NATIONAL PARK SERVICE LANDS / JURISDICTIONS ANNEX TO THE SAVANNAH CAPTAIN OF THE PORT ZONE AREA CONTINGENCY PLAN

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1 NATIONAL PARK SERVICE LANDS / JURISDICTIONS ANNEX TO THE SAVANNAH CAPTAIN OF THE PORT ZONE AREA CONTINGENCY PLAN Fort Pulaski National Monument Fort Frederica National Monument Cumberland Island National Seashore Revised: January INTRODUCTION AND PURPOSE OF ANNEX The purpose of this Annex is to provide an operational guide to federal/state/local responders when an oil discharge or release of hazardous substances impacts or threatens to impact resources owned or managed by the National Park Service (NPS). On the Georgia shoreline, these resources include Fort Pulaski National Monument, Fort Frederica National Monument, and Cumberland Island National Seashore lands, coastal habitats, wilderness areas, the cultural resources, the wildlife communities, and the public use areas therein. This Annex is intended to supplement the U.S. Coast Guard Area Contingency Plan (ACP) for the Georgia/Southern South Carolina Coastal Sector as a zone-specific Annex. It is not intended to duplicate or supersede anything in the Georgia/South SC Coastal ACP. The NPS recognizes and employs the Incident Command System as the incident management framework for emergency response. This Annex is crafted to support planning, logistics and operations of ICS during a spill response and to integrate the NPS with other agencies, governments and/or organizations. In addition, the NPS has relevant expertise and qualified personnel to assist the Federal On-Scene Coordinator in responding to spills impacting NPS jurisdiction. These capabilities include general biological, natural, and cultural resource managers available to evaluate, measure, monitor, and contain threats to park system lands and resources and to provide technical assistance; archeological and historical expertise in protection, preservation, evaluation, impact mitigation, and restoration of cultural resources; law enforcement and emergency personnel. NPS Managers are responsible for preserving and protecting public lands and, in some instances, surrounding waters and submerged lands. This Annex provides guidance and conditions for oil discharge / hazardous substance release prevention and emergency countermeasure response actions on and around the shorelines, beaches, wetlands, and islands owned and managed by the NPS that comprise the three above stated units. This Annex contains: Each park unit s most vulnerable intertidal resources, priority listed and mapped 1 Priority Area Summary forms for those most sensitive resource areas, including geographic location information and protection strategy recommendations Emergency contacts for each park unit and lists of trained emergency response staff Lists of available park facilities/equipment/staging areas for emergency operations 1 Priority Protection Maps located on pgs (Fort Pulaski), 32 (Fort Frederica) and (Cumberland Island)

2 NPS Annex to the Savannah COTTP Zone ACP 2. DESCRIPTION OF PARK UNITS A. Overview Map Figure 1 shows the state of Georgia and the location of these three NPS Units on the Georgia coastline. Figure 1. Location map for the three NPS Units in coastal Georgia. A. Fort Pulaski National Monument Fort Pulaski (FOPU) lands are located approximately 15 miles east of Savannah, Georgia at the mouth of the Savannah River, the location of the U.S. s fourth largest container port. Oil and hazardous material releases have occurred in the vicinity of Fort Pulaski several times in the past five years. Port traffic, river currents, and tidal flows in and around the mouth of the Savannah River and the nearby creek mouths are such that Fort Pulaski s sensitive marshlands and archeological sites have been put at risk of contamination by oil discharge or hazardous substance release to water. Fort Pulaski s boundaries include 5,000 acres of pristine tidal marshland and 500 acres of upland communities, home to six federally or state listed threatened and endangered species, public oyster beds, federally registered historic structures, and recreational hiking and biking trails. The monument lands cover acres on Cockspur Island, in the middle of the river between its north and south channels, and 5,027.6 acres on McQueens Island, bordering the river to the south. (See Figure 2 below) Cockspur Island houses historic structures and sensitive wetland habitat. McQueens Island is primarily a marshland, with only 5% of its total area in upland associated with U.S. Highway 80 and the abandoned Central of Georgia Railroad grade. It provides the public with hiking/biking trails and access to oyster beds, and is an important habitat for bivalves and shorebirds. Page 2 of 57

3 NPS Annex to the Savannah COTTP Zone ACP Figure 2. Fort Pulaski National Monument lands include McQueens Island and eastern Cockspur Island. B. Fort Frederica National Monument Fort Frederica (FOFR) lands lay on the inland side of St. Simons Island on the Frederica River. (See Figure 3 below) The border of the monument is located 13 miles northeast of the Brunswick shipping port, with predominantly agri-bulk and automobile transport cargo ship traffic. Pleasure craft are present in waters surrounding Fort Frederica, but boats passing down the Frederica River are limited to small craft due to shallow waters. Fort Frederica is an archeological site with sensitive cultural resources above and below water in addition to100 acres of marshland to the west of the main fort site, across the Frederica River. The marsh is important habitat for shorebirds. The endangered West Indian manatee is also present in Frederica River. Because the fort, river and marshlands exist in the intertidal zone, Fort Frederica lands are at risk of contamination by oil discharge or hazardous substances release to water. Page 3 of 57

4 NPS Annex to the Savannah COTTP Zone ACP Figure 3. Overview map of Fort Frederica, situated on St. Simons Island C. Cumberland Island National Seashore Cumberland Island (CUIS) is located on the southern Georgia coast near the border with Florida. The barrier island is approximately 35 miles north of Jacksonville and the site of a significant Jacksonville shipping port whose large vessel leading cargoes include containerized and roll-on/rolloff general cargo, automobiles, breakbulk cargoes, and dry and liquid bulk products, including petroleum and phosphate. 2 The northern tip of Cumberland Island is 12 miles south of the port of Brunswick, with agri-bulk and automobile transport freighter traffic as stated above. Just to the south of the island is the smaller port of Fernandina, which traffics mostly smaller vessels such as shrimp and pleasure boats. The Intracoastal Waterway passes nearby, hosting some commercial barge traffic. With extensive intertidal habitat and proximity to several shipping channels, the Cumberland Island National Seashore is at risk of damage by oil discharge or hazardous substances release to water. Cumberland Island is a long barrier island stretching 17.5 miles and totaling 36,415 acres of which 16,850 are marsh, mud flats, and tidal creeks. (See Figure 4 below) The northern section of Cumberland Island includes a federally designated wilderness area that is mostly uplands with some bordering marsh and dune lands, covering a total of 8,840 acres. The island provides important habitat for federally listed species - loggerhead sea turtles, wood stork, and piping plovers. The island is an important stopover point for migrating birds on the transatlantic migratory flyway. Federally listed West Indian manatees and Northern right whales are present in surrounding waters. Historic and pre-historic cultural resources are also present along Cumberland Island s intertidal zone. 2 Shipping digest Port Information page. Page 4 of 57

5 NPS Annex to the Savannah COTTP Zone ACP Figure 4. Overview map of Cumberland Island National Seashore barrier island. Page 5 of 57

6 NPS Annex to the Savannah COTTP Zone ACP 3. LAWS, REGULATIONS, AND MANAGEMENT POLICIES Management of the national park system is directed and guided by specific laws, regulations, and policies that will impact or control emergency spill response actions taken within any specific national park system unit. A. General Authorities i. National Park Service Organic Act (16 U.S.C. 1 et seq.). Establishes the National Park Service within the Department of the Interior and directs the NPS to promote and regulate the use of the Federal areas known as national parks, monuments, and reservations hereinafter specified to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations. ii. General Authorities Act of 1970 (16 U.S.C. 1a-1 and 1a-8). Combines all areas administered by the NPS in one National Park System and amends the Organic Act to specify that the National Park System shall include any area of land and water now or hereafter administered by the Secretary of the Interior through the NPS for park, monument, historic, parkway, recreational, or other purpose. iii. The National Park Resources Protection Act of 1996 (16 USC 19jj). Any person who causes the loss of, or injures a park system resource is liable to the United States for response costs and damages. iv. Wilderness Act (Public Law ) Section 4(c). States that within any wilderness area designated by this Act and, except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area. 3 v. National Historic Preservation Act (NHPA) Compliance and Consultation (Section 106). In 1997, the National Response Team completed a Programmatic Agreement on Protection of Historic Properties during Emergency Response under the National Response Plan. This agreement provides an approved procedure to meet the consultation requirements of the regulations for implementing Section 106 of the National Historic Preservation Act. To meet the pre-planning needs, each historic site within a Park unit potentially at risk is included in the section on Protection Priorities, so that they are identified and prioritized, and strategies are recommended for their protection. A Historic Properties Specialist is listed in the Notification table for each park unit and should consult on response activities on and around cultural resource sites. 4 vi. Antiquities Act (1906) and regulations at 43 CFR 3 (16 U.S.C. 431, 432, 433; P. L (June 8, 1906)) and Archaeological Resources Protection Act (1979) as amended and 3 The National Park Service uses the minimum tool (i.e. - Minimum Requirement Analysis) to weigh impacts and determine activities allowed in NPS managed wilderness areas. As the NPS has the administrative authority to allow certain non-conforming uses in wilderness during emergency operations, NPS officials must be consulted by responders prior to entrance into the wilderness area or the use of any such action. 4 See Page 6 of 57

