TRADING IN ECA AREAS HFO TO LSFO CHANGE OVER

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1 SQEMS WORKING INSTRUCTION WIN-TEC-24 1 of 6 References: 1. SCOPE To establish a dedicate procedure for each type of Company vessels relevant to the change-over from highsulphur (H.F.O.) to low-sulphur (L.S.F.O.) fuel oil before entering an Emission Control Area. To provide the proper means to comply with Marpol Annex VI Reg RESPONSIBILITY Masters To monitor the change over procedure to low-sulphur fuel oil and keep records and evidence of any step taken; To be sure to be always compliant with Reg. 14 of Marpol Annex VI; To request necessary quantity of L.S.F.O. to allow the ship to perform the requested voyage in ECA areas, taking into account quantity on board of H.F.O. and the vessel s storage capacity for L.S.F.O; To minimize any loss of time during the change over to L.S.F.O before entering ECA areas. Chief Eng. To carefully follow the present instruction to change over fuel to be burnt on M.E./DD.GG/boilers from H.F.O. to L.F.O; To ensure Master by officially informing (recording on the official Deck and Engine Record Books) that M.E. and auxiliaries are running on L.S.F.O. before entering ECA areas; To be sure to be always compliant with Reg. 14 of Marpol Annex VI; To instruct Engineers about ECA areas and mandatory requirements for entering and sailing in those areas. Vessel Sup. To provide the necessary technical support and actions to the vessel when needed. Technical Manager To provide adequate technical support to the vessel when needed; To keep this specific instruction duly updated. Operation Dept. To provide info to the vessel on the limits of any ECA area to be entered during a commercial voyage; To timely inform Masters of voyage orders involving trading in ECA areas in order to allow a smooth and correct change over of H.F.O./L.S.F.O. to be used; To supply necessary low-sulphur fuel oil quantities in order to allow the vessel to enter and exit ECA areas with safe R.O.B. quantity; To allow the vessel the time necessary to carry out change over to low-sulphur fuel oil in due time, according to regulations. Chartering Dept. To consider the required time to change to L.S.F.O before fixing the vessel; To consider, before fixing, the L.S.F.O. R.O.B. on board and/or available places where L.S.F.O. is existing for replenishment/supply. Prepared by: Reviewed by: Approved by: Tech. Dept. Fleet Director General Manager Distribution: to all managed vessels

2 2 of 6 3. GENERAL According to Marpol Annex VI, Reg. 14, Company establishes that all Company managed vessels will have to use fuel oil with a sulphur content that does not exceed 1.00% m/m (0.10% m/m on and after 1 January 2015) as documented by bunker delivery note, when trading in ECA areas. Then, vessels will be allowed to enter the ECA areas only when L.S.F.O is being burnt in M.E. and auxiliaries. The IAPP Certificate or the related Statement for those Flags that have not yet adhered to MARPOL Annex VI should be amended showing that vessel can operate in the ECA areas (point of IAPP Certificate stick). 3.1 Vessel preparation to load low-sulphur fuel oil L.S.F.O. storage tank: transfer the R.O.B. H.F.O. in the dedicated H.F.O. storage tank by means of transfer pump; Drain some H.F.O unpumpable fuel residues into the drain Perform flushing of manifold/bunkering lines into H.F.O. storage tank. Flushing should last at least 10 mins; After flushing, the L.S.F.O. can be transferred into the dedicated storage As per MARPOL regulation and Company policy, the Master must take bunker samples to be sent to DNV laboratory for analysis. 4. ACTION The actions to be done below described are customized for each class/type of managed vessel. Each vessel should refer to the reported actions, choosing the dedicated one: 4.1 AFRAMAX Tankers (Class: FINCANTIERI Ancona) Storage tanks locations (see drawing A): L.S.F.O. tank is located port side the ship (see drawing A frame 40-50). L.S.F.O. settling tank n. 1 port is located port side frame L.S.F.O. service tank n. 2 port is located frame Preparation for transfer of L.S.F.O. into the settling tank (see drawing C): Contents of the H.F.O. settling tank (n. 1 port) must be transferred by purifier lines to the existing H.F.O. service tank or H.F.O. settling tank (n. 2 port); Any H.F.O. fuel residues should be drained into drain The line from L.S.F.O. storage