Webinar: Standard Club Alternative Fuel Advisory Panel

Q&A

Do we have training/courses for handling alternative fuels?

The IMO adopted the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code) in 2015 and added related aspects to STCW convention.

As such, seafarers assigned on ships subject to the provisions of IGF code have to comply with Regulation V/3 of the STCW Convention, ‘Mandatory minimum requirements for the training and qualifications of masters, ratings and other personnel on ships subject to the IGF Code.’ For more details on the training aspect, please refer to ICS guidance and MPA circular.

The Fuel Quality Standards for the alternate fuels are not yet fully developed at par for conventional fuels. What would be P&I implications of any unsuitable alternate fuel being supplied to the ships?

Subject to the usual policy terms, P&I cover should respond in the usual way to liabilities and claims regarding alternative fuel as it would for ‘traditional’ bunkers.

MEPC 77 was supposed to discuss renewed guidelines for Interim Compliance Indications for Exhaust Gas Cleaning Systems. Can you throw light on it too?

The seventy-seventh session of the Marine Environment Protection Committee (MEPC-77) was held remotely from 22 to 26 November 2021.

MEPC-77 adopted resolution MEPC.340(77), the 2021 Guidelines for Exhaust Gas Cleaning Systems (EGCS), which will supersede the 2015 Guidelines. The updated Guidelines clarify a number of parameters to provide consistent terminology and enhance the uniform application of these EGCS standards, taking experience gathered from operation of such systems into consideration. It was agreed that the revised guidelines should be applied to ships which are keel-laid six months after adoption of the guideline. Furthermore, MEPC-77 approved MEPC.1/Circ.883/Rev.1 on Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument and agreed that only the flag and port state’s administration should be notified in such cases of failure.

Should alternative fuels be considered life cycle assessment (LCA)? Is there a reliable indicator of well-to-tank (WtT) at this time?

This was also discussed during the recent MEPC-77 meeting. MEPC-77 considered outcome of the 9th Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG 9), which made some progress on life cycle assessment (LCA) guidelines to assess the overall climate impact of marine fuels.

It is a complex issue and there are challenges particularly in the upstream side, i.e., well to tank (WTT) as IMO cannot have an oversight of global fuel production processes. Some prefer IMO to focus only on the ‘tank-to-wake’ (TtW) GHG emissions as that is the only part shipping/IMO can actively regulate and control. Others prefer a well-to-wake (WtW) approach taking full lifecycle GHG emissions into account. MEPC 77 invited further discussions and encouraged expert advice to further inform the development of LCA guidelines during subsequent working group discussions.

Traditionally liability conventions look at oil pollution impact. Alternate fuels like hydrogen may not cause pollution liability but may have far reaching safety consequences. Would current LLMC be applicable for incidences involving alternate fuels?

There appears to be a current gap in the framework of liability conventions when dealing with non-bunker fuels.  Any questions in this area will start, and potentially turn, on the type of alternative fuel being used – for example, a biofuel may fall within the definition of “oil” for the Bunker Convention – but as a general comment it appears there is no current limitation convention that deals specifically with a spill of an alternative fuel.  This will require considerable international cooperation to fix, ahead of which owners may see a mushrooming of national and / or regional regulations.

Are there wording / contract templates available for future charter contracts with regard to EEXI and CII?

Yes. BIMCO has recently published its EEXI Transition Clause 2021.  It deals solely with the transition phase and only then to modifications to Engine Power Limitation (EPL) or Shaft Power Limitation (SHAPOLI) while under time charter. 

BIMCO is also due to publish its CII Transition Clause too, though this may take longer as it deals with more complex issues such as data sharing, CII ratings and potentially maintenance obligations.

Another source of carbon clauses is the Chancery Lane Project. This is a not-for-profit organisation where lawyers can collaborate to draft industry appropriate clauses. They have recently drafted a number of ‘climate clauses’ dealing with (i) maximising energy efficiency, (ii) incentivising fuel efficiency, (iii) fuel reporting.

For reducing CO2 footprints to last the lifetime of ship, what ratio of fossil LNG and Bio Mix would be needed?

The approx. CI range of various NG solutions are as below:

LNG 70-74 gCO2 eq/Mj

Bio LNG -300 to 19 gCO2 eq/MJ

E-LNG 0-5 gCO2eq/MJ

For each vessel, the CII needs to be calculated and would be different depending upon factors such as, its cargo, route and fuel consumption. Thereafter, we need to find out how much substitution of BIO LNG /ELNG is needed to bring down its CII rating. There is no single thumb rule we can apply for all vessels.

Is there a global overview of the delivery options for the various fuels (LNG, ammonia, methanol, biofuels, etc.)?

This is available from various sources, DNV’s Alternate Fuel Insight is one of the good free sources for such information.

With regard to using the dual fuel (ie usual bunker and the LNG) it is assumed that those vessels are becoming “small” LNG carrier. Considering the cause of damages in insurance claims mainly related with the crew failure, what do you think about the “crew familiarization” especially for the “engine crew”?

