USCG Marine Safety Manual, Vol.

II: Materiel Inspection

SECTION C: INSPECTION OF ENGINEERING SYSTEMS, EQUIPMENT, AND MATERIALS
CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

A. INTRODUCTION

1. Background Fire and explosion are among the greatest threats to the mariner; a tankship carrying
crude oil, refined petroleum, or chemicals is an even greater threat. Fortunately, a
properly designed, installed, operating, and maintained inert gas system (IGS) will
completely prevent fire and explosion in an intact ship tank. Combustion is impossible
without oxygen; if there is some way to keep the oxygen below about 8 percent, the ship
will be free of danger from explosions in intact tanks. Typically, this is done by adding to
the tank atmosphere a gas that has less oxygen (often 5 percent or less) than air, which
has an oxygen concentration of 21 percent. Of course, when a tank is opened, as in a
collision, oxygen can enter the tank regardless of the IGS. In the 1920's and 1930's, one
American petroleum company suffered several tankship fires and decided to inert the
cargo tanks of its ships. Reportedly, its vessels have not had any intact cargo tank fires
since that time. Since the late 1970's, inerting has been required for most U.S. and
foreign tankships. As of 1 June 1983, inert gas (IG) systems are required aboard all U.S.
crude oil carriers over 20,000 deadweight tons (DWT) and all U.S. product carriers over
40,000 DWT. While in U.S. waters, foreign tankships of the same size must have IG
systems in operation. For the purpose of the IGS regulations, integrated tugbarge (ITB)
combinations that operate only in a combined mode are subject to the tankship rules for
IG systems.

NOTE: In addition, for chemical tankers and gas carriers the applicability of
alternate inerting requirements as allowed by SOLAS Regulation II-2/55.5
were adopted in 1985 through the International Maritime Organization (IMO)
Assembly Resolution.

2. References There are several good references in addition to 46 CFR 32.53 and Regulation 62 of
SOLAS 1974/78. Commandant's International Technical Series (CITS) Volume VII
(USCG CITS8011), "Regulations and Guidelines for Inert Gas Systems," contains the
SOLAS requirements, the IMO Guidelines For Inert Gas Systems, and the National
Academy of Sciences National Materials Advisory Board Study on Material Aspects of
Inert Gas Systems.

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SECTION C: INSPECTION OF ENGINEERING SYSTEMS, EQUIPMENT, AND MATERIALS
CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

3. Federal In the mid1970's, a series of tankship accidents led to the International Conference on
Initiatives Tanker Safety and Pollution Prevention (TSPP) of 1978 and the passage of the Port and
Tanker Safety Act of 1978 (PTSA). A major result of these initiatives is that most U.S.
and foreign tank vessels are required to have IG systems in operation while they are in
U.S. waters. The Coast Guard's IGS regulations are contained in 46 CFR 32.53 (Inert
Gas Systems); international rules are contained in Chapter II2, Regulation 62 (Inert Gas
Systems) of the International Convention for the Safety of Life at Sea (SOLAS), 1974.
The first set of amendments to SOLAS 74 were adopted and came into force on 1
September 1984; under them, a ship must satisfy applicable requirements to receive a
SOLAS Safety Certificate. The second set of amendments to SOLAS 74 come into effect
on 1 July 1986; they have only a minor effect on the IGS requirements. The Coast Guard
is developing changes to 46 CFR 32.53 to bring U.S. requirements into line with both
sets of amendments to SOLAS.

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SECTION C: INSPECTION OF ENGINEERING SYSTEMS, EQUIPMENT, AND MATERIALS
CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

B. SYSTEM CONCEPTS

1. Reasons for The "fire triangle" provides the basis to consider fire prevention techniques on tankships.
Inerting It would not be practical to remove the fuel, which in this regard is the vapor generated
Systems by the cargo. Unless the cargo is Grade E and carried at a temperature at least 5C below
its flash point (in which case there are no inert gas requirements), the cargo is volatile
enough to produce a flammable vaporair mixture above the fuel. After the cargo is
offloaded, unless the tank is gasfreed and cleaned of all residue and clingage on its
surfaces, a flammable atmosphere can be expected. If all ignition sources could be
eliminated, so would all chances for a fire. However, conditions such as lightning and
electrostatic fields generated during tank washing and heavy seas in partially ballasted
tanks will always be present as ignition sources. Hence, there is really no practical
alternative to inerting cargo tanks.

2. Means of
Inerting
Cargo Tanks

Introduction a. Introduction. There are several ways to inert a tank. The simplest would be
to add a pure nonflammable gas, such as nitrogen or carbon dioxide, to the
tank atmosphere. Unfortunately, these pure gases tend to be expensive, the
costs of their storage aboard ship tend to be high, and re-supply in some
ports is difficult. Thus, most "inerted" ships use the gases from a fuel burner,
from the ship's propulsion equipment (flue gas), or from a unit dedicated to
producing inerting gas (an inert gas generator (IGG)). The following general
description of an IGS includes components that may vary, depending upon
the manufacturer.

Use of Combustion b. Use of Combustion Gases. Use of combustion gases as the inerting medium
Gases proves advantageous due to its availability as needed and much lower cost,
if sufficient fuel and properly adjusted and operated equipment is provided.
Its disadvantage is that the raw combustion gases are impure and must be
treated before use in the cargo tanks. This is especially important for product
carriers, in which cargo purity is critical and some cargoes may react with
impurities in the inert gases. Each IGS has several components intended to
remove these impurities. For example, sulfur in the fuel appears in the inert
gas in the form of sulfur oxides, sulfurous acid, and sulfuric acid. If not
removed, they will attack the metal of the tank and gradually destroy it.
Passing the inert gas through a waterfilled device called a scrubber removes
most of these acids (see paragraph MSM II-C5.C.2 below).

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SECTION C: INSPECTION OF ENGINEERING SYSTEMS, EQUIPMENT, AND MATERIALS
CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

Gas Distribution c. Gas Distribution. When the inert gas is clean, cool, and waterfree, it is
pressurized and sent to the various cargo tanks. The distribution system
contains backflow prevention devices, control valves, alarms, and automatic
shutdowns. These alert personnel to a malfunction and, when necessary,
shut down the system before a dangerous condition is developed in the
tanks. Such conditions involve the oxygen concentration, the temperature
and pressure of the inert gas, the water flow to and water level within the
scrubber, and the backflow prevention devices (water seals). Because IG
systems are complex and subject to malfunction, it is important for ships'
crews to inspect and maintain them in good working order. The Coast
Guard's inspections verify that they are properly maintained and operable.

