OSRO Classification Guidelines.pdf

Guidelines for the U.S. Coast Guard Oil Spill Removal Organization

Classification Program

December 2021

United States Department of Homeland Security

United States

Coast Guard

Guidelines for the U.S. Coast Guard Oil

Spill Removal Organization Classification Program December 2021

Table of Contents

Executive Summary

CHAPTER 1. Classification Process and Requirements

A. OSRO Guidelines: A Brief History

B. Significant Revisions to the OSRO Guidelines

C. Application Process

D. Alternative Compliance

E. Alternate Classification Cities Program

F. OSRO Exercises

G. Personnel Training

H. Equipment Maintenance

I. Resource Requirements

J. Response Times

K. Status Changes in Equipment or Capabilities

L. OSRO Guidelines Biannual Review

CHAPTER 2. Preparedness Assessment Visits (PAV)

A. Introduction and Purpose

B. Roles and Responsibilities

C. Types and Frequency of Preparedness Assessment Visits

D. Preparedness Assessment Visit Process

E. Personnel Training

F. Examination of Equipment Systems and Maintenance Records

G. Preparedness Assessment Visit Equipment Criteria

H. Preparedness Assessment Visit Results

I. Other Reasons for Revoking an OSRO’s Classification

CHAPTER 3. Mechanical Classification Requirements for OSROs

A. Overview

B. Resource Requirements

C. Protective Boom

D. Oil Recovery Device Operating Environment

E. EDRC and Containment Boom

F. Temporary Storage Capacity

G. Response Vessels

H. Response Aircraft

I. MMPD and WCD Tier 1 Classification

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J. WCD Tier 2 and WCD Tier 3 Classifications

K. Dedicated vs. Non-dedicated Resources

L. Response Times

CHAPTER 4. Mechanical Classification Standards by Operating Area

A. Operating Areas

B. Adverse Weather Considerations

C. Shallow Water Requirements

D. Rivers and Canals

E. Great Lakes

F. Inland

G. Near Shore

H. Offshore

I. Open Ocean

J. Prince William Sound Classification

CHAPTER 5. OSRO Classification Dispersant Program

A. Introduction

B. Response Plan Requirements

C. Tier 1, 2, and 3 Worst Case Discharge (WCD) Classifications

D. Effective Daily Application Capacity

E. Location and Documentation of Dispersant Resources

F. Captain of the Port Zones

G. Travel Time

H. Dispersant Application Platform

I. American Society for Testing and Materials Standards

J. Aerial Oil Tracking and Application Capabilities for Dispersant Use

K. Personnel

L. Response Times and Dispersant Stockpiles

M. Estimated Dispersant System Potential Calculations

CHAPTER 6. OSRO Classification Guidelines for Nonfloating Oils

A. Overview

B. Nonfloating Oils Classification Evaluation

C. Application for Nonfloating Oils Classification

D. Nonfloating Oil Procedures and Core Equipment Standards

E. Resource Requirements

APPENDIX A. List of Acronyms

APPENDIX B. Glossary Terms

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CHAPTER 1. Classification Process and Requirements

A. OSRO Guidelines: A Brief History

1. Section 311(j) of the Federal Water Pollution Control Act (FWPCA), amended by section 4202 of the Oil Pollution Act of 1990 (OPA 90), requires the preparation and submission of response plans by the owners or operators of certain oil-handling facilities and for all vessels defined as “tank and non-tank vessels” (hereafter referred to as plan holders). Plan holders, through their response plans, must address the extremely complex system for assembling, mobilizing, and controlling response resources to maintain statutory compliance as well as being prepared to respond to oil spills within their area of operation. Plan holders are required to submit a response plan to the Coast Guard that identifies and ensures, by contract or other approved means, the availability of response resources (personnel and equipment) necessary to remove, to the maximum extent practicable, a worst case discharge (WCD), including a discharge resulting from fire or explosion, and to mitigate or prevent a substantial threat of such a discharge.

2. To relieve the burden upon the plan holders to provide extensive detailed lists of response resources, the Coast Guard created the Oil Spill Removal Organization (OSRO) classification program, administered by the National Strike Force Coordination Center (NSFCC), so that plan holders would be required to identify the OSROs only by name in their response plans, if the OSRO meets a plan holder’s planning requirements. If the OSRO is classified by the Coast Guard, then its capacity has been determined to equal or exceed the response capability caps needed by a facility, tank vessel and non-tank vessel plan holders. In addition, OSROs voluntarily participating in the classification program must maintain detailed lists of response resources in the Response Resource Inventory (RRI), which is administered by the NSFCC.

3. The RRI is the backbone of the classification system and its capabilities are two-fold: an inventory element and a classification element. The inventory element provides Federal On- Scene Coordinators (FOSCs) and contingency planners the ability to query available spill response equipment and its proximity to Coast Guard Captain of the Port (COTP) zones. The classification element, largely considered an incentive for OSROs to enter their inventories into the RRI, complements Facility Response Plan (FRP) and Vessel Response Plan (VRP) development and review processes by systematically classifying OSRO response capability up to the response capability caps.

4. Historically, the Coast Guard based OSRO classification levels upon three categories: (1) feet of containment boom; (2) temporary storage capacity (TSC); and (3) skimmer capacity, which translated into an estimated daily recovery capacity (EDRC) measured in barrels per 24-hour period. In December 1995, the guidelines added classification based upon COTPs zones and specific operating environments.

