Environmental Technology

Page 1

AUG 2014

ShipInsight • CRITICAL INFORMATION ON MARITIME TECHNOLOGY AND REGULATION • SPONSORED BY

ENVIRONMENTAL TECHNOLOGY • A guide to regulation and technology •

REGULATION Cleaner seas courtesy of MARPOL

NOX A matter of timing

OTHER WASTE WATER OIL & GREASE MEASURES Dealing with black Separators, seals Being greener and grey water and lubricants streams to keep the sea can keep owners in the black clean


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SHIPINSIGHT.COM

 | INTRODUCTION

A

S WITH EVERY OTHER INDUSTRY, the modern world demands that shipping is conducted with at least some element of environmental stewardship. It was not always that way; but while some persist in branding shipping a dirty industry it is in fact quite environmentally friendly and is acknowledged as being the most energy efficient means of moving large quantities of goods around the world. Efficiency is something that ship operators have always pursued for their own ends and most would argue that the prescribed requirements of some of the latest IMO regulations in this area are unnecessary and unwarranted. Even so, some ship operators may benefit and if nothing else the EEDI and exhaust emission regulations have spurred innovation and development in engines and propulsion systems that will give additional efficiencies and permit a greater choice of fuels going forward. Other aspects of environmental protection are not likely to give any benefit to operators and will result in extra costs for them to absorb. But few would argue that controls on discharging waste products and sewage into the ocean are welcome developments and operators are prepared to accept them so long as they see all operators treated equally. If they do have a complaint in connection with cleaning up shipping’s act, it is that all too often they are not getting the support they need from ports and terminals or from regulators happy to prosecute but not to provide facilities even where they are charged for. As things stand, there is little chance that shipping can evade the environmental spotlight but it can take some solace from the fact that each new area of regulation leaves less to be regulated on further down the line.

Malcolm Latarche

Malcolm Latarche AUGUST 2014 | 03


 BALLAST WATER TREATMENT

CONTENTS

XX PURPOSE OF A BRIDGE NAVIGATIONAL WATCH ALARM SYSTEM (BNWAS) IS TO MONITOR BRIDGE ACTIVITY AND 06 | CHAPTER 1 – Regulation DETECT OPERATOR Cleaner seas courtesy of MARPOL, the VGP and more DISABILITY WHICH 14 | CHAPTER 2 – NOx COULD LEAD TO A matter of timing, exhaust gas recirculation, catalytic reduction or water MARINE ACCIDENTS. 20 | CHAPTER 3 – ExxonMobil Premium HDME 50 Marine Fuel 24 | CHAPTER 4 – SOx A choice between changing fuels or coming clean with scrubbers 34 | CHAPTER 5 – Waste water Dealing with black and grey water streams 42 | CHAPTER 6 – Oil & grease Separators, seals and environmentally friendly lubricants to keep the sea clean 50 | CHAPTER 7 – Other measures Being greener can keep owners and operators in the black

Editor: Malcolm Latarche malcolm@shipinsight.com Head of Design: Chris Caldwell Layout & Production: Steven Price Advertising Sales: advertising@shipinsight.com Address: ShipInsight, 12 - 14 Bridge Steet Leatherhead, Surrey, KT22 8BZ, UK www.shipinsight.com

ShipInsight 04 | AUGUST 2014

This guide is produced by ShipInsight Ltd. Care is taken to ensure the information it contains is accurate and up to date. However ShipInsight Ltd accepts no responsibility of inaccuracies in, or changes to, such information. No part of this publication may be produced in any form or by means including photocopying or recording, without the permission of ShipInsight Ltd.

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JULY 2014 | 05


ENVIRONMENTAL TECHNOLOGY

ďƒ¨ | CHAPTER 1: REGULATION

Cleaner seas courtesy of MARPOL

E

VEN BEFORE SHIPS HAD ENGINES they had the potential to impact on the environment. As well as the alien species that hitched a ride on ships whether in the ship, in the cargo or under the hull, there was the waste produced by the crew and passenger on board and occasionally a cargo that needed to be dumped at sea. With the advent of engines came oil, firstly as lubricants and later for fuel – steam engines of course ran on coal which is mostly inert and has no effect on the environment but were heavy users of lubricants. Oil inevitably means oily waste is generated and with no regulation barring it, that waste was regularly dumped at sea. This was recognised quite early on after the first diesel engine was used in 1912 but it was the increase in crude oil transport and the consequent disposal of tanks washings at sea that was the spur for the first regulations prohibiting disposal of oil. That was not to be until The International Convention for the Prevention of Pollution of the Sea by Oil (OILPOL) was formulated at London in 1954. The 1954 Convention came into force in 1958 and was amended in 1962, 1969 and 1971. It was eventually superseded by the International Convention for the Prevention of Pollution from Ships (MARPOL) and its measures are now included there. OILPOL did not put a complete ban on disposal at sea and

06 | AUGUST 2014


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merely prohibited the dumping of oily wastes within a certain distance from land and in ‘special areas’ where the danger to the environment was especially acute. It also imposed a requirement for contracting parties to provide reception facilities but, more than half a century on, the lack of facilities is still a bone of contention for the industry. OILPOL was mainly concerned with operational discharges as was the 1973 version of MARPOL drawn up by the IMO. This was to be amended by the Protocol of 1978 adopted in response to a spate of tanker accidents in 1976-1977. As the 1973 MARPOL Convention had not yet entered into force, the 1978 MARPOL Protocol absorbed the parent Convention. The combined instrument entered into force on 2 October 1983. In 1997, a Protocol was adopted to amend the Convention and a new Annex VI was added which entered into force on 19 May 2005. MARPOL has been updated by amendments through the years. Most of the measures in MARPOL are the province of the IMO’s Marine Environment Protection Committee (MEPC) which is also entrusted with the development of other environmental conventions. IMO says of MARPOL that it includes regulations aimed at preventing and minimising pollution from ships - both accidental pollution and that from routine operations - and currently includes six technical Annexes. Special Areas with strict controls on operational discharges are included in most Annexes. The Annex I Regulations for the Prevention of Pollution by Oil (entered into force 2 October 1983) covers prevention of pollution by oil from operational measures as well as from accidental discharges; the 1992 amendments to Annex I made it mandatory for new oil tankers to have double hulls and brought in a phase-in schedule for existing tankers to fit double hulls, which was subsequently revised in 2001 and 2003. Annex II Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk (entered into force 2 October 1983)

THE INTERNATIONAL CONVENTION FOR THE PREVENTION OF POLLUTION OF THE SEA BY OIL (OILPOL) WAS FORMULATED AT LONDON IN 1954. AUGUST 2014 | 07


ENVIRONMENTAL TECHNOLOGY

details the discharge criteria and measures for the control of pollution by noxious liquid substances carried in bulk; some 250 substances were evaluated and included in the list appended to the Convention; the discharge of their residues is allowed only to reception facilities until certain concentrations and conditions (which vary with the category of substances) are complied with. In any case, no discharge of residues containing noxious substances is permitted within 12 miles of the nearest land. Annex III Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form (entered into force 1 July 1992) contains general requirements for the issuing of detailed standards on packing, marking, labelling, documentation, stowage, quantity limitations, exceptions and notifications. For the purpose of this Annex, “harmful substances� are those substances which are identified as marine pollutants in the International Maritime Dangerous Goods Code (IMDG Code) or which meet the criteria in the Appendix of Annex III. Annex IV Prevention of Pollution by Sewage from Ships (entered into force 27 September 2003) contains requirements to control pollution of the sea by sewage; the discharge of sewage into the sea is prohibited, except when the ship has in operation an approved sewage treatment plant or when the ship is discharging comminuted and disinfected sewage using an approved system at a distance of more than three nautical miles from the nearest land; sewage which is not comminuted or disinfected has to be discharged at a distance of more than 12 nautical miles from the nearest land. In July 2011, IMO adopted the most recent amendments to MARPOL Annex IV which entered into force on 1 January 2013. The amendments introduce the Baltic Sea as a special area under Annex IV and add new discharge requirements for passenger ships while in a special area. Annex V Prevention of Pollution by Garbage from Ships (entered into force 31 December 1988) deals with different types of garbage 08 | AUGUST 2014


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REGULATION

and specifies the distances from land and the manner in which they may be disposed of; the most important feature of the Annex is the complete ban imposed on the disposal into the sea of all forms of plastics. In July 2011, IMO adopted extensive amendments to Annex V which entered into force on 1 January 2013. The revised Annex V prohibits the discharge of all garbage into the sea, except as provided otherwise, under specific circumstances. Annex VI Prevention of Air Pollution from Ships (entered into force 19 May 2005) sets limits on sulphur oxide and nitrogen oxide emissions from ship exhausts and prohibits deliberate emissions of ozone depleting substances; designated emission control areas set more stringent standards for SOx, NOx and particulate matter. In 2011, after extensive work and debate, IMO adopted mandatory technical and operational energy efficiency measures; The energy efficiency design index (EEDI), Ship energy efficiency management plans (SEEMPs) and the energy efficiency operational index (EEOI) which were included in Annex VI and entered into force on 1 January 2013. MARPOL with its six annexes and SOLAS between them regulate many aspects of ship construction aimed at minimising the environmental aspects of ships. Similarly MARPOL has influenced many operational practices onboard tankers and every other type of ship. These areas will not be covered by this guide, which is focussed on describing the technology and equipment designed to aid compliance with those areas of regulation that can only be met using equipment. In the main these are regulated by Annexes I, IV, V and VI of MARPOL but there are other areas outside of these where shipping has to meet regulatory demands. As examples, the International Convention on the Control of Harmful Anti Fouling Substances on Ships, 2001 and the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 are being addressed by a new generation of coatings and a growing number of ballast water treatment systems. AUGUST 2014  | 09


