International Regulation News Update: Marine Environment Protection Committee's 63 Session

MEPC 63 Session (27 February to 2 March 2012)
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International Regulation News Update

http://www.eagle.org/eagleExternalPortalWEB / Resources / Regulatory Information
Marine Environment Protection Committees 63rd Session

(27 February to 2 March 2012)
Regulatory Development MARPOL VI AIR POLLUTION PREVENTION (pages 1- 3)
Ship Energy Efficiency Design Index - EEDI EEDI for Existing ships Guidelines on Survey & Certification of EEDI SEEMP Guidelines MBM Measures NOx Code Revision VOC Control Ship Application All Ships
MISCELLANEOUS (pages 3- 4)
MARPOL Annex V (Garbage) Ship Recycling Regional Ship Reception Facilities Oily Water Bilge Systems
All Ships
BALLAST WATER MANAGEMENT (pages 4- 10)

BWM Compliance BWM Certification Current BW System Approval Status Final Approval Granted Basic Approvals Granted
All Ships
( All Ships includes all marine craft including barges, drill rigs, submersibles, and floating platforms)
ABS REGULATORY AFFAIRS: INTERNATIONAL REGULATION NEWS UPDATE ,
MAY 2012
(VOL 21, NO.1)
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The 63rd session of the Marine Environment Protection Committee met in London from 27 February to 2 March 2012. Requirements for ship energy efficiency continue to be the focus of deliberations. Additionally, several new ballast water treatment systems were approved as discussed below.
MARPOL VI AIR POLLUTION PREVENTION Ship Energy Efficiency Design Index - EEDI In preparation for the new Chapter 4 to MARPOL Annex VI which, upon entry into force on 1 January 2013, will require all new ships 400 gt to be provided with an Attained EEDI, the Committee revised MEPC.1/Circ.681 which contains interim guidelines on the method of calculation of the Attained EEDI for new ships. These revisions are the 2012 Guidelines on the method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships and are contained in resolution MEPC.212(63). The primary revisions are highlighted below: 70% deadweight (65% was previously specified) is used as capacity to harmonize service speed, deadweight and power of containerships a capacity correction factor is applied to the attained EEDI bulk carriers and oil tankers built to the Common Structural Rules (CSR) of classification societies to account for increased lightship weight and the corresponding reduction in deadweight capacity a correction factor (proportional to the ratio of the minimum design dwt and the enhanced design dwt) is applied shipspecific structural enhancements to account for increased lightship, for example, due to increased longitudinal strength, structural class notations, bow slamming reinforcement and collision strength correction factors for power and capacity were adjusted for iceclassed ships to take into account new data with the recognition that the corrections for large iceclassed tankers would be revisited during the future review process as allowed for under the new Chapter 4.
a cubic correction factor (dwt/cubic cargo capacity) is applied to the Attained EEDI for chemical carriers to take into account the increased lightship due to the greater number of cargo tanks and increased scantlings of those tanks to carry the higher density cargoes relative to oil tankers, both of which need to comply with the same Required EEDI a cubic correction factor (dwt/cubic cargo capacity) is applied to the Attained EEDI for LNG carriers having direct diesel driven propulsion system to take into account the specific design features (wide beam and shallow draft) which maximizes cubic capacity for high volume light cargoes and for access to remote and draft restricted ports. as an option to applying the weather factor of 1.0 to all ships, EEDI can be determined by conducting the shipspecific simulation of its performance at representative sea conditions in which case attained EEDIweather is assigned to the ship EEDI for Existing ships Based on a submission from INTERCARGO, the Committee unanimously agreed that the EEDI, as specified in MARPOL VI/Chapter 4, is not to be applied to existing ships. The decision took into account that applying EEDI to existing ships could result in a large portion of the existing global fleet being penalised as not meeting the Required EEDI as existing ships were not designed to comply with this design index. Also, the disparity in available information that is needed to properly calculate and verify EEDI parameters would present challenges in applying EEDI to existing ships. Despite some recommendations that energy efficiency design based Market Based Measures (MBM) should not be submitted to the agreed MBM impact assessment study, others considered that there should be some means to compare the energy efficiency of existing ships. Accordingly, it was agreed that MBM proposals which are dependent on EEDI should be revised based on MEPC 63 agreement on the application of EEDI to existing ships.
