Salvage and Marine Firefighting

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

• 33 CFR Part 155

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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.

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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.
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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.
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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

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Currently four commercial entities are approved
as primary resource providers

• Donjon-SMIT
• Marine Response Alliance LLC
• Resolve Marine Group, INC.
• TT Bisso, LLC

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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

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Service Location of incident response activity timeframe Location of incident response activity timeframe Location of incident response activity timeframe Maximum Waiver Time Period
Salvage Assessment Survey Inland and Near shore area Off-shore
1. Remote assessment and consultation 1 1 0
2. Begin assessment of structural stability 3 3 1
3. On-site salvage assessment 6 12 1
4. Assessment of structural stability 12 18 1
5. Hull and bottom survey 12 18 2
Stabilization
6. Emergency towing 12 18 3
7. Salvage plan 16 22 3
8. External emergency transfer operations 18 24 3
9. Emergency lighting 18 24 0
10. Other refloating methods 18 24 3
11. Making temporary repairs 18 24 3
12. Diving services support 18 24 3
Specialized Salvage Operations
13. Special salvage operations plan 18 24 5
14. Subsurface product removal 72 84 5
15. Heavy Lift Estimated Estimated N/A
(2) Marine Firefighting Assessment Planning At Pier (hours)
16. Remote assessment and consultation 1 1 1 0
17. On-site fire assessment 2 6 12 1
Fire Suppression
18. External firefighting teams 4 8 12 4
19. External vessel firefighting systems 4 12 18 4
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• 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.

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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.

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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
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• 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

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Activation of SMFF GSA annex

• WSMCs involvement and relations with the
  vessels qualified individual (QI)

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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

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CAPS/Dispersant Regulations

• Old regulations allowed for a credit against up
  to 25 of on water oil recovery capability IF
  vessels 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

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Coast Guard Authorization Act

• Movement of higher volume port area line from
  Port Angeles to Neah Bay

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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.

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Pre-Staged Response Equipment Locations
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Questions?