CALIFORNIA STATE LANDS COMMISSION CUSTOMER SERVICE MEETING JANUARY 30, 2008 AVAILABILITY OF RECEPTION FACILITIES: FACT OR FALLACY?? JOE ANGELO DEPUTY MANAGING DIRECTOR

AGENDAINTERTANKO RECEPTION FACILITY REQUIREMENTS REQUIREMENTSISSUESSOLUTIONS

INTERTANKO INTERNATIONAL ASSOCIATION OF INDEPENDENT TANKER OWNERS MEMBERSHIP 270+ MEMBERS270+ MEMBERS 2,770+ TANKERS2,770+ TANKERS 230+ MILLION DWT230+ MILLION DWT MORE THAN 80% OF INDEPENDENT TANKER FLEETMORE THAN 80% OF INDEPENDENT TANKER FLEET 300+ ASSOCIATE MEMBERS300+ ASSOCIATE MEMBERS

INTERTANKOMISSION PROVIDE LEADERSHIP TO THE TANKER INDUSTRY IN SERVING THE WORLD WITH THE SAFE, ENVIRONMENTALLY SOUND AND EFFICIENT SEABORNE TRANSPORTATION OF OIL, GAS AND CHEMICAL PRODUCTS

INTERTANKO PRIMARY GOAL LEAD THE CONTINUOUS IMPROVEMENT OF THE TANKER INDUSTRY’S PERFORMANCE IN STRIVING TO ACHIEVE THE GOALS OF: ZERO FATALITIESZERO FATALITIES ZERO POLLUTIONZERO POLLUTION ZERO DETENTIONSZERO DETENTIONS

RECEPTION FACILITY REQUIREMENTS MARPOL 73/78 ANNEXEX I, II AND V 33 CFR PART 158

ANNEX I - OIL MARPOL 73/78 ANNEX I REGULATION 38 (previously REGULATION 12) EACH PARTY UNDERTAKES TO ENSURE THE PROVISION OF RECEPTION FACILITIES AT OIL LOADING TERMINALS, REPAIR PORTS AND OTHER PORTS IN WHICH SHIPS HAVE OILY RESIDUES TO DISCHARGE, ADEQUATE TO MEET THE NEEDS OF THE SHIPS USING THEM WITHOUT CAUSING UNDUE DELAY TO SHIPS

ANNEX I - OIL RECEPTION FACILITIES SHALL BE PROVIDED IN: ALL PORTS & TERMINALS WHICH LOAD CRUDE OILALL PORTS & TERMINALS WHICH LOAD CRUDE OIL ALL PORTS & TERMINALS WHICH LOAD OIL IN BULK OTHER THAN CRUDE OIL (MORE THAN 1000 TONS)ALL PORTS & TERMINALS WHICH LOAD OIL IN BULK OTHER THAN CRUDE OIL (MORE THAN 1000 TONS) ALL PORTS WITH SHIP REPAIR YARDS OR TANK CLEANING FACILITIESALL PORTS WITH SHIP REPAIR YARDS OR TANK CLEANING FACILITIES ALL PORTS & TERMINALS HANDLING SHIPS WITH SLUDGE TANKSALL PORTS & TERMINALS HANDLING SHIPS WITH SLUDGE TANKS ALL PORTS FOR OILY BILGE WATER AND OTHER RESIDUESALL PORTS FOR OILY BILGE WATER AND OTHER RESIDUES ALL LOADING PORTS FOR BULK CARGOES FOR OIL RESIDUES FROM COMBINATION CARRIERSALL LOADING PORTS FOR BULK CARGOES FOR OIL RESIDUES FROM COMBINATION CARRIERS

ANNEX II - NLS MARPOL 73/78 ANNEX II REGULATION 18 (previously REGULATION 7) EACH PARTY UNDERTAKES TO ENSURE THE PROVISION OF RECEPTION FACILITIES ACCORDING TO THE NEEDS OF SHIPS USING ITS PORTS, TERMINALS OR REPAIR FACILITIES

