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NSFCC | Operations | Response Support Division | Response Resource
Assessment Branch


Frequently Asked Questions

Preparedness Assessment Visits

What is a PAV?

A Preparedness Assessment Visit is the NSFCC’s primary mechanism for assessing a region’s environmental emergency response capabilities.

What does the RRAB look for when conducting Classified OSRO site visits on a PAV?
To verify the assets of Classified OSROs, the RRAB accomplishes the following:

What does the RRAB look for when conducting site visits at other-than-Classified-OSRO locations on a PAV?

To gather information relating to the assets available to the key Federal decision-maker from other-than-Classified-OSROs, the RRAB requests the following:

Any equipment operation or maintenance/personnel training record review is optional.


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Definitions

What is an OSRO?
 

From the Glossary in the OSRO Classification Guidelines, an OSRO, or Oil Spill Removal Organization, is any person or persons who owns or otherwise controls oil spill removal resources that are designated for, or are capable of, removing oil from the water or shoreline.

What are "core resources"?
 

As explained in the OSRO Classification Guidelines, the core resources are separated into five categories:

What is EDRC?
 

From the Glossary in the OSRO Classification Guidelines, EDRC, or Effective Daily Recovery Capacity, is the calculated capacity of oil recovery devices as determined by using a formula defined in 33 CFR 154, Appendix C and 33 CFR 155 Appendix B that accounts for limiting factors such as daylight, weather, sea state, and emulsified oil in the recovered material.

What is TSC?
 

From the Glossary in the OSRO Classification Guidelines, TSC, or Temporary Storage Capacity, is any temporary storage capable of being utilized on-scene at a spill response and is designed and intended for storage of flammable and combustible materials.

What are Operating Areas?
 

From the Glossary in the OSRO Classification Guidelines, an Operating Area is defined as the 6 geographic locations in which a facility or tank vessel is handling, storing, or transporting oil. The following are the 6 operating areas:

What are Operating Environments?
 

From the Glossary in the OSRO Classification Guidelines, an operating environment is used to define the conditions in which response equipment is designed to function. The following are the 4 operating environments:

What does AMPD mean?
 

AMPD refers to Average Most Probable Discharge. From 33 CFR Parts 154.1020 and 155.1020 , AMPD means a discharge of the lesser of 50 barrels or 1% of the volume of the Worst Case Discharge. This classification has been dropped from the Coast Guard's Classification Matrix; however, the local Captain of the Port (COTP) will determine and verify AMPD response levels within their Area of Responsibility.

What does MM or MMPD mean?
 

MM or MMPD refers to Maximum Most Probable Discharge. From 33 CFR Parts 154.1020 and 155.1020, MMPD for a facility is a discharge of 1,200 barrels or 10% of the volume of a WCD, whichever is less. For a tank vessel with a capacity equal to or greater that 25,000 barrels of oil, a discharge of 2,500 barrels; for a vessel with a capacity of less than 25,00 barrels, a discharge of 10% of the tank vessel's oil cargo capacity.

What does the WC or WCD mean?
 

WC or WCD refers to Worst Case Discharge. From 33 CFR Parts 154.1020 and 155.1020 , WCD for a onshore facility and a deepwater port is the largest foreseeable discharge in adverse weather conditions; in the case of a tank vessel, it's the discharge, in adverse weather conditions, of a tank vessel's entire oil cargo.

What does "Contracted" mean?
 

Letter of Intent (LOI) has been removed from the OSRO Classification Program as a possible resource status and the definition of "contracted" has been modified to include other approved means of assuring resources. For facilities, see “Operating in compliance with the plan” ( 33 CFR 154.1020 ) and “Methods of ensuring the availability of response resources by contract of other approved means” (33 CFR 154.1028). F or vessels, see “Contract or other approved means” (33 CFR 155.1020) and the section on “Geographic-specific appendices for each COTP zone in which a vessel operates” (33 CFR 155.1035 (i)).

What is an ACC?
 

