Oil Spill Equipment Regulations

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The predominant regulatory requirements for oil spill equipment originate from MARPOL of

the IMO and the US government’s Oil Pollution Act (OPA) 1990.

In particular jurisdictions other local regulations may also apply.  It is important to know and

be prepared for these

before

sailing to that jurisdiction.

IMO & MARPOL

•  MARPOL Annex 1, Regulation 37 (formerly regulation 26) requires all oil tankers of

150gt and above and all other vessels of 400gt and above to carry on board a

Shipboard

Oil Pollution Emergency Plan

or SOPEP.

•  This plan must include onboard emergency equipment (sorbents) and training for marine

personnel on an IMO recognised pollution course.

•  Marpol does not specify a particular list of oil spill equipment that must be onboard but

sets standards for sorbents in A535/13.  Unitor sorbents meet this requirement.

United states Oil Pollution Act 1990

1.  Tankers of 400ft (122m) or more which enter US waters and that are carrying more

than 10,000 barrels (1590m

) of oil must have equipment able to handle at least a 12

3

barrel (1900 litre) on-deck spill.  They must also have an oil pollution emergency plan.

(33 CFR §155.205)

2.  Tankers less than 400ft (122m) that are carrying oil in bulk must have equipment able

to handle a spill on deck of at 7 barrels (1100 litres) spill.  (33 CFR §155.210)

3.  Inland oil barges must be equipped to deal with a spill of at least 1 barrel (159 litres).

(33 CFR 45715 §155.215)

4.  Vessels carrying oil as a secondary cargo must carry appropriate equipment and

supplies for the containment and removal of on-deck oil cargo spills of a least on-half

barrel.  (33 CFR 45715 §155.220)

5.  Oil spill sorbents must satisfy the standards set by section 4202 of OPA.  Unitor

sorbents meet this standard.

OPA REQUIRED EQUIPMENT

The spill equipment for cases 1 and 2 must include all of the following, while cases 3 and 4

must include just items A to E inclusive:

A.  Sorbents

B.  Non-sparking hand scoops, shovels and buckets

C.  Containers suitable for holding recovered waste

D.  Emulsifiers for deck cleaning

E.  Protective clothing

F.  A minimum of one non-sparking portable pump with hoses

G.  Scupper plugs

1

Oil Spill Equipment Regulations

CALIFORNIAN CODE OF REGULATIONS SECTIONS 840 – 845.2

These regulations are in addition to those summarised under the OPA 1990 heading (above)

and apply to vessels involved in oil transfer operations (including bunkering).  Such vessels

must provide appropriate equipment and supplies for the containment, removal and storage of

on-deck oil spills of at least seven barrels (1100litres).

•  These regulations apply to both transfer and receiving vessels.

•  In addition to all the

OPA Required Equipment

above, there must be 15 gallons (57 litres)

of deck cleaning agent.

•  The required equipment must remain ready and the pumps with required hoses must be

ready for immediate use during transfer operations.

2

Regulation 18 Fuel Oil Quality

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In an attempt to reduce the problems of poor quality fuel affecting air pollution, this regulation has attempted to reduce the increasing problem of waste dumping in marine residual fuel oils. The wording and detail of the regulation should be defined enough to of real use, but as recent decisions have shown, this needs to be tested in a Court of Law before everybody fully understands and obeyed its requirements. The regulation states that the fuel oils:

a)         Be a blend of hydrocarbons derived from petroleum refining.

b)         Be free from inorganic acids

c)         Shall not include added substances or chemical waste which

i)          jeopardises the safety of the ship, or effects the performance of the machinery

ii)         is harmful to personnel, or

iii)        contributes to overall air pollution

The bunker note must contain a declaration that the fuel conforms to the requirements stated above. These bunker notes must be available for inspection by Port Authorities.

Carbon Monoxide

CO is formed due to the incomplete combustion of organic material where the oxidation process does not have enough time to occur completely. This toxic gas is unlikely to be produced in large concentrations in diesel engines that have a large excess oxygen. This compound can still be burnt to form CO₂, and is usually only present when pockets of excess fuel are present, hence higher levels may indicate inefficient fuel atomisation or penetration.

Carbon Dioxide

Co₂ is not toxic however, it has been linked to the greenhouse effect and global warming.

