Fuelling regulation

What happens when technology beats regulation? LNG is a prime candidate to answer this question. Vessels have been built, according to strict requirements, but what about the rules and regulations that govern these developments? How do they come into play? DNV, the Holland Shipbuilding Association and Deen Shipping provide us their views on solutions that have been found and perhaps will be found in the future.

The emission regulations that will come into play in 2015 and 2016 mean companies are looking into options to meet the required standards. One of the options could be LNG, liquefied natural gas. LNG is not unknown in the sea shipping industry. Many vessels that travel the seas and oceans transport the natural gas and some even use the boil-off, residue of gas from a slightly warmed cryogen tank, as fuel. The IMO, the International Maritime Organisation, is currently working on an IGF code, the International Code of Safety for ships using gas or other low flash-point fuels. David Anink, sector manager at the Holland Shipbuilding Association, works within the IMO workgroup that is concentrating on establishing the IGF Code. “There is no set standard yet for LNG in the sea shipping industry”, he states. “The IGF code will bring a sense of normalcy for ship owners and shipyards. Though, this does not mean we don’t know enough about LNG. And, unlike the inland shipping industry, gas fuel is not forbidden. This of course has to do with surroundings. Establishing the code is a process in which a lot of experience is taken into account, without forgetting the risk assessments that are being generated.”

Concessions need to be done

Building a code requires experience, something Norway has. This country has a solid decade of experience with LNG. As such, they are the logical go-to people when building the IGF code. Anink: “The fundamental structure of code and regulation can be derived from what Norway has been doing, of course technology has moved on, but this will always be the case. Concessions will have to be done in the code, so to realise this part of technology – you have to change the existing code. How will you make innovation possible otherwise?”

Pure LNG and dual-fuel

As pointed out by Anink, to this day it is forbidden within the inland shipping industry to use natural gas as a fuel. To be able to allow vessels to sail, such as Deen Shipping’s inland vessel Argonon, the vessels had to be exempted from the initial rules and regulations.

We have the technology,
but the regulations take
years to form

Bert de Vries of the Holland Shipbuilding Association comments: “The reason why the vessels have to be exempted is because there is no regulation on natural gas for the inland shipping industry. This means a ship owner, such as Deen Shipping, has to prove his ship is equally safe to a ‘normal’ inland shipping vessel. This also means governmental bodies have to be involved very early on in the process. How did the Argonon fare? It, along with three other vessels, has been exempted from these regulations. The other vessels are two GreenStream Tankers by Peters Shipyards for Interstream Barging and the Eco-Liner built by Damen-owned Bodewes. Though there are considerable design differences between all the vessels, the safety can be guaranteed on all vessels, which is why they have been exempted. The Argonon works with a 81% to 19% ratio of LNG and diesel. The other vessels will be pure LNG vessels. LNG is considerably cleaner.”

Dutch pioneers

In regards to emission, the inland shipping industry does well: CO2 has been reduced and so has the SOx emission, all that remains now are the NOx emission and particulate matter. A consideration for reduction must also be made when choosing dual-fuel or pure LNG. De Vries continues: “The rules and regulations for the inland shipping industry are governed by the CCNR, the Central Commission for the Navigation of the Rhine in Strasburg. The related member states are Switzerland, France, Germany, the Netherlands and Belgium. This group decides what happens within regulations for inland shipping and must do so unanimously. Naturally, the Dutch government needs to give its approval and I think they have been very enthusiastic about the LNG development. Also, the LNG developments were a surprise for the CCNR, they were really taken aback by the request from the Netherlands about what to do. Now, we would all like to get going, but no one is sure what the rules are. So, when you think about it, the Dutch are pioneers! We have the technology, but unfortunately, these kinds of regulations take years and years to form. The changing emission regulations will help the industry to get the regulation on track, but I believe it will take many, many years yet before we see anything firm happening. You also have to consider that the inland shipping industry has a different renewing strategy. Where trucks can renew their engine every five years, inland shipping has to rely on their innovation to last at least 20 years, if not longer. This requires different strategies.”

