International Regulation News Update / Resources / Regulatory Information
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1 International Regulation News Update / Resources / Regulatory Information Marine Environment Protection Committee s 64 th Session (1 to 5 October 2012) Regulatory Development MARPOL VI AIR POLLUTION PREVENTION (pages 1-2) Required EEDI for Future Ships Calculation of the Attained EEDI Application of SEEMP Impact of EEDI on Major Conversions VOC Control BALLAST WATER MANAGEMENT (pages 2-5) BWM Implementation Concerns Certification Transitional Measures Final Approval Granted Basic Approvals Granted MISCELLANEOUS (page 6) Shipboard Incineration Ship Recycling Ship Application All Ships All Ships All Ships ( All Ships includes all marine craft including barges, drill rigs, submersibles, and floating platforms) ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE, JANUARY 2013 (VOL 22, NO.1)
2 The 64 th session of the Marine Environment Protection Committee met in London from 1 to 5 October Guidance and interpretations to implement requirements for ship energy efficiency were adopted. Additional approvals of new ballast water treatment systems were granted and measures were agreed to facilitate initial implementation of the Ballast Water Management (BWM) Convention. MARPOL VI AIR POLLUTION PREVENTION Required EEDI for Future Ships Under Chapter 4 of MARPOL VI, the initial Required EEDI value (Phase 0) is reduced in three-10 percent increments according to ship type and size as indicated in Table 1, below. Table 1 - Ship Type/Size vs Reduction Factors Ship Type Bulk Carrier Gas Tanker Tanker Oil Chem, NLS Container Ship General Cargo Ship Refrigerated Cargo Carrier Combination Carrier DWT (kt) Phase No Reduction Factors D < 20 n/a 0-10* 0-20* 0-30* D < 10 n/a 0-10* 0-20* 0-30* D < 20 n/a 0-10* 0-20* 0-30* D < 15 n/a 0-10* 0-20* 0-30* D < 15 n/a 0-10* 0-15* 0-30* D < 5 n/a 0-10* 0-15* 0-30* D < 20 n/a 0-10* 0-20* 0-30* * linearly interpolate between two values and deadweight Phase 0 applies to the first generation of ships: with a building contract placed on or after 1 January 2013; or in the absence of a building contract, with a keel laid or which is at a similar stage of construction on or after 1 July 2013; or regardless of the building contract or keel laying date, with a delivery on or after 1 July However, Chapter 4 is silent on the definition of subsequent generations of new ships for the application of the remaining three Phases of Required EEDI baseline values. Recognizing this gap, the Committee approved MEPC.1/Circ.795 which defines the subsequent generations of new ships as indicated in Table 2, below. Table 2 is to be read consistent with the definition of the first generation of new ships where the Phase applies to the ship s contract for construction or, in the absence of a building contract, the keel laying date. In both cases, however, the delivery date governs regardless of the former two dates. Delivery Table 2 - EEDI Phase Application Contract 1 Jul Jul Dec Jan Dec Jan Dec 2028 On/After 1 Jan 2029 Delivery Keel lay 1 Jul Jul Dec Jan Dec Jan Dec 2028 On/After 1 Jan Jan Jan Dec Jan Dec 2019 n/a Jan Dec On/After 1 Jan Jul Jul Jun 2015 n/a 0 1 Jul Jun Jul Jun On/After 1 Jul ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE, JANUARY 2013 (VOL.22, NO.1) page 1 of 6
3 Calculation of the Attained EEDI In determining a ship s Attained Ship Energy Efficiency Design Index (EEDI) in accordance with the procedure contained in resolution MEPC.212(63), the Committee agreed that it is necessary to establish a lower threshold for the minimum installed propulsion power for bulk carriers, oil and chemical tankers and combination carriers. Accordingly, these ships are to have a minimum power to maintain manoeuvrability under adverse weather conditions (Beaufort 8 6.0m significant wave height/19.0 m/s mean wind speed). The method for determining this lower minimum threshold is contained in a set of interim guidelines which were approved by the Committee and are subject to approval by MSC 91 in December Application of SEEMP In response to a proposal submitted by IACS and ICS, the Committee issued MEPC.1/Circ.795 which clarifies the following: Fixed and floating platforms (including floating production and/or storage units) and drilling rigs, regardless if self propelled or non-self propelled, are excluded from carrying a SEEMP onboard. SEEMPS are to be written in the working language/languages understood by ship s personnel. SEEMPs are required to be carried on board not later than the first intermediate or renewal survey of the IAPP Certificate, whichever occurs first, on or after 1 January The lack of a SEEMP on board during the first intermediate/renewal survey of the IAPP Certificate does not impact the validity of the IAPP