STAX Engineering, LLC
215 W Figueroa Street
Santa Barbara, CA 93101
September 25, 2024
City of Richmond
Charles Gerard, Port Director
450 Civic Center Plaza
Richmond, California 94804
Re: STAX Engineering Proposal in response to City of Richmond’s RFP “POINT POTRERO MARINE TERMINAL OCEAN-GOING VESSEL AT BERTH REGULATION”
Dear Charles Gerard:
STAX Engineering, LLC is proud to present our unparalleled CARB Approved Emission Control System (CAECS) for the Port of Richmond’s Point Potrero Marine Terminal (PPMT), in direct re- sponse to the City’s RFP “POINT POTRERO MARINE TERMINAL OCEAN-GOING VESSEL AT BERTH REGULATION.” With a collective executive and operations team experience of over 70 years, STAX Engineering is the most seasoned company in the industry. Our founder, Bob Sharp, pio- neered emissions capture and control technology over two decades ago and has consistently improved its design, making the STAX system the most versatile and technologically advanced CAECS, capable of serving any vessel in the most demanding operational environments.
Our patented self-mooring (spud-equipped barge), with its patented (optional) self-propulsion design, is a testament to our commitment to addressing the unique space and operational challenges at the PPMT. STAX treatment barges feature the industry’s longest positioning boom reach, and their compact and modular design allows for easy capacity expansion or modifica - tion to adapt to the changing needs of vessels visiting the Port. Furthermore, STAX Engineering is the only company with a CARB EO for container and auto carrier/RORO vessels and one for tanker vessels, which is expected to receive approval very soon (Q4 2024). These factors enable us to provide the most comprehensive service to control emissions from vessels visiting your port, ensuring that your air quality objectives are met with the highest level of effectiveness and efficiency.
Our proven operational and logistical track record, demonstrated by our successful commission- ing of a barge at the Port of Los Angeles / Long Beach in 2022 and in Oakland in 2023, along with our rapidly expanding fleet (three more systems under construction and planned for service later this year), underline our ability to meet your service requirements. We are proud to have the most experienced team of trained operators, and our existing contract with the Internation- al Boatman’s Union (IBU) ensures our continued superior service, which has fostered successful customer relationships and secured multi-year and multi-terminal contracts with container, RORO, and tanker vessel operators and terminals.
STAX will obtain all necessary certifications, permits, and permissions to provide CAECS services in the Port of Richmond. STAX will comply with all City of Richmond ordinances. STAX proposes the use of the City Standard Contract for the proposed City costs to offset STAX capi- tal costs to deploy the CAECS.
In conclusion, STAX Engineering is the most experienced CAECS service provider, backed by robust financial support, a top-notch management and operational team, and a proven successful service provision track record. By choosing STAX, you ensure immediate, worry-free compliance for you and your customers. We eagerly anticipate the opportunity to collaborate with you and your team. Please do not hesitate to reach out if you require further information or have any questions.
Sincerely,
Michael Walker
CEO
STAX Engineering, LLC
BIDDER: STAX ENGINEERING, LLC
OCEAN-GOING VESSEL
AT BERTH EMISSIONS
CONTROL SERVICES
POINT POTRERO MARINE TERMINAL
OCEAN-GOING VESSEL AT BERTH REGULATION
BIDDER: STAX ENGINEERING, LLC
CONTENTS
QUALIFICATIONS AND EXPERIENCE .............................................................................1 MANAGEMENT AND STAFFING ..................................................................................... 3
DESCRIPTION OF THE CAECS AND APPROACH
TO PROVIDING SERVICES ............................................................................................... 5 SPACE REQUIREMENTS ........................................................................................................6 CARB EXECUTIVE ORDERS ...................................................................................................7 STAX (PORT) LOCATIONS ................................................................................................8 SCHEDULE ...........................................................................................................................8 COST PROPOSAL ...............................................................................................................8
APPENDIX
QUALIFICATIONS AND EXPERIENCE
STAX Engineering, LLC (STAX) is pleased to present this proposal to provide emissions control services for ocean-going vessels to meet CARB’s At Berth Regulation requirements in the Port of Richmond’s Point Potrero Marine Terminal (PPMT). Our comprehensive under- standing of the marine industry, proven record of superior compliance service, and dedi - cated 24/7/365 operation with two STAXcraft barges in revenue service set us apart from competitors. This track record of successful compliance service of vessels is a testament to our ability to deliver on our promises and meet the needs of our clients, instilling confidence in the feasibility and success of our proposal.
STAX Engineering is leading the industry, driven by a dedicated investor team and bolstered by robust revenue streams from our operational barges. With a strategic financing mecha- nism in place, STAX is fully prepared to expand its barge fleet efficiently to meet the require- ments of the impending At Berth Regulation compliance deadline of January 1, 2025. The company has already secured agreements with numerous carriers and terminals, ensuring timely deployment of capture and control barges well before the deadline. Currently, three barges are under construction in the shipyard, with several more in the pipeline, affirming STAX’s commitment to meeting regulatory obligations and advancing environmental stew- ardship in maritime operations. This strategic planning and preparedness should provide the audience with reassurance about the implementation and adherence to the regulatory obligations of our proposal.
STAX Engineering, LLC 1
STAX Engineering is the only company awarded executive orders by the California Air Resources Board (CARB) for CARB-approved emission control systems (CAECS) complying with their At-Berth Regulation for container and auto carriers/RORO vessels with approved test plans to expand the operating envelope of our systems to include all vessel sizes by Q4 of this year. STAX, with our CARB-approved tanker test plan, is well on its way to obtaining additional approval from CARB to service the tanker sector beginning next year.
STAX Engineering, LLC 2
Our commitment to exceptional service, financial stability, technology, and seasoned professionals has helped us secure contracts with multiple carriers, terminals, and ports.
Our clientele includes the top two auto carriers in California, Nippon Yusen Kabushiki Kaisha (NYK Line) & Hyundai GLOVIS Co., Ltd., two leading container carriers, CMA CGM Group and ZIM Integrated Shipping Services Ltd. (ZIM), a tanker terminal operated by Shell plc, three auto carrier terminals, AMPORTS, SSA, and Toyota and one port, Port of Hueneme. This extensive client base reflects our relentless pursuit of excellence and innovation in the indus- try.
MANAGEMENT AND STAFFING
STAX Engineering is a team of professionals specializing in Emissions Capture and Control Systems (ECCS) technology with over 70 years of combined experience in ECCS design and service. The STAX leadership team consists of Mike Walker, a proven technology Chief Exec- utive Officer; Bob Sharp, our Founder and Chief Technology Officer; Dr. John Holmes (CAPT, USCG, ret.), our Chief Operating Officer; and Dr. Randall Pasek, our Chief Regulatory Officer.
Michael Walker has been CEO of STAX since 2019. During this time, he has overseen the construction of several barge systems and manages product commercialization, marketing, contracting, and accounting.
Michael has over 20 years of operations, management, and leadership experience in building companies, from the pre-commercialization start-up phase to successful market penetration and integration in environmental infrastructure markets. His financial acumen provides a solid foundation for STAX’s future expansion and ongoing operations.
