Oil Pollution Act Liability Limits 

in 2014 

Report to Congress 

October 2, 2014 

U. S. Coast Guard 
This page was intentionally left blank 
i 

Foreword 

I am pleased to present the following report, “Oil Pollution Act 

Liability Limits in 2014,” as prepared by the U.S. Coast Guard. 

This document has been compiled pursuant to a requirement in 

Section 603(c) of the Coast Guard and Maritime Transportation Act 

of 2006 (Pub. L. 109-241) which directs the Commandant to provide 

an analysis of the extent to which oil discharges from vessels and nonvessel sources have or are likely to result in removal costs and 

damages for which no defense to liability exists and that exceed the 

established liability limits. 

The National Pollution Fund Center (NPFC) continues to anticipate 

the Oil Spill Liability Trust Fund (OSLTF) will be able to cover projected non-catastrophic 

liabilities, including claims, without further increases to vessel liability limits. Annual report 

updates do not provide any significant new information or recommendations. Accordingly, the 

Coast Guard believes that this reporting requirement has outlived its legislative purpose and 

informative value. As such, the Department recommends the Committee repeal this reporting 

requirement and, for the Committee’s consideration, offers up the following remedial text. 

“SEC. xxx. REPEAL; ANNUAL UPDATES ON LIMITS ON LIABILITY. 

“Section 603(c)(3) of the Coast Guard and Maritime Transportation Act of 2006 (Public 

Law 109-241; 120 Stat. 554; 33 U.S.C. 2704 note) is repealed.”. 

Pursuant to congressional requirements, this report is being provided to the following Members 

of Congress: 

The Honorable John D. Rockefeller IV 

Chairman, Senate Committee on Commerce, Science, and Transportation 

The Honorable John Thune 

Ranking Member, Senate Committee on Commerce, Science, and Transportation 

The Honorable Bill Shuster 

Chairman, House Committee on Transportation and Infrastructure 

The Honorable Nick J. Rahall II 

Ranking Member, House Committee on Transportation and Infrastructure. 

 
ii 

I am happy to answer any further questions you may have, or your staff may contact my Senate 

Liaison Office at (202) 224-2913 or House Liaison Office at (202) 225-4775. 

Sincerely, 

Paul F. Zukunft 

Admiral, U. S. Coast Guard 

Commandant
iii 

Table of Contents 

I. Legislative Language 1

II. Background 2

III. Analysis of Discharges 3

IV. Impacts on the Fund 8

V. Findings with Respect to Further Liability Limit Adjustments 11

Attachment A: Incidents Exceeding Liability Limits by Vessel Type 16

Attachment B: Incidents Exceeding Liability Limits by Incident Date 19

Attachment C: Incidents Exceeding Liability Limits with Limits to Achieve 50% Cost Share 24
1

I. Legislative Language 

This report responds to the language set forth in section 603(c) of the Coast Guard and Maritime 

Transportation Act of 2006, (Pub. L. 109-241), which states: 

 

SEC. 603. LIMITS ON LIABILITY. 

(c) REPORT.— 

(1) Initial Report. – Not later than 45 days after the date of enactment of 

this Act, the Secretary of the department in which the Coast Guard is 

operating shall submit a report on liability limits described in paragraph (2) to 

the Committee on Commerce, Science, and Transportation of the Senate and 

the Committee on Transportation and Infrastructure of the House of 

Representatives. 

(2) Contents. – The report shall include, at a minimum, the following: 

(A) An analysis of the extent to which oil discharges from vessels and 

nonvessel sources have or are likely to result in removal costs and 

damages (as defined in section 1001 of the Oil Pollution Act of 1990 (33 

U.S.C. 2701)) for which no defense to liability exists under section 1003 

of such Act and that exceed the liability limits established in section 1004 

of such Act, as amended by this section. 

(B) An analysis of the impacts that claims against the Oil Spill 

Liability Trust Fund for amounts exceeding such liability limits will have 

on the Fund. 

(C) Based on analyses under this paragraph and taking into account 

other factors impacting the Fund, recommendations on whether the 

liability limits need to be adjusted in order to prevent the principal of the 

Fund from declining to levels that are likely to be insufficient to cover 

expected claims. 

(D) Annual Updates. - The Secretary shall provide an update of the 

report to the Committees referred to in paragraph (1) on an annual basis. 
2

II. Background 

The Oil Pollution Act of 1990 (OPA) was enacted in the wake of the T/V EXXON VALDEZ oil 

spill to promote measures for the prevention of oil spills on navigable waters, the adjoining 

shorelines, and the exclusive economic zone. It provided a more robust Federal response to spills, 

increased the liability of polluters (Responsible Parties (RPs)) for such spills, and provided for 

compensation to those that incur removal costs and damages as a result of these spills. 

OPA provides that RPs are strictly liable for removal costs and damages resulting from a discharge 

up to statutory liability limits. In general, RPs are liable without limit only if the discharge results 

from gross negligence or willful misconduct or a violation of operation, safety, or construction 

regulations (OPA § 1004 (33 U.S.C. § 2704)). 

The Fund plays a critical role in the OPA regime. It pays Federal costs for oil removal when a 

discharge occurs and reimburses third-party claims for uncompensated removal costs and damages 

when a responsible party does not pay or is not identified. The types of damages compensable under 

OPA include damages to natural resources, loss of subsistence use of natural resources, damages to 

real or personal property, loss of profits or earning capacity, loss of government revenues, and 

increased cost of public services. In addition, the Fund is an important source of annual 

appropriations to various Federal agencies responsible for administering and enforcing a wide range 

of oil pollution prevention and response programs addressed in OPA (OPA § 1012 (33 U.S.C. § 

2712)). 

Specific to this report, the Fund is available, as provided by OPA, to pay claims for removal costs 

and damages resulting from an oil discharge that exceed the responsible party’s liability limits. This 

includes payment of claims from RPs who pay or incur removal costs or damages in excess of their 

liability limits and can establish their entitlement to the limits under the circumstances of the 

discharge (OPA § 1008 (33 U.S.C. § 2708)). 

Claims to the Fund are payable only from the Fund, and payments are limited by the available 

balance. For any single discharge incident, the Fund is authorized to pay no more than $1 billion, of 

which no more than $500 million may be paid for natural resource damages (OPA § 9001(c) (26 

U.S. Code § 9509)). 

Pursuant to section 603 of the Coast Guard and Maritime Transportation Act of 2006, liability limits 

for vessel discharges were substantially increased. In that same section, Congress requested this 

analysis and report. 

 
3

III. Analysis of Discharges 

This section provides an analysis of the extent to which oil discharges from non-vessel and vessel 

sources have resulted, or are likely to result in removal costs and damages, as defined in OPA, that 

exceed liability limits established in OPA, as amended by the Coast Guard and Maritime 

Transportation Act of 2006 (Pub. L. 109-241). 

