alaska tanker company - prince william sound … tanker company atc’s support for ballast water...

Alaska Tanker CompanyPrince William Sound Regional Citizens Advisory Council

January, 2016

DearAnilandallAlaskaTankerCompanyStaff,

Congratulationsoncompleting20millionman‐hourswithonlyonelosttimeinjuryandspillingnooiltosea.Forthelast14years,AlaskaTankerCompanyhasexemplifiedtheworkingrelationshipweallstrivefor– keepingoureconomygoingintheabsolutesafestwaypossible.ThisunprecedentedaccomplishmentwouldnothavebeenachievedwithoutthehardworkanddedicationofeveryoneatATC.

Yourcommitmenttoeachother,throughteamwork,isacommitmenttotheentirewestcoastoftheUnitedStatesandCanada.Whileyourshipshavequietlycarriedone‐thirdofAlaskaNorthSlopecrudeoilalongourshores,theaccoladesfromuslivinginthoseareashave,attimes,beenjustasquiet.Howeverpleaseknow,thatwerecognizealltheeffortputforthtoachievethisworld‐classmilestoneandsincerelythankeachandeveryoneofyou.

Bestwishesandcontinuedsafety,

AmandaBauerPresidentPrinceWilliamSoundRegionalCitizensAdvisoryCouncil

Alaska Tanker Company

ATC’s Ballast Water Management Program

Agenda1) What ATC has done to support Ballast Water research

2) Summary of IMO and USCG requirements‐ Application to ATC’s fleet‐What actions ATC has taken to assess system availability

3) Projected view of Ballast Water ‐ Status of the USCG Type Approval of the Ballast

Water Management Systems (BWMS) available

4) Why it is important for ATC to have a system that’s proven

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ATC’s Support for Ballast Water (BW) Treatment Research

1999‐2003: Initial prototype Nutech‐O3 ozonation system installed and tested onboard TONSINA. Cost for system installation was over $3 million,

including 11 miles of ozone piping in the BW tanks.

Research lead by Dr. Russell Herwig of University of

Washington

Results were successful for all organism sizes tested with the exception of the amphipods (GT 50 microns.) Continued testing

recommended.

ATC has continually supported the effort to find and develop new ballast water treatment technology:

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Sampling zooplankton with vertical plankton tow.

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ATC’s Support for Ballast Water Treatment Research

Hawaii

2005‐2008: Second prototype Nutech‐O3 ozonation system installed and tested onboard PRINCE WILLIAM SOUND. Cost for system installation was over

$1 million.

Research performed by David A. Wright, Univ. of MD Center for Environmental

Science.

Results show the ability to meet the IMO standards for all organism sizes with

the exception of nematodes (10‐50 micronrange.) Further testing recommended.

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Hawaii

2008: ALAKSAN NAVIGATOR provided the platform for Smithsonian Environmental Research Center (SERC) testing in October 2008.

Research was performed to identify methods to verify BWE using the chemical constituents in seawater (tracers) to distinguish water that originates in ports (bays and estuaries) from open ocean water.

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Hawaii

2012: All four ATC ships have had their ballast water tested at least once, with 2 ships tested twice, this summer while in port in Valdez, AK.

The Smithsonian Environmental Research Center’s (SERC) objective for this study is to characterize the biology of ballast water to assess propagule delivery during

approximately 20 voyages into Valdez, and into the Chesapeake Bay.

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ATC’s Ballast Water Management Practices

ATCs’ Current Ballast Water (BW) Management Practice:

Since the implementation of the NPDES VGP, ATC has been performing full exchanges on all ballast water tanks when the ships are at sea. These include:

Full flow‐through exchange on ballast tanks in the cargo block.

Complete empty/refill exchanges on all other ballast tanks.

Regular use of Mud‐Out when loading in coastal waters.

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ATC’s Ballast Water Management System installation dead line dates

ATCs’ Schedule for Vessel Dry-dockings and possible BWMS installation opportunities:

ShipNext ATC

Scheduled Dry‐dock (DDX)

Required IMO Installation Date

(next Renewal Survey after ship’s Anniversary Build date in 2016, or first Renewal Survey after

Entry into Force)

Required USCG BW Installation Date

(At Next Required DDX after 1/1/16)

Alaskan Frontier Summer 2018 6/21/19 8/4/18

Alaskan Explorer Summer 2019 3/20/20 9/27/19

Alaskan Navigator Summer 2020 11/21/20 8/27/20

Alaskan Legend Summer 2016* 8/17/21 8/17/21*

9* USCG Extension granted to extend AK Legend’s date beyond the original USCG BWMS Installation date of 8/18/16.


