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

Salvage and Marine Firefighting
&
CAPS/Dispersant Regulations:
Vessel Response Plans for Oil
33 CFR Part 155
BACKGROUND
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.
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.
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.
When determining a resource provider, owner/operators
must select a provider that meets these criteria to the
maximum extent possible.
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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
Currently four commercial entities are
approved as primary resource providers:
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Donjon-SMIT
Marine Response Alliance LLC
Resolve Marine Group, INC.
T&T Bisso, LLC
19 SMFF services that are required to be listed in the Geographic
Specific Appendices, with resource provider and contact
information
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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
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Making temporary repairs
Diving Services support
Special salvage operations plan
Subsurface product removal
Heavy lift
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MARINE FIREFIGHTING
Remote Assessment and consultation
On-site fire assessment
External firefighting teams
External vessel firefighting systems
Service
(1)
Location of incident response
activity timeframe
Inland and Near
shore area
Salvage
Maximum
Waiver Time
Period
Off-shore
Assessment & Survey:
1. Remote assessment and consultation
1
1
0
2. Begin assessment of structural
stability
3. On-site salvage assessment
4. Assessment of structural stability
5. Hull and bottom survey
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6
12
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18
18
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1
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12
16
18
18
22
24
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3
3
18
18
18
18
24
24
24
24
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3
3
3
18
72
Estimated
24
84
Estimated
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5
N/A
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1
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2
6
12
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4
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8
12
12
18
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Stabilization:
6. Emergency towing
7. Salvage plan
8. External emergency transfer
operations
9. Emergency lighting
10. Other refloating methods
11. Making temporary repairs
12. Diving services support
Specialized Salvage Operations:
13. Special salvage operations plan
14. Subsurface product removal
15. Heavy Lift
(2)
Marine Firefighting
At Pier (hours)
Assessment & Planning
16. Remote assessment and
consultation
17. On-site fire assessment
Fire Suppression:
18. External firefighting teams
19. External vessel firefighting systems
• 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.
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.
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
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:
1. Remote assessments and consultations quarterly
2. Emergency Procedures exercises quarterly
3. Shore-based SMFF management team tabletop exercises
annually
4. Response provider equipment deployment exercises
annually
5. Exercise the entire response plan every three years
Activation of SMFF GSA annex
WSMC’s involvement and relations
with the vessel’s qualified individual
(QI)
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
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 preapproved areas
Coast Guard Authorization Act
Movement of higher volume port
area line from Port Angeles to Neah
Bay
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.
Pre-Staged Response Equipment
Locations
Questions?