Developments in LNG regulation
Jose Navarro, Global Gas Technology Specialist at Lloyd’s Register has shared his insights on the LNG regulation landscape with The Motorship at GasTech in Houston.
The rapid growth in interest in LNG as a solution to the IMO’s 2020 global sulphur cap regulations, and further ahead as a potential transition fuel as the IMO works towards its ambitions for 2030 and 2050, is placing attention on the regulatory landscape for LNG as fuel.
“Recently during CCC6, differing interpretations of The International Code of Safety for Ships Using Gases or Other Low-Flashpoint Fuels (IGF Code) and the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) were discussed,” Navarro, LR’s South Korea-based global technical lead on LNG vessels, noted.
One example case was the potential for different interpretations on how to calculate the “critical pressure” of the gas when reading both Codes, with some Flag State Administrations settling on 45 bar and others identifying 180 bar as the maximum.
More broadly, the potential for divergent interpretations was a risk for OEMs and other suppliers. Navarro cited the implications for OEMs developing double wall pipe for the supply of gas as an example of the knock-on effects of the uncertainty.
“The effects extend from bunkering operation, through the supply of fuel to engines. The possible impact stretches across the LNG solution,” Navarro said.
The application of different interpretations in the negotiation of future shipbuilding contracts is a risk factor for shipowners. As shipyards have identified the risk that criteria could be interpreted in different ways, the cost of the outcome of the risk assessments is being passed on to shipowners in shipbuilding contracts.
LR has been collaborating in joint development projects around LNG carrier and LNG-fuelled ship designs. “If we are able to de-risk that variation through a joint development project through the standardisation of designs, that would be a benefit for the shipyards, and shipowners.” Navarro noted.
The outputs from the projects were expected to be discussed at IACS, along with insights from similar projects being undertaken by other classification societies. A significant set of JDPs agreed in September are due to deliver results by March.
Safety and environmental aspects
While resolving potentially divergent interpretations between the IGF Code and the IGC Code was part of the regulatory agenda, LR’s experience of collaborating on shipbuilding projects had deepened its understanding of safety issues. “Just look at how section 9.1 of the IGF Code has developed since its first iteration,” Navarro said, citing the addition of requirements to prevent leakages, and restrict venting.
The increasing focus on environmental issues and technological innovations within the industry overall was also occupying LR’s attention.
Navarro noted that the implementation of solutions to manage boil-off gas (BOG) aboard was increasingly important, as public opinion was increasingly likely to take a critical perspective on venting and any possible fugitive leaks.
A range of solutions ranging from gas combustion units (GCU) through to more sophisticated reliquefaction systems were possible.
Navarro also noted that there was a difference between regulatory and operational requirements. While the regulatory requirements regarding BOG stipulate the containment system should be sufficient to manage the BOG for 15 days, some of the latest generation of ultra large container vessels are being built with a single bunker strategy for a 45-day round trip between East Asia and the port of Rotterdam. Another area where LR was able to contribute was in well supply system design requirements.
“These are examples of how we seek to reconcile the competing demands of enhancing safety, minimising environmental impacts with reducing costs for our customers,” Navarro said.
The rapid pace of technological development in LNG containment systems, and advances in digitalisation tools and modelling is creating new opportunities for classification societies.
The sophistication of containment system monitoring solutions had increased rapidly in the last decade or so. In fact, the sophistication of LNG gas protection systems (as well as the emergence of digital twin models) means that any damage within the containment system would be detected without the need for a physical inspection.
One of the coming opportunities was whether classification societies could reduce the requirement for physical inspections, whilst maintaining the same level of safety as per the current regulatory requirements. The benefits would go beyond increased operational availability, Navarro noted.
Simply by reducing the requirement for tanks inspections during dry dock from five years to every seven and a half years, it would be possible to reduce the inevitable GHG emissions associated with such inspections by a third over a 15-year period.
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