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For further information, contact ABS Regulatory Affairs at tel 212-292-8806 | email: gshark@eagle.org
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Guidelines on Survey & Certification of EEDI The Committee adopted guidelines for the survey and certification of the Attained EEDI. The process is conducted in two stages: Preliminary verification is carried out at the design stage which should include model tests for determining the ships power curves. This leads to the development of an EEDI Technical File (which contains the details of the parameters used to calculate the Attained EEDI). Details are provided as to the determination of the parameters in the Technical File; and Final verification of the EEDI Technical File is carried out at the sea trials consistent with the parameters used in the method of calculation of the Attained EEDI. Specifications for sea conditions, ship speed and shaft power and RPM of the main engine are provided. SEEMP Guidelines The Committee adopted resolution MEPC.213(63) which contains revisions of the Guidelines for Ships Energy Efficiency Management Plan (SEEMP) as contained in MEPC.1/Circ.684 in three areas. The SEEMP: should recognize that the trade a ship is engaged in may determine the feasibility of the efficiency measures under consideration. The methods of improving energy efficiency for ships such as pipe laying, seismic survey, OSVs and dredgers may be very different when compared to conventional cargo carriers; should recognize that when a ship diverts from its scheduled passage to engage in search and rescue operations, data obtained during such operations need not be used in ship energy efficiency monitoring; and no longer acknowledges that shipowners and operators may make public the results of the actions they have taken which have impacted ship efficiency. In response to a proposal by IACS and ICS, the Committee confirmed that, for existing ships, the SEEMP is to be onboard at the first intermediate or renewal survey, as required by the IAPP Certificate, that is carried out on or after 1 January 2013.
It was further confirmed that in the event the SEEMP is not found on board at that initial survey, the validity of the IAPP Certificate is not impacted by the lack of a SEEMP since it is a survey item solely under the International Energy Efficiency Certificate. Market Based Measures - MBM Opening remarks by the Secretary General once again underscored the need for IMO to take a leading role in addressing emissions from international shipping. With that background, the Committee agreed to carry out a comprehensive impact assessment and feasibility study of MBM options on economic development and growth in developing countries. The assessment would include the previous ten proposals which target GHG reductions through in-sector emission reductions from shipping and out-of-sector emissions reductions. Funds generated by such measures are intended to be used for GHG mitigation activities in other sectors. Under the impact assessment, an appointed Steering Committee would commission consultants to undertake the study at an estimated cost of USD $500K to USD $700K. Consultants with appropriate multi-discipline expertise and experience would gather trade and other data and develop computer models. Draft terms of reference for the assessment aim to assess possible socio-economic impacts, both positive and negative, on developing countries, least developed countries, smallisland developing States and remotely located developing countries with large trading distances. In particular, the impact of MBM in international shipping on consumers and industries in such States will be the center of focus. Any possible unintended environmental impact, positive or negative is also to be assessed. Although there was no consensus as to the possible uses for revenues generated by an MBM for international shipping, it did take note of the following possibilities identified by IMOs GHG-WG 3 which will be further considered at MEPC 64 in November 2012: provide incentives to shipping to achieve improved energy efficiency;
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offset purchase of approved emission reduction credits; provide rebates to developing countries; finance adaptation and mitigation activities in developing countries; finance improvement of maritime transport infrastructure in developing countries; support R&D to improve energy efficiency of international shipping; support IMOs Integrated Technical Cooperation Program NOx Code Revision The Committee adopted resolution MEPC.217(63) which contains revisions to the NOx Technical Code which, on entry into force on 1 August 2013, allow for an alternative approach (Scheme B) to be used to certify engines fitted with selective catalytic reduction (SCR) units. Scheme B allows certification of engines, which cannot be precertified either on a test bed or on board under the NOx Codes standard requirements, by allowing for analytic modeling to estimate the effect that the proposed SCR design and arrangement will have on the NOx emissions from the engine to which it is to be fitted. This modeling is to be validated by testing that can be undertaken using a scaled bench top mockup operating on synthetic exhaust gas. The entire Engine Group (engines that require minor onboard adjustments and modifications) would not be approved until the NOx reduction efficiency, relative to the Parent Engine NOx Technical File, has been demonstrated with the SCR installed onboard. VOC Control In accordance with the provisions of MARPOL Annex VI, Governments are obligated to report on ports or terminals under their jurisdiction at which volatile organic compounds (VOCs) emissions from tankers are regulated. As such, tankers loading at these ports and terminals are to be provided with a vapour collection system approved by the flag Administration which is to be used during loading. The Committee issued MEPC.1/Circ.744 which contains a listing of those terminals, and their tanker size limits, located in The Netherlands and in the Republic of Korea.