A. Non-vessel Sources 

The incident involving the DEEPWATER HORIZON and Macondo Well is the only incident known 

to have resulted in costs and/or damages exceeding the statutory liability limit for an offshore 

facility. RPs for an offshore facility are liable for all removal costs plus $75 million for damages 

absent an action that disqualifies the RP from the liability cap. The full extent of the damages from 

the DEEPWATER HORIZON incident cannot be predicted with any degree of certainty. While BP 

has reportedly paid billions to settle damages and other claims, other damages, including Federal, 

State and Indian Tribe trustee natural resource damages, remain to be determined and paid. On May 

12, 2010, the Administration proposed raising the limitation on liability for all RPs, including RPs 

for offshore facilities. As the background data for all offshore incidents since the enactment of OPA 

show, DEEPWATER HORIZON constitutes a single data point for determining what amended 

liability for damages is needed. There have been no other offshore facility incidents that approach 

the “all removal costs plus $75 million” limit under existing law. 

With respect to offshore facility incidents (other than the incident involving the DEEPWATER 

HORIZON), best available data indicate there have been 53 incidents since the enactment of OPA 

that have resulted in removal costs and damages (6 Mobile Offshore Drilling Units and 47 Offshore 

Platforms). Figure 1 shows the frequency of these incidents by year and facility type. 

Figure 1: Number of Offshore Facility Incidents by Year and Facility Type 

(Excludes 2010 Deepwater Horizon Oil Spill)

 

0

2

4

6

8

10

12

1990

1992

1994

1996

1998

2000

2002

2004

2006

2008

2010

2012

Mobile Offshore Drilling Units Offshore Platforms
4

Figure 2 shows the total incident cost for each of these incidents. As depicted, the highest cost 

incident, at approximately $18.2 million (in 2014 dollars), does not meet the statutory limit of 

liability of all removal costs (plus $75 million for damages). 

Figure 2: Total Incident Cost of Offshore Facility 

Incidents by Facility Type (2014 Dollars / Excludes 2010 Deepwater Horizon Oil Spill) 

The 2010 Enbridge Energy Partners Lakehead Line 6B pipeline oil spill in Michigan is the sole 

onshore facility discharge that has reportedly resulted in removal costs and damages that exceed 

the onshore facility liability limit. RPs for an onshore facility are liable for removal costs and 

damages of $350 million absent an action that disqualifies the RP from the liability cap. 

As of March, 14, 2014, Enbridge Energy Partners reported costs of more than $1.1 billion 

resulting from its pipeline spill. The full extent of the removal costs and damages from the 

Enbridge Energy Partners Lakehead Line 6B pipeline incident cannot be predicted with any 

degree of certainty at this time. As the background data for all onshore facility incidents since 

the enactment of OPA show, the Enbridge Energy Partners Lakehead Line 6B discharge 

constitutes a single data point for determining an amended liability limit for discharges from 

onshore facilities. There have been no other onshore facility incidents that approach the $350 

million limit under existing law. 

With respect to onshore facility incidents (other than the incident involving the Enbridge pipeline), 

best available data indicate there have been 4,465 incidents since the enactment of OPA. Figure 3 

shows the frequency of these incidents by year. 

 

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

$16,000,000

$18,000,000

$20,000,000

1990

1992

1994

1996

1998

2000

2002

2004

2006

2008

2010

2012

Mobile Offshore Drilling Units Onshore Platforms
5

Figure 3: Number of Onshore Facility Incidents by Year 

(Excludes 2010 Enbridge Pipeline Oil Spill)

Figure 4 shows the total incident cost of the five most expensive onshore facility incidents per 

year. As depicted, the highest cost incident, at approximately $40.0 million (in 2014 dollars), 

does not meet the statutory $350 million limit of liability. 

Figure 4: Total Incident Cost of the Five Most Expensive Onshore Facility Incidents per Year (2014 Dollars / 

Excludes 2010 Enbridge Pipeline Oil Spill) 

 

0

50

100

150

200

250

300

350

400

450

500

$0

$5,000,000

$10,000,000

$15,000,000

$20,000,000

$25,000,000

$30,000,000

$35,000,000

$40,000,000

$45,000,000
6

B. Vessel Sources 

Best available data indicate 67 oil discharges from vessels have resulted in removal costs and 

damages that exceed the amended liability limits. Data have been updated to incorporate new 

incidents, and reflect revised estimates of costs and damages associated with previously reported 

incidents.1 Discharge incidents are listed by vessel type in Attachment A and by incident date in 

Attachment B. 

Figure 5 depicts the number of such discharges per year. The higher total for 1999 is the result of a 

typhoon in American Samoa, which resulted in oil discharges involving eight fishing vessel wrecks. 

The figure illustrates the variance in numbers of incidents from year to year. 

 

Figure 5: Number of Incidents Exceeding Limits of Liability 

Figure 6 shows a breakdown of these 67 incidents by vessel type. Fishing vessels account for 37.3 

percent of the historical incidents that result in damages in excess of the liability limits, while cargo 

and other self-propelled non-tank vessels represent 44.8 percent of the incidents. Single hull and 

double hull tank barges represent 10.4 percent and 4.5 percent, respectively. Single hull tank ships 

account for only 3.0 percent of such discharges. There are no double hull tank ship incidents among 

the 67 incidents. 

 

1

 References throughout this report to data for the year 2014 are partial year data ending on May 1, 2014. 
7

Figure 6: Number of Incidents Exceeding Limits of Liability by Vessel Type 

Figure 7, total removal costs and damages from these incidents by vessel type, portrays a similar 

picture. Total costs in excess of liability limits for cargo/other self-propelled vessel discharges have 

been the highest. Total costs for single hull tank ship and tank barge discharges that exceed liability 

limits have also been significant. Per discharge costs from single hull tank ship incidents are the 

highest (approximately $198.5million) in light of the quantities of oil these vessels carry. Per 

discharge costs for all tank barges are also substantial (approximately $75.4 million). Larger cargo 

vessels also carry enough fuel to result in costly discharges (approximately $23.6 million per 

incident). The small size and limited quantities of oil characteristic of most fishing vessel incidents 

accounts generally for the lower total costs of such discharges (approximately $2.5 million), shown 

here and in more detail in Attachment A. 

Total removal costs and damages for these discharges since enactment of OPA is approximately 

$1.9 billion. 

Figure 7: Total Incident Costs by Vessel Type 

0

2

4

6

8

10

12

14

16

18

20

22

24

26

28

30

32

Single Hull

Tank Ship

Double Hull

Tank Ship

Single Hull

Tank Barge

Double Hull

Tank Barge

Cargo/Other

Self-Propelled

Vessel

Fishing Vessel

Number of Inciden

$0

$100,000,000

$200,000,000

$300,000,000

$400,000,000

$500,000,000

$600,000,000

$700,000,000

$800,000,000

Single Hull

Tank Ship

Double Hull

Tank Ship

Single Hull

Tank Barge

Double Hull

Tank Barge

Cargo/

Other SelfPropelled

Vessel

Fishing

Vessel
8

IV Impacts on the Fund 

This section provides an analysis of the impacts on the Oil Spill Liability Trust Fund (hereafter 

referred to as “the Fund”) resulting from claims against the Fund for vessel incidents in which costs 

and damages exceed liability limits.2 

A. Historical Impact 

As indicated in Figure 8, the Fund’s financial obligation in cases where removal costs and damages 

exceed liability limits (listed in Attachment A) is substantial despite recent liability limit 

amendments. The top portion of the bar for each vessel type represents the Fund’s share of the risk 

(in excess of applicable liability limit). The bottom portion of the bar for each vessel type represents 

RP risk (RP liability limit based on gross tonnage or minimum limit as applicable for each 

discharge). 

