The test procedures for the 15ppm Bilge Alarm are described in MEPC 49 Test Specifications. Basically, the accuracy of the Bilge Alarm is determined by comparing its readings against a known flow of Test Fluid injected into a known flow of water. The grab samples are analyzed in a laboratory to Standard ISO9377-2:2000, using solvent extraction and gas chromatography for the determination of the hydrocarbon oil index in water.
The methodology is clear and the oil content for the test effluent is known. Therefore, in the approval process, the Bilge Alarm is demonstrated under controlled, predictable and repeatable conditions. To get the Bilge Alarm approved, the instrument needs to correctly display the optical effect created by the known oily water mixture, as the equivalent parts per million of oil content. In other words, the instrument is calibrated for this purpose before the approval test, then shown to read oil content correctly.
As we all know, bilge water aboard a ship, or more accurately the effluent from the Bilge Separator is not the same mixture of oil and water as the one in the approval process. In the approval process the IMO Test Fluid "C" is used, which is a 1kg mixture of water, containing 25g of heavy fuel RMG 35, plus 25g of light fuel DMA , plus 0.5g surfactant and 1.7g of iron oxides. By comparison,the effluent coming out of the Bilge Separator contains typically more than 2 types of oils as it contains heavy fuel, light fuel lube oils as well as other oils; it contains probably more than 0.5g of surfactants as cleaners and detergents are present, from the cleaning of surfaces and as part of modern lube oils as well; solids content of the effluent most likely is quite different too. Then of course there is the color of the bilge water, also different than the test liquid. All this to say that the Bilge Alarm does not compare apples with apples; it is tested with "apples" but then required to read "oranges" aboard a ship.
The Bilge Alarm is approved by IMO for on-line, continuous measuring, using an optical value as a reference for oil content. The measuring system is at best an approximation, rather than a scientific measurement of hydrocarbon content in water. Port State Control procedures confirm that compliant bilge water effluent is determined by a calibrated Bilge Alarm and not a laboratory analysis.
Because the Bilge Alarm is calibrated to a specific oily water mixture, there will be a difference between the actual hydrocarbon content of compliant real life effluent and the test liquid. How big the difference will be is dependent on the complexity of the bilge water the Bilge Separator has to treat.
Wednesday, November 17, 2010
Thursday, October 21, 2010
World Oil Demand in 2011
In the October 2010 Monthly Oil Market Report OPEC provides data on the current global oil situation.
Total world oil demand is projected to grow by 1.05 million barrels per day, or 1.22%. Demand is driven primarily by growth in the developing economies, where demand is expected to grow by 2.05%, whereas demand in the OECD will only grow by 0.13%. Primary drivers for the growth in oil demand are the developing countries, lead by China and India.
What may be of interest to marine is how OPEC sees residual oil shrinking. According to to the forecast, the primary drivers for growth in oil demand are gasoline (+19%), other products (+19%) and gas/diesel oil (+26%), while residual fuel is projected to shrink by 10% in 2011.
What seems evident is that refined product demand growth impacts on residual fuel availability. This trend seems to have started with the oil crisis in the mid 70's and is now accelerating with the tremendous growth in the developing economies. Additional pressure on residual oil comes from slow growth on the oil supply side, which forces refiners to increase yield. In North America, the increased reliance on feedstock from the oil sands, shrinks residual oil supply from local sources.
Declining residual supply suggests deteriorating residual fuel quality, which is diagonally opposite to the tightening fuel quality requirements of IMO. This raises the question, by when will heavy fuel oil no longer meet the required fuel quality standards?
Total world oil demand is projected to grow by 1.05 million barrels per day, or 1.22%. Demand is driven primarily by growth in the developing economies, where demand is expected to grow by 2.05%, whereas demand in the OECD will only grow by 0.13%. Primary drivers for the growth in oil demand are the developing countries, lead by China and India.
What may be of interest to marine is how OPEC sees residual oil shrinking. According to to the forecast, the primary drivers for growth in oil demand are gasoline (+19%), other products (+19%) and gas/diesel oil (+26%), while residual fuel is projected to shrink by 10% in 2011.
What seems evident is that refined product demand growth impacts on residual fuel availability. This trend seems to have started with the oil crisis in the mid 70's and is now accelerating with the tremendous growth in the developing economies. Additional pressure on residual oil comes from slow growth on the oil supply side, which forces refiners to increase yield. In North America, the increased reliance on feedstock from the oil sands, shrinks residual oil supply from local sources.
Declining residual supply suggests deteriorating residual fuel quality, which is diagonally opposite to the tightening fuel quality requirements of IMO. This raises the question, by when will heavy fuel oil no longer meet the required fuel quality standards?
Wednesday, September 22, 2010
What can we learn from the Irika sentencing
The US DoJ posted their news release on the Sentencing of Irika Shipping S.A.
When the MV IORANA arrived in Baltimore in January 2010, crew members alerted the USCG port state control officer of illegal dumping of oil and garbage at sea. Granted, this was a blatant case of willful pollution, which no respectable company will tolerate, however, there are a few points in the press release worth noting, if a company operates into the USA.
From reading some of the USCG publications and comments by lawyers, it seems to me the following 2 things probably played a significant part why the fine for the offence was ultimately $ 4,000,000.
Irika pleaded guilty, by my count, to 8 felony charges, each carrying a maximum penalty of $ 500,000. While lawyers frown upon admitting guilt, it seems to me that cooperation by ship officers can significantly reduce the criminal penalty. My math suggests that the court imposed the maximum $500,000 per felony. Cooperation by the senior officers would have reduced the count by at least 2, or the fine by $ 1,000,000 or more!
