GREENER SHIPPING SUMMIT 2017

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1 GREENER SHIPPING SUMMIT 2017 EU MRV Regulation Methods of Data Collection of Fuel Differences/Consequences/Evaluation of Methods Antonios Georgantzis 14 November 2017 Eugenides Foundation

2 The EU MRV Timeline July 2015 The EU MRV shipping Regulation came into force August 2017 Submission to verifiers of a MP for each vessel January December 18 Start of the first monitoring and reporting period April 2019 Deadline for submitting a verified Emissions Report June 2019 Document of compliance available on board for the vessels arriving or departing from European Port.

3 EU Applicable Legislation documents 3 EU Regulation 2015/ The main document for MRV Regulation EU Regulation 2016/ Amendment to MRV Regulation EU Regulation 2016/ The implementing regulation for MPs and Templates EU Regulation 2016/ The document for determination of the cargo EU Regulation 2016/ The document for verification and accreditation

4 IMO DATA COLLECTION SYSTEM TIMELINE October 2016 MEPC 70 adopted the Data Collection System and amendments of SEEMP 2018 Spring Adoption of an initial IMO CO2 reduction strategy January Data collection commences Summer. Data for 2019 to be reported Autumn. Beginning of IMO analysis of fuel consumption data Summer. Data for 2020 to be reported to IMO Spring.IMO decisions on future policy basis on the analysis of data Spring. Adoption of revised IMO strategy including any additional CO2 reduction measures as appropriate

5 Introduction of a Completely New Management System 5 New Detailed and prescriptive procedures and records are required with new roles, duties and responsibilities Documentation control for amendments and new versions and storage of records of MP system are required Development of Risk Assessments for a FLOW CHART OF ACTIVITIES New maintenance and calibration processes are established Internal and external assessment and verification is required Periodical Management Review is required New Document of Compliance covering vessel and company is issued

6 Contents of the Monitoring Plan - MP 6 EU Regulation 2016/ The implementing regulation for MPs and Templates

7 When providing information on elements and procedures as part of the MP pursuant to Article 6(3) of EU Reg 2015/757, Companies should be able to refer to.. Contents of the Monitoring Plan - MP Procedures effectively implemented as part of the existing Management System International Safety Management Code ISM Ship Energy Efficiency Management Plan SEEMP or to systems and controls covered by harmonised quality, environmental or energy Management standards such as EN ISO 9001:2015 EN ISO 14001:2015 EN ISO 50001: EU Regulation 2016/ The implementing regulation for MPs and Templates

8 B. Basic Data B1. Identification of Ship 8 Type of the ship: The Annex I Table B.1 identification of the ship of EU 2016/1927 suggest to select one of the following categories: Oil tanker Chemical tanker.etc The regulation doesn t cover the combination

9 B.3 Emission sources 9 Describe as per 3(c) of Article 6 of EU 2015/757 the emission sources onboard: Main Engine(s) Auxiliary Engines Gas Turbine(s) Auxiliary & Composite Boiler(s) Inert Gas Generator Diesel Driven Power Pack Engines Emergency Diesel Generator

10 B.3 Type of Fuels Used 10 For each one of the emission sources record one or more of the following Fuels used: HFO, LSHFO (LFO), MGO/DO, LNG, LPG, Methanol, Ethanol Use the emission Factor for each of the above Standard Fuels referred to the template. For Non-Standard Fuel Make an analysis in a recognized laboratory, following a specific sampling methodology

11 B.5 Update the Completeness of Emissions Sources 11 You need to fill in table B.5. describing: The procedures used for identifying the ES, estimating ES not regularly monitored, ensuring that all information data are included the time period of reporting The version of it The responsible person for implementing this procedure of completeness The location and retention where the records kept, including the IT software Completeness as defined by ISO (International Standard for GHG Emissions and Verification) The verifier shall check that in the MP the ES are monitored completely & accurately. (Not biased eliminated & describing precision & uncertainties)

12 C. Activity Data Monitoring of Fuel Consumption 2. List of voyages 3. Distance travelled 4. Amount of cargo carried (& number of passengers) 5. Time spent at sea

13 C.1 Monitoring of Fuel consumption Methods used to determine fuel consumption of each Emission Source 2. Procedures for determining fuel bunkered and stock takes in Fuel Tanks 3. CROSS CHECKS between BDN and stock takes 4. Description of measurement equipment involved 5. Procedures for recording, retrieving, transmitting and storing information regarding measurements 6. Method for determination of density 7. Level of uncertainty associated with fuel monitoring 8. Procedure for ensuring quality assurance of measuring equipment 9. Method for determining and recording the FC on laden voyages

14 1.1 Methods Used to determine fuel consumption of each ES 14 a) Method A - Bunker Fuel Delivery Note (BDN) and periodic stock takes of fuel tanks b) Method B - Bunker fuel tank monitoring on board c) Method C - Flow meters for applicable combustion processes d) Method D - Direct CO2 emission measurements

