479
Coefficient
.589
.541 -.947 .901 .254 .670 -.814 -.880 -.533 .090
'1977 Values were predicted from regression analysis model.
TREND » OF REGIONS REGIONS
Decreasing S I, II, 111, IX, X
Not Decreasing 5 IV, V, VI, VII, VIII
Generally Upward All (legions
No signit'iKinf- r at 0.95 level
-------
TABLE 2 TOTAL SPILL VOLUME BY REGION AND YEAR (IN THOUSAND GALI.ONS OF OIL)
YEAR I OF GAI.S REGION REGION REGION REGION REGION REGION REGION REGION REGION REGION ALL
I II III IV V VI VII VIII IX X REGIONS
11)77* I OF GALS (115) (328) (1,465) (6,847) (23,980) (2,471) (0) (405) (0) (0) (33,879)
1976 I OP GALS 218 1,093 908 6,068 22,365 3,073 467 280 1,526 273 36,272
1975 I OF GALS 341 1,868 2,131 3,462 4,241 3,462 169 462 560 441 18,557
1974 » OF GALS 365 4,825 608 1,534 1,130 10,067 403 164 1,243 293 20,632
1973 I OF GALS 548 3,399 1,018 1,904 1,012 4,658 2,292 138 6,596 1,778 23,343
ALL » OF GALS 1,472 11,184 4,665 12,967 28,748 22,679 3,331 1,045 9,926 2,786 98,804
YEARS
r Correlation -.961*' -.769 .231 .903 .848 -.454 -.751 .665 .740 -.778 .595
Coefficient
* 1977 Valuer Mere predicted from regression unulysis modol.
TREND » OF RECIONS REGIONS
Decreasing 6 1, 11, VI, VII, IX, X
Not Decreusing 4 III, IV, VI, VIII
Generally ll|>w;iril All regions
" Significant r ut 0.95 level (Region I)
-------
TABLU l AVERAGE VOLUME SPILLED BY REGION AND YEAR (IN GALLONS OF OIL)
YEAR
VOLUME REGION
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION ALL
X REGIONS
I97u
VOLUME 353
1105
639 3764 15,531 790
2537
2224 965 216 2763
1975
VOLUME 651
1261
1399 2728
4,187 1442
1134
8724 352 487 1560
1974
VOLUME 608
2885
365 1261
1,254 2673
2276
2101 649 233
1557
1973
VOLUME 824
2493
672 1792
1,177 1287 17,105 4067 3495 1208
1851
ALL
YEARS
VOLUME 611
2031
761 2513 6,823 1548
5.172
3571 1422 568 1680
-------
TABLE 4 TOTAL NUMBER OF TRANSPORTAT I ON Rlil-ATIil) SIMI.LS BY REGION AND YEAR (1973-1976)
YIAII
1977*
1976
I Or SPILLS REGION
I
» 01- SPILLS
9 Ol' SIM LIS
(234)
248
RliGION REGION RliGION REGION RliGION RliGION REGION RliGION REGION ALL
II III IV V VI VII VIII IX X REGIONS
(410) (564) (839) (654) (1571) (94) (77) (545) (431) (5415)
181 537 774 611 1395 95 71 717 537 5366
1975 I OF SPILLS 251
617
632
6S8
431
1352
85
32
700
370 5128
1974 I OP SPILLS 282
704
686
648
443
1273
121
47
959
445 5608
1973 I OF SPILLS 280
560
579
529
345
1001
87
21
1045
583 5030
ALL
YliAKS « OF SPILLS 1061
r Correlation -.899
Coefficient
2262
-.590
2434
-.359
2609
.961*
* 1977 Values were predicted from regression analysis.
TREND
1830
.912
I OF REGIONS
Decreasing 6
Not" Decreasing 4
Generally Upward All regions
5021
.920
388
-.093
171
.805
REGIONS
Ij II. Ill, VII, IX, X
iv; v. vi, viii
" Significant r at 0.95 level (Region IV)
3421
-.927
1935 21132
-.289 .264
-------
TABU: s TOTAL NUMBER OF NON-TRANSPORTATION RELATED SPILLS BY REGION AND YEAR (1973-1976)
YliAR S OK SPILIS REGION REGION
I II
I977. fl OF SPILLS (80) (230)
1976 » OF SPILLS 97 204
1975 a OF SPILLS 90 312
1974 » OF SPILLS 123 280
1973 S OF SPILLS 124 261
ALL
YEARS a OF SPILLS 434 1057
I' Correlation -.838 -.400
Coefficient
REGION REGION REGION REGION
III IV V VI
(436) (170) (409) (10S1)
405 155 407 1330
398 137 283 1118
314 108 225 1674
337 108 280 1677
1454 508 U!>!'» 5799
.827 .949 .737 -.751
REGION REGION REGION REGION ALL
VII VIII IX X REGIONS
(50) (SO) (101) ( 41) (2615)
48 45 109 102 2902
38 20 125 97 2618
22 29 102 129 3006
34 11 142 219 3193
142 105 478 547 11719
.696 .828 -.5S0 -.873 -.678
1977 Values were (iroJictcd from regression analysis model.
TREND 8 OF REGIONS REGIONS
Dec reusing 5 I, II , VI,IX, X
Not Decreasing 5 III, IV, V, VII, VIII
No significant r at 0.95 level (Region IV almost significant)
-------
TABU! 6 I'liRCr.hfl'ACn OP NON-TRANSPORTATION ItliLATUD SIMI.I.S AS I'EKCIiNTAGI: OI; (TRANSPORTATION ~ NON-TRANSPORTATION) SPILLS
PliRCNT
YI:AR RATIO REGION REGION REGION REGION REGION REGION RUCTION REGION REGION REGION TOTAL
I II III IV V VI VII VIII IX X
l!>76 t RATIO 28.11 34.87 42.99 16.68 39.98 48.80 33.57 38.79 13.20 IS.96 3S.10
1975 % RATIO 26.39 33.58 38.64 17.23 39.63 45.26 30.89 38.46 15.15 20.77 33.80
1974 \ RATIO 3(1.37 28.45 21.40 14.28 33.68 56.80 15.38 38.16 9.61 22.47 34.90
1973 * RATIO 30.69 31.79 36.79 16.95 44.80 62.62 28.10 34.47 11.96 27.31 38.83
TOTAI. 1 RATIO 29.03 31.85 37.40 16.30 39.SO 53.59 26.79 38.04 12.30 22.04 35.6",
-------
TABLE 7 TOTAL VOLUME OF TRANSPORTATION RELATED SPILLS RV REGION AND YEAR (IN THOUSAND GALLONS OF OIL)
YEAR VOLUME
REGION
I
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
ALL
REGIONS
1977*
1976
VOLUME
VOLUME
(0) (98) (1406) (1175) (13,388) (1.711) (420) (326) (1,276) (0) (19,298)
40 704 800 379 13,199 2,425 432 157 1,258 91 19,486
1975 VOLUME
139 1,560
1,794 3,292
862 1,817
144
430
291 420 10,749
1974 VOLUME
231 3,676
370 1,166
774 8,417
364
131 1,054 93 16,276
1973 VOLUME
247 2,772
582 1,701
484 3,245
169
92
255 1,578 11,125
ALL VOLUME
YEARS
658 8,713
3,545 6,539 15,320 15,904
1,109
809
2,858 2,182
57,636
(.'or re la lion
Coefficient
-.964 -.820
.426
.193
* 1977 Values were predicted from regression analysis model.
.790 -.388
.515
.414
.Sol -.756
.598
THEN!)
Dec reusing
Not Decreasing
All regions - Generally Upward
0 01- REGIONS
REGIONS
5 I . II. IV. VI, X
5 111, V, VII, VIII, IX
"Significant r ut 0.95 level (Region I)
-------
TABU! 8. TOTAL VOI.UM: OK NON - TRANSWGRTAT I ON KEIJVTED SPILLS BY REGION AND YliAK (IN THOUSAND GALLONS OP OIL)
YEAR
VOLUME
RUGIOH
I
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
ALL
REGIONS
1977*
1970
1975
1974
1973
VOIJIME
VOMJME
VOLUME
VOLUME
VOLUME
ALL VOLUME
YEARS
(113)
168
182
125
293
767
(220)
380
255
980
576
2192
(32)
76
320
187
408
992
(5660)
5670
(10542) (1601) (-1013)
136
371
156
6339
9088
3349
333
442
13,206
616
3009
1375
1040
6037
36
22
38
2120
2213
(109)
120
32
II
39
203
(250)
245
129
179
120
673
(Ml)
178
14
107
88
385
(17,654)
16,575
7.443
3,705
5,284
33.00S
Correlation -.S74
Coefficient
-.535
-.762
.772
1977 Vuluos were predicted from regression analysis aiudcl.
TREND
Decreasing
Not Dec reusing
Generally Upward
.911
.045
I 0I: REGIONS
4
6
All regions
No sign! ficunt r's lit 0.95 level.
.775
.634
HEG10NS
1, II .III, VII
IV, V. VI. VIII. IX, X
.731
.339
.843
-------
TABLE 9 PERCENT NON-TRANSPORTATION RELATED SPILL VOLUME BY REGION AND YEAR (1973-1976)
YEAH PERCNT
REGION
I
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
ALL
REGIONS
1976 PERCNT 80.42
35.08
8.71
93.73 40.78
3.73
7.20
43.49
16.32 65.91
39.54
1975 PEKCNT 56.57 14.05 15.16
4.04
73.50 62.33
13.16
6.97
30.68 3.29
28.57
1974 PI:RCNT 35.11 21.05 33.60
24.12 30.07
14.04
9.47
7.87
14.48 53.34
24.31
1973 PERCNT 54.19
17.21
41.25
84.21
47.68
24.28 92.63
29.90
32.08
5.30
42.87
ALL
YEARS
PEKCNT 53.80 20.10 21.86
49.22 46.29 27.51 66.62
20.06
19.05
14.98
36.41
-------
TABLE 10 AVERAGE VOI.IIME OF TRANSPORTATION RELATED SI' 1 tl-S DY REGION AND YEAR (IN GALIANS OF Oil.)
YEAR VOI.UMI!
