UNDER WATER SURVEY OF VESSELS (All about UWILD / IWS /UWS/ In Water Survey Notations)
Disclaimer
“This document has been developed purely as guidance to be used at the user’s own risk. No responsibility is accepted by the Authors, their Members or by any person, firm, corporation or organization for the accuracy of any information, or omission, in this document or for any consequence whatsoever resulting directly or indirectly from applying or relying upon this guidance even if caused by a failure to exercise reasonable care. This document does not provide legal advice. Nothing in this document is intended to replace, amend, supersede or otherwise depart from any legal or regulatory requirements. In the event of any conflict or contradiction between any legal or regulatory requirements and the guidance contained in this document then the legal or regulatory requirements shall prevail.”
WHAT IS UNDER WATER SURVEY OF A VESSEL?
The inspection of vessel in the presence of attending surveyor of a recognised organisation (classification society), whether scheduled or unscheduled, for accessing the condition of hull, it’s paint, markings and it’s fittings below the waterline and some part of exposed area of hull and it’s fittings which frequently goes under water, is called underwater survey.
Different Classification Societies provide different notations for under water Survey in the class certificates
Following are examples of few Notations related to under water survey provided by different classification societies
- UWILD – American Bureau of Shipping (ABS)
- IWS – Class NK
- UWS – Lloyd’s Register (LR)
- IN WATER SURVEY – Indian register of shipping (IRS)
- INWATERSURVEY – Bureau Veritas (BV)
- Bottom-In water Survey – RINA
- BIS: DNVGL
WHAT ARE THE CRITERIA OF VESSEL GOING UNDER WATER SURVEY?
A scheduled under water survey which is often termed as “Under Water Inspection In lieu of Drydocking” (UWILD) or In Water Survey (IWS) is generally a part of intermediate survey. Following to be satisfied for vessel to go for inspection under UWILD/IWS.
- Vessel must have an approved UWILD or IWS plan also called as “Booklet for In water survey”
- Vessel must have the maintained UWILD or IWS notation in it’s certificate of compliance.
Unscheduled Under water inspection:
- For measuring hull fouling. In some countries like New Zealand and Australia, hull fouling is a serious issue. Vessel visiting these countries must take necessary precaution in regard of hull fouling. Hence under water inspection and cleaning becomes necessary if vessel is visiting the above-mentioned ports.
- Vessel Performance Issues: If vessel is facing Speed-fuel Consumption issues, underwater inspection and cleaning should be carried out.
- Damage/repair/accident survey for accessing the extent and severity of damage.
How to get UWILD/IWS Notation?
- All requests for Underwater Inspection in Lieu of Drydocking Survey are to be forwarded by owner/operator/shipbuilding yard to the applicable Office of classification society for review and authorization.
- The concerned class will provide the guidelines for getting the UWILD/IWS notation.
- An initial survey is planned for the vessel, vsl notified, survey fixed after paying the survey fee.
- All arrangements made as per the guidelines provided by class. Plans showing the following items are to be submitted to the attending Surveyor, together with the proposed inspection procedures for review, well in advance of the inspection.
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- Location of bottom shell seams and butts (Shell Expansion), including any doublers, straps, bottom plugs, appendages and all underwater openings.
- Hull markings or other means to orient the diver and identifying photographs, which entail specific areas of plating, (e.g., locations of bulkheads or tanks) sea suction and discharge openings, propeller blades and rudder surfaces. Such preparations may include a weld bead grid system on the hull, a contrasting colour coating system, a movable grid, an acoustic locating system, or any other arrangement that is satisfactory to the Surveyor.
- Reference data and instructions to the diver for any necessary underwater operations such as means of access to sea chests to inspect the external side of hull connections and sea values, to rudder bearings to determine clearances of rudder bearings or to propeller shaft strut and stern bearings.
- Most recent gauging and it’s report from last Special Periodical Survey and the as-built scantlings for the underwater body.
- Initial survey of vessel carried out in following manner
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- New vessel survey is carried out during construction period.
- Existing vessel survey is carried out of water, that is in Dry dock.
- The results of initial survey are documented and submitted for further review.
- After a satisfactory review and approval of the UWILD plan the vessel is issued a certificate of compliance or included in the class notation. The UWILD notation is mentioned in the section “Additional Notations” of this certificate.
What are the limitations of UWILD/IWS?
- UWILD/IWS is applicable if Vessel has no outstanding recommendations for hull and it’s fittings.
- If damage affecting the fitness of the vessel is recorded during the course of the survey, the vessel has to be docked to carry out the necessary repairs.
