2012 Ocean Ranger Guidebook Revision 3-7-12 - Alaska ...

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2012 Ocean Ranger Guidebook 3-7-12 Section 4: Visible Emissions, Air Quality General background: All marine vessels must comply with the air emission standard found at 18 ACC 50.070 while they operate in Alaska waters. Alaska is one of the few states that has regulations that include opacity (visible emissions from marine vessels. These regulations apply to all vessels regardless of size or type. The standard requires that visible emissions (opacity) from vessel smoke stacks be no greater than 20% opacity for three minutes while docked or anchored. There are exemptions on the “three minutes rule” while the vessel is maneuvering to/from anchor or port anchorage and for startup prior to departure. ADEC has been monitoring emissions from marine vessels since at least 1994. The Cruise Ship Program (CPVEC) took over monitoring of cruise ships under 46.03.488, while ADEC Division of Air monitors and enforces on violations for other marine vessels. ADEC uses opacity as a limit for marine vessel emissions 1 (and emissions from many shoreside emitters). EPA method 9 is used to determine opacity by visual means. CPVEC staff and an opacity contractor take Method 9 readings in all major Alaskan cruise ports, as well as some of the other Alaskan ports. In addition the US Forest Service monitors opacity in Tracy Arm and the National Park Service monitors opacity in Glacier Bay and other National Parks. In Glacier Bay National Park there is also a federal opacity regulation (36 CFR 13.65 (b)(4))which is similar to the Alaska regulations. 1 Emissions from combustion source may include NOx, Sox, PM, VOC etc. emissions in the context of opacity is visible emissions. NOVs 20 0 15 11 1 2 1 2 0 2 Figure 1: Low opacity from stack Cruise Ship Notice of Violations per Year 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 10 3 150
2012 Ocean Ranger Guidebook 3-7-12 In 2011 ADEC and its opacity contractor took 235 Method 9 readings of large and small cruise ships and ferries. CPVEC also receives public complaints regarding cruise ships and ferries. Eleven complaints were received in 2011. CPVEC also received 33 self-reports of excess emissions (under 18 AAC 50.240) from cruise ships. Ocean Rangers are not trained to perform opacity readings but have contributed significantly to the cruise programs opacity monitoring by reporting cases of heavy smoke, soot, and equipment failures. They have also documented many operators effectively and successfully minimizing emissions to meet the opacity limits. Opacity is a surrogate for air pollution. There are many types of air pollution, such as oxides of nitrogen, sulfur, and carbon, particulates, volatile organic components, and carcinogens. While it would be more difficult to measure all of these parameters, visible opacity is used to General opacity background information: Opacity is the reduction of transmitted light caused by particles, mists, or gases. It can be caused by partially burned fuel or ash from the combustion processes. Opacity was originally measured using the Ringelmann scale which used grids to compare to the opacity of the smoke. It only worked well with black smoke, and was replaced with EPA Method 9. The Ringelmann method did introduce the 20% limit, which was based on increasing the efficiency of combustion. The idea was that over 20% would show incomplete combustion. Method 9 is a visual method that requires training and certification. The method contains requirements that are designed to reduce potential bias. Because of the requirements for angles and distances from the stack it would be difficult to have Ocean Rangers perform opacity readings onboard. More information on opacity readings can be found in the reference part of this section. Subsection 1: Opacity (Visible Emissions); Air Quality Job Aid Item: 4.1.a Text: Stack emissions are minimized and monitored. Operational (combustion) procedures in place. (18 AAC 50.070) Background: Cruise Ships in Alaska often monitor air emissions using opacity meters (Continuous Opacity Monitoring System (COMS)) and with visual checks by video camera located on the stack or in person. Most ships have procedures on keeping emissions below the regulatory limit. Please note that opacity meters can be useful onboard, but may not match the visible opacity as there are many factors including calibration, equipment error, and levels alarms are set at. 151
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2012 Ocean Ranger Guidebook Revision 3-7-12 - Alaska ...

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