U.S.A. TANKER REQUIREMENTS INTERTANKO NORTH AMERICAN PANEL OCTOBER 29 th, 2014 PRESENTATION:...

GALLAGHER MARINE SYSTEMS LLC.

U.S.A. TANKER REQUIREMENTS

INTERTANKO NORTH AMERICAN PANEL

OCTOBER 29th, 2014

PRESENTATION: GALLAGHER MARINE SYSTEMS, LLC. KULDEEP SINGH


INDIVIDUAL STATE - REGULATORY REQUIREMENTS


Written Testimony to a Senate Committee June 12, 2012

The United States is a maritime and Arctic nation. We have one of the world’s longest coastlines, measuring more than 95,000 miles, and the world’s largest Exclusive Economic Zone (EEZ), responsible for over $122 billion in revenue annually. The U.S. maritime transportation system is comprised of 361 ports and thousands of miles of maritime thoroughfares that support 95% of U.S. foreign trade. Most of that trade is transported on over 7,500 vessels that make more than 60,000 visits to U.S. ports annually. The need to secure our maritime rights and interests, including ocean resources, is paramount. Excerpt from: “The Law of the Sea Convention: Perspectives from the U.S. Military”


AIR, LAND AND WATER – ALL COVERED


THE U.S. CHALLENGE


FEDERAL REQUIREMENTS SAMPLE PRIOR ARRIVAL CHECKS

• NVMC REPORT – ENOA• BWM REPORT TO NBIC• ENSURE VALID VRP & COFR• ENSURE VGP NOI SUBMITTED & INSPECTION/S• CONDUCT DRILLS INCLUDING NOTIFICATION• COMPLETE COMMERCIAL OBLIGATIONS – SCAC

NUMBER • CONDUCT OPERATIONAL & NAVIGATIONAL TESTS

33CFR164.25

• COMPLETE ADDITIONAL LIGHTERING REQUIREMENTS


FEDERAL REQUIREMENTVESSEL GENERAL PERMIT

• NPDES - CWA• ADDRESSES 27 VESSEL EFFLUENTS • FIRST PERMIT 19TH DEC 2008 (5 YEARS VALIDITY)• INTENDED AIM – HARMFUL “DISCHARGE

ELIMINATION”


FEDERAL REQUIREMENTVESSEL GENERAL PERMIT

• PROMOTES - BEST MANAGEMENT PRACTICES• REQUIRES - SAMPLING MAINLY FOR VESSELS BUILT

AFTER 19TH DECEMBER 2013

• INDIVIDUAL STATE REQUIREMENTS - 25 STATES

REQUIREMENTS INCORPORATED IN VGP • STATE REQUIREMENTS - MAINLY

HARMONIZED WITH VGP BUT SOME STATES HAVE

ADDITIONAL REQUIREMENTS


CALIFORNIA STATE – SEWAGE REGS


California State - NDZ

• Largest in the USA• Location: All coastal waters out to 3 nm from the

California coastline• Applicability: all passenger ships and oceangoing

vessels larger than 300 tons with sewage holding tank capacity.

• Other States also have NDZs


FEDERAL REQUIREMENTBALLAST WATER MANAGEMENT


CALIFORNIASTATE – BWM

California does not provide exemption for vessel deviation. Ships arriving Cal. ports must conduct BWM, regardless if it would result in deviation or delay of the voyage. – CSLC LETTER 14 AUG 2014 MID OCEAN EXCHANGE > 200 nm; > 2000m OR PCR EXCHANGE > 50 nm; > 200 m


NORTH AMERICAN - ECA

Effective Date Sulfur Limit %m/m (ppm)On and after 01 JULY 2010 1.5% (15,000)On and after 01 JULY 2010 1.0% (10,000)On and after 01 JAN 2015 0.1% (1,000) (93% reduction

since July 2010)


CALIFORNIASTATE ARB REQUIREMENTS

January 1, 2014Marine gas oil (DMA) at or below 0.1% sulfur; or marine diesel oil (DMB) at or below 0.1% sulfur


SOME INDIVIDUAL STATE REQUIREMENTS


Guam, American Samoa and Alaska

OSRO coverage meets USCG planning standards in the continental United States and Puerto Rico but not the areas highlighted in yellow above…


VRP Approval letters with remote area endorsements

American Samoa

Guam

Western Alaska


WHAT IS APC & WHY REQUIRED?

