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OVERVIEW OF CHANGES TO ENVIRONMENTAL REGULATIONS BMUSF 2010

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OVERVIEW OF CHANGES TO ENVIRONMENTAL REGULATIONS BMUSF 2010

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    1. OVERVIEW OF CHANGES TO ENVIRONMENTAL REGULATIONS BMUSF 2010 Capt. Edward Wilmot Vice-President Great American Insurance Group

    4. OPA STATUTORY MINIMUM LIMITS RISE TO $854,400 SCHEDULED TO RISE EVERY 3 YEARS RECOMMEND 4X1 BUMBERSHOOT TO ENSURE SUFFICIENT WRECK REMOVAL AND NRDA STATES BEGINNING TO VIEW INCIDENTS AS A REVENUE STREAM INCREASED DOJ INVOLVEMENT

    5. NON-TANK VESSEL RESPONSE PLANS APPLICABLE TO NON-TANK VESSELS OVER 400 GRT REQUIRES CONTRACTED RESPONSE CAPABILITY EVENTUALLY WILL REQUIRE CONTRACTED SALVAGE AND FIREFIGHTING

    6. FIREFIGHTING AND SALVAGE INITIALLY REQUIRED FOR TANK BARGES PLANS TO EVENTUALLY INCLUDE NON-TANK VESSELS WILL REQUIRE CONTRACTED RESPONSE READ AND INCORPORATE NFPA 1405 – GUIDE FOR LAND BASED FIREFIGHTERS WHO RESPOND TO FIRES ABOARD MARINE VESSELS

    7. BE CAREFUL WHAT YOU WISH FOR!!! VGP Discharges incidental to normal operation of a vessel exempt 2005 lawsuit by NW Environmental Advocates –exemption invalid – initially only sought to regulate ballast – courts said everything – 26 new waste-streams

    8. Who is required to have a Vessel General Permit? Recreational vessels are exempt. Vessels more than 300 GRT or having the ability to hold or discharge more than 8 cubic meters of ballast must file a Notice of Intent

    9. What waste streams are regulated? Deck Runoff Bilgewater Oily water Separator effluent Hull coating Leachate Aqueous film forming foam Cathodic protection Chain locker Effluent Controllable Pitch Hydraulic fluid Distillation Brine Elevator pit effluent Firemain system Freshwater layupGraywater Refrigeration and air condensate Discharge Sewage of any sort Small boat engine wet exhaust 10 add’l Miscellaneous discharges

    10. ENFORCEMENT TO BE REGULATED BY COAST GUARD CONCENTRATING ON VESSELS OVER 1600 GRT FOR NOW RESPONDING TO REPORTS OF DISCHARGE BY BOATERS IN THE NORTHWEST SIGNS OF INTEREST BY DOJ

    11. ITS ALL ABOUT PAPERWORK ACCURATE VOYAGE LOG DOCUMENT ALL VIOLATIONS LOG ALL INSPECTIONS, DEFICIENCIES AND CORRECTIVE ACTIONS RECOMMEND DEVELOPING A CHECKLIST OF LOG ENTRIES WITH STANDARDIZED WORDING FOR EACH ENTRY

    12. PENALTIES ADMINISTRATIVE – UP TO $37,500/DAY INJUNCTIVE – CAN PREVENT VESSEL FROM OPERATING OR REQUIRE CORRECTIVE ACTION CRIMINAL – FINES AND IMPRISONMENT SEPARATE PENALTIES UNDER CLEAN WATER ACT /VGP FOR FALSE STATEMENTS

    13. VGP POLICY COVERS CIVIL ADMINISTRATIVE PENALTIES FOR ACTUAL DISCHARGES THAT VIOLATE STATUTE AND DEFENSE COSTS TYPICAL LIMIT IS $1M EXCLUSIONS FOR TRAINING AND RECORDKEEPING VIOLATIONS AND ACTUAL STRUCTURAL CHANGE REQUIREMENTS

    14. AIR POLLUTION 2008 IMO Adopted Marpol Annex VI – Regulations for Prevention of Air Pollution from Ships USA adopts as Maritime Pollution Prevention Act of 2008 USA & Canada have Applied to IMO to have all Coastal waters of both nations designated as an Emissions Control Area

    15. AIR POLLUTION REGULATIONS OWNERS OF ENGINES OVER 175 HP INSTALLED ON VESSELS TRADING INTERNATIONALLY AND BUILT AFTER 1/1/2000 MUST HAVE EPA INTL. AIR POLLUTION CERTIFICATE AND MANUAFACTURER FILE SHOWING COMPLIANCE WITH NOx LIMITS OF MARPOL MUST BURN FUEL THAT MEETS Sox requirements (USA MARINE DIESEL MEETS THIS REQUIREMENT EPA MAY EXEMPT VESSELS SOLELY TRADING IN USA

    16. STORAGE TANKS EPA RULES REQUIRING DOUBLE WALLS BEING ENFORCED

    17. ACL & COSCO BUSAN WHAT DO THEY HAVE IN COMMON?

    18. COMMONALITY COSTLY MISMANAGED? EXTRAORDINARY INVOLVEMENT OF THE DOJ

    19. ROOT CAUSE FIRST SPILLS MANAGED BY THE MEDIA AND THE POLITICIANS

    20. IMPACT ON INDUSTRY INDUSTRY LOSS REDUCTIONS IN LINE SIZE SOME COMPANIES REFUSING EXCESS IF THERE IS ANY UNDERLYING POLLUTION RISK EXCESS LIABILITY RATES FINALLY INCREASING.

    21. Thank you!!

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