Chemical Tankers: Regulatory Update. Janet Strode General Manager International Parcel Tankers Association

Transcription

1 Chemical Tankers: Regulatory Update Janet Strode General Manager International Parcel Tankers Association

2 Application of Inert Gas Carriage of Used Cooking Oil Disposal of oil from galleys Review of IBC Code Review of requirements for discharge of residues Carriage of Biofuels Low Flash Fuels Ballast Water Management 2

3 Application of Inert Gas Amendments to SOLAS now formally adopted and enter into force 1 January 2016 Apply to new oil tankers (below 20,000 DWT) and new chemical tankers Lower size limit of 8,000 DWT Chemical tankers may inert prior to discharge rather than prior to loading 3

4 Cargoes with Oxygendependent inhibitors IBC Code states that must not be inerted until immediately prior to commencement of discharge MEPC Circular (later to be included in amendment to the IBC code) states that shipper must advise the level of oxygen required for the inhibitor to work properly PPR 2 agreed to unified interpretation of SOLAS: When a product containing an oxygen-dependent inhibitor is carried on a ship for which inerting is required under SOLAS regulation II-2, the inert gas system shall be operated as required to maintain the oxygen level in the vapour space of the tank at or above the minimum level of oxygen required under paragraph of the IBC Code and as specified in the Certificate of Protection. 4

5 Carriage of Used Cooking Oil PPR 2 agreed to the assignment of carriage requirements for Used Cooking Oil: a c d e f g h i i i j k l m n o Used cooking oil X S/P 2 2g Open No Yes O No ABC No ; ;

6 Disposal of Cooking Oil from Ships Galleys Proposals for interpretation of MARPOL Annex V to allow for disposal of cooking oil Via sludge tank Directly into fuel tank PPR 2 rejected these suggestions cooking oil must be Disposed of ashore, or incinerated 6

7 REVIEW OF THE IBC CODE 7

8 Type 1 Acetone cyanohydrin (+1G) Carbon disulphide Crotonaldehyde (+1G) Ethylene chlorohydrin Glutaraldehyde solutions Lactonitrile solution Nitrating acid (+1G) beta-propiolactone Propionitrile Trixylyl phosphate Type 2 Alkylaryl phosphate mixtures 1,5,9-Cyclododecatriene N,N-Dimethyldodecylamine Methylcyclopentadienyl manganese tricarbonyl (+2G) 1,2,3-Trichlorobenzene (molten) Tricresyl Phosphate (1% or more ortho-isomer) 8

9 Type 2 18 Products e.g. Adiponitrile Dibutylamine Fluorosilicic acid (+2g) Furfural Hexanol Nonanoic acid Octanoic acid Sulphuric acid e.g. Acetonitrile 18 Products Acrylamide solution Butyl acrylate Diisopropylamine Ethylene dichloride Methyl acrylate Methyl methacrylate Type 3 9

10 Diethylene glycol Ethylene carbonate Glycerine Chapter 18 to Type 3 Hexamethylenetriamine solutions Hexylene glycol Methyl propyl ketone Polyaluminium chloride solution Polyglycerin sodium salt solution Potassium formate solution Propylene carbonate Propylene glycol Sodium sulphate solutions Triethylene glycol 10

11 Toxic Products T in column k of chapter 17 indicates presence of toxic vapours Currently approx. 190 products Additional 260 products to be given this notation total 60% of products in Code 11

12 For example: Alcohols, including: Methanol Octanol Hexanol Acids, including Phosphoric Sulphuric Citric Glycols, including Diethylene glycol Hexylene glycol Ethylbenzene Ethylene Cyanohydrin Some Olefin mixtures Potassium hydroxide Styrene monomer Tall oil Toluene Triethanolamine UAN Vinyl acetate 12

13 Increased special requirements 15.17: Increased ventilation 15.19: Overflow control 15.12: Toxic products Exhaust openings Vapour return line Stowage Not adjacent to oil fuel tanks Separate piping systems Separate vent systems PV valves minimum 0.02 gauge 13

14 Reg Bow and stern unloading lines cannot be used unless approved by the Administration Reg Heating or cooling medium must be external to the tank or kept separate from other ship s services Reg 13.2 Must have toxic vapour detection equipment or, if not available, obtain an exemption from the Administration necessity for additional breathing-air supply 14

15 NB: 8 products currently not subject the Code to be subject to these increased requirements: Diethylene glycol Ethylene carbonate Hexamethylenetriamine solutions Hexylene glycol N-methylglucamine solution Methyl propyl ketone Polyglycerin, sodium salt solution Propylene carbonate 15

16 Review of discharge requirements under MARPOL Annex II 16

17 17

18 Submission to PPR 1 (2014) Denmark, the Netherlands, Norway, Poland, Sweden and the United Kingdom discharge of High-Viscosity and Persistent Floating products and their impact on the environment. approximately 66 recorded incidents of waxes and vegetable oils washing up on beaches since 2010 Not classic pollution incidents [but]: impairs the recreational and tourism values of beaches and coastlines Society bears the expense of the clean-up, many seabirds die as a result of becoming coated in the substance 18

19 19

20 Submission to MEPC 68 (April 2015) Germany, Netherlands, Norway, United Kingdom, Denmark, Sweden and Spain Proposal for new item to be added to work programme of PPR Sub-Committee in order that the discharge requirements for cargo residues and tank washings are reviewed for highviscosity and persistent floating products, to reduce the impact on the environment 20

21 following list of items would need to be further evaluated as possible contributors: effectiveness of stripping requirements, taking into account clingage definition of solidifying substances definition for high-viscosity substances the definition of "en route" for the purposes of discharge adequacy of pre-wash requirements availability/adequacy of reception facilities the utility and ongoing need for MARPOL Annex II, regulation