REGION
1
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
IliGlON
VIII
REGION
IX
REGION
X
ALL
REGIONS
1977* VOLUME
(I)
(637)
(2406) (1384) (21,899) ( 791 ) (4431) ( 6733) ( 1840) (0) (3573)
1976 VOI.IIME
165
1848
1489
490
21.601
1739
4551
2204
1754
169 3631
1975 VOLUME
555
2529
2838
5003
2,000 1344
1699 13,427
416
1131 2096
1974 VOLUME
818
5221
539
1707
1,748 6612
3007
2,792
1009
209 2902
1973 VOLUME
883
4951
1004
3216
1,404
3241
1939
4.369
244
2707 2212
ALL
YEARS VOLUME
620
3851
1456
2506
8,372 2858
2858
4.731
835
1128 2727
r Correlation
Coefficient
-. 957**
-.912
.488
-.323
.790
-.527
.649
.102
.719
-.727 .628
* 1977 Values predicted from regression analysis model.
p>
t
I—¦
o
t OF REGIONS
5
5
TREND
Decreasing
Not Decreasing
Generally Upward All regions
'* Significant r at 0.95 level (Region I)
REGIONS
irii, iv. vi, x
111, V, VII, VIII, IX
-------
TABU- 11 AVERAGE VOUIHC OK NON-TKANSHORTATION RELATED SflLLS (IN GALLONS OF OIL)
YEAR
VOI.UMli
REGION
I
REGION
II
KECION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION REGION ALL
IX X REGIONS
1977
VOI.UMH (1S59)
(1170)
(0)
( 36,362) (27,449) ( 1498)
(0)
( 1702)
(1943) ( 1595) ( 6305 )
1976
VOLUME
1730
1865
188
36,580 22,329
463
699
2676
2251
1723
5711
I97S
VOLUME 2018
818
805
1,012 11,816
2689
576
1610
230
147
2843
1974
VOLUME 1015
3500
595
3,434 1,480
821
1.731
386
1750
826
1232
1973
ALL
YEARS
VOLUME 2360
VOLUME
Correlar ion
Cocffi ci ent
1767
.200
2208
2074
-.433
1212
689
-.866
1,449 1,557
12,478 11,051
.767
.942
620
1041
.174
62,351
15,584
-.524
3559
1933
-.134
847
1408
.384
403
703
.613
165S
2816
.881
* 1977 Values were predicted from regression analysis model.
TREND
S 01 REGIONS
Decreusing 5
Not Decreasing 5
Generally Upward All regions
REGIONS
I, II, III, VII, VI11
IV, V, VI, JX, X
No significant r's at 0.95 level (Region V almost significant)
-------
TABU: 12 TOTAL NUMBER OF MINOR NON-TRANSPORTATION RELATE!) SI'ILLS BY REGION AND YEAR (1973-1975)
YEAR
1977*
1976
» or SI'ILLS
I OF SI'ILLS
> OF SPILLS
REGION
I
(76)
88
REGION
II
(204)
181
REGION
III
(414)
389
REGION
IV
(137)
125
REGION
V
(332)
342
REGION
VI
(989)
1283
REGION
VII
(45)
42
REGION
VIII
(30)
25
REGION
IX
(87)
97
REGION
X
(34)
93
TOTAL
(2345)
2665
1975
I OF SPILLS 75
272
359
115
231
1055
32
14
110
93
2356
1974
I OF SI'ILLS 106
239
284
79
189
1523
13
27
92
122
2674
1973
I OF SPILLS 100
227
310
91
251
1644
26
130
212
2996
TOTAL ? OF SPILLS 369 919 1342 410 1013 5505 113 71 429 520 10691
r Correlation -.630 -.360 .851 .841 .630 -.766 .714 .592 -.617 -.884 -.64B
Coefficient
*1977 Values were predicted from regression analysis mudel.
TREND
I OF REGIONS
Decreasing 5
Not Decreasing 5
Generally llownwurd All regions
REGIONS
I, II, VI, IX. X
III, IV, V, VII, VIII
No significant r ut 0.95 level.
-------
TABLE 13 TOTAL NUMBER OF MODERATE NON-TRANSPORTATION RI-IATED SPILLS BY REGION AND YEAR (1973-1975)
YEAR
# OF SPILLS
REGION
I
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION REGION
IX x
TOTAL
1977*
a OF SPILLS
(3)
(24)
(26)
(27)
(SO)
(SI)
(7)
(H)
(13)
(5) (180)
1976
» OF SPILLS
18
19
23
37
10
11
143
1975
# OF SPILLS 14
35
33
20
51
11
221
1974
t OF SPILLS 13
33
27
22
32
124
271
1973
I OF SPILLS 21
24
20
13
23
24
147
TOTAL H 0I: SPILLS 54
110
99
78
96
236
24
30
35
20
782
Correlation -.926
Coefficient
-.260
.059
.802
-.098
.316
.742
.834
-.130
* 1977 Values were predicted from regression analysis model.
TREND 0 OF REGIONS
Decreasing 3
Not Decreasing 7
Generally Downward All regions
REGIONS
I. II. VI ..
III. IV. V. VII. VIII, IX. X
Significant r at 0.95 level.
-------
TABLE 14 TOTAL NUMULK OF MAJOK NON-TRANSPORTATION RlilATIil) SPILLS UY REGION AND YI!AR (1973-1975)
YEAR a OF SPILLS
1977* I OP SPILLS
REGION REGION
II
I
(2)
(3)
IlKtil ON REGION REGION ItliGION REGION REGION REGION
III IV V VI VII VIII IX
(4) (7) (14) (12) (0) (J) (1)
REGION TOTAL
X
(4)
(41)
1976 I OF SPILLS
II
II
45
1975 I 0I: SPILLS
II
12
42
1974 * OP SPILLS
1973 t OF SPILLS
10
28
10
57
50
TOTAL # OF SPILLS
11
28
16
17
31
61
13
194
Correlation
Coefficient
.308
-.949
-.240
.540
.752
-.197
.756
-.774
.756
-.591
* 1977 Values were predicted from regression analysis model.
TREND
* OF REGIONS
Decreasing 6
Not Decreasing 4
Generally Downward All regions
REC10NS
I, II. Ill, VI, VII. IX
IV, V. VIII, X
No significant r at 0.95 level (Region 11 utmost significant)
-------
TAItLE 15 TOTAL VOI.IIM1: OF MTNOH NON-TRANSI'ORTATION REIATEU SI'IILS BY REGION AND YEAR (IN HIOtlSAND GALS)
YEAR
VOLUME
REGION
I
RliGION
II
REGION
IM
KliCION
IV
KliCION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
TOTAL
1977* VOLUME ( 5326 ) ( 20,596) C5,62t| ( 13,704 ) (44,124 ) ( 45,411 ) ( 6196 ) ( 6664 ) ( 12,857 ) ( 5702) ( 186,108)
1976 VOLUME
6560
IS,749 20,146 7,997 39,377 49,181 4073
635b
9,471
5645 164,555
1975
VOLUME
8751
28,225 3b,774 17,043 28,014 61.34S
6226
1540
12,074 4502 204,494
1974 VOLUME 9957 20,269 20,310 11,116 15,609 90,729
2245
4907
6,757 4059 185,988
1973
VOLUME 11,219 18,532 25,826 5,630 18,521
68,886
1980
925
5,302
4388 161,209
TOTAL VOLUME 36,487 82,775 103,086 41,786 101,521 270,141
14,524
13,728
33,604 18,594 716,246
r Corre lilt ion -.988"
Coefficient
- . 009
- .010
.341
. 902
-.654
.674
.637
.768 .788
. 182
1977 Values were predicted from regression analysis model.
THEN!)
Dec reus iii)>
Not Decreasing
General 1/ ll|>hrar
-------
TABLE 16 TOTAL VOLUME OI: MODERATE N0N-TKANSP0KTAT10N KUI-ATF.D SI'II.I.S BY REGION AND YEAU (IN THOUSAND GALS)
YEAR
1977*
1976
VOI.Ifffl:
VOLUME
VOLUME
RliGION
1
(13)
21
RCGION
II
6B
REGION
III
57
REGION
IV
( 08) ( 77 ) ( 102 )
80
REGION
V
( 128)
REGION
VI
( >74 )
118
REGION
VII
30
IIEGION
VIII
( 31 ) (65)
70
REGION
IX
( 33)
36
REGION
X
18
TOTAL
(10 ( S83)
498
I97S
VOLIJMI!
SO
106
90
87
100
180
16
30
10
684
1974
VOLUME
43
113
100
80
101
432
24
30
15
944
l'J73
VOLUME
67
106
SI
44
76
69
IS
26
36
24
514
IOTAL
VOLUME
181
393
298
291
277
799
85
117
132
67
2640
Corrclutlon -.888
Coeffiuient
-.764
.043
.763
.848
-.084
.674
.641
-.507
. 192
IU77 Vulncs were predicted from regression analysis model.
TREND I OF REGIONS REGIONS
Decreasing 4 1, II, VI, X
Not Uocreasing 6 III, IV, V, VII, VIII. IX
Generally DownwurU All regions
No significant r's ut 0.95 level.
-------
TABLE 17 TOTAL VOLUME OF MAJOR NON-TRANSPORTATION RELATED SPILLS BY REGION AND YEAR (IN THOUSAND GALS)
YEAH VOLUME
REGION
I
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
TOTAL
11)77* VOLUME (94)
(131)
(0) ( SS46) (10,315) (1382)
(0)
(47)
(204)
(152) (16)
1976 VOLUME 140
297
5582
8,880 4S0
45
200
153
16
11*7 5 VOLUME 122
1974 VOLUME
72
1973 VOLUME 214
TOTAL VOLUME 548
121
847
453
193
70
331
35
274
107
3,217 2,765
217
347
851
12
902 2,103
1,718 594
5,998 12,661 4,968 2,115
16
13
074
87
147
79
513
0 6.556
88 2,578
60 4,609
301 29,490
Correlation -.377
Coefficient
.498
-.528
.767
.911
.070
.809
.691
.213 .830
* 1977 Values were predicted from regression analysis model.
THENI> B OI: REGIONS REGIONS
Decreasing 4 I,II,III, VII
Not Decreasing 6 IV, V. VI, VIII, IX, X
Generally Upward All regions
No significant r's at 0.95 level.