tank to the settling tank should be flushed by transfer pump to H.F.O. settling tank (n. 2 port) for at least 10 min.; After completion of the lines/tanks flushing the L.S.F.O. contained in the storage tank can be transferred to the L.S.F.O. settling tank (n. 1 port ) and the purifier put in service for about 30 min. to flush lines/heater (if necessary, gravity disk should be replaced) and the purifier continuously re-circulating in L.S.F.O. settling tank Transfer of L.S.F.O. into M.E. system (see drawing C and D) option A The contents of L.S.F.O. service tank must be reduced to the minimum capacity (around 10%) of tank capacity; With this level the new L.S.F.O. contained in the settling tank can be transferred by purifier system to the service tank and the Master must record the date and time hour in which this operation has started; Assuming M.E. consumption at 1.5 cum/h, transfer capacity of the purifier should be increased at 5 cum/h in order to have the H.F.O. contained in the M.E. system consumed and in 14.8 hours the service tank filled in with L.S.F.O.; With this option we can assume to complete transfer from H.F.O. to L.S.F.O. in 24 hours and ready to enter ECA areas.

3 3 of Transfer of L.S.F.O. into M.E. system (see drawing C and D) option B vessel near to ECA area M.E. should be stopped; H.F.O. contained in the service tank should be removed by purifier and transferred into the H.F.O. settling L.S.F.O. contained in the settling tank should be transferred through purifier into L.S.F.O. service M.E. can be run with L.S.F.O. and after 6 hrs sailing, time assumed as necessary to complete the full system flushing with L.S.F.O., the vessel can enter a ECA area Transfer of L.F.O. into M.E. system (see drawing C and D) option C vessel near to ECA area M.E. should be changed at D.O. consumption and M.E. lines cleaned from H.F.O. H.F.O. service tank contents should be removed by purifier and transfer to H.F.O. settling tank. Any residues drained into drain After that the L.S.F.O. contained in the settling tank can be transferred by purifier into the L.S.F.O. service M.E. can then be changed from D.O. consumption to L.S.F.O.; This operation is quite immediate and requires only the time necessary to empty and clean L.S.F.O. service tank from previous H.F.O. content and allow the ship to enter ECA areas in few hours and without M.E. stop 4.2 PANAMAX Tankers (FOUR MOON) Storage tanks locations : L.S.F.O. tank is located port side the ship (frame : tank id C402). L.S.F.O. Settling tank is located frame tank id C450. L.S.F.O. Service tank is located frame tanks id C451. The ship is equipped with one settling tank and only service tank only. The same tanks will be used for L.S.F.O. operation after flushing of the system Preparation for transfer of L.F.O. into the settling tank: Ensure that adequate quantities of ready to use F.O. for engine and boiler remain continuously available during any change-over procedure from H.F.O. to L.S.F.O. in the service Contents of the H.F.O. settling tank must be transferred by transfer pump lines to the existing H.F.O. storage Any H.F.O. fuel residues should be drained into drain The line from L.S.F.O. storage tank to the settling tank should be flushed with L.S.F.O. by transfer pump to H.F.O. settling tank for at least 10 min.; After flushing the L.F.O. contained in the storage tank can be transferred to the L.S.F.O. settling tank and the purifier put in service for about 30 min. to flush lines/heater (if necessary gravity disk should be replaced); These operations will require about 6 hours Transfer of L.S.F.O. from settling tank to service tank option A Service tank H.F.O. quantity should be reduced or tank emptied as much as possible; L.S.F.O. contained in the settling tank can then be transferred by purifier system to the service tank and the Master must record the date and time hour in which this operation has started; Filling the service tank with L.S.F.O. and start use of the L.S.F.O. in order to flush all system; Calculate the time required for the dilution of H.F.O. by L.S.F.O. to achieve the required sulphur limit of 1.5% according to H.F.O. and L.S.F.O. sulphur content, fuel consumption rate, quantity of H.F.O. in the fuel system and service tank prior to dilution (see relevant Attachment); With this option, we can assume to complete the dilution from H.F.O. to L.S.F.O. in 24 hours and ready to enter ECA areas.

