Professional Documents
Culture Documents
Ixtoc-I Oil Spill Damage Assessment Program-1979
Ixtoc-I Oil Spill Damage Assessment Program-1979
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Prepared by:
National Oceanic and Atmospheric Administration
and
U. S. Environmental Protection Agency Region 6
In cooperation with the following
Federal and State agencies:
U. S. Department of the Interior
Bureau of Land Management
Fish and Wildlife Service
National Park Service
U. s. Geological Survey
State of Texas
Department of Water Resources
Bureau of Economic Geology
Parks and Wildlife Department
General Land Office
Corpus Christi State University
Texas A & I University
Texas A & M University
University of Texas
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CONTENTS
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I.
II.
Introduction
Goals, Objectives, and Benefits
III.
Technical Approach
IV.
Ongoing Monitoring
VI.
V.
VII.
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Management Plan
Schedule
Budget Summary
Appendix I.
Appendix II.
Proposed Projects
Agency/ Personnel Participants in
Preparation of Environmental
Damage Assessment Plan
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Figure II-1.
Figure II-2.
Figure III-1.
Figure III-2.
Table IV-1.
Figure V-1.
Figure VI-1.
Table VII-1.
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- ACKNOWLEDGEMENTS -
The contributions made to this plan by individuals and organi zations are
greatly appreciated and acknowledged. A complete list of participants
in this effort is included in Appendix 2.
Special appreciation is extended to Corpus Christi State University for
support facilities and to the IXTOC I Damage Assessment Team who actively
participated by dedicating endless days and nights to this effort.
This plan is dedicated to the one individual who worked her fingers to
the bone -- Dolly Ulna.
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EXECUTIVE SUMMARY
The purpose of this proposed cooperative federal and state program
is the assessment of damages to northwest Gulf of Mexico resources
caused by the IXTOC I oil spill. Oil has impacted the U.S. offshore
areas, barrier beaches and inlets from Brownsville to fifteen miles
north of Aransas Pass. Although the seasonal change to southerly currents
is now curtailing additional impacts, the expected shift to northerly
flow during February will again threaten the U. S. coast with oil particularly
if attempts to control the well are unsuccessful.
State and federal responsibility for assessment of damages from
pollution incidents of this type stems from legal mandates which designate
agencies as public trustees and protectors of the Nation's natural
resources. The damage assessment program coordinates the federal/
state/non-government response to the environmental and socioeconomic
impacts of the IXTOC I oil spill.
The goal of the Damage Assessment Program is to:
EVALUATE THE DAMAGE TO NORTHWEST GULF OF MEXICO
RESOURCES RESULTING FROM THE IXTOC I OIL SPILL.
To achieve the program goal, it is necessary to assess the impacts
on specific components of the ecosystem. The following five objectives
are formulated to meet the responsibilities of federal and state governments:
1
A program management plan has been designed to ensure that the
program meets its objectives. In accordance with this plan, a Program
Manager, selected from the lead agency (NOAA), will have responsibility
for the overall direction of damage assessment efforts, and will be
assisted in this task through interaction with two advisory committees,
a scientific management team, a data management team and an administrative group.
Budget requirements for the damage assessment program include
$4.2 million during the first year and $5.6 million to be distributed
over the following two years for a total of $9.8 million to be requested
in supplemental funds.
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1
INTRODUCTION
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Since 3 June 1979, a blowout on the drilling rig IXTOC I in the Bay
of Campeche has resulted in the release of approximately 3 million
barrels of oil into the Gulf of Mexico. Attempts at drilling relief
wells or capping the well have been unsuccessful to date. No reliable
estimate of when the flow of oil from the well may be stopped is available .
The IXTOC I incident has resulted in the largest spill into the marine
environment ever documented. In comparison, the Amoco Cadiz spill,
which caused significant environmental and economic damage along the
French coast in 1978, released approximately 1.5 million barrels.
From June to September oil was carried northward by Gulf currents
and has impacted the coastal environments of Texas. A mid-September
change in prevailing winds and currents has caused the oil to remain in
Mexican waters curtailing additional U.S. impacts. In February the
currents are expected to resume their northward flow and the oil will
again threaten the U. S. coastline particularly if IXTOC I has not been
controlled.