-------
TABLE 18 AVERAGE VOLUME OF MINOR NON - TKANSi'ORT AT I ON RELATED SI'ILLS BY REGION AND YliAR (IN GALS)
YEAR VOIJIMI: REGION REGION REGION
I II III
*
1977 VOLUME 78 98 62
1976 VOLUME 75 87 52
1975 VOLUME 117 104 102
1974 VOLUME 31 RS 72
1973 VOLUME 112 82 83
ALL
YEARS 99 90 77
r CORRELATION"-Of* .444 -.389
COEFFICIENT
* 1977 Viiliics were predicted from regression
/—»
(U
i
oo
REGION REGION REGION REGION '
IV V VI VII
107 139 46 157
64 115 38 97
148 121 58 195
141 83 60 173
62 74 42 76
102 100 49 129
.036 .895 163 .I'JO
lysis model.
TREND « OF REGIONS REGIONS
AVG
REGION REGION REGION A LI.
VIII IX X REGIONS
217 133 75 78
254 98 61 61
110 110 48 87
182 73 33 70
1(15 41 21 sa
193 7 . 3(» 67
.296 .882 .yj«j - .344
"Signi ficiint r ;it 0.95 level
Decreasing
Not Decreasing
3
7
I. Ill, VI
II. IV, V. VII, VIII, ix!*x
-------
TABLE }9 AVERAGi: VOLUME OF MODERATE NON-TRANSPORTATION RELATED SPILLS BY REGION AND YEAR (IN THOUSAND GALLONS)
YEAR
VOLUME
REGION REGION
( II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
ALL
REGIONS
1977
VOLUME (4.5)
(35)
(3)
(3.5)
(1.2) (3.5)
(4.5) (2.5)
(2)
(2)
(3.3)
1976
vouimi;
3.5
1975
VOLUME
3.1
1974
VOLUME
3.5
1973
VOI4IME
3.5
ALL
YEARS
VOLUME
3.4
3.6
3.0
3.7
2.9
3.4
3.5
3.9
3.8
3.4
3.4
CORRELATION
COEITICIENT
.894
-.866
.258
.405
-.4
-.894
-.632 -.258
p-
i
t—
VO
* 1977 Values were predicted front regression analysis model.
TREND
Decreusing
Not Decreasing
Generally Downward
8 01 REGIONS
4
6
All regions
No significant r ut 0.9S level.
REGIONS
V, VIII, IX, X
1, II, III, IV, VI, VII
-------
TABLE 20 AVERAGE VOLUME 01 MAJOR NON-TRANSPORTAT I ON REIAIED SriLLS BY REGION AND YEAR (IN GALLONS)
YEAR
VOLUME REGION REGION REGION REGION REGION ICG ION
I II III IV V VI
REGION
VII
REGION
VIII
REGION
IX
REGION ALL
X REGIONS
11)77 *
VOI.UME
(73)
(49)
(13)
(696)
(924)
(Ml)
(0)
(17)
(201)
(44) (167)
1976
VOLUME
47
59
700
807
41
15
200
SI
0.4
1975
VOLUME
122
24
33
18
292
230
16
22
156.4
1974
VOI.UME
18
106
23
92
72
30
12
35
30
45.0
1973
VOLUME
71
45
47
27
58
90
526
13
20
60
92.0
ALL
YEARS
VOLUME
50
CORRELATION .094
COEEPICIENT
61
-.148
37
-.581
353
.764
408
.910
81
.074
423
15
.786
40
.778
43
. 106
152.0
.564
* 1977 Values were predicted from regression analysis model.
TREND I OF REGIONS
Uecreuslng
Not Decreusing
REGIONS
II. III. VII, X
I. IV. V, VI, VIII. IX
No significant r nt 0.95 level.
-------
TABLE 21 TOTAL OIL SPILL POTENTIAL BY REGION AND YEAR (IN 101" GALLONS OF OIL)
B OF GALS REGION REGION REGION REGION REGION
I II III IV V
a OP GALS 1.89 3.19 2.79 4.04 4.93
« 01 GALS 1.59 2.68 2.34 3.40 4.14
« OF GA1.S 1.66 2.62 2.57 3.41 4.14
« OP OA IS 1.86 3.10 2.65 3.58 4.29
» OF CAI.S 1.87 3.13 2. SO 3.30 4.15
0 OF GALS 6.98 11.73 10.05 13.69 16.52
I'rojectcil 'lot;.Is
Does Not Include 1976 Projections
REGION REGION REGION REGION REGION ALL
VI VII VIII IX X REGIONS
3.95 1.38 0.66 2.88 0.86 26.8
3.32 1.16 0.72 2.42 0.72 22.5
3.41 1.14 0.69 2.34 0.72 22.9
3.45 1.20 0.72 2.52 0.76 24.1
3.10 1.15 0.70 2.30 0.66 22.8
13.29 4.65 2.84 9.54 2.87 92.3
-------
TAIU.I3 22 SI'ILL RATH IN GALI.ONS SI' 11.I.I.I) I'liH I1I01ISAND GALLONS liXI'OSHO (1973-1976)
YEAR RATI: REGION Rl.fi I ON K Ed I ON
I II III
REGION RUG I ON
IV V
REGION REGION REGION
VI VII VIII
AVC.
REGION REGION ALI.
IX X
AVG.
AM.
HliGIONS REG.
1977* UATl: (.008) (.031 ) (.034) (.174) (.494 ) ( .084 ) (-.055) (.056) (-.067) (-.055) (.121 ) (.125)
1076 RATE 0.012
0.034
0.033 0.150
0.454 0.078
0.034 0.033
0.053
0.032 0.120
0. 135
1975 RATE 0.021
0.070
0.039
0.101
0.102 0.147
0.14
0.064
0.023
0.061 0.064
0.082
1974 RATI: 0.022
0.171
0.024
0.045
0.027 0.295
0.035 0.023
0.053
0.040 0.073 0.090
1973 RATH. 0.029
0.077
0.038
0.053
0.023 0.135
0.192 0.019
0.262
0.234 0.062 0.102
r Correlation -.962
Coefficient
-.508
.922
.862
-1.445 -.772
.526
.768
-.790 .782
.504
1977 Vulues were predicted from regression Analysis model.
IttEND
Decrcasing
Not Decreasing
Generally Upward
a oL regions
6
4
All regions
"Significant r at 0.95 level
REGIONS
I". II, VI, VII, IX, X
III, IV, V, VIII
-------
TABLE 2S TOTAL NUMBER OP SPCC VIOLATIONS JJY REGION AND YEAR (1974-1U77)
YEAR TOTAL REGION REGION REGION REGION REGION REGION REGION REGION REGION
I
II
III
IV
VI
VII
VIII
IX
REGION ALL
X REGIONS
If 7 8, TOTAL (109)
1077**
1976
I97S
TOTAL 31
TOTAL 173
TOTAL
63
(194)
119
184
205
(3)
35
74
103
(162) (175)
153
150
488
102
156
92
(493)
385
219
78
(77)
32
102
95
(33) .(»60)
35
20
63
161
105
(24) (1819)
17 992
54
25
1,293
1.263
1974
TOTAL
17
34
132
10
13
25
241
ALL
YEARS
TOTAL
284
542
.393
212
- .996
I' CORRELATION .278
COI1IT IC1 liNT
* l-'roin Verb;>I information supplied by region.
** Incomplete D.itu.
**1978 Values were predicted from regression
anaIysis model.
923
-.207
TREND
360
.728
Decreasing
Not Decreasing
Generally Upward
685
.987
« OF REGIONS
All regions
~Significant r at 0.95 level.
242
.185
89
.490
356
.575
REGIONS
II , III* X
I. IV. V. VI*VII, VIII,
96
. 205
3,789
.789
-------
TABLE 24
TOTAL MIHHP.R SrcC ASSESSMENTS BY REGION AND YEAR (1974-1977)
YEAR
1978*
t OP ASS1TS KEG I ON REGION REGION REGION REGION REGION REGION REGION REGION REGION ALL
I OP ASS' TS
I
(184)
II
(194)
( 0 )
IV V
(162) ( 137)
VI VII
(319) ( 74)
VIII
IX
REGIONS
( 33) ( 142) ( 43) ( 112S)
1977
I OP ASS1 TS
33
119
153
85
290
32
35
79
14
753
1976
I 0I: ASS' TS
175
184
ISO
104
219
96
20
131
57
936
1975
I OP ASS'TS
62
205
488
58
34
95
95
12
920
1974
I OP ASS'TS
13
34
132
13
25
192
ALI.
YEARS
« OP ASS'TS
CORRELATION
COEPPICIRNT
383
.638
542
.393
923
-.207
* 1978 Vulues were predicted from regression analysis model.
247
.858
546
.893
236
.175
87
.477
311
83
.627 .450
3358
.629
TREND I OP REGIONS
REGIONS
IV
Decreasing I
Not Decreasing 8 I, II, VI, VI, VII, VIII, IX, X
Generally Upwird Ail regions
-------
TABLE 25 TOTAL AMOUNT OF SPCC ASSESSMENTS BY KEGION AND YEAR (1974-1977)
YEAR AMOUNT
REGION REGION
1 II
REGION REGION REGION REGION
III* IV V VI
REGION REGION REGION
VII VIII IX
REGION
X
ALL
REGIONS
1978*' AMOUNT ($293,062) ($12,050) (0) ( $191,710) ($189,117) ($1,555,S5fJ ( $154,632) ($79,700) ($256,976) ($152,175) ($3,137,300)
1977 AMOUNT $ 93,150 $205,500
$114,750 $137,500 $1,239,305 $ 9,707 $71,100 $148,700 $48,700 $2,068,212
1976 AMOUNT $404,450 $197,850
$112,500 $159,650 $ 636,100 $295,850 $36,950 $234,800 $229,650 $2,307,400
1975 AMOUNT $ 80,800 $491,850
$366,000 $ 71,150 $ 92,500 $211,900 $ 4.650 $226,750 $ 31,700 $1,577,300
1974 AMOUNT $ 4,625 $ 0
1973 AMOUNT $583,024 $894,800
COUKri-ATION
r COEFFICIENT -430 "•854
$ 99,000 $ 0
$ 3.600 $ 6,000 $19,750 $ 26,250
0 .043
* 1978 Viilnes were predicted from regression analysis model.
Until Unuvui luble TREND
Decreusing
Not Decreasing
$692,250 $368,300 $1,971,505 $523,457 $132,450 $636,500 $309,850
.842
.720
• 961k
» OF REGIONS
.084
REGIONS
.501
.170
II
I, IV. V, Vlt VII, VIII, IX, X
$ 169,225
$6,112,137
.867
~ Significant r ut 0.95 level.