ANNEX II - NLS RECEPTION FACILITIES SHALL BE PROVIDED IN: PORTS AND TERMINALS INVOLVED IN SHIPS’ CARGO HANDLING FOR THE RECEPTION OF RESIDUES AND MIXTURES CONTAINING SUCH RESIDUES RESULTING FROM COMPLIANCE WITH THE ANNEX WITHOUT UNDUE DELAY FOR THE SHIPS INVOLVEDPORTS AND TERMINALS INVOLVED IN SHIPS’ CARGO HANDLING FOR THE RECEPTION OF RESIDUES AND MIXTURES CONTAINING SUCH RESIDUES RESULTING FROM COMPLIANCE WITH THE ANNEX WITHOUT UNDUE DELAY FOR THE SHIPS INVOLVED SHIP REPAIR PORTS UNDERTAKING REPAIRS TO NOXIOUS LIQUID SUBSTANCE (NLS) TANKERSSHIP REPAIR PORTS UNDERTAKING REPAIRS TO NOXIOUS LIQUID SUBSTANCE (NLS) TANKERS CARGO UNLOADING TERMINALS SHALL PROVIDE ARRANGEMENTS TO FACILITATE STRIPPING OF CARGO TANKS OF SHIPS UNLOADING NLS

ANNEX V - GARBAGE MARPOL 73/78 ANNEX V REGULATION 7 EACH PARTY UNDERTAKES TO ENSURE THE PROVISION OF RECEPTION FACILITIES AT PORTS AND TERMINALS FOR THE RECEPTION OF GARBAGE ACCORDING TO THE NEEDS OF SHIPS USING THEM WITHOUT CAUSING UNDUE DELAY TO SHIPS

IMO ACTIVITY “INADEQUACY OF RECEPTION FACILITIES” IS A CONTINUING AGENDA ITEM FOR THE MARINE ENVIRONMENT PROTECTION COMMITTEE (MEPC)“INADEQUACY OF RECEPTION FACILITIES” IS A CONTINUING AGENDA ITEM FOR THE MARINE ENVIRONMENT PROTECTION COMMITTEE (MEPC) MEPC ADOPTS (FOR THE THIRD TIME) IN 2005 A CIRCULAR ON “REPORTING ALLEGED INADEQUATE RECEPTION FACILITIES”MEPC ADOPTS (FOR THE THIRD TIME) IN 2005 A CIRCULAR ON “REPORTING ALLEGED INADEQUATE RECEPTION FACILITIES” MEPC ALSO ADOPTS CIRCULAR ON REPORTING TO HAVE PORT STATES PROVIDE:MEPC ALSO ADOPTS CIRCULAR ON REPORTING TO HAVE PORT STATES PROVIDE: - LIST OF RECEPTION FACILITIES IN ITS PORTS; AND - PROVIDE RESULTS OF INVESTIGATIONS INTO REPORTED INADEQUATE RECEPTION FACILITIES

33 CFR 158 BASIC PRINCIPLES – A PORT OR TERMINAL THAT WANTS TO RECEIVE SHIPS MUST HAVE A RECEPTION FACILITYA PORT OR TERMINAL THAT WANTS TO RECEIVE SHIPS MUST HAVE A RECEPTION FACILITY A PORT OR TERMINAL MUST HOLD A CERTIFICATE OF ADEQUACY (COA) ISSUED BY THE USCGA PORT OR TERMINAL MUST HOLD A CERTIFICATE OF ADEQUACY (COA) ISSUED BY THE USCG NO SHIP MAY ENTER A PORT OR TERMINAL THAT DOES NOT HAVE A VALID CERTIFICATE OF ADEQUACYNO SHIP MAY ENTER A PORT OR TERMINAL THAT DOES NOT HAVE A VALID CERTIFICATE OF ADEQUACY

33 CFR 158 A PORT MEANS – (1) A GROUP OF TERMINALS THAT COMBINE TO ACT AS A UNIT AND BE CONSIDERED A PORT FOR THE PURPOSES OF THIS PART, OR (2) A PORT AUTHORITY OR OTHER ORGANIZATION THAT CHOOSES TO BE CONSIERED A PORT FOR THE PURPOSE OF THIS PART

