Standards and Rules for Bunkering of Gas-Fuelled Ships

During early March 2013 EMSA released a study on Standards and Rules for Bunkering of Gas-Fuelled Ships with the objective of providing a detailed description of the existing rule framework related to LNG bunkering. Currently about 30 gas-fuelled vessels are operating mostly in the Baltic Sea and Norwegian waters most of them on the authority of the Norwegian administration. Hence, Norway had early on experience with gas as fuel for ships and initiated the development of the IMO’s international ‘Guidelines on Safety for Natural Gas-Fuelled Engine Installations in Ships’ in 2004.

These interim guidelines (MSC Resolution 285.(86)) were adopted in June 2009 and focus on the use of natural gas on board of vessels and the requirements for the installations on board. Besides the interim guidelines, the use of LNG as a maritime fuel for ships is not formally recognized by IMO rules. To facilitate the approval process for gas-fuelled vessels a code for the use of gas as ship fuel is being developed. This International Code of Safety for ships using gases or other low flashpoint fuels (IGF Code) is still under development and will cover safety and operational issues for gas-fuelled seagoing vessels. In comparison to the above mentioned guidelines, the IGF Code will have the status of an internationally adopted and legally binding regulatory instrument.

Regarding the bunkering of LNG, the IGF Code will define requirements for the bunkering systems onboard the receiving vessel and general operational requirements regarding the preparation, post processing, responsibilities and communication focusing the (receiving) gas-fuelled ship. No specific operational guidance taking into account all types of bunkering modes and requirements for each kind of transfer system for all facilities involved are considered.

To close the gap regarding the bunkering of LNG as fuel for ships in the regulatory framework, another Norwegian initiative led to the establishment of the Working Group 10 (WG 10) within the Technical Committee 67 (TC 67) of the International Organisation for Standardisation (ISO) in 2011. The objective of the ISO TC 67 WG 10 is the development of international guidelines for bunkering of gas-fuelled vessels focusing on requirements for the LNG transfer system, the personnel involved and the related risk of the whole LNG bunkering process. The members of the WG 10 decided to develop a technical report as a high level document to be finalized by 2014. For the time being, with experiences of bunkering of LNG being not widespread, Working Group 10 is not able to develop an international standard for bunkering LNG.

While regulations for the use of gas on seagoing vessels and the related bunkering guidelines are already under development, similar activities for inland vessels have just started. Unlike the rule framework for seagoing vessels, the transport of LNG by inland tankers is not allowed. Within the ‘European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN)’ the necessary entry of LNG within the cargo list is missing, which leads to the prohibition of transport via inland waterways tanker. For both unregulated items, the transport of LNG as cargo by inland waterway tanker and the use of LNG as fuel for inland waterway vessels, activities are initiated to develop necessary appendixes of the ADN and the Rhine Vessel Inspection Regulations.

The existing guidelines of the International Society of Gas Tanker and Terminal Operator (SIGTTO) and those by the International Oil companies Marine Forum (OCIMF) describe the handling and transport of LNG as cargo. However, these documents cannot directly be used for regulating the bunkering of LNG as ship fuel due to the fact that these documents are dealing with the transport and transfer of large quantities of LNG as cargo and handled by an experienced crew on ships and terminals. For the bunkering of LNG as ship fuel, safety requirements given by SIGTTO and OCIMF may be adapted for the handling of smaller amounts of LNG, a bunkering process which takes place at any berth within harbour areas, between different types of bunker sources and receiving vessels as well as handling by crews with little or no experience in daily handling of LNG and in the presence of passengers on board of the vessels.

In summary, the regulatory framework for bunkering of LNG as fuel for ships including relevant regulations of the LNG supply chain (transport on inland water ways) is not available for the time being but can be based on other existing standards and guidelines e .g .the SIGTTO ‘Ship to Ship Transfer Guideline’ for the Ship to Ship bunkering or the ISO 28460 ‘Ship to shore interface and port operations’ for the Terminal to Ship bunkering of LNG.

The report has identified regulatory gaps which can be summarized in the list below:

1. The entire use of LNG as marine fuel and LNG bunkering procedures are not regulated by IMO requirements and standards as LNG is formally not fully recognised as fuel for the time being.
2. The future status of the ISO Technical Report on LNG bunkering within the international rule framework will have to be reinforced through references in other common Standards and/or legal texts.
3. The definition of the bunkering process and the division of responsibilities for bunkering LNG as fuel is not covered by the Technical Report of the ISO TC 67 WG 10.
4. Responsibilities mentioned in the current Draft IGF Code are limited to the Ship to Ship transfer.
5. A conceptual delineation between transfer of LNG as cargo and bunkering of LNG as fuel is missing.
6. The connection and disconnection process of portable LNG fuel tanks is not defined in the current draft of the IGF Code and the Technical Report of the ISO TC 67 WG 10.
7. The absence of appropriate rules relating to the transportation of LNG on European inland waterways affects the lack of construction requirements for LNG inland tankers, bunker barges and gas-fuelled inland waterway vessels.
8. The use of LNG as fuel is not permitted on inland waterway vessels in general and is only possible by exemptions by the Central Commission for the Navigation of the Rhine (CCNR), which consequently does not stimulate the creation of larger LNG demand.
9. Despite the large range of national legislation, further guidance or Standards for small scale LNG bunkering stations could be developed using current best practices.
10. Despite various industry driven initiatives common guidelines for port rules on LNG bunkering procedures are not yet available.
11. Crew training requirements for LNG carrying or fuelled inland vessels and barges not exist and have to be developed especially with a view on using inland barges as bunker barges.
12. No International Standards for the specification of LNG as marine fuel are available.
13. No requirements and guidelines are available for the measurement of the sulphur content of LNG as fuel.
14. A Standard for the safe sampling of LNG as fuel is missing.
15. No Standard is available for the Standardisation of the equipment for the connection of communication devices and process monitoring including Emergency Shut Down (ESD) between the LNG delivering facility and the receiving gas-fuelled vesse.
16. Procedures and equipment for gas measurement are missing.
17. Operational guidelines need to be developed to reduce potential negative environmental impacts related to the possible release of methane.

Finally EMSA’s report emphasizes that For all possible LNG bunkering activities and related processes the general safety principle as stated in the Draft LNG bunkering of the ISO TC 67 Working Group 10 should be followed:

“Safety should be the primary objective for the planning, design and operation of facilities for the delivery of LNG as marine fuel”.

Source: EMSA