Figure 8: RP vs. Fund Share of Total Incident Costs under Current Limits by Vessel Type 

Of the approximately $1.9 billion in estimated removal costs and damages from these incidents over 

the last 23 years, the Fund’s share of risk totals approximately $1.3 billion (68%). This amount 

represents a maximum potential impact on Fund risk resulting solely from the application of the 

liability limit levels. While the rate of such incidents is difficult to predict and may vary widely 

 

2

 As discussed above, historically, with the exception of the DEEPWATER HORIZON and ENBRIDGE data points, 

only vessel incidents had total incident costs that exceeded limits of liability. Therefore, facilities are not included 

in the discussion of RP and Fund risk cost sharing. 

$0

$100,000,000

$200,000,000

$300,000,000

$400,000,000

$500,000,000

$600,000,000

$700,000,000

$800,000,000

Single Hull

Tank Ship

Double Hull

Tank Ship

Single Hull

Tank Barge

Double Hull

Tank Barge

Cargo/

Other SelfPropelled

Vessel

Fishing

Vessel

Fund Share

RP Share

45%

55%

25%

75%

39%

61%

61%

39%

90%

10%
9

from year-to-year (as indicated by Figure 5), the risk to the Fund can be expressed broadly as an 

annual cost of approximately $56.7 million (total costs of $1.3 billion over 23 years) in excess of 

amended limits in 2014 dollars. 

B. Impact from Claims 

Over the past 23 years, the National Pollution Funds Center has paid $810 million to claimants in 

connection with OPA incidents. Of this total, $426 million (or 52.6 percent) was paid in respect 

to circumstances where removal costs and damages exceeded the applicable liability limit 

amount (Figure 9). These "limit of liability" payments include payments made directly to the 

RPs for the removal costs and damages they paid or incurred in excess of liability limits, as well 

as third-party claims paid by the Fund because the RP had spent up to its limit of liability. 

Figure 10 shows that of the $149.1 million in claims under adjudication as of May 1, 2014, $124.5 

million (or 83.5 percent of the total dollars) are pending claims by RPs who have incurred incident 

costs exceeding their liability limits or claims by third parties where incident costs exceeded the 

liability limits. 

 Figure 9: Total Claims Paid Figure 10: Total Pending Claims 

C. Recent Trends 

The potential impact to the Fund resulting from payments to RPs, third parties for claims, and 

response costs where vessel incident costs exceeded the RPs’ limits of liability varies substantially 

from year to year, but has averaged approximately $56.7 million per year over the past 23 years. 

While the potential impact is significant, it is also useful to note the available data show a continued 

trend toward more Fund risk in recent years. 

As illustrated in Figure 11 and Attachment B, the Fund share of the risk for discharges that result in 

estimated removal costs and claims that exceed liability limits has increased over time, to 90% of 

costs in the most recent period after 2010. This increased risk is largely the result of the greater cost 

of such incidents in recent years. 
10

Figure 11: RP vs. Fund Share of Total Incident Costs 

The Energy Improvement and Extension Act of 2008 (Pub. L. 110-343) extended the barrel tax 

through December 31, 2017, and increased the tax from five cents to eight cents for 2009-2016, and 

to nine cents for 2017. Tax revenues are deposited into the Fund, which should provide additional 

income to the Fund over the next several years. Based on current revenue and expenditure 

projections, the NPFC forecasts that the Fund should maintain liquidity through 2020 (See Figure 

12). 

However, as noted earlier, the impact on the Fund from the DEEPWATER HORIZON catastrophe 

remains uncertain. If the Fund were to bear substantial removal costs and damages from the 

catastrophe without recovery, additional revenue may be needed to continue to carry out Fundfinanced programs. 
11

V. Findings with Respect to Further Liability Limit 

Adjustments 

This section discusses findings, based on historical trends and analyses, and taking into account 

other factors impacting the Fund, on whether the liability limits need to be adjusted in order to 

prevent the principal of the Fund from declining to levels that are likely to be insufficient to cover 

expected claims. 

A. Future Year Fund Outlook 

The NPFC anticipates the Fund will be able to cover its projected non-catastrophic liabilities, 

including claims, without further increases to liability limits except if DEEPWATER HORIZON 

impacts develop. However, increases to liability limits for certain vessel types would result in a 

more equitable division of risk between the Fund and RPs and have a positive impact on the balance 

of the Fund. 

Figure 12 projects the end of year balance of the Fund through 2020 based on estimated revenues 

and expenditures (no adjustment for inflation or potential DEEPWATER HORIZON impacts): 

Figure 12: Fund Forecast Balance (Millions of Dollars) 

Notably, several classes of Fund expenditures are independent of revisions to the limits of liability, 

such as Federal removal costs and annual appropriations. The Fund provides resources to the 

Federal government to respond to oil discharges (Federal removal costs) and to compensate 

claimants for their removal costs and damages when a RP cannot be identified, does not respond, or 

does not compensate claimants. See OPA § 1012(a)(1), (4) (33 U.S.C § 2712(a)(1), (4)). The Fund 

also pays when recourse against RPs is not available, such as when a RP declares bankruptcy or 

cannot be identified. Thus, the Fund is the ultimate insurer with respect to oil removal costs and 

damages when there is a discharge or substantial threat of discharge to navigable waters, adjoining 

shorelines, or the exclusive economic zone. 

$-

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

2013 2014 2015 2016 2017 2018 2019 2020
12

The Fund also pays various agencies responsible for administering and enforcing OPA and 

provisions of the Federal Water Pollution Control Act. See OPA § 1012(a)(5) (33 U.S.C. § 

2712(a)(5)). Administrative and enforcement costs that are not allocable to a specific oil discharge 

are not recoverable from liable RPs. 

Figure 13 shows total Fund expenses in recent years for agency appropriations, Federal removal 

costs, and claims for removal costs and damages, of which claims resulting from incident-related 

costs exceeding the limits of liability is a subset. 

Figure 13: Total Fund Expenditures (Thousands of Dollars) 

Figure 13 illustrates that, with the exception of the DEEPWATER HORIZON oil spill costs in 2010 

through 2013, the Federal removal costs and claims payments for which RPs may be liable have 

represented only a portion, often well less than half, of the annual expenditures from the Fund. This 

graph displays all costs for vessel or facility discharges. 

The DEEPWATER HORIZON experience has demonstrated that the $75 million limit on damages 

for a catastrophic offshore facility incident could be inadequate and the Administration has proposed 

raising that limit on damages. With the exception of DEEPWATER HORIZON, roughly half of the 

removal costs in Figure 13 are for onshore and offshore facility discharges. Historical data indicates 

that the $350 million liability limit for onshore facilities is adequate for non-catastrophic spills.3

 

With respect to the Fund expenses for removal costs and claims allocable to vessel spills, the Fund 

frequently pays when an RP is unknown. In these cases, liability limits have no impact on Fund risk. 

Vessel and facility liability limits will affect the Fund only to the extent RPs are available and have 

the ability to pay. 

