FACILITY RESPONSE PLAN REVIEW CHECKLIST

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1 FACILITY RESPONSE PLAN REVIEW CHECKLIST Fixed / Mobile Facility Name: Facility ID: 1 st Reviewer: Date: 2 nd Reviewer: Date: Guidance for completing the Facility Response Plan Review Checklist for Fixed or Mobile Facilities. Coast Guard facility inspectors shall complete the checklist by verifying the contents within are in line with the requirements as per 33 CFR 154 (Note updates to removal equipment requirements/alternative technology per 74 FR 167 / 31 Aug 2009 / Pg ). Each inspected item contained in the checklist must be notated as one of the following: YES Item meets requirements of this checklist and referenced regulations. NO Item does not meet requirements of this checklist and referenced regulations or is missing altogether. Page # - Optional (Denotes Page or Section Number in Facility s Response Plan)

2 Purpose The purpose of a facility response plan is to enhance the preparedness of the owner/operator and facility personnel to respond to an actual or threatened discharge of oil. The key elements in effective preparedness are properly trained personnel, prearranged private response resources, and a plan for timely and efficient activation and employment of equipment and personnel. With this purpose in mind, comment on the plan s overall effectiveness, workability and organization for ease of use toward the goal of enhancing preparedness Applicability Verify MTR Facility is: Fixed Mobile Verify MTR Facility classification is: Substantial Harm Significant & Substantial Harm & 108 Alternatives / Exemptions Verify if there are any alternatives /exemptions granted for the MTR facility under this plan. (Note: If any have been granted, revisions must be reflected in the plan. Indicate here the type of and whether the required amendments have been made to the plan) General Response Plan Contents Y N Page # Comments (a) Verify the plan is written in English (b) Verify the response plan is divided into the sections listed and formatted in order specified or contains a cross-referenced index page. Plan must have a marker identifying each of the following below: (b)(1) (b)(2) (b)(2)(i) (b)(2)(ii) (b)(2)(iii) (b)(2)(iv) (b)(2)(v) (b)(3) (b)(3)(i) (b)(3)(ii) (b)(4) (b)(5) (b)(5)(i) (b)(5)(ii) (b)(5)(iii) (b)(5)(iv) (b)(5)(v) (b)(5)(vi) (b)(5)(vii) (c) Introduction and plan contents Emergency response action plan: Notification procedures Facility s spill mitigation procedures Facility s response activities Fish and wildlife and sensitive environments Disposal plan Training and Exercises: Training procedures Exercise procedures Plan review and update procedures Appendices: Facility-specific information List of contacts Equipment lists and records Communications plan Site-specific safety and health plan List of acronyms and definitions A geographic-specific appendix for each zone in which a mobile facility operates Verify required contents for each section and subsection of the plan are contained in ,.1040, and.1041, as appropriate 2

3 General Response Plan Contents (con t) Y N Page # Comments (d) Verify response plans submitted to COTP must contain at a minimum, all information required in , 1040, and 1041, as appropriate. Note: Plan may contain additional information required by outside agencies (e) Verify that for initial and subsequent submission, if plan does not follow format specified in paragraph (b) of this section, must be supplemented with a detailed cross reference section to identify the location of the applicable sections required by this subpart (f) Verify response plan information consistent with NCP (40 CFR 300) and ACP covering that area. Owners or operators shall ensure plans are IAW the ACP in effect 6 months prior to initial submission or annual plan review required under (a). Facility O/OP s are not required to, but may at their option, conform to an ACP which is less than 6 months old at the time of plan submission Significant & Substantial Harm Facilities (S&SH) (a) Verify the introduction and plan content includes: (a)(1) Facility s name, full street address (& mailing address-if different), telephone/fax numbers (a)(2) Facility s geographic location; such as river mile or location from a known landmark that would appear on a map or chart (a)(3) The name, address, and procedures for contacting the facility s owner or operator on a 24-hour basis (a)(4) (a)(5) (a)(6) A table of contents During the period that the submitted plan does not have to conform to the format contained in this subpart, a cross-index, if appropriate A record of change(s) (b) Verify the Emergency Response Action Plan content includes the following: (b)(1) Notification procedures: (b)(1)(i) Contains a prioritized list identifying persons including name, phone number (unless listed elsewhere), and role in plan who must be notified of a discharge or substantial threat of discharge of oil. This section must include: (b)(1)(i)(a) Facility response personnel, the spill management team, Oil Spill Removal Organizations (OSRO s), QI(s) /AQI(s); and (b)(1)(i)(b) Federal, State, or local agencies, as required (b)(1)(ii) Notification form similar to one shown in Fig. 1- Information on Discharge of Form must include notification of the NRC. It must also contain prominent statement that initial notification must not be delayed pending collection of all information 3

