This procedure shall ensure that the vessel has adequate fuel to conduct the voyage safely and that safe bunkering operations in conformance with regulations and recommendations is in force. Bunkering operations must be completed without threat to either personnel or the environment.
All fuel bunkering systems must be properly and effectively maintained to minimise the risk of failure and spillage during bunkering operations.
In particular, bunker lines are to be pressure tested at least annually, or at any other time where there is reason to suspect there may be an issue.
The vessel must carry an adequate reserve of fuel for the planned voyage.
All ships must carry at least the following minimum fuel reserve:
• For voyages longer than seven days:
o Main Engine: 5 days reserve at safe economical speed
o Auxiliary Engines: 5 days reserve (not required if both Main Engine and Auxiliary Engines use the same grade of fuel)
• For voyages of less than seven days
o Main Engine: 3 days reserve at safe economical speed
o Auxiliary Engines: 3 days reserve (not required if both Main Engine and Auxiliary Engines use the same grade of fuel) The Ship Management Team may reduce or increase the above reserves in cases where they consider them to be inappropriate. Any decision to reduce or increase the reserve must be made in writing and give reasons.
The reserve may only be reduced if, with the reduced reserve, the vessel is at every stage of the voyage still able to reach a port where a supply of fuel that can be used in the vessels Main and Auxiliary engines. Approval to reduce the reserve must be received in writing from the Ship Management Team, and will only be granted after a thorough risk assessment.
Un-pumpable fuels are not to be included in reserve calculations.
It is the Ship Management Team’s responsibility to set the fuel specifications for the machinery on board the vessel. In determining the fuel specifications the following will be taken into consideration:
• Service and Settling Tank arrangement, mixing tank and sludge capacity.
• Pre-heating, centrifuging, fuel treatment and handling facilities on board.
• Condition of machinery and vessels past experience.
• Industrial standards for fuel quality such as ISO.
• National and international regulations for the fuel on board the vessel.
• Vessels trading area that may have limited supply options.
• Recommendation of Class Society and relevant rules.
Since January 2020, fuel with a sulphur content higher than 0.5% may not be used onboard (unless an exhaust gas cleaning system is fitted and approved). Since March 2020, such fuel may also not be carried.
If the ship receives non-compliant fuel, the Managing Director is to be notified, and a course of action agreed between the ship and the Company, having due regard to relevant international and national requirements.
The Chief Engineer is responsible to ascertain the bunker tanks in use and establish their capacities based on the Tanks Plan, Sounding tables, Stability, trading area, Class records, current actual operating practice on board and condition of the vessel and equipment.
Fuel specifications such as “Low Sulphur Fuel” requirements may also need to be considered in establishing the fuel capacity of the vessel. The fuel requirements of auxiliary plant and machinery such as boilers, emergency generator and life boats must be taken into consideration when ordering bunkers.
The lay-out plan of the bunker tanks with piping system, manifold, transfer pumps, sounding pipes and vent system are shown on drawings the bunkering arrangement plan is to be in the Deck Office and Engine Room.
All bunker tanks are to be sounded daily, and the soundings are to be recorded in a dedicated folder.
The Chief Engineer must ensure that the useable bunker R.O.B. and consumption figures to be recorded in the Engine Log Book and send this information to the Master by the Noon each day. This figure is an important one and careful consideration must be given to establish its accuracy at each occasion.
If there are other bunkers on board which are old, unusable or unrecorded for whatsoever reasons, the Chief Engineer must bring this to the knowledge of the Master and the company immediately.
Under a time charter the Master shall order bunkers through the charterer and mark the delivery receipts ‘For Charterers A/C only’. Under a voyage charter, the Master will order the bunkers from Owner/Manager.
Bunker fuel containing H2S may be supplied without advance notice given to the vessel and those involved with bunkering should be alerted to this possibility. If bunkering with fuel containing H2S close to or above the threshold limit value is unavoidable then access to areas adjacent to and downwind of the loading area and respective tank vents is to be prohibited during bunkering operations. The advice of the Ship Management office is to be sought urgently before bunkering is commenced.
1. General
For the purposes of these instructions the term “Bunkering” refers to the bulk transfer from shore facility, barge etc. to vessel of fuels and lubricating oils and the transfer from ship to shore or barge of sludge and other residual oils.
Simultaneous receipt of different grades of bunkers is prohibited. Only one grade at a time is to be taken. However, this restriction does not apply to lubricating oils.
