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Question 19. Captain Corbett testified that operating capability of open Ocean oil 

 recovery equipment will likely not exceed current state-of-the-art of eight to ten foot 

 seas and 20 knot winds, and that in addition to hazard to personnel and equipment 

 in more severe sea states an oil spill will not remain on the ocean's surface in 

 sufficient quantity to make mechanical clean-up feasible. Given these facts, why has 

 the Coast Guard not advocated the use of low toxicity dispersants in such conditions 

 such as are commonly used throughout the remainder of the world? Would not the 

 use of dispersants as an acceptable tool increase the U.S. response capability to a 

 satisfactory level? 



Captain Corbett when discussing use of dispersants commented, "Sometimes when 

 we disperse, we do it intentionally. That is not necessarily good. It might save 

 Amenity Beach but it might kill a fish or two ..." Please comment on the known 

 effects of low toxicity dispersants on fish populations. 



Answer. Until recently, there were very few low toxicity dispersants. Even now 

 there is disagreement in the scientific community on the effects of dispersants. Our 

 policy recognizes the fact that the situation is being clarified and that dispersants 

 are a useful option. Of course, any dispersant use would be under the provisions of 

 Annex X of the National Contingency Plan, a copy of which is enclosed. Also 

 enclosed is a portion of a U.K. Ministry of Agriculture, Fisheries and Food report on 

 research into the toxicity and control criteria of oil dispersants which we obtained 

 from the USEPA. We suggest any further inquiries be directed to that agency which 

 is the lead agency and has overall responsibility for the government policy on the 

 use of dispersants. 



Question 20. Captain Corbett stated, in effect, that oil spill clean-up equipment in 

 the Philadelphia area is inadequate for the OCS. Was this equipment designed for 

 OCS operations and does its presence, in fact, have any relationship to OCS oper- 

 ations? Is the Coast Guard aware of industry clean-up equipment dedicated to mid- 

 Atlantic OCS operations? Is such equipment designed to operate in the OCS? 



On what basis have the 11 sites for stockpiling Coast Guard clean-up equipment 

 been chosen? 



Answer. While a large number of commercial contractors and cleanup coopera- 

 tives exist in the Philadelphia area, most specialize in shore cleanup and have 

 equipment that functions in protected waters and near shore locations. Our experi- 

 ences have indicated that there is insufficient call for offshore equipment to make 

 the large capital investment needed to maintain this capability attractive to the 

 commercial sector unless stimulated by requirements such £is those that are cur- 

 rently intended for activities on the Georges Bank. 



We have requested from the USGS a specimen of mid-Atlantic contingency plans 

 and will forward a copy when received. 



In answer to your second question, the eleven sites were chosen on the basis of a 

 spill risk analysis based on historical spill data. The study identified locations of 

 expected spills and was the key to site area selection. 



Question 21. Does the Naval Weather Service Detachment have cumulative prob- 

 ability distribution data on wind speeds and wave height for the Georges Bank area 

 to support that published in the EIS for Sale 42? Is or is not the wave height less 

 than 10 to 12 feet greater than 90 percent of the time? 



Answer. The Coast Guard has no independent data to support or challenge the 

 findings of the studies cited in the EIS concerning the sea conditions on Georges 

 Bank. We understand that NOAA, under the supervision of the office of Environ- 

 mental Data and Information Service is undertaking a "Climatological Oil Spill 

 Planning Guide for Coastal Federal Region I" which should shed much light on this 

 subject. 



Question 22. What type of capability does the Coast Guard envision for responding 

 to spills in the Gulf of Alaska resulting from OCS activities? 



Answer. The Coast Guard plans to treat the Gulf of Alaska as other OCS Areas. 

 The USGS has published OCS orders governing oil and gas operations which require 

 the lessee to provide an oil spill contingency plan including an equipment inventory. 

 This will greatly increase industry's capability. The Coast Guard plans to maintain 

 pollution response equipment at our Pacific Strike Team location, presently Hamil- 

 ton AFB, near San Francisco; at or near Seattle, WA and Kodiak, AK. Equipment 

 and people from the locations would be the first to respond from Coast Guard owned 

 resources. The Coast Guard is also coordinating our Research and Development and 

 response efforts with those of Canadian officials. 



Question 23. Could you explain precisely from your perspective the role of the 

 Coast Guard, the Department of the Interior, and the industry in the development, 

 evaluation, and approval of an oil spill contingency plan? 



Answer. The USGS requires, through their OCS orders governing oil and gas 

 lease operations, that an Oil Spill Contingency Plan be submitted by the lessee for 



