This paper was prepared for presentation at the SPE / APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production. The Serepca-1 was a Suezmax type oil tanker, built in 1974, and converted into a floating storage and offloading unit (fso) in 1984. The ship was a significant source of raw material and contained waste that could turn her dismantling into both a human health and environmental hazard.
This paper was prepared for presentation at the SPE / APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production. The Serepca-1 was a Suezmax type oil tanker, built in 1974, and converted into a floating storage and offloading unit (fso) in 1984. The ship was a significant source of raw material and contained waste that could turn her dismantling into both a human health and environmental hazard.
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This paper was prepared for presentation at the SPE / APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production. The Serepca-1 was a Suezmax type oil tanker, built in 1974, and converted into a floating storage and offloading unit (fso) in 1984. The ship was a significant source of raw material and contained waste that could turn her dismantling into both a human health and environmental hazard.
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Attribution Non-Commercial (BY-NC)
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Baixe no formato PDF, TXT ou leia online no Scribd
Decommissioning of a FSO Containing Hazardous Waste: A Successful
Story Claude-Henri Chaneau, J ean-Claude Bourguignon, Guillaume Goubard, Pierre Bang, Total E&P, Philippe J ean PJ N consulting, Benoit Lefebvre, SITA France, Tom Peter Blankestijn, Sea2Cradle and Emmanuel Tambe Ayuk, SNH Copyright 2012, SPE/APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production
This paper was prepared for presentation at the SPE/APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production held in Perth, Australia, 1113 September 2012.
This paper was selected for presentation by an SPE/APPEA program committee following review of information contained in an abstract submitted by the author(s). Contents of the paper have not been reviewed by the Society of Petroleum Engineers or the Australian Petroleum Production & Exploration Association Limited and are subject to correction by the author(s). The material does not necessarily reflect any position of the Society of Petroleum Engineers or the Australian Petroleum Production & Exploration Association Limited, its officers, or members. Electronic reproduction, distribution, or storage of any part of this paper without the written consent of the Society of Petroleum Engineers or the Australian Petroleum Production & Exploration Association Limited is prohibited. Permission to reproduce in print is restricted to an abstract of not more than 300 words; illustrations may not be copied. The abstract must contain conspicuous acknowledgment of SPE copyright.
Abstract The Serepca-1 was a Suezmax type oil tanker, built in 1974, and converted into a floating storage and offloading unit (FSO) in 1984. She was moored off the coast of Cameroon and ceased her oil storage activities in 2007. The end-of-life of any tanker has economic, environmental and social implications. Various environmental surveys were made to identify hazardous materials and to produce the ship's Green Passport. The FSO was a significant source of raw material and contained waste that could turn her dismantling into both a human health and environmental hazard. An initial decontamination prior to ship export for dismantling was performed offshore. A specialised contractor removed, conditioned and safely stored hazardous materials such as mercury and PCB containing transformers. These wastes were exported to European waste disposal facilities under Basel Convention regulations. It was revealed as the best technical and regulatory approach and was made possible thanks to the Green Passport. The ability of several international shipyards to dismantle the FSO, and dispose of other hazardous wastes in conditions ensuring human health and environmental protection, was evaluated through technical and HSE audits. The shipyards included those listed by the European Commission Directorate and other yards evaluated by international organisations and having demonstrated a proactive approach in terms of environmental protection, occupational safety, health care and dialogue with the local population. Finally, the FSO was exported to a Chinese shipyard under Basel Convention regulations. This paper's objective is to present the environmental approach applied to this FSO's end-of-life, and explains the choices behind her offshore decontamination and subsequent dismantling in China. Total E&P chose a transparent pro-active project communication strategy. The company contacted and regularly discussed the project with the Ship Dismantling Platform, a major NGOs active in the area of ship dismantling.
Introduction The Serepca-1 tankers oil storage activities ceased in May 2007, and it is in this context that a full decommissioning project was set up. The Serepca-1 was a former oil tanker, built in 1974. In 1984, she was converted into a floating storage unit (or FSO), and positioned in the Biafra bight, off the coast of the Republic of Cameroon. Its 14 tanks stored Kol crude oil, extracted from the Rio del Rey oil field. However, given the oil tankers age, Company Rules, the company has decided to replace her. The end-of-life of any ship, and particularly that of an oil tanker, has economic, environmental and social implications (Knapp et al. 2008; Chang et al. 2010). Given the large quantity of steel contained in her structure, an oil tanker constitutes a significant source of raw material. The elimination strategy selected, however, can turn such a tanker and the various polluting, toxic or inflammable substances onboard, into both a human health and an environmental hazard (Chang et al. 2010). The greatest difficulties are encountered with the oldest ships, as they contain many substances that are now forbidden, such as asbestos or PCBs (Polychlorobiphenyls). Other examples of hazardous materials often found onboard include the heavy metals contained in paints, ship-born chemicals, hydrocarbons, gases and the residues contained in ships tanks. Several decontamination phases must be carried out in perfect sequences prior to any dismantling operation in order to prevent environmental and human health risks. When one looks at the international situation, one sees that, during the last 2 SPE 157017 two dozen years, most of the worlds commercial and war ships have been sent to developing countries, to be dismantled in conditions damaging to the environment and human health. The evolution of environmental regulations in the OECD countries during the 1980s caused the cost of hazardous waste disposal operations to increase in industrialised countries. As a result, hazardous wastes have been exported to developing countries where environmental regulations were less thorough. It is in reaction to this situation, that the international community implemented the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (1989). The United Nations Environment Program (UNEP) administered the Convention. The Basel Convention has nonetheless proved insufficient in the case of ship dismantling as there is debate as to whether the concept of waste can be applied to a ship (Moen 2008). Consequently, each year, between 200 and 600 large end-of-life ships are dismantled and recycled on the tidal beaches, with damaging impacts upon the environment and local populations (DNV 2000; ILO 2001; Tewari 2001; ILO 2004; Gkdemiz et al. 2012a, 2012b). Indeed, the absence of safety and environmental protection measures, led to large numbers of accidents on the dismantling sites, significant health risks for workers and neighbouring populations, and pollution of coastal areas (DNV 2000; ILO 2001; Neser et al. 2012a, 2012b). Various international authorities have produced guidelines that provide recommendations for ship dismantling (DNV and Appledore Int. 2000; EPA 2000; COWI and HHI 2007). However, none of these guidelines were legally binding. In 2007, a draft convention, (future Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009), was currently under preparation by the International Maritime Organisation (IMO) to remedy this situation and to provide an appropriate legal framework. This convention was then adopted during the diplomatic conference held in Hong-Kong, China from the 11 th to the 15 th of May 2009. Ship dismantling issues have never been as sensitive as they are now, and this is a time of significant regulatory shifts. It is in this context that the Rio del Rey partnership, represented by Total E&P Cameroun, envisaged the Serepca-1 tankers end-of- life. Five alternatives were initially considered: sale of the ship as is, where is , conditional sale, conditional sale following removal of specific hazardous materials, agreement of a dismantling contract with a yard, and immersion. This papers objectives are to demonstrate how the decommissioning project analysed these alternatives in the light of several criteria, in particular environmental and social impacts and, in accordance with the good practices and standards and, how the Project implemented the best strategy to dismantle the FSO in a sound way. The project started in 2007 and ended in 2009, with the deconstruction of the Serepca-1.
