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Non-Tank Vessel Response Plan Requirements

On September 30, 2013 the Final Rule on Non-Tank Vessel Response Plans (NTVRP) went into effect requiring all non-tank vessels 400 gross tons and over to submit and have an approved NTVRP before January 31, 2014. NTVRP requirements are scaled according to combined fuel and cargo oil capacity in three groups:

  1. less than 250 barrels
  2. less than 2,500 barrels, but greater than or equal to 250 barrels
  3. 2,500 barrels or greater
Nontank vessels in category 3 above (2,500 barrels or greater) generally must meet the same functional planning requirements as tank vessels. Generally, all NTVRPs must identify a qualified individual having full authority to implement removal actions, identify and ensure by contract or other approved means the availability of personnel and equipment to respond to a discharge, and describe training, equipment testing, drills, and roles of individuals in the event of a discharge. Depending on fuel and cargo capacity, vessels must have NTVRPs that meet response resource requirements for an average most probable discharge ("AMPD"), maximum most probable discharge ("MMPD"), or worst case discharge ("WCD"). In addition, NTVRPs must address a variety of types of resources, such as salvage, lightering, fire fighting, dispersants, aerial tracking, shoreline protection, and shoreline cleanup. Response resources required for each category are summarized in the below matrix.

Nontank vessel's fuel and cargo oil capacity AMPD MMPD WCD Salvage Emergency lightering Fire Fighting Dispersant3 Aerial Tracking4 Shoreline protection Shoreline cleanup
2,500 barrels or greater NO1 YES YES YES YES YES YES YES YES YES
Less than 2,500 barrels, but greater than or equal to 250 barrels NO1 YES NO YES2 YES2 YES2 YES2 YES2 YES YES
Less than 250 barrels NO1 YES2 NO YES2 NO NO NO NO NO NO
  1. For nontank vessels carrying oil as fuel only. Nontank vessels carrying oil as cargo must meet AMPD response resources in 33 CFR 155.5050(d)(1) as applicable.
  2. The indicated response resources that must be located within the stipulated response times in the specified geographic areas need only be identified and planned for in the VRP, but not ensured available by contract. Submission of a written consent from the response resource provider must accompany the VRP for approval. This is considered an acceptable "other approved means." See 33 CFR 155.5020. "Contract or other approved means", paragraph (5).
  3. Dispersant response resources are only required for waters where dispersant pre-authorization has been authorized IAW the Area Contingency Plan. See 33 CFR 155.5050(i).
  4. Aerial oil spill tracking response resources are not required for inland areas.