LNG Bunkering Guide – What It Is and How to Use It

The maritime industry, facing increasing pressure to reduce its environmental footprint, is actively exploring cleaner fuel alternatives. Among these, Liquefied Natural Gas (LNG) has emerged as a promising solution, offering significant reductions in sulfur oxides, nitrogen oxides, and particulate matter emissions compared to conventional heavy fuel oil. A crucial aspect of this transition is the development and implementation of efficient and safe methods for LNG bunkering a ship. This article will delve into the intricacies of this process, exploring the various techniques, infrastructure requirements, safety considerations, and the overall impact of LNG bunkering on the future of sustainable maritime transport.

LNG as an alternative fuel for Shipping has been increasingly adopted as a strategy for environmental compliance, either sailing or at port. With an immediate significant impact on the reduction of Sulphur Oxides emissions (SOx), Particulate Matter (PM), and also of Nitrogen Oxides (NOx) the motivations for the use of LNG as fuel in maritime transport are today highly favoured by a relevant multi-layered regulatory frame. At international level MARPOL Annex VI defines gradual and tiered approaches to the reduction of both SOx and NOx, respectively through Regulations 14 and 13 (figures 1 and 2, below).

On the Safety page the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), entering into force on the 1st January 2017, establishes the requirements for safe design, construction, and operation, of LNG fuelled vessels. On the EU frame the Sulphur Directive (Dir. 2012/33/EU) and the Directive on the deployment of an Alternative Fuels Infrastructure (Dir. 2014/94/EU) establish the particular European framework for the development of LNG as an alternative fuel for shipping. The Sulphur Directive by including LNG as a possible Emission Abatement Method Reference is made to the provisions in the Sulphur Directive (Directive 2012/33/EU) allowing for the use of different Emission Abatement Methods, as defined by (Article 4, c), subject to the criteria listed in Annex II of the Directive. (In the letter of Article 4, c) Member States shall allow the use of emission abatement methods by ships of all flags in their ports, territorial seas, exclusive economic zones and pollution control zones, as an alternative to using marine fuels that meet the low-sulphur requirements. It remains however to be noted that the criteria specified in the Sulphur Directive relates to the use of a mixture of BOG (Boil Off Gas) with HFO, by LNG carriers, at port, in order to meet the 0,10 % EU sulphur cap in ports. Notwithstanding this LNG is used as an alternative fuel, representing a clear option for ships that, otherwise, would have to either use low-sulphur oil fuels or adopt a different Emission Abatement Method.x, and Directive 2014/94/EU by establishing the clear obligation for EU Member States to make LNG, as an Use of Cargo as Fuel on Gas Tankersalternative fuel for shipping, available at maritime ports Member States to put in place an appropriate number of refuelling points for LNG to enable LNG inland waterway vessels or seagoing ships to circulated throughout the EU TEN-T Core network by 31 December 2025.x by the end of 2025 (for inland waterways ports the target objective is set for the end of 2030).

In the above context the development of LNG as an alternative fuel for shipping has been remarkably fast, with the involvement of ship operators, shipyards, Class Societies, different national competent authorities, including the obvious and fundamental active participation of Port Authorities.

The technological steps given in the design of LNG fuelled vessels and LNG bunkering operations has been fast and keeping every stakeholder at the same pace in the development process is essential for a coherent, consistent and harmonized deployment of a safe LNG. The industry has been paramount in the whole process, adopting a good part of the LNG knowledge. A good part of the responsibility for the consolidation of knowledge and experience transferability from LNG cargo to LNG as a fuel for shipping is to be given to the Society for Gas as a Marine Fuel (SGMF, a new non-governmental organisation (NGO) established to promote safety and industry best practice in the use of gas as a marine fuel.x

LNG for Shipping in a Nutshell

The table below summarizes the main technology aspects of LNG as fuel for shipping, with a brief indication of the main advantages and current challenges for this alternative fuel.

The full potential of LNG as Fuel for Shipping is yet to be explored. Many studies have been carried out to explore the technical and economic feasibility of this fuel and the results have shown promising conclusions leading to the inevitable assumption that further development of LNG ship fuel solutions will be seen in a very near future. Context driven aspects, such as fuel oil prices, are a possible “slowdown factor” for the adoption of LNG, nevertheless it is important to develop the tools and the understanding that LNG as fuel will be a reality which will grow in maritime transport.