Oil from the IXTOC I spill is affecting a large geographical area
and a multitude of local and regional interests . Potentially impacted
by the spill is a $2 billion tourist industry and a $600 million commercial fishery . In addition, several threatened and endangered species
may have been affected. Given the extent and diversity of the affected
resources, a cooperative damage assessment program which recognizes as
many interests as possible is the only practical means by which to
develop a comprehensive and accurate evaluation of total damage. Lacking
such an evaluation, it is difficult to separate fact from conjecture.
Many questions will go unanswered and future planning will be seriously
hampered.
The damage assessment plan presented here is designed to employ
state and federal multiagency capabilities under unified direction in
order to:
1.
2.
3.
I- 1
HISTORICAL BACKGROUND
Over the past 15 years, there have been a number of spills around
the world for which some kind of damage assessment has been attempted.
Most of these studies have been aimed at individual research questions
or at a single aspect of the fundamental damage assessment problem.
Even so, the damage assessment problem has undergone considerable constructive evolution, as the following examples illustrate .
In U. S. waters, the first major spill for which damage assessment
was attempted was the Santa Barbara well blowout in 1969. The Santa
Barbara studies focused on massive mortalities of various types of
marine fauna . In the litigation that followed, the State of California
sued the oil companies involved for damage to the state natural resources
and economy and for loss of taxes and proprietary income. A compromise
settlement was reached without a legal determination of the proper
measure of governmental damages.
A spill from the barge Florida in West Falmouth Harbor , Massachusetts,
in 1969 was the first major spill for which an integrated scientific
assesssment was attempted. The study was concerned mainly with impacts
to the benthos of Buzzards Bay, Massachusetts, and did not include any
assessment of economic damages. The data were never used to support
litigation.
A damage assessment following the NEPCO 140 barge oil spill in the
St. Lawrence River in 1976 was conducted during the 2 year period following
the discharge. Study areas were identified by an International Joint
Team which also served as a steering committee throughout the duration
of the study. This team was the by-product of efforts sanctioned in the
National Contingency Plan. Primary study objectives included assessment
of the spill impact upon indigenous biological populations, detection of
residual petroleum hydrocarbons within affected ecosystems, determination
of the extent of bioaccumulation of hydrocarbons, assessment of socioeconomic
impacts upon local communities, and synthesis of the technical findings
into a decision document for use by agencies as a management tool. The
study met its objectives and the results have been published in a final
report.
In 1976, the Argo Merchant ran aground off the coast of Massachusetts,
spilling 170.000 barrels of No. 6 fuel oil into the northwest Atlantic.
Within 2 days, a massive scientific investigation began, coordinated by
the NOAA/USCG Spilled Oil Research Team. The Argo Merchant spill studies,
although scientifically sound, were inconclusive and did not, for the
most part, quantify impacts on natural resources in the region. Nevertheless,
this scientific effort was the first step toward damage assessment
contingency planning in the United States. NOAA and EPA, in a series of
jointly sponsored workshops around the country, assembled scientific
information related to oil spills for both information exchange and the
development of a coordinated system for assessing damages. In addition,
a National Scientific Team was created to respond to major spills and
spills of special interest, with the following objectives:
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Two distinct studies of damage from the Amoco Cadiz are being
conducted--an ecological study of oil impact and an economic investigation
(conducted by NOAA) of French losses through fisheries, tourism, and
indirect effects on the economy. Methodogical advances in economic
damage assessment from the latter investigation will be employed in the
proposed damage assessment, which integrates the contributions (and
constraints) of chemical oceanography, biology, and economics.
THE CURRENT SITUATION
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in the Gulf of Mexico is scheduled for completion next year. The Texas
Deep Water Port Authority is seeking approval for construction of a
superport previously known as Seadock, off the Texas Coast. Additional
proposals for inshore deepwater port facilities at Galveston, Texas and
Any major oil spill from either of
Harbor Island, Texas remain active.
these locations could severely impact natural resources in the proposed
study area. Among the returns from the proposed program will be the
creation of a permanent program plan that can be activated quickly in
future spills, and a data base of factual information on which resource
managers can base decisions concerning similar offshore oil and gas
development.
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The benefits that result from accomplishing each of these objectives are
presented below.
