When USS Greenville collided with Ehime Maru, the Japanese fishing vessel quickly sank, releasing an oil slick estimated by the US Coast Guard (USCG) to contain from 500 to 20,000 gallons of oil. No effort was made to contain or recover the oil at sea. The priority at the time was saving lives. In addition, the prevailing trade winds moved the slick further offshore and caused the relatively light diesel oil to naturally disperse without threatening any sensitive resources.

The Navy learned that at the time of the collision, Ehime Maru had approximately 65,000 gallons of fuel (marine diesel) and approximately 1,200 gallons of lubricating oil on board, in addition to very small quantities of kerosene, paints, solvents, and various compressed gasses. In planning the recovery operation, salvors addressed a potential "worst case spill" of 45,000 gallons, but assumed much less oil remained onboard. In terms of potential environmental impact, it is significant that the Navy intended to move Ehime Maru and remaining onboard pollutants from a deepwater offshore location to a shallow near-shore location. The potential pollution source was to be relocated from an area of relatively low environmental sensitivity to an area of relatively high environmental sensitivity virtually on the shores of Oahu.

For legal reasons beyond the scope of this article, the Ehime Maru operation was considered a proposed federal agency action that required the Navy to prepare an Environmental Assessment (EA) and conclude a Finding of No Significant Impact (FONSI) before initiating the operation. The bottom line was that ADM Fargo, CINCPACFLT, went on record up front by stating that the Navy salvors would not significantly affect the environment while conducting the Ehime Maru operation. The environmental protection "mitigation measures" described in the EA (the use of helicopter surveillance, oil containment booms, oil skimmers, dispersants, etc.) were a rigidly pre-established requirement. In addition, the ten-week EA process involved extensive Navy coordination with various federal and state trustee agencies, so the salvors were under much greater trustee scrutiny than would normally be the case.

Various federal laws and regulations, including the National Oil and Hazardous Substance Pollution Contingency Plan, prescribe how to respond to OHS spills in US waters. OPNAVINST 5090.2B assigns responsibilities and provides guidance for Navy compliance with these federal and state laws and regulations. As a minimum, what Navy divers and salvors need to know is:

1. It's illegal to spill or release OHS into US waters (even during salvage operations).
2. If OHS is released into the water, it must be reported to federal and state authorities.
3. The spiller must clean up the spill.
4. Federal and state On-Scene Coordinators (FOSC and SOSC) have authority to terminate or take over your salvage and clean-up operations if you do not protect the environment in accordance with applicable laws and regulations.
5. Other federal and state "trustee" agencies have regulatory authority to protect various sensitive resources and may insist upon reviewing Navy salvage plans and overseeing operations.
6. Most federal and state agency personnel are trained to participate in joint multi-agency operations under the National Interagency Incident Management System Incident Command System (ICS). They expect the Navy to be familiar with the ICS project management process.
7. Finally, and here's the good news, Navy On-Scene Coordinators (NOSCs) have been pre-assigned for all Navy operating areas to coordinate Navy environmental protection efforts and to provide liaison with federal, state, and foreign government authorities on environmental issues.

Navy salvage authorities should coordinate marine salvage planning and operations with the cognizant NOSC. If necessary, the NOSC can facilitate salvage operations by mobilizing spill response resources from Navy, other government agencies, or commercial sources, as for the Ehime Maru operations.

Response Organization
The organizational structure for Ehime Maru operations was a hybrid of the ICS to address multi-agency environmental concerns and the standard Navy operational structure for the overall recovery operation. Briefly stated, CINCPACFLT directed the operation, with the Supervisor of Salvage (SUPSALV) providing Navy salvage contractor support for Ehime Maru lift and relocation, and Mobil Diving and Salvage Unit One (MDSU ONE) providing diving services at the shallow water site. RADM Klemm from the CINCPACFLT staff directed the overall Navy recovery operation and was Incident Commander for the ICS organization.

As one of three members of the ICS Unified Command, RADM Klemm coordinated with the USCG FOSC and the SOSC from the Hawaii Department of Health on all decisions affecting environmental protection efforts. The Unified Command, at the top of the ICS organization, provides a command structure that recognizes the responsibilities and authorities of all three government officials under applicable environmental law. Under the standard ICS organizational structure, marine salvage efforts are directed within ICS two organizational levels below the Unified Command.

For these operations, the USCG FOSC allowed recovery efforts to be managed external to the ICS structure, perhaps because RADM Klemm headed both recovery and environmental protection organizations and ensured close Navy coordination with federal and state agencies. The control of marine salvage operations under the ICS Unified Command, when there is significant risk of serious environmental impact, is an open and potentially troubling issue for Navy salvors. It is important to understand the issues and recognize the legal authorities and responsibilities of the FOSC, SOSC, and the various trustee agencies. A little cooperation and diplomacy could prevent an operation from being prematurely terminated or taken out of your hands. The pre-designated NOSC should be the liaison in these matters.

Due to the nature and scope of the Ehime Maru operation, CINCPACFLT, as the Area Environmental Coordinator over all NOSCs in his Area of Responsibility (AOR), assumed the NOSC responsibilities from the subordinate Regional Commander NOSC. CINCPACFLT was fortunate to have a highly experienced former NOSC representative from Commander Naval Region Hawaii, on his staff. She became RADM Klemm's Deputy Incident Commander under the ICS organization, directing environmental protection operations.

