Baltic Marine Environment Protection Commission

Transcription

1 Baltic Marine Environment Protection Commission Maritime Working Group Tallinn, Estonia, 6-8 September 2016 MARITIME Document title Results of questionnaire to revise HELCOM Recommendation 28/3 on Guidelines on Bunkering Operations and Ship to Ship Cargo Transfer Code 8-2 Category INF Agenda Item 8 - Detection, investigation and prosecution of offenders of anti-pollution regulations Submission date Submitted by Finland Reference Background According to the decision of HELCOM MARITIME 15/2015 the coordinator of the Correspondence Group prepared and circulated a questionnaire among the member states to collect information on what are the needed amendments to the HELCOM Recommendation 28/3 on bunkering and STS operations. A compilation of the received answers is found in of this document. The questionnaire is found in Attachment 2. Unfortunately, the CG could not complete the work as planned. However, the material can be used in the future to finalize the revision. Action requested The Meeting is invited to: take note of the information in. Page 1 of 1

2 Summary Table of the Answers by the Member States 1. Which fuel types in addition to petroleum based products should be considered when updating the Recommendation 28/3? LNG Methanol Biofuels Others, specify Use a generic descriotion to adapt future fuel types FINLAND NA NA NA NA NA NA LITHUANIA POLAND LPG, MARPOL Annex I and II If possible a holistic approach should be taken to this issue, taking into accountthe term Alternative Fuel instead of considering individual products 2. Which Regulations should be taken into account when updating the Recommendation 28/3? a) Related to petroleum C20 products other than amended MARPOL Annex I NA FINLAND OCIMF, Ship to Ship Tranfer Guide NA NA LITHUANIA NA POLAND IBC CODE, IMSBC CODE, IMDG CODE See below

3 b) Related to LNG IGC-Code FINLAND OCIMF, Ship to Ship NA NA LITHUANIA POLAND IGC Code, resolution MSC 285 (86), elements of terminal to ship operations The port of Gothenburgs local regulations "Green Bunering" could be used a good exampe when updating the Recommendation 28/3 regarding bunkering. Ship to Ship Transfer Guide for Petroleum, Chemicals and Liquefied Gases issued by Chemical Distribution Institute, ICS, Oil companes International marin Forum and Spciety of International Gas Tanker and Terminal Operators should be taken into account regarding STS-operations. c) Related to Methanol Under development by IMO FINLAND OCIMF, Ship to Ship Transfer Guide NA NA LITHUANIA POLAND Resolution MSC 285 (86), IGF Code as above

4 d) Related to biofuels Under development by IMO FINLAND OCIMF, Ship to Ship Transfer Guide NA NA LITHUANIA POLAND Resolutiom MSC 285 (86), IGF Code as above 3. Should we consider areas designated for STS operations and bunkering in the Baltic Sea? A. BUNKERING FINLAND LITHUANIA POLAND This should be MS decision. If needed, areas to be avoided are to prefer before designated areas for operations.

5 B. STS OPERATIONS FINLAND LITHUANIA POLAND, The area chosen should be suitable under the given circumstances, and may differ under varying weather conditions etc., Designated STS areas should be established so that STS and bunkering operations are carried oit in a controlled way (i.e. there is minimized risk for difficult weather conditions and oil response equipments/vessels are available nearby) This should be MS decision., We don t have records of spesific problems with STS operations,and we don t have much experience with these operations however we are interested to learn about experiences of othher countries. If needed, areas to be avoided are to prefer before designated areas for operations. 4. Do we need more specific Guidelines included in the HELCOM Recommendation? A) on bunkering Petroleum LNG Methanol Biofuels based products FINLAND

6 LITHUANIA POLAND B) on STS-operations in the Baltic Sea? Petroleum LNG Methanol Biofuels Coal Fertilazers based OBS! DK: Gases as defined in the IGC, not only LNG products OBS! DK: Chemical products as defined in MARPOl ANNES II should be included FINLAND LITHUANIA POLAND PL:Shipowner and operators handling STS for cargo under Annex II and III should have a STS plan 5. Should bunkering and STS-operations be allowed in all weathers and ice-conditions? FINLAND

