CORDOVA OIL SPILL RESPONSE FACILITY - Not … 09, 2004 · Memorandum Date: July 9, 2004 To: Mark...

APPENDIX B CONSULTATIONS WITH OIL SPILL RESPONSE PROVIDERS

Developed for the Draft Environmental Impact Statement, December 2005

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Memorandum

Date: July 9, 2004

To: Mark Boatwright, BIA – Alaska Region

From: Bill Craig

Subject: Cordova Oil Spill Response Facility – Summary of Conversations with Spill Responders

In April and May 2004, URS contacted the organizations responsible for response planning and readiness in Prince William Sound (PWS) to gather information useful for developing functional and engineering criteria for the proposed Cordova Oil Spill Response Facility. Information was provided by John Kotula, Robert Ballesteros, and Leslie Pearson of the Alaska Department of Environmental Conservation (ADEC) Division of Spill Prevention and Response, Commander Mark Swanson of the U.S. Coast Guard (USCG) Valdez, Nancy Bird, Michelle O’Leary, and Lou Bodry of PWS Regional Citizens Advisory Council (PWS RCAC), Melissa Kompkoff of Cordova District Fishermen United (CDFU), Barry Romberg, Steve Hood, Deb White, and Grant Medford of Alyeska/SERVS, Carl Lautenberger of the Environmental Protection Agency (EPA), and John LeClair of Alaska Chadux Corporation (Chadux). Also contacted was Jim Holley of Alaska Marine Trucking, an agent for Lynden Transport and Alaska Marine Lines. To introduce the project and facilitate discussions, URS sent a letter to each of these spill response organizations by facsimile or by email. These letters posed a series of questions intended to help determine the functional and engineering criteria for the facility. The letters are included as Attachment 1. Following delivery of the letters, telephone conversations were conducted with each person except that Carl Lautenberger (EPA), Leslie Pearson (ADEC), and Nancy Bird (PWS RCAC) provided their responses by email. Bill Craig and Jack Colonell of URS and Jim Campbell and John Pickering of PND Incorporated (the conceptual engineering subcontractor on the project) participated in conversations with John Kotula (ADEC), Commander Mark Swanson (USCG), Melissa Kompkoff (CDFU), Barry Romberg, Deb White, and Grant Medford (Alyeska). Bill Craig conducted the remainder of the conversations. Jim Holley (Alaska Marine Trucking) did not receive a letter, but was contacted regarding existing freight shipping methods and equipment, since he is intimately familiar with the logistics of moving freight in and out of Cordova. Conversation records and written responses are included as Attachment 2. The letters posed nine questions. These questions and a summary of the responses received are presented below.

1. What is your role in response preparedness in the area? Answers: Responsibilities ranged from the federal on-scene coordinator (USCG), regulators (ADEC and EPA),

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crude oil shipping industry (Alyeska/SERVS), citizens oversite council of the crude oil shipping industry (PWS RCAC), and oil spill response cooperative (Alaska Chadux Corp.) EPA pointed out that they are not the primary agency responsible for planning, preparedness, and response in the coastal zone, but that when requested they do provide technical assistance for coastal zone planning and preparedness to the Alaska Regional Response Team.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answers: Most people pointed out the excellent airport that Cordova has and its role for receiving urgently needed equipment from outside the region. Others pointed out Cordova’s large fishing fleet that would respond quickly to spills as an advantage the community offers. Commander Swanson (USCG) and Nancy Bird (PWS RCAC) felt that it would be helpful to make the process of moving equipment from the airport to response vessels more efficient. John Kotula (ADEC) pointed out that response readiness in PWS and Cordova currently meets the planning standard but that there is always room for improvement. Several people felt that the facility should be configured to allow better communications (telephone, email, high speed internet) for the many people who would be involved in coordinating the response. Many people also pointed out the importance of the Cordova facility to respond to spills on the Copper River Delta in addition to PWS. Other people offered specific suggestions on features that are summarized under other topics presented below.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Answers: All of the people asked this question emphasized the role that air transportation of equipment would have. Most also thought that some equipment would be shipped to the region by barge or cargo ship, but most felt vessel transported equipment would be lower priority than that shipped by air. Some suggested that the equipment mobilized by vessels would go through communities to the west such as Whittier, Valdez, or Kodiak. Leslie Pearson (ADEC) envisions containerized equipment arriving at the existing barge ramp and being trucked to the facility. Nancy Bird (PWS RCAC) pointed out that in the near future, receiving equipment by fast ferry would be likely since a fast ferry is being constructed for PWS and should be ready for the 2005 summer season. Jim Holley (Alaska Marine Trucking) was asked about current freight capabilities in Cordova. Mr. Holley said that freight is transported to Cordova by tug and barge from Seattle on a weekly schedule. It takes 6 days from time of departure to arrive in Whittier and 3 more days to arrive in Cordova. Mr. Holley said the current system is convenient and efficient and he does not see any need to ship supplies using containerships or other large cargo ships, even in the event of another large spill. Mr. Holley said the barges currently used are 400 feet by 100 feet with a 12-foot draft. One of the tugs used is the 112-foot long Gulf Titan, which has a 35-foot beam and draws 20 feet of water; other tugs in their fleet draw similar or less water. Mr. Holley said that in the event of another large spill, equipment and supplies

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could be trucked to Valdez or Whittier from the west coast and would arrive in approximately 3 days. They would then be shipped via barge or landing craft to the location where needed, including possibly Cordova.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Answers: Most people pointed out that fishing vessels and SERVS vessels would be used to respond. Several people also mentioned the State Ferry Kennicott, which was designed to serve as a command center in the event of another large spill. Commander Swanson (USCG) also said that cutters and buoy tenders would be also used and the buoy tender Sycamore is currently home ported in Cordova. Barry Romberg (Alyeska) clarified that the draft for the 460 barge is “8/37”, which represents an 8-foot draft when loaded with response equipment and a 37-foot draft when also full of recovered oil and water. Mr. Romberg also stated the response barges would never call on Cordova when they contained oil/water; therefore the draft requirement for this barge for Cordova purposes is 8 feet. He said deepest draft SERVS vessels are the tugs, which draw 21 or 22 feet. SERVS provided a list of vessels in their fleet and their characteristics such as length and draft.

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answers: Most people felt there were pros and cons associated with consolidating equipment. Most people felt that by staging equipment in several locations, the ability to respond quickly to small, localized spills was improved. Most people who specifically talked about alternative locations felt that all of the equipment should not be staged at Shepard Point since avalanches could prevent access to vital equipment. Michelle O’Leary (PWS RCAC) thought it would be good public relations to have the equipment in one location, since everyone could see it and feel like the community was prepared. Barry Romberg (Alyeska) stated that they felt that from their interests, a location as close to the tanker lanes as possible would be best.

6. Do you have any recommendations for the following specific features?

• Staging area size. Answers: Most people did not have any specific recommendations on staging area size except that Barry Romberg (Alyeska) said it should be at least one acre since that is the size of the area they currently use. John Kotula (ADEC) said the area needed to be large enough to sort and assemble equipment. Barry Romberg stated that having the staging area near the water is very important. John LeClair (Chadux) indicated an area the size of the current ferry parking/staging lot extending to the fuel (ocean) dock would be ideal.

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• Dock dimensions. Answers: Most people who responded to this question felt that the dock should be large enough to dock one of the largest vessels such as a SERVS barge or the State Ferry Kennicott as well as three to four fishing vessels.

• Weight and size of material to be moved over the dock. Answers: Commander Swanson (USCG) said that this would be limited to what could fit on a plane. Barry Romberg Alyeska) felt that the dock should be designed to handle equipment in containers 20 feet long. John Kotula (ADEC) felt that most out-of-region equipment would be on pallets. Michelle O’Leary (PWS RCAC) pointed out that the mini-barges currently stored in Cordova may be moved over the dock and some of the equipment such as boom and skimmers can be fairly large. As discussed above, most people thought some lower priority equipment would come to Cordova by vessel, although some of these people pointed out that existing freight facilities could accommodate this need.

• Equipment and storage facilities that should be located at the site. Answers: Several people expressed support for a roof over part of the facility to provide shelter while sorting and assembling equipment. Barry Romberg (Alyeska) said that they meet the minimum standard with connex containers but that access to a roofed facility would be ideal. Michelle O’Leary (PWS RCAC) felt that no heavy equipment such as loaders or forklifts needed to be dedicated to the facility but that MOAs should be established to ensure their availability when needed. John Kotula (ADEC) said that forklifts and cranes should be available to sort and move equipment. Lou Bodry (PWS RCAC) felt that dock mounted cranes should be furnished to facilitate loading response vessels. John LeClair (Chadux) supported providing storage space for approximately 25,000 gallons of recovered product since bladders and the SERVS barges currently would accommodate small and very large spills. John LeClair also expressed support for an oil/water separator.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: SERVS said it would be nice to have a helicopter-landing pad. Commander Swanson (USCG) said dispersants could be stored at the facility for application via vessel. Lou Bodry and Michelle O’Leary (PWS RCAC), and Barry Romberg (Alyeska) stated that it would be good to have office space, phone lines, and internet connections available. John LeClair (Chadux) felt that the ability to store and treat recovered product would be beneficial.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answers: Road Access: People were divided on this issue and most

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felt that at a minimum, all of the equipment should not be staged in an area where it could be inaccessible due to avalanche hazards. Michelle O’Leary (PWS RCAC), John Kotula and Robert Ballesteros (ADEC), Carl Lautenberger (EPA), and John LeClair (Chadux) felt that the facility should always be road accessible. Nancy Bird (PWS RCAC) felt that if the facility was constructed at Shepard Point, the road should be closed during periods of avalanche danger. Barry Romberg (Alyeska) stated that year round access was needed and that seasonal avalanche dangers would be a detriment. Lou Bodry (PWS RCAC) said he was concerned about Shepard Point if there was no way to bring down the avalanches during dangerous conditions. Melissa Kompkoff (CDFU) said she was concerned about road access to Shepard Point due to avalanches and she would like to see someone housed there if the facility is built there. Commander Swanson (USCG) pointed out that occasional road closures due to avalanche hazards are common in Alaska and occasional closures of the access road would be acceptable. Vessel Access: Almost everyone felt that some delay of the largest vessels would be acceptable; Commander Swanson said that tidal delays would simply be in the noise of logistics. Everyone felt that fishing vessels needed all tide access. Barry Romberg stated that the facility needed all tide access but that there was no pressing need to bring the deeper draft vessels into Cordova. Steve Hood (Alyeska) stated that SERVS does not have any trouble accessing Cordova with their 21 to 22 foot draft tugs (the deepest draft response vessels with potential to call on the facility). Leslie Pearson (ADEC) felt that the road and channel should be “all weather, all conditions.”

