Revised Safety Regulations for Facility and Vessel Vapor Control Systems – Effective Aug. 15, 2013

September 13, 2013 in News

Hudson can help!!!

 

The Department of Homeland Security issued revised safety regulations effective August 15, 2013 for facility and vessel vapor control systems (VCSs).  33 CFR 154 Subpart E is now replaced in its entirety by Subpart P.  The revised regulations contain significant clarification to requirements for certification of new facilities, recertification of existing facilities as well as introduces new requirements such as periodic operational reviews.  S. T. Hudson Engineers, Inc. is actively assisting several of our clients in understanding the requirements for these revisions as well as providing certification, recertification, and operational review services.

 

The new regulations:

 

  • 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 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 currently 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 33 CFR Part 154, Appendix B, which provides specifications for flame arresters and requires 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 regulatory requirements;

 

  • Phase in requirements for existing VCSs to moderate the economic impact of new requirements for those VCSs;

 

  • Make conforming changes in regulations other than 33 CFR Part 154, Subpart E and 46 CFR Part 39; and

 

  • Make nonsubstantive 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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