 

3

 A notice of proposed rulemaking to adjust the limits of liability for vessels, deepwater ports and onshore facilities 

to reflect significant increases in the consumer price index, as required by OPA 90 (33 U.S.C. 2704(d)(4)), was 

published in the Federal Register on Tuesday, August 19, 2014 (see 79 FR 49206). 

$0

$50,000

$100,000

$150,000

$200,000

$250,000

$300,000

$350,000

$400,000

$450,000

$500,000

2008 2009 2010 2011 2012 2013

Claims

Deepwater Horizon

Removal Costs and

Claims

Removal

Appropriations
13

B. Further Liability Limit Adjustments 

Adjustments to liability limits help more equitably divide liabilities between the Fund and RPs. OPA 

is founded on the “polluter pays” principle. At the same time, OPA also places limits on the 

polluter’s liability to pay for clean-up of spills except in certain circumstances, and the Fund is the 

ultimate insurer for removal costs and damages. As previously noted, on May 12, 2010, the 

Administration proposed raising the limitation on liability for all RPs, including RPs for activities 

other than offshore drilling activities (such as shipping). 

Analysis indicates establishing different liability limits for non-tank vessels, which include fishing, 

cargo, and other self-propelled vessels, by tonnage (i.e., greater than 300 gross tons and less than or 

equal to 300 gross tons) would provide more equitable limits on smaller vessels. 

Figure 8 demonstrates that for vessel discharges where removal costs and damages exceed current 

liability limits, the Fund bears a majority of the cost even if every RP is available and pays to its 

limit. Figure 14 illustrates how further adjustments to limits of liability per gross ton might achieve 

an equal sharing of that risk between RPs and the Fund. The bottom portion of the bar represents the 

RP risk at the current limits of liability based on gross tonnage or minimum limits as applicable for 

each discharge. The middle portion represents the additional cost the RP would pay if the additional 

limits were applied, which would leave the Fund covering 50 percent of the total incident costs (the 

top portion of each bar). 

Figure 14: Gross Tonnage Limits of Liability for 50 percent Cost Share 

$0

$100,000,000

$200,000,000

$300,000,000

$400,000,000

$500,000,000

$600,000,000

$700,000,000

$800,000,000

Single Hull Tank

Ship

Double Hull Tank

Ship

Single Hull Tank

Barge

Double Hull Tank

Barge

Non-Tank Vessel 

> 300 gross tons

Non-Tank Vessel 

< or = 300 gross

tons

Fund Share after 50%

Co s t Share

Increas ed RP Share if

50% of Incident Cost

RP Share at Current

Limits

Adjusted

Limit: 

$3,500/gt

Adjusted 

Limit:

$7,700/gt

Adjuste

d Limit:

$1,400/g

t

Adjusted

Limit:

$5,300/gt

Adjusted 

Limit:

$11,400/gt
14

For example, to split the estimated clean-up costs evenly between the Fund and the vessel operators, 

liability limits for single hull tank ships would increase to $3,500 per gross ton, single hull tank 

barges to $7,700 per gross ton, double hull tank barges to $11,400 per gross ton, non-tank vessels 

greater than 300 gross tons to $1,400 per gross ton, and non-tank vessels less than or equal to 300 

gross tons to $5,300 per gross ton. 

Figure 15 indicates the minimum amount a RP would be expected to pay for an incident (based on 

average historical costs of incidents by vessel type in 2014 dollars), if the limits of liability were 

adjusted so that costs were shared evenly between the RP and the Fund. 

Figure 15: Minimum Liability Limits for 50 percent Cost Share 

Figure 16 summarizes the 50 percent cost share limits and minimums and compares them to the 

current limits. Attachment C illustrates how these limits would protect the Fund from paying the 

majority of the total incident cost when applied to the 67 incidents discussed earlier. The current 

limits distinguish between single hull tank vessels, double hull tank vessels and non-tank (other) 

vessels. As discussed in Section II, however, analysis has shown these categories might best be 

subdivided as follows: categories of Tank Ship and Tank Barge are addressed separately as subsets 

of single and double hull Tank Vessel, and the Non-Tank Vessel category is divided between vessels 

greater than 300 gross tons and vessels less than or equal to 300 gross tons.4

 

4

 The comparative results for single and double hull tank barges may appear incongruous at first glance. While 

double hull vessels may be safer, and be less likely to spill oil, the data shows that a catastrophic discharge from a 

double hull tank barge can be just as expensive as one from a single hull tank barge. 

$0

$25,000,000

$50,000,000

$75,000,000

$100,000,000

$125,000,000

$150,000,000

$175,000,000

$200,000,000

$225,000,000

$250,000,000

$275,000,000

Single Hull Tank

Ship

Double Hull Tank

Ship

Single Hull Tank

Barge

Double Hull Tank

Barge

Non-Tank Vessel 

> 300 gross tons

Non-Tank Vessel 

< or = 300 gross

tons

Fund Share after 50 % Cos t

Share (Average/ Ves sel)

Increased RP Share if 50%

(Average/ Ves sel)

RP Share at Current Limits

(Average/ Ves sel))

Minimum

 Limit:

$99.2 M

Minimum

 Limit:

$34.1 M 

Minimum

 Limit:

$1.0 M

Minimum

 Limit:

$19.3 M

Minimum

 Limit:

$46.1 M
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

15 

Figure 16: Limits of Liability under OPA 

If the vessel is a. . . The current limits of liability are the ‘greater of:’ But to achieve an 

of liability would 

Tank Ship 

With a single hull, double sides only, or double bottom only 

Greater than 3,000 gross tons: $3,200 per gross ton or $23,496,000 Less than or equal to 3,000 gross tons: $3,200 per gross ton or $6,408,000 

$3,500 per gross t

With a double hull 

Greater than 3,000 gross tons: $2,000 per gross ton or $17,088,000 Less than or equal to 3,000 gross tons: $2,000 per gross ton or $4,272,000 

No data 

Tank Barge With a single hull, double sides only, or double bottom only 

Greater than 3,000 gross tons: $3,200 per gross ton or $23,496,000 Less than or equal to 3,000 gross tons: $3,200 per gross ton or $6,408,000 

$7,700 per gross t

With a double hull 

Greater than 3,000 gross tons: $2,000 per gross ton or $17,088,000 Less than or equal to 3,000 gross tons: $2,000 per gross ton or $4,272,000 

$11,400per gross 

Non-Tank Vessel Greater than 300 gross tons $1,000 per gross ton or $854,400. $1,400 per gross t

Less than or equal to 300 gross tons $1,000 per gross ton or $854,400. $5,300 per gross t
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

16 

Attachment A: Incidents Exceeding Liability Limits by Vessel Type Vessel Type: Tank Ship (Single Hull)

Project Name Incident Year Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability 

T/V JULIE N 1996 ME 18,500 $52,601,200 1.51 $79,428,000 $59,126,000 T/V ATHOS I 2004 NJ 37,900 $252,014,200 1.26 $317,538,000 $121,264,000 TOTAL $396,966,000 $180,390,000 

Vessel Type: Tank Barge (Single Hull) 