7 NPS Annex to the Savannah COTTP Zone ACP regulations at 43 CFR 7 and 36 CFR 79 (16 U.S.C. 470aa-470mm, P. L (October 31, 1979)). Both of these statutes prohibit the unauthorized disturbance or removal of archeological resources on public lands and authorize the regulation of archeological investigations of these resources. B. NPS Regulations / Permits The national parks are governed by regulations that provide for the proper use, management, government, and protection of persons, property, and natural and cultural resources within areas under the jurisdiction of the National Park Service. These regulations can be found at 36 CFR, Parts Applicable sections for oil spill response actions include, but are not limited to 36 CFR, Part 1 General Provisions; Part 2 Resource Protection, Public Use and Recreation; Part 3 Boating and Water Use Activities; Part 6 Solid Waste Disposal Sites In Units of the National Park System. i. Special Use Permits Under 36 CFR 1.6, the NPS may require a permit for response operations and activities on or within park unit boundaries to outline and specify any special conditions or stipulations related to cleanup operations and the protection of park resources. A sample permit with the list of conditions and blank permit forms are attached at the end of this document on pages Appropriate coordination and pre-planning between the NPS and the spill response community will ensure that applicable regulation will not unreasonably impede the efficiency or effectiveness of any response actions. C. Management Policies 2006 The NPS has a basic set of Service-wide policies governing the operation of all park units. Adherence to policy is mandatory unless specifically waived or modified by the Secretary of the Interior or the Director of the NPS. These policies will guide response actions taken on park lands or waters. Key policy sections include, but are not limited to the following: i. Unimpaired or Non-Derogation Standard - Congress defines a single standard for the management of the National Park System and that standard is impairment as defined in the NPS Management Policies 2006 (Chapter 1.4). Generally, impairment is an impact that would harm the integrity of park resources or values, including the opportunities for the public to enjoy those park resources or values. Specifically, an impact is likely to constitute an impairment to the extent that it affects a resource or value whose conservation is (Chapter 1.4.5): Necessary to fulfill specific purposes identified in the establishing legislation or proclamation of the park, or Key to the natural or cultural integrity of the park or to opportunities for enjoyment of the park; or Identified as a goal in the park s general management plan or other relevant NPS planning documents as being of significance. Page 7 of 57

8 NPS Annex to the Savannah COTTP Zone ACP This standard will be considered an Applicable or Relevant and Appropriate Requirement (ARAR) in determining protection priorities and response actions and in determining cleanup standard of lands and waters within all NPS park units. ii. Use of the Incident Command System for Emergency Operations NPS Management Policies of 2006 (Chapter ) direct all NPS emergency operations to be conducted under the Incident Command System of the National Interagency Incident Management System (NIIMS), and all multi-agency incidents to be conducted under the Unified Command System within the Incident Command System. D. NPS Emergency Response Requirements i. Activities Which Require Park Superintendent Approval The Superintendent's approval is required for the following emergency response activities: a. Cleanup and Response Measures--All cleanup and response measures occurring on NPS owned/managed lands require prior authorization of the Superintendent. This includes in-situ burning and use of chemical countermeasures. b. Ground Disturbance--Any activities that might result in disturbance of soil or vegetation must be approved by the Superintendent. These would include activities such as the installation of camps and staging areas, and the use of vehicles, vessels or earth-moving equipment. c. Aircraft Operations--Any fixed wing or helicopter landings in the Park must be approved by the Superintendent. d. Access to NPS lands--any traffic across, through or over NPS owned/managed lands requires prior notification and authorization by the Superintendent. e. Park Land or Beach Closures--Any closures occurring on NPS owned/managed lands require notification and prior authorization of the Superintendent. The Superintendent must issue a formal closure according to NPS regulations outlined in 36 CFR 1.5. f. Completion of Clean-up Superintendent must approve completion of clean-up on NPS owned or managed lands and waters. ii. Air Quality The use of in-situ burning as a spill response countermeasure has the potential to damage or denigrate air quality or air quality-related values within park units. Emissions of particulate matter from a spill burn may denigrate such values as visibility and viewscapes, of national park lands located downwind from the burn whether the burn is on park lands or not. Under NPS regulations pursuant to the Clean Air Act, Superintendents have a responsibility to protect the air quality related values (including visibility) in all park units, and they have an affirmative responsibility to protect air quality in park units designated Page 8 of 57

9 NPS Annex to the Savannah COTTP Zone ACP Class I airsheds. 5 Thus, any actions that cause or contribute to denigration of air quality in any Class I federal area are subject to specific review by the NPS. Although in-situ burns are usually of short duration and unlikely to violate EPA prescribed short-term air quality standards, the NPS will also have to consider localized impacts on park visitors and park resources that may be impacted by the burn. If an in-situ burn is proposed in the vicinity of a visitor use area, (i.e. visitor center, campground, picnic area, etc.), it may be necessary to temporarily close these areas during a burn. If a burn is proposed in a sensitive resource area, actions might need to be taken to prevent damage to proximate resources. Therefore, the NPS must be notified of and agree to the use of in-situ burning where the smoke may affect the air shed of the Park unit. iii. Oiled Equipment and Debris The transporting of oiled equipment and debris through NPS lands has the potential to damage park resources. Collection and removal of oiled debris and transport of oiled equipment should be handled in such a manner that does not impact NPS resources. Special Use Permits may be required for any necessary movement of oiled materials across NPS lands. iv. Places of Refuge / Decontamination Sites NPS lands are federally protected for their valuable natural and cultural resources; they are therefore not appropriate for use as places of refuge or decontamination sites. Anchorage areas may be more appropriate for these usages. E. Radio Communications Capabilities The National Park Service operates and maintains conventional land mobile radio (LMR) communications systems that operate in the authorized Federal Government frequency band of MHz. This particular frequency band is administered by the National Telecommunications Information Administration (NTIA) and frequency assignment are processed and obtain through the National Park Service's Radio Program Division and Communications Security Division and the Department of the Interior's Radio Program and Spectrum Management Office. All frequencies utilized by the National Park Service for its day-to-day public safety, law enforcement, security, and emergency management missions are exempt from the Freedom of Information Act (FOIA). The conventional LMR systems utilized by the NPS are compliant with the Telecommunications Industry Association standard TIA-102, also known as the Association of Public Safety Communications Officials Project 25 (P-25) standard. These systems are also compliant with the Federal Information Processing Standard (FIPS-197) Advanced Encryption Standard (AES). Where radio encryption is deployed, the radio encryption software is backwards compatible and capable of communicating with cooperators using the older Digital Encryption Standards (DES) encryption algorithm. Some park units have aeronautical mobile (aviation) and maritime mobile (marine) radio communications capabilities. The NPS practices the use of Federal Interoperability channels for emergency response missions. To obtain additional 5 NPS Management Policies 2006, Chapter 4.7.1: Air Quality/Air Resource Management Page 9 of 57

10 NPS Annex to the Savannah COTTP Zone ACP information and/or coordinate radio communications capabilities for a specific park unit please contact the park unit's radio coordinator (see notification Table 2. for each park unit). 4. PARK SPECIFIC INFORMATION A. Fort Pulaski National Monument i. Authorities Enabling Legislation Fort Pulaski National Monument was established by proclamation of President Calvin Coolidge on October 15, 1924 (No. 1713, 43 Stat. 1968) under authority of the Antiquities Act of June 8, 1906 (34 Stat. 225) and set aside "the entire area comprising the site of the old fortifications which are clearly defined by ditches and embankments, which enclose about twenty acres." An Act of Congress, approved June 26, 1936 (49 Stat. 1979), extended the boundaries of the Monument to include all lands of Cockspur Island. A strip of land along the north shore of Cockspur Island was permanently reserved to the Corps of Engineers for "...deposit of dredging materials and other purposes." Two parcels on McQueens Island were donated to the NPS by the State of Georgia; acres at the east end of the island in March of 1935 and approximately 5,000 acres of marsh donated in January of On May 25, 1959 two small islands were added to the Monument by Presidential Proclamation (No. 3254); the old Cockspur Island Lighthouse and Daymark Island, on which there are no improvements. Congressional Statement of Purpose The Monument was established to preserve and protect the historic site and structures associated with Fort Pulaski. This is the primary objective of the resource management program. The secondary objective of the program is to manage the flora and fauna of the monument in such a manner that natural processes can occur unimpeded to the greatest extent possible. ii. Jurisdiction NPS jurisdiction extends along the shoreline of Fort Pulaski National Monument lands to the mean low tide line. NPS also wholly owns Oyster Creek, a navigable channel through McQueens Island, including the creek s water surface, column and bottom. Spill responders must notify and obtain approval from the Superintendent or other park managers for actions taken inside these NPS zones. (See Map No. 1, p.22) The Fort Pulaski Master Plan, approved in June 1971, says An act of the Georgia Legislature dated December 22, 1808, ceded exclusive jurisdiction over Cockspur Island to the United States. The United States has concurrent jurisdiction on McQueens Island. Two current deed reservations exist with the State of Georgia on McQueens Island; a 150 feet wide right-ofway of U.S. 80 and a two hundred feet wide portion of the abandoned Central of Georgia Railroad right-of-way. Page 10 of 57