4 4 of Transfer of L.S.F.O. into M.E. system (see drawing C and D) option B vessel near to ECA area M.E. and boiler should be stopped; H.F.O. contained in the service tank should be removed by purifier and transfer in the H.F.O. storage L.S.F.O. contained in the settling tank should be transferred through purifier into L.S.F.O. service M.E. can be run with L.S.F.O. and after 12 hrs sailing time assumed as necessary to complete the full system flushing with L.S.F.O., then vessel can enter a ECA area Transfer of L.F.O. into M.E. system (see drawing C and D) option C vessel near to ECA area M.E. and boiler should be run with D.O. and M.E. lines thus cleaned from H.F.O. L.S.F.O. service tank contents should be removed by purifier and transferred to H.F.O. settling tank. Any residues drained into drain After that the L.S.F.O. contained in the settling tank can be transferred by purifier into the L.S.F.O. service M.E. can then be changed from D.O. consumption to L.S.F.O.; This operation is quite immediate and requires only the time necessary to empty and clean L.S.F.O. service tank from previous H.F.O. content and allow the ship to enter ECA areas in 6 hours and without M.E. stop. 4.3 BULK Carrier (FOUR SPRINGS) Storage tanks locations (see attachment 12 D ): L.S.F.O. tank is located STBD side the ship (ex STBD slop tank reduced in volume during conversion). L.S.F.O. settling tank n. 1 port is located port side frame L.S.F.O. service tank n. 2 port is located frame Preparation for transfer of L.S.F.O. into the settling tank (see attachment 12 C ): Contents of the H.F.O. settling tank (n. 1 port) must be transferred by purifier lines to the existing H.F.O. service tank or H.F.O. settling tank (n. 2 port); Any H.F.O. fuel residues should be drained into drain The line from L.S.F.O. storage tank to the settling tank should be flushed by transfer pump to H.F.O. settling tank (n. 2 port) for at least 10 min.; After completion of the lines/tanks flushing the L.S.F.O. contained in the storage tank can be transferred to the L.S.F.O. settling tank (n. 1 port ) by means of transfer pump and the purifier left in service for about 30 min. to flush lines/heater and continuous recirculation into L.S.F.O. settling tank Transfer of L.S.F.O. into M.E. system (see attachment 12 C ) option A The contents of H.F.O. service tank must be reduced to the minimum capacity (around 10%) of tank capacity; With this level the new L.S.F.O. contained in the settling tank can be transferred by purifier system to the service tank and the Master must record the date and time hour in which this operation has started; Assuming M.E. consumption at 1.5 cum/h, transfer capacity of the purifier should be increased at 5 cum/h in order to have the H.F.O. contained in the M.E. system consumed and in 14.8 hours the service tank filled in with L.S.F.O.; With this option we can assume to complete transfer from H.F.O. to L.S.F.O. in 24 hours and ready to enter ECA areas Transfer of L.S.F.O. into M.E. system (see attachment 12 C ) option B vessel near to ECA area M.E. should be stopped; H.F.O. contained in the service tank should be removed by purifier (considering tank level already reduced by normal consumption) and transferred into the H.F.O. settling L.S.F.O. contained in the settling tank should be transferred through purifier into L.S.F.O. service

5 5 of 6 M.E. can be run with L.S.F.O. and after 6 hours sailing, time assumed as necessary to complete the full system flushing with L.S.F.O., the vessel can enter a ECA area Transfer of L.F.O. into M.E. system (see attachment 12 C ) option C vessel near to ECA area M.E. consumption should be changed to D.O. supply/return lines cleaned from H.F.O; H.F.O. service tank contents should be removed by purifier (considering tank level already reduced by normal consumption) and transferred to H.F.O. settling tank. Any residues drained into drain After that, the L.S.F.O. contained in the settling tank can be transferred by purifier into the L.S.F.O. service M.E. can then be changed from D.O. consumption to L.S.F.O.; This operation is quite immediate and requires only the time necessary to empty and clean L.S.F.O; service tank from previous H.F.O. content and allow the ship to enter ECA areas in 6 hours without M.E. stoppage. 