T/B VISTABELLA 1991 PR 1,100 $6,071,800 1.74 $10,565,000 $6,408,000 T/B (TAMPA BAY COLLISION) 1993 FL 9,300 $68,900,000 1.64 $112,996,000 $29,638,000 T/B MORRIS J. BERMAN 1994 PR 5,400 $95,488,300 1.60 $152,781,000 $23,496,000 M/V SCANDIA & T/B NORTH CAPE 1996 RI 5,500 $49,000,000 1.51 $73,990,000 $23,496,000 T/B BUFFALO #292 1996 TX 1,500 $21,493,700 1.51 $32,456,000 $6,408,000 T/B B NO. 120 2003 MA 6,900 $61,054,300 1.29 $78,760,000 $23,496,000 T/B EMC 423 2005 IL 1,400 $12,778,500 1.21 $15,462,000 $6,408,000 TOTAL $477,010,000 $119,350,000 

Vessel Type: Tank Barge (Double Hull) 

T/B DBL 152 2005 LA 9,700 $55,348,900 1.21 $66,972,000 $19,482,000 T/B DM932 2008 LA 800 $104,464,800 1.10 $114,911,000 $4,272,000 KIRBY 27706 2014 TX 1,600 $95,000,000 1.00 $95,000,000 $4,272,000 TOTAL $276,883,000 $28,026,000 

Vessel Type: Cargo/Other Self Propelled Vessel 

M/V KUROSHIMA 1997 AK 4,200 $19,702,600 1.48 $29,160,000 $4,160,000 M/V KURE 1997 CA 36,000 $47,218,900 1.48 $69,884,000 $36,009,000 M/V NEW CARISSA 1999 OR 36,600 $50,501,400 1.42 $71,712,000 $36,571,000 M/V STUYVESANT 1999 CA 7,100 $11,700,000 1.42 $16,614,000 $7,111,000 M/V SERGO ZAKARIADZE 1999 PR 16,500 $15,966,700 1.42 $22,673,000 $16,502,000 SS J LUCKENBACH 2001 CA 7,900 $40,887,000 1.34 $54,789,000 $7,869,000 M/V KIMTON 2001 PR 200 $713,700 1.34 $956,000 $854,000 VICTORIA ROSE HUNT 2003 MA 100 $1,085,700 1.29 $1,401,000 $854,000 M/V RED DIAMOND 2003 FL 200 $2,595,200 1.29 $3,348,000 $854,000 
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

17 

Vessel Type: Cargo/Other Self-Propelled Vessel (Cont.) 

Project Name Incident Year Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability CRANE BARGE MONARCH 2003 CA 200 $2,481,700 1.29 $3,201,000 $854,000 M/V BOWSTRING 2003 FL 300 $1,606,500 1.29 $2,072,000 $854,000 M/V SELENDANG AYU 2004 AK 39,800 $152,869,900 1.26 $192,616,000 $39,755,000 M/V ORIENTAL I 2004 FL 200 $727,400 1.26 $916,000 $854,000 ALBION 2005 CA 200 $1,207,100 1.21 $1,461,000 $854,000 M/V CASITAS 2005 HI 300 $1,710,700 1.21 $2,070,000 $854,000 MAMA LERE 2006 TX 400 $1,217,300 1.18 $1,436,000 $854,000 M/V COSCO BUSAN 2007 CA 65,100 $110,557,900 1.14 $126,036,000 $65,131,000 M/V SENECA 2007 MI 200 $1,211,000 1.14 $1,381,000 $854,000 LST-1166 2007 OR 2,400 $5,151,000 1.14 $5,872,000 $2,418,000 CATALA 2007 WA 5,700 $6,138,500 1.14 $6,998,000 $5,700,000 C/V SEA WITCH 2008 MD 17,900 $20,629,900 1.10 $22,693,000 $17,902,000 BIG BOY & SCOOBY DOO 2008 PA 200 $1,010,800 1.10 $1,112,000 $854,000 WENONAH 2009 CA 300 $947,800 1.11 $1,052,000 $854,000 SOUND DEVELOPER 2009 AK 200 $1,657,100 1.11 $1,839,000 $854,000 MONARCH 2009 AK 300 $2,698,200 1.11 $2,995,000 $854,000 M/V PRINCESS KATHLEEN 2010 AK 5,900 $14,185,900 1.09 $15,463,000 $5,875,000 DAVY CROCKETT 2011 WA 4,600 $22,457,500 1.05 $23,580,000 $4,643,000 TUG TIGER 2011 CA 200 $4,205,500 1.05 $4,416,000 $854,000 JIREH 2012 PR 1,000 $16,467,300 1.03 $16,961,000 $979,000 RESPECT 2013 CA 200 $2,349,700 1.02 $2,397,000 $854,000 TOTAL $707,103,000 $264,295,000 

Vessel Type: Fishing Vessel 

F/V TENYO MARU 1991 WA 4,200 $6,062,900 1.74 $10,549,000 $4,167,000 F/V JIN SHIANG FA 1993 AS 400 $2,013,000 1.64 $3,301,000 $854,000 F/V YU TE NO. 1 1999 AS 200 $1,164,600 1.42 $1,654,000 $854,000 F/V AMIGA NO. 5 1999 AS 200 $3,355,700 1.42 $4,765,000 $854,000 F/V KWANG MYONG 1999 AS 200 $1,554,800 1.42 $2,208,000 $854,000 F/V KORAM NO. 3 1999 AS 200 $1,403,100 1.42 $1,992,000 $854,000 F/V KWANG MYONG NO 72 1999 AS 200 $2,182,900 1.42 $3,100,000 $854,000 F/V KWANG MYONG NO 58 1999 AS 200 $1,557,600 1.42 $2,212,000 $854,000 F/V KORAM NO 1 1999 AS 200 $1,378,400 1.42 $1,957,000 $854,000 
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

18 

Vessel Type: Fishing Vessel (Cont.) 

Project Name Incident 

Year

Incident 

Location

Gross 

Tonnage

Total 

Incident Cost 

Inflation 

Factor

Total Incident 

Cost (2014 

Dollars)

Limits of 

Liability

F/V KWANG MYONG NO 51 1999 AS 200 $1,249,200 1.42 $1,774,000 $854,000 F/V JESSICA ANN 2000 ME 200 $947,000 1.38 $1,307,000 $854,000 F/V SWORDMAN I 2000 HI 100 $1,528,600 1.38 $2,109,000 $854,000 F/V WINDY BAY 2001 AK 400 $3,396,400 1.34 $4,551,000 $854,000 F/V VANGUARD 2001 AK 200 $699,800 1.34 $938,000 $854,000 F/V GENEI MARU #7 2002 AK 100 $869,800 1.32 $1,148,000 $854,000 F/V TERESA LYNN 2002 FL 200 $690,800 1.32 $912,000 $854,000 F/V NEW HORIZON 2004 CA 100 $805,300 1.26 $1,015,000 $854,000 F/V MWALIL SAAT 2004 GU 200 $3,413,500 1.26 $4,301,000 $854,000 F/V THE BOSS 2004 OR 200 $926,100 1.26 $1,167,000 $854,000 F/V MILKY WAY 2005 WA 200 $1,039,600 1.21 $1,258,000 $854,000 CAPT MIKE 2009 LA 100 $2,413,400 1.11 $2,679,000 $854,000 F/V MAR-GUN 2009 AK 200 $1,388,100 1.11 $1,541,000 $854,000 DEEP SEA 2012 WA 200 $2,231,000 1.03 $2,298,000 $854,000 F/V LONE STAR 2013 AK 100 $2,275,000 1.02 $2,321,000 $854,000 DAIKI MARU 7 2014 GU 100 $1,550,000 1.00 $1,550,000 $854,000 TOTAL $62,606,000 $24,672,000 GRAND TOTAL $1,920,568,000 $616,734,000 
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

