intertanko some technical ®ulatory activities latin american panel 25 april 2006, rio de...
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INTERTANKOINTERTANKOSome Technical &Regulatory Some Technical &Regulatory
Activities Activities Latin American PanelLatin American Panel
25 April 2006, Rio de Janeiro25 April 2006, Rio de Janeiro
[email protected]@intertanko.com
Summary of the PresentationSummary of the Presentation1.1. Engine Room Waste Treatment Associate Engine Room Waste Treatment Associate
Systems Systems 2.2. Fixed Hydrocarbon Gas Detection Systems in Fixed Hydrocarbon Gas Detection Systems in
DH TankersDH Tankers3.3. Hot Work Onboard FPSOs - Hot Work Onboard FPSOs - An Alternative to
ISGOTT. . . If time permits. . . If time permits
4.4.Updates from IMO:Updates from IMO:a.a. Air emissions;Air emissions;b.b. STS Transfer in MARPOL;STS Transfer in MARPOL;c.c. Coating – Performance StandardCoating – Performance Standard
Engine Room Waste Treatment Engine Room Waste Treatment Associate SystemsAssociate Systems
(ERWTAS)(ERWTAS)Latin American PanelLatin American Panel
25 April 2006, Rio de Janeiro25 April 2006, Rio de Janeiro
[email protected]@intertanko.com
BackgroundBackground
• Alarming results from the USCG and other PSC Alarming results from the USCG and other PSC MoUs campaigns to control ships’ bilge water MoUs campaigns to control ships’ bilge water dischargesdischarges
• Ship engineers and master convicted for “Ship engineers and master convicted for “criminal criminal violation and deliberate and knowing conductviolation and deliberate and knowing conduct” – since ” – since 1998, 18 years cumulative prison sentences in US 1998, 18 years cumulative prison sentences in US
• Prosecution against shipping companies – since Prosecution against shipping companies – since 1998, cumulative $133 million in fines in US1998, cumulative $133 million in fines in US
• All types of vessels involvedAll types of vessels involved
• Prosecutions for: bypassing the OWS/OCM, flushing Prosecutions for: bypassing the OWS/OCM, flushing the OCM with fresh water, false logging / fake ORB, the OCM with fresh water, false logging / fake ORB, etc. etc.
INTERTANKO ActionINTERTANKO Action
• ISTEC identified need for two step approaches:–software - Guide for correct entries into the ORB
–hardware – a guide for best practices for design & operations
• ER ORB – entry errors and omissions– Section C is for fuel sludge not for discharge at sea but for incineration or
delivery to reception facilities
– Section D for bilge water collection, treatment and discharge through the 15ppm system
• ER ORB - difficulty to understand the terminology– “non-automatic discharge overboard or disposal otherwise of bilge water
which has accumulated in machinery spaces” (meaning accumulated in bilge water holding tank) – leads to wrong logging into section C instead of section D
– ”discharge” or ”transfer”
ERWTASERWTASScope of the GuideScope of the Guide
• A critical review of the current systems for A critical review of the current systems for treatment of engine room wastestreatment of engine room wastes
• Promote performance standards for enhanced Promote performance standards for enhanced onboard procedures and operationsonboard procedures and operations
• Innovative arrangements to improve the Innovative arrangements to improve the efficiency of these systemsefficiency of these systems
• Possible changes to relevant MARPOL Possible changes to relevant MARPOL regulationsregulations
• Advise for compliance procedural approachesAdvise for compliance procedural approaches
• Reference manual for crew trainingReference manual for crew training
Recent developments in IMORecent developments in IMO
• IMO considers a proposal to modify the current MEPC Circular 235 for the design of an Integrated Bilge Water Treatment System (IBTS).
• IBTS suggests for segregation of oil sludge, oil-water mixture and clean water holding systems; proposal limits the amount of oily water needed to be treated by the separation system before discharge to the sea
• INTERTANKO agrees with this as basic line but the Guide will go beyond it
Recent developments in IMORecent developments in IMO
• Previously: IMO resolution MEPC.60(33) - bilge water separators to be tested with a mixture of oil and water
• After January 1, 2005: IMO Resolution MEPC.107(49): – bilge water separators to be tested also with a stable
emulsion
–oil-in-water monitor to include a recording function for date, time, alarm and operating status. The recording of the operation to be stored for 18 month
General IssuesGeneral Issues
• Current onboard waste treatment systems Current onboard waste treatment systems not fit for purpose not fit for purpose
• Design assumptions inadequateDesign assumptions inadequate
• No hollisitc concept of waste treatment No hollisitc concept of waste treatment managementmanagement
• Lack of standardisation of the equipment Lack of standardisation of the equipment provided to shipsprovided to ships
• Unclear guidelines for loggingUnclear guidelines for logging
ERWTASERWTAS Principles for efficient waste
treatment
KNOW-HOW:
Oily waste chemistry
KNOW-HOW:
Oily waste management
• Process design• Upstream and
downstream conditions
• Understanding of how emulsions form and break down
• Selection of chemicals
Manufacturers Designers/Ship Operators
Waste contentWaste content
• Waste content:Waste content:–droplets of emulsified water/oil &– ultra-fine suspended solids
• Waste content:Waste content:–oiloil
– waterwater(50%-90%)(50%-90%)
– chemicalschemicals
– detergentsdetergents
– sootsoot
– greasegrease
– etc. etc.