2. Maximum Tank Filling Volumes
Bunker and Lubricating oil tanks must not be filled to more than the following capacities:
• Fuel Oil Tanks with a capacity of less than 700 m3 total capacity: 85%
• Fuel Oil Tanks with a capacity of more than 700 m3 total capacity: 85%
- (or with the written approval of the Ship Management Team 90%*)
• Lubrication Oil Storage tanks: 95%
The above maximum capacities are the absolute maximum permitted filling capacities. The Company will not tolerate even “small” "overfills" beyond these levels.
*The Ship Management Team in deciding whether to permit a tank of greater than 700m3 capacity to be filled to 90%, must consider if there is a genuine need or clear benefit to filling the tank as such, and that the need or benefit cannot be effectively realized in some other way.
3. Regulatory Requirements
At all time during bunkering operations the ship is to ensure compliance with all regulatory requirements. All entries and records made bust be in accordance with MARPOL, with this system and with any other relevant regulatory regimes.
Any paperwork completed, whether provided by the ship, the Company or the Barge or Fuel Supplier should be copied and retained onboard for at least 36 months.
The Oil Record Book is to be completed correctly for each bunkering operation. All entries are to be in accordance with MARPOL and with any other specific flag state requirements. The Oil Record Book must be presented to the Master for signature regularly, at most no less frequently than once a week.
Bunker Delivery Notes are required to be retained onboard for at least 36 months. There must be one Bunker Delivery Note for each distinct delivery.
Failure to comply with regulatory requirements can lead to detention of the vessel, prosecution of the owner, Master or Chief Engineer. In some jurisdictions Masters and Chief Engineers may be imprisoned for failures that result in pollution incidents.
4. Personnel
The Chief Engineer is to clearly identify who will be involved in the bunkering operation, what their roles and responsibilities will be and this is to be recorded on the bunkering checklist. Personnel who are less or not familiar with the ship or the company bunkering procedure must be supervised by personnel who are familiar.
Trainees or Cadets must be directly supervised whenever they are given responsibilities during a bunkering operation.
5. Bunkering Plan
Prior to every bunkering operation, the Chief Engineer is to ensure that a bunkering plan has been prepared and communicated to all personnel involved in the bunkering operation. The Company has included a bunker plan in the bunkering checklist and this should be used.
The Bunker plan must show, as a minimum:
• Which tanks will be bunkered
• The sequence in which tanks will be filled
• The volume of bunkers in each tank prior to bunkering
• The maximum permitted volume in each tank
• The quantity and grade that will be bunkered in each tank
• The initial and maximum filling rates for each tank
In addition to being discussed, the bunker plan is to be posted at the Bunker Station, in the Control Room and anywhere else the Chief Engineer deems necessary.
The bunker plan must also be communicated to the bunker barge.
6. Bunkering Operations Checklist
The Company has provided a checklist for bunkering, Form M37 Bunkering Operations Checklist. This form is to be used for every bunkering operation and must be completed fully every time. The form is to be completed in paper format.
Any requirement contained in that form that is not listed here is to be considered part of this bunkering procedure.
Completed M37 Bunkering Operations Checklists are to be retained onboard for at least 36 months in a dedicated file.
7. General Notes on Delivery and Sampling
• Take temperature and soundings of all bunker tanks on board the barge, truck or shore facility and your vessel, before and after the bunkering. These calculations must be retained with the bunker delivery note.
• Bunker suppliers should be invited to witness the samples being taken during the bunkering operation and must be asked to sign the sealed samples and a statement that he has witnessed the sampling. Should they decline to comply with this procedure their refusal must be remarked on the delivery note and log book, and the Ship Management Team must be informed.
• Fully representative samples should be taken during the bunkering at every bunkering operation. The sampling technique and dispatch to the nominated laboratory are to be carried out in accordance with the instructions of the laboratory and the Ship Management Team.
• At set of ship samples jointly witnessed by the supplier is to be retained on board, in a safe place outside the accommodation (such as the protected paint locker) pending the receipt of the analysis. If the analysis is satisfactory, or at least 6 months have passed, the sample can be discarded.
• A MARPOL Annex VI sample jointly witnessed by the supplier must be obtained from the supplier and is to be retained on board , in a safe place outside the accommodation (such as the protected paint locker) until at least 36 months from the date of bunkering and later if the bunkers have not been consumed. The sample should be numbered and the number correlated with the bunker delivery note in the MARPOL Annex VI file. As for Bunker Delivery Notes one sample must be taken and retained for each delivery. For example a delivery from two barges forming a single stem requires two samples.
• Wherever possible do not mix HFO and/or MDO from different suppliers and/or different bunkering operations.