19 

Attachment B: Incidents Exceeding Liability Limits by Incident Date Incident Year: 1991 

 Vessel Type Project Name Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability 

 Fishing Vessel F/V TENYO MARU WA 4,200 $6,062,900 1.74 $10,549,000 $4,167,000  Tank Barge (Single Hull) T/B VISTABELLA PR 1,100 $6,071,800 1.74 $10,565,000 $6,408,000  TOTAL $21,114,000 $10,575,000 

Incident Year: 1993 

 Fishing Vessel F/V JIN SHIANG FA AS 400 $2,013,000 1.64 $3,301,000 $854,000 

 Tank Barge (Single Hull) 

T/B (TAMPA BAY COLLISION) FL 9,300 $68,900,000 1.64 $112,996,000 $29,638,000 

 TOTAL $116,297,000 $30,492,000 

Incident Year: 1994 

 Tank Barge (Single Hull) T/B MORRIS J. BERMAN PR 5,400 $95,488,300 1.60 $152,781,000 $23,496,000 

 TOTAL $152,781,000 $23,496,000 

Incident Year: 1996 

 Tank Barge (Single Hull) 

M/V SCANDIA & T/B NORTH CAPE RI 5,500 $49,000,000 1.51 $73,990,000 $23,496,000 

 Tank Barge (Single Hull) T/B BUFFALO #292 TX 1,500 $21,493,700 1.51 $32,456,000 $6,408,000  Tank Ship (Single Hull) T/V JULIE N ME 18,500 $52,601,200 1.51 $79,428,000 $59,126,000  TOTAL $185,874,000 $89,030,000 

Incident Year: 1997 

 Cargo/Other SPV M/V KUROSHIMA AK 4,200 $19,702,600 1.48 $29,160,000 $4,160,000 

 Cargo/Other SPV M/V KURE CA 36,000 $47,218,900 1.48 $69,884,000 $36,009,000  TOTAL $99,044,000 $40,169,000 
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

20 

Incident Year: 1999 

 Vessel Type Project Name Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability  Cargo/Other SPV M/V NEW CARISSA OR 36,600 $50,501,400 1.42 $71,712,000 $36,571,000  Cargo/Other SPV M/V STUYVESANT CA 7,100 $11,700,000 1.42 $16,614,000 $7,111,000  Cargo/Other SPV 

M/V SERGO ZAKARIADZE PR 16,500 $15,966,700 1.42 $22,673,000 $16,502,000 

 Fishing Vessel F/V YU TE NO. 1 AS 200 $1,164,600 1.42 $1,654,000 $854,000  Fishing Vessel F/V AMIGA NO. 5 AS 200 $3,355,700 1.42 $4,765,000 $854,000  Fishing Vessel F/V KWANG MYONG AS 200 $1,554,800 1.42 $2,208,000 $854,000  Fishing Vessel F/V KORAM NO. 3 AS 200 $1,403,100 1.42 $1,992,000 $854,000  Fishing Vessel 

F/V KWANG MYONG NO 72 AS 200 $2,182,900 1.42 $3,100,000 $854,000 

 Fishing Vessel 

F/V KWANG MYONG NO 58 AS 200 $1,557,600 1.42 $2,212,000 $854,000 

 Fishing Vessel F/V KORAM NO 1 AS 200 $1,378,400 1.42 $1,957,000 $854,000  Fishing Vessel 

F/V KWANG MYONG NO 51 AS 200 $1,249,200 1.42 $1,774,000 $854,000 

 TOTAL $130,661,000 $67,016,000 

Incident Year: 2000 

 Fishing Vessel F/V JESSICA ANN ME 200 $947,000 1.38 $1,307,000 $854,000 

 Fishing Vessel F/V SWORDMAN I HI 100 $1,528,600 1.38 $2,109,000 $854,000  TOTAL $3,416,000 $1,708,000 

Incident Year: 2001 

 Cargo/Other SPV SS J LUCKENBACH CA 7,900 $40,887,000 1.34 $54,789,000 $7,869,000 

 Cargo/Other SPV M/V KIMTON PR 200 $713,700 1.34 $956,000 $854,000  Fishing Vessel F/V WINDY BAY AK 400 $3,396,400 1.34 $4,551,000 $854,000  Fishing Vessel F/V VANGUARD AK 200 $699,800 1.34 $938,000 $854,000  TOTAL $61,234,000 $10,431,000 

Incident Year: 2002 

 Fishing Vessel F/V GENEI MARU #7 AK 100 $869,800 1.32 $1,148,000 $854,000 

 Fishing Vessel F/V TERESA LYNN FL 200 $690,800 1.32 $912,000 $854,000  TOTAL $2,060,000 $1,708,000 
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

21 

Incident Year: 2003 (Cont.) 

 Vessel Type Project Name Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability  Incident Year: 2003  Cargo/Other SPV VICTORIA ROSE HUNT MA 100 $1,085,700 1.29 $1,401,000 $854,000  Cargo/Other SPV M/V RED DIAMOND FL 200 $2,595,200 1.29 $3,348,000 $854,000  Cargo/Other SPV 

CRANE BARGE MONARCH CA 200 $2,481,700 1.29 $3,201,000 $854,000 

 Cargo/Other SPV M/V BOWSTRING FL 300 $1,606,500 1.29 $2,072,000 $854,000  Tank Barge (Single Hull) T/B B NO. 120 MA 6,900 $61,054,300 1.29 $78,760,000 $23,496,000  TOTAL $88,782,000 $26,912,000 

Incident Year: 2004 

 Fishing Vessel F/V NEW HORIZON CA 100 $805,300 1.26 $1,015,000 $854,000 

 Cargo/Other SPV M/V SELENDANG AYU AK 39,800 $152,869,900 1.26 $192,616,000 $39,755,000  Fishing Vessel F/V MWALIL SAAT GU 200 $3,413,500 1.26 $4,301,000 $854,000  Fishing Vessel F/V THE BOSS OR 200 $926,100 1.26 $1,167,000 $854,000  Tank Ship (Single Hull) T/V ATHOS I NJ 37,900 $252,014,200 1.26 $317,538,000 $121,264,00 Cargo/Other SPV M/V ORIENTAL I FL 200 $727,400 1.26 $916,000 $854,000  TOTAL $517,553,000 $164,435,00

Incident Year: 2005 

 Tank Barge (Double Hull) T/B DBL 152 LA 9,700 $55,348,900 1.21 $66,972,000 $19,482,000 

