Environmental Developments: Practical Implications and Considerations for the tanker operator Tim...

Environmental Developments: Practical Implications and Considerations for the tanker operator

Tim Wilkins: INTERTANKO Seminar, Mumbai 2005

Environmental Developments

Ballast Water Management & Ship Recycling

The Practical Implications and Considerations

for the tanker operatorTim WilkinsEnvironmental Manager

INTERTANKO London Office



Ballast Water Management: Practical Implications and Considerations

• International Ballast Water Convention plus 14 Guidelines

• We want implementation to be simple, effective and practical

• National Implementation of the International Ballast Water Convention – with national interpretations

• We want to avoid deviation from the International Convention

Largest Impact on Shipping since MARPOL 73/78




1. Meeting the Treatment Standard• Ballast Water Exchange and/or Treatment Technology

2. Demonstrating Compliance• Certification

• Record Book

• Reporting

• Surveys

• PSC Inspections



Ballast Water Management: Meeting the Treatment Standard – Ballast Exchange

Case Study One

Tanker from Canada to California – is there a ballast requirement?

1. International ConventionRegulation B-4 Ballast Water Exchange

1 A ship conducting Ballast Water exchange to meet the standard in regulation D-1 shall:.1 whenever possible, conduct such Ballast Water exchange at least 200 nautical miles from the nearest land and in water

at least 200 metres in depth, taking into account the Guidelines developed by the Organization;.2 in cases where the ship is unable to conduct Ballast Water exchange in accordance with paragraph 1.1, such Ballast

Water exchange shall be conducted taking into account the Guidelines described in paragraph 1.1 and as far from the nearest land as possible, and in all cases at least 50 nautical miles from the nearest land and in water at least 200 metres in depth.

2 In sea areas where the distance from the nearest land or the depth does not meet the parameters described in paragraph 1.1 or 1.2, the port State may designate areas, in consultation with adjacent or other States, as appropriate, where a ship may conduct Ballast Water exchange, taking into account the Guidelines described in paragraph 1.1.3 A ship shall not be required to deviate from its intended voyage, or delay the voyage, in order to comply with any particular requirement of paragraph 1. 4 A ship conducting Ballast Water exchange shall not be required to comply with paragraphs 1 or 2, as appropriate, if the master reasonably decides that such exchange would threaten the safety or stability of the ship, its crew, or its passengers because of adverse weather, ship design or stress, equipment failure, or any other extraordinary condition.5 When a ship is required to conduct Ballast Water exchange and does not do so in accordance with this regulation, the reasons shall be entered in the Ballast Water record book.




Case Study One

Tanker from Canada to California – is there any ballast requirement?

1. International Convention

2. National Legislation - NI Circular 07-04, Change 1

Enclosure 2, paragraph 6 states;

"In areas other than the Great Lakes and the Hudson River, masters are not required to divert or delay a voyage in order to conduct mid-ocean BWE. Whenever a vessel enters US waters after operating beyond he EEZ, but cannot conduct mid-ocean BWE because the voyage to the US was such that the vessel did not transit outside 200nm of any coast for enough time to conduct exchange, the vessel must retain its unexchanged ballast water while operating in US waters and only discharge the minimal amount of unexchanged ballast water that is operationally necessary to safely conduct cargo operations. Such situations may be likely for vessels that enter the US EEZ from a Caribbean, Canadian, or South American port where a direct transit to the US may not take the vessel more than 200nm from shore for sufficient time to conduct BWE before reaching their US destination."




Case Study One


1. International Convention – IMO Ballast Convention


3. State Legislation – California Lands Commission

State of California Assembly Bill 703, Chapter 849; Ballast Water Management for Control of Nonindigenous Species

Chapter 1, paragraph 71200(j)

" "Voyage" means any transit by a vessel destined for any California port from a port or place outside the EEZ, including intermediate stops at a port of place within the EEZ. For the purposes of this division, a transit by a vessel from a United States port to any other United States port, if at any time the vessel operates outside the EEZ or equivalent zone of Canada, is also a voyage."




Case Study One





4. State Legislation – New California Lands Commission

State of California Assembly Bill 433, an act to amend Section 71200 (among others). New section;

" "Voyage" means any transit by a vessel destined for any California port or place from a port or place outside of the coastal waters of the state."




Case Study One





4. State Legislation – New California Lands Commission

5. Port Legislation – Port of Oakland Authority

Tanker has to exchange ballast en route or risks being sent from the port to exchange ballast on arrival (lost time / loss of

earnings)



Ballast Water Management: Meeting the Treatment Standard – Treatment Technology


Treatment Technology

Standard (D-2)

Organisms 50microns or larger:less than 10 viable organisms per m3

Organisms between 10 and 50 microns: less than 10 viable organisms per ml

• Guidelines for approval of Ballast Water Management Systems

• Procedure for Approval of Ballast Water Management Systems that make use of Active Substances

• Guidelines for the approval and oversight of prototype ballast water treatment technology programmes





Ships Constructed before 2009 with BW capacity 1500-5000, treatment technology in use after 2014

Phase in for Treatment System Installation (B-3)

Ships Constructed before 2009 with BW capacity less than 1500 and greater than 5000, treatment technology in use after 2016

Ships Constructed on or after 2009 with BW capacity less than 5000, treatment technology in use from 2009

Ships Constructed after 2009 but before 2012 with BW capacity greater than 5000, treatment technology in use after 2016

Ships Constructed at 2012 or after with BW capacity greater than 5000, treatment technology in use after 2012




Case Study Two

A) 40,000dwt Product Tanker to be delivered July 2007

Ballast water capacity greater than 5000m3 so will be able to conduct ballast water exchange until 2016, when it will then have to have been retrofitted with a ballast water treatment system.

