Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Environmental Developments Ballast Water Management & Ship Recycling The Practical Implications and Considerations for the tanker operator Tim Wilkins Environmental Manager INTERTANKO London Office

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Practical Implications and Considerations International Ballast Water Convention plus 14 Guidelines We want implementation to be simple, effective and practical National Implementation of the International Ballast Water Convention – with national interpretations We want to avoid deviation from the International Convention Largest Impact on Shipping since MARPOL 73/78

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Practical Implications and Considerations 1. Meeting the Treatment Standard Ballast Water Exchange and/or Treatment Technology 2. Demonstrating Compliance Certification Record Book Reporting Surveys PSC Inspections

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Ballast Exchange Case Study One Tanker from Canada to California – is there a ballast requirement? 1.International Convention Regulation B-4Ballast Water Exchange 1A ship conducting Ballast Water exchange to meet the standard in regulation D-1 shall:.1whenever possible, conduct such Ballast Water exchange at least 200 nautical miles from the nearest land and in water at least 200 metres in depth, taking into account the Guidelines developed by the Organization;.2in cases where the ship is unable to conduct Ballast Water exchange in accordance with paragraph 1.1, such Ballast Water exchange shall be conducted taking into account the Guidelines described in paragraph 1.1 and as far from the nearest land as possible, and in all cases at least 50 nautical miles from the nearest land and in water at least 200 metres in depth. 2In sea areas where the distance from the nearest land or the depth does not meet the parameters described in paragraph 1.1 or 1.2, the port State may designate areas, in consultation with adjacent or other States, as appropriate, where a ship may conduct Ballast Water exchange, taking into account the Guidelines described in paragraph A ship shall not be required to deviate from its intended voyage, or delay the voyage, in order to comply with any particular requirement of paragraph 1. 4A ship conducting Ballast Water exchange shall not be required to comply with paragraphs 1 or 2, as appropriate, if the master reasonably decides that such exchange would threaten the safety or stability of the ship, its crew, or its passengers because of adverse weather, ship design or stress, equipment failure, or any other extraordinary condition. 5When a ship is required to conduct Ballast Water exchange and does not do so in accordance with this regulation, the reasons shall be entered in the Ballast Water record book.

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Ballast Exchange Case Study One Tanker from Canada to California – is there any ballast requirement? 1.International Convention 2.National Legislation - NI Circular 07-04, Change 1 Enclosure 2, paragraph 6 states; "In areas other than the Great Lakes and the Hudson River, masters are not required to divert or delay a voyage in order to conduct mid-ocean BWE. Whenever a vessel enters US waters after operating beyond he EEZ, but cannot conduct mid-ocean BWE because the voyage to the US was such that the vessel did not transit outside 200nm of any coast for enough time to conduct exchange, the vessel must retain its unexchanged ballast water while operating in US waters and only discharge the minimal amount of unexchanged ballast water that is operationally necessary to safely conduct cargo operations. Such situations may be likely for vessels that enter the US EEZ from a Caribbean, Canadian, or South American port where a direct transit to the US may not take the vessel more than 200nm from shore for sufficient time to conduct BWE before reaching their US destination."

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Ballast Exchange Case Study One Tanker from Canada to California – is there any ballast requirement? 1.International Convention – IMO Ballast Convention 2.National Legislation - NI Circular 07-04, Change 1 3.State Legislation – California Lands Commission State of California Assembly Bill 703, Chapter 849; Ballast Water Management for Control of Nonindigenous Species Chapter 1, paragraph 71200(j) " "Voyage" means any transit by a vessel destined for any California port from a port or place outside the EEZ, including intermediate stops at a port of place within the EEZ. For the purposes of this division, a transit by a vessel from a United States port to any other United States port, if at any time the vessel operates outside the EEZ or equivalent zone of Canada, is also a voyage."

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Ballast Exchange Case Study One Tanker from Canada to California – is there any ballast requirement? 1.International Convention – IMO Ballast Convention 2.National Legislation - NI Circular 07-04, Change 1 3.State Legislation – California Lands Commission 4.State Legislation – New California Lands Commission State of California Assembly Bill 433, an act to amend Section (among others). New section; " "Voyage" means any transit by a vessel destined for any California port or place from a port or place outside of the coastal waters of the state."

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Ballast Exchange Case Study One Tanker from Canada to California – is there any ballast requirement? 1.International Convention – IMO Ballast Convention 2.National Legislation - NI Circular 07-04, Change 1 3.State Legislation – California Lands Commission 4.State Legislation – New California Lands Commission 5.Port Legislation – Port of Oakland Authority Tanker has to exchange ballast en route or risks being sent from the port to exchange ballast on arrival (lost time / loss of earnings)

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Treatment Technology 1. Meeting the Treatment Standard Ballast Water Exchange and/or Treatment Technology Treatment Technology Standard (D-2) Organisms 50microns or larger: less than 10 viable organisms per m 3 Organisms between 10 and 50 microns: less than 10 viable organisms per ml Guidelines for approval of Ballast Water Management Systems Procedure for Approval of Ballast Water Management Systems that make use of Active Substances Guidelines for the approval and oversight of prototype ballast water treatment technology programmes

