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

Salvors : Partners in OPA 90 Compliance & More Lindsay Malen Director, Business Development NAMEPA: Posidonia 2014

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

Marine Response Alliance • 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 of need!

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 18 hrs 24 hrs Transfer Operations Emergency Lightering 18 hrs 24 hrs Other Refloating 18 hrs 24 hrs Methods Temporary Repairs 18 hrs 24 hrs Diving Services 18 hrs 24 hrs Support

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

Non-Tank Final Rules: • 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: www.reginfo.gov Vessels not carrying specific grades of oil as cargo, that carry over 250 barrels of oil as propulsion fuel • 15 Criteria set forth by the USCG

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?

Activation! • 40 hours until the VRP was finally activated. • MRA was contracted by Vessel’s SMFF provider http://www.cleangulf.org/files/2013/02/ For-Clients_Prospectus.p • After activation two McAllister towing vessels were on scene shortly with a salvage master’s supervision she was successfully refloated and returned to owners

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