INTERTANKO Some Technical &Regulatory Activities Latin American Panel 25 April 2006, Rio de Janeiro...

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



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



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



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)


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


Case 2: Hot work in tank working within 250mm of a boundary bulkhead.


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


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.


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.


• 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



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)

SOx emissions – MDO only?CIMAC Guide

SOx emissions – MDO only?Should INTERTANKO suggest it?

CIMAC Guide

?

?

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.


• 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.


• 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

INTERTANKO Some Technical &Regulatory Activities Latin American Panel 25 April 2006, Rio de Janeiro...

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