Salvage and Marine Firefighting Salvage and Marine Firefighting RequirementsRequirements

IntertankoIntertanko

North American PanelNorth American Panel

March 21, 2011March 21, 2011

Steven Candito

President

National Response Corporation (NRC)

ImplementationImplementation

February 22, 2011February 22, 2011 Tank Vessels, but not Non Tank VesselsTank Vessels, but not Non Tank Vessels Dispersant requirements also Dispersant requirements also

implemented on February 22, 2011implemented on February 22, 2011 Dispersant and SMFF Interim Operating Dispersant and SMFF Interim Operating

Authorizations issued to August 21, 2011Authorizations issued to August 21, 2011

Required ServicesRequired Services SalvageSalvage

Assessment & SurveyAssessment & Survey StabilizationStabilization

• Emergency towing, transferring, re-floating, temporary repairs Emergency towing, transferring, re-floating, temporary repairs and diving support.and diving support.

Specialized Salvage OperationsSpecialized Salvage Operations• Subsurface product removal and heavy lift services.Subsurface product removal and heavy lift services.

Marine FirefightingMarine Firefighting Assessment & PlanningAssessment & Planning Fire SuppressionFire Suppression

• External firefighting teams and vessel firefighting systems.External firefighting teams and vessel firefighting systems. Primary Resource Provider (PRP) must be listed in Primary Resource Provider (PRP) must be listed in

VRP for each service, in each COTP zone of VRP for each service, in each COTP zone of operation.operation.

TimeframesTimeframesTable 155.4030(b)Table 155.4030(b)

Marine Firefighting Pre-Fire PlanMarine Firefighting Pre-Fire Plan

Outline of responsibilities and actions during a Outline of responsibilities and actions during a marine fire incident.marine fire incident.

Explains Resource Provider’s role, and incident Explains Resource Provider’s role, and incident support expectations.support expectations.

Coordination policies and procedures.Coordination policies and procedures. Copy of MFF Pre-Fire Plan goes to Resource Copy of MFF Pre-Fire Plan goes to Resource

Providers and into VRP.Providers and into VRP. Resource Provider must certify their agreement Resource Provider must certify their agreement

to implement MFF Pre-Fire Plan.to implement MFF Pre-Fire Plan.

Drill and Exercise RequirementsDrill and Exercise Requirements

VRPs must be exercised to ensure functionality.VRPs must be exercised to ensure functionality.

Quarterly:Quarterly: Remote assessment and consultationRemote assessment and consultation Emergency proceduresEmergency procedures

Annually:Annually: Shore-based salvage and shore-based marine FF management Shore-based salvage and shore-based marine FF management

Table-Top ExerciseTable-Top Exercise Response provider equipment deploymentResponse provider equipment deployment

Every Three Years:Every Three Years: All components of the VRP are to be exercised at least once.All components of the VRP are to be exercised at least once.

Funding AgreementsFunding Agreements

To list Resource Providers in a VRP, they must To list Resource Providers in a VRP, they must have a contract in place.have a contract in place.

Written agreements must be submitted with the Written agreements must be submitted with the VRP.VRP. Rates for resources and services must be agreed Rates for resources and services must be agreed

upon to avoid delayed response.upon to avoid delayed response. Service Provider must ensure by contract, the ability Service Provider must ensure by contract, the ability

to meet the regulatory time frames.to meet the regulatory time frames. The Coast Guard will consider the LOF in lieu of a The Coast Guard will consider the LOF in lieu of a

funding agreement with certain stipulations:funding agreement with certain stipulations: LOF must be referenced throughout the LOF must be referenced throughout the

agreementagreement BothBoth parties must sign the LOF and submit it to parties must sign the LOF and submit it to

the USCGthe USCG

Integration and CoordinationIntegration and Coordination SMFF providers must plan to integrate and SMFF providers must plan to integrate and

coordinate into existing response organizations coordinate into existing response organizations and with OSROsand with OSROs

Salvage Master v Unified CommandSalvage Master v Unified Command

Local Public Fire Departments v Specialized Local Public Fire Departments v Specialized Marine Fire FightersMarine Fire Fighters

Example of Cooperative Success Example of Cooperative Success between Salvor and OSRObetween Salvor and OSRO

July 12July 12thth, 2007, 2007 M/T White Sea runs aground M/T White Sea runs aground

at the entrance to NY Harbor.at the entrance to NY Harbor. Vessel was loaded with 500k Vessel was loaded with 500k

bbls of Crude. bbls of Crude. Salvor requested OSRO Salvor requested OSRO

(NRC) to source lightering (NRC) to source lightering barges. barges.

NRC utilized its Marine NRC utilized its Marine Resource Network (MRN) to Resource Network (MRN) to locate two barges.locate two barges.

All 558k bbls of Crude were All 558k bbls of Crude were transferred successfully.transferred successfully.

