Chemical Tankers:

Regulatory Update Janet Strode

General Manager

International Parcel Tankers Association

Application of Inert Gas

Carriage of Used Cooking Oil

Disposal of oil from galleys

Review of IBC Code

Review of requirements for discharge of residues

Carriage of Biofuels

Low Flash Fuels

Ballast Water Management

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Application of

Inert Gas • Amendments to SOLAS now

formally adopted and enter

into force 1 January 2016

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• Apply to new oil tankers (below 20,000 DWT) and new

chemical tankers

• Lower size limit of 8,000 DWT

• Chemical tankers may inert prior to discharge rather

than prior to loading

Cargoes with Oxygen-

dependent inhibitors IBC Code states that must not be inerted until immediately

prior to commencement of discharge

MEPC Circular (later to be included in amendment to the IBC code) states that shipper must advise the level of oxygen required for the inhibitor to work properly

PPR 2 agreed to unified interpretation of SOLAS:

“When a product containing an oxygen-dependent inhibitor is carried on a ship for which inerting is required under SOLAS regulation II-2, the inert gas system shall be operated as required to maintain the oxygen level in the vapour space of the tank at or above the minimum level of oxygen required under paragraph 15.13 of the IBC Code and as specified in the Certificate of Protection”.

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Carriage of Used Cooking Oil

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PPR 2 agreed to the

assignment of carriage

requirements for Used

Cooking Oil:

a c d e f g h i’ i” i’” j k l m n o

Used

cooking

oil

X S/P 2 2g Open No - - - Yes O No ABC No

15.19.6;

16.2.6;

16.2.9

Disposal of Cooking Oil from

Ships’ Galleys

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Proposals for interpretation of MARPOL Annex V to allow for

disposal of cooking oil

• Via sludge tank

• Directly into fuel tank

PPR 2 rejected these

suggestions – cooking oil

must be

• Disposed of ashore, or

• incinerated

REVIEW OF THE IBC

CODE

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Type 1

Acetone cyanohydrin (+1G)

Carbon disulphide

Crotonaldehyde (+1G)

Ethylene chlorohydrin

Glutaraldehyde solutions

Lactonitrile solution

Nitrating acid (+1G)

beta-Propiolactone

Propionitrile

Trixylyl phosphate

Type 2

Alkylaryl phosphate mixtures

1,5,9-Cyclododecatriene

N,N-Dimethyldodecylamine

Methylcyclopentadienyl manganese tricarbonyl (+2G)

1,2,3-Trichlorobenzene (molten)

Tricresyl Phosphate (1% or more ortho-isomer)

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18 Products e.g.

Adiponitrile

Dibutylamine

Fluorosilicic acid (+2g)

Furfural

Hexanol

Nonanoic acid

Octanoic acid

Sulphuric acid

18 Products e.g.

Acetonitrile

Acrylamide solution

Butyl acrylate

Diisopropylamine

Ethylene dichloride

Methyl acrylate

Methyl methacrylate

Type 2

Type 3

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Chapter 18

to

Type 3

Diethylene glycol

Ethylene carbonate

Glycerine

Hexamethylenetriamine solutions

Hexylene glycol

Methyl propyl ketone

Polyaluminium chloride solution

Polyglycerin sodium salt solution

Potassium formate solution

Propylene carbonate

Propylene glycol

Sodium sulphate solutions

Triethylene glycol 10

Toxic Products

“T” in column k of chapter 17 indicates presence of

toxic vapours

Currently approx. 190 products

Additional 260 products to be given this notation –

total 60% of products in Code

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For example:

Alcohols, including:

Methanol

Octanol

Hexanol

Acids, including

Phosphoric

Sulphuric

Citric

Glycols, including

Diethylene glycol

Hexylene glycol

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• Ethylbenzene

• Ethylene Cyanohydrin

• Some Olefin mixtures

• Potassium hydroxide

• Styrene monomer

• Tall oil

• Toluene

• Triethanolamine

• UAN

• Vinyl acetate

Increased special requirements

15.17: Increased ventilation

15.19: Overflow control

15.12: Toxic products

Exhaust openings

Vapour return line

Stowage

Not adjacent to oil fuel tanks

Separate piping systems

Separate vent systems

PV valves minimum 0.02 gauge

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Reg 3.7.1

Bow and stern unloading lines cannot be used unless

approved by the Administration

Reg 7.1.6

Heating or cooling medium must be external to the tank

or kept separate from other ship’s services

Reg 13.2

Must have toxic vapour detection equipment or, if not

available, obtain an exemption from the Administration –

necessity for additional breathing-air supply

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NB: 8 products currently not subject the Code to be

subject to these increased requirements:

Diethylene glycol

Ethylene carbonate

Hexamethylenetriamine solutions

Hexylene glycol

N-methylglucamine solution

Methyl propyl ketone

Polyglycerin, sodium salt solution

Propylene carbonate

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Review of discharge

requirements under

MARPOL Annex II

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Submission to PPR 1 (2014) Denmark, the Netherlands, Norway, Poland, Sweden and the United Kingdom

“…… discharge of High-Viscosity and Persistent Floating products and their impact on the environment.”

approximately 66 recorded incidents of waxes and vegetable oils washing up on beaches since 2010

“Not classic pollution incidents [but]: impairs the recreational and tourism values of beaches

and coastlines

Society bears the expense of the clean-up,

many seabirds die as a result of becoming coated in the substance”

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Submission to MEPC 68 (April 2015) Germany, Netherlands, Norway, United Kingdom,

Denmark, Sweden and Spain

Proposal for new item to be added to work

programme of PPR Sub-Committee

“…in order that the discharge requirements for cargo

residues and tank washings are reviewed for high-

viscosity and persistent floating products, to reduce

the impact on the environment”

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“following list of items would need to be further

evaluated as possible contributors: “

effectiveness of stripping requirements, taking into account clingage

definition of solidifying substances

definition for high-viscosity substances

the definition of "en route" for the purposes of discharge

adequacy of pre-wash requirements

availability/adequacy of reception facilities

the utility and ongoing need for MARPOL Annex II, regulation 4.1.3.

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Stripping Requirements New Ships

(from 2007)

Existing IBC

(1986-2006)

Existing BCH

(Prior to 1986) Other Ships

X 75 litres + prewash

100 litres + 50 litres tolerance + prewash

100 litres + 50 litres tolerance + prewash

No carriage

Y 75 litres 100 litres + 50 litres tolerance

300 litres + 50 litres tolerance

No carriage

Z 75 litres 300 litres + 50 litres tolerance

900 litres + 50 litres tolerance

New Ships: 75 litres

Existing Ships: empty tanks to the most practicable extent

OS Unrestricted Unrestricted Unrestricted Unrestricted

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Stripping Test

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• Carried out with water

• Trim and list recorded

• Time taken recorded

Regulation 13.1.2

“Before any prewash is

carried out ……the relevant

tank shall be emptied to the

maximum extent in

accordance with the

procedures described in the

Manual.”

Solidifying and High Viscosity

Substances

“ a solidifying substance is a substance which :

in the case of a substance with a melting point of less

than 150C, is at a temperature of less than 50C above

its melting point at the time of unloading; or

in the case of a substance with a melting point of

equal to or greater than 150C, is at a temperature of

less than 100C above its melting point at the time of

unloading

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“High-viscosity substance means a noxious liquid

substance in category X or Y with a viscosity equal to

or greater than 50 mPa’s at the unloading temperature”

“equal to or greater than…50 mPa’s at 200C”

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“…underway on a course or courses,

including deviation from the shortest direct

route, which as far as practicable for

navigational purposes, will cause any

discharge to be spread over as great an

area of the sea as is reasonable and

practicable.”

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Definition of “en route”

Include all products defined as “persistent

floaters” in the GESAMP Composite List?

Possibly not full prewash but hot/cold wash for

set number of cycles of TC machine?

