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.
Tuesday, June 1, 2010
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.
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