Salvage and Marine Firefighting Requirements Intertanko North American Panel March 21, 2011 Steven Candito President National Response Corporation (NRC)

Implementation  February 22, 2011  Tank Vessels, but not Non Tank Vessels  Dispersant requirements also implemented on February 22, 2011  Dispersant and SMFF Interim Operating Authorizations issued to August 21, 2011

Required Services  Salvage Assessment & Survey Assessment & Survey Stabilization Stabilization Emergency towing, transferring, re-floating, temporary repairs and diving support.Emergency towing, transferring, re-floating, temporary repairs and diving support. Specialized Salvage Operations Specialized Salvage Operations Subsurface product removal and heavy lift services.Subsurface product removal and heavy lift services.  Marine Firefighting Assessment & Planning Assessment & Planning Fire Suppression Fire Suppression External firefighting teams and vessel firefighting systems.External firefighting teams and vessel firefighting systems.  Primary Resource Provider (PRP) must be listed in VRP for each service, in each COTP zone of operation.

Timeframes Table (b)

Marine Firefighting Pre-Fire Plan  Outline of responsibilities and actions during a marine fire incident.  Explains Resource Provider’s role, and incident support expectations.  Coordination policies and procedures.  Copy of MFF Pre-Fire Plan goes to Resource Providers and into VRP.  Resource Provider must certify their agreement to implement MFF Pre-Fire Plan.

Drill and Exercise Requirements  VRPs must be exercised to ensure functionality.  Quarterly: Remote assessment and consultation Remote assessment and consultation Emergency procedures Emergency procedures  Annually: Shore-based salvage and shore-based marine FF management Table-Top Exercise Shore-based salvage and shore-based marine FF management Table-Top Exercise Response provider equipment deployment Response provider equipment deployment  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 Agreements  To list Resource Providers in a VRP, they must have a contract in place.  Written agreements must be submitted with the VRP. Rates for resources and services must be agreed upon to avoid delayed response. Rates for resources and services must be agreed upon to avoid delayed response.  Service Provider must ensure by contract, the ability to meet the regulatory time frames.  The Coast Guard will consider the LOF in lieu of a funding agreement with certain stipulations: LOF must be referenced throughout the agreement LOF must be referenced throughout the agreement Both parties must sign the LOF and submit it to the USCG Both parties must sign the LOF and submit it to the USCG

Integration and Coordination  SMFF providers must plan to integrate and coordinate into existing response organizations and with OSROs  Salvage Master v Unified Command  Local Public Fire Departments v Specialized Marine Fire Fighters

Example of Cooperative Success between Salvor and OSRO  July 12 th, 2007  M/T White Sea runs aground at the entrance to NY Harbor.  Vessel was loaded with 500k bbls of Crude.  Salvor requested OSRO (NRC) to source lightering barges.  NRC utilized its Marine Resource Network (MRN) to locate two barges.  All 558k bbls of Crude were transferred successfully.

Planning Criteria, Not Performance Standards  Compliance = Contracting for adequate resources, from adequate providers who can meet response timeframes.  If contracted response resources do not arrive within the regulatory time requirements, this fact does not necessarily mean the regulations were not met.

Vetting SMFF Resource Providers  History of Successful Operations  Certified and Experienced Personnel  24-hour availability of personnel and equipment  On-going and continuous training program  Record of participation in drills and exercises  Possession of tested and approved salvage or marine firefighting plans  Membership in relevant national / international organizations  Insurance covering salvage and/or marine firefighting services they intend to provide  Sufficient working capital to support an operation  Equipment and experience translate to unique geographical locations  Capability to sustain operations in long, tough conditions  Health & Safety Record  Familiarity with ACPs for each contracted COTP area  Unlike OSROs, the USCG is not “classifying” salvors.  Tank vessel owners/operators are responsible for determining the adequacy of the service providers listed in their VRPs.  Selection criteria to be followed “to the maximum extent possible,” include:

Classification vs. Owner Vetting Classification  Easy for Owner  Harder for Salvor  More Expensive Now Retainer Fees Dedicated Tugs  Less Expensive Later Risk on USCG / Salvor Owner Vetting  Easy for USCG  Harder for Owner  Less Expensive Now Free or Minimal Fees No Dedicated Tugs  More Expensive Later Risk on Owner

Temporary Waivers from Response Time Requirements  If VRP holders are unable to identify a provider who can meet a response time for a specific COTP zone…  You may submit requests for temporary waivers of specific response time requirements.  Request must include plans to correct the shortfall.

Status of Implementation  Smooth transition since Feb. 22 nd – Most work completed ahead of time.  Over 8,000 vessels and 700 VRPs affected.  As of 3/03/2011, Interim Operating Authorization (IOA) has been granted to 7,982 Tank vessels and 582 VRPs.  Majority 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 service in some cases.

Status of Implementation (Continued)  North Carolina, Alaska and Guam identified as difficult areas for emergency towing services.  SMFF service providers are confident in their ability to expand services and fix these issues.

Questions Surrounding Towing Vessel Requirements  (e) – “…towing vessels must be capable of operating in environments where the winds are up to 40 knots.”  FAQ – “Emergency towing vessels must be identified (named)…”

“Core Four” Resource Providers  Marine Response Alliance (MRA)  Resolve Marine Group (RMG)  Donjon-SMIT  T&T Bisso Response

Questions???