AWO Work on Tank Barge Emissions Transportation Research Board January 12, 2014
America’s Towing Industry Largest segment of the U.S.-flag fleet 6,000 tugboats and towboats, 27,000 barges Operate on inland waterways, Great Lakes, Atlantic, Pacific and Gulf Coasts
The American Waterways Operators Trade association for the tugboat, towboat and barge industry More than 300 member companies represent 80 percent of equipment in the U.S.-flag towing industry AWO Responsible Carrier Program creates standards for safety and environmental stewardship
Safeguarding Our Environment
National Ambient Air Quality Standards EPA sets the maximum ambient concentration for criteria pollutants via the National Ambient Air Quality Standards (NAAQS) States that don’t meet NAAQS must develop state implementation plan (SIP) to reduce emissions to meet NAAQS Review of barge emissions was initially driven by an effort to reduce area-wide emissions for compliance with the Texas SIP
Working Together to Reduce Emissions “HAWK” Camera overflights in 2005 in Louisiana and Texas suggested inadvertent emissions coming from tank barges AWO Tank Barge Emissions Working Group formed as a response to “HAWK” results – First Tank Barge BMP drafted in 2006 – Collaboration with USCG, TCEQ, LDEQ and CTAC
AWO Barge Emissions BMPs All BMPs can be grouped into one of three primary types – Manual effort applied to keep barge vapor tight – Equipment maintenance, compatibility and design – Load/Discharge procedures and operations
BMP Stakeholders Entities involved in implementing the BMPs – Barge owner/operator – Cargo owner – Tankering personnel (barge owner or 3 rd party) – Inspection companies (hired by cargo owner) – Shoreside facilities (load/discharge)
BMP Example Guidance Cargo Vapor Pressure – “Tighten and replace packing when necessary with appropriate material for the cargo being carried” (pg. 9) -Barge companies should apply sound preventative maintenance and inspection programs to ensure that the barge is capable of maintaining vapor tightness when loaded. -A well managed maintenance program will keep emissions equivalent to or less than what would be expected from a shoreside facility’s fugitive emission monitoring program -The type of inspection this BMP requires also improves the effectiveness of other BMPs as the company is also able to identify other potential maintenance/equipment issues before they occur
BMP Revisions AWO elects to revise BMPs in 2009 Intended to enhance BMP’s value as a living document and further reduce inadvertent emissions Revised practices must be practical for operators Must be supported by continued industry-agency coordination
TCEQ/USCG Study – Houston Ship Channel In 2007 AWO members partner with TCEQ and USCG to provide information on barges in a specific area of the Houston Ship Channel Fast response air monitor is used along with vessel position Results indicate that 5-10 percent of monitor alarms were caused by tank barge traffic
LDEQ Study AWO signed MOU with LDEQ in 2009 Study would measure the effect of barge emissions on Baton Rouge air quality Used the Houston Ship Channel model near a monitor just south of BR, LA due to HSC’s huge success LDEQ found only approximately 1.5 percent of emissions triggers were possibly attributable to tank barges
MSCHD Study AWO partnered with Memphis and Shelby County Health Department (MSCHD) in 2009 MSCHD study investigated potential inadvertent tank barge emissions on McKeller Lake in Memphis using the GasFindIR camera Barge emissions impact on air quality shown to be minimal
BMP Study with EHCAP AWO/TWOA partnered with East Harris County Air Partnership in 2011 to study effectiveness of BMPs while under way and while in fleet >250 barges were observed using the GasFindIR camera at ranges of 25 feet to 250 yards 1 barge out of 250 was observed to have inadvertent emissions AWO presented the results and the BMPSs to refineries and terminal operators
Lynchburg Ferry APWL Removal TCEQ creates air pollutant watch list areas where ambient chemical concentrations are high enough to require additional focus Lynchburg Ferry added to Air Pollutant Watch List (APWL) in 2002 for benzene and styrene
Lynchburg Ferry APWL Removal Barge industry worked with TCEQ and USCG to monitor emissions Barge operators employed AWO BMPs and began controlling emissions from barge cleaning As a result, benzene and styrene emissions were reduced such that in 2013, TCEQ announced it is removing Lynchburg Ferry from the APWL
Benzene Reduction
Lessons Learned Barge emissions studies results consistently document minimal impact to an area’s ability to comply with EPA NAAQS AWO must work proactively with state agencies and must emphasize use of sound scientific methodologies
Questions/Discussion Brian Vahey bvahey@vesselalliance.com (703) 841-9300
Recommend
More recommend