3. Operation of
the System

Introduction a. Introduction. The purpose of an IG system is to keep the oxygen content of

the vapor space below the level needed for combustion. For crude carriers,
the oxygen content of the inert gas delivered to the cargo tanks should be no
more than 5 percent, to ensure that there is not enough oxygen in the tank to
support combustion.

NOTE: This figure may be lower for certain chemicals carried in product
carriers.

Operation b. Operation. 46 CFR 32.53 identifies which product/crude oil tankships must
be equipped with an IGS. (See MSM II-C5.B.4 for discussion of "Inerting
Requirements for Chemical Tankers and Gas Carriers.") For inerting
purposes, oil cargoes are those cargoes identified as pollution category I in
46 CFR Table 30.25-1. Note: These cargoes may be different from what is
considered to be oil for the application of Oil Pollution Act of 1990
requirements.) Questions have arisen concerning when an installed IGS
must be operated, especially when a tanker is carrying a cargo that is not
otherwise required to be inerted. While the requirements are clear,
questions have arisen concerning when an installed IGS must be operated,
especially when a tanker is carrying a cargo that is not otherwise required to
be inerted. Normally, confusion arises concerning existing crude/product
carriers between 20-40,000 DWT and vessels carrying only Grade E liquid
cargoes. Generally, vessels required to have an installed IGS must maintain
an inert atmosphere in the tanks whenever they are not gas free. However,
when an IGS equipped tanker is carrying a cargo that is not required to be
inerted and the tank, piping and venting conditions are functionally equivalent
to a non-IGS tanker, the system may be secured at the operator's option.
Table 15-1 summarizes the tanker categories that are required to have an
installed IGS and the conditions whereby the system may be secured. On
tankers that are required to maintain an inert tank atmosphere,

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CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

it is not necessary for the IGS to be operated continuously. Once a tank is

inerted and the tank openings closed and sealed, inert gas will leak out of the
tank at such a small rate that the IGS may need to be operated only
intermittently to maintain the inert tank atmosphere.

Requirements c. Requirements During Transfer and Tank Cleaning Operations. Offloading

During Transfer cargo is one of the few conditions under which the IGS must be in
and Tank Cleaning continuous operation. As the cargo is pumped out, inert gas must be
Operations introduced at an equal or greater volume rate, with excess inert gas flow
vented to the atmosphere; if this is not done, air will enter the tank. Loading
usually requires no additional inert gas if the tank is already inerted; the
incoming cargo will displace the inert gas in the tank, which is then vented.
Similarly, tank cleaning with fixed washing machines should not let inert gas
escape. Cleaning with portable machines, if done with proper temporary
seals around the machines, should release only a small amount of inert gas
(requiring the IGS to operate for a short period to replace the gas that
escapes). To gasfree an empty, clean tank, the IGS can be used to purge
the tank free of hazardous vapors. Before loading a flammable cargo into a
gasfree tank, the tank should be filled with an inert gas.

4. Inerting In considering the application of IGS requirements to chemical tankers, it was argued
Requirements that this type of tanker should be given special consideration. This is primarily because
for Chemical both the inert gas from shipboard IGS and impurities in the inert gas can contaminate
Tankers and chemical cargoes. For example, the carbon dioxide produced as an inerting agent can
Gas Carriers drive certain cargoes off specification. Additionally, there are other chemical cargoes
that are shipped with inhibitors that react with the oxygen in the tank to prevent the cargo
from undergoing unwanted reactions. Therefore, the displacement of oxygen through
inerting by any means (bottled nitrogen, inert gas generator, flue gas systems, etc.) can
cause breakdown of inhibitors used to prevent these reactions.

Since the implementation of the 1993 Amendments to SOLAS ’74, Regulation II-2/55.5
has allowed for substitute inerting requirements to be applied to chemical tankers and
gas carriers in lieu of the requirements in Regulation II-2/60. These substitute
requirements are contained in Res. A.473(XII), adopted on 19 November 1981. They
apply to chemical tankers and gas carriers carrying petroleum products only.

The inert gas applicability requirements set out in Regulation II-2/55.5 are further
modified by Res. A.566(14). In addition to the substitute requirements of Res.
A.473(XII), Res. A.567(14). Adopter on 20 November 1985. This extends the
applicability of substitute inerting requirements to the carriage of all flammable cargoes
on board chemical tankers and gas carriers. Res. A.566(14) also prescribes the
conditions under which no inerting is required.

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CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

Implementation a. Implementation. Res. A. 566(14) applies only to chemical tankers and gas
carriers, which would otherwise be subject to the IGS requirements of 46
CFR, 32.53 and SOLAS Regulation II-2/60 for tankers carrying crude oil and
petroleum products. These include all “new” chemical tankers and gas
carriers of 20,000 deadweight tons or more, as well as, those “existing”
vessels of 40,000 deadweight tons or more, but less than 40,000 deadweight
tons if fitted with tank washing machines having an individual throughput of
greater than 60 cubic meters per hour. The dates distinguishing “new” from
“existing” for the purpose of applying IGS requirements are contained in 46
USC 3701 and the 1978 protocol to SOLAS ’74. For easy reference, those
dates are included in this circular as Note 2 of enclosure (1).

b. After establishing that the IGS requirements for tankers carrying crude oil
Verify Vessel Type
and petroleum products would otherwise apply, it must be confirmed that the
(e.g., Gas, Chemical
ship in question is a chemical tanker or gas carrier. As evidence a vessel
Petroleum, Crude)
meets the applicable definition, it must be in possession of a valid Certificate
of Inspection (COI) (U.S. flag) or IMO Certificate of Fitness (foreign flag)
endorsed for the carriage of at least one cargo appearing in the
Tables/Chapters specified in the definition. For example, a U.S. flag tanker
in possession of a valid COI, endorsed for the carriage of any cargo listed in
Table 1 of 46 CFR 153, is considered to be a chemical tanker.

