Tuesday, June 29, 2010

Healthy Air: CARB and the Emission Control Area

By Charlie Walther and Mary Frances Culnane
June 2010

The state of California tends to be ahead of the rest of the country when it comes to environmental issues. Most recently, the manner in which California has addressed marine exhaust emissions has evolved into an emission control model adopted throughout the world.

Powerful Environmental Advocacy
Although the California Air Pollution Control Act was passed in 1947, it was the passage of the Mulford-Carrell Air Resources Act in 1967 which gave us the California Air Resources Board (CARB). CARB was created prior to the passage of the federal Clean Air Act, and California was the only state to enable this type of regulatory body; consequently, California is the only state permitted to possess such a regulatory agency. Other states may not set their own standards; however, they may follow CARB standards or utilize the federal standards.

Highlights of the original Mulford-Carrell Act included the creation of a State Air Resources Board to coordinate administration, research, and air conservation activities within the State, and the transfer to the Board of all personnel, equipment and assets of the Motor Vehicle Pollution Control Board and Vehicle Pollution Laboratory.

The act also specified duties to be performed by the new board, including the division of California into air basins and the adoption of ambient air quality standards for each basin.

The board assumed total responsibility for emissions from motor vehicles, and was tasked with the adoption of emission standards for all sources of air pollution and the enforcement of these standards, if, after public hearing and investigation, the Board finds that local authority has not taken reasonable action.

CARB was also tasked with conducting studies and inventories of sources of air pollution, monitoring air pollutants, and evaluating the effects of air pollution, as well as coordinating and collecting research data on air pollution and encouraging a cooperative State effort. Finally, the Board is responsible for reviewing all rules and regulations of local and regional authority, to assure that reasonable provision is made to control emissions and to achieve the air quality standards established by the State. The Act granted various methods to enforce the standards

CARB’s stated mission is to promote and protect public health, welfare and ecological resources through the effective and efficient reduction of air pollutants, while recognizing and considering the effects on the state’s economy.

It appears reasonable for CARB to develop sufficient marine exhaust emissions standards based upon evaluating technical studies, fielding expert advice from the industry and providing satisfactory responses to questions and concerns expressed during established public comment periods. Some have argued that CARB may have pushed beyond their stated mission with the recent passage of the Commercial Harborcraft Rule. Within the parameters of this unfunded mandate, CARB not only establishes air quality standards, but dictates methods to reach said standards while remaining exempt from the responsibility for any of the consequences of implementing such methods.

The concept of the Best Available Control Technology (BACT) is of particular concern, due to numerous conflicts with Federal regulations governing procurement of vessels or engines when using federal aid for purchasing same. One issue is that the federally funded procurement process guidelines require confidentiality during a procurement evaluation process, yet CARB involves itself in this process. Moreover, competitive information provided relative to both the technical and cost proposals may include trade secrets protected by statute. A case can be made for CARB removing themselves from the procurement process and establishing an emission standard, thus allowing industry to meet same, as opposed to CARB approving technology and without responsibility or liability placing the burden on the applicant for any failures as a result of implementing CARB approved technology.

CARB has evolved into an 11 member appointed board with an $860 million annual budget and a 1,200 member staff of administrators, regulators, technicians and compliance officers.

Legislation on the Horizon:
The International Maritime Organization (IMO) agreed to the USA EPA & Canada joint application for a 200-mile range emission control area (ECA) with enforcement commencing in August of 2012. Starting at a sulfur cap of 1%, this ECA will reduce to a 0.10% cap by 2015.

The current CARB sulfur restrictions that began on July 1, 2009 will decrease to 0.10% commencing in January 2012.

On the domestic side, a final rule was executed in December, 2009. New engine standards include Tier 2 and Tier 3 NOx limits for US vessels harmonized with MARPOL Annex VI, Hydrocarbon, Carbon and CO cap standards for US vessels. New fuel sales standards include a 0.1 percent sulfur fuel limit for use in ECAs (unless equivalent technology is utilized), and allows for 0.1 percent sulfur distillate sales in US for marine use. The new rule adopts Annex VI implementation regulations for all vessels operating in US waters.

Annex VI
New Annex VI Amendments were approved in October, 2008. These included global NOx controls in the form of the adoption of Tier 2 standards for a 20 percent reduction for new vessels built after 2011. Existing engine standards apply.

Annex VI Amendments also call for global PM and SOx controls, with limits in 2010 of 3.5 percent fuel sulfur, lowering to 0.5 percent fuel sulfur in 2020, although this new level could be delayed to 2025, subject to a fuel availability review in 2018.

Finally, Annex VI states a country or countries may propose to designate an ECA where more stringent standards apply.

In March, 2010 IMO adopted the North American Emission Control Area, which calls for 1 percent fuel sulfur between 2010 and 2014, lowering to 0.1 percent fuel sulfur from 2015 onward. An 80 percent Tier 3 NOx reduction for new vessels will be required from 2016.

In August, 2011 the North American ECA goes into effect. The following August will see the start of enforcement. From August 2012 to January 2015, the 1 percent sulfur limit will apply except in California, where lower limits will be applicable. Low sulfur heavy fuel oil (LSHFO) will still be an option, except in California. After January, 2015, 0.1 percent will be the sulfur limit for ALL marine fuels.

