Q88 LLC 1010 Washington Blvd. Stamford, CT USA

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1 Q88 LLC 1010 Washington Blvd. Stamford, CT USA Report of the IMO Sub-Committee on Pollution Prevention and Response PPR-1 and its Working Group on Evaluation of Safety and Pollution Hazards (ESPH), February 3-7, 2014 Prepared by: Capt. Soren C. Ibsen V.P. Milbros Systems Q88 LLC February 7, 2014

2 Meeting: PPR 1 Location: IMO Headquarters, London PPR Chairman: Mr. S. Oftedal (Norway) ESPH Chairman: Mr. D. MacRae (United Kingdom) ESPH Secretary: Ms. Patricia Charlebois (IMO) Attending Delegations to the ESPH Working Group: Member Governments: Belgium, China, Denmark, Finland, France, Germany, Greece, Indonesia, Iran (Islamic Republic of), Italy, Japan, Malaysia, Marshall Islands, Netherlands, Nigeria, Norway, Philippines, Poland, Republic of Korea, South Africa, Sweden, Turkey, United Kingdom, United States NGOs: International Chamber of Shipping (ICS), International Assoc. of Independent Tanker Owners (INTERTANKO), Dangerous Goods Advisory Council (DGAC), International Association of Ports and Harbours (IAPH), International Parcel Tankers Assoc. (IPTA), European Chemical Industry Council (CEFIC), BIMCO, International Bunker Industry Association (IBIA), The Nautical Institute (NI), Clean Shipping Coalition (CSC) 1. Evaluation of new products The following new products were evaluated by the group for inclusion in List 1 of MEPC.2/Circ. and will be included in the revision of Chapter 17 of the IBC Code scheduled for These details have already been updated in the Milbros system. List 1 Entry Piperazine, 68% Aqueous Submitted by United States PPR 1/3/1 Product name will be: Piperazine, 68% solution A similar named (Piperazine (70% or less) List 1 Tripartite Agreement expired on December 17, 2013, this entry will replace that entry on List Evaluation of cleaning additives 25 cleaning additives were presented to the group for evaluation. 22 cleaning additives met the criteria outlined in MEPC.1/Circ.590. These additional cleaning chemicals can be used starting immediately. A list of these new cleaning chemicals can be found on the last two pages of this report. These new cleaning chemicals will be added to the Milbros system soon. The Netherlands informed the IMO that all cleaning chemicals listed under the Manufacturer Vecom Marine Alliance BV will be changed to Unimarine International BV Elfochem. This information will be updated in MEPC.2/Circ.20 in December of 2014.

3 3. Review of MEPC.2/Circular - Provisional classification of liquid substances transported in bulk and other related matters There were a few minor errors in the latest MEPC.2/Circ.19, dated December 17, These include: List 1 includes an entry Glucitol/glycerol blend proproxylated (containing less than 10% amines), however that should have been a new entry Glucitol/glycerol blend proproxylated (containing 10% or more amines) with the carriage requirements listed. The Milbros system has already been updated with the proper new entry. List 1 Tripartite Agreement named Polymeric amine in aliphatic hydrocarbons has been deleted from List 1 and should not be used as it has been replaced by List 1 Product Name (Polyisobutene) amino products in aliphatic hydrocarbons as approved at ESPH 19. The Milbros system has been updated accordingly. List 4 Trade Name Polyoxyalkylene polyol blend has now been removed from List 4an has been replaced by List 1 Product name Glucitol/glycerol blend proproxylated (containing 10% or more amines). The Milbros system has been updated accordingly. Papers regarding new List 3 entries were reviewed. Confidential Mixture information was only shared with member states during the evaluation and collected after the discussion is complete. Non-Member states attendees were asked to leave the meeting during those discussions. The final results were then shared will all attendees. List 3 Entry Ucarsol Submitted by United States PPR 1/3/2 Existing List 3 entry, now valid for All Countries with no expiry date, Approved as submitted. List 3 Entry Pentylol Submitted by South Africa PPR 1/3/4 Existing List 3 entry, now valid for All Countries with no expiry date, Approved as submitted. All Countries, No Expiry Pollution Category Y, Ship Type 3 List 3 Entry Fraction TX Submitted by Italy PPR 1/3/5 List 3 Entry BK Reformed/Platformed Gasoline Submitted by Italy PPR 1/3/6