Identification of c. Next, each flammable cargo to be carried must be considered individually to

Cargo IG Need determine the inerting requirements applicable to the tank in which the cargo
is being carried. The flammable cargoes should be divided into the following
three categories:

 Crude oil;
 Petroleum products; and
 “Other than crude oil or petroleum products.”

NOTE: Flammable cargoes “other than crude oil or petroleum products” are
those listed in Table 1 of 46 CFR 153, Chapters VI or VII of the BCH Code,
or Chapters 17 or 18 of the IBC Code. The cargoes listed in Table 1 of 46
CFR 153 closely parallel those listed in Chapter VI of the BCH Code and
Chapter 17 of the IBC Code. There is no listing in U.S. regulations parallel to
Chapter VII and 18 are identical); however, many of those cargoes are listed
in 46 CFR 30.25-1.

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CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

d. For chemical tankers and gas carriers carrying flammable cargoes “other
than crude oil or petroleum products, “ there are no inerting requirements
provided the vessel was constructed before 1 July 1986. If the vessel was
constructed on or after 1 July 1986, no inerting is required provided the
following conditions are met:

 The individual tank(s) involved do not have a capacity exceeding 3000

m3;
 The individual nozzle capacities of the tank washing machines do not
exceed 17.5 m3/hr; and
 The total throughput for all the machines in use in a tank does not
exceed 110 m3/hr.

For all chemical tankers carrying flammable crude oil or petroleum products,
the IGS requirements of Res. A. 567(14) apply. If a chemical tanker was
constructed before 1 July 1986, the IGS requirements of Res. A.473(XII)
may be substituted for those in Res. A.567(14). The same requirements as
included in this paragraph for chemical tankers or an equivalent should be
applied to gas carriers when carrying flammable crude oil or petroleum
products.

There may be instances when a flammable cargo which is not crude oil or a
petroleum product also is not listed in 46 CFR 153, the BCH Code, or the
IBC Code. This is most likely to occur when a new chemical is marketed and
first transported. In situations such as this or any other time there is
uncertainty regarding the inerting requirements for a particular cargo carried
on board a chemical tanker or gas carrier, Commandant (G-MOC, 202-267-
1464) should be consulted.

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CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

TABLE C5-1: INSTALLATION & OPERATION REQUIREMENTS FOR INERT GAS SYSTEM (IGS) 1,2
VESSEL TYPE INSTALLATION REQUIRED? OPERATION REQUIRED?
Crude Oil Tankships
Existing ships3,4 Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
All cargo grades
New ships All cargo grades Yes for ships Yes for ships
Product Tankships
Existing ships3 Yes for ships 40,000 DWT & over Yes for ships
Grades A-D
40,000 DWT & over No No
Grade E5 Design limited
Operationally limited: No volatile Yes for ships 40,000 DWT & over No
residues from previous voyages 6,7,9
Volatile residues from previous Yes for ships 40,000 DWT & over Yes for ships 40,000 DWT & over
voyages
Any grade with high capacity Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
washing machines (exceeding 60
cubic meters/hour)
New ships
Grades A-D Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
Grade E5
Design limited No No
Operationally limited:
No volatile residues from previous Yes for ships 20,000 DWT & over No
voyages6,7,9
Volatile residues from previous Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
voyages
Crude Oil/Product Tankships 8: Existing ships3,4
Grades A-E crude oil Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
Grades A-D product 6,7
Yes for ships 20,000 DWT & over Yes for ships 40,000 DWT & over
Grade E5 product
Design limited No No
Operationally limited:
No volatile residues from previous Yes for ships 20,000 DWT & over No
voyages6,7,9
Volatile residues from previous Yes for ships 20,000 DWT & over Yes for ships 40,000 DWT & over
voyages
Any grade with high capacity Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
washing machines (exceeding 60
cubic meters/hour)

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TABLE C5-1: INSTALLATION AND OPERATION REQUIREMENTS FOR INERT GAST SYSTEM (IGS) 1,2 —
CONTINUED
VESSEL TYPE INSTALLATION REQUIRED? OPERATION REQUIRED?
Crude Oil/Product Tankships 8: New ships
Grades A-E crude oil Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
Grades A-D product Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
Grade E5 product
Design limited N/A N/A
Operationally limited:
No volatile residues from Yes for ships 20,000 DWT & over No
previous voyages6,7,9
Volatile residues from previous Yes for ships 20,000 DWT & over Yes for ships 20,000 DWT & over
voyages

NOTES:
1. This Table is based on the requirements of 46 CFR 32.53.
2. The requirements for U.S. flag ships (operating worldwide) and foreign flag ships (operating in U.S. ports) are
the same except as noted in footnote 8.
3. "New" and "Existing" tankers are defined in 46 U.S.C. 3701 (Contract date after June 1, 1979; in the absence
of a contract date, keel laying date after January 1, 1980; delivery after June 1, 1982.).
4. The U.S. and SOLAS regulations provide for inert gas exemptions for existing crude and crude/product carriers
in the range 20,000 to 40,000 DWT. However, the U.S. has not granted any exemptions to date for either U.S.
or foreign flag tankships, and U.S. does not recognize inert gas exemptions granted by foreign Administrations.
5. This entry applies to a Grade E cargo that is carried at a temperature lower than 5 degrees C below its closed
cup flashpoint. If it is heated to within 5 degrees C of its closed cup flashpoint, it is treated as if it were a Grade
A - D cargo for the purposes of the IGS system. Differentiation is made between tankers that are limited to
carriage of grade E cargoes by design and those that are capable of carrying more volatile cargoes but are
only engaged in Grade E trade (i.e., operationally limited). The intent is to ensure that tankers that are
operationally limited to Grade E cargoes are functionally equivalent to tankers that are limited by design to
Grade E. See Notes 6,7 & 9.
6. Note that where an inert gas system is installed but not operated, the inert gas main stop valve must be closed
and the inert gas blowers and inert gas generator, if any, secured.
7. In some venting system designs, when the IGS is not operating, the inert gas main can serve as a path for fire
and explosion to travel from one tank to another. Therefore if the tank venting system incorporates the inert
gas main and the tanks cannot be isolated from the inert gas main without risking over or under pressurizing
the tanks, the inert gas system must operate at all times.
8. Foreign flag crude/product tankships from 20,000 to 40,000 DWT that have received inert gas exemptions from
their Administration and that do not have inert gas systems installed may not carry crude oil in U.S. ports.
However, they may carry product in U.S. ports.
9. A tank is considered to be free of volatile residues from previous cargoes when it has been cleaned and gas
freed (safe for hot work) prior to loading the Grade E cargo. If the vessel shifts from the carriage of Grade D or
higher cargoes to the carriage of Grade E cargoes without gas freeing, the first Grade E cargo must be treated
as though it contained volatile residues. Subsequent Grade E cargoes need not be inerted provided the
requirements of footnote 5 are met.