Meeting Regulations
Since implementation of the CARB 24-mile diesel rule for oceangoing vessels went into effect the USCG has received an increase in the number of incidents regarding propulsion issues. There is a technical explanation for this, coupled with a solution, although the solution will increase operating costs.

Basically the vessel is operating on heavy fuel, which requires a considerable amount of heat to allow for proper injection properties. Although the changeover process from heavy fuel to CARB diesel may be described as simply pushing a button, the physics of such a process requires more attention to detail. Marine diesel engines are massive hunks of metal. While operating on heavy fuel the overall temperature of the engine, and especially the fuel injection system, is quite high considering the fuel injection temperatures hover around 248 degrees Fahrenheit. If, at 24 miles offshore the engineers simply injected room temperature CARB diesel into this hot, heavy diesel engine the potential explosion could be ferocious, or the injectors could seize, or any other number of catastrophic incidents could arise. Consequently, there is a procedure for changing over fuels. Generally, it takes between 45 minutes and 4 hours to completely change from heavy fuel to CARB diesel for a typical slow speed marine diesel engine. This process requires light fuel to gradually be mixed with heavy fuel in an appropriately termed mixing tank, or a mixing valve system, as the diesel engine temperature simultaneously drops.

The changeover process is when critical issues may occur; therefore, the process, in order to avoid incidents along the piloted transits of California waters, should be entirely completed prior to reaching the 24-mile point. Conversely, the changeover process should not be initiated until the vessel departs the 24-mile boundary as well. Herein lies the expense as the price of CARB diesel is well documented as being much higher than of heavy fuel with an estimated price differential of $200 - $250/metric ton premium for distillate fuels. Moreover, a vessel may utilize up to 5% more distillate fuel to gain the same power as when operating on heavy fuel. Some price comparisons suggest operating costs will increase $18 per container carried or $7 per passenger carried on a weekly Alaskan cruise.

Other areas to consider when operating on the lighter fuel include the effects on injection timing and attention required to cylinder oil Total Base Number (TBN), since utilizing the incorrect TBN cylinder oil for the fuel in operation could actually attack and wear the cylinder liners. Because the lighter fuel possesses fewer BTUs, one may also anticipate slightly less maneuvering power.

With the advent of the recent adoption of amendments to the MARPOL convention to formally establish a North American Emission Control Area, the marine diesel manufacturers are striving to insure that their products meet such standards.

Wärtsilä and ABB Turbo Systems developed a joint program, which includes two-stage turbocharging on large diesel engines coupled with advanced engine technology resulting in reduced fuel consumption and resultant engine emissions reduction. MAN B&W are working on a scrubber system to remove the sulfur from the exhaust. Other examples of innovations in emissions technology include EMD’s catalyst that fits in the manifold, thereby reducing the footprint of emission equipment. The GE Jenbacher biofuels engine uses biogas from anaerobic fermentation or organic waste from agriculture, foodstuff or feed industries, which can be a substitute for fossil fuels.

Current generation workboat engines are EPA Tier 2 compliant, with the EPA mandates being the driving force behind engine sales. The next generation engines will meet Tier 3 standards, largely with changes in engine architecture (injection and timing changes) while meeting Tier 4 standards will require some form of after treatment.

Clearly, changes are coming to marine fuels, and industry should be ready for them. Vessel Routing will need to be optimized to minimize distance traveled in the ECA, considering the area’s impacts on vessel schedule and the operating cost of any deviations. While there will be some impact on operating costs almost immediately, when 0.1% sulfur fuel is required, starting in 2015, per-voyage fuel cost impacts (into and out of the ECA) could be between $10,000 and $80,000 depending on the port, the route and the ship’s daily consumption.

The effect on annual fuel cost could reach $900,000 for ships on regular voyages into and out of the ECA, starting in 2015. For ships with multiple port calls in the ECA or in coastwise trade fuel cost impact will be higher.

To meet coastal fuel requirements, the “unifuel” ships of the recent past will have to become the dual fuel ships of the future.

Substantial increases in ECA-compliant fuel storage capacity will be needed on most ships, both existing and new, and changes will be needed to most ships’ fuel transfer, purifying and service systems to operate on the newly required low sulfur, low viscosity fuels.

At the end of the day, the rest of the US and Canadian ports will adopt the California model, and the air around the country’s ports will be that much cleaner.

Charlie Walther is a graduate of California Maritime Academy, who served as a Lieutenant, US Naval Reserve and in the US Coast Guard as Chief Engineer, followed by 20 years at Crowley Maritime in engineering and operations, the last five as Corporate Director of Engineering. He started Walther Engineering Services in 1989, and provides engineering and project management for ferries, tankers, tugs with emphasis on diesel propulsion. Some of Charlie’s past projects have included the US Navy X-Craft, where he was the senior tech rep for construction, test engineer and crew training, as well as the construction management of two new WETA ferries.

Mary Frances Culnane is a Chief Engineer who worked for Exxon Shipping Company, Chevron Shipping Company, Military Sealift Command (MSC) and the Bay Area Water Emergency Transportation Authority (WETA.) She currently is self-employed via Culnane Maritime Consulting. A 1980 graduate of the US Merchant Marine Academy, she has dedicated her life to maritime pursuits including shipping out, repairing/overhauling vessels, constructing new vessels, revitalizing classic wooden boats and collecting nautical antiquities.