1. Update on CTAC VCS Subcommittee
Jon Young/Ashley Castle
October 5, 2017

2. Task # 15-01 Title: Marine VCS Program Review & Update Task List:
Update CE Guidance
Draft recommendations to supplement the publication and implementation of the final rule.

3. Background on Tasks
The first Marine Vapor Control System (VCS) regulations were published in 1990.
New VCS Final Rules (33 CFR 154 Subpart P) were published July 2013.
Subpart P became effective for all Marine VCS on August 15, 2016.
The Subpart P regulations reduced the number of exemption requests and clarified many Subpart E issues, but many new questions arose.

4. Background on Tasks 1
In October 1991, a Certifying Entity guidance document was published for Subpart E; this document was not updated for Subpart P.
CG-ENG-5 requested CTAC to review and update the guidance document for Subpart P.
At the March 2017 meeting, the VCS subcommittee submitted a revised CE guidance document to CTAC covering approximately 95% of the subpart P regulations.

5. Background on Task 2
Due to a large volume of exemptions and alternate compliance requests, CG-ENG-5 requested CTAC make recommendations on the most common requests.
A final report was approved by CTAC in March 2016, and resulted in CG-ENG Policy Letter (PL 02-16).
A final report was approved by CTAC in March 2017 for the criteria for acceptable anti-flashback burners to supplement PL
PL only addressed 2 of the 3 recommendations. The recommendation not addressed in the PL deals with the Pressure Relief Valve (PRV) Settings.

6. VCS Subcommittee Activities
CTAC October 2017 (Task 1 and 2)
Final Report for the certifying entity guidelines addressing the remaining 5% of the regulations including alkylene oxides and pyrophoric iron sulfides.
Revisited the pressure relief valve recommendations submitted to CTAC in March 2016.
Identified Regulatory Reform items:
Recommended Regulatory Reforms include items in PL (result of March 2016 report from CTAC).
Other Recommended Regulatory Reform items: alkylene oxides, pressure relief set point and mobile vapor control systems. Subcommittee to develop regulatory reform submittals after October 2017 meeting

7. VCS Subcommittee Remaining Tasks
Draft recommendations to supplement the publication and implementation of the final rule.
33 CFR , referenced by 33 CFR154 Subpart P, Emergency cargo shutoff valves
Assist CG-ENG-5 with development of policy letter reflecting CE guidance.
Submit regulatory reform questionnaire for alkylene oxides, mobile vapor control systems, inclusion of Policy Letter 02-16, and the pressure relief valve settings.