What I suggest is that a company who's ships call on US ports, should have in place a vigorously implemented environmental policy and that their ship officers are aware on how to work with USCG officers during a port state control.
When the MV IORANA arrived in Baltimore in January 2010, crew members alerted the USCG port state control officer of illegal dumping of oil and garbage at sea. Granted, this was a blatant case of willful pollution, which no respectable company will tolerate, however, there are a few points in the press release worth noting, if a company operates into the USA.
From reading some of the USCG publications and comments by lawyers, it seems to me the following 2 things probably played a significant part why the fine for the offence was ultimately $ 4,000,000.
- Irika admitted the company had no budget for the vessel and no waste management plan, and crew members received little training regarding the company's environmental policies.
- Irika admitted obstructing justice in a couple of ways, including false statements by ship officers, destroying evidence, etc.
Irika pleaded guilty, by my count, to 8 felony charges, each carrying a maximum penalty of $ 500,000. While lawyers frown upon admitting guilt, it seems to me that cooperation by ship officers can significantly reduce the criminal penalty. My math suggests that the court imposed the maximum $500,000 per felony. Cooperation by the senior officers would have reduced the count by at least 2, or the fine by $ 1,000,000 or more!
What I suggest is that a company who's ships call on US ports, should have in place a vigorously implemented environmental policy and that their ship officers are aware on how to work with USCG officers during a port state control.
Thursday, September 9, 2010
Residual Fuel
As a follow up to last week, in the September issue of OPEC's monthly oil market report, on page 30 they show a pie chart of the projected demand growth for the various refinery products from 2010 to 2011. OPEC predicts a 1,0 million barrel/day increase in oil demand for 2011 and predicts all products to increase - except for residual fuel. OPEC predicts a decline in residual oil by 143,000 barrels/ day for the coming year.
In the previous blog I stated that according to data published by the IEA residual fuel represented 15.1% of global refinery output in 2008. Based on that figure the 143,000 barrel reduction in residual fuel, for the coming year, represents essentially a 1.1% drop in the supply of feed stock for heavy fuel blending. In other words, the quality of the blended fuel will continue to deteriorate and availability of IMO compliant HFO may become an issue, maybe not immediately but probably in the long term.
In the previous blog I stated that according to data published by the IEA residual fuel represented 15.1% of global refinery output in 2008. Based on that figure the 143,000 barrel reduction in residual fuel, for the coming year, represents essentially a 1.1% drop in the supply of feed stock for heavy fuel blending. In other words, the quality of the blended fuel will continue to deteriorate and availability of IMO compliant HFO may become an issue, maybe not immediately but probably in the long term.
Tuesday, August 31, 2010
International Energy Agency
The 2010 Key statistics by the IEA are rather interesting. Oil consumption keeps rising, residual fuel production is declining and we see a shift in the global refining picture. The developing economies of China, Asia and the Middle East are adding refinery capacity aggressively while in the developed world capacity is being consolidated.
In 1973 33.8% of refinery throughput ended up as residual fuel, by 2008 this shrank to 15.1% globally. In Canada refineries produce only about 7% residual oil from their feedstock, in the USA it is lower still. The fact that refiners today produce more light product per barrel of oil, suggests that the quality of the residual fuel is deteriorating.
Regulations are tightening, calling for cleaner stack emissions from ships, on the other hand residual fuel quality is declining. The question then is, how will ship owners comply with these tightening regulations? Will they be able to burn lower quality residual fuels forever with secondary treatment of the exhaust gases, or will they be forced to burn premium-priced light fuel, because marine fuel won't be available anymore; in part due to the increased refinery yield, in part due to the shift in refining to the emerging economies?
Is it possible that tightening oil supply will some day force ship owners to burn distilled product?
In 1973 33.8% of refinery throughput ended up as residual fuel, by 2008 this shrank to 15.1% globally. In Canada refineries produce only about 7% residual oil from their feedstock, in the USA it is lower still. The fact that refiners today produce more light product per barrel of oil, suggests that the quality of the residual fuel is deteriorating.
Regulations are tightening, calling for cleaner stack emissions from ships, on the other hand residual fuel quality is declining. The question then is, how will ship owners comply with these tightening regulations? Will they be able to burn lower quality residual fuels forever with secondary treatment of the exhaust gases, or will they be forced to burn premium-priced light fuel, because marine fuel won't be available anymore; in part due to the increased refinery yield, in part due to the shift in refining to the emerging economies?
Is it possible that tightening oil supply will some day force ship owners to burn distilled product?
Monday, August 23, 2010
Air Toxics from Cement Plants
In the most recent EM magazine by the Air & Waste Management Association, on page 44 there is an article on the threat to the American cement industry by tight EPA air emission standards. According to the Portland Cement Association the stringent standards and need to install expensive controls could force 30 plants to close and it puts another 12 plants "at risk" of being forced out of business.
What the EPA wants to achieve with the tighter emission rules is a reduction in the annual emissions of mercury (by 11,600 tons), hydrocarbons (by 11,700 tons), particulate matter (by 10,500 tons), hydrochloric acid (by 2,800 tons) and sulfur oxides (by 160,000 tons).
The Portland Cement Association did a webinar on this and the power point presentation, as a summary, is posted on the web. What I found interesting is how well the cement plant population aligns with marine transportation arteries (as per slide 4 of the presentation).