7 LITHUANIA POLAND 6. If, should we recommend/impose weather and ice-condition restrictions on these activities? to recommendations to restrictions in general FINLAND Many different factors affects the safety of the STS operation (e.g. how weather protected (wind/waves) is the area, is the STS operation carried out at anchor or in movement, is the ice field moving or stabile). The captain of the ship has the _ overall responsibility of the STS operation and he should have the right of decision to stop or continue the operation. Administration has always the option to stop the STS operation or give restrictions. Responsible authority could be for example coast guard or local VTS. LITHUANIA POLAND Not in spesific terms, Bunkering of LNG should not be allowed in stormy weather, high waves and temperature A shipd master is responsible for his/her ships safety and should be qualified to determine suitable conditions. However, it might be preferable to keep the existing recommendation

8 regarding ice consitions. 7. Should we include also recommendation on preparedness on oil combatting during the bunkering and STS-operations in the Recommendation 28/3? FINLAND Recommendations for availability of the oil response equipment and the instructions for preparedness before the start of STS operation (i.e. oil booms, support LITHUANIA POLAND vessel if necessary)., Shipboard oil pollution emergency plan might be enough but the issue of prepardness on oil combatting should be properly discussed. Gothenburgs local regulations "Green Bunkering" could be used as a good example. The port of

9 Attachment 2 Questionnaire on amendments to HELCOM Recommendation 28/3 GUIDELINES ON BUNKERING OPERATIONS AND SHIP TO SHIP CARGO TRANSFER Introduction A new chapter 8 regulating prevention of pollution during transfer of oil cargo between two oil tankers was added to MARPOL Annex I and consequential amendments were made to the Supplement to the IOPP Certificate, Form B (resolution MEPC.186(59)). Accordingly MARITIME 14 agreed to establish a Correspondence Group to revise HELCOM Recommendation 28/3 and drafted Terms of Reference for the work included in Annex 5 of the Outcome of MARITIME14. This questionnaire is developed by the coordinator of the Correspondence Group to clarify among the Baltic Sea actors what are the needed amendments to the HELCOM Recommendation 28/3 on bunkering and STS operations. Background information:

10 Attachment 2 Country : Denmark [ ] Estonia [ ] Finland [ ] Germany [ ] Latvia [ ] Lithuania [ ] Poland [ ] Russian Federation [ ] Sweden [ ] Sector: Ship-owner: bulk carrier [ ] tanker [ ] container [ ] general cargo ship [ ] ro-ro ship [ ] ro-ro passenger ship [ ] Fuel supplyer: LNG [ ] bunker oil (HFO, MGO) [ ] methanol [ ] biofuel [ ] Ports: Port Authority or Harbour Master [ ] Authorities, administrations: Member States/National/Regional or other Authority [ ] Non-governmental organisation (NGOs) [ ] Other [ ] Please specify Questions 1. Which fuel types in addition to petroleum based products should be considered when updating the Recommendation 28/3 Fuel a) LNG [ ] b) Methanol [ ] c) Biofuels [ ] d) Others, pls specify 2. Which Regulations we should be taken into account when updating the Recommendation 28/3? a) related to petroleum based products other than amended MARPOL Annex I b) related to LNG c) related to Methanol d) related to biofuels 3. Should we consider areas designated for STS operations and bunkering in the Baltic Sea?

11 Attachment 2 a) bunkering [ ] [ ] b) STS operations [ ] [ ] Could you please spesify? 4. Do we need more specif Guidelines included in the HELCOM Recommendation? A) on bunkering [ ] [ ] If, could you pls specify conserning which fuel type? a) petroleum based products [ ] b) LNG [ ] c) Methanol [ ] d) Biofuels [ ] B) on STS-operations in the Baltic Sea? [ ] [ ] If, could you pls specify conserning which type of cargo? a) petroleum based products [ ] b) LNG [ ] c) Methanol [ ] d) Biofuels [ ] e) Coal [ ] f) Fertilizers [ ] 5. Should bunkering and STS-operations be allowed in all weathers and ice-condistions?

12 Attachment 2 [ ] [ ] 6. If, should we recommend/impose weather and ice-condition restrictions on these activities? [ ] [ ] 7. Should we include also recommendation on preparedness on oil compatting during the bunkering and STS-operations in the Recommendation 28/3? [ ] [ ]