The OCIMF and IACS positions relating to secondary venting. An update.

David Savage SIRE Training and Development manager.

Secondary Venting
SOLAS International Convention for the Safety of Life at Sea Chapter II-2 Construction - Fire protection, fire detection and fire extinction Part C Suppression of fire Regulation 11 Structural integrity - 6 Protection of cargo tank structure against pressure or vacuum in tankers

6.3.2. Secondary means for pressure/vacuum relief A secondary means of allowing full flow relief of vapour, air or inert gas mixtures to prevent over-pressure or under-pressure in the event of failure of the arrangements in paragraph 6.1.2. Alternatively, pressure sensors may be fitted in each tank protected by the arrangement required in paragraph 6.1.2, with a monitoring system in the ships cargo control room or the position from which cargo operations are normally carried out. Such monitoring equipment shall also provide an alarm facility which is activated by detection of overpressure or under-pressure conditions within a tank.

The IACS position

Venting
IACS UI SC140 (October 1998) (Rev. 1 June 1999) (Rev. 2 Nov 2005)
Secondary Means of Venting Cargo Tanks (Reg. II-2/4.5.3.2.2 and Reg. II-2/11.6.3.2) 1. A P/V breaker fitted on the IG main may be utilised as the required secondary means of venting. 2. The height requirements of Reg. II-2/4.5.3.4.1 and 11.6.2 and the requirements for devices to prevent the passage of flame of Reg. II-2/4.5.3.3 are not applicable to the P/V breaker provided the settings are above those of the venting arrangements required by Reg. II-2/11.6.1. 3. Where the venting arrangements are of the free flow type and the masthead isolation valve is closed for the unloading condition, the IG systems will serve as the primary under pressure protection with the P/V breaker serving as the secondary means.

Secondary Venting
IACS UI SC140 (October 1998) (Rev. 1 June 1999) (Rev. 2 Nov 2005)

Secondary Means of Venting Cargo Tanks (Reg. II-2/4.5.3.2.2 and Reg. II-2/11.6.3.2) 4. Inadvertent closure or mechanical failure of the isolation valves required by SOLAS Reg. II-2/4.5.3.2.2 and the FSS Code, Ch. 15, 2.3.2.2 need not be considered in establishing the secondary means since: a) The valves are operated under the control of the responsible ships officer and a clear visual indication of the operational status of the valves is required by SOLAS Reg. II2/4.5.3.2.2, as amended, and b) The possibility of mechanical failure of the valves is remote due to their simplicity.

Some Incidents since 2001

2001 - ONWARDS - OVER PRESSURISATION INCIDENT
Vessel
KHANNUR KRONVIKEN GOLDEN DREAM

Date

Description of Incident

ASPHALT VICTORY VALLE DI CASTIGLIA R.M.K. 54 ALESSANDRO F

LOUGH FISHER BOW FORTUNE

Reported through Lloyds Hotline that vessel experienced overpressurisation of her cargo tank of LNG in No.4 tank 10-Sep-01 during discharging operation at everett, Boston. As a result some cracking was caused in the tank. Reported through Loyds Hotline that vessel sustained steel damage due to over pressurisation of the cargo tank 12-Feb-02 system, will require some 360 tonnes of steel renewals. It has been reported that the vessel had a cargo tank explosion due to over pressurization while N2 purging of cargo 26-Sep-02 tanks. Explosion occurred in No.3 cargo tank of asphalt tanker Asphalt Victory (17840 gt, built 1983), bound Providence, R.I., at 1424, local time, May 12, 50 miles south-east of Providence. Explosion caused by over-pressurisation of tank and 14-May-03 caused a rupture. Report received from MSINSPECT: Vessel had a condiiton of class which indicates vessel tank got overpressurised and 21-May-03 vessel structure suffered substantial deformity. Operators informed that M.T. "Serra Theresa", IMO 9254965, was involved in a tank expansion incident, due to 01-Jul-03 overpressurisation, during blow through of shore line after loading. From VIQ evaluation - Two conditions imposed to the class due to deformations, the second of these deformations, 12-Sep-03 between frames 72 and 78, was caused due to slight tank overpressure. From VIQ evaluation on 16th Sept 2003 - The vessel experienced an oil spill incident in March 2003 and as a result of shutting down incorrect valves with subsequent overpressurisation, some distortion the bulkheads, stringers and web 17-Sep-03 frame brackets . 03-Oct-03 From VIQ evaluation - Tank overpressurisation causing structural damage during a loading operation Unacceptable Sire report:

Some Incidents since 2001 (Continued)

