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Vessel Response Plan Program

Overview

VRP Program Responsibilities/History Tank Vessel Response Plans Nontank Vessel Response Plans Waivers Rulemakings Salvage and Marine Firefighting Requirements

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United States Coast Guard

Vessel Response Plan Program

Prepare/align Industry and Units to Requirements of existing, new & upcoming regulations (Tank, Nontank, S&MFF). Consistent enforcement efforts, foster compliance by industry, & possibly spur build-up of response resources in remote areas. Verify a vessel's compliance with VRP & NTVRP requirements. Verify GSAs that vessel is approved for ­ listed on approval letter and VRP database.

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United States Coast Guard

PROGRAM HISTORY

In the aftermath of the EXXON VALDEZ oil spill in 1989, Congress passed the Oil Pollution Act of 1990. OPA 90 is the single largest piece of legislation entrusted to the U.S. Coast Guard. Tank Vessels required to submit response plans. Nontank Vessels ­ required to submit response plans since August 2005; Notice of Proposed Rulemaking published Aug 2009. Tank Vessel Response Plans required to have Salvage and Marine Fire Fighting Resources identified/contracted by February 2011.

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United States Coast Guard

Tank Vessel Response Plans

33 CFR 155.1015 Applies to;

U.S. vessel or Foreign Constructed or adapted to carry, or that carries, oil in bulk as cargo or oil cargo residue. Transfer oil in a port or place subject to the jurisdiction of the U.S.

Does not apply to; Ø Ø Ø Ø Foreign vessels engaged in innocent passage Offshore Supply Vessels Dedicated response vessels when conducting response ops Public Vessels

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United States Coast Guard

Vessel Response Plan

Prior to conducting operations (or prior to port entry) provide an approved VRP. Prior to conducting operations (or prior to port entry) provide an approved GSA (geographic specific appendix) for the COTP zone, including evidence of OSRO coverage. Prior to conducting operations, provide the QI contact information. Update VRP with current contact/notification information.

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United States Coast Guard

One Time Waivers

33 CFR 155.1025(e) Owner or operator has a valid VRP or SOPEP; and The plan is onboard the vessel; and A QI has been identified to the master of the vessel; and The owner or operator has identified through contract or other approved means the private resources necessary to respond to the maximum extent practicable to a worst case discharge from the vessel in that zone. Requests for one time voyage VRP waivers must be requested from each affected COTP.

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United States Coast Guard

Nontank Vessel Response Plans

History On August 9, 2004, the President signed the Coast Guard and Maritime Transportation Act of 2004 (CGMTA 2004). Sections of the FWPCA require the CG to issue regulations that require an owner or operator of a nontank vessel to prepare and submit to the Coast Guard a plan for responding, to the maximum extent practicable, to a worst case discharge, and to a substantial threat of such a discharge, of oil. Section 701(c) of the CGMTA 2004 required that these response plans be prepared and submitted to the CG no later than one year after the date of enactment of the 2004 Act.

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United States Coast Guard

Nontank Vessel Response Plans

Implementing Regulations NPRM was Published on August 31, 2009 90 Day Comment Period Closes November 30, 2009 Public Meetings Washington D.C. October 28th Oakland, CA November 3rd New Orleans, LA November 19th

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United States Coast Guard

Nontank Vessel Response Plans

Applicability: Self-propelled; Uses oil as fuel for main propulsion; 400 GT (ITC) or greater; Operates on the Navigable Waters of the U.S.

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United States Coast Guard

Nontank Vessel Response Plans

Enforcement focused on vessels 1600 GT & above Only impacts vessels who have not submitted plans Use of COTP Operational Controls until plans have been submitted and have obtained "Pending" or "Interim Ops" Status "Awareness & Education" impact on vessels between 400 - 1600 GTs

Nontank Vessel Response Plans

Confirm Nontank VRP approval for the COTP zone and those zones where vessel intends to conduct operations. VRP Database will show vessel as either "Pending" or "Interim Ops" ­ Either is OK for vessel to operate.

NTVRP contains contracts for OSRO(s) in COTP zone NTVRP contains designated QI NTVRP contains information on drills/training ­ crew should be familiar with oil spill response and equipment carried onboard the vessel

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United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule 33 CFR Part 155

The Oil Pollution Act of 1990 mandated that tank vessel owners ensure the availability of adequate response resources to respond to a vessel's worst-case discharge, including fire and explosion. The VRP regulations published in 1996 were not specific for salvage and marine firefighting requirements. Following a long history of public meetings, and regulatory postponements, on December 31, 2009, the Coast Guard issued the final Salvage and Marine Firefighting regulation which became effective in early 2009.