5. In June 2002, the Coast Guard modified the guidelines to include classifying OSROs in six operating areas versus four, eliminating Average Most Probable Discharge (AMPD) classifications, and incorporating Maximum Most Probable Discharge (MMPD) through WCD Tier 3. In addition, the guidelines introduced Alternate Classification Cities (ACCs) within COTP

December 2021 zones to stimulate increases in classified OSRO coverage. Further, the guidelines added time delivery parameters to calculate response times based on whether or not companies had personnel on-site 24 hours a day, capable of mobilizing and deploying equipment upon notification, and whether or not the equipment being used was owned, contracted, or obtained for company use by other approved means.

6. In 2019, the Coast Guard modified the guidelines to bring them into compliance with regulatory requirements and to eliminate exceptions and waivers which were not permissible under the existing statutes/regulations. The guidelines clarified that the alternative compliance program consistent with 33 CFR §§ 154-155 continued to remain a part of the guidelines.

7. In a collaborative process with the maritime response industry, BSEE has introduced a set of response system planning calculators which provide the Estimated Recovery System Potential (ERSP) of the response plan. The Coast Guard recognizes the value of these calculators as a planning tool, and is actively working to develop near-shore and coastal ERSP calculators to assist planholders in identifying and meeting their planning goals. Existing regulations within 33 CFR §§154, 155 mandate the use of Effective Daily Recovery Capacity (EDRC) to evaluate response equipment, and these guidelines continue to use EDRC as a key performance metric.

Although not required for classification, the Coast Guard encourages OSRO and planholders to evaluate their plan performance through multiple methods; including ERSP (where applicable).

B. Significant Revisions to the OSRO Guidelines

1. The most significant revision in this edition clarifies the intent of the contracted Temporary

Storage Capacity calculations, located in Chapter 3.F.2. Like dedicated storage, non-dedicated temporary storage may only be counted towards the classification requirements when it is available to meet response time requirements. Therefore, non-dedicated storage must be regularly operated within the COTP zone or ACC in order to meet the requirements of 3.F.2.

2. These guidelines also add a clarification in Chapter 6 covering Nonfloating Oil OSRO applications. Applicants for a Nonfloating Oil classification must maintain an equipment inventory sufficient to perform services across the full range of the operating area and operating zone sought. Classifications will not be given for partial capabilities (e.g., response capabilities only for shallow water areas <6ft). OSROs must demonstrate the capability to respond to all areas and conditions where nonfloating oil response operations may take place within that zone, and must provide an equipment inventory which demonstrates the capability to work in a variety of water depths, conditions, and bottom types.

C. Application Process

1. Any OSRO may voluntarily apply for classification by contacting the NSFCC. Participation in the

OSRO classification program is voluntary; however, once an OSRO chooses to participate in the classification program, full compliance is mandatory in order to maintain the classification.

2. The RRI website can be found at the following link:

https://cgrri.uscg.mil/logon.aspx?ReturnUrl=%2fdefault.aspx.

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3. OSROs should review the guidelines prior to applying as each classification program has specific requirements. Guidance regarding this program may be obtained from:

Commanding Officer National Strike Force Coordination Center ATTN: Response Resource Assessment Branch 1461 North Road Street, Elizabeth City, NC 27909-3241 Tel: (252) 331-6000 / Fax: (252) 331-6012 Email: D05-SMB-NSFCC-RRI@uscg.mil http://www.uscg.mil/hq/nsfweb/nsf/nsfcc/ops/ResponseSupport/RRAB/rrab.asp

4. NSFCC assigns classification based on the information supplied by each OSRO. Participation in the RRI is mandatory for an OSRO to receive classification. For an application to be accepted, an OSRO must complete all pertinent RRI data fields.

5. For a majority of the classification programs, the NSFCC utilizes the response times, discharge quantities, and equipment requirements specified in the FRP and VRP regulations and in these guidelines to determine the appropriate classification(s) for each COTP zone or ACC requested by an OSRO. For all classifications, OSROs requesting new classification should complete the initial registration and equipment entry into the RRI and provide the NSFCC with a complete response equipment inventory list. For the nonfloating oil classification, OSROs should complete the application outlined in Chapter 6 and, upon approval from the NSFCC, enter their nonfloating response equipment inventory list into

RRI.

6. Following the classification assessment by the NSFCC, the NSFCC will schedule an initial Preparedness Assessment Visit (PAV) with the applicant. The NSFCC will coordinate with the appropriate COTP and District Response Advisory Team (DRAT) to schedule the PAV.

7. An OSRO may withdraw from the participating in the classification program at any time with written notice to the NSFCC. However, in order to return to the program, the OSRO will be reevaluated through the full application process

8. The following figures depict the evaluation and review process for becoming a classified OSRO. The timelines depicted below do not begin until the NSFCC receives all necessary documentation.

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Figure 1-1: OSRO Classification Review Process

Figure 1-2: OSRO Nonfloating Oil Classification Review Process

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D. Alternative Compliance

1. Alternative Compliance Background: Previously, an OSRO was able to submit for an optional acceptable classification for EDRC, travel speed, TSC, and boom. However based on a regulatory review, the optional acceptable classification program ended. In its place, OSROs may apply for an alternative compliance if an OSRO feels that one or more of the alternative calculations allowed by regulations are applicable and necessary. OSROs shall also document if their alternative compliance request relates to an approved or pending alternative planning criteria. OSROs shall submit requests electronically or in writing to the NSFCC. OSROs or plan holders seeking alternatives for categories other than what is in Table 1-1 should use the Alternative Planning Criteria process.

