Have SOLAS 2016 inert gas requirements boosted safety

or

added operational burden

SOLAS & Nitrogen

The inerting of flammable chemical cargoes has always been supported

BUT

Already in 2010 the question was raised:

Will there be clear instructions and guidelines and will this apply to all flammable chemical cargoes or if a list of products with exemptions will be required.

SOLAS & Nitrogen

➢Reg.4 - 5.5.1.2 For tankers of 8,000 tonnes deadweight and upwardsconstructed on or after 1 January 2016 when carrying cargoes described in regulation 1.6.1 or 1.6.2, the protection of the cargo tanks shall be achieved by a fixed inert gas system in accordance with the requirements of the Fire Safety Systems Code, except that the Administration may accept other equivalent systems or arrangements, as described in paragraph 5.5.4.

SOLAS & Nitrogen

➢Reg.16 – 3.3.2 Notwithstanding the above, for chemical tankers, the application of inert gas, may take place after the cargo tank has been loaded, but before commencement of unloading and shall continue to be applied until that cargo tank has been purged of all flammable vapours before gas-freeing. Only nitrogen is acceptable as inert gas under this provision.

may?

SOLAS & Nitrogen

➢Reg.16 - 3.3.4 In the event that the inert gas system is unable to meet the requirement in paragraph 16.3.3.1 and it has been assessed that it is impractical to effect a repair, then cargo discharge and cleaning of those cargo tanks requiring inerting shall only be resumed when suitable emergency procedures have been followed, taking into account guidelines developed by the Organization."

IBC Code: Inhibited Cargoes

"15.13.5 When a product containing an oxygen-dependent inhibitor is to be carried:

.1 in a ship for which inerting is required under SOLAS regulation II-2/4.5.5, as amended, the application of inert gas shall not take place before loading

or during the voyage, but shall be applied before commencement of unloading*;

.2 in a ship to which SOLAS regulation II-2/4.5.5, as amended, does not apply, the product may be carried without inertion (in tanks of a size not

greater than 3,000 m3). If inertion is to be applied on such a ship, then the application of inert gas shall not take place before loading or during the

voyage, but shall be applied before commencement of unloading*.

What if Charterer / Terminal requirements are different?

Inerting Requirements

IBC Code guidance Limited Guidance ?

Purging prior Gas freeing

IBC Code 8.5 Cargo tank purging: When the application of inert gas is required by 11.1.1, before gas-freeing, the cargo tanks shall be purged with inert gas through outlet pipes with cross-sectional area such that an exit velocity of at least 20 m/s can be maintained when any three tanks are being simultaneously supplied with inert gas. The outlets shall extend not less than 2 m above the deck level. Purging shall continue until the concentration of hydrocarbon or other flammable vapours in the cargo tanks has been reduced to less than 2% by volume."

IBC Code 15.12.1.4 (Toxic Cargoes): the vent height may be reduced to 3 m above the deck or fore-and-aft gangway, as applicable, provided high-velocity vent valves of an approved type, directing the vapour/air mixture upwards in an unimpeded jet with an exit velocity of at least 30 m/s, are fitted.

What about Toxic Cargoes?

Padding/Inerting & Purging

Padding/Inerting & Purging on route

Vapours Vapours

Vapours VapoursAirstream

Padding/Inerting after loading

Padding (Inerting a loaded cargo tank) on Chemical Tankers was always a High Risk operation.

➢Potential of Tank Overpressure➢Overflow through P/V Valves➢Tank damage / rupture

➢Exposure to Nitrogen and Cargo vapours➢Exit velocity of 20m/s to be maintained? – Approved? ➢Approved outlet 30m/s for Toxic cargoes? - What means approved?➢Both relevant for Padding / Inerting?

Tank Cleaning

What might be an issue for tank cleaning?

➢Drying-effect of Nitrogen➢Cargoes with Inhibitor➢ Cargoes sensitive for drying

➢Purging & Gas Freeing➢Purging with N2 Generator➢Gas Freeing with Gas Freeing vent

➢Company Tank Cleaning Procedures

➢Industry Tank Cleaning Guidelines

Challenges – or – Operational burden?

➢Clear Regulations and definitions?

➢Updated Industry Guidance and Guidelines?

➢Company Cargo Operation Procedures?

➢Company Tank Cleaning procedures?

➢Charterer Instructions?

➢Potential for new Tank Cleaning operations?

➢Occupational Health?

➢Commercial Pressure?

Incidents of the past

Would the new SOLAS regulation have avoided incidents in the past?

Examples:

➢2012 Bung Alpinia – Explosion

➢2012 Stolt Valor – Explosion

➢2012 Royal Diamond No. 7– Explosion

➢2013 Maritime Maize – Fire

Incident avoidance

➢Experience

➢Training

➢Intervention

➢Compliance with oRules and RegulationsoCompany procedures

Does the new regulations for chemical cargoes with a FP<60°C

require:clarification and / or additional

ROBUST guidelines?

Thank youAxel Kahl

Twistering 1A, 21147 Hamburg / Germany

Phone: +49 40 98764844Fax: +49 40 98764845Mobile: +49 15221883222Email: axel.kahl@chemicalmarine.comWeb: www.chemicalmarine.com