4.4 AFRAMAX Product Carrier (FOUR WIND/SKY) Storage tank location The tank designated for LSHFO is the L.S. H.F.O. ST.(S), Fr 46-52, with a capacity of m3 (see Attachment 12F) Preparation for bunkering LSHFO At the beginning of L.S. bunker operation, the bunker line to be drained/washed into any HFO storage tank with LSHFO for at least 10 minutes. Switch over the bunker valves to the dedicated LSHFO ST (S) Preparation for entering in ECA areas HFO separator suction to be switched from HFO Settling tank to LSHFO Settling tank (42.5 m3) suction; HFO separator delivery to be switched to LS Service tank (42.5 m3) after 30 minutes of flushing; LSHFO settling tank to be filled by transfer pump from LSHFO STORAGE tank after line flushing Preparation for exiting from ECA areas All valves / machineries to be re-set to original position (HFO consumers); It is not necessary to carry out any flushing being the LSHFO consumed while changing back to HFO. See Attachment 12H with sketch drawing of piping/systems lay out LSHFO Change Over Calculator The calculated time for HFO to LSHFO changeover is about 1 hr. The calculated time for LSHFO to HFO changeover is about 15 min. 4.5 SUEXMAX Tanker (FOUR SMILE) Storage tank location The storage tank designated for LSHFO is the STBD H.F.O. Fr 35-55, with a total capacity of 1851m3 (see Attachment 12G) Preparation for bunkering LSHFO HFO ROB in dedicated LSHFO STBD to be transferred to PORT side HFO storage tank by means of transfer pump; At the beginning of bunker operation, the bunker line to be drained/washed into the PORT side HFO tank with LSHFO for at least 10 minutes; Switch over the bunker valves to the dedicated STBD LSHFO tank Preparation for entering in ECA areas Settling tank NOT to be refilled at least 3 days before entering the ECA area; Purifier (from Settling to Service) to be stopped 1 day before entering the ECA area; Settling tank to be emptied by draining the ROB into the F.O. overflow/drain HFO settling tank to be filled by transfer pump with LSHFO from LS Storage tank STBD;

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7 6 of 6 HFO service tank: some quantity to be drained to F.O. overflow D/B ensuring that a minimum safety quantities is maintained into the service tank for normal operation of the ME, DD/GG and Boiler. Safety level approx 12m3; HFO separator to be re-started and LSHFO from settling tank to be transferred HFO service The total change over time is approximately 12 hours (without considering the time needed to reduce the Settling and Service tank level to the minimum safe) Preparation for exiting from ECA areas Two days before to exit the ECA area the Settling tank should NOT be refilled; When a minimum quantity of LSHFO remain into the Settling tank, the same should be loaded on top by means of transfer pump from HFO Storage Service tank LOAD ON TOP to be done in way to refill the purified HFO from Settling to Service tanks; M/E, DD/GG and Boilers consumption is back to HFO; See Attachment 12H with sketch drawing of piping/systems lay out. Attachments Nr. 12A Nr. 12B Nr. 12C Nr. 12D Nr. 12E Nr. 12F Nr. 12G Nr. 12H Nr. 12I Guidelines for Bunker Change Over: AFRAMAX Type Guidelines for Bunker Change Over: PANAMAX Type (Four Moon) Guidelines for Bunker Change Over: BULK Carrier Type (Four SPRINGS) Designated Tank for LSFO: BULK carrier Type (Four SPRINGS) Intentionally Left Blank Designated Tank/Guidelines for AFRAMAX Product carrier (FOUR WIND/SKY) Designated Tank for LSFO: SUEZMAX tanker (Four SMILE) Guidelines for Bunker Change Over: SUEZMAX tanker (Four SMILE) Intentionally left blank