Table 1-1: Acceptable Alternative Compliance and Regulatory Citations

Category

Response Plan Regulations Facility Vessels

33 CFR § 154 33 CFR § 155

EDRC

Appendix C, Section 6.3

Appendix B, Section 6.3

Travel Speed

Appendix C, Section 2.6

Appendix B, Section 2.6

TSC

Appendix C, Section 9.2

Appendix B, Section 9.2

2. Alternative Compliance Procedures:

a. Any approved alternative compliance will be valid for a maximum of three years. Six months prior to expiring, the NSFCC will notify the OSRO either to reapply for the alternative compliance or to update their resources in RRI to reflect that the alternative compliance is no longer necessary.

b. After the OSRO has sent the alternative compliance request to the NSFCC either by mail or electronically, the NSFCC will solicit input from the applicable COTP, District, Area, and Coast Guard Office of Marine Environmental Response Policy (CG-MER) prior to making an approval decision within 60 days of receiving all required documentation.

3. Estimated Daily Recovery Capacity (EDRC):

a. 33 CFR § 154 Appendix C and 33 CFR § 155 Appendix B allow OSROs to submit an alternative compliance for EDRC on behalf of plan holders via the instructions in the regulations cited in Table 1-1 of these guidelines.

b. OSROs or plan holders submitting these requests must provide the appropriate documentation requested in the regulations; including the specific tests utilized and the results for the specific class of equipment requested, or provide verified performance data from real-world operations.

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4. Vessel Speeds: For classification purposes, the regulation calculates vessel speeds using the planning speed criteria of 5 knots (kts). The speed of five kts is a conservative planning criterion which is specified in 33 CFR § 154 and § 155 and takes into account mobilization time and environmental factors. However, OSROs that demonstrate that a vessel can consistently and safely perform at speeds greater than five kts may request their classification(s) be determined using an alternative transit speed. Alternative speeds are most likely to apply to large vessels such as Oil Spill Response Vessels (OSRVs), tugboats, and barges.

a. OSROs who wish to use alternative transit speeds for water transit shall submit their alternative compliance requests electronically or in writing to the NSFCC. The requests should specify the individual vessel(s) the alternative speeds will apply to and must, at a minimum, include the following documentation:

(1) Logs and records indicating vessel speed over various routes;

(2) Charts indicating routes and distance transited; and

(3) Mobilization plan (including personnel recall numbers).

b. Upon concurrence, the NSFCC will factor in the alternative speeds when determining the OSRO's classification for the applicable vessels. If the OSRO has already received a classification, the information will be used to revise that classification.

5. Vehicle Speed: No request for alternative over-the-road speeds will be accepted. The set planning standard for over-the-road vehicles is 35 mph. The NSFCC sets this speed based on external factors such as average speed limits and traffic, so actual mechanical ability does not increase the planning standard.

6. Aircraft Speed: For classification purposes, the regulation calculates aircraft using the planning speed of 100 kts. If OSROs demonstrate an aircraft can perform at speeds greater than 100 kts safely, they can request an alternative compliance for transit speed.

a. OSROs that wish to use alternative transit speeds for air transit shall submit their requests electronically or in writing to the NSFCC. The requests should specify:

(1) Logs and records indicating aircraft speed over various routes;

(2) Confirmation that they have reviewed and are abiding by all applicable Federal Aviation Administration (FAA), state and local regulations and policies; and

(3) Charts indicating routes and distance transited.

b. Upon concurrence, the NSFCC will factor in the alternative speeds when determining the OSRO's classification for the applicable aircraft and COTP zones. If the OSRO has already received a classification, NSFCC will use the information to revise the classification.

7. Temporary Storage Capacity: 33 CFR § 154 Appendix C and 33 CFR § 155 Appendix B allow OSROs to submit an alternative compliance for TSC on behalf of plan holders via the instructions in the regulations cited in Table 1-1 of these guidelines.

E. Alternate Classification Cities Program

1. Traditionally, OSRO capability has been measured from COTP zones identified in 33 CFR §

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3.05-10 through 33 CFR § 3.85-15. Recognizing that commercial operation often occurs in ports other than the COTP zones, the Coast Guard has identified ACCs. ACCs are Coast Guard designated locations used in addition to the zone in which the COTP is located for classifying OSROs. ACCs help to alleviate the concern that, in larger COTP zones, a spill could occur at a greater distance from the COTP zone to which an OSRO could not respond within the regulatory timeframes. However, regulation requires the plan holder to calculate response times using the location the vessel operates farthest from the storage location of the OSROs response equipment. This may not be the COTP city or the ACC. It may be an area offshore.

2. The following ACCs are geographic locations within the United States that have been designated to fill coverage gaps between COTP zones:

a. Cape Fear River, NC; COTP North Carolina

b. Huntington, WV; COTP Ohio Valley

c. Paducah, KY; COTP Ohio Valley

d. Panama City, FL; COTP Mobile

e. Port Canaveral, FL; COTP Jacksonville

f. Toledo, OH; COTP Detroit

g. Cleveland, OH; COTP Buffalo

h. Oswego, NY; COTP Buffalo

i. Marquette, Ml; COTP Sault Ste. Marie

j. Traverse City, MI; COTP Sault Ste. Marie

k. Alpena, MI; COTP; Sault Ste. Marie

l. Chicago, IL; COTP Lake Michigan

m. Eureka, CA; COTP San Francisco

n. Morro Bay, CA; COTP Los Angeles/Long Beach

o. Cape Flattery, WA; COTP Puget Sound

p. Coos Bay, OR; COTP Columbia River

q. Portland, OR; COTP Columbia River

r. American Samoa; COTP Honolulu

s. Adak, AK; COTP Western Alaska

t. Kodiak, AK; COTP Western Alaska

u. Prudhoe Bay, AK; COTP Western Alaska

v. Nome, AK; COTP Western Alaska

w. Unalaska, AK; COTP Western Alaska

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x. Ketchikan, AK; COTP Southeast Alaska