Materials and methodology The Serepca-1 The Serepca-1 (SR1) was built in 1974 by Howalds Werke Deutsche Werft AG (Hamburg, Germany). The ship, registered in Poland under the name Kasprowy Wierch , first intended use was as an oil tanker. She was a single hull, Suezmax type ship with a 284 meters overall length (LOA), a 21380 tons lightweight, and a 15.7 meters maximum draft. The vessel had a storage capacity of 956000 barrels and provided accommodation for up to 65 passengers. Her central section was occupied, from the main deck to the bunker, by 14 storage tanks (4 central tanks, 5 port tanks and 5 starboard tanks), the purge tank (water cell) and the slop tank. There was no separate tank for ballast waters (Fig. 1). The ship was acquired in August 1983 by the Socit dEtudes et de REcherches Ptrolires du CAmeroun (Serepca company). Serepca became Elf Serepca in 1958, and then Total E&P Cameroun following the merger between TotalFina and Elf Aquitaine in 2000. The ship was registered under the Republic of Cameroons flag. In 1984, the Compagnie Marseillaise de Rparation (CMR) converted the ship into a Floating Storage Offloading unit (FSO), registered as the Serepca-1 .The Serepca-1 was moored (with eleven 4-inch attachment hooks fixed onto rammed pilings) in the Rio del Rey offshore production basin, in the Biafra Bight, off the coast of the Republic of Cameroon. The Rio del Rey Basin is situated 80 nautical miles from Douala, and 10 nautical miles south of the Bakasi peninsula, next to the Nigerian border. Its surface area is 600 km. Seawater depth is approximately 4.5 meters to the north of the basin, 35 meters to the south, and 22 meters beneath the Serepca-1. FSOs are generally used in offshore oil fields, as an alternative to the routing of oil to the coast via pipelines. Production platforms transferred the crude oil to the FSO for storage until it could be unloaded in a commercial tanker. In 1998, the SR1 underwent major transformations performed by the ship repair company Lisnave (Portugal) during dry docking operations. At that time it was decided to remove its propulsion units because the FSO was anchored all time and operations did not require her to move. The activities for crude oil storage ceased completely in May 2007. Up until the end of 2007, the ship provided accommodation for the teams working in the Rio del Rey Basin. Crude was then rerouted from the production platforms to a new Suezmax tanker for storage. Regulatory framework within the 2007-2009 period The ship dismantling regulatory framework was not precisely defined in the 2007-2009 period, even though various authorities have produced several ship dismantling studies (Hamzah 2003; Moen 2008). Several guidelines , from the International Maritime Organisation (IMO), International Labour Organisation (ILO), the Conference of Parties to the Basel Convention (BC), the International Chamber of Shipping (ICS) and from the Draft of the 2009 IMO Convention, have proposed objectives (ILO 2004; IMO 2003, 2004, 200,5 2006; Commission of the European Communities 2007, MEPC 2007). However, none were legally binding. Significant efforts were made to reach an international consensus on a common convention providing the legal framework for sound ship recycling (Moen 2008; Chang et al. 2010). However, many areas SPE 157017 3 that are directly related to dismantling operations were regulated (Hamzah 2003). These areas include: marine pollution prevention, waste transport and treatment, labour law The Basel Convention, for example, is a major text that regulates the transboundary movements of hazardous wastes (Moen 2008). The Republic of Cameroon has included itself in the following international conventions and is equipped with the following national regulatory texts: - The United Nations Convention on the Law of the Sea (UNCLOS). - The International Maritime Organisation (the IMO having produced Guidelines on Ship recycling ). - The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, and its African counterpart, the Bamako Convention. - The1996 Law relating to Environmental Management in Cameroon (the Environmental Code). - The 1999 Petroleum code and the 2002 Gas Code. - The 2000 Law relating to Maritime Areas of the Republic of Cameroon. - The 2005 Decree governing Environmental Impact Assessments. The guidelines for the ship dismantling. In the last decade, several major international authorities worked on and issued a number of directives. The first well-structured approaches dated back to the year 2000, and were initiated by Det Norske Veritas. This independent foundations work in the area of ship inspection and classification is internationally recognised. Several other guides followed, in particular the Guide for Ship Scrappers issued by the United States Environmental Protection Agency (US EPA) and the Industry Code of Practice on Ship Recycling issued in 2001 by the Industry Working Party on Ship Recycling. This working group was established under the co-ordination of the International Chamber of Shipping (ICS) in February 1999 in response to growing concerns expressed by governments, environmental groups and the industry itself regarding the legal, labour and environmental facets of ship dismantling. The Party comprised representatives from several international associations of tanker owners and ship owners, such as INTERCARGO or INTERTANKO, the Baltic and International Maritime Council (BIMCO) and the Oil Companies International Marine Forum (OCIMF: an association of 59 of the largest oil companies in the world). Then, from 2002 to 2004, three major United Nations institutions adopted the following guidelines: - Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships, adopted on December 13 th 2002 at the 6 th Meeting of the Conference of Parties to the Basel Convention. - Guidelines on Ship Recycling , adopted on December 5 th 2003 at the 23 rd Assembly of the International Maritime Organisation. - Safety and Health in Shipbreaking: Guidelines for Asian countries and Turkey, approved for publication by the International Labour Organisations governing body at its 289 th Session in March 2004. These three documents each provided recommendations for the various stakeholders in the ship dismantling process: ship owners, dismantling facility owners, competent authorities in the States concerned. Their recommendations addressed a variety of issues, such as: ship design, dismantling yard design, site selection, ship preparation prior to dismantling, preventive measures for environmental and human health protection, hazardous material management, etc. In an attempt to reach some level of overall coordination, a joint ILO/IMO/Basel Convention working group on ship scrapping was created to examine the guidelines produced by the three organisations and identify gaps, overlaps and/or ambiguities. The three documents were deemed complementary: the Basel Convention Conference of Parties Guidelines focusing on environmental protection, and the ILO Guidelines putting greater emphasis on occupational health and safety. The three institutions recognised the need, prior to any final dismantling operations, for the elaboration of both a Ship Recycling Plan and, integral to this Plan, a Green Passport. A green passport is a document that describes, quantifies and localises all the materials known to be potentially hazardous utilised in the construction of the ship, her equipment and systems. Shipyard must produce Green Passports at the time of construction of boats. Successive owners of a ship must then maintain the accuracy of the Green Passport and incorporate into it all relevant design and equipment changes, in order to facilitate the decontamination and dismantling phases and reduce associated risks. For the oldest ships, the inventory of potentially hazardous materials must be performed ex post facto, during an onboard audit. The Basel Convention and the Transboundary Movement of Waste. The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal is a major text that feeds ship dismantling debate. Developed by the United Nations Environment Program, the convention was adopted on March 22, 1989, and came into force in 1992. The Convention currently has 170 Parties, including the Republic of Cameroon. The Basel Conventions objective is to minimize waste movement across international borders, in order to protect human health and the environment. To reach this objective, the Convention has created a control system. The Conventions general obligations are as follows: - The export or import of hazardous wastes or other wastes to or from non-Party States is prohibited. - No waste can be exported if the State of Import has not consented in writing to the import of such wastes. - Information concerning the transboundary movement of wastes must be communicated to the States concerned by means of a Notification. This is to allow in the States concerned the evaluation of the consequences of the foreseen movement upon human health and the environment. - Transboundary movement of waste can only be approved if such transport and disposal of waste is not hazardous. - Wastes that are to be the subject of a transboundary movement must be packaged, labelled, and transported in compliance with international rules and standards, and be accompanied by a movement document from the point at 4 SPE 157017 which a transboundary movement commences to the point of disposal. - Any Party can impose additional requirements if they are consistent with the provisions of the Convention. The Annex I of the Convention defines the categories of wastes that must be controlled. These include: - Y8: Waste mineral oils. - Y9: Waste oils/water, hydrocarbons/water mixtures, emulsions. - Y10: Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs) and/or polychlorinated terphenyls (PCTs) and/or polybrominated biphenyls (PBBs). - Y20 to Y31: Anything containing heavy metals. - Y36: Asbestos (dust and fibres). - Y41: Halogenated organic solvents. Any Party can add wastes classified as hazardous by their national legislation to this list. In addition, in 1995, Parties also agreed to the Basel Convention Ban Amendment, or Ban amendment (Decision III/1). This amendment proposed a ban on transboundary movement of hazardous wastes intended for final disposal. The amendment also proposed a ban, as of J anuary 1998, on transboundary movement of hazardous wastes intended for reclamation and/or recycling from what are known as Appendix VII States/countries (members of the Organisation for Economic Co-operation and Development (OECD), of the European Community or Liechtenstein) to non-Annex VII States/countries (all other Parties to the Convention). In the absence of sufficient ratifications, neither this amendment, nor Annex VII, has yet entered into force in international law. However, both are legally binding for European Community (EC) Member States, as they have been integrated into EC regulations, in particular into Regulation (EC) n 1013/2006 of the European Parliament and of the Council (cf. Annex I). On the African Continent, the sister convention is the Bamako Convention on the Ban of the Import into Africa and the Control of Transboundary Movement and Management of Hazardous Wastes within Africa. This Convention was signed on J anuary 30th, 1991 in Bamako in Mali, and entered into force on March 10 th , 1999. The Republic of Cameroon signed the Convention on March 1 st , 1991, and ratified it on December 21 st , 1995. Protection of the marine environment from pollution. The 1982 Montego Bay United Nations Convention on the Law of the Sea (UNCLOS), in force since 1994, is the most universal convention in place today for cooperation on the law of the sea and related issues, such as the protection of marine environments against polluting activities associated with navigation. The Convention proposes a thorough legal framework for a wide range of issues relating to the marine environment (exploitation, preservation, international cooperation, scientific research, education, technology transfer to developing countries, etc.) and thereby overlaps with other conventions on biological diversity and maritime pollution (MARPOL, OILPOL, Ramsar 71, etc.). The 1972 London Convention and its 1996 Protocol, is in force since 1975. Its objective is to prevent pollution caused by waste dumping at sea. The Convention bans the dumping of certain wastes, listed in its Annex I (oil/petroleum, mercury, cadmium, radioactive wastes...), and requires a prior special permit for the dumping of a number of other substances listed in its Annex II (wastes containing arsenic, nickel, pesticides, etc.). Ship immersion is authorised if such ships are first cleaned, and