Unacceptable Sire report: There was no class documentation available onboard concerning the repairs made following an over pressurization of No: 3 stb. cargo tank that occurred in August 2003. The vessel only had shipyard specifications. CHEMBULK HONGKONG 19-Jan-05 Incident w From SIRE evaluation It was noted on the ESP file on board Structural Condition Evaluation Report & Survey report files that the vessel had 03-Mar-05 carried out extensive repairs on tanks No 2 starboard during recent dry dock, due to over pressurization . 02-Apr-05 Spray (<1gal.water) of oil from hatch aft end of tk due to overpressurization 02-Apr-05 TKM over pressured system, gasket failed, < 2qt. Reported by Operator - Maersk Bering had an incident of overpressurisation of cargo tanks during loading operation whereby the deck tranverse girders on top of No. 5 cargo tanks have buckled and become deformed. The Maersk 17-Oct-05 Bering was loading Gas oil at time of incident. Loading LCO. A pressure surge/overpressurisation in the main cargo line ruptured an expansion bellows joint, with a spray of cargo on deck and overboard. Emergency shutdown activated. Crew mobilised to contain and clean up spill. 29-Nov-05 Quantity not established. Vessel loading HCO Slurry. Vessel suffered overpressurisation of No 3 stbd cargo tank, with level at about 60% full. No injuries, no pollution, no leakage to ballast tanks. Vessel sustained distortion of trunk and fracture of welding on 09-Mar-06 external supports. EMRUSH - mt Marisp had a cargospill during loading Hydro Crackate at Esso botlek. As per master vsl requested max loadrate of 1200 cbm/h, during cargospill loadrate was 1800 cbm/h which caused overpressure in tank. Cargospill 19-Jun-06 appr. 20 ltrs on deck / 1 lt in water. Reported by Baton Rouge Terminal - Bow Santos has experienced a tank breach (deck fracture) due to N2 24-Apr-07 overpressurization at BAYTANK terminal.

ERMAN S WEB222 S30 GUANGZHOU INTERNATIONAL

CAP CAMARGUE

FS SOLENE

MARISP BOW SANTOS

Secondary Venting What the VIQ 08 Edition says

OCIMF SIRE Vessel Inspection Questionnaire Inspector guidance 8.30 Are SOLAS secondary venting requirements being complied with? A secondary means of full flow relief of vapour, air or inert gas mixtures shall be provided to prevent overpressure or under-pressure in the event of failure of the primary venting arrangements. Alternatively, pressure sensors may be fitted in each tank protected by the primary venting arrangement with a monitoring system in the cargo control room or the position from which cargo operations are normally carried out. Such monitoring equipment shall also provide an alarm facility which is activated by detection of overpressure or under-pressure conditions within a tank. (SOLAS 2000 II-2/11.6.3.2) Note: Class societies may accept a system that may not comply with the SOLAS requirements for Secondary means of full flow relief.
In such cases the question should be answered No. A full description of the system as fitted should be made as an observation to allow an assessment of acceptability to be made.

Secondary Venting Inerted vessels

In the case of inerted vessels, if pressure sensors are provided as the means of secondary protection, the alarm settings for the pressure sensors must be set to actuate when the tank pressure reaches 10% greater than the normal actuation settings of the pressure valves themselves. In the case of the under-pressure settings, the pressure in a tank should never be permitted to fall below zero and the pressure sensors should be set to alarm above zero.

(Side note: The reason for the latter guidance on the vacuum side is because of the concerns relating to pyrophoric ignition in inerted tanks with the introduction of air. In the event that the IG pressure falls to <50mm/WG, the fans will stop and trip the cargo pumps.)

Secondary Venting non-inerted tanks

In the case of non-inerted vessels If pressure sensors are provided, the overpressure setting should be set to alarm at 10% greater than the normal actuation settings of the pressure valves, and at a vacuum 10% greater than the normal actuation settings of the vacuum valves. In all cases, a description of the secondary venting arrangements should be provided, in particular what vents or pressure/vacuum sensing systems are available on each tank when the main inlet valve to IG/vent main is shut. Where electronic pressure/vacuum sensors are provided, identify and record whether the alarms are set to operate at the correct value or some other value.

Secondary Venting VRS Operations

VIQ 8.59 (C) If the vessel is operating with a vapour return line connected, are appropriate transfer procedures in place? Vessels equipped with vapour collection systems must be fitted with a pressure sensing device that senses the pressure in the main vapour collection line, which: (a) Has a pressure indicator located on the vessel where the cargo transfer is controlled; and (b) Has a high pressure and a low pressure alarm that: (1) Is audible and visible on the vessel where cargo transfer is controlled; (2) Alarms at a high pressure of not more than 90 percent of the lowest pressure relief valve setting in the cargo tank venting system; and (3) Alarms at a low pressure of not less than four inches water gauge (0.144 psig) for an inerted tankship, or the lowest vacuum relief valve setting in the cargo tank venting system for a non-inerted tankship. (CFR 46 39.20-13)

Secondary Venting VRS Operations

Note: Particular attention should be paid to monitoring the pressure in the cargo tanks and the associated line system. P/v valves, the ullaging system and the level alarms should have been thoroughly tested prior to the transfer commencing and there should be awareness of the initial transfer rate and maximum allowable transfer rates.

