current and the "valid until" field should be dated for five years from the date of the plan's
submission. (NOTE: Absence of information regarding a facility response plan should be
viewed as the facility not being in compliance with the requirement to have a plan).
After the preliminary review, a comprehensive review is conducted on response plans
subsmitted by facilities defined as a "significant and substantial harm" facility in 33 CFR
154.1020. As was indicated earlier, the checklist contained in enclosure (1) is intended to
allow a reviewer to conduct a comprehensive analysis of a plan while allowing the plan
preparer latitude in the plan's form and format. The checklist is designed for use by
personnel familiar with, and having a good working knowledge of, the facility response
plan regulations. In addition, the checklist is appropriate for significant and substantial
harm facilities with Groups I-IV petroleum oils. For facilities handling Group V and non-
petroleum oils, review and analysis beyond that indicated by the checklist may be
appropriate. (NOTE: Oil groups and persistent and non-persistent oils are defined in both
references (a) and (b)).
Non-petroleum and Group V oils are treated differntly for planning purposes. Parts
154.1047 and 154.1049 of Title 33 of the Code of Federal Regulations, require the owner
or operator to identify the procedures and equipment necessary to respond to a worst case
discharge of these oils. There are no specific requirements for identifying the amount of
response resources. The Interim Final Rule allows the owner or operator to determine the
type and amount of equipment needed to respond to a worst case discharge of non-
petroleum oils. The Coast Guard's review is designed to determine if the response scenario
is appropriate for the identified oil's characteristics and the resources identified are
satisfactory in type and consistent with the volume of oil that may be spilled as a result of
the worst case discharge. For Group V oils, the plan must also include procedures,
strategies, and identification of equipment to locate, recover, and mitigate discharges.
During the comprehensive review process, the reviewer should keep in mind that these
response plans are not written for use by an OSC, but are developed to assist the owner or
operator in preparing themselves and their people for an oil spill. During review, each
item on the checklist should be in the plan in sufficient detail to permit the plan to be
useful prior to and during a spill response. The reviewers should ask themselves, "Does
the plan demonstrate that the owner or operator has gone through the planning process and
is now better prepared to respond to a spill?"