11 NPS Annex to the Savannah COTTP Zone ACP iii. Vulnerability to damage from oil discharge or release of hazardous substances Fort Pulaski National Monument s Cockspur Island sits in the center of the Savannah River between the North and South Channels, immediately upstream of the mouth. Heavy traffic of large container ships, barges, dry-bulk and tanker ships pass through the North Channel daily. A recent breach of spoil land on the west end of Cockspur Island (January, 2008) renders the island wetlands even more vulnerable to contamination due to the new opening into the South Channel. Shores of the Savannah River and surrounding environs are subject to a broad tidal range, achieving a maximum of 9.7 feet during spring neap tides. iv. Priority Resource Areas Fort Pulaski National Monument lands host a few specific sites where the Monument s most sensitive natural and cultural resources require high priority or special spill protection. Two of these areas contain sensitive cultural resources and three are gateways for hazardous material spills to enter important wetland habitat. All of the sites may be damaged both directly by the spilled material and indirectly by the impacts of on-shore clean-up activities. Among the resources at risk are: (see Map No. 1, p.22) Historic structure of Cockspur Island lighthouse (FOPU 1) North Pier and adjacent areas (FOPU 2) Wetland habitat access point of Oyster Creek at Tybee River (FOPU 3) Wetland habitat access point of Oyster Creek at Lazaretto Creek (FOPU 4) These areas are not currently listed as protection priorities in the Sector Georgia ACP, with the exception of the site at Oyster Creek and Tybee River (FOPU 3), labeled Oyster Creek (A95) on Response Map #: GA-5/SC-62 in the ACP. In the case of this site, the Priority Protection sheet on page 26 of this document provides additional point of contact, response resource and staging area information for response at this site. The Protection Priorities section below lists these four Fort Pulaski sites in order of priority. v. Protection Priorities Fort Pulaski National Monument has identified the sensitive areas within park boundaries and set protection priorities for these sites in the event of a spill. Since it may be impossible to protect all sites simultaneously, the NPS has established protection priority levels for sensitive sites. Protection priorities are designated in terms of their order of protection when threatened by a spill: Priority A sites are to be protected first; Priority B sites are to be protected once all the Priority A sites at risk have been protected; and Priority C sites are to be protected once all the Page 11 of 57

12 NPS Annex to the Savannah COTTP Zone ACP Priority A and B sites at risk have been protected. Only those priority areas at risk should be protected. Protection strategies are based on the most likely threat of a spill on water and the placement of booms to exclude or deflect the floating slick. The spill trajectory is an important consideration in identifying the areas at risk, so that protection resources are used most efficiently. Trajectory analysis is provided by the NOAA Scientific Support Coordinator. Details for each priority site, including suggested protection strategies, are outlined on the Protection Priority forms on pages Protection priorities for Fort Pulaski National Monument are as follows: Table 1. Priority Areas at Fort Pulaski National Monument Priority Level Site number A FOPU 1 A FOPU 2 A FOPU 3 A FOPU 4 Site Name Cockspur lighthouse Island North Pier beach/wetland Oyster Creek at Tybee River Oyster Creek at Lazaretto Creek Priority Levels: A = Protect first B = Protect after A C = Protect after B Resources Historic structure, oyster beds cultural resources / wetland access point tidal flat / wetlands tidal flat / wetlands Resource Type C/E C/E E E Access / Staging Area Boat only / Ramp at US 80 and Lazaretto Creek Light vehicle access to pier / small parking area Boat only / Ramp at US 80 and Lazaretto Creek Boat only / Ramp at US 80 and Lazaretto Creek Resource types: C = Cultural Resources E = Environmental H = Human Use Protection Strategy Deflective boom Sand/Shell berm as natural barrier Exclusion booming Exclusion booming Each protection priority site is shown on the accompanying map (p. 22), using the three, two or one diamond symbols to designate an A, B, or C priority and number to identify the site. For each site, there is a detailed priority site summary that provides appropriate information about the resources at risk and the recommended protection strategy. All four priority sites on Fort Pulaski lands are three diamond, A Priority level. Page 12 of 57

13 NPS Annex to the Savannah COTTP Zone ACP vi. Park Emergency Management Structure a. Notification and Key Contacts Table 2. Points of Contact, Fort Pulaski National Monument Type of # Affiliation Name Position resource expertise Business contact After hours contact 1 Primary park Administrative Tammy Herrell contact Officer All (912) (912) Secondary Natural Resources park contact Manager (912) Tertiary park contact 4 NPS Dispatch NPS Emergency 24-hour National Incident Command N/A NPS Dispatch Center (EICC) National NPS Spill Response Dave Anderson N/A contact Coordinator (202) (240) Southeast Region 6 Regional Mark Ruggiero Emergency Services N/A (404) x619 (850) contact Coordinator Resource types: C = Cultural Resources E = Environmental H = Human Use b. Available Response Resources Fort Pulaski National Monument has a limited number of personnel trained for specific spill containment and cleanup duties. In the event of a spill, Park staff will function primarily in support and oversight roles. Fort Pulaski also has some communications, marine and terrestrial equipment available for emergency response. The following table lists Park personnel trained in specific support roles as of April 2008, as well as available equipment and areas to stage response. Table 3. Response resources available at Fort Pulaski National Monument (4/08) Number Notes years, levels, Resource Type Names / Kind Available locations Trained Staff HAZWOPER 1 Tammy Herrell 2 Trained Staff SCAT (Shoreline Countermeasure / Cleanup 1 Assessment Team) Tammy Herrell experience from spill cleanup in 2006 and Deep Horizon Trained Staff ICS 1 Tammy Herrell ICS 100, 200, 300 and 400. Served as Finance Section Chief during Katrina Trained Staff Federal Law Enforcement 0 N/A Trained Staff EMT 0 N/A N/A Historic Properties Trained Staff 0 N/A N/A Specialist Parking areas, boat Visitor s Center parking lot, Staging Areas Operations 2 dock, helispot** admin. offices area (dock Page 13 of 57

14 NPS Annex to the Savannah COTTP Zone ACP and helispot) Equipment Communications 5 Telephone lines in Administrative offices Equipment Marine 2 Equipment Terrestrial 1 Tractor Equipment Terrestrial 7 Golf carts **See map on page 14 for Staging area locations. Class 1 single engine outboard boats 18 ft., 5-6 person capacity with front-end loader / Maintenance shed Maintenance shed, Admin. garage vii. Park Strategies a. Cleanup Strategy The resource maps incorporated into this Annex identify potential response measures by shoreline type. Note that these are potential cleanup strategies. No categorical approval has been given for their use. There is great potential in shoreline cleanup to do more harm than good, especially in the area of archeological sites. All shoreline cleanup crews will be monitored by a ranger or resource specialist who is familiar with resource concerns in the area. b. Wildlife Conservation Strategy Five federally listed threatened or endangered species and one state listed / federally protected species reside on Fort Pulaski National Monument lands. The seasonality, habitat, and location on Park lands are provided for each species in the table below. An issue of significance to note is that special laws exist to protect the Bald Eagle. The Fish and Wildlife Service has issued the National Bald Eagle Management Guidelines, which provides breeding season sensitivity information and recommendations to avoid breaking those laws and to mitigate potential impacts on Bald Eagles during response efforts. 6 Fort Pulaski otherwise defers to the US Fish and Wildlife Service for wildlife conservation strategy in the event of a spill. Table 4. Threatened and endangered species present on Fort Pulaski National Monument lands. Species Birds Federal Status State Status Habitat Season Location on FOPU Lands Wood stork E E Bald eagle T Primarily feed in fresh and brackish wetlands; nest in cypress or other wooded swamps. Active rookeries in Chatham County as of Nests in trees adjacent to waterways Jun-Nov Breeding season: Sep- Jun. Eagles sensitive to disturbance Commonly seen foraging on tidal flats and along trails on McQueens Island. Commonly seen flying over the park while foraging for fish. 6 USFWS National Bald Eagle Management Guidelines, pgs Page 14 of 57

