1. Introduction

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1 TABLE OF CONTENTS SEPA EIS FACT SHEET EIS SUMMMARY DRAFT ENVIRONMENTAL IMPACT STATEMENT List of Tables List of Figures List of Acronyms 1. Introduction Project Overview Purpose and Need Project Background Environmental Review Process EIS Scoping Process Draft EIS Preparation, Publication, and Review Final EIS Publication Public, Agency, and Tribal Involvement Federal, State, and Local Permits and Approvals Draft EIS Organization Scope of Analysis Methodology Direct and Indirect Impacts Cumulative Impacts References Proposed Action and Alternatives Overview of Proposed Action Benefits and Disadvantages of Delaying Implementation Proposed Project Location Existing Refinery Design and Operations Existing Refinery Facilities Existing Refinery Operations Proposed Project Proposed Project Facilities Naphtha Hydrotreater Expansion New Isomerization Unit New Aromatics Recovery Unit and New Boiler New Marine Vapor Emission Control System New Tanks Area i

2 2.7. Construction of Proposed Facilities Individual Component Site Preparation and Construction Construction Workforce Construction Vessel Traffic Construction Vehicle Traffic Construction Staging and Laydown Areas Construction Site Controls Operational Changes due to the Proposed Project Vehicle Traffic Marine Vessel Traffic New Materials Used in the Refining Process Increased Material Usage Operational Site Controls Alternatives Considered Technology Alternatives Considered Siting Alternatives Alternative Methods of Transport No Action Alternative Related Actions References Geologic Resources Laws, Regulations, and Guidance for Geologic Resources and Geologic Hazards Study Area and Methodology Study Area Methodology Geologic Resources Affected Environment Potential Impacts on Geologic Resources Potential Impacts of the No Action Alternative Additional Mitigation Measures Geologic Hazards Affected Environment Potential Impacts from Geologic Hazards Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Air Quality and Climate Change Laws, Regulations, and Guidance for Air Quality and Climate Change Study Area and Methodology Study Area Methodology ii

3 4.3. Affected Environment Historical Climate Existing Climate and Meteorology Potential Impacts on Air Quality and GHG Impacts on Air Quality and GHG from Construction Impacts on Air Quality and GHG from Operations and Maintenance Impacts on Air Quality from Vessel Traffic during Operations Impacts on Air Quality and GHG from Spills Impacts on Air Quality and GHG from Spill Response Impacts on Air Quality and GHG from Fuels Conversion to Xylenes Summary of Potential Impacts on Air Quality and GHG Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts on Air Quality Cumulative Impacts on Climate Change Climate Change Project Greenhouse Gas Emissions Cumulative Impact References Freshwater Resources Laws, Regulations, and Guidance for Freshwater Resources Study Area and Methodology Study Area Methodology Surface Water Affected Environment Potential Impacts on Surface Water Potential Impacts of the No Action Alternative Additional Mitigation Measures Groundwater Affected Environment Potential Impacts on Groundwater Potential Impacts of the No Action Alternative Additional Mitigation Measures Wetlands Affected Environment Potential Impacts on Wetlands Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Terrestrial Vegetation and Wildlife Laws, Regulations, and Guidance for Terrestrial Vegetation and Wildlife iii

4 6.2. Study Area and Methodology Study Area Methodology Affected Environment Terrestrial Vegetation Terrestrial Wildlife Potential Impacts on Terrestrial Vegetation and Wildlife Construction Operations Unplanned Events Summary of Potential Impacts on Terrestrial Vegetation and Wildlife Potential Impacts of the No Action Alternative Additional Mitigation Measures Potential Impacts on Special Status Species Species Protected under the Migratory Bird Treaty Act Threatened and Endangered Species (State and Federal) State Sensitive and State Candidate Species Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Marine and Nearshore Resources Laws, Regulations, and Guidance for Marine and Nearshore Resources Water Quality Fish Work Window Compliance Study Area and Methodology Study Area Methodology Affected Environment Ecosystem Overview Protected Areas Special Status Species and Habitats Potential Impacts on Marine and Nearshore Resources Impacts on Marine and Nearshore Resources from Construction Impacts on Marine and Nearshore Resources from Marine Vessels and Operation Impacts on Marine and Nearshore Resources from Marine Spills Summary of Impacts on Marine and Nearshore Resources Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Energy and Natural Resources iv

