Services

Full service technical support for the international maritime and petroleum industries.

Vessels

Plan Preparation & Maintenance

Tanker Compliance

USCG Vessel Response Plan (VRP)

  • Tanker vessels calling the United States, that are constructed or adapted to carry oil in bulk as cargo or oil cargo residue, must have a Vessel Response Plan (VRP) approved by the U.S. Coast Guard (USCG) before the vessel can enter U.S. waters.
  • New VRP approvals can take up to 60 calendar days to be issued by the USCG. Vessel additions to an existing plan can take up to 30 calendar days. Currently, the USCG approval time is approximately 14 calendar days.
  • Tanker vessels attempting to enter U.S. waters without an approved VRP can apply for a VRP One Time Waiver or remain out of port until the VRP approval is issued.

Federal Certificate of Financial Responsibility (Federal COFR)

  • Vessels over 300 GT, using the navigable waters of the United States, or any vessel, REGARDLESS OF TONNAGE, that is LIGHTERING or TRANSSHIPPING oil in the Exclusive Economic Zone of the United States, must have a COFR issued by the USCG / National Pollution Fund Center (NPFC). COFRs can take up to 21 calendar days to be issued. Currently, COFRs are usually issued in 1 to 2 weeks.
  • Public vessels and non-self-propelled barges that do not carry oil as fuel or cargo and do not carry hazardous substances as cargo do not need to have a federal COFR.

USCG/California - Integrated Contingency Plan(ICP)

  • The ICP is a combination of both the VRP (Federal) and the CCP (California state) and therefore all requirements for both the VRP and CCP are met by using this one manual.

California Tanker Contingency Plan (CCP)

  • Tanker vessels calling the state of California must submit a California Contingency Plan (CCP) to California’s Office of Spill Prevention and Response(CA OSPR).
  • Plans must be received by CA OSPR at least 5 business days before a vessel’s entry into CA state waters (3 nautical miles).
  • Fines ranging from $2,000 to upwards of $10,000 or more will be issued if a plan has not been submitted at all or is submitted late.

California Certificate of Financial Responsibility (CA COFR)

  • Vessels calling the state of California must have a certificate of financial responsibility (CA COFR) from California’s Office of Spill Prevention and Response (CA OSPR).
  • A CA COFR application can take 21 calendar days to process. Currently, CA COFRs are usually issued in approximately 1 week or less.
  • Fines ranging from $2,000 to an upwards of $10,000 or more will be issued if a vessel enters CA state waters without a CA COFR.

Panama Canal Shipboard Oil Pollution Emergency Plans (PCSOPEP)

  • A PCSOPEP must be submitted to the Panama Canal Authority (ACP) for vessels that are transiting the Panama Canal and have an oil carrying capacity over 400 metric tons or more.
  • PCSOPEPs must be received by the ACP no less than 96 hours before the vessel’s arrival in Panama Canal waters.
  • If a PCSOPEP has not been submitted, or was not submitted in time, the vessel will be required to pay a fine. Fines start at $2500 and are based on the vessel’s size and whether or not they’ve had a violation in the past.

Vessel General Permit (VGP) Compliance Management Plan

  • The Vessel General Permit (VGP) is a Clean Water Act National Pollutant Discharge Elimination System (NPDES) permit that authorizes, on a nationwide basis, discharges incidental to the normal operation of non-military and non-recreational vessels greater than or equal to 79 feet in length.
  • The Gallagher Marine Systems VGP Compliance System is intended to be a supplement to the existing SMS or ICCP systems.
  • Use of the Gallagher Marine Systems VGP Compliance Manual is not compulsory, but complying with the NPDES Vessel General Permit is mandatory.

Vessel General Permit (VGP) Notice of Intent Filing (NOI)

  • The Clean Water Act NPDES regulations require that each point source, e.g. vessel, seeking to discharge pollutants to the waters of the U.S. must obtain a permit under the NPDES program and be compliant with those limitations and requirements.
  • Any vessel that meets the conditions requiring submission of an NOI must file its own NOI seeking coverage under the general permit.

Remote Area, Alternative Planning Criteria (APC) for Alaska, Guam, and America Samoa

  • An Alternative Planning Criteria (APC) approval is required for tanker vessels calling Alaska, Guam, Saipan, or American Samoa. APC approval is also required for tanker vessels transiting through the waters of the Alaska, Guam, and America Samoa while going to or from a U.S. port.
  • In remote areas of the U.S., where OSRO (Oil Spill Removal Organization) resources necessary to respond to a WCD (Worst Case Discharge) are not available or do not exist, a vessel needs to obtain coverage from a local OSRO, and show proof of coverage to USCG HQ (Headquarters) and/or the local USCG through the APC request process.
  • Remote area OSRO coverage can take anywhere from 1 to 10 business days to arrange. Additionally, the USCG can take anywhere from 5 to 90 calendar days to review and approve APC requests.
  • Interim Operating Authorization (IOA) requests can be submitted in conjunction with APC requests, and can allow the vessel to trade to or transit the remote area while waiting for the APC approval.

Alaska Contingency Plans and Alaska COFRs: Tanker Vessels

  • Tank vessels calling a port in Alaska are required to have an AK Plan and an AK COFR (Alaska Certificate of Financial Responsibility).
  • Tank vessels are usually temporarily added to the existing AK plan and AK COFR of the Alaska terminal/facility that they are calling.
  • The addition of a tank vessel to the terminal/facility’s plan is usually done automatically by the terminal/facility.