It is one of the basic products of combustion and the only viable method of reduction is to reduce the quantity of fuel burned. Diesel engines currently meet the guidelines.

Hydrocarbons

This is the small quantity of fuel, which leaves the cylinder unburnt due to insufficient temperature, which can occur near the liner wall (wall quenching). It is dependant upon the type of fuel used, and if fuel preparation and combustion is efficient, then this emission quantity should be small.

Particle emission or smoke

Particle emission, as well as hydrocarbons are thought to be carcinogenics.

The limit of smoke allowable is determined by different methods, i.e. smoke numbers (which express the degree of blackening on a white filter paper, Bosch or Bacharach), or smoke values (which quantifies the reduction in light passing through the exhaust plume, Hartridge or Ringelmann).

This exhaust plume is more visible on the larger engines, as the plume has a larger diameter. The particles may be due to a number of sources:-

            a)         agglomeration of very small (1µm) particles of partly burnt fuel,

            b)         ash content of fuel oil and cylinder oil,

            c)         partly burnt lube oil,

            d)         combustion chamber/exhaust system deposits peeling off.

Soot for source a) (responsible for 90%) is produced during the combustion process by pyrolysis (burning without visible flame). This consumes the lighter fractions of the fuel, leaving a hard shell that is slow to burn, and hence would be exhausted as soot. Soot levels increase when diffusion combustion is prominent.

Soot levels will also be increased when any the following are present:-

·         Slow burning fuel present with:-

i)          High asphaltene fuels. The fuel combusts much later and thus consumption of soot is reduced,

            ii)         Fuel on liner wall. This will cause the fuel to burn slowly as droplet temperatures will be low.

            iii)        Larger droplets of fuel (poor atomisation). This reduces the rate of diffusion combustion, and hence makes the fuel slower burning.

·         Increased cylinder temperatures present when:-

            i)          Scavenge temperatures are high. Increasing the inlet temperatures from 20 to 100^oC will increase smoke levels by 50%. This is probably due to increased pyrolysis, hence the fuel is being `baked' instead of consumed.

Remember that soot is not only a pollutant, but it will collect in the uptakes mainly on the cooler surfaces, especially if `wet' with oil, and increase exhaust gas boiler back pressure and increase the possibility of boiler fires.

Regulation 14 Sulphur Oxides

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The regulation has two limits of the sulphur content of the fuel oil, namely:

·         4.5% for engines operating anywhere in the world,

·         but only 1.5% for engines operating in the new SO_x Emission Control Areas (SECA), presently the Baltic, but soon to include the North Sea and English Channel. The vessels entering these areas must record the change over of the fuel tanks, with regards to date, time and vessel position.

These emissions will be transformed into H₂SO₄ by the reaction of rain, and this falls to the ground as Sulphuric Acid rain.

The level of emissions produced is directly related to the level of sulphur present in the fuel. This sulphur will oxidise to form SO₂ and SO₃, at the ratio of 15:1. We presently combat this reaction by using high alkaline oils to prevent high cylinder corrosion, and this oil addition will slightly reduce exhaust emissions. However to achieve significant reductions we must:

1.    Use fuel that has a low level of sulphur present. This will usually mean an increase in the fuel purchase price (10 to 20% greater for a change of 3.5% to 1%), also problems with reduced lubrication of fuel injection equipment.

2.    Water wash the exhaust gases using Calcium in lime water or sea water, in an exhaust scrubber.  

EMISSIONS

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A draft protocol has been compiled by the IMO organisation to reduce the effects of vessel emissions on overall air pollution. This protocol forms Annex VI of the MARPOL 73/78 Regulations. Applies to every ship of 400 gross tons and above. Entered into force 19^th May 2005. The main parts of the protocol which affect vessel operation are regulations 12 to 18, namely:

Regulation 12           Ozone Depleting Substances

Regulation 13           Nitrogen Oxides

Regulation 14           Sulphur Oxides

Regulation 15           Volatile Organic Compounds

Regulation 16           Shipboard Incinerators

Regulation 17           Reception Facilities

Regulation 18           Fuel Oil Quality

The vessel complying with these new regulations will be issued with an IAPP certificate, similar to the present IOPP for oil pollution.

