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OCR for page 7
1
INTRODUCTION
When loading their cargo tanks, tankships and barges carrying vola-
tile liquids expel vapors, displaced by entering cargo or ballast. The
vapors contain volatile organic compounds (VOCs), which can exacerbate
respiratory conditions. Thus, the maritime emissions are part of the
larger national air pollution problem.
About 95 percent of tank vessel VOC emissions are from crude oil and
gasoline cargoes. About two-thirds come from inland barges, and the
remainder from tankships. These emissions amount to only about 0.2 per
*
An analysis of the impact of volatile organic compound emissions
from tank barges and tankships on ozone concentrations in port areas was
conducted by Booz-Allen & Hamilton, Inc. at the request of the American
Waterways Operators (Booz-Allen & Hamilton, Inc., 1987b).
The analysis shows that marine VOC emissions represent a small per-
centage of the total VOC emissions in four selected port areas--New
York/New Jersey, Houston, Philadelphia, and Los Angeles/Long Beach. In
three of the port areas, each of the largest ten point sources of VOCs
exceeded the total of all marine VOC emissions. Control of hydrocarbon
emissions from loading and ballasting operations would produce decreases
in VOC emission levels in the four port areas of from 0.03 to 2.3 per-
cent. Furthermore, analysis of wind direction during exceedances indi-
cates that marine sources do not normally contribute pollutants toward
ozone monitors during days of nonattainment conditions. Of the four
ports evaluated, only the New York/New Jersey area could possibly expect
any measurable reduction in ozone levels if emissions during marine
transfer operations were controlled. In contrast, the Los Angeles/Long
Beach and Philadelphia marine VOC emission levels are very low in compar-
ison to total VOC emission levels. Marine emission levels in Houston
were higher than Los Angeles/Long Beach and Philadelphia, but prevailing
wind conditions indicate that the marine VOC emission sources were not
contributing to nonattainment levels. The analysis concludes that,
"Marine tank vessel operations are a minor contributor of VOC emissions,
particularly when viewed in context of automobiles and major industrial
sources. . . . [I]n the ports of New York/New Jersey ? Houston, Philadel-
phia and Los Angeles/Long Beach, controlling marine emissions would have
no or minimal impact on measured ozone levels and exceedances."
7
OCR for page 8
8
cent of all volatile organic vapor emissions nationally; they are about
one-tenth as great as vapor emissions from automobile fueling (EPA,
1986~. However, they may be significant locally.
Under current air quality regulations, emissions from tank vessels
are generally not subject to controls. However, several states, in
order to meet federal air quality standards for ozone, are considering
controls (see Appendix B). The national standard for ozone is not being
met in most large centers of population, and the statutory deadline for
attainment is December 31, 1987. Areas in nonattainment by that date
will be required to submit plans for additional control of volatile
organic compound emissions. Figure 1-1 shows the ozone nonattainment
areas by county. In general, heavily populated areas fail to meet the
standards. In attainment areas, new source review requirements being
considered in some states may involve vapor emission controls for new
terminals.
Technology for controlling vapor emissions from marine cargo loading
is available and in use for some cargoes. Vessels and marine terminals
that load liquefied natural gas, acrylonitrile, and other hazardous
fluids (and a few that load crude oil or gasoline in areas of strict air
quality control) routinely capture and reuse or dispose of vapors emit-
ted during cargo operations, piping the vapors to incinerators, flares,
or recovery systems. Safety devices are employed to prevent or limit
the effects of fires and explosions.
Controlling vapor emissions from gasoline and crude oil loading
would require extending this practice broadly. Processing flammable
vapors could present an added hazard at barge and tankship terminals,
and would entail substantial investments by the tank vessel and terminal
industries. These prospects have raised concerns on grounds of both
safety and economic impact.
Regulations being considered in several states would require loading
terminals to install and operate systems for piping hydrocarbon vapors
to recovery or disposal equipment. Vessels, too, would be retrofitted.
Installing and operating these systems could challenge the engineering,
operational, and training standards of some sectors of the industry,
especially at the lower technology end of the scale, such as inland
barges and small product terminals. The drive to clean up the air in
this instance raises a potential conflict of national interest between
air quality, as regulated by the U.S. Environmental Protection Agency
(EPA) and the states, and operational safety, the primary concern of
industry and the U.S. Coast Guard.