Certificate. Impact of EEDI on Major Conversions MEPC.1/Circ.795 also provides clarification of the provisions in MARPOL VI, regulation 2(24), with respect to a major conversion that substantially alters the dimensions, carrying capacity or engine power of the ship. A conversion involving a change in hull dimension, length between perpendiculars, assigned freeboard or substantial increase (e.g., 5% or more) of total engine power for propulsion would require the converted ship to comply with the Required EEDI corresponding to the original contract for construction date, keel laying date (if applicable), or delivery date for that ship. BALLAST WATER MANAGEMENT BWM Implementation Concerns The BWMS Convention will enter into force twelve months after the date on which not less than thirty states representing thirty-five percent of the world s merchant fleet tonnage have ratified the Convention. The current ratification status of the BWM Convention is thirty-six member States representing 29.07% of the world s merchant fleet. A submission by several Member States and Industry Organizations raised concerns on a number of issues impacting ratification and implementation of the BWM Convention that need to be addressed to ensure its proper and effective implementation: The G-8 Guidelines used for type approval do not provide for documentation in sufficient detail (e.g., filter back-flush time, operating pressures or conditions) in order to assess the adequacy of the system relative to the needs and operation of the vessel in real world conditions. Further, the Guidelines do not fully take into account the possibility of an increase of corrosion for technologies using oxidation to treat ballast water. Availability of BW treatment systems will be a significant challenge as an estimated 8700 ships (with a ballast capacity not more than 5000 m3) will require to have installed and use a BW system on the date of entry into force of the Convention. In addition, the remainder of ships requiring installation of BW systems in the years between entry into force and the final dates permitted under regulation B-3 will be significant and compressed into a relatively short period of time. ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE, JANUARY 2013 (VOL.22, NO.1) page 2 of 6
4 The compatibility of draft operating procedures for ballast water sampling and analysis versus the G-8 Type Approval Guidelines remains a concern as there is the potential for properly used and maintained Type Approved systems being found noncompliant when assessed in accordance with the draft operating procedures. This is mainly attributable to the representativeness of samples, the lack of standardized procedures for conducting the sampling and analysis, and the limited level of confidence of the sampling process. Based on the above concerns, the Committee agreed to the development of an Assembly resolution which would contain a scheme to ease and facilitate the smooth implementation of the Convention, but it would not revise the compliance date contained in regulation B-3 for ships constructed before Certification Transitional Measures The Committee approved a new Circular which addresses transitional measures for implementing the BWM Convention on entry into force. The Committee agreed that it would be impracticable, for those responsible, to prepare, review and approve BWM Plans and survey and certify all ships of 400 gross tonnage and above within the 12-month period between the date when the conditions for the entry into force have been satisfied and the actual entry-into-force date of the Convention. To address the impracticability, the Circular allows the issuance of International Ballast Water Management Certificates by or on behalf of signatory States (within the 12 month period between the date when the conditions for entry into force have been satisfied and the actual entry into force date of the Convention). In the event a BWM Plan is onboard but has not been approved, the Circular allows a statement to be issued to the Company indicating when the BWM Plan has been received for review by the Administration or authorized RO thereby allowing the vessel to trade for three months with an unapproved BWM Plan onboard. Additionally, the Circular acknowledges that BWM Plans approved in accordance with resolution A.868(20) remain valid until the plan requires revision due to the installation of a ballast water management system at which time the plan is to be reviewed in accordance with resolution MEPC.127(53). Final BW System Approvals Final Approvals were granted to three (3) more systems by the Committee: DESMI Ocean Guard (DOG) BWMS. The DOG BWMS, submitted by Denmark, uses a combination of filtration (40 µm with automatic backflushing) and disinfection with low pressure UV irradiation and