y. Sitka, AK; COTP Southeast Alaska

z. Yakutat, AK; COTP Southeast Alaska

aa. Aberdeen, SD; Inland ACC

bb. Denver, CO; Inland ACC

cc. Gallup, NM; Inland ACC

dd. Lincoln, NE; Inland ACC

ee. Lubbock, TX; Inland ACC

ff. Miles City, MT; Inland ACC

gg. Missoula, MT; Inland ACC

hh. Oklahoma City, OK; Inland ACC

ii. Salt Lake City, UT; Inland ACC

jj. Saipan; COTP Guam

kk. Lewes – Lower Delaware Bay; COTP Delaware Bay

ll. Akutan; COTP Western Alaska

mm. Sand Point; COTP Western Alaska

nn. Atka-Nazan Bay; COTP Western Alaska

oo. Shemya Island – Alcan Harbor; COTP Western Alaska

pp. Buldir Pass; COTP Western Alaska

qq. Amchitka Pass; COTP Western Alaska

rr. Sanak Island; COTP Western Alaska

ss. Attu Transit Zone; COTP Western Alaska

tt. Amukta Pass; COTP Western Alaska

uu. King Cove; COTP Western Alaska

vv. Attu Island; COTP Western Alaska

ww. St. Thomas; COTP San Juan

xx. St. Croix; COTP San Juan

3. OSROs wishing to provide services for plan holders in areas where it may be appropriate to determine classification using an ACC should send all requests for ACC designations to the NSFCC. The NSFCC consults with the applicable COTP and CG-MER as they review requests and establish new ACCs.

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F. OSRO Exercises

1. Both the FRP and VRP regulations require plan holders to conduct annual equipment deployment exercises involving the OSROs listed in their response plans pursuant to 33 CFR §

154.1055 and 33 CFR § 155.1060. An OSRO who is listed as the primary response organization in a response plan and wishes to obtain and maintain a classification shall participate in, record, and maintain documentation of these completed exercises.

2. For OSROs using a combination of owned and contracted resources to meet the requirements for classification, exercises should include both categories of resources working together and integrating separate system components provided by multiple OSROs.

3. In addition to equipment deployment, exercises should include mobilization, transportation and logistics support aspects, especially as they relate to WCD Tier 1 resources.

4. While implementing plan holder exercise requirements per 33 CFR § 154.1055 and/or 33 CFR § 155.1060, 40 CFR § 300.212, or while implementing NPREP exercises, to the maximum extent practicable, OSROs are encouraged to work with plan holders, COTPs, and Area Committees to hold equipment deployment exercises in conjunction with annual spill management team and area exercises. Additionally, OSROs are encouraged to use these exercises as an opportunity to validate response strategies contained in response and contingency plans.

G. Personnel Training

1. The FRP and VRP regulations require plan holders to ensure response personnel are trained to perform their jobs in alignment with 33 CFR § 154.1050, § 155.1055, and § 155.5055. The OSRO classification program requires an OSRO to provide similar assurances. OSROs must conduct periodic training to reinforce required knowledge.

2. An OSRO should provide confirmation that it has identified the skills necessary to demonstrate in a response and show that personnel have received the proper training to perform in those areas. Training records and descriptions of the methods in which training is delivered to personnel shall be available for review. An effective response training program should include, but is not limited to, the following:

a. Actions to take in accordance with designated job responsibilities;

b. Occupational Safety and Health Administration (OSHA) requirements outlined in 29 CFR § 1910.120;

c. A clear, streamlined communication program; and

d. Training on specific response equipment identified in the OSRO application for all classification programs.

3. OSROs shall maintain training records for three years following completion of the training. All records must be available for review during a PAV.

H. Equipment Maintenance

1. An OSRO must ensure that response resources listed in its application are inspected periodically and maintained in good operating condition in accordance with the manufacturer’s recommendations, best commercial practices, and as per 33 CFR § 154.1057, § 155.1062, and §

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155.5062. This includes ancillary equipment, such as hoses, secondary pumps and trailers.

OSROs should have a clear, preventative and corrective maintenance system in place.

Furthermore, OSROs must document all inspections and maintenance and maintain the records for three years. All maintenance records must be available for review during the PAV.

I. Resource Requirements

1. The number of personnel needed to support a response depends on numerous factors. For the

OSRO classification program, the number of personnel required for a classification for each COTP zone or ACC is based on the location of resources and certain environmental and geographic factors. During the application process, through the RRI, an OSRO will identify, per the guidance contained herein, the number of personnel required to mobilize and operate the resources at each of its resource sites.

2. Each site that meets the time requirements for a classification should have its personnel requirements totaled for that classification. If the OSRO has identified sufficient personnel that meet the response time requirements and concurrently deploys and operates all equipment necessary for that level of classification, then an OSRO qualifies for the resource requirement of that specific classification.

3. Resources counted for OSRO classification can be owned or contracted and dedicated or non-dedicated. Since non-dedicated resources may not be available to respond immediately, extended notification and mobilization times are assigned to these resources. FRP and VRP regulations require plan holders to ensure the availability of response resources by contract or other approved means. OSROs must meet these same requirements for all response resources (dedicated, non-dedicated, owned and non-owned equipment and personnel) that they claim for classification purposes. The resource owner should list all contracted equipment in the RRI prior to an OSRO listing a resource as contracted.

