The Standard P&IClub issued an article outlining club’s considerations regarding LNG (Liquefied Natural Gas) as a marine fuel.
Compared to road transportation, inland shipping has been considered to have a lower carbon footprint. Since January 2011, EU regulations have required low sulphur fuel for inland shipping, but the next raft of regulations is for emission reductions for nitrous oxides (NOx) and particulate matter (PM). As an interim step towards zero emission fuels, LNG has come out as a valuable solution. Coupled with investment for LNG bunkering infrastructure in North Europe, it is becoming more commercially and economically viable and the first LNG inland ships have started operating.
LNG powered ships is not new technology. The LNG tanker fleet has used boil off gas since the 1980’s. LNG tankers have a good safety record and are designed and operated within established IMO regulations and recommendations: IGC – Safe Carriage by Sea of Bulk Liquefied Gasses; Resolution MSC 285(86) Interim Guidelines on Safety for Natural Gas-Fuelled Engine Installations in Ships (2009); and the recently accepted draft “International Code for Ships using Gas or other Low Flash-point Fuels” (IGF Code)
Rules and regulations
For ships operating on the European inland waterways, mostly the ARA (Amsterdam Rotterdam Antwerp) and the river Rhine with adjacent rivers and canals, IMO regulations don’t apply. The relevant rules fall between the EU International Carriage of Dangerous Goods (ADN) and the Central Commission for the Navigation on the Rhine (CCNR) regulations.
These existing rules have many gaps and contradictions for carriage of lowflash point fuel as bunkers instead of cargo. ADN regulations have recently been revised and these new regulations have been formally accepted by the EU. These new regulations cover rules on ship design, operational safety and crew training for ships fuelled by LNG. Next to the ADN standards and guidelines, class societies and ISO have issued standards applicable to, inter alia, the system design and safety issues regarding LNG fuelled ships.
The technical risks of a LNG fuel ship, (which must have two fuel systems i.e. either a duplicated LNG system or more commonly, duel fuel MDO and LNG), can be ‘designed out’ by using detailed risk assessments with the aim of achieving inherent safety by controlling the hazards first before introducing mitigation. The ship design cannot be viewed in isolation: service life events such as commissioning, dry-docking and repairs should be considered. The forthcoming rules are risk assessment based rather than prescriptive; thus flag administrations and classification societies need to be consulted early on in the design process.
From a P&I loss prevention perspective, the key risks are interactions with other ships and shore facilities; interactions with other ship board operations; the storage, handling and transfer of LNG; maintenance of LNG systems; and emergency preparedness for an accidental gas release. In other words, ‘the human element’.
There are three principle methods for LNG bunkering: direct from shore, from truck and ship-to-ship transfer. Bunker stations and procedures should be designed to protect the ship and crew from hazards. There are several important design considerations for bunkering: safety, vapour management, filling limits, communication and emergency shut-down. When training their crew owners and operators should be aware of the interface between LNG fuelled ships and the bunkers supply link.
ADN sets out requirements on crew training, as an owner/manager is required to arrange training based on crew role and responsibilities. Training is type specific as decided by the company training manager. However, until training requirements are fully developed and adopted, the responsibility for providing sufficient training falls to individual owners and operators.Even though LNG shipping has good safety records, training and knowledge is essential, as dealing with LNG as bunkers is a task very different from dealing with HFO bunkers or LNG as cargo. Training requirements are mandated by the EU and implemented by Flag administrations alongside any national laws. Compliance with such requirements is cross-checked by vetting inspectors and class societies.
Emergency procedures also need to be developed specifically to deal with the additional hazards posed by LNG such as: fire and leakage procedures, hazardous zoning and protection, safety exclusion zones and dropped objects.
For more information please read the Standard Bulletin issued by Standard Club
Source: Standard P&I Club
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