1. U.S.A. TANKER REQUIREMENTS
INTERTANKO
NORTH AMERICAN PANEL
OCTOBER 29th, 2014
PRESENTATION:
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KULDEEP SINGH
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2. INDIVIDUAL STATE - REGULATORY REQUIREMENTS
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3. Written Testimony to a Senate Committee June 12, 2012
The United States is a maritime and Arctic nation. We have one of the world’s longest coastlines, measuring more than 95,000 miles, and the world’s largest Exclusive Economic Zone (EEZ), responsible for over $122 billion in revenue annually. The U.S. maritime transportation system is comprised of 361 ports and thousands of miles of maritime thoroughfares that support 95% of U.S. foreign trade. Most of that trade is transported on over 7,500 vessels that make more than 60,000 visits to U.S. ports annually. The need to secure our maritime rights and interests, including ocean resources, is paramount.
Excerpt from: “The Law of the Sea Convention: Perspectives from the U.S. Military”
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4. AIR, LAND AND WATER – ALL COVERED
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5. GALLAGHER MARINE SYSTEMS LLC.
THE U.S. CHALLENGE
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6. FEDERAL REQUIREMENTS SAMPLE PRIOR ARRIVAL CHECKS
NVMC REPORT – ENOA
BWM REPORT TO NBIC
ENSURE VALID VRP & COFR
ENSURE VGP NOI SUBMITTED & INSPECTION/S
CONDUCT DRILLS INCLUDING NOTIFICATION
COMPLETE COMMERCIAL OBLIGATIONS – SCAC NUMBER
CONDUCT OPERATIONAL & NAVIGATIONAL TESTS 33CFR164.25
COMPLETE ADDITIONAL LIGHTERING REQUIREMENTS
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7. FEDERAL REQUIREMENT VESSEL GENERAL PERMIT
NPDES - CWA
ADDRESSES 27 VESSEL EFFLUENTS
FIRST PERMIT 19TH DEC 2008 (5 YEARS VALIDITY)
INTENDED AIM – HARMFUL “DISCHARGE ELIMINATION”
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8. FEDERAL REQUIREMENT VESSEL GENERAL PERMIT
PROMOTES - BEST MANAGEMENT PRACTICES
REQUIRES - SAMPLING MAINLY FOR VESSELS BUILT AFTER 19TH DECEMBER 2013
INDIVIDUAL STATE REQUIREMENTS - 25 STATES REQUIREMENTS INCORPORATED IN VGP
STATE REQUIREMENTS - MAINLY HARMONIZED WITH VGP BUT SOME STATES HAVE ADDITIONAL REQUIREMENTS
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9. CALIFORNIA STATE – SEWAGE REGS
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10. GALLAGHER MARINE SYSTEMS LLC.
California State - NDZ
Largest in the USA
Location: All coastal waters out to 3 nm from the California coastline
Applicability: all passenger ships and oceangoing vessels larger than 300 tons with sewage holding tank capacity.
Other States also have NDZs
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11. FEDERAL REQUIREMENT BALLAST WATER MANAGEMENT
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12. GALLAGHER MARINE SYSTEMS LLC.
CALIFORNIASTATE – BWM
California does not provide exemption for vessel deviation. Ships arriving Cal. ports must conduct BWM, regardless if it would result in deviation or delay of the voyage. – CSLC LETTER 14 AUG 2014
MID OCEAN EXCHANGE > 200 nm; > 2000m
OR PCR EXCHANGE > 50 nm; > 200 m
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13. GALLAGHER MARINE SYSTEMS LLC.
NORTH AMERICAN - ECA
Effective Date
Sulfur Limit %m/m (ppm)
On and after 01 JULY 2010
1.5% (15,000)
1.0% (10,000)
On and after 01 JAN 2015
0.1% (1,000) (93% reduction since July 2010)
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14. CALIFORNIASTATE ARB REQUIREMENTS
January 1, 2014
Marine gas oil (DMA) at or below 0.1% sulfur;
or marine diesel oil (DMB) at or below 0.1% sulfur
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15. SOME INDIVIDUAL STATE REQUIREMENTS
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16. Guam, American Samoa and Alaska
OSRO coverage meets USCG planning standards in the continental United States and Puerto Rico but not the areas highlighted in yellow above…
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17. VRP Approval letters with remote area endorsements
American Samoa Guam Western Alaska
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18. WHAT IS APC & WHY REQUIRED?