all onboard hazardous substances/materials removed. The London Convention has been amended several times, in particular in 1993. These amendments concern the phasing out of the dumping at sea of industrial wastes, incineration at sea, and the dumping at sea of radioactive wastes and other radioactive materials. The Protocol to the London Convention, adopted in 1996 by the Contracting Parties, represents a major change of approach. The definition of "sea" is modified: until then limited to marine waters, it now also includes the marine soil and subsoil. The lists of banned materials and tolerated materials requiring a permit no longer apply. Indeed, the Protocol prohibits all dumping and incineration of wastes or matter at sea, with the exception of those listed in its Annex I: dredged material, sewage sludge, fish waste, or material resulting from industrial fish processing operations, vessels and platforms or other man-made structures at sea, inert, inorganic geological material, organic material of natural origin, etc. The Convention requires that studies be performed to address waste generation minimization and to evaluate carefully the alternatives to waste dumping at sea. The Protocol has not yet entered into force. MARPOL Convention 73/78 is an international convention for the prevention of pollution from ships. This combination of two treaties adopted in 1973 and 1978, provides an international regulatory framework for the prevention of pollution from ships transporting oil (Annex I), chemical products in packaged form (Annex II) or in bulk (Annex III), as well as from ship sewage (Annex IV), garbage (Annex V) and air emissions (Annex VI). The Convention entered into force in 1983. Only its Annexes are compulsory. Certain activities are regulated according to their distance from the coastline Towards a new international dismantling convention The Q790 case illustrated the controversy surrounding the Basel Conventions interpretation and its application to end-of-life ships (CESM 2006; Greenpeace 2006). Debate, however, goes beyond the definition of waste (Moen 2008; Chang et al. 2010). While it is now agreed that a ship can be considered as waste, when exactly a ship becomes a waste is a question that remains unanswered. Must there be manifested intention to discard the ship? While such intention is very apparent for state ships or merchant ships that are abandoned or unfit for navigation following accidents at sea, this is not the case for the majority of ships. Thus, the decision to dismantle a ship, as long as she is still fit to navigate and/or reparable, only becomes final once the dismantling contract is signed. Furthermore, the Basel Convention lays heavy responsibilities upon the waste exporting State. However, as it is complex to determine when exactly the transfer begins, it is also difficult to identify the exporting State. Moreover, the exporting State most often has no power over the ship owner. Furthermore, several studies have concluded that the Basel Convention is not adapted to end-of-life ships. Indeed, the conventions application is impeded SPE 157017 5 in practice by several factors, one major obstacle being the limited dismantling capacity available in OECD countries (insufficient yards, yards of insufficient capacity, access difficulties, lengthy waiting lists). In addition, ship dismantling activities bring economic benefits to the developing countries, as labour is cheap, people need to work, and the demand for raw materials is strong. Metal and equipment retrieval from end-of-life ships feeds these countries economies, which explains why their dismantling sites are financially attractive (Knapp et al. 2008). Debate concerning the Basel Conventions interpretation and the non-legally binding nature of the main international authorities directives has very clearly demonstrated the need for a regulatory framework adapted to ship dismantling. The IMOs Environment Council, convened on J une 24th 2005, consequently pronounced itself in favour of the negotiation of a legally binding instrument within the IMO framework. A Convention was in preparation at the time of the SR1 project. This convention should guarantee a level of protection equivalent to that enforced by the Basel Convention, whilst resolving the problems associated with waste transfers and with the Basel Conventions application to global maritime economics. The IMO Convention was expected to bring about the following improvements: - Enforcement of regulations that should facilitate ship dismantling. These applied to the design and construction of ships, their operation, and their preparation for recycling (in particular the Green Passport requirement). - Certification of the ship recycling facilities that respect environmental and human health standards. - Establishment of an appropriate enforcement mechanism enabling flag, port and recycling States to control the end- of-life process in a safe and environmentally sound manner. This Convention was set up in 2009, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. In the interim period until 2012, the European Union has defined a series of actions to be taken within the EU. These are presented in the Commission Green Paper on Better Ship Recycling (2007). The objective of this Green Paper was to define precisely the ship recycling measures outlined in the EUs Maritime Policy Green Paper. The management of ballast waters were also a key subject (IMO 2004). Significant volumes of water had to be managed in accordance with the existing regulations. The project used IMO regulations as basic roadmap: According to IMO resolution A 868 (20), ballasts waters should be changed during international voyages. Despite this resolution was not recognized by China and Cameroon, it was scheduled to change these waters during the final trip to the yard. All along the initial phases of the decommissioning project, the team faced the difficulty linked to the absence of a firm and reliable legal structure so a specific set of requirements have then to be set up and approved by Partners in order to meet all the expectations from a legal point of view and from implicated stakeholders (Table 1). Stakeholders are of importance in the decommissioning of ships The projects stakeholders are persons, groups or organisations who can be impacted positively or negatively, either directly or indirectly, by the project and/or can impact the project positively or negatively, either directly or indirectly. The number of stakeholders is high, as ship dismantling raises a wide range of issues (economic, environmental and/or social). Stakeholders are both international, like those concerned with the transboundary movement of waste (international organisms, NGOs, etc.), and national or local (service sector companies, industry, local authorities, etc.). The international authorities responsible for the regulations were also potential project stakeholders. Here are listed below some of the key stakeholders implicated all along the project. The global ship dismantling industry: a positive stakeholder. Several recent studies including the Ship Dismantling and Pre- cleaning Study performed for the European Commission and a report produced by the French Interdepartmental Committee on the Dismantling of Civilian and Military End-of-Life Ships (Mission Inter-ministrielle portant sur le dmantlement des navires civils et militaires en fin de vie), both performed in 2007 have drawn up inventories of the dismantling yards currently available in OECD countries. There are yards in operation both in Europe (Belgium, Netherlands, Italy, Lithuania) and in other non OECD countries (Turkey, Norway, USA). European yards have limited capacity. Furthermore, both the accessibility and size of Europes naval yards limit the dimensions of the ships that they can receive. European yards deal mainly with fishing boats and inland water ships, and deal marginally with small military ships and merchant vessels (up to 150 m long and 10 to 12 m draft). There are several dismantling sites in the USA, however American legislation does not currently permit foreign ships to access these sites. The largest recycling capacity in the OECD was found in Turkey. There are yards in Turkey that satisfy international management standards (ISO 9001, ISO 14001 and OHSAS 18001). However, some European Union member states have expressed their concern regarding Turkish recycling procedures, as the voluntary ship beaching often performed is not generally considered acceptable. Outside the OECD, most of the dismantling yards with internationally recognised human health and environmental certifications are in China. China has worked hard to modernise her yards, putting an emphasis on dry dock facilities. The J iangsu, Zhong Xin and Shuangsui yards in particular have upgraded their facilities and methods in order to satisfy Western environmental and occupational management standards (ISO 14001 and OHSAS 18001). Certifications have been delivered by various agencies, including the China National Institute of Standardisation (CNIS). Indian dismantling yards have undergone a vast certification process, initiated by the Gujarat Maritime Board. Indeed, the certification of 22 sites has been reported in the press. International Certification Services (Asia) Pvt. Ltd has certified most of the yards. The RINA certification company has certified others. A few yards that already satisfy the ISO 9001, ISO 14001 and OHSAS 18001 standards are investing in personal protective equipment and worker training and, following the example of the Shree Ram Vessel yard, are in the process of modernising their production tools (cranes, mechanised shears). The yards also provide hazardous waste treatment (individual containers and equipment for asbestos 6 SPE 157017 disposal, waste storage in treatment centres). The Indian Supreme Court is examining the recommendations put forward by a technical committee on the regulations that should be enforced in the Alang dismantling yards. Non-governmental organisations (NGOs): a powerful stakeholder. The Clemenceau affair demonstrated the interest taken by associations and NGOS in ship dismantling, and the resulting importance of transparent communication with these stakeholders, and their involvement in dismantling projects. The action organised by Greenpeace, Ban Asbestos and the FIDH in the Clemenceau affair is not a one-off occurrence. Since 1998, a number of international ship dismantling projects have been singled out and contested. In February 2001, for example, the Sandrien oil tanker was immobilised in the port of Amsterdam by the Dutch Environmental Inspection Services, as she was about to leave for Asia to be dismantled. The next year, the State Council of the Netherlands ruled that exporting the tanker, which contained hazardous materials including asbestos within her structure, would violate European waste movement regulations (Basel Convention). This ruling established a precedent in the Netherlands. Greenpeace has continued to exert pressure on various countries including Belgium (the Forthbank in 1999 and the Silver Ray in 2003), Turkey (the Sea Beirut in 2004), and India (the Hesperus in 2003). Other organisations also monitor the situation closely. The NGO Shipbreaking Platform is active on shipbreaking. The NGO is composed by several NGOs. The main ones are as follows: - BAN, Basel Action Network, is focused on confronting the excesses of unbridled free trade in the form of Toxic Trade (trade in toxic wastes, toxic products and toxic technologies) and its devastating impact on global environmental justice. Working at the nexus of human rights and environment, BAN confronts the issues of environmental justice at a macro level, preventing disproportionate dumping of the world's toxic waste and pollution on our global village's poorest residents. Further, BAN promotes sustainable and just solutions to our consumption and waste crises. - Ban Asbestos is a network of local organisations monitoring anti-asbestos legislation where it exists and litigating for the abolition of asbestos where anti-asbestos legislation is lacking. - Bellona Foundation is a multi-disciplinary international environmental NGO based in Oslo, Norway. Founded in 1986 as a direct action protest group, it has since become a recognised technology and solution oriented, environmental defender with offices on two continents. Altogether, some 40 ecologists, nuclear physicists, engineers, economists, lawyers, advisors and journalists work at Bellona. - European Federation for Transport & Environment, founded in 1989, is Europe's principal environmental organisation campaigning on sustainable transport. T&Es