Challenge

Customer currently owns a fixed based Vapor Combustion Unit (VCU) to control emissions during their barge loading operations subject to US Coast Guard 46 CFR Part 39 — Vapor Control Systems. The equipment is becoming outdated with components that are nearing the end of their service life. If the VCU fails unexpectedly, the facility would have no means of vapor control. Without an operational vapor control system, barge loading would be halted, resulting in product movement delays. The vapor control from ship and barge loading is regulated under 33 CFR 154 Subpart P Marine Vapor Control Systems. (https://www.ecfr.gov/current/title-33/chapter-I/subchapter-O/part-154/subpart-P)

 

Solution

In anticipation of potential failures with the customer’s VCU, Envent supplied a temporary system including an US Coast Guard certified according to 46 CFR Part 39 – Envent Dock Safety Unit (EDSU) and Envent Mobile Emissions Control System (EMECS). The system was fully tested, including interlocks and safety controls. A test load was conducted under the supervision of a Coast Guard certifying entity. This on-site demonstration allowed the certifying entity to approve the temporary Marine Vapor Control System (MVCS) for a five-year period.

 

Benefit

By receiving the 5 year certification for the temporary MVCS with the EDSU enrichment skid and EMECS thermal oxidizer, the customer gained a reliable, fully certified vapor control solution in order to mitigate the risk of downtime from their aging VCU. The system maintains compliance safely and effectively by enriching and destroying VOCs with a destruction rate efficiency of 99.99%. This ensures continuous, barge loading operations in compliance and prevents any potential delays with transporting liquid product.