To put two of the cement industry's toxins into perspective, considering the coming ECA:
What the EPA wants to achieve with the tighter emission rules is a reduction in the annual emissions of mercury (by 11,600 tons), hydrocarbons (by 11,700 tons), particulate matter (by 10,500 tons), hydrochloric acid (by 2,800 tons) and sulfur oxides (by 160,000 tons).
The Portland Cement Association did a webinar on this and the power point presentation, as a summary, is posted on the web. What I found interesting is how well the cement plant population aligns with marine transportation arteries (as per slide 4 of the presentation).
To put two of the cement industry's toxins into perspective, considering the coming ECA:
- With an ECA in domestic waters, SOx from ships would be cut by less than 40,000 tons, and
- Marine does not contribute to mercury pollution.
Wednesday, August 18, 2010
Horse Power
From time-to-time I wonder about the need for high powered personal vehicles.
A recent write-up on the new Jaguar cars got me thinking whether we needed 510HP in a car to go 280km/h rather than only the pedestrian speed of 240km/hr. Similarly, North American motor journalists tell us we need monster bikes of more then 1000cc to move us.
I think it is understood that oil is a finite source of energy, we will deplete it. The World Business Council for Sustainable Development (WBCSD) in their Vision 2050, suggest that with business as usual we will require every last resource on Earth, and another Earth, and a third more. "That's obviously a huge issue" says Dr. Mohammad Zaidi, executive VP and chief technical officer at ALCOA.
Vision 2050 suggests we better start acting now, changing from the current exploitation model to a sustainable model. Maybe we should look at the horse power issue on our vehicles?
In 2008 Canada generated 734Mt of greenhouse gases; emissions from cars, SUVs and motor cycles accounted for 85.664Mt equal to 11.67% of the total. I wonder how much the emissions from personal vehicles could be reduced by scaling back on engine power in our cars and bikes. My guess is that we'd be just as mobile with less than half the current average engine power. The reason I say this is that in North America we tend to drive European cars with larger engines than are common in Europe.
Vision 2050 suggests we are exceeding now Earth's capacity. If we look for sustainability to 2050 I suggest we heed WBCSD's call for action now; maybe reducing the engine power in our personal transportation is a good start?
A recent write-up on the new Jaguar cars got me thinking whether we needed 510HP in a car to go 280km/h rather than only the pedestrian speed of 240km/hr. Similarly, North American motor journalists tell us we need monster bikes of more then 1000cc to move us.
I think it is understood that oil is a finite source of energy, we will deplete it. The World Business Council for Sustainable Development (WBCSD) in their Vision 2050, suggest that with business as usual we will require every last resource on Earth, and another Earth, and a third more. "That's obviously a huge issue" says Dr. Mohammad Zaidi, executive VP and chief technical officer at ALCOA.
Vision 2050 suggests we better start acting now, changing from the current exploitation model to a sustainable model. Maybe we should look at the horse power issue on our vehicles?
In 2008 Canada generated 734Mt of greenhouse gases; emissions from cars, SUVs and motor cycles accounted for 85.664Mt equal to 11.67% of the total. I wonder how much the emissions from personal vehicles could be reduced by scaling back on engine power in our cars and bikes. My guess is that we'd be just as mobile with less than half the current average engine power. The reason I say this is that in North America we tend to drive European cars with larger engines than are common in Europe.
Vision 2050 suggests we are exceeding now Earth's capacity. If we look for sustainability to 2050 I suggest we heed WBCSD's call for action now; maybe reducing the engine power in our personal transportation is a good start?
Monday, August 9, 2010
How will that pan out?
The Dow Jones News wire gave updates on the vehicle sales in China, India and Russia. China has surpassed the USA as the world's largest car market. For the January to July 2010 period car sales in China grew by 42.8% year-over year! Sales increases in India and Russia on the side of personal use vehicles as well as trucks grow also in double digit percentages. In addition to the car sales there are then the sales of motor cycles and scooters, which are significant in these developing markets. Obviously gasoline and diesel consumption in these emerging markets will increase much faster than in the OECD, and with it there will be a shift in the global oil supply and refining markets.
The OECD is supplied by multinational oil companies within a free market trading principle. On the other hand, most emerging economies are supplied from state run oil companies. I am wondering whether or not this will affect easy access to oil for the OECD refiners.
The OECD is supplied by multinational oil companies within a free market trading principle. On the other hand, most emerging economies are supplied from state run oil companies. I am wondering whether or not this will affect easy access to oil for the OECD refiners.
Monday, August 2, 2010
A recent oil pollution case in the USA
The latest press release from the United States Dept. of Justice on a case of falsifying oil record book entries is interesting for the following reasons:
- The US lays criminal charges based on the "fraudulent statements" to the port state control officer, e.g. presenting an ORB with false entries. - In this case, the company and officers were convicted.
- The severity of the sentence and fines decreases with cooperation and forthcoming statements by the company and crew. - In this case the fine to the company and the sentences handed down (so far) are relatively mild.
- The fate of the C/E will be determined in a separate hearing. - Of interest is the reference to the sentencing guidelines in this paragraph.
- The company agreed to implement an elaborate and detailed environmental compliance plan for the fleet.
Tuesday, July 27, 2010
I recently bought a TDI
I used to drive a car that used about 7 liters of premium gasoline per 100 km. Since I do a lot of driving, I jumped on the opportunity to purchase a Jetta TDI, anticipating lower fuel costs.
Here is my first assessment of my ecological performance, using the conversion figures as per the Canadian GHG summaries.