4. OSROs shall ensure the resource information in the RRI is accurate to maintain classification and service plan holders.

5. A full and up-to-date inventory in the RRI will help COTPs and Area Committees know what response resources are available in their zones. Though not a requirement, Coast Guard requests that OSROs enter their full equipment inventory into the RRI, and not just the minimum needed for classification.

J. Response Times

1. OSROs are required to meet certain response times as per 33 CFR § 154.1045, § 154.1047, §

155.1050, § 155.1052, § 155.5050 and § 155.5052. The regulations set the response times for classification; the RRI standardizes the classification through a series of calculations. To receive a classification for a specific COTP zone or ACC, an OSRO must ensure its resources and trained personnel are able to meet the specified response times in that area.

2. Plan holders are required to use OSROs that are able to respond with resources from where they are stored to the incident location in accordance with various regulations in 33 CFR 154 and 155. The Coast Guard uses criteria in regulation to determine response times to the COTP city and ACCs when determining classification. A plan holder is then required to determine the

December 2021 response time to the facility location or vessel location farthest from the response equipment storage site when different from the COTP city or ACC.

3. The RRI computes response times for the Mechanical and Dispersant classification programs by combining the notification times, mobilization times, and travel times of the resource sites used for a specific classification. Response plan regulations require the plan holder to include the time for notification, mobilization, and travel when computing response times (33 CFR § 154 Appendix C, paragraph 2.6 and 33 CFR § 155 Appendix B, paragraph 2.6). Therefore, the time needed for a resource to move from its primary staging site to a classification point is the sum of the notification, mobilization, and travel times.

4. Mobilization is the time it takes to get the resources assembled and prepared at the staging site. Mobilization begins once notifications are complete and ends when the resources are ready to move off-site. The time to notify and mobilize resources at a site is largely based on how much control the OSRO has over those resources (i.e., dedicated, non-dedicated, owned and contracted). For this reason, different mobilization times are used for calculating OSRO classifications based on resource status (see Table 1-2 below). Using this table, an OSRO determines the notification/mobilization time for each response resource included in its application, and provides that information on the status of each response resource during the application process. Note: Full-time personnel are a dedicated resource; part-time personnel are a non-dedicated resource. On-site indicates a 24-hour staffed resource site, as opposed to personnel who have to be recalled. Also, add one half hour to response time to account for the time between the discovery of discharge and the notification to the OSRO.

Table 1-2: Resource Notification/Mobilization Response Times in Hours

Resource Status

Response Personnel Availability On-Site (OS) Recall (R)

Owned/Dedicated (O/D) 1 2

Contract or Dedicated (C/D) 1.5 2.5

Owned/Non-dedicated

(O/ND)

2.5

3.5

Contract /Non-dedicated

(C/ND)

5. Travel times are computed using standard speeds and the highway or water distance between an OSRO site and a COTP office address or coordinates of the ACC. The distance is calculated in a direct line, but it is the responsibility of the plan holder, in coordination with the OSRO, to ensure the response resources can arrive within the timelines specified in applicable regulations.

6. As previously mentioned, the regulation uses travel speeds of 35 miles per hour (mph) for land, 5 kts for water, and 100 kts for aircraft for OSRO classification calculations. The regulation divides the distance by the speed to determine the travel time using the equation below. The total response time assigned to each site is the sum of the notification time, mobilization time, and travel time to the geographic point.

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Travel Time = (Distance between OSRO Site and COTP Zone or ACC) / Travel Speed Total Response Time = Notification Time + Mobilization Time + Travel Time

K. Status Changes in Equipment or Capabilities

1. Once classified, an OSRO shall report any significant changes made to its response resources to the NSFCC and COTP within 72 hours.

a. The regulation defines “significant changes” as a reduction in the OSRO’s classified capacity by a factor of 10% or greater, for a period of 48 hours or longer.

b. Additional changes should also be updated in the RRI within 72 hours in the case of moving equipment from one site location to another site or deleting equipment that is no longer functioning that could impact classification.

2. Reductions in OSRO capabilities caused by surging of equipment into another COTP zone during a response may result in a loss of OSRO classification if it drops their capabilities below their classification threshold.

3. For changes in coverage due to planned maintenance that will exceed 48 hours, the OSRO should provide NSFCC , the appropriate COTP(s) and its plan holders using their resources, with as much advance prior notice as possible along with a description of the reduction in capability and any proposed mitigating measures.

4. The NSFCC reviews any mitigating measures submitted by an OSRO and either approves, proposes, or requests more information from the OSRO. The NSFCC, in consultation with the applicable COTP and CG-MER, determines if the OSRO needs to provide additional mitigating measures based on the amount of time the equipment is to be out of service, the expected decrease in coverage, and the areas impacted. If mitigating measures are approved, the NSFCC will coordinate notifications to affected COTPs. Any mitigating measures implemented by an OSRO should commence prior to the start of the planned gap. If the mitigating measures do not meet the requirements for classification, then the OSRO will lose its classification until it restores full coverage.

5. The RRI has a feature that notes when an OSRO site has been verified last by a user from the OSRO. This new mechanism will notify the NSFCC when an OSRO site’s inventory has not been updated or verified in the last six months. If this occurs, the NSFCC will contact the OSRO and prompt them to verify the site’s inventory.