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answers: Everyone was supportive of making the dock available for other uses. Most stated these other uses should be capable of clearing the dock quickly and should maintain a clear path between the equipment and the dock.

Date: September 28, 2006 To: Kristin K’eit, Regional Environmental Specialist, BIA Alaska Region From: Taylor Brelsford, Project Manager Subject: Supplement to Cordova Oil Spill Response Facility - Summary of

Conversations with Spill Responders In July 2004, URS contacted the Native Village of Eyak (NVE) as an organization responsible for response planning and readiness in Prince William Sound (PWS) to gather information for developing functional and engineering criteria for the proposed Cordova Oil Spill Response Facility. Follow-up calls to document responses from the NVE were not made at that time. In September 2006, BIA reinitiated this consultation at NVE’s request. The full written response from Bruce Cain, NVE Executive Director, dated September 13 and September 14, 2006, is included in Attachment 2. This memo summarizes the NVE responses to the nine questions asked of all oil spill responders. It supplements the summary of July 9, 2004, which covered the replies from eight other response organizations. 1. What is your role in response preparedness in the area? NVE is a federally recognized tribal government which serves in a role of “strong advocacy . . . to insure that the required oil spill capacity in our area is built and maintained.” Tribal members were directly involved in the response to the Exxon Valdez oil spill, and since 2002, have implemented an active response service system, through a Pollution Removal Funding Agreement and a Memorandum of Agreement with the U.S. Coast Guard. NVE noted that they are part of an agency reporting network with 24 hour communication and that they have responded to six spills since 2002, receiving excellent reviews on performance and cost effectiveness. As a supplemental capacity, NVE reported that two seasonal fisheries monitoring field camps on the Copper River could serve in logistics and communications capacities if ever there were a spill from the Trans Alaska Pipeline into the Copper River. In the electronic message of September 14, 2006, NVE provided additional information about dedication and responsiveness of the NVE crew in facing highly challenging conditions in the spill responses since 2002. 2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region. NVE stated that the deepwater port, road connection and pre-positioned response equipment are needed. The new facility would allow NVE to move from a volunteer team with borrowed equipment to a more systematic effort with staffing by a dedicated crew leader, as well as training and drills. In the NVE perspective, the logistics breakdowns in the EVOS incident showed the need for the staging area and deepwater port.

URS Corporation 2700 Gambell Street, Ste 200 Anchorage, AK 99503 Phone: 907.562.3366 Fax: 907.562.1297 www.urscorp.com

3. What modes of transportation should the facility accommodate for out of region equipment arriving in Cordova prior to deployment to the response site (including re-supply)? NVE recommended that the facility have the capacity to accommodate a very wide range of vessels from Alaska, the Bering Sea, and Eastern Asia. This includes large container ships, Alaska Ferry vessels, all SERVS equipment, fishing vessels of all sizes, multi-use vessels that can be converted to oil spill response, and specialized equipment from Alaska, the East coast of Russia, Asia and Japan, Canada and the US, Navy troop ships for housing, cruise ships for housing, and any other vessel of opportunity that is available and that can be pulled into service. NVE also identified a detailed list of response equipment and supplies that could be flown into the Cordova Airport, transported to Shepard Point and trans-loaded to spill response, supply, and logistics support vessels. 4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? NVE referred to the response to Question #3. Can you provide the length, draft, beam, name, homeport or other pertinent details of representative vessels? NVE identified a number of large, deeper draft vessels that should be accommodated These included the SERVES fleet, container ships, cruise ships, tank vessels, international multi-purpose and single purpose oil spill response vessels, including those in the North Sea. Collectively, these vessels had lengths from 400 to 900 feet, and drafts from 38 to 70 feet. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? NVE had questions about the purpose of this item, but did not provide information in response. Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? NVE stated that all alternative locations except Shepard Point would detract from capabilities, generally because they would impose an additional 8-10 miles transit distance to get from the tanker lanes to the resupply point. Other locations wouldn’t handle the larger vessels. 5. Do you have any recommendations for the following specific features? NVE recommended a staging area of 10 acres, and a dock capable of handling a 600-foot ship with a 40-foot draft, based on the 1996 PND Site Suitability Study for Shepard

Point. Regarding the weight and size of material to be moved over the dock, NVE provided an extensive list of equipment and materials. Some of the larger and heavier items would include oil skimmers, shipping containers up to 54 feet, skimmers response equipment, heavy equipment, loaders, dozers, cranes, and recovered oil. NVE recommended that equipment and storage facilities located at the site should include the pre-positioned oil spill response equipment in shipping containers, an office with phone and computer, and a large loader with changeable container forks and snow bucket. 6. What needs might be covered by this facility that are currently not available at SERVS? NVE identified three functions: storage for pre-positioned equipment, ability to re-supply a massive logistics effort, and ability to dock deep draft vessels and connect by road to the airport. NVE also stated that establishing the facility would bring Alyeska into compliance with the courts action in the Alyeska Consent Decree, and offers criticism of the adequacy of environmental protection performance by Alyeska and BP. 7. What are your recommendations for the minimum reliability standards for main and road access for the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? NVE stated that the facility should be available at all times, and asserted that the risks of avalanche closure for the road to Shepard Point are no different than several other Alaskan locations and can be adequately controlled through a monitoring and mitigation program. 8. Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water or would some amount of delay be acceptable? NVE stated that since this is an emergency facility, the facility must provide for “urgent rapid action” with all necessary equipment. This statement is supportive of all tide access and opposes any delays waiting on tide states. In NVE’s view, Shepard Point provides the minimum, and additional marine access capacity, while no other alternative location does. NVE objected to this question. 9. What other uses of the staging area or dock could be allowed without interfering with the primary purpose? NVE stated that if the staging area were larger, at 10 acres, then compatible uses would include other boat repair, haul out, storage, shipping and receiving, possibly a ferry terminal, lease to a navy or coast guard or commercial ship, etc.

Attachment 1 Letters To Response Groups

April 27, 2004

Leslie Pearson Alaska Dept. of Environmental Conservation 555 Cordova Street Anchorage, Alaska 99501-2617

Dear Ms. Pearson:

The U.S. Department of Interior, Bureau of Indian Affairs (BIA), with participation by the cooperating agencies, the Native Village of Eyak (NVE), the Army Corps of Engineers (Corps), and the Federal Highway Administration (FHWA), is preparing an Environmental Impact Statement (EIS) to analyze alternatives for developing an oil spill response facility in the Cordova area. The purpose of this facility is to enhance oil spill response capabilities in southeast Prince William Sound (PWS). Enhancement includes how such a facility fits into current oil spill contingency activities and how such a facility might meet future needs over a larger geographic area. The components of the facility that have been preliminarily identified are a dock, staging area, and road connection to the Cordova airport. URS has been retained as a third party contractor to BIA to prepare the EIS.

As you know, oil spill response equipment is currently staged and maintained in Cordova by Alyeska, U.S. Coast Guard, ADEC, and possibly others. Cordova is also identified in contingency plans as a portal for rapid mobilization of out-of-region equipment; specifically, Cordova’s all-weather airport would be utilized to receive equipment flown to Alaska from stockpiles in the lower 48 and around the world.

Since you have expertise in oil spill response readiness in the area, we would like your involvement early in this planning process to help us develop functional and engineering criteria for the facility. Specific issues we would like to discuss are:

1. What is your role in response preparedness in the area?

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region?

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)?

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Would the State Ferry Kennicott be likely to call on the facility in the event of a major spill?

2700 Gambell Street, Suite 200 . Anchorage, AK 99503 (907) 562-3366

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction?


x� Staging area size x� Dock dimensions x� Weight and size of material to be moved over the dock x� Equipment and storage facilities that should be located at the site.

7. What needs might be covered by this facility that are currently not available at SERVS?

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable?

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose?

Thank you for your assistance with this project. As we discussed, I look forward to discussing these issues with you later this week. I can be reached at (907) 261-9756.

