Risk-based Decision Making & USA Compliance Requirements & Methods

Transcription

1 Risk-based Decision Making & USA Compliance Requirements & Methods BWM Tech North America, Miami, FL 27 29September 2016 John P Dooley jdooley@choiceballast.com

2 Choice applies a Structured Risk-based Decision Making (RBDM) A process organizes information possibility of unwanted outcomes a broad, orderly structure more informed management decisions. (USCG) Benefits Common decision-making process - understood and expected Systematic analysis of risk reveals leads to different conclusions Better decisions - easy to defend because of the process

3 RISKS Financial Risk of Loss / Replacement / CAPEX Major CAPEX (BWTS, Engineering, Installation) Uncertain Regulations - G8 Changes Lack of USCG Type Approval Operational Risk of Lost Operations / OPEX Novel technologies, efficacy and efficiency Safety of vessel, personnel and environment Integration with vessel operations & controls Compliance Risk of Being Detained / Fined Uncertainty of meeting D2 standard Uncertain PSC Inspection Procedures Sampling during stripping Lack of operational experience / data UNCERTAINTY vs. CERTAINTY UNCERTAINTY INCREASED RISK ABSOLUTE CERTAINTY DECREASED RISK PROBABILITIES AND EXPECTED OUTCOMES UNKNOWN SOME KNOWLEDGE OF PROBABILITES AND EXPECTED OUTCOMES RISK PROBABILITIES AND EXPECTED OUTCOMES KNOWN

4 Financial & Operational Risk - Feasibility Studies Innovative solutions 3D Scan & Modeling Space Constraints In ER Machinery Arrangements Flow & Head Calculations

5 RISK ACCEPTANCE CRITERIA LIKELIHOOD/ PROBABILITY Likely or frequent (Once per voyage) 4 Safety & Installation RISKS Standard Analysis Tools Ballast SEVERITY Water / IMPACT Treatment System AFRAMAX Tankers at STX Shipyard Product Tankers at HMD Hazardous Area Installation FMECA Software Safety Assessment Arrangement Drawings Failure Mode Failure Mode Possible Failure Code Description Cause Flow Analysis HAZID Ship-specific Risk Assessment Item Ref. Item Description & Function Failure Mode Moderately Likely (once per year) 3 Negligible Marginal Critical Catastrophic Failure Mode & Effects Criticality Analysis (FMECA) Local Effect BALLASTING OPERATION Project No: Detection Effects Compensation Performed By: Revision: Final Effect Detection Severity Ranking Method A Provision Date: 17-Aug-15 Ranking By: Ethan Trupia Checked: Jan Flores Approved: John Dooley Loss of Steam Possibility Of Feed TCV-080 Machanical Contact Failed Component 4 Heater Skid Water Exceeding Project Possible No: Ballast None Temperature Control Performed 2 By: Identified Hazard 1 20 Closed Probable Cause Ultimate Consequence Failure Safeguards Shutdown L C R Recommendations/Action Taken Control 37C Revision: A Valve Unlikely (one per BALLAST WATER INTAKE & FILTRATION Date: HAZOP 1 Solenoid Valve SDV-025 Control Relay Digital Output a. Pipe design By: pressure above pump Ethan Trupia class of vessel per 2 Loss of Steam shut off head, Checked: b. Ship's remote valve Jan Flores Contact Failed Pipe rupture, ballast Component water on deck, Possibility position Of indication, Feed Approved: Possible c. Ship's Ballast ballast John Dooley A. Confirmation of proper valve positioning for ballasting 5 Heater Skid None 10 None year) a. Filter isolation Open valve(s) closed flooding of ballast tank. Failure interruption of Water tank Below level indication, 15C Shutdown d. Filter back operation and bypass in BWMP, B. Verify ship has remote Overpressure of Ballast Line Control 1 3 MED/LOW b. BW filter clogged ballasting. Flooding of BWTS Filter flush, e. Filter bypass, f. Filter valve position indication of filter inlet and outlet valves. C. Process Parameter Service & Location Deviation Possible Causes Consequences Safeguard Recommended Action Highly unlikely Room differential pressure alarm, g. Flow filter-bypass procedures to be included on BWMP. indication h. Filter design pressure a. Flow indication, b. Valve position Procedures for proper valve positioning to be (once per lifetime FLOW of 1 Seawater Ballast Intake No Flow Loss of Steam Inlet/Outlet Possibility above system Of Feed MAWP TCV-080 Machanical Component Isolation Valves (2) Interruption Possible Ballast of ballasting operation indication from ships alarm and included in the BWMP. Confirm remote valve Failed Open 5 Heater Skid Water a. Pipe Exceeding design pressure above pump None 10 Temperature Control a. Flange leak. Failure Shutdown monitoring system (AMS) indication from ships AMS. class of vessels) Compromise Control of longitudinal strength 37Cshut off head, b. Ship's ballast tank A. BALPURE Valve Operations Manual include inspection Unplanned Flooding of # 5 Ballast Tank b. Pipe leak, level indication c. pressure test of the 1 3 a. Filter MED/LOW back flush, b. Differential and stability. procedures, these shall be Procedures followed by ships for filter Crew. operation (including 2 Solenoid Valve SDV-025 N/A c. Valve leak system. d. Ship's crew inspection pressure alarm in the filters, c. Flow FLOW Seawater Ballast Intake No Flow Filter Clogged Interruption of ballasting operation valve positioning) and cleaning to be Trivial or Minor Injury Serious Fatality, Major procedures. indication, d. Filter bypass, e. Part of SAFETY negligible. a. Flange (non- leak. LTI) Injury Injury Loss of Steam included in the BWMP. BWTS Filter Room flooding Component Possibility Of Feed Possible Ballast BWTS periodic maintenance b. Pipe Failed leak, Closed 4 no Heater major Skid consequences A. pressure test of the system. None 1 1 LOW (LTI) 10 None Failure Water Below 15C Shutdown Control a. Ballast Flow not filtered, b. Potential Procedures of valve positioning to be FLOW Seawater Ballast Intake Filter Bypass Filter Bypass valve Open a. Ship's valve remote position Bypass Valve indication alarm a. compromising of Ship Stability, non-compliance of discharge standard included in the BWMP. a. Filter Minor isolation system valve(s) Major closed Total Ship indication, b. Filter back flush, c. Filter Confirmation of proper valve positioning for ballasting Interruption of Ballast Water Supply b. Compromising of ships longitudinal 1 2 LOW VESSEL B. Filter repair Clogged Ship differential pressure alarm d. Flow operation and bypass in BWMP. Loss strength Indication a. Flow Indicating Transmitter (FIT) Damage supplied for inlet to cells for protection Seawater - Inlet to a. Overheating Electrolyzer, No sea or air No Small Considerable in case of low or no flow, b. Low-Low FLOW System (Feed to No/Low Flow Manual Isolation Valve(s) Closed b. No/Low Chlorine production, ENVIRONMENTAL pollution. Electrolyzer) Environmental Spill Environmental flow trip, c. Low flow alarm, d. Flow c. Increased deposits on the anode Damage impact. signal required permissive to start unit, e. High voltage alarm Frequency of Occurrence (Probability) RPN