- For vessels 15 years of age or over and subject to the Enhanced Survey Program (ESP), Underwater Inspections in Lieu of Drydocking (UWILD/IWS) are not permitted as an alternate to Drydocking Surveys.
- Non-ESP vessels 15 years of age or over applying to maintain UWILD/IWS notation are subject to special consideration based on the following review and examination before being permitted to have underwater inspection
- Review of vessel’s records to ensure that no unusual repairs have been required/made
- Internal examination of representative tanks and cargo holds
- Underwater Inspection In Lieu of Drydocking Survey (UWILD/IWS) may be restricted or limited where there is record or indication of abnormal deterioration, existing recommendation, or damage to underwater body, rudder, or propeller.
- Flag Administrations may have specific regulations for Underwater Surveys in Lieu of Drydocking, including requirements for enrolment, hull markings, extent of visibility and procedures for older vessels.
A Successfully completed Underwater survey is the alternative to intermediate Drydocking survey which can be held at 2.5th year, 7.5th year and 12.5th year intervals hence an ESP vessel such as Bulk carriers can take up minimum 3 under water surveys till the age of 15 years and after that no more underwater survey in lieu of drydocking. A non-ESP vessel (vessel other than Oil tanker, Bulk carriers, Combination carriers and chemical tankers) after 15 years of age can be further allowed to opt for in water survey in lieu of drydocking if condition of vessel is sound and no unusual repair has been carried out previously.
What are the areas covered in the under-water survey?
Hull part:
- Condition of random area of hull plating which includes condition of paint, any sign of damage, dent and amount of corrosion and fouling
- Condition of Bulbous bow
- Condition of bilge keel
- Condition of rudder trunk area.
- Condition of plugs securing and their identification marks punched over them and to be provided on hull in the form of weld beads
- Echo sounder and speed log fittings no damage.
- Sea suctions, gratings, their numbers in full weld beads and painted and amount of fouling
- Overboard valves openings their numbers in full weld beads and painted.
- Various hull markings like tug push marks, bulbous bow marks painted.
- Condition of Stern Frame any damage, amount of fouling.
- Condition of anodes and it’s securing, percentage of consumption.
- Condition of other ship specific underwater fitting such as thrusters, stabilizers etc.
Propeller:
- Condition of propeller blades for any damage, fouling etc
- Condition of propeller boss and fins if applicable.
- Wear down of stern bush (propeller drop): Wear down/Poker gauge reading
- Condition of rope guard and anything entangled with propeller
- Condition of stern frame
Rudder:
- Condition of pintle and neck bearings, clearance of bearings checked by surveyor where ever possible depending upon the arrangement of the rudder stock.
- Condition of rudder plating
What are the key features to be incorporated in to vessel’s design in order to get UWILD notation and carryout under water inspection there after?
- Rope guards to be provided an access hole and a diver’s grip on top and bottom. Accesses holes to be aligned with gauge position.
2. Blade Positions on propeller and boss to be marked so that propeller is kept locked in the same position each time the survey carried out.
3. Rudder lower pintle to be fitted with a removable Box and Inspection Hole to facilitate the measurement of lower pintle clearances.
4. Identification marks, all marks to be welding beads and painted. Below shows sea chest’s and discharge over board’s identification marks for reference.
5. Hinged sea chest Grids for ensuring the diver that sea suction openings are clear and clean if necessary
6. Bottom plugs of to be fitted flush with shell on each water ballast tank in double bottom, peak tanks, fuel oil tanks in double bottom, Bilge separated oil tank, fuel oil overflow tank, bilge tank and stern tube cooling water tank.
7. Each bottom Plug to be punched marked and welding bead on shell plate to be provided for identification purpose.
How to Go ahead with Under water Survey
Planning:
- Ship schedule closely monitored both by vessel and office between the window period of intermediate survey of vessel.
- To decide on the vessel schedule when it is in light condition. Where possible, the underwater examination should be carried out in protected waters, preferably with weak tidal streams and currents and with the vessel at light draft.
- Office sends the formal survey request to the class. Class suggests the availability as per tentative vessel’s schedule along with the quotation.
- Office reviews the quotation and confirm the Survey request.
- A class approved Diving company is booked for the scheduled date, the diving company has to employ fully qualified divers approved by class. Class may request to arrange a cleaning of hull prior undertaking the survey for having a meaningful examination of the Hull.
- Office notifies vessel about the booking of class surveyor and Diver company.
- Vessel liaise with surveyor and diver company and keeps them update with latest vessel schedule.