Regulation 13  Nitrogen Oxides

The main thrust of this regulation is to reduce and control NO_x emissions from diesel engines. The regulation is for new or converted engines of over 130kW built after 1/1/2000. Although the type of fuel plays a major part in the composition of the emissions, the major factor that determines the amount of No_x is engine speed. For the engines that fall under this criterion, the engine must have limits of NO₂ from the engine of:-

            17                    g/kWh for engines under 130 rpm

            45n^-0.2             g/kWh for engines between 130 and 2000 rpm (where n = rpm)

            9.8                   g/kWh for engines over 2000 rpm

These emissions contribute to `smog' formation by increasing ozone concentrations in highly inhabited areas, affecting the respiration of humans and plants, and as NO₂ is soluble in water it will be absorbed by rain to produce acidic precipitation.

These oxides are formed during the combustion process when the normally inert nitrogen reacts with the plentiful oxygen present, to form nitrogen oxides. The initial reaction is the formation of Nitric Oxide (NO), which is later converted to form Nitrogen Dioxide (NO₂, visible as a yellow/brown gas) and Nitrus Oxide (N₂O), typically 5% and 1% of the original NO quantity.

The nitrogen comes from:-

a)            the fuel (fuel NO_x, which is totally converted),

b)            the air (thermal NO_x, the amount converted depends on how long and at what temperature the reactants are held at).

Large bore slow speed engines inherently produce larger quantities of NO_x emissions, as the slower speeds and larger bores both result in higher gas temperatures.

The controlling factors of how much NO_x will be produced depends upon the concentration of oxygen, and the temperature and duration of combustion (increases x3 for every 100°c),

To reduce NO_x emissions we can use:-

Primary methods – denitration of fuel, alternative fuels (LPG) or affecting combustion,

Secondary methods – during exhaust.

Procedures for wet lay-up of boilers

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important proper action is taken before the vessel is laid up to avoid

corrosion created by low pH and/or oxygen pitting in the water.

The lay up procedure has to be started a few days before the boiler system

will be stopped.

1.  The boiler treatment levels should be kept as follow: p-alkalinity 200

ppm and chloride readings must be kept low as possible.

2.  Regular blow downs must be given to reduce the potential sludge

deposits at a minimum:

•  Surface blow down to remove possible oil contaminants

•  Bottom blow down to remove potential sludge

3.  Oxygen Scavenger Plus should be dosed the last 3 days 1,5 ltr/day

to reduce the oxygen content.

4.  One hour before the boiler will be stopped a final dosage must be

given with 1 ltr/Oxygen Scavenger Plus/ton (calculated the full

capacity of the boiler)

5.  The boiler must be filled up complete with a water “head” created by

a hose via the air vent connected to a drum above the boiler.

6.  The water level in the drum should be checked regular to be sure

that there would be no oxygen intake.

7.  Maintain boiler water at pH 9 by dosing with Condensate Control.

To return the boiler in service the water level must reduced till normal

working level and lite-off as per boiler manufacturer instructions

Procedures for dry lay-up of boilers

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1.  When securing the boiler, decrease pressure and make total blow down

(surface & bottom) of the boiler as per the manufactures boiler manual.

2.  Once the boiler has cooled down, then completely drain. Proper boiler

cooling prevents any sludge or debris baking onto the surface of the

boiler – water sides.

3.  Blank flanges should be made with rubber gaskets, for all pipes leading

into or out of the boiler; the boiler should be gas tight - including all vent

lines, scum lines, sight glass lines and all headers / drain lines. (Except

the excess steam, drum, vent at the very top of the boiler, and one

header / drain at the lowest point of the boiler).

4.  These two points; the steam drum vent line and drain line should have a

ball valves or pin valve on them so the boiler can be filled and purged

with gas.

5.  Only after the boiler is completely drained can the water drum, steam

drum and headers be opened, inspected and manually cleaned if

required. All other debris, sludge and other impurities should be taken

out at this stage.

6.  The next stage is to completely dry the boiler. This can be done using a

dehumidifier set up at various points in the boiler.

7.  During this process any further dry debris should be removed from the

headers and water drum, steam drum, Etc.

8.  After the boiler is completely dry and the debris removed, silicea gel

bags can be put into the headers, water drum and steam drum. This

should be calculated based on size of the boiler.

9.  Only at this point should the boiler be made gas tight an in dry lay-up

condition.