What I used to do on about 63 liters of premium gasoline I now do on about 45 liters of diesel fuel, I am using about 25% less fuel! By using less fuel and one requiring less energy input in the refining process, the proportional GHG reduction at the refinery level is about 27.5% (using the price difference as indicator of energy requirement).
The GHG emissions (in CO2 equivalents) from my use of the car changes from 7 x 2.45kg/l = 17.15kg/100km (for the premium gasoline powered vehicle) previously to 5 x 2.80kg/l = 14.00kg/100km. My environmental footprint is reduced by about 18%.
SOx (and with it PM) is a wash as both fuels have similar S-content.
All in all, I am satisfied with my GHG reductions so far.
In ecolonomic speak (ecological and economic benefits), there is a pretty good correlation between the 25% financial benefit and the over 18% GHG reduction.
Here is my first assessment of my ecological performance, using the conversion figures as per the Canadian GHG summaries.
What I used to do on about 63 liters of premium gasoline I now do on about 45 liters of diesel fuel, I am using about 25% less fuel! By using less fuel and one requiring less energy input in the refining process, the proportional GHG reduction at the refinery level is about 27.5% (using the price difference as indicator of energy requirement).
The GHG emissions (in CO2 equivalents) from my use of the car changes from 7 x 2.45kg/l = 17.15kg/100km (for the premium gasoline powered vehicle) previously to 5 x 2.80kg/l = 14.00kg/100km. My environmental footprint is reduced by about 18%.
SOx (and with it PM) is a wash as both fuels have similar S-content.
All in all, I am satisfied with my GHG reductions so far.
In ecolonomic speak (ecological and economic benefits), there is a pretty good correlation between the 25% financial benefit and the over 18% GHG reduction.
Monday, July 19, 2010
The Bilge Water Discharge Line
Treated bilge water is considered an oil free effluent under the pollution prevention regulations.Therefore a port state control officer (PSCO) may expect that the O/B discharge line is completely free of oil.
Our experience with shipboard work is that sight glasses, installed in the O/B discharge line, become oil coated with time. Therefore, in a ship that processes a lot of bilge water, the same thing will happen in the discharge piping; traces of oil will become visible in the piping. The more bilge water is processed the more severe the oil accumulation.
Another factor that increases oil accumulation in the discharge line is when a 3-way valve is used to divert non-compliant effluent back to the bilge. Whenever the ppm level of the effluent exceeds the permitted discharge level, the pipe run between bilge separator and discharge shut-down device becomes contaminated.
We suggest therefore annual cleaning of the O/B discharge line, to make sure no oil shows in the line when a flange connection is broken. we suggest including this procedure in your best practices.
Our experience with shipboard work is that sight glasses, installed in the O/B discharge line, become oil coated with time. Therefore, in a ship that processes a lot of bilge water, the same thing will happen in the discharge piping; traces of oil will become visible in the piping. The more bilge water is processed the more severe the oil accumulation.
Another factor that increases oil accumulation in the discharge line is when a 3-way valve is used to divert non-compliant effluent back to the bilge. Whenever the ppm level of the effluent exceeds the permitted discharge level, the pipe run between bilge separator and discharge shut-down device becomes contaminated.
We suggest therefore annual cleaning of the O/B discharge line, to make sure no oil shows in the line when a flange connection is broken. we suggest including this procedure in your best practices.
Monday, July 12, 2010
Bilge Water Management
The United States (USCG and Dept. of Justice) recommend companies have in place a vigorously implemented management plan for bilge water, which should include a budget, adequate shipboard spares and training of the crew. The July 9, 2010 DoJ press release on the plea agreement with Irika Shipping is the first time I see reference made to the above. As stated previously, a vigorously implemented environmental management plan can reduce or prevent criminal charges against the officers and corporation.
Monday, June 28, 2010
Bilge Water Heating
Once in a while the question is asked about the need of heating bilge water for processing. The question is asked, because some makers offer heaters in their bilge separators.
Anyone who cooks pasta knows that it takes quite a while to heat a pot of water on the electric stove. Let me demonstrate on hand the old British system how much heat is required to heat bilge water while processing. By definition 1 British Thermal Unit (BTU) is the energy required to raise the temperature of 1 lb of water by 1 degree Farenheit. Applying this to a small 1 ton/hr bilge separator, the size of the heater can be determined as follows:
To raise the temperature of the 1,000 liters (2,200 lbs) process water by 1 degree Centigrade (1.8 deg.F), we need to apply 1.8 x 2.2 x 1000 = 3,960 BTU/hr; which factors out to a heater capacity of 1.16kW. - To get a meaningful 10 deg C (18 deg F) temperature rise in a 1 ton/hr unit we'd need to install an 11.6kW (15HP) heater, with a 2.5 ton/hr separator a 29kW heater is required!
The other side of the coin in bilge water heating is heat density of the heating element. Oil has roughly half the heat value of water, therefore when heating the oily water mixture the oil will "bake" to the high density heating surface of the element, causing the electric heater to burn out.
All this to say that in my personal opinion, whether the ship is burning HFO or distillate, it is not really possible to heat the bilge water significantly while processing. A heating element in the bilge separator may very well be practical as a freeze protection.
Anyone who cooks pasta knows that it takes quite a while to heat a pot of water on the electric stove. Let me demonstrate on hand the old British system how much heat is required to heat bilge water while processing. By definition 1 British Thermal Unit (BTU) is the energy required to raise the temperature of 1 lb of water by 1 degree Farenheit. Applying this to a small 1 ton/hr bilge separator, the size of the heater can be determined as follows:
To raise the temperature of the 1,000 liters (2,200 lbs) process water by 1 degree Centigrade (1.8 deg.F), we need to apply 1.8 x 2.2 x 1000 = 3,960 BTU/hr; which factors out to a heater capacity of 1.16kW. - To get a meaningful 10 deg C (18 deg F) temperature rise in a 1 ton/hr unit we'd need to install an 11.6kW (15HP) heater, with a 2.5 ton/hr separator a 29kW heater is required!
