When a tank vessel with a capacity of 250 barrels is transferring oil to a facility, U.S. regulations require an emergency means to stopping the flow of oil. Where must these emergency means be operable from?
• Oil transfer operations requirements in 33 CFR (small tank vessel, about 250 barrels) • Role and definition of the person in charge (PIC) during oil transfers • Location from which the PIC actually controls/monitors the transfer under normal conditions
• During a transfer, where is the person who is legally responsible for the operation normally stationed? • Would regulations require the emergency shutdown to be operated from multiple spaces, or from the place where the transfer is actually controlled? • Think about which location allows the fastest and surest action by the responsible person if something goes wrong.
• Verify in 33 CFR Part 155 what it says about emergency means to stop the flow of oil for smaller tank vessels • Confirm what the regulation calls the "usual operating station" or normal control point for the person in charge • Check whether the rule explicitly requires multiple locations or only ties the control to the PIC’s operating position.
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