In the same inevitable way Ports will have to consider due facilitation of LNG, depending on specific technical (and business) feasibility, Safety, Risks and Security Aspects in Liquefied Natural Gas Industryrisk and safety, amongst other factors. The present guidance is proposed as an additional tool to assist Port Authorities to welcome LNG as fuel in a clear and safe manner.

Background

As mentioned above, LNG is today a technically feasible option as an alternative fuel for shipping. An increasing number of ships have adopted it, with an increasing number of newbuilds at the order book.

The forecasts, despite any context related oil price variations, still present an interesting uptake in all major ship types.

• Fuel engine technology;
• ship design;
• fuel tank containment systems;
• control & detection, amongst other, are some of the different areas where LNG fuelled vessels can differ from each other.

The technological diversity however does, in all cases, introduce an increase in systems’ complexity, and the low flashpoint nature of LNG highlights the Risk & safety concerns with a fuel that is not only physically so different from traditional oil fuels but that also brings additional operational challenges regarding its transport, delivery and use.

On the regulatory context, the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), approved in its final draft version in June 2015, is due to enter in force on the 1st January 2017. It contains mandatory provisions for the arrangement, installation, control and monitoring of machinery, equipment and systems using low-flashpoint fuels, focusing initially on LNG.

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The Code addresses all areas that need special consideration for the usage of low-flashpoint fuels, taking a goal-based approach, with goals and functional requirements specified for each section forming the basis for the design, construction and operation of ships using this type of fuel.

LNG bunkering operations are however characterized by the interaction of multiple stakeholders and different regulatory contexts. This poses a challenge in different levels.

Whereas the IGF Code establish technical and functional requirements for LNG bunkering equipment and operations, its focus is mainly on the receiving vessel, and on its preparation for safe LNG bunkering operations. The bunkering interface is of course required to incorporate these requirements and be in line with them, ensuring consistency with other relevant regulatory instruments such as the ADR Convention or the Seveso Directive. Some functional requirements for bunkering have been included in the draft IGF Code but are mostly related to the receiving vessel, leaving the organization for bunkering, from the port side, outside of scope. Some important concepts are however included in the IGF, particularly in Chapter 18 where the “Person in Charge” (PIC) is defined, together with requirements on Check-lists and Communications, only to mention a few.

Recent Standards & Guidance Development for LNG Bunkering

There are currently different standards and guidance on LNG bunkering, either developed or under development. ISO has issued the Guidelines for systems and installations for supply of LNG as fuel to ships (ISO/TS 18683:2015), early in 2015, and is currently working on the finalization of ISO/DIS 20519 Specification for bunkering of gas fuelled ships. The last document is expected to bring a substantial set of functional requirements for LNG bunkering equipment and operations, including aspects such as bunker connectors, hoses, risk assessment, communications, safety distances, amongst many other aspects.

SGMF, also early in 2015, has launched their SGMF LNG Bunkering Safety Guidelines, as the reflection from contribution of different industry stakeholders, with the objective to provide the LNG bunkering industry with the best practices in order to ensure that LNG fuelled ships are re-fuelled with high levels of safety, integrity and reliability. The LNG Bunkering risk on Liquefied natural gas ships assessment and safety zonesBunkering Safety Guidelines include chapters on LNG Hazards (Leaks, Cryogenic, LNG Fire and Explosion), Safety Systems (Roles, People in Charge, Communications and Emergency Systems), Bunkering Procedures and Specific Safety Guidance for the different LNG bunkering modes.

IACS, the International Association of Classification Societies, has published in June 2016 the IACS Recommendation on LNG bunkering (Rec.142), a document which would later result in an update of the SGMF LNG Bunkering Safety Guidelines, in May 2017, with this later document incorporating both earlier SGMF work and the integral reproduction of Rec. 142.