The other side of the coin in bilge water heating is heat density of the heating element. Oil has roughly half the heat value of water, therefore when heating the oily water mixture the oil will "bake" to the high density heating surface of the element, causing the electric heater to burn out.
All this to say that in my personal opinion, whether the ship is burning HFO or distillate, it is not really possible to heat the bilge water significantly while processing. A heating element in the bilge separator may very well be practical as a freeze protection.
Wednesday, June 23, 2010
Why not LNG?
If I read the IEA's medium-term Oil & Gas Markets 2010 correctly, we are moving towards tighter oil, while we have ample natural gas available from North American sources.
The medium-term looks forward to 2015 only. The oil supply down the road relies on an OPEC capacity increase by 2014 and increased reliance, also from 2014 onward on the Canadian oil sands and biofuels.
Another concern might be the shift of refining capacity; China, Asia and the Mid-East are adding refining capacity of 9 mb/d whereas the OECD cuts capacity by at least 1.4 mb/d by 2015.
With the ECA requirements tightening by 2015 and being fully implemented by 2020 (for which we have no projections), we will rely more on foreign finished product than we do today, especially for marine fuel as domestic refiners will cater to the higher volume land based transport sector. Therefore, it would almost seem logical to consider LNG as THE alternative fuel for marine transport for the medium to the long term; this would reduce GHG and harmful emissions from ships while providing secure, long-term low cost fuel.
The medium-term looks forward to 2015 only. The oil supply down the road relies on an OPEC capacity increase by 2014 and increased reliance, also from 2014 onward on the Canadian oil sands and biofuels.
Another concern might be the shift of refining capacity; China, Asia and the Mid-East are adding refining capacity of 9 mb/d whereas the OECD cuts capacity by at least 1.4 mb/d by 2015.
With the ECA requirements tightening by 2015 and being fully implemented by 2020 (for which we have no projections), we will rely more on foreign finished product than we do today, especially for marine fuel as domestic refiners will cater to the higher volume land based transport sector. Therefore, it would almost seem logical to consider LNG as THE alternative fuel for marine transport for the medium to the long term; this would reduce GHG and harmful emissions from ships while providing secure, long-term low cost fuel.
Tuesday, June 15, 2010
Bilge Water Discharge
The 5-ppm bilge water limit for the Great Lakes (Canadian inland waters) is in essence a 0-ppm limit with the +5ppm deviation permitted in the MARPOL regulations.
Back, when the effluent limit was debated the regulator made a distinction between oily water entering the bilge separator and oil free effluent leaving the bilge separator. It took me a while to understand that the discharge, which satisfies the regulations, is (by rule) an oil free discharge. Therefore, bilge water effluent quality below the alarm point setting is oil free water that can be discharged, effluent exceeding the alarm point setting is an oily water mixture and therefore a pollutant
Like I said, it took me a while to grasp that concept. Looking at it from the practical side, it does make sense to me too. Here is why:
Oil separates from water by gravity. Large oil droplets rise fast, small ones slow. That means the discharge from the bilge separator contains only oil droplets that are too small to be separated and removed from the water. Therefore the discharge water contains only fine oil droplets, evenly dispersed in the effluent stream.
At 15ppm, the international limit, the total oil dispersed represents a volume equal to a 2.5 x 2.5 x 2.5mm oil quantity in one liter of water; 5ppm is a volume of 1.7 x 1.7 x 1.7mm in one liter of water. This oil is not present in a single oil drop , but evenly distributed in tiny oil droplets throughout the water column, in a stable mixture.
How big a threat of pollution is then the compliant bilge water discharge? Is there a chance of visible oil pollution? Compliant bilge water discharges do not pose an environmental threat. Here is how I look at it. The ship needs to be moving to be allowed to discharge. Let's say the ship moves at 2 knots, which is about 3.6km/hr, roughly 1 meter/second. With a 3.5t/hr bilge separator, the ship discharges 3500 liters/hr, roughly 1 liter per second. Therefore, the oil drop I mentioned above, evenly dispersed in the 1 liter of water is discharged over the 1 meter of distance traveled.
Back, when the effluent limit was debated the regulator made a distinction between oily water entering the bilge separator and oil free effluent leaving the bilge separator. It took me a while to understand that the discharge, which satisfies the regulations, is (by rule) an oil free discharge. Therefore, bilge water effluent quality below the alarm point setting is oil free water that can be discharged, effluent exceeding the alarm point setting is an oily water mixture and therefore a pollutant
Like I said, it took me a while to grasp that concept. Looking at it from the practical side, it does make sense to me too. Here is why:
Oil separates from water by gravity. Large oil droplets rise fast, small ones slow. That means the discharge from the bilge separator contains only oil droplets that are too small to be separated and removed from the water. Therefore the discharge water contains only fine oil droplets, evenly dispersed in the effluent stream.
At 15ppm, the international limit, the total oil dispersed represents a volume equal to a 2.5 x 2.5 x 2.5mm oil quantity in one liter of water; 5ppm is a volume of 1.7 x 1.7 x 1.7mm in one liter of water. This oil is not present in a single oil drop , but evenly distributed in tiny oil droplets throughout the water column, in a stable mixture.
