390 



SPECIFIC COMMENTS 



Page 7 — Last sentence on page 7 leads into an excerpt of the 1969 amendments 

 and the i)roi)ose<l legislation, and is continued on pnge 8. For clarity, it is recom- 

 mended that the first part of the excerpt at the top of page 8 be headed "For Ships, 

 Other Than Tankers, the Discharge of Oil or Oily Mixtures Will Be Prohibited 

 Unless :". 



Page 12 — Recommend reference to section 11 of the Federal Water Pollution 

 Control Act be updated to reflect the 1972 amendments. 



Page 21 — The discussion of some limitations of the effectiveness of load on top 

 operations is good in general, however, such discussion could be misinterpreted in 

 the manner presented. There appears to be two distinct and separate problems. 

 One problem is related to the so-cal'ed "persistent oil" carriers, and tlie LOT, 

 tank cleaning, and ballasting problem, while the other problem is related to oil 

 product or the so called "non-persistent oil" carriers. Discussion of the two 

 problems are interchanged on page 21 making it difficult to reach a conclusion. 



Page 23 — Discussion of the worst case situation and the rationale for total oil 

 carried by U.S. vessels does not appear to include oils carried in intracoastal 

 movements. However, the discussion on page 24 and 25 of discharge limitations 

 indirectly clarifies a part of this question. But, even this indirect approach would 

 be difficult for the average reader to interpret. 



Page 25 — The definition of oil in the proposed action is so restricted that the 

 implication of increased requirements for shoreside reception facilities could be 

 misleading. Shoreside reception facilities are certainly an alternative for prevent- 

 ing marine pollution by oil : however, since the load on top technique can possibly 

 comply with the proposed discharge limitations for persistent oils, the necessity 

 for additional shoreside reception facilities at this time is not apparent. Of course, 

 the main exceptions would be short haul situations and tanker repair facilities. 



Page 36 — The recent U.S. efforts to strengthen the IMCO Convention of 1954 as 

 amended is cVar evidence that the 1969 amendments are not good enough to pre- 

 vent pollution of the seas by oil. Therefore, to state unequivocally that, "there are 

 no adverse effects to the environment as a result of this bill" may be an error. This 

 proposed action will certainly minimize or reduce pollution of the seas by oil, but 

 adverse long term effects on the environment could exist but may not be well 

 understood. 



Page 40 — The 5 ppm oil in water concentration in an effluent from a shoreside 

 reception facilty is indeed a conservative figure. It might be more appropriate, 

 based on present day technology, to use design criteria of between 10-20 ppm oil 

 in water concentration. 



Page 49 — EPA applauds the statement on this page. 



Thank you for the opportunity to comment on the draft impact statement. 

 Should you have any questions regarding the above comments please contact the 

 undersigned. 



Sincerely yours, 



H. D. Van Ci.ea\-e, 

 Principal Reviewer. 



Department of the Army, 

 Office of the Chief of Engineers, 



Washington, B.C., February 5, 1973. 

 Commander D. B. Charter, Jr., 

 U.S. Coast Guard, 

 Department of Transportation, 

 Washington, D.C. 



Dear Commander Charter: This is in response to your letter of 28 September 

 1972 requesting our comments on your draft environmental statement concerning 

 the amendment of the Oil Pollution Act of 1961. 



We have reviewed the draft statement and have no comment at this time. 

 Sincerely, 



Howard L. Sargent. Jr., 

 CnJnnrl. C-orps nf Evninrcrs. 

 Executive Director of Civil Works. 