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

FOCUS ON RESOURCE AVAILABILITY Defines salvage and marine firefighting services / resources. Establishes planning timeframes for response. Provides criteria for determining resource provider adequacy.

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

SALVAGE AND MARINE FIREFIGHTING SERVICES: SALVAGE: Assessment and Survey Stabilization Specialized Salvage Operations MARINE FIREFIGHTING Assessment and Planning Fire Suppression

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

Salvage and Marine Firefighting Service Timeframes: Salvage: Assessment and Survey

REMOTE ASSESSMENT AND CONSULTATION BEGIN ASSESSMENT OF STRUCTURAL STABILITY ON-SITE SALVAGE ASSESSMENT ASSESSMENT OF STRUCTURAL STABILITY HULL AND BOTTOM SURVEY

NEAR (HOURS) OFFSHORE (HOURS)

1 3 6 12 12

1 3 12 18 16

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

Salvage:

NEAR

(HOURS)

OFFSHORE

(HOURS)

Stabilization

EMERGENCY TOWING SALVAGE PLAN EXTERNAL EMERGENCY TRANSFER EMERGENCY LIGHTERING OTHER REFLOATING METHODS MAKING TEMPORARY REPAIRS DIVING SERVICES SUPPORT

12 16 18 18 18 18 18

18 22 24 24 24 24 24

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

Salvage: Specialized Salvage Operations

SPECIAL SALVAGE OPERATIONS PLAN SUBSURFACE PRODUCT REMOVAL HEAVY LIFT

NEAR (HOURS)

OFFSHORE (HOURS)

18 72

ESTIMATED

24 84

ESTIMATED

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

Salvage and Marine Firefighting Service Timeframes: Marine Firefighting: Assessment and Planning

PIER NEAR OFFSHORE (HOURS)

(HOURS) (HOURS)

REMOTE ASSESSMENT & CONSULTATION ON-SITE FIRE ASSESSMENT

1 2

1 6

1 12

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

Salvage and Marine Firefighting Service Timeframes: Marine Firefighting: Fire Suppression

EXTERNAL FIREFIGHTING TEAMS EXTERNAL VESSEL FIREFIGHTING SYSTEMS

PIER NEAR OFFSHORE (HOURS)

(HOURS) (HOURS)

4 4

8 12

12 18

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

15 Resource Selection Criteria:

1. 2.

Currently working in response service needed Has documented history of participation in successful salvage and/or marine firefighting operations, including equipment deployment Owns or has contracts for equipment needed to perform response services Has personnel with documented training certification and degree experience Has 24-hour availability of personnel and equipment and history of response times compatible with the regulation

3. 4. 5.

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

15 Resource Selection Criteria:

6. 7. Has ongoing continuous training program Has successful record of participation in drills and exercises

10. Has salvage and marine firefighting plans used and approved during real incidents 9. Has membership in relevant national and/or international organizations

10. Has insurance that covers the salvage and/or marine firefighting services which they intend to provide

United States Coast Guard

Salvage and Marine Firefighting Requirement, Vessel Response Plans for Oil, Final Rule

15 Resource Selection Criteria:

11. Has sufficient up front capital to support an operation 12. Has equipment and experience to work in the specific regional geographic environments where the vessel operates 13. Has the logistical and transportation support capability required to sustain operations 14. Has the capability to implement the necessary engineering, administrative and personal protective equipment controls to safeguard the health and safety of their workers 15. Has familiarity with the salvage and marine firefighting protocol contained in the local ACPs for each COTP area for which they are contracted

United States Coast Guard

Aleutian Trade Act

Established following OPA 90 to provide for the transportation of cargo in the Aleutian trade. Aleutian Trade Defined: 2102 Vessels subject to Inspection: 3301 Fishing Vessel Defined: 2101 (11a) Fish Processing Vessel Defined: 2101 (11b) Fish Tender Vessel Defined: 2101 (11c) Inspection Exemption: 3302 46 CFR 28 Subpart G

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United States Coast Guard

Aleutian Trade Act

United States Coast Guard

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