COMDTINST 16450.32A
m. If deficiencies are noted during the comprehensive review, a letter is sent to the owner or
operator describing each deficiency and what is required to correct it. This letter must
specify the time allowed to correct the deficiencies. The time period is left to the
discretion of the COTP based on consideration of the nature of the deficiency and how
useful the plan is as presently written. Generally, 30 to 60 days should be allowed to
correct deficiencies. Provided that any operating authorization has not expired, the facility
may contiune to operate during this period. COTPs are also encouraged to assist facility
owners or operators towards achieving compliance with the OPA 90 response plan
requirements.
n.
When all deficiencies have been corrected, or if no deficiencies are noted during the
comprehensive review, the COTP will send an approval letter. The response plan
approval letters must be signed by the COTP. In accordance with 33 CFR 154.1060(c),
plan approval may be for a period of up to 5 years from the date of the plan's submission.
COTPs may approve plans for a period of less than 5 years in an effort to manage their
future review work load because these plans will be up for review in 5 years. However,
this discretion should be applied judiciously, and most approvals should be for 5 years
(from the date of submission). It is expected that plan approvals will stagger themselves
naturally due to the plan review process and changes in owners, operators, and other
significant events that require plan revision and resubmission for approval. After final
approval for the plan has been granted, the MSIS record should be updated to reflect the
results of the review. For approved plans, an entry should be made showing the status to
be "valid" and the date the approval expires. Plans which fail to obtain approval should
have the status of "expired."
6.
VESSEL RESPONSE PLAN REVIEW (VRP).
a.
VRPs are required for all vessels that are constructed or adapted to carry oil in bluk as
cargo or cargo residue except: vessels exempted in 33 CFR 155.1015(c) and fishing and
fish tender vessels of not more than 750 gross tons when engaged only in the fishing
industry (See Public Law 103-206).
b.
Due to the transitory nature of vessel operations, all vessel response plans are reviewed at
the national level by Commandant (G-MEP-6). These reviews are conducted against the
national planning standards set forth in reference (a). Further, due to the transitory nature
of
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