• Three-phase separation is the key
www.alfalaval.com
Chemicals in the engine room
Cleaning &maintenance
Fuel oiladditives
Lube oiladditives
Chemicals forwater treatment
Acidcleaners
Alkalinecleaners
Petroleumcleaners
Boilerwater
Coolingwater
Seawater
Evaporators
Potablewater
Bilgewater
Dispersants
Corrosioninhibitors
Ash depositremovers
Soot & scaleremovers
Pour pointdepressants
Dispersants
TBNreserve
Corrosioninhibitors
Compatibiltycontrollers
Anti-wearagents
Anti-oxidants
SolutionsSolutions
• Minimise the amount of generated waste (Minimise the amount of generated waste (design and design and housekeeping solutionshousekeeping solutions))
• Prevent unnecessary mixture of oil, water, chemicals, Prevent unnecessary mixture of oil, water, chemicals, etc. (etc. (design solutiondesign solution))
• Standardising the design of the waste treatment Standardising the design of the waste treatment installation and of the equipment (installation and of the equipment (regulatory solutionregulatory solution):):– Capacity and number of sluge/bilge water tanksCapacity and number of sluge/bilge water tanks
– Location and design of the sludge/bilge water tanksLocation and design of the sludge/bilge water tanks
– Adequate drain piping and drain collection Adequate drain piping and drain collection
– Onboard incinerator capacityOnboard incinerator capacity
• Transfer of sludge to slop tanks ?Transfer of sludge to slop tanks ?
• Capacity of IncineraotrsCapacity of Incineraotrs
www.alfalaval.com
Clean drain
Main engine air cooler drain
Cooling fresh water, sea water
Steam drain
Bilge waterholding
Bilge water settling
LO sludge
FO sludge
Waste/Slop oil
Drains & leaks
Tank overflows
Bilge wells
Over-
board
Oil-Water Separator
Bilge water cleaning
Cleaner water processing
Drains & leaksCleaning &
maintenance
Purifers Purifers
Oil pump drains
Compressed air drains
Workshop drains
Recoveredoil
To boiler/Incinerator/(Slop tank)
ER waste treatment process
Tank design and managementTank design and managementFor bilge water and oily sludge/slop/waste oilFor bilge water and oily sludge/slop/waste oil
Settlingtank
Settledtank
Oil skimming
Oil skimming
Sludge drain
To treatment
Heat
HousekeepingFuel tank
Fuel oilsludge
Boiler
Incinerator
Ashore
Lube oilsludge
Tre
atme
nt
Overboard
Recycle?
Heavilypollutedwater
Condensateetc.
Tre
atme
nt
Chemicals- QSDs- Additives- Effectiveness?
Concentrated solids
Reduced chemical usage
Performance-driven development
Focus on “back-end” processes
Closed loops, re-utilisation & self-
containment
Minimised leakages
Reduced oil losses
Reduced water consumption
Process vision Equipment vision
WasteWasteminimisationminimisation
Procedures and PoliciesProcedures and PoliciesINTERTANKO ChairmanINTERTANKO Chairman
• There is a needs of some kind of an audit system or procedure to ensure that in fact crews are complying. While such an audit scheme does not have to audit every vessel all the time, there clearly is a need based upon what we hear from DOJ in the US, and what we are seeing elsewhere, to have some method of occasional checking on what is happening in practice aboard the ships.
• I think it is imperative for INTERTANKO to set a good example here and require some sort of an operational audit of environmental practices, AND, I think it is imperative for P&I Clubs to require the same.
