2013 Vessel General Permit -

Transcription

1 2013 Vessel General Permit - Requirements for Vessels Visiting US Ports Elias Kariambas Manager, Marine Business Development Global Marine Organization Athens, Greece 9 June 2016 TRADING IN US WATERS SEMINAR

2 VGP Applicability Applicability: Waters of the US extending to the outer reach of the 3 mile territorial sea (CWA Section 502(8)), including all navigable waters of the Great Lakes subject to the jurisdiction of the United States Vessels Non-military and non-recreational vessels greater than or equal to 79 feet in length 2

3 2013 Vessel General Permit (VGP) Effective 19 December 2013 to 18 December 2018 Regulates 27 discharges Requires Annual Report Specific 401(c) requirements for 25 States (VGP Part 6) Notice of Intent required for vessels: Greater than or equal to 300 Gross Tons, or Having a ballast capacity of at least 8m3 3

4 2013 VGP Annual Report Completed once each calendar year All analytical monitoring results must be in the Annual Report Must be submitted electronically, unless waiver is granted Example of Annual Report form is included in Appendix H of VGP Annual report due by 28 February of the following year 4

5 Bilgewater (VGP 2.2.2) Newbuild vessels greater than 400 gross tons Oil and Grease Content analyzed once per year by: Method ISO (2000) Water Quality Determination of Hydrocarbon Oil Index Part 2: Method Using Solvent Extraction and Gas Chromatography; or EPA Method 1664 Oil content meter (OCM) reading must be recorded State specific requirements CT and NY prohibit the discharge of bilgewater RI requires the discharge of all bilgewater prior to entering RI waters 5

6 Bilgewater Reduced Monitoring Analytical results for oil and grease are less than 5 ppm for two consecutive years Sampling and analysis not required for subsequent years if: Vessel equipped with Oily Water Separator (OWS): Capable of meeting a 5 ppm oil and grease limit; or An alarm preventing discharge of water with oil and grease content above 5 ppm Oil Content Monitor (OCM) calibrated annually OCM never reads above 5 ppm 6

7 Ballast Water (VGP 2.2.3) Ballast water management (BWM) requirements generally align with USCG and IMO VGP includes the same discharge standards and similar options for ballast water management as USCG Effluent limits for BWMS that use active substances Biocide or Residual Chlorine Dioxide Chlorine (Total Residual Oxidants (TRO as TRC)) Ozone (Total Residual Oxidants (TRO as TRC)) Peracetic Acid Hydrogen Peroxide (for systems using Peracetic Acid) Limit (Instantaneous Maximum) 200 µg/l 100 µg/l 100 µg/l 500 µg/l 1,000 µg/l 7

8 Ballast Monitoring Functionality Monitoring Performance indicators verify BWMS operating to manufacturer s specifications EPA provided list of required metrics for 18 technology types Required at least once per month Equipment Calibration Sensors and other control equipment must be calibrated annually and as recommended by the system manufacture Biological Organism Monitoring Small volume samples analyzed for three specific biological indicators total heterotrophic bacteria, E. coli, and enterococci. Residual Biocide and Derivative Monitoring for BWMS that use Active Substances Records of sampling and testing maintained on board for 3 years USCG 8

9 Ballast Water Monitoring Frequency Biological Indicator Organism Monitoring BWMS with High Quality Data 2 times during first year If sampling results below permit limits for 2 consecutive events, reduce monitoring to once per year after the first year BWMS without High Quality Data 4 times per year Residual Biocide and Derivative Monitoring for BWMS that use Active Substances BWMS with High Quality Data BWMS without High Quality Data Initial Monitoring 3 times in the first 10 discharge events (not to exceed a 180 day period) 5 times in the first 10 discharge events (not to exceed a 180 day period) Maintenance monitoring 2 times per year 4 times per year 9

10 Controllable Pitch Propeller & Thruster Hydraulic Fluid & Other Oil-to-Sea Interfaces (VGP 2.2.9) Use of an Environmentally Acceptable Lubricant (EAL) is required in all oil-to-sea interfaces or immersed equipment, unless technically infeasible EPA Identified EAL Labeling Programs: Blue Angel European Ecolabel Nordic Swan Swedish Standards SS and Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) requirements 10