How big a threat of pollution is then the compliant bilge water discharge? Is there a chance of visible oil pollution? Compliant bilge water discharges do not pose an environmental threat. Here is how I look at it. The ship needs to be moving to be allowed to discharge. Let's say the ship moves at 2 knots, which is about 3.6km/hr, roughly 1 meter/second. With a 3.5t/hr bilge separator, the ship discharges 3500 liters/hr, roughly 1 liter per second. Therefore, the oil drop I mentioned above, evenly dispersed in the 1 liter of water is discharged over the 1 meter of distance traveled.
Tuesday, June 1, 2010
From Truck to Rail to Ship
It seems to me that the environmental agenda evolves from what is closest to us then moves to the more remote. In the case of diesel engines, it started with truck engines, then progressed to locomotive engines and now marine engines come under scrutiny.
Automotive diesel engines burn very clean fuel today, with S-content of not more than 50ppm, or 0.005% S-content by mass; therefore emit only small amounts of SOx and particulate matter. Regulations now require also the installation of secondary exhaust gas treatment (SCRs) and particulate filters on trucks and cars; to eliminate NOx and PM.
Locomotive engines are somewhat bigger than truck engines and with size some basic mechanical requirements need to be satisfied. The fuel pumps and the diesel injectors are bigger than what we see in trucks, therefore sliding surfaces become bigger and the lubricating oil film the fuel provides becomes more difficult to maintain as the fuel becomes lighter and less viscous. Installation of exhaust gas after treatment on locomotives becomes an issue because of size and suitability for the fuel used. The question is, can locomotives be made as clean as trucks, when it comes to exhaust emissions?
Stepping then up in size again to the large bore marine engines the problem gets bigger. The lubrication provided by the fuel in the injection equipment increases in importance because these components are massive.
What I hear from the experts is that diesel engines up to 250mm bore should operate with a fuel viscosity of at least 1.8cSt at the fuel injection pump, above that bore 2.0cSt or higher is recommended. These viscosity values mean that for the safe operation on a ship fuel temperature needs to be maintained and cooling or chilling of the distillate fuel may become necessary to maintain the lubricating properties of the fuel. As it stands now, it seems that ULS road diesel can not be safely burnt in the large bore marine engines.
Automotive diesel engines burn very clean fuel today, with S-content of not more than 50ppm, or 0.005% S-content by mass; therefore emit only small amounts of SOx and particulate matter. Regulations now require also the installation of secondary exhaust gas treatment (SCRs) and particulate filters on trucks and cars; to eliminate NOx and PM.
Locomotive engines are somewhat bigger than truck engines and with size some basic mechanical requirements need to be satisfied. The fuel pumps and the diesel injectors are bigger than what we see in trucks, therefore sliding surfaces become bigger and the lubricating oil film the fuel provides becomes more difficult to maintain as the fuel becomes lighter and less viscous. Installation of exhaust gas after treatment on locomotives becomes an issue because of size and suitability for the fuel used. The question is, can locomotives be made as clean as trucks, when it comes to exhaust emissions?
Stepping then up in size again to the large bore marine engines the problem gets bigger. The lubrication provided by the fuel in the injection equipment increases in importance because these components are massive.
What I hear from the experts is that diesel engines up to 250mm bore should operate with a fuel viscosity of at least 1.8cSt at the fuel injection pump, above that bore 2.0cSt or higher is recommended. These viscosity values mean that for the safe operation on a ship fuel temperature needs to be maintained and cooling or chilling of the distillate fuel may become necessary to maintain the lubricating properties of the fuel. As it stands now, it seems that ULS road diesel can not be safely burnt in the large bore marine engines.
Tuesday, May 25, 2010
Annex I Violations
Every month or so, the US Department of Justice (DoJ) has a press release on a conviction of or guilty plea by a ship or owner on a MARPOL Annex I (oil pollution) violation.
As I stated previously, the US DoJ uses fraudulent oil record book (ORB) entries to lay criminal charges against the officers of the ship and the company. In the most recent press release DoJ state that the ship did not maintain the Annex I required ORB accurately, at least between 2006 and 2009. Whereas in Canada pollution charges are based on pollution, as detected by satellite, plane or other observation, a ship visiting US ports can be charged for pollution based on the inaccurate ORB entries, regardless of where or when they were made. The criminal act is in the presentation of the fraudulent entries in the ORB to the port state control officer.
If fraudulent ORB entries are found and pollution suspected, there is the fine, potential jail for the officers, the fleet is put on a 3 year probation and the company is required to implement an Environmental Compliance Plan (ECP) with annual audit of 75% of the fleet.
In the old FRAM filter commercial the mechanic said "you can pay me now, or pay me later", meaning that it costs to replace a filter but it costs more to repair the engine. Similarly here; yes, an ECP costs money, but the better housekeeping practices it instills do reduce operating costs. On the other hand, muddling along without an ECP carries the risk of deteriorating shipboard practices which may ultimately result in Annex I violations.
The US DoJ suggests that a vigorously implemented ECP can shield the corporation from criminal charges and the related fines.
As I stated previously, the US DoJ uses fraudulent oil record book (ORB) entries to lay criminal charges against the officers of the ship and the company. In the most recent press release DoJ state that the ship did not maintain the Annex I required ORB accurately, at least between 2006 and 2009. Whereas in Canada pollution charges are based on pollution, as detected by satellite, plane or other observation, a ship visiting US ports can be charged for pollution based on the inaccurate ORB entries, regardless of where or when they were made. The criminal act is in the presentation of the fraudulent entries in the ORB to the port state control officer.
