The US Coast Guard revises vapour control requirements


Lieutenant Jodi J. Min, senior chemical engineer, Hazardous Materials Division, US Coast Guard, Washington DC, United States of America



With an effective date of August 15 2013, the US Coast Guard revised its safety regulations for vessel and facility vapour control systems (VCS) to promote safe operation in an expanded range of activities. These revised regulations improve operational safety by regulating VCS design, installation, and use, however they do not require anyone to install or use them.

One of the Coast Guard's overarching responsibilities is to act as necessary to prevent damage to land and structures on or along US navigable waters to protect the waterways and their resources. Another overarching charge is to regulate vessels and their liquid bulk dangerous cargo operations to protect life, property, and the marine environment. In fulfilment of these responsibilities, the US Coast Guard amended its previous VCS regulations that were originally circulated in 1990. As mentioned previously, these regulations do not require any facility or vessel to control vapour or be equipped with a VCS, nor do they require a vessel to take away vapour from facilities. The requirement to control such vapours follows on from the US Clean Air Act Amendments of 1990 (CAA 90) as implemented by the US Environmental Protection Agency (EPA). Under CAA 90, EPA issues national standards for control of volatile organic compounds (VOC) and other air pollutants emitted during marine tank vessel operations. Implementation of CAA 90 also authorises individual states to set vapour emission standards and to require that marine terminals and tank vessels be equipped with these systems.

Advancements in technology and policy

VCS design and technology today is much more advanced and controls more vapours than in 1990. Back then systems were limited to crude oil, gasoline blend, or benzene vapour; the EPA and individual states now permit or require the control of vapour emissions from many other cargoes. In addition, EPA regulations now require marine tank vessels operating at major terminals that control VOC vapours to be vapour-tight and equipped with vapour collection systems.

From 1990, US Coast Guard practice was to accommodate design and technology improvements by using exemption and equivalency determination provisions. This enabled them to approve individual applications by VCS owners or designers who could show that their improvements provide a level of safety at least equivalent to that provided by regulations. As applicability of VCS expanded shortly after 1990 to additional cargo types and to tank barge cleaning facilities (TBCF), the Coast Guard provided interim safety guidance in the form of a Navigation and Vessel Inspection Circular 1-96 (NVIC 1-96). However, safety guidance in a NVIC is not legally binding on industry, and reliance on exemption and equivalency reviews involves extra risk for VCS owners and designers, and extra review time for the Coast Guard. US Coast Guard efforts in updating the regulations were also guided by the principles of retrospective review outlined in a recent Presidential Executive Order (Executive Order 13563, Jan. 18, 2011). Therefore, the Coast Guard's goal in updating its VCS regulations was to have the regulations apply in a wider range of circumstances. We believe we have achieved this goal.

The updated regulations should accomplish the following:

• Reflect the expanded number and scope of federal and state regulations for VCSs since 1990.
• Reflect advances in VCS technology and operational practices since 1990, particularly in vapor-balancing operations, cargo line clearing operations, and multi-breasted tandem barge-loading operations.
• Incorporate safety guidance and reflect VCS regulatory exemptions and equivalency approvals.
• Provide new regulations for cargoes and operations, such as TBCFs, that have become subject to Federal or State regulatory CAA-90 expansion since 1990.
• Provide for periodic operational reviews to ensure that VCSs are properly maintained and operated after they are certified.
• Provide an alternate test program for analyzers and pressure sensors, in addition to existing 24-hour pre-transfer/ cleaning instrument testing requirements, to provide greater regulatory flexibility.
• Require certifying entities (CEs) to be operated by licensed professional engineers to ensure that certification is conducted by properly qualified professionals, and clarify the role of the CE in VCS design, installation, and hazard reviews.
• Remove specifications for flame arresters and instead require flame arresters to meet third-party standards, because of apparent lack of public demand for these devices.
• Attempt to achieve greater clarity through the use of tabular presentation.
• Update industry standards that are incorporated by reference into our regulatory requirements.
• Phase in requirements for existing VCSs to moderate the economic impact of new requirements for those VCSs.
• Make conforming changes in other regulations other than 33 CFR part 154.
• Make non-substantive changes in the wording or style of existing regulations, either to improve their clarity or to align them with current federal regulatory style guidance

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