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MARINE SAFETY ADVISORY NO. 23-11 To: Subject: Date: Regional Marine Safety Offices, Nautical Inspectors, Masters, Owners/Agents HYDROSTATIC TESTING OF BUNKER LINES -- CLARIFICATIONS 14 March 2011
On 9 March 2011, the Administrator advised its vessels in Marine Safety Advisory (MSA) No. 21-11 of a United States Coast Guard (USCG) Bulletin (18 February 2011) regarding Hydrostatic Testing of Bunker Lines. The USCG bulletin has raised many questions and, as a result, we are issuing this MSA in an attempt to answer them. The hydrostatic testing requirements stem from Title 33, Part 156 the United States Code of Federal Regulations (CFR). Although the USCG is focusing on the hydrostatic testing of bunker lines, it is important to understand that: The requirement for the testing of nonmetallic hoses (e.g., bunker lines) applies to the transfer of oil or hazardous materials to, from or within each vessel (in U.S. navigable waters or contiguous zone) with a capacity of 250 barrels or more. See 33 CFR 156.100. Testing must be accomplished annually or as part of the biennial and mid-period inspections. See 156.170(f)(3). The type of testing required by 33 CFR 156.170(c)(1)(iii) and (iv) is static liquid pressure testing. Testing with air is not acceptable. Recordkeeping is required under 33 CFR 155.820.
For your reference, the relevant USCG regulations are provided in Appendix I of this MSA. The Administrator has been asked about the testing of bunker barge hoses. Vessels are required to test their own hoses. This applies to bunker barges as well. If one doesnt have ownership/control of the hoses then its not theirs to test. Lastly, it is our understanding that it is not only USCG Sector New Orleans that is inspecting for the proper testing of bunker lines. Apparently, all USCG Sectors are focusing on this issue as a result of the Bulletin from Sector New Orleans.
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156.100 Applicability.
This subpart applies to the transfer of oil or hazardous material on the navigable waters or contiguous zone of the United States to, from, or within each vessel with a capacity of 250 barrels or more; except that, this subpart does not apply to transfer operations within a public vessel.
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(3) For vessels, annually or as part of the biennial and mid-period inspections. (g) If a facility or vessel collects vapor emitted from a vessel cargo tank with a vapor control system, the system must not be used unless the following tests and inspections are satisfactorily completed: (1) Each vapor hose, vapor collection arm, pressure or vacuum relief valve, and pressure sensor is tested and inspected in accordance with paragraphs (b), (c), and (f) of this section; (2) Each remote operating or indicating device is tested for proper operation in accordance with paragraph (f) of this section; (3) Each detonation arrester required by 154.820, 154.826(a), and 154.828(a) of this chapter or 46 CFR 39.403(d), and each flame arrester required by 154.826(a), 154.828 (a) and (c) of this chapter has been inspected internally within the last year, or sooner if operational experience has shown that frequent clogging or rapid deterioration is likely; and (4) Each hydrocarbon and oxygen analyzer required by 154.820(a) and 154.824 (d) and (e) of this chapter or 46 CFR 39.403(a) is calibrated: (i) Within the previous two weeks, or (ii) Within 24 hours prior to operation when the vapor control system is operated less frequently than once a week. (h) Upon the request of the owner or operator, the COTP may approve alternative methods of compliance to the testing requirements of paragraph (c) of this section if the COTP determines that the alternative methods provide an equal level of protection. (Approved by the Office of Management and Budget under control number 16250095) [CGD 75124, 45 FR 7177, Jan. 31, 1980, as amended by CGD 88102, 55 FR 25445, June 21, 1990; CGD 86034, 55 FR 36256, Sept. 4, 1990; CGD 93056, 61 FR 41461, Aug. 8, 1996; USCG200625150, 71 FR 39210, July 12, 2006]
155.820 Records.
The vessel operator shall keep a written record available for inspection by the COTP or OCMI of: (a) The name of each person currently designated as a person in charge of transfer operations. (b) The date and result of the most recent test and inspection of each item tested or inspected as required by 156.170 of this chapter; (c) The hose information required by 154.500(e) and (g) of this chapter unless that information is marked on the hose; and (d) The Declaration of Inspection as required by 156.150(f) of this chapter. [CGD 75124, 45 FR 7175, Jan. 31, 1980, as amended by CGD 86034, 55 FR 36255, Sept. 4, 1990]
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