NVIC 01-96: Vapor control systems at tank barge cleaning facilities

Commandant 2100 2nd Street SW U.S. Coast Guard Washington DC 20593-0001 Staff Symbol: G-MOS-3 Phone: 202 267 1217 COMDTPUB P16700.4 NVIC 1-96 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. Subj: SAFETY STANDARDS FOR THE DESIGN AND OPERATION OF A MARINE VAPOR CONTROL SYSTEM (VCS) AT TANK BARGE CLEANING FACILITIES

Safety Standards for the Design and Operation of a Marine Vapor Control System (VCS) at Tank Barge Cleaning Facilities. — Purpose. The purpose of this Circular is to provide recommended safety standards for the

design and operation of a marine VCS at tank barge cleaning facilities.

Safety Standards for the Design and Operation of a Marine Vapor Control System (VCS) at Tank Barge Cleaning Facilities. — Background.

a. Tank barge cleaning facilities are utilized by the barge industry to gas-free and clean cargo tanks on tank barges prior to a change of cargo or conducting repair/retrofit work. The vapor space in the cargo tanks of barges entering these facilities contains cargo vapors from the last cargo carried and sometimes from cargoes previous to the last cargo. These vapors may contain high levels of Volatile Organic Compounds

(VOCs) and/or Hazardous Air Pollutants (HAPs).

Existing work practices for gas-freeing and cleaning of cargo tanks result in the release of these VOCs and HAPs to the atmosphere, causing a degradation of air quality reductions. b.

In 1990, Congress amended the Federal Clean Air Act.

One section of the Amendments requires states to achieve and maintain a 15 percent (%) reduction in their VOC emissions level below the 1990 base year level by 1996 in non-attainment areas within individual states.

This amendment has required states to review their State Implementation Plans (SIPs) in order to determine potential sources of emissions reductions.

The tank barge cleaning industry has been identified in several states as a viable source of emissions reductions, and two states have subsequently passed regulations requiring the control of emissions from tank barge cleaning facilities.

Controlling vapor emissions at tank barge cleaning facilities will require the installation and use of a marine VCS.

Electronic Version Only Standard Distribution normaly shown on first page of printed copy is a grid is: B:b 2 B:c 2 B:n 30 D:k 1 E:o 2 Navigation and Vessel Inspection Circular No 1-96 c.

In June 1990, the Coast Guard promulgated safety regulations for the design and operation of marine vapor control systems for facilities contained in Title 33, Code of Federal Regulations (CFR) Part 154, Subpart E and vessels contained in Title 46 CFR 39.

These regulations were developed from recommendations submitted to the Coast Guard by the Chemical Transportation Advisory Committee (CTAC) and apply to the control of emissions from vapors collected during vessel lightering operations and from vapors collected by a marine transfer facility during cargo loading operations.

During the CTAC study and subsequent development of the regulations by the Coast Guard, it was not anticipated that tank barge cleaning facilities would employ a VCS in their operations.

Consequently, tank barge cleaning facility operations were not included as part of the CTAC study, and the current VCS regulations are not applicable to these facilities. d.

The Coast Guard recognized a need to conduct a detailed review of cleaning facility operations to determine the technical feasibility of utilizing a VCS during gas-freeing and tank cleaning operations, to identify pertinent safety issues, and to develop standards for the safe design and operation of a VCS.

In April 1994, the CTAC Subcommittee on Marine Vapor Control Systems, at the request of the Coast Guard, convened to commence work on evaluating the technical and safety aspects of the application of a VCS during tank barge cleaning operations, and develop recommended safety standards for implementation by the Coast Guard.

The Subcommittee was comprised of members representing the tank barge industry, cleaning facility operators, marine chemists, third party VCS certifying entities, and cargo shippers.

The Subcommittee completed its work in June 1995 and forwarded its recommendations to CTAC.

These recommendations were approved by the CTAC membership and forwarded to the Coast Guard in January 1996.

These recommendations have been utilized by the Coast Guard to form the basis for the enclosed safety standards.

Safety Standards for the Design and Operation of a Marine Vapor Control System (VCS) at Tank Barge Cleaning Facilities. — Discussion.

a. The enclosed safety standards for the design and operation of a VCS have been developed for use by tank barge cleaning facilities during gas-freeing and tank cleaning operations on tank barges, and represent the minimum acceptable level of system safety. The Coast Guard recognizes that the design and installation of a VCS represents a major capital investment on the part of cleaning facilities and barge operators, and has attempted to provide as much flexibility as possible in the design options for both cleaning facilities and tank barges. Navigation and Vessel Inspection Circular No 1-96 b. The Coast Guard does not have, nor does it seek, the statutory authority to require cleaning facilities to control emissions of VOCs and HAPs during gas-freeing and tank cleaning operations. Accordingly, the Coast Guard does not require the use of a VCS at cleaning facilities. Rather, the Coast Guard's role is to promote safety within the maritime industry and to protect the marine environment. This can be accomplished through the development and implementation of uniform national safety standards.

Safety Standards for the Design and Operation of a Marine Vapor Control System (VCS) at Tank Barge Cleaning Facilities. — Implementation. Captains of the Port and Officers in Charge, Marine Inspection are

encouraged to bring this Circular to the attention of appropriate individuals in the maritime industry within their zones. The Coast Guard fully intends to further publish these recommended safety standards as statutory regulations. Therefore, adherence to these safety standards is strongly recommended for tank barge cleaning facilities. Encl: (1) Safety Standards for the Design and Operation of A Marine VCS at Tank Barge Cleaning Facilities Non-Standard Distribution: B:a G-MOS-3(5), G-MOS-2(2), G-MCO-2(2), G-MCO-3(2). B:z MSC-3 (5). C:e New Orleans, Houston, Galveston (30), All other offices (5). C:m New York (10). E:n Baton Rouge (5).