If fraudulent ORB entries are found and pollution suspected, there is the fine, potential jail for the officers, the fleet is put on a 3 year probation and the company is required to implement an Environmental Compliance Plan (ECP) with annual audit of 75% of the fleet.
In the old FRAM filter commercial the mechanic said "you can pay me now, or pay me later", meaning that it costs to replace a filter but it costs more to repair the engine. Similarly here; yes, an ECP costs money, but the better housekeeping practices it instills do reduce operating costs. On the other hand, muddling along without an ECP carries the risk of deteriorating shipboard practices which may ultimately result in Annex I violations.
The US DoJ suggests that a vigorously implemented ECP can shield the corporation from criminal charges and the related fines.
Tuesday, May 11, 2010
Canada's ECA Limits
The North American ECA will come into force in 2012. This designation will apply to the Canadian economic exclusion zone, south of the Arctic Waters. The IMO designation will apply therefore to the external waters and the internal waters of Canada. The Canadian inland waters are not included part of the IMO designation. Canada has yet to decide on how the ECA will apply on the inland waters, particularly how non-convention ships will be regulated on the Great Lakes and the St. Lawrence River.
One question needing clarification is, where is the border line for the inland waters? In the oil pollution regulations Canadian inland waters start at the western tip of Anticosti Island. In the old sewage regulations, IMO compliant marine sanitation devices could be used in the waters east of the first Lock of the Seaway, i.e. into the Port of Montreal. I would expect that Canada uses the oil pollution regulation limit, i.e. the western tip of Anticosti Island, for the designation of the internal waters under the ECA.
For the Canadian inland waters, Canada asked for comments by May 31, 2010 from the shipping industry. Transport Canada has on the table 3 options on how to implement an ECA in the inland waters
Here is the conundrum for the domestic fleet. In the ECA zone all vessels are required to burn ECA compliant fuel. MARPOL Annex VI does not allow for vessel or fleet averaging of the sulfur content, the fuel burnt must meet the ECA prescribed S-limit. Therefore, a domestic vessel sailing to a port outside the inland waters of Canada will need to burn fuel with less than 1.00% S-content with the introduction of the ECA, then starting 2015 they will have to burn fuel with not more than 0.10%.
This means, that after 2012, any domestic, non-convention vessel needs to comply with the ECA fuel requirements on domestic voyages, which extend beyond the inland water limit - unless Canada waves the ECA requirements for the domestic fleet.
One question needing clarification is, where is the border line for the inland waters? In the oil pollution regulations Canadian inland waters start at the western tip of Anticosti Island. In the old sewage regulations, IMO compliant marine sanitation devices could be used in the waters east of the first Lock of the Seaway, i.e. into the Port of Montreal. I would expect that Canada uses the oil pollution regulation limit, i.e. the western tip of Anticosti Island, for the designation of the internal waters under the ECA.
For the Canadian inland waters, Canada asked for comments by May 31, 2010 from the shipping industry. Transport Canada has on the table 3 options on how to implement an ECA in the inland waters
Here is the conundrum for the domestic fleet. In the ECA zone all vessels are required to burn ECA compliant fuel. MARPOL Annex VI does not allow for vessel or fleet averaging of the sulfur content, the fuel burnt must meet the ECA prescribed S-limit. Therefore, a domestic vessel sailing to a port outside the inland waters of Canada will need to burn fuel with less than 1.00% S-content with the introduction of the ECA, then starting 2015 they will have to burn fuel with not more than 0.10%.
This means, that after 2012, any domestic, non-convention vessel needs to comply with the ECA fuel requirements on domestic voyages, which extend beyond the inland water limit - unless Canada waves the ECA requirements for the domestic fleet.
Monday, May 3, 2010
The Ballast Water Countdown
IMO, with BWM.1/Circ.15, as updated on their WebSite today, advised that Brazil had ratified the International Convention for the Control and Management of Ships' Ballast water and Sediments, 2004. With this signature there are now 24 Contracting States to the Convention, representing approx. 23.29% of the gross tonnage of the world's merchant shipping.
The convention will enter into force 12 months after the date on which at least 30 states, representing 35% of the world's gross tonnage have signed on. It seems the convention will come into force, pretty well as was indicated at the last CMAC meeting.
Canadian shipowners might want to consider the possibility, that Ballast Water regulations might apply to domestic shipping, eventually as well; as was suggested at the CMAC meeting.
The convention will enter into force 12 months after the date on which at least 30 states, representing 35% of the world's gross tonnage have signed on. It seems the convention will come into force, pretty well as was indicated at the last CMAC meeting.
Canadian shipowners might want to consider the possibility, that Ballast Water regulations might apply to domestic shipping, eventually as well; as was suggested at the CMAC meeting.
Wednesday, April 21, 2010
Low sulfur fuel
The European Union (EU) directive 2005/33/EC, which came into force January 2010, requires ships to burn fuel with better than 0.1% sulfur by mass, at berth in EU ports.
This requirement does not distinguish between steam ships or motor ships. To comply with this requirement Shell undertook a study on the impact of low sulfur (LS) marine gas oil (MGO) in marine boilers for their LNG carriers. The writeup on this study was published in Marine Engineers Review (MER) March 2010.
This article should be of interest to Canadian and US regulators, as well as the Great Lakes fleet operators, in their discussions on the implementation of an environmental control area (ECA) for the Great Lakes.