Procedures and PoliciesProcedures and Policies
• State and display clear environmental policiesState and display clear environmental policies• Incentives for employees’ compliance and measures to Incentives for employees’ compliance and measures to
enhance safety and environmental proceduresenhance safety and environmental procedures• Zero tolerance for violations from the rules or lack of Zero tolerance for violations from the rules or lack of
reporting of problemsreporting of problems• Enhance ORB procedures – use the INTERTANKO Enhance ORB procedures – use the INTERTANKO
Guide for correct entries as a reference manualGuide for correct entries as a reference manual• Enhance onboard training/familiarisation proceduresEnhance onboard training/familiarisation procedures• Establish clear handover templatesEstablish clear handover templates• Seals and tags for overboard lines and flangesSeals and tags for overboard lines and flanges• Install lock boxes on monitoring equipment and Install lock boxes on monitoring equipment and
interlocks to prevent tricking of monitoring equipmentinterlocks to prevent tricking of monitoring equipment• Internal and external onboard audits Management/audit Internal and external onboard audits Management/audit
ConclusionsConclusions
• “New thinking” in the engine room• Waste-efficient equipment and solutions,
including configuration and size of bilge water tank, sludge tanks and incinerators
• Integrated process approach to the ER• Standardisation of equipment and automation• Training of seafarers• Adequate ship procedures and policies
Some results from field testing
• Results well below 15 ppm, normally < 5 ppm• Chemicals not needed• Separation temperatures of 60-70 °C
feed effluent
Fixed Hydrocarbon Gas Fixed Hydrocarbon Gas Detection Systems in DH Detection Systems in DH
TankersTankersLatin American PanelLatin American Panel
25 April 2006, Rio de Janeiro25 April 2006, Rio de Janeiro
[email protected]@intertanko.com
BACKGROUNDBACKGROUND
• DH structure on tankers > 5,000 dwt DH structure on tankers > 5,000 dwt
• Increased protection against accidental pollutionIncreased protection against accidental pollution
• Introducing operational and safety challengesIntroducing operational and safety challenges
• DH tankers designed to stay intact butDH tankers designed to stay intact but
• Complex structure to be inspected & maintainedComplex structure to be inspected & maintained
• Corrosive cargoes and atmosphere may lead toCorrosive cargoes and atmosphere may lead to
• Mechanical or fatigue damage/cracks andMechanical or fatigue damage/cracks and
• Risk of cargo “migration” from cargo tanks into Risk of cargo “migration” from cargo tanks into double hull void spacesdouble hull void spaces
BACKGROUNDBACKGROUND
• DH tankers are safe but a second layer of DH tankers are safe but a second layer of defence against cargo migration is neededdefence against cargo migration is needed
• Mitigation alternatives:Mitigation alternatives:–permanent inert atmosphere on empty tanks permanent inert atmosphere on empty tanks
oror
–means of effcient hydrocarbon gas detectionmeans of effcient hydrocarbon gas detection
• EMSA Panel on DH Tankers identified this EMSA Panel on DH Tankers identified this concern and recommended mandatory concern and recommended mandatory requirement for the latter alternativerequirement for the latter alternative
ACTION PLANACTION PLAN
• INTERTANKO involved and took the leadINTERTANKO involved and took the lead
• INTERTANKO drafted new SOLAS regulationINTERTANKO drafted new SOLAS regulation
• Draft sent to IACSDraft sent to IACS
• IACS/INTERTANKO to jointly finalise the new IACS/INTERTANKO to jointly finalise the new regulationregulation
• EMSA kept informed and in agreement to let the EMSA kept informed and in agreement to let the industry do the jobindustry do the job
• SOLAS regulation to be presented to IMO in SOLAS regulation to be presented to IMO in Dec. 2006, earliest date to come into force, July Dec. 2006, earliest date to come into force, July 2009/January 20102009/January 2010
THE PROPOSED REGULATIONTHE PROPOSED REGULATION
• Application: all tankers [5,000]/[20,000] dwt and above Application: all tankers [5,000]/[20,000] dwt and above built on or after [??]built on or after [??]