Regulation and code

Gerard Deen, owner of Deen Shipping and the Argonon, comments: “There is no regulation for the inland shipping industry regarding natural gas. You can find more for the sea shipping industry. As such, we used this as our basis. The CCNR wanted us to prove the Argonon is just as safe as any other vessel on a more ‘typical’ fuel. Based on our experiences and that of other vessels, the CCNR will use this information to conduct a code which will hopefully be available by 2017. Our experience in the field will be very valuable. Though many people have the technical know-how, we actually know how it works on a day-to-day basis.” Building vessels can be done and is being done, when you move to the subject of bunkering, it comes with its own set of issues. Matthé Bakker, head of solutions Netherlands at DNV, states: “Let us take the break-bulk terminal on the Maasvlakte, Rotterdam, the Netherlands as an example. On the one hand you have well developed landbased regulation and guidelines for this type of bunkering facility, but you also have to consider the fact that vessels dock from the sea and that port side and/or ship side regulations can be entirely different, let alone that regulations are governed by different authorities.” Regarding regulation, Bakker states that although there are few rules and regulations on LNG as fuel and bunkering of LNG specifically, we already know a lot about working in dangerous substances, something LNG is part of and a variety of standards and guidelines exist for LNG in general. Bakker: “The interface between land and water makes LNG bunkering a challenge, in which port authorities, land based authorities and ship authorities all have a – final – say, and which have to be aligned with national governments, international law and eventually IMO. The IGF code will offer interim guidelines for gas-fuelled ships, which will eventually become more and more permanent. It will help companies realise their LNG projects. An ISO LNG bunkering standard is expected shortly and also Dutch initiatives like the development of PGS 33 will add more clarity in the near future. The current absence of specific rules and regulations means initiating a LNG as fuel project might pose a bit of a challenge but it is still very feasible” 

Bunkering possibilities

Deen: “LNG is available in large quantities in the Netherlands, we only require a small amount for the Argonon. As such our LNG comes from Zeebrugge, Belgium, by lorry. Together with the Port of Rotterdam we have been offered a quay where we can do our bunkering. This works for now and as it is ‘only’ us. The future will see the delivery of more LNG vessels and we need to anticipate what will happen when you have to wait in line to bunker. We are currently working on our own bunker station together with the Linde Group in Rotterdam, where we and other vessels can bunker. Next to that we purchased a large quantity of LNG, so come 2015 we will be the first customer of our own bunker station. That is really exiting. Not only Rotterdam is working on bunkering, Hamburg, Germany and Antwerp, Belgium are also hard at work. In fact, early December we also bunkered in Antwerp following the same principle we use in Rotterdam.”

Developments will
need to continue to
make LNG a success

Best practices

Bunkering is a hot topic and the CCNR will organise a trip on the Rhine together with a delegation to pinpoint locations that would be ideal for bunkering. Though, as a nation, it is important to work hard at being the first to achieve a bunker infrastructure. Our way of bunkering is evaluated every year and again, the best practice will be used for the regulation code. Not only regulations are a time consuming feat, safety remains a bump in the road. Not because of the substance, but more related to public perception. De Vries: “Safety is not an issue with LNG, I mean you must always remain safe, but the fuel itself is really quite safe. We don’t shy away from LPG or turning the gas on in our houses, so why fear LNG? LNG can be bunkered of a truck, another vessel or a bunker station along the route. People fear what will happen in a head on collision. I can tell you, nothing! Just as in a car accident. How many bunker stations will be necessary? Not many, if you count that a vessel can travel from Rotterdam to Basel and back, not many at all. Perhaps one or two in the Netherlands and a couple more abroad. Bunker stations will also be relative to the amount of LNG vessels that require bunkering. For now, bunkering will be done, such as on the Argonon, by lorry.”

Make LNG a success

Now, it must be noted that these LNG developments mostly reach to new build vessels. Refits are a whole new ball park. Will vessels be able to convert to LNG or will this be too costly? And what does this mean for the collective development of LNG? All parties agree that developments will need to continue to make LNG a success. For now, all we know is that the future will see LNG becoming part of our lives. The question is: according to which code or regulation?

Rebecca McFedries