INTERTANKO Some Technical

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INTERTANKOSome Technical Regulatory Activities

• Latin American Panel
• 25 April 2006, Rio de Janeiro
• dragos.rauta_at_intertanko.com

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Summary of the Presentation

• Engine Room Waste Treatment Associate Systems
• Fixed Hydrocarbon Gas Detection Systems in DH
  Tankers
• Hot Work Onboard FPSOs - An Alternative to ISGOTT
• . . . If time permits
• Updates from IMO
• Air emissions
• STS Transfer in MARPOL
• Coating Performance Standard

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Engine Room Waste Treatment Associate
Systems(ERWTAS)

• Latin American Panel
• 25 April 2006, Rio de Janeiro
• dragos.rauta_at_intertanko.com

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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.

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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

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ERWTASScope 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

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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,
  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

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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

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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

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ERWTAS Principles for efficient waste treatment
KNOW-HOW Oily waste chemistry
KNOW-HOW Oily waste management

• Understanding of how emulsions form and break
  down
• Selection of chemicals

• Process design
• Upstream and downstream conditions

Designers/Ship Operators
Manufacturers
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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

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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

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Tank design and managementFor bilge water and
oily sludge/slop/waste oil
Oil skimming
Oil skimming
Settling tank
Settled tank
Heat
To treatment
Sludge drain
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Housekeeping
Chemicals - QSDs - Additives - Effectiveness?
Fuel tank
Fuel oil sludge
Treatment
Boiler
Lube oil sludge
Incinerator
Ashore
Overboard
Heavily polluted water
Treatment
Condensate etc.
Recycle?
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Process vision
Equipment vision
Minimised leakages
Concentrated solids
Reduced oil losses
Closed loops, re-utilisation self-containment
Waste minimisation
Reduced water consumption
Focus on back-end processes
Reduced chemical usage
Performance-driven development
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Procedures and PoliciesINTERTANKO 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 PI Clubs to
  require the same.

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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

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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

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Some results from field testing

• Results well below 15 ppm, normally lt 5 ppm
• Chemicals not needed
• Separation temperatures of 60-70 C

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Fixed Hydrocarbon Gas Detection Systems in DH
Tankers

• Latin American Panel
• 25 April 2006, Rio de Janeiro
• dragos.rauta_at_intertanko.com

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BACKGROUND

• DH structure on tankers gt 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

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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

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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

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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
• Equivalent systems existing fixed gas detection
  systems and existing operative systems for
  permanent inerting
• Retrofitting DH tankers if none of such systems
  is onboard
• IMO to develop Technical Specifications for new
  gas fixed systems (as suggetsed by
  INTERTANKO/IACS)
• Type approval for equipment/installation

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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
• 2/space for tankers gt50,000 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
• Sampling and gas analysis every 30 minutes
• Alarms for gas leakage and for clogged sampling
  pipes
• Design for
• easy testing and calibration
• permitting use of portable instruments

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Hot Work Onboard FPSOs An Alternative to ISGOTT

• Latin American Panel
• 25 April 2006, Rio de Janeiro
• dragos.rauta_at_intertanko.com

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Background

• Life maintenance of FPSOs and FSOs involves
  steel renewals and modifications within enclosed
  vessels and tanks
• Currently there are no specific industry
  guidelines addressing the associated hot work
  issues for FPSOs
• The closest and most frequently referenced
  guidelines are the International Safety Guide
  for Oil Tankers Terminals, (ISGOTT)

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Background

• ISGOTT guidelines written for tankers, and found
  consistently impractical to apply to a producing
  FPSO
• Impractical to treat FPSOs and FSUs 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 FPSOs

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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.

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ISGOTT requirements
Consequence of reduced storage smaller offload
parcels, split offloads or dead freight
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An alternative to ISGOTT for FPSOs

• 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)

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An alternative to ISGOTT for FPSOs
Case 1 Hotwork within tank at a distance of more
than 500 mm from a boundary bulkhead
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An alternative to ISGOTT for FPSOs
Case 2 Hot work in tank working within 250mm of
a boundary bulkhead.
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An alternative to ISGOTT for FPSOs

• 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

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An alternative to ISGOTT for FPSOs
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An alternative to ISGOTT for FPSOs

• HW on a Common Bulkhead
• reverse side thoroughly cleaned and tank
  ballasted to above work area
• adjacent tank COWd, 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.

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An alternative to ISGOTT for FPSOs

• 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.

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An alternative to ISGOTT for FPSOs
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An alternative to ISGOTT for FPSOs

• 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

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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.

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Conclusions

• It has been found consistently impractical to
  fully apply ISGOTT to producing FPSOs
• Hot work procedures on FPSOs 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

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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

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Updates from IMOAir emissions STS Transfer in
MARPOL Coating Performance Standards

• Latin American Panel
• 25 April 2006, Rio de Janeiro
• dragos.rauta_at_intertanko.com

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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)

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SOx emissions MDO only?
CIMAC Guide
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SOx emissions MDO only?Should INTERTANKO
suggest it?
CIMAC Guide
?
?
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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.

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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.

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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 BLGs 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

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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.

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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