15 1.1 Methods Used to determine fuel consumption of each ES 15 Method A: Bunker Fuel Delivery Note (BDN) and periodic stock takes of fuel tanks This method is based on the quantity and type of fuel as defined on the BDN combined with periodic stocktakes of fuel tanks based on tank readings. The fuel at the beginning of the period, plus deliveries, minus fuel available at the end of the period (and de-bunkered fuel) between the beginning of the period and the end of the period together constitute the fuel consumed over the period The period means the time between two port calls or time within a port. For the fuel used during a period, the fuel type and the sulphur content needs to be specified

16 1.1 Methods Used to determine fuel consumption of each ES 16 Method B: Bunker fuel tank monitoring on board This method is based on fuel tank readings for all fuel tanks on-board. The tank readings shall occur daily when the ship is at sea and each time the ship is bunkering or de-bunkering The cumulative variations of the fuel tank level between two readings constitute the fuel consumed over the period The period means the time between two port calls or time within a port. For the fuel used during a period, the fuel type and the sulphur content need to be specified Fuel tank readings shall be carried out by appropriate methods such as automated systems, soundings and dip tapes. The method for tank sounding and uncertainty associated shall be specified in the monitoring plan

17 1.1 Methods Used to determine fuel consumption of each ES 17 Method C: Flow meters for applicable combustion processes This method is based on measured fuel flows on-board. The data from all flow meters linked to relevant CO 2 emission sources shall be combined to determine all fuel consumption for a specific period The period means the time between two port calls or time within a port. For the fuel used during a period, the fuel type and the sulphur content need to be monitored The calibration methods applied and the uncertainty associated with flow meters used shall be specified in the monitoring plan

18 1.1 Methods Used to determine fuel consumption of each ES 18 Method D: Direct CO2 emission measurements The direct CO 2 emissions measurements may be used for voyages and for CO 2 emissions occurring in ports located in a Member State's jurisdiction. CO 2 emitted shall include CO 2 emitted by main engines, auxiliary engines, gas turbines, boilers and inert gas generators. For ships for which reporting is based on this method, the fuel consumption shall be calculated using the measured CO 2 emissions and the applicable emission factor of the relevant fuels This method is based on the determination of CO 2 emission flows in exhaust gas stacks (funnels) by multiplying the CO 2 concentration of the exhaust gas with the exhaust gas flow The calibration methods applied and the uncertainty associated with the devices used shall be specified in the monitoring plan

19 1.1 Methods Used to determine fuel consumption of each ES 19 Chosen Methods for fuel consumption

20 1.2 &1.3 Uplifts and cross checks 20 Develop procedures for bunkering and stockstakes measurements Stating & documenting all assumptions for bunkering Stating ALL calculations and methodologies of measurements Documenting the explanation and/or Justification for choice of procedures, methodologies, parameters, key Factors Documenting external factors that may affect bunkering or measurements Bear in mind: Fuel at the beginning of period, plus deliveries, minus levels at the end of period Period means the time between two ports of call or within the port Type of fuel and Sulphur are specified Periodic stockstake is based on fuel tank readings (automated systems, soundings) Volume in Ltr is converted in tones used the density

21 1.4. Description of the measurement Instrument involved 21 It must be included: Dip tapes Automated systems used in the tanks Flow meters Temperature systems Sampling systems Name, age, technical specifications, maintenance procedures, calibration procedures, and Emission source applied to shall be recorded

22 1.5. Procedures for recording, retrieving, transmitting and storing information regarding measurements 22 How the data are being produced (BDN records, tank measurements, LOP) Where are being stored onboard the vessel (Hard copies, electronic formats) Who is the responsible person (C/E onboard, Performance Monitoring Officer) How are being processed and what controls are in place Input Controls (Measured DATA to Hard copies) Transformation Controls (error checking during the process of collating, transferring, processing, calculating, estimating, aggregating or adjusting input data) Output Controls (Comparison between input and output) How are being transmitted to the Company(Noon Electronic Reports) and With what frequency

23 1.6 Determination of density 23 Actual density recorded in BDN: (fuel suppliers to report tested as per ISO3675:1998 or ISO 12185:1996) Actual on board measurements (ISO 650:1977 hydrometers for general purposes or ISO 12185:1996 Oscillating U-tube method) Laboratory analysis (ISO 3675:1998 or ISO 3838: 1984) Standard density values As given in Petroleum measurement tables (ISO 91-1 and 91-2: 1991)

24 1.6 Determination of density (continue) 24 Actual Density is not necessary in mass flow meters How to deal with unpredictable situations Who is responsible for determining the actual density value (fuel supplier, master etc.) Controls applied for ensuring accuracy of density data The IS used for processing and transmitting actual density value How and where fuel density data is recorded Justifications where applicable for using standard value

25 1.7 Level of Uncertainty 25 The company should complete and document an uncertainty assessment for each method selected Applicable Regulation Factors affecting the uncertainly Risks related with each factor Estimated level of uncertainty per method Uncertainty values for each monitoring method

