INTERNATIONAL MARITIME ORGANIZATION

E
IMO DE 47/6/3 22 December 2003 Original: ENGLISH

SUB-COMMITTEE ON SHIP DESIGN AND EQUIPMENT 47th session Agenda item 6 PROTECTION OF FUEL TANKS Double hull formulation Submitted by Germany SUMMARY Executive summary:

This document includes a proposal for relevant criteria for the protection of fuel oil tanks based on the on the principles of the probabilistic oil outflow methodology (revised MARPOL Annex I, regulation 21). Paragraph 10 DE 46/29; DE 46/INF.4; and MEPC 49/16/6

Action to be taken: Related documents:

Background 1 Large commercial ships often carry quantities of fuel that are greater than the lower limit of MARPOL 73/78, Annex I, regulation 13F or 13G requirements for the protection of cargo tanks of oil tankers. Germany therefore agrees and supports that practicable and reasonable measures should be identified and implemented for the protection of fuel tanks against collision and stranding. In the aftermath of the Erika in 2001 the matter was taken up by the MSC and included in the work programme of the DE Sub-Committee. 2 In order to promote a discussion on this issue, a document had been submitted by the Netherlands to DE 46 for relevant new MARPOL requirements in respect of double hull protecting larger bunker tanks. The Netherlands proposal (DE 46/29) is based on the formulae used in MARPOL Annex I, regulation 13F and calculates the minimum width of double hull at ships sides as a function of the deadweight of the vessel. 3 Germany strongly supports the need for this kind of measure to ensure marine environmental protection from the spillage of oil by fuel tanks. The formulation of such requirement, however, should be made based on a more sophisticated formulation than the earlier proposal to allow for a more sophisticated approach covering all kinds of ship types rather than only oil tankers. This can be achieved by making use of the hypothetical oil outflow parameter as recently developed for the revised MARPOL Annex I.

For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

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Problem 4 As mentioned above, Germany supports the proposed measure. Any formulation based on deadweight, however, in defining a required width of a double hull for bunker tanks is considered problematic for a number of reasons. Some of these are mentioned in the following to illustrate the problems with the recently proposed formula: .1 Deadweight is significantly depending on ship types. Any bulk carrier with 20,000 dwt, 600 m bunker fuel tanks and a speed of 14 knots may have more or less the same main dimensions as a passenger ferry with only 5,000 dwt, but a speed of 25 knots and 2,000 m bunker fuel tanks. With a double hull requirement based solely on deadweight, the bunker fuel tanks of the bulker would have to be protected to a greater extent than the larger ones of the ferry. This does not seem feasible. Any conversion of a built vessel would become rather difficult. For example, the lengthening of a vessel, the removal of unused cargo equipment (cranes), the construction of so-called ducktails and several other nowadays typical conversions leading to a possibly substantial alteration in deadweight (in most cases this is the task of such conversions) would become more or less impracticable, due to limitations of deadweight by the built width of the fitted double shell of bunker fuel tanks. If deadweight were to govern the size of the double shell width, this would significantly impair the conversion market. Additionally, this would also apply in cases of mere draught increases. Identical sister ships may differ in the lightship weight by more than one percent, due to changes in design of supplied equipment, tolerances in steel plate thickness and a lot of other reasons outside the responsibility of the yard. If deadweight were to govern the size of the double shell width, it will cause problems in ship designs. Basing fuel oil tank protection requirements on deadweight would generally reduce the flexibility in design within a series of ships. Within a series of ships some sister vessels might be built with a higher ice class standards, others without. Some vessels will be equipped with cargo gears, others not, etc. All these rather small differences will have impact on deadweight and they sum up. Today this is common procedure to built and employ such sister ships. In future such small changes to the construction, equipment or operation of any vessel may necessitate additional changes of the interior design of a vessel, if bunker fuel tank protection requirements were to be based on deadweight. In design stages there is also the problem of the accuracy of light ship weight estimation. When building a new first vessel, the design (workshop drawings, especially for equipment and machinery) and the construction of the first vessel is going more or less parallel. Due to this the yard is making a weight estimation of the whole vessel at the beginning of the project. This estimation is more or less accurate and will be amended through its construction. Some times the light ship weight will be overestimated. Today, this would result in additional deadweight, and the vessel will be considered a more efficient design due to its higher earning capacity. If fuel oil tank protection requirements were based on deadweight it would create a problem in this respect.