-------
TABLE 26 AVERAGE AMOUNT OP SI'CC ASSESSMENTS BY REGION AND YEAR (1974-1977)
YEAR AMOUNT
REGION
I
REGION
II
REGION
III*
REGION REGION
IV " V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
ALL
REGIONS
1078* AMOUNT ($38111) ($1060)
( 0 ) ( $750) ( $1850) ($5125) ($4343) ( $2560) ( $153) ( $4353)
1977
1976
1975
1974
ALL
YEARS
AMOUNT
AMOUNT
AMOUNT
AMOUNT
AMOUNT
CORRELATION
COEFFICIENT
$2823 $1726
$2311
$ 3S6
$1522
.991*
$1075
$1303 $2399
$1650
-.508
$750
$750
$750
$750
$750
* No assessment data available
** Bused on uveruged totals supplied by Region
* 1978 Values were predicted from regression analysis model.
TREND
Decreasing
Not Decreasing
$1617 $4273
$1535 $2
-------
TABLE 27 TOTAL NUMBER OF SI'CC COLLECTIONS BY REGION AND YEAR (1974-1977)
YEAR TOTAL REGION REGION REGION
I II III
1978* TOTAL (40) (19) (62)
1977 TOIAL 48 40 43
1976 TOTAL 80 36 71
1975 TOTAL 76 69 28
1974 TOTAL 0 0 0
ALL TOTAL 204 145 142
YEARS
CORRECTION -.803 -.80S .204
r COEFFICIENT
REGION REGION REGION REGION
IV V VI VII
(136) (171) (112) ( 50 )
153 0 85 19
150 83 55 68
488 5S 6 43
132* 0 1 6
923 138 147 136
-.378 .983 .963 .302
REGION REGION REGION ALL
VIII IX X REGIONS
( 17 ) ( 56 ) (25) ( 405)
11 57 20 476
12 40 29 624
19 23 8 815
1 0 0 140
43 120 57 2055
.401 1645 .249 -.261
* Although 132 cut lections may have been made for 1974 violations,
il is unlikely that these were .ill actually made in 1974.
TREND » OF REGIONS REGIONS
Decreasing 3 I, II, IV
Not Decreasing 7 III, V, VI*. VII, VIII, IX, X
Generally Upwartl All regions
~Significant r at 0.95 level (Rogion V almost significant due to missing data.)
-------
TABU! 28 TOTAI. AMOUNT OF SPCC COLLECTIONS BY REGION ANI> YEAR (1974-1977)
YEAH
AMOUNT
REGION
I
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
A 1.1.
REGIONS
1978*
AMOUNT ( 24.190) (19,722) ( 52,425) (23,300) ( 27,550) ( 35,052) ( 25,863) ( 7575) ( 66,913) (20,025) (345,864
1977 * AMOUNT 23,235 37,850 33,000 22,950 25,738 28,550
9,985 67S0
37,600 15,550 218,520
1976 AMOUNT 17,400 20,175 38,850 22,500 34,075 33,500
33,405 2050
58,625 8,950 278,530
1975
AMOUNT
8,430 53,675 11,500 73,200 26,825 10,100
15,300 4925
17,750
5,250 226,850
1974
AMOUNT
21,800
1.650
400
23,850
ALL AMOUNT 49.065 120,700 83.350 138.450
YEARS
1- CORRELATION .946
COEFFICIENT
-.242
.896
-.240
60,900
.202
72,150
. 466
60,340 14,125
.414
.734
113,975 29,750 718,955
.785
.994
.733
* Incomplete l»nta
** 1978 Viilncs were predicted from regression analysis model.
treni>
Dec ren s i ng
Not Decreasing
I OF REGIONS
2
8
REGIONS
II, IV
I, III, V, VI, VII, VIII, IX, X1
• Signi f lciint r at 0.95 level (Region I almost significant).
-------
TABLE 29 AVERAGE AMOUNT OF SPCC COLLECTION BY REGION AND YEAR (1974-1977)
YEAR
AMOUNT
REGION
1
REGION
II
REGION
III
REGION
IV*
REGION
V
REGION
VI
IEG10N
VII
REGION
VIII
REGION
IX
REGION ALL
X REGIONS
1978*
AMOUNT ($415) ( $1351) ( $1041) ( $150) ( $ 914) ( $ 641) ( $633) ( $ 617) ($ 1393) ( $ 930) ( $ 597)
1977 AMOUNT $306
$ 946 $ 767
$150
$ 709
$336
$525
$ 660 $ 660
$ 775 $ 459
1976 AMOUNT $218
1975 AMOUNT $176
1974 AMOUNT
$810
$778
0
$547
$410
$150
$150
$150
$ 410
0
$610
$ 487 $1,183
0
$491
$355
$275
$ 171
$ 258
$1,465
$ 259 $ 772
0
$ 309
$ 655
$ 446
$ 278
$ 170
ALL
YEARS
AMOUNT $240 $832 $587 $150 $ 441
CORRELATION .964 .865 .975 0 .783
COEFFICIENT
* Based on averaged totals supplied by Region.
** 1978 Values were predicted from regression analysis model.
TREND I OF REGIONS
Decreasing
Not Decreasing
+ Significant r ut 0.95 level
p
tvj
<0
$ 491
-. 012
$444
.978
REGIONS
VI
$ 328
.658
$ 950
.575
it II. Ill* IV, V, VII, Vint IX, X
$ 522
.728
$ 350
.960
-------
TABLE 30 PROI'OSIil) SI'I LI. IT.NALTIP.S BY YEAR AND KI1CION (IN THOUSANDS)
Y lift It
1977*
1976
I97S
1974
1973
ALL
YHARS
AlkMJ'fr
AMOUNT
AMOUNT
AMOUNT
REGION REGION
I
AMOUNT ($162)
AMOUNT $197
$188
CORRELATION -.486
COEFFICIENT
II
($0)
AMOUNT $157 $ ISO
$ 352
$171 $ S89
$ 715
$713 $ 1806
-.993*
REGION REGION
III IV
$157
$271
$207
$308
$944
-.749
$198
$288
$413
$325
$1223
-.733
TEGION
V
$251
$195
$279
$464
$1189
- .801
REGION
VI
$595
$793
$878
$551
$2816
.039
KEG101
VII
($139) ($180) ($117) ($716) ($42)
$44.
$33
$37
$37
$151
.480
K EC I ON RliGION RliGION ALL
VIII IX X REGIONS
( $36) ($0)
$25
$34
$13
.567
$115
$129
$30 $474
$893
($79) ($1167)
$133 $1824
$57
$100
$16S
-.943 -.388
$2349
$3178
$3660
$102 $1610 $455 $11,012
-.995
1977 Values were predicted from regression analysis model.
TREND
Decreasing
Not Decreasing
~Generally Downward
I OP REGIONS
7
3
REGIONS
I, II*. III. IV, VI, IX, X
VI, VII, VIU
* Significant r ut 0.95 level
-------
TABLE 31 COLIJiCTED SPILL PENALTIES BY YEAR AND REGION (IN THOUSANDS)
YEAR
1977*
1 976
197S
11)74
1973
ALL
YEARS
AMOUNT
AMOUNT
AMOUNT
AMOUNT
AMOUNT
AMOUNT
AMOUNT
r C0RR1II.AT10N
COEITIUENT
REGION
I
($60)
$75
$102
$100
$132
$408
. 935
REGION
II
(0)
$62
$151
$283
$360
$8SS
-. 995
REGION
III
(106)
$105
$173
$132
$173
$583
-.613
REGION
IV
(130)
$134
$188
$183
$197
$702
-.840
REGION
V
REGION
VI
* 1977 Vulucs were predicted from regression anal/sis model.
SUMMARY
(142) (431)
$159
$136
$104
$170
Decreasing
Not Decreasing
Gcnerully Downward
$377
$528
$538
$421
$569 $1863
-.004 -.231
REGION
VII
(40)
$38
$31
$30
$27
$126
.943
I OI; REGIONS
8
2
REGION
VIII
(19)
$13
$21
$18
$ 9
$62
.364
REGION
IX
(40)
$87
$115
$160
$209
$571
-.993
REGION ALL
X REGIONS
All regions
* Significant l ut 0.95 level.
REGIONS
I. 1I + , III. IV. V, VI. IX+.X
VII. VIII
(68)
$96
$37
$62
$93
$288
-.074
(1000)
$1156
$1480
$1609
$1792
$6027
-.981 +
-------
TABLE 32 PERCENTAGE AMOUNTS OP SPII.I. PENALTIES COLLECTED
YEAR
PERCENTAGE
REGION
r
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION ALL
X REGIONS
1976
PERCENTAGE
48
41
67
68
63
63
86
52
76
72
63
1975
PERCENTAGE 52
43
64
65
70
67
94
62
89
65
63
1974
PERCENTAGE 58
43
64
44
37
61
81
60
31
62
51
1973
PERCENTAGE 70
50
56
61
37
76
73
69
23
S6
49
ALL
YEARS
PERCENTAGE
57
47
62
57
48
66
83
61
35
63
55
-------
TABI.E 33 PERCENTAGE AMOUNTS OF ASSESSED SPCC PENALTIES COI.1JECTED
YEAH
PERCENTAGE
REGION
I
REGION
II
REGION
III *
REGION
IV
REGION
V
REGION
VI
'MEG I ON
VII
REGION
VIII
REGION
IX
REGION ALL
X REGiONS
1977
PERCENTAGE
34.94
18.42
20
18.72
2.30
102.86
9.49
25.28
32.06 10.56
11)70
PERCENTAGE
4.30
10.20
20
21 .34
5.27
II .29
5.55
24.97
3.90 12.07
1
-------
TABU: 34 TOTAL NUfUER OF 311(b)(5) VIOIATIONS BY REGION AND YEAR
YEAR « OF VIOL. REGION REGION
I II
I977»" I OF VIOL. 0 0
1976 I OF VIOL. 1 0
1975 I OF VIOL. 0 0
1974 I OF VIOL. 2 I
1973 I OF VIOL. 2 1
ALL I OF VIOL.
YEARS 5 2
RF.GION REGION REGION REGION
III IV V VI
0 2 0 3"
0 4 0 0
1 4 9 2
0 30 S 1
3 20** S 13
4 60 19 19
REGION REGION REGION REGION
VII VIII IX X
4 0 0 0
5 0 0 0
13 0 10
16 0 6 0
22 1 10
60 I 8 0
* One Kcforrul includeJ 14 unreported spills.
" One ItcFcrrul included 3 unreported spills.