11 EAL Technical Infeasibility No EAL approved for use in given application Products which are pre-lubricated and no EAL is available EAL meeting specifications is not available within any port in which vessel calls EAL-seal life cycle is less than ship drydocking cycle Vessel drydocking necessary (temporary reason until drydocking date) Cost of EALs is not an acceptable reason Oil-To-Sea Interfaces Identified by VGP Section Controllable Pitch Propeller (CPP) Thrusters Paddle Wheel Propulsion Stern Tubes Thruster Bearings Stabilizers Rudder Bearings Azimuth Thrusters Propulsion Pod Lubrication Submersible wire rope that may normally be submerged Mechanical equipment subject to immersion, including dredges and grabs 11

12 Graywater (VGP 2.15) Specific monitoring requirements Collect two samples per year, at least 14 days apart Analyze for: Biochemical Oxygen Demand (BOD) Fecal coliform (or e. coli) Suspended solids ph Total residual chlorine State specific requirements: Nine states (CA, CT, GA, HI, ME, MI, NH, RI, and WA) - specific requirements Six states (CA, CT, ME, MI, NH, and WA) specific prohibitions on graywater discharge 12

13 Sampling: General Plan ahead Sampling only required if discharged in waters subject to permit Sample holding times vary Find accredited laboratories US laboratory not required Ensure laboratory can accommodate hold time Identify a laboratory that can assist with sample equipment and shipping of samples 13

14 2016 American Bureau of Shipping. All rights reserved. Air Emissions Requirements & EPA Penalty Policy Elias Kariambas Manager, Marine Business Development Global Marine Organization Athens, Greece 9 June 2016 TRADING IN US WATERS SEMINAR

15 MARPOL Annex VI: ECAs Emission Control Areas Baltic Sea North Sea and English Channel North America, Canada, Hawaii US Caribbean Waters, ECA, 1 Jan After a year of uncertainty Tier III NOx date finalized at MEPC.66 North America and US Caribbean 2016 Other areas as detailed by the ECA designation 15

16 NOx, SOx, PM: Reduction Potential Solutions Use alternative fuels (i.e. LNG) Infrastructure measures (i.e cold ironing) Selective Catalytic Reduction (SCR) Exhaust Gas Recirculation (EGR) Exhaust Gas Cleaning System (EGCS) Fuel switching to low sulphur residuals and distillates oils Technology NOx SOx CO 2 PM Use LNG as fuel yes yes yes yes Infrastructure measures (i.e cold ironing) yes yes yes yes Selective Catalytic Reduction (SCR) yes Exhaust Gas Recirculation (EGR) yes Exhaust Gas Cleaning System (EGCS) - yes - - Switching to low sulphur fuel oil - yes - yes - Means negative, negligible or positive effect. 16

17 NOx: Use of Dual Fuel Engines in ECAs Low pressure DF engines may meet Tier III NOx limits without exhaust after treatment technologies The Technical File would detail: Two different modes of operation, for example, Tier II (liquid fuel mode) and Tier III (gas fuel mode) The maximum liquid to gas fuel ratio to comply with the Tier III limits The Tier II to Tier III changeover procedure Details of the Auxiliary Control Devices (ACD) which limit operation in gas mode, e.g. during starting, stopping, low load, maneuvering and reversing which may result in higher transient NOx emissions EIAPP Certificate would be completed for both Tier II and Tier III NOx emission values MEPC.1 Circ. 854 provides guidance for situations where a ship is required to be in a gas free condition together with further guidance on Tier III compliance aspects in ECAs 17

18 NOx: Selective Catalytic Reduction (SCR) Over 500 ships over the past 20 years Consists of: Reducing agent storage tank Reducing agent feeding/dosing unit Injector and mixer Reactor with catalyst elements A control system The reducing agent used is often a water solution (40%) of urea (CO(NH2)2) Urea is not defined as a hazardous material, but as it has corrosive effects, the tank must be made of a suitable material The catalyst elements are normally dimensioned according to the need to meet the expected catalyst lifetime of 3 to 6 years or 12,000 to 24,000 running hours The minimum temperature is typically between 280 C and 340 C. The upper temperature limit is 400 to 450 C. 18

19 NOx: Selective Catalytic Reduction (SCR) The IMO Tier III NOx limits are measured on the EIAPP test cycle (paragraph 3.2 of NOx Technical Code 2008, as amended) and SCR operation is required to be tested on the test bed at 25%, 50%, 75% and 100% engine load points Urea increases CO 2 emissions by 1% as typical urea consumption is about 6.5 g/kwh resulting in about 4.8 kg CO 2 /MWh and engine typical CO 2 emissions are 600 to 650 kg CO 2 /MWh Soot blowing should be periodically activated to avoid fouling of unburned fuel and lubricating oil and remove dust and deposits from the catalyst layers An EGCS can be installed before or after a SCR unit to meet SOx and NOx ECA requirements Before the SCR unit: the exhaust would need to be dried/heated prior to the SCR unit After the SCR unit: the SCR unit would be designed for the use of higher sulphur fuel oils Used SCR elements are treated as hazardous material and have to be handled in line with the local disposal laws SFOC increase: 2-3 g/kwh at low loads 0 g/kwh when the engine load is sufficient to ensure proper exhaust gas temperature 19

