CLAIM SUMMARY / DETERMINATION FORM

Date : 02/25/2010 

Claim Number : N08057-023 

Claimant : Express Marine Inc.

Type of Claimant : Corporate (US)

Type of Claim : Loss of Profits and Earning Capacity 

Claim Manager : 

Amount Requested : $201,369.83 

I. Facts 

Tug Baltimore & Barge EMI 1850 

On the morning of July 23, 2008, the tank barge DM 932 sank as a result of a collision and 

discharged oil into the Mississippi River, a navigable waterway of the United States. 

II. Responsible Party

American Commercial Lines LLC (ACL) owned the barge at the time of the incident and is a 

responsible party (RP) under the Oil Pollution Act. 

III. Claimant 

Express Marine Inc. has a fleet of tugs and barges which transport dry bulk and liquid cargoes 

along the Atlantic and Gulf Coasts, Caribbean and associated bays, harbors and rivers. They are 

the registered owners and operators of the U.S. Flagged vessels Baltimore and EMI 1850. 

IV. Claim Description 

A. Original Claim Submission

1. The law firm of Palmer Biezup & Henderson LLP, representing Express Marine Inc., 

submitted a Loss of Profits and Earning Capacity claim for damages and losses resulting 

from the July 23, 2008 oil discharge in the Mississippi River from barge 932. The claim was 

received at the National Pollution Fund Center (NPFC) on May 12, 2009 in the amount of 

$142,679.88.

1

 The Claimant requests $113,238.00 in demurrage/delay time, alleging that on 

two separate occasions, their vessels were delayed a total of 167.76 hours. Claimant alleges 

that under the contract of affreightment, they would have been able to collect demurrage 

payable at $675.00 per hour for 167.76 hours of delay equaling $113,238.00, if the oil spill 

had not created a valid Force Majeure event. The Claimant also requests 20% ($22,647.60) 

in administrative expenses related to the delay. This additional amount is requested to cover 

activities that it’s administrative and management personnel undertake.2

 In addition, 5% 

($6,794.28 total) is claimed as interest on both the delay ($5,661.90) and administrative 

expenses ($1,132.38). 

 

1 See, Palmer Biezup & Henderson LLP letter to the NPFC dated May 6, 2009. 2 See, Palmer Biezup & Henderson LLP letter to the NPFC dated May 6, 2009, page 6, para. 2.

(b) (6)
2. At the time of the oil spill, Express Marine Inc. was operating the tug Baltimore and barge 

EMI 1850 under a contract of affreightment with Progress Fuels Corporation (PFC). PFC 

purchases coal for use in an electric generating plant owned and operated by Progress Energy 

Florida, Inc. (PEF), located near Red Level, Citrus County, Florida, known as the Crystal 

River Plant. The contract of affreightment required Express Marine to provide a dedicated 

seagoing tug and barge unit to transport coal to the Crystal River Plant on a continuous basis 

from terminals nominated by PEF. The tug Baltimore and barge EMI 1850 (herein known as 

“vessels”) were utilized exclusively by Express Marine to transport coal under the contract of 

affreightment. 

3. In July, 2008, PEF was utilizing the International Marine Terminal (IMT) to supply coal 

for loading by Express Marine under the affreightment contract. IMT is located in Myrtle 

Grove, Louisiana on the West Bank of the Mississippi River at Lower Mississippi River 

(LMR) mile 57.

4. Under the legal analysis section of the Claimants submission letter, the Claimant states 

they are not submitting any corporate financial statements and that they are irrelevant to the 

evaluation or the payment of the claim.”3

B. Amended Sum Certain With New Delay Valuation 

While responding to a National Pollution Fund Center (NPFC) request for additional 

information, the Claimant amended the claimed amount to $201,369.83.

4

 In this letter, the 

Claimant provided an attached “cash flow” spreadsheet, which they allege shows that on 

average the tug Baltimore and barge EMI 1850 loaded at IMT on the Mississippi River every 

seven days and the invoiced amount for each trip averaged $162,133.52. The Claimant then 

states that considering the 167.76 hours (6.9 days) delayed as alleged in the first presentment 

of the claim, the loss now equals $159,817.33 in damages ($162,133.52 / 7 = $23,161.93 and 

6.9 x $23,161.93 = $159,817.32). The Claimant also requests 20% ($31,963.46) in 

administrative expenses related to the delay and 5% ($9,589.04 total) as interest on both the 

delay ($7990.87) and administrative expenses ($1,598.17). 