Alternative Planning Criteria (APC) Operating Procedures developed to mitigate the risk of maritime incidents - Alaska Maritime Prevention & Response Network.
Designed to mitigate risk in remote areas where spill response resources are sparse.
These Procedures apply to oil tankers operating in Western Alaska waters outside of Cook Inlet - Coast Guard Captain of the Port Western Alaska zone up to the seaward boundaries of the U.S. EEZ
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19. APC – PROCEDURES OVERVIEW
Procedures are mainly centered around Maritime Domain Awareness & Engagement with enrolled vessels equipped with AIS
Vessels in the region tracked in real time x 7 via AIS
Notification requirements & procedures if there is an incident of a threat of an incident.
Safe routing measures
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20. OFFSHORE RISK MITIGATION ROUTES ALEUTIAN ISLANDS
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21. Network Operating Procedures changes for Tankers:
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22. Vessels not holding a Western Alaska endorsement?
Vessels are tracked via AIS by the NETWORK. If a vessel transits Western Alaska but does not have an endorsement for this zone, the USCG is notified.
USCG then take further action. sent to vessel, operator/owner & QI:
Current USCG Approval Letter
showing NO endorsement for Western Alaska
A list of “non compliant vessels that are transiting the area but have NOT entered into the APC.
Reference 33 CFR 155 regarding Geographic Specific Appendices (i.e. endorsements)
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23. REQUIRE APC ENROLLMENT FOR
GUAM & AMERICAN SAMOA
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24. How do you obtain the endorsements?
Vessel must enter into contract with an approved OSRO or entity in the location they are trading or transiting (to or from a U.S. port). These OSRO/entities are as follows:
2. Vessels must follow Alternate Planning Criteria (APC) in the respective area (Guam, American Samoa, Western Alaska).
Tankers: 33 CFR // Nontankers: 33 CFR
Guam
American Samoa
Western Alaska
NaRCO or MSRC
AND
OSROCO
Solar OR Green Ops
“Network”
Alaska Chadux
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25. GALLAGHER MARINE SYSTEMS LLC.
SPECIAL REQUIREMENTS
If trading to these remote locations…
YES
If transiting these locations, going to or from a U.S. port…
If on Innocent Passage…
For Guam and American Samoa NO
For Western Alaska
NO*
*However, if the vessel has an existing Western Alaska endorsement, they are required to follow the requirements associated with that endorsement (Alternate Planning Criteria) even when transiting Western Alaskan waters on Innocent Passage.
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26. Costs for required APC compliance:
For Tankers you must:
Enter into a contract & remit payment to the respective contractor(s):
Please request fee structure if you need it as the above fees are not all inclusive and are subject to change.
Location
Contractors
Fee:
Follow APC Requirements?
American Samoa
(Pago Pago)
Green OPS OR
SOLAR Environmental
AND
MSRC OR NARCO
Up to $3,000
$500 port call
Per contract
YES
Guam
Oil Spill Response Operations Company
(OSROCO)
Up to $10,950
Per port call
+ annual admin fee of
$1,050/year
Western Alaska
Alaska Maritime Prevention and Response Network
(NETWORK)
Alaska Chadux
$7,500
$850
Transit: $850 for both Tank and Non Tank vessels; however, when enrolling into the NETWORK for non tank vessels, this includes the Chadux fee.  Tanker vessels pay $850 (Chadux coverage) plus NETWORK ($7500) for transit
Attached is the Chadux rates for nontank vessels calling to AK.

27. Trading To WA… VERSUS Transiting …going to/from U.S. port
LOCATION:
CONTRACTORS
WHILE TRADING
CONTRACTORS WHILE TRANSITING
(to/from a US Port)
FEE:
American Samoa
As noted in previous table
Guam
Western Alaska
AND
Alaska Chadux coverage
Up to $9,500 (NT)
$0.08/bbl capacity (Tanker)
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28. California State Requirements
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29. California Contingency Plans
California Plan Submissions & issuance of approval letters.
