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68 Spring 2019 manual details transfer operations and spill, testing, and safety procedures, which are required for each certifi cation or recertifi cation. During the operational review, the certifying entity will review all applicable documentation, including: Operating guidelines and operating manual. Facility plans. Piping and instrumentation diagrams. Process calculations and product properties. Specifications for instrumentation and equipment. Cause-and-effect diagrams. Control narratives. Qualitative failure analysis (QFA). In addition to the documentation review, the certifi cation entity reviews all technical properties of the products handled and the enriching, inerting and diluting systems. A critical piece of documentation is the QFA, which includes a report of all plausible disaster scenarios and safeguards for each. The QFA also verifi es that all required safeguards listed in Part 154 are in place and functioning properly. The QFA must demonstrate that the vapour control system (VCS) can operate safely and continuously and has all the proper alarms and automatic shutdowns to prevent unsafe operation and to minimise damage if an accident were to occur. Owners and operators, or third-party consultants authorised to act on their behalf, must complete the QFA to identify potential compliance issues well in advance of the offi cial operational review. In completing the QFA, the loading process must be walked through and documented from start to fi nish. Dry test runs of the logic as well as detailed documentation reviews are necessary prior to the loading operation with the certifying entity to ensure that the loading operations and associated safety systems function properly. In addition to mechanical and control system documentation, the certifying entity also reviews training procedures and record keeping to verify compliance with USCG safety regulations. After reviewing all documentation, the certifying entity will visit the facility to observe a loading operation to confi rm that the maximum certifi ed loading rate is being observed and that all safety shutdowns and alarms are in place and working properly. The onsite certifying entity review will: Verify that the actual built system matches engineering design plans. Ensure that maximum vacuum levels are not exceeded. Verify that vacuum breakers are in proper working order. Observe all normal start-up, operational and shutdown procedures. Observe a dry test and wet test. Ensure that the liquid emergency shutdown valves operate properly. As facility owners and operators must ensure that all required documentation is on hand and easily accessible, pre-reviewing these required steps with a third-party consultant may be benefi cial in preventing issues that otherwise would be uncovered by the certifying entity. The consultant can serve as the asset owner's primary point of contact with the certifi cation entity. Other steps can be taken to audit and prepare documentation and conduct onsite testing to prepare staff for the offi cial review. Finally, the consultant can be authorised to facilitate the onsite review with the certifi cation entity. This process can take anywhere from a few weeks to a few months, depending on the level of complexity of the system and the amount of pre-reviews conducted by the certifying entity. Achieving efficient recertification For facilities or assets that were built and certifi ed prior to 2013, the updated safety regulations may require some physical modifi cation for compliance. Additionally, any changes made beyond replace-in-kind to an operating system must be recertifi ed before the facility is allowed to resume operations. This is another step that may justify the investment in a third-party consultant. The scope of this assignment would be to identify, quantify and document mechanical and control system changes, as well as any downstream effects, to support the recertifi cation process. Some of these changes might include alterations to valve or mechanical system confi gurations as well as control confi gurations and safety systems. Other changes may include handling new products, making system modifi cations not directly correlated to facility equipment, or expanding loading profi les to include new product types, new vessel types or multi-breasted barge loading. Conducting an initial evaluation of changes being made with the certifying entity is highly recommended. This step will help determine whether changes qualify as replace-in-kind or will change the system and require it to comply with the new regulations. Onsite testing dry runs are essential to successful operational reviews during the recertifi cation process. If a third-party consultant is involved, these dry runs should include onsite reviews to verify that operations match documentation and to simulate loading and safety shutdown test scenarios. Certifying new facilities Greenfi eld facilities must comply with all requirements listed in 33 CFR 154 Subpart P, and compliance begins at the design stage. It is critical for the design engineer and all equipment manufacturers to understand detailed requirements and verify that they are met. It is imperative that the design engineer and the certifi cation entity remain autonomous to protect the integrity of the certifi cation process. The certifi cation entity cannot be involved in the design of the system or conduct the QFA. If an additional consulting engineer is engaged to oversee certifi cation processes, it will be critical for that additional engineer to also work closely with the design engineer and equipment manufacturers to ensure that shop and factory testing of equipment is conducted prior to arrival and installation at the facility. For example, the vapour collection system must be equipped with a remotely operated cargo vapour shutoff valve with position indication that closes within 30 sec. of a shutdown event, or if the signal or power is interrupted. A manual shutoff value must also be provided. It is strongly

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