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SECTION C: INSPECTION OF ENGINEERING SYSTEMS, EQUIPMENT, AND MATERIALS
CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

4. Problems of Potentially, there is one significant problem introduced by the IGS systems: creation of
Reactive pyrophoric iron sulfide. This solid chemical is formed at a very slow rate (building up over
Products a period of months or years) by the reaction of the iron in the cargo tank surface with the
sulfur compounds in the cargo. Iron sulfides react spontaneously and very rapidly with
oxygen in the air, giving off heat. In an uninerted tank, this is not a problem. Each time
that the tank is emptied (usually every few weeks), the iron sulfides react with the oxygen
before much of a deposit has formed; thus, there is no opportunity for a buildup. If the
tank is inerted, however, the tank surfaces may not be exposed to air for as long as 2 or
more years and the iron sulfide may build up. When suddenly exposed to air, it will react,
give off heat, and ignite any flammable vapors present. Although the International
Maritime Organization (IMO) is examining this problem, no definitive solution has been
found. A tankship should not be offloaded with an inoperative IGS because the process
results in large amounts of oxygen entering the tank. In such cases, an external source
of inerting gas should be used as a substitute for the inoperative system.

5. Basic IG systems are complex, and the marine inspector should invest the time to learn what
Inspection an IGS is, how it is designed, and how it can fail. Adding to this complexity is the fact that
Consider- there are numerous IGS designs in use today. These involve different methods of
ations producing inert gases, various ways to clean the gases themselves, and a vast number
of combinations of types and arrangements of valves and piping. The inert gas is either
treated flue gas from the ship's boilers or combustion gases from a separate, dedicated
IGG. The major difference between flue gases and products of an IGG is that the sulfur
oxide, sulfurous acid, and sulfuric acid concentrations are considerably lower when a low
sulfur fuel is burned in the IGG. Otherwise, the principles of unable to support
combustion operation, components, and general design are similar. Prior to inspecting an
installed IGS, the inspector must become familiar with the particular system he or she will
inspect, including a review of the manufacturer's instruction manual and the ship's
operation and maintenance manual. The latter must provide specific outline plans,
instructions, and safety precautions for the particular vessel.

SAFETY NOTE: Above all, the inspector must be careful: if an IGS has
made a tank atmosphere, it will not support life, either. A person who enters
an inerted space without adequate breathing apparatus will die within a few
minutes.

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C. TYPICAL SYSTEM COMPONENTS FROM THE GAS SOURCE TO THE TANK

1. Boiler Uptake These valves are located near the main boiler uptake to isolate the IGS scrubber from
Valves (Flue the boiler uptake. Alternatively, if a dedicated IGG is used, this valve will be located near
Gas Isolating the IGG; it is closed when the IGS system is not operating. Associated with each boiler
Valves, IGG uptake valve is a steam sootblowing system. A spectacle blank is also fitted between the
Isolating boiler uptake valve and the IGS scrubber to ensure complete isolation of the IGS plant
Valves) and cargo. This is very important to ensure that inert gas is not introduced into the
system during maintenance.

2. IGS Scrubber
(Scrubber The raw inert gases are hot and contain soot, sulfur oxides, sulfurous acid, and sulfuric
Tower, acid; all of these can be harmful to the cargo and the cargo tanks. The scrubber cools
Absorption the gases and removes the contaminants by bubbling the gases through large quantities
Tower, and of seawater (there must be two sources of water for the scrubber). The gases are then
Gas Washer) sprayed with additional quantities of water, or rise through a packed bed of ceramic
forms, plastic shapes, or metal trays through which seawater falls, increasing the
efficiency of the water in cleaning the inert gas. The warm, acidic, dirty seawater is then
piped overboard. If the scrubber is provided with a heater to prevent the water from
freezing, an automatic control system is installed to prevent its overheating. The scrubber
also acts as an automatic safety device by preventing a backflow of gas to the boiler
uptake or the IGG (see Figure C51).

3. Demister The gas from the scrubber has significant amounts of moisture, both from the burning
Units process and from bubbling through the seawater in the scrubber. The demister is located
close to the scrubber to remove entrained water from the IGS gas stream. If this water is
not removed, it increases the corrosion rate in the system's piping, valves, and cargo
tanks. Water may also contaminate the cargo. The demister may consist of "pads" or
"mattresses" of woven polypropylene or fiberglass, or centrifuge separation (cyclone
dryers). There are many designs, which vary considerably.

Two or more independent blowers are located near the demister to draw the inert gas
4. IGS Blowers through the scrubber and the demister and deliver it to the IGS distribution system at the
(Fan Units) required pressure. Since the greatest need for inert gas is during offloading, the blower
capacity is set at 125 percent of the maximum rated capacity of the cargo pumps. This
provides a margin of safety to ensure that no air enters the cargo tanks. This capacity
may be provided by two blowers of equal size, or by one large and one small blower.
Separate inlet and discharge valves are fitted to each blower unit. On most plants, the
valves are handoperated, but on some the discharge valves are combined with the main
and auxiliary pressure regulating valves.

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5. Pressure The pressure-regulating valve is used to adjust the pressure between the IGS and the
Regulating cargo tanks. An overpressurized cargo tank can rupture if the pressure in the IGS value
Valve (Gas is too high. It is also important to prevent backflow from the cargo tanks, which could
Regulating lead to inert or cargo gases entering the machinery spaces. A fire or explosion could
Valve, IGS occur if cargo gases mix with air and enter the boilers, the engines, or the IGG. The
Control pressure-regulating valve is installed to regulate the flow of inert gas to the IGS deck
Valve, Main main, maintain the IGS pressure, and prevent gas backflow when the IGS malfunctions
Valve) or is shut down. The value position may be controlled either manually or automatically.
For automatic control, the IGS pressure is used to set the valve in a pneumatic,
hydraulic, or electric feedback control to maintain a constant pressure regardless of the
rate cargo discharge.

