Transportation of Ethanol and Vegetable Oils Understanding the revisions to MARPOL Annex II and the IBC Code

November 1, 2007

BG LNG Services LLC

24th October 2006
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AGENDA

INTRODUCTION SUBSTANCES RECLASSIFICATION TRANSPORTATION OF ETHANOL TRANSPORTATION OF VEGETABLE OILS PROCEDURES & ARRANGEMENTS MANUAL

Introduction

MARPOL Annex II & IBC Code Revision

Assignment of hazard profile to each substance Vessels affected - oil products tankers, chemical carriers and other tankers carrying noxious liquid substances Date of entering in force 1 January 2007 Impact of reclassification of certain substances Handling of residues (stripping and discharge requirements) Procedures and Arrangements Manual

Substances Reclassification

Five-tier system changed to four-tier system Each substance in IBC Chapters 17 and 18 has been recategorized. Evaluation includes aspects such as bioaccumulation, acute toxicity, chronic toxicity, biodegradation, long-term human health effects and possible effect on marine wildlife/habitats. Procedures to categorize substances not listed in Chapters 17 or 18 and/or in MEPC 2/Circulars were defined. Biofuels are currenty under consideration by IMO

Substances Reclassification

Transportation of Ethanol (Ethyl Alcohol)

Listed in Charter 18 of IBC Code 2007 Edition as Category Z, therefore IBC Code requirements do not apply.

Can be carried under a Noxious Liquid Substance (NLS) Certificate. NLS requirements of MARPOL Annex II indicate lower limits of residue within the tanks and has revised limitations on the discharge of such residues

Ethanol classification IBC Code

Ethanol Transportation Requirements

Oil Carrier requirements plus NLS requirements of MARPOL Annex II for Category Z:

Tank Stripping Requirements empty to the maximum extent for existing vessels, 75 liters for vessel constructed or converted after 1 January 2007 Underwater Discharge (not mandatory for vessels built before 1 January 2007) Procedures and Arrangements Manual

Ethanol Transportation - ABS Requirements

Applicable Rules:

Steel Vessels requirements of Oil Carrier (Part 5C Chapters 1 or 2 of the Rules) + MARPOL Annex II (Category Z) + Administration Steel Vesels under 90 m requirements of Oil Carrier (Part 5) + Resolution A.673(16) + Administration

Steel Barges requirements of Oil Tank Barge (5-2-3 of the Steel Barges Rules) + MARPOL Annex II (Category Z) + Administration

Carriage of Ethanol - Operational Concerns

No Rule or mandatory requirements for specific painting scheme Operators indicating that pure epoxy is not recommended. Suitable coatings would be Isocyanate Epoxy, Novalac Expoxy and Phenolic Epoxy Piping systems materials and components should be suitable for Ethanol Foam concentrate of the fixed deck foam system shall be compatible with Ethanol Tankers of 20K DWT and above require IGS. The acidity of Ethanol is affected during transportation by the presence of the CO2 from the inert gas generator
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Transportation of Vegetable Oils

Now classified under IBC Code and requires a double hull tanker for carriage. Certain vegetable oils can be carried in Type 2 ships and others can be carried in Type 3. Vegetable oil carried in deep tanks in existing dry cargo ships has been legislated separately in MEPC 48 (54) (tanks are to be no closer than 760 mm from the shell plating).

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Ship Type Arrangements

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Ship Type Arrangements

Ship Type
B/5 or 11.5 m (the lesser) 760 mm

CL

CL

CL

SWL

B/15 or 6 m, the lesser but 760 mm

Type 1

Type 2 Max. Amount of Cargo per Tank

Type 3

1,250 m3

3000 m3

No Limit

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Transportation of Vegetable Oils (cont.)

MARPOL Annex II permits an exemption of the Administration for vegetable oils identified with footnote k in Chapter 17 of IBC Code. Exemption allows the carriage of such oils in NLS tanker meeting the requirements for ships Type 3 (instead of 2), except for cargo tank location.