6 PureBallast 2 ATB TANK BARGES Hyde GUARDIAN Gold 2 ATB TANK BARGES 5 TUGS Hazardous Area Installation Flow Analysis Electric Load Analysis Arrangement Drawings Detail Design Class Submittals

7 Financial, Operational & Compliance RISK Planning, Survey & Feasibility Study BWTS Vetting & Selection Installation Engineering Submittal Documents & Class Interface Onboard Compliance & Training

8 Freedom of The Seas BWTS Installation and Approval Project Timeline and Activities

9 BWTS Philosophy Document 3.0 Ballast Water Management Plan (BWMP) 3.1 Ballasting 3.2 De-Ballasting 3.3 Gravity Ballasting/De-ballasting 3.4 Heeling Tank Exchange 3.5 Grey Water Tank Flushing 3.6 Emergency Use as Bilge System Pump 4.0 Safety Risk Assessment 5.0 Piping Systems 5.1 Ballast Water Treatment System P&ID 5.2 Modifications to Ballast Water System 5.3 Additional Piping Systems 6.0 Electrical Systems 6.1 Electrical One Line Diagram 6.2 Modifications to Electrical System 6.3 Electrical Load Analysis 6.4 Circuit Breaker Capacities and Selectivity 6.5 Emergency Stop (Ventilation) 6.6 Hazardous Areas 7.0 Control Systems 7.1 Power Supply Arrangement 7.2 I/O List 7.3 BWTS Alarms 7.4 Interface with Ship s Alarm and Monitoring System (AMS) 8.0 Fire Safety 9.0 Stability 10.0 Structural Arrangement Allows Gravity Ballasting, but NOT De-ballasting Select Gravity Ballast Mode Set the ship s existing ballast valves Flow, pressure, and UV dosage monitored by BWTS Back wash cycle BWTS alarm for low flow Option Switch to Ballast mode and start ballast pump

10 Valve Alignment Table New BWTS-Controlled Valves Existing Ballast System Valves Controlled / Alarmed MAS

11 3.0 Ballast Water Management Plan (BWMP) 3.1 Ballasting 3.2 De-Ballasting 3.3 Gravity Ballasting/De-ballasting 3.4 Heeling Tank Exchange 3.5 Grey Water Tank Flushing 3.6 Emergency Use as Bilge System Pump 4.0 Safety Risk Assessment 5.0 Piping Systems 5.1 Ballast Water Treatment System P&ID 5.2 Modifications to Ballast Water System 5.3 Additional Piping Systems 6.0 Electrical Systems 6.1 Electrical One Line Diagram 6.2 Modifications to Electrical System 6.3 Electrical Load Analysis 6.4 Circuit Breaker Capacities and Selectivity 6.5 Emergency Stop (Ventilation) 6.6 Hazardous Areas 7.0 Control Systems 7.1 Power Supply Arrangement 7.2 I/O List 7.3 BWTS Alarms 7.4 Interface with Ship s Alarm and Monitoring System (AMS) 8.0 Fire Safety 9.0 Stability 10.0 Structural Grey Water Tank Flushing: Class comments: We note that there is connection between the ballast system and grey water system. Kindly note that some port states will not accept the use of such connections. Additionally, BWTS may be sensitive towards contamination from grey water. While not in contradiction with MARPOL Annex IV, this connection may be in conflict with the BWM Convention when the latter enters into force.