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Beneflta
Protect
Consumer
llealth
Maintain
ConaiJIIM!r
Confidence
Support
Fishery and
Wildlife
Hanage~~~ent
Decisions
Support
Coastal
Use
Management
Decisions
Support
Regulatory
and
Legis latl ve
Processes
Prev"ent and
Provide
Mitigate
Basis for
Copensation Resource
for D1111111ges
Daaasea
lnfonnation
Transfer
Public
Awareness
of Risk
Auoclatcd
with OCS
Deve lop~~en t
Support
Mandatory
Closure of
Elllhayments
to Fishing
Assist
Judicial
Process for
llealth
Settlement
Claims
Rapid
Awareness
of Extension
Agents of
Potential
Contaminatlo
Risk to
lluMl:lnS
From or.s
Development
Ob.J ec t1 ves
Active
Assess Potential
Impacts on
Hu111an llealth
I ~~~pound
Adultered
Fishery
Productl
~iarket for
(;ulf Coaet
Fishery
Product
Assess lpacts
on Cotnnaerdal
and Recreational
Fishery Resource~
H
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Assess Impacts
on Marine
haals, Birds,
and Endangered
Species
Adjus t
Fishing
Seasons in
lleavily
lq>scted Bays
& Estuaries
Support New
"Loss to
Zoning
Reduce
Fi&hery"
Ordinances
Data
Fishing
I' rohib it lng
Pressure
Encroachment Avallable
of Residence for Econotdc in Coastal
Lagoons
Upon Lagoons Adjuster
Reduce
Relocate
Public
Turtle Brood Pressure
Stock to
On
Unhtpacted
Impacted
Breedin&
Rookery
Sites
Areas
Support for
Reduced
Dredging of
Channels in
Impacted
Areas
"l.oss to
Beach Vis1t01
Development
Days" Data
in Noncritl- Available
cal Resource {or Economic
Areas
Adjuster
Re cr~tatlonal
Uevelnp an
laaprove .l
llana~(>,.oent
and
SctentJ.r I.e
Appro01cl1 to
Damage Assessment
r.ontinued
:rotcctton
of Consumer
liealth
Continued
ltaintenance
of Consumer
Confidence
"Loss of
Birds" Data
Available
for Economic
Adjuster
Establish
Permanent
Bird
Cleaning
Capabillty
in Key Resource Areas
Pr01a0te
Deter.ine
Effecta of
Losa of
Seafood .in
Seafood
Products
Assess
Soc ioeconomlc
Impacts
Easy l.D.
of Potential
Health
Proble111s
Related to
Future Spill
Be t ~ er
Better
}lanasecnt of tlanagetaent
Fishery and
of Coastal
Use
Wild! He
Resources
Figure 11-1.
Better
Support of A Cont l nually
Regulatory
I&Dprovtng
and
Bash of
Legislative Compel"'sation
Procetlses
for Damages
Better
Prevention lio
lll t J ga tion
of Resources
From Damages
By a Spill
Risk to
Coowerclal &
Recreational
Fishin& Resources fro111
o<:s
Development
!IUS~
tO
Har:ine
1111tlllllals.
Link Fishery Birds &
& Wildlife
EndansereJ
Experts to
Species fr011
Solve Co111111on ocs
Problems
Dcve lopG.cn t
Rapid Awareness of Need.
Risk to
of Sport
Nonliving
Fishing
Resources
Industry
Passed to
from OCS
Fishery
Development
Association
Continua lly
Improving
Methods of
Information
Tran~<fer
A CuntJnuln&
Increase in
Awareness
Assoc iated
With OCS
D~vclopment
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Losses to the public and private sectors from the oil spill
may reach many millions of dollars. The damage assessment program
will document and quantify these losses so that some form of
compensation can be made to parties who experience losses caused by
the oil spill.
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(7)
A number of state
protect the living and
The assessment program
their participation in
taken into account and
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III
TECHNICAL APPROACH
The damage resulting from the IXTOC I oil spill will ultimately be
reflected in impacts to man. Impacts may include loss of income from
decreases in fisheries, tourism, and recreation; impaired health; and
damage to non commercial wildlife such as birds and endangered species.
The purpose of this program is to assess these impacts and recognize
that a viable program must be limited to resources that are easily
identifiable. Technical measures of resource losses must be translated
into a common standard of value to be most useful to decision makers and
the public . By this means the study elements of the program can be
focused on a coherent endpoint defined by losses to human values.
Decision Making
Successful management of a damage assessment program depends upon
the development of standardized criteria to support decision making
requirements. Several important steps are included in making decisions
in the technical management. Examples of major steps in management
decisions are:
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Figure III-1.