C. Vessel Delays

1. First Delay – Loading 

On July 25, 2008, after discharging cargo at the Crystal River Plant, the vessels received 

orders from PEF to immediately proceed to IMT for loading. Upon arrival at the mouth of 

the Mississippi River, the vessels were forced to anchor at Southwest Pass on July 27, 2008 

at 1305 local time (LT). On July 28, 2008 at 1900 LT, the vessels were granted permission 

by the Coast Guard to transit up river to the Magnolia Anchorage. The vessels arrived at this 

anchorage on July 29, 2008 at 1200 LT. On July 30, 2008, at 1010 LT the vessels shifted to 

the upper end of Pt. Celeste Anchorage to wait for the loading berth. Loading of the vessels 

did not commence until August 1, 2008 at 1140 LT, allegedly due to a backlog of vessels at 

IMT caused by the oil spill. Total hours claimed on this first delay are 118.59. 

2. Second Delay – Loading 

 

3 See, Palmer Biezup & Henderson LLP letter to the NPFC dated May 6, 2009, page 4, Legal Analysis section. 4 See, Palmer Biezup & Henderson LLP letter to the NPFC dated September 4, 2009, page 6 & 7.
After completion of loading on August 2, 2008 at 0830 LT, the vessels departed IMT and 

arrived at the Crystal River Plant on August 4, 2008. After discharging its cargo at 1110 LT 

on August 8, 2008, the vessels received instructions from PEF to immediately return to IMT 

for loading. The vessels anchored at Pt. Celeste anchorage on August 10, 2008 at 1000. 

Claimant alleges that the tug Baltimore issued a Notice of Readiness to load at this time. The 

force majeure declared by IMT and PEF remained in effect due to the continuing impact of 

the oil spill and resulting river closures. Loading of the vessels did not commence until 

August 12, 2008 at 1110 LT. Total hours claimed on the second delay are 49.17. This spans 

the elapsed time from issuance of the Notice of Readiness until actual commencement of 

loading. 

D. Mitigation and Saved Expenses 

In the Claimant’s response letter to the NPFC dated September 4, 2009, they provide that 

there was no other location to load coal except in New Orleans during the spill period and 

that under the contract extension agreement, Express Marine was required to provide 

transportation services on an exclusive multi-year basis and did not have the right to seek 

alternative employment for the vessels, nor did it have the right to redirect the vessels to 

alternative ports.

E. Claim Submission to the RP

1. The Claimant, Express Marine Inc., submitted the original claimed amount of 

$142,679.88 to the RP through Worley Catastrophe Response, LLC on March 4, 2009 as 

indicated on Claimants original submission letter received by the NPFC on May 12, 2009.5

 

On March 18, 2009, Worley Catastrophe Response requested additional information 

(Claimant’s Exhibit B). In a letter dated April 13, 2009, the Claimant responded that the 

information requested was entirely irrelevant to the evaluation and payment of the claim 

(Claimant’s Exhibit C). The RP issued a letter to the Claimant on April 29, 2009, stating 

their claim had been denied for the reasons set forth in the declaratory judgment complaint 

filed in the Eastern District of Louisiana on April 28, 2009 (Claimant’s Exhibit D). The 

declaratory judgment was stayed and administratively closed until further orders of the court 

on September 2, 2009 by Judge Ivan L. R. Lemelle, United States District Judge of the 

United States District Court, Eastern District of Louisiana.6 The RP’s appeal was dismissed 

by the court on November 24, 2009.7

2. By letter dated May 19, 2009, the NPFC notified the RP that the Claimant presented the 

original claim totaling $142,679.88 to the Fund.8

3. The NPFC has not been provided evidence by the Claimant or the RP as to whether the 

Claimant’s amended claim in the amount of $201,369.83 has been presented to the RP as 

required under OPA. 

V. APPLICABLE LAW

 

5 See, Palmer Biezup & Henderson LLP letter to the NPFC dated May 6, 2009, number 4, claim status. 6 See, United States District Court, Eastern District of Louisiana, Case 2:09-cv-03392-ILRL-KWR, document 70, 

 dated September 2, 2009.