• Alternative Planning Criteria (APC) Operating Procedures developed to mitigate the risk of maritime incidents - Alaska Maritime Prevention & Response Network.

• Designed to mitigate risk in remote areas where spill response resources are sparse.

• These Procedures apply to oil tankers operating in Western Alaska waters outside of Cook Inlet - Coast Guard Captain of the Port Western Alaska zone up to the seaward boundaries of the U.S. EEZ


APC – PROCEDURES OVERVIEW

• Procedures are mainly centered around Maritime Domain Awareness & Engagement with enrolled vessels equipped with AIS

• Vessels in the region tracked in real time - 24 x 7 via AIS

• Notification requirements & procedures if there is an incident of a threat of an incident.

• Safe routing measures


OFFSHORE RISK MITIGATION ROUTES ALEUTIAN ISLANDS


Network Operating Procedures changes for Tankers:


Vessels not holding a Western Alaska endorsement?

• Vessels are tracked via AIS by the NETWORK. If a vessel transits Western Alaska but does not have an endorsement for this zone,the USCG is notified.

• USCG then take further action. Email sent to vessel, operator/owner & QI:– Current USCG Approval Letter

• showing NO endorsement forWestern Alaska

– A list of “non compliant vesselsthat are transiting the area buthave NOT entered into the APC.

– Reference 33 CFR 155 regarding GeographicSpecific Appendices (i.e. endorsements)


REQUIRE APC ENROLLMENT FOR

GUAM & AMERICAN SAMOA

https://www.google.co.kr/maps/place/Guam/@13.444304,144.793731,7z/data=!4m2!3m1!1s0x671f76ff930f24ef:0x5571ae91c5b3e5a6?sa=X&ei=QQo-VMymMJKUyASJ14Ew&ved=0CCYQ8gEwAA

https://www.google.co.kr/maps/place/American+Samoa/@-14.306407,-170.6950175,7z/data=!4m2!3m1!1s0x71a684b79248fdc9:0xf3ee739e2dae4bdd?sa=X&ei=Wgo-VIOkJsqnyAS2o4HwCw&ved=0CCQQ8gEwAA


How do you obtain the endorsements?

1. Vessel must enter into contract with an approved OSRO or entity in the location they are trading or transiting (to or from a U.S. port). These OSRO/entities are as follows:

2. Vessels must follow Alternate Planning Criteria (APC) in the respective area (Guam, American Samoa, Western Alaska).–Tankers: 33 CFR 155.1065 // Nontankers: 33 CFR 155.5067

Guam American Samoa Western Alaska

NaRCO or MSRC NaRCO or MSRC NaRCO or MSRC

AND AND AND

OSROCO Solar OR Green Ops “Network”

Alaska Chadux


SPECIAL REQUIREMENTS

• If trading to these remote locations…• YES

– If transiting these locations, going to or from a U.S. port…• YES

– If on Innocent Passage…• For Guam and American Samoa

– NO

• For Western Alaska– NO*– *However, if the vessel has an existing Western Alaska

endorsement, they are required to follow the requirements associated with that endorsement (Alternate Planning Criteria) even when transiting Western Alaskan waters on Innocent Passage.

Costs for required APC compliance:• For Tankers you must:

– Enter into a contract & remit payment to the respective contractor(s):

Please request fee structure if you need it as the above fees are not all inclusive and are subject to change.

Location Contractors Fee: Follow APC Requirements?

American Samoa(Pago Pago)

Green OPS OR

SOLAR Environmental AND

MSRC OR NARCO

Up to $3,000 OR

$500 port callAND

Per contract

YES

Guam Oil Spill Response Operations Company (OSROCO)

Up to $10,950Per port call

+ annual admin fee of$1,050/year

YES

Western Alaska Alaska Maritime Prevention and Response Network(NETWORK)

ANDAlaska Chadux

$7,500AND

$850

YES


Trading To WA… VERSUS

Transiting …going to/from U.S. port

LOCATION: CONTRACTORSWHILE TRADING

CONTRACTORS WHILE TRANSITING(to/from a US Port)

FEE:

American Samoa As noted in previous table

As noted in previous table


Guam As noted in previous table



Western Alaska As noted in previous table

ANDAlaska Chadux

coverage


As noted in previous tableAND

Up to $9,500 (NT)$0.08/bbl capacity

(Tanker)


California State Requirements


California Contingency Plans • California Plan Submissions &

issuance of approval letters.