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HUMAN HEALTH
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FISHERIES
MARINE MAMMALS,
BIRDS, ENDANGER-I------I
ED SPECIES
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SOCIOECONOMIC
L'!PROVED DAMAGE
ASSESSMENT
APPROACH
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Step-by-Step Process in
Decision-Making
VARIATION
III-2
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Figure III-1.
1
CAN
DATA BE
COLLECTED WHICH
CAN BE EFFECTIVELY
COMPARED TO
BASELINE DATA?
YES
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NO
YES
DESIGN MONITORING OF
OBVIOUS EFFECTS SHOWING
ACUTE CAUSALITY
u
ANALYZE THE RETURNS
PER COST OR EFFORT
RECEIVE PROPOSALS
III-3
Continued
NO
ELIMI~ATE FROM
OPERATIONAL PROGRAM
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Figure III-1.
NO
IS STUDY
APPROPRIATE
TO
OBJECTIVES?
YES
&~INE SAMPLING,
ANALYSIS PROCEDURES
AND QUALITY OF CONTROLS
FOR EACH DATA SET IN
PROPOSAL
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YES
STANDARDISE, CALIBRATE
BASELINE AND OTHER OBJECT
STUDIES
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III-4
Continued
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the hard bottom and reef communities are essential to the production of
commercial fish. While recognizing that it may not be possible to
establish exact correspondence between the number of acres of habitat
destroyed and the number of adult shrimp lost as a result of the spill,
by assessing the changes oil brings about in the availability or function
of these support factors, some indirect evidence can be presented that
provides a link between resource damage and the IXTOC I spill.
3.
Key species are animals that may or may not have a direct economic
or ecological importance but which have an intrinsic value established by
national policy. This category includes marine mammals, birds, and
endangered species. Assessing impacts on these species will involve
studies similar to those outlined in the previous section. Because many
of these species occupy the beaches for part if not all of their lives,
oil impacts to beach habitats will receive major emphasis in achieving
this objective. Certain organismal and chemical studies on non-endangered
species will be required to support the habitat and population survey
studies.
4.
Socioeconomic Impacts
III-6
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The human health studies will assess the health risk from the
consumption of hydrocarbon-contaminated fish products and direct exposure
to IXTOC I oil. Economic evaluation of these health risks uses data on
contamination of the fishery products and expert opinion on health
risks. Through techniques that sample consumer preferences, an economic
loss can be attached to the health risk to workers and the general
public.
The next program element examines impacts on commercial and recreational
fisheries. One objective is to estimate the effect of IXTOC I oil on
present and future catch/effort ratios of Gulf of Mexico commercial
fisheries. Data generated through this program element will be used as
an input to the socioeconomic studies, which will evaluate commercial
fisheries losses as one of the market commodities damaged by the spill.
Findings on commercial fisheries will assist in determination of recreational
fisheries losses.
The other biological program element focuses on non-fishery wildlife.
Such wildlife, including marine mammals, birds, and endangered species
have tangible value to society; numerous examples exist in which valuable
goods and services have been expended to view, study or preserve them .
Establishing the economic value of any injury to these species will be
extremely difficult but it is hoped that interviews with recreationists
and others impacted by the oil spill can be used to establish society's
willingness to pay to prevent such damage.
III- 7
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IV
ONGOING MONITORING:
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IV- 1
Table IV-1
Ongoing or Completed Monitoring Studies: IXTOC I Oil Spill
1.
2.
3.
4.
5.
6.
7.
8.
9.
IV-2
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Table - Continued
10.
11.
Study of ~oncentration gradient of hydrocarbons along the TexasMexican C?ast (MOUSSE II).
Duration:
Mid-August 1979
University of Texas and Energy Resources Company
12.
13.
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MANAGEMENT PLAN
Program Management
A program management organization (Fig. V-1) has been designed to
ensure that the damage assessment program meets user needs, is comprehensive
and can command and coordinate all necessary scientific and administrative support functions.
A Program Manager having overall technical and administrative
responsibility for the program will be supplied by the lead agency , the
National Oceanic and Atmospheric Administration (NOAA). This person
will ensure that damage assessment activities satisfy program objectives
and are developed and implemented ~& planned.
Reporting to the Program Manager are two Advisory Committees (Program
and Scientific), the Scientific Management Team, the data management
group and the administrative group.