Bob Sharp, an original capture and control technology pioneer since 2004, is the Founder and CTO of STAX Engineering. Bob has experi- ence developing several ECCS barges, implementing lessons learned over the past 20 years, and researching principles in science and health to develop the current next-generation (STAX) system. Bob founded STAX in 2016.
Dr. John Holmes, COO of STAX Engineering, is a former Coast Guard Captain with over 40 years of maritime experience. He has served in various roles, including Independent Marine Consultant, COO, For- tune 500 executive, and senior-level U.S. Coast Guard Officer. He has previously captained the San Pedro Bay Ports and was Deputy Exec- utive Director for the Port of Los Angeles from 2007-2013, oversee- ing operations at the nation’s largest Port. John began working with barge-based ECCS in 2013 and joined STAX in 2022.
Dr. Randall Pasek, Chief Regulatory Officer, has extensive experience with operations and regulatory compliance of ECCS systems. He has amassed over 35 years in air pollution control, with al- most two decades of experience at the California Air Resources Board and a decade of experience working on similar off-road projects at the South Coast Air Quality Management District. Dr. Pasek joined STAX in 2018.
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The expanded STAX team comprises more than 30 full-time employees, including additional support staff supplied by the International Boatman’s Union (IBU). The STAX management model focuses on decentralized (local) operations with a centralized support infrastructure.
The operational support team includes an Assistant Director of Operations, Barge Supervi- sors, Systems Manager, Support Engineer, System Operators, and deckhands. Each area of operation has a local area manager and Barge Supervisors tasked with ensuring the main- tenance and operation of the STAXcraft barge, scheduling personnel and tug(s), and work- ing with and being available for local stakeholders to ensure that the barge(s) meet CARB requirements with minimal impact to port operations.
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A STAX crew, including a Barge Supervisor, two System Operators, and three deckhands, will operate each barge. Service will be crewed on twelve-hour shifts by a two-person team consisting of one System Operator and one deckhand. The System Operator supervises the barge’s operations, places the collection device, and monitors and adjusts the system. The deckhand maintains the lines, operates the spuds, and assists the System Operator in moni- toring service operations. The local Barge Supervisor (a qualified System Operator) will serve as the relief System Operator and perform supervisory duties. The third deckhand will serve as a relief. IBU has committed to providing deckhands for our PPMT barge.
In addition, all STAX barges are connected by the internet to key technology, engineering, and maintenance personnel who can examine the health and operation of the processing systems remotely to assist the crew with efficient system operation.
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DESCRIPTION OF THE CAECS AND APPROACH TO PROVIDING SERVICES Our STAX Engineering team and technology are ideally suited to operating smoothly in the Port of Richmond. The STAX CAECS typically includes a 160-foot-long and 40-foot-wide barge, STAXcraft, that contains two processing units, STAXbox, powered by electricity provided by on-board diesel generators. The STAXcraft barge draws approximately three feet (depending on the ballast the barge has on board) and has approximately six feet of free- board. All U.S. Coast Guard-required safety equipment and certifications are included in the design.
The STAXcraft includes a patented exhaust capture system, XCAP™, consisting of a placement arm (boom) with the industry’s most extended reach (252 feet, 279 feet with pedestal) and a proprietary connection system (bonnet) adaptable to all types of exhaust pipe configurations (U.S. Patents 11,325,687 and 11,345,455).
STAX has experience with auto carrier/RORO vessels with unique stack configurations and added fixtures. We tested our ECCS system on vessels from four companies with four unique stack configurations during auto carrier testing for CARB EO approval.
The STAX placement arm has two ducts equipped to capture exhaust from two exhaust pipes simultaneously. Ship exhaust is ducted to two independent STAXbox purification sys- tems, which control NOx, PM10, PM2.5, DPM, and ROG to meet regulatory levels.
The STAX system is powered by Tier 4F gensets running on renewable diesel that meets or exceeds grid-neutral requirements. These generators burn specially blended renewable die- sel with an ultra-low carbon intensity (CI). STAX barges have federal and state Certificates of Financial Responsibility (COFR) and a NonTank Vessel Oil Spill Contingency Plan approved by the State of California.
A central data management system that records and analyzes emissions in real-time con- trols and monitors the entire STAX system. System Operators and remote personnel can monitor the system 24/7 to ensure its health and efficient operation. STAX will monitor and report per the At Berth Regulation requirements and any Executive Order provisions through an automated emissions monitoring system, generating 7-day and 30-day reports. STAX will report malfunctions to the Port and CARB within the regulatory time frames. All data and records are stored for the required five years.
STAX provides the most flexible system for barge positioning. STAX will select the best out of three options to move and position the STAXcraft barge. The preferred approach is to use local tug service. A STAXcraft barge may also use its patented self-propulsion system (U.S.
Patent 10,953,960). Lastly, STAX may use the tugs already available on-site to escort the vessels for movement of the barge. This operational flexibility helps STAX meet unique chal- lenges during day-to-day vessel traffic and for all vessel placement scenarios.
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STAX has developed Standard Operation Procedures (SOPs) that ensure proper coordina- tion with the vessel and tug. One such document is the STAX Engineering Introduction and Safety Instructions, which includes detailed information on the STAX system, answers to fre- quently asked questions, data forms for vessel operators, and a comprehensive list of critical safety issues. This document is sent to vessels one week before scheduled service visits.
The STAX team has consistently delivered on several hundred service calls within 2 hours of “Ready to Work” and 1 hour of “Pilot on Board” as mandated by CARB regulations. STAX fur- ther solidifies its commitment to safety by pledging to collaborate with the Port to devise a port-specific rapid response plan for relocating the barge if required by ships shifting berth- to-berth.
STAX leaves no room for uncertainty when it comes to meeting CARB deadlines. We have op- erations personnel on standby 24 hours a day, ready to spring into action. It is STAX policy to promptly engage tugs to ensure the barge is prepared and waiting for a ship’s arrival. STAX has maintained a flawless record, never failing to meet the CARB requirements.
STAX SPACE REQUIREMENTS
A STAXcraft barge will require approximately 180 feet of dock space. Parking for a maximum of six staff vehicles will be required daily. A 240-volt shore power receptacle and a small secure shoreside storage area are also requested.
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CARB EXECUTIVE ORDERS AND APPROVED TEST PLANS
STAX is the 2021 California Air Resource Board’s grant recipient for technology advancement, ensuring our solutions meet expanding regulations today and in the future.
Executive Orders for STAX CARB-approved emission control systems (CAECS) for compliance with the At Berth Regulation.
EO G-23-294
A barge based capture and control system to treat emissions from auxiliary engines on ocean-going container vessels.
EO G-24-054
A barge based capture and control system to treat emissions from auxiliary engines on ocean-going auto carriers/roll-on roll-off (RORO) vessels.
It is important to note that CARB Executive Orders are issued based on the capacity of the systems on the vessel available for EO testing. STAX will continuously conduct testing and evaluation to expand our Executive Orders and ensure that our ECCS continues to meet the requirements of any vessel that calls on West Coast ports.
STAX anticipates receiving a third EO later this year for a barge based capture and control system to treat emissions from auxiliary engines on ocean-going tanker vessels.
The Appendix includes copies of CARB Executive Orders for container and RORO vessels, letters for three CARB-approved test plans for tanker vessels, and the expansion of the load range for the container and RORO vessel categories. All testing is expected to be completed in Q3 of this year, and Executive Orders will be issued before the end of the year.