Sincerely,

Bill Craig

URS Corporation


April 21, 2004

Barry Romberg, PE, PMP Operations Advisor Alyeska Pipeline / SERVS

Dear Mr. Romberg: The U.S. Department of Interior, Bureau of Indian Affairs (BIA), with participation by the cooperating agencies, the Native Village of Eyak (NVE), the Army Corps of Engineers (Corps), and the Federal Highway Administration (FHWA), is preparing an Environmental Impact Statement (EIS) to analyze alternatives for developing an oil spill response facility in the Cordova area. The purpose of this facility is to enhance oil spill response capabilities in southeast Prince William Sound (PWS). Enhancement includes how such a facility fits into current oil spill contingency activities and how such a facility might meet future needs over a larger geographic area. The components of the facility that have been preliminarily identified are a dock, staging area, and road connection to the Cordova airport. URS has been retained as a third party contractor to BIA to prepare the EIS. As you know, oil spill response equipment is currently staged and maintained in Cordova by Alyeska, U.S. Coast Guard, ADEC, and possibly others. Cordova is also identified in contingency plans as a portal for rapid mobilization of out-of-region equipment; specifically, Cordova’s all-weather airport would be utilized to receive equipment flown to Alaska from stockpiles in the lower 48 and around the world. Since you have expertise in oil spill response readiness in the area, we would like your involvement early in this planning process to help us develop functional and engineering criteria for the facility. Specific issues we would like to discuss are:

1. What is your role in response preparedness in the area? 2. How do you see a proposed facility in the Cordova area functioning in relation to

your responsibilities in the region? 3. What modes of transportation should the facility accommodate for out-of-region

equipment arriving in Cordova prior to deployment to the response site (including resupply)?

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you update/verify the information in the attached table that presents the characteristics of SERVS vessels that have been presented in recent contingency plans? The beam of the larger vessels would also be helpful if available. Also, could you verify the draft for the 460 barges (i.e., would the barges draft 38 feet when they would need to call on Cordova or would that only be when they are laden with oily water)?




• Staging area size • Dock dimensions • Weight and size of material to be moved over the dock • Equipment and storage facilities that should be located at the site.




Thank you for your assistance with this project. As we discussed, we will be ready to discuss these issues and address other concerns you may have at 11:00 Friday morning at 261-6722. Sincerely,

Bill Craig URS Corporation


SERVS Vessels Likely to Call on the Cordova Oil Spill Response Facility

Vessel Type Length Depth Maximum Draft

Potential to Call on Cordova

Pioneer Service Utility Vessel 207 17 16’ 9” Freedom Service Utility Vessel 207 17 16’ 9” Heritage Service Utility Vessel 207 16’ 9” Liberty Service Utility Vessel 207 16’ 10” Constitution Service

Utility Vessel 207 16’ 9”

Nanuq, Tan’erliq Enhanced Tractor Tug

153 20

Unknown Prevention and Response Tugs

140 20

Guard Protector Class Tug 120 19’7” Unknown Invader and Theriot

Tugs 136 – 149

21

Gulf Service Escort/Towing Vessel

222 17’ 6”

Responder 500-2 Nearshore Barge 400 20 14’ 2” Allison Creek Inland Tank Barge 201 12.8 12.8 Barge 450-8 Skimming/Storage

Barge 400 25 19’ 10.5”

Barge Mineral Creek

Skimming/Storage Barge

460 37’ 6”

Tidemar 460 Skimming/Storage Barge

460 37’ 6”

Barge 450-1 Skimming/Storage Barge

400 25

Barge 450-3 Skimming/Storage Barge

400 25 19” 10.5”

Z-Big 1 Storage Barge 400 25 19’ 6” Barge 570 Lightering Barge 328 23 Krystal Sea Landing Craft 138 7’ 6” Mini Barge Portable Storage

Barge 41 4’ 6” 3’ 6”

Pollutank Portable Barge 50 9.1 Valdez Star Skimming Vessel 123 10 JI 344 Storage Barge

Skimming/Storage Barge

330 20’ 9” 16’ 3”


April 26, 2004

Carl Lautenberger Alaska Operations Office (Region X) U.S. Environmental Protection Agency 222 West 7th Avenue Anchorage, Alaska 99513

Dear Mr. Lautenberger:







4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels?








Thank you for your assistance with this project. As we discussed, I look forward to discussing these issues with you later this week. I can be reached at (907)261-9756.

Sincerely,

Bill Craig

URS Corporation


May 4, 2004

John LeClair Alaska Chadux Corporation 2347 Azurite Court Anchorage, Alaska 99507

Dear Mr. LeClair:


As you know, oil spill response equipment is currently staged and maintained in Cordova by Alyeska, U.S. Coast Guard, ADEC, and probably by you. Cordova is also identified in contingency plans as a portal for rapid mobilization of out-of-region equipment; specifically, Cordova’s all-weather airport would be utilized to receive equipment flown to Alaska from stockpiles in the lower 48 and around the world.













Thank you for your assistance with this project. I look forward to discussing these issues and addressing other concerns you may have.

Sincerely,

Bill Craig

URS Corporation


April 21, 2004

CDR Mark Swanson U.S. Coast Guard Valdez, Alaska

Dear Mr. Swanson: The U.S. Department of Interior, Bureau of Indian Affairs (BIA), with participation by the cooperating agencies, the Native Village of Eyak (NVE), the Army Corps of Engineers (Corps), and the Federal Highway Administration (FHWA), is preparing an Environmental Impact Statement (EIS) to analyze alternatives for developing an oil spill response facility in the Cordova area. The purpose of this facility is to enhance oil spill response capabilities in southeast Prince William Sound (PWS). Enhancement includes how such a facility fits into current oil spill contingency activities and how such a facility might meet future needs over a larger geographic area. The components of the facility that have been preliminarily identified are a dock, staging area, and road connection to the Cordova airport. URS has been retained as a third party contractor to BIA to prepare the EIS. As you know, oil spill response equipment is currently staged and maintained in Cordova by Alyeska, U.S. Coast Guard, ADEC, and possibly others. Cordova is also identified in contingency plans as a portal for rapid mobilization of out-of-region equipment; specifically, Cordova’s all-weather airport would be utilized to receive equipment flown to Alaska from stockpiles in the lower 48 and around the world. Since you have expertise in oil spill response readiness in the area, we would like your involvement early in this planning process to help us develop functional and engineering criteria for the facility. Specific issues we would like to discuss are:

1. What is your role in response preparedness in the area? 2. How do you see a proposed facility in the Cordova area functioning in relation to

your responsibilities in the region? 3. What modes of transportation should the facility accommodate for out-of-region

equipment arriving in Cordova prior to deployment to the response site (including resupply)?





• Staging area size • Dock dimensions • Weight and size of material to be moved over the dock • Equipment and storage facilities that should be located at the site.




Thank you for your assistance with this project. As we discussed, we will call you on Friday at 9:00 to discuss these issues and address other concerns you may have. Sincerely,

Bill Craig URS Corporation


July 7, 2004

Bruce Cain Native Village of Eyak P.O. Box 1388 Cordova, Alaska 99574

Dear Mr. Cain:















Thank you for your assistance with this project. As we discussed, we will call you to discuss these issues and address other concerns you may have.

Sincerely,

Bill Craig

URS Corporation


Attachment 2 Conversation Records and Written Responses

May 7, 2004 Leslie Pearson (ADEC) Responses to URS letter Dated April 27, 2004 Cordova Oil Spill Response Facility

1. My position is the Prevention & Emergency Response Program Manager for the Alaska Department of Environmental Conservation. The mission of the Prevention and Emergency Response Program (PERP) is to protect public safety, public health and the environment by preventing and mitigating the effects of oil and hazardous substance releases and ensuring their cleanup through government planning and rapid response. This is a statewide program with 34 people dedicated to emergency response, planning, and preparedness. For response planning purposes, the state is divided into 10 regions. The City of Cordova is within the Prince William Sound region for the state. The PWS region is considered a “high risk” region for potential oil spills due to the transport of crude oil via tanker vessels. The Copper River delta is also considered a highly sensitive environmental area in the Prince William Sound area.

2. Certainly not having a deep water dock in Cordova is one of the greatest limiting factors for response capabilities in Southeast Prince William Sound. As a key staging area in the Trans-Alaska Pipeline vessel contingency plans, the Copper River Delta portion of the plan has only been exercised with mixed results. The BP Spill of National Significant drill in 2000 was the first and only time that out of region resources were brought into Cordova and deployed to the field. There were some issues related to equipment loading because of the tides. A response facility in Cordova would improve and enhance response capabilities in the area, particularly for responses in the Copper River Delta.

3. Tractor trailer combinations that could accommodate TOTE type containerized shipments. I envision containers coming into the barge dock and being transferred to this facility for transfer to landing craft type vessels, response barges or fishing vessels.

4. Definitely fishing vessels but also tugs up to the size of the Pathfinder or the Nanuq used in the PWS oil tanker trade. Also air boats and hover craft would be good for the Copper River Flats and Delta. The State Ferry Kennicott could be activated and used during a significant event, as well as the new generation of fast ferry’s- M/V Chenega. I don’t have the details for each of these vessels. The information could be easily obtained by the DOT/Alaska Marine Highway (ferry), Crowley Marine (tugs) and Lynden Transportation (hover craft).

5. ADEC has a response container staged at the small boat harbor in Cordova and we’ve got a community response agreement with the City, whereby they maintain custodial responsibilities and access. To consolidate the U.S. Coast Guard, DEC and industry container in one staging area would be beneficial. Each entities container should be clearly marked and distinct due to access agreements and the different regulatory (industry) parameters (CPlan).