 Cargo/Other SPV ALBION CA 200 $1,207,100 1.21 $1,461,000 $854,000  Cargo/Other SPV M/V CASITAS HI 300 $1,710,700 1.21 $2,070,000 $854,000  Tank Barge (Single Hull) T/B EMC 423 IL 1,400 $12,778,500 1.21 $15,462,000 $6,408,000  Fishing Vessel F/V MILKY WAY WA 200 $1,039,600 1.21 $1,258,000 $854,000  TOTAL $87,223,000 $28,452,000 

Incident Year: 2006 

 Cargo/Other SPV MAMA LERE TX 400 $1,217,300 1.18 $1,436,000 $854,000 

 TOTAL $1,436,000 $854,000 
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

22 

Incident Year: 2007 

 Vessel Type Project Name Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability  Cargo/Other SPV M/V COSCO BUSAN CA 65,100 $110,557,900 1.14 $126,036,000 $65,131,000  Cargo/Other SPV M/V SENECA MI 200 $1,211,000 1.14 $1,381,000 $854,000  Cargo/Other SPV LST-1166 OR 2,400 $5,151,000 1.14 $5,872,000 $2,418,000  Cargo/Other SPV CATALA WA 5,700 $6,138,500 1.14 $6,998,000 $5,700,000  TOTAL $140,287,000 $74,103,000 

Incident Year: 2008 

 Tank Barge (Double Hull) T/B DM932 LA 800 $104,464,800 1.10 $114,911,000 $4,272,000 

 Cargo/Other SPV C/V SEA WITCH MD 17,900 $20,629,900 1.10 $22,693,000 $17,902,000  Cargo/Other SPV 

BIG BOY & SCOOBY DOO PA 200 $1,010,800 1.10 $1,112,000 $854,000 

 TOTAL $138,716,000 $23,028,000 

Incident Year: 2009 

 Fishing Vessel CAPT MIKE LA 100 $2,413,400 1.11 $2,679,000 $854,000 

 Cargo/Other SPV WENONAH CA 300 $947,800 1.11 $1,052,000 $854,000  Cargo/Other SPV SOUND DEVELOPER AK 200 $1,657,100 1.11 $1,839,000 $854,000  Cargo/Other SPV MONARCH AK 300 $2,698,200 1.11 $2,995,000 $854,000  Fishing Vessel F/V MAR-GUN AK 200 $1,388,100 1.11 $1,541,000 $854,000  TOTAL $10,106,000 $4,270,000 

Incident Year: 2010 

 Cargo/Other SPV 

M/V PRINCESS KATHLEEN AK 5,900 $14,185,900 1.09 $15,463,000 $5,875,000 

 TOTAL $15,463,000 $5,875,000 

Incident Year: 2011 

 Cargo/Other SPV DAVY CROCKETT WA 4,600 $22,457,500 1.05 $23,580,000 $4,643,000 

 Cargo/Other SPV TUG TIGER CA 200 $4,205,500 1.05 $4,416,000 $854,000  TOTAL $27,996,000 $5,497,000 
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

23 

Incident Year: 2012 

 Vessel Type Project Name Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability  Cargo/Other SPV JIREH PR 1,000 $16,467,300 1.03 $16,961,000 $979,000  Fishing Vessel DEEP SEA WA 200 $2,231,000 1.03 $2,298,000 $854,000  TOTAL $19,259,000 $1,833,000 

Incident Year: 2013 

 Fishing Vessel F/V LONE STAR AK 100 $2,275,000 1.02 $2,321,000 $854,000  Cargo/Other SPV RESPECT CA 200 $2,349,700 1.02 $2,397,000 $854,000  TOTAL $4,718,000 $1,708,000 

Incident Year: 2014 

 Tank Barge (Double Hull) KIRBY 27706 TX 1,600 $95,000,000 1.00 $95,000,000 $4,272,000  Fishing Vessel DAIKI MARU 7 GU 100 $1,550,000 1.00 $1,550,000 $854,000  TOTAL $96,550,000 $5,126,000 Total 1991-2000 $709,187,000 $262,491,00Total 2001-2013 $1,211,382,000 $354,243,00GRAND TOTAL $1,920,568,000 $616,734,00

SPV - Self-Propelled Vessel
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

24 

Attachment C: Incidents Exceeding Liability Limits with Limits to Achieve Vessel Type: Tank Ship (Single Hull) 

Project Name Incident Year Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability Fund Exposure Act

OSL

Co

Incu

T/V JULIE N 1996 ME 18,500 $52,601,200 1.51 $79,428,000 $59,126,000 $20,301,000 $28,37T/V ATHOS I 2004 NJ 37,900 $252,014,200 1.26 $317,538,000 $121,264,000 $196,274,000 $210,2TOTAL $396,966,000 $180,390,000 $216,575,000 $238,6

Vessel Type: Tank Barge (Single Hull) 

T/B VISTABELLA 1991 PR 1,100 $6,071,800 1.74 $10,565,000 $6,408,000 $4,157,000 $4,78T/B (TAMPA BAY COLLISION) 1993 FL 9,300 $68,900,000 1.64 $112,996,000 $29,638,000 $83,358,000 $2,39T/B MORRIS J. BERMAN 1994 PR 5,400 $95,488,300 1.60 $152,781,000 $23,496,000 $129,285,000 $95,4M/V SCANDIA & T/B NORTH CAPE 1996 RI 5,500 $49,000,000 1.51 $73,990,000 $23,496,000 $50,494,000 $9,04T/B BUFFALO #292 1996 TX 1,500 $21,493,700 1.51 $32,456,000 $6,408,000 $26,048,000 $16,8T/B B NO. 120 2003 MA 6,900 $61,054,300 1.29 $78,760,000 $23,496,000 $55,264,000 $1,75T/B EMC 423 2005 IL 1,400 $12,778,500 1.21 $15,462,000 $6,408,000 $9,054,000 $5,83TOTAL $477,010,000 $119,350,000 $357,659,000 $136,1

Vessel Type: Tank Barge (Double Hull) 

T/B DBL 152 2005 LA 9,700 $55,348,900 1.21 $66,972,000 $19,482,000 $47,490,000 $19,7T/B DM932 2008 LA 800 $104,464,800 1.10 $114,911,000 $4,272,000 $110,639,000 $23,37KIRBY 27706 2014 TX 1,600 $95,000,000 1.00 $95,000,000 $4,272,000 $90,728,000 $408TOTAL $276,883,000 $28,026,000 $248,857,000 $43,54

Vessel Type: Non-Tank Vessel > 300 GT 

F/V TENYO MARU 1991 WA 4,200 $6,062,900 1.74 $10,549,000 $4,167,000 $6,382,000 $6,06F/V JIN SHIANG FA 1993 AS 400 $2,013,000 1.64 $3,301,000 $854,000 $2,447,000 $2,42M/V STUYVESANT 1999 CA 7,100 $11,700,000 1.42 $16,614,000 $7,111,000 $9,503,000 $379
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

25 

Vessel Type: Non-Tank Vessel > 300 GT (cont.) 