- Necessary info is shared among vessel, attending surveyor and diver company for close coordination and better in water survey preparation.
- Master sends the port agent details to surveyor and diver company. Both surveyor and diver company directly liaise with agent for coming onboard. All necessary permission required from port control for diving operation is obtained by diving company with the help of port agent or any other local agent.
- Master informs port control, with assistance of the agent, and attain permission to carry out the diving operation for survey purpose.
Preparation for diving operation
- Initial meeting comprising Master, chief engineer, diving team supervisor and attending class surveyor is done and scope of work discussed. The scope of work to be sufficient to include all items which would normally be examined if the vessel was on drydock.
- Plans containing Location of bottom shell seams and butts (Shell Expansion), including any doublers, straps, bottom plugs, appendages and all underwater openings discussed.
- Hull markings or other means to orient the diver and identifying photographs, which entail specific areas of plating, (e.g., locations of bulkheads or tanks) sea suction and discharge openings, propeller blades and rudder surfaces.
- Reference data and instructions to the diver for any necessary underwater operations such as means of access to sea chests to inspect the external side of hull connections and sea valves, to rudder bearings to determine clearances of rudder bearings or to propeller shaft strut and stern bearings.
- Most recent gauging and gauging report from last Special Periodical Survey and the as-built scantlings for the underwater body.
- A safety checklist to be followed which also help in preparations for carrying out diving operation safely. Please refer Appendix-A “CONTENTS OF A TYPICAL INWATER SURVEY REPORT” for check list.
- All arrangements made for carrying out diving operation safely and Means are provided to enable the Surveyor to accomplish visual inspection of area outside of the shell plating above the waterline and exposed portions of appendages (such as propeller, rudder and rudder bearings).
Commencement of diving operation:
- Once everything is ready Diving Flag is raised, master informs port control about commencing diving operation. Commencement of diving operation is logged in to port log.
- Underwater inspection begins by qualified divers under the surveillance of the attending Surveyor and one representative from vessel, preferably master or chief engineer.
- A good two-way communication between the Surveyor and divers is to setup.
- The vessel’s underwater body is to be sufficiently clean and the sea water is clear enough to permit meaningful examination and photography by the diver. “Sufficiently clean” is taken to mean that sections of the underwater body, including flat keel plating forward, amidships and aft, are cleaned to the extent that the Surveyor can determine the condition of the plating, the welding and the coating. Additional cleaning may be necessary. Overall or spot cleaning may be required at the discretion of the attending Surveyor.
- An examination of the entire vessel below the waterline is to be carried out by a Class approved diver using closed-circuit television with two-way communication. The progress of the dive is to be monitored by the onboard Surveyor as required and is to be photographically documented along with videos. Items that must be recorded on the tape/photograph include but are not limited to:
- Time at which dive commences
- Point of commencement
- Time viewed
- Hull parts
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- Conditions of hull markings
- Random areas of plating
- All sea chests
- All inlets and discharges
5. Rudder
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- Pintles
6. Propeller: Follow Appendix-B for detailed procedure
7. Time and point of completion of the dive
Completion of diving operation:
- Port control is informed about completion of diving operation.
- Time of completion to be recorded in port log.
- The ship system which was locked or isolated for the safety reasons can be returned to normal.
- The above examination is to be supplemented by the diver’s report describing and attesting to the conditions found. A copy of this report and pertinent photographs are to be submitted to the attending Surveyor. Copies are also to be retained onboard. Please refer Appendix-A “CONTENTS OF A TYPICAL INWATER SURVEY REPORT”
If no abnormality noted by attending surveyor, underwater inspection may be credited as an alternative of Drydocking Survey.
- If the Underwater Inspection reveals damage or deterioration that requires further attention, the Surveyor may require that the vessel be drydocked in order to undertake a detailed survey and necessary repairs.
Exclusions:
- If by some reason the attending surveyor is not able to determine the condition because of dirty water, the diving operation may be suspended, class may grant extension till the next port.
- An ESP Vessel above 15 years of age, seeking extension, an in-water survey is carried out which is only for postponement purpose and docking is not credited
Ashish Goyal
Chief Eng. Dockendale Ship Management
Email: [email protected]
Below are following appendixes for references.
