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OSHA 33 CFR 155.780 - Emergency Shutdown

OSHA 33 CFR 155.780 - Emergency Shutdown

(OP)
We have ULSD being imported into the terminal. Does this fall under the definitoin of an oil product since it is a "refined product?"

33 CFR 151.05 - Definitions
“Oil” means petroleum whether in solid, semi-solid, emulsified, or liquid form, including but not limited to, crude oil, fuel oil, sludge, oil refuse, oil residue, and refined products, and, without limiting the generality of the foregoing, includes the substances listed in Appendix I of Annex I of MARPOL. “Oil” does not include animal and vegetable based oil or noxious liquid substances (NLS) designated under Annex II of MARPOL.

If this section applies, does that mean that we must have a means of emergency shut off (i.e. ESD valve), or can we use some other means (i.e. manual valve) for this sort of thing? Does this apply to the vessel or to the terminal, or possibly both?

33 CFR § 155.780 Emergency shutdown
(a) A tank vessel with a capacity of 250 or more barrels that is carrying oil or hazardous material as cargo must have on board an emergency means to enable the person in charge of a transfer operation to a facility, to another vessel, or within the vessel to stop the flow of oil or hazardous material.
(b) The means to stop the flow may be a pump control, a quick-acting, power actuated valve, or an operating procedure. If an emergency pump control is used, it must stop the flow of oil or hazardous material if the oil or hazardous material could siphon through the stopped pump.
(c) The means to stop the flow must be operable from the cargo deck, cargo control room, or the usual operating station of the person in charge of the transfer operation.

RE: OSHA 33 CFR 155.780 - Emergency Shutdown

Certainly sounds (and feels) like it counts as "Oil", and not having a good way to limit a developing diesel spill is a recipe for future uncomfortable discussions with the authorities.

Have you looked at the scope of the "or an operating procedure" option?

A.

RE: OSHA 33 CFR 155.780 - Emergency Shutdown

(OP)
It seems to me that so long as an operator, with a radio, is standing next to the valve at the dock, then we can meet this criteria. Thoughts?

RE: OSHA 33 CFR 155.780 - Emergency Shutdown

Diesel fuel is considered an oil so the terminal better have an SPCC that includes emergency shutoff procedures.

RE: OSHA 33 CFR 155.780 - Emergency Shutdown

I think the requirement and responsibility fall on the vessel which is offloading the product to control and stop the flow in an emergency. As the receiver, I agree it falls under your SPCC plan for receiving product from a vessel.
Always have a plan: what could go wrong, and what can I do if it happens?

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