Finally, the International Association of Ports and Harbours (IAPH) have developed specific LNG bunker checklists (IAPH LNG Bunker Check-Lists) for known LNG bunkering scenarios: ship-to-ship, shore-to-ship and truck-to-ship. These check-lists include specific requirements relevant for all parties involved in the LNG bunkering operations and are already in place in some ports where LNG bunkering operations are already in place.

Collectively, the above standards and guidelines represent the most significant set of references for LNG bunkering operations, today. Together with different national requirements and local/port regulations they are instruments for safe LNG bunkering operations, including provisions on risk & safety, bunkering/transfer equipment, training, bunkering procedures, amongst other aspects. Different bunkering modes are included and all stakeholders involved are featured with proposed good practice for safe operations addressing all parties.

• The receiving LNG-fuelled vessel, the LNG bunker barge/vessel;
• LNG truck;
• Terminal Operators, Person-in-Charge (PIC);
• they all find specific requirements which are relevant either to the equipment used in LNG bunkering operations, or to the procedures established as basis for the operation.

Despite some variations in terminology, all existing guidance mentioned above is consistent with a common 3-phase approach, dividing LNG bunkering, in whichever mode, into:

1. Pre-Bunkering;
2. Bunkering and;
3. Post-Bunkering.

An additional 4th phase can even be considered: the Planning (where feasibility, risk and other studies pertaining permitting and certification are developed).

The missing part, in the opinion of the ESSF and its subgroup of experts on LNG, is the guidance to Port Authorities/Administrations in the specific context of LNG bunkering planning, permitting and operations. Check-Lists and guidance, as mentioned above, give a good reference to the requirements for Ports to put in place; however this is only part of what is expected from competent port authorities.

Byelaws, permitting, risk-based restrictions and tailor-made Emergency Response, amongst other aspects, are exclusive areas where Port Authorities/Administrations are given statutory powers and develop measures for good governance within the port area under their jurisdiction. Guidance to these competent authorities, on the different relevant aspects of LNG bunkering, is the objective of this document. The simple diagram presented in figure 1, below, (further developed in the definition of the Scope for the present guidance) presents the complete frame for LNG Bunkering where a triangle is completed between LNG Bunker supplier, Receiving Vessel and Port (competent) Authority.

EU Context

Directive 2014/94/EC on the deployment of alternative fuels infrastructure, part of the EU Clean Power for Transport package establishes a comprehensive set of requirement for an inter-modal development of an alternative fuel infrastructure. As defined by Directive 2014/94/EC, availability of LNG in EU core ports is scheduled for 31 December 2025 (maritime ports) and 31 December 2030 (inland ports), with the same document establishing an obligation for EU Member States to develop appropriate standards containing detailed technical specifications for refuelling points for LNG for maritime and inland waterway transport.

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In the context of the Directive, EU Member States are currently developing their National Policy Frameworks, in line with the provisions of Article 3 of the same instrument, to be notified to the European Commission by 18 November 2016. Following the notification of these, down to the operational level and towards implementation, it is important that EU harmonization can be supported, not only by reference to higher level international documents, standards or guidelines, but also by having in place guidance to the lower level requirement definition, where local and port authorities are envisaged.

Despite the provisions of the Directive, in fact, LNG bunkering is already well advanced and taking place in several ports in Northern Europe, with first movers and pilot project initiatives where LNG fuelled vessels operation represent the largest share of the worldwide LNG fuelled fleet. Co-financing programs, such as the CEF CEF – Connecting Europe Facility is a policy aiming to realise a core transport network comprising nine major corridors, to be completed by 2030. The infrastructure package stipulates a need to update the current energy infrastructure and also identifies a need to improve gas infrastructure. As part of the CEF, this package identifies priority gas corridors and projects that can be considered potential projects of public interest and likely to need funding under CEF.x, for studies, pilots and implementation works have been promoting and facilitating this development. It is now important to extract the main lessons learnt, specific experience-based advice and to address the most relevant challenges to harmonization, such as permitting procedures and training/qualification requirements for all those involved in the operation.

The Engineering solutions are already in place, demonstrated not only through the implementation of different LNG bunkering initiatives but also in several Feasibility Studies for prospective projects and ongoing implementation works. Not only it is possible to bunker LNG to a variety of different LNG fuelled vessels but also it is possible to do it safely and following a variety of different possible bunkering modes. The infrastructure is therefore expected to develop highlighting further the need to have a consistent minimum set of good practice references which, together with the existing standards and industry guidelines, can assist authorities in the different areas of LNG bunkering.