- Appendix-A: CONTENTS OF A TYPICAL INWATER SURVEY REPORT
- Appendix-B: PROCEDURE FOR CHECKING STERN TUBE BEARING WEAR DOWN (PROPELLER DROP)
- Appendix-C: RESULTS OF UNDERWATER SURVEY CARRIED OUT ON DIFFERENT VESSELS
- Appendix-D:
- EXAMPLE OF INCLUSION OF UWILD NOTATION IN ABS CLASS CERTIFICAT
- EXAMPLE OF INCLUSION OF IWS NOTATION IN ABS CLASS CERTIFICAT
References:
- ABS GUIDE FOR THE CLASS NOTATION, UNDER WATER INSPECTION IN LIEU OF DRYDOCKING
- IRS Rules for IN WATER SURVEY
- Class NK Rules For IWS
- Section 1. Of Rules for Classifications: Ship – DNVGL-RU-SHIP-Pt6Ch9. Edition October 2015
- Bureau Veritas Classification e-rules on In-water Survey (INWATERSURVEY), Ch1, Sec2, [6.14.3]
- In water Survey Booklet of Different vessels
- Consultation with Cpt. Stetson Jude Rebeiro, Master with Dockendale Ship Mgmt. (India) Pvt. Ltd.
Oops! fuel oil Sulphur content is out of limit.
Disclaimer
“This document has been developed purely as guidance to be used at the user’s own risk. No responsibility is accepted by the Authors, their Members or by any person, firm, corporation or organization for the accuracy of any information, or omission, in this document or for any consequence whatsoever resulting directly or indirectly from applying or relying upon this guidance even if caused by a failure to exercise reasonable care. This document does not provide legal advice. Nothing in this document is intended to replace, amend, supersede or otherwise depart from any legal or regulatory requirements. In the event of any conflict or contradiction between any legal or regulatory requirements and the guidance contained in this document then the legal or regulatory requirements shall prevail.”
Oops! fuel oil Sulphur content is out of limit.
It would be 9 months since the Sulphur max limit in fuel was implemented world-wide, starting from 1st Jan 2020, satisfying IMO regulation. New global Sulphur limit has been reduced from 3.5% m/m to 0.5% m/m and for Emission Control Area (ECA) it is the same as before 0.1 % m/m.
Vessels are complying with this new regulation using either of two methods as stated below
- Using compliant fuel, that is, Sulphur limit meeting the requirements of IMO regulations.
or
- Using alternative provision. where vessels can use fuel having more that 0.5% m/m Sulphur provided fitted with approved scrubber system (EGCS-Exhaust gas cleaning system)
Bunkering process in brief:
As a normal practice the Sulphur limit of a bunker is verified first in certificate of quality (COQ) provided by bunker supplier along with bunker nomination before the start of bunkering operation. The acceptance of bunker is granted if Sulphur percentage and other parameters mentioned in COQ satisfy the requirements of IMO standards (MARPOL annex VI).
During bunkering, representative bunker samples are drawn and sealed in the presence of supplier and vessel’s representative. At least 4 samples are drawn, these are
- Vessel Retention
- Lab analysis
- MARPOL
- Bunker Barge
Depending upon further requirements more samples can be drawn such as MARPOL(Barge), Surveyor’s Sample etc
This article is concerning verification of Sulphur percentage in fuel and it’s compliance hence the focus will only be on Sulphur percentage of fuel not on other parameters.
Verification of Sulphur percentage by vessels:
In my knowledge, right now, there is no approved onboard test method which could give, vessel’s representative, right to reject the bunker nomination on the basis of the result of the test.
Some vessels are provided with portable Sulphur analyzers but I doubt that can be used for rejecting the bunker nomination even if the results of it shows more than the limit (off spec). this is because the accuracy of onboard analyzer can always be questioned and rejecting a bunker nomination without a solid ground may invite monetary disputes between supplier and vessel. In such situation vessel can safeguard her interest by giving a note of protest to the bunker supplier.
Following method is followed largely, onboard, for the verification of Sulphur percentage in bunkered fuel.
The sample labelled as “Lab” is sent to shore-based lab for analysis. The lab analysis report is then used to verify the Sulphur limit along with other parameters.
If the report shows Sulphur percentage within limit vessel will continue to use it.
If the report shows off limit (off-spec) Sulphur percentage, vessel will report this matter to all concerned parties and bunker supplier will be notified.
Case History
In a known incidence, a vessel bunker Sulphur content mentioned in BDN was 0.49 % m/m. The representative sample of this bunker was tested at a shore-based laboratory. The Sulphur content by lab was verified as 0.51%.m/m.
Vessel reported this matter to office/owners/charterers, supplier was notified. Supplier came up with following explanation
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As far as Sulphur is concerned a result of 0.51% from a ships own sample is within the 95% confidence for the test and is therefore considered on spec. The test report as supplied should state that the result is within the 95% confidence interval and is therefore not deemed to be off spec.