ozone to treat the ballast water at uptake and discharge. The low pressure UV lamps used for disinfection are also employed to provide ozone by means of UV irradiation of atmospheric oxygen. The produced ozone is a secondary disinfectant and is transported via airflow and is introduced to the ballast water flow via an eductor in a side stream flow after the UV unit. Fig.1 DESMI Ocean Guard (DOG) BWMS The DOG BWMS is fully automated with programmable logic controllers (PLC) and informative touch panels. The monitoring and controls include flow meters, pressure transmitters, water quality and ozone gas sensors, and automatic valves. The UV lamps are expected to have a service life of 12,000 operating hours, and the PLC control system is designed to inform the operator of necessary maintenance operations. Confirmation from the operator of maintenance work performed is also logged. ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE, JANUARY 2013 (VOL.22, NO.1) page 3 of 6
5 JFE Ballast Ace using NEO-CHLOR MARINE The JFE Ballast Ace system using NEO-CHLOR Marine,, submitted by Japan, has been developed by JFE Engineering Corporation of Japan. It uses the proprietary dry granular powder, Neo-Chlor Marine, manufactured by Shikodu Chemical Corporation also of Japan. The main component is sodium dischloroisocyanurate dehydrate which is immediately converted to the active substance sodium hypochlorite and isocyanuric acid by dissolving in water. Sodium hypochlorite is used to treat the ballast water at uptake in the system and a sodium sulfite aqueous solution is used to neutralize the ballast water prior to discharge. Prior to disinfection by Neo-Chlor Marine the ballast water passes through a filtration system to eliminate larger organisms and suspended matter. The material collected by the filter is retuned with a back flush to the marine environment in the region of uptake. Smart Ballast BWMS The Smart Ballast BWMS, submitted by the Republic of Korea, employs in situ electrolysis to produce sodium hypochlorite directly from the seawater to treat the ballast water. During de-ballasting, the treated ballast water is monitored by a TRO sensor in the discharge pipe and a feed back control system controls the dosage of the neutralizing solution into the deballasting pipe to maintain a TRO concentration of less than 0.2 mg/l in the discharge water. The electrolysis unit of the Smart Ballast BWMS is a full flow system mounted directly in the main ballast pipe line. The TRO sensors provide feedback to the control unit, which in turn adjust the power supply to the electrolysis unit to supply the required sodium hypochlorite concentration. No dedicated filter system is intended to be installed as part of the Smart Ballast BWMS. Fig.2 - JFE Ballast Ace - NEO-CHLOR MARINE The dosage of total residual oxidants (TRO) is controlled by TRO sensors which determine the TRO concentration in the discharge and adjust the amount of sodium sulfite neutralizer to be added prior to discharge. The TRO concentration in the treated ballast water after neutralization is then determined by high sensitivity TRO sensors. The JFE Ballast Ace requires the storage of dry granular powder Neo-Chlor Marine and the neutralizer chemical sodium sulfite on board the ship. Fig.3 - Smart Ballast BWMS The neutralizing solution is prepared by mixing sodium thiosulfate (stored as a crystalline powder in a polyethylene container) with fresh water for the neutralization unit. This solution is injected into the de-ballasting line. A mixer is installed to ensure good mixing of the deballasting water and neutralizing solution. The injection of the neutralizing solution is controlled by a total residual oxidant (TRO) sensor. Basic BW System Approvals Basic Approvals were granted to five (5) more systems by the Committee: KTM-BWMS The KTM-BWMS, submitted by the Republic of Korea, employs in-situ electrolysis creating sodium hypochlorite with a Plankill Pipe which damages the zooplankton by physical effects of collision and turbulence before electrolysis. ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE, JANUARY 2013 (VOL.22, NO.1) page 4 of 6
