154 facility applicability?
Facilities that transfer 250 barrels or more
What is the Coast Guards Jurisdiction at a 154 Facility? Draw a picture
-MTA valves?
-First valve inside/closest to secondary containment
- If there is no secondary containment it would be the valve adjacent to the storage tanks.
What is primary and secondary containment and where is it defined?
-?????idk
What other regulation applies to 154 regulated facilities?
105- MTSA
What types of manuals and paperwork are you going to looking at on a 154 inspection? - 154.740
*LOI – 154.110
*DOI
i.What is probably the most important part of the DOI? – Emergency Shutdowns.
- Operations Manual – 154.310 & .315
i. Is it required to be reviewed annually? Yes
ii. PIC list? Must be up to date - Training Records
i. What are the PIC training requirements? 154.710
-48 hours of experience in transfer operations at a facility in operations - Completed a training and qualification program established by the facility operator and described in the Operations Manual.
- The facility operator must certify that each person in charge has the knowledge of, and skills necessary to:
1. The hazards of each product to be transferred;
2. The rules in this part and in part 156 of this chapter;
3. The facility operating procedures as described in the operations manual
4. Vessel transfer systems
5. Vessel transfer control systems
6. Each facility transfer control system to be used
7. Follow local discharge reporting procedures
8. Carry out the facility’s response plan for discharge reporting and containment. - Facility response plan
i.Applicability? 154.1015- Fixed MTR onshore facilities capable of transferring oil to or from a vessel with a capacity of 250 barrels or more and deepwater ports (Sub)
- Mobile MTR facilities used or intended to be used to transfer oil to or from a vessel with a capacity of 250 barrels or more (Sub)
- Those MTR facilities specifically designated as substantial harm facilities by the COTP under § 154.1016.(Sub)
- Deepwater ports, and fixed MTR onshore facilities capable of transferring oil to or from a vessel with a capacity of 250 barrels or more except for facilities that are part of a non-transportation-related fixed onshore facility with a storage capacity of less than 42,000 gallons. (S&S)
- Those MTR facilities specifically designated as significant and substantial harm facilities by the COTP under § 154.1016. (S&S)
ii. How long is it good for? – 5 years
iii. Is it required to be review annually? Yes 154.1065(a)
What is the difference between a “substantial harm” and a “significant and substantial harm” facility? 154.1016 154.1035 , 154.1040
* What is a mobile considered?
A “substantial harm” facility is considered to have the potential to cause significant environmental damage from an oil spill.
“significant and substantial harm” facility is considered to have an even higher risk of causing major environmental damage due to factors like larger storage capacity, location near sensitive ecosystems, or a history of significant spills, requiring a more robust response plan and stricter regulations.
What are the contents of a FRP?
154.1030
- Introduction and plan content
- Emergency response action plan
- Training and exercises
- Plan review and update procedures
- Appendices
Where would you find worse case discharge of a facility?
- The release of all tanks?
33CFR154.1029
IDK
What are the FRP differences between a mobile and a fixed facility?
- 154.1035 vs .1040 & .1041
1035: For mobile facilities that operate in more than one COTP zone, the plan must identify the oil spill removal organization and the spill management team in the applicable geographic-specific appendix. The OSRO and the spill management team must be included for each COTP zone in which the facility will handle store or transport oil in bulk.
1040: If the facility is a fixed facility, the containment boom and sorbent material must be located at the facility. If the facility is a mobile facility, the containment boom and sorbent must be available locally and be at the site of the discharge within 1 hour of its discovery.
1041: Each mobile MTR facility must carry the following information as contained in the response plan when performing transfer operations:
- A description of response activities for a discharge which may occur during transfer operations. This may be a narrative description or a list of procedures to be followed in the event of a discharge.
- Identity of response resources to respond to a discharge from the mobile MTR facility.
- List of the appropriate persons and agencies (including the telephone numbers) to be contacted in regard to a discharge and its handling, including the National Response Center.
- The owner or operator of the mobile facility must also retain the information in this paragraph at the principal place of business.
What is required to be a Qualified Individual?
33CFR154.1026
Must:
- Be available on a 24-hour basis and be able to arrive at the facility in a reasonable time.
- Be in the United States
- Speak English
- Be trained in the responsibilities of the qualified individual under the response plan.
- Have full authority to: activate and engage with OSROs, Liaison with FOSCR and obligate funds required to carry out response activities.
What is role of a Q.I.?
- Have full authority to:
Activate and engage with OSROs
Liaison with FOSCR
Obligate funds required to carry out response activities.
How must the Q.I. be designated?
On a document in the FRP
He must know he/she is
154 Drill and exercise requirements?
- Qualified Individual Exercises (Quarterly) (EVERY 3MONTHS)
- Spill management team tabletop exercises (annually). In a 3 year period one must be a WCD.
- Equipment Deployment Exercises:
* Semiannually for facility owned equipment
* Annually for OSRO owned equipment
One shall be unannounced.
-Unannounced exercises, as directed by the COTP. (GUIE)
ALL RECORDS MUST BE MAINTAINED FOR 3 YEARS
What is the Exercise requirement for OSRO and Facilities owned response equipment?
33CFR154.1055
Facility Owned: Semi-annually
OSRO Owned: Annually
Is the facility responsible for exercising OSRO equipment along with their own response equipment?
Yes
If a facility participates in an CG initiated exercise, how long until we require a new exercise?
At least 3 years
If an OSRO is not classified as a CG OSRO (BOA Contract) what is required?
33CFR154.1028(a)
-A written contractual agreement with an oil spill removal organization.
- Certification by the facility owner or operator that specified personnel and equipment required under this subpart are owned, operated, or under the direct control of the facility owner or operator, and are available within stipulated response times in the specified geographic areas.
- Active membership in a local or regional oil spill removal organization that has identified specified personnel and equipment required under this subpart that are available to respond to a discharge within stipulated response times in the specified geographic areas
- A document which Identifies the personnel, equipment, and services capable of being provided by the oil spill removal organization within stipulated response times in the specified geographic areas.
VCS Applicability?
- Each facility that controls vapors emitted to or from vessel cargo tanks
- A vessel, other than a tank vessel, that has a vapor processing unit located onboard for recovery, destruction, or dispersion of vapors from a tank vessel’s cargo tanks
33CFR154.2000
Who can certify a VCS system?
33CFR154.804
Can the VCS Installer be a certifying entity?
33 CFR 154.804(i)
What regulatory manual holds information about the VCS and has a diagram?
–
Hose test records
154.740(c) date and result of most recent test or examination of hoses tested under 156.170(c)(1)(iii) - not burst, bulge, leak or abnormally distort under static liquid pressure of at least 1.5 the MAWP.
Test must be Annual or 30 days before the first transfer conducted past one year from the date of the last test and inspections
What site will you find hose testing requirements listed under?
156.170
156.170(c)(1)(iii) - not burst, bulge, leak or abnormally distort under static liquid pressure of at least 1.5 the MAWP.
Test must be Annual or 30 days before the first transfer conducted past one year from the date of the last test and inspections
If a hose is not used for 2 years, what requirements must be met in order for it to be reused?
156.170(f)(1)
It must be tested 30 days before the scheduled transfer
30 days before the first transfer conducted past one year from the date of the last test and inspections