May 7, 2004 Leslie Pearson (ADEC) Responses to URS letter Dated April 27, 2004 Cordova Oil Spill Response Facility

6. No recommendations at this time.

7. Additional capability to respond in the Copper River Delta and over around Katalla all the way to Icy Bay. SERV’s is not the only response contractor for Prince William Sound. Alaska Chadux has equipment staged in Cordova to support spills from non-tank vessels, oil tank farms and barge operations. A facility that could accommodate all entities, government and industry would be a benefit.

8. All weather, all conditions road and channel because these things never seem to happen when the weather is good and conditions are just right.

9. Since the facility is proposed as a response facility then during a response use would be a priority. I don't think there would need to be many restrictions as long as it is worked out so that there would never be a hindrance or delay to a prompt response when needed.

RECORD OF TELEPHONE CONVERSATION

DATE: 4/26/04 TIME: 15:10 JOB NO.: 26219634

RECORDED BY: Bill Craig OWNER/CLIENT: BIA

TALKED WITH: Steve hood OF Alyeska/SERVS

NATURE OF CALL: INCOMING X OUTGOING PHONE # 278-1611 ext 6974

ROUTE TO: INFORMATION ACTIONS

MAIN SUBJECT OF CALL: Cordova EIS

ITEMS DISCUSSED: Steve returned Bill Craig’s voice message from 4/20/04 regarding engineering criteria for Cordova Oil Spill Response Facility.

I told Steve that we had talked with Barry Romberg of SERVS on Friday. Steve said that Barry was the most appropriate person to talk to. Steve added that they had recently moved a response vessel and found tying up to the Homer dock difficult in the wind since a skiff was required to secure the lines. Steve wanted to make sure that when we design the dock structure we take into account the prevailing storm winds and ensure that the line handlers can do their work safely.

Steve stated that SERVS does not have any problem accessing Cordova currently with their 21 to 22 foot draft tugs.

I told Steve that we intended to offer draft designs to SERVS for recommendations at a later date.

S:\ADMINISTRATION\FORMS\TelephoneConversation.doc URS Corporation


DATE: 4/23/04 TIME: 11:10 JOB NO.: 26219634


TALKED WITH: Barry Romberg OF Alyeska/SERVS

NATURE OF CALL: INCOMING X OUTGOING PHONE # 278-1611 ext 6767



ITEMS DISCUSSED: Bill Craig and Jack Colonell of URS and Jim Campbell and John Pickering of PND called to discuss function and engineering criteria for Cordova Oil Spill Response Facility.

We went through the following questions, which we posed to Barry in our letter to him dated April 21, 2004.

1. What is your role in response preparedness in the area? Answer: If TAPS oil were spilled within the 200-mile EEZ, Alyeska would respond. SERVS maintains equipment on approximately 1 acre of land on the North Fill with boom, skimmer, hoses. This equipment is mostly nearshore equipment that would be used by the fishing vessels SERVS also keeps under contract in Cordova. They would also respond to Copper River Delta.

Note Deb White and Grant Medford from SERVS joined the call.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answer: A location closer to the tanker lanes would be optimal. Would be ideal to have roofed facility closer to water.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Answer: Advantage of using Cordova is the excellent airport, the linkage between the airport and the facility must be strong. He said equipment arriving by water would be containerized and it would be useful to use Cordova if the spill was local, but that Valdez could accommodate this equipment.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you update/verify the information in the attached table that presents the characteristics of SERVS vessels that have been presented in recent contingency plans? The beam of the larger vessels would also be helpful if available. Also, could you verify the draft for the 460 barges (i.e., would the barges draft 38 feet when they would need to call on Cordova or would that only be when they are laden with oily water)? Answer: Barry clarified that the vessel characteristics he provided yesterday provide two drafts for the barges. The first draft is when they are loaded with response equipment and do not contain recovered oil/water and the second


draft would be if they were loaded with recovered oil/water. For the 460 barge the draft is 8/37 and he stated it would never call on Cordova when it contained oil/water; therefore the draft requirement for this barge for Cordova purposes is 8 feet. He said deepest draft vessels are the tugs, which draw 21 or 22 feet.

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answer: He believes it would be nice but from SERVS perspective there is no real benefit.


• Staging area size. Answer: 1 acre minimum and he would like to have space to land a helo.

• Dock dimensions. Answer: Use vessel list he provided.

• Weight and size of material to be moved over the dock. Answer: Should be able to move 20-foot connexs.

• Equipment and storage facilities that should be located at the site. Answer: He did not want any facility in Cordova to store/treat oily water. Barry said that they meet the minimum planning requirement with connexs, but access to a roofed facility would be ideal. Since they meet the minimum standard, SERVS is not willing to spend any extra money on this.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: Helo pad, inside storage, closer to water and tanker lanes, phones, faxes, office space etc.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answer: Need road year round, seasonal avalanche closures would be a detriment. Must have all tide access; however, no pressing need to bring larger vessels into Cordova.

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answer: Other uses acceptable, must maintain clear access between staging area and water. Must be able to move vessels tied to dock. Must be able to load fishing vessels quickly.

Note: He said he would not want to see a dirt road; it should be paved. The current requirement for maintaining the equipment is to be able to get the gate unlocked and open, snow cleared, and doors open on connexs within 2 hours of call out.


"Romberg, Barry" To: "'[email protected]'" <[email protected]> <RombergBA@alyeska- cc: pipeline.com> Subject: RE: Proposed Cordova Oil Spill Response Facility 04/22/2004 11:16 AM

Bill,

Here is a matrix that describes the current fleet.

I will call as planned to discuss the other questions in your letter.

-Barry

-----Original Message---- -From: [email protected] [mailto:[email protected]] Sent: Wednesday, April 21, 2004 4:05 PM To: Romberg, Barry Subject: Proposed Cordova Oil Spill Response Facility

Barry, The letter is attached, we will be at 261-6722 at 11:00 on Friday to discuss these issues and any others that you may have.

Thank you Bill Craig Environmental Scientist URS Corporation, Alaska (907)261-9756

(See attached file: SERVS Letter.pdf)

mailto:[email protected]

%5Bmailto:[email protected]%5D

SERVS Vessel and Barge Fleet Utilization 4/22/2004

Cordova Vessel Type Length Beam Draft Potential* Primary Use Secondary Use Tan'erliq Escort Tug - VSP Drive 153 48 22 3 Tanker Escorts Docking & Barge Assist Nanuq Escort Tug - VSP Drive 153 48 22 3 Tanker Escorts Docking & Barge Assist Alert Escort Tug - Z Drive 140 42 22 3 Tanker Escorts Docking & Barge Assist Aware Escort Tug - Z Drive 140 42 22 3 Tanker Escorts Docking & Barge Assist Attentive Escort Tug - Z Drive 140 42 22 3 Sentinal Service Docking & Barge Assist Sea Voyager Conventional Twin Screw Tug 150 40 21 3 Sentinal Service Response Barge Assist Stalwart Conventional Twin Screw Tug 137 37 21 3 VMT Docking Assist Response Barge Assist Bulwark Conventional Twin Screw Tug 137 37 21 3 VMT Docking Assist Response Barge Assist Pathfinder Conventional Twin Screw Tug 137 37 21 3 VMT Docking Assist Response Barge Assist Sea Flyer Conventional Twin Screw Tug 137 37 21 3 VMT Docking Assist Response Barge Assist Endurance Utility Vessel (OSRV) 207 40 17 4 Response Barge Assist Anchor / Mooring Maintenance Valdez Star Self Propelled Skimmer 123 31 10 2 Skimming/Storage - VMT Skimming/Storage - PWS Krystal Sea - 2005 Integrated Tug & Barge 240 34 10 10 Containerized Cargo (Lynden) Near Shore Response Barge 450-1 Skimming & Storage Barge (OSRV) 400 100 5 / 22 4 Skimming/Storage - PWS Skimming/Storage - GOA Barge 450-8 Skimming & Storage Barge (OSRV) 400 100 5 / 22 4 Skimming/Storage - PWS Skimming/Storage - GOA Barge Mineral Creek Skimming & Storage Barge (OSRV) 460 84 8 / 37 3 Skimming/Storage - VMT Skimming/Storage - GOA Barge 450-3 Skimming & Storage Barge (OSRV) 400 100 5 / 22 1 Skimming/Storage - VMT Skimming/Storage - PWS Barge 500-2 Near Shore Response Barge 400 100 5 / 16 4 Near Shore Response Storage of Recovered Oil Barge 570 Lightering Barge 328 80 5 / 23 2 Tanker Lightering Near Shore Response Barge Allison Creek Tank Barge 201 42 4 / 13 1 Storage of Recovered Oil Storage of Recovered Oil Barge Sawmill Creek Deck Barge 125 34 3 / 8 3 Storage/Transport of Boom Storage/Transport of Boom

* (0 - 10) Cordova Port Call Potential 0 Never 3 Maybe once per 5 years 6 Once per Year 10 Several Times per Year


DATE: 4/30/04 TIME: 1:50 JOB NO.: 26219634


TALKED WITH: Michelle O’Leary OF PWS RCAC

NATURE OF CALL: INCOMING OUTGOING X PHONE # 424-7758



ITEMS DISCUSSED: Bill Craig of URS called to discuss function and engineering criteria for Cordova Oil Spill Response Facility.

We went through the following questions, which we posed to Michelle in our letter to her dated April 20, 2004.