primary focus is on European policy and its work is supported by 45 NGO member organisations working in 21 countries to promote an environmentally sound approach to transport. The T&E secretariat in Brussels works closely in various ways together with the European institutions, while member organisations have close contacts with national decision-makers and campaign at national level. - FIDH, the International Federation of Human Rights, was created in 1922. It now includes 141 national human rights NGOs from all regions of the world. FIDH has a generalist mandate and consequently works on all human rights be they civil, political, economic, social, or cultural rights. FIDH carried out fact-finding missions on shipbreaking in India and Bangladesh, which resulted in the publication of a mission report in 2002 entitled Labour Rights in Shipbreaking Yards in South Asia, Where do the floating dustbins end up?. In 2005 FIDH, Greenpeace and YPSA released a report entitled End of Life Ships The Human Cost of Breaking Ships. - Greenpeace is an international non-governmental organisation founded in 1971, working on global and environmental problems. Greenpeace started its shipbreaking campaign by highlighting this environmental and human rights disaster in 1998. Since then the environmental organisation has been working for a global solution be it through the Basel Convention, the IMO (International Maritime Organisation) and the ILO (International Labour Organisation) as well as in the shipbreaking countries such as India and Turkey. - IBAS, the International Ban Asbestos Secretariat, is an independent body dedicated to the worldwide eradication of the continuing use of asbestos and the minimisation of dangers from asbestos products already within society. IBAS works to obtain a universal ban on the future use of all forms of asbestos. The organisation also provides information that will assist asbestos victims seeking redress and financial compensation from employers, asbestos manufacturers, governments and others who may have caused their diseases. The NGO Robin des Bois is also an active NGO but it is not a member of the Platform on Shipbreaking. Created in 1985, its objective is to bring together, both on a national and an international level, all people and corporate bodies wishing, by means of non-violent actions, to participate in the protection of the environment and humanity, the defence of endangered species, the safeguard of natural habitats, and the promotion of rational and equitable natural resource management. The NGOs ambition is not simply to protest, but to propose solutions. When able to, it provides voluntary assistance to citizens, and puts all its energy into upholding dialogue with all persons or corporate bodies. Since 1988, Robin des Bois has participated in ministerial and interministerial working groups to carry its objectives forward in the places where decisions are taken. The NGO holds official positions in certain authorities, is member of working groups and has played the role of observer for three international conventions. Robin des Bois has published, since 2006, a regular ship demolition information and analysis bulletin entitled alacasse.com . The NGO is in favour of the development of dismantling yards in Europe, and the improvement and consolidation of partnerships and bilateral agreements with Asian yards. Local stakeholders: In Cameroon the local stakeholders mainly consisted in Institutions such as: - Socit Nationale des Hydrocarbures du Cameroun (SNH) is a public institution directly attached to the Secretary-Generals service of the Republic of Cameroons President. It is a financially independent industrial and commercial institution. Created in 1980, its mission is to promote and manage the interests of the State in the oil and gas sector. It manages the promotion, development and monitoring of oil and gas activities throughout the country, and works with international companies. Its head- office is located in Yaound. SPE 157017 7 - Environment and Nature Protection Ministry (MINEP), created in 2005, MINEP is responsible for the development, application and evaluation of the governments environmental policy. MINEP was implicated in the Basel Conventions setting up. - Industry, Mines and Technological Development Ministry, is the authority that supervises the Total E&P Cameroun Company. It manages mining in the country and monitors oil industry activities. It participates in the Technical Committee and the Operations Committees, and is responsible for the technical management of both the administrative and security aspects of the oil industrys activities. - Economy and Finance Ministry: The Direction Gnrale des Impts is Total E&P Camerouns main correspondent with regards to taxation. A Direction Gnrale des Impts executive is Administrator of Total E&P Cameroun. This executive participates in contractual negotiations and performs tax audits. - Total E&P Cameroun Partners (SNH, Pecten, an affiliate from Shell) were important local stakeholders who had to approve the decommissioning strategy and associated costs. Total E&P met with members of the identified stakeholders. At national level, the abandonment of the SR1 was performed under the Basel Convention regulatory framework. The involvement of the MINEP was then very important. At the international level, the project team members met the NGO Platform on Shipbreaking to present the project and welcomed constructive criticism. The meetings took place in Paris and in Brussels during the performance of the project at key milestones: at the beginning, before strategy definition and before SR1 left Cameroon. During these meetings, the projects advancement and potential modifications were presented, with positive feedback from the NGOs. The NGO Platform representatives globally appreciated the incorporation of environmental and social aspects into the project. In the presence of representatives of the NGO and the FIDH, the strategy of decommissioning was welcomed. No objection was made to the selection of a Chinese yard, but recommendations and advice were given. In parallel, the NGO Robins des Bois made several articles and web releases about the project in their quarterly reports (2008, 2009, 2010a, 2010b). The project had only a limited communication with the organisation.
Results and key findings The Green Passport of the Serepca-1: a complete waste audit Total E&P Cameroun had the Serepca-1s Green Passport prepared prior to all interventions. As explained above, the International Maritime Organisation (IMO) advocates the preparation of a Green Passport in its IMO Guidelines on Ship Recycling, adopted in 2003 (Resolution A.962(23)). The passport provided an inventory of the potentially hazardous materials present onboard, and this inventory was used to assist the planning of the ships dismantling. The passport was also updated before the SR1 left Cameroon during the dismantling process following specific decontamination operations. Annex 3 of IMO Resolution A.962 (23) that provides a Green Passport format was used as a model. The hazardous materials inventory was split into three parts, which reflected the origin of the substances presence onboard: - Part 1: ship design, construction and maintenance (potentially hazardous materials in the ships structure and in both her operational and more domestic day-to-day equipment). - Part 2: ship operation/exploitation (operationally generated wastes). - Part 3: the stores required for day-to-day ship life and day-to-day crew life (stores). The Serepca-1s Green Passport identified, localised and quantified the potentially hazardous materials presented in the whole boat. The independent expert company, Tecnitas, consulting subsidiary of the Bureau Veritas firm, prepared the first Serepca-1s Green Passport in 2007, following an onboard ship audit performed from May 30 th to June 5 th , 2007. Before decommissioning, a final audit was performed by another third expert Van der Poel (m.a.r.c BV)), a member of the International Ship Recycling Association. This audit was ordered by the recycling yard in 2008 under supervision of Maersk Ship Recycling Services, (now Sea2Cradle). The non hazardous waste consisted in all material in the rooms of the FSO: bed, bathroom equipments, TVs, computers, papers etc The hazardous wastes were as follows (Table 2): - Tank bottom sediments (approx. 226 m 3 ). - PCB (Polychlorobiphenyls): o Inside electric transformers (16 t). o Transformers (35 t). - Mercury (approx. 19 kg). - Fluorescent tubes (approx.1350). - Ionizing materials like fire detectors (approx.160). - Sealed gas: refrigerant (approx. 180 kg), SF6 inside 31 switches. - Asbestos: non friable inside materials (floor coverings 2500 m 2 , joints), potentially friable, inside the suspended ceilings (approx. 100 m) and partitions (approx. 900 m), doors (approx. 40 doors), flex sleeves of ventilation ducts. - Hydrocarbons: lubricating oil (approx. 3 000 litres), hydraulic oil (approx. 2 000 litres), diesel (several litres). A good knowledge about what and where hazardous materials on board especially asbestos was essential to prepare the decommissioning works. All major risks on board were to be identified in order to avoid unexpected situations, such as workers health unsafe situations, unexpected cleanup costs, delays in transportation, loose of cargo, and liability claims. This knowledge is not only essential for ship owners or management, but also for other workers who may come into touch with hazardous materials on board. To anticipate these questions, specific surveys were performed to quantify the quantity of 8 SPE 157017 asbestos material and to ensure whether or not asbestos dust was present especially in the ceilings which could create specific problems during dismantling. In controlled conditions, in one specific room where asbestos was present, samples were taken to determine whether asbestos dusts were settled or not and whether asbestos dust could be generated during the removal of ceilings. The analysed samples and the monitoring by third expert showed that in all sample, asbestos was not detected. The Serepca-1 decommissioning strategy The precise knowledge of waste inside a FSO was a key parameter that helped to determine the best disposal strategy. Selection of ships end-of-life disposal procedures. Total E&P Cameroun has envisaged several disposal alternatives for the Serepca-1 tanker during the early phase of the project: 1. Sale of the ship as is, where is. 2. Conditional sale as is (the dismantling site being specified in sales contract). 3. Conditional sale following decontamination. 4. Agreement of a dismantling contract with a recognised dismantling yard. 5. Immersion. Determining which of these 5 alternatives ensured the best Human Health and Environmental protection was the first step. A multi-criteria analysis was performed to this end, using the ELECTRE software, which allows comparative assessment of the different alternatives (LAMSADE 1994). This involved the definition of selection criteria and operational parameters defining the conditions in which one alternative is preferred over another: External Technical Criteria - Technical feasibility with regard to planning constraints. - Feasibility with regard to international regulations. - Public perception and social acceptability. Social Criteria - Socio-economic benefits. - Negative impacts upon populations (other than HSE risks). - Social and occupational conditions of decontamination operations. - Social and occupational conditions of dismantling operations. HSE (Health, Safety and Environment) Criteria - Environmental impact. - Pollutant transfer and disposal conditions (other than for ballast waters). - Ballast water management. - Management of the metallic scrap. The ELECTRE software evaluated and ranked each alternative. The result of the assessment was that the dismantling in a naval yard compliant with international standards was the alternative which best respected environmental and social requirements. Note that the scenario 5 was quickly discarded due to legal reasons. The selections of the dismantling site and of the waste management company in charge of removal, treatment and disposal of the waste were parallel processes with lot of cross implications. Determination of the transfer to the yard strategy: manned or not manned? The final trip of such FSO was not an easy task because she had no propulsion units: no rudder and no propeller. The removal of anchors was highly sensitive because without any anchors, the SR1 needed to be maintained by tow, otherwise she became a high hazard to the surrounding tankers and operational platforms. It