I have enclosed a graph which demonstrates this as well as the CIMAC guidelines for interpretation of analysis results and Verifuel understanding ISO 4259 document.
As you can see the owners vessel tested sample can’t be seen to be of spec until its outside the 95% confidence at 0.51 (i.e. 0.54%) (if it’s in the grey, it’s OK)
As such, 0.51, 0.52. 0.53% S on a vessel tested sample is on spec and the customer has no claim.
IF the vessel tested sample test outside the 95% confidence, i.e. 0.54% or over (the right side red colour), then that initiated the testing of the official, barge retained, BDN listed suppliers sample.
At that stage the supplier has a responsibility to deliver to the spec, so his official sample results must be at, or below the 0.50% specification.
All the above and the picture are representation of the CIMAC guideline – explaining how all the industry experts (including ISO 4259 Chairman) have interpreted ISO 4259, which is inherent in ISO 8217.
These principles apply to all test methods, not only Sulphur
unquote
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Unquote
Need to be understood
What is this 95% confidence?
In the simplest way it can be defined as the Statistical terminology used to provide a marginal deviation, variation, allowance or tolerance to the test results.
To understand further the 95% confidence principle following need to be understand
Repeatability – expressed as ‘r’ Is the closeness of agreement, usually found, between independent results obtained in the normal and correct operation of the same method on identical test material, in a short interval of time, and under the same test conditions (same operator, same apparatus, same calibration standard and same laboratory).
Reproducibility – expressed as ‘R’ Is the closeness of agreement, usually found, between individual results obtained in the normal and correct operation of the same method on identical test material but under different test conditions (different operators, different apparatus, different calibration standards and different laboratories).
The supplier and vessel test results come from two different labs hence reproducibility (R) of the test is used to define the acceptance limits of parameters (e.g. Sulphur percentage) causing disputes. The acceptance limits so defined will satisfy ISO 4259 this in turn helps in avoiding the unnecessary disputes generated from the marginal variation in test results.
For commercial marine fuel transactions, the 95% confidence testing boundary is given by ISO 4259 which is 0.59 times the reproducibility value (R); hereafter expressed as 0.59R. Whereas, in the usual case, there is a single test result, the value of R is that which is stated in the relevant test method. However, where multiple tests have been undertaken or where more than one laboratory has been involved in the testing this given R value is modified by the relevant equations as given in ISO 4259. It is to be noted that the confidence testing boundary for a characteristic is not an error margin; it is the direct result of the inherent reproducibility of the fuel test method.
How to arrive the upper acceptance limit?
As per ASTM D4294. Repeatability (r) in weight percent (wt. %) according to ISO 8754 for Sulphur in concentration range of 0.03 to 0.05 wt. % (a) and greater than 0.05 wt. % (b). The target concentration is represented as S.
For a marine fuel the later equation is applicable as the target concentrations are 0.1% s m/m, 0.5 % s m/m and 3.5 % S m/m.
𝑅=0.1781 ×(𝑆+0.05)
𝑅=0.0812 ×(𝑆+0.15) – applicable for marine fuels
Sulphur Limits (% m/m) | Target concentration (S) | Reproducibility 𝑅=0.0812 ×(𝑆+0.15) | Upper acceptance limit = Sulphur limit+0.59 R |
0.1 | 0.1 | 0.02 | 0.11 |
0.5 | 0.5 | 0.05 | 0.53 |
3.5 | 3.5 | 0.29 | 3.67 |
Reference to implications of ISO 4259 requirements, the recipient with a single test result above the specification limit but below the ‘limit plus 0.59R’ cannot claim that the specification has not been met and consequently has to accept that the product has met the specification and there is no requirement to carry out additional testing. The recipient can only consider that a maximum specification limit value has been exceeded if their test result exceeds the limit plus 0.59R.
Is it legally acceptable to use 95% confidence interval terminology for judging fuel samples having minor variation in Sulphur percentage?
As per MEPC circular MEPC.1/Circ.882, 16 July2019, “EARLY APPLICATION OF THE VERIFICATION PROCEDURES FOR A MARPOL ANNEX VI FUEL OIL SAMPLE
(REGULATION 18.8.2 OR REGULATION 14.8)”
There are three types of samples.
- MARPOL delivered sample means the sample of fuel oil delivered in accordance with regulation 18.8.1 of MARPOL Annex VI.
- In-use sample means the sample of fuel oil in use on a ship.