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Treatment Technology 1. Meeting the Treatment Standard Ballast Water Exchange and/or Treatment Technology Ships Constructed before 2009 with BW capacity , treatment technology in use after 2014 Phase in for Treatment System Installation (B-3) Ships Constructed before 2009 with BW capacity less than 1500 and greater than 5000, treatment technology in use after 2016 Ships Constructed on or after 2009 with BW capacity less than 5000, treatment technology in use from 2009 Ships Constructed after 2009 but before 2012 with BW capacity greater than 5000, treatment technology in use after 2016 Ships Constructed at 2012 or after with BW capacity greater than 5000, treatment technology in use after 2012

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Meeting the Treatment Standard – Treatment Technology Case Study Two A)40,000dwt Product Tanker to be delivered July 2007 Ballast water capacity greater than 5000m 3 so will be able to conduct ballast water exchange until 2016, when it will then have to have been retrofitted with a ballast water treatment system. B)8,000dwt Chemical Tanker to be delivered July 2007 Ballast capacity of less than 5000m 3 but greater than 1500m 3, will have to be retrofitted with a ballast water treatment system by C)Existing VLCC – delivered 2003 Ballast water exchange until 2016, retrofitted after BUT, if prototype system installed and test programme approved by IMO, 5 year exemption given, upgrade system in 2021.

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Practical Implications and Considerations 1. Meeting the Treatment Standard Ballast Water Exchange and/or Treatment Technology 2. Demonstrating Compliance Certification Record Book Reporting Surveys PSC Inspections

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Demonstrating Compliance International Ballast Water Management Certificate – Appendix I Ballast Water Management Plan – INTERTANKO/ICS and IMO Guideline Ballast Water Record Book – Appendix II Officers and Crew to be able to understand requirements (training) Ballast Water Management reporting – national only Surveys – initial, renewal (5 yr), intermediate, annual, additional PSC Sampling – undue delay / clear grounds?

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Demonstrating Compliance - Today Are we up to date? -Ballast Water Management Plan onboard (includes Ballast Water Record Book) -Checking of port, national and regional requirements? Ballast exchange or reporting? -Ballast Water Exchange Requirements? 200nm and/or 200m depth – ballast exchange zone? -Inspection requirements: sampling (master/designated officer aware of procedure) -Newbuilding implications (when delivered and how large – 4999m 3 ?) -Treatment systems – beware the hype / be aware of the exemptions -Familiarity of Convention and its Guidelines

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ballast Water Management: Demonstrating Compliance - Today Guidelines for sediments reception facilities Guidelines for Ballast Water Sampling Guidelines for ballast water management equivalent compliance Guidelines for Ballast Water Management and Development of Ballast Water Management Plans Guidelines for ballast water reception facilities Guidelines for Ballast Water Exchange Guidelines for Risk Assessment under Regulation A-4 Guidelines for approval of Ballast Water Management Systems Procedure for Approval of Ballast Water Management Systems that make use of Active Substances Guidelines for approval and oversight of prototype ballast water treatment technology programmes Guidelines for Ballast Water Exchange Design and Construction Standards Guidelines for sediment control on ships Guidelines for additional measures including emergency situations Guidelines on designation of areas for ballast water exchange

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Questions & Discussion

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Industry Code of Practice (1999) IMO Guidelines (2003) ILO & Basel Guidelines Consideration of Mandatory Elements Market Forces Shipping Industry Green Recycling International Ship Recycling Convention Shipping Industry Feedback Workable Practical Objectives Met Ship Recycling A Fresh Start

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Industry Code of Practice (1999) IMO Guidelines (2003) ILO & Basel Guidelines Consideration of Mandatory Elements Market Forces Shipping Industry Green Recycling International Ship Recycling Convention Shipping Industry Feedback Workable Practical Objectives Met Ship Recycling A Fresh Start

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ship Recycling Elements of a mandatory scheme 1. Recycling Facilities Licensed recycling facilities Ship owners to use only licensed approved facilities Ship owners to remove material the facility cannot 2. Mandatory reporting scheme 3. Ship Recycling Plan Prepared by the recycling facility – MEPC Circ Ship Recycling Contract Ensuring key elements of the Guidelines are included 5. Gas free for Hot Work Certificate Ship owner and facility to arrange for certification – MEPC Circ.466 Responsibility

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai Potentially Hazardous Materials Restrict use of hazardous substances on new ships States to minimize hazardous substances in existing ships Hazardous materials inventory on board when ship sent to recycling facility Ship owners to mark potentially hazardous materials 7. Green Passport Ship builders to provide Green Passport to owner Ship owners to maintain validity of Green Passport Ship owner to deliver Green Passport to recycling facility Ship Recycling Elements of a mandatory scheme

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Ship Recycling Shipping Industry Proactivity Follow Guidelines as closely as practicable – MEPC Circ.467 Identify areas of concern Notify Associations who can in turn notify IMO Pool resources and find solutions (HMI, Green Passport, Gas-free) Continue to highlight role of other stakeholders Share information on recycling facilities (market to force changes?) Green Recycling Facilities? Green recycling is ideally defined as scrapping performed in full accordance with the developed recycling guidelines.

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Environmental developments Environment will continue to take centre stage Kyoto, Biodiversity, Sustainability Mandatory requirements vs. Self regulation Political tug-of-war: National vs. Regional vs. International Political Will vs. Technical/Operational Reality A responsible, sustainable and respected industry able to influence its own destiny

Environmental Developments: Practical Implications and Considerations for the tanker operator Tim Wilkins: INTERTANKO Seminar, Mumbai 2005 Questions & Discussion