Salvors : Partners in OPA 90 Compliance & More Lindsay Malen - - PowerPoint PPT Presentation

NAMEPA: Posidonia 2014 Salvors : Partners in OPA 90 Compliance & More

Lindsay Malen Director, Business Development

TITAN Salvage

• Founded in 1980 by David Parrot
• Acquired by Crowley Maritime in 2005
• One of the very few organizations in the world

doing marine salvage, emergency response and wreck removal as its core business

• Member of the International Salvage Union

(ISU) and the American Salvage Association (ASA)

• Depots in the US, UK, Singapore, Australia, &

UAE

• Formed in 1994 Marine Response Alliance (MRA), meets or exceeds all

current and proposed criteria set forth by the USCG for all SMFF Vessel Response Plans

• Strategically placed member owned equipment for coverage of USCG

COPT Zones

• With our Partners we are a premier SMFF provider, OPA 90 compliance

is our core business

• Individually and collectively we are there for our owners in their times
• f need!

Marine Response Alliance

OPA 90 Tank Final Rules:

Being enforced since 2011 “The authority for implementing these regulations is delegated to COTPs and their representatives. Salvage and Marine FireFighting response networks have been put in place. Shipowners have entered contracts, with funding agreements, for response to be available within timeframes (constantly audited). Coast Guard leadership is needed to monitor substantial threats of pollution and reinforce when SMFF responses are needed.”

USCG COTP Zones

SMFF Response Timeframes

Salvage CONUS OCONUS Emergency Towing 12 hrs 18 hrs Salvage Plan 16 hrs 22 hrs External Emergency Transfer Operations 18 hrs 24 hrs Emergency Lightering 18 hrs 24 hrs Other Refloating Methods 18 hrs 24 hrs Temporary Repairs 18 hrs 24 hrs Diving Services Support 18 hrs 24 hrs

SMFF Response Timeframes

Marine Firefighting At Pier CONUS OCONUS Remote Assessment 1 hrs 1 hrs 1 hrs On-site fire assessment 2 hrs 6 hrs 12 hrs External firefighting teams 4 hrs 8 hrs 12 hrs External vessel firefighting systems 4 hrs 12 hrs 18 hrs

• As per USCG NTVRP final rules were published enforced 1-30-14
• Look the same as Tank Regs; Require Funding Agreement with a

USCG approved Salvage Marine Fire Fighting (SMFF) provider

• Non-Tank vessels are defined as:

Vessels not carrying specific grades

• f oil as cargo, that carry over

250 barrels of oil as propulsion fuel

• 15 Criteria set forth by the USCG

Non-Tank Final Rules:

www.reginfo.gov

What have we seen since Feb-2011

• A hand full of OPA 90 cases amongst 5 SMFF providers
• The Tank Regulations were a test drive
• What is the punishment for not activating your VRP correctly?
• Enforcement is beginning…

When to activate VRP

• USCG NVIC 2-10 – Guidance for Implementation and Enforcement of

SMFF Regulations for VRPs:

• “The response plan is activated once the Master has determined that the

resources and personnel available on board cannot meet the needs of an actual or potential incident.”

No cost to put your SMFF on notice!

NOTIFICATION I

• Loaded Bulker
• Non-Tank
• Grounding
• Mile 153, Lower Mississippi River
• Donaldsonville, LA
• USCG District 8: New Orleans

NOTIFICATION I

• MRA Notified of “potential activation” at 0630
• Vessel free by 0915
• Plan Not Activated, QI provided notice of potential activation
• Response plans were activated
• Response assets on standby
• WELL DONE CAPT!

ACTIVATION

• Loaded Tank Ship
• Lost Drums of Metal Cleaner

Overboard

• Drums being delivered to vessel:

NOT PETROLEUM NOT CARGO

• At Terminal
• USCG District 8 – Houston-

Galveston

• Lost at 1730
• 2 Floating – 1 Sank

• Plan activated 2245
• MRA as SMFF required to write a USCG

approved Salvage plan

• Drum recovered less than 18 Hours after

activation This was not the case…

Activation??????

• A bulk carrier was hard

aground parallel to popular tourist beach

• Multiple refloat attempts

by Capt not successful

• What is the compliant

thing to do?

http://www.cleangulf.org/files/2013/02/ For-Clients_Prospectus.p

• 40 hours until the VRP

was finally activated.

• MRA was contracted by

Vessel’s SMFF provider

• After activation two

McAllister towing vessels were on scene shortly with a salvage master’s supervision she was successfully refloated and returned to owners

Activation!

Lessons Learned:

• Do not be afraid to activate your VRP, it is a requirement, much worse can happen

to you if you do not activate your VRP

• This is a common instance so work with your partners in compliance to determine

what is the right way to handle – SMFF, QI, USCG Do not let this be the result!

Drill Requirements

• 1. Remote Assessment and Consultation Exercise

Schedule: Quarterly

• 2. Emergency Procedures Exercise

Schedule: Quarterly

• 3. Shore-Based Salvage Management Team TTX

Schedule: Annually

• 4. Shore-Based Marine FF Management team TTX

Schedule: Annually

• 5. Response Provider Equipment Deployment Exercise

Schedule: Annually

• 6. Exercise of the Entire Response Plan

Schedule: Triannually

Salvors are your Partners In Preparedness

• Drills and exercises are

very useful tools for QI’s, ship owners, and salvors

• Many situations that we

have seen on paper in drills have happened in real life

• This kind of proactive

approach to large scale scenario drills will create better performance and response from all sides

For More Information Contact

Lindsay Malen Director, Business Development LM@MarineResponseAlliance.com Samina Sadaf Mahmood Manager, Marine Response Alliance SM@MarineResponseAlliance.com 24hr Emergency Call Line +1 206 332 8200 Office +1 954 545 7872 MRA@MarineResponseAlliance.com www.MarineResponseAlliance.com