7 See, United States District Court, Eastern District of Louisiana, Case 2:09-cv-03392-ILRL-KWR, document 78, 

 filed November 30, 2009.

8 See, NPFC letter to the RP dated May 19, 2009.
All claims for removal costs or damages shall be presented first to the responsible party or 

guarantor of the source designated under section 2714 (a) of this title. 33 U.S.C. §2713(a). 

If a claim is presented in accordance with subsection (a) of this section and 

(1) each person to whom the claim is presented denies all liability for the claim, or 

(2) the claim is not settled by any person by payment within 90 days after the date upon which 

(A) the claim was presented, or 

(B) advertising was begun pursuant to section 2714 (b) of this title, whichever is later, 

the claimant may elect to commence an action in court against the responsible party or guarantor 

or to present the claim to the Fund. 33 U.S.C. §2713(c).

Claims may be presented first to the Fund if the President or his delegated representative has 

advertised or notified claimants that the Fund is accepting claims resulting from an oil discharge. 

33 U.S.C. §2713(b)(1)(A). 

The uses of the OSLTF are described at 33 U.S.C. §2712. It provides in relevant part that: 

“(a) Uses generally

The Fund shall be available to the President for – 

(4) [T]he payment of claims in accordance with section 2713 of this title for uncompensated 

removal costs determined by the President to be consistent with the National Contingency Plan 

or uncompensated damages; . . . 

(b) Defense to liability for Fund 

The Fund shall not be available to pay any claim for removal costs or damages to a particular 

claimant, to the extent that the incident, removal costs, or damages are caused by the gross 

negligence or willful misconduct of the claimant.”

Damages include damages for injury to natural resources, injury to or economic losses from the 

destruction of real or personal property, loss of subsistence use of natural resources, Government 

loss of revenues, loss of profits or earning capacity as a result of loss or destruction of real or 

personal property or natural resources, and costs of increased public services. 33 U.S.C. 

§2702(b). Damages are further defined in OPA to include the costs of assessing the damages. 

33 U.S.C. §2701(5). 

Damage claims must be presented within 3 years after the date on which the injury and its 

connection with the discharge in question were reasonably discoverable with the exercise of due 

care. 33 U.S.C. §2712(h)(2). 

In any case in which the President has paid an amount from the OSLTF for any removal costs or 

damages specified under 33 U.S.C. §2712(a), no other claim may be paid from the Fund for the 

same removal costs or damages. 33 U.S.C. §2712(i). 

Congress directed the President to promulgate regulations “for the presentation, filing, 

processing, settlement, and adjudication of claims...” 33 U.S.C. §2713(e). Those regulations are 

found at 33 CFR Part 136. 

Under 33 CFR 136.105(a) and 136.105(e)(6), the claimant bears the burden of providing all 

evidence, information, and documentation deemed necessary by the Director, NPFC, to support 

the claim. Further, a claim presented to the Fund should include, as applicable: 
“[T]he reasonable costs incurred by the claimant in assessing the damages claimed. This 

includes the reasonable costs of estimating the damages claimed, but not attorney’s fees or other 

administrative costs associated with preparation of the claim.” 33 CFR 136.105(e)(8). 

With regard to claims for loss profits and impairment of earning capacity, the NPFC must 

independently determine that the proof criteria in OPA and the implementing regulations, at 33 

CFR Part 136, are met, including the general provisions of 33 CFR 136.105, and the specific 

requirements for loss of profits and earning capacity claims in Subpart C, 33 CFR 136.231, et 

seq. 

Pursuant to the provisions of 33 CFR 136.231, claims for loss of profits or impairment of earning 

capacity due to injury to, destruction of, or loss of real or personal property or natural resources 

may be presented to the Fund by the claimant sustaining the loss or impairment. 

“In addition to the requirements of Subparts A and B of this part, a claimant must establish the 

following— 

(a) That real or personal property or natural resources have been injured, destroyed, or lost. 

(b) That the claimant’s income was reduced as a consequence of injury to, destruction of, or loss 

of the property or natural resources, and the amount of that reduction. 

(c) The amount of the claimant's profits or earnings in comparable periods and during the period 

when the claimed loss or impairment was suffered, as established by income tax returns, 

financial statements, and similar documents. In addition, comparative figures for profits or 

earnings for the same or similar activities outside of the area affected by the incident also must 

be established. 

