Salvage and Marine Firefighting & CAPS/Dispersant Regulations: Vessel Response Plans for Oil

1. Salvage and Marine Firefighting &CAPS/Dispersant Regulations: Vessel Response Plans for Oil 33 CFR Part 155

2. Requirements to identify Salvage and Marine Firefighting (SMFF) resources have been required since 1993. USCG expected that the significant benefits of a quick and effective SMFF would be sufficient incentive for industry to develop SMFF capabilities, similar to the development of oil spill removal organizations that was seen in the early 1990s. In 1997, it became apparent that the expected SMFF capability was not occurring. Background

3. All vessel owner/operators that carry group I-IV oils, and required to have a vessel response plan must have been in compliance by February 22, 2011.

4. Owner/Operators must identify, in the Geographical-specific Appendixes (GSAs) of the Vessel Response Plan, SMFF and Response timeframes. Additionally Owner/Operators must list those resource providers that are contracted to provide these services.One Primary Resource Provider must be identified for each COTP zone with a method of contact.

5. When determining a resource provider, owner/operators must select a provider that meets these criteria to the maximum extent possible. • Currently working in response services needed • Document history of successful salvage/marine firefighting ops, incl equipment deployment • Owns or has contracts for equipment • Personnel with training certification and degree experience • 24 hr availability of personnel and equipment • On-going training program, firefighting provides meet NFPA guidelines • Successful record of participation in drills and exercises • Salvage or firefighting plans used and approved during a real incident • Membership in relevant national/international organizations • Insurance that covers the services which they intend to provide • Sufficient up front capital to support an operation • Equipment and experience to work in the GSA • Logistical and transportation support capability required for extended periods • Capability to implement necessary eng, admin, & Personal Protective Equipment (PPE) controls • Familiarity with salvage& firefighting protocols in the ACP and COTP area

6. Currently four commercial entities are approved as primary resource providers: • Donjon-SMIT • Marine Response Alliance LLC • Resolve Marine Group, INC. • T&T Bisso, LLC

7. 19 SMFF services that are required to be listed in the Geographic Specific Appendices, with resource provider and contact information SALVAGE • Remote assessment and • consultation • Begin assessment of structural stability • On-site salvage assessment • Assessment of structural stability • Hull and bottom survey • Emergency towing • Salvage plan • External emergency transfer operations • Emergency lightering • Other refloating methods • Making temporary repairs • Diving Services support • Special salvage operations plan • Subsurface product removal • Heavy lift • MARINE FIREFIGHTING • Remote Assessment and consultation • On-site fire assessment • External firefighting teams • External vessel firefighting systems

9. The times listed are planning criteria and not performance standards. • Response times will be evaluated during drills which require activation of the VRP including the SMFF annex. • Any concerns in response capabilities will be noted and addressed with the Resource Provider for potential revision of the GSA.

10. COTP Enforcement • All vessels are that fall within this regulation are screened prior to arrival. On February 22nd they are required to have SMFF GSAs as part of the GSAs. • Vessels regulated by this rule that do not have GSAs in place will receive a COTP Order not to enter port unless an Interim Operating Authorization from the Coast Guard is approved.

11. Since plan review can be time consuming, Coast Guard headquarters will be issuing Interim Operating Authorizations for a period not to exceed 180 days to vessels who have submitted SMFF VRP updates

12. The Vessel Owner/Operator required to have a response plan shall conduct exercises to ensure that the plan will function in an emergency. The minimum requirements are: • Remote assessments and consultations quarterly • Emergency Procedures exercises quarterly • Shore-based SMFF management team tabletop exercises annually • Response provider equipment deployment exercises annually • Exercise the entire response plan every three years

13. Activation of SMFF GSA annex WSMC’s involvement and relations with the vessel’s qualified individual (QI)

14. QI Actions • Initiates VRP • Includes activation of oil, hazmat, salvage, and marine fire fighting responses (if applicable) • QI activates oil and hazmat response by contacting previously identified OSRO • QI activates SMFF GSA annex by notifying the primary resource provider

15. CAPS/Dispersant Regulations • Old regulations allowed for a credit against up to 25% of on water oil recovery capability IF vessel’s contracted for dispersant capabilities • New regulations are removing the credit and requiring the procurement of dispersant contracts for vessels carrying groups II-IV oils that operate in year-round dispersant pre-approved areas

17. Coast Guard Authorization Act Movement of higher volume port area line from Port Angeles to Neah Bay

18. Higher Volume Port Area Line Relocation • The Coast Guard Authorization Act of 2010 section 710: • Replaces Port Angeles, WA with Cape Flattery, WA as the “higher volume port area” specified in Coast Guard regulations (33 CFR 155.1020). The Act mandates the change to occur within 1 year. • Requires Coast Guard to review any changes to vessel response plans under the FWPCA resulting from such modification within 5 years of the Act. • Although the higher volume port area line will be moving, at this time there is no anticipated relocation of pre-staged response equipment.

19. Pre-Staged Response Equipment Locations

20. Questions?