• Stamp the Bunker delivery receipt for volume and temperature only, and on behalf of charterers only as far as possible. If such stamp not accepted, Letter of protest to be issued and protest logged in Engine room log.
• As far as possible, do not use the received bunkers until a result of the analysis has been received.
• If the bunkers need to be surveyed, the Company will arrange for a bunker surveyor. The firm supplying the surveyor are also required to supply the equipment necessary to carry out the survey. Please establish very clearly who the surveyor is working for.
• The surveyor must take three samples of the bunkers being taken on board. The Chief Engineer is to oversee the sampling. Two seal samples are to be kept on board and the surveyor is to take one sample for testing. The surveyor may be responsible to check the quantities being bunkered also. Bunkers samples must be identified by the following:
o Date and ship.
o Specific Gravity and amount of bunkers taken on board.
o Port / barge / supplier from which the bunkers were taken on board.
o Sample number and signatures of supplier.
o It must be noted that heavy contaminants such as catalytic fines will settle quickly to the bottom of the tank. If such contaminants are suspected this must be brought to the surveyor’s attention as samples taken subsequent at bunkering may not be representative.
The SOPEP describes response actions should a bunker overflow or pollution occur. The emergency contingency plan described in the SOPEP (or OPA 90 Vessel Response Plan as applicable) is to be followed if any oil escapes into the water or if there is a substantial threat of same.
The ship has equipment and materials for the containment and clean-up of spills on deck. Use absorbent materials to soak up spilled oil, and a dispersing agent to remove the final traces of oil from the deck. Clean up response is to be in accordance with the contingency plans and procedures in the vessels SOPEP. Oil dispersant is not to be used in the water unless approved by the relevant authorities.
If for any reason materials are used from the SOPEP locker the Ship Management Team must be informed.
Following a circular from a P & I Club, and in view of the recent difficulties experienced in connection with inferior quality bunkers provided by suppliers and/or charterers, information and instructions provided herewith are to be followed in order to safeguard owner's rights.
Sub-Standard Bunkers may result in:
• Poor performances and stoppages at sea.
• Increase of bunker consumption.
• Damage to vessel's machinery.
• Obligatory deviation.
• Cargo damage.
• Necessity of tug assistance.
• Vessels being considered unseaworthy.
The company uses a recognized laboratory for fuel quality testing. The service provides the Company and vessel with information on critical fuel quality parameters. Together with the analysis results, practical and specific recommendations/advice will be given on fuel. The fuel analysis results may also be used as evidence should engine damage occur due to the supply of poor quality fuel.
For medium speed engines the CCAI (Calculated Carbon Aromaticity Index) must be noted as this is a measure of ignition quality. Excessive ignition delay will cause damage to the engine. If the CCAI is above 850 by analysis then the Ship Management Team are to be contacted. The Chief Engineer is to pay particular attention to the advice and recommendations given in the report for fuel handling, purification and viscosity value.
The Chief Engineer (who is responsible for the proper sampling, sealing, labelling) should order the initial "Fuel Test Kit". This kit contains, sampling bottles, labels for sampling bottles and address labels, seals, forms, list of nominated air-courier agents, a folder containing all the necessary guidelines for: sampling, packing, transportation, form "Request to Witness Sampling", "Sample Taking and Forwarding Check List".
It is of utmost importance that the lab instructions are carefully studied and followed in order to benefit most from this service. The speed at which results are obtained depends on fast and reliable transportation, this again relies on the correct handling on board and the vessel's agent in port and by insisting and verifying with the ship's agent that he (the agent) arranges for an immediate pick-up of the samples by the nominated air couriers. Labs have contracts with these air-couriers for priority handling at fixed prices.
Where bunker tanks are fitted with high and low suctions, it is essential that the low suctions are always used, except in an emergency. Such an emergency situation would be when water had settled out in an appreciable quantity at the bottom of the tank. In this case the high suction valve is to be opened, and the low suction valve shut, until such time as the water has been drained off via the tank sludge cocks.
When bunkers are transferred from storage to settling tanks, soundings are to be regularly taken to verify the remote reading gauges and avoid the effects of any inaccuracy in the gauge readings.
Prior to Dry-docking the Ship Management Team is to be consulted to determine bunkers that are to ROB and their location on reaching the docking Port.
When it is necessary to heat bunker tanks to assist with transfer of fuel from bunker storage tank to handling tanks The Chief Engineer is to closely monitor the tanks to ensure overheating does not occur. The Chief Engineer is to ensure all fuel tank sounding and air pipes which pass through cargo spaces or ballast tanks are examined at least once every six months.