20 NOx: Exhaust Gas Recirculation (EGR) EGR was first considered for marine-2-stroke-development in the early 1980s Recirculation of a portion of the exhaust gases, typically 20 to 40% Lowered amounts of oxygen and increased heat capacity result in decreased combustion temperatures which reduce the NOx formation Mainly consists of a: Exhaust gas wet scrubber A control valve A high pressure blower A water treatment system A control unit for controlling the water treatment system A NaOH dosing system Sludge tank Specific SFOC increase: 1-2g/kWh at all loads Scrubber of the EGR system has to comply with the washwater discharge criteria, of IMO Resolution MEPC.184(59) 20

21 SOx: Switching to Low Sulphur Fuel Oils Fuel storage, settling and service tank arrangement and capacity Separate pump for low-sulphur fuel oil operation Additional cooler/ chiller to control viscosity Separate piping arrangement with fuel change over mechanism Use of low BN lubrication oil for engines Modifications in electronic control system for both engines and boiler Modifications on boiler burner and relevant software system Fuel change over procedures 21

22 EPA Penalty Policy for Violations by Ships EPA Penalty Policy applicable to ships operating in the North American and U.S. Caribbean Sea Emissions Control Areas (ECAs) Purpose of the policy: Deter potential violators Ensure that the EPA assesses fair and equitable penalties Expedite the resolution of claims for certain categories of non-compliance The Policy is immediately effective Section 1908(b) of APPS, EPA may assess a civil penalty of $25,000 per violation per day. Day considered to be one calendar day. The preliminary deterrence amount includes two components: Economic benefit component (resulting from noncompliance) Gravity component (reflecting the seriousness of the violation) 22

23 The Economic Benefit Component Economic benefit of noncompliance Where: B=(Fe-Fw)*U Fe is the cost per metric ton of compliant fuel Fw is the cost per MT, of the non-compliant fuel that was used by the ship U is the amount (MT) of non-compliant fuel burned while in the US portion of the ECAs. Two methods for determining the cost of fuel: Direct reporting of fuel cost by ship s records Estimation as the average world-wide fuel costs Two methods for determining the amount of noncompliant fuel burned (U): Direct reporting of fuel used by ship s records with supporting calculations Estimation based on fleet characteristics and fuel consumption assumptions 23

24 Example of Economic Benefit Component For a Suezmax tanker, assume that the ECA distance is 200 NM. Appendix 1 Speed is 13.2 knots, M/E daily fuel consumption is 52.8 MT, A/E daily fuel consumption is 5.6 MT The time (T) to travel the ECA distance is calculated as follows: Distance/Speed = 200 nm/13.2 knots = 15.1 hours. The hourly fuel (HF) consumption is calculated as follows: M/E+ A/E daily consumption/ 24hours = ( )/24 = 2.4 MT/h. Therefore, the total fuel consumed (U) while traveling in the ECA is calculated as follows: U = T*HF = 15.1 hours * 2.4 MT/h = 36.2 MT. Assuming Fe $675/MT and Fw $328/MT. the economic benefit (B) is: B= (Fe-Fw)*U = ($675-$328)*36.2 = $12,

25 The Gravity Component Extent and gravity for first-time violations: Assuming fuel 1.25% sulfur, the gravity component is $500*U, where U is 36.2 MT: $18,100 The Suezmax tanker did not have a written fuel change-over procedure onboard: $2,500. Total gravity component is $18,100+$2,500 = $20,600 25

26 Overall Adjustment Technical measures aim to improve fuel efficiency or reducing the power Component Summary of Penalty Adjustment Factors Adjustment Factor(s) Economic benefit : $12,561 None Gravity: $20,600 Overall (EB + Gravity) $12,561 + $28,840 = $41,401 Degree of willfulness or negligence $4,120 Degree of cooperation - $2,060 History of noncompliance $6,180 Litigation risk Ability to pay Supplemental environmental projects Statutory maximum The overall penalty must be less than or equal to the statutory maximum which is calculated as $25,000 x (days of violation) x (number of violations) = $25,000 x 1 x 2 = $

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