LAWS AND REGULATIONS CONCERNING
AIR QUALITY AND MARITIME SAFETY
The Clean Air Act and the States
The federal Clean Air Act (CAA) of 1970, as amended, created the
basis for a cooperative federal and state program to control air pollu-
tion. Under the act, National Ambient Air Quality Standards (NAAQS) are
established by the EPA for certain "criteria pollutants." For areas not
OCR for page 9
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10
in attainment of a standard, each state must develop and enforce a State
Implementation Plan (SIP), with specific emissions limitations to meet
the standard by statutory deadlines.
Ozone in the lower atmosphere is one of the criteria pollutants,
with a compliance deadline of December 31, 1987, and several states are
now considering regulating sources of volatile organic compounds. VOCs,
mainly hydrocarbon vapors, are precursors of ozone. Among the sources
being considered for control are marine terminals serving tank barges
and tankships.
Marine vessels, unlike other mobile emission sources such as auto-
mobiles, are not expressly regulated by federal air quality legisla-
tion. The extent of EPA's power to regulate the emissions of so-called
mobile sources indirectly, by attributing them to their stationary
gathering points (in this case, marine terminals), is not explicitly
defined. It is unclear whether EPA may require states to regulate
indirectly marine vessel emissions. In the absence of explicit gui-
dance, some states have determined that loading and ballasting emissions
from vessels can be attributed to the adjacent shore facility.
However, the CAA does not preclude states from doing so in a SIP.
(Appendix C discusses the CAA and related legal and policy issues as
they apply to the control of hydrocarbon vapor emissions from tankships
and barges.) Under the pressure of the ozone deadlines, and the severe
penalties for nonattainment, several states are considering this step.
Coast Guard Authority in Marine Safety
The U.S. Coast Guard, under the Port and Tanker Safety Act (PTSA) of
1978 (33 USC section 1221-31 and 46 USC chapter 37) and other statutes,
has clear and comprehensive responsibility for marine safety and for
preventing the pollution of water by vessels. Under this authority, the
Coast Guard regulates the design, construction, repair, maintenance,
operation, and manning of tank vessels.
The Coast Guard, except to a limited degree, has no specific regula-
tions in place to address the safety of vapor control devices on board
tank vessels, although it does approve and inspect vapor recovery equip-
ment under its general regulatory and inspection authority. The Coast
Guard has general authority to review and approve the safety aspects of
shoreside facilities at terminals. It may shut down terminals whose
operations are identified as unsafe.
Vapor control regulations might apply equally to both domestic and
foreign vessels visiting a port in which controls are in force. There-
fore, issues of national uniformity and deference to international
regulation require careful consideration.
ESTIMATING EMISSIONS
To estimate emissions of VOC vapors from maritime sources, it is
necessary to develop an understanding of the marine terminals and
vessels that handle petroleum cargoes, and of the cargoes themselves.
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11
Sources of Emissions
When liquid cargo is loaded into a tank, some vaporizes into the
tank atmosphere. As the tank is filled, the vapors are displaced and
forced out of tank vents. The displaced gases contain the VOC vapors of
the cargo being loaded and vapors from the previous cargo, if the tank
was not purged of gas or "gas-freed" since the last time it was loaded.
A cargo tank that has undergone crude oil washing (see Chapter 2)
releases more vapors than a tank that has not. Figure 1-2 illustrates
the emission of vapors while loading.
ULLAGE
HATCH~:
VAPOR TO
ATMOSPHERE
_ PRESSURENACUUM
l VALVE ,-
_ ~I
it_ IGS OR Vim HEADER ~-
~_ ~ CARGO LOADING HEADER -
:; )~d
...' , , . 1 1
VAPORS
· t.t-1.1.1...1.:1.1:1:I:t..l
FIGURE 1-2 Emissions from cargo loading.
Vapor emissions from tankship ballasting are also of some concern,
although diminishing in importance. After unloading, many tankships
travel without cargo. For stability, they must carry water as ballast.
When ballast water is loaded into cargo tanks full of vapor from the
preceding cargo, the vapor is displaced and emitted in much the same way
as in loading cargo. Most tankships built since 1980 are required by
domestic law and international agreement to use segregated ballast tanks
and thus do not emit vapors during ballasting. Older and smaller tank-
ships remain unaffected by the requirement. Inland barges do not carry
ballast.