STAX (PORT) LOCATIONS
For further confirmation of our treatment and service record, STAX is pleased to share the following port locations where STAX operates.
Port of Los Angeles (since 2022)
Port of Long Beach (since 2022)
Port of Oakland (since 2023)
Port of Hueneme (Q4 2024)
Port of Benicia (Q1 2025)
STAX operations at the Port of Richmond will continue to deliver the same high-quality service that we have demonstrated by implementing our time-proven training, operations, customer service, and top-quality equipment.
SCHEDULE
STAX will have a barge available for service in PPMT by January 2025. STAXcraft barges three, four, and five are in production and expected to be ready for deployment in the third and fourth quarters of 2024.
COST PROPOSAL
STAX Engineering will provide one barge system with management, staffing, and support for servicing auto carriers/RORO vessels for all hours for all days per year.
The Port of Richmond will be responsible for $500,000 to offset the capital costs to deploy the barge in PPMT. Billing and payments may be spread across as many as 24 months.
STAX will service auto carrier/RORO ships on a tier system based on the number of visits/ hours, with rates ranging between $1500 - $3200 per hour. STAX has existing multi-year and multi-terminal contracts in place with NYK Line and Hyundai GLOVIS Co., Ltd. STAX will bill these carriers directly per the terms of their contracts.
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APPENDIX
FORMS
ATTACHMENT B
RICHMOND SANCTUARY CITY CONTRACTING ORDINANCE NO. 12-18
Docusign Envelope ID: D45D7BDF-A0C0-42E3-824B-D6E70216C836 Docusign Envelope ID: D45D7BDF-A0C0-42E3-824B-D6E70216C836 Docusign Envelope ID: D45D7BDF-A0C0-42E3-824B-D6E70216C836 Docusign Envelope ID: D45D7BDF-A0C0-42E3-824B-D6E70216C836
CITY OF RICHMOND
Sanctuary City Compliance Statement
The undersigned, an authorized agent of (hereafter "Contractor"), h as had an o pportunity to rev iew the requ irements of City of Richmond Ordinance 12 -18 ( hereafter " Sanctuary C ity Contracting O rdinance" or “SCCO”). Contra ctor unders tands and agrees th at the C ity m ay choose w ith whom it will m aintain business relations and may refrain from contracting with any person or entity that provides Data Broker or Extreme Vetting services to the U.S. Immigration and Customs Enforcement Division of the United States Department of Homeland Security (“ICE”). Contractor understands the meaning of the following terms used in the SCCO:
a. " Data Broker” means either of the following:
i. The co llection of information, including personal information about consumers, from a wide variety of sources for the purposes of reselling such information to their customers, which include both private-sector business and government agencies;
ii. The a ggregation of data that was collected for another purpose from that for which it is ultimately used.
b. “Ex treme Vetting” means data mining, threat modeling, predictive risk analysis, or other similar services."
Con
tractor unders tands th at it is not e ligible to rec eive or r etain a City contra ct if at the time the Contra ct is executed, or at any time during the term of the Con tract, it provides Data Broker or Ex treme Vetting services to ICE.
Contractor further unders tands and agrees that Contractor's fail ure to comply with the S CCO shall constitute a material default of th e Contract and the C ity Manag er m ay terminate the Contra ct and b ar Contra ctor fro m bidding on future contracts with the City for five (5) years from the effective date of the contract termination.
By execu
ting this Statement, Contractor certifies that it complies with the requirements of the SCCO and that if at any time during the te rm of the Contract it ceases to comply, Contractor will promptly notify the City Manager in writing. Any person or entity who knowingly or willingly supplies false information in violation of the S CCO shall be guilty of a misdemeanor and subject to a $1,000 fine.
Based on the for egoing, the undersi gned dec lares und er penalty of perjury und er the laws of the State of California that the foregoing is true and correct. Executed this d ay of , 20 , at , C alifornia.
Printed Name: T itle:
Signed: Date:
Business Entity:
Docusign Envelope ID: D45D7BDF-A0C0-42E3-824B-D6E70216C836 9/20/2024
24 September
STAX Engineering, LLC
20th
Santa Barbara
CEO
STAX Engineering, LLC
Michael Walker
ATTACHMENT C
RESOLUTION NO. 86-21 - DISCLOSURE STATEMENT OF LIMITED LIABILITY COMPANIES FORM
Docusign Envelope ID: 1A042FF3-F92C-4B2E-8C35-FE6808A4FED7 Docusign Envelope ID: 1A042FF3-F92C-4B2E-8C35-FE6808A4FED7 Docusign Envelope ID: 1A042FF3-F92C-4B2E-8C35-FE6808A4FED7 Disclosure Statement for Limited Liability Companies
This Statement Shall be included with all Bid and Proposal Submissions Is your Business a Limited Liability Company (LLC)? YES NO If you answered YES, please provide the City with the names and business addresses of any and all shareholders, directors, officers, members, managers, other authorized persons, partners, and “Beneficial Owners” of the applying LLC. A Beneficial Owner is any person or entity who: (1) exercises substantial control over the applying LLC; (2) owns 25% or more of the interest in the applying LLC; or (3) receives substantial economic benefits from the assets of the applying LLC.
If any LLC shareholder, director, officer, member, manager, other authorized person, partner, or Beneficial Owner is itself an LLC or other business entity, the names and business addresses must also be provided for any and all shareholders, directors, officers, members, managers, other authorized persons, partners, and Beneficial Owners of that LLC or other business entity all the way up through each entity in the organizational chart until ultimate ownership by individual people is disclosed.
Name: _____________________
Title: _____________________
Address:__________________________________________
Name: _____________________
Title: _____________________
Address:__________________________________________
Name: _____________________
Title: _____________________
Address:__________________________________________
☐ Check this box if additional ownership information is attached to this Disclosure Statement.
In signing this Disclosure Statement, I represent that the information submitted in this Disclosure Statement, and any attachments, is true and correct.
Signature: _____________________
Printed Name: _____________________
Title: _____________________
Date: _____________________
STAX Holding, Inc.