MISCELLANEOUS MARPOL Annex V (Garbage) Guidelines for the Implementation of MARPOL Annex V were approved by the Committee as contained in resolution MEPC.220(63). Revision to Annex V will enter into force on 1 January 2013 as per resolution MEPC.201(62). The more significant amendments of Annex V prohibit the discharge of: cargo hold cleaning agents and additives classified as being harmful to the marine environment contained in hold wash water is now prohibited. incinerator ash (which had previously been allowed to be discharged outside of Special Areas 12 nautical miles or more from the nearest land) regardless of the area of operation. The Committee invited Delegates to submit proposals for guidance on the self-classification of cargo residues, cleaning agents and additives harmful to the marine environment by the shippers using MARPOL Annex V criteria until 1 January 2015, after which full implementation is required. Guidelines for the Development of Garbage Management Plans (GMP) were also approved as contained in resolution MEPC.220(62). Every ship 100gt, every ship certified to carry 15 persons and fixed or floating platforms are required to carry a GMP. Ship Recycling The Committee adopted two sets of guidelines that pertain to ship recycling facilities: 2012 Guidelines for Safe and Environmentally Sound Ship Recycling" as contained in resolution MEPC.210(63). These Guidelines address the responsibilities of the Ship Recycling Facility through the Ship Recycling Facility Plan including worker safety and training, protection of human health and the environment, roles and responsibilities of personnel, emergency preparedness and response and systems for monitoring, reporting and record-keeping.
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2012 Guidelines for the Authorization of Ship Recycling Facilities" as contained in resolution MEPC.211(63). These Guidelines recommend a scheme for the Governments Competent Authority to authorize Ship Recycling Facilities. The scheme includes verification of necessary documentation; site inspection and monitoing; audit scheme and specific procedural action relating to issuing, amending, suspending, withdrawing and renewing the Document of Authorization to conduct Ship Recycling (DASR). The Committee endorsed the proposal, which will be included in Survey and Certification Guidelines which are under development, that accepts that a Statement of Compliance on Inventory of Hazardous Material for existing ships will be considered as complying with the requirements of the Convention for an interim period up to the Convention's entry into force, after which the Administration may issue the IHM Certificate on the basis of the IHM SOC. Regional Ship Reception Facilities The Committee adopted amendments to MARPOL Annexes I, II, IV and V to allow Small Island Developing States to develop regional arrangements for port reception facilities, both inside and outside of special areas. Such arrangements may be achieved through regional arrangements based on guidelines approved by the Committee where, because of such States' unique circumstances, regional arrangements are the only practical means to satisfy MARPOLs requirements. A unique arrangement as agreed under MARPOL Annex II for the discharge requirements of prewash residues in chemical carriers. The revision now allows the discharge of prewash residues to be made to a Regional Ship Waste Reception Centre specified in the applicable Regional Reception Facility Plan as an option to the port of unloading. BALLAST WATER MANAGEMENT BWM Compliance The current ratification status of the BWM Convention is 33 Governments representing 26.46 % of the world's merchant fleet tonnage.
The Convention enters into force when 30 Governments representing 35% of the world's merchant fleet tonnage ratify the Convention. Governments remain reluctant to ratify the Convention due a lack of approved Sampling and Analysis Protocols which will be used by PSC control to enforce compliance BWM Certification A submission by IACS and several other industry organizations raised a concern to the Committee in that the BWM Convention allows no phase-in period for ships constructed prior to the entry into force of the Convention. As such, the entire international fleet 400 gt will need to be certified to have onboard and approved ballast water management plan. After considering the above concern, the Committee agreed that BWM Certificates may be issued prior to entry into force provided they are endorsed to state validity begins from entry into force date. Additionally, such certificates may also be issued without an approved BWMP on board provided the certificate has attached to it a statement issued to the Company indicating the date when the BWM Plan was received for review. In such a case, the BWM Certificate is valid for three months beyond the date the BWM Plan was received. Current BW System Approval Status Pages 8 and 9 of this Update provide a current status of the Basic, Final and Type Approvals provided to BW Treatment Systems. Final BW System Approvals Final Approvals were granted by the Committee to the following systems. SiCURE BWM System is a system, developed by Siemens Water Technologies, employs a two-stage treatment process that utilizes technology which currently controls biological fouling and corrosion where seawater is used as cooling or process water. Filtration of zooplankton and some larger phytoplankton is initially carried out by a 40 micron filter followed by oxidizing/disinfecting aquatic invasive species using sodium hypochlorite (a chlorine compound) that is produced electrochemically using a stand-alone electrochemical generator.