33 CFR 158 RECEPTION FACILITY MEANS – ANYTHING CAPABLE OF RECEIVING SHIPBOARD OILY MIXTURES, NLS OR GARBAGE, INCLUDING FIXED PIPING, TANK BARGES, RAILROAD CARS, TANK TRUCKS, OTHER MOBILE FACILITES, CONTAINERS, OTHER RECEPTACLES OR ANY COMBINATION OF FIXED AND MOBILE FACILITIES

33 CFR OIL A PORT OR TERMINAL WHICH RECEIVES OCEANGOING TANKERS OR ANY OTHER OCEANGOING SHIP OF 400 GROSS TONS OR MORE, CARRYING OILY MIXTURES MUST HAVE A RECEPTION FACILITY

33 CFR 158 – OIL RECEPTION FACILITY GENERAL CRITERIA BE AVAILABLE AT THE PORT OR TERMINALBE AVAILABLE AT THE PORT OR TERMINAL HOLD NECESSARY PERMITS/LICENSESHOLD NECESSARY PERMITS/LICENSES BE CAPABLE OFBE CAPABLE OF - RECEIVING OIL MIXTURES WITHIN 24 HOURS OF NOTICE BY SHIP - COMPLETING RECEPTION OF BALLAST WATER CONTAINING OILY MIXTURES IN LESS THAN 10 HOURS - COMPLETING RECEPTION OF OTHER OILY MIXTURES IN LESS THAN 4 HOURS

33 CFR OIL RECEPTION FACILITY SPECIFIC CRITERIA FOR PORTS AND TERMINALS THAT –FOR PORTS AND TERMINALS THAT – - LOAD CRUDE OIL - LOAD MORE THAN 1,000 METRIC TONS OF OIL OTHER THAN CRUDE OIL - ARE USED EXCLUSIVELY BY NON- SELF-PROPELLED TANK BARGES SHIP REPAIR YARDSSHIP REPAIR YARDS

33 CFR OIL CRITERIA – LOADING CRUDE OIL – CAPACITY TO RECEIVE OIL RESIDUE – 10 METRIC TONSOIL RESIDUE – 10 METRIC TONS BILGE WATER – 10 METRIC TONS OR 2 METRIC TONS x DAILY VESSEL AVERAGE, WHICHEVER IS GREATERBILGE WATER – 10 METRIC TONS OR 2 METRIC TONS x DAILY VESSEL AVERAGE, WHICHEVER IS GREATER BALLAST WATER – 30% OF DWT OF LARGEST TANKER x 1 OR DAILY VESSEL AVERAGE WHICHEVER IS GREATERBALLAST WATER – 30% OF DWT OF LARGEST TANKER x 1 OR DAILY VESSEL AVERAGE WHICHEVER IS GREATER

33 CFR OIL CRITERIA – LOADING OIL OTHER THAN CRUDE OIL – CAPACITY TO RECEIVE OIL RESIDUE – 10 METRIC TONSOIL RESIDUE – 10 METRIC TONS BILGE WATER – 10 METRIC TONS OR 2 METRIC TONS x DAILY VESSEL AVERAGE, WHICHEVER IS GREATERBILGE WATER – 10 METRIC TONS OR 2 METRIC TONS x DAILY VESSEL AVERAGE, WHICHEVER IS GREATER BALLAST WATER – 30% OF DWT OF LARGEST TANKER x 1 OR DAILY VESSEL AVERAGE WHICHEVER IS GREATERBALLAST WATER – 30% OF DWT OF LARGEST TANKER x 1 OR DAILY VESSEL AVERAGE WHICHEVER IS GREATER OIL CARGO RESIDUE – 0.2% OF TOTAL CARGO CAPACITY OF LARGEST TANKER x 1 OR DAILY AVERAGE WHICHEVER IS GREATEROIL CARGO RESIDUE – 0.2% OF TOTAL CARGO CAPACITY OF LARGEST TANKER x 1 OR DAILY AVERAGE WHICHEVER IS GREATER