5 8.1. Laws, Regulations, and Guidance for Energy and Natural Resources Study Area and Methodology Study Area Methodology Affected Environment Electricity Water Natural Gas Gasoline and Diesel Construction Materials Potential Impacts on Energy and Natural Resources Impacts on Energy and Natural Resources Availability or Quality from Construction Impacts on Energy and Natural Resources Availability or Quality from Operations and Maintenance Impacts on Energy and Natural Resources from Spills Summary of Impacts on Energy and Natural Resources Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Environmental Health Laws, Regulations, and Guidance for Environmental Health Study Area and Methodology Study Area Methodology Air Emissions and Health Affected Environment Potential Impacts on Health Potential Impacts of the No Action Alternative Additional Mitigation Measures Traffic Safety Affected Environment Potential Impacts on Traffic Safety Potential Impacts of the No Action Alternative Additional Mitigation Measures Noise Affected Environment Potential Impacts from Proposed Project Noise Potential Impacts of the No Action Alternative Additional Mitigation Measures Unplanned Events Potential Impacts on Health from Fires at the Refinery During Operations and Maintenance v

6 Potential Impacts on Health from Spills Summary of Potential Impacts on Health from Unplanned Events Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Land Use and Shoreline Use Laws, Regulations, and Guidance for Land Use and Shoreline Use Study Area and Methodology Study Area Methodology Land Use and Shoreline Use Affected Environment Potential Impacts on Land and Shoreline Use Potential Impacts of the No Action Alternative Additional Mitigation Measures Recreation Affected Environment Potential Impacts on Recreation Potential Impacts of the No Action Alternative Additional Mitigation Measures Aesthetics and Visual Resources Affected Environment Potential Impacts on Aesthetics and Visual Resources Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Social and Economic Environment Laws, Regulations, and Guidance for Social and Economic Environment Study Area and Methodology Study Area Methodology Housing Affected Environment Potential Impacts on Housing Summary of Impacts on Housing Potential Impacts of the No Action Alternative Additional Mitigation Measures Public Services Affected Environment Potential Impacts on Public Services vi

7 Potential Impacts of the No Action Alternative Additional Mitigation Measures Economic Resources: Employment Income Affected Environment Potential Impacts on Employment Income Potential Impacts of the No Action Alternative Additional Mitigation Measures Economic Resources: Tax Receipts Affected Environment Potential Impacts on Economic Resources: Tax Receipts Potential Impacts of the No Action Alternative Additional Mitigation Measures Environmental Justice Affected Environment Potential Impacts on Minority and Low-Income Populations Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Cultural Resources Laws, Regulations and Guidance for Cultural Resources Study Area and Methodology Study Area Methodology Affected Environment Cultural History Inventory of Resources Potential Impacts on Cultural Resources Impacts on Cultural Resources from Construction and Operations Impacts on Cultural Resources from Marine Spills Summary of Impacts on Cultural Resources Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts References Marine Transportation Laws, Regulations, and Guidance for Marine Transportation Study Area and Methodology Study Area Methodology Summary of Potential Impacts from Spills Vessel Traffic vii

8 Affected Environment Potential Impacts on Vessel Traffic Potential Impacts of the No Action Alternative Additional Mitigation Measures Vessel Safety Affected Environment Potential Impacts on Vessel Safety Potential Impacts of the No Action Alternative Additional Mitigation Measures Marine Spills and Spill Response Affected Environment Behavior of Xylenes and Reformate in the Marine Environment Spill Scenarios and Regulatory Requirements Spill Modeling Assessment Methodology Spill Modeling Results Spill Likelihood Spill Response Summary of Potential Impacts from Spills Potential Impacts of the No Action Alternative Additional Mitigation Measures Cumulative Impacts from Marine Transportation References List of Preparers Distribution List Appendices 1-A, Determination of Significance 1-B, Impact Criteria Tables 2-A, Existing Programs and Operations 2-B, NPDES Permit 2-C, Construction Equipment 2-D, Geotechtechnical Drawings 2-E, Self-Propelled Modular Transporter (SPMT) Drawings 4-A, Ambient Air Quality Impacts Analysis 6-A, Flora Species List for the Proposed Project Area 6-B, Upland Special Status Terrestrial Vegetation And Wildlife Species 10-A, Skagit County Industrial Land Study 12-A, Historical Assessment and Archeological Resources Technical Memorandum 12-B, Unanticipated Discovery Plan for Cultural Resources 13-A, Fate and Behavior Analysis in the Marine Environment: Reformate and Mixed Xylenes 13-B, Chapter 13 Figures viii