Shell found that LSMGO can be burnt in marine boilers, but it requires some system changes. Traditionally boilers are fired by heavy fuel oil (HFO) which must be heated, on the other hand LSMGO must be cold to avoid gassing in the supply line. Compared to HFO, LSMGO has a 6% higher calorific value, poorer lubrication characteristics and a 10% shorter flame length, etc. In closing the article states that their "study of the use of LSMGO in main and auxiliary engines resulted in a proposal for modification of vessel equipment and operations to enable the safe and robust changeover to LSMGO fuel". Stating that the low viscosity and lubrication characteristics are a concern for some rotating equipment in marine engines.
What the article suggests is that the exemption of US flagged steamers from LS fuel requirements and the economic hardship exemptions for motor ships, as contemplated by the US regulator is based on economics and disregards the reason why the USA and Canada petitioned IMO for the ECA designation.
This requirement does not distinguish between steam ships or motor ships. To comply with this requirement Shell undertook a study on the impact of low sulfur (LS) marine gas oil (MGO) in marine boilers for their LNG carriers. The writeup on this study was published in Marine Engineers Review (MER) March 2010.
This article should be of interest to Canadian and US regulators, as well as the Great Lakes fleet operators, in their discussions on the implementation of an environmental control area (ECA) for the Great Lakes.
Shell found that LSMGO can be burnt in marine boilers, but it requires some system changes. Traditionally boilers are fired by heavy fuel oil (HFO) which must be heated, on the other hand LSMGO must be cold to avoid gassing in the supply line. Compared to HFO, LSMGO has a 6% higher calorific value, poorer lubrication characteristics and a 10% shorter flame length, etc. In closing the article states that their "study of the use of LSMGO in main and auxiliary engines resulted in a proposal for modification of vessel equipment and operations to enable the safe and robust changeover to LSMGO fuel". Stating that the low viscosity and lubrication characteristics are a concern for some rotating equipment in marine engines.
What the article suggests is that the exemption of US flagged steamers from LS fuel requirements and the economic hardship exemptions for motor ships, as contemplated by the US regulator is based on economics and disregards the reason why the USA and Canada petitioned IMO for the ECA designation.
Tuesday, April 13, 2010
The Oil Record Book
I like the language of the Department of Justice of the United States of America, it makes it clear what to avoid.
In a recent press release they state that "a federal grand jury has indicted two European shipping corporations this week for environmental crimes in the Eastern District of Texas". The two companies have been indicted and charged with "conspiring to violate environmental laws"...
The allegations are that crew members of the ship "failed to maintain an Oil Record Book as required by federal law" from March 2008 through August 2009.
As I said before, the United States will prosecute the crew and the company when an ORB with fraudulent entries is presented to their port state control officer. The criminal act is presenting the ORB with the fraudulent entries, not pollution itself.
In a recent press release they state that "a federal grand jury has indicted two European shipping corporations this week for environmental crimes in the Eastern District of Texas". The two companies have been indicted and charged with "conspiring to violate environmental laws"...
The allegations are that crew members of the ship "failed to maintain an Oil Record Book as required by federal law" from March 2008 through August 2009.
As I said before, the United States will prosecute the crew and the company when an ORB with fraudulent entries is presented to their port state control officer. The criminal act is presenting the ORB with the fraudulent entries, not pollution itself.
Monday, February 1, 2010
GHG Emissions from Ships
There is considerable activity on the IMO-DOCS Website on coming regulations for greenhouse gas (GHG) emissions from shipping.
IMO is looking at market-based measures to address GHG emissions from shipping for ships above 400 tons.
With a Maritime Emissions Trading System (METS) in place, GHG emissions could be calculated based on the bunker delivery notes. To accurately capture GHG costs for the company, emissions would need to be auctioned on a regular basis. e.g. for monthly reporting of GHG emissions, weekly carbon auctions would be required.
It seems pretty clear that something on GHG emissions will be implemented. Whatever the future IMO requirements will be, there will be more recording and reporting and verification requirements. With it the workload of the company will increase, as will the risk for the owners and crews, if we use the US's approach to port state control issues.
IMO is looking at market-based measures to address GHG emissions from shipping for ships above 400 tons.
With a Maritime Emissions Trading System (METS) in place, GHG emissions could be calculated based on the bunker delivery notes. To accurately capture GHG costs for the company, emissions would need to be auctioned on a regular basis. e.g. for monthly reporting of GHG emissions, weekly carbon auctions would be required.
It seems pretty clear that something on GHG emissions will be implemented. Whatever the future IMO requirements will be, there will be more recording and reporting and verification requirements. With it the workload of the company will increase, as will the risk for the owners and crews, if we use the US's approach to port state control issues.
Wednesday, January 20, 2010
Greenhouse Gas Emissions
IMO's Marine Environment Protection Committee (MEPC) is discussing greenhouse gas emissions from international maritime transport.
The International Chamber of Shipping has been working on criteria for assessing market-based instruments (MBIs) for some time. This document presents some of the criteria that should be used in the analysis of MBIs and proposes some building blocks for a system that appears to meet the various requirements of the different industry sectors.
ICS states that they promote the following criteria for the debate on MBIs:
The International Chamber of Shipping has been working on criteria for assessing market-based instruments (MBIs) for some time. This document presents some of the criteria that should be used in the analysis of MBIs and proposes some building blocks for a system that appears to meet the various requirements of the different industry sectors.
ICS states that they promote the following criteria for the debate on MBIs:
- that any solution should result in a real reduction of the global CO2 inventory;
- that any solution considered for shipping must accommodate and reflect the global nature of the shipping industry and its direct relationship with world trade; and
- that the position of shipping as the most efficient transport mode must be enhanced.
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