1. What is your role in response preparedness in the area? Answer: Michelle is on the scientific advisory committee. In the event of another large spill, she would issue a technical disaster guidebook on the socioeconomic impacts. She is involved in ensuring readiness of the response centers.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answer: She believes the jet airport is the biggest advantage Cordova offers. She would also like to see a dedicated or standby building arranged so that in the event of another large spill, it could be used as a communication and dispatch center. It should have space for USCG, ADEC, community, PWS RCAC and should be equipped with phone and fax lines. This building/office space does not have to be connected to the equipment storage or dock. She thinks 2 locations are necessary, the first location being the communication/dispatch center and the other the equipment center.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Answer: Out of region equipment would be mobilized by cargo jet aircraft or by fast ferry. She does not believe mobilizing equipment by ocean going vessel makes sense unless it is a Copper River Delta spill. All other spills, ocean going vessels would call on Whittier.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Answer: Michelle doesn’t see the need for bringing the large SERVS tugs into Cordova.

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answer: She does not see the need


to consolidate equipment. She said it may be more efficient to do this and it may also be good public relations to have a higher visibility facility so that everyone knows where it is. She feels locating the facility at Shepard Point would severely limit response capability , especially to the Copper River Delta, since she feels avalanche hazards would close road often. She is also concerned about the seismic stability of Shepard Point since it is itself rockslide material. She also questioned the vulnerability of SP to tsunamis.


• Staging area size. Answer: She does not believe a new area is needed. She believes the City Dock and current SERVS storage yard is adequate. She pointed out that the airport could also be used. She suggested formalizing some of this space by executing MOAs with the owners/managers.

• Dock dimensions. Answer: She said she likes the idea of using the City Dock. Dock should be large enough to accommodate the Kennicott, one tender and three or four fishing boats.

• Weight and size of material to be moved over the dock. Answer: Consider minibarges, 20’ containers, some large pieces of equipment such as boom and skimmers.

• Equipment and storage facilities that should be located at the site. Answer: Michelle said there was no need to have dedicated equipment but that it should be arranged by executing MOAs with local suppliers. She said it would be nice to have a warehouse but that is not necessary. She believes the lack of phones, fax lines and office space are the biggest problem now.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: Answer: They need a scaled down version of the Valdez operations center.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answer: She believes no road closures would be acceptable. Some delays are acceptable for the larger vessels since the maximum delay would be 6 hours.

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answer: All other uses are acceptable except that it must be able to clear the dock and load the fishing vessels in a couple of hours.



DATE: 4/28/04 TIME: 9:00 JOB NO.: 26219634


TALKED WITH: Jim Holley OF Alaska Marine Trucking, Cordova




ITEMS DISCUSSED: Bill Craig (URS) called Jim to determine the method and equipment used to ship freight to/from Cordova and what would be foreseeable in the event of another large spill in PWS. Jim is an agent for Lynden Transport and Alaska Marine Lines.

Jim said that freight is transported to Cordova by tug and barge from Seattle on a weekly schedule. It takes 6 days from time of departure to arrive in Whittier and 3 more days to arrive in Cordova. Jim said the current system is convenient and efficient and he does not see any need to ship supplies using containerships or other large cargo ships, even in the event of another large spill. He also ships shelf-stable seafood from Cordova using the same system.

Jim said the barges used are 400’ by 100’ with a 12’ draft. One of the tugs used is the Gulf Titan, which is 112’ by 35’ with a 20’ draft; other tugs in their fleet draw similar or less water. Lynden’s website at http://www.lynden.com/aml/flooteq.html provides vessel characteristics for their fleet. He does not see any major changes in the size or draft of this equipment in the foreseeable future. He said their current requirements for accessing their facility on the north containment fill dock is a tide stage of +4’. He also mentioned that vessels that draft more than 30’ cannot access Cordova.

Jim also said there is land available near their facility for staging the oil spill response equipment that would be close enough to the dock that it could be handled with a forklift. The current location for the SERVS equipment depot is distant enough that it is first loaded onto truck, unloaded at the dock and then loaded onto vessels.

Jim said that in the event of another large spill, equipment and supplies could be trucked to Valdez or Whittier from the west coast and would arrive in approximately 3 days. They would then be shipped via barge or landing craft to the location where needed, including possibly Cordova.


http://www.lynden.com/aml/flooteq.html


DATE: 4/23/04 TIME: 9:10 JOB NO.: 26219634


TALKED WITH: John Kotula OF ADEC Spill Prevention and Response –

Valdez





We went through the following questions, which we posed to John in our letter to him dated April 21, 2004.

1. What is your role in response preparedness in the area? Answer: He supervises implementation of the Contingency plan for crude oil carriers in State waters. His jurisdiction would apply to spills in State waters and other spills that threaten to migrate to State waters.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answer: John stated that current response capability in PWS and Cordova meet the response planning standard, although there is always room for improvement. Much more equipment is currently maintained in Cordova than other communities since it is the homeport of the majority of the fishing vessels that would be used to respond.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Answer: Out of region equipment would be mobilized by cargo jet aircraft from around the world. He said that some equipment would require assembly/setup prior to loading onto vessels and it would be nice to have shelter to perform this. He said that supplies required for a long term response would probably go through Seward or Kodiak, maybe by barge, and the use of Cordova for out of region mobilization is probably low.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Answer: ADEC relies on fishing vessels, primarily bowpickers and seiners and 129 are under contract in Cordova; there are also many other vessels that could be contracted/trained if needed. He does not envision larger response vessels being stationed in Cordova.


5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answer: From his responsibility he sees no cost or benefit from consolidating. As far as locations go, he would recommend having fuel and housing nearby.


• Staging area size. Answer: Must be large enough to sort/assemble equipment.

• Dock dimensions. Answer: Vessels range from 26’ to around 50’; he recommends something large enough to dock four vessels at once.

• Weight and size of material to be moved over the dock. Answer: Consider that it will probably be on pallets and will be deck loaded on fishing vessels (seiners).

• Equipment and storage facilities that should be located at the site. Answer: Should have cranes, forklifts, and truck space to move and sort equipment. Covered storage space would be ideal.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: Would be nice to have a covered area to work out of rain and snow. When asked, he said there was no need to treat/store recovered oil and water in Cordova.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answer: Equipment has to be accessible 100% of the time. As far as tide delays, he said some delay would be acceptable for the deepest draft response vessels, but fishing vessels must be able to access at all tides.

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answer: Spill response has to have priority over other uses. Other uses are OK, there just cannot be delays in response.

Note: John is responsible for crude oil spill preparedness only. For non-crude spills, he recommended talking to Leslie Pearson, Bob Drier, or Robert Valesterous. URS will contact these people.



DATE: 4/23/04 TIME: 9:40 JOB NO.: 26219634


TALKED WITH: Melissa Kompkoff OF Cordova District Fishermen United





We went through the following questions, which we posed to Melissa in our letter to her dated April 21, 2004.

1. What is your role in response preparedness in the area? Answer: Her responsibility is to ensure that fishing vessels are ready and crews are trained. She has this responsibility only to SERVS; she believes Native Village of Eyak may also have vessels for other spills.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answer: She would like to see equipment consolidated, particularly the SERVS connexs on the North Fill and the minibarges on the ferry dock.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Not discussed.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Answer: SERVS uses the 500-2 barge to bring equipment to Cordova.

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answer: She recommended considering something midway between Shepard Point and Cordova, discussed use of smaller jet bowpickers to respond to the Copper River Delta on most tides. Seine boat sized vessels would also be used on the flats except they would have to time the tides.


• Staging area size. Answer: She did not have any recommendations.


• Dock dimensions. Answer: She did not have any recommendations.

• Weight and size of material to be moved over the dock. Answer: She did not have any recommendations.

• Equipment and storage facilities that should be located at the site. Answer: She did not have any recommendations.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: She had no additional recommendations here, she stated she was very pleased with current response capability.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answer: Melissa is concerned about road access due to avalanche hazards. She would like to see someone housed at Shepard Point if it is built there.

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answer: She could not think of any acceptable or unacceptable uses. She is in favor of it being a multipurpose facility.



DATE: 05/03/04 TIME: 9:50 JOB NO.: 26219634


TALKED WITH: Lou Bodry OF PWS RCAC




ITEMS DISCUSSED: Bill Craig of URS received a call from Lou to discuss function and engineering criteria for Cordova Oil Spill Response Facility.

We went through the following questions, which we posed to Nancy Bird of PWC RCAC in our letter to her dated April 20, 2004. Nancy Bird copied Lou.

1. What is your role in response preparedness in the area? Answer: Lou is an RCAC board member and is on the finance committee and dispersants working group. He has also recently been appointed to the AK Regional Response Team, a group that supports the on scene federal coordinator.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answer: Cordova has a good location geographically, a great airport and also has most of the PWS fishing fleet which would be pressed into service in the event of a big spill. Cordova is the closest community to the CR Delta.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Answer: Out of region cargo jet aircraft would mobilize equipment. Supplies shipped by vessel would not be urgent and could use ferry dock.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Answer: SERVS and fishing vessels.

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answer: There are pros and cons regarding consolidating. Lou does not think it should all be placed at SP due to avalanche hazards. Having equipment spread out is OK, just so long as people know where the equipment is and vehicles are available to transport to waterfront.



• Staging area size. Answer: Lou did not provide recommendation.

• Dock dimensions. Answer: The dock should accommodate more than a few vessels, one tender and three or four fishing boats, for example. The dock could be a big bottleneck if not large enough.

• Weight and size of material to be moved over the dock. Answer: Lou did not provide recommendation.

