CHALLENGES MET IN THE PREPARATION OF MRV PLAN The Shipping Operator Perspective
Company s Profile CONSOLIDATED MARINE MANAGEMENT INC. has been established on 1st October 1997 as a Ship Owning Management Company. CMM has developed, documented and implements a Health, Safety, Quality, Environment and Energy Management System (HSQEEnMS) CMM is qualified and certified to manage Oil Tankers, Chemical Tankers and Gas Carriers. 2
CMM Fleet [9] (V)LGC Carriers VESSEL FLAG CAPACITY (m 3 ) YEAR / YARD BUILT COMMERCIAL STATUS Hellas Fos 82,352 2008 / HHI V/C Hellas Glory 82,386 2008 / HHI T/C to CHEVRON Hellas Serenity 82,440 2008 / HHI T/C to CSSA Hellas Hercules 84,134 2015/HHI T/C to CHEVRON Hellas Poseidon 84,084 2015/HHI T/C to SHELL Hellas Gladiator 84,116 2016/HHI T/C to CSSA Hellas Sparta 84,055 2016/HHI T/C to SHELL Hellas Eagle 60,638 2016/HHI T/C to KOCH Hellas Apollo 60,638 2016/HHI T/C to KOCH 3 KOSTAS VLACHOS 05/04/2017
CMM Fleet [5] LR2 Product Carriers VESSEL FLAG CAPACITY (m 3 ) YEAR / YARD BUILT COMMERCIAL STATUS King Philippos 125,689 2012 / HHI T/C to BP Lady Henrietta 125,689 2012 / HHI T/C to BP Captain John 130,357 2014 / HSHI T/C to NAVIG8 Captain Paris 130,357 2014 / HSHI T/C to NAVIG8 Captain Spiro 130,357 2014 / HSHI T/C to NAVIG8 KOSTAS VLACHOS 05/04/2017 4
CMM Fleet [9]MR Product / Chemical Carriers VESSEL FLAG CAPACITY (m 3 ) YEAR / YARD BUILT COMMERCIAL STATUS King Gregory 54,079 2012 / HMD T/C to CARGILL Lady Malou 54, 079 2013 / HMD T/C to CARGILL Hellas Enterprise 53,652 2008 / STX T/C to KOCH Hellas Explorer 53,514 2008 / STX T/C to KOCH Hellas Avatar 52,019 2015/HMD T/C to CARGILL Hellas Fighter 52,019 2015/HMD T/C to CARGILL Hellas Revenger 52,019 2016/HMD T/C to KOCH Hellas Nemesis 52,019 2016/HMD T/C to KOCH Hellas Aphrodite 52,019 2016/HMD T/C to CSSA KOSTAS VLACHOS 05/04/2017 5
CMM Fleet New Buildings MR Project HULL No. FLAG CAPACITY (m 3 ) DELIVERY DATE / YARD SHIP TYPE CLASS 2637 52,000 (2017) HMD MR Product / Chemical LR 2638 52,000 (2017) HMD MR Product / Chemical LR 441 52,000 (2017) HVS MR Product / Chemical LR 442 52,000 (2017) HVS MR Product / Chemical LR KOSTAS VLACHOS 05/04/2017 6
The EU MRV Timeline 2015 2017 1 July 2015 The EU MRV shipping Regulation came into force 31 August 2017 Submission to verifiers an MP for each vessel 2018 1 January 2018-31 December 18 Start of the first monitoring and reporting period 2019 2019 30 April 2019 Deadline for submitting A verified Emissions Report 30 June 2019 Document of compliance available on board for the vessels arriving or departing from European Port. 7
IMO DATA COLLECTION SYSTEM TIMELINE 2016 October 2016 MEPC 70 adopted the Data Collection System and amendments of SEEMP 2018 Spring 2018. Adoption of an initial IMO CO2 reduction strategy 2019 2020 2021 2023 1 January Data collection commences Summer. Data for 2019 to be reported Autumn. Beginning of IMO analysis of fuel consumption data Summer. Data for 2020 to be reported to IMO Spring.IMO decisions on future policy basis on the analysis of data Spring. Adoption of revised IMO strategy including any additional Co2 reduction measures as appropriate KOSTAS VLACHOS 05/04/2017 8
Applicable Legislation documents EU Regulation 2015/757-29-04-15 The main document for MRV Regulation EU Regulation 2016/2071-22-09-16 Amendment to MRV Regulation EU Regulation 2016/1927-04-11-16 The implementing regulation for MPs and templates EU Regulation 2016/1928-04-11-16 The document for determination of the cargo EU Regulation 2016/2072-22-09-16 The document for verification and accreditation 9
A Complete New Management System Why? New Detailed and prescriptive procedures and records are required with new roles duties and responsibilities Documentation control for amendments and new versions and storage of records of MP system are required Development of Risk Assessments for a FLOW CHART OF ACTIVITIES. New Maintenance and calibration processes are established Internal and external assessment and verification is required Periodical Management Review is required New Document of compliance covering vessel and company is issued. 10
Bureaucracy A new bureaucratic system is created with new meanings for shipping such as: Materiality, Uncertainty, Inherent Risk, Control Risk, Detection Risk, completeness, accuracy, Consistency, transparency and relevance of information as per ISO 14064 Brings additional Administrative workload to the ship personnel putting at risk: The safety of the ship and the personnel onboard; Compromises the real controls for restriction of emissions; Pay a special attention to the system rather to the human and the environment Contains grey areas and introduce a verification process with complex levels of verification such as the independent reviewer 11