NOTE: Electrical equipment in a hazardous location must be suitable, i.e.,

explosion-proof, intrinsically safe, or purged and pressurized.

6. Deck Water
Seal

Introduction a. Usually located on the main deck, the deck water seal is the primary
safeguard to automatically prevent a reverse flow of cargo gas from a tank to
the boilers, the engines, or the IGG. The deck water seal offers a positive
break in the system by means of a water trap. This permits inert gas to be
delivered to the main deck while preventing gas backflow, even when the
IGS is shut down. The regulations require two independent water supplies for
the deck water seal. When the IGS is operating, the scrubber pump supply is
used; the second supply, normally the salt water service pump, is used when
the IGS is not operating. Each pump must be capable of operation at all
times. The deck water seal is provided with a heater to prevent the water
from freezing and an automatic control system that prevents overheating of
the seal. Although not required, a demister is usually fitted to remove
entrained water. There is always a water layer through which the inert gas
bubbles (see Figures C52 through C54).

Type b. There are three general types of deck water seals: wet, dry, and semidry.
Requirements
(1) The wet seal is described in Figure C52. It is deemed the most reliable
and is the only type generally approved for use on U.S. vessels.

(2) The semidry seal operates dry after the IG flow displaces the water.
Venturi action returns the water when a gas block is needed as
described in Figure C53. This type of seal as been approved for U.S.
vessels on a casebycase basis, if the unit is quickacting, has no
moving parts, and has no sensors that are subject to failure.

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(3) The dry seal operates normally dry and is filled with water when the IG
plant is shut down or when tank pressure exceeds the IG pressure.
This system requires more operating parts, reacts slower and is not
deemed as reliable as the wet type. Dry seals are not approved for use
on U.S. vessels. See Figure C54 for a more complete description.

(4) A double blockandbleed arrangement is used on some foreign vessels

in place of the water seal. This involves two closely spaced valves to
stop the inert gas flow (the "double block") plus a means to release (or
"bleed") any gas trapped between the valves. This automatic device is
not permitted on U.S. ships as a substitute for the required water seal.

7. Deck
Mechanical As an additional safeguard to prevent the backflow of gas from the cargo tanks, one or
NonReturn more mechanical nonreturn valves are installed on the cargo tank side and in series with
Valve the deck water seal.

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FIGURE C52: TYPICAL IG SYSTEM COMPONENTS

NON-HAZARDOUS AREA HAZARDOUS AREA

FROM
FLUE
GAS
UPTAKE DECK
IG PRESSURE MECHANICAL DECK
REGULATING ISOLATING IG DECK
NON-RETURN MAIN TO
DEMISTER VALVE VALVE VALVE
#1 IG MAST
BLOWER IG BRANCH
LINES TO
BLOWER BLOWER CARGO
INLET OUTLET DECK TANKS
VALVES VALVES WATER
SCRUBBER SEAL
CARGO
#2 IG
TANK
BLOWER
ISOLATING
VALVES
LIQUID FILLED
PRESSURE
VENT VACUUM
VALVE BREAKER
FLUE GAS
ISOLATING INERT GAS PLANT INERT GAS DISTRIBUTION SYSTEM
VALVES

TYPICAL ARRANGEMENT FOR AN INERT GAS SYSTEM

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FIGURE C53: DECK WATER SEAL — WET TYPE

GAS FLOW TOWARDS CARGO TANKS BACK PRESSURE IN CARGO TANKS

DEMISTER
PADS

DECK WATER SEAL — WET TYPE

FIGURE C54: DECK WATER SEAL — SEMI-DRY TYPE

GAS FLOW TOWARDS CARGO TANKS BACK PRESSURE IN CARGO TANKS

VENTURI

DECK WATER SEAL — SEMI-DRY TYPE

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FIGURE 154: DECK WATER SEAL—DRY TYPE

GAS FLOW TOWARDS CARGO TANKS BACK PRESSURE IN CARGO TANKS

DROP
TANK

AUTOMATIC
VALVE
CONTROL

DECK WATER SEAL — DRY TYPE

In the dry type seal, the water is drained from the seal when the IG plant is in operation (gas flowing to
the tanks), and filled with water when the IG plant is either shut down, or the tank pressure exceeds the
IG blower discharge pressure. Filling and drainage are performed by automatically operated valves
controlled by the levels in the water seal and the drop tank, and by the operating state of the blowers.
U.S. vessels must be equipped with seals that are completely passive in operation, so that failure of
sensors, control systems, or moving parts cannot cause failure to establish a seal. Active seals, such as
the dry seal shown above, are not acceptable.

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CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

8. Deck This valve is used to isolate the inert gas plant from the deck distribution subsystem and
Isolating the cargo tanks; it therefore constitutes the "first" barrier to any reverse flow of cargo
Valve (Main tank gas when the IGS is started, tested, or secured. A second valve is necessary unless
Isolating the deck mechanical nonreturn valve has a positive means of closure.
Valve)

9. Deck This subsystem consists of a single inert gas main running the entire length of the cargo
Distribution deck, starting at the deck isolating valve aft and ending at the vent valve forward. One or
System more pressure/vacuum devices are fitted to the inert gas main to prevent the cargo tanks
from being over or under-pressurized. The inert gas main contains a means for receiving
an outside source of inert gas when the IGS is not functioning. From the inert gas main,
individual branch lines run to the cargo tanks. Stop valves or equivalent closures are
fitted at each branch line, so that each cargo tank can be isolated from the inert gas
system. If there is a connection between the inert gas main and the cargo piping system,
there must be valves or similar closures to isolate the systems from one another.