VOC vapors are also released by tank "breathing," the result of
pressure changes in the cargo tank owing to changes in temperature.
These emissions are small, and they occur mainly away from ports while
vessels are underway, or, in the case of barges, while they are
fleeted. Small vapor emissions also occur during cargo gauging, when a
hatch cover is opened to permit inspectors to measure the cargo; no
attempt was made to calculate this small amount of emissions.
-
Emissions from unloading are not addressed in this report because
emissions from unloading tank vessels are released, if at all, on
shore. These emissions are subject to state regulation and licensing.
OCR for page 12
12
TABLE 1-1 EPA Emission Factors in Pounds Per 1,000 Gallons of Liquid
Loading Operations
Emission Source Ships Barges Tanker Ballasting
Gasoline 1.8 3.4 0.8
Crude oil 0.61 1.0 1.2
JP-4 0.5 1.2 Unknown
Kerosene 0.005 0.013 Unknown
Distillate oil no. 2 0.005 0.012 Unknown
Residual oil no. 6 0.00004 0.00009 Unknown
Source: U.S. Environmental Protection Agency (1985~.
Facilities that clean cargo tanks are also sources of vapor
emissions. These facilities are outside the scope of this study.
Emission Factors
Emissions of VOCs are estimated by multiplying the amount of liquid
cargo loaded by an emission factor, generally expressed in pounds per
1,000 gallons of liquid. Emission factors have been developed for many
organic compounds. Table 1-1 summarizes typical emission factors devel-
oped by the U.S. Environmental Protection Agency (1985) and given in the
agency's AP-42 publication. Table 1-2 lists additional emission factors
from Scott Environmental Technology, Inc. (1981~. The difference in
emission factors between tankships and tank barges is due to differences
in tank configuration. Tankship tanks are deeper and have less surface
area; consequently less cargo is evaporated.
Vessel Population
Tank vessels include both tankships, which are self-propelled, and
tank barges, which are not. Aside from some oceangoing barges and a few
oceangoing integrated tug-barge combinations, the tank barges generally
ply the inland waterways of the United States. The tankships other than
for petroleum importation are used mainly in coastal traffic, since
almost no petroleum is exported.
Tankships in active trade in and with the United States range in
size from less than 1,000 deadweight tons (dwt) to 406,000 cwt. Data on
tankships holding active U.S. Coast Guard certificates of inspection or
compliance (necessary documents for entry into U.S. ports) at the end of
1986 show 152 U.S.-flag tankships of more than 20,000 dwt trading in
U.S. waters (9.4 million dwt) as well as 990 foreign-flag tankships of
more than 20,000 dwt (77.3 million dwt). In 1986 there were only 81
OCR for page 13
13
TABLE 1- 2 Scott Environmental Technology Emission
Factors in Pounds Per 1, 000 Gallons of Liquid
Product
Benzene
JP -4
JP-5
Kerosene
Mixed chemicals
Lube oil
Naphtha
Distillate oil
Loading/Ballast Emissions
1.0
0.6
0.005
O.005
0.005
0.005
0.3
0.3
0.005
Source: Scott Environmental Technology (19811.
U.S.-flag tankships of less than 20,000 dwt, whose total tonnage of
240,000 dwt reflects the very small size of many of these vessels.
In 1986, 3,968 barges in the United States were certificated to
carry subchapter D cargoes (generally flammable liquids , including crude
oil and gasoline) or both subchapter D cargoe* and subchapter O cargoes
(chemicals with hazards beyond flammability). Inla*d barges gener-
ally range in size from 10, 000-40, 000 barrels (bbl).
U.S. and international regulations require most tanksh~ps to have
segregated or clean ballast tanks. (The amount of ballasting emissions
depends on the amount of ballasting in uncleaned cargo-tanks.) They
require most ships to have inert gas systems to charge the atmosphere
above the cargo with a nonreactive gas as a safety measure. The gas
piping of inert gas systems can be used as a vapor header, through which
cargo vapors could be piped to vapor recovery or disposal units. It can
also be used in transferring vapors from tank to tank during ballasting,
thus limiting emissions (see Chapter 21. Figure 1-3 is a diagram of the
international regulatory requirements.