(d) Whether alternative employment or business was available and undertaken and, if so, the 

amount of income received. All income that a claimant receives as a result of the incident must 

be clearly indicated and any saved overhead and other normal expenses not incurred as a result 

of the incident must be established.” 33 CFR 136.233 (a) – (d)

If a third party claimant or an RP is able to establish an entitlement to lost profits, then 

compensation may be provided from the OSLTF. But the compensable amount is limited to the 

actual net reduction or loss of earnings and profits suffered. Calculations for net reductions or 

losses must clearly reflect adjustments for the following: all income resulting from the incident; 

all income from alternative employment or business undertaken; potential income from 

alternative employment or business not undertaken, but reasonably available; any saved 

overhead or normal business expenses not incurred as a result of the incident; and state, local, 

and Federal tax savings. 33 CFR 136.235 (a) – (e).

Under 33 CFR 136.115(d), the Director, NPFC, will, upon written request of the claimant or the 

claimant's representative, reconsider any claim denied. The request for reconsideration must be 

in writing and include the factual or legal grounds for the relief requested, providing any 

additional support for the claim. The request for reconsideration must be received by the NPFC 

within 60 days after the date the denial was mailed to the claimant or within 30 days after receipt 

of the denial by the claimant, whichever date is earlier.

VI. DETERMINATION 

The barge 932 oil spill disrupted shipping in and out of the Mississippi River. The NPFC 

reviewed the Coast Guard situation report-pollution (SITREP-POL) reports, which clearly state 

that vessels were delayed from 7/23/2008 until well after 7/28/2008. SITREP-POL Eight, stated 

b. The NPFC finds the first vessel delay did start on 7/27/08 at 1305. That delay 

ended once the vessel weighed anchor in transit to Myrtle Grove on 7/28/08 at 

1900 (29.92 hours). The vessel was again delayed on 7/29/08 at 0535 when it 

anchored at Magnolia anchorage. That delay ended once the vessel weighed 

anchor in transit to Pt. Celeste anchorage on 7/30/08 at 1010 (28.58 hours). The 

vessel again became delayed upon anchoring at Pt. Celeste anchorage on 7/30/08 

at 1110. This delay ended when the vessel weighed anchor and transited to IMT 

on 8/01/08 at 0945 for loading (46.58 hours). (See Claimant’s Exhibit A - 

attachment 4 for dates and times). The NPFC finds the total time the vessel was 

delayed during the first claimed delay is 105.08 hours. 

2. Second Delay Loading

a. According to SITREP-POL Twenty, on 8/10/08, there was still a safety zone in 

place from Mississippi River mile marker 97 through 40, requiring slow 

movement of vessels through this area due to continuing clean up efforts.12 

Subsequently, the NPFC finds it reasonable that there would still be a back up of 

vessel loadings at the IMT terminal, requiring these vessels to anchor. 

b. The NPFC finds the second vessel delay did start on 8/10/08 at 1000 when, 

according to the tug Baltimore’s logbook (Claimant’s Exhibit A - attachment 4), 

the vessels anchored at Pt. Celeste Anchorage awaiting a berth at IMT for 

loading. The Claimant alleges that this delay ends 8/12/08 at 1110, when the 

barge EMI 1850 began loading at IMT. However, the NPFC finds that this delay 

ended when the vessels weighed anchor on 8/12/08 at 0835, enroute IMT for 

loading. The transit to IMT and crew change, as noted in Claimant’s Exhibit A – 

attachment 4, are considered normal operations that would not be compensable as 

delay time. Therefore, the NPFC finds the total time the vessel was delayed 

during this second claimed delay is 46.58 hours. Claimant’s Exhibit A, 

attachment 6 supports this figure. 

3. The NPFC noted in the contract of affreightment that the Claimant would have 

 been entitled to a demurrage payment of $675.00 an hour if, as stated by the 

Claimant in their original submission to the NPFC, the oil spill had not created a 

valid Force Majeure event. Regardless of whether the Claimant was entitled to 

the demurrage payment or not, the NPFC does not find this valuation of damages 

(loss) accurate or reasonable. A demurrage payment would have resulted in 

increased revenue due to the spill, instead of providing documented proof of a 

true loss. 