*** Incomplete Data.
ALL
REGIONS
9
10
30
61
68
178
-------
TAIil.D 35
YEAR DISPOSITION REGION REGION REGION
1 II III
liiJIWAI. CASES
(b)CASES PROS EC' I)
11)77 (c)CASES DISMISS.
(il) PENDING/UNKNWN
(u)TOTAI. CASES
(b)CASES PROSEC'D
1976 (c)CASES DISMISS.
(d)PENDING/UNKNWN
(u)TOTAL CASES
(b)CASES PROSEC'D
11)75 (c)CASUS DISMISS.
(U)PENDINQ/UNKNWN
(a)'IOTAI. CASES
(b)CASES PROSEC'D
11)74 (c)CASES DISMISS.
(U)PENDINC/ UNKNWN
ra) ltri'AI. CASES 2 1 3
(b)CASI:S PROSEC'D I - 1
l!)7; (c)CASES DISMISS. - - 1
(d)l'ENDING/ UNKNWN 1 1 1
* One Iteteiral included 14 unreported spills.
** One Referral included 3 imro|>orte(l spills.
DISPOSITION OF 311(b)(5) CASES BY REGION AND YEAR
REGION REGION REGION REGION REGION REGION
IV V VI VII VIII IX
REGION ALL
REGIONS
4
1
1
2
5
1
9
1
1
7
10
I
4
5
13
1
12
30
1
21
8
30
3
6
21
16
1
3
12
61
6
13
42
20*
7
4
9
22
I
12
9
68
13
26
29
-------
TAB 1.13 56 RATIO OP I OF SPCC VIOIATIONS TO NIIMMiR OP NON-TRANSPORTATION RELATED SPILLS
YEAR RATIO RI'.GION REGION REGION REGION REGION REGION REGION REGION REGION REGION MX
1 II III IV V VI VII VIII IX X REGIONS
1976 RATIO 1.78 0.90 0.18 0.96 0.38 0.16 2.12 0.44 1.48 0.53 0.44
1975 RATIO 0.70 0.66 0.26 3.56 0.32 0.07 2.50 0.45 0.84 0.26 0.48
1974 RATIO 0.14 0.12 o 1.22 0.04 0.01 0.59 0.86 0.06 0 0.08
AI.L RATIO o.82 0.53 0.15 1.91 0.28 0.07 1.94 0.57 0.81 0.24 0.32
YEARS
-------
TABLE 37 AVERAGE SI'CC ASSESSMENT PER GALLON OF AVERAGE SPILL VOLUME (1974-1976)
YEAR ASS'T REGION REGION REGION REGION REGION REGION REGION REGION REGION REGION ALL
I II III IV V VI VII VIII IX X REGIONS
1976 ASS'T $6.55 $5.25 $0,199 $0,099 $ 3.67 $1.21 $ 0.831 $ 1.86 $ 11.15 $0.89
1975 ASS'T $2.00 $5.62 $0,275 $0,293 $ 1.87 $1.97 $ 0.085 $ 6.78 $ 5.42 $1.09
1974 ASS'T $0,585 $0.59S $ 0.449 $0,202 $ 0.376 $ 8.09 $0.56
AM. ASS'T $2.49 $0.81 $0.30 $0.22 $ 2.33 $0.43 $ 0.42 $ 1.43 $ 6.S7 $1.08
YI-AUS
-------
TABLE 38 AMOUNT OF SPCC ASSESSMENTS PER NON-TRANSPORTATION RELATED SPILL BY REGION AND YEAR (1974-1976)
YEAR
AMOUNT REGION REGION
I II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
ALL
REGIONS
1976
AMOUNT 4169.59
967.89
725.81 392.21 478.27 6163.54 821.11
2154.13 2251.47
995.
1975
AMOUNT 897.78 1576.44
2671.53 251.11
82.74 5576.31 232.5
1814.00 326.80
602.
1974
AMOUNT 37.60
1009.26
2.15
272.73 681.03
257.35
56.
ALL
YEARS
AMOUNT 1580.
866.
1442.
252.
.77
4759.
649.
1452.
795.
157.
-------
TABLE 39 AVERAGE AMOUNT OR SPCC COLLECTION PER AVERAGE VOLUME OP NON-TRANSPORTATION RELATED SPILL
YEAR
AMOUNT REGION
I
REGION
II
REGION
III
REGION
IV
REGION
V
REGION
VI
REGION
VII
REGION
VIII
REGION
IX
REGION
X
ALL
REGIONS
1976 AMOUNT $0,176 $0,434 $2.91 $ 0,004 $0,018 $1.32 $ 0,702 $ 0,064 $ 0.6S1 $0,179 $0.07
1975 AMOUNT $0,087
1974 AMOUNT 0
$0,951
$ 0,509 $0,148
$0,041 $ 0,626 $0,616 $0,161 $3.36 $4.45
$ 0.044 $ 0.215
$ 0.159 $ 0.668
$0.09
$0.14
Ail.
YEARS
AMOUNT $0.14
$0.40
$ 0.8S $0.01
$0.04 $ 0.47 $ 0.03 $0.17
$0.67
$0.74 $ 0.12
-------
APPENDIX B
FIGURES
-------
NUMBER
OF
SPILLS
SPILL VOLUME
AVERAGE SPILL VOLUME
36xt03
-
36x106
-
)6xitr
-
30
-
30
-
30
-
24
-
24
-
24
-
IB
-
18
-
18
—
12
-
12
-
12
-
6x10 3
-
6x1$
-
6X103
-
1973 74 75 76 73 74 75 76 73 74 75 76
FIGURE 1 NATIONAL TOTAL OIL SPILL TRENDS BY YEAR
-------
Total Number of Spills by Region
Total Volume of Spills by Region
Average Volume of Spills by Region
6X105
mo-
a*
I
6X10'
1x10*
6X10
1)
10?
0
ro
a
UlR) R1 R /, R S Rfi R 7 PflR0 Fin Rj R? R1 R/. PI Rfi R7 Rfl R*1 RK1 Rl Ri Rl R /, RS Rfi R7 Rfl RH R1fl
-------
6X10
IX 103 -
CT*
I
C/J
R1 ft2 R3 Rt R5 R6 R7 RS R9 RIO R1 R2 R3 RA R5 R6 R7 R8 K9 RIO R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO:
FIGURE 3 . EPA REGIONAL TOTAL OIL SPILL TRENOS |9 74
FIGURE2 . EPA REGIONAL TOTAL OIL SPILL TRENDS 1973
-------
Total Numbers of Spills by Region
Total Volume of Spills by Hegioii
Average Volume of Spills by Region
6x 10
IX Id'
cr
6X10
1*10°
6*J0-
1*10
0
x
o
R| R2 R3 Rt R5 R6 R7 Rfl R9 RIO R| R2 R3 R4 R5 R6 R7 RO R9 RIO
i;i<;iii.s, iu7S
R1 R2 R3 Rt R5 R6 R7 Rtt R9 *10
-------
TOTAL NUMBER. OF SPILLS BY REGION
TOTAL VOLUME OF SPILLS BY REGION
AVERAGE VOLUME OF SPILLS BY REGION
6x103
IxlO3
cT
i
LO
6xltf
Ixllf
X
-------
36x10 -
6x10- -
1973 74 75 76
73 74 75 76
73 74 75 76
FIGURE 6 . NATIONAL TRANSPORTATION-RE LATEO OIL SPILL TRENDS BY YEAR
-------
a*
i
36x10'
30
24
18
12
6x103
NUMBER OF SPILLS
3 6 xlrf'
30
24
18
12
6x106
SPILL VOLUME
36x1(r
30
24
IB
1973 74 75 76
12
6x10'
AVERAGE SPILL VOLUME
73 74 75 76
73 74 75 76
FIGURE 7 HATIOIIAI IIOII- TRANSPORTATION RE I AT EU OIL SPILL TRENDS BY YEAR
-------
Number of Oil Spills by Region
Volume of Oil Spills by Ueftion
Average Volume of Spills by Region
6#1
-------
Number of Oil Spills by Region
Volume of Oil Spills by Region
Average Volume of'Spills :by Region
6x1 Q-5
1X10
or
i
to
6X10C
1x10®
0
(N
6X103
1x10*
Rl R2 R3 R4 R5 R6 R7 R8 R9 RIO Rl R2 R3 R4 R5 RB R7 R8 R9 RIO Rl R2 R3 R4 R5 R6 R7 R8 R9 RIO
l;l(^imi! !»• III'A ItlilHONM, TRANSPORTATION RI-I.ATIW Oil. SIM I.I. TRF.NDS, 1974
-------
Number of Oil Spills by Region
Volume of Oil Spills by Region
Average Volume of Spills by Region
6* IP
lxfO
6xl06
1x10'
6x10
1x10'
X
m
CO
' RI R2R3 R4 R5R6 R7 R8 R9 RIO R1 R2 R3 R4 R5 R6 R7 RB R9 RIO R1 R2 R3 R* R5 R6 R7 R0 R9 Rlfl
IKillltll 1 0 ¦ l:l'A IMiCIONM. TRANSPORTATION IM: I-ATI l> Oil. SIM I.I. TIM'NMS I"?--,
-------
tyuutber of Oil Spills by Region
Volume of Oil Spills by Region
Average Volume of Spills by Region
6*10
IX 103
X
6X106
IX 10'
0
CO
6X10'
1x103
2.
0
CO
o
X
G3
CO
N
R1 R? R3 R{ R5 R6 R7 R8 R9 RIO R1 R2 R3 R4 R5 R6 R7 Rfl R9 RIO Rl R2 R3 R4 R5 R6 R7 RB R9 RIO
ricumn . ita im-cicmai, transportation Ri-:i.ATi-n on, spn.i. tri-inds, i<>76
-------
Total Number of Spills by Region
Total Volume of Spills by Region
Averaue Volume of Spills by Ret?ion
6k103
U10J
i
i
6x10
W 10l
=c
£~
6X10-
IK 10
in
0
x
in
CO
N
CO
RI R2 R3 R4 ft5 R6 R7 Rft R9 RIO Rl R2 R3 R4 R5 R6 R7 RB R9 RIO Rl R2 R3 R* R5 R6 R7 R0 R9 RIO
HGURi 12 KPA RFGinNAl HON-TRANSPORTATION RELATED OIL SPILL TRENDS .1973
-------
Total Number of Spills by Region
Total Volume of Spills by Region
Average Volume of Spills by Region
6*10'
IX 10'
a"
I
Ol
6# 10
*
lxl oc
1—I
6X10'
3
lxio
r>-i
R1 R? f3 R< R5 R6 R7 80 R9 RIO Rl R2 R3 (4 R5 R6 R7 RB R9 R» R1 R2 R3 R4 R5 R6 R7 R8 R9 RlO
FIGURE 13 EPA REGIONAL HON - IRAN SPORTATION RELATED OIL SPILL TRENOS 19 74.
