USA - Master's Guide to Compliance in US Waters Doc No: NN0217G

Version: 26
National Advisory Notices

Purpose
To inform vessels about applicable regulatory requirements in U.S. waters
Scope
Applies to all vessels managed by Teekay Shipping Limited calling U.S. ports.
Introduction
The Master of any vessel making a call to the United States faces a number of
regulatory issues that are specific to the US.
To ensure compliance with a number of US federal and state regulations, the attached
guides and attachments are intended to help the Master effectively and efficiently.
Master shall fully familiarize himself with the contents of all the attachments to this
NAN.
USCG - Government Initiated Unannounced Exercises (GIUE)
Background
According to the 2016 PREP Guidelines the USCG reserves the authority to conduct
GIUE including SMFF resource providers which may affect both tank and nontank
vessel plan holders. It is anticipated that every COTP may conduct as many as two (2)
GIUE each year involving tank vessels. The other two (2) will be reserved for Bulk Oil
Transfer Facilities, which also are subject to the GIUE program. As there are currently
forty-two (42) COTP Zones, this means as many as eighty-four (84) GIUE may involve
tank vessels each year. The following impacts are expected for plan holders asked to
participate in a GIUE:
• Scenarios will include a discharge of 50 barrels of oil from the vessel during
cargo transfer operations.
• Facilities and vessels are expected to deploy spill response equipment.
• Exercise will not exceed 4 hours.
• Operational impact will be minimized during these exercises.
• USCG is coordinating with EPA and State Officials to avoid duplication.
• All costs are the responsibility of the plan holder.
GIUE Selection Criteria
The USCG will be using a risk based process to select candidates for GIUE including:
• Concerns about the ability of the plan holder’s equipment or OSRO to meet the
planning requirements.
• Economic, public safety or political concerns in the area where the vessel or
facility operates.
• Past performance in actual spills or exercises.
• Products carried or transferred.
• Proximity to environmentally sensitive areas outlined in the Area Contingency
Plan (ACP).
• Safety and environmental compliance history of the plan holder.

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USCG Evaluation
The USCG will be evaluating the notification in addition to the primary objective to
deploy equipment. Boom will need to be deployed within one (1) hour and a recovery
device within two (2) hours. The exercise needs to be conducted safely and a timeline
documented noting important events and notifications made must be produced.
• Successful completion of the GIUE will result in credit for: QI notification exercise,
Equipment deployment exercise, and an unannounced exercise. A vessel that
successfully completes an exercise will not be required to participate in another
GIUE for at least 36 months from the date of the exercise in that COTP Zone. Plan
holders with multiple vessels in their plan will also not be subject to another GIUE
in the COTP Zone where the exercise was completed for 36 months from the date
of a successful exercise. However, all vessels in the fleet plan may be subject to
a GIUE in any other of the different COTP Zones at any time.
Unsatisfactory performance will result if the plan holder cannot properly implement its
response plan. Factors that could result in unsatisfactory performance include the
following:
• Failure to notify and active response resources in a timely manner.
• Response resources are not available and deployed within the specified time
frames.
• Response resources are not in proper operating condition.
• Response personnel are not adequately trained in implementing the response
plan.
• Significant safety violations are observed during equipment deployment.
The USCG will document any deficiencies and establish a deadline to correct them. If
a Plan Holder does not satisfactorily complete a GIUE, they will likely be subject to
another one until proper response capabilities can be demonstrated. The COTP may
also prohibit cargo operations until the AMPD provider of the Plan Holder can
demonstrate proper response capabilities.
Required Actions
(A) MASTER:
Once the Master has been notified by the USCG of an unannounced exercise they
should:
• Immediately notify your AMPD provider (MSRC) and authorize deployment of
response resources.
• Contact the Qualified Individual at O'Brien's Command Center: +1 985 781
0804.
• State that the vessel is conducting a “Government Initiated Unannounced
Exercise” and provide details of the exercise scenario received from the USCG.
• Indicate who the AMPD provider (MSRC) is to O’Brien’s. It is paramount that
the QI know who AMPD provider is.
• Contact the vessel manager and keep the shore team fully appraised of
initiation, progress and completion of the GIUE.
• Carry out all notifications as required by the VRP and VRP exercise Evaluation
Checklist. (Attachment#17)
• Keep a detailed log of all the notifications and events.

