2013 Vessel General Permit -

Requirements for Vessels Visiting US PortsRequirements for Vessels Visiting US Ports

TRADING IN US WATERS SEMINAR

Elias Kariambas Manager, Marine Business DevelopmentGlobal Marine Organization

Athens, Greece9 June 2016

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

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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:

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� Notice of Intent required for vessels:

� Greater than or equal to 300 Gross Tons, or

� Having a ballast capacity of at least 8m3

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

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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

Bilgewater (VGP 2.2.2)

� Newbuild” vessels greater than 400 gross tons

� Oil and Grease Content analyzed once per year by:

� Method ISO 9377-2 (2000) Water Quality–Determination of Hydrocarbon Oil Index–Part 2: Method Using Solvent Extraction and Gas Chromatography; or

� EPA Method 1664

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� 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

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

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– 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

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

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Biocide or ResidualLimit

(Instantaneous Maximum)

Chlorine Dioxide 200 µg/l

Chlorine

(Total Residual Oxidants (TRO as TRC)) 100 µg/l

Ozone

(Total Residual Oxidants (TRO as TRC)) 100 µg/l

Peracetic Acid 500 µg/l

Hydrogen Peroxide

(for systems using Peracetic Acid) 1,000 µg/l

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

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� 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

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

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– 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 Monitoring3 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

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

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� European Ecolabel

� Nordic Swan

� Swedish Standards SS 155434 and 155470

� Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) requirements

EAL Technical Infeasibility

� No EAL approved for use in given application

Oil-To-Sea Interfaces Identified by VGP Section 2.2.9

Controllable Pitch Propeller (CPP)

Thrusters

Paddle Wheel Propulsion

Stern Tubes

� Products which are pre-lubricated and no EAL is available

� EAL meeting specifications is not available within any port in which vessel calls

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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

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

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

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� 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

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

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� Ensure laboratory can accommodate hold time

� Identify a laboratory that can assist with sample equipment and shipping of samples

©2016 American Bureau of Shipping. All rights reserved.

Air Emissions Requirements &

EPA Penalty Policy EPA Penalty Policy

TRADING IN US WATERS SEMINAR

Elias KariambasManager, Marine Business DevelopmentGlobal Marine Organization

Athens, Greece9 June 2016

� Emission Control Areas

� Baltic Sea

� North Sea and English Channel

� North America, Canada, Hawaii

� US Caribbean Waters, ECA, 1 Jan. 2014

MARPOL Annex VI: ECAs

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2014

� 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

� 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

NOx, SOx, PM: Reduction Potential Solutions

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Technology NOx SOx CO2 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.

� 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,

NOx: Use of Dual Fuel Engines in ECAs

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� 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

� 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

NOx: Selective Catalytic Reduction (SCR)

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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.

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 CO2 emissions by 1% as typical urea consumption is about 6.5 g/kWh resulting in about 4.8 kg CO2/MWh and engine typical CO2 emissions are 600 to 650 kg CO2/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

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� 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 hazardousmaterial and have to be handled in line with thelocal 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

� 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

NOx: Exhaust Gas Recirculation (EGR)

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� 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)

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

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� 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

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 assessesfair and equitable penalties

Expedite the resolution of claims

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� 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)

The Economic Benefit Component

� Economic benefit of noncompliance

B=(Fe-Fw)*U

Where:

� 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.

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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

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

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� 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 = (52.8 + 5.6)/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 = $12,561.

The Gravity Component

� Extent and gravity for first-time violations:

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� 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

Overall Adjustment

� Technical measures aim to improve fuel efficiency or reducing the power

Summary of Penalty Adjustment Factors

Component Adjustment Factor(s)

Economic benefit : $12,561 None

Gravity: Degree of willfulness or

negligence $4,120

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Gravity: $20,600

negligence $4,120

Degree of cooperation - $2,060 History of noncompliance $6,180

Overall (EB + Gravity)

$12,561 + $28,840 =

$41,401

Litigation riskThe overall penalty must be

less than or equal to thestatutory maximum which is

calculated as $25,000 x (days of violation) x (number of

violations) = $25,000 x 1 x 2 = $50.000

Ability to pay

Supplemental environmental projects

Statutory maximum

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