• Equipment and storage facilities that should be located at the site. Answer: The facility should have dock mounted cranes such as the crane in the small boat harbor. It would be nice to have a roof over the staging and sorting area, it would not have to be an enclosed building.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: They need a scaled down version of the Valdez operations center with high speed internet connections.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answer: Lou said it would be nice to have 24/7 access but some tide delays would be OK since they would only be for a few hours at a time. He is concerned about the proposed Shepard Point road since it could be closed for a week or more if there is no way to shoot down avalanches.

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answer: He likes the idea of a multipurpose dock but other users must be able to clear their activity quickly. Lou is a seiner and he gave an example of someone laying out a seine for mending and not being able to clear it in time to load the fishing vessels. Lou suggested that other uses of staging area need to be out of the way and clear access to equipment and the dock needs to be maintained. He said the facility should have an ops plan to outline compatible uses.


April 27, 2004 Nancy Bird Responses to URS Letter Dated April 20, 2004 Cordova Oil Spill Response Facility

1. What is your role in response preparedness in the area? As a Board member for PWS RCAC (representing the City of Cordova), I understand my role in response preparedness is to review and critique current response plans. During an actual spill event, I believe my chief responsibility/role would be to facilitate good communications/issues I may hear about to the RCAC staff and appropriate Coast Guard and EPA authorities.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? It’s an indirect relationship; I want to ensure that there is adequate response equipment and plans in place and a Cordova facility is one part of that puzzle. The current system, while a dramatic improvement from 15 years ago, could be enhanced by the development of a deep water port that – in combination with Cordova’s airport – could provide better access for large quantities of additional equipment that may be required in a major oil spill event.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Assuming this equipment is arriving via air, truck transportation will be required from the airport – 13 miles from downtown Cordova - to the Cordova facility. From the Cordova facility to the actual response site will require fishing vessels and/or barges, tugs or SERVS vessels.

4. What are the characteristics or existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport and other pertinent details of representative vessels? To the best of my knowledge, currently vessels retained by SERVS for oil spill response range in size from approximately 24-28 feet (mostly bowpickers) to limit-seiner size vessels of 58-feet in length. Drafts for these vessels probably range from 3 feet to 8 feet. Cordova District Fishermen United should be able to provide pertinent details. Additionally, of course, there are all of the SERVS vessels. I’m not aware of a need to accommodate even larger vessels than these.

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? I do not consider it advisable to consolidate all oil spill equipment in one area for several reasons: primarily (1) in the event of natural disaster, i.e., an earthquake or avalanche, it would be helpful to have several locations of response equipment because one area might be unreachable while another may still be reachable; (2) in the event of smaller oil spills, it might be easier and allow for a faster response to oil response equipment if this equipment is located in several storage locations.

I recognize there is a drawback to having equipment in several locations when a larger spill occurs and all the equipment is needed. However, it is a two-edged coin and, due to the high risk of both a major earthquake and the avalanche danger along the north

April 27, 2004 Nancy Bird Responses to URS Letter Dated April 20, 2004 Cordova Oil Spill Response Facility

end of Orca Road (beyond the current Orca Adventure Lodge), I strongly support a diversification of storage units for oil spill response equipment.

6. Do you have any recommendations for the following specific features? • Staging area size • Dock dimensions • Weight and size of material to be moved over the dock • Equipment and storage facilities that should be located at the site

No, I don’t have any expertise in this area.

7. What needs might be covered by this facility that are currently not available at SERVS? In the event of another Exxon Valdez size spill, Cordova’s airport and the local vessel fleet would provide incredible access for moving large amounts of equipment required to respond. Also, in the event of a spill or vessel problem in the mid-Sound and/or through Hinchinbrook Entrance, Cordova’s airport is more accessible even in bad weather than Valdez.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? The road does not need to be drivable at all times nor does the channel need to accommodate absolutely every vessel at all times. We live in a very extreme environment part of the year and we must recognize this and live within reasonable limits that promote safety as a highest priority. My support for an oil spill response facility that might be based at Sheperd Point is contingent on the road being closed during periods of avalanche danger. This community has already suffered two deaths due to avalanches. I have learned from those incidents and will do all in my power to prevent further deaths.

9. What other uses of the staging area and/or dock could be allowed without interfering with the primary purpose? There may be some uses that could conflict but so long as all other users are informed that oil spill responders will have first priority for the staging area and dock, I don’t see major conflicts.

April 27, 2004 EPA Responses to URS Letter Dated April 26, 2004 Cordova Oil Spill Response Facility

1. ) What is your role in response preparedness in the area?

• EPA is one of two lead federal agencies for federal oil spill response prevention, preparedness and response as per the National Response System, (NRS) as laid out in the National Contingency Plan, (NCP), 40 CFR300.

• The USCG which is the other lead federal agency is responsible for providing a Federal On Scene Coordinator, (OSC) in the “Coastal Zone while EPA provides the OSC in the Inland Zone.

• In Alaska the Coastal Zone is defined as all marine waters subject to tidal influence and a band of adjoining shoreline extending 1,000 yards inland of the mean high tide line.

• The Inland Zone includes all navigable waters inland of the 1,000 yard boundary with the US Coast Guard. Thus the waters and adjoining shorelines of Prince William Sound and the Gulf of Alaska are considered the “Coastal Zone” for which the USCG is the lead federal agency

• The EPA cooperates with the USCG and provides technical assistance when requested through the Alaska Regional Response Team for planning and preparedness activities in the Coastal Zone including Prince William Sound but is not the primary agency responsible for planning, preparedness and response in this are, our focus is on the Inland Zone and our expertise and response role deals with inland waters oil spill response.

2. ) How do you see a proposed facility in the Cordova Area functioning in relation to your responsibilities in the Region?

• In light of the above discussion this facility minimally impacts EPA’s responsibilities in the Region. As stated above our agency’s role is with inland waters oil spill response. Our understanding is that this facility is planned to support spill response in the marine / coastal zone in the area of Prince William Sound and Cordova.

3. ) What modes of transportation should the proposed facility accommodate for out of Region equipment arriving in Cordova prior to deployment to the response site ( including resupply)

• Considering that Cordova is accessible only by air or vessel the facility should be prepared to unload and reload equipment from bags , response vessels and cargo ships as well as have road access to the Cordova airport.

4. ) What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate.?

• In view of EPA’s area of focus and expertise we recommend that you consult with personnel with the US Coast Guard, Marine Safety Office Valdez, ( Commanding Office Commander Mark Swanson) the Alaska Department of Environmental Conservation , Spill Preparedness and Response ( John Kotula & John Engles) the Pronce William

April 27, 2004 EPA Responses to URS Letter Dated April 26, 2004 Cordova Oil Spill Response Facility

Sound Regional Citizens Advisory Council, ( Joe Banta) and Alyeska Pipeline Service Company , Ship Escort and Response Vessel System.

5. ) Is it advisable to consolidate all of the existing oil spill equipment under different ownership into one area?

• There are advantages as well as disadvantages from such an undertaking. Appropriate agreements covering access, use, liability, maintenance, etc. would need to be worked out among equipment owners. Some equipment which individual companies and facilities own and m maintain may be required for immediate access and use which would need to be evaluated prior to pooling the equipment. Participating equipment owners would need to evaluate if the arrangement could meet their individual needs while obtaining some economy of scale savings in storage, maintenance, etc.

6. ) Do you have any recommendation for the following specific features ?

• Same as answer # 4.

7. ) What needs might be covered by this facility that are not currently covered by SERVS?

• Spill response for non TAPS trade spills, i.e. spills originating from cargo vessels, fish tenders, private vessels, etc.

8. ) What are your recommendations for the minimum reliability standards for marine and road access to the facility, etc?

• Again I’d defer to the primary response agencies and stakeholders but it would appear that for the facility to be an effective response depot access must be available on a 24 / 7 basis year round.

9. ) What other uses of the staging area or dock could be allowed without interfering with its primary purpose?

• Rather than specifying individual activities I would suggest that criteria be established based upon the primary use of the facility , i.e spill equipment storage, stagging and mobilization, for use in evaluating if secondary activities would pose a conflict. This criteria could include questions such as ability to clear or remove obstacles associated with a proposed secondary activities.


DATE: 5/13/04 TIME: 4:30 JOB NO.: 26219634


TALKED WITH: John Leclair, Robert

Ballesteros OF Chadux, ADEC




ITEMS DISCUSSED: Bill Craig of URS meant with John Leclair of Chadux and Robert Ballesterous of ADEC after Chadux completed an oil spill response drill in Cordova. The purpose of the meeting was to discuss function and engineering criteria for the Cordova Oil Spill Response Facility.

We went through the following questions, which we posed to John Leclair in our letter to him dated April 21, 2004.

1. What is your role in response preparedness in the area? Answer: Chadux is an oil spill, response/cleanup cooperative. Orca Oil is a member of the coop. Robert Ballesteros is with Alaska DEC, Division of Spill Prevention and Response.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answer: They see the facility as a place to stage equipment, receive equipment, and ideally providing some indoor storage space.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? In almost all instances, equipment would arrive by air to Cordova. Only for a very large spill would equipment be shipped to the region by large ocean going vessels since it would be faster to truck equipment from the lower 48 to Valdez for deployment.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Answer: Fishing vessels, barges, landing crafts, skimmers such as the Valdez Star, USCG Cutters, and the State Ferry Kennecott.

5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answer: Chadux felt that consolidating equipment is not always a good idea, and said that they would probably


continue to store their equipment at Orca Oil. DEC liked the idea of consolidating equipment since everyone would know where to go to access equipment when spills occur.


