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North American ECA What to expect from the Coast Guard?

North American ECA What to expect from the Coast Guard?. Lieutenant Sarah (Thibeault) Rodiño Port State Control U.S. Coast Guard Sector San Francisco 21 November 2013. North American Emission Control Area (ECA). Entry into force was 01AUG12. USCG referred 346 deficiencies to EPA

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North American ECA What to expect from the Coast Guard?

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  1. North American ECA What to expect from the Coast Guard? Lieutenant Sarah (Thibeault) Rodiño Port State Control U.S. Coast Guard Sector San Francisco 21 November 2013

  2. North American Emission Control Area (ECA) • Entry into force was 01AUG12 USCG referred 346 deficiencies to EPA (since entry into force)

  3. USCG ECA Deficiency Stats 2012 2.8% of inspections performed resulted in an ECA deficiency

  4. Annex VI ECA Examniations What can ship-owner/master expect? • Exam conducted by the Coast Guard • Part of normal/scheduled exam • Examination • Check records, logs, certificates • Spot check BDNs, fuel samples • Review non-availability reports • Communications of non-compliance • Be forthright and honest

  5. ECA Violations Note: all ECA violations will be reported to the EPA who may take enforcement action to include administrative penalties and judicial action

  6. ECA Violations Note: all ECA violations will be reported to the EPA who may take enforcement action to include administrative penalties and judicial action

  7. ECA Violations Note: all ECA violations will be reported to the EPA who may take enforcement action to include administrative penalties and judicial action

  8. ECA Violations • Administrative Deficiencies • MINOR • Crew did not properly document in the log book: • the volume of low sulfur fuel oils in each tank; • date & time • the position of the ship when fuel oil changeover operation was completed • MAJOR • Entry indicates changeover occurred prior to entering ECA • PSCO discovers changeover occurred after entering ECA Note: all ECA violations will be reported to the EPA who may take enforcement action to include administrative penalties and judicial action

  9. Fuel Oil Requirements Annex VI, Reg. 14 and 18: SOx & Particulate Matter (PM) and Fuel Oil Availability and Quality Shipboard Requirements Fuel Oil : Sulfur Content Caps Fuel Quality Standards Operations: Bunker Notes Bunker Samples Fuel Oil change-over procedures Fuel Oil change-over log-book entries

  10. Exemptions – Regulation 3.2 • Ship may be exempted from fuel sulfur limits to allow trials for development of new emission reduction/control technology or engine design improvements (e.g. conversion to LNG fuel, development of exhaust gas scrubber technologies). • USCG Headquarters Approval

  11. QUESTIONS? EPA-Non-Availability Reporting: https://cdx.epa.gov/ ECA Guidance: http://www.epa.gov/otaq/oceanvessels.htm • Coast Guard Guidance : • Homeport Annex VI web page: select the following links: Missions > Domestic Vessels > Domestic Vessel General > MARPOL ANNEX VI • CG-543 Policy Letter 09-01 (Annex VI Implementation) • CG-CVC Policy Letter 12-04 (ECA)

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