Do you operate a refinery, terminal, or tank farm that includes vapor control systems (VCS) to minimize emissions while loading ships and barges? Do you know when your system was installed? All Marine Vapor Control Systems (MVCS) are required to undergo an “Operational Review” which must be conducted by a US Coast Guard “Certifying Entity” (CE), and depending on when your system was installed or last reviewed, you may need to conduct a new Operational Review.
All new Vapor Control Systems (VCSs) built during or after 2013 were required to comply with 33CFR154, Subpart P. Existing operating systems that were built in compliance with the earlier 33CFR154, Subpart E were to comply with Subpart P by August of 2016. Per §154.2021(a), each VCS must undergo an Operational Review by a Certifying Entity (CE) within 5 years of its initial certification or last Operational Review. The objective of the Operational Review per §154.2021 and §154.2024 is to ensure proper operation and maintenance of the VCS.
Please note that the regulation stipulates WITHIN 5 YEARS of the initial certification or last Operational Review. Therefore, it is strongly advised to verify the date of your system’s last Operational Review. The latest Operational Review letter issued for the MVCS should be maintained at the facility per §154.2021(d). The 5-year Operational Review can be relatively painless if necessary records are available and up to date.
Requirements of the MVCS Operational Review are provided in 33CFR154.2024. The required records should be readily available. It is highly recommended that a facility gathers the records for the operational review prior to calling in a CE.
Facility Information needed for the CE so that they can complete the Operational Review includes:
- Last Operational Review Letter.
- List of cargos the VCS is designed for an certified VCS cargo transfer rate.
- Operations Manual
- Training Plans for Facility Personnel in Charge (PIC)
- Training Plans for VSC Maintenance Personnel
- VCS Equipment and Instrumentation test procedures.
- Training records and list of facility Personnel in Charge
- VCS records, testing and inspection per §154.740 & §156.170.
- Pre-Transfer conference form.
- List of all VCS modifications and re certification records since last Operational Review.
- List of all VCS equipment and instrumentation with changes since last Operational Review indicated. All changes should have documentation and approval.
- Facility VCS P&IDs from Initial Certification or last re-certification or last Operational Review.
This information should be gathered prior to calling in a CE for the Operational Review. There may be additional information requested by the CE but that should be minimal and easily retrieved. The CE will review the information supplied by the facility, perform a system walkdown to ensure no changes and to confirm that the VCS complies with documentation and regulations. The CE will observe the 24-hour pre-transfer system and instrument testing, the pre-transfer conference, initial stages of transfer and maximum loading capacity.
With the requirement for a CE to witness a transfer at maximum loading capacity, it is important that the facility schedule the CE Transfer Observation for a vessel that can accept full facility design transfer rate.
Norton Engineering Consultants are listed with the USCG as a Certifying Entity and stand ready to assist VCS owner/operators in all facets of the 5 Year Operational Review of their VCS, or with upgrading or modifying their VCS as needed. Contact us today!