• Staging area size. Answer: They did not have any specific size in mind but said that an area the size of the ferry staging parking lot out to the fuel dock would be ideal. They also said it should be paved.

• Dock dimensions. Answer: They did not have any recommendations.

• Weight and size of material to be moved over the dock. Answer: Loaded connex containers.

• Equipment and storage facilities that should be located at the site. Answer: Dock cranes, storage tanks for recovered product, freshwater, launch ramp, and electricity.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: Chadux felt it would be good to have some storage tanks for recovered product. They pointed out that product from small spills would be placed in portable bladders and product from very large spills would be placed in the SERVS barges. They recommended storage space of 25,000 gallons to handle the mid-sized spills. They also would like to have access to a separator for treating recovered product.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answer: Chadux and DEC felt that the road had to be accessible at all times and that tide delay for the largest vessels is acceptable.

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answer: They supported multi-use but cautioned that the other uses would probably not be able to use the facility during a response. This could be a burden to a business that that was relying on use of the facility but could not for an extended period during a protracted cleanup effort.

Note: Chadux and DEC felt strongly that the facility should be as close to Cordova as possible to most efficiently rely on lodging, restaurants, and support services such as fuel. They felt access to deep water was not as important as the benefits afforded by being close to town.



DATE: 4/23/04 TIME: 10:20 JOB NO.: 26219634


TALKED WITH: CMDR Mark Swanson OF US Coast Guard Valdez

NATURE OF CALL: INCOMING X OUTGOING PHONE # 835-7210




We went through the following questions, which we posed to Commander Swanson in our letter to him dated April 21, 2004.

1. What is your role in response preparedness in the area? Answer: He would be the Federal on-scene coordinator, responsible for ensuring compliance with National Contingency Plan.

2. How do you see a proposed facility in the Cordova area functioning in relation to your responsibilities in the region? Answer: PWS region is hampered by weather and transportation inefficiencies. Whittier is now available to vehicle traffic but is distant from the shipping lanes and from southern PWS. He likes the idea of connecting Cordova’s all-weather airport with a true deepwater port. During a significant spill, a lot of resources could be brought into the southern portion of PWS by boat or by air. Valdez is a big facility with deepwater docks but is far from SE PWS and does not have a good airport. Better aircraft to barge/response vessel system infrastructure would be helpful.

3. What modes of transportation should the facility accommodate for out-of-region equipment arriving in Cordova prior to deployment to the response site (including resupply)? Answer: Aircraft primarily, and also by boat. Container barges are used now; he doesn’t know if container or cargo ships would be likely to call on Cordova.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? Can you provide the length, draft, beam, name, homeport, and other pertinent details of representative vessels? Answer: There is a proposed rule making in the works since OPA 90 to require capability for salvage operations and fire fighting response. He does not know the specific characteristics of these salvage or fire fighting vessels. He mentioned SERVS vessels and that the Coast Guard has the buoy tender Sycamore stationed in Cordova. He will determine the draft of the Sycamore and provide to us.


5. Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? Answer: He sees the facility more to respond to large spills. The Coast Guard currently has a connex staged near the small boat harbor and an MOU with the Native Village of Eyak to respond to diesel spills from vessels in the harbor. He would not like to see this equipment moved. It would be better to have equipment scattered and easily accessible to areas with high spill potential.


• Staging area size. Answer: He did not have any recommendations.

• Dock dimensions. Answer: He did not have any recommendations.

• Weight and size of material to be moved over the dock. Answer: Would be limited to what would fit on a plane.

• Equipment and storage facilities that should be located at the site. Answer: He did not have any recommendations.

7. What needs might be covered by this facility that are currently not available at SERVS? Answer: Dispersant could be relocated to Cordova and made accessible to application by plane or boat.

8. What are your recommendations for the minimum reliability standards for marine and road access to the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water, or would some amount of delay be acceptable? Answer: Road must be plowed in the winter and occasional closures due to avalanche hazards are acceptable considering most roads in Alaska are occasionally closed. Tide delays would be acceptable with 2nd and 3rd tier response vessels; this would be in the noise of logistics. The question would be can a particular vessel access the facility at all?

9. What other uses of the staging area and or dock could be allowed without interfering with the primary purpose? Answer: He said this would be unlimited except that he wouldn’t want a dedicated vessel tied up that would lock it up. Cargo is OK, whatever uses are allowed must be able to clear from the dock quickly. Other uses would help finance O&M costs.

Note: Commander Swanson discussed his ideas on how the project could help him fulfill his other responsibilities; particularly important to him was responding to emergencies in the cruise ship and containership fleets. He talked about the scenario of a cruise ship grounding, break down or fire where thousands of people need to be brought ashore. He said he would like to see a deep water dock in the southern portion of PWS with enough infrastructure to offload and shelter these people and perhaps even use shoreside fire fighting equipment, and Cordova is a logical location. He said we should consider that such a facility could attract problems, such as a vessel leaking oil seeking repairs.

Note: On 4/26/04, the characteristics of the USCG Buoy Tender stationed in Cordova were obtained from the internet (www.uscg.mil/datasheet/225wlb.htm). The Sycamore has a length of 225 feet, beam of 46 feet, and draft of 13 feet.


Niles Cesar, Alaska Regional Director P.O. Box 25520 Juneau, AK 99820 September 13, 2006 Dear Niles: This letter is in response to an email from Kristin K’eit dated September 12, 2006. (Copy attached). It requests a response to a letter dated July 7, 2004 from Bill Craig of URS Corporation to myself. (Copy attached). I have already previously responded to this letter and I informed Mr. Craig that his questions were misleading and missed the point of the project. I will review my previously given information here in the order of questions in his letter.


a. The Native Village of Eyak is a Federally recognized Tribe with 525 members. We are the proposing agency. You have a trust responsibility to protect our members from damage to our resources an our livelihoods by oil spills. You are required by law and have an obligation under the Indian Self Determination Act to advocate for and recognize our interest as a Federally Recognized Tribe and support our requested action of constructing a deep-water port and oil spill response facility at Shepard Point. As an executive branch agency, you have a responsibility to execute the court ordered decree to construct an oil spill response facility at Shepard Point.

Our traditional use area encompasses Prince William Sound, the Copper River and the Gulf of Alaska. A majority of our members are commercial fishermen and we all survive off subsistence resources of this area. We have suffered unmeasurable loss from the Exxon Valdez Oil Spill. Our Village and our members have thousands and thousands of pages of documentation filed with the courts that documents our losses. We request that you review this public documentation so that you will partially understand what we had. And what we don’t have now. And why we are requesting that this long overdue project be completed. Our governmental interest for the well being of our members and the lack of compliance by Alyeska, Exxon-Mobile, the State of Alaska and the Federal Government with the court ordered settlement of the Alyeska and Exxon consent decrees has forced our Village to take an active role in oil spill response. We have also been forced to take a strong advocacy role in insuring that the required oil spill capacity in our area is built and maintained. The Alyeska consent decree orders that a deep-water port and a connecting road be built at Shepard Point and that oil spill response equipment will be pre-positioned at this site. This has not been done and it has been over 10 years since the consent decree was signed. We request the assistance of all agencies involved in the permitting of this project to help us get it built where it is ordered to be built.

b. The Native Village of Eyak members and Tribal Council have been heavily involved in the hopelessly inadequate response and clean up of the Exxon-Valdez oil spill. Our secretary treasurer was one of the first responders on the scene. The tale of woe is more than adequately documented by others. Please review it. Our members and council spent thousands of man-hours working on the clean up. We have suffered losses from destroyed fisheries, destroyed habitat, destroyed economies and destroyed lives. This experience gives us a strong background of what is needed and what is not needed. We need to build the deep-water port and connecting road to Shepard Point. We need to preposition response equipment at this site and we need a trained on call response crew.

c. The Native Village of Eyak has an active response system. We have a Pollution Removal Funding Agreement (PRFA) and a Memorandum of Agreement with the US Coast Guard to respond to oil spills. We have responded to 6 spills since the PRFA was put in place in 2002. We have access to the US Coast Guard emergency response equipment in Cordova and the Alaska Department of Environmental Conservation response equipment. The Coast Guard Equipment consists of two 20-foot connex boxes that hold an inventory of oil containment boom, absorbent boom, absorbent pads, sweep boom, anchors and hardware. The DEC equipment is similar equipment stored in a 40-foot connex box. We have responded to spills in very rough storms and on holidays when no other personnel were available. The Coast guard has given us excellent reviews on our performance and cost effectiveness of responding to spills.

d. We are part of the agency-reporting network on oil spills with the Coast Guard. We have a 24-hour contact list and email list. They report any vessel that may be in danger of or actually discharging pollution into Prince William Sound.

e. We have two remote research camps on the Copper River below Chitina. These camps have 24-hour live satellite communications, Radio communications, personnel and jet boats from May to September. These camps are in a position to provide logistics and communications in a very remote section of the Copper River if a spill on the pipeline ever got into the Copper River. The rest of the year, the river is frozen. The Camps still could be used with helicopter or ski plane access if needed.

2. How do you see a proposed facility in the Cordova area functioning in relation

to your responsibilities in the region? a. We need a deep-water port at Shepard Point, a connecting road and pre-

positioned response equipment. b. NVE has a spill response squad. We have been using borrowed

equipment and volunteers for many years. If we have a facility of our own at Shepard Point, we could have a dedicated crew leader and conduct drills and training at the facility. We would also work with Alyeska to get additional equipment and personnel stationed at Shepard Point so we are prepared.

c. When (not if) the next major spill happens, the deep-water port will provide a staging area for supporting the response effort. Review of the effort put in on the last major spill will give you an idea of the massive logistical effort this is.