Secondary Venting
Typical OCIMF Member chartering requirements Cargo tank venting MUST be through approved systems that expel vapours clear of the tank deck area in accordance with ISGOTT. It is strongly preferred that the secondary means of providing protection against tank over/under pressurisation be provided by full flow independent P/V valves and/or pressure monitoring system fitted to each tank. These full flow P/V valves should be so fitted that they cannot be isolated from the tanks they protect and should be capable of allowing sufficient volume of gas to prevent damage at the tanks maximum loading/discharge rates.

SOLAS Reg. II-2/4.5.3.2.2 and Reg. II-2/11.6.1

5.3.2.2. Where the arrangements are combined with other cargo tanks, either stop valves or other acceptable means shall be provided to isolate each cargo tank. Where stop valves are fitted, they shall be provided with locking arrangements which shall be under the control of the responsible ships officer. There shall be a clear visual indication of the operational status of the valves or other acceptable means. Where tanks have been isolated, it shall be ensured that relevant isolating valves are opened before cargo loading or ballasting or discharging of those tanks is commenced. Any isolation must continue to permit the flow caused by thermal variations in a cargo tank in accordance with regulation 11.6.1.1.

6.1. General The venting arrangements shall be so designed and operated as to ensure that neither pressure nor vacuum in cargo tanks shall exceed design parameters and be such as to provide for: .1. the flow of the small volumes of vapour, air or inert gas mixtures caused by thermal variations in a cargo tank in all cases through pressure/vacuum valves; and

.2. the passage of large volumes of vapour, air or inert gas mixtures during cargo loading and ballasting, or during discharging. 6.2. Openings for small flow by thermal variations . Openings for pressure release required by paragraph 6.1.1 shall: .1. have as great a height as is practicable above the cargo tank deck to obtain maximum dispersal of flammable vapours, but in no case less than 2 m above the cargo tank deck; and

.2. be arranged at the furthest distance practicable but not less than 5 m from the nearest air intakes and openings to enclosed spaces containing a source of ignition and from deck machinery and equipment which may constitute an ignition hazard. Anchor windlass and chain locker openings constitute an ignition hazard.

6.3. Safety measures in cargo tanks 6.3.1 Preventive measures against liquid rising in the venting system. Provisions shall be made to guard against liquid rising in the venting system to a height which would exceed the design head of cargo tanks. This shall be accomplished by high-level alarms or overflow control systems or other equivalent means, together with independent gauging devices and cargo tank filling procedures. For the purposes of this regulation, spill valves are not considered equivalent to an overflow system.

6.3.2. Secondary means for pressure/vacuum relief A secondary means of allowing full flow relief of vapour, air or inert gas mixtures to prevent over-pressure or under-pressure in the event of failure of the arrangements in paragraph 6.1.2. Alternatively, pressure sensors may be fitted in each tank protected by the arrangement required in paragraph 6.1.2, with a monitoring system in the ships cargo control room or the position from which cargo operations are normally carried out. Such monitoring equipment shall also provide an alarm facility which is activated by detection of over-pressure or under-pressure conditions within a tank.

6.3.3. Bypasses in vent mains . Pressure/vacuum valves required by paragraph 6.1.1 may be provided with a bypass arrangement when they are located in a vent main or masthead riser. Where such an arrangement is provided there shall be suitable indicators to show whether the bypass is open or closed.

6.3.4. Pressure/vacuum-breaking devices . One or more pressure/vacuum-breaking devices shall be provided to prevent the cargo tanks from being subject to: .1. a positive pressure, in excess of the test pressure of the cargo tank, if the cargo were to be loaded at the maximum rated capacity and all other outlets are left shut; and .2. a negative pressure in excess of 700 mm water gauge if cargo were to be discharged at the maximum rated capacity of the cargo pumps and the inert gas blowers were to fail.

 Such devices shall be installed on the inert gas main unless they are installed in the venting system required by Regulation 4.5.3.1or on individual cargo tanks. The location and design of the devices shall be in accordance with Regulation 4.5.3 and paragraph 6.

All very well, but ask yourself this basic question...

What protection does the tank have if this valve is shut?

The extent of the problem today

Analysis of the SIRE database (>6,000 vessels) shows approximately 5% (approx 300 reports) No responses to Q8.30