-------
Total Number of Spills by Region
Total Volume of Spills by Region
Average Volume of Spills by Region
X
6*10
1*10
^r4 1 I
6X10*
IX 10-
0
x
rs
x
Rl R2 R3 R( R5 R6 R7 Rfi R9 RIO R| R2 R3 U R5 R6 R7 R8 R9 RIO R] R2 R3 84 R5 R6 R7 R8 R9 RIO
FIGURE U EPA RFGIOIIAI NOH- TRANSPORTAIIOtl RELATED OIL SPILL 1REN0S . 197b
-------
TOTAL VOLUME OF SPILLS BV REGION
AVERA6E VOLUME OF SPILLS BY REGION
6x|03 -
1x10?
I
0
x
cn
6 xlO3
IxlO3
0
tn
CO
CO
0
X
cn
ro
(S
N
Rl R2 R3 RA R5 R6 R7 Rfl R9 RIO R1 R2 R3 R* R5 R6 R7 R9 R9 RIO R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO
Fl fillRF 1 5 FPA PFGIflNAI HON - T PANSPdRTAT I ON RFIATED OIL SPILL TRENDS .1976
-------
NUMBER OF SPILLS
SPILL VOLUME
AVERAGE SPILL
VOLUME
5x10 3
-
5x105
-
5x102
-
4
-
4
-
4
-
3
-
3
-
3
-
2
-
2
-
2
-
1x10 3
-
U105
-
IxlO2
-
1973 74 75 76 73 74 75 76 73 74 75 76
FIGURE 16 NATIONAL I01AI MINOR TRANSPORTATION RELATED Oil SPILL TRENDS BY YEAR
-------
cr*
i
NUMBER OF SPILLS
5xl02
IxlO2
5x10 6
IxlO6
SPILL VOLUME
5x103
1973 74 75 76
IxlO3
AVERAGE SPILL VOL UME
73 74 75 76
73 74 75 76
FIGURE 17. NATIONAL TOTAL MOOERATE TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR
-------
cr
i
5xl02
1x10
NUMBER OF SPILLS
5x|07
1x10'
SPILL VOLUME
5xH£
1x10'
AVERAGE SPIIL VOLUME
1973 74 75 76
73 74 75 76
73 74 75 7 6
FIGURE IB. NATIONAL TOTAL MAJOR TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR
-------
5x103 -
1 xlO3 -
cr
I
1973 74 75 76
73 74 75 76
73 % 75 76
FIGURE 19 NATIONAL TOTAL MINOR NOll-TR AH SFORTATI OH RELATED OIL SPILL TRENDS BY YEAR
-------
HUMBER
OF
SPILLS
SPILL VOLUME
AVERAGE
SPILL
VOLUME;
5x10?
-
5x10 6
5xlQ3
-
4
-
I
A
-
3
-
3
3
-
2
-
2
2
-
1x10?
-
1 x 10®
IxlO3
-
1973 74 75 76 73 74 75 76 73 % 75 76
FIGURE 20. IIATIOHAL TOTAL MODERATE NOII-TRANSPORTAIlOtf RELATED OIL SPILI TRENDS BY YEAR
-------
NUMBER OF SPILLS
5x»
1x10
CT*
I
5xt07
1X|07
SPILL VOLUME
5xl05
IxlQ5
1973 i 74 75 76
73 74 75 76
73 74 75 76
FIGURE 21. NATIONAL TOTAL NAJOR NON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR
-------
NUMBER OF SPILLS
5*10'
1x10*
SPILL VOLUME
5x10'
IxlO2
AVERAGE SPILL VOLUME
1973 74 75 76 73 74 75 76 73 74 75 76
FIGURE 22 MINOR HON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR, REGION 1
-------
cr
i
|SJ
Ol
5x10 -
IxlO2 -
SPILL VOLUME
5*10
IxlO2
AVERAGE SPILL VOLUME
1973 74 75 76
73 74 75 76
73 74 7 5 76
FIGURE 23 . MINOR HON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR RE6I0N 2
-------
SPILL VOLUME
AVERAGE SPILL VOLUME
5x10'
IxTO2
1973 74 75 76
73 74 75 76
73 74 75 76
FIGURE 24 . MINOR HON-TRANSPORTATION BELATED OIL SPILL TRENDS B| YEAR. REGION 3
-------
cr
i
In)
lh
HUHBER OF SPILLS
5x10 2
1x10'
5x|0*
IxlO4
SPILL VOLUHE
5x|0 2
IxlO2
AVERAGE SPILL VOLUME
1973 74 75 7 6
73 74 75 76
73 74 75 76
FIGURE 25. MINOR NON~ TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR .REGION 4
-------
NUMBER OF
SPILLS
SPILL
VOLUME
AVERAGE
SPILL
VOLUME
5xl02
-
5x10*
-
5X102
-
4
-
4
-
4
-
3
-
3
-
3
-
2
-
2
-
2
-
1x10?
-
Ik 10*
-
1x10*
-
073 74 75 76 73 74 75 76 73 74 75 76
ro
FIGUGE 26 . MINOR N0I| - TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR .REGION 5
-------
cr
i
ivj
•^1
NUMBER: OF 'SPILLS
5x103
1x10
5*)0'
IxlO5
SPILL VOLUME
5x10
1X10?
1973 74 75 76
73 74 75 76
7 3 7 4 75 7 6
FIGURE 27 . MINOR NON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR , REGION 6
-------
3
NUMBER OF
SPILLS
SPILL VOLUME
AVERAGE
SPILL VOLUME
5 k 103
0
5*102
o
(n
rs
4
(p
4
-
3
-
3
-
-
2
-
2
-
-
IxlO3
-
IxlO2
-
B73 H 75 76 73 74 75 76 73 74 75 76
FIGURE 28. MINOR HON-TRANSPORTATION RELATED OIL SPILL TRENOS BY YEAR REGION 7
-------
cr
i
IsJ
lO
HUHBER OF SPILLS
5x10
1x10
5x1Q3
1x10-
SPILL VOLUME
G
CO
S3
X
tO
rr>
to
5x10
1x10'
AVERAGE SPILL VOLUME
197 3 74 75 76
73 ; 74 75 ¦ 76
73 74 75 76
FIGURE 29. MINOR NON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR . REGION B
-------
cr
i
01
o
5xl02 -
IxlO2 -
1973 74 75 76
73 74 75 76
73 74 75 76
FIGURE 30. MINOR HON-IR AHSPOR TAT I0H RELATED OIL SPILL TRENDS BY YEAR, REGION 9
-------
CT
I
Ca»
NUMBER OF SPILLS
5x102
1 x 10-?
5*W
1x 103
SPIU VOLUME
M U 75 76
5X10
1x102
AVERAGE SPILL VOLUM
73 % 75 75
73 74 75 76
FIGURE 31 MINOR NON-TRANSPORTPORTAIION BELATED OIL SPILL TRENDS BY YEAR REGION 10
-------
NUMBER OF
SPILLS
SPILL VOLUME
AVERAGE
SPILL VOLUME
5x10
5x1Q4
0
5X103
4
-
A
-
C3
X
r-*
to
4
-
3
-
3
-
3
-
2
-
2
-
2
-
1x10
-
1x10*
-
IxlO3
-
1973 % 75 76 73 7t 75 76 73 74 75 76
FIGURE 32. MODERATE HOH - 1R AHSP OR TAT IOH RELATED OIL SPILL TRENDS BY .YEAR REGION 1
-------
(10
10
NUHPER Of SPILLS
SPILL
VOLUME
AVERAGE SPIL(.-
VOLUME
-
5x10$
-
5*10 3
-
-
4
-
4
-
-
3
-
3
-
-
I
-
2
-
-
IxlO5
-
IxlO3
-
1973 74 75 76 73 74 75 76 73 74 75 76
FIGURE 33^ MODERATE NON - TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR , REGION 2
-------
NUHBER OF SPILLS
SPILL VOLUME
AVERAGE SPILL , VOLUME
5x10
-
5x|05
5x1Q3
-
4
-
4
4
-
3
-
3
3
-
2
-
2
2
-
1x10
-
1x|05
—IxlO3
-
1973 74 75 76 73 74 75 76 73 74 75 76
V *
FIGURE 34 MODERATE NON~T RAIISPOR TAT 10 N RELATED OIL SPILL TRENDS BY YEAR, REGION 3
-------
o*
I
Ol
Ol
NUMBER OF SPILLS
5x10
1x10
5x101
IxlO3
SPILL VOLUME
5xiq;
IxlO3
1973 74 75 76
73 74 75 76
73 74 75 7 6
FIGURE 35 MODERATE NON-TR AHSPOR TAT I ON RELATED OIL SPILL TRENDS BY YEAR, REGION 4
-------
NUMBER
OF
SPILLS
SPILL
VOLUME
AVERAGE SPILL
VOLUME
5x10
-
5xl05
-
5x10 3
-
4
-
4
-
4
-
3
-
3
-
3
-
2
-
2
-
2
-
1x10
-
ixio5
-
IxlO3
-
1973 74 75 76 73 74 75 76 73 74 75 76
FIGURE 36 MODERATE NOtl-IRAHSPORTATIOII RELATED OIL SPILL TRENDS BIT YEAR, REGION 5
-------
o-
I
1/4
-J
NUMBER OF SPILLS
5xK)2
1x10?