10. Typical Gas

Venting
Arrangements
a. Each tank vessel has a venting system that is capable of venting vapors
Venting System displaced from the cargo tanks during loading and ballasting. There are also
pressure/vacuum (P/V) valves to protect the cargo tanks from overpressure
or vacuum resulting from thermal variation when the cargo tanks are isolated
from the inert gas mains. Some of the possible arrangements are:

(1) A single common venting system, using the IGS deck main and branch
lines from each tank and venting to the atmosphere through one or
more mast risers or highvelocity vents. Precautions must be taken to
prevent an arrangement by which tank vents can be blocked off;

(2) A common venting system, using a separate vent main and vent lines
from each tank, with the system venting to the atmosphere through
one or more mast risers or highvelocity vents; or

(3) Individual vents on each tank, using either standpipes (vent stacks) or
highvelocity vents.

b. Tank high level alarms have been accepted in lieu of equal area venting
High Level Alarms required by 46 CFR 56.5085(a)(7). However, precautions are necessary to
prevent tank over pressurization during cargo or ballast loading. The oil
transfer procedures, crude oil washing (COW), and equipment manual and
ballasting instructions should include requirements for testing high level
alarms and the proper positioning of valves for each type of operation.

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11. System Each tank vessel has an operating and maintenance manual. There are devices located
Document- downstream of the blowers to indicate the oxygen concentration, the IGS pressure and
ation temperature, and means of automatically recording this information. The records of
oxygen concentration and IGS pressure should remain aboard the vessel for at least 2
years.

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CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

D. GAS FLOW THROUGH THE IG SYSTEM

1. Introduction Inert gas is provided from the main or auxiliary propulsion uptake point or from the IGG,
and flows through the flue gas isolating valve or IGG isolating valve, to the IGS scrubber.
Before entering the bottom of the "scrubbing tower," the gas is cooled by bubbling
through a water seal or by passing through a water spray (see Figure 155 for a diagram
of a typical IGS arrangement).

2. Water Flow In the scrubbing tower itself, the gas moves upward through a supply of downward-
flowing seawater. To maximize the contact between the gas and the water, several water
layers created by one or more of the following arrangements may be used:

a. Spray nozzles;

b. Trays of "packed" stones or plastic shapes;

c. Perforated "impingement" plates; or

d. Venturi nozzles and slots. Seawater is supplied to the scrubber by an

independent, continuously rated "scrubber pump." The saltwater service
pump is normally piped into the system to provide a secondary or backup
supply of seawater. The scrubber effluent ("wash" or "cooling water") is both
warm and acidic, and special corrosionresistant piping must be used to
discharge it overboard. A vacuum breaker (Ubend) is necessary to prevent
possible loss of water in the seal.

NOTE: The scrubber must have an adequate supply of salt water for the
prescribed gas flow. A low saltwater level means that the scrubber will not
work as designed or not at all.

Fresh water flushing facilities are provided so that all acidic solutions and all salt water
may be removed from the scrubber when the IGS is shut down.

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3. Refinement At the top of the scrubbing tower, water droplets are removed from the inert gas mixture
of the IG by one or more demisters. The operating blower draws the gas from the
Mixture and scrubber/demister unit under vacuum and delivers it to the inert gas distribution at the
Flow Control required pressure and volume. The total capacity of the blowers must be at least 125
percent of the maximum rated capacity of the cargo pumps. The blowers may be either
steam turbine or electric powered. Steam inlet and return valves are manually operated,
but both blowers can be controlled from the engine control room. To prevent the blowers
from overheating when there is no demand for inert gas in the cargo tanks, and to allow
gas concentration to be developed during startup, a recirculating line is fitted to return the
blower discharge to the scrubber. Flow is controlled by recirculating or bypass valves,
operated independently by gas flow demand, or in conjunction with the gas pressure
regulating system.

4. Alternate Some IGS blowers are used to gas free the cargo tanks in lieu of portable blowers or a
Blower separate fixed gas freeing blower system. In this arrangement, the installation is fitted to
Arrange- isolate the flue gas and substitute suction from the atmosphere. As with the scrubber,
ments fresh water flushing facilities are fitted to remove acidic residues in the blower casings.
The fresh air then passes through the pressure regulating valve, the deck isolating valve,
the IGS main, and the individual branch lines into the cargo tanks.

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E. INTERNAL INSPECTIONS OF IG SYSTEMS

1. Introduction The marine inspector must appreciate the potential for introducing "dirty" or corrosive gas
into the IGS by improper operating procedures or poor maintenance practices. This
situation will create an environment for rapid system degradation or component failure.
The following policy is not intended to be applied during routine testing of the IGS on
either a U.S. or foreign tanker. Internal inspections are anticipated on U.S. tankers
during biennial inspections for certification and drydockings. This cycle is considered a
minimal requirement, as many manufacturer instruction manuals recommend that owners
inspect various components of the IGS on an annual, semiannual, or weekly basis.

2. Specific
Inspection
Guidelines

Scrubber a. Where feasible, all access plates and internal components such as demister
pads and scrubber trays shall be removed. Soot and scale deposits shall be
removed prior to the inspection. The following areas and internal
components should be given close attention:

(1) Internal coatings should be completely intact. Check for signs of

chipping or cracking, particularly around internal fastenings.

(2) Inspect gas inlet pipe in the scrubber water seal for corrosion and
holes or leaking flanges, especially above the water level, that would
allow gas to bypass the seal and render it ineffective.

(3) Closely inspect the internal area at the bottom of the scrubber for
corrosion, especially in way of the effluent discharge line. Check the
discharge line for clogging.

(4) Inspect float switches, temperature sensors, Venturi slots, impingement

plates, packed trays, and demisters (as applicable) for damage,
wastage, and corrosion.

(5) Ensure that the water heater (used to prevent water freezing) and its
control system are in good condition.

(6) Inspect fresh and saltwater inlet piping for corrosion or wastage, and
especially for holes or leaking flanges. Check spray nozzles for clogging
and intact condition.

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Valves b. Boiler uptake (or IGG) valves, blower inlet and discharge valves, recirculating
valves, pressure regulating valves, deck mechanical nonreturn valves, deck
isolating valves, and IGS isolating valves shall be disassembled for
inspection. Valve internals shall be inspected for cleanliness, and for signs of
corrosion or erosion. Careful attention should be given to "butterfly"
mechanisms to ensure free, smooth operation and proper seating. Check
nonreturn valve seals. If accessible, either through inspection ports or
disassembled components, the internal areas of the inert gas main and
branch lines shall be checked for excessive scale buildup or soot deposits,
which could result in a critical gas pressure drop between the IGS blowers
and the cargo tanks.