15 NPS Annex to the Savannah COTTP Zone ACP Piping plover T T Mammals Manatee E E Reptiles Loggerhead sea turtle T T Fish Primarily feed in fresh and brackish wetlands. Maintains a broad grazing range in warm, marshy coastal waters. Nests on barrier island sand beaches; forages in warm ocean waters and river mouth channels Sep-May Jun- Oct Nest: May- Aug; Hatch: Jul-Oct Dec-Aug; Shortnose Spawn: Febsturgeon 1 E E Atlantic seaboard rivers May 1 This species is the responsibility of the National Marine Fisheries Service. Frequently seen loafing or foraging in intertidal areas. Sightings occur mainly in the South Channel and in Oyster Creek. Sighted foraging in Oyster Creek marshes and creek ways in south McQueens Island wetlands. Range includes waters surrounding Cockspur Island; up-river west of the island to the exposed tidal flat in river mouth viii. Recreational Uses and Visitor Protection a. Park Land Use Zoning The dike and trail systems and the access bridge on Fort Pulaski National Monument are vulnerable to damage in the event of a spill and emergency response. The dike system can support only light vehicles to avoid damage to the historic structures. The trail system that provides the major access ways to the shoreline of Cockspur Island s North Channel side is best suited for golf cart traffic since pathways are narrow. A small truck with a front-end loader could pass through to the North Pier if necessary to build the shell berm barrier. b. Designated Wilderness Fort Pulaski National Monument has no designated wilderness areas. c. Public Use Facilities/Sites Fort Pulaski National Monument public use facilities include a visitor s center and network of trails in the surrounding area on Cockspur Island, as well as a hiker/biker trail along U.S. Highway 80 on McQueens Island. Annual visitation averages 348,000 people with heaviest visitation occurring in the summer months. Fort Pulaski supports minimal recreational fishing along the access bridge as well as from beaches on Cockspur Island s North Channel side. Beaches are not easily accessed and do not support recreational use. d. Park Facilities and Infrastructure Page 15 of 57

16 NPS Annex to the Savannah COTTP Zone ACP Three park facility and infrastructure issues at Fort Pulaski National Monument include: Three surface water intakes are located on Cockspur Island. They are controlled by a 36-inch, 24-inch, and an 18-inch flapper valve by the fort, to allow flushing of the moat around the fort. The valves are manually opened only when needed. Notifying NPS staff in the event of an oil discharge or hazardous chemical release will alert staff to keep intakes shut. Cockspur Lighthouse, North Pier, and Fort Greene are historic resources that need to be accessed with caution. (See map on pg. 22) The access bridge that connects Cockspur Island to U.S. Highway 80 / McQueens Island has both a weight restriction for vehicular traffic (30 tons normally, 10 tons currently - under construction) and a clearance restriction to pass underneath by boat of 8 feet at high tide and 15 feet at low tide. Page 16 of 57

17 NPS Annex to the Savannah COTTP Zone ACP FORT PULASKI NATIONAL MONUMENT: PROTECTION PRIORITY MAP no. 1 Page 17 of 57

18 NPS Annex to the Savannah COTTP Zone ACP FORT PULASKI NATIONAL MONUMENT: PROTECTION PRIORITY MAP no. 2 Page 18 of 57

19 A NPS Annex to the Savannah COTTP Zone ACP PRIORITY NPS PRIORITY AREA SUMMARY Date 14 July 2008 Name: Cockspur Lighthouse, Fort Pulaski Nati Site No. FOPU 1 Map Nos. 1and 2 Monument USGS Quad: Fort Pulaski, GA NOAA Chart: NOAA ESI Map#: GA-5 Agency /Contact: National Park Service, Fort Pulaski National Monument Phone: Primary: Tammy Herrell, Administrative Officer (912) or (912) Secondary: (912) Site Description: His structure, natural area Lat: Long: Tidal Range: Max Spring Tides = 9.7 ft Max Current: kts Geographic Location: Southeast tip of Cockspur Island, Fort Pulaski National Monument Physical Description: Lighthouse on small, eroding island with very little supratidal habitat. During the lowest high tides, the water reaches the base of lighthouse structure. SHORELINE TYPE (ESI ranking): 1. Exposed Rocky Shor 2. Wave Cut Platforms 3. Fine Sand Beaches 4. Coarse Sand Beaches 5.Sand & Gravel Beaches X 6. Shell Beaches X 7. Exposed Tidal Flats 8. Sheltered Rocky Shores 9. Sheltered Tidal Flats 10. Marshes 11. Man Made Structures Resources At Risk Seasonal Priorities: SP X SU X F X W X Habitats: Intertidal oyster beds, shell berms, fill material Wildlife: Bird loafing area Threatened/Endangered Species: Possible short-nosed sturgeon, West Indian manatee Other: Lighthouse is on the NPS List of Classified Structures and thus is of historical importance. The wood pilings at the base of the lighthouse have significant shipworm damage. Protection Strategies: Degree of Protectability: High Medium X Low Staging Areas: Lazaretto Creek boat ramp, about 1.7 miles south and up Lazaretto Creek. Collection Points: N/A Special Considerations: The site has high wave energy under normal conditions, thus it will be difficult to effectively boom around the lighthouse. Therefore, protection should be attempted only if there is a significant risk of impact, so not to waste resources. Access and Directions to the Site: No land-based access. Site is due north 0.5 miles from the mouth of Lazaretto Creek, and 1.7 miles from the Lazaretto Creek boat ramp which is located to the right off US 80 right before the bridge crossing Lazaretto Creek, on the road to Tybee Island. Protection Method: Boom: Deflect x Protect Recover Minimum Boom Length: ft. 600 boom configured as a hexagon around the lighthouse, 400 boom configured as a V in front of lighthouse. Can use both strategies at the same time. Any cleanup activities would have to be conducted under the supervision of the NPS. The Superintendent will direct any issues of dissatisfaction, concerns or recommendations regarding clean-up actions to the FOSC or Liaison Officer. Page 19 of 57

20 A PRIORITY NPS PRIORITY AREA SUMMARY Date: 7 January 2008 Site No. FOPU 2 Map Nos. 1 and 2 Name: North Pier, Fort Pulaski National Monument USGS Quad: Fort Pulaski, GA NOAA Chart: NOAA ESI Map#: GA-5 Agency /Contact: National Park Service, Fort Pulaski National Monument Phone: Primary: Tammy Herrell, Administrative Officer (912) or (912) Secondary: (912) or (912) Site Description: Lat: Cultural resource site, Long: Tidal Range: Max Spring Tides = 9.7 ft Max Current: kts wetland access Geographic Location: North shore of Cockspur Island, Fort Pulaski National Monument, along the North Channel of the Savannah River. Physical Description: Narrow, steep sand beach with eroding salt marsh scarps and a washover oyster shell berm. Behind the washover are extensive areas of salt marsh and muddy tidal flats. Floating contaminants could be washed over the berm during high water conditions (very high tides, storm waves) and enter the salt marsh. Pier end is composed of granite blocks. There are remains of wooden pilings offshore. SHORELINE TYPES (ESI ranking): 1. Exposed Rocky Shore 2. Wave Cut Platforms 3. Fine Sand Beaches 4. Coarse Sand Beaches 5.Sand & Gravel Beache X 6. Shell Beaches/ X 7. Exposed Tidal Flats 8. Sheltered Rocky Shores X 9. Sheltered Tidal Flats X 10. Marshes 11. Man Made Struct Resources At Risk Seasonal Priorities: SP X SU X F X W X Habitats: Major concern is the salt marsh/sheltered tidal flat behind the washover berm where hazardous material spills could persist and be very difficult to remove. Wildlife: Marsh/tidal flat area is highly used by birds for foraging. Threatened/Endangered Species: Possible short-nosed sturgeon, West Indian manatee Other: The remains of Fort Greene possibly lie below the pier and area to the west. Therefore, any excavation or removal actions would be of particular concern. Protection Strategies: Degree of Protectability: X High Medium Low Staging Areas: Ready vehicle access to the pier via the dike and/or trail. There is a small parking area just landward of the pier that could be used for staging. Collection Points:N/A Special Considerations: Because of the historic resources present, all work would have to be conducted under the supervision of NPS staff. Access and Directions to the Site: Located within the boundary of Fort Pulaski National Monument, off US 80. Protection Method: Boom: Deflect Protect Recover Minimum Boom Length: ft. Establish deflection strategy, will need 2600 boom The Superintendent will direct any issues of dissatisfaction, concerns or recommendations regarding clean-up actions to the FOSC or Liaison Officer.