L. OSRO Guidelines Biannual Review The NSFCC and CG-MER shall conduct a biannual review and update process of the Guidelines for the U.S. Coast Guard Oil Spill Removal Organization Classification Program.

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CHAPTER 2. Preparedness Assessment Visits (PAV)

A. Introduction and Purpose

1. PAVs are a critical component of the oil spill response preparedness system, providing on-site verification of resources and their condition.

2. NSFCC, DRAT, and COTP personnel shall collaborate with industry representatives on PAVs to ensure thorough oversight and awareness of the OSROs (and their capabilities) within their area of responsibility.

3. The PAV program encompasses various stages geared towards classifying OSROs for specific response thresholds, ensuring OSRO resources are consistent with classifications, examining equipment systems, and reviewing maintenance and training programs.

4. The Coast Guard may visit each location listed in the OSRO’s application to account for and verify all listed resources, including both owned and contracted equipment and locations.

5. The following guidance within this chapter provides OSROs with an overview of the PAV process and a basic framework of what to expect during a PAV.

B. Roles and Responsibilities

1. CG-MER serves as the program office for the OSRO classification program. CG-MER shall:

a. Provide the NSFCC with requested VRP information to include, but not limited to, which OSROs serve as resource providers for vessel plan holders, which COTP zones the vessels operate in, and any other related information;

b. Assist the NSFCC with coordinating or conducting PAVs when requested by the NSFCC, and shall attend two PAVs annually; and

c. At the beginning of every fiscal year, facilitate a PAV scheduling conference call between CG-MER, the NSFCC, and DRAT Supervisors.

2. The Commanding Officer of the NSFCC serves as the Administrator of the OSRO classification program, including all components of the PAV process. The NSFCC leads or coordinates all PAVs. In addition, the NSFCC shall:

a. Maintain a list of OSROs, their classification status (if applicable), and when they last received a PAV;

b. Annually schedule PAVs. Ensure DRATs and COTP personnel have access to the PAV schedule;

c. Schedule and coordinate spot check PAVs when requested by DRAT or COTP;

d. Notify applicable DRATs and COTP personnel to assist with application process outlined in Figures 1-1 and 1-2 of these guidelines;

e. Ensure DRATs and COTP personnel have access to RRI and other applicable PAV documentation in advance of a scheduled PAV;

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f. Notify OSROs of a scheduled PAV, or spot check PAV, and designate one point of contact for OSROs to communicate questions beforehand;

g. Complete an After Action Report (AAR) for each COTP zone or ACC, and archive and send it to CG-MER, the applicable DRAT, and COTP;

h. Brief the COTP upon completion of a PAV and assist with the identification of OSRO equipment shortfalls or issues;

i. Lead or facilitate coordination of PAV spot checks within COTP zones or ACCs; and

j. Notify CG-MER of changes to classifications based on new input and determinations from PAVs

3. The DRAT Supervisor, or their representative, shall serve as the District representative for PAVs and shall work with the FOSC, COTP personnel, National Strike Force (NSF) representatives, and other federal, state, local, and tribal stakeholders to optimize District pollution response preparedness. DRAT Supervisors (or their representative) shall:

a. Maintain a comprehensive knowledge of OSRO inventories located throughout the District;

b. Provide the District Commander and COTPs information on pollution response equipment capabilities, strategies, and operations;

c. Assist the NSFCC with PAV coordination and when operationally available, assist with the

PAV;

d. Assist the NSFCC with the COTP brief upon completion of a PAV;

e. Identify District response equipment shortfalls, including the identification of any challenges associated with cascading equipment into or within the District;

f. Coordinate with the NSFCC to schedule a spot check PAV when the DRAT/COTP determines a spot check PAV is needed; and

g. Brief results of PAV spot checks, upon completion, to the NSFCC and COTP.

4. COTPs should provide, when operationally available, representatives to assist with a PAV. Also, COTPs shall:

a. Upon request from the NSFCC or DRAT, provide the NSFCC or DRAT with required FRP information to include, but not limited to, which OSROs serve as resource providers for facility plan holders, and any other related information;

b. Notify the DRAT when a PAV spot check is deemed appropriate;

c. Provide feedback to the NSFCC and DRATs if they observe discrepancies during an actual response or exercise.

5. The NSFCC and CG-MER shall coordinate on all decisions that affect the OSRO classification program and the PAV process.

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C. Types and Frequency of Preparedness Assessment Visits

1. To clarify roles and responsibilities, the following is a list and broad overview of the types of

PAVs and expected participants:

a. Routine PAV – Participants: NSFCC (lead), DRAT, servicing NSF team and COTP personnel. A routine PAV verifies response equipment listed within RRI and the OSRO’s application for classification at the time of the visit. The Coast Guard will assess OSROs using the process outlined in Sections D through G of this chapter within the scheduled COTP zone or ACC.

(1) Frequency – An OSRO should expect one routine PAV every four years. The Coast Guard schedules these PAVs based on higher volume port areas (HVPAs), National Preparedness for Response Exercise Program (PREP) exercise schedule, high-risk geographic locations, COTP zones, Government-Initiated Unannounced Exercise (GIUE) performance, ACCs and upon specific requests from a District Commander or COTP. The COTP reserves the right to increase the frequency of PAVs or conduct PAV spot checks within their respective zone and shall coordinate directly with the NSFCC.