33 CFR OIL CRITERIA – EXCLUSIVELY BY NON-SELF PROPELLED TANK BARGES – CAPACITY TO RECEIVE OIL RESIDUE – 10 METRIC TONS OR 1 METRIC TON x DAILY VESSEL AVERAGE, WHICHEVER IS GREATEROIL RESIDUE – 10 METRIC TONS OR 1 METRIC TON x DAILY VESSEL AVERAGE, WHICHEVER IS GREATER BILGE WATER – 10 METRIC TONS OR 2 METRIC TONS x DAILY VESSEL AVERAGE, WHICHEVER IS GREATERBILGE WATER – 10 METRIC TONS OR 2 METRIC TONS x DAILY VESSEL AVERAGE, WHICHEVER IS GREATER

33 CFR OIL CRITERIA – SHIP REPAIR YARDS – CAPACITY TO RECEIVE BALLAST FROM BUNKER TANKS, WASH WATER AND RESIDUES FROM CLEANING BUNKER TANKS AND OIL RESIDUE TANKS – 8% OF BUNKER CAPACITY OF LARGEST SHIP SERVEDBALLAST FROM BUNKER TANKS, WASH WATER AND RESIDUES FROM CLEANING BUNKER TANKS AND OIL RESIDUE TANKS – 8% OF BUNKER CAPACITY OF LARGEST SHIP SERVED SOLID OIL CARGO RESIDUES – 0.1% OF DWT OF LARGEST TANKER SERVEDSOLID OIL CARGO RESIDUES – 0.1% OF DWT OF LARGEST TANKER SERVED BALLAST WATER – 1500 METRIC TONS OR 4.5% OF DWT OF LARGEST TANKER SERVEDBALLAST WATER – 1500 METRIC TONS OR 4.5% OF DWT OF LARGEST TANKER SERVED LIQUID OIL CARGO RESIDUES – 1% OF DWT OF LARGEST CRUDE OIL TANKER SERVED, 0.5% OF DWT OF LARGEST BLACK PRODUCT TANKER AND 0.2% OF DWT OF LARGEST WHITE PRODUCT TANKERLIQUID OIL CARGO RESIDUES – 1% OF DWT OF LARGEST CRUDE OIL TANKER SERVED, 0.5% OF DWT OF LARGEST BLACK PRODUCT TANKER AND 0.2% OF DWT OF LARGEST WHITE PRODUCT TANKER

33 CFR NLS A PORT OR TERMINAL WHICH RECEIVES OCEANGOING SHIPS CARRYING NOXIOUS LIQUID SUBSTANCES (NLS) MUST HAVE A RECEPTION FACILITY

33 CFR NLS RECEPTION FACILITY GENERAL CRITERIA BE AVAILABLE AT THE PORT OR TERMINALBE AVAILABLE AT THE PORT OR TERMINAL HOLD NECESSARY PERMITS/LICENSESHOLD NECESSARY PERMITS/LICENSES BE CAPABLE OFBE CAPABLE OF - RECEIVING NLS RESIDUES WITHIN 24 HOURS OF NOTICE BY SHIP - COMPLETING TRANSFER OF NLS RESIDUES WITHIN 10 HOURS

33 CFR NLS RECEPTION FACILITY SPECIFIC CRITERIA – CAPABLE OF RECEIVING EACH DAY FOR PORTS AND TERMINALS –FOR PORTS AND TERMINALS – - 75 CUBIC METERS OF NLS RESIDUE FOR EACH SOLIDIFYING CAT A NLS - 50 CUBIC METERS OF NLS RESIDUE FOR EACH SOLIDIFYING CAT B NLS SHIP REPAIR YARDS –SHIP REPAIR YARDS – - 75 CUBIC METERS OF NLS RESIDUE FOR EACH SOLIDIFYING CAT A NLS - 50 CUBIC METERS OF NLS RESIDUE FOR EACH CAT A (NONSOLIDIFYING), CAT B, CAT C AND CAT D NLS