215 W Figueroa St, Santa Barbara, CA 93101
Robert Sharp
Founder, CTO
1895 Old Ranch Road, Camarillo, CA 93012
Michael Walker
CEO
Docusign Envelope ID: 1A042FF3-F92C-4B2E-8C35-FE6808A4FED7 9/24/2024
CARB
EXECUTIVE ORDERS
Executive Order G-23-294 1
State of California
AIR RESOURCES BOARD
Executive Order G-23-294
CARB Approval of the STAXbox.A-1 system used to control emissions from container vessels for compliance with the Control Measure for Ocean-Going Vessels At Berth STAX Engineering (STAX)
STAXbox.A-1
WHEREAS August 27, 2020, the California Air Resource Board (CARB) adopted the Control Measure for Ocean-Going Vessels (OGV) At Berth, California Code of Regulations, sections 93130 - 93130.22 (2020 At Berth Regulation), which establishes requirements for ocean-going vessels at berth in a California port to reduce oxides of nitrogen (NOx), diesel particulate matter (PM), and reactive organic gases (ROG) emissions from auxiliary engines; WHEREAS section 93130.5 of the 2020 At Berth Regulation establishes requirements for an emission control strategy to qualify as a CARB Approved Emission Control Strategy (CAECS) that can be used to reduce emissions from ocean-going vessel auxiliary engines and applicable tanker auxiliary boilers while at berth in a California port; WHEREAS no emission control strategy may be used to comply with the requirements of the 2020 At Berth Regulation unless CARB approves it as a CAECS; WHEREAS t he 2020 At Berth Regulation requires that the emission control strategy, if applicable for auxiliary engines, achieves emission rates of less than 2.8 grams per kilowatt hour (g/kW-hr) for NOx, 0.03 g/kW-hr for PM 2.5, and 0.1 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS for strategies approved after 2020, greenhouse gas (GHG) emissions from the strategy must be grid-neutral using the grid emission rate for the year that the technology is granted an Executive Order, as specified under section 93130.5(d); WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for tanker auxiliary boilers, achieves emission rates less than 0.4 g/kW-hr for NOx, 0.03 g/kW-hr for PM 2.5, and 0.02 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d); WHEREAS STAX developed STAXbox.A-1, a barge-based capture and control system to reduce emissions from the auxiliary engines on an ocean-going vessel while at berth; WHEREAS, STAXbox.A-1 consists of the following components and subcomponents as specified in the Description of Control Strategy in “Test Plan: STAXbox Emissions Control System” (Test Plan) including: an exhaust capture system using flexible ducting, and an emission control system comprising of a particulate filter and Selective Catalytic Reduction (SCR) unit to reduce NOx, PM, and ROG;
Executive Order G-23-294 2
WHEREAS STAX submitted their final Test Plan on February 28, 2023, and CARB issued STAX a Test Plan approval letter on April 10, 2023;
WHEREAS STAX submitted the “Emissions Measurement from Ocean Going Container Vessels Using a Capture and Control System” (Test Report) and “Application for CARB Approval of STAX Engineering’s STAXBox Emissions Control System as a CARB Approved Emissions Control Strategy (CAECS)” (request for Executive Order) for the STAXbox.A-1, dated May 2, 2023;
WHEREAS CARB reviewed and evaluated the Test Report and request for Executive Order for the STAXBox Emissions Control System based on the requirements specified in the 2020 At Berth Regulation;
WHEREAS CARB found the submitted documents indicate STAXbox.A-1 achieves the emission reductions and has GHG emissions that are grid neutral for 2023 as stated in the Test Report and required by the 2020 At Berth Regulation under section 93130.5(d); WHEREAS the Executive Officer finds it is appropriate to issue this Executive Order that identifies the operating conditions, recordkeeping, and monitoring requirements for STAX’s use of the STAXbox.A-1 to allow its use as a CAECS for compliance with the 2020 At Berth Regulation;
WHEREAS this ap proval does not constitute an air pollution or land use permit, nor does it relieve the responsibility of STAX or the end user to comply with all Federal, State, and local laws, rules, and regulations;
WHEREAS STAX is subject to the 2020 At Berth Regulation as a CAECS operator; NOW, THEREFORE, IT IS ORDERED that the STAXbox.A-1 is approved for use in demonstrating compliance with the 2020 At Berth Regulation as a CAECS, when used by STAX as intended and in accordance with the following terms and conditions, and in accordance with all other applicable requirements in the 2020 At Berth Regulation.
APPROVED OPERATING CON DITIONS
Parameter Value
Ocean-going vessel engine type One auxiliary engine
Ocean-going vessel type Container vessel
Ocean-going vessel fuel composition limitation
Marine distillate fuel meeting 0.1% sulfur content
limit (0.1% sulfur marine gas oil (MGO) or marine
diesel oil (MDO)), or R99/R100 renewable diesel
fuels that meet the specifications of MGO/MDO
SCR inlet operating temperature range in degrees
Fahrenheit (⁰F) 600 – 720⁰F
Ocean-going vessel engine maximum continuous
rating (MCR) in kilowatts (kW) 3,500 kW
Executive Order G-23-294 3
Parameter Value
Ocean-going vessel allowable operating range (kW) 266 kW to 890 kW Allowable exhaust flow rate in standard cubic feet
per minute (scfm) 3,642 to 6,330 scfm of engine exhaust Maximum engine exhaust temperature requirements 1,000⁰F Static Pressure Differential pressure between -2 to -20 inches of water across the diesel particulate filter
Other parameters that affect performance 1-2 inches of water back pressure at the capture system inlet
GRID Neutral Target – CA CO2e state output
emission rate from eGRID2021 in pounds per
megawatt hour (lb/MWh)
480.5 lb/MWh
Maximum CAECS auxiliary generator operating load
(kW) 382 kW
CAECS auxiliary generator renewable diesel carbon
intensity limit in grams of carbon dioxide equivalent
per megajoule of fuel (g CO2e/MJ)
29.49 g CO2e/MJ fuel
Maximum ammonia slip emissions in parts per
million by volume, dry basis (ppmdv) 5 ppmdv averaged over 60 minutes
OPERATIONAL REQUIREMENTS
BE IT FURTHER ORDERED, STAX will operate the STAXbox.A-1 following the notification and operational requirements per sections 93130.12(b)(1) and 93130.12(b)(2):
1. At least seven calendar days before a vessel’s arrival, the operator of the CAECS must coordinate in writing with the vessel operator and terminal operator for the use of the strategy and supply the vessel operator with information about the compatibility with the vessel and terminal of the CAECS.
2. During each visit, the operator of the CAECS shall:
a. Begin controlling emissions within two hours of vessel “Ready to Work”; b. Record inlet and outlet levels of emissions during the visit; c. Continue controlling emissions until at least one hour before “Pilot on Board”; and
d. Ensure vessels are operating on CARB compliant distillate marine fuel.
MONITORING R EQUIREMENTS
BE IT FURTHER ORDERED, for every 1,000 hours of operation (and at a minimum annually), STAX shall submit data to the Executive Officer from the continuous emission monitoring system (CEMS) for each visit the CAECS is operated, to verify that the emission reduction levels are maintained, paying the applicable Certification Fee for the At Berth Regulation (Division 3, Chapter 16, Article 7, sections 2913 and 2914) for each visit.
Executive Order G-23-294 4
BE IT FURTHER ORDERED, the CEMS parameters submitted to the Executive Officer must follow the parameters and measurement methods listed in STAX’s Test Plan submitted on February 28, 2023.
BE IT FURTHER ORDERED, within 30 days of a vessel departure, for every visit where STAXbox.A-1 is used as a CAECS, STAX shall report to CARB visit information as required by section 93130.12(b)(3).
BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their vessel operator customers the information necessary for vessel operators to submit their visit information to CARB as required by section 93130.7(e)(4), including the following:
1) Emissions control start date and time
2) Emission control end date and time
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.
BE IT FURTHER ORDERED, when vessel operators submit visit information to CARB as required by section 93130.7(e)(4), the vessel operator must also report the following information per the compliance instructions for section 93130.7(e)(4)(Q):
1) Total power generated by vessel’s auxiliary engines while at berth in kW-h. Data must be recorded at a minimum once an hour.
BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their terminal operator customers the information necessary for terminal operators to submit their visit information to CARB as required by section 93130.9(d)(5), including the following:
1) Emissions control start date and time;
2) Emission control end date and time;
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.
BE IT FURTHER ORDERED, STAX shall maintain the STAXbox.A-1in accordance with “Section 5. Maintenance” of STAX’s Test Plan.
BE IT FURTHER ORDERED, the Executive Officer may request that the STAXbox.A-1 be tested annually using the test methods specified in the 2020 At Berth Regulation to demonstrate the overall percentage of the emission reduction being achieved, and the results of such testing shall be provided to the Executive Officer within 30 days of testing per section 93130.5(j) of the 2020 At Berth Regulation.
MALFUNCTI ON REPORTING and RECORDKEEPING REQUIREMENTS
BE IT FURTHER ORDERED, STAX shall report within 24 hours to CARB, by electronic means, any malfunction that is expected to create emissions in excess of any applicable emissions Executive Order G-23-294 5
limitation for a period greater than one hour and shall retain for five years all records pertaining to the malfunction pursuant to section 93130.12.
BE IT FURTHER ORDERED, a delay or interruption in emissions control caused by a malfunction is eligible for remediation for the hours of uncontrolled emissions only when CARB is notified by STAX according to the provisions of section 93130.12(c).
BE IT FURTHER ORDERED, STAX shall submit a corrective action report within seven calendar days after a malfunction has been corrected as pursuant to section 93130.12(d).
BE IT FURTHER ORDERED, records made pursuant to section 93130.12 shall be kept for a minimum of five years and STAX shall submit information to CARB according to section 93130.19.
BE IT FURTHER ORDERED, this approval is subject to the following conditions:
• STAX must submit documentation, within 30 days upon request, to CARB showing STAXbox.A-1 is being maintained and the maintenance schedule in “Section 5.
Maintenance” of STAX’s Test Plan is being adhered to.
• STAX must keep records, including purchase receipts, for a minimum of five years, for renewable diesel purchases demonstrating the fuel used on the STAXbox.A-1 complies with the Approved Operating Conditions in this Executive Order. • S TAX must communicate with the vessel operator and ensure the vessel is only operating one auxiliary engine while the STAXbox.A-1 is controlling emissions. • Delays or interruptions in emissions control caused by a malfunction, or when the operational requirements in section 93130.12(b)(2) are not met may result in enforcement actions and ultimately revocation of the EO unless the visits are made compliant through use of the Remediation Fund or with a Vessel Incident Event (VIE) or Terminal Incident Event (TIE).
DESIGN CHANGES AND EXTENSIONS
BE IT FURTHER ORDERED, no changes are permitted to STAXbox.A-1 design, or approved operating parameters set forth in STAX’s application, test plan, and this Executive Order and its appendices, unless CARB is notified in advance per section 93130.5(i)(2). Design changes include changes to any part of the STAXbox.A-1 system including the exhaust capture hood, ducting, control equipment, and deployment platform. The changes must be approved in writing by the Executive Officer and any applicable Certification Fees for the At Berth Regulation (Division 3, Chapter 16, Article 7, sections 2913 and 2914) must be paid before the modifications may be used for compliance with the 2020 At Berth Regulation. The Executive Officer may revoke this Executive Order if the STAXbox.A-1 design or approved operating parameters are changed without prior notification and approval by the Executive Officer.
BE IT FURTHER ORDERED, this Executive Order shall have a duration of five years from the date it is executed unless it is revoked by CARB as set forth in section 93130.5(l). As specified in section 93130.5(i)(1), at least six months prior to the expiration of this Executive Order G-23-294 6
Executive Order, STAX may apply for an extension by submitting an extension application to the Executive Officer asserting that the strategy has not changed and is still effective, following the requirements specified in section 93130.5(d) as provided in section 93130.5(i)(1) of the Control Measure, after paying any applicable Certification Fees for the At Berth Regulation (Division 3, Chapter 16, Article 7, sections 2913 and 2914).
BE IT FURTHER ORDERED, marketing of the STAXbox.A-1 using any identification other than that shown in this Executive Order or marketing of the STAXbox.A-1 for an application other than those listed in this Executive Order shall be prohibited unless prior approval is obtained from CARB.
BE IT FURTHER ORDERED, this Executive Order does not relieve STAX from complying with all other applicable regulations.
BE IT FURTHER ORDERED, this Executive Order may be revoked if the Executive Officer determines that STAXbox.A-1 does not comply with any of the requirements in this Executive Order.
Executed at Sacramento, California, this 4th day of December, 2023.
______________________________
Bonnie Soriano, Branch Chief
Freight Activity Branch
Transportation and Toxics Division
Executive Order G-24-054 1
State of California
AIR RESOURCES BOARD
Executive Order G-24-054
CARB Approval of the STAXbox.A-1 system used to control emissions from auto carriers/roll-on roll-off (ro-ro) vessels for compliance with the Control Measure for Ocean-Going Vessels At Berth
STAX Engineering (STAX)
STAXbox.A-1
WHEREAS August 27, 2020, the California Air Resource Board (CARB) adopted the Control Measure for Ocean-Going Vessels (OGV) At Berth, California Code of Regulations, sections 93130 - 93130.22 (2020 At Berth Regulation), which establishes requirements for ocean-going vessels at berth in a California port to reduce oxides of nitrogen (NOx), diesel particulate matter (PM), and reactive organic gases (ROG) emissions from auxiliary engines; WHEREAS section 93130.5 of the 2020 At Berth Regulation establishes requirements for an emission control strategy to qualify as a CARB Approved Emission Control Strategy (CAECS) that can be used to reduce emissions from ocean-going vessel auxiliary engines and applicable tanker auxiliary boilers while at berth in a California port; WHEREAS no emission control strategy may be used to comply with the requirements of the 2020 At Berth Regulation unless CARB approves it as a CAECS; WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for auxiliary engines, achieves emission rates of less than 2.8 grams per kilowatt hour (g/kW-hr) for NOx, 0.03 g/kW-hr for PM 2.5, and 0.1 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS for strategies approved after 2020, greenhouse gas (GHG) emissions from the strategy must be grid-neutral using the grid emission rate for the year that the technology is granted an Executive Order, as specified under section 93130.5(d); WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for tanker auxiliary boilers, achieves emission rates less than 0.4 g/kW-hr for NOx, 0.03 g/kW-hr for PM 2.5, and 0.02 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d); WHEREAS STAX developed STAXbox.A-1, a barge-based capture and control system to reduce emissions from the auxiliary engines on an ocean-going vessel while at berth; WHEREAS, STAXbox.A-1 consists of the following components and subcomponents as specified in the Description of Control Strategy in “Test Plan: STAXbox Emissions Control System” (Test Plan) including: an exhaust capture system using flexible ducting, and an Executive Order G-24-054 2
emission control system comprising of a particulate filter and Selective Catalytic Reduction (SCR) unit to reduce NOx, PM, and ROG;
WHEREAS STAX submitted their final Test Plan for ro-ro vessels on February 28, 2023, and CARB issued STAX a Test Plan approval letter on April 10, 2023; WHEREAS STAX submitted the “Emissions Measurement from Ocean Going Roll On/Roll Off (RoRo) Vessels Using a Capture and Control System” (Test Report) for the STAXbox.A-1, on May 26, 2023 and request for Executive Order;
WHEREAS CARB reviewed and evaluated the Test Report and request for Executive Order for the STAXBox.A-1 Emissions Control System based on the requirements specified in the 2020 At Berth Regulation;
WHEREAS CARB found the submitted documents indicate STAXbox.A-1 achieves the emission reductions and has GHG emissions that are grid neutral for 2024 as stated in the Test Report and required by the 2020 At Berth Regulation under section 93130.5(d); WHEREAS the Executive Officer finds it is appropriate to issue this Executive Order that identifies the operating conditions, recordkeeping, and monitoring requirements for STAX’s use of the STAXbox.A-1 to allow its use as a CAECS for compliance with the 2020 At Berth Regulation;
WHEREAS this approval does not constitute an air pollution or land use permit, nor does it relieve the responsibility of STAX or the end user to comply with all Federal, State, and local laws, rules, and regulations;
WHEREAS STAX is subject to the 2020 At Berth Regulation as a CAECS operator; NOW, THEREFORE, IT IS ORDERED that the STAXbox.A-1 is approved for use in demonstrating compliance with the 2020 At Berth Regulation as a CAECS, when used by STAX as intended and in accordance with the following terms and conditions, and in accordance with all other applicable requirements in the 2020 At Berth Regulation. The approved operating conditions including the vessel and engine types for which the STAXbox.A-1 is verified can be found in Attachment 1.