Contents of the MP A. Revision record sheet B. Basic Data C. Activity Data D. Data Gaps E. Management F. Further Information 12
B. Basic Data B1. Identification of Ship Type of the ship: The Annex I Table B.1 identification of the ship of EU 2016/1927 suggest to select one of the following categories: Oil tanker Chemical tanker.etc The regulation doesn t cover the combination 13
B.3 Emission sources Describe as per 3(c) of Article 6 of EU 2015/757 the emission sources onboard: M/E, A/E, Gas Turbines, Boilers and IGG No reference is made to: The diesel driven power packs on oil/chemical carriers and The Incinerators Do we need to include those? YES or NO? 14
B.3 Type of Fuels Used For each one of the emission sources record one or more of the following Fuels used: HFO, LSHFO, MGO/DO, LNG, LPG, Methanol, Ethanol Use the emission Factor for each of the above Standard Fuels referred to the template. For Non-Standard Fuel Make an analysis in a recognized laboratory, following a specific sampling methodology Are included in the above category the blended fuel and the mixtures of fuel with sludges? 15
B.5 Update the Completeness of Emissions Sources You need to fill in a table B.5. describing: The procedures used for identifying the ES, estimating ES not regularly monitored, ensuring that all information data are included the time period of reporting the version of it; the responsible person for implementing this procedure of completeness; the location and retention where the records kept, including the IT software. Do not underestimate the key word completeness as defined by 14064 The verifier shall check that in the MP the ES are monitored completely & accurately. (Not biased eliminated & describing Precision& uncertainties) 16
C. Activity Data 1.Monitoring of fuel consumption; 2.List of Voyages; 3. Distance travelled; 4.Amount of cargo carried & Number of passengers; 5. Time spent at sea; KOSTAS VLACHOS 05/04/2017 17
C.1 Monitoring of Fuel consumption 1. Methods used to determine fuel consumption of each ES; 2. Procedures for determining fuel bunkered and stock takes in FT 3. CROSS CHECKS between BDN and stock takes; 4. Description of measurement equipment involved; 5. Procedures for recording, retrieving, transmitting and storing information regarding measurements; 6. Method for determination of density; 7. Level of uncertainty associated with fuel monitoring; 8. Procedure for ensuring quality assurance of measuring equipment 9. Method for determining and recording the FC on laden voyages 18
1.1 Methods Used to determine fuel consumption of each ES a) Bunker Fuel Delivery Note (BDN) and periodic stock takes of fuel tanks; b) Bunker fuel tank monitoring on board; c) Flow meters for applicable combustion processes; d) Direct CO2 emission measurements 19
1.2&1.3 Uplifts and cross checks Develop procedures for bunkering and stockstakes measurements: Stating & documenting all assumptions for bunkering Stating ALL calculations and methodologies of measurements Documenting the explanation and/or Justification for choice of procedures, methodologies, parameters, key Factors. Documenting external factors that may affect bunkering or measurements Bear in mind: Fuel at the beginning of period, plus deliveries, minus levels at the end of period. Period means the time between two ports of call or within the port Type of fuel and Sulphur are specified Periodic stockstake is based on fuel tank readings (automated systems, soundings) Volume in Ltr is converted in tonnes used the density. 20
1.4. Description of the measurement Instrument involved It must be included: Dip tapes; Automated systems used in the tanks Flow meters; Temperature systems; Sampling systems Name, Age, technical specifications, maintenance procedures, calibration procedures, and Emission source applied to shall be recorded 21
