NAMEPANovember 6, 2015

The Cost ofNon-Compliance

SECTOR MIAMI

• Documents/Plans:• Certificate of Financial Responsibility• Vessel Response Plans

• Equipment type approval• Domestic and Port State Control Exams

• Cruise ship waste stream exam• Test Oily Water Separator

• Facility and Container Inspections• Operations Manual approval • Response Plan approval• Government Initiated Exercises

COMPLIANCECG means to enhance compliance include:

Options:• Deficiency• Notice of Violation and Civil Penalty• Suspension and Revocation• Captain of the Port Orders• Detention• Banning• Criminal Prosecution• Federalized Incident Response

NON-COMPLIANCE

VESSEL BANNINGMust have three detentions in 18 months – Several bans in 2015

Side shell Wastage

Impaired visibility

Excessive oil leakage

Unsafe Gangway

• Connection discovered on pipe leading from Overboard discharge connection to the OWS.

• A temporarily clear hose affixed to the overboard pipe on the inboard side of a pipe flange. 3 inches inboard of the flange. Hose is attached using clamp.

• Normal fixed piping connection lays alongside of temporary clear hose.

• Condition of piping found by MSD Lake Worth, Sector Miami, District 7 Legal and CGIS SE attended vessel to conduct further investigation and expanded ISM/MARPOL I exams.

DETENTION/POTENTIAL CRIMINAL

POTENTIAL CRIMINALBarge Sinking in violation of a Captain of the Port Order

ACOE removal costs in excess of $2 million and one fatality.

Blocking Fort Piercechannel

POTENTIAL CRIMINAL

Intoxicated Master – M/V WASABORG – August 2015

FEDERALIZED RESPONSEM/V ENDEAVOR grounding– No responsible Party – October/November 2015

Any Questions?