4 List 3 Entry BK Gasoline Submitted by Italy PPR 1/3/7 List 3 Entry Fraction C6 Submitted by Italy PPR 1/3/8 List 3 Entry Fraction C7 Submitted by Italy PPR 1/3/9 However the ESPH group had indicated that the above five products from Italy would be more appropriately regulated under MARPOL Annex I as an Oil and cleaning of these products over the side could result in significant traces of oil on the sea surface, which would be identified by patrol flights and vessels as illegal oil pollution. Tanker operators should be guided accordingly. It was also pointed out by the group that thirty-three (33) products in MEPC.2/Circ.19 are scheduled to expire on December 17, If these products are still being carried, then the appropriate administration should be urged to prepare a paper for ESPH 20 to add these products as permanent entries with no expiry date. The products are listed below: List 1 products.1 Bis(2-propylheptyl)phthalate (Sweden).2 Disulfide Oil (United States).3 n-dodecyl Mercaptan (Belgium).4 Lauric acid methyl ester/myristic acid methyl ester mixture (United States).5 2-Methyl-1,5-pentanediamine (United States).6 n-octyl Mercaptan (Belgium).7 Phosphorus containing polyamine acid (United Kingdom).8 Renewable Naphtha (Finland).9 Salt of Polyamino carboxylic acid (United Kingdom).10 Sodium Aluminate Solution (United States).11 Sodium carboxylate solution (Belgium) List 3 products.12 Antifreeze Preparation (Brazil).13 EC1575A (United Kingdom).14 EC6671A (United Kingdom).15 EC9360A (United Kingdom)

5 .16 EC9378A (United Kingdom).17 EC9398A (United Kingdom).18 EC9660A (United Kingdom).19 EEHC1 (United Kingdom).20 Ethanol/Bitrex Fuel (Norway).21 Gyptron SA3070 (Norway).22 Heavy aromatics HVA 9B (United Kingdom).23 Heavy aromatics HVA 9C (United Kingdom).24 Heavy aromatics HVA 9K (United Kingdom).25 Heavy aromatics HVA 9V (United Kingdom).26 Heavy aromatics HVA 9W (United Kingdom).27 Heavy aromatics HVA 9Y (United Kingdom).28 Heavy aromatics HVA 9Z (United Kingdom).29 Lubrizol (United States).30 LUBRIZOL FM2600TL (United States).31 Lubrizol PV 1023 (United States).32 Petroscreen SC 16D (United Kingdom).33 Vertiscreen 052R (Norway) 4. Further review of the safety criteria guidelines in Chapter 21 of the IBC Code to address inconsistencies in Chapters 17 and 18. A Draft revision of Chapter 21 has been agreed, and now the ESPH group will review how this will effect carriage requirements for all Chapter 17 and 18 cargoes. The group will also review which cargoes are missing data in the IMO database which would be helpful in this review and possibly aid in maintaining current carriage requirements instead of possible more stringent carriage requirements. The following list of cargoes MAY end up increasing from Ship Type 3 or 2 to Ship Type 1, which would mean in most cases the cargoes could not be carried in bulk anymore on many chemical tankers. I say MAY because this review is not complete and more data may be available which will keep these cargoes at Ship Type 2. If any owners are carrying any of these cargoes on a regular basis, you should let Milbros know so we can bring that information to the attention of the ESPH group. Products TENTATIVELY being considered to move from Ship Type 3 or 2 to Ship Type 1 Allyl Alcohol Carbon Disulphide Chloroacetic acid (80% or less) Chlorosulphonic acid Fluorosilicic acid (20-30%) in water solution Glutaraldehyde solutions (50% or less) Nitrating acid (mixture of sulphuric and nitric acids) beta-propiolactone Sodium dichromate solution (70% or less)

6 5. Review products requiring oxygen dependent inhibitors INTERTANKO submitted paper PPR 1/3/11 to this session to request that the information required to be included on inhibitor certificates as outlined in the IBC Code be expanded to not only include if the inhibitor is Oxygen Dependent, but if the inhibitor is Oxygen Dependent to include the minimum level of oxygen required for the inhibitor to be effective. Provided MEPC and MSC agree, Paragraph of the IBC Code will be amended to read: whether the additive is oxygen-dependent and if so, the minimum level of oxygen required in the vapour space of the tank for the inhibitor to be effective must be specified Until the IBC Code is amended an MSC/MEPC Circular will be published provided the committees agree to the changes. It is pointed out that for new ships above 8000DWT built after a date in 2016 (to be determined) will require inerting for all low flash (<60C) cargoes. For low flash cargoes requiring oxygen dependent inhibitors tanks are not to be inerted prior to loading or during the voyage but only inerted prior to and during the discharge. During the meeting The Dangerous Goods Advisory Council (DGAC) raised some concerns by a chemical manufacturer that certain Acrylates, Methacrylates and Acrylic Acids may require oxygen levels in the vapor space above the 5% maximum required for inerting during discharge operations under the SOLAS regulations. Industry groups were urged to provide paper(s) with more information for review at ESPH Consider the issues related to the discharge of high viscosity and persistent floating products. A discussion was undertaken on Paper PPR 1/3/3 submitted by (Denmark, Netherlands, Norway, Poland, Sweden and the United Kingdom) with respect to the number and nature of recent incidents involving the discharge of high-viscosity and persistent floating products, including vegetable oil and paraffin wax residues washing up on beaches on the North Sea and the Baltic Sea coastal states over the past several years. The ESPH Group discussed the possible causes the may be contributing to the incidents and concluded the following list of items would need to be further evaluated as possible contributors: Effectiveness of stripping requirements, taking into account clingage (MARPOL Annex II, regulation 12) Definition of solidifying substances (MARPOL Annex II, regulation 1.15) Definition for high viscosity substances (MARPOL Annex II, regulation ) The definition of "en route" for the purposes of discharge (MARPOL Annex II, regulation 1.6) Adequacy of pre-wash requirements (MARPOL Annex II, regulation 13) Availability/adequacy of reception facilities The utility and ongoing need for MARPOL Annex II, regulation The ESPH Group noted that a more detailed review of this issue was required. There was much discussion in plenary on the way forward on this topic. It was agreed that MEPC needs to confirm that this is either a planned or unplanned output of the IMO and how to proceed forward.