Environmental Protection Plan:
The greatest risk to the environment during Ehime Maru recovery was the potential for release of remaining diesel fuel. With the ship in 2,000 feet (600m) of water, there was no practical way to quantify the actual oil spill risk or to remove remaining oil prior to moving the vessel. The Navy assumed a worst-case spill of 45,000 gallons of diesel fuel. The mitigating measures prescribed in the EA for this worst-case spill included helicopter surveillance, up to four offshore oil skimmer systems, several thousand feet of containment boom, and a dispersant capability. These resources were kept in ready standby at the pier or deployed for on-scene standby, depending on anticipated risk during the four key phases of the recovery operation.

Under OPNAVINST 5090.2B, SUPSALV is responsible for providing offshore and salvage-related spill response equipment to Navy operational commanders. At the request of the NOSC, SUPSALV offshore spill response equipment and contractor personnel from the Emergency Ship Salvage Material (ESSM) system were mobilized to implement the environmental protection plan. CINCPACFLT contracted for the services of the local commercial industry oil spill cooperative, Clean Islands Council, to provide an additional Oil Spill Response Vessel (OSRV) and the necessary dispersant capability.

Dispersants are chemicals that may be applied to a floating oil slick to break up the slick and disperse the oil as tiny droplets into the water column. Dispersant use in US waters remains controversial, but the USCG FOSC had authority to approve their use if the booms and skimmers failed to adequately protect sensitive Hawaiian resources.

Other environmental concerns addressed in the EA and impacting recovery operations included physical damage to sea grass and coral at the SWRS due to vessel anchors and mooring systems, displacement of sea turtles and other endangered or threatened species due to recovery activities at the SWRS, casualty or salvage debris such as cargo nets or fishing gear left on the bottom that could entrap marine life, and introduction of alien (non-indigenous) species to Hawaiian waters on hulls or in the ballast waters of diving and salvage platforms mobilized from foreign waters. These concerns were addressed through mitigation measures prescribed in the EA and through the on-going coordination of the NOSC with trustee agencies.

Protection Plan Implementation
The Ehime Maru environmental protection plan was implemented as planned. As expected, very little oil remained onboard due to collision damage and probably also due to partially filled tanks being crushed as the vessel rapidly descended. Very little oil was released to the environment during recovery operations. Oil that was released formed very light sheens on the surface that rapidly dissipated naturally.

The EA specified that, prior to final relocation to deep water from the SWRS, remaining OHS would be removed "to the maximum extent practicable," with diver safety the overriding concern. SUPSALV ESSM personnel developed an oil removal plan for Ehime Maru and assembled prototype systems tailored to the requirement. MDSU One divers operated these systems with topside support from ESSM personnel. The systems included a mini-hot tap for through-hull access to fuel tanks, a diver-held suction wand for overhead removal of oil from vessel spaces, a topside sampling and distribution manifold, and a variety of pumps for various applications. All systems were successfully operated, but very little oil remained to be removed. Small quantities of paint, solvents, and compressed gas cylinders were located but, for safety reasons, these materials were secured in lieu of removal.

Lessons Learned
It is fortunate that nearly all Ehime Maru fuel and lube oil were released well offshore prior to recovery operations and likely caused no significant environmental impact. It is unfortunate but true that this could not have been predicted with certainty prior to the recovery operation. Final hot tapping at the SWRS confirmed that the tanks most likely to contain fuel were in fact open to the sea and contained only seawater. Despite frequent Navy and USCG surveillance overflights, only very low-volume (though frequent) oil sheening was observed throughout Navy operations. The Navy's extensive, and expensive, standby spill response forces recovered virtually no significant volume of oil. Nevertheless, all mitigation measures required under the EA were successfully implemented, and had a large spill occurred, the Navy would have been fully prepared.

The value of Ehime Maru standby spill response operations in terms of Navy preparedness for future marine casualties cannot be overstated. The Navy's next major spill response will likely be a true emergency response requiring mobilization in minutes and hours rather than months. For Region Hawaii's AOR, all elements of a successful major spill response have been properly exercised. Regional Spill Management Team (planning and response) personnel have now worked with and are familiar with most local/regional spill response resources, including SUPSALV's Pearl Harbor ESSM base, the local industry spill cooperative, and the largest regional spill response contractor, as well as several commercial work boat, tow boat, and other marine operations contractors. Valuable, positive working relationships have been forged within the National Response System with the USCG FOSC, the SOSC, and the key trustee agencies.

The environmental messages for the Navy diving and salvage community are:

1. There are rigid prohibitions against releasing OHS into the environment.
2. There is an elaborate National Response System that will be activated should a spill occur during salvage operations in US waters. The situation is similar in most foreign waters.
3. There is a worldwide Navy organization for dealing with Navy environmental issues, and regional Navy On-Scene Coordinators should be involved early in salvage operations planning and notified immediately should a spill occur during salvage operations.
4. There are spill prevention and response tools available to the Navy salvor, including some SUPSALV ESSM systems (such as hot taps) available for operation by Navy divers and salvors. UW