Transcript Document 7343252

INTERTANKO
Some Technical &Regulatory
Activities
Latin American Panel
25 April 2006, Rio de Janeiro
[email protected]
Summary of the Presentation
1. Engine Room Waste Treatment Associate
Systems
2. Fixed Hydrocarbon Gas Detection Systems in
DH Tankers
3. Hot Work Onboard FPSOs - An Alternative to
ISGOTT
. . . If time permits
4.Updates from IMO:
a. Air emissions;
b. STS Transfer in MARPOL;
c. Coating – Performance Standard
Engine Room Waste Treatment
Associate Systems
(ERWTAS)
Latin American Panel
25 April 2006, Rio de Janeiro
[email protected]
Background
• Alarming results from the USCG and other PSC
•
•
•
•
MoUs campaigns to control ships’ bilge water
discharges
Ship engineers and master convicted for
“criminal violation and deliberate and knowing
conduct” – since 1998, 18 years cumulative
prison sentences in US
Prosecution against shipping companies – since
1998, cumulative $133 million in fines in US
All types of vessels involved
Prosecutions for: bypassing the OWS/OCM,
flushing the OCM with fresh water, false logging
/ fake ORB, etc.
INTERTANKO 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”
ERWTAS
Scope of the Guide
• A critical review of the current systems for
•
•
•
•
•
treatment of engine room wastes
Promote performance standards for enhanced
onboard procedures and operations
Innovative arrangements to improve the
efficiency of these systems
Possible changes to relevant MARPOL
regulations
Advise for compliance procedural approaches
Reference manual for crew training
Recent 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, oilwater 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 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 Issues
• Current onboard waste treatment systems
•
•
•
•
not fit for purpose
Design assumptions inadequate
No hollisitc concept of waste treatment
management
Lack of standardisation of the equipment
provided to ships
Unclear guidelines for logging
ERWTAS
Principles for efficient waste
treatment
•
•
KNOW-HOW:
KNOW-HOW:
Oily waste chemistry
Oily waste management
Understanding of how
emulsions form and
break down
Selection of
chemicals
Manufacturers
•
•
Process design
Upstream and
downstream
conditions
Designers/Ship Operators
Waste content
• Waste content:
– droplets of emulsified water/oil &
– ultra-fine suspended solids
• Waste content:
•
– oil
– water(50%-90%)
– chemicals
– detergents
– soot
– grease
– etc.
Three-phase separation
is the key
Chemicals in the engine room
Cleaning &
maintenance
Chemicals for
water treatment
Fuel oil
additives
Lube oil
additives
Acid
cleaners
Boiler
water
Dispersants
Dispersants
Alkaline
cleaners
Cooling
water
Corrosion
inhibitors
TBN
reserve
Petroleum
cleaners
Seawater
Ash deposit
removers
Anti-wear
agents
Evaporators
Soot & scale
removers
Corrosion
inhibitors
Potable
water
Pour point
depressants
Compatibilty
controllers
Bilge
water
Antioxidants
www.alfalaval.com
Solutions
•
•
•
•
•
Minimise the amount of generated waste (design and
housekeeping solutions)
Prevent unnecessary mixture of oil, water, chemicals,
etc. (design solution)
Standardising the design of the waste treatment
installation and of the equipment (regulatory solution):
– Capacity and number of sluge/bilge water tanks
– Location and design of the sludge/bilge water tanks
– Adequate drain piping and drain collection
– Onboard incinerator capacity
Transfer of sludge to slop tanks ?
Capacity of Incineraotrs
ER waste treatment process
Oil pump drains
Drains & leaks
Compressed air drains
Tank overflows
Workshop drains
Purifers
Main engine air cooler drain
Cooling fresh water, sea water
Steam drain
Purifers
Bilge water cleaning
FO
sludge
LO
sludge
Waste/Slop oil
Oil-Water Separator
Cleaner water
processing
Recovered
oil
To boiler/
Incinerator/
(Slop tank)
Drains & leaks
Cleaning &
maintenance
Bilge wells
Bilge water
settling
Bilge water
holding
Clean
drain
Overboard
www.alfalaval.com
Tank design and management
For bilge water and oily sludge/slop/waste oil
Oil skimming
Heat
Settling
tank
Settled
tank
Sludge drain
Oil skimming
To treatment
Housekeeping
Lube oil
sludge
Treatment
Fuel oil
sludge
Fuel tank
Boiler
Chemicals
- QSDs
- Additives
- Effectiveness?
Incinerator
Ashore
Condensate
etc.
Overboard
Treatment
Heavily
polluted
water
Recycle?