necessitated then a precise coordination between several involved external teams. Her transfer to the yard involved the use of one tug boat that had to be refuelled to reach final destination. The SR1 had to be reballasted and deballasted during her final trip according to IMO guidelines. A ballast water management plan was then prepared. Then, it was necessary to maintain on board a small crew that had to live on the FSO. To maintain the living conditions in key parts of the FSO, electricity, safety equipments, fire detection had then to be maintained until the yard. These necessary items influenced drastically the waste management strategy. Selection of the dismantling site. The dismantling of the Serepca-1 involved the manipulation of hazardous wastes such as PCB from transformers, friable and non-friable asbestos, mercury, democking residues from tank (hydrocarbon- impregnated sediments), ballast waters, ionizing fire detectors A Green Passport was then prepared in order to list, localize and quantify all hazardous materials onboard. Audits evaluated the ability of a number of naval yards to dismantle the ship and dispose of hazardous wastes in conditions ensuring human health and environmental protection. Total E&P set up a complete audit team to visit and assess the capabilities to dismantle the SR1. A selection of different naval yards was proposed based on the following criteria: - A yard in the ships flag State: the Republic of Cameroon. - Yards whose operators spontaneously tendered to Total for the contract. - Yards included in the inventory provided in the European Commission Directorate General for the Environments J une 2007 Ship Dismantling end Pre-Cleaning of Ships final report. - Yards evaluated by implicated international organisations and having demonstrated a proactive approach in terms of environmental protection, occupational safety and dialogue with the local population. - Yards in different geographical zones (Europe, Africa, Asia) in order to compare dismantling processes and SPE 157017 9 practices, etc. Countries dismantling the most ships are India, China, Pakistan and Turkey (only OECD member country). The Basel Conventions Guidelines seem to consider that human health and environmental protection is sufficient only in China and Turkey. The audit team focused on the following criteria: 1. Site: location, type (beach, dry dock..), Industrial equipments, "Green" experience, technical aspects 2. Safety: Access of the personnel, Certification of equipments, specific Safety (PPE, Procedures ), Emergency (in and out of the yard), Permitting /procedures (confined space.) 3. Waste management: Asbestos (removal, confinement, PPE, Monitoring) PCB / Mercury / Refrigerant Gas / hydraulic oil, Storage, follow up 4. Waste treatment. Several yards were then selected (Table 3). Amongst these yards, some were discarded due to technical aspects, other retained for visit and audits (Table 3, Fig.2). Here is below the most representative findings of representatives yards involved in the decommissioning of ships: the Leyal yard in Turkey, Harland & Wolff yard in Ireland, the Changjiang yard in China and the Leela yard in the Alang Bay in India. The Harland & Wolff (H&W) yards dry dock was well suited to this type of activity (easy access from all sides, control of potential environmental impacts during hazardous material removal from the hull as the dry dock is by definition a confined area, etc.). Furthermore, the yard complied with regulations, which correspond to European standards. This guaranteed the implementation of high waste management and occupational safety standards. Waste treatment contractors complied with British regulations, and so conformed to European standards. Thanks to its experience in the construction, transformation and repair of large offshore or naval structures, the yard was skilled in the management of large projects, relying on a network of subcontractors with the required ability to execute a project. However, H&Ws tanker dismantling know-how was very limited, and due to the absence of onsite or nearby treatment facilities, waste had to be transported by sea to England. Dismantling operation would take about one year. Finally, the site had just one dry-dock for dismantling, and cannot therefore dock the Serepca-1 securely until this dock becomes available, should the dock be occupied upon the ships arrival. The Leyal yard located in Aliaga is surrounded by small companies dismantling ships directly on the beach. Dismantling operations combined both afloat and land-based technologies. Tackles pulled the ship onto a waterproofed work area. As there was almost no tidal zone, the delimitation between the dry working area and the sea was clear-cut. This normally reduced the risk of debris discharged into the sea. In addition, during visit it was observed floating booms surrounding the ship being dismantled, to control any accidental discharges of oil. The work area was equipped with a wastewater and storm water drainage system. Cranes were used to displace large sections cut out from the ship to the onland cutting and material sorting area, where structures were re-cut to enable their transportation by truck. Metals were then sent to a nearby steelworks. Yard personnel were equipped with hardhats, steel-toed boots and gloves. Cranes also transported the personnel that worked in the elevated areas of the ship. These personnel were equipped with harnesses. Prior to each dismantling operation, onboard air quality and radioactivity were evaluated first by Leyal, and then by a team of certified, independent experts. This team of experts established an inventory of the hazardous materials still present onboard and defines the waste extraction and disposal procedures to be followed. The company had an authorisation to treat wastes including asbestos, PCBs and hydrocarbons. The asbestos waste was stored in airtight packages in a delimited and marked area. Workers dealing with asbestos were equipped with full-face cover-pressurised masks and full-body coveralls. The yard had 3 mobiles depressurised chambers that provided airlocks between contaminated and non-contaminated zones. Contaminated zones were confined (sealed windows, access through an airlock). In addition, atmospheric concentrations of asbestos particles were monitored. Asbestos removal procedures complied with the German TRGS 591 regulation. Hazardous wastes were stored in dedicated concrete-capped areas. Liquid wastes such as oils and hydrocarbons were stored in drums on a concrete-capped bay equipped with a drainpipe connected to an oil separator. Hazardous wastes were treated by nationally certified companies; in particular the Izaydas household and hazardous waste incineration plant. Certified transportation companies managed the hazardous waste transportation. Finally, the site was awarded ISO 9001, ISO 14001 and OHSAS 18001 certifications in 2006. One weak point like the H&Ws yard was that it only handled one dismantling operation at a time. The SR1 would need to wait for the yard to be available. The Leyal naval yard was then found to be apt to dismantle the Serepca-1 in a manner respectful of the environment and in relatively good working conditions. However, safety improvements needed to be made, in particular to vessel access, as access was poorly secured and inadequate in the case of an emergency evacuation. Leyal clearly committed to retrofit its site and improving environmental and occupational conditions. Lastly, the length of the dismantling process was estimated at 1 year. The Changjiang shipbreaking yard in China had a long experience to dismantle boats at quay. The company was created in 1998. The yard had a partnership with Maersk Recycling signed. The Maersk team on site was dedicated to the dismantling of Maersks end of life chips but also aimed at providing supports to foreign companies. The yard operated 4 quays, with a mean demolition capacity of 8 to 10 ships, each weighing about 20000 tons. The yards access canal was over 9 m deep, with 50 m air clearance (headroom) above the water. The yard dismantled about 20 ships a year, and could provide various waste elimination services using specialised contractors. Chinese regulation did not impose an authorisation procedure for asbestos removal. The naval yard removed asbestos using the following equipments: disposable coveralls and masks fitted for asbestos removal, a mobile Dutch decontamination air lock given by Maersk and changing rooms equipped with showers. However, the clean area and the contaminated area were not physically separated, as a room connected both areas. The 10 SPE 157017 threshold value for worker exposure to asbestos in China was 0.8 fibres per cm 3 (0.1 in Europe). Airborne asbestos fibres were not measured. Asbestos wastes were conditioned either in double heavy-duty polyethylene bags, or coated with plastic and loaded onto pallets, and then sent to the Wuxi hazardous waste landfill. Hazardous waste was stored in closed, identified and well-maintained buildings. Third experts mandated by Total E&P performed audits of the waste disposal facilities. The naval yard provided good ship deconstruction working conditions. Dismantling occurred at dockside, which facilitates the access to the ship. The yard was large, clean and had an onsite incinerator and wastewater treatment system. Dismantling was usually completed in a relatively short time (4 months). The yard was certified ISO 14001, 2004. Furthermore, the scale of the yard and docks guaranteed that the Serepca-1 could be docked until she was dismantled. Audits concluded that some improvements were needed in respect of the asbestos removal procedures. These includes: 1) the presence of a HSE supervisor throughout the dismantling process, 2) the confinement of the asbestos removal zone, placed under negative pressure, 3) the use of assisted breathing filtering equipment and the use of European standards in term of worker exposure to asbestos, 4) the redesign and modification of the changing room area and the measurement of airborne fibres by a certified laboratory during works. A major issue concerned the PCB management in China. None of the visited incinerators were fitted to treat these type of waste; no technology was identified to treat the transformers themselves even after cleaning. Finally, the law did not authorize to import PCB in China. The yard was selected for bidding. The Leela Ship Recycling yard is located in India in the Alang bay. It is a site of a width of about 87 meters for an equivalent length. It was located directly on the beach surrounded by numerous sites. The entry consisted of offices and technical buildings. The storage of dangerous waste was in a concrete building with a roof divided in 5 parts. Each part was dedicated to a defined type of product: asbestos / radioactive products / rubber / residues of painting / insulating wool. In the cell dedicated to asbestos, some bags remained (simple) plastic blacks sealed by an adhesive tape identified with the mention asbestos. The site was equipped with an incinerator potentially reaching 1200C equipped with a 20m height chimney. This incinerator was installed in an old steel container. About 0,4 m 3 could be burned by one loading. No drainage system was in the storage section that stored the barrels of oily waste or toxic waste on standby for evacuation. The means of lifting observed on site were very limited and consisted into an old crane (capacity of 35 T) and a telescopic crane van. A tractor with trailer was used to convey the waste, equipment etc. The mechanical capacity was supplemented by 3 winches which seemed simply lying on the sand. These winches allowed approaching progressively the boats on the beach and taking part in the displacement of the blocks of steel to the cutting zone. The site had a partnership with an American company for the removal of asbestos. This collaboration resulted in trainings for the site staff. An inspector visited the site before and after the depollution to give the green light for the following phase. Once materials containing asbestos were removed from the boat, they were transported in the dedicated area. There, under more or less effective controlled conditions of containment, asbestos was dissociated from the equipments with the help of a surface-active agent and put in plastic bags. These bags were then transported to the landfill of the Alang area (located at 3 or 4 km from the yard), owned by GMB but operated by a private contractor, GEPIL (Gujarat Enviro Protection Infrastructure Ltd). The landfill site was divided in three zones that accommodated all type of waste. These areas of an approximate surface