4 (b)(2) Facilities spill mitigation procedures: (b)(2)(i) Describe volume(s) and oil groups (persistent / nonpersistent) that would be involved in the: (b)(2)(i)(a) Average most probable discharge from the MTR facility (b)(2)(i)(b) Maximum most probable discharge from the MTR facility (b)(2)(i)(c) Worst Case Discharge from the MTR facility; and (b)(2)(i)(d) If applicable, worst case discharge from the non-mtr portion of facility (b)(2)(ii) Prioritized procedures for facility personnel by job title to mitigate or prevent a spill resulting from operational activities associated with internal or external facility transfers including procedures to shut down affected operations in event of: (b)(2)(ii)(a) Failure of manifold, mechanical loading arm, other transfer equipment on hoses as appropriate (b)(2)(ii)(b) Tank overfill (b)(2)(ii)(c) Tank failure (b)(2)(ii)(d) Piping rupture (b)(2)(ii)(e) Piping leak bother under pressure and not under pressure, if applicable (b)(2)(ii)(f) (b)(2)(ii)(g) (b)(2)(iii) (b)(3) (b)(3)(i) (b)(3)(ii) (b)(3)(iii) (b)(3)(iii)(a) (b)(3)(iii)(b) (b)(3)(iii)(c) (b)(3)(iii)(d) (b)(3)(iii)(e) (b)(3)(iii)(f) (b)(3)(iii)(g) (b)(3)(iii)(g) (b)(3)(iv) Explosion or fire Equipment failure (e.g. pumping system or relief valve failure, or failure of other equipment associated with internal or external transfers) List of equipment and responsibilities of facility personnel to mitigate an average most probable discharge Facilities response activities: Description of facility personnel s responsibilities to initiate and supervise a response pending arrival of QI or AQI Description of the responsibilities and authority of the QI and AQI as required in Identify personnel who will manage response actions and provide a description of duties for the following positions: Command and Control Public Information Safety Liaison with government agencies Spill Operations Planning Logistics support Finance This subsection of the plan must identify the oil spill removal organization (OSRO) and the spill management team (SMT) that are capable of providing the following resources: 4

5 (b)(3)(iv)(a) Equipment and supplies to meet the requirements of , or subparts H or I of this part, as appropriate (b)(3)(iv)(b) Trained personnel to operate equipment and staff the OSRO and SMT for seven days (b)(3)(v) This section must include job descriptions for each SMT member within the organizational structure described in paragraph (b)(3)(iii) of this section. These job descriptions include the responsibilities and duties of each SMT member in a response action. (b)(3)(vi) For facilities that handle, store, or transport group II through group IV petroleum oils, and that operate in waters where dispersant use is pre-authorized, this subsection of the plan must also separately list the resource providers and specific resources, including appropriately trained dispersant-application personnel. Must be available by contract or other approved means as described in (a). Must include the following: (b)(3)(vi)(a) Identification of each primary dispersant staging site to be used by each dispersant-application platform to meet the requirements of this subpart (b)(3)(vi)(b) Identification of platform type, resource-providing organization, location, and dispersant payload of reach dispersant-application platform identified. Location data must identify the distance between the platform s home base and the identified primary dispersant staging site for this section (b)(3)(vi)(c) For each unit of dispersant stockpile required to support the effective daily application capacity (EDAC) of each dispersant-application platform necessary to sustain each intended response tier of operation, identify the dispersant product resource provider, location, and volume. Location data must include the stockpile s distance to the primary staging sites where the stockpile would be loaded onto the corresponding platforms (b)(3)(vi)(d) If an OSRO has been evaluated by the USCG, and its capability is equal to or exceeds the response capability needed by the owner or operator, the section may identify only the OSRO, and not the information required in paragraphs (b)(3)(vi)(a) (C) of this section (b)(3)(vii) This subsection must separately list the resource providers and specific resources necessary to provide aerial oil tracking capabilities. The oil tracking resources to be listed must include the following: (b)(3)(vii)(a) Identification of the source provider; and (b)(3)(vii)(b) Type and location of aerial surveillance aircraft that are ensured available, through contract or other approved means, to meet the oil tracking requirements of (j) 5

6 (b)(3)(viii) For Mobile facilities that operate in more than one COTP zone, the plan must identify the OSRO and the SMT in the applicable geographic-specific appendix. The OSRO(s) and the SMT discussed in paragraph (b)(3)(iv) of this section must be included for each COTP zone in which the facility will handle, store, or transport oil in bulk (b)(4) (b)(4)(i) (b)(4)(ii) (b)(4)(ii)(a) (b)(4)(ii)(b) (b)(4)(ii)(c) (b)(4)(iii) (b)(5) (c) (c)(1) (c)(2) (d) (e) (e)(1) Fish and Wildlife and Sensitive Environments Identify areas of economic importance and environmental sensitivity, as identified in the ACP, which are potentially impacted by a WCD. For a worst case discharge, the plan must: List areas of economic and environmental sensitivity which may potentially be impacted by discharge of persistent, non-persistent, or non-petroleum oils Describe the specific planned response actions to protect identified areas Contain a map or chart (with legend) showing the locations of sensitive areas which may potentially be impacted. Must also depict response actions, which will be used to protect these areas For a WCD, this section must identify appropriate equipment and required personnel, available by contract or other approved means as described in , to protect fish and wildlife and sensitive environments which fall within the distances calculated using the methods outlined in this paragraph Disposal Plan - This subsection must describe any actions to be taken or procedures to be used to ensure that all recovered oil and oil contaminated debris produced as a result of any discharge are disposed according to Federal, state, or local requirements Training and Exercises - This section must be divided into the following two subsections: Training procedures Describes the training procedures and programs of the facility owner or operator to meet the requirements in Exercise procedures Describes the exercise program to be carried out by the facility owner or operator to meet the requirements of Plan review and update procedures This section must address the procedures to be followed by the facility owner or operator to meet the requirements of and the procedures to be followed for any post-discharge review of the plan to evaluate and validate its effectiveness Appendices This section of response plan must include the appendices described in this paragraph Facility specific information Must contain a description of the facility s principal characteristics: 6