ATC’s Ballast Water Management Practices

IMO, USCG, EPA and California Ballast Water treatment performance standards:

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Organism Size Class CA Interim Discharge Stds(2007)

IMO Discharge Stds (2005) Fed. Standards (2012)

2013 NPDES Vessel General Permit

(VGP)

Number of living organisms: Number of viable organisms:

Number of living organisms:

Number of living organisms:

Larger than 50 µm (micrometer or one

millionth of a meter) in minimum dimension

No detectable living organisms < 10 per m3 < 10 per m3 of BW < 10 per m3 of BW

10‐50 µm in minimum dimension < 0.01 per ml < 10 per ml < 10 per ml < 10 per ml

Less than 10 µm in minimum dimension:

< 1,000 bacteria per 100 ml< 10,000 viruses per 100 ml No Standard No Standard No Standard

Escherichia. coli < 126 cfu (colony forming units) per 100 ml < 250 cfu per 100 ml < 250 cfu per 100 ml < 250 cfu per 100 ml

Intestinal enterococci < 33 cfu per 100 ml < 100 cfu per 100 ml < 100 cfu per 100 ml < 100 cfu per 100 ml

Toxogenic Vibrio cholerae< 1 CFU per 100 ml; or < 1 CFU per gram of wet weight of zoological

samples

< 1 CFU per 100 ml; or LT 1 cfu per 1 gm wet weight of

zooplankton sample< 1 cfu per 100 ml < 1 cfu per 100 ml

(human Cholera)< 1 CFU per 100 ml; or < 1 CFU per gram of wet weight of zoological

samples

< 1 CFU per 100 ml; or LT 1 cfu per 1 gm wet weight of

zooplankton sample< 1 cfu per 100 ml < 1 cfu per 100 ml


ATC’s Current Evaluation of Potential BWMSs

To identify a compliant system ATC has been evaluating potential BWMSs. The following manufactures have been considered:

To install a BWMS by 8/4/18, ATC will need to:

Order long lead items by November 2016.

Identify USCG Type approved, and vessel compliant system.

Begin purchasing these systems in summer of 2017 to able to meet AK FRONTIER’s next scheduled dry‐dock in the summer of 2018 .

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The following manufacturers have been eliminated because of failure to meet operating capacity or safety issues:

The following manufacturers have been eliminated because of failure to meet operating capacity or safety issues:

Alfa Laval

• Insufficient capacity max. rate 2500 m3 per hour.

JFE


Mahle


OptiMarin


Ecochlor

• Substantial risk with handling of sulfuric acid a minimum of 3 times/yr

RWO


Hyde Marine

• Capacity wise system is at the working limit at 6000 m3

Techcross

• System does not reach rated capacity.

NK‐O3

• Safety issues surrounding use of O3.

Quingdao OceanGuard


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The following manufacturers are still being considered, however, neither have received system USCG Type Approval, nor have

demonstrated that they can comply with the California interim BW discharge performance standards:

The following manufacturers are still being considered, however, neither have received system USCG Type Approval, nor have

demonstrated that they can comply with the California interim BW discharge performance standards:

Oceansaver•Advantages:‐Manufacturer has applied for USCG Type

Approval. ‐Meets capacity.‐ Can treat at low dosage levels of chlorine

which does not harm protective coatings.‐ Does not require the carriage or use of any

chemicals.

Severn Trent’s BalPure

•Advantages:‐Manufacturer has applied for USCG Type

Approval.‐Meets capacity.

•Disadvantages:‐ High chorine levels may effect tank coatings.‐ Requires the carriage and addition of sodium bisulfate for neutralization of treated BW prior to discharge.

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The USCG expects the first BWMS to receive Type Approval in Summer, 2016. This will not be a UV system. (Maritime Executive, 12/23/15)

• Currently manufacturers have filed 30 letters of intent with the USCG, expressing their intention to start testing a ballast water treatment system. The Coast Guard estimates about half that number are presently at some stage of testing with one of the five approved independent labs.

• Independent labs have indicated that the test facilities are booked through the end of 2015 and for most of 2016

The USCG announced on 12/14/15 that the Most Probable Number methodology of testing UV systems is not considered an equivalent alternative to the testing method prescribed in the USCG regulations for Type Approval of BWMSs.

• As a result of this decision, as reported by Maritime Executive, the industry foresees a delay when the Coast Guard will conclude on the first type approval of any BWMSs.



This means currently are no systems available for purchase, and there still may not be by the summer of 2017 when needed for AK Frontier.

This means currently are no systems available for purchase, and there still may not be by the summer of 2017 when needed for AK Frontier.

The USCG and BWMS manufacturers need more time to continue assessing systems in order to achieve system USCG Type Approval.

ATC needs more time to continue to search for a system that reports they can meet the CA BW discharge performance standards.

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It is imperative that ATC have a BWMS that is proven and operationally tested.It is imperative that ATC have a BWMS that is proven and operationally tested.

ATC’s Mission of safe, reliable transport of 1/3rd of Alaska’s oil helps protect our shared environment and generates over 30% of Alaskan tax revenues

1 in every 10 bbls of oil shipped into both Washington and California is on ATC ships

This mantle of responsibility compels us to be careful and conservative in our selection & installation of BWMSs.

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alaska tanker company - prince william sound … tanker company atc’s support for ballast water...

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