of 3000 m had plastic liners for underground protection. The rainwater could be collected at the bottom of the pit in a tank. No treatment facility for hazardous waste and inert waste were in the vicinity of the yard. No children or women in rags were observed during the visit on the sites and many workers were equipped with a minimum of PPE. Asbestos was not burned on the beach. And, it was certain that improvements took place in these last years. But in term of safety and environment, the practices still remained in 2007 below an acceptable level. No adequate means for the removal of materials (particularly of dangerous materials) between the boat and the site where no possible access for the crane, no solution for a safe treatment of the PCB, mercury, cooling agents etc.., the landfill for asbestos was too small and associated techniques were not adapted for a safe removal of asbestos for the personnel, the removal of large steel parts was performed by a non-controlled fall on the beach, lack of prevention of a potential pollution of the beach; all these findings cannot be improved in a short period; The yard was then not selected. The visits and audits pre-qualified, then, 3 yards (Figure 2): the Leyal yard in Turkey, Harland & Wolff yard in Ireland and the Changjiang yard in China. The ELECTRE multi-criteria analysis tool was also used in parallel to determine which of these yards best fulfil the technical, environmental and social requirements involved in the dismantling of a ship such as the Serepca-1. The following criteria were selected Environmental Criteria - Environmental protection measures. - Impact upon natural resources in the event of an accident. - Experience and green-experience . Technical Criteria - Feasibility with regards to planning constraints. - Facilities and equipment. - Equipment certification and maintenance. Hygiene and Occupational Safety Criteria - Worker access to ship. - Occupational safety. - Emergency management within the naval yard. - Emergency management outside the naval yard. SPE 157017 11 - Work permits and procedures. - Asbestos worker protection. Waste Management Criteria - Asbestos waste confinement and management. - PCB removal. - Mercury removal. - Refrigerant gases removal. - Hydraulic oil removal. - Asbestos treatment. - PCB contaminant treatment. - Mercury treatment. - Refrigerant gases treatment. - Ionising fire detector treatment. - Paint treatment. - Waste traceability. - Naval yard treatment facilities. The multi-criteria analysis ranks the Changjiang naval yard in China the highest; however the three naval yards were quite close in rank. Discussions were then handled between the three yards to evaluate different waste removal scenarios (Fig. 2) and to ascertain some critical findings such as how to improve the safety in the Turkish yard, or how to improve asbestos removal in China. The two yards aimed at fulfilling Company recommendations. Based on a revised and optimal waste management strategy, technical clarifications were then given by the bidders. By integrating the technical and commercial proposals, the Changjiang yard in China was then awarded. Selection of the Waste Management Company. The initial objective of the Project was to perform a full offshore depollution including the complete asbestos removal of the boat. 24 international companies were identified and contacted based on their recognized capabilities to undertake such a work. Only 7 companies answered to the pre-qualification questionnaire and 17 companies declined. 4 companies were prequalified; 2 submitted a proposal to the Call for Tender, 1 declined, the others made a joined proposal. Total E&P Cameroun organized site visits of the SR1 with the 2 bidders that passed successfully the technical aspects. The opening of the technical and commercial proposals showed that the full removal of asbestos could not be safely undertaken offshore. The mitigations proposed by the bidders were technically almost impossible and lead to an overall unrealistic budget. In parallel of this CFT process, the selection of the decommissioning yard was ongoing (see paragraph above) and results influenced the waste management strategy (Table 4). By integrating the findings of the audits of decommissioning yards, the approved transfer strategy and the capabilities of waste management companies to perform such a work in Cameroon, it was then decided that some waste were removed and treated in Cameroon, other were removed and exported to Europe and finally, the remaining waste remained on board until the final yard to be removed and treated in the country (Table 4). At the end of CFT process, the French Sita company specialized in waste removal, treatment and disposal was awarded. In Cameroon, Cometal Cpy removed the tank bottom sediments that were transferred and burned in a cement factory after compatibility test. Decontamination & Basel Convention n1 to export to Europe some of the identified hazardous waste. Expert evaluations revealed that performing an initial, optimal decontamination of the Serepca-1 prior to its export for dismantling was the best technical (facilities) and regulatory (Basel Convention) approach. Ship decontamination planning was made possible thanks to the ships Green Passport, and the consultants initial environmental audit of the ship. The Serepca-1 was partly decontaminated offshore prior to towage. Sita employees with the help of local compagnys workers removed, conditioned and safely stored hazardous materials on Total E&P Cameroun onshore Wouri base, in the interim prior to export to European hazardous waste disposal facilities. Offshore decontamination had associated environmental risks, in particular for the natural marine environment. The main hazard resided in waste transfer from the Serepca-1 to the tugboats navigating to and from the port. Security measures were taken for the manipulation of hazardous products. Dedicated drip pans and lifting tools were constructed in Cameroon for the transfers. In parallel of the works, Total E&P Cameroun teams with Sita teams prepared the needed documents for the export of waste. Once the several transfer notification documents (for the waste to Belgium, and for the waste for France) had been approved by the various competent authorities (State of export, State of import and States of transit), all removed wastes except tank democking residues (hydrocarbon containing mud and sediments) were exported to Europe to specialised treatment facilities (Table 5). Decontamination & Basel Convention n2 to export to China the hull containing some waste. In parallel of the waste transfer to Europe, prior to towage, the Serepca-1 was granted a Cleaning and Gas Free Certificate, as well as authorisation from all involved parties to leave Cameroonian territorial waters, in compliance with the Basel Convention. Furthermore, the transformers with PCB and mercury decontamination of the ship were notified to authorities. Towage started when the Chinese authorities approve the ships import conditions, as required by the Basel Convention. Preparation of the SR1 for final trip, demooring, towage and arrival in China. Prior her departure, the SR1 had to be prepared for her final destination. As some crew were maintained on board at departure until Cap de Bonne Esperance and 12 SPE 157017 from Singapore to the China; it was necessary to maintain living and operating conditions including electricity, safety equipments including fire detection and fire fighting capabilities. In addition, as ballast waters had to renew three times, pumps needed to be operational. As all transformers were removed, a new autotransformer without PCB was installed. The towing specialist Svitzer towed the ship, once her 11 moorings had been removed. Three tugs were necessary for the demooring operations while one tug was used for towage. On the 18/03/2009, the SR1 final trip to China started. An Argos beacon placed onboard the tug, emitted a signal each hour, so that the Serepca-1s itinerary was followed continuously from the Cameroonian coast to the Chinese naval yard. Total E&P Cameroun remained the ship owner until her arrival at the Changjiang naval yard, upon which the ship became naval yard property. The objective here was to give insurance that the ship would not be resold in a third party country during ship transfer. Three ballast water exchange operations were performed during the trip. Towage lasted 105 days, with a port of call in Singapore to refuel the tug. The ship arrived in China waters at the end of J une 2009 but due to a typhoon and bad weather conditions, she could not enter the Yangtze River. Finally, with the assistance of 5 more tugs, the main tug towing the SR1 started to enter the Yangtze River on the 02/07/2009. On the 03/07/2009, the ship arrived in J angyin. Upon the ships arrival, an inspection was carried out to verify ship compliance with notification documents and ballast waters were sampled for analyses on the 26/08/2009 (Table 6). The Serepca-1 decommissioning operations Procedures for final decontamination and dismantling operational in the naval yard were in the ship recycling plan. The major steps of the dismantling are summarised as follows: 1. Upon the Serepca-1s arrival, all material other than steel was removed from the ship. This included: furniture, insulation material, asbestos, recyclable equipment, the residual fluids in piping, etc. Prior to ballast water discharge, biological and chemical analyses were performed after chlorine treatment in order to eliminate the risk of introducing invasive species with the ballast waters (Table 6). 2. The ship was cut up into several sections that were laid ashore in designated metal cutting areas. Metal cutting did not begin until an inspector validated removal of all materials, as specified in operational procedure. 3. During this time, materials were conditioned and sent to the appropriate storage or recycling units as defined in the contract. These facilities were previously audited by third party experts for Total E&P Cameroun. 4. Waste traceability: The naval yard managed waste transfer and disposal, and provided the certificate delivered by the various subcontractors at each step (transport, reception, and disposal). 5. In order to ensure that this phase unfold in compliance with international recommendations and best practices, Maersk Recycling team represented Total E&P Cameroun on site to assess that dismantling conditions fulfilled the terms of the contract and reported on a regular basis to Total E&P Cameroun. 6. Asbestos removal was supervised by independent professionals: specific trainings were delivered prior the work then independent laboratory surveys ensured that the conditions for working and asbestos removal respected the defined European standards Asbestos removal training was performed on the 9 th 2009 by Mr. Marc van de Poel of Sloopservice (Arnhem, The Netherlands). After theory, workers went to the SR1 to identify all asbestos containing materials (ACM) which were identified and marked in bold red spray paint thanks to the green passport results. All loose items were removed from the vessel (furniture, flooring, ..). After this pre-cleaning phase, all the non-ACM insulation in bulkheads and deckheads was removed. During this time, preparations were made for ACM removal. It started on the 08/08/09. Access to the vessel was limited to the asbestos removal team wearing full protective clothing and all windows and outside doors were sealed. A 3 chamber wooden cabinet fitted with the fans and filters was placed at both Port and Stdb main accommodation access doors. This acted as the airlock and also kept the area of both stair wells under pressurized. Air testing was carried out by ETS Testconsult Ltd of Hong-Kong. Air monitoring samples were sent every day to Hong-Kong for analysis and results sent by return. The ACM panelling in both stair wells was carefully removed and edges sealed with tape. These panels were the stacked and sealed in double plastic layers. After both stairwells were cleared, new air lock was created at the entrance to the ECR and panelling removed as per accommodation. The removal of the ACM was completed on 8 th September; it took about 40 days to remove the asbestos. Cleaning of non ACM continued until 13 th September, then cutting started until the 26/10/2009. The implicated workforce consisted of 50 workers for pre-cleaning, around 10 workers for ACM removal and 80 to 100 workers for steel cutting on ship and on site. On the 16/12/2009, the representatives of Maersk Recycling and of the yard met together in Total headquarters in Paris to celebrate the end of the decommissioning of the SR1.