- On board sample means the sample of fuel oil intended to be used or carried for use on board that ship.”
Representative samples provided with BDN in accordance with MARPOL, Annex VI, regulation 18.8.1 comes under “MARPOL delivered fuel oil sample” and the acceptable range for this is in accordance with table 1 as mentioned in the circular.
“In use sample” and “Onboard samples” are tested in accordance with table 2 as mentioned in MEPC circular MEPC.1/Circ.882.
It is evident from table 1 and table 2 that samples delivered with BDN (MARPOL delivered samples) are not given any allowance. Hence 95 % Confidence limit explanation cannot hold good to justify a marginal increase of Sulphur content in bunker fuel sample from the limit ‘V’ mentioned in table-1.
95% confidence, or 0.59R (where R is the reproducibility of the test method) does not apply to MARPOL delivered samples as per table 1, the average test result from one laboratory must be at or below the applicable limit, e.g.0.10% or 0.50% Sulphur, to be considered to have met the requirement of the regulation.
Reference to table 2 as shown above, 95% confidence principle can be applied to “in use sample” and “onboard samples”. meaning an average test result up to the limit +0.59R will be considered to have met the regulatory requirement. This means 0.50 % m/m Sulphur VLSFO can go up to 0.53% m/m and LSMGO, 0.1% m/m Sulphur can go up to 0.11. Please refer table 2 as mentioned above.
MARPOL Annex VI, Appendix VI, paragraph 2.2
If the result of X is greater than the applicable limit required by annex VI, Verification Procedure Stage 2 should be conducted; however, if the result of “X” is greater than the specification limit 0.59R (where R is reproducibility of test method), the fuel oil shall be considered non-compliant and no further testing is necessary.
This would mean, if Average test result of 2 MARPOL delivered samples is more than the limit (0.1, 0.5 %) required by annex VI the sample is still not considered off spec till the average is more than 0.59R that mean a for a 0.5% Sulphur fuel, average of test results cannot be considered off spec till it is more than 0.53%, in the same way for a 0.1% Sulphur fuel, average of test results cannot be considered off spec till it is more than 0.11%
Summary:
- Reference to 1/Circ.882, 16 July2019, table 1, for a MARPOL delivered sample, test results have not given any allowance from it’s limits and fuel is considered to be not meeting the requirements if test results are greater than the specified limits 0.1 or 0.5. that mean 95% confidence principle cannot be applied for MARPOL delivered samples.
On the other hand, MARPOL Annex VI, Appendix VI, paragraph 2.2 test results have been given allowance 0.59R from it’s limits and fuel are considered to be not meeting the requirements only when the test results are greater than test margin value 0.11% or 0.53%. more over MARPOL Annex VI, recommend the use of fuel satisfying ISO 8217 standards. ISO 8217 in turn uses ISO 4259:2017-2 and ASTM D4294 standards for the verification of test results as per 95% confidence principles hence can say that MARPOL Annex VI allows the use of 95% confidence principles for the verification of test results.
It is quite clear from above explanations that 95% confidence principles can legally be accepted for the verification of test results when the results show a marginal increase in the Sulphur percentage from it’s limits.
- Reference to 1/Circ.882, 16 July2019, table 1 and table 2 there are two different approaches of verification of test results. It is different for MARPOL delivered samples from “in use sample & onboard samples” which may cause confusion. Organizations like CIMAC, IBIA etc. have raised concerned for not having the same principle in place for MARPOL delivered samples as it is used for in use sample & onboard samples. Some organization has already recommended that IMO should be invited to re-consider the Annex verification procedure, taking into account the technical facts and the established commercial practice. If there is to be a robust and reliable enforcement of the Sulphur limits, there needs to be a single universal unambiguous approach.
- Incidence where a test result of a MARPOL delivered sample having minor variation in Sulphur percentage from the limits specified by IMO and considered on spec basis 95% confidence still may invite an unwanted PSC extended inspection if not properly explained by vessel responsible staff/representative/chief engineer and PSC inspector may start suspecting it as a potential noncompliance. It is the responsibility of ship staff to explain their part in all respect so that an unwanted extended PSC inspection could be avoided.
Such incidences give rise to unwanted communication and documentation, waste lot of positive energy and snatch the peace of the mind of vessel staff. Hence it is the responsibility of the vessel staff to take a proactive approach in critical operations like bunkering and take all necessary precautions throughout the whole operation. In case of doubt, it is best to communicate with office. A proper planning, execution, monitoring and exercising due diligence during operation can save vessel staff from getting trapped in such Oops moments.