OPERATIONAL REQUIREMENTS
BE IT FURTHER ORDERED, STAX will operate the STAXbox.A-1 following the notification and operational requirements per sections 93130.12(b)(1) and 93130.12(b)(2):
1. At least seven calendar days before a vessel’s arrival, the operator of the CAECS must coordinate in writing with the vessel operator and terminal operator for the use of the strategy and supply the vessel operator with information about the compatibility with the vessel and terminal of the CAECS.
2. During each visit, the operator of the CAECS shall:
a. Begin controlling emissions within two hours of vessel “Ready to Work”; b. Record inlet and outlet levels of emissions during the visit; Executive Order G-24-054 3
c. Continue controlling emissions until at least one hour before “Pilot on Board”; and
d. Ensure vessels are operating on CARB compliant distillate marine fuel.
MONITORING REQUIREMENTS
BE IT FURTHER ORDERED, for every 1,000 hours of operation (and at a minimum annually), STAX shall submit data to the Executive Officer from the continuous emission monitoring system (CEMS) for each visit the CAECS is operated, to verify that the emission reduction levels are maintained, paying the applicable Certification Fee for the At Berth Regulation (Division 3, Chapter 16, Article 7, sections 2913 and 2914) for each visit.
BE IT FURTHER ORDERED, the CEMS parameters submitted to the Executive Officer must follow the parameters and measurement methods listed in STAX’s Test Plan submitted on February 28, 2023.
BE IT FURTHER ORDERED, within 30 days of a vessel departure, for every visit where STAXbox.A-1 is used as a CAECS, STAX shall report to CARB visit information as required by section 93130.12(b)(3).
BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their vessel operator customers the information necessary for vessel operators to submit their visit information to CARB as required by section 93130.7(e)(4), including the following:
1) Emissions control start date and time
2) Emission control end date and time
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.
BE IT FURTHER ORDERED, when vessel operators submit visit information to CARB as required by section 93130.7(e)(4), the vessel operator must also report the following information per the compliance instructions for section 93130.7(e)(4)(Q):
1) Total power generated by vessel’s auxiliary engines while at berth in kW-h. Data must be recorded at a minimum once an hour.
BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their terminal operator customers the information necessary for terminal operators to submit their visit information to CARB as required by section 93130.9(d)(5), including the following:
1) Emissions control start date and time;
2) Emission control end date and time;
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.
BE IT FURTHER ORDERED, STAX shall maintain the STAXbox.A-1in accordance with “Section 5. Maintenance” of STAX’s Test Plan.
Executive Order G-24-054 4
BE IT FURTHER ORDERED, the Executive Officer may request that the STAXbox.A-1 be tested annually using the test methods specified in the 2020 At Berth Regulation to demonstrate the overall percentage of the emission reduction being achieved, and the results of such testing shall be provided to the Executive Officer within 30 days of testing per section 93130.5(j) of the 2020 At Berth Regulation.
MALFUNCTION REPORTING and RECORDKEEPING REQUIREMENTS
BE IT FURTHER ORDERED, STAX shall report within 24 hours to CARB, by electronic means, any malfunction that is expected to create emissions in excess of any applicable emissions limitation for a period greater than one hour and shall retain for five years all records pertaining to the malfunction pursuant to section 93130.12.
BE IT FURTHER ORDERED, a delay or interruption in emissions control caused by a malfunction is eligible for remediation for the hours of uncontrolled emissions only when CARB is notified by STAX according to the provisions of section 93130.12(c).
BE IT FURTHER ORDERED, STAX shall submit a corrective action report within seven calendar days after a malfunction has been corrected as pursuant to section 93130.12(d).
BE IT FURTHER ORDERED, records made pursuant to section 93130.12 shall be kept for a minimum of five years and STAX shall submit information to CARB according to section 93130.19.
BE IT FURTHER ORDERED, this approval is subject to the following conditions:
• STAX must submit documentation, within 30 days upon request, to CARB showing STAXbox.A-1 is being maintained and the maintenance schedule in “Section 5.
Maintenance” of STAX’s Test Plan is being adhered to.
• STAX must keep records, including purchase receipts, for a minimum of five years, for renewable diesel purchases demonstrating the fuel used on the STAXbox.A-1 complies with the Approved Operating Conditions in this Executive Order. • STAX must communicate with the vessel operator and ensure the vessel is only operating one auxiliary engine while the STAXbox.A-1 is controlling emissions. • Delays or interruptions in emissions control caused by a malfunction, or when the operational requirements in section 93130.12(b)(2) are not met may result in enforcement actions and ultimately revocation of the Executive Order unless the visits are made compliant through use of the Remediation Fund or with a Vessel Incident Event (VIE) or Terminal Incident Event (TIE).
DESIGN CHANGES AND EXTENSIONS
BE IT FURTHER ORDERED, no changes are permitted to STAXbox.A-1 design, or approved operating parameters set forth in STAX’s application, test plan, and this Executive Order and its appendices, unless CARB is notified in advance per section 93130.5(i)(2). Design changes include changes to any part of the STAXbox.A-1 system including the exhaust capture hood, ducting, control equipment, and deployment platform. The changes must be approved in Executive Order G-24-054 5
writing by the Executive Officer and any applicable Certification Fees for the At Berth Regulation (Division 3, Chapter 16, Article 7, sections 2913 and 2914) must be paid before the modifications may be used for compliance with the 2020 At Berth Regulation. The Executive Officer may revoke this Executive Order if the STAXbox.A-1 design or approved operating parameters are changed without prior notification and approval by the Executive Officer.