B) 8,000dwt Chemical Tanker to be delivered July 2007

Ballast capacity of less than 5000m3 but greater than 1500m3, will have to be retrofitted with a ballast water treatment system by 2014.

C) Existing VLCC – delivered 2003

Ballast water exchange until 2016, retrofitted after 2016. BUT, if prototype system installed and test programme approved by IMO, 5 year exemption given, upgrade system in 2021.





2. Demonstrating Compliance• Certification

• Record Book

• Reporting

• Surveys

• PSC Inspections



Ballast Water Management: Demonstrating Compliance

• International Ballast Water Management Certificate – Appendix I

• Ballast Water Management Plan – INTERTANKO/ICS and IMO Guideline

• Ballast Water Record Book – Appendix II

• Officers and Crew to be able to understand requirements (training)

• Ballast Water Management reporting – national only

• Surveys – initial, renewal (5 yr), intermediate, annual, additional

• PSC Sampling – undue delay / clear grounds?



Ballast Water Management: Demonstrating Compliance - Today

Are we up to date?

- Ballast Water Management Plan onboard (includes Ballast Water Record Book)

- Checking of port, national and regional requirements? Ballast exchange or reporting?

- Ballast Water Exchange Requirements? 200nm and/or 200m depth – ballast exchange zone?

- Inspection requirements: sampling (master/designated officer aware of procedure)

- Newbuilding implications (when delivered and how large – 4999m3?)

- Treatment systems – beware the hype / be aware of the exemptions

- Familiarity of Convention and its Guidelines



Ballast Water Management: Demonstrating Compliance - Today

Guidelines for sediments reception facilities

Guidelines for Ballast Water Sampling

Guidelines for ballast water management equivalent compliance

Guidelines for Ballast Water Management and Development of Ballast Water Management Plans

Guidelines for ballast water reception facilities

Guidelines for Ballast Water Exchange

Guidelines for Risk Assessment under Regulation A-4

Guidelines for approval of Ballast Water Management Systems

Procedure for Approval of Ballast Water Management Systems that make use of Active Substances

Guidelines for approval and oversight of prototype ballast water treatment technology programmes

Guidelines for Ballast Water Exchange Design and Construction Standards

Guidelines for sediment control on ships

Guidelines for additional measures including emergency situations

Guidelines on designation of areas for ballast water exchange



Questions & Discussion



Industry Code of Practice (1999)

IMO Guidelines (2003)

ILO & Basel Guidelines

Consideration of Mandatory Elements Market Forces

• Shipping Industry• Green Recycling

International Ship Recycling Convention

Shipping Industry Feedback

• Workable• Practical• Objectives Met

Ship RecyclingA Fresh Start



Ship RecyclingElements of a mandatory scheme

1. Recycling FacilitiesLicensed recycling facilitiesShip owners to use only licensed approved facilitiesShip owners to remove material the facility cannot

2. Mandatory reporting scheme3. Ship Recycling Plan

Prepared by the recycling facility – MEPC Circ.419

4. Ship Recycling ContractEnsuring key elements of the Guidelines are included

5. Gas free for Hot Work CertificateShip owner and facility to arrange for certification – MEPC

Circ.466Responsibility



6. Potentially Hazardous MaterialsRestrict use of hazardous substances on new shipsStates to minimize hazardous substances in existing shipsHazardous materials inventory on board when ship sent to recycling facilityShip owners to mark potentially hazardous materials

7. Green PassportShip builders to provide Green Passport to ownerShip owners to maintain validity of Green PassportShip owner to deliver Green Passport to recycling facility

Ship RecyclingElements of a mandatory scheme



Ship RecyclingShipping Industry Proactivity

Follow Guidelines as closely as practicable – MEPC Circ.467

• Identify areas of concern

• Notify Associations who can in turn notify IMO

• Pool resources and find solutions (HMI, Green Passport, Gas-free)

• Continue to highlight role of other stakeholders

• Share information on recycling facilities (market to force changes?)

• Green Recycling Facilities? Green recycling is ideally defined as scrapping performed in full accordance

with the developed recycling guidelines.



Environmental developments

• Environment will continue to take centre stage

• Kyoto, Biodiversity, Sustainability

• Mandatory requirements vs. Self regulation

• Political tug-of-war:

• National vs. Regional vs. International

• Political Will vs. Technical/Operational Reality

A responsible, sustainable and respected industry able to influence its own destiny



Questions & Discussion

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