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This compound is, however, used in minimum required dosages commensurate with the quality of the ballast water being treated. A de-chlorination module needs to be installed for vessels with voyage times less than 5 days as this is the minimum time it takes for the chlorine compound to decay. For ships that occasionally operate in fresh or brackish water a minimum water salinity of 14 g/L chloride is maintained before entering the electrolyzer unit by introducing water with sufficient salinity that is stored in a dedicated ballast tank.
Figure 1 SiCURETM BW Treatment System A typical footprint of the skid-mount system requires about 4.2 m2 to treat up to 1000 m3/h, but this will vary depending on the horizontal and vertical arrangement of the filter. Tests carried out show the annual corrosion rates to be between 0.1 to 1.2 mm/year which is line with that reported for untreated seawater ballast water tanks by The Tanker Structure Cooperative Forum. Two epoxy-based ballast water tank coatings, after six months of exposure, showed no degree of blistering, no defects under 10-fold magnification and no cracking, flaking or de-lamination. ERMA FIRST BWM System - is a modular treatment system with a nominal treatment capacity of 100 m3/hr/module. Treatment occurs in two stages. Initially, ballast water passes through a 500 m self-cleaning filter prior to a cyclonic separator removing material 20 m in size. Then, electrolysis of the ballast water producing in situ of up to 10 mg/L of free active chlorine which flows into the ballast tanks so that the residual oxidants disinfect any harmful organisms taken onboard.
Performance tests carried out during the development of the system have shown that the biological efficacy required by the D-2 standard of the Convention can be achieved in less than 24 hours. During de-ballasting, total residual oxidants are neutralized. A second free chlorine sensor of the de-ballasting system monitors total chlorine level to a maximum concentration in the discharged water of 0.1 mg/L. Corrosion rates of bare steel are increased by the presence of hypochlorite at the biologically effective dose rates under constant exposure conditions. However, the amount of corrosion increase is not considered significant over the life of a ship due to the relatively small amount of time that elevated hypochlorite concentrations would be present. While tests were also conducted using the ASTM standard D 1654 92 for coated specimens to investigate and rate the damage arising from exposure to two levels of hypochlorite exposure, no quantifiable analysis is possible with respect to life expectancy from laboratory testing as this can only be statistically verified in the highly aggressive environments far exceeding the total residual concentrations associated with this system.
Figure 2 ERMA 6 m3/h model system 3 At 100 m /hr treatment, hydrogen gas, produced during treatment, has a concentration less than 0.1 ppm, considerably lower low than the hydrogen lower explosive limit. Monitoring of hydrogen gas generation was performed during shipboard testing as well as during the landbased testing of the system.
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During shipboard testing for hydrogen measurement, the electrolytic cells operated at the maximum current (200 Amps) and at the nominal flow rate (100 m3/h) for each module of the 500 m3/h treatment system. In all measurements, hydrogen gas was not detected. In response to IMOs request, a 6-month laboratory study to evaluate the potential corrosion impact of treated ballast water has been initiated. MICROFADETM BWM System - previously received IMOs Basic Approval as The Kuraray BWMS, this system consists of filtration and disinfection processes. Automated filtration is performed to allow for long-term clog-free operation. Disinfection is achieved by infusing calcium hypochlorite into the ballast water automatically for the measured flow rate so as to maintain 2 mg/L of free active chlorine.
has a number of filtration compartments with mesh sizes of 30 m ~ 50 m. Organisms which are not removed by the filters are squeezed through the filters and, as such, are damaged and more vulnerable to treatment by the electrolyzer unit which is installed directly in the main of ballast pipe. Sodium hypochlorite is the main disinfectant and is generated by reaction to chlorine produced from anode and sodium hydroxide produced from cathode during the electrolysis process. The total residual oxidant concentration of the treated water is monitored automatically for controlling the power supply in order to regulate the production of chlorine and, in turn, the total residual oxidant concentration. During voyage, the disinfectants inhibit re-growth of harmful aquatic organisms and protect the ballast water from possible pollutants. A neutralizing agent (sodium thiosulfate) is automatically injected to keep the concentration of total residual oxidant in the de-ballasted water below 0.2 mg/L. Longterm (> 6 months) corrosion tests were performed and no significant differences between treated ballast water and natural seawater for six months.