ENVIRONMENTAL TECHNOLOGY

Both of these areas are the subject of other ShipInsight Guides which deal with them more comprehensively than they are covered in this. However, there is a chapter in this guide which deals with the wider subject of water waste and another covering the topic of coatings. So far all of the regulation mentioned has been promulgated by the IMO but there are also local regulations in some parts of the world that affect the equipment installed on ships. Once again ballast water treatment serves an example; with the US having adopted its own rules that are already in force while the IMO convention has not yet been ratified by sufficient states to come into force and in Brazil where ballast exchange is permitted but treatment by systems – even those approved by the IMO – is not yet recognised as meeting local rules. US RULES COVER MORE

Concurrent with the development of MARPOL, the US was introducing its own regulations in the form of the Clean Water Act (CWA) passed by the US Congress in 1972 and covering cleaning up the territorial waters of the US. This was done through the National Pollutant Discharge Elimination System (NPDES) permit programme which controls water pollution by regulating sources that discharge pollutants into the nation’s waters. In most cases, the NPDES permit program is administered by individual states but for matters extending beyond individual states, the Environment Protection Agency (EPA) is the governing body. Section 301(a) of the CWA prohibits the discharge of any “pollutant” unless authorised by an NPDES permit. Shortly after the enactment of the CWA, the EPA issued a regulation that exempted from NPDES permitting “any discharge of sewage from vessels, effluent from properly functioning marine engines, laundry, shower, and galley sink wastes, or any other discharge incidental to the normal operation of a vessel”. After the turn of the century, environmentalists began legal actions in some states demanding ships should not be exempted from the regulations. In December 2003, the California federal district and appeals courts ruled that the EPA had exceeded its 10 | AUGUST 2014


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REGULATION

authority when it excluded ships’ discharges from the NPDES permitting system. As a consequence EPA had to implement a permit system for a wide variety of vessel discharges which would affect all US-flagged vessel and foreign-flagged vessels trading to the US. This resulted in the introduction in 2008 of the Vessel General Permit (VGP) that would apply to all affected vessels whose owners filed a Notice of Intent. A document explaining the VGP can be found at the following web address: www.epa.gov/npdes/pubs/vessel_vgp_permit.pdf It is a long – 165 pages – document but explains the system in detail together with amendments introduced by individual states. In the fact sheet that it issued as a guide to the VGP, the EPA emphasises that it fought efforts to require incidental discharges to be permitted not because it dismissed the significance of aquatic invasive species, or other environmental hazards resulting from these discharges, but rather because, in its view, permitting was not the best or most efficient way of addressing the problem. The EPA notes that Congress has already enacted legislation that directed the US Coast Guard, rather than the EPA, to address and come up with a regulatory programme for the discharge of ballast water and other discharges, and that nothing in the CWA prevented individual states from coming up with regulations to control ballast water discharges under state law. In 2013, a new version of the VGP was introduced. It will continue to regulate 26 specific discharge categories that were contained in the 2008 VGP, and would provide coverage for fish hold effluent in the event that a permitting moratorium currently in effect expires in December 2014. For the first time, the final VGP contains numeric ballast water discharge limits for most vessels. The permit generally aligns with requirements contained within the 2012 U.S. Coast Guard ballast water rulemaking. Additionally, the VGP contains requirements to ensure ballast water treatment systems are functioning correctly. The final permit also provides additional environmental protection for certain vessels. For example, certain high-risk vessels entering

AFTER THE TURN OF THE CENTURY, ENVIRONMENTALISTS BEGAN LEGAL ACTIONS IN SOME STATES DEMANDING SHIPS SHOULD NOT BE EXEMPTED FROM THE REGULATIONS. AUGUST 2014 | 11


ENVIRONMENTAL TECHNOLOGY

REGULATION

the Great Lakes must conduct additional management measures to reduce the risk of introducing new invasive species to US waters. The final VGP also contains more stringent effluent limits for oil to sea interfaces such as propeller shaft seals and also exhaust gas scrubber washwater. EPA has also amended several of the VGP’s administrative requirements, including allowing electronic recordkeeping, requiring an annual report in lieu of the one-time report and annual noncompliance report, allowing combined annual reports for some vessel operators. TIMELINE: MARPOL ANNEX VI 26 Sept 1997

Annex VI formally adopted

1 Jan 2000 Engine-makers begin building and certifying NOx Tier I engines 19 May 2005 Annex VI enters into force SOx – 4.5% global, 1.5% ECA NOx Tier I 19 May 2006

Baltic Sea SECA established

11 Aug 2007

EU implements North Sea SECA

21 Nov 2007

Official IMO date for North Sea SECA

1 Oct 2008

MEPC approves revised Annex VI and NOx Technical Code

17 July 2009

MEPC approves proposed US/Canada ECA (SOx,

NOx and PM)

1 July 2010

SOx 1.0% ECA

1 Jan 2011

NOx Tier II

1 July 2011 MEPC approves proposed US Caribbean ECA (SOx, NOx and PM) SOx 3.5% global 1 Jan 2012

SOx 3.5% Global

1 Aug 2012

Implementation of US/Canada ECA

1 Jan 2014

Implementation of US Caribbean ECA

1 Jan 2015

SOx 0.1% ECA

1 Jan 2016

NOx Tier III (only applicable in ECAs)

2018

Review into availability of low-sulphur fuel

1 Jan 2020 SOx 0.5% global (if deemed possible following 2018 review) 1 Jan 2025 12 | AUGUST 2014

SOx 0.5% global (delayed date of 2018 review)

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ENVIRONMENTAL TECHNOLOGY

 | CHAPTER 2: NOX

Krystallon Scrubbers

H

IGHEST ON TODAY’S LIST of shipping’s environmental impacts is the matter of exhaust emissions and particularly NOx, SOx, particulates and CO2. Each of these requires different treatment and controlling some can affect the production of others. All exhaust emissions come under MARPOL Annex VI and have been regulated according to the timeline on the previous page. NOx is given particular attention because of the technical complexities involved with it and a large part of Annex VI is the NOx Technical Code 2008. In all internal combustion engines and boilers it is necessary to mix air with the fuel to allow combustion to take place. Air is mostly composed of nitrogen and oxygen with a few trace gases and the fuels are a complex mix of hydrocarbons with other components depending on their type. Different fuel types burn best at different temperatures and this along with their chemical composition and the spray pattern into the combustion chamber is instrumental in determining the exhaust gases produced. LNG is often proposed as the ideal solution to reduce NOx emissions and while it is true that the level of NOx from a gas burning engine is very low it is only a solution for ships equipped with pure gas or dual fuel engines. It is possible for some diesel engines to be converted but this is a major conversion and one that would have to be evaluated weighing up many factors.

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The production of NOx is easier to control in some engine types than others and as a consequence the allowed limits for each stage of the roll out programme differ depending on engine speed with the low speed engines given the highest permissible output as shown in the following tables. NOX EMISSIONS Tier I (all ships effective 19 May 2005) Engine speed <130rpm

17.0g/kWh

>130–2,000rpm

45 × rpm(-0.2)g/kWh

>2,000rpm

9.8g/kWh

Tier II (ships built from 1 January 2011) Engine speed <130rpm

14.4g/kWh

>130–2,000rpm

44 × rpm(-0.23)g/kWh

>2,000rpm

7.7g/kWh

Tier III (ships built from 1 January 2016) Applies only to ships operating in ECAs Engine speed <130rpm

3.4g/kWh

>130–2,000rpm

9 × rpm(-0.2)g/kWh

>2,000rpm

2.0g/kWh

The NOx Technical Code allows for a variety of ways of proving compliance. Ensuring engines meet the NOx limits is in the first instance down to the engine maker. The engine should come with a technical file and a certificate confirming the engine complies with the relevant limits. Thereafter, the owner has a choice of three methods of ensuring the engine continues to perform as required.

