欧盟硫含量指令

ACTIONS REQUIRED ON ISSUES OF SAFETY AND CLASS RELATED ISSUES
Fuels satisfying the above requirements have different properties than those for which the ship machinery equipment and relevant installation has been designed, constructed, tested and certified up to now. Therefore, before the new type of fuel starts to be used on any existing ship it is required to confirm that any risks related with its use have been evaluated and if found at unacceptable level, necessary actions to be taken.
While the responsibility to ensure that each vessel is suited for the operation on the fuels required by the above directive remains with the operator, Lloyd’s Register is making every effort to provide as much assistance as possible offering timely advice on what it is needed to be done and further realisation on same.
In this respect several informative documents have been issued up to now offering necessary advice on the matter, the most critical of which from technical aspects are the following:
•Classification News 17/ 2009
•Classification News 35/ 2009
•Guidance Notes for the Design Appraisal of Main and Auxiliary Boilers Operating on Low Sulphur Distillate Oil, November 2009,
•FOBAS Bulletin 07/2009
The above publications, which are live documents updated as necessary to include latest developments on this ongoing issue, aim at informing the operators regarding their legislative obligations, alerting them on the safety issues, advising on what to do and informing on when they need to submit plans for consideration and / or arrange of verification by class surveyors on board.
Due to the fact, however, that installations of the existing ships, operational procedures and the makers’ approach can vary significantly, while implementation details of the legislation including actual time frame are yet unclear, LR is continuously seeking input form operators and makers to be in the position to offer advice on optimum solutions which satisfy the Rule requirements and mitigate the risks in all respects.
This is achieved through client meetings tailored to accommodate each operator’s individual needs which may involve relevant consultant and/or prospective systems modifications integrator and also through organising relevant workshops where a broader audience can participate.
Summarizing the feedback from the above interactions we have tried to capture the main points of the current regulatory regime and LR relevant position in the form of frequently asked questions and answers.
Questions mostly related to legislative requirements and fuel properties issues and associated hazards are addressed in the relevant attachment of FOBAS Bulletin 07/2009 (see in particular questions numbered 18, 21, 25, 26, 32, 50 and 55 to 58) while those relate more specifically to technical details, required modifications and plan submission/survey requirements, survey form safety Class Rules aspects are offered in the following pages.
Further Questions
It is hoped that we have addressed most of the possible questions however if there are further questions please contact your local LR Design Support Office in the first instance.
FREQUENTLY ASKED QUESTIONS
1. What actions should be taken by an owner before MGO can be used on an existing vessel for the first time?
To check and confirm that existing equipment, systems and procedures are suitable for operating with MGO.
2. How can this be done?
By consulting the Original Equipment designers/ manufacturers requesting advice on what may be needed in that respect. Further information on this is given on LR Classification news 17/09 (for engines) and 35/09 (for boilers).
3. How could an owner be directed to the points on which he will need advice by an expert entity (Original Engine Manufacturer or other)?
An internal HAZID analysis, Risk assessment or equivalent should be used to identify any relevant risk, evaluate whether they remain within acceptable levels or further actions for elimination or mitigation are needed.
It is important that the Original Equipment Manufacturer (OEM) of all identified equipment be contacted for specific advice.
While it is expected that in most cases there will be a need for modifications as well as updating of operational procedures it is clarified that:
a. If no modification is proposed by any equipment/system manufacturer as above
then only operational procedures including change-over need to be changed in order to meet ISM requirements (see also FOBAS Bulletin 07/2009 question 32). All relevant documents are to be kept in file as part of the ISM system documentation. No plans need to be submitted to class in that case.
b. If modifications need to be carried out then plans need to be submitted for
approval as per Rules requirements. For modifications related to boilers the
“Guidance Notes for the Design Appraisal of Main and Auxiliary Boilers Operating On Low Sulphur Distillate Oil, November 2009” should also be followed.
4. Is the OEM the only option acceptable by Class?
LR does not object to proposals made by other competent entities provided they are supported by an appropriate technical justification.
In that case a system integrator, i.e. the entity that will have the overall responsibility for the whole system modification will have to be defined and made known to class.
It would be logical for either the operator or a technical consultant to undertake the role, however overall responsibility still rests with owner.
5. When does a risk assessment need to be submitted and what is the expected extent? Although it strongly recommended for an owner to base his decision for any required modifications on both diesel engines and boilers on a risk assessment; this is to be
demonstrated/submitted as supporting document only with the boiler installation modifications. However this information may be requested by LR for diesel engines.
For the case of main propulsion boilers this risk assessment is expected to be based on very thorough HAZID/HAZOP studies together with all stakeholders.
For the auxiliary boilers (steam for loading/unloading of tankers, heating of fuel/cargo or even accommodation) this may be as simple as a list of all equipment/systems that may be affected by the use of the new fuel with cross references to the statements of the relevant entities confirming their suitability.
However, entities issuing statements of suitability of existing equipment should be in position to fully document same (i.e. HAZOP, theoretical technical justification and analysis, prototype tests, certificates etc.)
6. In case where modifications are required who should prepare the plans, who should submit same and where?
The preferred approach is the turn-key solution offered by OEM who provides, the service of designing the complete ship specific plans, together with the modification kits, and submits them to class and obtain relevant approvals.
If this is not the case, owner/operators should assure that the plans for the specific system equipment by the entity offering them have been granted relevant general / approval and/or type approval as applicable. On that basis owner/operator or a relevant designer office may prepare and submit the ship specific Piping and Instruments diagrams together with the relevant information and the risk assessment to the local Lloyd’s Register office for review.
7. What is the LR Policy on issuance of factual statements on the Status of plan approval and on board verifications for the modifications required on existing LR ships to burn LSDO?
LR is prepared to issue factual statements describing the process followed.
However, we note that at this moment issuance of such statement is not required either by the EU Directive or by any IMO or Flag/PORT State Administration.
LR is however monitoring the regulatory developments and the approaches being taken by flag and port states, in order to be in a position to support operators with any documentation requirements which may be imposed.
8. Are redundancy requirements imposed by the class?
Noting that during at berth operation it is owner responsibility to operate under EU directive requirements Class does not have redundancy requirements for stand by LSDO pumps, coolers which may incorporate chillers etc.
This however will not be the case for at sea operation in ECA areas after 2015.
In this respect, it strongly recommended that such issues be addressed at this stage also.
LR is considering means/measures to record and follow the extent that a vessel can burn LSDO (i.e. at berth only or at berth and at sea).
Redundancy of power on control and monitoring factions related to the safe operation of boiler/ burner of course should be satisfied with on both cases.
9. What is the LR position on using partly common HFO/ LSDO lines?
While there are no specific Rules requirements it is recognized that totally separate HFO/LSDO lines from the service tank to the burner is advantageous in any respect and should be the solution to be followed on the new buildings.
For existing installation however, although the same solution is strongly recommended, consideration may be given to acceptance of common lines at owners request taking into account the relevant risk assessment results and operational procedures followed by the operator.
10. Is there a specific requirement for the change over from HFO to LSDO to be made automatically and does this affect the UMS notation if applicable?
The operator practices on UMS operation vary considerably depending on the confidence they have in their crews, operations procedures and automation system on board.
LR would not expect whatever the automation available such change over to take place under unattended engine room. It is left to the operator’s discretion to decide the preferred method without this affecting the UMS notation.
11 Is class approval necessary, and under which conditions?
LR Rules require that Class is notified when modifications are made, especially when the safety systems are involved.。