From the Glossary in the OSRO Classification Guidelines , an Alternate Classification City is a designated geographic location along the U. S. coastline used in addition to or in lieu of a COTP City for an OSRO Classification.

What are the training requirements for working for an OSRO?
 

Effective response training should include the following:

OSRO Classifications

Which set of Guidelines apply to me?
 

All NEW OSRO applications will be measured by the Guidelines signed in April 2001, until the new guidelines are signed.

How are the distances determined from the site when computing response times?

Currently, the distances are calculated using the straight-line method.

Who has responsibility for certifying AMPD coverage? 

New AMPD guidance will be provided to the plan holders (facility and vessels) to assist them in fulfilling requirements specified in 33 CFR Parts 154 and 155. AMPD Coverage will be verified at the COTP level.

How are OSROs classified? 

OSROs are classified based on three things:
1) Core equipment that is either owned, contracted, or obligated under a Letter of Intent;
2) Response personnel that are either on-site or available in recall status;
3) Total response times.

Were resources such as fixed storage and vacuum trucks included in the reclassification process under the new OSRO Classification Guidelines?
 

Fixed storage contributed to 35% of an OSRO's TSC for River/Canal, Inland, and Great Lakes Operating Areas only. Vacuum trucks contributed to 45% of an OSRO's EDRC and TSC in the same operating areas.

What is containment boom?
 

33 CFR Part 154 and 155 require the availability of 1000 feet of containment boom within 1 hour of discovery. In addition to the basic 1000 foot requirement, the OSRO Classification Guidelines require 300 feet of containment boom for each skimming system.

Why is my EDRC less than the resources I own or have contracted? 

Since temporary storage capacity (TSC) and EDRC are interrelated, the EDRC is normalized when this value is greater than TSC. Therefore, in some cases, your EDRC value will only be credited for half the amount of available TSC.

How is containment boom determined?
 

As outlined in the OSRO Classification Guidelines, Containment Boom and Effective Daily Recovery Capacity (EDRC) are interrelated for OSRO classifications. Since EDRC is adjusted due to Temporary Storage Capacity (TSC), the containment boom is likewise adjusted according to the available number of skimming systems and their combined average EDRC. The adjusted containment boom requirement is calculated by determining the number of skimming systems that make up the actual containment boom requirement.

For example, if the total containment boom requirement is 21,100 feet, then subtracting the 1000 feet for the basic boom requirement results in 20,100 feet. Since 300 feet are required per skimming system, divide 20,100 by 300 feet. This yields a requirement of 67 skimming systems.

Next, apply the algebraic expression:
Actual EDRC = Adjusted EDRC
Actual EDRC is 67 skimming systems and Adjusted EDRC is X.
Therefore, 67 skimming systems = X

The value for X is the adjusted number of skimming systems required to support the Adjusted EDRC. Multiplying the X value by 300 feet and adding 1000 feet to this amount will yield the new adjusted Containment Boom requirement.

Will any existing resource waivers be included as part of the new classification process under the new OSRO Classification Guidelines?
 

With the exception of "boom waivers", all existing resource waivers have been included as part of the new OSRO classification process. In order to have boom waivers included, OSROs will be required to submit a copy of their current waiver approval letters to bring all waivers into compliance with the 3-year effective limit as outlined on page 31 of the OSRO Classification Guidelines. Existing waivers will expire three years from the date the final matrix is published. The reclassification process did not include previous waivers since we are applying a new set of guidelines. Any waivers within a COTP zone will have to be resubmitted to the NSFCC following COTP review and approval of the waiver. Alternate compliance methods (i.e. waivers) will remain in effect for a three-year period.

Why did I lose MMPD or WCD1 classifications despite meeting total response time parameters?
 

Notification and mobilization tables factor in an additional response time based on the availability of equipment and personnel as well as the degree of control over these resources.

Why did I gain an MMPD classification in Rivers/Canals when I did not have one before?
 

The boom requirements have been reduced from 8,000 feet to 4,000 feet which is more than the old "A" classification required but less that the old "B."

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Last Modified 9/19/2013