Project Name Incident Year Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability Fund Exposure Act

OSL

Co

Incu

M/V SERGO ZAKARIADZE 1999 PR 16,500 $15,966,700 1.42 $22,673,000 $16,502,000 $6,171,000 $6,06SS J LUCKENBACH 2001 CA 7,900 $40,887,000 1.34 $54,789,000 $7,869,000 $46,920,000 $44,05F/V WINDY BAY 2001 AK 400 $3,396,400 1.34 $4,551,000 $854,000 $3,697,000 $3,39M/V SELENDANG AYU 2004 AK 39,800 $152,869,900 1.26 $192,616,000 $39,755,000 $152,861,000 $97,7MAMA LERE 2006 TX 400 $1,217,300 1.18 $1,436,000 $854,000 $582,000 $1,21M/V COSCO BUSAN 2007 CA 65,100 $110,557,900 1.14 $126,036,000 $65,131,000 $60,905,000 $4,20LST-1166 2007 OR 2,400 $5,151,000 1.14 $5,872,000 $2,418,000 $3,454,000 $5,15CATALA 2007 WA 5,700 $6,138,500 1.14 $6,998,000 $5,700,000 $1,298,000 $6,13C/V SEA WITCH 2008 MD 17,900 $20,629,900 1.10 $22,693,000 $17,902,000 $4,791,000 $20,63M/V PRINCESS KATHLEEN 2010 AK 5,900 $14,185,900 1.09 $15,463,000 $5,875,000 $9,588,000 $14,18DAVY CROCKETT 2011 WA 4,600 $22,457,500 1.05 $23,580,000 $4,643,000 $18,937,000 $22,45JIREH 2012 PR 1,000 $16,467,300 1.03 $16,961,000 $979,000 $15,982,000 $16,46TOTAL $694,889,000 $257,355,000 $437,533,000 $301,7

Vessel Type: Non-Tank Vessel < or = 300 GT 

F/V YU TE NO. 1 1999 AS 200 $1,164,600 1.42 $1,654,000 $854,000 $799,000 $5,29F/V AMIGA NO. 5 1999 AS 200 $3,355,700 1.42 $4,765,000 $854,000 $3,911,000 $2,76F/V KWANG MYONG 1999 AS 200 $1,554,800 1.42 $2,208,000 $854,000 $1,353,000 $965F/V KORAM NO. 3 1999 AS 200 $1,403,100 1.42 $1,992,000 $854,000 $1,138,000 $813F/V KWANG MYONG NO 72 1999 AS 200 $2,182,900 1.42 $3,100,000 $854,000 $2,245,000 $1,59F/V KWANG MYONG NO 58 1999 AS 200 $1,557,600 1.42 $2,212,000 $854,000 $1,357,000 $967F/V KORAM NO 1 1999 AS 200 $1,378,400 1.42 $1,957,000 $854,000 $1,103,000 $788F/V KWANG MYONG NO 51 1999 AS 200 $1,249,200 1.42 $1,774,000 $854,000 $919,000 $659
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

26 

Vessel Type: Non-Tank Vessel < or = 300 GT (cont.) 

Project Name Incident Year Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability Fund Exposure Act

OSL

Co

Incu

F/V JESSICA ANN 2000 ME 200 $947,000 1.38 $1,307,000 $854,000 $452,000 $947F/V SWORDMAN I 2000 HI 100 $1,528,600 1.38 $2,109,000 $854,000 $1,255,000 $1,52F/V VANGUARD 2001 AK 200 $699,800 1.34 $938,000 $854,000 $83,000 $700M/V KIMTON 2001 PR 200 $713,700 1.34 $956,000 $854,000 $102,000 $714F/V GENEI MARU #7 2002 AK 100 $869,800 1.32 $1,148,000 $854,000 $294,000 $870F/V TERESA LYNN 2002 FL 200 $690,800 1.32 $912,000 $854,000 $57,000 $69VICTORIA ROSE HUNT 2003 MA 100 $1,085,700 1.29 $1,401,000 $854,000 $546,000 $94M/V RED DIAMOND 2003 FL 200 $2,595,200 1.29 $3,348,000 $854,000 $2,493,000 $2,59CRANE BARGE MONARCH 2003 CA 200 $2,481,700 1.29 $3,201,000 $854,000 $2,347,000 $2,48M/V BOWSTRING 2003 FL 300 $1,606,500 1.29 $2,072,000 $854,000 $1,218,000 $1,60F/V NEW HORIZON 2004 CA 100 $805,300 1.26 $1,015,000 $854,000 $160,000 $305F/V MWALIL SAAT 2004 GU 200 $3,413,500 1.26 $4,301,000 $854,000 $3,447,000 $3,41F/V THE BOSS 2004 OR 200 $926,100 1.26 $1,167,000 $854,000 $312,000 $926M/V ORIENTAL I 2004 FL 200 $727,400 1.26 $916,000 $854,000 $62,000 $727F/V MILKY WAY 2005 WA 200 $1,039,600 1.21 $1,258,000 $854,000 $403,000 $539ALBION 2005 CA 200 $1,207,100 1.21 $1,461,000 $854,000 $606,000 $1,20M/V CASITAS 2005 HI 300 $1,710,700 1.21 $2,070,000 $854,000 $1,216,000 $1,71M/V SENECA 2007 MI 200 $1,211,000 1.14 $1,381,000 $854,000 $526,000 $1,21BIG BOY & SCOOBY DOO 2008 PA 200 $1,010,800 1.10 $1,112,000 $854,000 $258,000 $1,01CAPT MIKE 2009 LA 100 $2,413,400 1.11 $2,679,000 $854,000 $1,824,000 $2,41F/V MAR-GUN 2009 AK 200 $1,388,100 1.11 $1,541,000 $854,000 $686,000 $199WENONAH 2009 CA 300 $947,800 1.11 $1,052,000 $854,000 $198,000 $948SOUND DEVELOPER 2009 AK 200 $1,657,100 1.11 $1,839,000 $854,000 $985,000 $1,65MONARCH 2009 AK 300 $2,698,200 1.11 $2,995,000 $854,000 $2,141,000 $24
This listing includes all incidents regardless of vessel size or type and regardless of whether a claim to the Fund by a responsible party for amounts in excess of liability limit

Costs include Federal removal costs and claims paid that have been verified. Other costs are estimated from best available information but cannot otherwise be verified. Fu

and do not imply that the responsible parties will be able to limit their liability under the statute where the issue has not yet been determined. 

27 

Vessel Type: Non-Tank Vessel < or = 300 GT (cont.) 

Project Name Incident Year Incident Location Gross Tonnage Total Incident Cost Inflation Factor Total Incident Cost (2014 Dollars) Limits of Liability Fund Exposure Act

OSL

Co

Incu

TUG TIGER 2011 CA 200 $4,205,500 1.05 $4,416,000 $854,000 $3,561,000 $4,20DEEP SEA 2012 WA 200 $2,231,000 1.03 $2,298,000 $854,000 $1,444,000 $2,23F/V LONE STAR 2013 AK 100 $2,275,000 1.02 $2,321,000 $854,000 $1,467,000 $1,09RESPECT 2013 CA 200 $2,349,700 1.02 $2,397,000 $854,000 $1,542,000 $2,35DAIKI MARU 7 2014 GU 100 $1,550,000 1.00 $1,550,000 $854,000 $696,000 $TOTAL $74,821,000 $31,612,000 $43,209,000 $52,2GRAND TOTAL $1,920,568,000 $616,734,000 $1,303,834,000 $772,2