7 Based on these continuing incidents not being sustainable going forward, it is expected that in the future there will be changes to prewash requirements for a number of products in Chapter 17 including vegetable oils. Owners, Operators and Masters are reminded, when discharging high-viscosity, high melting point and persistent floating cargoes, should the tanks and lines not be emptied to the fullest extent and efficient stripping limits as outlined in the ship s P&A Manual, due to clingage on tank bulkheads, overhead and tank bottom and within the pipeline system or other system failures, then the tank should be prewashed and slops disposed ashore. Owners, Operators and Masters are also reminded, should all the stripping requirements under the P&A Manual be met while discharging these cargoes, due regard should be given to the area where the tank washing residues are discharged to the sea to ensure that the residues are spread over as wide an area as possible for the environment to absorb the residues and consider the weather, current conditions and distance offshore so to minimize the possibility of any floating residues of washing up on beaches. Meaning parties should not just be guided by the MARPOL Annex II requirements of being 12 miles offshore and other requirements. 7. Clarification on the use of generic cleaning products. IPTA submitted paper PPR 1/3/10 to this session to provide clarification on the use of generic cleaning products not included in Annex 10 of the MEPC.2/Circular, but can be found elsewhere in either chapters 17 or 18 of the IBC Code or List 1 of the Circular. It was agreed that the following new text be inserted in Annex 10 of the MEPC.2/Circular: "It should be noted that where products or their solutions that appear in chapter 17 or 18 of the IBC Code or List 1 of the MEPC.2/Circular are used as washing media, their discharge shall be governed by regulation of MARPOL Annex II and they do not need to be listed here."

8 8. Any other business A number of questions have arisen with regard to the application of the new regulation 5-2 of Chapter VI of SOLAS regarding the Prohibition of the blending of bulk liquid cargoes and production processes during sea voyages, which entered into force on 1 January It was agreed there was a need to develop some guidance with regard to the interpretation and application of the new regulation, in particular for the carriage of MARPOL Annex I cargoes. This is expected to be completed during ESPH 20. There is already been a number of previous discussions on this topic at various ESPH meetings and guidance is already available in various documents and are recapped as follows: The 2011 Guidelines for the carriage of blends of petroleum oil and biofuels, as amended (MEPC.1/Circ.761/Rev.1) The discussion of the ESPH Working Group on the intended exclusion of bunkering operations from this prohibition (BLG 16/WP.3, paragraph 6.3) That the prohibition of the blending of cargoes would not apply where cargo is recirculated within its cargo tank or through an external heat exchanger during the voyage (MSC 90/28, paragraph 14.3) NOTE: It is the intent of this point to allow the recirculation of cargo within one tank during the sea voyage including previously blended cargoes while in port or cargoes where additives were added, to allow mixture and maintaining a homogeneous mixture during the sea voyage. Next Meeting: The next intersessional meeting ESPH 20 will be held in London, September 29 to October 3, The next PPR Sub-Committee Meeting is tentatively scheduled to be held January 19 to 23, 2015.

9 CARGO TANK CLEANING ADDITIVES EVALUATED AND FOUND TO MEET THE REQUIREMENTS OF REGULATION OF ANNEX II OF MARPOL Name of cleaning additive Name of manufacturer Reporting Country 1 MarClean BioSolve Tank CC The BioSolve Company USA 2 CHEMIPOL CHEMO Greece 3 DYE OUT CHEMO Greece 4 IGS CLEANER CHEMO Greece 5 TANKSHINE CHEMO Greece 6 ER-TEEPOL ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 7 ERCLEAN-HCF ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 8 ERCLEAN IGS ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 9 ERCLEAN CTC ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 10 ER-APC AQUA ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 11 COAL TAR REMOVER ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 12 RUST REMOVER ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 13 ER-APC EXTRA 200 ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 14 ER-HDC ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 15 ERCLEAN BUFFER ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 16 ER-APC EXTRA 50 ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 17 MULTICLEANER ERTEK KIMYA TIC.ve SAN.LTD.STI Turkey 18 SEACLEAN T Blutec srl. Italy 19 ECOCLEAN Blutec srl. Italy 20 ALKACLEAN Blutec srl. Italy 21 Acquaclean MPA Blutec srl. Italy 22 RUST CLEAN Blutec srl. Italy