BE IT FURTHER ORDERED, this Executive Order shall have a duration of five years from the date it is executed unless it is revoked by CARB as set forth in section 93130.5(l). As specified in section 93130.5(i)(1), at least six months prior to the expiration of this Executive Order, STAX may apply for an extension by submitting an extension application to the Executive Officer asserting that the strategy has not changed and is still effective, following the requirements specified in section 93130.5(d) as provided in section 93130.5(i)(1) of the Control Measure, after paying any applicable Certification Fees for the At Berth Regulation (Division 3, Chapter 16, Article 7, sections 2913 and 2914).
BE IT FURTHER ORDERED, marketing of the STAXbox.A-1 using any identification other than that shown in this Executive Order or marketing of the STAXbox.A-1 for an application other than those listed in this Executive Order shall be prohibited unless prior approval is obtained from CARB.
BE IT FURTHER O RDERED, this Executive Order does not relieve STAX from complying with all other applicable regulations.
BE IT FURTHER ORDERED, this Executive Order may be revoked if the Executive Officer determines that STAXbox.A-1 does not comply with any of the requirements in this Executive Order.
Executed at Sacramento, California, this 21
st day of March, 2024.
______________________________
Bonnie Soriano, Branch Chief
Freight Activity Branch
Transportation and Toxics Division
Attachment:1 Approved operating conditions for ro-ro vessels.
Executive Order G-24-054 6
Attachment 1
APPROVED OPERATING CONDITIONS FOR RO-RO VESSELS
Parameter Value
Ocean-going vessel engine type One auxiliary engine
Ocean-going vessel type Ro-ro vessel
Ocean-going vessel fuel composition limitation
Marine distillate fuel meeting 0.1% sulfur content
limit (0.1% sulfur marine gas oil (MGO) or marine
diesel oil (MDO)), or R99/R100 renewable diesel
fuels that meet the specifications of MGO/MDO
STAXbox.A-1 exhaust capture hood Flexible ducting
SCR inlet operating temperature range in degrees
Fahrenheit (⁰F) 600 – 720⁰F
Ocean-going vessel engine maximum continuous
rating (MCR) in kilowatts (kW) 3,500 kW
Ocean-going vessel allowable operating range (kW) 266 kW to 890 kW Allowable exhaust flow rate in standard cubic feet
per minute (scfm) 3,642 to 6,330 scfm of engine exhaust Maximum engine exhaust temperature requirements 1,000⁰F Static Pressure Differential pressure between -2 to -20 inches of water across the diesel particulate filter
Other parameters that affect performance 1-2 inches of water back pressure at the capture system inlet
GRID Neutral Target – CA CO2e state output
emission rate from eGRID2022 in pounds per
megawatt hour (lb/MWh)
457.5 lb/MWh
Maximum CAECS auxiliary generator operating load
(kW) 320 kW
CAECS auxiliary generator renewable diesel carbon
intensity limit in grams of carbon dioxide equivalent
per megajoule of fuel (g CO2e/MJ)
19.16 g CO2e/MJ fuel
Maximum ammonia slip emissions in parts per
million by volume, dry basis (ppmdv) 5 ppmdv averaged over 60 minutes
CARB-APPROVED
TEST PLANS
arb.ca.gov 1001 I Street • P.O. Box 2815 • Sacramento, California 95812 (800) 242-4450 January 12, 2024
Michael Walker, CEO
STAX Engineering, Inc.
65 Pine Avenue, Suite 943
Long Beach, California 90802
[email protected]
Dear Michael Walker:
California Air Resources Board (CARB) staff have reviewed the amended Test Plan for the barge-based STAXbox.A-1 system (XCRAFT-1 + XBOX-1P) to treat emissions from container vessel auxiliary engines.
STAX Engineering, Inc. (STAX) submitted “Research Test Plan to Expand Containership CAECS and Test XCap Connector” (Test Plan, Version 1, dated October 31, 2023) to CARB while Executive Order (EO) approval for the STAXbox.A-1 system was still pending. The STAXbox.A-1 was granted EO G-23-294 on December 4, 2023.
CARB staff reviewed the Test Plan (Version 1) and provided comments to STAX on December 15, 2023. At CARB staff’s suggestion, STAX subdivided the testing identified in Test Plan (Version 1) and submitted Test Plan A (Version 2) on December 17, 2023, to include only testing for the purposes of 1) expanding the operating conditions for the STAXbox.A-1 system, and 2) evaluating the XCAP connector which is an added component that may be attached to the original flexible ducting connector to improve exhaust capture design. CARB staff met with STAX on December 19, 2023, and STAX revised and resubmitted Test Plan A (Version 3) later that same day. CARB staff reviewed Test Plan A (Version 3) and provided comments to STAX on December 20, 2023. STAX revised and resubmitted Test Plan A (Version 4) on December 21, 2023, though the title page of the document was not updated and still lists the December 19, 2023, date from the previous version. STAX submitted additional information on January 2, 2024, regarding the XCAP connector dimensions and the minimum and maximum exhaust pipe diameter that can be serviced using this XCAP. CARB staff reviewed Test Plan A (Version 4) and provided comments to STAX on January 10, 2024. STAX revised and resubmitted Test Plan A (Version 5, attached) on January 11, 2024.
Based on CARB staff’s review, and pursuant to Health and Safety Code section 93130.5(f) of the 2020 At Berth Regulation, STAX’s Test Plan A (Version 5, submitted January 11, 2024) is hereby approved in accordance with testing requirements under the 2020 At Berth Regulation and the CARB Recommended Emissions Testing Guidelines for Ocean-Going Vessels.
Michael Walker, CEO
January 12, 2024
CARB approval is based on the system description, design, and operational procedures outlined in STAX’s Test Plan A (Version 5). No changes or modifications are permitted to the STAXBox.A-1 system, including the capture system design and operation, without prior CARB approval. In order to modify EO G-23-294 to reflect the requested changes outlined in the Test Plan, STAX will need to complete all testing outlined in their Test Plan A (Version 5) and provide all reports generated from these tests.
The application requirements that STAX must meet to submit test results are outlined in section 93130.5 of the 2020 At Berth Regulation. Per section 93130.5(i) of the 2020 At Berth Regulation, if testing deviates from the approved Test Plan without prior CARB approval, the Executive Officer may deem the application incomplete or disapprove the application. An example of deviating from the Test Plan includes conducting testing on additional vessel visits beyond those approved in the Test Plan and claiming such visits qualify for the research exception set forth in section 93130.8(d) or 93130.10(e) of the 2020 At Berth Regulation. CARB reserves the right to request the results of any testing conducted beyond the testing described in the approved Test Plan.
Vessel visits that coincide with the tests specified in the approved test plan may count as a compliant visit under the research exceptions in section 93130.8(d) or 93130.10(e) of the 2020 At Berth Regulation; however, these sections only apply for testing identified in Test Plan A (Version 5) and conducted after the date of this letter when Test Plan A (Version 5) was approved. All testing must adhere to the system description, design, and operational procedures outlined in the approved Test Plan. To complete the testing outlined in Test Plan A (Version 5), a total of 12 vessel visits are approved to utilize the research exception to compliance with the 2020 At Berth Regulation set forth in section 93130.8(d) or 93130.10(e).
STAX is responsible for tracking the usage of the 12 approved vessel visits that may utilize the research exception, and STAX must provide a copy of the approved Test Plan to each vessel participating in the research. STAX is also responsible for communicating with the vessel operator to ensure the operator knows what tests are being performed during the visit, and which number out of the 12 approved visits the vessel is participating in. As noted above, any tests completed in excess of those approved in the Test Plan would not be eligible for the research exception to compliance with the 2020 At Berth Regulation set forth in section 93130.8(d) or 93130.10(e). If more than 12 vessel visits are needed to complete all the testing outlined in the approved Test Plan, STAX must seek additional approval from CARB.
Testing for a new purification train to be added to the XCRAFT-1 barge (XBOX-1S) and a new system (XCRAFT-2 + XBOX-2P) will be addressed in future Test Plan(s).
Michael Walker, CEO
January 12, 2024
If you have any questions, please contact Angela Csondes, Manager, Marine Strategies Section, at [email protected].
Sincerely,
B
onnie Soriano, Chief, Freight Activity Branch, Transportation and Toxics Division Enclosure: STAX CARB Expanded EO XCAP research test plan.005 cc: Angela Csondes, Section Manager, Marine Strategies Section
arb.ca.gov 1001 I Street • P.O. Box 2815 • Sacramento, California 95812 [email protected] February 16, 2024
Michael Walker, CEO
STAX Engineering, Inc.
65 Pine Avenue, Suite 943
Long Beach, California 90802
[email protected]
Dear Michael Walker:
California Air Resources Board (CARB) staff have reviewed the amended Test Plan B for the two barge-based STAXbox.A-1 systems (XCRAFT-1 + XBOX1-2; XCRAFT-2 + XBOX2-1) to treat emissions from container vessel auxiliary engines.
STAX Test Plan Submission History
On October 31, 2023, STAX Engineering, Inc. (STAX) submitted “Research Test Plan to Expand Containership CAECS and Test XCap Connector” (Expanded Test Plan) to CARB while Executive Order (EO) approval for the STAXbox.A-1 system, under STAX’s original test plan for container vessels, was still pending. The STAXbox.A-1 was granted EO G-23-294 on December 4, 2023.
CARB staff reviewed the Expanded Test Plan and provided comments to STAX on December 15, 2023. At CARB staff’s suggestion, STAX subdivided the testing identified in the Expanded Test Plan into Test Plans A and B.
• Test Plan A was approved separately in a letter to STAX dated January 12, 2024, and includes testing for the purposes of expanding the operating conditions for the STAXbox.A-1 system and evaluating the XCAP connector. Upon successful completion of the testing and performance demonstration described in Test Plan A, EO G-23-294 will be amended to include the expanded operating conditions and the XCAP connector.
• STAX submitted Test Plan B on December 23, 2023, which includes testing for the purposes of demonstrating equivalency of two additional STAXbox.A-1 purification trains (XBOX1-2 and XBOX2-1) to the train approved under Test Plan A so the two additional trains can be used for compliance with the 2020 At Berth Regulation.
CARB staff reviewed Test Plan B and provided comments to STAX on January 19, 2024. To address CARB staff’s comments, STAX revised and resubmitted Test Plan B on January 21, 2024 (though this document is dated January 22, 2024). CARB staff met with STAX on February 8, 2024 to discuss Test Plan B and the process for approving duplicate systems, and provided comments following the meeting. To address CARB staff’s comments, STAX revised and resubmitted Test Plan B on February 8, 2024 (though this document is dated February 9, 2024).
Michael Walker
February 16, 2024
Stipulations for CARB Approval of Test Plan B
Based on CARB staff’s review, and pursuant to Health and Safety Code section 93130.5(f) of the 2020 At Berth Regulation, STAX’s Test Plan B (submitted February 8, 2024, attached) is hereby approved in accordance with testing requirements under the 2020 At Berth Regulation and the CARB Recommended Emissions Testing Guidelines for Ocean-Going Vessels. To complete the testing outlined in Test Plan B (submitted February 8, 2024), a total of 20 vessel visits (10 visits per train) are approved to utilize the research exception to compliance with the 2020 At Berth Regulation set forth in section 93130.8(d) or 93130.10(e).
The two additional trains (XBOX1-2 and XBOX2-1) are duplicates of the modified XBOX1-1 train approved under Test Plan A. Since there are modifications to the XBOX1-1 train that are pending approval under Test Plan A, the testing described in Test Plan A must be
completed by STAX and reviewed and approved by CARB before STAX’s two additional trains (XBOX1-2 and XBOX2-1) can be granted Executive Order approval for compliance with the 2020 At Berth Regulation.
CARB approval is based on the system description, design, and operational procedures outlined in STAX’s Test Plan B (submitted February 8, 2024). No changes or modifications are permitted to the STAXBox.A-1 system, including the capture system design and operation, without prior CARB approval. CARB approval for the STAXBox.A-1 system remains limited to containership auxiliary engines and one engine/exhaust stream only.
Although the XCRAFT-1 barge is equipped with XBOX1-1 and XBOX1-2, STAX is only approved to operate one XBOX at a time. No simultaneous control of two auxiliary engines shall be performed. STAX will need to complete all testing outlined in their Test Plan B (submitted February 8, 2024) and provide all reports generated from these tests.
The application requirements that STAX must meet to submit test results are outlined in section 93130.5 of the 2020 At Berth Regulation. Per section 93130.5(i) of the 2020 At Berth Regulation, if testing deviates from the approved Test Plan without prior CARB approval, the Executive Officer may deem the application incomplete or disapprove the application. An example of deviating from the Test Plan includes conducting testing on additional vessel visits beyond those approved in the Test Plan and claiming such visits qualify for the research exception set forth in section 93130.8(d) or 93130.10(e) of the 2020 At Berth Regulation. CARB reserves the right to request the results of any testing conducted beyond the testing described in the approved Test Plan.
Vessel visits that coincide with the tests specified in the approved test plan may count as a compliant visit under the research exceptions in section 93130.8(d) or 93130.10(e) of the 2020 At Berth Regulation; however, these sections only apply for testing identified in Test Plan B (submitted February 8, 2024) and conducted after the date of this letter when Test Plan B was approved. All testing must adhere to the system description, design, and operational procedures outlined in the approved Test Plan B.
Michael Walker
February 16, 2024
STAX is responsible for tracking the usage of the 20 approved vessel visits that may utilize the research exception, and
STAX must provide a copy of the approved Test Plan B to each vessel participating in the research. STAX is also responsible for communicating with the vessel operator to ensure the operator knows what tests are being performed during the visit, and which number out of the 20 approved visits the vessel is participating in. As noted above, any tests completed in excess of those approved in the Test Plan B would not be eligible for the research exception to compliance with the 2020 At Berth Regulation set forth in section 93130.8(d) or 93130.10(e). If more than 20 vessel visits are needed to complete all the testing outlined in the approved Test Plan, STAX must seek additional approval from CARB.
If
you have any questions, please contact Angela Csondes, Manager, Marine Strategies Section, at [email protected].
Sincerely,
Bonnie Soriano, Chief, Freight Activity Branch, Transportation and Toxics Division Attachment: [STAX CARB Expanded EO XCAP research test plan new systems .003.docx] cc: Angela Csondes, Section Manager, Marine Strategies Section
STAX ENGINEERING, LLC
MICHAEL WALKER
+1 (805) 708-2275
[email protected]
RANDALL PASEK
+1 (949) 201-5778
[email protected]