13 October 2016/ Our Ref.: 3948-10145/DTL
MINUTES
Bunker Sub-Committee (BSC) 37th Meeting
12:30 - 17:00hrs, 22 September 2016, Amathus Hotel, Limassol, Cyprus
(approvedvia correspondence 13. October / circulated on 18. October 2016)
BSC: Present:Laurin Maritime AB / Mr. / Bertil / Andersson
Minerva Marine Inc / Mr. / Stavros / Daniolos
Lloyd's Reg of Shipping-FOBAS / Mr. / Naeem / Javaid (for Wilson)
Veritas Petroleum Services / Mr. / Bjørn Olav / Odland
Springfield Shipping Co Pan SA / Capt. / Dionisios / Siganakis
Dampskibsselskabet NORDEN A/S / Mr. / Klaus / Stamp (Chairman)
ISTEC: Present
Andriaki Shipping Co Ltd / Mr / Panos / Kourkountis
Roxana Shipping / Mr. / Takis / Koutris
Guest: Present / Mr. / Dean / Tseretopoulos
Staff: Present
INTERTANKO US Office / Mr. / Joseph J. / Angelo
INTERTANKO London Office / Mr. / GilYong / Han
INTERTANKO Oslo / Mr. / Dragos / Rauta
INTERTANKO London Office / Capt. / Anup / Singh
BS-C: Apologies:
IBIA / Mr. / Nigel / Draffin
Intertek Shipcare / Mr. / Michael / Green
IBIA / Mr. / Peter / Hall
IBIA / Mr. / Trevor / Harrison
Andros Maritime Agencies Ltd / Mr. / Trevor / Leney
Wilhelmsen Ships Service / Mr. / Jonas / Ostlund
Stena Oil / Mr. / Patrik / Pettersson
Tsakos Energy Nav Ltd. (TEN) / Mr. / George / Saroglou
Hellenic Tankers Co. Ltd / Mr. / Christos S / Verveniotis
ViswaLab / Dr. / R. / Vis
Lloyd's Register of Shipping / Mr. / Timothy / Wilson
The Chairman, Mr Klaus Stamp, welcomed all participants, in particular those attending the meeting for the first time. A new Secretary for the sub-Committee was introduced. The Chairman reminded all attendees that the meeting is to be conducted in strict compliance with the INTERTANKO Antitrust Guidelines:
ANTI-TRUST/COMPETITION LAW COMPLIANCE
INTERTANKO’s Anti-Trust/Competition law Compliance Statement:INTERTANKO’s policy is to be firmly committed to maintaining a fair and competitive environment in the world tanker trade, and to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in these markets. These laws include the anti-trust/competition laws which theUnited States, the European Union and many nations of the world have adopted to preserve the free enterprise system, promote competition and protect the public from monopolistic and other restrictive trade practices. INTERTANKO’s activities will be conducted in compliance with its Anti-trust/Competition Law Guidelines.
AGENDA:
1.Minutes from the last meeting
2.Nomination to join the BSC
3.Bunker Quality
4.Onboard fuel Sampling
5.Engine Room fuel sampling
6.ISO 8217 Revision
7.New carbon to CO2 factor, very low and ultralow sulphur fuels
8.IMO 2020 Fuel Oil Availability Study
9.Next Meeting
******
1.Minutes from the last meeting
The draft minutes from the 36th meeting was approved with no alterations. Secretariat suggested that from this meeting onwards, draft minutes be approved by correspondence instead of placing it to the next meeting as an approval-request agenda item. This new procedure will apply to all Committees and Sub-Committees for uniformity. BSC approved this new procedure.
Action No.1 / DeadlineCirculate BSC 37 draft minutes to members for comment and approval by correspondence. / 10/10/2016
2.Nomination to join the BSC
Mr. Christos S. Verveniotis, Technical Manager, Hellenic Tankers Co. Ltd, though not present, was welcomed as a new member of the sub-Committee.
The Chairman encouraged INTERTANKO membership to actively participate in the sub-Committee by nominating their representatives. The Secretariat indicated that two new members from Odfjell and Stena Bulk AB may join the sub-Committee at the next meeting.
3.Bunker Quality
The Chairman provided a briefing on decisions made at MEPC 69 mainly relating to the responsibility of quality control measures prior to fuel oil being delivered to a ship. MEPC 69 agreed that best practices for fuel oil purchasers and Member States should be developed by a MEPC correspondence group, whilst deciding that it should not pursue consideration of the adequacy of the current legal frame work in MARPOL Annex VI/Reg.18. The logic behind this decision was that the roles and responsibilities of ensuring fuel oil quality were rather a contractual issue out of the framework of IMO and should therefore not be treated under MARPOL. Secretariat is however continuing to use opportunities during the MEPC meetings to make the point that unless local authorities in ports impose a stricter regime for local fuel suppliers, the adequacy of the legal framework remains questionable.
In addition to best practices for purchasers and Member States, MEPC 69 invited the bunker supplier industry to develop best practice for fuel oil providers and submit it to MEPC for consideration at a future session. IBIA would lead the task of developing draft Guidelines for fuel oil providers.
INTERTANKO is part of the IMO CG developing best practices for fuel oil purchasers and Member States. The CG is now active focusing on 10 major items with target completion date of MEPC 71 (2017). The major goals and related items to be covered by the best practice guidelines were presented to the sub-Committee at the meeting as shown in the attached side show.
The sub-Committee discussed at length one of the goals which IMO listed for the guidelines for purchasers /ship operators, namely the location where a MARPOL sample is to be taken. According to IMO Guidelines (Res. MEPC.182(59)), the sample (so-called MARPOL sample) of the fuel delivered to the ship should be obtained at the receiving ship’s inlet bunker manifold and should be drawn continuously throughout the bunker delivery period. However, still not uniform practices are reported world-wide, e.g., where the MARPOL sample is not continuous drip samples as required.
The sub-Committee noted that there was a need to clarify responsibilities of flag states, fuel oil providers and ships in case where a dispute arises. The IMO fuel verification procedure (MARPOL Annex VI/Appendix VI) stops short of addressing this. It has also been noted that local regulations (such as security regulations) may hinder that the MARPOL sample is taken at the receiving ship’s rail as to be witnessed by the ship crew and supplier.
The discussions led to a proposal to collect data on claims brought by suppliers and to undertake some analysis about suppliers whose fuels had been found to be non-compliant. If ranking of bunker suppliers were to be contentious, it would be beneficial for the sub-Committee to have anonymous data on non-compliant suppliers, say, from VPS and FOBAS databases.
The sub-Committee noted that IMO invited fuel suppliers to develop their own guidelines and present them to MEPC at a future session. Although noting what ship operators would expect, the sub-Committee had to accept the fact that IMO is not willing to be involved in developing standards of industries which are not under the IMO’s own regulatory framework. It was suggested that INTERTANKO inquiries with IBIA if we can be part of their drafting process. In any case, it was noted that the Guidelines for Fuel Suppliers need to be presented to MEPC for review and our points can be made then.
Singapore’s mandatory use of bunker mass flow metering (MFM, Technical Reference 48) from 2017 would open a new chapter with an electronic bunker delivery note (BDN) mobile application which would allow real time transfer of bunkering information. However, concerns were expressed that this would not become a remedy to cure all potential problems in bunkering. Even with a flow meter installed, crew watch would still be necessary but crew are not allowed to stay on board a bunker barge. What if a dispute remains even after co-checking by C/O and the supplier,
The above discussions led to Action No. 2 below.
The sub-Committee also recalled a previous request from IBIA (see item 8.3.2 of BSC #36 minutes, HSE approach) on assessment of a further need for the standardization of connections for bunkering operations (dimensions, size, type). Members of the sub-Committee were in agreement that, according to their experience, there is no problem or lack of standardisation, at least as long as they are aware of. Since no one from IBIA attended the meeting, it was not possible to seek further clarifications.
LR FOBAS offered to check whether its study on bunker sampling connections would be relevant and, if so, would share the results with the sub-Committee subject to the confidentiality clearance.
Finally, the Secretariat introduced results of remote sensing of SOx emissions from ships conducted by HELCOM Baltic Marine Environment Protection Commission. The project covered remote monitoring of ships over the period of 2015 and 2016 by means of a sniffer at the Great Belt Bridge. Over the 3,600 measurements, 50 observations (2%) had a Sulphur Fuel Content (SFC) above 0.2%. Only a few incidents of gross non-compliance (SFC above 0.5%) were observed. This means a high degree of compliance for the observed ships at the Great Belt Bridge. See figure below.
The sub-Committee paid particular attention to the ships whose fuels had been found to be well above the limit. In reply to members’ question, the Secretariat informed that the authorities had not contacted the so identified non-compliant ships as the ships had already left the boundary of jurisdiction of the monitoring authorities.
Action No.2 / DeadlineExplore the possibility of INTERTANKO taking part of the IBIA’s work to develop draft Guidelines for fuel oil providers.
INTERTANKO’s input will be focused on:
-Jurisdiction of fuel oil suppliers’ bunkering
-Legal frame for fuel oil suppliers
-Raise issues relating to the MARPOL sampling and encourage IBIA to address the sampling issues in the draft Guidelines / 30/10/2016
Action No.3
Circulate the IMO CG’s first draft Guidelines for flag states to the sub-Committee for comment. / When available
4.Onboard fuel Sampling
The Chairman recalled that USCG had suspended their voluntary fuel sampling but indicated that they will retain the capability to do periodic sampling and may conduct future operations to continue to verify compliant fuel use and that supplied fuel meets the 0.1% requirement as shown on the BDN.
Transport Canada announced that effective from 22 August 2016, their inspectors will go on board the ships operating in waters under Canadian jurisdiction and conduct 0.1 % sulphur content verification. According to the safety notice, they will use portable analysers. Based on this initial assessment on board, they will decide next steps . It was noted that since the announcement, no information was available on how many ships had been visited and verified. Members were encouraged to share verification information.
Action No.4 / DeadlineMembers are encouraged to exchange information on Transport Canada’s onboard sulphur content verification on their ships. / Open
Action No.5
Seek more information from Transport Canada regarding verification methods, e.g. more details on the use of a portable analyser. / 30/10/2016
Secretariat
5.Engine Room fuel sampling
Three IMO papers were introduced:
-IMO draft Guidelines for onboard sampling – expected to be endorsed at MEPC 70 (Oct 2016).
-Norway paper MEPC 70/15/3 proposing amendments to MARPOL Annex VI/Reg.14 to gradually phase in the requirement for ships to have designated fuel oil sampling points.
-IACS paper MEPC 70/9/3 proposing additional changes to facilitate safe and proper fuel sampling.
The sub-Committee considered the IACS’ proposed drainage requirements for sampling points (MEPC 70/9/3, Figure 1).
Stop valve: controls the
volume / pressure of fuel
flowing into the cubitainer.
(delicate controlling)
An enclosed glass type box.
to check whether there is an
overflow.
In case of an overflow, fuel is
led to a drain tank
The sub-Committee agreed to propose the following change to Figure 1 above.
-In the “sample cubitainer” box, as an additional safety barrier, a spring-load type valve is to be added.
In addition, the sub-Committee agreed that there should be only one sampling point to be required, as opposed to multiple sampling point(s), as follows:
Sampling point *
(M/E) (Aux. Engine) (Boiler)
Note: *In case a fuel supply line (pipe) is provided from FO service tank to
M/E, Aux/Eng and Boiler separately and individually, a single sampling point would not be feasible. In case a common fuel supply line (pipe) from FO service tank is provided to M/E, Aux/Eng and Boiler, which is now an increasing trend, a single sampling point is recommended.
Action No.6 / DeadlineExpress the above proposed two changes at MEPC 70 as appropriate. / at MEPC 70
6.ISO 8217 Revision
LR advised that the draft revision of ISO 8217 would soon be circulated to National standardization authorities for comments and may be published, depending upon the outcome of votes from individual authorities, by the end of 2016. CIMAC is also developing Guidelines to better understand the revised ISO 8217. The current draft of ISO 8217 proposes to add 3 new marine distillate grades that can include up to 7.0 volume % FAME (fatty acid ethyl ester). These are DF grades that are identical to existing marine distillates called DMA, DMZ and DMB, except for DF’s 7.0 volume % FAME. In case where DF grades are used, CIMAC recommends that it is a good idea to take practical measures, i.e. maintaining fuel temperature at least 10 degree above the pout point and refraining from storing fuel in tanks exposed to cold ambient conditions.
LR advised that due to the recent draft revision of ISO 8217 containing grades with up to 7.0 % FAME, ship operators should be more specific in their purchase when ordering distillate grades to ensure that they procure right types of fuel, instead of just ordering general ISO 8217 grades.
This is to ensure that ship operators know exactly what kind of fuel they are buying.
LR also advised the sub-Committee that when ordering ULSFOs, operators should order ULSFOs by referring to ISO 8217 existing grades. This will ensure that fuel purchasers are protected by all clauses of ISO 8217. For example, ExxonMobile’s HDME50, whose storing and handling is similar to HFO (in terms of high viscosity and high flash point), has MGO characteristics too. Hence, called hybrid fuel produced from distillate with further hydrocracking treatment. However, some distillates cannot be mixed with HFO due to compatibility concerns. SK Energy’s SK ULSFO is also a new hybrid low sulphur fuel said to be in compliance with ISO 8217 RME180 specification fuels.
Most of these new hybrid fuels are blended products and have some characteristics of distillate products. Secretariat advised that under the EU MRV Directive and IMO’s GHG database reporting, ship operators will be requested to report what type of fuel their ships burn. Despite their distillate characteristics, most of these hybrid fuels are very waxy in nature and therefore these need to have heating arrangements and should not be stored in tanks which are subject to low external temperatures such as ship’s side tanks.
After a lengthy discussion, the sub-Committee agreed that there shall be a separate classification for hybrid fuels in the revised ISO standards. Compatibility issues can appear when HFO is blended with MGO or ULSFO.
Action No.7 / DeadlineLR FOBAS to keep the members updated on the development of new ISO 8217 revision / When relevant
By LR FOBAS
7.New carbon to CO2 factor, very low and ultralow sulphur fuels
During discussions on additional provisions for the EU MRV regulation, a question was raised on values of carbon to CO2 conversion factors for new low sulphur fuels which are not distillates. If fuels are not classified in ISO 8217, what is conversion factor for ULSFO, is it to be treated as distillate or residual? The sub-Committee agreed that there should be proper ISO specifications classifying this new fuel.
LR advised that for ULSFOs, density can be taken as a proxy for carbon/hydrogen ratio – this is the basis of the specific energy calculations on ISO 8217 where the principal factor is density. “New ECA Fuels” generally fall within the RMB-RMD range. Therefore, the usage of the existing carbon-hydrogen ratio to CO2 factor for the “light fuel oils” – RMA-RMD – as given in MEPC.245(66) would remain appropriate to such fuels.
Ref. MEPC.245(66) 2014 EEDI calculation guidelines, para.2 reads:
FuelLight Fuel Oil (LFO) / Reference
ISO 8217 Grades RMA through RMD / Carbon content
0.8594 / Conversion factor
3.151
Action No.8 / Deadline
Encourage their respective home countries’ standard setting authorities to establish a separate classification for the new “hybrid” fuels in the revised ISO standards. / Open
by members
EU MRV
Secretariat briefed on the progress made with respect to EU MRV. To recap, and for future reference, the following summary was provided:
-EU MRV came into force on 1 July 2015.
-The EU regulation will require ships (of above 5,000 GT) to report their aggregate fuel consumption, total lengths of their voyages to and from an EU port over one calendar year.
-The first monitoring period will start on 1 Jan 2018.
-Ships will be required to prepare a Monitoring Plan and deliver it to Verifiers for verification by the end of August 2017.
-EC established two sub-groups under ESSF(European Sustainable Shipping Forum) to consider developments of additional elements such as definitions, verification and qualifications of verifiers.