LNG IS OFTEN PROPOSED AS THE IDEAL SOLUTION TO REDUCE NOX EMISSIONS. AUGUST 2014 | 15


ENVIRONMENTAL TECHNOLOGY

The first is the engine parameter check, under which it needs to be demonstrated that all those areas that influence NOx production remain in strict accordance with the engine maker’s original test bed condition as regards components, calibration, setting and operational parameters. Adopting this may mean that no change to engine settings can be made without it being accounted for in the technical file and it may mean that use of third-party spare parts is out of the question. The parts affected would probably include all those for the fuel injection system, camshaft, valves and valve timing, pistons, heads and liners, connecting rods and piston rods, charge air system and turbochargers, plus others depending on the engine type. While some operators are quite happy to stick to OEM spares, others prefer cheaper pattern parts and for the latter there are two options to consider, namely the simplified measurement method or direct monitoring on board. Simplified measurement entails an effective repeat of the initial manufacturer’s test-bed certification procedure at every intermediate and special survey. This may involve specialist attendance. There is, however, no requirement that all parts on the engine need to be OEM parts. Alternatively, direct measurement and monitoring is possible, using type-approved equipment available from a number of suppliers. Monitoring can either take the form of spot checks logged with other engine operating data on a regular basis and over the full range of engine operation, or monitoring can be continuous and the data stored. A variety of technologies are used in the monitoring systems, most of which rely on traditional gas detection techniques. As is to be expected, each of the makers believes that its equipment (or the technology used in it) is the most appropriate. No system is perfect, however, and each of them could develop faults that would affect the accuracy of the test results. Probes and sensors can become clogged, affecting accuracy either way; leaks in the exhaust system and absorption of gases are also problems that have been identified. To overcome this problem, the monitoring equipment needs to be calibrated on a 16 | AUGUST 2014

Wärtsilä Hamworthy scrubber technology


SHIPINSIGHT.COM

NOX

regular basis to ensure that it is functioning correctly. The reliability of monitoring systems has improved over time as their use has expanded. When there was only a need to monitor NOx emissions most of the systems in use were set up to do just that. However, now that SOx scrubbers (see next chapter) are becoming more common, so the makers of monitoring systems have enhanced their products to cover other regulated exhaust emissions. The new breed of monitors come with other enhancements and at least one model on the market has a GPS input and can be programmed to send an alarm to the bridge when the vessel is close to a regulated emissions control zone in order that arrangements can be put in hand to ensure compliance with the rules effective there. It should be noted that the NOx limits apply to the engine and not the ship. A vessel which has replacement engines fitted will need to comply with the limits applicable at the time of the engine manufacture. There is also provision in the code for engines being obliged to comply with a higher Tier limits if the OEM produces means to make this possible. MAN Diesel & Turbo is one maker that has done this for a limited number of engine types. Meeting the NOx Code limits for Tier I and Tier II has been achieved without too much difficulty and for Tier III a number of options are being explored. These include:• Engine Tuning (Miller timing) • Fuel water emulsions or direct water injection • Air humidification • Exhaust Gas Recirculation (EGR) • Selective Catalytic Reduction (SCR) - up to 95% reduction – more difficult but achievable on slow speed diesels due to lower exhaust gas temperature – allows engine to be tuned for minimum fuel consumption • Liquefied Natural Gas (LNG) can achieve Tier 3 levels without treatment

MONITORING CAN EITHER TAKE THE FORM OF SPOT CHECKS LOGGED WITH OTHER ENGINE OPERATING DATA ON A REGULAR BASIS AND OVER THE FULL RANGE OF ENGINE OPERATION. AUGUST 2014 | 17


ENVIRONMENTAL TECHNOLOGY

The first four options are under the control of engine manufacturers and will doubtless be incorporated into future engine models. Several makers have already announced Tier III compliant engines but that does not mean that other methods will not also be made use of not least because with some of the options there are drawbacks such as increased fuel consumption or sub-optimal operation. Engine tuning works by reducing the length of the compression stroke by way of later closing of the inlet valve. This has the effect of reducing the combustion temperature and helps prevent the formation of NOx. The use of water either as an emulsion, direction injection or by humid air also reduces the combustion temperature. EGR has been common in smaller road engines for some time and is now being adopted into marine engines. By recirculating exhaust gas into the charge air, the oxygen content in the cylinder is reduced and the specific heat capacity increased. Both cause lower combustion temperatures and therefore fewer NOx emissions. Tier III only applies when vessels are operating in ECAs that limit NOx emissions. When outside of such areas, the engines need only meet Tier II standards and this makes SCR a possibly attractive option. In an SCR system a reducing agent (gaseous ammonia, aqueous ammonia or aqueous urea solution) is added into the stream of exhaust gas. The exhaust gases and reducing agent at a temperature of 300 to 400ยบ C are absorbed onto a catalyst, upon which the nitrogen oxides are transformed on the catalytic surface into nitrogen (N2) and water (H2O). When urea is used then CO2 is also formed during the process. SCR is capable of removing up to 99% of the NOx which is comfortably in excess of the 80% reduction from Tier I levels required under Tier III. SCR systems are not fool proof. If the exhaust gas temperature is too high, the ammonia burns rather than forming a compound with nitric oxide. If it is too low, it forms ammonium hydrogen sulphate and gradually blocks the catalytic converter. The same 18 | AUGUST 2014


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NOX

happens if the sulphur content of the exhaust gas is too high. The minimum temperature required depends on the fuel’s sulphur content. The catalyst in an SCR system consists of a ceramic carrier with the active catalyst an oxide of a metal such as tungsten or vanadium. SCR systems are separate from the engine and although leading engine makers are involved in their development, there are also independent suppliers. Similar to the situation with SOx exhaust gas cleaning systems, there are relatively few manufacturers and both have formed loose trade bodies. For scrubbers it is the EGSCA and for SCR it is the International Association for Catalytic Control of Ship Emissions to Air (IACCSEA). SCR systems do have a relatively high capital cost and annual running costs to take into account. The catalyst will need replacing at intervals of around four to five years but because the catalysts are arranged in a layered system which allows for only damaged catalysts to be identified, removed and exchanged it is not necessary to replace the entire catalyst at the same time. IACCSEA has recently developed a tool that can be downloaded from the organisations website and which allows an estimate of the capital and running costs of a system for individual ships to be calculated. A limiting factor in the take-up of SCR beyond the fact that the need for them is really only just beginning has been the size and weight of the systems and the need to carry sufficient supplies of ammonia (normally in the form of urea). Even on the smallest ship type the reagent storage tanks would likely need to be 5m³ and on a large tanker, bulker or container ship possibly ten times larger than that. As regards the requirements of the NOx Technical Code, a ship fitted with an SCR system will need to also be fitted with continuous monitoring equipment to prove compliance.

AUGUST 2014 | 19


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ďƒ¨ | CHAPTER 3: EXXONMOBIL

Lubricants meet the requirements

WHAT VESSEL OPERATORS NEED TO KNOW ABOUT THE REVISED VESSEL GENERAL PERMIT

Q: What is the Vessel General Permit (VGP)? The VGP regulates incidental discharges from normal vessel operations. The VGP is designed to ensure operators comply with the US Environmental Protection Agency (EPA) Clean Water Act and Oil Pollution Act. Q: How is the revised VGP different from previous years? All vessels must now use an environmentally acceptable lubricant (EAL) in all oil-to-sea interfaces. There are also specific stipulations to maintain seals and equipment to regulation standards, and specific fines for non-compliance. Q: What vessels need to fall under the latest VGP? The VGP impacts all commercial vessels greater than 79 feet. This includes those constructed on or after 19th December 2013 and all vessels built before this date, unless technically infeasible. Q: What jurisdiction does the VGP cover? The VGP covers the waters of the United States, up to a range of 3 miles out from the coast, and Great Lakes. 20 | AUGUST 2014


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Q: When did the latest VGP come into effect? The 2013 VGP came into effect on December 19th 2013. Q: In operational terms, what applications have been affected by the revised VGP? Applications that have been affected by the updated VGP include stern tubes, controllable pitch propellers, stabilisers, rudders, paddle wheels, thrusters, azipods, wire ropes and towing notch interfaces. It is also recommended (but not a requirement) that deck equipment use EALs if there is a risk of leakage running overboard. Q: Do you have any more information? For further information visit the EPA website – www.epa.gov WHAT EXXONMOBIL IS DOING TO HELP OPERATORS COMPLY WITH THE REVISED VGP

Q: Does ExxonMobil have VGP compliant products? Yes. In September 2013, ExxonMobil launched Mobil SHC Aware™, a comprehensive series of synthetic, environmentally acceptable lubricants that are VGP complaint.* Developed through extensive laboratory and in-service testing, the Mobil SHC Aware range includes: • Mobil SHC Aware™ H hydraulic fluids • Mobil SHC Aware™ ST stern tube lubricants • Mobil SHC Aware™ Grease EP 2 multi-purpose grease • Mobil SHC Aware™ Gear range of gear oils

Mobil SHC Aware lubricants meet the stringent requirements for environmentally acceptable lubricants as outlined in the 2013 VGP from the U.S. EPA, in addition to helping marine operators enhance vessel reliability, minimise maintenance costs and reduce potential environmental impact.