– Plan must be submitted at least five “working” days before entering California waters.

– Please consider GMS production time as well.

• If you have vessels that may go to California, please let GMS know immediately.


CaliforniaCertificate of Financial Responsibility

• Submit at least TEN DAYS BEFORE entering California waters.– Applications received with

less than ten days will receive a penalty.

• Preliminary Contingency Plan Approval AND a valid COFR are required before entering California waters.

– COFR application “in process” is acceptable


Cost of Compliance Versus

Cost of Noncompliance• Cost of compliance

– CA COFR– CA Contingency Plan– QI/SMT/OSRO/SMFF

• Cost of non-compliance– In this recent example,

cost is $4,000 for first time offender.

– Penalties increase with each occurrence.


California has a very active boarding program…

• Remember that California has an active boarding program. We are seeing an increase in non-conformities such as these:


Incorrect bolts at the manifold…

• What is the standard?– California standard is open

to interpretation.• How many threads should

protrude from a flange bolt?• We learned that the industry

standard is 1.5 threads exposed.


Washington StateChanges in Resource Providers…


WASHINGTON STATE• OLD:

– Vessels trading to Washington State had to enter into a contract with the Washington State Maritime Cooperative (WSMC) the only Primary Response Contractor (PRC) for this area.

• WSMC had an agreement with National Response Corporation (NARCO)

• CHANGE:– WSMC & NARCO dissolved their agreement in 2013– NARCO & WSMC are now competing PRCs

• WSMC is teamed with MSRC • NARCO has all necessary assets to provide required

services/coverage.


ERTV Tanker Fee

• Tanker fee based upon the following:– Size– Credits

• Double Hull• Redundant Engine/Steering• ISO 14001

• LPG is listed under tankers and is not considered a NT


Alaska


Alaska DEC – Boarding Program

• Alaska has an active boarding program.– Alaska Department of

Environmental Conservation

• Ensure vessels have:– Proper documentation

• Organized & presentable

– Knowledge of required notification procedures


Hawaii


Hawaii Dispersant Coverage• Vessels trading/transiting the waters of Sector Honolulu.

– need a contract with Hawaii-basedOSRO - Clean Island Council.

– GMS can arrange this contract OR you can do so via your agent.


HawaiiVessel General Permit Filing

Hawaii requires their own version of a VGP filing

• The application must be completed on-line then the form printed, signed, and post mailed to the State. – http://health.hawaii.gov/cwb/


Canada


US Great Lakes not Canada


Canadian Contracts

• Two OSRO providers when calling to Canada & divided geographically:– Eastern Canada Response Corporation (ECRC)

• 2 business days to arrange• $750 CAD per vessel plus $17.50 wire fee• Valid one year from date of enrollment

– Western Canada Marine Response Corporation (WCMRC)• 2 business days to arrange• $790 CAD per vessel plus $10 bank surcharge• Valid one year from date of enrollment

• Final contracts are provided once payment has been received.


THE SOLUTION


THE SOLUTION

• INFORMATION SHARING• SHIPBOARD U.S. SPECIFIC PROCEDURES • SHIPBOARD TRAINING• SHIPBOARD PRE-ARRIVAL CHECKLISTS• SHIPBOARD ACCESS TO INTERNET BASED INFO• DISCUSSIONS DURING SEA STAFF SEMINARS• RETENTION OF U.S. EXPERIENCED SEAFARERS• ACTIVE PARTICIPATION IN NPRM PROCESS


SAMPLE CHECKLIST


PRE-ARRIVAL CHECKS


THANK YOU“An ounce of prevention is worth a pound of cure”. - Benjamin Franklin

U.S.A. TANKER REQUIREMENTS INTERTANKO NORTH AMERICAN PANEL OCTOBER 29 th, 2014 PRESENTATION:...

Documents

Transcript of U.S.A. TANKER REQUIREMENTS INTERTANKO NORTH AMERICAN PANEL OCTOBER 29 th, 2014 PRESENTATION:...