(2) Other Government Agency (OGA) Equipment Verifications (EVs) - Other agencies have initiated the development of their own equipment verification programs. To strengthen interagency collaboration while reducing a duplicative burden on the OSROs, the Coast Guard should coordinate with its interagency partners prior to conducting PAVs. The Bureau for Safety and Environmental Enforcement (BSEE), the U.S. Environmental Protection Agency (EPA), and the Pipeline and Hazardous Materials Safety Administration (PHMSA) have all initiated their own equipment verification programs.

b. PAV Spot Checks – Participants: NSFCC (coordinator), DRAT, servicing NSF team and COTP personnel. PAV spot checks are conducted on OSROs that participate in the program. PAV spot checks verify requirements outlined in Sections D through G of this chapter and that the equipment listed within RRI is up to date. PAV spot checks may be utilized to verify corrective action when prior OSRO system or documentation discrepancies are recorded during a past PAV, exercise, or response, or at the discretion of the COTP. PAV spots check may occur announced or unannounced.

(1) Frequency – Contact NSFCC in order to conduct a PAV spot check. At the beginning of every fiscal year, the NSFCC, CG-MER, and DRATs will meet to coordinate PAV spot checks. Once the dates for the aforementioned PAVs, verifications for alternatives, and interagency equipment verifications are finalized, the PAV spot checks will be individually scheduled between each DRAT and their COTPs when operationally feasible.

PAV spot checks are mutually (COTP/DRAT) determined based on risk, personnel availability, and feedback from COTPs concerning the requested quantity of PAV spot checks and how many OSRO sites can be assessed.

D. Preparedness Assessment Visit Process

1. Once the NSFCC or PAV team schedules the PAV for an owned and/or contracted OSRO site, the

PAV team lead will print the OSRO’s RRI data for that particular location. OSROs shall notify the PAV team lead or the NSFCC as soon as possible if unscheduled operations or other challenges may limit the scope or timing of the PAV.

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2. Prior to visiting the OSRO site, the PAV team should review the classification(s) that particular OSRO holds and the associated guidance contained within these guidelines. At the minimum, the PAV team shall complete the following process:

a. Complete a visual survey of all listed resources and operate at least 10% of listed equipment systems to ensure satisfactory condition and function to include (when applicable):

(1) Boom;

(2) Vessels;

(3) Skimmers;

(4) Vacuum systems;

(5) Product transfer pumps;

(6) Temporary storage;

(7) Dispersants;

(8) Dispersant delivery systems;

(9) Aerial oil tracking aircraft (manned or unmanned);

(10) Nonfloating oil resources (detection, recovery);

(11) Shoreline cleanup resources; and

(12) Miscellaneous OSRO equipment (e.g., salvage and marine firefighting equipment, hazardous material response equipment, oil-water separators).

b. Ensure response resources are properly maintained. Verify that a preventative and corrective maintenance system is in place. Validate maintenance-related documentation.

c. Verify the OSRO personnel listed as available and trained to mobilize, deploy, and operate the equipment.

d. Verify compliance with all Hazardous Waste Operations and Emergency Response (HAZWOPER) requirements listed in 29 CFR § 1910.120 and ensure documentation accurately reflects all listed personnel who have satisfactorily completed HAZWOPER.

e. Verify the response inventory’s operability and logistic support capability. Where applicable, review the site’s logistic narrative and determine the status of the support services listed in the narrative (e.g., equipment rentals, commercial drivers, personnel services) plus their ability to mobilize and sustain the resources.

f. Verify records of exercise participation, including AARs or lessons learned, to ensure the OSRO continues to improve operations and is rectifying previous areas of concern.

3. While the aforementioned process is the primary framework, it is not all-inclusive. The Coast Guard PAV team lead may determine a more in-depth look is required to verify a specific component in the OSRO’s operation.

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E. Personnel Training

1. The Coast Guard verifies that response personnel at the resource site are trained in accordance with HAZWOPER regulations (29 CFR § 1910.120) and other job-specific requirements (e.g., commercial driver’s license (CDL), diver certifications or merchant mariner credential) by conducting a review of personnel training records located at the OSRO site.

2. Prior to the Coast Guard’s visit, the OSRO should review personnel records and subcontracting or consulting agreements to verify the number and availability of trained personnel listed within the RRI. The OSRO should provide these records to the Coast Guard upon request.

F. Examination of Equipment Systems and Maintenance Records

1. The PAV conducts a review of the OSRO’s listed resources as required by the appropriate classification program and level. When completing the visual equipment survey, the Coast Guard will examine equipment systems from each classification category. All systems that count toward classification should be in working order and able to be deployed into the marine environment. While PAVs are not an operational equipment deployment exercise, the verification of the equipment’s ability to function properly is key. During the PAV, if an OSRO cannot account for the equipment’s proper operation (recent spill or exercise), they may be required to operate one or more systems for the PAV team. PAV team leads are encouraged to operate equipment as “systems” rather than as individual components of a system (i.e., testing compatible pumps and skimmers)

2. In addition to a physical examination of equipment systems, the PAV team will conduct a review of all applicable equipment maintenance record as required by 33 CFR § 154.1057, 33 CFR § 155.1062, and 33 CFR § 155.5062. Records should be maintained on-site at manned locations, and include the equipment maintenance history and proof of ownership, lease, or subcontract. At unmanned sites with staged equipment, the OSRO should have equipment maintenance records readily available.

G. Preparedness Assessment Visit Equipment Criteria

1. The PAV team should consider, when applicable, the following criteria (not all-inclusive):

(1) Boom:

(a) Overall condition;

(b) Evidence of ownership, lease, or subcontract;

(c) Manufacturer, type, and quantity;

(d) Compatibility of connectors;

(e) Number and adequacy of anchors;

(f) Transportability;

(g) Planned operating area(s); and

(h) Condition of shoreline cleanup boom.