Crew competency, training, and familiarization is one of the most important aspects for dual fuel operations. The training requirements are usually specified by the flag state rules. National and international rules provide good guidance on this. The training includes vendor training at shipyard, simulator training, and also classroom training. There is also a requirement on the number of LNG bunkering operations carried out under supervision or training, before a crew member is allowed to carry out independent operations.

One example is the TR56 Part IV, which is connected to LNG bunkering in Singapore.

What other dual or tri engine fuel combinations are under development?

There is a lot of research conducted on IC engines running on alternative fuels like ethane, LPG, ammonia, methanol etc. In addition, new technologies like Fuel Cell are also being considered, a number of them are agnostic towards the fuel used and are able to run on LNG, ammonia or hydrogen.

Why do we discuss de-carbonization and not de-fossilization instead, so that biofuels will enter the track of discussions? Biofuels are readily available, the bio-blends with VLSFO or MGO dramatically reduce CO2 emissions. When carbon is produced it is degenerated and will not add value to green gas effect..

One of the many ways to comply with the IMO’s strategy on the reduction of greenhouse gas (GHG) emissions from ships is to use biofuels or biofuel blends. Biofuels are derived from biologically renewable resources such as plant-based sugars, etc. Commonly used biofuels are hydrotreated vegetable oil (HVO) and fatty acid methyl ester (FAME). The sixth edition of ISO 8217:2017 standards introduced DF (Distillate FAME) grades, but these allow up to 7% fatty acid methyl ester(s) content by volume.

The International Council on Combustion Engines (CIMAC) published guidelines for managing marine distillate fuels containing up to 7% FAME. This was shared in the club’s previous article 'Use of IMO 2020 Compliant Fuels'.

The main issue with biofuels (containing high percentage of FAME) is its propensity to undergo degradation. Due to potential oxidation and sedimentation issues, prolonged storage of this fuel in tanks should be avoided. Furthermore, FAME is hygroscopic, and tanks containing fuel blended with FAME should have efficient drainage systems to regularly drain water from the bottom of the tank.

Members also need to account for a handful of technical challenges such as oxidation stability, cold flow properties, risk of microbial growth, clogging of filters, and increased engine deposits. Such fuels should be analysed to check the total acid number (TAN) and oxidation stability. This should also include checks to determine if there is a presence of microbial contamination.

It is recommended to consult with the manufacturers of engines, boilers, and other auxiliary equipment such as oily water separators, filters etc. in order to ensure their ability to handle these kinds of fuels. Their guidance will be very crucial to ascertain whether engines and other machineries are designed to run with high content of biofuel. Also, for certain types of engines, ship managers may need to choose a different lube oil.

If the various alternative fuels are embraced by the industry, it seems that there will be a variety of options available. How do you foresee this developing, will there be a market for all these fuels?

As mentioned during the webinar, most of the alternative fuels and technologies are still undergoing technical, economic, and environmental review. There is no one-size-fits-all solution, and a lot of considerations will go into selecting appropriate option based on ship type/age, trading area, retrofitting costs, operating budget, fuel price/availability, infrastructure development, safety issues, etc.

LNG, LPG, biofuel, methanol, ammonia, and hydrogen, as well as the usage of fuel cells and batteries, are some of the main options. Each has its own set of advantages and disadvantages and switching between them is not easy - engines and other machinery will need to be capable of burning the fuel in question.

There are numerous other considerations in relation to the various fuel options. For example, biofuel brings a handful of technical challenges such as oxidation stability, cold flow properties, risk of microbial growth, clogging of filters, and increased engine deposits; and hence, it requires careful handling. Handling of other alternative fuel options on vessels could be complex as well and will require a highly trained crew.

Most of the gases in liquid form requires storage at cryogenic temperature - specific safety standards will need to be satisfied. Hydrogen, for example, has a wide flammability range, while ammonia is highly toxic. Stringent measures will be required to protect crew from exposure.

Hydrogen is a clean fuel; however, manufacturing hydrogen fuel is energy-intensive and has carbon by-products. What is now called brown hydrogen is created through coal gasification. The process for producing grey hydrogen from natural gas throws off carbon waste. Blue hydrogen uses carbon capture and storage for the greenhouse gases produced in the creation of grey hydrogen. Green hydrogen production – the ultimate clean hydrogen resource – uses renewable energy to create hydrogen fuel, which could be quite expensive.

Similarly, green ammonia will cost two to four times as much to make as conventional ammonia. The green and blue ammonia value chains differ in the hydrogen production method used; green ammonia being generated from water electrolysis and blue ammonia being generated from a conventional pathway, using natural gas, but with the addition of carbon capture. In terms of storage capacity, energy density/calorific value of the fuel is critical. More storage space on the ship will be required if a fuel does not have an energy density that is at least comparable to what it has now. Hydrogen, ammonia, and methanol, for example, have a lower density, requiring larger tanks onboard ships.

Lastly, for a fuel to become widely used, it must have adequate scalability, i.e., both the infrastructure and the demand must be there. This may be easier for ships on regular liner route, but ships traveling between ports will have a difficult time finding the relatively scarce option.

Please could you share a copy of the presentation?

A copy of Capt. Akshat Arora's presentation is available to download via the link at the bottom of the page.