LSMGO
Hong Kong Extends Port Facilities and Light Dues Incentive Scheme for Use of Clean Fuel
The Hong Kong Marine Department issued a notice, 91 of 2015, announcing that they have extended the Port Facilities and Light Dues Incentive Scheme 31 March 2018.
Registration of ocean going vessels (OGVs) under the current incentive scheme will expire on 25 September 2015. To continue enjoying the 50% reduction in port facilities and light dues up to 31 March 2018, OGVs (through their owners, charterers, managers or agents) are required to make a new one-off registration with the Environmental Protection Department (EPD) under the Extended Incentive Scheme. OGVs not registered under the current incentive scheme can also make similar application to join the Extended Incentive Scheme.
The Environmental Protection Department will notify the applicant in writing the result of the application within 10 days after receiving the application and all the relevant documents. The names of successfully registered vessels will be put on the “List of Registered Vessels”. The List will be uploaded to the Environmental Protection Departments Website.
The incentive scheme was launched in year 2012 from 26th Sep 2012 and was notified to industry wide notice 132 of 2012.
To qualify for the incentive scheme, OGVs must while berthing in Hong Kong commit to taking measures to reduce emissions of sulphur dioxide (SOx) by such measures as utilizing marine fuel with sulphur content not more than 0.5%, utilizing liquefied natural gas (LNG), or utilizing an onshore power supply.
To support my/our application for grant of a Concession under the Incentive Scheme, shipping agent / shipmaster will have to submit to the Director of Marine Department the following documents within 3 days after the Vessel leaving Hong Kong
waters:
(a) Completed Fuel Switching Declaration Form signed by the shipping agent and shipmaster, indicating the fuel switchover time upon arrival and departure from berth. The section of “Undertaking and Declaration by the shipmaster” must be signed under the witness of an onboard crew member;
(b) Certified true copy of Bunker Delivery Note (BDN) signed by the shipmaster under the witness of an onboard crew member showing the last delivery of fuel with sulphur content not more than 0.5%. The date of the BDN shall be within 6 months before the arrival at Hong Kong; and
(c) Certified true copy of Engine Room Log Book signed by the Chief Engineer and counter-signed by the shipmaster under the witness of an onboard crew member, which indicate that the Vessel has initiated the fuel switchover procedure upon arrival at berth and only fuel with sulphur content not more than 0.5% has been used after 1 hour from initiating fuel switch operation and throughout the remaining berthing period, until 1 hour before the departure of the Vessel
Marshall Island Flag’s Recommendation on Low Sulphur Marine Gas Oil
Since 1 January 2015, the Republic of the Marshall Islands (RMI) Maritime Administrator (the “Administrator”) has noted a number of reported main engine and auxiliary engine malfunctions in MARPOL designated Emission Control Areas (ECAs). All of the incidents occurred either while changing over from heavy fuel oil (HFO) to ECA compliant low Sulphur fuel oil, i.e., low Sulphur marine gas oil (LSMGO), or sometime after the changeover was completed.
Based on the information we have available, it appears that what many of these cases have in common are leaking. It is likely that many of the leaks would have gone unnoticed or would have been considered minor when using HFO. However, these same leaks are proving problematic when ECA compliant fuel oil is used. A probable cause for this is that the viscosity of LSMGO is lower than for HFO. Another common issue is seized high pressure fuel pumps.
Although the details of how the management and coordination of bunker supplies will vary and are subject to both the charter party agreement and how the ship is traded, e.g., spot market, time charter, etc., it is noted that in accordance with ISM Code requirements the ship manager remains responsible for:
(a) ensuring the supply of quality LSMGO which meets main and auxiliary engine manufacturers’ fuel oil specifications;
(b) ensuring ship’s staff handling of LSMGO to ensure it is not inadvertently co-mingled with HFO or non-compatible LSMGO;
(c) coordination of the ship’s staff change-over from HFO to LSMGO in preparation for the ship’s entrance into a designated ECA, including communications of specific material details about the LSMGO such as its Specific Gravity, concentration of any potential contaminants, etc.; and
(d) ensuring procedural and technical assurances are in place to ensure critical machinery resiliency when running on LSMGO, e.g., greater potential for fuel oil system leaks due to the lighter and less viscous LSMGO.
Unless already done, ship owners and managers are urged to consult with the manufacturer of the main engines and auxiliary engines fitted on their ships and classification society to obtain guidance regarding:
• Procedures to changing over to LSMGO;
• Special operating requirements, e.g., lubricating oil requirements, fuel system settings, etc., when burning LSMGO;
• Changes to recommended maintenance requirements; and
• Changes to parts related to the fuel oil injection system.
Ship owners and managers should also review, and if appropriate revise, their safety management system, preventative maintenance system requirements, and list of critical spare parts and stores based on the guidance received. Designated Persons Ashore and ship Superintendents should ensure that Chief Engineers and senior engineers are familiar with these requirements as well as the increased risks associated with burning LSMGO.
The following additional recommendations are based on reports previously received:
• Ensure shore side Technical, Commercial and Supply staffs work closely together to ensure that when ordering fuel oil to ensure that the correct ISO standard, Sulphur content and other technical requirements are specified.
• Review and, as appropriate, revise fuel oil management procedures to ensure:
o fuel oil is not consumed until it has been tested and verified compliant all applicable requirements;
o incompatible fuel oils are not stored in the same tank; and,
o bunker tanks are cleaned on a regular basis and kept free of excess buildup of sludge and/or water.
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