Plan must be submitted at least five “working” days before entering California waters.
Please consider GMS production time as well.
If you have vessels that may go to California, please let GMS know immediately.
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30. California Certificate of Financial Responsibility
Submit at least TEN DAYS BEFORE entering California waters.
Applications received with less than ten days will receive a penalty.
Preliminary Contingency Plan Approval AND a valid COFR are required before entering California waters.
COFR application “in process” is acceptable
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31. Cost of Compliance Versus Cost of Noncompliance
CA COFR
CA Contingency Plan
QI/SMT/OSRO/SMFF
Cost of non-compliance
In this recent example, cost is $4,000 for first time offender.
Penalties increase with each occurrence.
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32. California has a very active boarding program…
Remember that California has an active boarding program. We are seeing an increase in non-conformities such as these:
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33. Incorrect bolts at the manifold…
What is the standard?
California standard is open to interpretation.
How many threads should protrude from a flange bolt?
We learned that the industry standard is 1.5 threads exposed.
Provided as further information concerning bunker hose flange "boltgate", which I think has about run its course.   I did some research this morning and found the following information.
Kuldeep provided a copy of the California oil transfer regs which essentially says "bolts of the correct size, bolt in every hole".  It leaves open to interpretation if incorrect size menas bolts of either incorrect diameter or too short to allow "full thread engagement", or both.
The ASME Standard for flanged connections specifies standard bolt lengths but says shorter bolts may be used so long as it achieves “full thread engagement” (discussed below).
Rick told me this morning that OSPR had/were using an “industry standard” of 1.5 threads exposed.
Then looking for a definition of “full thread engagement” I found the following website from a fastener company which says “it depends”. 
So what does a standard from a recognized authority say?
I found a pirated copy of the lengthy ASME Standard B   Annex D of this Standard (attached – Page 109) discusses calculating bolt lengths using flanges and gaskets made in accordance with the Standard.  One of the footnotes says:   "The equations used in this Annex are for calculated bolt lengths established to ensure full thread engagement of heavy hexagon nuts when worst-case tolerances occur on all relevant dimensions of the flanged joint.  The use of shorter bolt lengths is acceptable provided that full thread engagement is obtained at assembly (see Para ).
Para says:  “Bolt Lengths. Stud bolt lengths, including the height of two heavy hexagon nuts, are shown as dimension L in Tables 7, 10, 13, 15, 17, 19, and 21 (Tables F7, F10, F13, F15, F17, F19, and F21 of Annex F). The tabulated stud bolt length L does not include the height of end points. An end point is defined as an unthreaded length, such as a chamfer,  which extends beyond the thread. The method of calculating bolt lengths is explained in Annex D. The tabulated bolt lengths are reference dimensions. Users may select other  bolting lengths.”
Para says:   “Bolting Recommendations.  For flange joints, stud bolts with a nut at each end are recommended for all applications, and especially for high temperature service.”
FWIW, the ANSI and ASTM B16.5 standard are identical.
BTW, the difference between ANSI and ASTM:  “ANSI concentrates on taking the U.S. businesses at top levels by promoting voluntary consensus standards. ASME, on the other hand, concentrates on delivering solutions to the real issues faced by the engineering professionals in day-to-day life.”
So the bottom line is there is no definitive rule on how many threads should protrude from a flange bolt or stud and nut arrangement, but it should be at minimum some small amount to demonstrate/ensure full thread engagement.
As Rick points out, a ship receiving a NOV on this item has been a rare occurrence and rather than a special Client Advisory we might add a recommendation on this subject as a slide to be used during environmental updates/FTSs, etc.
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34. Changes in Resource Providers…
Washington State
Changes in Resource Providers…
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35. GALLAGHER MARINE SYSTEMS LLC.
WASHINGTON STATE
OLD:
Vessels trading to Washington State had to enter into a contract with the Washington State Maritime Cooperative (WSMC) the only Primary Response Contractor (PRC) for this area.