(e)(1)(i) A physical description of the facility including a plan of the facility showing the mooring area, transfer locations, control stations, locations of safety equipment, and the location and

7 (e)(1)(i) A physical description of the facility including a plan of the facility showing the mooring area, transfer locations, control stations, locations of safety equipment, and the location and capacity of all piping and storage tanks (e)(1)(ii) Identify the sizes, types, and number of vessels that the facility can transfer oil to or from simultaneously (e)(1)(iii) Identify the first valve(s) on facility piping separating the MTR portion from the non-mtr portion of the facility, if any. (e)(1)(iv) Information on the oil(s) and hazardous material handled, stored, or transported at the facility in bulk. A material safety data sheet (MSDS) meeting requirements of 29 CFR , 33 CFR (a)(5) or an equivalent will meet this requirement. This information can be maintained separately providing it is readily available and the appendix identifies its location. This information must include-- (e)(1)(iv)(a) Generic or chemical name (e)(1)(iv)(b) Description of the appearance and odor (e)(1)(iv)(c) Physical and chemical characteristics (e)(1)(iv)(d) Hazards involved in handling the oil(s) and hazardous materials (e)(1)(iv)(e) List of firefighting procedures and extinguishing agents (e)(1)(v) Make note of-- the appendix may contain any other information which the facility owner or operator determines to be pertinent to an oil spill response (e)(2) (e)(2)(i) (e)(2)(ii) (e)(2)(iii) (e)(3) (e)(3)(i) (e)(3)(ii)&(iii) List of contacts This appendix must include a list of 24-hour contacts for key personnel and organizations (unless listed elsewhere), the list must include: Primary and alternate(s) QI Contacts for OSROs retained under contract see paragraph (b)(3)(iv) Appropriate Federal, State, and local officials Equipment lists and records must include: List of equipment and facility personnel required to respond to an average most probable discharge. The location of equipment must also be included A detailed listing of all major equipment indentified in the plan which is available by contract or other means identified in See (e)(iii) for allowed exceptions. The list, if required shall include skimmers; booms; dispersant application, insitu burning, bioremediation equipment, and supplies; communications, firefighting and beach cleaning equipment; and heavy equipment 7

(e)(4) Communications plan Must describe the primary and alternate method of communication during discharges, including communications at the facility and at remote locations within the areas covered

8 (e)(4) Communications plan Must describe the primary and alternate method of communication during discharges, including communications at the facility and at remote locations within the areas covered by the response plan (e)(5) Site-specific safety and health plan Must describe the safety and health plan to be implemented for any response locations(s). It must provide as much detailed information as is practicable in advance of an actual discharge. This appendix may reference another existing plan required under 29 CFR (e)(6) List of acronyms and definitions Must list all acronyms used in the response plan including any terms or acronyms used by Federal, State, or local governments and any operational terms commonly used at the facility, and including all definitions that are critical to understanding the response plan Substantial Harm Facility (SH) (a) Verify owner or operator of the facility, under ; submitted response plan meets the requirements of , except as modified by this section (b) Note that the facility s response activities section of the response plan need not list the facility or corporate organizational structure that will be used to manage the response, as required by (b)(3)(iii) (c) (d) Verify owner or operator of the facility ensure the availability of response resources required to be identified in (b)(3)(iv) by contract or other approved means described in Verify owner or operator has at least 200 feet of containment boom, and the means of deploying and anchoring the boom, available at the spill site within 1 hour of the detection of a spill to respond to the AMPD in lieu of the quantity of containment boom specified in (c)(1) unless COTP specifies otherwise. In addition, must be adequate sorbent material for initial response to an AMPD. --If Fixed facility; boom and sorbent material must be located at the facility. --If Mobile facility; boom and sorbent material must be available locally and be at the site of the discharge within 1 hour of its discovery. 8

9 Mobile MTR Facilities Y N Page # Comments (a) (a)(1) (a)(2) (a)(3) (b) Verify the following information is contained within the response plan and Mobile facility is required to carry when performing transfer operations: Description of response activities for a discharge which may occur during transfer operations. May be in narrative form or list of procedures to be followed in event of discharge Identity of response resources to respond to a discharge from the mobile MTR Facility List of the appropriate person and agencies (includes phone numbers) to be contacted, to include NRC Verify plan states owner or operator of the mobile facility must retain the information in this paragraph at the principal place of business Discrepancies: Cite(s): Comments: 9

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