21 A PRIORITY NPS PRIORITY AREA SUMMARY Date: 7 January 2008 Name: Oyster Creek, Fort Pulaski National Site No. FOPU 3 Map No. 1 Monument, at junction with Tybee River USGS Quad: Fort Pulaski, GA NOAA Chart: NOAA ESI Map#: GA-5 Agency /Contact: National Park Service, Fort Pulaski National Monument Phone: Primary: Tammy Herrell, Administrative Officer (912) or (912) Secondary: (912) or (912) Site Description: Lat: wetland Long: Tidal Range: Max Spring Tides = 9.7 ft Max Current: kts Geographic Location: Oyster Creek drains much of McQueens Island, which is within the boundary of the Fort Pulaski National Monument. It has connections to Lazaretto Creek, Tybee Creek, and Tybee River. This sheet describes the site where it connects with Tybee River. Physical Description: Extensive salt marsh habitat with extensive mud flats and oyster beds SHORELINE TYPES (ESI ranking): 1. Exposed Rocky Sh 4. Coarse Sand Beaches 2. Wave Cut Platform 5.Sand & Gravel Beaches 3. Fine Sand Beaches 6. Shell Beaches/ 7. Exposed Tidal Flats 8. Sheltered Rocky Shores X 9. Sheltered Tidal Flats X 10. Marshes 11. Man Made Structures Resources At Risk Seasonal Priorities: SP X SU X F X W X Habitats: Extensive salt marshes with large areas of open sheltered tidal flats and oyster beds Wildlife: Important area for birds. Valuable habitat for fish and shellfish. Threatened/Endangered Species: Possible short-nosed sturgeon, West Indian manatee, wood stork, sea turtles Other: Important shellfish area. One of only a few areas open to the public for recreational shellfish harvest. It is the only one in the Savannah area. High recreational use of waterways. Protection Strategies: Degree of Protectability: High X Medium Low Staging Areas: Lazaretto Creek boat ramp Collection Points: No specific sites have been identified. All of the shoreline is either salt marsh or tidal flat. Will need on-water recovery operations. Special Considerations: Boom anchoring system should be designed to deal with a tidal range of up to 9.7 feet. Access and Directions to the Site: No land-based access. Site is accessed via the Lazaretto Creek boat ramp, which is located to the right off US 80 right before the bridge crossing Lazaretto Creek, on the road to Tybee Island Protection Method: Boom: Deflect X Protect Recover Minimum Boom Length: ft. Exclusion booming to keep floating oil discharge or hazardous substances from entering the small tidal channels. Will need onwater recovery systems for spill recovery at containment/deflection sites. Will have to deploy booms at creek mouths because of extensive areas of very soft mud flats inside. Depending on the spill site and trajectory, it may be necessary to deploy booms at multiple sites to keep the spilled material out of Oyster Creek. The Superintendent will direct any issues of dissatisfaction, concerns or recommendations regarding clean-up actions to the FOSC or Liaison Officer.

22 A PRIORITY NPS PRIORITY AREA SUMMARY Date: 7 January 2008 Name: Oyster Creek, Fort Pulaski National Site No. FOPU 4 Map No. 1 Monument, at junction with Lazaretto Creek USGS Quad: NOAA Chart: NOAA ESI Map#: GA-5 Agency /Contact: National Park Service, Fort Pulaski National Monument Phone: Primary: Tammy Herrell, Administrative Officer (912) or (912) Secondary: (912) or (912) Site Descript Lat: wetland Long: Tidal Range: Max Spring Tides = 9.7 ft Max Current: kts Geographic Location: Oyster Creek drains much of McQueens Island, which is within the boundary of the Fort Pulaski National Monument. It has connections to Lazaretto Creek, Tybee Creek, and Tybee River. This sheet describes the site where it connects with Lazaretto Creek. Physical Description: Extensive salt marsh habitat with extensive mud flats and oyster beds. SHORELINE TYPE (ESI ranking): 1. Exposed Rocky Shore 2. Wave Cut Platforms 3. Fine Sand Beaches 4. Coarse Sand Beaches 5.Sand & Gravel Beaches 6. Shell Beaches/ 7. Exposed Tidal Flats 8. Sheltered Rocky Shores X 9. Sheltered Tidal Flats X 10. Marshes 11. Man Made Structures Resources At Risk Seasonal Priorities: SP X SU X F X W X Habitats: Extensive salt marshes with large areas of open sheltered tidal flats and oyster beds Wildlife: Important area for birds. Valuable habitat for fish and shellfish. Threatened/Endangered Species: Possible short-nosed sturgeon, West Indian manatee, wood stork, sea turtles Other: Important shellfish area. One of only a few areas open to the public for recreational shellfish harvest. It is the only one in the Savannah area. High recreational use of waterways. Protection Strategies: Degree of Protectability: High X Medium Low Staging Areas: Lazaretto Creek boat ramp Collection Points: No specific sites have been identified. All of the shoreline is either salt marsh or tidal flat. Will need on-water recovery operations. Special Considerations: Boom anchoring system should be designed to deal with a tidal range of up to 9.7 feet. Access and Directions to the Site: No land-based access. Site is accessed via the Lazaretto Creek boat ramp, which is located to the right off US 80 right before the bridge crossing Lazaretto Creek, on the road to Tybee Island Protection Method: Boom: Deflect X Protect Recover Minimum Boom Length: ft. Exclusion booming to keep floating spills from entering the small tidal channels. Will need on-water recovery systems for spill recovery at containment/deflection sites. Will have to deploy booms at creek mouths because of extensive areas of very soft mud flats inside. Creek mouth is about 850 feet wide, with marshes on both channels. Depending on the spill site and trajectory, it may be necessary to deploy booms at multiple sites to keep the spill out of Oyster Creek. The Superintendent will direct any issues of dissatisfaction, concerns or recommendations regarding clean-up actions to the FOSC or Liaison Officer.

23 B. Fort Frederica National Monument i. Authorities Enabling legislation: Fort Frederica National Monument was established as a National Monument on the barrier St. Simon s Island in Georgia on September 10, Monument lands cover 250 acres, including the Bloody Marsh Battle Site, six miles south of Fort Frederica, and approximately 100 acres of marshlands across from the fort adjacent to the Frederica River. ii. Jurisdiction Jurisdictional boundaries around Fort Frederica National Monument lands extend to the mean high tide mark on both the east and west sides of the Frederica River and around NPS owned marshlands. Fort Frederica National Monument, Map No. 1 shows the extent of marshlands opposite the fort (p. 32). Frederica River is under the jurisdiction of the state of Georgia. iii. Vulnerability to Damage from Hazardous Material Spills Fort Frederica National Monument is located 13 miles north of the Port of Brunswick, Georgia, that specializes in the handling of break-bulk, agri-bulk, and Roll-on Roll-off cargo ships. The Intracoastal Waterway crosses the mouth of the Frederica River. With a tidal range of up to 9.7 feet and very little freshwater input, tidal currents are strong and can transport spilled materials many miles upstream from the spill site. iv. Priority Resource Areas Fort Frederica National Monument lands host a few specific sites where the Monument s most sensitive natural and cultural resources require high priority or special spill protection. They may be damaged both directly by the contaminant and indirectly by the impacts of onshore clean-up activities. Among the resources at risk are: Marshes, waterfront Fort area, and submerged cultural resources of Fort Frederica Marshlands west of the Fort, across Frederica River Both of these areas are listed under high protection priority A185 on Response Map # GA- 25 in the Sector Georgia ACP, however little or no information is provided on the priority site sheet for protection or staging. The site map on page 32 and priority sheets on pages 33 and 34 offer specific information on the resources present and protection strategies recommended by National Park Service land managers.

24 v. Protection Strategies Fort Frederica National Monument has identified the sensitive areas within park boundaries and set protection priorities for these sites in the event of a spill. Since it may be impossible to protect all sites simultaneously, the NPS has established protection priority levels for sensitive site of A: protect first, B: protect after A, and C: protect after B. Details for each priority site, including suggested protection strategies, are outlined on the Protection Priority forms on pages Protection strategies are based on the most likely threat of a spill on water and the placement of booms to exclude or deflect the floating slick. Protection priority criteria for Fort Frederica National Monument are as follows: Table 5. Priority Areas at Fort Frederica National Monument Priority Site Resource Site Name Resources Level number Type Salt marsh, Fort Frederica A FOFR 1 intertidal area B FOFR 2 Wetlands west of Fort, across river submerged historic structure Marshlands Access / Staging Area C/E Road access / Small grassy area behind yacht club dock E Road access / Small grassy area behind yacht club dock Protection Strategy Deflective boom Deflective booming Priority Levels: A = protect first B = protect after A C = protect after B Resource types: C = Cultural Resources E = Environmental H = Human Use Each protection priority site is shown on Fort Frederica Map no. 1 on page 32, using a symbol and number to identify the site. For each site, there is a detailed priority site summary that provides appropriate information about the resources at risk and the recommended protection strategy. For cultural resources, appropriate park staff must be consulted for any ground disturbing activities or actions that may affect a historic structure/site. vi. Park Emergency Management Structure a. Notification and Key Contacts Table 6. Points of Contact, Fort Frederica National Monument Affiliation Name Position Type of expertise Chad A C/H Primary Park Thomas, Chief of Maintenance contact Tammy Administrative Officer All Herrell Secondary Cultural Resource C Denise Spear Park contact Specialist Tertiary Park Mary Beth All Superintendent contact Wester Dispatch EICC National Emergency N/A National NPS contact Dave Anderson Dispatch NPS Spill Response Coordinator N/A Business contact (912) (912) After contact hours (912) (912) (912) (912) (912) (912) (202) (240) Regional NPS Mark SE Region Emergency All (404) x619 (850)