EXXON MOBIL OFFER THE ADDITIONAL BENEFITS OF HIGH PERFORMANCE LUBRICANTS SUCH AS OUTSTANDING EQUIPMENT PROTECTION, HELPING SHIP OWNERS REDUCE COSTS AND INCREASE PRODUCTIVITY. AUGUST 2014 | 21


ENVIRONMENTAL TECHNOLOGY

Do your VGP compliant products meet Original Equipment Manufacturer (OEM) requirements? ExxonMobil has many OEM endorsements in place and is continuing to evaluate the requirement for any additional approvals. Does the US Coast Guard/EPA know your products are VGP compliant? We recognise that consistent understanding and execution are critical to the successful implementation of any regulations. ExxonMobil has been proactively engaging with the US Coast Guard and the EPA to provide education on lubricant technologies and how they support the EPA/Coast Guard’s objectives to improve environmental stewardship, while also proactively providing education on our products and their capabilities. How can I find out more information? For further information please visit www.exxonmobil.com/marine *Environmentally acceptable lubricants are defined in the VGP as lubricants that are biodegradable, minimally toxic and are not bioaccumulative. Risk of thermal shock reduced

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EXXON MOBIL PREMIUM HDME 50 MARINE FUEL

EXXONMOBIL LAUNCHES EXXON MOBIL PREMIUM HDME 50 MARINE FUEL

E

XXONMOBIL MARINE FUELS & LUBRICANTS has launched a new marine fuel designed to help marine operators comply with the 0.10 percent sulphur cap set to be introduced in Emission Control Areas (ECA) beginning 1 Jan. 2015. ExxonMobil Premium Heavy Distillate Marine ECA 50 (HDME 50) is a new category of marine fuel formulated to meet the 2015 ECA sulphur limit and to help marine engineers safely and efficiently operate their engines and boilers. ExxonMobil Premium HDME 50 offers performance benefits associated with both marine gas oil (MGO) and heavy fuel oil (HFO). The fuel contains a low sulphur content associated with MGO, and has the higher flashpoint and lower volatility properties typically found in HFO. These characteristics enable marine operators to comply with the upcoming sulphur cap and to reduce the risk of engine and boiler damage. The higher viscosity of ExxonMobil Premium HDME 50 makes storage and handling the fuel on board similar to HFO. With the fuel having to be heated, the risk of thermal shock to engine components is reduced during switchovers when entering and leaving an ECA. Thermal shock can result in fuel pumps seizures and engine shutdowns. Prior to its introduction, ExxonMobil Premium HDME 50 was tested with Wallenius Wilhelmsen Logistics, one of the world’s leading shipping and logistics groups, and is suitable for use in main and auxiliary engines and marine type boilers. Following successful field trials, the new fuel has received No Objection Letters from MAN Diesel & Turbo (MDT) for use in MAN B&W two-stroke and MAN B&W Holeby genset designs, provided MDT’s specific engine type guidelines are followed. ExxonMobil Premium HDME 50 is already in use by a range of vessel operators. It is available from Antwerp via barge delivery for vessels operating in the Amsterdam, Rotterdam and Antwerp (ARA) region. In addition, ExxonMobil continues to offer MGO at more than 40 ports worldwide. AUGUST 2014 | 23


ENVIRONMENTAL TECHNOLOGY

ďƒ¨ | CHAPTER 4: SOX

Pollution - Big consequences in Asia

M

OST OF THE WORLD HAS ADOPTED the MARPOL ANNEX VI regulations but there are some regional regulations in force that go beyond it. Notably these are all ports in member states of the EU where a 0.1% limits is in place under the EU Sulphur Directive, California and Hong Kong. On 1 January 2014, the California Ocean-Going Vessels Fuel Regulation came into effect and set new reduced limits the for both marine gas oil (DMA) and marine diesel oil (DMB) of 0.1% m/m. The regulation comprises a fee provision by which ships that are unable to achieve the fuel compliance can pay a fee instead. In Hong Kong, the Air Pollution Control (Marine Light Diesel) Regulation came into force on 1 April 2014. It introduced a new sulphur content cap of 0.05% m/m for locally supplied marine MARPOL ANNEX VI SOX LIMITS Outside an ECA established to limit SOx and particulate matter emissions

Inside an ECA established to limit SOx and particulate matter emissions

4.50% m/m prior to 1 January 2012

1.50% m/m prior to 1 July 2010

3.50% m/m on and after 1 January 2012

1.00% m/m on and after 1 July 2010

0.50% m/m on and after 1 January 2020*

0.10% m/m on and after 1 January 2015

* - alternative date is 2025, to be decided by a review in 2018 24 | AUGUST 2014


SHIPINSIGHT.COM

light diesel. It also plans to impose the global cap of 0.5% on vessels in port. MARPOL Annex VI sets limits by mass for the sulphur content of fuels as the primary means for controlling SOx emissions from ships. Because it is purely a product of the combustion process, SOx is only an issue for vessels burning residual fuels either in diesel engines or in boilers. Ships that operate purely on distillates, LNG or any of the newer gas fuels that do not contain sulphur are not affected by any of the regulations controlling SOx and are saved the additional expense of complying with the requirements of MARPOL. In 2009, the MEPC.184(59) guidelines for Exhaust Gas Cleaning Systems (EGCS) were adopted. These guidelines enable a ship to achieve low-sulphur requirements by water washing the exhaust gas stream prior to discharge to the atmosphere. Each country party to Annex VI needs to ensure that its port and terminal facilities can accommodate residues from exhaust gas cleaning systems. Reducing SOx levels in exhaust emissions can come about in one of two ways. Either the sulphur level in fuel has to be reduced or abatement technology – commonly referred to as scrubbing – has to be employed. Unlike with NOx, there are no adjustments that engine manufacturers can make but the use of low sulphur fuel requires additional precautions that need to be taken in the choice of engine lubricants. When the SOx timetable and emission limits were being determined a decade ago, many within the industry believed that the only means to meet them would be a wholesale switch to distillate fuels. In a debate that became very heated at times there were even calls for residual fuels to be banned completely so that all ships would be obliged to burn the same fuel and thus ensure a level playing field. Even though the price differential between standard and lowsulphur fuels of around $70 was then much smaller than it is today, the idea of a ban on residuals did not sit well with many ship operators. While the first ECA sulphur limits were achievable using

SHIPS THAT OPERATE PURELY ON DISTILLATES, LNG OR ANY OF THE NEWER GAS FUELS THAT DO NOT CONTAIN SULPHUR ARE NOT AFFECTED. AUGUST 2014 | 25


ENVIRONMENTAL TECHNOLOGY

low-sulphur fuel oils, the reduction to 0.1% in 2015 was always going to be impossible to meet given the state of technology at the time. Although most industry expects were expecting owners to opt for running on distillate fuels, some within the industry pinned their faith on fledgling scrubber technology. Others have been slower and with a new deadline approaching on 1 January 2015, the take up of scrubbers is only just beginning to accelerate. A MATTER OF CHOICE

Scrubbing technology is already established in shore-based situations cleaning up emissions from oil and coal-based power plants. The technology falls into two distinct categories – wet and dry. Wet scrubbers are further divided into two types; open loop and closed loop which were developed separately but which are now usually combined into a hybrid system that can employ the most appropriate technology depending upon prevailing circumstances. In an open loop scrubber seawater is used as the scrubbing and neutralising medium and no additional chemicals are required. The exhaust gas from the engine or boiler passes into the scrubber and is treated with seawater. The volume of seawater will depend upon engine size and power output but equates approximately to around 40m3 per MWh meaning a quite high pumping capability is required. The system is around 98% effective and even allowing for fuel oil with 3.5% sulphur should have no problem reaching the maximum 0.1% 2015 ECA level. When fuel oil containing sulphur is burned in the presence of air, the sulphur in the fuel combines with oxygen to form sulphur oxides. In a scrubber, the sulphur oxides in the exhaust are passed through a water stream reacting with it to form sulphuric acid and are removed from the exhaust gas which then passes out of the system. Sulphuric acid is highly corrosive but when diluted with sufficient alkaline seawater it is neutralised and the wash water can be discharged into the open sea after being treated in a separator to remove any sludge. The alkalinity of seawater varies due to a number of reasons. In estuaries and close to land it 26 | AUGUST 2014


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SOX

may be brackish and closer to neutral and in some areas where underwater volcanic activity takes place the water may naturally be slightly acidic. An open loop system can work perfectly satisfactorily only when the seawater used for scrubbing has sufficient alkalinity. Fresh water and brackish water are not effective and neither is seawater at high ambient temperature. For this reason, an open loop scrubber is not considered as suitable technology for areas such as the Baltic where salinity levels are not high. MARPOL regulations require the wash water to be monitored before discharge to ensure that the PH value is not too low. A closed loop scrubber works on similar principals to an open loop system but instead of seawater it uses fresh water treated with sodium hydroxide as the scrubbing media. This converts the SOx from the exhaust gas stream into harmless sodium sulphate. Unlike the flow through method of open loop scrubbers, the wash water from a closed loop scrubber passes into a process tank where it is cleaned before being recirculated. The fresh water can either be carried in tanks or else produced on board if a fresh water generator is installed on the ship. In order to prevent build-up of sodium sulphate in the system, a small amount of wash water is moved at regular intervals either over side or to a holding tank and new freshwater added. The volume of wash water required in a closed loop system is around half that of the open loop version however, more tanks are required. These are a process or buffer tank in the circulation system, a holding tank where discharge to sea is prohibited and a storage tank able to have a controlled temperature between 20º and 50ºC for the sodium hydroxide which is usually used as a 50% aqueous solution. There must also be storage space for the dry sodium hydroxide. The hybrid system is a combination of both wet types that will operate as an open loop system where water conditions and discharge regulations allow and as a closed loop system at other times. Hybrid systems are proving to be the most popular because they can cope with every situation.