Guidance Map

Instructions Guidance

The EMSA Guidance on LNG Bunkering to Port Authorities/Administrations, hereafter referred to as “EMSA Guidance” offers, simultaneously, a reference to guide Port Authorities/Administrations (PAAs) through the relevant stages of LNG Bunkering Planning and Operations and, at the same time, an informative source on the different. The EMSA Guidance is divided into 4 (four) main Sections and 17 (seventeen) sub-sections as presented in the Guidance Map. The table below presents the main objectives and practical aspects that can be found in each of the fifteen sub-sections.

The objectives inside each section, as above described, is to provide PAAs with Information and Guidance on LNG Bunkering. Firstly, Information on the aspects already covered by other instruments (regulations, standards, industry guidelines), such as technical requirements for design, LNG bunkering concepts, modes and procedures for safe LNG transfer. Secondly, by providing Guidance to Port Authorities and Administrations in developing of the necessary control mechanisms, allowing for the safe development of LNG bunkering in EU Ports.

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The Guidance is structured in 4 (four) parts and 15 (fifteen) sections, following the natural sequence of the LNG bunkering Process. Each section contains Information and Guidance in a distinguishable manner through the format of the text and structure given to each sub-section. Figure 6 shows the difference in text section format between more informative part and the good The word “best” is generally not used in the onshore/offshore industries. This is because the goal is to encourage good practices that meet the legal requirements. The word “best” implies exceeding the legal requirements (it also implies there is nothing better). For many reasons (often cost) “best” cannot be adopted although “good” practices can and are more likely to be adopted.x practice guidance provided to PAAs by this Guidance.

Labels are provided on the side of the document, dividing further the Guidance into the 9 (nine) labels as presented in tables 2 and 4. The labels provided for an intuitive division where the titles and sections are divided according to the sequence in LNG Bunkering.

Table 4. EMSA Guidance on LNG Bunkering – Sections insight
Part	Section	Title	Labels
A. General	1	Scope and Applicability	GENERAL
	2	LNG as Fuel
	3	Environment
B. Governance	4	Regulatory Frame	GOVERNANCE
	5	Ports
	6	Feasibility
	7	Permitting
C. Risk & Safety	8	Risk	RISK
	9	Control Zones
D. Organization	10	Process Map & Organization	ORGANIZATION
	11	SIMOPS
E. Bunkering	12	Bunkering	BUNKERING
	13	Incident Reporting
F. Emergency	14	Emergency Preparedness & Response	EMERGENCY
G. Certification	15	Certification	CERTIFICATION
	16	Qualification & Training

Scope, Applicability & Definitions

This Guidance sets best practice control measures for LNG bunkering, and small scale LNG storage, relevant to Port Authorities-Administrations in their role on permitting, evaluating, approving, certifying, controlling, overviewing, documenting and providing/coordinating response in case of emergency.

Scope

The scope of this Guidance is limited to LNG bunkering Elements related to LNG as cargo, LNG terminals or other LNG wider value chain are excluded from the scope of this Guidance.x, covering the following elements Scope for the EMSA Guidance based on a gap analysis of existing references, in the context of the EU LNG Study, LOT1.x:

Regulations

• High level instrument at EU and international levels, relevant for LNG bunkering.
• Standards.
• Guidelines.
• Industry best practice.
• Port Regulations.

Operations

• Control Zones.
• Safety Distance approval.
• Simultaneous Operations (SIMOPS).
• Mooring of the receiving ship and bunker facility.
• Check-lists.
• Operational Envelopes (weather conditions, sea state, wind speed and visibility).
• General Procedures for Port Authorities.

Permitting

• Spatial planning.
• Approval of bunker locations.
• Definition of simplified.
• Overall responsibility for the good governance and framework for LNG bunker operations in the port.

Risk & Safety

• LNG Bunkering Risk Assessment.
• Definition of Risk Acceptance Criteria.
• Evaluation of Risk Assessment reports – Best practice for the evaluation of Risk Assessment report.