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• After the evaluation of the whole response to GIUE, USCG will issue GIUE
Result Letter – This letter to be immediately shared with the Shore Team (VM),
QI and AMPD provider.
(B) QI (O’Brien’s):
• Notify the AMPD provider to ensure immediate deployment of response
personnel and equipment has commenced.
• Complete other required regulatory notifications to the appropriate federal and
state agencies.
• Prepare a GIUE documentation form (Attached). This form includes a timeline
of the actions and notifications made, a description of the scenario, and contact
information for the vessel, the AMPD provider, Designated Person Ashore
(DPA), and Duty Incident Commander (IC).
• Send the completed GIUE documentation form to the vessel Master and DPA.
United States Department of Agriculture
As per the USDA requirements fresh provisions received at Hawaii are not
acceptable in rest of USA. If any fresh provisions are found from Hawaii these will be
removed and sealed.
Revised 2016 PREP Guidelines
U.S Coast Guard (USCG) issued revised 2016 National Preparedness for Response
Exercise Program (PREP) guidelines that reduce the frequency of the Remote
Assessment and Consultation Exercises (RACE) for vessel response plan holders.
From 1st October 2018 new PREP guidelines went into effect. For the RACE, plan
holders are only required to complete one exercise per plan on a triennial (3-year)
cycle, rather than one (1) exercise for each vessel in their plan per calendar year. The
plan holder may select any vessel from those listed in their VRP or NTVRP to complete
the exercise.
Required Actions:
1. No Action Required:
If at least one (1) vessel has completed a RACE that includes a salvage and
marine firefighting component, either as a combined exercise or separately, the
plan holder has satisfied the RACE requirement for the triennial cycle or next
three (3) years. In this case, the remaining vessels in the fleet do not need to
complete a separate RACE drill for 2018.
2. Complete one RACE per fleet per triennial cycle or every three (3) years:
Moving forward, plan holders should ensure that at least one (1) vessel listed in
their VRP or NTVRP has conducted a RACE for salvage and for marine
firefighting within the past three (3) years to remain in compliance with the USCG
exercise requirements.
3. Recordkeeping:
Records of the RACE that have been conducted to date should remain available
on board the vessel for a minimum of three (3) years. For future exercises, all
vessels listed in the plan should maintain a record of the RACE, even if they are
not the selected vessel.
Following is the procedure to initiate RAC Drill:

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1. Call O’Brien’s and communicate to the agent that you would like to conduct
your RAC drill
2. O’Brien’s will then notify Ardent (Salve & Marine Fire Fighting)
3. Ardent will then call back the vessel Master to complete the drill
4. Use also Ardent’s OPA-90 Incident Checklist to complete the drill
5. Provide Ardent’s Duty Officer with the following information:
- Vessel Name
- IMO
- Contact Name & Phone Number
- Email
- Classification Society
- Scenario of Drill
- Cargo
- Next Port of Call
6. Ardent’s Duty Officer will also use the incident checklist as a guiding tool for
the drill
7. After successful completion of RAC and within 48 hours, Ardent will issue an
exercise documentation form to vessel for review and signature. Vessel to
sign this form and return to [email protected]
8. Once Ardent receives with signature RAC drill is complete.
Attachments
Double-click/Right click on the icon next to the attachment to view the file
1. US Masters Guide 2021 Rev 0
2. 2021 Alaska Checklist Rev 2
3. 2021 American Samoa Checklist Rev 0
4. 2021 Ballast Water Management Checklist Rev 0
5. 2021 California Checklist Rev 1
6. 2021 Gulf of Mexico Checklist Rev 0
7. 2021 Great Lakes Checklist Rev 0
8. 2021 Guam & CNMI Checklist Rev 0
9. 2021 Hawaii Checklist Rev 0
10. 2021 Pacific North West Checklist Rev 1
11. 2021 SOE & CVTIS Checklist Rev 1
12. 2021 VGP Checklist Rev 0
13. Emergency Response Team Guide to Response in US Waters 2021 Rev 0
14. Fuel Transfer Procedures Cross Reference 2021
15. Fuel Transfer Procedures Cross Reference 2018 (For TML vessels)
16. Guide to Media & Public Affairs 2021 Rev 0
17. 2016 PREP Guidelines

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18. MER MSIB 2016-002 2016 PREP Guidelines
19. GIUE Form
20. MER PL 01-15 CH-1 GIUE Policy
21. 2021 Exercise Checklist Rev 1
22. Internal Documentation Form – Shipboard Exercises
23. 2016 PREP Guidelines - Core Components for Exercising Response Plans
(Appendix A)
24. 2016 PREP Guidelines - Vessel Requirements (Section 3)
25. Vessel Circular 020-16 - 2016 National Preparedness for Response Exercise
Program Guidelines
26. USCG – MSIB – FAQ’s on NPREP 2016: Vessel Response Plan Exercises –
GIUE’s and SMFF
27. O’BRIEN’S Circular 034-18, USCG: Updated PREP Guidelines to Reduce RACE
Frequency (dated19th October 2018)
28. USCG 2016 National Preparedness for Response Exercise Program (PREP)
Guidelines - Version 2016.1
29. USCG Notice of Availability - Update to the 2016 National Preparedness for
Response Exercise Program (PREP) Guidelines
30. Ardent’s 2020 OPA-90 Drill & Exercise Program
31. Ardent’s OPA-90 Incident Checklist

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