IN AN OPEN LOOP SCRUBBER SEAWATER IS USED AS THE SCRUBBING AND NEUTRALISING MEDIUM. AUGUST 2014 | 27


ENVIRONMENTAL TECHNOLOGY

The wet systems are not the most compact pieces of equipment and would take up considerable space if it were necessary to install them in under deck machinery spaces. Fortunately they can be installed in the funnel casing and can in some cases replace part of the conventional exhaust system. A dry system – of which only one has yet been devised for marine use and the maker of it has since ceased trading – employs pellets of hydrated lime to remove sulphur. An additional benefit is that the high temperature in the scrubber burns off any soot and oily residues. The lime pellets absorb sulphur and transform to gypsum. Although spent pellets need to remain on board for discharge at ports, they are not considered as waste because they can be used for fertiliser and to produce plasterboard among other things. The dry system has a lower power consumption than wet systems as no pumps are required. However, the weight of the unit is much higher than wet systems. All scrubber systems require a treatment bypass for when the ship is operating without the need to use the scrubber. This prevents damage to the scrubber and reduces maintenance. Care needs to be taken to ensure that the scrubber is not causing backpressure to the engine as this could be damaging and will affect NOx reduction systems. The wording or MARPOL means that the decision whether to allow scrubbers to meet the emission requirements rests with flag states, and although none have yet declared against scrubbers it is possible that their use may not be available to every vessel. Where scrubbers are allowed, MARPOL rules permit their use by setting equivalent emission limits in regulations 14.1 and 14.4 of ANNEX VI. These limits are expressed as a ratio of SO2(ppm)/CO2(% v/v) and work out at approximately 43.3 for each 1% of sulphur content in the fuel as shown in the following table.

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SOX

Fuel Oil Sulphur Content (% m/m)

Ratio Emission SO2(ppm)/CO2(% v/v)

4.50

195.0

3.50

151.7

1.50

65.0

1.00

43.3

0.50

21.7

0.10

4.3

Note: The use of the Ratio Emissions limits is only applicable when using petroleum based Distillate or Residual Fuel Oils. Flag states that decide to permit scrubbers on board ships will need to ensure that operators can prove compliance. Under ANNEX VI regulation 4 there are two schemes allowed for a system to be permitted that mirror the requirements for NOx compliance.

One demands that the performance of any scrubber is certified before use and, as with the NOx systems, providing it is always operated within approved parameters there is no need for continuous exhaust emission measurements on the ship. Parameters that must be continuously recorded include scrubbing water pressure and flow rate at the scrubber inlet, exhaust pressure before the scrubber and the pressure drop, fuel oil combustion equipment load, and exhaust gas temperature either side of the scrubber. A record of chemical consumption must also be maintained. Under the second scheme, the exhaust gas must be continuously monitored when the equipment is in use and there is no need for the system’s performance to be certified. Under both schemes the condition of any washwater discharged to sea must be continuously monitored for acidity, turbidity and PAH (a measure of the harmful components of oil) and data logged against time and ship’s position. A test for nitrate content is also required at each renewal survey. Wet scrubbers are good at removing particulate matter and soot which although not currently regulated for specifically are likely to be so in future. Typically a scrubber will remove at least 500kg of particulate matter for every 100 tonnes of fuel oil

THE HIGH TEMPERATURE IN THE SCRUBBER BURNS OFF ANY SOOT AND OILY RESIDUES. AUGUST 2014 | 29


ENVIRONMENTAL TECHNOLOGY

burned and possibly more depending on how much wash water is used. These solids must be removed before the wash water is discharged overboard and to conserve space the system should have a separation phase included that removes as much of the water as possible before sending the sludge to be stored for later disposal ashore. Scrubbers are increasingly being fitted to newbuildings but the majority now in operation have been retrofits. The time for a retrofit is currently more than a typical scheduled drydocking meaning that extra lost earning days add to the capital outlay. The capital cost of scrubbers is currently high at between $500,000 to $5M depending upon maker and vessel size but that would conceivably reduce if volume sales materialise. Payback time for a scrubber depends upon three variables; the capital and installation cost of the system, annual fuel consumption in ECAs and the price differential between distillate fuel and the normal fuel used on the vessel. Makers often talk of a payback time of less than year for ships operating full time in ECAs. Take up rates for scrubbers may be improved if flag states and others offer state aid. So far this has been mooted in Europe and Finland is one of the first EU states to take action in line with a new EC directive establishing a â‚Ź30 million fund that owners can draw on to cover half the capital and installation cost of any system they install. GLOBAL CAP COULD BE A GAME CHANGER

Currently the focus is on the rapidly approaching 2015 deadline for the reduction to 0.1% sulphur in fuels applying in ECAs but the biggest change will come in 2020 or 2025 depending on an IMO review of fuel availability. The final effect of the current Annex VI regulation on sulphur will be the reduction to sulphur limits of 0.5% applying globally. This is potentially a much more expensive regulation for the whole shipping industry to deal with as all fuel will need to be low sulphur. It is then when the demand for scrubbers is likely to soar especially if they are proven effective in dealing with the more 30 | AUGUST 2014


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stringent demands in ECAs coming in 2015. When the global cap of 0.5% comes into force, it is expected that the price difference between ordinary HFO and low sulphur fuels and distillates will widen beyond what it is today. Ships equipped with scrubbers will still retain the option of burning virtually any fuel but those without will be obliged to use only the more expensive fuel. For newbuildings, another option is to install a dual-fuel or pure gas burning engine as LNG does not contain sulphur. However, some see this as a risky strategy as the future price of LNG is an unknown factor and while there appears to be plenty available on a global scale, the switch away from coal, nuclear and oil for shorebased power production in the developed world could be a factor in pushing future prices upward. MAKING THE SWITCH

While scrubbers can allow ships to continue to make use of lower cost fuels with high sulphur content, they do not suit every operating strategy. For a ship which enters an ECA or any other area (EU and Californian ports) where sulphur is limited only on very few occasions, the capital outlay on a scrubber may not be recouped in a reasonable period. For such vessels the only means to remain compliant is to switch from HFO to low-sulphur distillate fuel prior to entering the controlled area. Switching fuels is something many operators calling at EU and ECA ports have become familiar with over the last few years but which may still be unfamiliar to crews operating mostly outside of these areas. The process can be long winded and is not without hazards that need to be taken into account. For example, low-sulphur fuels may damage existing HFO pumps because of reduced fuel oil viscosity and lubricity leading to overheating and excessive wear. Fuel injection pumps can be similarly affected necessitating their replacement by special equipment such as tungsten-carbidecoated pumps. Unless approved by the engine manufacturer, such changes may affect the engine’s compliance with NOx legislation. When running on HFO many components of the fuel system

SCRUBBERS ARE INCREASINGLY BEING FITTED TO NEWBUILDINGS BUT THE MAJORITY NOW IN OPERATION HAVE BEEN RETROFITS. AUGUST 2014 Â | 31


ENVIRONMENTAL TECHNOLOGY

SOX

are either heated directly or will become hot because of the fuel temperature. MGO running through hot piping may vaporise, creating vapour locks that interrupt the fuel supply to the engine. During the changeover, rapid or uneven temperature change could cause thermal shock, creating uncontrolled clearance adaptation, which in turn may lead to sticking/scuffing of the fuel valves, pump plungers, suction valves and, in the worst-case scenario, total seizure of the pump. To maintain an appropriate viscosity if MGO is used in an engine designed to run on HFO, a new cooler may have to be fitted; in some cases it may even be appropriate to install a chiller to remove heat through vapourcompression or an absorption refrigeration cycle. Ships entering ECAs must have a defined written procedure on board to comply with Marpol Annex VI Regulation 14. The rules also require that the following be recorded in the engine logbook: • volume of low-sulphur fuel oils in each tank; • date, time and position of vessel when changeover occurred before entering an ECA and • date, time and position of the vessel when changeover took place after leaving it.

Several equipment-makers have developed devices intended to facilitate switchover for crews. Electronically controlled engines may be easier to manage during switchover, but that is a sideeffect of the technology. Devices designed with the changeover in mind include automatic switchover management systems and components for inclusion into the fuel treatment process. Some have the ability to log the data and even transmit it to a shore office. Where this feature is available it may be used to counter claims about illegal use of fuels in ECAs. Some devices also allow switching of fuels running at full load. Sensors detect if fuel temperature changes too rapidly, in which case the system freezes the position to protect the engine’s fuel injection system from thermal shock and sends an alarm. For safety, the fuel changeover process can also be stopped manually. It some is also possible to integrate a flow and density meter to calculate total fuel consumption. 32 | AUGUST 2014


www.PureteQ.com

Design Criterias • Energy efficient • Fitted as In-line or By-Pass system easy to build in • Capacity from 4 MW to 20 MW • Weighs 30 to 40% less • Can be placed horizontal, vertical and anything in between to minimize structural work on retrofit • Easy maintainable i.e. nozzles can be replaced while in operation

A high-tech, light weight composite or alloy scrubber system for the purification of flue gas. Hydrodynamic fluid distribution ensures optimal absorption of sulphuric acid and particles.

