4th. November, Wednesday 2020: 1300-1500 Hrs.

Compliance challenges on Sulphur cap in first 10 months – Vessel Operator’s Perspective.

DISCLAIMER

This presentation slides are intended only for uses by University of Trinidad and Tobago Internal Staff and Students as well as for today’s presentation. No copying or use of this presentation should occur without the permission of the author. UTT retains all intellectual property interests associated with the presentation. UTT makes no claim, promise, or warranty of any kind about the accuracy, completeness, or adequacy of the substance of the presentation and expressly disclaims liability for errors and omissions in such capacity. The views stated in this presentation and on the following slides are only those of the presenter and not necessarily those of UTT.

a) Low Sulphur distillate fuels.b) Low Sulphur Heavy fuels.c) High Sulphur Heavy fuels + EGCSd) Alternatives: LNG/LPG/Ethane/Methanol/CNG/Biofuels

Supporting the Owner’s for selection of sustainable energy renewal process.

Necessary amendments in the SMS to comply with ISM code to meet applicable regulations, New Operational guidelines and Certifications. (IOPP/IAPP)

a) Ship Implementation Plan (SIP)b) IMO DCS - (SEEMP) reporting.c) Proper Bunkering , Sampling , BDN and ORB entries.d) Fuel Changing over plans

Appropriate Crew Training program to meet the MOC (Management of Change) due to new fuel choice.

a) Applicable New MARPOL Annex VI Regulations.b) SIP / BDN / FONARc) New Applicable amendments in SMS.d) Bunkering Practice / Sampling / Handling / Reporting.

Experience developing phase – Monitoring closely the ME-AE-Boiler-Purifier- Heating-Filtering, IG Plant and EGCS performances.

a) ME-AE Performance Parameters. Cylinder oil consumptionb) Purifier performance analysis. Liner Wear monitoring.c) Maintaining appropriate fuel temperature.d) Scavenge Inspection report , Condition based PMS.e) Lube Oil selection, performance - Analysis

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2020

DEVELOPMENT PROCESS

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ENGAGEMENT WITH THE OWNER’S FOR SUSTAINABLE ENERGY SOLUTIONS

To meet 2020 Sulphur fuel standard, now the blenders must blend the fuel with distillate.

DMX grade to be used for Emergency Equipment.

Vessel may carry high Sulphur fuels only if it is marked in IAPP Certificate.

BDN the trump card.

Several ports are banning open loop scrubber water disposal.

Fuel oil Quality.

De Bunkering.

Safety of vessel.

Off Hire / Commercial loss.

Speed Claims.

Crew Training.

Crew work and rest hours balance.

SCANNED BY THE INDUSTRY AND ASSUMPTION MADE FOR ASSOCIATED RISK’S

WHAT IS THE COMPLIANT FUEL – TO MEET 2020 STANDARD ?Not compulsory. However, advantageous option for sustainability.Recommended under MEPC. 320(74) Section. 1.2.2.1

8217-2017. with PAS 23263

Annex: I-Reg 1 of 4 Annex: VI Reg : 2, 14 & 18

MARPOL

Pollution/Spill• Human Error• Skill

Delays• Information• Skill –

communication & management

Quantity Dispute• Standard

supplier & terms

• Skill – accuracy of calculation

• Malpractices

Quality Dispute•supplier & terms

•Proper sampling.

•Receiving in empty tank

What is Compliant Fuel Standard.- Training

Fuel management on board– Procuring Strategy

Fuel management on board – Bunkering

Fuel management on board – Bunker Delivery Note

Fuel management on board– Expectation and Preparation for PSCO

Fuel management on board– Fuel Analysis

Fuel management on board– Action while calling Unratified Countries.

Fuel management on board– IMO role in Fuel Quality, Availability and MARPOL

Compliance

LEGAL BINDINGS

TIME CHARTERER OWNER MANAGER

SECTION

ISM DESCRIPTION TOOLS

1.4Functional requirements for a safety management system (SMS)

DOC , SMC

2Safety and environmental protection policy

COMPANY POLICY

6 Resources and personnel

STCW CERTIFICATE & TRAINING , CREW SKILL, DMLC, CBA , SEA .

7Development of plans for shipboard operations

OPERATION PROCEDURES

8 Emergency preparednessSOPEP/SMPEP/VRP/Ems/MFAG

10Maintenance of the ship and equipment.

PMS, SURVEY

SHIP BUDGET MEETING

SHIPMAN 2009 (Ship management, Smartcon)

SECTION 2 – Services – 4. Technical Management: -The Managers shall provide technical management which includes, but is not limited to, the following services:(a) Ensuring that the Vessel complies with the

requirements of the law of the Flag State;(b) Ensuring compliance with the ISM Code;(c) Ensuring compliance with the ISPS Code;(d) Providing competent personnel to manage the

upkeep and general efficiency of the Vessel;(j) Arranging for the sampling and testing of bunkers.

INTERTANKTIME 80 (Time charter, Oil, Tanker)

BIMCO BUNKER TERMS 2018

BUNKER STEM ORDER

DIFFERENT BUNKERING CODE

ISO 13739 -2010, Procedures for transfer of bunkers to vessels

Singapore we have SS600: 2014 - Singapore Standard Code of Practice for Bunkering (With TR48-2015)

Gibraltar - Bunkering - Code of Practice

GOST Russian Standard

DIFFERENT BUNKER STANDARD

ISO 8217 : 2017 (Latest) + PAS 23263

BS 6843-1:1996 Replaced By : BS ISO 8216-1:2005

ASTM D2069, D396-19, D975-19b

Complete Local – Consensus agreement

LEGAL BINDINGS

BIMCO SHIPMAN

ISM

ISM 1.4: CERTIFICATES –DOC/SMC/IOPP/ MSMC

ISM 1.4:H&M , BCLC, P&I

ISM 2: POLICY

ISM 6: CREW, SKILL, TRAINING, DMLC,CBA,SEA, STCW CERTIFICATES

ISM 7: OPERATION PROCEDURE – BUNKERING PROCEDURES

ISM 8: EMERGENCY PROCEDURE. SOPEP/SMPEP/ MFAG/Ems/MSDS

ISM 10: PMS, SURVEY

ISPS -DoS

SOLAS II-II-1/3-9 Safe AccessII-2 Reg 4 Flash PointVI-5.1 MSDS

MARPOLAnnex I – Reg 37 SOPEPAnnex VI Reg 2 DefinitionsAnnex VI Reg 14 & 18

ISO 8217:2017 + PAS 23263

ISO 13739:2010

ISGOTT (2.3.6.4) (2.7),(11) (12.3) (13) (22) (23) (25)

CONCAWE H2S REPORT

MEPC 182(59) SAMPLING

OCIMF-EFFECTIVE MOORING (4TH. ED)

OCIMF: SHIP TO SHIP TRANSFER GUIDE 1ST. ED

CFR 40 US EPA.US CARBEU DIRECTIVE 2016/802COMPANY SMS MANUAL

FOR JOB DESCRIPTIONS, RESPONSIBILITIES, LIMITATIONS

CHARTER PARTY

BIMCO BUNKERING TERMS 2018

BUNKER STEM ORDER

TO ACHIEVE SAFE AND EFFECTIVE BUNKERING IDEALLY NEED TO WALK THROUGH THE FOLLOWING PROCESS

MARPOL ANNEX VI:- Regulation 18.5 ISO 13739:2010 Petroleum products — Procedures for transfer of bunkers to vessels

1 Name and IMO Number of receiving ship name of receiving vessel;

2 Port IMO number of the receiving vessel;

3 Date of commencement of delivery date of commencement of the delivery;

4 Name, address, and telephone number of marine fuel oil supplier name, address and telephone number of the marine fuel oil supplier;

5 Product name(s) bunker specification (grade name);

6 Quantity in metric tons quantity (metric tonnes);

7 Density at 15oC (kg/m3*) density at 15 °C, as supplied;

8 Sulphur content (% m/m)** viscosity at 40 °C or 50 °C, as supplied;

9 A declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in conformity with regulation 18.3 of this Annex and that the Sulphur content of the fuel oil supplied does not exceed:regulation 14.1; regulation 14 .4.a or the purchaser's specified limit value of _____ (% m/m), as completed by the fuel oil supplier's representative and on the basis of the purchaser's notification that the fuel oil is intended to be used:

sulphur content as supplied;

MARPOL ANNEX VI:- Regulation 18.6 a declaration signed and certified by the fuel oil supplier's representative that “The bunker(s) supplied is/are in conformity with Regulation 14 and Regulation 18

1 The bunker delivery note shall be kept on board the ship in such a place as to be readily available for inspection at all reasonable times. It shall be retained for a period of three years after the fuel oil has been delivered on board."

a record of the supplier's sample seal numbers and any counter sample seal numbers;

MARPOL ANNEX VI:- Regulation 18.8.1 delivery port;

1 The bunker delivery note shall be accompanied by a representative sample of the fuel oil delivered taking into account guidelines developed by the Organization.* The sample is to be sealed and signed by the supplier’s representative and the master or officer in charge of the bunker operation on completion of bunkering operations and retained under the ship’s control until the fuel oil is substantially consumed, but in any case, for a period of not less than 12 months from the time of delivery

bunker tanker name or name of supplying terminal;

next port of call;

receiving vessel's stamp and signature of the Master/Chief Engineer;

signature and, where applicable, stamp from the Cargo Officer;

STANDARD BUNKER DELIVERY NOTE

GENERAL LAYOUT OF WORLDWIDE COUNTRIES TO INDICATE STATUS OF MARPOL ANNEX VI IMPLEMENTATION

This picture depicts countries not ratified the MARPOL Annex VI yet. However, even a ship is calling ports on these countries there is no exclusion. Whenever a vessel calling ports within Ratified countries must comply with MARPOL Annex VI reg 14 and 18

As at 04/11/2020 MARPOL Protocol 97 (Annex VI)-List of Unratified CountriesAfghanistan, Albania , Algeria, Angola. Argentina, AustriaBahrain, Bosnia & Herzegovina, Brunei DarussalamCambodia, Cameroon, Cabo Verde, Colombia, Comoros, Costa Rica, Cote d'Ivoire, CubaDem. People's Rep. Korea, Dem. Rep. of the Congo, Djibouti, Dominica, Dominican RepublicEcuador, Egypt, El Salvador, Equatorial Guinea, Eritrea, EthiopiaFiji, Gambia, Georgia, Grenada, Guinea, Guinea-Bissau,Haiti, Iraq, IsraelKazakhstan, Lebanon, Libya, Madagascar, Maldives, Mauritania, Mauritius, Mexico, Micronesia (Fed. States of) Mozambique, Myanmar,Namibia, Nauru, New Zealand, Nicaragua, Oman, Pakistan, Papua New GuineaQatar, Sao Tome & Principe, Senegal, Seychelles, Solomon Islands, Somalia, Sri Lanka, Sudan, Suriname,Thailand, Togo, United Rep. of Tanzania, VenezuelaYemen

According to INTERTANKO guide example: According to MEPC.1Circ. 736 Rev. 2:

A couple of vetting observations regarding ORB 1 entries.

• The Oil Record Book Part 1 did not record the ISO No of bunkers during a bunkering and did not record the ISO No or Sulphur Content.

• Oil Record Book part 1. Code 'H' entries for 26.3 were not recorded as per MEPC.1 / Circ. 736 / Rev 2, Fuel oil bunkers ISOxxxx entry was missing for the fuel oil bunkers taken.

Available guidelines on board are as follows:

INVESTIGATION REVEALS IN SPITE OF AVAILABLE GUIDELINES ON BOARD VESSEL REMAIN UNSUCCESSFUL TO FILL UP ORB

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THE CORRECT FUEL GRADE NOT WRITTEN STILL THE CHIEF ENGINEER ACCEPTED THE BDN

The GN Code / Product Code column is blank, yet the vessel put signature in the BDN

Under 14 (1) following are the choice:The Sulphur content of any fuel oil used on board ships shall not exceed the following limits:.1 4.50% m/m prior to 1 January 2012;.2 3.50% m/m on and after 1 January 2012; and.3 0.50% m/m on and after 1 January 2020.The correct value not selected from above 3There is no regulation under 4(a)Regulation 18.1 Each Party shall take all reasonable steps to promote the availability of fuel oils which comply with this Annex and inform the Organization of the availability of compliant fuel oils in its ports and terminals. ( Nothing to do with BDN)

18.3. Fuel oil for combustion purposes delivered to and used on board ships to which this Annex applies shall meet the following requirements:.1 except as provided in subparagraph 3.2:.1.1 the fuel oil shall be blends of hydrocarbons derived from petroleum refining. This shall not preclude the incorporation of small amounts of additives intended to improve some aspects of performance;.1.2 the fuel oil shall be free from inorganic acid; and.1.3 the fuel oil shall not include any added substance or chemical waste which:.1.3.1 jeopardizes the safety of ships or adversely affects the performance of the machinery, or.1.3.2 is harmful to personnel, or.1.3.3 contributes overall to additional air pollution..2 fuel oil for combustion purposes derived by methods other than petroleum refining shall not:.2.1 exceed the applicable Sulphur content set forth in regulation 14 of this Annex;.2.2 cause an engine to exceed the applicable NOx emission limit set forth in paragraphs 3, 4, 5.1.1 and 7.4 of regulation 13;.2.3 contain inorganic acid; or.2.4.1 jeopardize the safety of ships or adversely affect the performance of the machinery, or.2.4.2 be harmful to personnel, or.2.4.3 contribute overall to additional air pollution.

18.3 has 2 parts the correct part, not selected for

THIS IS THE SAMPLE BDN WHICH WAS INITIALLY PREPARED BY THE SUPPLY BARGE AND FINALLY AMENDED AS THE CHIEF ENGINEER INSERTED THE CLAUSE DURING PRE BUNKERING MEETING

TOO HIGH A TEMPERATURE TO LOAD BUNKER.• NEED TO CONSIDER IF VESSEL WAS LOADED OR

IN BALLAST.• IF LOADED WHAT WAS THE CARGO• DOES THE CARGO HAVE ANY TEMPERATURE

RESTRICTION

THIS IS GENERIC NAME. NOT APPROPRIATE FOR ORB ENTRIES.NEED TO CHECK THE MSDS IF IT IS REFLECTING HSFO IF NOT THEN MUST REJECT DURING PRE BUNKERING MEETING

SAFE ACCESS IS A REQUIREMENT UNDER SOLAS AND ILO PUBLICATION CHAPTER 8. THE VESSEL IS RESPONSIBLE FOR SAFE ACCESS UNDER BUNKERING CONTRACT.SUCH COMMENTS MAY GO AGAINST THE VESSEL UNDER CHARTER PARTY TERMS AND BIMCO SHIPMAN AGREEMENT TO DEMONSTRATE DUE DILIGENCE BY THE CHIEF ENGINEER TO PROTECT OWNER’S INTEREST

REFINERY

SWEET CRUDE

0.5% FO

BLENDING

MIXED CRUDE

REFINING ( Atmospheric or Vacuum Distillation)

0.5% FO 0.5% FO

HYDRO-TREATING

HYDRO-CRACKING

0.5% FO

HYDRO-CONVERSION

0.5% FO 0.5% FO

TRADERS

Note: straight run fuels are blended in the refinery, however while doing so a refinery may procure the cutter stock from market or other refineries to maintain the profit.Traders – Blends fuel by purchasing different feedstocks and cutter stocks from refineries to maintain the profit.

Cutter stock from various sources

RM FUEL PROCESSING DIAGRAM

WHAT IS IMO DOING TO ENSURE FUEL OIL QUALITY?

Notifications received where fuel oil suppliers have failed to meet the requirements are available to view on GISIS:

https://gisis.imo.org/Public/MARPOL6/Notifications.aspx?Reg=18.9.6

The best practice guidance for Member States/coastal States will be aimed at assisting Member States in carrying out their responsibilities under MARPOL Annex VI, to ensure effective implementation and enforcement Both sets of best practice guidance are aimed at assisting in the effective implementation of the Annex VI regulation on fuel oil quality.

So far 1933 reports has been recorded

Till date only 135 FONAR made and only 6 has been accepted as remaining found to be not complying with the regulations

CONCLUSION:1. Bunker Quality issue is old issue not generated for 2020 new fuel standard.

Earlier the fuel was blended keeping viscosity in mind, now fuel is blended keeping Sulphur limits in mind.

TO MITIGATE THE RISK:

1. Proper Crew Training.2. Negotiate with the Owner and always get the bunkering contract from The

Charterer, instead of Bunker Stem Order.3. Always receive bunker in an empty tank (Industry acceptance of empty tank is

less than 1% of total volume)4. Never mix bunker even from the same supplier but two different barges.5. Always consume bunker after fuel oil analysis.6. Bunker change over plan must strictly adhere with.7. Always reduce settling tank to minimum, prior transferring new bunker.8. Whenever changing over to new bunker monitor all the engine parameters at

least for next 48 Hrs. closely.9. Must collect and safekeep bunker sample properly.10. Always insist Charterer’s to procure bunker from reliable sources. Thank you very much for your time:

Bhaskar Sengupta.Deputy Environmental Compliance Manager. (BSM)