Regulatory Compliance Shipowner Perspective

Transcription

1 Regulatory Compliance Shipowner Perspective Mare Forum USA May 2013 By: Rear Admiral Robert C. North, U.S. Coast Guard (Ret.) Member, Board of Directors, Genco Shipping and Trading

2 Overview Genco background Priority regulatory initiatives Genco compliance activity General compliance issues and concerns Ballast water management Vessel General Permit (VGP) changes and compliance MARPOL Annex V Compliance issues and concerns enforcement Longer term issues/concerns

3 Genco Background Owns a fleet of 53 bulk carriers, Capesize, Pananmax, Supramax, Handymax and Handysize with aggregate carrying capacity of 3,812,000 dwt, operating on time charters. Average vessel age is 8 years with newest built No current new construction. Cargoes include grain, coal, steel products, iron ore and other bulk cargoes, worldwide. Commercial management in-house with operational management outsourced to three managers.

4 Priority Regulatory Initiatives International Convention for the Control of Ship s Ballast Water and Sediments, 2004 U.S. Coast Guard Ballast Water Management Regulations U.S. EPA Vessel General Permit (VGP) Maritime Labour Convention (MLC) 2006 MARPOL 73/78 Annexes V and VI

5 Genco Compliance Activity Working on evaluation and selection of ballast water treatment systems (BWTS) and an installation schedule. Developing compliance plan for the new VGP. Employing low sulphur fuel oil for ECA compliance. North American ECA fuel availability minimal problem to date. Developing SEEMPs Ships undergoing MLC 2006 certification.

6 General Compliance Issues and Concerns Cost of compliance BWTS; fuel oil vs. scrubber systems to reduce air emissions under MARPOL Annex VI. Drydock scheduling to comply with BWTS installation schedules. Revised MARPOL Annex V restrictions on discharge of cargo washings and availability of such reception facilities. VGP: Developing a BW monitoring program and other compliance.

7 Ballast Water Management Genco worldwide operations require BW treatment system serviceable in a wide range of water salinity, temperature and turbidity. Must operate with existing ship s power plant. Must be type approved by an Administration and applied for U.S. Coast Guard AMS and type approval. Manufacturer must provide full transparency of type approval test conditions and data. BWM Convention implementation schedule vs. U.S. schedule.

8 VGP Changes Environmentally acceptable lubricants (EAL) for oil to sea interfaces such as stern tube, thrusters and rudder bearings, etc. must be used unless technically infeasible More electronic record keeping allowed. Quarterly discharge sampling requirement eliminated. Revised Annual Report process and combined Annual Reports permitted for some operators. VGP and U.S. Coast Guard BW treatment implementation schedule the same but still some differences.

9 Ballast water monitoring plan. VGP Compliance Environmentally acceptable lubricants (EAL) for oil to sea interfaces. Oily water separator discharge monitoring. State 401 certifications BW exchange and scrubber discharge prohibitions.

10 MARPOL Annex V Revised MARPOL Annex V entered into force 1 JAN Prohibits discharge of cargo hold washings containing cargo residues harmful to the marine environment (HME). IMO 2012 Guidelines for the Implementation of MARPOL Annex V includes criteria for declaring cargoes HME. Survey of available of reception facilities for cargo residues considered HME showed availability in only about 18% of ports known to receive HME cargoes. IMO Marine Environmental Protection Committee (MEPC) 65 developed Circular for interim measures.

11 Compliance Issues and Concerns - Enforcement VGP U.S. Coast Guard/EPA MOU BW monitoring U.S. Coast Guard and EPA requirements. MLC 2006 Genco ships use a mix of Flags, not all Parties to MLC. PSC acceptance of Class statements of compliance. Lack of available reception facilities for cargo washings

12 Longer Term Issues/Concerns The dry bulk market. Fuel oil availability as sulphur levels decrease; Caribbean ECA. Evaluation of use of economics of low sulphur fuel oil vs scrubbers. Scrubber sludge reception facilities? VGP scrubber requirements. Increased stringency of BW treatment standard. BW treatment system and shipyard availability Availability MARPOL Annex V reception facilities.

13 THANK YOU!