• New tankers below [5,000]/[20,000] dwt to comply with New tankers below [5,000]/[20,000] dwt to comply with current SOLAS II-2/5.7.2.2. (portable instruments and current SOLAS II-2/5.7.2.2. (portable instruments and fixed pipe system for emergency inerting)fixed pipe system for emergency inerting)
• Exemption from the rule: DH tankers with constant Exemption from the rule: DH tankers with constant operative inerting system operative inerting system
• Existing DH tankers:Existing DH tankers:– Equivalent systems: existing fixed gas detection systems and Equivalent systems: existing fixed gas detection systems and
existing operative systems for permanent inertingexisting operative systems for permanent inerting– Retrofitting DH tankers if none of such systems is onboardRetrofitting DH tankers if none of such systems is onboard
• IMO to develop Technical Specifications for new gas IMO to develop Technical Specifications for new gas fixed systems (as suggetsed by INTERTANKO/IACS)fixed systems (as suggetsed by INTERTANKO/IACS)
• Type approval for equipment/installationType approval for equipment/installation
TECHNICAL SPECIFICATIONSTECHNICAL SPECIFICATIONS
• Istallation: Istallation: – central unit for gas measurement and analysis located in a safe central unit for gas measurement and analysis located in a safe
area (e.g. cargo control room, navigation bridge, etc.) area (e.g. cargo control room, navigation bridge, etc.) – gas sampling pipes in all ballast tanks and void spaces adjacent gas sampling pipes in all ballast tanks and void spaces adjacent
to cargo tanks, including the forepeak tankto cargo tanks, including the forepeak tank
• Sampling points:Sampling points:– 2/space for tankers >[50,000] dwt (upper point at [1-2] m from 2/space for tankers >[50,000] dwt (upper point at [1-2] m from
the top and lower point at [1-2] m (min. 0.5 m) from the bottom)the top and lower point at [1-2] m (min. 0.5 m) from the bottom)– DB ballast tanks only: no requirement for upper sampling pointDB ballast tanks only: no requirement for upper sampling point
• Sampling and gas analysis every 30 minutesSampling and gas analysis every 30 minutes• Alarms for gas leakage and for clogged sampling pipesAlarms for gas leakage and for clogged sampling pipes• Design for:Design for:
– easy testing and calibrationeasy testing and calibration– permitting use of portable instrumentspermitting use of portable instruments
Hot Work Onboard FPSOsHot Work Onboard FPSOs An Alternative to ISGOTT
Latin American PanelLatin American Panel
25 April 2006, Rio de Janeiro25 April 2006, Rio de Janeiro
[email protected]@intertanko.com
Background
• Life maintenance of FPSO’s and FSO’s involves steel renewals and modifications within enclosed vessels and tanks
• Currently there are no specific industry guidelines addressing the associated hot work issues for FPSO’s
• The closest and most frequently referenced guidelines are the “International Safety Guide for Oil Tankers & Terminals”, (ISGOTT)
Background• ISGOTT guidelines written for tankers, and
found consistently impractical to apply to a producing FPSO
• Impractical to treat FPSO’s and FSU’s as tankers; steel plates must be changed-out on station, whilst producing, rather than during a ballast voyage or in dry dock
• There is a need for the industry to develop an alternative approach, specific to FPSO’s
ISGOTT requirementsThe fundamental problem arises from the ISGOTT requirement that
“Adjacent cargo tanks, including diagonally positioned cargo tanks, should either have been cleaned and gas freed to hot work standard, or cleaned and hydrocarbon vapour content reduced to not more than 1% by volume and kept inerted, or completely filled with water.”
ISGOTT requirements
Consequence of reduced storage – smaller offload parcels, split offloads or dead freight
An alternative to ISGOTT for FPSO’s
• Hotwork on any FPSO conducted in accordance with an industry Guide/Code of Practice
• Code of Practice may result in certain deviations from ISGOTT, but also the implementation of additional safety precautions
• Code of Practice to be based on many years of cumulative operating experience
• Code of Practice may suggest that no hot work takes place within 500mm (or exceptionally 250mm) of a live bulkhead (250mm has been verified by heat transfer tests as acceptable with respect to heat transfer)
An alternative to ISGOTT for FPSO’s
F ig u re 3 : C ase 1, A pp lica tion o f S B M req u irem ents outw ith the 500m m zone
Case 1: Hotwork within tank at a distance of more than 500 mm from a boundary bulkhead
An alternative to ISGOTT for FPSO’s
Case 2: Hot work in tank working within 250mm of a boundary bulkhead.
An alternative to ISGOTT for FPSO’s
Tanks may be put in a safe condition in a number of ways:
• cleaned and prepared as per hot work tank, (cases where hot work is needed in both tanks)
• cleaned, ballasted to a height of 2m above the location of the hot work, and inerted
• crude oil washed, water washed, and inerted with clean IG
An alternative to ISGOTT for FPSO’s
HW on a Common Bulkhead• reverse side thoroughly cleaned and tank
ballasted to above work area• adjacent tank COW’d, water washed &
inerted with clean IG.• 02 in adjacent tank less than 5%• purging in adjacent tank to reduce HC
content to less than 1% by volume.
An alternative to ISGOTT for FPSO’s
Additional requirements to ISGOTT include:• Specific hotwork procedures are developed onboard
by Unit Superintendent, Safety Officer and Cargo Supt.
• The procedure is reviewed onboard by risk assessment. If the risk level is determined as High, further safeguards must be introduced to reduce the risk to Medium or Low.