5xl05
1x10'
SPILL VOLUME
5x10 -
1x10'
AVERA6E SPILL VOLUME
1973 74 75 76
73 74 75 76
73 74 75 76
FIGURE37 MODERATE HOH~ TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR REGION 6
-------
or
i
01
00
NUMBER OF SPILLS
5x10
1x10
5x#>4
1x10'
SPILL VOLUME
5x103
1xW;
1973 74 75 76
73 74 75 76
73 74 75 76
FIGURE 30 MODERATE HON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR, REGION 7
-------
NUMBER OF SPILLS
SPILL
VOLUME
AVERAGE SPILL
VOLUME
5x10
5xlOf
5x10 3
-
t,
-
X
m
cn
t£>
4
-
3
-
3
-
3
-
2
-
2
-
2
-
1x10
-
Ixlfl4
-
IxlO3
-
1973 74 75 76 73 74 75 76 73 74 75 76
lO
s /
FIGURE 39 MODERATE HOH TRAIISPORTATIOH RELATED OIL SPILL TRENDS BY YEAR, REGION 6
-------
NUMBER OF SPILLS
SPILL VOLUME
AVERAGE SPILL
VOLUME
5x10
-
5x10*
-
5xl03
-
4
-
4
-
4
-
3
-
3
-
3
-
2
-
2
-
2
-
1x10
1x10*
IxlO3
1973 n 75 76 73 74 75 76 73 74 75 76
o
FGURE 40 MODERATE HON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR, REGION 9
-------
cr
i
NUMBER OF SPILLS
5x10
1x10
WW
U10
SPILL VOLUME
5*103
IxlO3
1373 74 75 76
73 74 75 76
73 74 75 76
FIGURE 41 . MODERATE HON-TRANSPORTATION RELATED OIL SPILL TRENDS, BY YEAR , REGION 10
-------
1973 74 75 76 73 74 75 76 73 74 15 76
FIGURE 42 MAJOR IIOH~TR AN SPORTAT ION RELATED OIL SPILL IRE (IDS BY YEAR , RE6I0II I
-------
cr
i
NUMBER OF SPILLS
5x10
1x10
5X1Q3
1x10*
SPILL VOLUME
0
x
5x10
IxlO5
1973 74 75 76
73 74 75 76
73 74 75 76
FIGURE 43- MAJOR NOI|-TRANSPORTATION REt A TED OIL SPILL TRENDS BY YEAR, REGION 2
-------
HUHBER
OF
SPILLS
SPILL
VOLUME
AVERAGE SPILL
VOLUME
5x10
-
5*105
-
5x10*
-
4
-
4
-
4
-
3
-
3
-
3
-
2
-
2
-
2
-
U10
-
1x105
-
1x10*
-
1973 74 75 76 73 74 75 7 6 73 74 75 76
FIGURE 44. MAJOR l|Ot|-IRAHSPOR1ATIOII RELATED OIL SflLL TRENDS BY YEAR ,RE6I0II 3.
-------
NUMBER OF SPILLS
SPILL
VOLUME
| !
average; SPILL
VOLUME
5x10
-
5xl05
-
0
LO
O
X
rsi
CO
5xl05
-
0
in
52
X
Qr>
CD
4
4
in
4
(O
3
-
3
-
3
-
2
-
2
-
2
-
1x10
-
lxlO5
-
lxlO5
-
1973 74 75 76 73 74 75 76 73 74 75 76
cn
FIGURE 45. MAJOR tlOII-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR , REGION 4
-------
NUMBER OF SPILLS
SPILL VOLUME
AVERAGE
SPILL
VOLUME
5x10
5XVJ6
0
5x»5
U3
FIGURE 46 MAJOR HON-TRANSPORTATION RELATED OIL SPILL TRENDS BY YEAR .REGION 5
-------
O-
I
•^1
1x10 -
1973 Ik 75 76
73 74 75 76
73 U 75 76
FIGURE 47. MAJOR NON-TRASPORTATION RELATED OIL SPILL TRENDS BY YEAR , REGION 6
-------
o*
I
00
5x10
1x10
NUMBER
OF
SPILLS
SPILL VOLUME
AVERAGE
SPILL VOLUME
5xl05
0
5x105
in
o
s
4
fs
4
-
3
-
3
-
-
2
-
I
-
-
1x10 5
-
1x10®
-
1
1
1973 74 7 5 7 6 73 74 7 5 7 6 73 74 7 5 7 6
FIGURE 48. MAJOR HON" TRANSPORTATION RELATED OIL SPILL TRENDS B1 YEAR , REGION 7
-------
cr
i
NUMBER OF SPILLS
5x10
1x10
5*10*
2
1x10*
SPILL VOLUME
5x|0*
1x10*
AVERAGE SPILL VOLUME
1973 74 75 76
73 74 75 76
73 7 4 7 5 76
FIGURE 49. MAJOR NOJ|-TRANSPORTATIOII RELATED OIL SPILL TREIIDS BY YEAR .REGION 8
-------
SPILL VOLUME
AVERAGE SPILL VOLUME
5x105
IxtO5
1973 74 75 76
73 74 75 76
73 74 75 76
FIGURE 50 . MAJOR HON-TRANSPORTATION REL AT EO OIL SPILL TRENDS BY YEAR, REGION 9
-------
NUMBER
0F
SPILLS
SPILL
VOLUME
AVERAGE SPILL
VOLUME
-
5x105
—
5x10*
-
-
*
-
I
-
-
3
—
3
-
-
2
-
2
-
-
IxIQ5
-
1x10*
-
1973 % 75 76 73 7* 75 76 73 74 75 76
FIGURE 51. MAJOR NOH-TR ANSPORTA TION RELATED OIL SPILL TRENDS BY YEAR, REGION 10
-------
Total Number of Oil Spills by Region
6x10"
1* 10-
Total Volume of Spills by Region
6X10'
l*io-
Average Volume of Spills by Region
R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO R| R2 R3 R4 R5 R6 R7 RB R9 RIO Rl R2 R3 R4 R5 R6 R7 R8 R9 RIO
rnaiRI 52 . F:PA RP.flTONAI. TOTAI. MINOR NON-TRANSPORTATION RP.I.ATP.O OIL SPIU, TRI-NHS, 1973-1976
-------
Total Number of Oil Spills by Regior
6x10-
1* 10*
Total Volume of Spills by Region
£
in
o
on
o>
6x10
IV105
Average Volume of Spills by Region
81 R2 R3 R4 R5 R6 R7 RB R9 RIO R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO Rl R2 R3 R4 R5 R6 R7 R8 p9 RIO
nr;inti:53 ri'A rriionai. totai. modi-uaii-: non -trans i'ortatron ri:i.ati:i) on. sni.i, tri;ni>s, i973-n>76
-------
Total Number of Oil'Spills by Region
6* 10
1* 10
a*
I
VI
6x10
1X1#
Total Volume of Spills by Region
0
x
(CJ
(6
r>i
6x10"
1x10^
Average Volume of Spills by Region
R1 R2 R3 R< R5 R6 R7 R6 R9 RIO R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO R1 R2 R3 RA R5 R6 R7 R8 R9 RIO
FT(illRI: 54 . lll'A RF.fi TONAL TOTAL MA.JOH NON-TR^NSl'ORTATION RT. I.AI'I-O OIL SPTLL TRJ-NOS, 1973-1976
-------
TOTAL NUMBER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPILLS BV REGION
AVERA6E VOLUME OF OIL SPILES BY REGION
(}
(N
CD
-4"
iO
6x|0'
Ixtr
6x10'
Ixioi2
Rl R2 R3 R4 R5 R6 R7 R8 R9 RIO R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO Rl R2 R3 R4 R5 R6 R7 R0 R9 RIO
FIGURE 55 EPA REGIONAL TOTAL MINOR HON - TRANSPORTATION RE LATEO OIL SPILl TRENDS, 197 3
-------
6x10 2
5
I
3
2
1x102
O*
I
VI
cr»
TOTAL NUMBER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPILLS BY REGION
AVERAGE VOLUME OF OIL SPILLS BY REGION
o
X
m
fS
6x10'
lxH*
0
a
x
r».
o
6x10'
1x102
Rt R2 R3 R< R5 R6 R7 RB R9 RIO R1 R2 R3 RA R5 R6 R7 R0 R9 R|0 R1 R2 R3 R4 R5 R6 R7 RB R9 RIO
FIGURE 56 EPA REGIONAL TOTAL HINOR HOII - TRAIISPORTATjOH RELATED OIL SPILL TREIIOS, 1974
-------
TOTAL NUMBER OF OIL SPILLS BY REGION
0
x
in
in
6x10^
lxlQi
TOTAL VOLUME OF OIL SPILLS BY REGION
6x10'
Ixltf
AVERAGE VOLUME OF OIL SPILLS BY REGION
Rl R2 R3 R4 R5
FIGURE 57.
R6 R7 R8 R9 RIO Rl R2 R3 R4 R5 R6 R7 R8 R9 R10 81 R2 R3 m R5 R6 R7 R8 R9 RIO
I
EPA REGIONAL TOTAL MINOR HON - TRANSPORTATION RELATED OIL $PJLL TRENDS, 197 5
-------
10 2
5
4
3
10?
T01AL NUMBER OF OIL SPILLS BY REGION
0
CM
13
X
CO
CD
C*4
6x10*
-MQ*
TOTAL VOLUME OF OIL SPILLS BY REGION
6x10'
Ixl02
AVERAGE VOLUME OF OIL SPILLS BY REGION
R1 R2 R3 R4 R5 R6 R7 R8 R9 R10 Rl R2 R3 R4 R5 R6 R7 R8 R9 RIO R1 R2 R3 R4 R5 R6 R7 Rfl R9 RIO
FIGURE 59 . EPA REGIONAL TOTAL MINOR NON-TRANSPORTATION RELATED OIL SPILL TRENDS, 1976
-------
TOTAL NUMBER OF OIL SPILLS BY REGION
6x10
IxlO4
TOTAL VOLUME OF OIL SPILLS BY REGION
0
X
in
0
x
(O
f>.
6x10
IxlO3
AVERAGE VOLUME OF OIL SPILLS BY REGION
R) R2 R3 RA R5 R6 R7 Rfl R9 RIO R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO Rl R2 R3 Rt R5 R6 R7 R0 R9 R10
FIGURE 59 EPA REGIONAL TOTAL MODERATE NON- TRANSPORTATION RELATED OIL SPILL TRENDS , 1973
-------
TOTAL NUMBER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPILLS BY REGION
AVERAGE VOLUME OF OIL SPILLS BY REGION
6x10
1x10
tr
i
o
o
r*i
6x10-
1x105
6x10?
