COMDTINST 16450.32A
however, is to see if the owner or operator has realistically prepared for the different spill
scenarios; not to see if the planned response is identical to the Coast Guard's plan.
Enclosure (1) contains a critical area review checklist that is intended to allow for
flexibility in the form and format of a plan, while ensuring that issues critical to
preparedness are adequately addressed within the plan.
f.
All response plans should undergo a preliminary review to determine if the statutory
elements prescribed by OPA 90 and the implementing regulations are present. During this
preliminary review, the following items must be checked. The plan includes (1) an outline
of the notification procedures, (2) identifies the qualified individual and alternate qualified
indivdual, (3) identifies the worst case discharge scenario, (4) identifies the resources
ensured available to respond to a worst case discharge (although at this time, the response
capability of the resources is not evaluated), and (5) describes required training and drills.
g.
If a plan does not pass the preliminary review, a letter should be sent notifying the owner
or operator that their plan does not contain the essential elements required within a
response plan and that the missing elements must be included before the plan can be
accepted and/or further reviewed for approval. The letter should also remind the owner or
operator that as their plan is lacking the elements required of a plan, the facility is not
permited to handle, store or transport oil.
h.
If a plan passes the preliminary review, a letter should be sent to the owner or operator
advising them that the plan has been accepted and, if a "significant and substantial harm"
facility, that the plan will be undergoing a comprehensive review for approval.
Additionally, if an owner or operator has certified the adequacy and availability of the
response resources, in accordance with the provisions of 33 CFR 154.1025(c), the COTP
may authorize the handling, storage, or transporting of oil, for up to 2 years from the date
of plan submission, pending the Coast Guard's approval of the plan.
i.
Once the COTP has authorized operation under the plan, an entry must be made in the
Facility File Status Summary (FFSS) of (MSIS). For a significant and substantial harm
facility, the "Response Plan: Plan Approval Letter" field should be updated to show a
current status code of "Pending Approval (PA)" and the date the authorization letter
expires entered in the "valid until" field. For a substantial harm facility, the status code
should be
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