Transcript North American ECA Industry Presentation

Enforcement Provisions

CG-CVC Policy Letter 12-04
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U.S. Coast Guard ECA Job Aid
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CG-543 Policy Letter 09-01
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EPA Interim Guidance
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EPA Final Rule – 75 Federal Register 22896
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Under Annex VI MARPOL the North American
Emission Control Area (ECA) will become
enforceable on August 1, 2012.
 On that day, the sulfur content of the fuel oil used
onboard ships operating in this area may not
exceed 1.00%.

All vessels who operate in the North
American ECA are required to be in
compliance with the Annex VI ECA fuel oil
sulfur standard.

It extends up to 200
nautical miles from the
coasts of the United
States and Canada.

It includes the eight
main Hawaiian Islands.

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MARPOL Annex VI, Regulation 14
Two methods to comply
 Use of low sulfur fuel
 Equivalent Arrangement

Method utilized listed on IAPP Certificate
 Section 2.3 and 2.6
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Exceptions
 Securing the safety of a ship or saving life at sea;
 Damage to a ship or its equipment.

Exemptions
 OCS exploration.

All reasonable precautions were taken after
the occurrence for the purpose of preventing
or minimizing the emissions.

The master must report to the certificate
issuing authority.
 Records must be on board

The Coast Guard has agreed to work with the
U.S. Environmental Protection Agency (EPA)
to implement and enforce of the North
American ECA standards.

The EPA has lead for ECA violations

CG has lead on MARPOL Annex VI violations
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Operators may encounter situations where
low sulfur fuel oil is not available for
purchase.
MARPOL Annex VI, Reg 18.2.4 requires
notification to be made to the flag
Administration and to the competent
authority of the relevant port of destination.
EPA is responsible for receiving the US
notifications.

No waivers will be issued for Non-availability.
On June 26, 2012, the EPA published an Interim
Guidance on the Non-Availability of Compliant
Fuel Oil for the North American Emission Control
Area.
 The guidance includes the Fuel Oil Non-Availability
Reporting, which is available on EPA’s website at
http://www.epa.gov/otaq/oceanvessels.htm.


Vessels should submit a Fuel Oil NonAvailability Report to the EPA at [email protected] as soon as the vessel
determines, or becomes aware, that it will be
unable to procure and use compliant fuel oil
in the North American ECA, but no later than
96 hours prior to entering the North
American ECA.

All required information can be found on
pages 5 and 6 of the Interim Guidance on the
Non-Availability of Compliant Fuel Oil for
the North American Emission Control Area.

MARPOL Annex VI Regulation 18.2
 Present a record of the actions taken to attempt
to achieve compliance; and
 Provide evidence that it attempted to purchase
compliant fuel oil and that attempts were made to
locate alternative sources and that despite best
efforts to obtain compliant fuel oil, no such fuel oil
was made available for purchase.
If a Coast Guard unit receives notification of nonavailability from a foreign vessel, they will direct the
submitter to the EPA’s web site to submit a nonavailability report.
 The CG cannot and will not submit for the vessel.

What to expect during exams
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Records to be inspected to determine if the
fuel oil used onboard the ship meets the
standard.
 Bunker Delivery Notes
 Representative Fuel Oil Samples
 Fuel Oil Changeover Procedures
 Fuel Oil Changeover Logs
 Voyage Plans

Record of changeover recorded in such logbook as prescribed by the Administration.
 The volume of low sulphur fuel oils in each tank.
 The date, time, and position of the ship when any
fuel-oil-change-over operation is completed prior
to the entry into an ECA or commenced after exit
from such an area.
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Written procedures to show how/when the
fuel oil changeover is to be done to ensure
that only compliant fuel oil is burned within a
designated ECA.
Allow sufficient time for the fuel oil service
system to be fully flushed prior to entry into
an ECA.
Show line up of tanks, piping and valves.
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Deficiencies ECA Related
 EIAPP
 NOx technical code
 Fuel oil availability
 Fuel oil quality
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These will be forwarded to EPA for
enforcement

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Review records of actions taken and evidence
of submission to Admin/EPA
Request a corrective action plan signed by
the master stating that compliant fuel oil is:
 scheduled to be received prior to departure
 scheduled to be received at the next U.S. port
 Not scheduled for purchase

Gather copies for forwarding to EPA
 Signed and stamped by master
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Annex VI Non ECA Deficiencies
 IAPP
 Bunker Delivery Notes / Fuel Samples
 Incinerator
 Ozone Depleting Substances
 Volatile Organic Compounds
 Safety Management System

Deficiencies regarding above are CG Issue and will
be dealt with as normal PSC deficiencies
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Logical processes for inclusion in a shipboard
procedures and responsibilities for personnel
regarding ECA requirements.
 Crew Competency/knowledge of
▪ ECA requirements
▪ Changeover Procedures
▪ Voyage Plans

Where evidence of criminal liability on the
part of the mariner, owner, operator or other
involve party of the ship is found
 intentional use of non-compliant fuel
 falsified log books

The Coast Guard will conduct an investigation
under the authority of 14 USC 89a (APPS)

Information on Fuel Oil Non-Availability
Reporting, which is available on EPA’s website
at
http://www.epa.gov/otaq/oceanvessels.htm

Fuel Oil Non-Availability Report to the EPA at
[email protected]
PSC Arrivals Branch