The Scientific Management Team will act as the executive body of
the disciplinary working groups. The Team will consist of five objective
coordinators and two support coordinators; and will be supported by a
staff which will function as a communication link among the operational
groups. The Team will be responsible for working with principal investigators
and other Team members to ensure the integration and coordination of all
scientific activities. The Team will be responsible for establishing
priorities and criteria for studies which are consistent with program
objectives.
A Program Advisory Committee will be made up of representatives of
state and federal agencies. The Committee will suggest modifications of
program objectives, coordinate intergovernmental projects and evaluate
program accomplishments.
A Scientific Advisory Committee will be comprised of scientists
familiar with the Gulf of Mexico and assessment of damages. The Committee
will assist in identifying research needs and information requirements
in addition to reviewing proposals for technical merit.
Data Management
Management of data acquired within the framework of the Damage
Assessment Program consists of establishing and monitoring schedules for
the collection, processing, validation, and archiving of data for a
given task and relating that task to other tasks within the Program.
V-1
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Program
Advisory
Committee
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Administration
Logistics
Support
Staff
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Management Team
Birds, Mammals
Endangered
Species
Staff
Generic
Damage
Assessment
Approach
Staff
I
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-Chemistry
-Qil Fate and
Transport
Principal
Investigators and
Field Teams
Figure V-1.
Socioeconomic
concerns
Staff
Staff
Support
0
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Fisheries
Data
Management
Staff
Scientific
Human
Health
Scientific
Advisory
Committee
Program
Manager
V-2
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2.
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4.
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SCHEDULE
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L-
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1979
JUN
BLOWOUT
JUL
I AUG I
SEP
I OCT I
NOV
DEC
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1980
JAN 1-F~r MAR
c:::J
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!..-...;
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APR
1 MAY
OILING OF
- --------- CURRENTS
SOUTHt:RN
NORTHERN CURRENTS
-1----------------
1OILING
OF U.S. AREAS
OILING OF OTHER COASTLINES
--? --------------..--------------------------~
OF SPILLED OIL (U.S.)
t----------- ---CLEANUP
_________
. . ,. . ,. ___
<
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(?)
----------------~~
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SUPPLEMENTAL FUNDING
1------------
I
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Figure VI-1.
STUDIES TO
\~AIT
..
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VII
n
[]
BUDGET SUMMARY
Funding requirements for the program elements of the damage assessment
program by years is shown in Table VII-1. It is expected that approximately
$4.2 million will be needed during the first year, the remaining $5.6
million will be distributed over the following two years.
The budget estimate accounts for monitoring of spill movement,
uptake of hydrocarbons within various resources and actual damage assessment
studies for various resources. Program and data management elements are
included.
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VII-1
Table VII-1.
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Program Elements
Year 1
Years 2 and 3
Total
Human Health
178
223
401
Fishery Resources
734
319
1053
1038
1279
2317
Socioeconomic
353
277
630
Improved Approaches
167
333
500
Support function:
Chemistry
734
1166
1900
Program Management
547
1095
1642
Data Management
470
940
1410
TOTALS
4,221
5~632
9~853
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APPENDIX 1
PROPOSED PROJEC1S
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Project Title
Duration
-.
Date to be
Completed
Cost
(Thousands
- .aL.Dollal:.s)
Scope of Work
1.
Organoleptic screening of
Gulf of Mexico seafoods
1 1/2 years
1980
31
2.
Survey of petroleum
residues in selected
Gulf of Mexico fishery
species
3 years
1982
320
3.
Monitoring of petroleum
uptake in humans
1 year
1980
so
CJ
- - - -- ~
Project Title
L.....:
Date to be
Completed
Duration
Cost
(Thousands
Scope of Work
af. nnllAr!Q\
1.
1 year
1980
190
2.
a)
1 year
Nov. '80
60
b)
1 year
Nov. '80
65
c)
1 year
Mar. '81
18
Dec. '79
Jan. '80
Feb. '80
40
3.
Assessment of hydrocarbon
impact on eggs of menhaden
3 cruises
4.
3 years
1982
200
5.
1 year
1980
90
C-.
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Project Title
6.
7.
8.
Fouling community
assessment
9.
Monitoring of benthic
communities
,.
c:::J
r-,
r1
II
r-1
I..