33 CFR NLS PORTS AND TERMINALS EQUIPMENT BE CAPABLE OF RECEIVING CAT B OR CAT C NLS CARGO DURING STRIPPING OPERATIONS AT A FLOW RATE OF 6 CUBIC METERS PER HOUR WITHOUT THE BACK PRESSURE AT THE SHIP’S MANIFOLD EXCEEDING 14.7 POUNDS PER SQUARE INCHBE CAPABLE OF RECEIVING CAT B OR CAT C NLS CARGO DURING STRIPPING OPERATIONS AT A FLOW RATE OF 6 CUBIC METERS PER HOUR WITHOUT THE BACK PRESSURE AT THE SHIP’S MANIFOLD EXCEEDING 14.7 POUNDS PER SQUARE INCH AN INSTRUCTION MANUAL THAT LISTS THE EQUIPMENT AND PROCEDURES TO MEET THE ABOVEAN INSTRUCTION MANUAL THAT LISTS THE EQUIPMENT AND PROCEDURES TO MEET THE ABOVE

33 CFR GARBAGE ALL PORTS OR TERMINALS UNDER THE JURISDICTION OF THE UNITED STATES MUST HAVE A RECEPTION FACILITY

33 CFR GARBAGE RECEPTION FACILITY GENERAL CRITERIA HOLD NECESSARY PERMITS/LICENSESHOLD NECESSARY PERMITS/LICENSES BE CONVENIENTLY LOCATEDBE CONVENIENTLY LOCATED BE SITUATED SO GARBAGE CANNOT READILY ENTER THE WATERBE SITUATED SO GARBAGE CANNOT READILY ENTER THE WATER BE ARRANGED SO IT DOES NOT INTERFERE WITH PORT OR TERMINAL OPERATIONSBE ARRANGED SO IT DOES NOT INTERFERE WITH PORT OR TERMINAL OPERATIONS BE CAPABLE OFBE CAPABLE OF - RECEIVING APHIS REGULATED GARBAGE WITHIN 24 HOURS OF NOTICE BY SHIP - MEDICAL OR HAZARDOUS WASTES AS DEFINED IN 40 CFR (WITH EXCEPTION)

33 CFR GARBAGE RECEPTION FACILITY SPECIFIC CRITERIA - CAPABLE OF RECEIVING EACH DAY FOR PORTS AND TERMINALS, ALL GARBAGE THAT THE MASTER OR PERSON WHO IS IN CHARGE OF THE SHIP DESIRES TO DISCHARGE EXCEPT – LARGE QUANTITIES OF SPOILED OR DAMAGED CARGOES NOT USUALLY DISCHARGED BY A SHIP, ORLARGE QUANTITIES OF SPOILED OR DAMAGED CARGOES NOT USUALLY DISCHARGED BY A SHIP, OR GARBAGE FROM SHIPS NOT HAVING COMMERCIAL TRANSACTIONS WITH THAT PORT OR TERMINALGARBAGE FROM SHIPS NOT HAVING COMMERCIAL TRANSACTIONS WITH THAT PORT OR TERMINAL

33CFR 158 REPORTING INADEQUATE RECEPTION FACILITIES ANY PERSON MAY REPORT TO THE LOCAL COAST GUARD COTP THAT RECEPTION FACILITIES ARE INADEQUATE

33 CFR 158 USCG REGULATIONS ARE COMPREHENSIVE PROVIDE FLEXIBILITY CLEARLY STIPULATE CRITERIA CONTAIN ENFORCEMENT PROVISIONS ENCOURAGE FEEDBACK

ISSUES USCG HAS NO DIRECT AUTHORITY TO REQUIRE RECEPTION FACILITIESUSCG HAS NO DIRECT AUTHORITY TO REQUIRE RECEPTION FACILITIES USCG ONLY HAS AUTHORITY TO CERTIFY THEIR ADEQUACYUSCG ONLY HAS AUTHORITY TO CERTIFY THEIR ADEQUACY USCG “WILL RELY ON MARKET FORCES TO KEEP RECEPTION FACILITY USAGE REASONABLE”USCG “WILL RELY ON MARKET FORCES TO KEEP RECEPTION FACILITY USAGE REASONABLE” RECEPTON FACILITY COA REMAINS VALID UNTIL SUSPENDED OR REVOKEDRECEPTON FACILITY COA REMAINS VALID UNTIL SUSPENDED OR REVOKED