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DE 47/6/3

5 Any double hull requirement for very small oil tanks [<30 m] is considered to be problematic as well. A lot of small operationally required tanks must be fitted in the double bottom of engine-room at the lowest point of a system (for example lubrication oil circulation tanks, drain tanks, etc.). If double hull will be required for this kind of very small oil tanks, the design of engine-rooms must be changed significantly, engine-rooms would become inadequately larger. Worked example 6 On a German ship yard a number of ships, admittedly the sample consist of different sizes of tankers, have already been built with fuel tank protection even though there is not yet any requirement in place for fuel tanks on tankers not located within the cargo tank length. In the annex details of built ships are presented as an example. Proposal 7 MEPC 42 has approved guidelines that describe the procedures for obtaining approval of alternative tanker designs to double hull standards on the basis of probabilistic outflow performance standards. MEPC 49 has also approved a simplified outflow analysis approach to replace the current hypothetical outflow regulations 22 to 24 of MARPOL Annex I. 8 Adopting a performance-based criterion such as the proposed approach based on the principles of the probabilistic oil outflow methodology gives the designer and future operator the freedom to optimise the fuel tank arrangement with regard to requirements of design and operational considerations, while assuring an environmentally sound standard taking into account the specific tank sizes and their location relating to the overall risk. 9 Germany therefore proposes that a performance-based standard be developed based on an approach as described in the two related MARPOL requirements, i.e. the guidelines developed for MARPOL Annex I, regulation 13(7) and the revised hypothetical outflow regulations 22 to 24 of MARPOL Annex I. Action requested of the Sub-Committee 10 The Sub-Committee is invited to note the above information and take action as considered appropriate. ***

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ANNEX
LINDENAU GmbH Schiffswerft & Maschinenfabrik

DE 47/6/3
Ship Nr. S 245 S246 First delivery Description

Deadweight 12000 tdw

Type

Lpp

B 24,0 m

H 12,35 m

Draught 8,38 m

HFOCapacity 739 m

Chemical 115,06 m Tanker Type 2 /Product Tanker

1997 Double Hull covers the HFO Tanks against side shell. The Double Hull space is open to Engine Room. Distance of Double Hull to side shell is 800 mm at minmum.

32300 tdw

Oiltanker / Product Tanker

168,0 m

28,0 m

16,8 m

856 m

S 254

S240, S241, S242, S244, S256, S270

1996 Double Hull covers the HFO Tanks against side shell. The Double Hull space is a closed void space. Distance of Double Hull to side shell is 800 mm at minimum.

8000 tdw

Oiltanker / Product Tanker

110,4 m

18,0 m

9,4 m

7,4 m

499 m

S260

S261, S262, S263, S 264, S 265

2002 Double Hull covers the HFO Tanks against side shell. Parts of Double Hull spaces are closed void spaces, others are open to the engine rooms. Distance of Double Hull to side shell is 800 mm at minimum.

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LINDENAU GmbH Schiffswerft & Maschinenfabrik

12326 tdw

Chemical 135,7 m Tanker Typ 2/ Oil Tanker

19,6 m

10,65 m

8,37 m

441 m3

S 227

S216, S219

1984

MDO Tank covers the HFO Tanks against side shell. Distance of Double Hull to side shell is 800 mm at minimum.

23480 tdw

Chemical 166,0 m Tanker Type 1/ Oil Tanker

24,6 m

13,5 m

10,33 m

1062 m3

S 234

S235, S236

1991

MDO Tank covers the HFO Tanks against side shell. Distance of Double Hull to side shell is minimum 800 mm

13050 tdw

Chemical 138,5 m Tanker Type 2 /Product Tanker

19,6 m

10,65 m

8,36 m

414 m

S 250

S247, S248, S249

1998

MDO Tank and Void space covers the HFO Tanks against side shell. Distance of Double Hull to side shell is minimum 800 mm

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