Deck Water Seal c. This shall be disassembled. Internal coatings shall be inspected for
intactness; housing and heating coils, for corrosion; gas inlet pipes, for
corrosion, holes, or leaking flanges (especially above the water level) that
would permit gas to bypass the seal; and drain lines, for clogging or
corrosion. The demister pads must be clean and free of soot and scale
deposits. Check that the heater (used to prevent water freezing) and its
control system are in good condition. Only the wet type of water seal is
permitted; in this type there is always water present in the device and the
inert gas flowing through the seal always bubbles through a layer of water.
Semidry seals, in which water is not always present, are approved for U.S.
vessels on a casebycase basis. "Dry" water seals and the double blockand-
bleed assemblies are not permitted aboard U.S. vessels.

Blowers d. The inspection ports and access plates on all blowers shall be opened.
Blower impellers, bearings, and casings shall be checked for corrosion or
excessive buildup of deposits that may cause blade failure. If accessible,
fresh water flushing spray nozzles shall be checked for intactness or
clogging; the blower drain piping, for corrosion or clogging.

P/V Valves e. P/V valves shall be disassembled and inspected for corrosion and the
choking of flame screens from soot, oil entrainment, and rust. The forward
pressure release valve shall be disassembled and the butterfly mechanism
inspected for free, smooth operation and proper seating. If feasible, the
liquidfilled, pressure/vacuum breaker shall be drained and inspected for
sludge, sediment, or soot deposits that could render the component
ineffective. Highvelocity vent installations shall be inspected for internal
deposits or corrosion that may reduce venting capacity or prevent tight
closure.

Flue Gas Uptakes f. If accessible, the flue gas uptake should be inspected for clogging from soot
deposits when the boilers, engines, or IGG's are secured. On systems with
IGG's, the combustion chamber shall be checked for soot, scale, or fuel
deposits that could indicate improper combustion control or a distorted fuel
spray pattern.

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Calibration g. Check the equipment used for the calibration of the fixed and portable gas
concentration measurement devices.

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F. OPERATIONAL INSPECTIONS

1. Introduction The following tests shall be conducted on U.S. tankships during biennial and mid-period
inspections and on foreign tankships, at each annual safety examination. On all vessels,
these tests shall be conducted prior to allowing COW in a U.S. port. The scope of such
tests must be sufficient to ensure that the IGS is operating within the manufacturer's
design parameters and that the installed safeguards will operate as designed in the event
of system malfunction. The marine inspector must review the manufacturer instruction
manual and the vessel's operating and maintenance manual, and must be alert to
conditions that must be simulated. In no case shall the inspector accept a manual that
does not address specific safety precautions for the particular vessel.

2. Inspection
Procedures

a. Externally inspect the condition of all piping and components, including

scrubber, fans, valves, bellows expansion pieces, standpipes, and screens,
for signs of corrosion and gas/effluent leakage.

b. Observe all IGS blowers in operation for proper operation and for excessive
bearing noise or vibration. Ensure that the scrubber room ventilation system is
operating.

c. Observe the operation of both the salt water scrubber pump and the pump
used to provide an alternate salt water supply.

d. If the scrubber design uses a water seal, check for proper water level. Some
foreign vessels are fitted with water sprays only, but U.S. vessels must have a
wet type water seal.

e. Observe the deck water seal for automatic filling and check the water level
with the local gauge, if possible. Check for the presence of water carryover
(especially in the wet and semidry types) by opening the drain cocks on the
IG main during operation. Check that the heater coil for cold weather
operation is operational.

f. Check the operation of all remotely operated or automatically controlled

valves, particularly the flue gas isolating valves. Check that there are
functioning indicators showing whether the valves are open or shut.

g. If possible, check the level of the liquid in the pressure/vacuum breaker.

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h. Check to ensure that all salt water supply pressure gauges, oxygen and gas
pressure recorders, and temperature and pressure gauges are fully
operational. The fixed inline oxygen analyzing equipment will be calibrated
during the operation of the IGS. Observe a calibration check of the
equipment by a qualified member of the ship's crew. Spotcheck several
recordings made since the last inspection during normal system operation for
compliance with oxygen and pressure level requirements.

i. Examine the blower drives, the seawater pumps, valves, and strainers for
the scrubber and the water seal; the piping connections at the scrubber;
water seals; and the shell plating.

j. Observe that all portable instruments are properly calibrated and operating
as required by the manufacturer instruction manual. These may include an
oxygen analyzer, a combustion gas indicator, and a hydrocarbon gas
indicator. Sample points should be provided for the use of portable
instruments for monitoring cargo tank atmospheres.

k. If an IGG is used, examine the automatic combustion control system, the

combustion chamber and its mountings, the forced draft fan, and both fuel oil
service pumps.

3. Operational
Tests

a. The operation of both audible and visual alarms should be observed in the
cargo control room, the engine control room, and the pilothouse. The marine
inspector shall consult the manufacturer instruction manual and the ship's
operation and maintenance manual for guidance in establishing proper test
procedures. Simulation may be necessary for some tests. However,
simulation tests of the alarm panel shall not be accepted as evidence of
satisfactory operation of the following alarm and safety shutdown systems:

(1) High oxygen content of gas in IGS main; alarms activated at an 8

percent concentration.

(2) Low gas pressure in IGS main downstream of all nonreturn devices;
alarms activated at 100mm (4 inches) water gauge. An automatic
shutdown of the cargo pumps may be fitted on some vessels. Also,
high gas pressure in the IGS main downstream of all nonreturn
devices.

(3) A low level water alarm, high level water alarm, or low flow pressure
alarm fitted to the deck water seal to shut down the IGS blowers
automatically.

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(4) IGS blower high discharge temperature alarm that will automatically
shut down the IGS blowers and the gas regulating valve; alarms
activated at 150°F (65.6°C) or less for U.S. vessels and at
temperatures indicated in approved operation manual for foreign
vessels.

(5) High gas pressure of the inert gas supply forward of the nonreturn
devices.

(6) IGS blower failure alarm and automatic shutdown of main or regulating
valve.

(7) Power supply failure for the automatic control system gas regulating
valve and the indicating devices showing the proper quantity and
quality of the inert gas supply.