3. What modes of transportation should the facility accommodate for out of

region equipment arriving in Cordova prior to deployment to the response site (including re-supply)? a. All existing vessels that currently transit Southeast Alaska, the Gulf of

Alaska, the Bering Sea and Eastern Asia. This includes container ships from Sea-Land, Tote, and Maersk, Alaska Ferry vessels, all SERVS equipment, all fishing vessels, trawlers, catcher processors and factory trawlers, all multi-use vessels that can be converted to oil spill response. Specialized equipment in Alaska, the East coast of Russia, Asia and Japan, Canada and the US, Navy troop ships for housing, cruise ships for housing, and any other vessel of opportunity that is available that can be pulled into service.

b. Modes need to be supported, Land, Sea and Air. c. Flown in skimmers response equipment, boom, tanks, bladders, hoses,

pumps, boilers, fuel, dispersants, cranes, material handling equipment, housing, food, clothing, parts and supplies, personnel, need to be landed at the Cordova Airport and transported to Shepard Point for trans-loading onto spill response vessels, supply vessels, housing vessels and other support vessels.

d. The facility needs to be able to accommodate large container ships, trucks, large forklifts, cranes and all smaller vessels.

e. Skimmers will be flown in and deployed from around the world. Tank vessels of opportunity will be taken and placed in service to hold recovered oil.

4. What are the characteristics of existing and foreseeable future oil spill response vessels that the facility should accommodate? a. See #3 above. Can you provide the length, draft, beam, name, homeport or other pertinent details of representative vessels? a. SERVS Fleet, maximum draft 38 feet, max length 400 feet, Container

ships for supply operations up to 70 feet draft length 900 feet, Cruise ships for housing vessels up to 60 feet draft length 600 feet, Tank vessels of opportunity draft up to 60 feet, length up to 600 feet. Navy troop ships up to 30 foot draft 600 feet. Look on the Internet and consult other international oil spill response providers. There is a growing fleet of multi-purpose and single purpose oil spill response vessels in the international fleet especially in the North Sea that are high capacity and designed to work in heavy weather. These have drafts up to 40 feet.

Is it advisable to consolidate all of the existing oil spill equipment under different ownership in one area? b. What do you mean? What are you trying to get at? Where is it now?

Do you anticipate that any locations in the study area would detract from the capability to respond to spills under your jurisdiction? c. All alternatives except Shepard Point. See NVE comments on the EIS at

all stages of its preparation. All other alternatives than Shepard Point require additional 8-10 miles transit distance to get from the tanker lanes to a re-supply point. All other alternatives than Shepard Point require transiting a narrow shallow channel with strong currents and won’t handle the larger vessels. They would have to anchor at Shepard point.


Staging Area Size a. 10 Acres. This is what is needed to accommodate pre-positioning of

planned equipment, staging and sorting for a 400 foot barge and to allow for traffic congestion of re-supply, fueling, material handling, equipment parking, personnel vehicles etc. The proposed 3 acre staging area is too small.

Dock dimensions b. Capable of handling a 600-foot ship with a 40-foot draft. See 1996 PND

Site Suitability Study for Shepard Point. The proposed design depth is too shallow.

Weight and size of material to be moved over the dock c. Oil Skimmers, all standard shipping containers up to 54 feet, skimmers

response equipment, boom, tanks, bladders, hoses, pumps, nozzles, boilers, fuel, dispersants, cranes, material handling equipment, housing modules, housing vessels, food, clothing, parts, supplies, personnel, sewage waste trucks, generators, fuel, pipe, engines, air compressors, heavy equipment, loaders, dozers, cranes, recovered oil.

Equipment and storage facilities that should be located at the site. d. Pre-positioned oil spill response equipment in shipping containers. Office

and communications shack, sanitary facilities, power, telephone, computer, large loader with changeable container forks and snow bucket.

6. What needs might be covered by this facility that are currently not available at

SERVS a. The ability to store pre-positioned oil spill response equipment at Shepard

Point. b. The ability to re-supply a massive logistics effort from Shepard Point

saving 10 miles of transit time in shallow water up Orca inlet.

c. The ability to dock deep draft vessels at Shepard Point and connect by road to the Cordova Airport for re-supply operations.

d. The ability to bring Alyeska (which is SERVS sole customer) into compliance with court ordered construction of a required oil spill response facility.

e. The reason this facility is being ordered is because Alyeska was grossly inadequate in its response and criminally unprepared for the last spill. Why is SERVS, which reports to Alyeska, being used as a benchmark? What is Alyeska’s previous track record? What is the current track record of BP on its feeder lines? Its time someone listened to the people being affected and enforcing the required minimum protection the court has ordered more than 10 years ago. Who will suffer if the facility at Shepard Point is not built? Who benefits?

7. What are your recommendations for the minimum reliability standards for

main and road access for the facility? For example, does the road need to be drivable at all times or can it be closed during periods of avalanche danger? a. The facility should be available at all times. Is there any facility available

at all times anywhere in Alaska? Is there an avalanche chute at 5 mile? Has an avalanche here closed the road in the last 10 years? How long did it take to open it up? Was it in a few hours? Were there other chaotic activities going on at the same time? Did we work it out? Why isn’t this avalanche chute, which affects all alternatives, questioned and the avalanche chute at Shepard Point is? Is this a bias? The avalanche chutes at Shepard Point will need to have a gun mount and an avalanche control program. Just like, other well traveled roads in Alaska that provide emergency response like the Richardson Highway at Thompson Pass, the Seward Highway at Turnagain Pass and many others.

Does the channel between PWS and the dock need to be deep enough to pass the deepest vessels at all stages of the tide, including extreme low water or would some amount of delay be acceptable? b. This in an emergency response facility. We need to be ready for

emergencies. We don’t know what, when or how the emergency will present itself. We do know it will require urgent rapid action with all equipment we can get access to as quickly as we can get going. Why is this question even being asked? Is this providing deliberate bias into the study? To answer the question, we must have access at all tides with all equipment that meets the design criteria. This is a requirement of at least a -35 MLLW depth at the dock and -40 MLLW clear channel to sea. It would be a lot better if it were a -50 MLLW dock depth and -60 MLLW clear channel to sea. Shepard Point can provide this increased capacity at no incremental cost. No other alternative comes close. Would you design a fire department in such a way that you could only get your largest fire trucks out of the fire hall at high tide twice a day? Who comes up with this stuff?

c. We believe this is a misleading question allowing existing carriers with economic conflicts of interest to side step the issue of a design requirement for a deep water port.

8. What other uses of the staging area or dock could be allowed without

interfering with the primary purpose? a. If you build a 10-acre staging area, other boat repair, haul out, storage,

shipping and receiving could be done. Possibly a ferry terminal, lease to a navy or coast guard or commercial ship, etc.

b. If you have a 3-acre staging area, you are going to have a tough time doing much other than oil spill response equipment storage and training.

If you have any questions, please give me a call. Sincerely: NATIVE VILLAGE OF EYAK Bruce Cain, Executive Director

Added in e-mail message of 9/14/06 In my response information sent last night, also note the following. The six oil spills that the Native Village of Eyak has responded to since 2002 were real live actual spills that we cleaned up. We were called out and responded, picked up equipment and cleaned up the spills. These were NOT drills which is the only experience the SERVS fleet can claim. We don't talk, we act. All of the call outs we have received was because no one else would respond or provide information to the Coast Guard, including the City of Cordova. We have responded in storms, and on holidays and when no one else would go. We have many similar stories on our responses which have been marine based, in high currents in open water, in slack water in the harbor, on a lake, in a creek, and on land. We are here protecting our area no matter what needs done. The others probably won't be. A typical example is as follows: On a typical day with tons of projects on our schedule, I got a call. Members of the SERVS fleet and a board member of CDFU was in our office. The call was from the Coast Guard to check out a reported spill in a creek. The SERVS fleet and CDFU board member suddenly had other things to do and took off. We never saw him again for the two weeks we spent on the clean up. NVE responded to the spill with re-assigned staff, council members and volunteers. We located the source of the leak, notified the owner who dug up the tank and replaced it and we placed boom and sorbent in the creek and maintained it for two weeks. We did not bill anyone for this response, we just did it because it had to be done. The so-called experts consulted in the study talk a good talk when there is money to be made doing mock training exercises in their own subsidized boats in a clean environment on a convenient preplanned schedule. However, when there is real dirty work to be done on a holiday, in a storm or in a place where you have to think, react and respond, they are not going to be there. We are. We have proven it. We deserve credibility in our recomendations. The others are just for show. Bruce Bruce Cain Executive Director Native Village of Eyak PO Box 1388 Cordova, AK. 99574 Ph (907) 424-7738 Fax (907) 424-7739

Attachment 1 to NVE Correspondence of September 13, 2006. 9/12/2006 Kristin K'eit writes: Bruce, I'm glad you and Vijai were able to talk recently. As you two agreed, we would like to receive NVE's response to consultation regarding NVE's expertise with oil spill response in Prince William Sound. Attached are the questions provided to all spill responders. I will be prepared to take your responses by phone at work today or almost anytime this week that will work for both of us. You may also provide responses via email/fax. Whichever you prefer. Kristin K'eit Attachment 2 to NVE Correspondence of September 13, 2006. Letter from URS Corporation to NVE, dated July 7, 2004, requesting input on oil spill response preparedness and planning.

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