25 contact Ruggiero Services Coordinator Resource types: C = Cultural Resources E = Environmental H = Human Use b. Available Response Resources Resource Fort Frederica National Monument has a limited number of personnel trained for specific spill containment and cleanup duties. In the event of a spill, Park staff will function primarily in support and oversight roles. Fort Pulaski also has some communications, marine and terrestrial equipment available for emergency response. The following table lists Park personnel trained in specific support roles as of April 2008, as well as available equipment and areas to stage response. Table 7. Response resources available at Fort Frederica National Monument (4/08) Number Type Names / Kind Available Notes years, levels, locations Trained Staff HAZWOPER 3 Chad Thomas,Brandon Lacey, JD Dornbush N/A SCAT (Shoreline experience from spill cleanup in 2006 and Deep Trained Staff Countermeasure / Cleanup 0 Tammy Herrell Assessment Team) Horizon Trained Staff ICS 0 N/A N/A Trained Staff Federal Law Enforcement 0 N/A N/A Trained Staff EMT 0 N/A N/A Historic Properties (912) , Trained Staff 1 Denise Spear Specialist (912) Staging Areas Operations 2 Equipment Communications 0 N/A Visitor s Center, field by Yacht Club dock** Equipment Marine 0 N/A N/A Equipment Terrestrial 1 Equipment Terrestrial 2 Golf carts John Deere Tractor w/scoop Equipment Terrestrial 1 Mid-sized pick-up truck Access Visitor s Center parking lot via Frederica Road, access field via dirt road from maintenance yard Some phone lines and radio channels may be available. Maintenance shed Parked outside Visitor s Center Equipment Terrestrial 3-4 Hand shovels Maintenance shed ** See Map on page 31 for Staging area locations vii. Park Strategies a. Cleanup Strategy The resource maps incorporated into this Annex identify potential response measures by shoreline type. Note that these are potential cleanup strategies. No categorical approval has been given for their use. There is great potential in shoreline cleanup to do more harm

26 than good, especially in the area of archeological sites. All shoreline cleanup crews will be monitored by a ranger or resource specialist who is familiar with resource concerns in the area. b. Wildlife Conservation Strategy One federally listed endangered species has been confirmed on Fort Frederica National Monument lands, the West Indian manatee. The seasonality, habitat, and location of manatee on or near Park lands are provided in Table 8 below. For more specific responserelated guidance, Fort Frederica defers to the US Fish and Wildlife Service for wildlife conservation strategy in the event of a spill. Table 8. Endangered species present on Fort Frederica National Monument lands. Species Federal Status West Indian Manatee E E State Status Habitat Season Coastal waters, estuaries, and warm water outfalls Apr-Nov Location on FOFR Lands Commonly seen foraging in and around Frederica River viii. Recreational Uses and Visitor Protection a. Park Land Use Zoning The village archeological site and the moat remains on Fort Frederica National Monument lands are vulnerable to damage in the event of a spill and spill response. The village occupies a large area between the Visitor s Center and the Fort. This area is considered sensitive and should not be driven on except by golf carts in the company of Park managers. The moat remains can support only light vehicles (golf carts) to avoid damaging the historic structures, and it is preferred that no vehicles drive across them. b. Designated Wilderness Fort Frederica National Monument has no designated wilderness areas. c. Public Use Facilities/Sites Fort Frederica National Monument public use facilities include a visitor s center and small network of trails in the surrounding area. Annual visitation averages 300,000 people with heaviest visitation occurring in the summer months. ix. Park Facilities and Infrastructure

27 Limited housing for responders may be available in the housing by the maintenance yard. However, it is currently under construction. Fort Frederica National Monument has no facilities available for wildlife rescue/rehabilitation or command posts.

28 FORT FREDERICA NATIONAL MONUMENT: PROTECTION PRIORITY MAP no.1

29 A PRIORITY NPS PRIORITY AREA SUMMARY Date: 14 July 2008 Site No. FOFR 1 Map No. 1 Name: Fort Frederica National Monument The pa the fort that is located in the intertidal zone USGS Quad: Brunswick West, GA NOAA Chart: NOAA ESI Map#: GA-25 Agency /Contact: National Park Service, Fort Frederica National Monument Phone: Primary: Chad A Thomas (912) or (912) Secondary: Denise Spear, Culture Resource Specialist (912) or (912) Site Description: partially Lat: submerged historic structure Long: Tidal Range: Max Spring Tides = 9.7 ft Max Current: kts Geographic Location: On the Frederica River, Fort Frederica National Monument, on the back side of St. Simons Island Physical Description: Part of the old fort that occurs in the intertidal zone. 1000m area of the Frederica River bottom adjacent to old fort s upland structure. SHORELINE TYPE 1. Exposed Rocky Shore 4. Coarse Sand Beaches (ESI ranking): 2. Wave Cut Platforms 3. Fine Sand Beaches 5.Sand & Gravel Beaches 6. Shell Beaches 7. Exposed Tidal Flats 8. Sheltered Rocky Shores 9. Sheltered Tidal Flats Resources At Risk Seasonal Priorities: SP X SU X F X W X Habitats: Salt marsh Wildlife: Bird concentration area X 10. Marshes 11. Man Made Struct Threatened/Endangered Species: West Indian manatee Other: Fort Frederica is on the National Register of Historic Places. Protection Strategies: Degree of Protectability: High Medium X Low Staging Areas: There is a grassy area behind the dock, accessible via a dirt road from the maintenance area that could be used for staging equipment without affecting the historical structures on the site Collection Points: N/A Special Considerations:. Access and Directions to the Site: From U.S. 17, take the F.J. Torras Causeway to St. Simons Island. At first traffic light on the island, turn left onto Sea Island Road. Go 1.5 miles to next traffic light, and turn left onto Frederica Road. Follow Frederica Road for two miles (take second right off roundabout). The park entrance is located 300 yards past Christ Church. Protection Method: Boom: Deflect x Protect Recover Minimum Boom Length: 3,000 ft. Deflection booming should be deployed so it is effective during both flood and ebb tidal conditions. No shore-based collection point available. Any cleanup activities would have to be conducted under the supervision of the NPS. The Superintendent will direct any issues of dissatisfaction, concerns or recommendations regarding clean-up actions to the FOSC or Liaison Officer. 29

30 B PRIORITY NPS PRIORITY AREA SUMMARY Date:14 July 2008 Site No. FOFR 2 Map No. 1 Name: Wetlands adjacent to and across from the Frederica National Monument USGS Quad: BrunswNOAA Chart: NOAA ESI Map#: GA-25 West, GA Agency /Contact: National Park Service, Fort Frederica National Monument Phone: Primary: Kim Coons, Chief Ranger (912) or (912) Secondary: Denise Spear, Cultural Resource Specialist (912) or (912) Site Descript Lat: wetlands Long: Tidal Range: Max Spring Tides = 9.7 ft Max Current: kts Geographic Location: On the Frederica River, Fort Frederica National Monument, on the back side of St. Simons Island Physical Description: The salt marsh on both sides of the Frederica River in front of the fort. SHORELINE TYPE 1. Exposed Rocky Sh 4. Coarse Sand Beaches (ESI ranking): 2. Wave Cut Platform 5.Sand & Gravel Beaches 3. Fine Sand Beaches 6. Shell Beaches 7. Exposed Tidal Flats 8. Sheltered Rocky Shores 9. Sheltered Tidal Flats Resources At Risk Seasonal Priorities: SP X SU X F X W X Habitats: Salt marsh X 10. Marshes 11. Man Made Structure Wildlife: Bird concentration area Threatened/Endangered Species: West Indian manatee Other: Fort Frederica is on the National Register of Historic Places. The salt marshes are a key element of the viewscape of the park. Protection Strategies: Degree of Protectability: High X Medium Low Staging Areas: There is a grassy area behind the dock, accessible via a dirt road from the maintenance area that could be used for staging equipment without affecting the historical structures on the site Collection Points: N/A Special Considerations:. Access and Directions to the Site: From U.S. 17, take the F.J. Torras Causeway to St. Simons Island. At first traffic light on the island, turn left onto Sea Island Road. Go 1.5 miles to next traffic light, and turn left onto Frederica Road. Follow Frederica Road for two miles (take second right off roundabout). The park entrance is located 300 yards past Christ Church. Protection Method: Boom: Deflect x Protect Recover Minimum Boom Length: 1,000 ft. Deflection booming should be deployed so it is effective during both flood and ebb tidal conditions. No shore-based collection point available because the entire adjacent habitat is salt marsh. It is estimated that 500 feet of boom will be needed for each side of the shoreline on the Frederica River. Any cleanup activities would have to be conducted under the supervision of the NPS. The Superintendent will direct any issues of dissatisfaction, concerns or recommendations regarding clean-up actions to the FOSC or Liaison Officer. 30