1.5. Procedures for recording, retrieving, transmitting and storing information regarding measurements How the data are being produced (BDN records, tank measurements, LOP) Where are being stored onboard the vessel; (Hard copies, electronic formats) Who is the responsible person; (C/E onboard, Performance Monitoring officer) How are being processed and what controls are in place; Input Controls (Measured DATA to Hard copies) Transformation controls (error checking during the process of collating, transferring,processing,calculating,estimating,agreegating or adjusting input data) Output controls (Comparison between input and output) How are being transmitted to the company; (Noon Electronic Reports)and With what frequency 22
1.6 Determination of density Actual density recorded in BDN: (fuel suppliers to report tested as per ISO3675:1998 or ISO 12185:1996) Actual on board measurements (ISO 650:1977 hydrometers for general purposes or ISO 12185:1996 Oscillating U-tube method) Laboratory analysis (ISO 3675:1998 or ISO 3838: 1984) Standard density values As given in Petroleum measurement tables (ISO 91-1 and 91-2: 1991) 23
1.6 Determination of density (continue.) Actual Density is not necessary in mass flow meters How to deal with unpredictable situations Who is responsible for determining the actual density value (fuel supplier, master etc.) Controls applied for ensuring accuracy of density data; The IS used for processing and transmitting actual density value; How and where fuel density data is recorded; Justifications where applicable for using standard value. 24
1.7 Level of Uncertainty The company should complete and document an uncertainty assessment for each method selected Applicable Regulation Factors affecting the uncertainly Risks related with each factor Estimated level of uncertainty per method. 25
Applicable Regulation 6.2.f (iv) of EU Reg.2015/757: A procedure to be developed ensuring the total uncertainty of fuel measurements.. Annex I B of EU Reg,2015/757: The uncertainty associated with the BDN shall be specified in the MP The method for tank sounding and uncertainty associated shall be specified in the MP The calibration methods applied for flow meters and the uncertainty associated shall be specified in the MP Article 16 of EU Reg. 2016/1928: Maximum total level of uncertainty 5% accepted by the verifiers 26
Factors affecting the uncertainty Equipment Processes People Material Environment Management (any equipment, computer tools, etc. related with the measurement) (policies, procedures, rules, regulations, clauses) (anyone in the chain of measurement process) (Fuel, water, air impurities) (Temperature, trim/list, waves etc.) (Responsibilities, roles, audits, reviews and data handling) 27
Possible Causes Risks Related with each Factor Accuracy as function of capacity Data gaps due to software failure Data gaps due to hardware failure Un-calibrated equipment Lack precision due to fault installation Processes Procedures not specific Not running controls on key assays Incorrect formulas and factors Not adequate measurement method Missing emission sources and fuels Inconsistency of techniques Not familiar with measuring device Failure to follow procedures Erroneous data entry Not same level of training Effect Equipment People Failure to measure fuel consumption correctly Density / Viscosity Change of properties Enclosed impurities (i.e. sludge_ Mixing with air (during bunkering) Material Environment Temperature Vibration Rolling / Pitching Dust and dirt on measuring devices Trim / list Job titles and roles not properly defined Reporting responsibilities not properly defined Monitoring responsibilities not properly defined Training and reviews not undertaken properly Not regular evaluation of the monitoring plan Management 28
Estimated Level of Uncertainty per Method of Measurement BDN & Periodic Stock Takes of Fuel Tanks: Beyond the control of ship s operator Statistically the accuracy level is ranged between (1-5%) (bunkerspot Cardiff University) Set-up an experienced factor per supplier with the aim to create ship specific estimate Set-up a qualitative (e.g. high, medium, low) and/or quantitative procedure for each supplier 29
Estimated Level of Uncertainty per Method of Measurement Bunker Fuel tank monitoring onboard Uncertainly up to 2% between the tank tables as produced by yards and the real volume as determined by ISO Standard 4269:2001 Uncertainty regarding Fuel tank readings, calibration certificates Uncertainties for electronic fuel tank readings(2-5%). (CE-Delft 2013) Manual tank gauges Very inaccurate( ECOFYS study). 30
