PPR 3-18-1 - Clarification On Regulation 36 of MARPOL Annex I For Categorizing Offshore Terminal (Singl... (OCIMF)
PPR 3-18-1 - Clarification On Regulation 36 of MARPOL Annex I For Categorizing Offshore Terminal (Singl... (OCIMF)
PPR 3-18-1 - Clarification On Regulation 36 of MARPOL Annex I For Categorizing Offshore Terminal (Singl... (OCIMF)
SUMMARY
Output: 1.1.2.3
Background
1 During the course of normal cargo transfer operations at offshore marine terminals
(SPMs and CBMs) and upon completion of cargo operations, the subsea hoses and fittings
may remain filled with oil or upon request from the terminal and following good industry
practice, they may be filled with sea water while idle or when having maintenance conducted
upon them. This is primarily achieved by back flushing from the tankers cargo manifold and it
is a long established industry process.
2 Subsea hoses and fittings may be filled with seawater in order to mitigate pollution
risks to the marine environment from potential leaks from subsea fittings, hoses and pipelines
and/or for safety during maintenance activities.
3 Newly built offshore terminals are encouraged to adopt a design that allows
recirculation through the hoses to the shore, however, many existing terminals do not have
a recirculation facility. Subsequently, shipboard tanker cargo/ballast operations require the
management of the line flush seawater in accordance with MARPOL Annex I with appropriate
entries made in the Oil Record Book (Part II). However, this poses a practical challenge as
flush water (seawater) is not defined under MARPOL Annex I, although it is clearly an oily
water mixture.
4 OCIMF invites the Sub-Committee to review the attached annex (OCIMF Single Point
Mooring Maintenance and Operation Guide – 3rd Edition 2015 – chapter 4.7) as background
reading of the industry good practice guidance (the full document is available from Witherbys
Publishing).
Discussion
5 The use of seawater for line flushing to offshore marine terminals (SPMs and CBMs)
is a recognized shipboard operation which ensures safety and increases environmental
protection by displacing the line content with seawater in order to leave the idle hose full of
water rather than cargo. Prior to the next use of the hoses for cargo transfer, the seawater and
any cargo residue left in the idle hose is commonly loaded to the ship's slop tanks to avoid
contamination of the main cargo transferred.
6 It is important to note that the operation being described under this unified
interpretation, for the purpose of clarity, is very specific to that of displacing the cargo from the
hose string with seawater while idle or for maintenance purposes. The draft unified
interpretation is not intended to be applicable to what might be considered as similar operations
at Floating (Production) Storage Offtake units (F(P)SOs) involving production, commissioning
or decommissioning water and which therefore, may include other products than just cargo
residue and seawater.
8 The line flush consists principally of seawater and the possibility of oily mixture from
cargo residue. The quantity of the line flush should be recorded and disposed of in accordance
with MARPOL legislation.
9 The challenge that OCIMF has identified comes when the tanker arrives at the
discharge terminal where some terminals/local authorities are reluctant to accept the line flush
due to the unspecified and undocumented composition of the content. However, OCIMF
contends that the composition of the content is known and thus should not present an issue.
11 Furthermore, the Oil Record Book (Part II) should include an entry under Item J. It is
suggested that the entry uses wording similar to the example below in order to remove any
uncertainty:
.1 at load port where flush water is received by the tanker, use the suggested
wording for remarks:
12 It is considered good practice that a receipt describing the line flush should be
provided by the terminal operator to confirm the contents as seawater and cargo residue and
therefore considered as cargo slops and not part of the cargo according to the provisions
of MARPOL.
***
ANNEX
Serious incidents have occurred during line flushing operations at SPMs through the lack of
effective controls, non-adherence to procedures and the use of inappropriate equipment.
Because the use of water is thought to be safe, terminals may have underestimated the
hazards and consequences.
Terminals should have a documented philosophy for water flushing, which should include:
4.7.1 Flushing
Water flushing is commonly carried out to evacuate petroleum cargoes from SPMs before any
of the following operations:
A small number of terminals routinely flush SPMs after each cargo operation. Typically, these
terminals have procedures with the following precautions in place for tankers to carry out
a flush on completion of discharge:
Terminals should develop procedures for an effective flush that removes all petroleum
residues. Procedures that should be taken into account include:
o Minimum volume.
o Pressure.
o Flow rate.
Some terminals have successfully used gel pigs to ensure an effective flush using the minimum
volume of water.
Support vessels that are required to carry out flushing operations should be designed,
equipped and manned to carry out the operations safely.
Traditionally, flushing was carried out from or to tankers. It is now more common for flushing
to be carried out from support vessels because of the changes in tanker ballast systems and
the difficulties caused by tankers retaining oily water on board.
The following precautions should be considered before any flushing takes place from a support
vessel.
Support vessels should have a flushing system that complies with the following requirements:
o The pump and piping should be fit for purpose and designed to deliver the
required pressure and flow rate.
o The flushing system should be independent of, and physically isolated from,
any other system.
o The system should be designed with a physical means of preventing the
backflow of petroleum liquids and gases into the support vessel.
o A pressure/vacuum gauge should be fitted in a position where it will reliably
indicate the pressure before valves to the hose connection are opened.
o Flush system components should be rated at a pressure that is consistent with
the maximum working pressure.
o Ventilation systems to the accommodation and machinery spaces should not
permit the ingress of vapours from the working deck or flush pump area.
o The flush system should be independent of the firewater system, so that the
firewater main may be kept pressurised and ready for use.
Terminals should comply with the following requirements regarding support vessel charters:
o A written procedure that the support vessel's Master and crew are familiar with
and have agreed.
o The terminal's procedure should be reviewed and signed off by all the relevant
disciplines involved in the activity, including:
Terminal operations.
Maintenance.
Process engineering.
HSSE.
The support vessel’s Master and/or Operations Superintendent.
o Single point accountability for the activity should be established within the
terminal operations and maintenance disciplines. Under no circumstances
should a support vessel's marine contractor conduct flushing without effective
operational control and oversight from terminal personnel.
o Effective communications should be established between the operation
locations, for example the SPM, support vessel, tank farm and control room.
o Support vessel crews should be specifically trained in flushing operations,
including an awareness of ISGOTT (Reference 12) and the basic hazards of
petroleum.
o Support vessel crews should complete their own job safety analyses and risk
assessments.
o The flush pump should be started and pipework pressurised before valves to
the hoses are opened.
o Where line clearance is to a tank, the tank should be at as low a level as
possible to minimize back pressure. In any event, the maximum back pressure
should be documented in the flush procedure."
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