Additionally, the NPFC would need to study comparable financials to establish a 

reasonable loss as required by the law under 33 CFR 136.233 (c) below: 

“The amount of the claimant's profits or earnings in comparable periods and 

during the period when the claimed loss or impairment was suffered, as 

established by income tax returns, financial statements, and similar documents. 

In addition, comparative figures for profits or earnings for the same or similar 

activities outside of the area affected by the incident also must be established.” 

 

12 See, SITREP-POL Twenty, para. H.
Under the legal analysis section of the Claimant’s original submission letter to the 

NPFC dated May 6, 2009, the Claimant stated they are not submitting any 

corporate financial statements and that they are irrelevant to the evaluation or the 

payment of the claim. The NPFC does not agree with this statement. Under OPA, 

the law requires comparative figures of financial documents that can support 

claimed damages which result in an actual loss be presented to the NPFC. 

4. The NPFC does not find a flat $675.00 an hour demurrage allowed in an 

Affreightment Contract between two parties satisfies proof of damages under 

OPA. Therefore, the NPFC does not find the $113.238.00 in vessel 

delay/demmurage compensable as presented.

b. Administrative Costs

1. The NPFC evaluated the Claimants request for $22,647.60 (20%) in 

compensation for administrative costs. The Claimant states that these costs were 

requested to cover activities that administrative and management personnel 

undertook monitoring the spill activity, while communicating with Progress Fuels 

Corporation, the Coast Guard and oil spill contractors regarding the movement of 

the barge, along with costs associated with overhead. 

2. The Claimant stated there were no detailed time records of activities and therefore

requested a percentage (20%) of the damages to cover these costs. The NPFC 

does not find this a reasonable valuation method to determine these costs. Under 

OPA, the NPFC would need documentation showing an actual loss instead of a 

general percentage based valuation. Therefore, the NPFC does not find the 

$22,647.60 in administrative costs compensable as presented. 

c. Interest

The NPFC evaluated the Claimants request for $6,794.28 (5%) interest on the vessel 

delay and administrative portion of this claim. This is denied because that amount is 

not a loss of profit cost or damage compensable under OPA.

B. Amended Sum Certain With New Delay Valuation 

1. Claim: While answering an NPFC request for additional information email dated May 

27, 2009, the Claimant amended their sum certain. They now seek total compensation in the 

amount of $201,369.83. Claimant asserts there were $159,817.33 in vessel delay costs, 20% 

of the claimed delay amount ($31,963.46) in administrative costs related to these delays, and 

5% ($9,589.04) of the claimed delay and administrative costs in interest. 

2. Documentation: 

a. Claimant utilized the documents listed under the original claim submission while 

providing the following additional information to support the claimed vessel delays, 

administrative costs and interest:
1. Claimant’s letter dated September 4, 2009 to the NPFC addressing additional 

information requested by the NPFC with attached “cash flow” spreadsheet. 

3. NPFC Findings: 

a. Vessel Demurrage/Delay

1. While answering an NPFC request for additional information email dated May 

27, 2009, the Claimant re-valuated their alleged lost earnings in the amount of 

$159,817.33. Claimant provided an attached “cash flow” spreadsheet, which the 

Claimant alleges shows that on average the tug Baltimore and barge EMI 1850 

loaded at IMT on the Mississippi River every seven days and the invoiced amount 

for each trip averaged $162,133.52. The Claimant then states that considering the 

167.76 hours (6.9 days) delayed as alleged in the first presentment of the claim, the 

loss now equals $159,817.33 in damages ($162,133.52 / 7 = $23,161.93 and 6.9 x 

$23,161.93 = $159,817.32). Claimant also alleges that because of the oil spill, 

Express Marine lost $283,558.80 in the third quarter of 2008. 

2. As stated in A.3.a.1-2 above, the NPFC finds the total claimed vessel delay time 

to be 151.66 hours not 167.67 hours. 

3. After reviewing the “cash flow” spreadsheet, the NPFC found the Claimant did 

not accurately present the quarterly cash flow and losses. The Claimant’s “cash 

flow” spreadsheet provides the following total invoice amounts: 

 a. Quarter 2: $1,817,651.70 

 b. Quarter 3: $1,540,385.00 

 c. Quarter 4: $1,830,235.91 

 The NPFC’s review finds the following: 

 a. Quarter 2: $1,817,651.70 

 b. Quarter 3: $1,710,729.18 

 c. Quarter 4: $1,659,891.73 

 The Claimant moved the 9/28/08 – 10/01/08 trip (number 8975) from quarter 

three (the quarter in which the oil spill occurred) into quarter four, which gave 

quarters two and four a larger cash flow return in comparison to quarter three. In 

reality, there is no clear loss which can be placed on the oil spill in the third 

quarter. The cash flow in the fourth quarter is even lower than the third quarter. 