Maritime Turbo Scrubber


ENVIRONMENTAL TECHNOLOGY

ďƒ¨ | CHAPTER 5: WASTE WATER

BIOCON waste water treatment

I

N RECENT YEARS, BALLAST WATER treatment has been the topic of major interest as regards water treatment systems on board vessels. The delay in ratifying the IMO convention continues to hold up sales and installations although the US requirements have meant that more operators are installing systems than was previously the case. The subject of ballast water treatment is extensive and is covered in detail in the ShipInsight Ballast Water Guide which can be downloaded from shipinsight.com. As a consequence the topic will not be discussed here. Leaving aside oily bilge water which is covered in the next chapter, there are two other streams of waste water produced on board ships. Commonly known as black and grey water these are sewage and general cooking and cleaning waste respectively. On a global scale sewage is subject to regulation and Annex IV of MARPOL is where the international regulations can be found. There are no international rules applying to grey water although some contend that the chemicals used in laundry, dishwashing and cleaning can be as hazardous to the marine environment as sewage. Annex IV has been in force since September 2003, and applies to ships of 400GT and above and ships below 400GT that are certified to carry more than 15 persons. It contains a set of

34 | AUGUST 2014


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regulations regarding the discharge of sewage into the sea, ships’ equipment and systems for the control of sewage discharge and requirements for survey and issuance of the International Sewage Pollution Prevention Certificate (ISPP) that all ships subject to the regulation must carry. Rules on black water discharge, specified in MEPC 159(55) under MARPOL Annex IV, came into force in January 2010. They cut permissible sewage discharge levels of suspended solids from new buildings by more than half, even in open sea, the volume of allowable faecal coliform discharges by more than 70% and biochemical oxygen demand by 50%. The rules also introduced a particularly low limit of residual chlorine to protect the marine environment and aqua life from the side effects of sewage treatment. In 2011, Annex IV was revised so that a higher level of protection against sewage pollution can be applied in Special Areas. The amendments introduced the concept of Special Areas and the designation of the Baltic Sea as the first Special Area. It also introduced new provisions applying to Passenger Ships. The equipment required on board ships subject to Annex IV is detailed in Regulation 9. Prior to the 2011 amendments, only paragraph 1 was in force with paragraph 2 being added in 2012. REGULATION 9

1. Every ship which, in accordance with regulation 2, is required to comply with the provisions of this Annex shall be equipped with one of the following sewage systems: .1 a sewage treatment plant which shall be of a type approved by the Administration, taking into account the standards and test methods developed by the Organization∗, or .2 a sewage comminuting and disinfecting system approved by the Administration. Such system shall be fitted with facilities to the satisfaction of the Administration, for the temporary storage of sewage when the ship is less than 3 nautical miles from the nearest land, or .3 a holding tank of the capacity to the satisfaction of the

THERE ARE NO INTERNATIONAL RULES APPLYING TO GREY WATER ALTHOUGH SOME CONTEND THAT THE CHEMICALS USED IN LAUNDRY, DISHWASHING AND CLEANING CAN BE AS HAZARDOUS TO THE MARINE ENVIRONMENT AS SEWAGE. AUGUST 2014 | 35


ENVIRONMENTAL TECHNOLOGY

Administration for the retention of all sewage, having regard to the operation of the ship, the number of persons on board and other relevant factors. The holding tank shall be constructed to the satisfaction of the Administration and shall have a means to indicate visually the amount of its contents. * Refer to the Recommendation on International effluent standards and guidelines for performance tests for sewage treatment plants adopted by the Organization by resolution MEPC.2(VI). For existing ships national specifications are acceptable.

2. By derogation from paragraph 1, every passenger ship which, in accordance with regulation 2, is required to comply with the provisions of this Annex, and for which regulation 11.3 applies while in a special area, shall be equipped with one of the following sewage systems: .1 a sewage treatment plant which shall be of a type approved by the Administration, taking into account the standards and test methods developed by the Organization,2 or .2 a holding tank of the capacity to the satisfaction of the Administration for the retention of all sewage, having regard to the operation of the ship, the number of persons on board and other relevant factors. The holding tank shall be constructed to the satisfaction of the Administration and shall have a means to indicate visually the amount of its contents.�

The new paragraph 2 removed one of the previous sewage treatment options permitted to ships operating in the Baltic and also introduced new performance standards for treatment plants. In October 2012 The MEPC adopted the 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants. The new standards apply to new passenger ships from 1 January 2016 and for existing passenger vessels from January 2018. A decision on which nitrogen and phosphorus removal standard to adopt is expected to be made at MEPC 67 in October 2014. As can be seen from Regulation 9, the approval of sewage 36 | AUGUST 2014


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WASTE WATER

treatment plants is left to the flag state. There is plenty of choice both in numbers of suppliers and in the technologies and treatment methods used. Systems for treating sewage employ methods ranging from those based on physical or chemical separation to biological and electrolytic treatment systems. Not surprisingly because the objective is to destroy harmful bacteria in sewage many of the treatment methods employed are the same as those used in ballast water treatment systems. As well as biological treatment, hypochlorination and UV are commonly employed. Some systems do not rely on a single method but combine methods to increase effectiveness. Membrane bio-reactors are also popular. Greywater issues have remained largely absent from the maritime conscience, perhaps due to the rather more obvious and immediate effects of blackwater. But greywater can pose equally difficult challenges, particularly if a dangerous chemical finds its way into a sink, laundry or shower system. Greywater has managed to creep under the regulatory radar, mostly because it has a tenth of the levels of nitrogen and pathogens that appear in sewage and decomposes more rapidly. But due to the high volume of untreated greywater produced by the ever-increasing number of passenger cruise ships and ferries, manufacturers have developed systems aimed at greywater treatment. The development of greywater-oriented systems has also come about because of the need to establish ways to effect the complete degradation of organic matter found in greywater, including fat and grease. Many manufacturers are active in the sector and again a variety of technologies are employed. In order to remove fat and grease, some systems make use of separation technology similar to that used for treating oily bilge water and described in more detail in the following chapter. It is not unknown for black and grey water to become mixed due to operational reasons such as use of wrong tanks or when one tank becomes full and the only space available is in the other system’s holding tank. In 2012 at IMO MEPC 64, the delegation

THE MEPC ADOPTED THE 2012 GUIDELINES ON IMPLEMENTATION OF EFFLUENT STANDARDS AND PERFORMANCE TESTS FOR SEWAGE TREATMENT PLANTS. AUGUST 2014 Â | 37


ENVIRONMENTAL TECHNOLOGY

WASTE WATER

of the Netherlands informed the Committee of some preliminary results on a survey conducted on the performance status of the sewage treatment plants installed on board ships, which indicated that a vast majority of the equipment did not meet the existing sewage treatment standards due to improper use of detergent, lack of maintenance or not following the operational instructions. Revelations such as this can mean a concerted inspection campaign will be initiated by PSC regimes. Although MARPOL does not regulate grey water, some other national and state bodies do. Regional rules vary and change frequently. In Alaska, stringent limits regarding cruise ship discharges were introduced in 2000 (33CFR159 sub-part E) with grey water regulated for the first time. In addition to Alaska’s clean-up efforts, the Great Lakes, US waters (EPA Vessel General Permit, 2013), and inland waterways in Europe (2012/49/EU) have also regulated grey water treatment in various shapes and forms, each affecting certain shipping sectors. There are already four sets of different type approval specifications and at least five different compliancy regimes for operators and equipment makers to contend with. Some equipment makers have developed treatment systems that can handle both black and grey water. These systems ensure compliance with regulations and also save space as there is no need to duplicate equipment. Headworks CleanSeaŽ wastewater system being installed

38 | AUGUST 2014



ENVIRONMENTAL TECHNOLOGY COMPANY

WEBSITE

ACO MARINE

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AEC MARITIME

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ALFA LAVAL

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AQUAMETRO

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CASTROL

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CJC

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CLEAN MARINE

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COMPASS WATER SOLUTION

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CR OCEAN ENGINEERING

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CROLL REYNOLDS

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DECKMA

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DELTALANGH

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DESMI A/S

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DUPONT BELCO

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DVZ

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ENSOLVE BIOSYSTEMS

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EVAC

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EXXONMOBIL

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GEA WESTFALIA SEPARATOR GROUP

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GREEN INSTRUMENTS

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GREEN TECH MARINE

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GULF OIL

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HALDOR TOPSØE

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HITACHI ZOSEN

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INSATECH A/S

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JOWA

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MAN DIESEL

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MES

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PANASIA

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RSC BIO SOLUTIONS

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RWO

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SAACKE

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SKF

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THORDON BEARINGS

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TOTAL LUBMARINE

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VICKERS OIL

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VICTOR MARINE

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WARTSILA

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YARA

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40 | AUGUST 2014

NOX

SOX

DIESEL SWITCH

• •

• •

• • •

• •

• •


SHIPINSIGHT.COM EMISSION MONITORING

BLACK & GREY WATER

OWS/OCM

SEALS

LUBES

MISCELLANEOUS

• •

• • • •

• • •

• •

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• • • • •

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AUGUST 2014 | 41


ENVIRONMENTAL TECHNOLOGY

 | CHAPTER 6: OIL & GREASE

Alfa Laval PureDry

A

LTHOUGH MOST CURRENT INTEREST in shipping’s impact on the environment has been focussed on ballast water and exhaust emissions, it is pollution by oil that is the raison d’etre of MARPOL and most other regulation. Above all it is pollution resulting from operational reasons rather than accidental loss of cargo or bunkers as a result of grounding or collision that is the issue and this is covered in ANNEX I of MARPOL as well as the US EPA’s VGP introduced in 2008. The major part of ANNEX I is actually concerned with construction and cargo operations of oil tankers over 150GT and the parts which affect other vessel types over 400GT is confined to a very few operational matters as well as the form and issuing of the International Oil Pollution Prevention Certificate (needed in most ports to obtain custom’s clearance) and the need for ships to have and maintain an oil record book. The first demand as regards the operational waste oil from machinery is that the ship must be fitted with adequate holding tank capacity for any waste that cannot be dealt with by way of discharge or incineration. Most ships generate large amounts of oily waste (waste contaminated with oil) and waste oils (such as spent lubes or sludge from fuel and lube treatment systems). As well as the oil in the bilge water there will be grease, detergents and cleaning fluids along with contaminants that may 42 | AUGUST 2014