Estimated Level of Uncertainty per Method of Measurement FLOW METERS Uncertainty is estimated from 0.1-3.0% (ECOFYS 2014); Install flow meters after purifiers; If not installed flow meters in the return line calculate the quantity with other method; Calculate the quantity of retaining in the filter back flushing filter; Calculate the oil fuel leakages. An uncertainty analysis, which is statistically detailed quantitative and systematic procedure to ascertain and quantify uncertainty is necessary to be carried out 31
1.8.Procedures ensuring quality assurance of measuring equipment Develop new procedures or referring to existing procedures of the company for: Describing the calibration method and intervals; Describing the maintenance and inspection methods and intervals; Describing the defects and the corrections taken; Describing the regular accuracy checks for technical reasons Describing the periodic internal audits and technical review conducted Describing the appropriate training for personnel Describing the software used if any and the precautions taken. Performing uncertainty assessments 32
C.2. List of Voyages Companies should develop procedures for the list of voyages coming under the monitoring scheme; A software based on noon reports, departure and arrival reports shall make an extract of the required voyages; The department and the person in charge shall be reported; Attention is needed the voyage to cover berth to berth and not pilot to pilot; Validation of the data is required. Control of risks related of potential errors, omissions or misrepresentation Processes for collecting, processing, consolidating and reporting List of voyages and information 33
C.3. Distance travelled Real distance travelled or the most direct route? Estimation of a correction factor in the later case. Distance in NM measured over the ground or through the sea? Distance measured per day manually on the chart or electronically through e- navigation. Validation of the data on both cases taking into account potential risks Responsible person to receive the data in the office and validate them. Procedure which describes all the above IT landscape showing the data-flow for this data 34
C.4. Amount of cargo carried & Number of passengers; Refer to the companies procedures for the calculation the mass of the cargo Cross-check methods for ensuring accuracy Define the uncertainty as per clauses in the charter party Report the responsible department and person who receives the data at loading and discharging port Justify the differences Keep records ashore and onboard for a minimum period of time 35
C.5. Time spent at sea Develop a procedure for monitoring recording and reporting the time spent at sea Use GMT time in the noon, departure and arrival reports from berth to berth( Exclude time in anchorage) Cross-check the reported time with Voyage abstract Logs Describe the IT software you use for that purpose Validate the data extracted from the software Make clear where the records are stores and who is responsible for that. 36
D. Data Gaps Develop complete back up procedures for: Calculation fuel consumption; Calculation the distance travelled; Treating data gaps regarding cargo carried; Treating the gaps regarding the time spent at sea Be ready to justify in the annual report the reason of using the gap methodology; 37
Data Gap Approaches 1. Redundancy of systems, for delivery missing or incorrect data sets 2. Secondary system is not available 3. STANDARD DATA GAP PROCEDURE is applied: a. To reproduce an adjustment of the original data b. To reproduce data set by using another parameter; or c. Alternatively using Historical data 4. STANDARD DATA GAP PROCEDURE is not available Another reasonable solution 38
E. Management The company should develop procedures for : 1. Data Flow activities with Regular checks 2. Control Activities for: a. Quality assurance and reliability of IT b. Internal reviews and validation of EU MRV relevant data c. Corrections and Corrective actions d. Outsourced activities e. Documentation 39
Data Flow Activities Create a logical sequence of data collections and processing Assess the risks associated with the data flow and set up control measures After the application of control measures reassess the risks Reading from instruments Converting volume to mass Transferring data Processing, storing, retrieving Errors Misrepresentations Omissions Ensure controls have been effectively applied Remaining risks are sufficiently low A well-defined data flow When and who takes which data From where and what does he do with these data Where the stores data thereafter A set of control activities Search for duplicates Search for data gaps Control check by an independent person A risk assessment demonstrating risk reduced to an acceptably low level for Errors Mis/representations Omissions 40