9 LIST OF TABLES Table 1-1: Federal, State, and Local Permits and Approvals Table 1-2: Reasonably Foreseeable Future Projects and Actions Identified for Cumulative Impacts Analysis Table 2-1: Components of Reformate and Mixed Xylenes Table 2-2: Overview of Each Proposed Project Component Table 3-1: Laws, Regulations, and Guidance for Geologic Resources Table 3-2: Summary of Potential Impacts on Geologic Resources Table 3-3: Summary of Potential Impacts from Geologic Hazards Table 4.0: Air Quality Area Designations Table 4-1: Laws, Regulations, and Guidance for Air Quality and Climate Change Table 4-2: Ambient Air Quality Standards in Washington Table 4-3: Toxic Pollutant Acceptable Source Impact Levels in Washington Table 4-4: Annual Average Temperature, Humidity, Precipitation, and Wind Speed Data for Seattle, Spokane, Yakima, Walla Walla, and Quillayute Table 4-5: Recorded Severe Weather Occurrences for Washington ( ) Table 4-6: Estimated Construction Emissions Table 4-7: Proposed Project Emissions Table 4-8: PSD Permit Modeling Results Table 4-9: Northwest Clean Air Agency Modeling Results Table 4-10: Toxic Air Pollutant Modeling Results Table 4-11: Summary of Annual Estimated Greenhouse Gas Emissions Table 4-12: Vessel Shipments Emissions Table 4-13: The Proposed Project s GHG Emissions Reduction Credit Table 4-14: Summary of Potential Impacts on Air Quality Table 4-15: Proposed Project GHG Emissions Change Table 5-1: Laws, Regulations, and Guidance for Freshwater Resources Table 5-2: Overview of Surface Type and Drainage of Each Proposed Project Component Table 5-3: Stormwater Drainage Ditches in the New Tanks Area Table 5-4: Percentage Change Relative to Refinery Boundary and Developed Areas Table 5-5: Summary of Potential Impacts on Surface Water Table 5-6: Summary of Potential Impacts on Groundwater Table 5-7: Summary of Wetlands Located in the Proposed Project Area Table 5-8: Summary of Potential Impacts on Wetlands Table 6-1: Laws, Regulations, and Guidance for Terrestrial Vegetation and Wildlife Table 6-2: Desktop Sources Used to Identify Special Status Species for Further Consideration Table 6-3: Landcover Types within the Proposed Project Area Table 6-4: Wildlife Habitat Resources Table 6-5: Migratory Birds Protected under the Migratory Bird Treaty Act Table 6-6: Threatened and Endangered Species (State and Federal) Table 6-7: Other Special Status Species Table 6-8: Summary of Potential Impacts on Terrestrial Vegetation Table 6-9: Summary of Potential Impacts on Terrestrial Wildlife Table 7-1: Laws, Regulations, and Guidance for Marine and Nearshore Resources Table 7-2: Washington State Surface Water Quality Criteria Marine Table 7-3: WDFW and USACE In-water Work Windows Table 7-4: Key Terms Table 7-5: Depth Ranges of Eelgrass by Regions Table 7-6: Special Status Pacific Salmon Potentially Present within the Study Area Table 7-7: Special Status Forage Fish Potentially Present within the Study Area Table 7-8: Special Status Coastal Pelagic Fish Potentially Present within the Study Area Table 7-9: Special Status Groundfish Potentially Present within the Study Area Table 7-10: Other Special Status Fish Potentially Present within the Study Area Table 7-11: Special Status Turtles Table 7-12: Special Status Marine Mammals Table 7-13: Pinniped Haulout Site Description Table 7-14: Sources of Noise during Construction Table 7-15: Underwater Noise Thresholds for Marine Mammals and Fish Table 7-17: Summary of Potential Impacts on Marine and Nearshore Resources Table 8-1: Laws, Regulations, and Guidance for Energy and Natural Resources ix