The Claimant claimed an average quarterly revenue of $1,823,943.81 for quarters 

two and four, when in actuality the average quarterly revenue was $1,738,771.71. 

The Claimant stated a $283,558.80 loss in the third quarter because of the oil 

spill. The difference between the average second and fourth quarterly revenue of 

$1,738,771.72 and the third quarter of $1,710,729.18 equals $28,042.54. 

Through the three quarters presented on the spreadsheet, each trip averaged 

approximately three days. In the third quarter, besides the seven day trip (# 8886) 

from 7/25/08-8/01/08, there was another seven day trip (# 8873) 7/09/08-7/16/08 

and one seventeen day trip (# 8936) from 8/27/08-9/13/08. The NPFC finds the 

$28,042.54 third quarter difference in average costs cannot be directly attributed 

to the oil spill event. There are two other delays (trip 8873 - seven days and trip 
8936 - seventeen days) in the third quarter, which could have contributed to the 

alleged loss. In addition, no income tax returns, financial statements, or similar 

financial documents, as required by OPA, were submitted to justify the “cash 

flow” spreadsheet numbers presented by the Claimant. 

4. In an email dated January 25, 2010, which was written by the Claimants legal 

representative, Mr. to the NPFC, states, “the basic premise of the claim 

is that the oil spill resulted in our client not being able to carry as much coal from the 

Mississippi River to Florida as it would have if the spill had not occurred. Our client 

is only paid per ton of coal carried. The spill resulted in less tons of coal being 

carried and a corresponding loss of revenue resulted from the spill”.13 The NPFC 

has not found any documentation in the claim to support the Claimants basic premise 

of the claim as stated above. There is no definitive documentation provided to show 

that the vessels could not carry as much coal from the Mississippi River to Florida 

because of the oil spill, nor does it find that the Claimant lost a voyage due to the 

delays.

5. After considering all of the evidence submitted by the Claimant in support of the 

amended vessel delay claim amount of $159,817.33, the NPFC does not find it 

compensable as presented.

b. Administrative Costs

1. The NPFC evaluated the Claimants request for $31,963.46 in compensation for 

administrative costs. The Claimant states that these costs were requested to cover 

activities that administrative and management personnel undertook monitoring the 

spill activity, while communicating with Progress Fuels Corporation, the Coast Guard 

and oil spill contractors regarding the movement of the barge, along with costs 

associated with overhead. 

2. The Claimant stated there were no detailed time records of activities and therefore 

requested a percentage (20%) of the damages to cover these costs. The NPFC does 

not find this a reasonable method to determine these costs. The NPFC would need 

documentation showing an actual loss instead of a general percentage based 

valuation. Therefore, the NPFC does not find the $31,963.46 in administrative costs 

compensable as presented.

c. Interest

The NPFC evaluated the Claimants request for $9,589.04 (5%) interest on the vessel 

delay and administrative portion of this claim. This is denied because that amount is 

not a loss of profit cost or damage compensable under OPA. 

d. Amended Claim Presentation to the RP

No evidence has been presented to the NPFC that the Claimant has made presentment 

of the amended claim and new sum certain in the amount of $201,369.83 to the RP. 

Under OPA, 33 U.S.C. §2713(a), the Claimant is required to make presentment. 

 

13 See, Mr. email to the NPFC dated January 25, 2010, para. two.

(b) (6) (b) (6)
VII. SUMMARY 

The Claimant failed to demonstrate a loss of profits or earning capacity, which can be 

directly attributed to the barge 932 oil spill. 

Based on the above, I recommend that Express Marine, Inc. be offered $0.00 as full 

compensation for the alleged damages it suffered when its vessels, the tug Baltimore and 

barge EMI 1850, were delayed as a result of the barge 932 oil spill. 

VIII. DETERMINED AMOUNT: $0.00 

Claim Supervisor: Thomas S. Morrison 

Date of Supervisor’s Review: 

Supervisor Action: 

Supervisor’s Comments: