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hudsonespie · 5 years ago

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How Ships Can Prepare for PSC Inspection for IMO 2020?

The most awaited regulation of the decade for the maritime industry has been implemented from 1st January 2020. The implementation of 0.5% sulfur cap for marine fuel, popularly known as IMO 2020 will need strict compliance from the crew and shipowners, making it one of the most stringent regulations under MARPOL in the recent times.

Whenever any new regulations are implemented in the maritime industry, the first authorities to ensure ships are complying with them are the port state authorities.

Every port state authority will come onboard ships to check if the shipowners and the crew have done their part in making the new regulation effectively implemented onboard. Failing to do so will ask for hefty fines and even detention.

The IMO 2020 Regulation requires vessels to ensure ships machinery burns the fuel whose exhaust sulphur component by wt percentage is not more than 0.5%.

To know more, what exactly is IMO 2020, please watch this video-

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Needless to say, is extremely critical for the ships’ crews to be familiar with the new regulations, how it can be effectively implemented and all the associated documentation with it so that when a PSC inspector is onboard for checking the compliance, the ship can easily sail to the next port without any remarks or non-compliance.

How ship can prepare for IMO 2020 inspection by PSC?

The most important thing for the ship crew is to understand the requirements clearly. The fuel received onboard the ship will be considered as one of the most important evidence for any inspection.

Hence, with respect to the fuel oil, the crew must:

1. Ensure Bunker delivery note and Fuel Sample is kept onboard

As per the requirement, the BDN to be kept on board ship for three years from the date of issue. The BDN should be accompanied by a Representative Sample of the fuel delivered – the MARPOL Sample.

The fuel sample must be sealed with a sign of the supplier and ship’s representative. The sample has to be kept on board for 12 months from the date of delivery.

There have been many issues in the past related to missing BDN, unavailable sample or incomplete information in the MARPOL sample etc. which lead to the PSC scrutiny. When it comes to IMO 2020 sulphur regulation, Port state inspector will be more stringent in finding the faults.

Related Read: Bunker Delivery Note Amendments Enter Into Force As Sulphur 2020 Requirement Looms

2. Correct Soundings Record:

Apart from the BDN, the PSC will check the soundings of the tanks where the low sulphur fuel is kept or where the HSFO is kept for ships with exhaust gas scrubber.

Any discrepancies in the value of the sounding may lead to suspicion and further investigation.

Credits: US Navy/Wikipedia.org

Ensure the officer in charge of sounding keeps all the records in place and the volume correction is done appropriately as per the temperature of the oil.

The sounding log books need to updated regularly and signed by the chief engineer and the officer taking the soundings.

Related Read: Fuel Oil Consumption Calculations For Ships: What Seafarers Should Know

3. Fuel Transfer Record:

The ship must keep ready the fuel oil transfer plan for LSFO and HSFO fuel. Along with that, the PSC may ask for a fuel oil line diagram for reference. The tanks dedicated to LSFO must clearly be shown in the line diagram.

Tank cleaning details and dates to store the LSFO must be present in onboard records, including Oil Record Book.

The bunker details with LSFO must be recorded in the Oil Record book and signed by both Master and Chief engineer.

All records of any internal transfer, retention, disposal etc related to fuel oil will be cross-checked by the port stat inspector, hence these records need to be properly maintained.

4. Fuel Transfer plan and Piping Diagram

The plan and piping diagrams are important too as the PSC inspector will ask them to study them to understand whether the fuel change-over has been done properly, by cross-referring the data in the BDN, LSFO record book and ORB.

The location of the tank, the number of tanks used, pipelines in play etc. will be studied from the piping diagram. Any modification done for the storage and transfer of LSFO must be indicated and have survey approval from relevant authorities.

Ships visiting Emission Control Areas must have a Fuel oil change over plan to use fuel with 0.1% sulphur content. The plan must be readily available in the engine room and ship staff must know the detailed procedure as PSC inspector may ask them the procedure and local regulations.

If the PSC has doubts about the fuel and the lab results are not available, they will take the sample from service and settling tank for their own oil analysis.

Related Read: Fuel Oil Change Over Procedure for Ship’s Main and Auxiliary Engines

5. IAPP Certificate:

As per the MARPOL Annex VI requirement, all 400GT and above ships are bound to carry a valid International Air Pollution Prevention Certificate and supplement as a confirmation that the ship is fulfilling the requirements of this Annex.

The Supplement of the IAPP certificate provides the details of Sulphur Oxides and Particular Matter and how the control of emissions from the ship is achieved. It also contains the sulphur content limit values for fuel for ships plying within the ECA.

Any additional equipment fitted to reduce the sulphur content within the required limit such as scrubber tower etc. are also specified in the supplement of the certificate. Thus Master must ensure the IAPPC and Supplement are valid and updated to indicate the compliance arrangements on board which will be checked by the PSC.

6. Scrubber System:

Most of the ships have adopted exhaust gas scrubber system to comply with the upcoming sulphur emission rule because of the ease of using heavy fuel oil.

The PSC will be having a keen eye for the EGB and following things to be taken care of:

The Data recorder must be operational and records the time, position, pressure, flowrate etc. of the wash water. The PSC will check all these details to establish the correct operation of the EGB

The data recording device should be robust, tamper-proof, read-only and able to record at a rate not less than 0.0035 Hz The data should be retained on board ship for 18 months

The ship officer must take out the recent data in readable format for Port state inspector in case he/she demands it

PSC inspector may ask and check the approved documentation relating to any installed exhaust gas cleaning systems

At each renewal survey, nitrate discharge data is to be available in respect of sample overboard discharge is drawn from each EGC system within the previous three months before the survey.

The nitrate discharge data and analysis certificate is to be retained on board the ship as part of the EGC Record Book and made available for PSC if requested

Different port states have different regulations for the requirement of the open and closed-loop system. The ship officer must know if the port allows open scrubber or closed scrubber system to be operational in its territory and prohibit the discharge of effluent.

Related Read: 14 Technologies to Make the Ultimate Green Ship

The Port state inspector may demand to check the state of the wash water discharge pipe if it contains oil or not.

7. Record of Voyage:

The voyage records must be kept onboard as PSC inspector may demand to see the previous passages of the ship to know the time and coordinates for the entry in the port state or ECAs and if the ship has changed over to the compliant fuel in right time by cross-checking the data with ORB and other record books.

8. Fuel Oil Non-Availability Report:

If a ship is unable to acquire compliant fuel due to non-availability or any other reason, the master has to notify the flag state and other relevant authorities including the nearest or next port state.

This notification is called as FONAR or Fuel Oil Non-Availability Report.

This FONAR application and replies of the flag state respectively should be available for the PSC inspection. FONAR should be used only in case of extreme emergency and when all efforts fail to acquire a compliant fuel.

The PSC inspector will go through the report, correspondence and other details to accept the FONAR. However, a repeated FONAR may lead to negative reviews against the ship and the owner.

Related Read: ICS: FONARs Are ‘Not A Free Pass’ To Use Non-Compliant Low Sulphur Fuel

Other Important Preparation:

Apart from the above readiness, the ship’s crew must prepare the following:

Ensure all sounding pipe of fuel tanks have a lid and are marked.

All sounding pipes inside the engine room have a self-closing weighted arrangement.

Fuel tank gauge glasses are working and clean for visibility.

The sample point from the service and settling tank is clear and operational

Bunker sample locker is properly arranged

The oil record book is complete and all entries are countersigned by Master and Chief engineer

Fuel transfer plan, Pipeline diagram, Bunkerline diagram copies are pasted in relevant locations

The ship’s crew knows the basics of the IMO 2020 requirements and regulations

Exhaust Scrubber Tower is working fine and there are no leakages

Related Read: Practical Tips For Bunkering and Storage of Fuel Oil On Ships

From January 2020, the PSC inspector will be looking for shortcomings in the ship regarding the sulfur emission compliance. However, the ship crew must prepare for the complete PSC ship inspections.

Please read this article for more details- The Ultimate Guide to Port State Control (PSC) Inspection on Ships

Disclaimer: The authors’ views expressed in this article do not necessarily reflect the views of Marine Insight. Data and charts, if used, in the article have been sourced from available information and have not been authenticated by any statutory authority. The author and Marine Insight do not claim it to be accurate nor accept any responsibility for the same. The views constitute only the opinions and do not constitute any guidelines or recommendation on any course of action to be followed by the reader.

The article or images cannot be reproduced, copied, shared or used in any form without the permission of the author and Marine Insight.

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hudsonespie · 6 years ago

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New Guidance For IMO Global Sulphur Cap 2020 Compliance & All PSC Inspection Regimes

The new IMO global sulphur cap requirements enter force on 1st January 2020 and a robust and consistent approach to compliance is expected by all Port State Control (PSC) regimes. PSC inspections will be carried out in accordance with the IMO PSC procedures, the 2019 guidelines for PSC under MARPOL Annex VI.

In order to establish whether a ship is in compliance, PSC inspectors will likely focus their attention on documents and procedures maintained on board. In certain jurisdictions PSC inspectors will carry portable sulphur testing kits and if the results of these tests are inconclusive or indicate potential non-compliance then additional sampling will take place for verification ashore.

It is important therefore that ships’ crews are aware and familiar with the new regulations, associated documentation and procedures and are able to confidently demonstrate this knowledge to a PSC inspector.

Bunker Delivery Notes (BDNs) and Fuel Sampling

Details of fuel delivered on board for combustion purposes should be recorded by means of a BDN. The BDN should be accompanied by a Representative Sample of the fuel delivered – the MARPOL Sample. Most ships will also take commercial samples in the normal way. The Representative Sample is to be sealed and signed by the supplier’s representative and the Master (or senior officer in charge of the bunker operation) on completion of bunker delivery and retained on board until the fuel has been substantially consumed, but in any case for a period of not less than twelve months from the time of delivery. BDNs and associated samples should be easily identifiable and filed properly on board. BDNs should be retained on board for at least three years after the fuel has been received on board.

There are two locations where fuel sampling might be required by PSC: (1) downstream of the fuel oil service tank and (2) the storage tanks, “in use” and “on-board” respectively. In accordance with ISO 4259-2: 2017, and allowing for a 95% confidence limit, the maximum amount of sulphur allowed in these samples is 0.11% m/m for ECA fuel and 0.53% m/m for global fuel.

In situations where the Commercial Samples (taken during bunkering) indicate a higher sulphur content than noted on the BDN then the flag administration and PSC at destination need to be notified in writing without delay. Note that the ship will have likely sailed by the time these test results are known. In the event of any further investigation by PSC, the Representative Sample (MARPOL sample) will be used by PSC for further verification procedures and the ship may be ordered to de-bunker the fuel at the next port.

Additional documentation and procedural requirements during PSC Inspections

International Air Pollution Prevention Certificate (IAPPC).₁

Written procedures for fuel change-overs.₂

Shipboard Implementation Plan.₃

Tank plans and piping diagrams.₄

Fuel Oil Non Availability Report FONAR.₅

Voyage records: ECDIS and navigation charts.₆

Oil Record Book Part I – all entries for internal fuel transfers, bunkering, retention, disposal should be entered appropriately and signed.

Engine logbooks.

Tank sounding records.

Equivalent arrangements or alternate fuel.

IAPPC and Supplement

Every ship of 400 GT and above must have an International Air Pollution Prevention Certificate. The IAPPC, and Supplement, confirms that a ship and its equipment conform to the requirements of MARPOL Annex VI. The Supplement to the IAPPC details, in section 2, the way in which the control of emissions from the ship is achieved. Sulphur Oxides and Particular Matter are covered under section 2.3 of the Supplement. In this section, the sulphur content limit values for fuel are indicated for ships operating inside and outside of an ECA. Evidence that this criteria has been met needs to be supported by the BDNs kept on board. In situations where the ship is using equivalent emission abatement methods (a scrubber for example), these should be specified in the Supplement and listed under section 2.6.” Thus the IAPPC and Supplement need to be updated to indicate the arrangements on board.

Written procedures for fuel change-over

Ships burning different fuels to comply with the 2020 requirements whilst entering or leaving an ECA should carry written procedures describing how the fuel change-over is to be achieved. These procedures should allow sufficient time for the fuel service system to be fully flushed of all fuel exceeding the applicable sulphur limit, prior to entry into an ECA. Fuel change-over presents some challenges (such as avoiding fuel pump failure or seizure due to low viscosity of the distillate fuel oil), and risks (such as thermal shock to injection components or incompatibility of the fuels that may choke filters).

Fuel change-overs should be recorded in detail in the log book, as prescribed by the Flag administration. Items to be recorded include the volume of low sulphur fuel in each tank, the date, time, and position of the ship when change-over has been completed prior to the entry into the ECA, or commenced after exit from the ECA.

Shipboard Implementation Plan

This is not a mandatory document but recommended as PSC may consider the preparatory actions described in it (or the lack of such actions) when verifying compliance.

This document is specific to a particular ship and details:

Risk assessment, mitigation plans and impact of new fuels.

Details of fuel oil system modification.

Tank cleaning plan.

Fuel capacity and segregation capability.

Procurement of compliant fuel.

Fuel oil change-over plan from conventional HSFO to 0.5% fuel.

Documentation and reporting procedures.

Tank plans and piping diagrams

Studying these plans and diagrams will help PSC Inspectors understand whether the fuel change-over has been undertaken properly, especially when used in conjunction with the fuel logs and BDNs. In addition, the capacity plan, tank sounding tables and/or the stability information book will also provide the PSC Inspectors with useful information. Plans and piping diagrams should be updated in case of any modifications or new equipment.

FONAR

Any FONAR application along with correspondence with flag and next port PSC should be available on board. It is important to understand that FONAR should be used only as a last resort and should not be used repeatedly. Condition for approval of FONAR is expected to be very strict and repeated applications by a particular operator will attract negative attention.

Voyage records: ECDIS and navigation charts

Preservation of voyage details will allow the PSC Inspectors to understand the navigation of the ship and verify compliance. Historic ECDIS routes and associated navigational activities and daily reporting communications should all be kept on board for interrogation by the PSC.

References:

Res. MEPC.320(74) – 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI

Res. MEPC.321(74) – 2019 Guidelines for port state control under MARPOL Annex VI Chapter 3

MEPC.1/Circ.864/Rev.1 2019 – Guidelines for on-board sampling for the verification of the sulphur content of the fuel oil used on board ships

MEPC.1/Circ.881 – Notification on early application of the verification procedures for a MARPOL Annex VI fuel oil sample (Regulation 18.8.2 or 14.8)

MEPC.1/Circ.882 – Guidance for port state control on contingency measures for addressing non-compliant fuel oil

MEPC.1/Circ.883 – Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the exhaust gas cleaning system (EGCS) fails to meet the provisions of the 2015 EGCS guidelines

MEPC.1/Circ.878- guidance on the development of a ship implementation plan for the Consistent implementation of the 0.50% sulphur limit under Marpol Annex VI

European Maritime Safety Agency, Sulphur Inspection Guidance, Version May 2018

ukpandi.com

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