Nontank Compliance

USCG Vessel Response Plan (NTVRP)

  • Nontank self-propelled vessels that are larger than 400 GT and are calling the United States must have a Nontank Vessel Response Plan (NTVRP) approved by the U.S. Coast Guard (USCG) before the vessel can enter U.S. waters.
  • New Nontank approvals can take up to 60 calendar days to be issued by the USCG. Vessel additions to an existing plan can take up to 30 calendar days. Currently, the USCG approval time is approximately 14 calendar days.

Federal Certificate of Financial Responsibility (Federal COFR)

  • Vessels over 300 GT, using the navigable waters of the United States, or any vessel, REGARDLESS OF TONNAGE, that is LIGHTERING or TRANSSHIPPING oil in the Exclusive Economic Zone of the United States, must have a COFR issued by the USCG / National Pollution Fund Center (NPFC). COFRs can take up to 21 calendar days to be issued. Currently, COFRs are usually issued in 1 to 2 weeks.
  • Public vessels and non-self-propelled barges that do not carry oil as fuel or cargo and do not carry hazardous substances as cargo do not need to have a federal COFR.

California Nontank Contingency Plans (CANT):

  • Nontank vessels that are over 300 GT and are calling the state of California must submit a California Nontank Contingency Plan (CANT) to California’s Office of Spill Prevention and Response (CA OSPR).
  • Plans must be received by CA OSPR at least 5 business days before a vessel’s entry into CA state waters (3 nautical miles).
  • Fines ranging from $2,000 to an upwards of $10,000 or more will be issued if a plan has not been submitted at all or is submitted late.

California Certificate of Financial Responsibility: CA COFR

  • Vessels calling the state of California must have a certificate of financial responsibility (CA COFR) from California’s Office of Spill Prevention and Response (CA OSPR).
  • A CA COFR application can take 21 calendar days to process. Currently, CA COFRs are usually issued in approximately 1 week or less.
  • Fines ranging from $2,000 to an upwards of $10,000 or more will be issued if a vessel enters CA state waters without a CA COFR.

Panama Canal Shipboard Oil Pollution Emergency Plans (PCSOPEP)

  • A PCSOPEP must be submitted to the Panama Canal Authority (ACP) for vessels that are transiting the Panama Canal and have an oil carrying capacity over 400 metric tons or more.
  • PCSOPEPs must be received by the ACP no less than 96 hours before the vessel’s arrival in Panama Canal waters.
  • If a PCSOPEP has not been submitted, or was not submitted in time, the vessel will be required to pay a fine. Fines start at $2500 and are based on the vessel’s size and whether or not they’ve had a violation in the past.

Vessel General Permit (VGP) Compliance Management Plan

  • The Vessel General Permit (VGP) is a Clean Water Act National Pollutant Discharge Elimination System (NPDES) permit that authorizes, on a nationwide basis, discharges incidental to the normal operation of non-military and non-recreational vessels greater than or equal to 79 feet in length.
  • The Gallagher Marine Systems VGP Compliance System is intended to be a supplement to the existing SMS or ICCP systems.
  • Use of the Gallagher Marine Systems VGP Compliance Manual is not compulsory, but complying with the NPDES Vessel General Permit is mandatory.

Vessel General Permit (VGP) Notice of Intent Filing (NOI)

  • The Clean Water Act NPDES regulations require that each point source, e.g. vessel, seeking to discharge pollutants to the waters of the U.S. must obtain a permit under the NPDES program and be compliant with those limitations and requirements.
  • Any vessel that meets the conditions requiring submission of an NOI must file its own NOI seeking coverage under the general permit.

Alaska Contingency Plans: Nontank Vessels

  • Nontank vessels over 400 GT that are in Alaskan waters for a purpose other than transit must have a Nontank Vessel Streamlined Plan approved by the Alaska Department of Environmental Conservation (ADEC or AK DEC).
  • ADEC must receive plans at least 5 business days before a vessel enters Alaska state waters. Submissions that do not meet the time requirement should be accompanied by an explanation for why the submission was late.
  • Vessels entering Alaska state waters without an approved plan will be fined.

Alaska Certificate of Financial Responsibility (COFR)

  • Nontank vessels over 400 GT that are in Alaskan waters for a purpose other than transit must have an AK COFR issued by Alaska Department of Environmental Conservation (ADEC or AK DEC).
  • ADEC must receive AK COFR applications at least 15 calendar days before a vessel enters Alaska state waters or provide an explanation for why the submission was late.
  • Vessels entering Alaska state waters without an AK COFR will be fined.

Marpol Compliance

SOPEPs and SMPEPs: Shipboard Oil Pollution Emergency Plan/Shipboard Marine Pollution Emergency Plan

  • Vessels 150 GT or more, which are trading in international waters, must have an approved SOPEP (Shipboard Oil Pollution Emergency Plan).
  • Vessel 150 GT or more, which are carrying noxious liquid substances (NLS) in bulk and trading in international waters, must have an approved SMPEP (Shipboard Marine Pollution Emergency Plan.)
  • For U.S.-flagged vessels, the USCG can take up to 90 calendar days to issue approvals for new SOPEP/SMPEPs. Approvals for vessel additions to existing SOPEP/SMPEPs can take up to 30 calendar days. Currently, the USCG approval time is approximately 14 calendar days.