ISSUES LATE 1980’s AND 1990’s USCG RECEIVES SPORADIC REPORTS OF “INADEQUATE RECEPTION FACILITIES” THROUGH REPORTS SUBMITTED TO IMO MAIN COMPLAINTS TOO EXPENSIVETOO EXPENSIVE UNDUE DELAYUNDUE DELAY FOR ABOUT 20 YEARS USCG GIVES REPORTS OF INADEQUATE RECEPTION FACILITIES LOW PRIORITY

ISSUES IN THE 2000’s TWO MAJOR ISSUES SIGNIFICANTLY ALTERED THE PLAYING FIELD – US DEPARTMENT OF JUSTICE CRIMINAL PROSECUTION OF SHIP POLLUTION INCIDENTSUS DEPARTMENT OF JUSTICE CRIMINAL PROSECUTION OF SHIP POLLUTION INCIDENTS MARITIME SECURITY REGULATIONSMARITIME SECURITY REGULATIONS

ISSUESINTERTANKO AND OTHERS BEGIN A MORE AND OTHERS BEGIN A MORE FOCUSED CAMPAIGN TO BRING FOCUSED CAMPAIGN TO BRING THE PROBLEMS WITH THE AVAILABILITY OF RECEPTION FACILITIES IN US PORTS THE PROBLEMS WITH THE AVAILABILITY OF RECEPTION FACILITIES IN US PORTS TO THE ATTENTION OF THE USCG

ISSUES MAIN PROBLEMS INCLUDE – CERTIFIED RECEPTION FACILITIES UNWILLING TO RECEIVE WASTES (DISCHARGES PROHIBITTED)CERTIFIED RECEPTION FACILITIES UNWILLING TO RECEIVE WASTES (DISCHARGES PROHIBITTED) SEVERE RESTRICTIONS ON WHEN, WHERE OR HOW THEY WOULD RECEIVE WASTES (UNDUE DELAY)SEVERE RESTRICTIONS ON WHEN, WHERE OR HOW THEY WOULD RECEIVE WASTES (UNDUE DELAY) INADEQUATE CAPACITYINADEQUATE CAPACITY EXCESSIVE COSTSEXCESSIVE COSTS TECHNICAL DIFFICULTIESTECHNICAL DIFFICULTIES

SOLUTIONS UNDER THE LEADERSHIP OF RADM CRAIG BONE (ASSISTANT COMDT FOR PREVENTION IN DC) USCG RESPONDS – FIELD COTPS DIRECTED TO:FIELD COTPS DIRECTED TO: - ENSURE COMPLIANCE WITH COA DURING FACILITY EXAMS - EXAMINE DECLARATIONS OF INSPECTION - EXAMINE WASTE STREAM LOGS (REQUIRED UNDER RCRA)

SOLUTIONS CERTIFED RECEPTION FACILITY INFORMATION PUT ON INTERNET: RECEPTION FACILITY INFORMATION PUT ON INTERNET: RE-ISSUING COAs WITH 5 YEAR VALIDITY PERIOD AFTER EXAMRE-ISSUING COAs WITH 5 YEAR VALIDITY PERIOD AFTER EXAM UNDER INTERTANKO/USCG PARTNERSHIP, DEVELOP STANDARD FORMAT FOR REPORTING INADEQUATE RECEPTION FACILITIESUNDER INTERTANKO/USCG PARTNERSHIP, DEVELOP STANDARD FORMAT FOR REPORTING INADEQUATE RECEPTION FACILITIES

SOLUTIONS MARTINEZ RICHMOND MARTINEZ RICHMOND PACIFIC ATLANTIC TERMINALBAY MARINE BOATWORKS SHELL OIL REFINERYBP LUBRICANTS TESORO REFINING (AMORCO)CALIFORNIA OILS TESORO REFINING (AVON)CHEVRON LONG WHARF BENICIACONOCOPHILLIPS BENICIACONOCOPHILLIPS BENECIA PORT TERMINALIMTT VALERO REFININGLEVIN TERMINAL PITTSBURGNATIONAL GYPSUM PITTSBURGNATIONAL GYPSUM DOW CHEMICALPACIFIC ATLANTIC TERMINAL KOCH CARBONSSA TERMINAL VALERO REFININGTRANSLOGIX LLC USS POSCO (?)