Process vision
Equipment vision
Minimised
leakages
Closed loops, reutilisation & selfcontainment
Focus on “backend” processes
Reduced
chemical usage
Concentrated solids
Reduced
oil losses
Waste
minimisation
Reduced water
consumption
Performance-driven
development
Procedures and Policies
INTERTANKO 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 Policies
•
•
•
•
•
•
•
•
•
State and display clear environmental policies
Incentives for employees’ compliance and measures to
enhance safety and environmental procedures
Zero tolerance for violations from the rules or lack of
reporting of problems
Enhance ORB procedures – use the INTERTANKO
Guide for correct entries as a reference manual
Enhance onboard training/familiarisation procedures
Establish clear handover templates
Seals and tags for overboard lines and flanges
Install lock boxes on monitoring equipment and
interlocks to prevent tricking of monitoring equipment
Internal and external onboard audits Management/audit
Conclusions
• “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
Detection Systems in DH Tankers
Latin American Panel
25 April 2006, Rio de Janeiro
[email protected]
BACKGROUND
• DH structure on tankers > 5,000 dwt
• Increased protection against accidental pollution
• Introducing operational and safety challenges
• DH tankers designed to stay intact but
• Complex structure to be inspected & maintained
• Corrosive cargoes and atmosphere may lead to
• Mechanical or fatigue damage/cracks and
• Risk of cargo “migration” from cargo tanks into
double hull void spaces
BACKGROUND
• DH tankers are safe but a second layer of
•
defence against cargo migration is needed
Mitigation alternatives:
–permanent inert atmosphere on empty tanks
or
–means of effcient hydrocarbon gas detection
• EMSA Panel on DH Tankers identified this
concern and recommended mandatory
requirement for the latter alternative
ACTION PLAN
• INTERTANKO involved and took the lead
• INTERTANKO drafted new SOLAS regulation
• Draft sent to IACS
• IACS/INTERTANKO to jointly finalise the new
•
•
regulation
EMSA kept informed and in agreement to let the
industry do the job
SOLAS regulation to be presented to IMO in
Dec. 2006, earliest date to come into force, July
2009/January 2010
THE PROPOSED REGULATION
•
•
•
•
Application: all tankers [5,000]/[20,000] dwt and above
built on or after [??]
New tankers below [5,000]/[20,000] dwt to comply with
current SOLAS II-2/5.7.2.2. (portable instruments and
fixed pipe system for emergency inerting)
Exemption from the rule: DH tankers with constant
operative inerting system
Existing DH tankers:
•
•
IMO to develop Technical Specifications for new gas
fixed systems (as suggetsed by INTERTANKO/IACS)
Type approval for equipment/installation
– Equivalent systems: existing fixed gas detection systems and
existing operative systems for permanent inerting
– Retrofitting DH tankers if none of such systems is onboard
TECHNICAL SPECIFICATIONS
•
Istallation:
– central unit for gas measurement and analysis located in a safe
area (e.g. cargo control room, navigation bridge, etc.)
– gas sampling pipes in all ballast tanks and void spaces adjacent
to cargo tanks, including the forepeak tank
•
Sampling points:
•
•
•
Sampling and gas analysis every 30 minutes
Alarms for gas leakage and for clogged sampling pipes
Design for:
– 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)
– DB ballast tanks only: no requirement for upper sampling point
– easy testing and calibration
– permitting use of portable instruments
Hot Work Onboard FPSOs
An Alternative to ISGOTT
Latin American Panel
25 April 2006, Rio de Janeiro
[email protected]
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 requirements
The 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)
An alternative to ISGOTT for FPSO’s
Figure 3: Case 1, Application of SBM requirements outwith the 500mm zone
Case 1: Hotwork within tank at a distance of more than
500 mm from a boundary bulkhead
An alternative to ISGOTT for FPSO’s
Case 2: Hot work in tank working within 250mm of a
boundary bulkhead.
An alternative to ISGOTT for FPSO’s
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
An alternative to ISGOTT for FPSO’s
An alternative to ISGOTT for FPSO’s
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.
An alternative to ISGOTT for FPSO’s
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.
An alternative to ISGOTT for FPSO’s
An alternative to ISGOTT for FPSO’s
• 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 IMO
Air emissions; STS Transfer in
MARPOL; Coating –
Performance Standards
Latin American Panel
25 April 2006, Rio de Janeiro
[email protected]
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; twostep 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)
CIMAC Guide
SOx emissions – MDO only?
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.
STS Transfer – MARPOL regulation (?)
• 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.
STS Transfer – MARPOL regulation (?)
• 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 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