Date to be
Duration
Completed
Cost
(Thousands
_nf nnllArl':\
c:::J
CI
::::::!
Scope of work
1 year
1980
30
18 months
1981
140
3 months
1979
20
3 years
1982
200
:..--.J
-~-~ -
(Th~~==nds
Date to be
- - - - - -Project Title
Duration
Completed
l_______________:____________________________-1--~------------~--------------------~ .of Dollars) _
r---
Scope of Work
.....
---
1.
1 month
Completed
2.
5 months
Dec. '79
3.
2 years
1981
65
4.
a)
Oil effects on
distribution behavior
and reproductive
success of mammals
and turtles
2 years
1981
120
b)
Effects of oil on
intertidal organisms
and infauna--Mustang/
Padre Islands
1 year
1980
37
Intertidal-subtidal biological
samples for baseline data and
subsequent collections for
determination of oil impacts.
1 year
1980
10
5.
Sargassum community
assessment
Resuscitation, recovery,
collection of tissue samples
from dead marine mammals and
turtles.
Effects on reproduction
(nesting effort/hatching
success); population census
and trends in nesting, migratory,
and forage behavior utilizing
platforms of opportunity.
c__:
L.....:
c::J
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-----
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L,
r--1
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r-1
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r---1
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II
r-1
r-"1
:--,
~;--------=-r-Project Title
.....
Duration
j_
Date to be
COII>pleted
Cost
(Thousands
nf nn11 .. r!':'
-flo
r--1
c:J
Scope of Work
6.
Assessment of effects of
oil on migratory waterbirds
3 years
1982
850
7.
3 years
1982
150
8.
Toxicity, histopathology
and oil fingerprinting
for birds affected by oil
3 years
1982
750
9.
1/2 year
1980
125
3 years
1982
30
and
of
reof
- -
Project Title
---
Date to be
Completed
Duration
1
I
~---------------------------------~---------------~-----
Cost
(Thousands
of Dollars)
Scope of Work
- -
1 year
1980
180
3 years
1982
500
**Not included in budget; however, if the assumption that oil did not enter estuary system by monitoring
efforts, such a study may be deemed necessary .
---
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SOCIOECONOMIC IMPACTS
4Project Title
Duration
Date to be
_ Completed
Cost
(Thousands
c::J
of pall arsl
CJ
C)
c:J
Scope of Work
---------'
1.
3 months
1980
10
2.
4 months
1980
20
3.
Secondary regional
baseline data collection
3 months
1980
25
4.
2 years
1981
175
5.
2 years
1981
300
6.
S~condary
2 years
1981
100
regional impacts
L-
Date to be
Completed
Duration
Evaluation of damage
assessment program.
3 years
1982
500
2.
5 months
Feb. '80
18
....___
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of Dollars)
1.
"-
Cost
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Wor~
"'
1)
2)
3)
Annotated bibliography
of biological studies
in region .
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._________________
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Dollars)
___
1.
Identification of IXTOC I
crude: Determine chemical
parameters needed to confirm the identity of
environmental oil with
statistical validity
5 months
3/15/79
50
2.
Establish heirarchial
(layered) analytical
approach for chemical
analysis of damage
assessment samples
5 months
3/15/79
50
3.
3 years
1982
150
4.
3 years
1982
1200
5.
1 year
1980
50
6.
3 years
1982
200
--------
Project Title
Date to be
Completed
Duration
...
7.
t..__;
Geophysical factors
affecting the transport
and fate of IXTOC I oil
in Western Gulf of Mexico
r:.__:.:
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3 years
"""--'
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Cost
~
(Thousands
o..f.....DolLu:s
1982
..___.
200
,_
Scope of Work
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APPENDIX 2
AGENCY/PERSONNEL PARTICIPANTS
IN PREPARATION OF
ENVIRONMENTAL DAMAGE ASSESSMENT PLAN
(Names Taken From Registration List)
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I.
Federal Agencies
A.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
D
1
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B.
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D.
E.
F.
II.
State Agencies
A.
B.
1
1
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C.
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D.
E.
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III.
J
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Pat Hughes
University
A.
B.
2.
J
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G.
C.
D.
E.
IV.
Private Interests
A.
B.
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C.
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E.
1.
2.
3.
F.
G.
H.
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Graphics
1.
K.
South Carolina
J.
Columbia~
I.
Independent Consultant
1.
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