North American Emission Control Area - Blue Water Shipping
Enforcement Provisions CG-CVC U.S. Coast Guard ECA Job Aid CG-543 EPA EPA Policy Letter 12-04
Policy Letter 09-01 Interim Guidance Final Rule 75 Federal Register 22896 Under Annex VI MARPOL the North American Emission Control Area
(ECA) will become enforceable on August 1, 2012. On that day, the sulfur content of the fuel oil used onboard ships operating in this area may not exceed 1.00%. All vessels who operate in the North American ECA are required to be in compliance with the Annex VI ECA
fuel oil sulfur standard. It extends up to 200 nautical miles from the coasts of the United States and Canada.
It includes the eight main Hawaiian Islands. MARPOL Annex VI, Regulation 14 Two methods to comply Use of low sulfur fuel Equivalent Arrangement Method
utilized listed on IAPP Certificate Section 2.3 and 2.6 Exceptions Securing the safety of a ship or saving life at sea; Damage to a ship or its equipment. Exemptions OCS exploration.
All reasonable precautions were taken after the occurrence for the purpose of preventing or minimizing the emissions. The master must report to the certificate issuing authority.
Records must be on board The Coast Guard has agreed to work with the U.S. Environmental Protection Agency (EPA) to implement and enforce of the North American ECA standards.
The EPA has lead for ECA violations CG has lead on MARPOL Annex VI violations Operators may encounter situations where low sulfur fuel oil is not available for purchase. MARPOL Annex VI, Reg 18.2.4 requires
notification to be made to the flag Administration and to the competent authority of the relevant port of destination. EPA is responsible for receiving the US notifications. No waivers will be issued for Nonavailability. On June 26, 2012, the EPA published an
Interim Guidance on the NonAvailability of Compliant Fuel Oil for the North American Emission Control Area. The guidance includes the Fuel Oil NonAvailability Reporting, which is available on EPAs website at http://www.epa.gov/otaq/oceanvessels.ht m . Vessels
should submit a Fuel Oil Non-Availability Report to the EPA at [email protected] as soon as the vessel determines, or becomes aware, that it will be unable to procure and use compliant fuel oil in the North American ECA, but no later than 96 hours prior to entering the North American ECA. All
required information can be found on pages 5 and 6 of the Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North American Emission Control Area. MARPOL Annex VI Regulation 18.2 Present a record of the actions taken to
attempt to achieve compliance; and Provide evidence that it attempted to purchase compliant fuel oil and that attempts were made to locate alternative sources and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase. If a Coast Guard unit receives notification of non-availability from a foreign vessel,
they will direct the submitter to the EPAs web site to submit a non-availability report. The CG cannot and will not submit for the vessel. What to expect during exams Records to be inspected to determine
if the fuel oil used onboard the ship meets the standard. Bunker Delivery Notes Representative Fuel Oil Samples Fuel Oil Changeover Procedures Fuel Oil Changeover Logs Voyage Plans Record of changeover recorded in such log-book as prescribed by the
Administration. The volume of low sulphur fuel oils in each tank. The date, time, and position of the ship when any fuel-oil-change-over operation is completed prior to the entry into an ECA or commenced after exit from such an area. Written
procedures to show how/when the fuel oil changeover is to be done to ensure that only compliant fuel oil is burned within a designated ECA. Allow sufficient time for the fuel oil service system to be fully flushed prior to entry into an ECA. Show line up of tanks, piping and valves. Deficiencies
ECA Related EIAPP NOx technical code Fuel oil availability Fuel oil quality These will be forwarded to EPA for enforcement
Review records of actions taken and evidence of submission to Admin/EPA Request a corrective action plan signed by the master stating that compliant fuel oil is: scheduled to be received prior to departure scheduled to be received at the next U.S. port Not scheduled for purchase Gather
copies for forwarding to EPA Signed and stamped by master Annex VI Non ECA Deficiencies IAPP Bunker Delivery Notes / Fuel Samples Incinerator
Ozone Depleting Substances Volatile Organic Compounds Safety Management System Deficiencies regarding above are CG Issue and will be dealt with as normal PSC deficiencies Logical processes for inclusion in a
shipboard procedures and responsibilities for personnel regarding ECA requirements. Crew Competency/knowledge of ECA requirements Changeover Procedures Voyage Plans Where evidence of criminal liability on the part of the mariner, owner,
operator or other involve party of the ship is found intentional use of non-compliant fuel falsified log books The Coast Guard will conduct an investigation under the authority of 14 USC 89a (APPS) Information
on Fuel Oil NonAvailability Reporting, which is available on EPAs website at http://www.epa.gov/otaq/oceanvesse ls.htm Fuel Oil Non-Availability Report to the EPA at [email protected] PSC Arrivals Branch
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