Page 18: of Maritime Reporter Magazine (March 2, 2005)

operate in the U.S. navigable waters or

EEZ are not required to identify and have available response resources to respond to spills.); (4) describes the training, equipment testing, periodic unannounced drills, and response actions by crewmembers; (5) will be updated periodically; and (6) will be resubmitted for approval of each significant change. (7) The Coast Guard intends to issue a two-year authorization letter allowing the nontank vessel to operate without an approved response plan if the plan sub- mitted meets the above detailed require- ments and is accompanied by a certifica- tion by the owner or operator that the availability of response personnel and resources has been ensured by contract or other approved means. In the event that the Coast Guard lacks sufficient time to determine whether the submitted plan meets the above detailed require- ments, the agency may issue a short- term interim authorization letter for non- tank vessels where the submitted plan appears to meet the requirements and is accompanied by the certification.

This interim authorization letter will be valid until the review process has been completed.

As the Coast Guard expects that it will take at least one month to conduct an initial review of submitted plans just to determine whether the requirements appear to have been met, owners and operators are strongly encouraged to submit their nontank vessel response plans no later than July 9, 2005. The plans should be submitted to:

Commandant (G-MOR-2)

U.S. Coast Guard 2100 Second Street, SW

Washington, DC 20593-0001

Attn: VRP Programs

The nontank vessel oil spill response plans will closely resemble those required for tank vessels. There are some differences, though. For a small vessel (fuel capacity of less than 250 barrels), the plan need only address response to the vessel's average most probable discharge (one percent of the fuel capacity) and salvage resources.

For a vessel with a fuel capacity of 250 barrels or more, the plan must also address response to the vessel's maxi- mum most probable discharge (10% of the fuel capacity) and salvage and ligh- tering resources. For a vessel with a fuel capacity of 2,500 barrels or more, the plan must address response up to the

Tier I worst case discharge volume to the maximum extent practicable and sal- vage, firefighting, and lightering.

Vessels carrying very heavy fuel oil (group V petroleum oil) as fuel will have additional planning requirements. A worse case discharge is a discharge in adverse weather conditions of a vessel's entire fuel capacity.

The nontank vessel oil spill response plan, as well as the USCG approval let- ter, must be carried on the ship and made available to the Coast Guard upon request.

The master and all crewmembers with responsibilities under the plan must be familiar with the plan. During Coast

Guard boardings, crewmembers will be subject to questioning about their spill response duties.

Expenses related to this new require- ment are not addressed in the guidance, 18 Maritime Reporter & Engineering News

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