10 Table 8-2: Utility Coverage Areas for Energy and Natural Resources Table 8-3: Summary of Potential Impacts on Energy and Natural Resources Table 9-1: Laws, Regulations, and Guidance for Environmental Health Table 9-2: Health Conditions Affected by Air Pollution Table 9-3: Average Incidence Rates of Lung and Bladder Cancers (per 100,000 population), by Gender, Table 9-4: Summary of Potential Impacts on Health from Air Emissions Table 9-5: Average Daily Traffic on Primary Proposed Project Transport Roads Table 9-6: Summary of Potential Impacts on Traffic Safety Table 9-7: Typical Noise Levels and Possible Human Response Table 9-8: Noise Sensitive Areas in the Proposed Project Vicinity Table 9-9: Washington Maximum Permissible Noise Levels a Table 9-10: Typical Outdoor Sound Levels by Land Use Category Table 9-11: Noise Level Measurements in the Vicinity of the Proposed Project Table 9-12: Summary of Potential Impacts on Noise Table 9-13: NFPA Ratings for Ammonia, Perchloroethylene, and Sulfolane Table 9-14: Census Blocks Along the Marine Vessel Transportation Route with Estimated Poverty Rates Above the 80th Percentile for the State of Washington Table 9-15: Summary of Unplanned Events Risk and Potential Impacts on Health Table 10-1: Laws, Regulations, and Guidance for Land Use and Shoreline Use Table 10-2: Study Areas for Land Use and Shoreline Use Table 10-3: Overview of Proposed Project Area for Land and Shoreline Use Table 10-4: Summary of Potential Impacts on Land and Shoreline Use Table 10-5: Summary of Potential Impacts on Recreation Table 10-6: Summary of Potential Impacts on Aesthetics and Visual Resources Table 11-1: Relevant Laws, Regulations, and Guidance for Social and Economic Environment Table 11-2: Study Areas for Social and Economic Resources Table 11-3: Housing Units, Occupancy and Tenure Table 11-4: Housing Costs Table 11-5: Summary of Housing Impacts Table 11-6: Summary of Impacts on Public Services Table 11-7: Employment and Income (2015 Inflation-Adjusted Dollars) in the Study Areas, Average Table 11-8: Employment and Wages (Millions of 2015 Inflation-Adjusted Dollars), by Industry Sector, Average Table 11-9: Vessel Landings, Revenue and Fishing Effort, Table 11-10: Travel-Related Economic Data, 2009 (2015 Inflation-Adjusted Dollars) Table 11-11: Summary of Impacts on Economic Resources: Employment Income Table 11-12: Local Sales and Use and Lodging Tax Receipts in the Study Area, FY 2015 (Millions $) Table 11-13: Summary of Impacts on Economic Resources: Tax Receipts Table 11-14: Population and Race Data Table 11-15: Summary of Potential Impacts on Minority and Low-Income Populations Table 12-1: Laws, Regulations, and Guidance for Cultural Resources Table 12-2: Previous Archaeological Surveys within the Tesoro Anacortes Refinery Table 12-3: Cultural Resources within the Proposed ProjectAPE Table 12-4: Summary of Impacts on Cultural Resources Table 13-1: Relevant Laws, Regulations, and Guidance for Marine Transportation Table 13-2: Refinery Wharf Characteristics Table 13-3: Salish Sea Vessel Call Data 1999 to Table 13-4: Vessel Crossings by Waterway, Table 13-5: Vessel Calls at March Point, Table 13-6: Selected VEAT Data Table 13-7: Anchorage Areas near the Proposed Project Area Table 13-8: Vessel Traffic Levels at the Tesoro Anacortes Refinery Table 13-9: Proposed Project Vessel Movements Compared to Historical Data Table 13-10: Summary of Vessel Traffic Impacts Table 13-11: Summary of Vessel Incidents, 1995 to Table 13-12: Distribution of VTS Vessel Incident Types by Vessel Type Table 13-13: Summary of Potential Impacts on Vessel Safety Table 13-14: Wind Speed and Direction Selections for Spill Modeling Scenarios Table 13-15: Spill Modeling Output Summary Table 13-16: Neah Bay Scenario Worst-Case Maximum Potentially Impacted Areas and Mass Table 13-17: Port Angeles Scenario Worst-Case Maximum Potentially Impacted Areas and Mass Table 13-18: Rosario Strait Scenario Worst-Case Maximum Potentially Impacted Areas and Mass Table 13-19: Refinery Wharf Scenario Worst-Case Maximum Potentially Impacted Areas and Mass x