SOLUTIONS REPORTING INADEQUATE RECEPTION FACILITIES USCG STRONGLY RECOMMENDS THAT AN INADEQUATE RECEPTION FACILITY SHOULD BE REPORTED IMMEDIATELY TO LOCAL COTP (33 CFR ) TO CONDUCT AN INVESTIGATION ASAPUSCG STRONGLY RECOMMENDS THAT AN INADEQUATE RECEPTION FACILITY SHOULD BE REPORTED IMMEDIATELY TO LOCAL COTP (33 CFR ) TO CONDUCT AN INVESTIGATION ASAP IF NOT POSSIBLE OR PREFERRED, USE INTERTANKO FORMAT FOR SUBMITTAL TO USCG HEADQUARTERSIF NOT POSSIBLE OR PREFERRED, USE INTERTANKO FORMAT FOR SUBMITTAL TO USCG HEADQUARTERS

SOLUTIONS RECOMMENDED PROCESS – CHECK USCG WEB SITE TO DETERMINE IF FACILITY HAS COACHECK USCG WEB SITE TO DETERMINE IF FACILITY HAS COA CONTACT FACILITY TO DISCUSS DISCHARGE OF WASTESCONTACT FACILITY TO DISCUSS DISCHARGE OF WASTES IF PROBLEM ARISES, CONTACT COTPIF PROBLEM ARISES, CONTACT COTP IF PREFERRED, SUBMIT COMPLETED FORM TO INTERTANKOIF PREFERRED, SUBMIT COMPLETED FORM TO INTERTANKO FORM IS SUBMITTED TO USCG HDQTSFORM IS SUBMITTED TO USCG HDQTS REVIEWED AND, IF APPROPRIATE, FORWARDED TO FIELD OFFICE FOR INVESTIGATIONREVIEWED AND, IF APPROPRIATE, FORWARDED TO FIELD OFFICE FOR INVESTIGATION

SOLUTIONS RESULTS THUS FAR – 12 CASES OF REPORTED INADEQUATE RECEPTION FACILITIES12 CASES OF REPORTED INADEQUATE RECEPTION FACILITIES 8 CASES PROVIDED SUFFICIENT INFORMATION FOR USCG TO CONDUCT FOLLOW-UP INVESTIGATION8 CASES PROVIDED SUFFICIENT INFORMATION FOR USCG TO CONDUCT FOLLOW-UP INVESTIGATION 2 INVESTIGATIONS RESULTED IN USCG TAKING ADMINISTRATIVE ACTION IN THE FORM OF A LETTER OF WARNING2 INVESTIGATIONS RESULTED IN USCG TAKING ADMINISTRATIVE ACTION IN THE FORM OF A LETTER OF WARNING

CONCLUSIONS USCG REGS ARE COMPREHENSIVEUSCG REGS ARE COMPREHENSIVE USCG ENFORCEMENT WAS LAX, BUT THAT HAS CHANGEDUSCG ENFORCEMENT WAS LAX, BUT THAT HAS CHANGED MANY TANKER OPERATORS ARE RELUCTANT TO REPORT ON CHARTERER TERMINALSMANY TANKER OPERATORS ARE RELUCTANT TO REPORT ON CHARTERER TERMINALS INTERTANKO FORMAT PROVIDES VEHICLE TO REPORTINTERTANKO FORMAT PROVIDES VEHICLE TO REPORT REPORTING CAN MAKE A DIFFERENCEREPORTING CAN MAKE A DIFFERENCE

CONCLUSIONS ADEQUACY OF RECEPTION FACILITIES RECEPTION FACILITIES IN THE UNITED STATES IN THE UNITED STATES IS NOT A FALLACY IS NOT A FALLACY BUT IT IS BUT IT IS NOT YET A FACT NOT YET A FACT IN ALL US PORTS IN ALL US PORTS