Best management practices for the control and reduction of “inadvertent” cargo vapour emissions from tankers

Since INTERTANKO circulated the article below on the subject of best management practices for the control and reduction of “inadvertent” cargo vapour emissions from tankers, we have become aware this week that the Captain of the Port Houston-Galveston was notified of a scheduled commercial helicopter flight over the upper Houston Ship Channel on Tuesday, May 8 from 0800 to 1400 hrs. The purpose of the flight? Aerial photography and emissions detection.

 

Members are reminded of INTERTANKO’s best practices (see below in the downloadable document) and urged to implement them accordingly.

 

Weekly NEWS article issued 30 March 2007:

 

The intention of these Best Management Practices is to assist INTERTANKO’s membership by incorporating them into their daily routines in order to enhance environmental protection, reduce inadvertent cargo vapour emissions from tank vessels, and clearly demonstrate the ability of the industry to self-regulate.

 

In order for this document to be utilised by the maximum number of stakeholders it does not focus on specific operations, such as tank cleaning and gas-freeing, but on the day-to-day good housekeeping practices of the tanker industry. The document aims to pull these existing best practices together in a single reference document as a clear indication of INTERTANKO members’ commitment to environmental protection.

 

These best practices link to the “zero pollution” aspects of the Poseidon Challenge.

 

The matrix developed is based on the American Waterway Operators (AWO) model but adapted for our own members’ needs, and is seen by INTERTANKO as sound practice for both the oil and chemical tanker industry today. It has been endorsed by INTERTANKO’s Council this week.

 

The driving force behind these best practices is a reflection of INTERTANKO’s commitment to the protection of the environment. INTERTANKO believes that this proactive approach of developing best practices will greatly assist in addressing one of the most significant challenges it faces today, that of over-regulation.

 

There are many places in the world today, not only the U.S., where air pollution is receiving a higher level of attention. The threat of global warming continues to be a growing issue and as a consequence, these best practices are aimed at meeting the needs of our members to deliver our cargoes while minimising our impact on the environment and meeting the expectations of the public of the tanker industry.

 

As INTERTANKO members trade internationally, we believe that these best practices should be viewed as best practices on a global basis and be used by all good stewards of the environment.

 

INTERTANKO has therefore produced these Best Management Practices to reduce inadvertent cargo vapour emissions from tankers.

We are encouraging our members to implement these measures within their operations around the globe. The recommendations focus on good operational practices.

The best practice document may be accessed here.

 

BACKGROUND to the development of these best practices

 

In the United States, the federal Clean Air Act and other federal regulations adopted by the Environmental Protection Agency (EPA) require each state to achieve attainment with National Ambient Air Quality Standards (NAAQS). States that do not meet NAAQS must prepare a State Implementation Plan (SIP) under the Clean Air Act to incorporate reductions to meet NAAQS. Both Louisiana and Texas have air quality issues in demonstrating attainment for NAAQS for ozone. The Baton Rouge, Lake Charles and New Orleans areas in Louisiana have been identified as areas that are either near non-attainment or close to designation of non-attainment under the Clean Air Act. In Texas, Houston-Galveston and Beaumont-Port Arthur areas are in non-attainment and have SIPs in place to accomplish reductions to meet attainment of the ozone standard.

 

The Louisiana Department of Environmental Quality (LDEQ) is responsible for revising Louisiana’s SIP to demonstrate that Louisiana will be able to meet ozone standards. The Texas Commission on Environmental Quality (TCEQ) is responsible for SIP preparation and oversight in Texas. EPA approval of the SIP and attainment of NAAQS are essential for economic development and funding of federal projects.

 

Because highly reactive volatile organic compounds (HRVOCs) and volatile organic compounds (VOCs) may contribute to ozone formation, LDEQ and TCEQ have initiated demonstration projects utilising remote sensing cameras to identify potential sources of emissions in order to develop reduction strategies. The camera called the “Hawk” is an infrared camera system capable of providing real time leak detection data. The Hawk comes in both hand-held and aerial configurations (for use on helicopters and airplanes), and provides qualitative information with respect to identifying a potential source or plume. Both LDEQ and TCEQ have implemented over flights utilising the HAWK camera and observed emission events from barges, storage tanks and other shore side facilities. In some cases, these over-flights have identified cases of inadvertent emissions that have placed these segments of the industry under the scrutiny of the regulatory community.

 

In response to the Hawk data, The American Waterways Organisation (AWO) Southern Region developed a Best Management Practice Guide to reduce and control inadvertent emissions from barges, which identified various areas of activity that could accomplish emission reductions.

 

The AWO Best Management Practices commitment has been embraced by both LDEQ and TCEQ in addressing the issue of barge emissions on its own behalf, as opposed to requiring states or federal government to implement regulations.  

Contact: Howard Snaith or Margaret Doyle