11 Table 13-20: Extent and Thickness of Floating Spilled Material for a Worst-case Scenario Table 13-21: Neah Bay Scenario Maximum Most Probable Spill Potentially Impacted Areas and Mass (2,500 bbl) Table 13-22: Port Angeles Scenario Maximum Most Probable Spill Potentially Impacted Areas and Mass (2,500 bbl) Table 13-23: Rosario Strait Scenario Maximum Most Probable Spill Potentially Impacted Areas and Mass (2,500 bbl) Table 13-24: Refinery Wharf Scenario Maximum Most Probable Spill Potentially Impacted Areas and Mass (1,200 bbl) Table 13-25: Extent and Thickness of Floating Spilled Material for a Maximum Most Probable Spill Scenario Table 13-26: Summary of Spill Modeling Results Table 13-27: Summary of VTRA Base Case Spill Probabilities Table 13-28: Overview of the Likelihood of a Spill Occurring at Selected Locations within the Study Area Table 13-29: Summary of Potential Impacts from the Worst-case and Maximum Most Probable Spill Scenarios Table 13-30: Summary of Potential Impacts from the Average Most Probable Spill Scenario Table 13-31: Increase in Spill Likelihood Puget Sound 2015 Vessel Traffic Risk Assessment LIST OF FIGURES Figure ES-1: Proposed Project Location... 4 Figure ES-2: Proposed Project Area and Vicinity Map... 5 Figure ES-3: Process and Timing for the Proposed Project EIS... 6 Figure ES-4: Proposed Project Infrastructure Figure ES-5: Marine Vessel Transportation Route from the Refinery to the Pacific Ocean Figure ES-6: Example Project Vessels Figure ES-7: Exposure Pathways for a Marine Spill Figure ES-8: Example of a Boom Used in Spill Response Figure 1-1: Site Location Figure 1-2: Tesoro Anacortes Refinery Figure 1-3: EIS Process Figure 2-1: Project Components Figure 2-2: Project Area and Vicinity Map Figure 2-3: Xylene Isomers Figure 2-4: Marine Vessel Transportation Route from the Refinery to the Pacific Ocean Figure 2-5: Petroleum Product Breakdown Current Production Figure 2-6: Simplified Process Flow Diagram Figure 2-7: Petroleum Product Breakdown, Potential Production Figure 2-8: Naphtha Hydrotreater (NHT) Expansion, Isom Unit, and Aromatics Recovery Unit (ARU) Figure 2-9: Marine Vapor Emission Control System (VCU and DSU) Figure 2-10: Vapor Combustion Unit Figure 2-11: Dock Safety Unit Figure 2-12: New Tanks Area Figure 2-13: Project Construction Phase Durations Figure 2-14: North Texas Road Refinements Figure 2-15: Construction Employment over Time Figure 2-16: Proposed Heavy Haul Route Figure 2-17: Typical Self-Propelled Module Transporter Figure 2-18: Routes to Potential Fill Source Sites Figure 2-19: Proposed Construction Staging and Laydown Areas Figure 2-20: Tank Ship (above left), Articulated Tug and Barge (bottom), and Assist Tug (top right) Figure 2-21: Tesoro Anacortes Wharf Figure 2-22: Alternate Sites Considered Figure 3-1: Regional Geology Figure 3-2: Site Geology Figure 3-3: Site Soils Figure 3-4: Cascadia Subduction Zone Figure 3-5: Pacific Northwest Tectonic Plates Figure 3-6: Geologic Hazards Figure 4-1: Area of Influence Figure 4-2: State of Washington Class I Areas in Relation to the Proposed Project Figure 5-1: Freshwater Resources Study Area Figure 5-2: New Tanks Area Layout and Wetlands Figure 5-3: FEMA Flood Hazard Zones xi