1x103
HI R2 R3 R4 R5 R6 R7 Rfi R9 RIO R1 R2 R? R4 R5 R6 R7 Rfl R9 RIO Rl R2 R3 R4 R5 R6 R7 R8 R9 RIO
FIGURE 60 EPA REGIONAL TOTAL MODERATE NON - TRANSPORTATION RELATED OIL SPILL TRENDS , 1974
-------
6x>0
5
A
3
2
1x10
/—\
o4
i
o
TOTAL tfJHDER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPILLS BY REGION
AVERAGE'VOLUME OF OIL SHLLS BY REGION1
6x10 5
Ix1(£
6X10
1x103
R1 R2 R3 U R5 R6 R7 RB R9 RIO R] R2 R3 R< R5 R6 87 RB R9 RIO R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO
FinilRT fil FPA RFGIflHA I TOTAI MflflF RAT F NOW-T RAN SPORT ATION RFIATFD Till SPIN TRFMOS 1975
-------
TOTAL NUMBER OF OIL SPILLS BY RE6I0N
TOTAL VOLUME OF OIL SPILLS BY REGION
AVERAGE VOLUME OF OIL SPILLS BY REGION
6x10
1x10
cr
i
Ch
6x10-
IxlO5
6x10
IxlO3
R1 R2 R3 R4 R5 R6 R7 R8 R9 RIO Rl R2 R3 Rl R5 R6 R7 RS R9 RIO Rl R2 R3 R4 R5 R6 R7 R8 R9 WO
FIGURE 62 . EPA REGIONAL TOTAL MODERATE NON-TRANSPORTATION RELATED OIL SPILLS TRENDS, 197 6
-------
TOTAL DUMBER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPILLS BY REGION
AVERAGE VOLUME OF OIL SPILLS BY REGION
6x10
1x10:
cr*
i
On
Ol
6x10*
1x10®
0
in
o
x
0
x
m
R
6x10'
IxlO5
Rl 82 R3 R4 R5 R6 R7 R8 R9 RIO R1 R2 R3 R4 R5 R6 R7 R0 R9 RIO Rl R2 R3 U R5 R6 R7 R8 R9 R10
f IGURE 63 EPA REGIOHAI TOTAL MAJOR HON-TRANSPORT AT I ON RE LATE 0 OIL SPILL TRENDS .1973.
-------
TOTAL NUMBER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPILLS BY REGION
AVERAGE VOLUME OF OIL SPILLS BY REGION
6 x 10
1x10
a*
i
On
6xld
1x10
1
0
*4-
Co
<}
X
ir>
1
6x10-
Ixltf
Rl R2 R3 RA R5 R6 R7 RB R9 RIO R1 R2 R3 RA R5 R6 R7 R8 R9 RIO Rj R2R3 RAM R6 R7 RO R9 RIO
FIGURE 64 EPA REGIOHAL TOTAL MAIOR HON - TRANSPORTATION RE LATE 0 OIL SPILL TRENDS .1974
-------
TOTAL NUMBER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPlL|.S BY REGION
X
6J10
1x105
X
0
x
r—
0
x
in
io
6<105
IxlO5
81 R2 R3 R<, R5 R6 R7 RB R9 RIO R1 R2 R3 RA P5 R6 R7 R8 R9 RIO R| R2 R3 R4 R5 R6 R7 R0 R9 RIO
FIGURE 65. EPA REGIONAL TOTAL MAJOR NON -TRANSPORTATION RELATED OIL SPILL TRENDS ,197b
-------
TOTAL NUMBER OF OIL SPILLS BY REGION
TOTAL VOLUME OF OIL SPILLS BY REGION
AVERAGE VOLUME OF OIL SPILLS BY REGION
b* 10
1x10
cr
I
Ox
6x10
1x10*
0
in
o
in
in
0
CD
m
oo
a»
6x10*
1x11*
0
x
CD
0
a
CD
R1 R2 R3 R4 R5 R6 R7 R8 R9 RlO R2 R3 R4 R5 R6 R7 R0 R9 R10 R1 R2 R3 R4 R5 R6 R7 R0 R9 R10
FIGURE 66. EPA REGIONAL TOTAL MAJOR NON-TRANSPORTATION RELATE0 0|L SPILL TRENDS , 197 6
-------
cr*
i
ON
1x10? -
SPILL VOLUME
5x10
1x10
AVERAGE SPILL VOLUME
m 74 75 76
73 74 75 76
73 74 75 7 6
FIGURE 67. NATIONAL TQTAL MINOR UNKNOWN SOURCE RELATED OIL SPILL TRENDS BV YEAfi
-------
-------
a*
i
o
to
5 x 10
1x10
NUMBER OF SPILLS
5x105
1x10"
SPILL VOLUME
0
x
CT»
5x»5
1x10-
AVERAGE SPILL VOLUME
1973 74 75 76
73 74 75 76
• 73 74 75 76
FIGURE 69. NATIONAL TOTAL MAJOR UNKNOWN SOURCE RELATEP OIL SPILL TRENDS BY YEAR
-------
YEAR
FIGURE 70 - NATIONAL OIL SPILL POTENTIAL IN BILLION GALLONS PER YEAR (1950-19751
-------
50
40 -
30
in
o
~J
J
<
u
J
<
H
O
H 20
10*10
REG. 5
REG. 4
REG. 6
REG. 2
REG. 9
REG. 3
tEG. 1
REG. 7
REG.10
REG. 8
CT*
I
X
i
±
I
X
±
1960 61 62 63 64 65 66 67 68 69 70 71 72 73 74
YEAR
l'Lj>uro 71. Oil Spill Potential for Each Region in Million Gallons per Year (1960-1975)
75
76
77
-------
cr
i
V|
(s)
5x10J -
TOTAL AMOUNT SPCC ASSESSMENTS
5x10d
lKlO3
AVERAGE AMOUNT SPCC ASSESSMENTS
1974 75 76 77
1974 75 76 77
1974 75 76 77
FIGURE72 NATIONAL SPCC ASSESSMENT TRENDS ,1974-1977
-------
TOTAL NUMBER SPCC COliECIKHS
TOTAL AMOUNT ^PCC COLLECTIONS
AVERAGE AMOUNT SPCC COLLECTIONS
I
5x10'
1xl£
5x10
1x10?
1974 7 5 76 77
1974 75 76 77
974 75 7 6 77
FIGURE 73. NATIONAL SPCC COLLECTION TRENDS ,1974 - 1977
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APPENDIX C: LINEAR REGRESSION MODEL USED IN DATA ANALYSIS.
In analyzing measurements over time one is often interested in finding
a mathematical relationship between time (t) and the measured variable (y).
That is, one would like to know how changes in time affect the measured
variable, or how long it will take to reach a given value of y. A straight
line (linear) model was used in this project because of the relatively
small number of time periods available, i.e. only three or four years,
and hence, it would be difficult to prove a more complex mathematical
model fitted the data usefully.
The equation for the model used is:
A A
y 3 a
+
%t (1)
where y is the measurement of interest, e.g. number of spills per year, and
t is the year in question or time. From the data we wish to estimate the
line intercept, a, and the slope, b. Hence, for a given time t, we can
then predict the y value at that time if a linear relationship holds
approximately. We are hoping for many of the measured variables in this
report like number of annual oil spills that the intercept a is small
and the slope b is negative since then, in time the number of spills
will tend to zero. Unfortunately, some a's are large and some b's are
positive.
The estimation of the a and b terms will involve some elementary
statistics. We call the a estimate &, the b estimate and hence the y
estimate is
A A A
y 3 a + ot
where (tj -t) (yx -y) + ... f Ct-t) (y^ -y)
1) =
(tt -t)2 + ... + (tu -t)2
y is the average of the four years of data and t is the average
time. As an example of these formulas, we examine Table 13 - Region I
Time No. of Spills
u
= 1976
6 =
! y-
t3
= 1975
14 =
8 Yz
t2
= 1974
13 =
'• Y 2
tl
= 1973
21 «
s Y l
c-1
-------
(1973-1974,5) (21-13.5) + ... + (1976-1974.5) (6-13,5)
£ -
(1973-1974,5)2 + ... + (1976-1974.5)2
(5)
= -4.4
I = 13.5 + 4.4(1974.5) = 8701.3 (6)
y = ,8701.3 -4.4t•
Hence in Region I to predict the number of spills for 1977 we
put t =¦ 1977 and obtain y s 2.5 or 3 spills as shown in the table.
While the data were illustrated for four year, since most data used
in the report used four years, for an arbitrary number of years
(ti -t) (yi -y) + ... + (tn -t) (yn -y)
6 = (8)
(ti -t)2 + ... + (tn -t)2
where n is the number of years used.
Besides estimating the trend b it is desirable to know if it clearly
differs from zero. A zero b means no program'effect with time.
Standard references for the following formulas are given ;at the end
of this appendix. Instead of using b most references rework the question
in terms of the correlation coefficient' p were
and
ft = r_fl (10)
st
are the corresponding estimates. Oy is the standard deviation of the
measured variable and Sy its estimate. at is the standard deviation in
time and s* its estimate.
c-2
-------
p is estimated by r where
(ti -t) (xi -y) + ... + (t„ -t) (y„ -y)
r =
(11)
\J fti-tl2 +• ... •+ ft^-t)2 . \J ry i -y>2 + ... +• fy^-yV
if there are 4 data points. In the example
r = -.926.
Now the values of p(or r) are normalized between 1 and -1.
Values near -1 or 1 indicate strong trends. But the real question is
how close to 1 (or -1) should r be before we say a real trend exists
in the data. The formula found on page 65 of reference 1 or pages
5-7 of reference 2 give the answer:
t =
(n-2)r
Q-r2}
(12)
In our example with n = 4 and r = -.926, t = 3.469. Since the
standard t value for this case can be found in Student's t- tables to
be 4.303 where 4.303 is exceeded only one time in 20 if the trend is
not real, we have found r = -.926 does not clearly show a statistical
linear trend at the 95% significance level used in this report.
The use of 95% is standard statistical procedure in examining
results called the test of the hypothesis p = 0 or b = 0. If we had used
the non-standard one chance in 10 or 90% significance level then the
standard value to compare against is 2.920. For this standard we would
find the decreasing trend in Region I significant whereas for the 95%
standard we can at best say it is almost significant.
The model discussed in this appendix is just one of many possible
models which appear under the classification of regression models. If the
data were collected for 48 months instead of four years, seasonal trends
in spillage might be detected if a comprehensive data analysis program
were used, such as the time series models developed in Reference 3.
References
1. Anderson, T.W., Introduction to Multivariate Statistical Analysis.
John Wiley, 1958.
2. Texas Instruments, Applied Statistics (TI Manual for TI Programmable
58/59), 1977.
3. Box, G. and G. Jenkins, Time Series Analysis: Forecasting and Control.
Holden Day, 1970.
c-3
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