Emergency

• Approval of safety and emergency response plans.
• Emergency Preparedness & Response Plan.
• Shore side contingency plans, emergency response systems.
• Definition of emergency procedures for the different types of LNG Bunkering.
• Best practice in response to LNG Hazards.

Quality Management

• Several elements considered relevant to ensure the quality of the LNG bunkering process – standards and rulesLNG bunkering process, from a PAA perspective.
• Check-lists updated to include relevant indications for PAAs.
• Incident Reporting.
• Port Bye laws. Best practice in setting up port specific requirements.

Certification

• Accreditation of the Bunker Facility Operator (BFO).
• Qualification of the Person in Charge.
• Applicability of an accreditation scheme for LNG bunker operators in the ports under their authority.
• Certification of LNG bunker barges, non-IGC bunker vessels.

Training

• Training Matrix with identification of multiple training requirements in the Bunkering Interface.
• Competencies, Qualifications and Training for LNG Bunkering.
• Qualification for the PIC.
• Training Certification.

Applicability

The EMSA Guidance applies to Port Authorities/Administrations (PAAs) when involved in LNG Bunkering within their areas of port jurisdiction, either during the exploratory and planning phases or, at later stages of development, already in the context of actual LNG Bunkering operations.

The EMSA Guidance is applicable in a complimentary way to existing Standards, Guidelines and Industry Best Practice instruments, aiming to provide best practice recommendations to PAAs wherever their action is relevant, in control, evaluation, or even in guidance on the several different aspects of LNG bunkering.

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The EMSA Guidance is applicable to the control of LNG bunkering operations by PAAs in EU Core Ports, wherever EU law is applicable. It is applicable for:

• Different LNG Bunkering methods, Fuelling with LNG at berth and Shore-side LNG electricity production.
• Different ship types.
• And different locations (in port, off shore and terminal) worldwide.

Note:

1. Regulatory frame applicable to LNG bunker barges/boats/ships will depend on their area of operation. If below 500GT and not engaged in international voyages, in principle, IGC does not apply (unless enforced by national legislation). ADN agreement applies, to all LNG barges/boats/ships of contracting parties, engaged in the inland waterway transport of LNG.
2. Port Administration is, in the context of the EMSA Guidance, a holder of administrative responsibility; possibly with partial delegated authority (this can typically be the case of a private Port or of a landlord Port (mostly responsible for leasing the land). Different local, regional or national context should here be taken into account.
3. The Guidelines from ISO, IACS and SGMF offer guidance and establish requirements that cover Functional Requirements for LNG bunkering equipment, responsibilities of RS and BFO, Risk Assessment principles, amongst other aspects relevant for interaction (A) above.
4. Receiving Ship is assumed to be either an IGF Code vessel (if constructed, or converted to LNG fuel, after 1st January 2017). Before that date the IMO Interim Guidelines apply (Res. IMO MSC.285(86) Interim guidelines on safety for natural gas-fuelled engine installations in ships (2009)).

Objectives

The objectives defined for the EMSA Guidance on LNG Bunkering are to assist Port Authorities/Administrations with:

• The necessary elements to develop a harmonized procedure for the evaluation, control and through-life assessment of LNG bunkering projects.
• Definition of a unified set of first principles for permitting and approval, including a common risk assessment evaluation approach and common suggested risk acceptance criteria for the bunkering of gas as fuel in the respective.
• Implement harmonized bunkering procedures in EU ports to reduce the potential confusion caused by having to comply with different rules and regulations in different ports.
• Clear suggested definition for the responsibilities of the different involved parties including landside and waterside authorities regarding the bunkering of LNG, both in in case of normal operation and in case of malfunction or emergency.
• Definition of a procedure to allow evaluation, control and authorization of SIMOPS with LNG bunkering.
• Proposal for a harmonized approach to the approval of Control Zones in different bunkering scenarios, through the implementation of a concept of “meaningful protection”. In addition to a deterministic or probabilistic approach, it is suggested to include a context-based approach where the determination of Control Zones is driven mostly by the presence of elements meriting protection in the vicinity of the LNG bunkering location.

Author

Olga Nesvetailova

Freelancer

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