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have been removed from fuel and lube treatment systems, some of these may present more of a hazard to the marine environment than oil does. Prior to the introduction of regulations, all of this waste would generally have been disposed of at sea. Today all vessels above 400GT are required to filter the waste so as to reduce the oil content to a maximum of 15ppm (Canadian rules on the Great Lakes have a maximum of 5ppm) before discharging it at sea. Some classification societies also demand a higher standard of 5ppm to comply with their voluntary clean design notations The resultant waste must be retained on board for disposal ashore. The filtering is done by a bilge or oily water separator – a piece of equipment that has gained an unenviable reputation in recent years. As well as the separator, all vessels subject to the regulation must also be fitted with an oil content monitor (OCM) and bilge alarm to detect if the treated bilge water being discharged meets the discharge requirements. Separators used on board ships are not generally unique pieces of equipment design specifically for marine use but will be versions of separators used in many industries ashore. It is generally accepted that separators have not performed as well at sea as they do in applications ashore. There are many reasons for this including the fact that the waste products are less easy to deal with, the conditions at sea with constant movement in many planes affecting operation and the fact that installed systems often lack the capacity to meet the demands placed on them. As a consequence, they require constant monitoring and frequent cleaning and overhaul which has made them unpopular with many seafarers. This coupled with the operators’ desire to reduce the cost of disposing of treated waste ashore has led to several instances where the separator has been by-passed and waste discharged illegally overboard. These are the so-called ‘magic pipe’ incidents that lead to regularly reported prosecutions by port state control regimes and heavy fines and imprisonments especially in the US. The regulations may lay down a maximum limit of oil but they

THE SHIP MUST BE FITTED WITH ADEQUATE HOLDING TANK CAPACITY FOR ANY WASTE THAT CANNOT BE DEALT WITH BY WAY OF DISCHARGE OR INCINERATION. AUGUST 2014 | 43


ENVIRONMENTAL TECHNOLOGY

leave the means of achieving this open. As a consequence, several technologies are used across the diverse range of separators available and crew members may find themselves having to operate and service unfamiliar equipment. For someone trained on centrifugal separators, dealing with those that use membranes, flocculation or absorption filters means valuable time must be spent searching out manuals and attempting to make sense of them. Early separators were mostly of the gravity separation type that employ plate or filter coalescing technology to separate oil and water. The bilge water is usually heated gently to improve separation with the oil gradually settling out above the water content. The oil is then pumped to the holding tank and the water discharged to sea after passing through the OCM. Without further refinements, gravity separators can have difficulty in meeting the 15ppm standard especially when the bilge water contains emulsified oils which do not separate easily. Centrifugal separators also work using the different densities of oil and water but with the centrifuge greatly multiplying the gravity effect as the centrifuge accelerates. This type of separator is more efficient and can generally deal with emulsified oils. Many crew members are familiar with this type of equipment which is also used for preparing fuels and lubes before use by removing sludge and homogenising the fuel or lube. They are more compact than gravity type separators but have the disadvantage of requiring power to operate the centrifuge and because of their moving parts often have a higher maintenance requirement. One way for separator performance to be improved is to add a polishing device into the circuit. Several makers’ current systems include a polishing stage but for older vessels, adding a polishing unit between separator and monitor will improve the performance sufficient to prevent alarms sounding constantly. Other technologies are also used for cleaning bilge water including absorption and adsorption, flocculation, biological and membrane separation. Absorption and adsorption are very similar physicochemical processes and for the purpose of this guide can 44 | AUGUST 2014


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ENVIRONMENTAL TECHNOLOGY

be considered together. In both cases, the bilge water is forced through the sorption media in a reactor or contactor vessel and the oil is removed. When the sorption material has reached its full capacity it is removed and replaced with fresh material. Some sorption materials can be regenerated on board but others will need to be delivered to shore. Popular absorption materials include bentonite and zeolite used as substrates or in cartridges. Typically 100m3 of bilge water will require 10kg of media. Flocculation and coagulation make use of an emulsion breaking chemical to treat emulsions after any free oil has been separated. The chemical breaks down the emulsion and the released oil comes together to form flocks which can then be skimmed off leaving the remaining water to go through further filtration stages. This method tends to produce large amounts of sludge and requires an outlay on the chemical reagent. Biological treatment employs microbacteria in a bioreactor to literally consume the organic chemicals in the oil converting it to carbon dioxide and water. It is a slow but effective treatment for oil and emulsions as well as also removing some of the other solvents often found in bilge water. Capital outlay can be high but operating costs are low. Care must be taken to avoid overload on the microrganisms and maintaining operating temperature within the safe range to avoid destroying them. Membrane technology, ultrafine filtration and reverse osmosis are all physical means of preventing oil and other large molecules from remaining with the water that can pass through the filter barrier. They are efficient but require attention to prevent blocking of the filter or membrane. Avoiding problems with separators begins long before the device is switched on and involves a proper plan for managing waste streams and doing as much as possible to prevent emulsions forming especially if they are chemical emulsions resulting from the use of cleaning chemicals and detergents. So called primary emulsions in which larger drops of oil are dispersed in water generally separate through gravity within 24 hours. Secondary emulsions caused by turbulent conditions where oil 46 | AUGUST 2014


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OIL & GREASE

droplets are very fine become stable and will not separate easily. Solid material should also be prevented from contaminating the bilge as much as possible. Not only does it promote emulsification it also creates false alarm situations and shuts down the separator requiring crew intervention to restart the separation process. Filters and removal of solids before treatment will allow the separator to operate more effectively and for longer. Oil-in-water monitors may be fooled by suspended solids such as rust and scale which are quite innocuous but they may not detect the presence of some chemicals which could be toxic to marine life when discharged into the sea. The monitor is a crucial component of separators and is often not an in-house product of the separator maker. SEALING THE LEAKS

Lubricant leak from propeller shaft and rudder bearings are a common cause of pollution and have attracted attention in recent years. Until around 50 years ago, many ships were fitted with propeller shaft bearings made from lignum vitae an extremely dense timber with a high degree of natural lubricity but these were abandoned in favour of metal bearings and mineral oil lubricants. Now, as environmental regulations tighten, water-lubricated propeller shaft bearings are becoming a popular alternative to oil-lubricated bearings for commercial vessels. This was already happening before the US EPA revised the VGP last year but that action is likely to accelerate take up of water lubricated bearings and new seal types and also a greater use of new approved lubricants. Conventional seals inevitably leak over time due to wear and damage but water-lubricated bearings avoid oils and grease lubricants altogether. Seawater is pumped into the bearing and it simply discharges to the sea. It lubricates and dissipates heat from shaft friction and most manufacturers of water lubricated seals say their products provide equal performance. US rules mean lube changes Under the new VGP introduced in the US last year the list of

IT IS A SLOW BUT EFFECTIVE TREATMENT FOR OIL AND EMULSIONS AS WELL AS ALSO REMOVING SOME OF THE OTHER SOLVENTS OFTEN FOUND IN BILGE WATER. AUGUST 2014 Â | 47


ENVIRONMENTAL TECHNOLOGY

permitted substances and the quantity each ship above 300GT will be allowed to discharge was reduced – quite dramatically in some cases. One of the changes under the VGP affects lubricants in any equipment or system that has an oil-to-sea interface. In essence, that affects all propulsion systems and also deck machinery where run-off over the ship’s side could occur. Previously under the earlier 2008 VGP, operators were free to use any lubricant they wished but from December 2013 the rules require environmentally acceptable lubricants (EALs) unless doing so would be ‘technically unfeasible’. EALs are defined as biodegradable, which rules out all mineral-based lubricants and even some synthetic alternatives. The exact definition of an EAL is contained in an EPA document, EPA 800-R-11-002 November 2011, which can be accessed via the organisation’s website. Operators have to apply for a VGP before a vessel enters US waters and to do so they need to identify all oil-to-sea interfaces and lubricants involved. Among the most obvious systems are the stern tube, rudder bearings, CP propellers, thrusters, and fin stabilisers. In addition, winches, cranes, hatch covers, and even crane wires and the like must be considered. The ship will be required to document all lubricants and any reason why the use of an EAL would be technically unfeasible. Most major oil companies and some specialist suppliers have formulated compliant products that are readily available although with a premium price tag. However, these products are not necessarily compatible with some makes of seals, especially conventional rubber seals. This is a known problem and most combinations of lubricants and seals have been tested for compatibility over normal dry docking cycles of two to three years. In selecting an EAL, operators must therefore seek advice from the seal manufacturer and great care must be exercised if the vessel makes use of enhanced or extended dry docking strategies. Inspections with regard to EALs would involve visual sheen tests and inspections of deck runoff. Some checking will be carried out by state authorities, with California and Florida expected to be quite active. The ‘unless technically infeasible’ proviso can allow 48 | AUGUST 2014


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OIL & GREASE

some temporary relief if the ship has seals that are incompatible with any EALs, in which case it can continue to use mineral oil until the next planned docking, when the seals are to be replaced, or if the equipment manufacturer has no recommended seal-EAL combination for its product. Some pre- lubricated wire ropes are also included in the exemption. If the use of an EAL in an oil-to-sea interface is claimed to be technically infeasible, the ship must carry documentation to that effect. Supporting documentation written by the manufacturer or owner must not be more than one year old and must confirm the factual situation. Any such claims may be investigated by the US authorities, with severe penalties if they are found to be falsely declared. ACO Grease seperator