31 C. Cumberland Island National Seashore i. Authorities Enabling Legislation: Cumberland Island National Seashore, consisting of the area depicted on Boundary Map Cumberland Island National Seashore, CUIS-40,000B, was established by Act of Congress Public Law (86 Stat, 1066) on October 23, This Act also allowed the purchase of up to 100 acres on the mainland to provide access to the administrative and visitor facilities for the seashore. In 1978, Public Law (92 Stat, 3473) amended the previous Act of Congress referencing Boundary Map Cumberland Island National Seashore, CUIS-40,000D to hold the Park unit s new boundaries. (See Figure 2, p.36) Congressional Statement of Purpose: Congress established Cumberland Island National Seashore in order to provide for public outdoor recreation use and enjoyment of certain significant shoreline lands and waters of the United States, and to preserve related scenic, scientific, and historical values. ii. Jurisdiction The National Park Service has proprietary jurisdiction on Cumberland Island to the mean high tide line. The Corps of Engineers retains spoil areas near the south end of the island (below Dungeness) and Drum Point Island. The legislation calls for mutual agreement between NPS and the Corps on plans relating to water resource developments. The Georgia Department of Natural Resources has jurisdiction over the tidal beaches and marshlands below the mean high tide level. Response and cleanup actions along the shoreline of Cumberland Island National Seashore may require approval by both the State of Georgia and the National Park Service. iii. Vulnerability to damage from oil discharge or release of hazardous substances Cumberland Island National Seashore s vulnerability to spills is highest at the south end of the island where boat traffic through St. Marys Entrance and Cumberland Sound is heaviest. The Port of Fernandina is located in the Amelia River approximately 2 miles upstream from the mouth, and approximately 3.3 miles from Cumberland Island s southern tip. Shrimp boats, island ferries, and pleasure craft traffic passes through the area to and from St. Marys. Vessel traffic from the Kings Bay Naval Submarine Base enters Cumberland Sound from the northwest. The Intracoastal Waterway also passes along the length of Cumberland Island on Cumberland Sound. With a tidal range of up to 8.6 feet, tidal currents are strong and can quickly spread slicks far up tidal channels and into sensitive habitat areas. 31

32 Figure 2. Map of CUIS with boundaries, facilities, and roads. Mainland NPS lands at St. Mary s marked in yellow. 32

33 iv. Priority Resource Areas Cumberland Island National Seashore lands host a number of specific sites where the Seashore s most sensitive natural and cultural resources require high priority or special spill protection measures. Some of these areas are gateways for oil or hazardous substances to enter important wetland habitats. These habitats may be damaged directly by the contaminant and indirectly by the impacts of onshore clean-up activities. Among the resources at risk are the following areas: Cultural resource area north of Dungeness Dock Dungeness and Sea Camp Docks Raccoon Keys and adjacent tidal creeks Beach Creek South End tidal flat, tidal creeks, and marsh Three intermittent creek outflows along Atlantic Ocean Beach Tabby terrapin pen and other historic features, and dock at Plum Orchard Christmas Creek, Long Point Cultural resource area along Brickhill Bluff These sites are not listed as high protection priorities in the Sector Georgia ACP, with the exception of the north Brickhill River site, labeled A182 on Response Map # GA-32. The NPS protection priority at this site is further downstream along the upland bluff, where significant cultural resources reside. The Priority Protection sheet on page 57 provides location specific information, points of contact and recommended protection strategies. v. Protection Strategies Cumberland Island National Seashore has identified the sensitive areas within park boundaries and set protection priorities for these sites in the event of a spill. Since it may not be possible to protect all sites simultaneously, the NPS has established protection priority levels for sensitive sites of A: protect first, B: protect after A, and C: protect after A and B. Protection strategies are based on the most likely threat of a spill on water and the placement of booms to exclude or deflect the floating slick. Protection priorities for Cumberland Island National Seashore are as follows: Table 9. Priority Areas at Cumberland Island National Seashore Priority Site Level number Site Name Resources A CUIS 1 Bluffs north of Dungeness Dock Cultural resources B CUIS 2 Dungeness Dock high use dock, manatee loafing area A CUIS 3 Raccoon Keys Tidal flat with fringe salt marsh, fiddler crab burrows Resource Type C/E E/H Protection Strategy Protection boom Protection booming E Protection boom / sediment barrier 33

34 A CUIS 4 Beach Creek A CUIS 5 South End tidal flat B CUIS 6 Three creek outflows A CUIS 7 Terrapin pen, Plum Orchard A CUIS 8 Christmas Creek A CUIS 9 Brickhill bluff Tidal flat, salt marsh, shorebirds Tidal creeks, salt marsh, shorebird and plover area Stream entrances to wetlands, nest sites historic structure, oyster beds, mud flat Shorebird, plover and turtle foraging area Cultural resources, shorebird, turtle, marine mammal foraging area E Exclusion booming E Exclusion booming E Protection boom / sediment barrier C/E Protection booming E Exclusion booming C/E Deflection booming Priority Levels: A = Protect first B = Protect after A C = Protect after A and B Resource types: C = Cultural/Archeological E = Environmental H = Human Use Each protection priority site is shown on the accompanying maps (pages 45-48), using diamond symbols and a number to identify the site. For each site, there is a detailed priority site summary that provides appropriate information about the resources at risk and the recommended protection strategy. vi. Park Emergency Management Structure a. Notification and Key Contacts Table 10. Points of Contact, Cumberland Island National Seashore Type of Resource After hours Affiliation Name Position Expertise Business contact contact Primary park contact Dennis Parsons Chief Ranger All (912) x258 (912) Secondary Chief Resource park contact John Fry Management C/E (912) x262 (912) CUIS Radio Park Ranger H Coordinator Eric Ulitalo (Protection) (912) National NPS NPS Spill Response N/A contact Dave Anderson Coordinator (202) (240) National Dispatch Regional NPS contact Emergency Incident Coordinator (EICC) Mark Ruggiero 24-hour NPS National Emergency Dispatch SE Region Emergency Services Coordinator N/A (24 hour) N/A N/A (404) x619 Resource types: C = Cultural/Archeological E = Environmental H = Human Use (850)

35 b. Available Response Resources Cumberland Island National Seashore has a limited number of personnel trained for specific spill containment and cleanup duties. In the event of a spill, Park staff will function primarily in support and oversight roles. The following lists Park personnel trained in specific support roles, as well as equipment available on-site for emergency response: Table 11. Response resources available at Cumberland Island National Seashore (4/08) Resource Type Number Notes years, levels, Names / Kind Available locations Trained Staff HAZWOPER Current: Carl David Doug and John will renew 1 current, 2 Expired: Doug Hoffman, John (24 hour ) training in expired Fry spring of 2008 SCAT (Shoreline Trained Staff Countermeasure / 0 Cleanup Assessment N/A N/A Team) Trained Staff ICS 3 Dennis Parsons, Dennis Curry, Eric Ulitalo Basic ICS training Trained Staff Federal Law Dennis Parsons, Dennis Curry, 3 Enforcement Eric Ulitalo N/A Trained Staff EMT 2 Dennis Curry, Eric Ulitalo N/A Trained Staff Historic Properties (912) x262 1 John Fry Specialist (912) Captain s House, Carriage Operations Facilities for House, and Resource 3 Dungeness Complex Command Post Management/YCC facilities Operations Staging Areas for Plum Orchard, Dungeness 2 Response Complex See info. below* Operations Camps for Plum Orchard campgrounds, 2 Responders Dungeness Complex See maps for locations Stafford Field, High Point / Airstrips / Dungeness Field, Beach Field, Landing areas 2 / 4 Helispots Stafford Field, Plum Orchard See map on pgs mansion lawn Docks / Landings/ Boat Ramps Boat launch and landing areas Fuel 7 Fueling stations 2 3 / 2 / 1 Equipment Communications various Plum Orchard dock, Dungeness dock, Sea Camp dock / Plum Orchard landing, Dungeness landing / Crooked River State Park public boat ramp Dungeness Carriage House has gas and diesel for vehicles, boats can re-fuel at St. Mary s fuel dock 16 Radio Channels, 4 base stations, 1 repeater See maps for dock and boat ramp locations. Boat landings can be used for heavy equipment. Contact park staff for more details. See maps pgs All NPS boats and vehicles are equipped with radios. See info. below** Equipment Marine 9 Vessels from 66 ft. to 12 ft. See list below*** Equipment Terrestrial 1 John Deere 410 E Tractor with front-end loader and backhoe / Maintenance 7 A method to account for fuel used during response will need to be identified for reimbursement purposes. 35

36 Equipment Terrestrial 1 John Deere 2155 Tractor with front-end loader / Maintenance shed Equipment Terrestrial 1 John Deere 850 Tractor Maintenance shed Equipment Terrestrial 1 Road Grader Maintenance shed Equipment Terrestrial 10 / 7 shovels / axes, variety of rakes Maintenance shed shed Maintenance shed(s) located next to Carriage House in Dungeness Complex, on island. * Staging areas /facilities for response, dock and landing locations: Plum Orchard has campgrounds with bathrooms and drinking water. It is a possible staging area for spill response in the western mid-island intertidal marshlands area. Access via Table Point Road. Plum Orchard dock has approximately 60 ft of dock space and a limited landing area for off-loading vehicles and equipment. Dungeness Complex has kitchen facilities, barracks (30 beds; facilities could hold more if cots were brought in), maintenance facilities (carpenter shop, welding equipment, hand tools). The complex is located on the south end of the island approximately ½ mile east of the Dungeness Dock. Dungeness Dock has approximately 90 ft of dock space and a landing area for off-loading vehicles and equipment. This dock is located on the south end of the island. Sea Camp Dock has approximately 90 ft of dock space. This dock is located approximately 1 mile north of Dungeness Dock. Greyfield Inn has approximately 40 beds. This facility is a privately owned bed-and-breakfast operation with high end rates starting at $300 per night. As such, it is not considered an option for housing spill team members. Airstrips located at Stafford Field and High Point. Many areas are bird roosts or otherwise sensitive to overflights. Superintendent / Park managers must be consulted prior to any air operations inside the Park unit. (maps, ps ) Helicopters can land at Dungeness Field, Beach Field, Stafford Field, and Plum Orchard Mansion lawn. (maps, ps ) ** Communications Equipment: Radio Base Stations are located at the Captain s House, Sea Camp Visitor Center, and Carriage House on the island. There is also a base unit at the mainland Visitor Center in St. Marys. There is one repeater at the Plum Orchard emergency radio tower. All boats are equipped with marine VHF radios. Two boats, the Boston Whaler and the Skiff have Park radios installed. All CUIS certified boat operators carry handheld Park radios. 36