GESAMP Composite List: approx. 180 Persistent

Floaters, including:

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Prewash Requirements

All vegetable oils and animal fats,

including derivatives (Olein, Stearin, Distillates, etc)

FAME

Waxes

Acids, e.g.

Lauric

Neodecanoic

Oleic

Fatty acids

Alcohols, e.g.

Dodecanol

Octanol

Fatty alcohols

Alkylates

Phthalates

Polyolefins

Tall oil

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Reception facilities?

Additional port time?

Operational issues?

Increased emissions in port areas?

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Regulation 4.1.3 “This exemption was requested based on the

assumption that there would be a shortage of Ship Type

2 tonnage when Annex II of MARPOL came into force on

1 January 2007.”

“…the use of 4.1.3 causes confusion and problems for

administrations when issuing this exemption, as the

vessel have to switch between ST 2 and ST 3…”

“…therefore it is proposed that this exemption be

removed to reduce the burden on administrations.”

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CARRIAGE OF

BIOFUELS

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Brazil and Finland submitted document to

MEPC:

Proposal for inclusion of “technically suitable”

biofuels under Annex I (rather than Annex II)

Renewable Diesel (Alkanes C10-C26)

Renewable aviation fuel (Alkanes C10-C17)

Renewable Naphtha (Alkanes C5-C7)

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Vastly increased demand for biofuels

Classification should be based on end product, rather than feedstock

Carriage in Annex I tankers would mean less transits, which would in turn reduce GHG and other emissions

Fewer washing operations – better for the environment

No evidence presented for these claims

Argument

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Fundamental change of philosophy

Suggestion that Type 2 chemical tankers are not as

environmentally friendly as oil tankers

Would this lead to calls for other products to be

switched to Annex I?

FAME ?

Vegetable oils?

Implications

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Low Flash

Bunkers

US and Canada recognise that with EIF of reduced

sulphur limits availability of fuel will be tight

Claim that ships will be at disadvantage because of 600C

flashpoint limit

Road diesel fuels readily available but currently can’t be used on

ships because of flashpoint (550c in Europe and 520C in US)

Propose flashpoint limit for bunker fuel to be reduced from

600C to 520C

Safety issues?

Implications for cargoes?

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BALLAST

WATER

MANAGEMENT

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30 states

35% of world

tonnage

12 months

Entry into

Force Currently:

• 44 States

• 32.86% of world

tonnage

BWM Convention

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Effective Dates as per Assembly Resolution 1088

Source: ABS

Type Approval Process

Industry has expressed concerns that the approval

process as per the IMO’s G8 Guidelines not fit for

purpose

Concern expressed that individual systems may not

operate correctly in

Different salinities (fresh, brackish, marine)

Different water temperatures (cold, temperate, tropical)

Different sediment loads

Where flow rates are less than Treatment Rated Capacity

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MEPC 67 agreed to review of the G8 standard, to include

following elements: Testing using fresh, brackish and marine waters;

testing considering the effect of temperature in cold and tropical waters

specification of standard test organisms for use in testing

challenge levels set with respect to suspended solids in test water

type approval testing discounting test runs that do not meet the D-2 standard

the results of test runs being "averaged";

type approval testing realistically representing the flow rates the system is approved for

differences between type approval protocols of Member States

“Early adopters” not to be penalised

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United States

Vessel

Ballast Capacity

Compliance Date

Constructed on or after

1 December 2013 All Delivery

Constructed before 1

December 2013

< 1,500 m3 First scheduled drydocking after

1 Jan 2016

1,500 – 5,000 m3 First scheduled drydocking after

1 Jan 2014

> 5,000 m3 First scheduled drydocking after

1 Jan 2016

Treatment systems must be approved by USCG

Currently no systems approved

Some 45 systems given approval as “alternate”

systems, for up to 5 years

Some estimates are that first approvals will not come

out until mid-2016

What does a responsible owner do?

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Thank you for your attention

25 years serving the chemical tanker industry

www.ipta.org.uk

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