U.S. regulations incorporate and implement international regula-
tions, and, because of a U.S. statutory provision, are somewhat more
stringent in their requirements for existing product tankships of
*
The terminology refers to the subchapters of Title 46, Code of
Federal Regulations (CFR), under which liquid cargo is regulated when
carried in bulk on a vessel. Subchapter D is found in 46 CFR parts
30-38, and subchapter O is in 46 CFR parts 150-154. Subchapter D covers
roughly 400 liquid and liquefied gas cargoes having only the hazard of
simple flammability. Subchapter O covers approximately 300 liquid and
liqu*fied gas cargoes having hazards beyond simple flammability.
Approximately seven barrels are equivalent to one cwt.
OCR for page 14
1979 1980 1981 1982 1983 . 1984 1985 1986
New Tankers
Existing Tankers SOLAS/Safety-IGS Requirements
F.xl~tlng crawl (-() I~ci`~-t
Feinting, ~ retain ~r`,tiu~ t - 4()-, () kJ`` t
[:`l~ting cretin rebut t , () ~ l~ti`vt
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MARPOL/ Pollution, CBT, SBT, COW Requirements
[:xlsting crud`. 4~)-, (l kill`` t
:xl~ting t~rocluct 4() - k~iv~t
.. an. ~ ..~... .
invites IMO
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flag once Inert state requirement US/UK O IMO O
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]~)J2fl983 {::8If :: 10/2/1981
SBT or COW SBT or COW
lOf2''l983 ~10/2~1985
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.
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. ~C,5 I always r uired ·~h~n C OW i!; Alps ratted ·~l~ the at H(V\'N1 near hi ~-emptecl It Installation In unrta ~ noble and Impractical · 'Requirecl only ll tittec] health TIC cowl
stin'2 crucJe (,r F,r( duct tanker ()`er 7() 1~1^t tor `` huh th. . ret r \`dS ~,ldcec] att'r lo 31, ~ . r the deal 1.ll.1 att. r h A) ,h `,r clell`cred alter 12 ~l, ~ must h biro\ lded ~ 1th bBl In a-ran..
with Regulation 1 l ( 1, SlARI'( ll l'roto<-ol 1978 t lapa n en t`,rce~i tht same requ lrements n l Ilil8; t tO'I discharge monitoring and cat ntrol ss stem requ lred late 14t\~
FIGURE 1-3 Tanker safety and pollution prevention design requirements.
Source: Exxon Marine, 1987.
LEGEND: SBT (segregated ballast tank). When a tanker discharges its
cargo, it must take on ballast water to maintain a seaworthy condition.
Under present regulations, ships take water into empty cargo tanks.
Before the ship reloads, the ballast water is discharged either into
shore reception facilities or as clean ballast after a load on top (LOT)
operation. SBT requires sufficient tanks for carrying only ballast
water so that under ordinary circumstances ballast water does not enter
the cargo tanks. As the chart shows, this measure was adopted for
newbuildings.
PL (protective location). With the PL concept, SBTs are placed in
selected areas of the vessel where it is believed they can provide a
OCR for page 15
15
degree of optimum protection for the ship's crew and cargo in the event
of a grounding or collision.
CBT (clean ballast tank). In existing ships, CBTs are cargo tanks
dedicated to carrying ballast. As the chart shows, this option was
available for existing tankers only during the specified interim, until
the SBT became mandatory. Although similar in concept to SBTs, CBTs do
not require separate pipes and pumps for taking on and discharging
ballast.
COW (crude oil washing). COW is the cleaning of cargo tanks with
high-pressure jets of crude oil while the ship is discharging. The
crude oil pumped through the ship's tank washing machines acts as a
cleaning agent and removes oil residues, which are then pumped ashore
with the cargo. COW requires the installation of fixed-in-place washing
machines and IGS.
HCWM (high-capacity washing machine). HCWM is a tank-cleaning
machine with a capacity of 60 cubic meters per hour or more.
IGS (inert gas system). IGS permits a ship to maintain an inert,
that is, nonflammable, atmosphere in cargo tanks. In a typical system,
boiler flue gas is cleaned, cooled, and pumped to tanks. Although hydro-
carbon vapors might also be present in the tanks, oxygen levels in the
inert gas are too low to support combustion.