Conclusions and perspectives Dismantling is the most sustainable process, as the materials contained within the ship, such as steel, can be retrieved and reused. Natural resources can therefore be preserved and recycled and reclamation encouraged. Potential impacts were reduced by the decontamination operations performed prior to towage thanks to the green passport audits. Though it was unlikely that the Serepca-1 might sink during towage, the possibility was considered. Environmental impact could be considered lowered since the most hazardous materials have been removed from the ship. The audits performed throughout the project helped to significantly reduce environmental impacts. The environmental skills of all the removal, disposal and dismantling contractors were measured. The use of Basel Conventions ensured transparency in the whole abandonment process. The Serepca-1 underwent preliminary decontamination prior to export and dismantling, in compliance with the SPE 157017 13 Basel Convention. Hazardous waste management conditions have been designed to minimise environmental impact. Indeed, the subcontractors selected for ship decontamination have proven their ability to dispose of wastes following certified and environmentally monitored procedures. Waste treatment facility atmospheric emissions, effluent discharges, etc. in each case respect applicable standards. Finally, as long as all operations (waste removal, waste treatment, dismantling, etc.) were performed using existing infrastructures, they could be integrated into existing activities. Social impact could therefore be considered positive as employment was maintained as long as possible and/or created. As long as contractor occupational health and safety measures complied with international standards, human health risks could be kept under check. Total E&P faced then a significant challenge in the decommissioning of the SR1. Reputation is of great importance in such an abandonment project because the most important NGOs are implicated in the end of life ships. No one has forgotten how the Brent Spar or more recently the Clemenceau abandonments turned out in highly emotional and uncontrolled situations. But by adopting a step wised approach, by engaging with the Ship Breaking Platform NGO through a constructive and regular dialogue, by adopting the recommended best practices, the SR1 decommissioning project was a success at all levels.
Acknowledgements Many people have contributed to this project and, whilst the following list is not exhaustive, it is representative of the diversity of these contributions. The authors would therefore wish to thank all personnel met during the visits of yards. In particular all the listed persons below have contributed to the success of the abandonment of the SR1 in particular: Mrs Ingvild Jenssen from the NGO ShipBreaking Platform, Mr Li Hongwei and M. Yan Zhiping from Changjiang Shipbreaking Yard, Mr Kam Thomson from Maritime Delivery, Mr Wouter Rozenveld, M. Frank Fox, M. Wang Hua and Mrs Shuk Mei Liu from Maersk Ship Management, Mrs Anais Guillou and Mrs Sophie Canovas from Agilon, Mr Thierry Rojouan from DV Offshore, Mr Gilles Thomas from Giant Marine (Svitzer), Mr J acques Corby and Mr Franois Lejuste from Tecnitas, Mr J ean-J acques Morge, Mr Yves Curtil and Mr Anthony Bosh from Sita, Mr Patrick Abijou from Neptune Vision, Mrs Claire Sauvaire from Elephant at Work, Mr Olivier Dubois from UGGC & Assoils, Mr Patrick Pelissie from Apave, Mr Xavier Collet from Sogreah Magelis China, Mrs Christine Bossard from Robin des Bois, Mr Ren Quau and its crew team from the SEREPCA-1, Mr Bayiha Kodock, Mr Remi Boiton, Mr Benjamin Fabre, Mr J acques Jutten, Mr J ean- Marc Mbila, Mrs Aurelie Clave, Mr Samuel Billong Bisseck, Mr Alain Messie, Mr Nicolas Tortelli, Mr J ean-Claude Vachet, Mr J ean-Franois Lassale, Mr Hugh Brumpton, Mrs Sybille Fioroni, Mrs Catherine Sutton, Mr Laurent Cazes, Mr J ean- Marie Perdu, Mr Louis Bon, Mr Xavier Ecomard, Mr Thierry Monmont, Mr Marcus Moore, Mr Marc Somon, Mrs Christiane Eygun, Mr J ean-Michel Courrandier, Mr Mr J acques Mine, Mr Michel Grandprat, Mr Herv Lacamoire, Mr Roger Camps, Mr J ean-Yves Durieux, Mr J ean-Franois Vidalie, Mrs Pascale Kromarek from Total E&P Cameroun and Total E&P SA.
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IMO Guidelines on Ship Recycling (Res A962 (23)) London, UK: 5 December 14 SPE 157017 2003. As amended by IMO Resolution A.980(24). Amendments to the IMO Guidelines on ship recycling. London, UK, 1 December 2005, Publication n I865E. International Maritime Organization. 2004. Guidelines for the Development of Ship Recycling Plans (Circ 419). International Maritime Organization. 2004. International Convention for the Control and Management of Ships' Ballast Water and Sediments. International Maritime Organization. J uly 2005. Implementation of the IMO Guidelines on Ship Recycling (Circ 466). International Maritime Organization. July 2005. Promotion of the Implementation of the Guidelines on Ship Recycling (Circ. 467). International Maritime Organization. December 2005. Amendments to the Guidelines on Ship Recycling (Res A980 (24). International Maritime Organization. December 2006. Ship Recycling - Developments and Issues. J zquel S. and Dniela D. 2009. Epaves coules, un bien pour la mer ? AE2D : Agir pour lenvironnement et le dveloppement durable. [Online]. [Consulted on April 24th 2009]. Available at: <http://www.ae2d.infini.fr>. Knapp, S., Kumar, S.N. and Remijn, A.B. 2008. Econometric analysis of the ship demolition market. Marine Policy 32: 1023-1036. LAMSADE Paris Dauphine University - Research Unit n825 in association with the Centre National de Recherche Scientifique D.Valle, P.Zielniewicz. July 1994. Electre 3-4, Version 3.x, Methodology, Volume 1, Document 85. MEPC 56/3/22. Recycling of ships. Examination of the practical of the draft of the international convention for the safe and environmentally sound recycling of ships, submitted by the United Kingdom. IMO, London; 2007. Moen, A.E. 2008. Breaking Basel: The elements of the Basel Convention and its application to toxic ships. Marine Policy 32: 1053-1062. Neser, G., Kontas, A., Unsalan, D. et al. 2012a. Polycyclic aromatic and aliphatic hydrocarbons pollution at the coast of Aliaga (Turkey) ship recycling zone. Marine Polution Bulletin 64: 1055-1059. Neser, G., Kontas, A., Unsalan, D., et al. 2012b. Heavy metal contamination levels at the coast of Aliaga (Turkey) ship recycling zone. Marine Polution Bulletin 64, 882-887. Robin des bois. 2008. Bulletin d'information sur la dmolition des navires, September 2008, 18 pp, n 13, du 7 juin au 21 septembre 2008, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_13.pdf>. Robin des bois. 2009. Bulletin d'information sur la dmolition des navires, April 2009, 37 pp, n15, du 1 janvier au 3 avril 2009, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_15.pdf>. Robin des bois. 2010a. Bulletin d'information sur la dmolition des navires, J anvier 2010, 37 pp, n15, du 25 septembre au 31 decembre 2009, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_18.pdf>. Robin des bois. 2010b. Bulletin d'information sur la dmolition des navires, J uillet 2010, 37 pp, n15, du 5 avril au 1 J uillet 2010, Available at: <http://www.robindesbois.org/dossiers/a_la_casse_20.pdf>. Secretariat of the BASEL Convention - United Nations Environmental Program. 2003. Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships. Basel Convention series/SBC No. 2003/2, 112pp. Tewari, A., Joshi, H.V., Trivedi, H. et al. 2001. The effect of ship scrapping industry and its associated wastes on the biomass production and biodiversity of biota in in situ condition at Alang. Marine Pollution Bulletin 42: 462-469. UNEP. United Nations Environmental Program. 1992. Basel Convention on the Transboundary Movement of Hazardous Wastes and their Disposal, adopted at the Conference of Plenipotentiaries on March 22nd, 1989, 126pp. UNEP. Legal aspects of the full and partial dismantling of ships: Comments provided by Parties and others. Geneva, CH: UNEP; 18 October 2004. Publication no. UNEP/CHW.7/INF/10/Add.1, p. 6. Available at: <http://www.basel.int/meetings/cop/cop7/docs/i10a1e.pdf>.