Figure 3 MICROFADE BWM System Although there is no holding time after treatment, treated ballast water is monitored before discharge to ensure that the residual free active chlorine concentration does not exceed 0.2 mg/L. If such levels were found, sodium sulfite is automatically infused into the deballast line. Handling of calcium hypochlorite requires goggle-type protective glasses, a dust respirator, and protective gloves made of rubber in addition to protective clothing. Calcium hypochlorite needs to be stored to avoid direct sunlight and temperatures exceeding 35oC. Exposure test results revealed that the corrosion effect of treated water on the hull showed little significant difference in comparison with that of non-treated control water. AquaStarTM BWM System is composed of a Smart Pipe unit, an electrolyzer unit, a neutralization unit and a system control unit. Water first enters into the Smart Pipe unit which
TM
Figure 4 AquaStarTM BWM System Neo-PurimarTM BWM System treats ballast water taken as it is taken onboard through 50 m filters which removes particles, sediments and organisms. This filtration allows disinfection with minimum amounts of sodium hypochlorite, a chlorine compound, which is generated by electrolysis unit using one percent of the incoming ballast water.
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Sodium hypochlorite is injected into the filtered influent ballast water to effectively disinfect the organisms and bacteria remaining in the filtrate. Discharged ballast water is neutralized by sodium thiosulfate solution). Hydrogen gas, a by-product of the electrochemical process, is separated immediately upon exiting from the electrolytic cell by cyclone separation and is not allowed to enter into the ballast water piping. The gas is transmitted to a de-gasing tank which dilute the gas to 1% (well below the 4% Lower Explosive Limit) before exhausting to atmosphere. Corrosion test are underway for uncoated and marine epoxy coated steel complying with the IMO Performance Standard for Protective Coatings. The system has been full-scale tested with a capacity of 250 m3/hr using a test barge Basic BW System Approvals Basic Approvals were granted by the Committee to the following systems. Smart Ballast BWM System - consists of Plankill pipe, electrolyzer, neutralizer and a system control unit. Treatment starts with ballast water flowing through the Plankill pipeTM which physically damages the organisms by collision and turbulence thereby enabling a more efficient electro-chemical disinfection by the electrolyzer unit. This unit produces and controls the sodium hypochlorite, measured collectively as Total Residual Oxidant (TRO), which renders the organisms harmless. During de-ballasting, the neutralizer unit, using sodium thiosulfate, removes or reduces the remaining TRO of the treated water to levels similar to natural seawater concentration, using a controlled volume pump. The TRO concentration is continuously controlled by the feedback signal of TRO sensor during de-ballasting. After the electrolyzer unit, a ventilation system (degas tank) is installed to remove hydrogen gas and chlorine gas produced during the electrolysis process. Land-based corrosion testing is scheduled for a six month period in accordance with the IMO Performance Standard for Protective Coating.
Results will be included with the Final Approval application. DMU OH BWM System - uses a self-cleaning filtration unit to initially remove any particles or organisms larger than 50 m in size after which it passes through the Active Substances Producing (ASP) unit. The ASP unit automatically generates and controls the Active Substances that break down the cell membrane of marine aquatic organism and pathogen. Based on a series of biological tests, a retention time of 48 hours is considered adequate to meet the BWM Convention D-2 standard. From the preliminary results of the 6month testing still underway, no increased corrosion was found on the specimens in the treated water. The only chemical substance, sodium thiosulfate used as a neutralizer, needs to be kept in a tightly closed container, and stored in a cool, dry, and well-ventilated area, away from incompatible substances and foodstuff containers. Crew should wear chemical splash goggles and protective gloves when handling sodium thiosulfate EcoGuardianTM BWM System - consists of automatic backflushing 50 m filter, an electrochlorination unit which generates hypochlorite is applied as a disinfectant and a neutralization unit which adds sodium thiosulfate solution into the treated ballast water during deballasting to neutralize the total residual oxidant, TRO. For operation in the low salinity water, the electrochlorination unit needs to use onboard ballast water (less than 5% of ballast water flow to be treated) in order to generate hypochlorite. Hydrogen gas, produced during treatment, is separated by a hydrogen separator and then diluted to less than 1% of atmospheric concentration of hydrogen by forced air blowing which is in line with the fourfold safety of explosion limit of the 4% lower explosive limit (LEL) for hydrogen. Finally, this diluted hydrogen gas is vented to the outside of a ship. Corrosion testing has been scheduled to be carried out for 6 months.
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International Regulation News Update: Marine Environment Protection Committee's 63 Session

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International Regulation News Update: Marine Environment Protection Committee's 63 Session

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MEPC 63 Session (27 February to 2 March 2012)