6 This system requires the storage of the neutralizer sodium thiosulfate on board the ship. The details of the Plankill Pipe will be determined based on land based tests that have yet to be conducted, and the cleaning system to maintain the cleanliness of the Plankill Pipe during operation will be detailed in the operation manual to be supplied for Final Approval. Hamworthy Aquarius The Hamworthy Aquarius EC BWMS, submitted by the Netherlands, uses in-situ electrolysis creating sodium hypochlorite from a side stream of seawater to treat the ballast water. This system removes biota and sediment at the uptake of ballast water using a 40 µm filtration unit (having an automatic back flush function) followed by re-injection of a relatively high concentration of sodium hypochlorite, created by electrolysis of the side stream, into the ballast main. A neutralization unit is installed providing for the injection of the neutralizing agent sodium bisulfite at discharge. Fig.4 - Hamworthy Aquarius OceanDoctor BWMS The OceanDoctor BWMS, submitted by China, uses a combination of filtration with a selfcleaning filter (50 µm) and disinfection with UV irradiation and photo-catalytic oxidation to produce hydroxyl radicals. Low pressure mercury lamps serve as the UV source and during de-ballasting there is no further treatment of the ballast water, with the treated ballast water being discharged directly from the ship. An ultrasonic cleaner is installed in the UV chamber to clean the sleeves of the UV lamps automatically. HS Ballast BWMS The HS Ballast BWMS, submitted by the Republic of Korea, has been developed by Hwaseung R&A Co. Ltd. and uses in-situ electrolysis using seawater to produce hypochlorous acid to treat the ballast water. Hwaseung R&A is currently developing a neutralization module to inject the neutralizing agent sodium thiosulfate into the treated ballast water prior to discharge. The details of the automated neutralization module and the control system together with the details of the storage and handling of the sodium thiosulfate will be completely described in the application for Final Approval. GloEn-Saver BWMS The GloEn-Saver BWMS, submitted by the Republic of Korea, uses a combination of automatic back flushing filtration (50 µm) and insitu electrolysis of a side stream of ballast water uptake to produce a concentrated stream of sodium hypochlorite which is injected and mixed with the main stream of ballast water uptake. The maximum amount of sodium hypochlorite is controlled by using an online sensor installed immediately after the electrolysis unit. During de-ballasting, the neutralizing agent of sodium thiosulfate solution is injected prior to the discharge pump. This injection of sodium thiosulfate solution is automatically controlled by monitoring the de-ballasting flow rate and the residual sodium hypochlorite concentration with TRO sensors. The two TRO sensors are used to measure the residual TRO concentration at two points, before and after the neutralization unit. The electrolysis unit is designed to operate at a seawater salinity of 10 PSU (practical salinity unit) or more with a water temperature of 10 to 33 degrees C. When the BWMS is operated in waters at salinities of PSU the ballast water flow rate is to be significantly lowered. Additional tests of the BWMS for operation in fresh and brackish water will be conducted to determine the actual operating limits of the system and the results of these tests will be submitted with any application for Final Approval. ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE, JANUARY 2013 (VOL.22, NO.1) page 5 of 6
7 MISCELLANEOUS Shipboard Incineration The Committee issued MEPC.1/Circ.795 which clarifies the introduction of waste into incinerators of the continuous-feed type when the combustion chamber gas outlet temperature is below 850 C. Sludge oil, generated during normal operation of a ship, may be introduced into a continuous-feed type incinerator during the warm-up process when the combustion chamber temperature is above 500 C. This is in order to achieve the normal operation combustion chamber temperature of 850 C. The combustion chamber flue gas outlet temperature should reach 850 C within the period of time specified in the manufacturer's operations manual but should not be more than five minutes. Ship Recycling Two Guidelines supporting the Ship Recycling Convention were agreed by the Committee: 2012 Guidelines for the Survey and Certification of Ships (MEPC.222(64)) provide details for initial, renewal, additional and final surveys, all of which check that Part I of the Inventory of Hazardous Materials is properly maintained and updated to reflect changes in ship structure and equipment since the last survey. The final survey also checks that the location and approximate quantities of operationally generated wastes and stores are reflected in Parts II and III of the Inventory of Hazardous Materials Guidelines for the Inspection of Ships (MEPC.223(64)) allows PSC to verify that controls for maintaining the Hazardous Materials are effectively implemented in the event the Certificate or Inventory of Hazardous Materials is missing or not valid. Any inconsistencies in the Inventory versus onboard arrangements do not constitute a detainable deficiency provided it is addressed at the time of the next survey. ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE, JANUARY 2013 (VOL.22, NO.1) page 6 of 6
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