• Independent HW Safety Officer is present.• All procedures are then reviewed and approved by
the Shore Base Manager, and in the Production Management Office.
An alternative to ISGOTT for FPSO’s
• All hotwork requires a Permit to Work• An independent safety officer, reporting to the Unit
Superintendent, is present during the work execution• Tank setup (lighting, access and ventilation) is a
significant factor in the safe implementation of repair procedures
Future additional issues
Refinement of local cleaning definition to cover such things as rope access welding.
Procedures and facilities to cover working
within 250mm of a live bulkhead.
Conclusions
• It has been found consistently impractical to fully apply ISGOTT to producing FPSO’s
• Hot work procedures on FPSO’s need to be specific to the work being performed. Risk assessment is an effective tool to assess the suitability of procedures.
• There needs to be a dialogue in the industry, and a sharing of experience
Conclusions
• INTERTANKO Offshore Tanker Committee (IOTC) agreed to develop an industry guide for HW procedures on FPSOs
• Link with OCIMF for further cooperation• Approach towards UKOOA and OLF (Norwegian Oil
Industry Association) for coordination• Inviting interested members to contribute to the
drafting process and support the recognition of such an industry guide by authorities in countries with offshore activities
Updates from IMOUpdates from IMOAir emissions; STS Transfer in Air emissions; STS Transfer in
MARPOL; Coating – MARPOL; Coating – Performance StandardsPerformance Standards
Latin American PanelLatin American Panel
25 April 2006, Rio de Janeiro25 April 2006, Rio de Janeiro
[email protected]@intertanko.com
Air Emissions
• Revision of MARPOL Annex VI – 2008/2010• SOx – lower limits (global & SECAs); more SECAs;
scrubbers; emission trading; • NOx – lower limits; different measures on 2-stroke, 4-stroke
large and 4-stroke smaller engines; existing tankers; two-step approach (2010/2014)
• VOC emissions – loading (equipment); in-transit (VOCON)• Particulate Matter – concern but lack of clear definition• Cold Ironing• Two correspondence groups• Inter-sessional meeting in Norway (November 2006)
STS Transfer – MARPOL regulation (?)
• Proposal by Spain and Mexico
• To mandate reporting 24 hrs. in advance of any STS operations to the nearest Coastal State (no matter ships in international waters)– Name, flag, call sign and IMO No. of the ship;– Date, time and geographical location of the planned transfer or
supply of fuel;– Fuel type and quantity;– Planned duration of operation;– Name, flag and call sign of the other ship involved in the operation;– Type of fendering;– Request for a pilot if necessary.
STS Transfer – MARPOL regulation (?)
• Both ships to keep permanent contact with the ”national point of contact” during the operation and comply with instructions given to them
• Prior to commencing operations both ships to sign ”their joint satisfaction the checklist”
• Regulation 44 - Powers of the coastal State - The coastal State off whose shores an oil-transfer or fuel-supply operation between two ships is taking place shall adopt such measures as it considers reasonable in order to safeguard its interests, and may even refuse to authorize such an operation if, in the judgement of the competent authorities, there arises a situation that is clearly dangerous.
• No STS operations in Special Areas and PSSAs.
STS Transfer – MARPOL regulation (?)
• Controversial and highly political issue• All South American Countries provided support to
Spain/Mexico• IMO Correspondence Group requested to:
– develop draft regulation as new Chapter 8 of the revised MARPOL Annex I
– explore if additional generic requirements are necessary for special areas and PSSA's taking into account BLG’s decision that a total ban is considered inappropriate
– consider whether different requirements should apply to STS bunkering operations
– further consider the advantages and disadvantages of including FPSO's and FSU's
STS Transfer – MARPOL regulation (?)INTERTANKO views
• Understanding the concept and intent• However, one should first demonstrate a compelling need to
instigate such regulations• Concern that bunkering operations and STS operations
appeared to be regarded as effectively the same operation within the proposals; they are different and they should not necessarily be covered by the same requirements
• Requested that the question of banning STS operations in MARPOL special areas and/or PSSA's needed careful consideration and should be reviewed by the IMO Legal Committee
• There is an associated risk that such regulations could force these operations further offshore and subject vessels to worse sea conditions and potentially greater risks.
• Advice and strong support from LAP are needed.
Coating – Performance StandardsCoating – Performance Standards
• Mandatory requirements for coating of ballast tanks in all ships
• Separate standard for Void Spaces – IMO correspondence group
• Mandate coating on COTs (top and bottom) – EMSA Panel on DH Tankers
• Develop performance standards for COTs – IACS/Industry Working Group