Fig. 2 - Results of the different evaluations of some visited yards for the decommissioning the SR1 (: 100% waste removal scenario at the yard : the new optimized waste management scenario (depollution offshore), : the new optimized waste management scenario + HSE improvements from yards (H&W had no possible area for more improvements since its reached the best score i.e. 100)).
SPE 157017 17
TABLE 1 - SR1 PROJECT STANDARDS, IMPLICATIONS AND DELIVERABLES Projects Standards Implications & Deliverables 1) SR1 hull was considered as a waste Basel conventions setting up 2) Green passport(s) has to be set up by third parties experts Field surveys by experts 3) A Ship Recycling Plan had to be written Expertise and experience 4) Decommissioning yards had to fulfil HSE standards Audit, CFTs 5) Decommissioning yards had to demonstrate their willing to improve their way of working if discrepancies were pointed out during audits Performance and positive attitude 6) A reliable and complete understanding of the waste management streams had to be set up before any field works Audits, reliability, Basel Conventions, CFTs, supervision 7) A Total E&P representative had to be present all along the dismantling phases to ensure that the SR1 decommissioning was done in a sound way as per approved specifications Yard acceptance, supervision 8) A stakeholder engagement had to be implemented through a positive and constructive dialogue Credibility, boldness, transparency
TABLE 2 - MAIN SUBSTANCES POTENTIALLY DANGEROUS IN THE SEREPCA-1 Pollutants Support Quantities Asbestos containing material Poop deck partition walls and suspended ceilings Approximately 960 m Flooring Some areas of flooring Doors Approximately 40 doors Ventilation system air trunking junction device In all ventilated rooms Paint additives Grey paint on partition walls and beneath poop deck bridges (Lead) Minimum 1800 m (450 m on 4 bridges) Pain inside the front bridge Approximately 1800 m PCBs Askarel electrical transformers Approximately 10 tons Gas Refrigerants (R12/R22) Approximately 200 kg CO2 Over 160 bottles Sulphur Hexafluoride SF6 31 bottles Mercury Measurement System Less than 10 kg Radioactive substances Fire detectors Over 160 detectors Tank bottom sludge Tanks Estimated 170 m 3 (approximately 5 cm thickness) Ballast waters Ballast waters 18 306 m 3
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TABLE 3 - MAIN FINDINGS FROM THE SELECTED YARDS Yard / Location Visited Key points Major Weakness Selected Veolia France/Bordeaux No Proximity from Cameroon Dry dock too small (247 m x 34 m) No Industrial environment European/France HSE & work standards SITA France/Cherbourg No Proximity from Cameroon Floating dock not available No Industrial environment European/France HSE & work standards Van Heyghen Recycling Belgium/Gent No Experience Lock too small (265 m x 37 m) No Industrial environment European/France HSE & work standards Able UK Ltd United Kingdom/Hartlepool No Experience, dry dock As of 23rd June 2009, yard was not licensed No Industrial facilities European/France HSE & work standards CNIC Cameroon/Limb Yes Proximity The yard consisted in a narrow quay which could not accommodate such decommissioning works No No existing structure to treat hazardous waste Leela Ship Recycling Yard India/Alang Yes Large experience Dismantling on the beach Low safety standards Management of hazardous waste No Changjiang Ship Recycling Yard China/Jiangyin Yes Large experience (Maersk, Shell, Exxon) Dismantling at quay is not recommended by the NGOs but tolerated Yes Quay, large infrastructures Human rights ware pointed out by NGOs Timing for dismantling Asbestos removal / can be easily improved Partnership with Maersk Ship Recycling Services PCB management Leyal Ship Recycling Ltd Turkey/Aliaga Yes International HSE Certifications (Iso 14001, ) Dismantling on the beach Yes Safety need to be improved Proximity of waste treatment facilities Limited experience for big ships (ENI) Relatively small infrastructure (one boat by one boat); Site surrounded by small decommissioning yards without any specific care to the Environment Harland & Wolff Heavy Industries Ltd Ireland/Belfast Yes Dry dock (Best Practices recommended by NGOs) Limited experience Yes Compliant with European Standards One year for dismantling Industrial Environment Only one dry dock used for many activities
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TABLE 4 - SR1 FINAL WASTE MANAGEMENT STRATEGY Type of waste Management: Fate / Treatment / Location Tank bottom sediments Removed offshore, shipped to Wouri base and incinerated in Cameroon PCB Removed offshore, shipped to Wouri base and shipped to Europe for treatments Mercury Removed offshore, shipped to Wouri base and shipped to Europe for treatment Ionizing materials Partially removed offshore , shipped to Wouri base and shipped to Europe for recycling Partially kept to maintain the FSO operational during transfer, treated in China: transfer to the Jiangsu Radioactive Environmental Monitoring Management Station Sealed gas Partially removed offshore , shipped to Wouri base and shipped to Europe for incineration Partially kept to maintain the FSO operational during transfer, treated in China (Extraction and incineration with smoke treatment) at the Wuxi facility Asbestos Removed at quay in China according to defined procedures in line with European legislation / landfilled in the Wuxi hazardous waste facility, in double heavy duty polyethylene bags Hydrocarbons Removed at quay in China: storage in special tanks, transportation to specialized subcontractors facility for sale for reuse; possibly Reuse for energy reclamation by incineration
TABLE 5 - WASTE MANAGEMENT STRATEGY FOR THE WASTE EXPORTED TO EUROPE UNDER BASEL CONVENTION PROCEDURE Type Quantity Removed Units Removed by Treated by Reception site Disposal/Recycling facilities Type of process Sediments 226 m3 COMETAL CIMENCAM FIGUIL Cameroon CIMENCAM Cameroon Incorporation in cement process PCB 16318 Kg SRA SAVAC SRA SAVAC INDAVER Anvers, Belgium INDAVER Anvers, Belgium Incineration Transformers 34732 Kg ORTEC S.I. SRA SAVAC Friedlander. SRA SAVAC SITA Decontamination Grimbergen Belgium SITA Decontamination Grimbergen Belgium Decontamination with solvent extraction and recycling metals SF6 sealed gas switches 167 Kg SRA SAVAC SRA SAVAC LRG Lyon, France LRG Lyon, France Incineration Refrigerating sealed gas 1 Bottle SRA SAVAC SRA SAVAC LRG Lyon, France Arkema France Incineration Fluorescent tubes 177 Ind. SRA SAVAC SRA SAVAC SCORI Frontignan, France LABOSERVICES Givors, France Recycling (center RECYCLUM) Mercury 14.6 Kg SRA SAVAC SRA SAVAC SCORI Frontignan, France LABOSERVICES Givors, France Recycling Ionising fire detectors 82 Ind. SRA SAVAC SRA SAVAC SIEMENS Building Technologies Buc, France SIEMENS building Technologies Buc, France Recycling Hydraulic oil and lubes 65 Kg SRA SAVAC SRA SAVAC SCORI Frontignan, France - Heat valorisation Batteries 470 Kg SRA SAVAC SRA SAVAC SCORI Frontignan, France LABOSERVICES Givors, France Recycling Acids solid & liquid 109 Kg SRA SAVAC SRA SAVAC SCORI Frontignan, France LABOSERVICES Givors, France Neutralisation Paint wastes 18.5 Kg SRA SAVAC SRA SAVAC SCORI Frontignan, France - Incineration Sampling gas cylinder 14 Cylinder SRA SAVAC SRA SAVAC SCORI Frontignan, France - Incineration
20 SPE 157017
TABLE 6 - SOME KEY EVENTS BEFORE AND AFTER THE DEPARTURE OF THE SR1 Year Date Events 2007 April End of crude oil storage operations May - July Green Passport: survey and report August - October Marine Environmental Baseline Study: survey and report Transfer of oil to Kingsway FSO, September-December Democking: removal of tank bottom sediments + Hygiene audit 2008 January Democking completed February Ballast water in tanks February - April Complementary audit for Green Passport (specific points: Asbestos) Laboratory analyses of ballast waters, sediments, .... Mars - July Visits of international yards 2009 January-February Removal of hazardous waste to be exported to Europe from SR1 to Wouri base March Removal of anchors 18 march Departure of SR1 03 July Arrival at quay Changyiang Ship Recycling Yard Customs clearance 07 July Crew repatriated Fumigation Ballast waters treated with chlorine Gas free certification 16 July Delivery ceremony in China with Total E&P, SNH, and Maersk 16 July Start of pre-cleaning operations Removal of furniture, loose items Preparation of asbestos material removal Asbestos material removal Asbestos particles monitoring by third expert laboratory (ETS TestConsult Ltd, Hong-Kong) 26 August Ballast water sampling and analyses by Total E&P and external consultancy (Sogreah China). 08 September Asbestos removal completed / start of steel cutting and hot works Site block cutting 17 September Final site clean up 26 October Demolition completed
Here are the porosity calculations for the given intervals:Interval, ft 4143-4157 4170-4178 4178-4185 4185-4190 4197-4205 4210-4217ρL, gm/cc 2.375 2.350 2.430 2.400 2.680 2.450φd, % 18 20 15 17 0 14