(8) Insufficient fuel oil supply to the IGG and the failure of the power
supply to the IGG.

b. Conduct backflow pressure test of water seal and nonreturn valve.

c. Test interlocking of soot blowers. The IGS will automatically shut down if
soot blowers are operated.

d. Test for automatic shutdown of the gas pressure regulating valve when the
IGS blowers are secured.

e. Test the automatic combustion control features of the IGG (if used) in
accordance with standard combustion test procedures for automatic auxiliary
heating equipment (see 46 CFR 63).

f. Test IGS remote shutdown required by 46 CFR 111.103.9.

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CHAPTER 5: INSPECTION OF INERT GAS SYSTEMS

G. SAFETY PRECAUTIONS

1. Introduction The purpose of an IGS is to establish positive pressure in a cargo tank with an
atmosphere that will not support combustion. If an atmosphere will not support a fire, it
will not support life. Clearly, such an inerted, pressurized atmosphere is highly
dangerous, producing unconsciousness and death in a short period. The following
guidance is intended to make inspectors aware of the fundamental steps that must be
taken to ensure IGS safety.

2. References In addition to this chapter of the Marine Safety Manual (MSM), the inspector should
consult the following sources:

a. 46 CFR 32.53;

b. The American Bureau of Shipping (ABS) Rules for Building and Classing
Steel Vessels, Appendix B, Regulation 10;

c. SOLAS 74/78, Chapter II2, Part E, Regulation 62, and amendments;

d. The manufacturer instruction manual;

e. The vessel's operating and maintenance manual; and

f. Commandant's International Technical Series (CITS), Volume VII (USCG

CITS8011), "Regulations and Guidelines for Inert Gas Systems."

3. Requirements The marine inspector must always have a ship's officer or port engineer trained in the
for an Escort operation of the IGS along as an escort. The ship's officer or the port engineer will
oversee all required tests and inspections.

4. Personal Always stand well clear of any ullage opening when the cover is being removed, even
Caution though the cargo tank pressure has been lowered to a "safe" level. Wear protective
goggles and clothing when conducting internal inspections of the system. Remember that
the potentially corrosive nature of the dirt, scale, and soot associated with the internals of
an IGS can irritate or damage your skin and eyes.

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The marine inspector shall, under no circumstances, enter a cargo tank when the IGS is
5. Require-
operating, or when the tank or the adjacent tanks have been inerted, unless the following
ments for
steps are taken:
Tank Entry
a. The cargo tank shall be certified "safe for workers" by a certified marine
chemist.

b. Pressure on the remainder of the system shall be lowered to 200mm (8

inches) water gauge to minimize the possibility of IGS leakage into the "gas-
free" cargo space.

c. The IGS branch line control valve to that tank shall be closed, with a person
stationed at the ullage opening within clear view of the valve. This person
should be wearing a selfcontained, pressuredemand breathing apparatus,
ready for immediate use, and should be provided with a rescue lifeline and a
standby person positioned as noted above.

NOTE: If an isolation blank is fitted instead, it shall be wired closed with the
label "Personnel in cargo tank."

d. Drain lines (if fitted) from the IGS main to that cargo tank shall be secured.

e. The relevant cargo line valve shall be closed.

f. The cargo tank shall be continually vented and regularly tested with the
portable oxygen analyzer.

g. An approved selfcontained, pressuredemand breathing apparatus shall be

worn for immediate use if needed. It shall be equipped with a beltmounted,
calibrated oxygen/combustion gas indicator in continuous operation.

6. Ventilation If the IGS is secured and the IGS blowers are being used to purge and ventilate the
Require- cargo tanks, the branch valve must be left opened. In this case, ensure that the
ments spectacle blank or valve downstream of the boiler uptake valve is in place and that a
person is stationed at that blank.

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Never inspect the flue gas bellows or scrubber unless: all branch line spectacle blanks
7. Branch Line are in place (or branch line isolation valves are closed); the spectacle blank downstream
Inspections of the boiler uptake valve is in place; isolation valves are closed; and the IGS has been
purged and certified "safe for workers" by a marine chemist. If a boiler is operating,
require a person to be stationed at the spectacle blank downstream of the boiler uptake
valve.

8. Internal When conducting internal inspections of pumprooms, cofferdams, permanent ballast

Inspections tanks, and fuel oil tanks on tank vessels fitted with IGS, be aware that inert gas may
of Enclosed have leaked into such tanks or compartments. While inspecting the tank or compartment,
Spaces the inspector shall be equipped with an emergency escape breathing apparatus (EEBA)
and a beltmounted, calibrated oxygen/combustion gas indicator that is in continuous
operation. Always test for sufficient (at least 19.5 percent) oxygen first, then test for
vapors above 10 percent of the lower flammable limit.

NOTE: A combustion gas indicator will not give an accurate indication of the
percentage of hydrocarbon gas in an oxygendeficient atmosphere. A
hydrocarbon gas content meter must be used to determine whether
hydrocarbon vapors are present in an inerted tank or compartment.

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H. PRESSURIZATION OF IG SYSTEMS

1. General The operational requirements in 46 CFR 32.535 require the master to ensure that the
Require- IGS is operated as necessary to maintain a positive pressure on the cargo tanks. This
ments requires the tank to be sealed at all times except when the tank is either gasfree or
carrying a cargo that cannot produce a flammable atmosphere. For certain cargoes, the
cargo purity is of critical importance; thus, the cargo tanks must be gasfreed and entered
prior to loading. In such instances, standard gasfreeing procedures must be followed.

2. During The high costs of crude oil and petroleum products can require cargo level measurement
Periods of and cargo sampling before and after loading, and before and after the cargo is
Cargo transferred. When manual measurement or cargo sampling is being conducted, no cargo
Access or ballasting operation shall be performed. The following requirements shall apply:

a. A minimal number of small tank openings may be uncovered for as short a

time as necessary to perform measurement or sampling.

b. If tanks are thus opened prior to cargo transfer, the tanks shall be
repressurized before beginning the transfer.

c. If tanks are thus opened after cargo transfer, the tanks shall then be
repressurized before beginning another transfer or the vessel leaves port.

d. Neither cargo transfer nor movement of the vessel shall begin until all
conditions have been checked and are in order.

e. During cargo transfer operations, the oxygen content and pressure of the
inert gas in the IG main shall be continuously recorded.

f. These instructions shall be contained in the system operating manual

required by 46 CFR 32.5385.

Controlling G-MOC Releasing G-M Revision 15 Jun 98 Page C5 - 30

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