(2) Recovery Devices (Skimmers and Vacuum Trucks):

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(a) Evidence of ownership, lease, or subcontract;

(b) Manufacturer, type, model, and throughput capacity;

(c) Compatibility of components (e.g., hoses, suction and skimmer head, couplings and connectors);

(d) Operability and maintenance;

(e) Condition of the prime mover and other supporting equipment;

(f) Holding capacity;

(g) Planned operating area(s); and

(h) Condition of shoreline cleanup boom.

(3) Oil Spill Response Vessels (Skimmers, Barges, and Support Craft):

(a) Evidence of ownership, lease or subcontract;

(b) Operability and maintenance;

(c) Storage capacity, shelf life and/or expiration date;

(d) Inspection/certification;

(e) Planned operating areas;

(f) Grade of oil carried;

(g) Offload capability; and

(h) Length, beam, draft, range, transit speed and crew size.

(4) Temporary Storage Devices:

(a) Evidence of ownership, lease or subcontract;

(b) Manufacturer, type and model (as applicable);

(c) Capacity (twice the daily capacity of recovery devices);

(d) Inspected and maintained in accordance with manufacturer’s recommendations;

(e) Contracted barges with current certificates;

(f) Planned operating area(s);

(g) Grade of oil carried; and

(h) Location of fixed storage.

(5) Boats:

(a) Sufficient numbers of trailers, outboard motors and Coast Guard-required safety equipment (life jackets, lights, etc.);

(b) Types and number of boats appropriate to the area of classification;

(c) Operability and maintenance;

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(d) Length, beam, draft, range, transit speed and crew size;

(e) Adequate working platform for oil spill response; and

(f) Certification/registration.

(6) Dispersants:

(a) Manufacturer, type and quantity;

(b) Volumes of dispersant(s) to support WCD tiers;

(c) Stowage;

(d) Identification of dispersant product resource provider;

(e) Primary staging site location;

(f) Distance between product’s home base and primary staging site;

(g) Amount of each stockpile required to support required effective daily application capacity (EDAC) of each dispersant application platform;

(h) Capability of commencing dispersant application operations at site of discharge within seven hours of decision by FOSC; and

(i) EDAC determination using Estimated Dispersant System Potential (EDSP) calculator.

(7) Application Platforms:

(a) Type;

(b) Providing resource organization;

(c) Distance between platform’s home base and identified primary dispersant staging site; and

(d) Dispersant payload for each dispersant application platform.

(8) Aerial Oil Tracking and Application Capabilities:

(a) Identification of resource provider;

(b) Type and location of aerial surveillance aircraft available, through contract or other approved means;

(c) At least 50% of each EDAC tier requirement must be achieved through the use of fixed-wing aircraft-based application platforms;

(d) Capability of arriving at the site of a discharge in advance of the arrival of response resources identified in the plan for WCD Tiers 1, 2 and 3 response times, and for a distance up to 50 nautical miles (NM) from shore (excluding inland areas);

(e) Capability of supporting oil spill removal operations continuously for three 10-hour operational periods during the initial 72 hours of the discharge; and

(f) Numbers of aircraft, pilots, and trained observation personnel.

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(9) Nonfloating Oil Response Resources:

(a) Evidence of ownership, lease, or subcontract;

(b) Identification of resource provider;

(c) Industry and professional certifications;

(d) Condition of detection and recovery equipment;

(e) Information management of software systems related to the detection and recovery equipment;

(f) Manufacturer, type, and model (as applicable);

(g) Operability and maintenance;

(h) Length, beam, draft, range, transit speed, and crew size;

(i) Capacity;

(j) Transportability;

(k) Primary staging site location;

(l) Inspected and maintained in accordance with manufacturer’s recommendations;

(m) Contracted barges with current certificates;

(n) Planned operating area(s); and

(o) Location of temporary/fixed storage.

(10) Groups II-IV (within inland, near shore, or offshore where preauthorization exists):

(a) Capability of commencing dispersant application operations at site of discharge within seven hours of decision by FOSC; and

(b) Capability to meet Tier 1, 2, and 3 response times for completed applications listed in Table 33 CFR § 155.1050(k).

(11) Records and Labeling:

(a) Equipment must be clearly marked for identification;

(b) Records must be available that support claims of ownership, lease, or subcontract;

(c) Complete maintenance records reflecting condition of equipment;

(d) Dispersant plans on site and updated (if applicable);

(e) Past three years of personnel training records must be made available; and

(f) Past three years of exercise records must be made available.

(12) Logistics Narrative. An OSRO shall provide a written narrative outlining the logistics requirements for each resource site listed in the RRI. Narratives need to provide enough information to document that an OSRO has the myriad and complex logistics support requirements for the mobilization and delivery of the response equipment and

December 2021 personnel from each resource site to each COTP zone or ACC requested. Narratives might contain, but are not limited to:

(a) Methods of personnel recall (if applicable);

(b) Methods of loading resources for mobilization;

(c) Methods of resource transport off-site to incident or staging;

(d) Methods of mobilizing, deploying, and supporting resources;

(e) Special response resources staging (e.g., prepackaging, palletizing, preloading); and

(f) Necessary site support services (e.g., tractors, trailers, drivers, cranes).

H. Preparedness Assessment Visit Results

1. During the PAV, the team may identify deficiencies within the OSRO’s inventory or documentation. The PAV team will identify the specific deficiencies for the OSRO and notify the NSFCC.