It is essential that all fuel tanks are regularly "de-sludged" using the sludge cocks provided. The Engineer Officer on duty must ensure that cocks are operated manually and he is in attendance at all times the cocks are open. They must never be operated by artificial means. The presence of water in excess of normal must be immediately brought to the attention of the Chief Engineer. The Duty Engineer is to ensure a close watch is maintained on the operation of the HFO Purifier(s) to ensure there is neither excessive water carry over or sludge discharge any signs of operation outside the normal is to be brought to the attention of the Chief Engineer.
The de-sludging is to be carried out at least once per watch on a watch keeping vessel. Prior to entering a bad weather area and whilst in heavy weather conditions, the frequency of draining must be increased. Tanks are to be de-sludged during preparation for departure and arrival into Port in good time prior to standby.
On vessels operating for periods of time with unmanned engine room spaces, the interval between de-sludging during the manned period is to be four hours. For the unmanned period, this is to be detailed by the Chief Engineer in the Night Order Book, but a minimum of 3 times during the unmanned period is required, at commencement of unmanned period, during the evening inspection of the Engine Room spaces, and at the end of the unmanned period.
The Settling and Service Tanks are on a rotational basis is to be emptied at intervals not exceeding 12 months where possible, for the purpose of sighting the internal condition, in particular any buildup of sludge, solids and other contaminants. Manual cleaning is to be done if applicable, during a safe period at a safe location.
It is strictly forbidden to enter a fuel tank unless the appropriate "enclosed space entry permit" conditions have been complied with and the permit issued. Planning for the cleaning will be an agenda item of the Ship Management meeting prior to the planned time of the inspection / cleaning operation. The opportunity must be taken to ensure close up inspection and testing of heating coils as well as all tank fittings including vent pipes and gauges.
Ships without an approved and effective exhaust gas scrubber operating within an Emission Control Area (ECA), the sulphur content of fuel oil used should not exceed 0.10% by mass (10 ppm). All main and auxiliary engines and boilers are affected by the Regulation, meaning that vessels using heavy fuel oil must have completed the change-over process and operate on ultra-low sulphur fuel upon entering an ECA.
Changeover from one fuel type to another is a critical operation that carries risk. It must be carried out in good time, and in a safe, effective way.
A written risk assessment is always required for fuel changeover.
Timing
It is important that the vessel has fully completed the fuel changeover operation before entering the relevant emissions control area. This means that all of the fuel in use, in engines and machinery, and in all piping leading from the tank to that machinery must be the correct grade and type before entry.
This requires careful calculation. To ensure the fuel changeover happens in good time, the ship must know:
- the amount of fuel in the engine(s) and other fuel burning machinery at any given time
- the amount of fuel in service piping at any given time
- the amount of fuel burned by the engine(s) and machinery per hour
The company will provide ships entering an ECA with a suitable calculator.
The Master is responsible for ensuring that the Chief Engineer is informed if the vessel will enter an emissions control area on the voyage and as the vessel approaches the area, the Chief Engineer is to be given suitable notice - 96, 48 and 24 hours before entering the area.
Summary of Relevant Sulphur Limits & Areas
Outside an Emissions Control Area: 0.5%
Inside an Emissions Control Area: 0.1%
Refer to MARPOL Annex IV for details of areas.
Fuel Changeover Requirements - Entering an ECA
For ships which are not fitted with dedicated low sulphur fuel oil settling and service tanks:
- Changeover preparation should commence min. 72 hours before entering the ECA
- The ship must consume all fuel oil in the settling tank (residue drain to overflow tank)
- Settling tank to be filled with low sulphur fuel
- Fuel in the service tank to be consumed (to minimum safe amount)
Once above steps are complete, the vessel will commence consuming low sulphur fuel. This must happen no later than 48 hours before entering the ECA to allow sufficient flushing time.
For ships which are fitted with dedicated low sulphur fuel oil settling and service tanks:
- Changeover must commence no less than 48 hours before entering the ECA
- Ship to confirm the LS fuel oil tanks are in fact filled with LS fuel
This will ensure sufficient time for full changeover.
The fuel oil filter differential pressure must be monitored at all times during the changeover.
Fuel Changeover Requirements - Leaving an ECA
Changeover to fuel of a higher sulphur content than permitted in an ECA must only commence after the ship has left the area in question.
Records
Correct records of every stage of the fuel changeover operation (both leaving and entering an ECA) must be made in the engine room logbook and the Fuel Oil Sulphur Record Book.