37 Ranger vehicles (4) and Resource Management vehicles (3) are equipped with Park radios. All Park personnel have cell phones. There are cell phones and land-line telephones located on the island at Sea Camp Visitor Center, the Captain s House, and the resource management field office. In the event of a spill, an in-house document with cell phone numbers and radio call numbers could be made available to spill teams. Eric Ulitalo is the CUIS Radio Coordinator; (912) *** Marine Equipment: 1 32 ft. maintenance crew transport boat, enclosed cabin with some open storage space in stern capacity: 20 persons, 4,000 lbs 1-23 ft. Parker Model 2320 resource management boat, enclosed cabin with open storage space in stern capacity: 9 persons, 2050 lbs 1 23 ft. Parker Model 23 Sport patrol boat capacity: 10 persons, 1900 lbs 1 Boston Whaler Model 25 Challenger patrol boat, enclosed cabin, bench seat in rear, used for emergency medical transport capacity: 12 persons, 3035 lbs 1 21 ft. Contender patrol boat, open center console capacity: unknown 1 23 ft Maritime Skiff, Model Maritime 23, small enclosed cabin capacity: 8 persons, 1950 lbs 1 66 ft, landing craft, used for transporting vehicles and equipment, 45-foot forward deck space capacity: 50,00 lbs 1 12 ft john boat, without motor 1 15 ft john boat, without motor *Note: Additional support may be available from the ferry concessioner. The two ferries used to transport visitors have a capacity of approximately 146 people per vessel. Logistics of reserving the boat(s) would need to be secured as far in advance as possible. Concessioner would likely charge fees for use. Ferry Concessioner Contact Information: Lang Seafood, Inc

38 Boat Ramps There is a public boat ramp (2 ramps) adjacent to the Cumberland Island Visitor Center in St. Marys. There is another public boat ramp located on the North River approximately one mile from the visitor center. Travel times from St. Marys to the island range from 15 to 30 minutes depending on the boat size, load, and weather/water conditions. A third public boat ramp is available for use at Crooked River State Park. This ramp is further north and located closer to the central and northern sections of Cumberland Island. vii. Park Strategies a. Cleanup Strategy The resource maps incorporated into this Annex identify potential response measures by shoreline type. Note that these are potential cleanup strategies. No categorical approval has been given for their use. There is great potential in shoreline cleanup to do more harm than good, especially in the area of archeological sites. All shoreline cleanup crews will be monitored by a ranger or resource specialist who is familiar with resource concerns in the area. b. Wildlife Conservation Strategy Five federally listed species reside on Cumberland Island National Seashore. The seasonality, habitat, and location on Park lands are provided for each species in Table 12 below. For more specific response-related guidance, Cumberland Island defers to the US Fish and Wildlife Service for wildlife conservation strategy in the event of a spill. Table 12. Listed species present on Cumberland Island National Seashore. Species Birds Federal Status Wood stork E E Piping plover T T Mammals State Status Habitat Season Location on CUIS Lands Primarily feed in fresh and brackish wetlands; nests in cypress or other wooded swamps. Active rookeries were found in Chatham County in 2001 and Winter on Georgia's coast; prefer areas with expansive sand or mudflats (foraging) or in close proximity to a sand beach (roosting) Jun-Nov Aug-May Wood storks forage and loaf in the numerous mud flats in marshes and freshwater wetlands on CUIS. One known roost site is Plum Orchard pond. There are currently no known nesting colonies on CUIS. (Protection Priority sites Nos. 3 and 6 B) Piping plovers loaf and forage along the entire stretch of beach from the St. Marys Entrance jetty to the northern tip at Christmas Creek (Protection Priority Nos. 5, 6A-C, 8) 38

39 West Indian Manatee E E Northern Right Whale E E Reptiles Loggerhead sea turtle T T Coastal waters, estuaries, and warm water outfalls Mate and calve in shallow coastal waters Nests on Georgia's barrier island sand beaches; forages in warm ocean waters and river mouth channels Apr-Nov Nov-May; Calving: Nov- Mar Nest: May- Aug; Hatch: Jul-Oct Commonly seen at Sea Camp and Dungeness Docks and the south end of CUIS (Protection Priority site No. 2, 4 Whales are present off the Georgia Coast during calving season. Location information can be obtained from the survey crew if needed during spill response operations. Nesting occurs along the entire stretch of beach from below the St. Marys Entrance jetty to the northern tip at Christmas Creek (Protection Priority Nos. 5, 6, and 8) viii. Recreational Uses and Visitor Protection a. Park Land Use Zoning Spill responders should be aware that there are private/retained-rights properties on the island. (See maps on pages 45-48) These in-holdings are scattered along the island with larger pockets including the Greyfield Inn and surrounding acreage, the Rockefeller tract between Sea Camp and Greyfield, the Stafford Mansion area, the Perkins tract at Malkintooth Creek, the High Point Complex and all of the uplands on Little Cumberland Island to the north of Christmas Creek. These lands are not owned or managed by the NPS. b. Designated Wilderness CUIS lands include 8,840 acres of designated wilderness located in the northern half of the island, from Willow Pond north to North Cut Road and west to Burbank and Terrapin points excluding a 25-foot right-of-way along the Main Road, Plum Orchard Spur, and North Cut Road. The restriction of use for the wilderness area follows the minimum requirement concept as outlined in the Wilderness Act. The Act states that use of equipment and vehicles/aircraft shall be permitted only as necessary to meet the minimum requirements for administration/management of the area, the extent of which shall be determined by the Park unit s Superintendent and Park managers. 8 Mechanized equipment use for spill response at Cumberland Island will be evaluated on a case-bycase basis by park staff. 9 8 NPS Management Policies, pgs To facilitate a fast and effective response and reduce paperwork, park units with wilderness areas should consider creating a special-use permit that pre-approves certain response activities such as over-land access for walk-in crews OR access via boats only, temporary approval for use of motorized boats to access backwater sloughs, marshes, creeks, etc., approval to deploy protective booming, or for manual cleanup using hand-tools/sorbent pads, etc. The conditions of such a permit should recognize the size and significance of a spill incident. The above stated response activities would help protect wilderness values in a high-impact spill, whereas in a light oiling/sheen scenario the park might determine that no action is the best action. 39

40 c. Public Use Facilities/Sites Cumberland Island National Seashore (CUIS) averages 43,000 visitors per year, with the heaviest visitation of the island, and visitor use of campgrounds, occurring in March and April. Daily visitation to CUIS via the concessioner-run ferry is capped at 300 per day. Additional day visitation occurs in the form of private boaters and private charter trips offered by the concessioner ferry. CUIS issues up to 60 camping permits per day for Sea Camp campground. Backcountry campsites are limited to a total of 60 persons per day. More specifically, backcountry campsites (Brickhill Bluff, Yankee Paradise, Stafford Beach and Hickory Hill) are capable of supporting 20 campers per night. Cumberland Island public use facilities include the Sea Camp visitor contact station, Ice House Museum, Plum Orchard Mansion, campgrounds and networks of trails that run throughout the island. Visitor day use is most concentrated on the trails around the Dungeness ruins and the ocean beach on the south end of the island. Sea Camp Ranger Station is located 1 mile north of the Dungeness area. Cumberland Island supports recreational fishing along the shore as well as in the streams, lakes and marshes throughout the island. Beaches are easily accessed via trails and support a fair amount of recreational use. The park also hosts six managed public deer/hog hunts each season from October through January within the island's Wilderness boundary. Hunter numbers range from 50 to Hunters typically camp at the Hunt Camp located just south of Plum Orchard Mansion or the Brickhill Campsite at Brickhill Bluff. ix. Park Facilities and Infrastructure a. Human-Use Resources Facilities appropriate for command post/wildlife rescue include the Captain s House, Carriage House, and Resource Management/YCC facilities in the Dungeness area. See map on page

41 CUMBERLAND ISLAND NATIONAL SEASHORE; MAP OF PROTECTION PRIORITIES 41

42 CUMBERLAND ISLAND NATIONAL SEASHORE; PROTECTION PRIORITY MAP 1, with responder informatio 42

43 CUMBERLAND ISLAND NATIONAL SEASHORE; PROTECTION PRIORITY MAP 2, with responder information 43

44 CUMBERLAND ISLAND NATIONAL SEASHORE; PROTECTION PRIORITY MAP 3, with responder information 44