LOT (load on top). LOT is a system based on the principle that when
oil and water mixtures are left standing, the oil separates and rises to
the top. The heavier clean water at the bottom can be drawn off and
returned to the sea; oil and water mixtures that remain are transferred
to a slop tank. After a period of time, the mixtures separate further,
and clean water can again be removed from the bottom of the tank. At
the next loading port, new cargo is loaded on top of the reclaimed oil
in these tanks. LOT, in use for many years, has contributed signifi-
cantly to the reduction of operational pollution from tankers.
20,000-40,000 cwt. Domestic product tankships of this size range, and
foreign product tankships visiting the United States, must have segre-
gated or clean ballast tanks by January 1, 1986, or by the date on which
the vessel is 15 years old, whichever is later.
Figures 1-4 and 1-5 show the numbers of vessels affected by these
domestic and international regulations.
Trade
The committee estimated the volumes of relevant liquid cargoes
loaded in U.S. ports to determine which cargoes make the most important
contributions to vapor emissions. Tables 1-3, 1-4, and 1-5 summarize
data from the U.S. Army Corps of Engineers on the 1984 transport of
crude oil, oil products, and chemicals in the United States.
Most U.S. harbors are too shallow to admit large tankships. At
these harbors, large ships must remain outside and off-load to a series
OCR for page 16
16
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SBT
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20-40 40-70 Over 70 20-40
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Existing New, from 1979-1982
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1 t~s~: ::.::. ::::.-:-:':.: :,.: :;.:;.:. :-:;.:. .-:.-:.1
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Under 15 yrs old
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SBT
20-40 40-70 Over70 Over30 MDWT
MDWr MDWI MDWr
Existing New, from 1978-1982
Oil/Product
SBT or
SBT or OthQr SBT or
other ~ other at SBT or
other
20-40 40-70 Over 70
MDW1 MDWT MDWT
20-40 40-70 Over70
MDWT MDWT MDWT
Existing New, from 1978-1982
New, after 1982
Under 15 yrs old
Over 15 yrs old
SBT
Over 20 MDWT
New, after 1982
FIGURE 1-4 U.S.-flag tankships in compliance with U.S. safety and
pollution-prevention requirements. Source: Based on U.S. Coast Guard
data.
OCR for page 17
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Crude Oil
SBT or SBT or SBT
Under t5 yrs old
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20-40 40-70 Over70 20-40 40-70 Over70 Over20 MDWT
MDWT MDWr MDWT MDWT MDWT MDWT
Existing New, from 1980-1982 New, after 1982
Product
SBT or
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1 5 yrs
SBT or SBT o'
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_ ~ ~ ~; ~,, t ~
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1~; vre other
20-40 40-70 Over70 20-40 40-70 Over70 Over30 MDWT
MDWT MDWT MDWT MDWT MDWT MDWT
Existing New, from 1980-1982 New, after 1982
*Note Scale Change
FIGURE 1-5 Foreign-flag tankships (trading at U.S. ports) in compliance
with safety and pollution-prevention requirements. Source: Based on
U.S. Coast Guard data.
OCR for page 22
22
Loading Ports for Domestic Oil and Gasoline
Tables 1-7 and 1-8 list loading volumes of crude oil and gasoline,
respectively, at U.S. ports loading more than 100,000 tons per year for
domestic shipping. These ports account for more than 98 percent of
crude loadings and 95 percent of gasoline loadings in domestic trade.
The tables also give the ports' ozone attainment status.
Tables 1-9 and 1-10 summarize the data by state. As the tables
show, the only states where ports in nonattainment for ozone load more
than 5 million tons of crude oil and gasoline annually are Texas, New
York, Louisiana, and California.
Loading Ports for Crude Oil and Gasoline Exports
Table 1-11 is a list of all U.S. ports that export gasoline. None
is in attainment of the ozone standard. Almost no crude oil is exported
from the United States.
Table 1-12 lists all U.S. ports loading more than 1 million short
tons of crude oil or gasoline, with their ozone attainment status.
Exports of gasoline and crude oil are less than 1 percent of the total
loadings for domestic movement of these cargoes.
FOCUS FOR ASSESSMENT
The foregoing estimates show that 95 percent of the VOCs emitted
from marine cargo handling are associated with loading crude oil and
gasoline at marine terminals. Accordingly, the committee focused on
those cargoes and operations.