22 Stripping Requirements New Ships (from 2007) Existing IBC ( ) Existing BCH (Prior to 1986) Other Ships X 75 litres + prewash 100 litres + 50 litres tolerance + prewash 100 litres + 50 litres tolerance + prewash No carriage Y 75 litres 100 litres + 50 litres tolerance 300 litres + 50 litres tolerance No carriage New Ships: 75 litres Z 75 litres 300 litres + 50 litres tolerance 900 litres + 50 litres tolerance Existing Ships: empty tanks to the most practicable extent OS Unrestricted Unrestricted Unrestricted Unrestricted 22 22

23 Stripping Test Carried out with water Trim and list recorded Time taken recorded Regulation Before any prewash is carried out the relevant tank shall be emptied to the maximum extent in accordance with the procedures described in the Manual. 23

24 Solidifying and High Viscosity Substances a solidifying substance is a substance which : in the case of a substance with a melting point of less than 15 0 C, is at a temperature of less than 5 0 C above its melting point at the time of unloading; or in the case of a substance with a melting point of equal to or greater than 15 0 C, is at a temperature of less than 10 0 C above its melting point at the time of unloading 24

25 High-viscosity substance means a noxious liquid substance in category X or Y with a viscosity equal to or greater than 50 mpa s at the unloading temperature equal to or greater than 50 mpa s at 20 0 C 25

26 Definition of en route underway on a course or courses, including deviation from the shortest direct route, which as far as practicable for navigational purposes, will cause any discharge to be spread over as great an area of the sea as is reasonable and practicable. 26

27 Prewash Requirements Include all products defined as persistent floaters in the GESAMP Composite List? Possibly not full prewash but hot/cold wash for set number of cycles of TC machine? GESAMP Composite List: approx. 180 Persistent Floaters, including: 27

28 All vegetable oils and animal fats, including derivatives (Olein, Stearin, Distillates, etc) FAME Waxes Acids, e.g. Lauric Neodecanoic Oleic Fatty acids Alcohols, e.g. Dodecanol Octanol Fatty alcohols Alkylates Phthalates Polyolefins Tall oil 28

29 Reception facilities? Additional port time? Operational issues? Increased emissions in port areas? 29

30 Regulation This exemption was requested based on the assumption that there would be a shortage of Ship Type 2 tonnage when Annex II of MARPOL came into force on 1 January the use of causes confusion and problems for administrations when issuing this exemption, as the vessel have to switch between ST 2 and ST 3 therefore it is proposed that this exemption be removed to reduce the burden on administrations. 30

31 CARRIAGE OF BIOFUELS 31

32 Brazil and Finland submitted document to MEPC: Proposal for inclusion of technically suitable biofuels under Annex I (rather than Annex II) Renewable Diesel (Alkanes C10-C26) Renewable aviation fuel (Alkanes C10-C17) Renewable Naphtha (Alkanes C5-C7) 32

33 Argument Vastly increased demand for biofuels Classification should be based on end product, rather than feedstock Carriage in Annex I tankers would mean less transits, which would in turn reduce GHG and other emissions Fewer washing operations better for the environment No evidence presented for these claims 33

34 Implications Fundamental change of philosophy Suggestion that Type 2 chemical tankers are not as environmentally friendly as oil tankers Would this lead to calls for other products to be switched to Annex I? FAME? Vegetable oils? 34

35 Low Flash Bunkers 35

36 US and Canada recognise that with EIF of reduced sulphur limits availability of fuel will be tight Claim that ships will be at disadvantage because of 60 0 C flashpoint limit Road diesel fuels readily available but currently can t be used on ships because of flashpoint (55 0 c in Europe and 52 0 C in US) Propose flashpoint limit for bunker fuel to be reduced from 60 0 C to 52 0 C Safety issues? Implications for cargoes?

37 BALLAST WATER MANAGEMENT 37

38 30 states BWM Convention 35% of world tonnage 12 months Entry into Force Currently: 44 States 32.86% of world tonnage 38

39 Effective Dates as per Assembly Resolution 1088 Source: ABS 39

40 Type Approval Process Industry has expressed concerns that the approval process as per the IMO s G8 Guidelines not fit for purpose Concern expressed that individual systems may not operate correctly in Different salinities (fresh, brackish, marine) Different water temperatures (cold, temperate, tropical) Different sediment loads Where flow rates are less than Treatment Rated Capacity 40

41 MEPC 67 agreed to review of the G8 standard, to include following elements: Testing using fresh, brackish and marine waters; testing considering the effect of temperature in cold and tropical waters specification of standard test organisms for use in testing challenge levels set with respect to suspended solids in test water type approval testing discounting test runs that do not meet the D- 2 standard the results of test runs being "averaged"; type approval testing realistically representing the flow rates the system is approved for differences between type approval protocols of Member States Early adopters not to be penalised 41

42 United States Vessel Ballast Capacity Compliance Date Constructed on or after 1 December 2013 All Delivery Constructed before 1 December 2013 < 1,500 m3 1,500 5,000 m3 > 5,000 m3 First scheduled drydocking after 1 Jan 2016 First scheduled drydocking after 1 Jan 2014 First scheduled drydocking after 1 Jan 2016

43 Treatment systems must be approved by USCG Currently no systems approved Some 45 systems given approval as alternate systems, for up to 5 years Some estimates are that first approvals will not come out until mid-2016 What does a responsible owner do? 43

44 Thank you for your attention 25 years serving the chemical tanker industry 44