Quality Assurance and Reliability of IT IT technology used for transmitting, analyzing, processing, calculating and storing data: Ensure that are designed, tested, implemented, controlled and maintained Reliable, Accurate, and timely processing of data is guaranteed. Develop controls such as: Access control Back up Recovery, Continuity planning and security 41
Internal Reviews and Validation of Data CHECK ON COMPLETENESS & COMPARISON OVER THE PAST YEARS SET UP CRITERIA FOR REJECTING DATA AS A MINIMUM REVIEW shall include: Data completeness check Trend analysis (comparison of the data over several years) Comparison of data resulting from different operational data collection systems Comparison of calculation factors that have been determined by analysis, calculated or obtain from the supplier. 42
Correction and Corrective actions Describe the appropriate actions taken if the data flow activities and control activities are not functioned effectively; Describe how the validity of output is assessed, how the cause of error is determined and how it is corrected; Corrections should come as actions for the improvement of the effectiveness of the system; Corrections may happen to MP itself 43
Outsourced Activities Outsourced processes must be included in the control system such as: Bunkering External laboratories Maintenance of measuring equipment Identify How: Data flow activities Control activities are checked by the outsourced processes 44
Documentation Develop procedures for record keeping, retention records, management of versions The data and records shall become available upon request Keep records and relevant data for 3 years. 45
F. Further Information Definitions and abbreviations 46
Comparison EU MRV IMO System Monitoring EU MRV Ships 5000 GT and above for per Voyage to/from EU port monitoring and on an annual basis EU Monitoring Plan Starting 1 st January 2018 IMO Fuel Data Collection System Ships 5000 GT and above Annual basis for ALL voyages Updated SEEMP (Part II) Starting 1 st January 2019` First monitoring period 2018 2019 Exemptions Parameters Reporting Warships, naval auxiliaries, fish-catching / processing ships, ships not propelled by mechanical means and government ships used for non-commercial purposes Amount and emission factor for each type of fuel consumed CO2 emitted per voyage falling in EU MRV/per annum Cargo carried Total Transport work Total Distance travelled Total Time at sea & in port Average Energy EFFICIENCY All the above parameters Ship Name IMO number Port of Registry Name of Shipowner Name of company with address, email and details of contact person EEDI or Estimated Index Value (EIV) Identity of verifier Ice class if applicable TBD Total Annual Fuel consumption - Design deadweight - Distance travelled over ground (O/G) Hours underway - All the above parameters - IMO Number - - - EEDI if applicable - Ice class if applicable 47
Comparison EU MRV IMO System Verification EU MRV EU accredited verifiers ISO standard procedures for the assessment of MP and verification of ER Reports to European Commission Flag state IMO Fuel Data Collection System Flag Administration/ recognized organisations IMO guidelines Certification Document of Compliance (June 2019) Statement of Compliance Publication Distinctive public database Anonymous public database Disclosure Public Confidential 48
Conclusions 1. A very heavy NEW management system is created; 2. Challenged areas for the shipping with new procedures and meanings; 3. A great attention should be given to the determination of uncertainties and data gaps; 4. A thorough risk assessment should develop with the aim to identify and control the inherent, the control and detection risks and minimize the uncertainties; 5. A detailed flow chart of activities should be prepared for better control; 6. Validation of the data is needed, including any predetermined materiality thresholds 7. Operational and control procedures shall be implemented to ensure the quality, integrity and security of the information. 8. A well competent verifiers with a good experience on business activities is required 49
THANK YOU FOR YOUR ATTENTION QUESTIONS? KOSTAS VLACHOS 05/04/2017 50