Planning Criteria, Planning Criteria, NotNot Performance Performance StandardsStandards

Compliance = Contracting for adequate Compliance = Contracting for adequate resources, from adequate providers who resources, from adequate providers who can meet response timeframes.can meet response timeframes.

If contracted response resources do not If contracted response resources do not arrive within the regulatory time arrive within the regulatory time requirements, this fact does not requirements, this fact does not necessarily mean the regulations were necessarily mean the regulations were not met.not met.

Vetting SMFF Resource ProvidersVetting SMFF Resource Providers

History of Successful OperationsHistory of Successful Operations Certified and Experienced PersonnelCertified and Experienced Personnel 24-hour availability of personnel and 24-hour availability of personnel and

equipmentequipment On-going and continuous training On-going and continuous training

programprogram Record of participation in drills and Record of participation in drills and

exercisesexercises Possession of tested and approved Possession of tested and approved

salvage or marine firefighting planssalvage or marine firefighting plans Membership in relevant national / Membership in relevant national /

international organizationsinternational organizations

Insurance covering salvage and/or Insurance covering salvage and/or marine firefighting services they intend marine firefighting services they intend to provideto provide

Sufficient working capital to support an Sufficient working capital to support an operationoperation

Equipment and experience translate to Equipment and experience translate to unique geographical locationsunique geographical locations

Capability to sustain operations in Capability to sustain operations in long, tough conditionslong, tough conditions

Health & Safety RecordHealth & Safety Record Familiarity with ACPs for each Familiarity with ACPs for each

contracted COTP areacontracted COTP area

Unlike OSROs, the USCG is not “classifying” salvors.Unlike OSROs, the USCG is not “classifying” salvors. Tank vessel owners/operators are responsible for determining the Tank vessel owners/operators are responsible for determining the

adequacy of the service providers listed in their VRPs.adequacy of the service providers listed in their VRPs. Selection criteria to be followed “to the maximum extent possible,” Selection criteria to be followed “to the maximum extent possible,”

include:include:

Classification Classification vs.vs. Owner Vetting Owner Vetting

ClassificationClassification

Easy for OwnerEasy for Owner Harder for SalvorHarder for Salvor More Expensive NowMore Expensive Now

Retainer FeesRetainer Fees Dedicated TugsDedicated Tugs

Less Expensive LaterLess Expensive Later Risk on USCG / SalvorRisk on USCG / Salvor

Owner VettingOwner Vetting

Easy for USCGEasy for USCG Harder for OwnerHarder for Owner Less Expensive NowLess Expensive Now

Free or Minimal FeesFree or Minimal Fees No Dedicated TugsNo Dedicated Tugs

More Expensive LaterMore Expensive Later Risk on OwnerRisk on Owner

Temporary Waivers from Response Temporary Waivers from Response Time RequirementsTime Requirements

If VRP holders are unable to identify a If VRP holders are unable to identify a provider who can meet a response time for provider who can meet a response time for a specific COTP zone… a specific COTP zone…

You may submit requests for You may submit requests for temporarytemporary waivers of waivers of specificspecific response time response time requirements.requirements.

Request must include plans to correct the Request must include plans to correct the shortfall.shortfall.

Status of ImplementationStatus of Implementation

Smooth transition since Feb. 22Smooth transition since Feb. 22ndnd – Most work – Most work completed ahead of time.completed ahead of time.

Over 8,000 vessels and 700 VRPs affected.Over 8,000 vessels and 700 VRPs affected. As of 3/03/2011, Interim Operating Authorization As of 3/03/2011, Interim Operating Authorization

(IOA) has been granted to 7,982 Tank vessels (IOA) has been granted to 7,982 Tank vessels and 582 VRPs.and 582 VRPs.

Majority of approved waiver requestsMajority of approved waiver requests emergency towing & marine firefighting at the pier.emergency towing & marine firefighting at the pier.

Short timeframes are proving difficult to ensure Short timeframes are proving difficult to ensure service in some cases.service in some cases.

Status of Implementation Status of Implementation (Continued)(Continued)

North Carolina, Alaska and Guam identified as North Carolina, Alaska and Guam identified as difficult areas for emergency towing services.difficult areas for emergency towing services.

SMFF service providers are confident in their SMFF service providers are confident in their ability to expand services and fix these issues.ability to expand services and fix these issues.

Questions Surrounding Towing Questions Surrounding Towing Vessel RequirementsVessel Requirements

155.4030(e) – “…towing 155.4030(e) – “…towing vessels must be capable of vessels must be capable of operating in environments operating in environments where the winds are up to 40 where the winds are up to 40 knots.”knots.”

FAQ – “Emergency towing FAQ – “Emergency towing vessels must be identified vessels must be identified (named)…”(named)…”

““Core Four” Resource ProvidersCore Four” Resource Providers

Marine Response Alliance (MRA)Marine Response Alliance (MRA)

Resolve Marine Group (RMG)Resolve Marine Group (RMG)

Donjon-SMITDonjon-SMIT

T&T Bisso ResponseT&T Bisso Response

Questions???Questions???