US Coast Guard Revises Marine Load Vapor Control Safety Requirements
The responsibility of protecting life, property, and the marine environment on or along US navigable waters falls on the shoulders of the US Coast Guard (USCG). Their job is becoming increasingly difficult with the increase in domestic crude production and associated movement. Throughout the US, all forms of transport are experiencing strain as industry produces and moves unprecedented quantities of petroleum products. The stress on existing logistical infrastructure has prompted the various regulatory agencies tasked with oversight of pipelines, railroads, and the maritime to turn their spotlight on safety.
Certain petroleum products emit volatile organic compounds (VOC’s) and other air pollutants. When a marine vessel loading operation takes place and volatile liquids are loaded, vapors are displaced which in most cases must be controlled through a marine vapor control system (MVCS). The Clean Air Act Amendments of 1990 (CAA 90) issued national standards for control of VOC’s and other pollutants emitted during marine vessel loading operations. CAA 90 also authorizes individual states to set vapor emission standards and to require that marine terminals and tank vessels be equipped with a MVC system. The national requirements can be found in 40 CFR 63 Subpart Y and 40 CFR 61 Subpart BB.
While the USCG regulations don’t require any vessel or facility to use a MVCS, they have revised the safety regulations of existing MVCS’s to be more consistent with Federal and State environmental requirements and provide guidelines for those to be constructed. Also, the changes regulate industry advancements in MVCS technology and codify the standards in design and operation of a MVCS at a tank barge cleaning facility. Other components of the revised regulations include:
- Expanded list of cargos having VOC emissions that require vapor control
- Provide for a certification process performed by a USCG-approved Certifying Entity (CE)
- Require CE’s to be operated by a licensed professional engineer
- Clarify the role of the CE in MVCS design, installation, and hazard review
- Provide for periodic operational reviews to ensure MVCS’s are properly maintained and operated
- Require that marine tankers operating at major terminals be vapor tight and equipped with MVCS
- Phase in requirements for existing MVCS’s to meet new regulatory requirements
- Include safety guidance and reflect MVCS regulatory exemptions and equivalency approvals
Much has changed since the Coast Guard originally began regulating marine loading operations in 1990. It is only appropriate that the various State & Federal regulatory agencies tasked with administering the standards keep pace with technological advancements. GEM Mobile Treatment Services (GEM) represents industry and keeps pace with the regulatory changes of the USCG by participating as an environmental representative on the USCG Chemical Transportation Advisory Committee (CTAC). Through our participation in the CTAC, we are able to communicate the perspective of the regulated community while regulations are drafted, ultimately ensuring there is a balance between industry and the regulatory community.
For more information on this subject, please contact Chris Longo, GEM Corporate Regulatory Compliance Manager at 562-595-7075.
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