Ashish Goyal
Chief Eng. Dockendale Ship Management
Email: [email protected]
References:
- Exxon Mobil marine technical article: acceptance limits for test results ISO 4259 and how it applies to ISO8217
- DNV-GL FAQ on Global Sulphur CAP 2020 https://www.dnvgl.com/maritime/global-sulphur-cap/FAQ.html
- 02 | 2016 CIMAC Guideline-The Interpretation of Marine Fuel Analysis Test Results. https://www.cimac.com/cms/upload/workinggroups/WG7/CIMAC_WG07_2016_Feb_Guideline_Interpretation__Fuel_Analysis_Test_Results_Final.pdf
- Webinar held on 30 July 2020 by MR. Venkata N Reddy, fleet manager, Dockendale Ship MGMT PVT Ltd.
- Reply from World Fuel Services Trading DMCC, made available by MR. Venkata N Reddy, fleet manager, Dockendale Ship MGMT PVT Ltd.
- Samples taken in accordance with the 2019 Guidelines for onboard sampling for the verification of the Sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1).”
- 1/Circ.882, 16 July2019, “early application of the verification procedures for a MARPOL ANNEX VI fuel oil sample (REGULATION 18.8.2 OR REGULATION 14.8)”
- Guidance for best practice for Member State/coastal State(1/Circ.884)
- Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships MEPC.1/Circ.875/Add.1 9 November 2018
- Resolution MEPC.182(59) adopted on 17 july 2009: 2009 guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL annex VI
- Resolution MEPC.320(74) : 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL ANNEX VI
- International standard ISO 4259:2017-2
- Unni Einemo ([email protected]) articles,
- a) IMO 2020 FAQ: Marginal sulphur exceedances https://ibia.net/2019/12/19/imo-2020-faq-marginal-sulphur-exceedances/
- b) IMO 2020 tools and guidelines, https://ibia.net/2019/12/19/imo-2020-tools-guidelines/
- IBIA article: Changes to sulphur verification procedures under MARPOL Annex VI, https://ibia.net/2019/10/01/changes-to-sulphur-verification-procedures-under-marpol-annex-vi/
- Sulphur inspection guidance – European Maritime Safety Agency
- Article of SHIMADZU Corporation: Analysis of Sulfur in Petroleum Products According to ASTM D4294 & ISO 8754 using Shimadzu’s EDX-7000
- Gard article, Are you 95% confident that your very low Sulphur fuel is on spec and MARPOL compliant?, http://www.gard.no/web/updates/content/28989213/are-you-95-confident-that-your-very-low-sulphur-fuel-is-on-spec-and-marpol-compliant
for downloading PDF version of this article please click below.
Oops, Sulphur contents are out of limit-
Limitations of remote-control operation of Marine Power plant and Auxiliary machinery
All the remote-control limitations satisfy SOLAS and IACS (international Association Classification societies) standards. The requirement may differ according to class notations. But basics remain common to all ships.
Remote control limitations mean shortcomings with the systems
Limitations of remote-control operation of Marine Power plant.
1. AE can start automatically any time which can lead to accidents if somebody is not careful while working in the close proximity of the generators.
Hence to prevent that following need to be observed.
a) That Warning signs are displayed near AEs that, “AEs can start any time”.
b) All rotating parts to be covered properly.
c) No safety to be bypassed.
d) It is essential to isolate, lockout and tagout the AE properly whenever any maintenance is carried out on them.
2. Any water leaks in combustion space will not be noticed and if AEs start in this situation from remote may lead to major damage to the AEs due to water hammer. Hence as a best management practices the AEs are always blown through first and started locally to avoid damages.
3. AE’s remote operation is dependent upon the input of various parameters. These parameters are measured with the help of various sensors. Malfunction of any of the sensors can lead to sudden stopping of AEs or render it in inoperable condition. That can lead to dangerous situations when vessel is navigating in narrow waters. Hence keeping such situations in mind two AE’s are run in parallel when navigating in narrow waters. And running generators are checked time to time physically to ensure their trouble-free operation.
4. The operator may not come to know about the fuel oil or lub oil leaks immediately and by the time alarm sounds or safety system actuate a shut down, might be too late by that time.
5. Any unusual sound in AEs may not be observed immediately if the AE’s are stared from remote. Hence as A best management practice the AEs are started from local and switch over to remote once insured that all is well.
6. Malfunction of any safety or shut down device may cause sudden stopping of AEs or AEs cannot be stared at all.
7. If excessive water in the starting air system AE may failed to start in remote starting. When AEs are stared from local sand, it is normal practice to drain the water from the starting air system. This is related to maintenance issues where the remote operation fails due to badly maintained water separators, automatic drains traps and dryers in the system.