12 Figure 5-4: Groundwater Monitoring Wells Figure 5-5: Vicinity Wetlands Figure 6-1: Terrestrial Vegetation Resources of March Point Figure 6-2: Areas of Interest near the Proposed Project Area Figure 6-3: Marine Bird Density within the Study Area Figure 6-4: Example of a Boom Used in Spill Response Figure 7-1: Marine Vegetation Adjacent to the Project Area Figure 7-2: Marine Vegetation in the Study Area Figure 7-3: Eelgrass East of the Causeway Figure 7-4: Critical Habitat Figure 7-5: Forage Fish Spawning Areas Adjacent to the Project Area Figure 7-6: Habitat Areas of Particular Concern for Groundfish Figure 7-7: Sea Lion Haulout Sites Adjacent to the Project Area Figure 7-8: Exposure Pathways for a Marine Spill Figure 9-1: Average Annual Daily Traffic around the Proposed Project Area, Figure 9-2: Noise Sensitive Areas in the Vicinity of the Proposed Project Figure 9-3: EJSCREEN Output: Census Blocks with Low-Income Population along the Marine Vessel Transportation Route 9-31 Figure 10-1: Skagit County Comprehensive Plan Zoning Map Figure 10-2: City of Anacortes Comprehensive Plan Zoning Map Figure 10-3: Skagit County Shoreline Management Master Program Map Figure 10-4: City of Anacortes Shoreline Master Program Map Figure 10-5: Fidalgo Bay and Padilla Bay Reserves Figure 10-6: Geographic Areas of Recreation Locations in the Study Area Figure 10-7: Recreational Resources in the Vicinity of the Refinery Figure 10-8: View of Existing Tesoro Anacortes Refinery from Fidalgo Bay Road Looking East (Existing View) Figure 10-9: Photo Simulation of Proposed Project Infrastructure from Fidalgo Bay Road Looking West (Proposed View) Figure 10-10: Photo Simulation of Proposed Project from Fidalgo Bay Road Looking East (Proposed View with Labels) Figure 11-1: EJSCREEN Output: Minority Population, Project Area and Marine Vessel Transportation Routes Figure 11-2: EJSCREEN Output: Low-Income Population, Project Area and Marine Vessel Transportation Routes Figure 11-3: EJSCREEN Output: Minority Population, Immediate Project Area Figure 11-4: EJSCREEN Output: Low-Income Population, Immediate Project Area Figure 12-1: Area of Potential Effects for the Proposed Project Figure 13-1: Vessel Transit Service Passage Lines Figure 13-2: Vessel Route Figure 13-3: Navigation Routes from March Point to Guemes Channel Figure 13-4: Navigation Routes Through Rosario Strait Figure 13-5: Navigation Routes through the Strait of Juan de Fuca, East Figure 13-6: Navigation Routes Through the Strait of Juan de Fuca, West Figure 13-7: Oil Spill Modeling Release Locations Figure 13-8: Worst-Case Spill (330,000 bbl), Neah Bay, Annual Average Spring Tide Figure 13-9: Worst-Case Spill (330,000 bbl), Port Angeles, Annual Average Spring Tide Figure 13-10: Worst-Case Spill (330,000 bbl), Rosario Strait, Annual Average Neap Tide Figure 13-11: Worst-Case Spill (330,000 bbl), Refinery Wharf, Annual Average Neap Tide Figure 13-12: Maximum Most Probable Spill, 2,500 bbl, Neah Bay, Annual Average Spring Tide Figure 13-13: Maximum Most Probable Spill, 2,500 bbl, Port Angeles, Annual Average Spring Tide Figure 13-14: Maximum Most Probable Spill, 2,500 bbl, Rosario Strait, Annual Average Neap Tide Figure 13-15: Maximum Most Probable Spill, 1,200 bbl, Wharf, Annual Average Neap Tide xii

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