WSMC had an agreement with National Response Corporation (NARCO)
CHANGE:
WSMC & NARCO dissolved their agreement in 2013
NARCO & WSMC are now competing PRCs
WSMC is teamed with MSRC
NARCO has all necessary assets to provide required services/coverage.
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36. GALLAGHER MARINE SYSTEMS LLC.
ERTV Tanker Fee
Tanker fee based upon the following:
Size
Credits
Double Hull
Redundant Engine/Steering
ISO 14001
LPG is listed under tankers and is not considered a NT
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37. GALLAGHER MARINE SYSTEMS LLC.
Alaska
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38. Alaska DEC – Boarding Program
Alaska has an active boarding program.
Alaska Department of Environmental Conservation
Ensure vessels have:
Proper documentation
Organized & presentable
Knowledge of required notification procedures
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39. GALLAGHER MARINE SYSTEMS LLC.
Hawaii
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40. Hawaii Dispersant Coverage
Vessels trading/transiting the waters of Sector Honolulu.
need a contract with Hawaii-based OSRO - Clean Island Council.
GMS can arrange this contract OR
you can do so via your agent.
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41. Hawaii Vessel General Permit Filing
Hawaii requires their own version of a VGP filing
The application must be completed on-line then the form printed, signed, and post mailed to the State.
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42. GALLAGHER MARINE SYSTEMS LLC.
Canada
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43. GALLAGHER MARINE SYSTEMS LLC.
US Great Lakes not Canada
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44. GALLAGHER MARINE SYSTEMS LLC.
Canadian Contracts
Two OSRO providers when calling to Canada & divided geographically:
Eastern Canada Response Corporation (ECRC)
2 business days to arrange
$750 CAD per vessel plus $17.50 wire fee
Valid one year from date of enrollment
Western Canada Marine Response Corporation (WCMRC)
$790 CAD per vessel plus $10 bank surcharge
Final contracts are provided once payment has been received.
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45. GALLAGHER MARINE SYSTEMS LLC.
THE SOLUTION
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46. GALLAGHER MARINE SYSTEMS LLC.
THE SOLUTION
INFORMATION SHARING
SHIPBOARD U.S. SPECIFIC PROCEDURES
SHIPBOARD TRAINING
SHIPBOARD PRE-ARRIVAL CHECKLISTS
SHIPBOARD ACCESS TO INTERNET BASED INFO
DISCUSSIONS DURING SEA STAFF SEMINARS
RETENTION OF U.S. EXPERIENCED SEAFARERS
ACTIVE PARTICIPATION IN NPRM PROCESS
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47. GALLAGHER MARINE SYSTEMS LLC.
SAMPLE CHECKLIST
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48. GALLAGHER MARINE SYSTEMS LLC.
PRE-ARRIVAL CHECKS
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49. GALLAGHER MARINE SYSTEMS LLC.
THANK YOU
“An ounce of prevention is worth a pound of cure” Benjamin Franklin
In summary, much of what I have covered you already know. However, we continue to see penalties and incidents that continue to occur. I have expressed the fact that US Federal and State agencies have increased both their presence, training and level of expectation on the shipping industry. You must, therefore, be conscientious about ensuring your vessels and personnel are prepared when they trade to the US.
Companies must continue to be diligent in continuous improvement through:
Training Shore staff and Seafarers
Performing Drills
Attendance at seminars
Companies should use external resources in the form of QI’s. Please do not look at a QI as an emergency resource only. Rather, the QI should be a resource that is utilized for your masters to ask questions and consult. This is true both in incidents and in simply asking pre-arrival questions.
Checklists like the one I showed you are extremely useful and assist in enabling Master’s to navigate through the treacherous regulatory waters made up of US Federal and State requirements. Utilization of the checklist and dependency on compliance resources such as your QI are valuable in avoiding regulatory pitfalls.
The cost of prevention & preparedness is far less then incurring penalties or being involved in an accident. Thank you for your time. If you have any questions, I will be happy to take them now. Or, alternatively, please send them to my attention at our general address listed on this slide. Once again, thank you.
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