8. The remote-control systems are Sensitive to vibrations and heat and dust hence required utmost attention for maintaining in good health.
Limitations of remote-control operation of Auxiliary machinery
1. Aux. Machinery can start automatically any time which can lead to accidents if somebody is not careful while working in the close proximity of the standby machinery.
Hence to prevent that following need to be observed.
a) That Warning signs are displayed near machineries, “machinery in standby mode can start any time”.
b) All rotating parts to be covered properly.
c) No safety to be bypassed.
d) It is essential to isolate, lockout and tagout the machinery properly whenever any maintenance is carried out on them.
2. Actual health of the running auxiliaries may not be assessed when the machinery is operated from remote station.
3. Remote operation of various pneumatically operated deck valves or dewatering valves or other machineries like pneumatically operated winches and davits may fail to operate in cold weather as moisture in the air tends to freeze in the system and may clog tiny orifices of control valves on main decks or in mast houses. To deal with this the effectiveness of dryer lubricator in the systems to be checked time to time. In this situation System may require additional heaters and or regular draining of air from the system.
4. Similarly, if the systems are hydraulically operated the oil become thick in cold weather and causes unusual leakages and rapturing of pipes if system is not warmed up before put in use. Hence the remote starting of system must be done with care and system must be put in circulation for a while which is generally done by manually operated valves. For example, the hydraulic system for hatch covers and mooring winches is put in recirculation in cold weather before operation.
Any kind of oil leakage may not be noticed till the time low level alarm sounds by that time system can lose a large quantity of system oil.
5. Power operated ventilation louvers and operation of fire dampers: the remote operation doesn’t ensure whether the louvers are completely closed or completely open. Same to be insured during the periodic inspection of the system.
6. Where machinery has more than one control station it become difficult to trace out the fault and sometimes, a fault at one control station render the whole system inoperable hence the effectiveness of the control system is checked time to time by operating the machinery from all operating stations.
7. Some remote operations of machineries required proper communication failing to do so may lead to severe accidents.
Remote starting of heavy machinery requires engine room to be informed for the requirement of extra power from DGS. Starting of such machineries from remote without proper preparation may lead to over loading of generators and eventually the blackout. For example, before starting ballast/De-ballast operation, Engine Room to be informed though todays latest automation systems can take care of such situation and can start another DG if load demand increases beyond a certain limit.
There are other issues related to maintenance of aux. system which may impair the remote operation of aux. machineries.
1. In steering system Excessive play in the linkages, leakages in hydraulic system and play between rudder stock and rudder cannot be identify by the control system which may impairs the accuracy of the steering system and may lead to accidents.
2. Inaccurate Remote level sensors and wrong indications of remote operated valves often cause problem in bilge and ballast operation and sometimes may lead to pump damage due to dry running of pumps. To deal with this the manual sounding of tanks is carried out and the valve open/close position is ensured manually. Wrong indication of sensors and valves sometimes may lead to overflow of tanks and severe stability problem if not crosschecked in time.
3. Lifeboat davits, bunker davits, provision cranes, gangway winches control systems are provided with various limit switches to safeguard the systems/machineries. Any malfunction of these limit switches may lead to accidents or make the system inoperable. As a safeguard the correct functioning of these limit switches is insured before putting the machinery in use from remote.
There are many other aspects related to limitations of remote operations of aux. machineries. Remote operations are unsafe without the proper knowledge of the system and it’s operation and need proper communication, monitoring and maintenance for trouble-free services. For further quarry please contact us on [email protected] we will be happy to answer you.
Connecting Rod Bolts renewal and Angle Tightening YANMAR ENGINES
Simulation launching of totally enclosed Life boats
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UV Sterilizer ” Additional Support to fight CORONA Virus”
This equipment is created onboard our ship African Harrier on 27 Mar2020 and we are using it as additional support to fight with the CORONA pandemic.
The equipment is created on the basic use of Ultraviolet rays in sanitization.
The equipment is being used for sanitation where other means of disinfection can not be used.
For example
Electronic radio equipment is used by master and pilot both hence water-based spray can not disinfect mouthpiece of radio.
Important documents can not be sanitized by a spray of disinfectants their the equipment made by us works well.
There are numerous examples where our UV equipment can be used as a better alternative as a sanitizer but strictly it can not be used on skins and eyes, and need to be handle by a trained person.
Our video is self-explanatory
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