26 Applicable Regulation f (iv) of EU Reg.2015/757: Ø A procedure to be developed ensuring the total uncertainty of fuel measurements.. Annex I B of EU Reg,2015/757: Ø Ø Ø The uncertainty associated with the BDN shall be specified in the MP The method for tank sounding and uncertainty associated shall be specified in the MP The calibration methods applied for flow meters and the uncertainty associated shall be specified in the MP Article 16 of EU Reg. 2016/1928: Ø Maximum total level of uncertainty 5% accepted by the verifiers

27 Estimated Level of Uncertainty per Method of Measurement 27 BDN & Periodic Stock Takes of Fuel Tanks: Ø Beyond the control of ship s operator Ø Statistically the accuracy level is ranging between (1-5%) (bunkerspot Cardiff University) Ø Set-up an experience factor per Supplier with the aim to create ship specific estimate Ø Set-up a qualitative (e.g. high, medium, low) and/or quantitative procedure for each supplier

28 Estimated Level of Uncertainty per Method of Measurement 28 Bunker Fuel tank monitoring onboard Ø Ø Uncertainly up to 2% between the tank tables as produced by yards and the real volume as determined by ISO Standard 4269:2001 Uncertainty regarding Fuel tank readings, calibration certificates Ø Uncertainties for electronic fuel tank readings(2-5%). (CE-Delft 2013) Ø Manual tank gauges very inaccurate( ECOFYS study)

29 Estimated Level of Uncertainty per Method of Measurement 29 FLOW METERS Ø Uncertainty is estimated from % (ECOFYS 2014) Ø Install flow meters after purifiers Ø If not installed flow meters in the return line calculate the quantity with other method Ø Calculate the quantity of retaining in the filter back flushing filter Ø Calculate the oil fuel leakages

30 1.8.Procedures ensuring quality assurance of measuring equipment 30 Develop new procedures or referring to existing procedures of the company for: Ø Describing the calibration method and intervals Ø Describing the maintenance and inspection methods and intervals Ø Describing the defects and the corrections taken Ø Describing the regular accuracy checks for technical reasons Ø Describing the periodic internal audits and technical review conducted Ø Describing the appropriate training for personnel Ø Describing the software used if any and the precautions taken Ø Performing uncertainty assessments

31 D. Data Gaps 31 Develop complete back up procedures for: Ø Calculation fuel consumption Ø Calculation the distance travelled Ø Treating data gaps regarding cargo carried Ø Treating the gaps regarding the time spent at sea Be ready to justify in the annual report the reason of using the gap methodology

32 Data Gap Approaches Redundancy of systems, for delivery missing or incorrect data sets 2. Secondary system is not available 3. STANDARD DATA GAP PROCEDURE is applied: a. To reproduce an adjustment of the original data b. To reproduce data set by using another parameter or c. Alternatively using Historical data 4. STANDARD DATA GAP PROCEDURE is not available 5. Another reasonable solution

33 E. Management 33 The company should develop procedures for : 1. Data Flow activities with Regular checks 2. Control Activities for: a. Quality assurance and reliability of IT b. Internal reviews and validation of EU MRV relevant data c. Corrections and Corrective actions d. Outsourced activities e. Documentation

34 Quality Assurance and Reliability of IT 34 IT technology used for transmitting, analyzing, processing, calculating and storing data: Ø Ensure that are designed, tested, implemented, controlled and maintained Ø Reliable, accurate, and timely processing of data is guaranteed Develop controls such as: Ø Access control Ø Back up Ø Recovery Ø Continuity planning and security

35 Internal Reviews and Validation of Data 35 CHECK ON COMPLETENESS & COMPARISON OVER THE PAST YEARS SET UP CRITERIA FOR REJECTING DATA AS A MINIMUM REVIEW shall include: Ø Data completeness check Ø Trend analysis (comparison of the data over several years) Ø Comparison of data resulting from different operational data collection systems Ø Comparison of calculation factors that have been determined by analysis, calculated or obtain from the supplier

36 Outsourced Activities 36 Outsourced processes must be included in the control system such as: Ø Ø Ø Bunkering External laboratories Maintenance of measuring equipment Identify How: Ø Data flow activities Ø Control activities are checked by the outsourced processes

37 Conclusions A very heavy NEW management system is created 2. Challenging areas for Shipping with new procedures and meanings 3. Great attention should be given to the determination of uncertainties and data gaps 4. A thorough risk assessment should be developed with the aim to identify and control the inherent, control and detection risks and minimize uncertainties 5. A detailed flow chart of activities should be prepared for better control 6. Validation of the data is needed, including any predetermined materiality thresholds 7. Operational and control procedures shall be implemented to ensure the quality, integrity and security of the information 8. A well competent verifiers with a good experience on business activities is required

38 38 THANK YOU FOR YOUR ATTENTION

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