Wing tanks or spaces shall be arranged such that cargo tanks are located inboard of the moulded line of side shell plating nowhere less than 760 mm. Double bottom tanks or spaces shall be arranged such that the distance between the bottom of cargo tanks and moulded line of bottom plating measured at right angles to the bottom shell plating is not less than B/15 (m) or 2.0 m at centerline, whichever is the lesser. Minimum distance shall be 1.0 m

The relevant certificate shall indicate exemption granted.

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Tank stripping limits

Requirement A Major Hazard Current MARPOL Annex II C Minor Hazard D Recognizable Hazard Revised MARPOL Annex II (1/1/2007) X Major Hazard

Pollution Category

B Hazard

Y Hazard

Z Minor Hazard

Maximum Residue After Stripping

Ship Details IBC/BCH 300 +50* liters# Not Applicable 100 +50* liters# 900 +50* liters# 300 +50* liters# 900 +50* liters# 300 +50* liters# Other If Z and in IBC Ch.18, empty to maximum extent. If OS and in IBC Ch.18, not applicable

X [1] < 1/7/86 (BCH Ships)

No minimum

300 +50* liters#

300 +50* liters#

1/7/86 X [1] < 1/1/2007 (IBC Ships)

No minimum

100 +50* liters#

100 +50* liters#

X [1] 1/1/2007 (IBC Ships)

Not Applicable

75 liters#

75 liters#

75 liters#

75 liters#

* performance test tolerance

# performance

test required

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Stripping performance test

Clean the tank and piping prior to testing ensure the ship trim (max. 3 deg. by the stern) and heel (max 1 deg.) give favorable drainage to the suction point in the tank fill the tank with water to the depth representing the normal end of unloading condition i.e. the point at which stripping is usually commenced. provide 100kPa (1 atmosphere) back pressure (usually a constant pressure valve) at the unloading manifold see figure

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Back-pressure arrangements

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Stripping performance

discharge and strip the tank according to the designated procedure the time taken for the stripping procedure is to be recorded close the manifold valve and open all valves and remove drain plugs the residue is then collected and measured the stripping performance details are to be entered in the P&A manual (including time taken)

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Discharge
Discharge Pollution Category A Major Hazard Any residue to reception facility, except 0.1% by weight or below. Current MARPOL Annex II B Hazard 1 ppm C Minor Hazard 10 ppm D Recognizable Hazard 1 part NLS to 10 parts water. Revised MARPOL Annex II (1/1/2007) X Major Hazard Any residue to reception facility, except 0.1% by weight or below. Y Hazard Any residue to sea

Z Minor Hazard
Any residue to sea

Concentration

En route Piping Outlet Location Underwater

7 Knots Not Applicable

7 Knots Underwater (not mandatory for ships with X [1] <1/1/2007 carrying Cat. Z)

Nearest land

12 nautical miles and water depth > 25m

12 nautical miles and water depth > 25m

X [1] - keel laying date or commencement date of conversion to a chemical carrier.

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List of Reclassified Vegetable Oils

Comparison of pollution categories and ship types of some vegetable oils before and after 1 January 2007 revision

Vegetable Oils

Pollution Category Before Revised D D D D D D D D D D D Y Y Y Y Y Y Y Y Y Y Y

Ship Type Before Revised Ch. 18 Ch. 18 Ch. 18 Ch. 18 Ch. 18 Ch. 18 Ch. 18 Ch. 18 Ch. 18 Ch. 18 Ch. 18 2(k) 2(k) 2(k) 2(k) 2(k) 2(k) 2(k) 2(k) 2(k) 2(k) 2(k)

Coconut Oil Corn Oil Cottonseed Oil Groundnut Oil Olive Oil Palm Kernel Oil Palm Oil Rapeseed Oil Safflower Oil Soyabean Oil Sunflowerseed Oil

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Procedures and Arrangements Manual

Every ship certified to carry substances of category X, Y or Z shall have on board a Manual approved by the Administration The main purpose of the Manual is to make operational procedures and physical arrangements available to the ships officers It is necessary to review the current Manual against the revised MARPOL Annex II to determine those sections that will require amendment, in particular with respect to the stripping requirements by the corresponding Administration To assist Owners in compiling the P&A Manual, a template is available at ABS website

www.eagle.org/regulatory

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Thank you for your attention !

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