AUGUST 2014 Â | 49


ENVIRONMENTAL TECHNOLOGY

ďƒ¨ | CHAPTER 7: OTHER MEASURES

VOMM - Treatment of food waste

A

LL SHIPS TEND TO GENERATE garbage such as food waste, packing materials, securing and separation materials and cargo residues. Getting rid of ship-generated waste costs money and it is likely that those costs have increased over the last 18 months since the 2011 amendments to MARPOL ANNEX V came into force on 1 January 2013. Incinerators or compactors were already installed on many ships allowing them to manage their waste but others have only rudimentary facilities that could eventually prove inadequate under the new regime. Even for those ships fitted with incinerators, the new regulations mean the ash residue is considered as garbage and should be disposed of ashore. The 2013 rules contained detailed descriptions of different 50 | AUGUST 2014


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waste types and where they may be discharged at sea. Segregating the waste requires effective management on board and alongside the new discharge regulations is a requirement for every ship above 100GT to have in place a garbage management plan and to carry a record book detailing all aspects of waste handling and disposal. A ship’s garbage management plan should contain a list of the particular ship’s equipment and arrangements for the handling of ship-generated garbage, and may contain extracts from and/or references to existing company instructions and manuals. In addition, a crew member has to be designated as the environmental control officer responsible for maintaining records and arranging disposal. Any garbage that cannot be disposed of onboard will need to be sent to a shore waste facility any may need to be segregated. The most appropriate procedures for handling and storing garbage will vary depending on factors such as the type and size of the ship, the area of operation, shipboard garbage processing equipment and storage space, the number of crew or passengers, the duration of the voyage, and regulations and reception facilities at ports of call. However, in view of the cost involved with the different garbage handling options, it is economically advantageous first to limit the amount of material that may become garbage from being brought on board the ship and, second, separate garbage eligible for discharge into the sea from other garbage that may not be discharged in this way. Several companies provide segregation and compacting plant suitable for any size of ship, although on small vessels it should be quite easy for the crew to fashion something suitable themselves. Compactors, baling presses, shredders, and crushers, can reduce the volume of ship generated waste by up to 90%. That is significant if the cost of shore disposal is taken into account.

EVEN FOR THOSE SHIPS FITTED WITH INCINERATORS, THE NEW REGULATIONS MEAN THE ASH RESIDUE IS CONSIDERED AS GARBAGE. AUGUST 2014 | 51


ENVIRONMENTAL TECHNOLOGY

SIMPLIFIED OVERVIEW OF THE DISCHARGE PROVISIONS OF THE REVISED MARPOL ANNEX TYPE OF GARBAGE

SHIPS OUTSIDE SPECIAL AREAS

SHIPS WITHIN SPECIAL AREAS

OFFSHORE PLATFORMS (MORE THAN 12NM FROM LAND) AND ALL SHIPS WITHIN 500M OF SUCH PLATFORMS

FOOD WASTE COMMINUTED OR GROUND

DISCHARGE PERMITTED 3NM FROM THE NEAREST LAND, EN ROUTE AND AS FAR AS PRACTICABLE

DISCHARGE PERMITTED 12NM FROM THE NEAREST LAND, EN ROUTE AND AS FAR AS PRACTICABLE

DISCHARGE PERMITTED

FOOD WASTE NOT COMMINUTED OR GROUND

DISCHARGE PERMITTED 12NM FROM THE NEAREST LAND, EN ROUTE AND AS FAR AS PRACTICABLE

DISCHARGE PROHIBITED

DISCHARGE PROHIBITED

CARGO RESIDUES1 NOT CONTAINED IN WASH WATER

DISCHARGE PERMITTED 12NM FROM THE NEAREST LAND, EN ROUTE AND AS FAR AS PRACTICABLE

DISCHARGE PROHIBITED

DISCHARGE PROHIBITED

CARGO RESIDUES1 CONTAINED IN WASH WATER

DISCHARGE PERMITTED 12NM FROM THE NEAREST LAND, EN ROUTE, AS FAR AS PRACTICABLE

DISCHARGE PERMITTED 12NM FROM THE NEAREST LAND, EN ROUTE, AS FAR AS PRACTICABLE AND SUBJECT TO TWO ADDITIONAL CONDITIONS2

DISCHARGE PROHIBITED

CLEANING AGENTS AND ADDITIVES1 CONTAINED IN CARGO HOLD WASH WATER

DISCHARGE PERMITTED

DISCHARGE PERMITTED 12NM FROM THE NEAREST LAND, EN ROUTE, AS FAR AS PRACTICABLE AND SUBJECT TO TWO ADDITIONAL CONDITIONS2

DISCHARGE PROHIBITED

CLEANING AGENTS AND ADDITIVES1 IN DECK AND EXTERNAL SURFACES WASH WATER

DISCHARGE PERMITTED

DISCHARGE PERMITTED

DISCHARGE PROHIBITED

CARCASSES OF ANIMALS CARRIED ON BOARD AS CARGO AND WHICH DIED DURING THE VOYAGE

DISCHARGE PERMITTED AS FAR FROM THE NEAREST LAND AS POSSIBLE AND EN ROUTE

DISCHARGE PROHIBITED

DISCHARGE PROHIBITED

DISCHARGE PROHIBITED

DISCHARGE PROHIBITED

ALL OTHER GARBAGE INCLUDING DISCHARGE PROHIBITED PLASTICS, SYNTHETIC ROPES, FISHING GEAR, PLASTIC GARBAGE BAGS, INCINERATOR ASHES, CLINKERS, COOKING OIL, FLOATING DUNNAGE, LINING AND PACKING MATERIALS, PAPER, RAGS, GLASS, METAL, BOTTLES, CROCKERY AND SIMILAR REFUSE MIXED GARBAGE

WHEN GARBAGE IS MIXED WITH OR CONTAMINATED BY OTHER SUBSTANCES PROHIBITED FROM DISCHARGE OR HAVING DIFFERENT DISCHARGE REQUIREMENTS, THE MORE STRINGENT REQUIREMENTS SHALL APPLY

These substances must not be harmful to the marine environment. According to regulation 6.1.2 of MARPOL Annex V the discharge shall only be allowed if: (a) both the port of departure and the next port of destination are within the special area and the ship will not transit outside the special area between these ports (regulation 6.1.2.2); and (b) if no adequate reception facilities are available at those ports (regulation 6.1.2.3).

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OTHER MEASURES

COATINGS

Coatings used to protect against hull fouling have different environmental impacts. By preventing fouling they allow ships to burn less fuel and therefore play a role in reduction of exhaust emissions. However, even though TBT which was said to have had an adverse environmental effect causing problems for some marine organism has now been banned from use, some are saying that the copper-based substitutes are also hazardous. Details on most of the current range of coatings and the technologies employed can be found in the ShipInsight Guide to Paints & Coatings. While criticisms are being directed at the replacement antifouling products for still having the potential to hard wildlife, the IMO has recognised the role that anti-foulings can have in preventing species transfer. In July 2011, the IMO issued RESOLUTION MEPC.207(62) “Guidelines for the control and management of ships’ biofouling to minimise the transfer of invasive aquatic species”. The guidelines are contained in a 25 page document and while couched in the typical language of IMO regulations, they are nothing more than industry best practice on application, inspection and maintenance of the hull coating system. Currently the guidelines are purely advisory, although flag states are encouraged to ensure their use on board ships. It is expected that at some future date, the guidelines will become mandatory. EFFICIENCY DRIVE

The push for efficiency improvements in ships needed partly to allow newbuildings to meet the EEDI requirements but mostly driven by operators desiring to reduce fuel costs is being met by manufacturers across a range of products. Every method of reducing fuel consumption that can be employed has the added environmental benefit of cutting exhaust emissions. Energy saving devices (ESDs) come in many guises from hull modifications, through to propeller/rudder combinations and appendages and adaptations to engines and machinery. Taking

BY PREVENTING FOULING THEY ALLOW SHIPS TO BURN LESS FUEL AND THEREFORE PLAY A ROLE IN REDUCTION OF EXHAUST EMISSIONS. AUGUST 2014 | 53


ENVIRONMENTAL TECHNOLOGY

things a little further, the term can include means of exploiting energy from the wind, sun and waves or storing excess power by way of batteries for use later. Today, ESDs have become linked in the minds of many to the slow steaming strategies adopted by some operators – particularly in the container trades. While it is true that some devices such as turbocharger cut-outs and concepts such as variable turbine geometry have come about simultaneously with slow steaming, their use can be extended to vessels for other reasons as well. Several means of cutting fuel use were explored in the ShipInsight Guide to ESDs and employing one or more of the devices could lead to savings from 2% to 17%. In many cases the payback period is measured in months and not years. Software too has a role to play in reducing fuel use and so cutting emissions. Two type of application in particular are worthy of particular consideration; Trim optimisation and weather routing. Both have been heavily promoted by proponents of e-navigation although the need for such software has been questioned by some who believe that it undermines the knowledge and expertise of ships’ navigating officers. Coatings play a role in reduction of exhaust emissions

54 | AUGUST 2014


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