OCR for page 23
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OCR for page 29
29
TABLE 1-9 Domestic 1985 Crude Oil Movements by State with 1985 Ozone
Nonattainment Status of Loading Ports Handling More Than 100,000 Short
Tons
Percentage of Loadings
State Nonattainment Attainment Total Short Tons
Areasa Areas (thousands)
Alabama 9372, 489
Alaska 100101,237
California 594112,795
Delaware 1008,155
Florida 100 659
Illinois 100 809
Louisiana 326821,845
New Jersey 100 197
New York 100 961
Ohio 100 743
Puerto Rico 100483
Texas 49517,048
Virgin Islands 100283
Total 157,704
aLoadings in nonattainment areas are about 23.5 percent of total.
OCR for page 30
30
TABLE 1-10 Domestic 1985 Gasoline Movements by State with 1985 Ozone
Nonattainment Status of Loading Ports Handling More Than 100,000 Short
Tons
Percentage of Loadings
State Nonattainment Attainment Total Short Tons
Areas Areas (thousands)
Arkansas 100304
California9192,082
Connecticut100 40
Delaware100 1,315
Hawaii 100196
Illinois68321,421
Indiana55451,109
Louisiana9379,297
Massachusetts100 318
Minnesota 100785
Mississippi 1002,784
Missouri100 13
New Jersey100 1,557
New York99123,117
Ohio100 624
Oregon100 489
Pennsylvania29712,458
Puerto Rico 100614
Tennessee100 317
Texas100 17,175
Virginia 1001,268
Virgin Islands 1001,336
Washington59S4,881
Total 73,989
aLoadings in nonattainment areas are 78.8 percent of total.
OCR for page 31
31
TABLE 1-11 Gasoline Exports by Porta
Gasoline Gasoline
Exports Exports
Port (tons) Port (tons)
California Michigan
Long Beach8,957 Detroit82
Los Angeles69 Saginaw186
Suisun Bay33,608 Total268
San Francisco41
San Pablo6,315 New Jersey
Carquinez48,796 Camden150
Strait Total150
Oakland255
Total98,091 New York
Albany45
Florida New York23,521
Port Everglades1,394 Total23,566
Palm Beach225
Miami227 Pennsylvania
Total1,846 Philadelphia173
Total173
Louisiana
New Orleans7,321 Puerto Rico
Lake Charles254 San Juan10,298
Total7,575 Total10,298
Maryland Texas
Baltimore1,220 Texas City462
Total1,220 Houston137,124
Corpus Christi70,362
Massachusetts Port Arthur17,682
Boston8,998 Freeport14,650
Total8,998 Total240,280
aNational total for gasoline exports is 392,455 tons
Source: U.S. Army Corps of Engineers data for 1985
.
OCR for page 32
TABLE 1-12 Ports Loading More Than 1 Million Tons of Crude Oil and
Gasoline Annually, 1985
1985 Ozone Loadings
Attainment (thousands of
Port Statusa tons)
Alabama
Mobile N 2,318
Alaska
Valdez A 99,625
Kenai A 1,177
Delaware
Lower Delaware Bay A 8,155
California
San Francisco N 3,949
Carquinez Strait N 1,300
Morro Bay A 4,270
Santa Barbara Channel Islands N 2,048
Suisun Bay N 1,100
Illinois
Madison County N 1,777
Louisiana
Baton Rouge
Cameron Parish
Destrehan
Lake Charles
New Orleans
Ostrica
Plaquemine Parish
Red and Atchafalaya Rivers A
Terrebonne Parish
Vermillion Parish
N
A
N
N
N
A
A
A
A
Mississippi
Pascagoula
A
New York
Upper Bay N
New York N
New York and New Jersey Channels N
3,158
2,926
1,964
2,952
1,383
3,130
2,006
1,194
2,011
1,312
2,784
2,276
13,434
7,949
Pennsylvania
Marcus Hook A 1,747
Texas
Beaumont
N
N
N
N
N
Corpus Christi
Houston Channel
Houston
Texas City
Port Isabel and vicinity A
Virgin Islands
Chris tians ted
A
2,900
7,428
3,206
2,137
2,870
3,125
1,620
aN = area in nonattainment for ozone; A - area in attainment.
Representative terms from entire chapter:
crude oil
