IBIA update on low flashpoint fuel regulations at IMO: LNG, fuel cells and methanol
- Clarifications prepared ahead of 2017 entry into force of IGF Code
- Requirements for fuel cells within IGF Code given priority
- Work has progressed on guidelines for use of methyl/ethyl alcohol (methanol)
- Use of high manganese austenitic steel for cryogenic service under consideration
- No sign of specific guidelines for other low flashpoint fuels such as diesel
Work on developing International Maritime Organization (IMO) regulations for low flashpoint fuels other than gas has progressed, but took a backseat to other higher priority agenda items at the third session of the Sub-Committee on Carriage of Cargoes and Containers (CCC 3). CCC is a sub-committee of the IMO’s Maritime Safety Committee (MSC).
CCC 3, which met at IMO headquarters in the week 5-9 September, needed to urgently consider a number of so-called unified interpretations (UIs) relating to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), which is due to take effect from the start of 2017.
The meeting managed to finalise several draft UIs, proposed by the International Associate of Classification Societies (IACS) in order to facilitate consistent and global implementation of the IGF Code. The UIs seek to clarify various IGF Code requirements relating to how gas fuel systems are safely put in place on ships, which will determine design and construction standards. It is crucial for shipyards to have this clarity when constructing ships with LNG fuel systems. The UIs that were agreed at CCC 3 will be in a draft MSC circular and will go forward to MSC 97 in November for formal approval.
Other items on the agenda relating to the IGF Code included amendments regarding fuel cells, developing technical provisions for ships using methyl/ethyl alcohol (which includes methanol) as a fuel and a proposal from South Korea to amend the regulation to allow for the use of high manganese austenitic steel for cryogenic service.
At present, there are no specific proposals in the mix to develop specific guidelines for other low flashpoint fuels such as diesel.
Responding to rapidly developing fuel cell technology
The IGF Code Correspondence Group (IGF CG) had made significant progress on developing draft amendments to the IGF Code regarding fuel cells using natural gas as their feed fuel.
CCC 3 agreed that it would be preferable to develop draft amendments to the IGF Code regarding fuel cells in a generic form, separate from the natural gas-specific parts of the IGF Code. Fuel cells may use a variety of feed fuels, including hydrogen and methanol.
Developing general provisions will allow the marine industry to tap into and benefit from the rapid development of fuel cell technology in other sectors in a bid to reduce emissions, and not be limited to those using natural gas as feed fuel.
Although this was a top priority item, it proved too complex to be completed at CCC 3, meaning it will continue in the IGF CG until CCC 4. The provisions will cover installation and fire safety as well as fundamental design, operation and core components of fuel cell power systems. It was agreed that the amendments regarding fuel cells will be developed as a new draft part E to the IGF Code.
The requirements for storage, piping and so forth for the fuels used to feed the fuel cell will, however, need to be addressed separately as that will be different for each type of feed fuel.
Those parts would need to be covered by either the IGF Code’s existing provisions for LNG fuel storage and piping given in part A-1 of the Code, or demonstrate compliance with the Code through an alternative design for any other type of low flashpoint fuels.
The IGF CG reporting to CCC 3 said good progress has been made on draft technical provisions for the safety of ships using methyl/ethyl alcohol as fuel, including bunkering procedures. CCC 3 also had results from the German MethaShip project and a study by the European Maritime Safety Agency (EMSA) to support the next steps.
While some countries now feel very positive about methanol as fuel, and that the provisions are nearing completion, CCC 3 also heard several calls for taking a conservative approach.
Another debate relates to whether methyl/ethyl alcohol should be added as new chapter to the IGF Code, making the technical provisions mandatory requirements, or initially only be added as guidelines. There were divergent views on this at CCC 3, with some supporting mandatory provisions to give industry certainty in applying design principles, while others argued only interim guidelines are appropriate until there’s been more experience with methanol as a fuel. This means the status of any technical provisions will be decided later, possibly at CCC 4.
Time constraints meant CCC 3 wasn’t able to give consideration to the subject; hence it goes back to the IGF CG for further development prior to CCC 4.
Suitability of specific type of steel for cryogenic service still under consideration
The latest MSC meeting (MSC 96) agreed to consider the suitability of high manganese austenitic steel for cryogenic service, which, according to a submission from South Korea, is superior to other material and can help strengthen the structures of LNG tanks and pipelines on ships. This in turn could help improve the design of LNG carriers and ships using LNG as fuel, and make it more economic to build such vessels. South Korea has proposed amending the IGF Code and IGC Code (the code for ships carrying gas as cargo) to include this material.
CCC 3 agreed that further examination of experimental/test data is required to confirm the suitability of high manganese austenitic steel for cryogenic service before considering amending the IGC and IGF Codes. This assessment will be undertaken by new correspondence group (CG) established at CCC 3 that will report to CCC 4.
Providing the amendments to include the material in the IGC and IGF Codes are adopted before 1 July 2018, they should enter into force on 1 January, 2020.
It is possible to use high manganese austenitic steel for LNG carriers and fuel systems prior to then if the provisions for equivalents and alternative design and arrangements are followed.
No moves on other low flashpoint fuels
MSC 96, which met in May this year, rubber-stamped the decision that all safety concerns with regards to ships using low flashpoint fuels should be addressed in the context of the IGF Code.
This means the door has been firmly shut on the possibility of amending the flashpoint requirement in SOLAS. There have been attempts to revise the 60°C minimum for marine distillates and align it with the minimum flashpoint limit for automotive diesel, which is 52°C in the US and 55°C in Europe.
The IGF Code provides a standard for ships using low flashpoint fuels, although at present it only deals specifically with LNG. When it enters into force on January 1, 2017, it will apply to all vessels above 500 gross tonnage that install low flashpoint fuel systems.
Specific regulations for other low flashpoint fuels can be added as new chapters to the Code, but in the meantime, ships installing fuel systems to operate on other types of low flashpoint fuels will need to individually demonstrate that their design meet the Code’s general requirements.
While there were a large number of submissions regarding development of provisions for using methyl/ethyl alcohol as fuel, there were no items on the agenda at CCC 3 indicating moves to work on new chapters for other low flash point fuels.
Report by Unni Einemo