12 Grey Water Tank Flushing Pipe route from BW Pump to GW Tank 3P Shown GW tank flushing bypasses BWTS, results in un-treated sea water remaining in the ballast lines Procedure - lines flushed 3 times >/= 13 NM from shore Valves alarmed and logged by the BWTS and MAS and noted in the Ship s Log Final tank flushing with treated ballast water

13 3.0 Ballast Water Management Plan (BWMP) 3.1 Ballasting 3.2 De-Ballasting 3.3 Gravity Ballasting/De-ballasting 3.4 Heeling Tank Exchange 3.5 Grey Water Tank Flushing 3.6 Emergency Use as Bilge System Pump 4.0 Safety Risk Assessment 5.0 Piping Systems 5.1 Ballast Water Treatment System P&ID 5.2 Modifications to Ballast Water System 5.3 Additional Piping Systes 6.0 Electrical Systems 6.1 Electrical One Line Diagram 6.2 Modifications to Electrical System 6.3 Electrical Load Analysis 6.4 Circuit Breaker mcapacities and Selectivity 6.5 Emergency Stop (Ventilation) 6.6 Hazardous Areas 7.0 Control Systems 7.1 Power Supply Arrangement 7.2 I/O List 7.3 BWTS Alarms 7.4 Interface with Ship s Alarm and Monitoring System (AMS) 8.0 Fire Safety 9.0 Stability 10.0 Structural Ballast Exchange Sequence: the relevant loading conditions must be included in the document. A summary of a typical ballast exchange sequence is shown in chapter Complete NAPA Loading Summary printouts required from the conditions the Captain used to provide the ballast exchange table.

14 IMO / USCG Phase I / Documents Phase II / Crew Knowledge Phase III / Equipment Condition & Operation Phase IV / Sample Discharge PORT STATE CONTROL - INSPECTION GUIDANCE IMO Guidance Resolution MEPC.252(67) Certificate Documentation BWMO Training BWMS Inspection BWMP Review Operational Parameters Indicative Sampling & Microbial Analysis to D2 Standard Sampling of Discharge if Warranted, Lab Analysis Signed copies onboard of properly completed and submitted forms is the best way to satisfy recordkeeping and reporting requirements and to ensure compliance - USCG USCG NVIC 07-04, Change 1 MI Notice Documents - IOPP Certificate TA Certificate - BWMP - BWRB Crew knowledge Vessel Examination Operational Inspection Equipment Compare BWTS Log to Documents Sampling of Discharge if Warranted, Lab Analysis EPA MOU 11 Feb 2011 Same as USCG Same as USCG Same as USCG Same as USCG

15 ONBOARD MANUALS Ballast Water Compliance Plan 1-Week Familiarization BWM Officer Overview, Regulations, Compliance Validation Recordkeeping and Reporting Training, Monitoring & Compliance Duties of the Ballast Water Management Officer Crew Training and Familiarization Particulars of the Ship Ballast Water Discharge Standard Demonstration of Compliance Recordkeeping and Reporting Measurement and Verification Procedure Instrumentation Monitoring and Verification

16 RECORDKEEPING & REPORTING IMO 2004 BWM Convention USCG 33 CFR Part CFR Part 162 EPA Final 2013 VGP Record Retention 2 years 2 years 3 years Vessel Specific Ballast Water Management Plan Regulation B-1 33 CFR (g) Ballast Water Record Book Regulation B-2 Ballast Water Reporting Form Detailed Training Logs Ballast Water Treatment System Data Log Ballast Water System Functional Monitoring Ballast Water Monitoring Equipment Calibration A 20/Res.868 Regulation B-6 (G4) Resolution MEPC.127(53) , NVIC 07-04, Change 1 OMB # A 20/Res.868 Final 2013 VGP Appendix H - Annual Report Final 2013 VGP Appendix H - Annual Report 33 CFR (g) (b) (b) (b) Final 2013 VGP Appendix J Effluent Biological Organism Monitoring Requirements and Effluent Limitations for BWTS using Active Substances Ballast Water Treatment System Recordkeeping & Reporting Courtesy Bio-Sea

17 ONBOARD MANUALS Ballast Water Operations & Technical Manual Safety System Operation, Controls Continuous Monitoring & Reporting Functional monitoring of BWTS System functional parameters Calibration of the monitoring equipment Data Logging & Reporting Training, Treatment, Monitoring & Compliance

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