E

SUB-COMMITTEE ON POLLUTION PPR 3/18/1

PREVENTION AND RESPONSE 11 December 2015
3rd session Original: ENGLISH
Agenda item 18

UNIFIED INTERPRETATION TO PROVISIONS OF

IMO ENVIRONMENT-RELATED CONVENTIONS

Clarification on regulation 36 of MARPOL Annex I for categorizing offshore terminal

(Single Point Moorings (SPMs) or Conventional Buoy Moorings (CBMs)) line flush with
seawater as part of tanker cargo/ballast operations in the Oil Record Book

Submitted by the Oil Companies International Marine Forum (OCIMF)

SUMMARY

Executive summary: This document seeks to clarify the appropriate cargo/ballast

operation category of offshore terminal (Single Point Moorings
(SPMs) or Conventional Buoy Moorings (CBMs)) line flush with
seawater that occurs during routine cargo transfer operations
on board an oil tanker under MARPOL Annex I

Strategic direction: 1.1

High-level action: 1.1.2

Output: 1.1.2.3

Action to be taken: Paragraph 13

Related documents: None

Background

1 During the course of normal cargo transfer operations at offshore marine terminals
(SPMs and CBMs) and upon completion of cargo operations, the subsea hoses and fittings
may remain filled with oil or upon request from the terminal and following good industry
practice, they may be filled with sea water while idle or when having maintenance conducted
upon them. This is primarily achieved by back flushing from the tankers cargo manifold and it
is a long established industry process.

2 Subsea hoses and fittings may be filled with seawater in order to mitigate pollution
risks to the marine environment from potential leaks from subsea fittings, hoses and pipelines
and/or for safety during maintenance activities.

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3 Newly built offshore terminals are encouraged to adopt a design that allows
recirculation through the hoses to the shore, however, many existing terminals do not have
a recirculation facility. Subsequently, shipboard tanker cargo/ballast operations require the
management of the line flush seawater in accordance with MARPOL Annex I with appropriate
entries made in the Oil Record Book (Part II). However, this poses a practical challenge as
flush water (seawater) is not defined under MARPOL Annex I, although it is clearly an oily
water mixture.

4 OCIMF invites the Sub-Committee to review the attached annex (OCIMF Single Point
Mooring Maintenance and Operation Guide – 3rd Edition 2015 – chapter 4.7) as background
reading of the industry good practice guidance (the full document is available from Witherbys
Publishing).

Discussion

5 The use of seawater for line flushing to offshore marine terminals (SPMs and CBMs)
is a recognized shipboard operation which ensures safety and increases environmental
protection by displacing the line content with seawater in order to leave the idle hose full of
water rather than cargo. Prior to the next use of the hoses for cargo transfer, the seawater and
any cargo residue left in the idle hose is commonly loaded to the ship's slop tanks to avoid
contamination of the main cargo transferred.

6 It is important to note that the operation being described under this unified
interpretation, for the purpose of clarity, is very specific to that of displacing the cargo from the
hose string with seawater while idle or for maintenance purposes. The draft unified
interpretation is not intended to be applicable to what might be considered as similar operations
at Floating (Production) Storage Offtake units (F(P)SOs) involving production, commissioning
or decommissioning water and which therefore, may include other products than just cargo
residue and seawater.

7 To best promote effective and consistent implementation of regulation 36.2 of

MARPOL Annex I and completion of the Oil Record Book, it is proposed that clarity is needed
on the correct management of these oily mixtures. Additionally, a common understanding on
this issue among all stakeholders will alleviate any confusion which could lead to unnecessary
delays through violations or detentions.

8 The line flush consists principally of seawater and the possibility of oily mixture from
cargo residue. The quantity of the line flush should be recorded and disposed of in accordance
with MARPOL legislation.

9 The challenge that OCIMF has identified comes when the tanker arrives at the
discharge terminal where some terminals/local authorities are reluctant to accept the line flush
due to the unspecified and undocumented composition of the content. However, OCIMF
contends that the composition of the content is known and thus should not present an issue.

Proposed unified interpretation

10 To avoid making any amendments to a mandatory instrument, it is the view of OCIMF

that this issue can be addressed by categorizing this flush water (seawater) under MARPOL
Annex I, regulation 36.2.10 "Disposal of residues".

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11 Furthermore, the Oil Record Book (Part II) should include an entry under Item J. It is
suggested that the entry uses wording similar to the example below in order to remove any
uncertainty:

.1 at load port where flush water is received by the tanker, use the suggested
wording for remarks:

(J) At the request of (terminal xxxxx) a quantity of flush water

(sea water) has been loaded into the ship's tanks as per item J 56
and J 55. Terminals certificate of origin attached;

(J) 55 Port Slop tank

56 220 m³ flush water
57.3 transferred from (terminal xxxxx) SBM hoses; and

.2 at discharge port where flush water is disposed of by the tanker:

(J) 55 Port slop tank

56 220 m³ flush water
57.1 Disposed to (terminal xxxx) reception tank 220 m³ (receipt
from reception facility attached), or
57.2 220 m³ flush water mixed with cargo (receipt from reception
facility attached).

Additional recommended best practice

12 It is considered good practice that a receipt describing the line flush should be
provided by the terminal operator to confirm the contents as seawater and cargo residue and
therefore considered as cargo slops and not part of the cargo according to the provisions
of MARPOL.

Action requested of the Sub-Committee

13 The Sub-Committee is invited to:

.1 consider the analysis and comments provided above;

.2 consider the proposal in paragraphs 10 and 11 above with respect to line

flushing, designation of oily mixtures and appropriate documentation within
the Oil Record Book (Part II); and

.3 take action as appropriate.

***

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ANNEX

EXTRACT FROM OCIMF PUBLICATION

SINGLE POINT MOORING MAINTENANCE AND OPERATIONS GUIDE (SMOG),

THIRD EDITION 2015

"4.7 Line flushing operations

Serious incidents have occurred during line flushing operations at SPMs through the lack of
effective controls, non-adherence to procedures and the use of inappropriate equipment.
Because the use of water is thought to be safe, terminals may have underestimated the
hazards and consequences.

Terminals should have a documented philosophy for water flushing, which should include:

o Applying a hazard and operability (HAZOP) analysis.

o Referring to a process flow diagram of the infrastructure, from the pumping
source to the final containment, including any support vessel or tanker systems
involved.
o Using written working procedures, including controls and communication.

4.7.1 Flushing

Water flushing is commonly carried out to evacuate petroleum cargoes from SPMs before any
of the following operations:

o Maintenance and inspection.

o Replacement of hoses.
o Disconnection of hose strings.
o Hydrostatic testing.
o Inspection of pipelines, such as by intelligent pipeline inspection guide (pig).

Flushing may also be required to prevent environmental pollution.

A small number of terminals routinely flush SPMs after each cargo operation. Typically, these
terminals have procedures with the following precautions in place for tankers to carry out
a flush on completion of discharge:

o Tanker nomination and acceptance criteria for flushing.

o Flush operation procedures.
o Shore tanks and terminal systems to handle free water.
o Corrosion protection throughout the cargo system.
o Cargo measurement and quality procedures.

4.7.2 Ensuring an effective flush

Terminals should develop procedures for an effective flush that removes all petroleum
residues. Procedures that should be taken into account include:

o Minimum volume.
o Pressure.
o Flow rate.

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o Previous cargo and time in the pipeline.

Some terminals have successfully used gel pigs to ensure an effective flush using the minimum
volume of water.

4.7.3 Flushing from support vessels

Support vessels that are required to carry out flushing operations should be designed,
equipped and manned to carry out the operations safely.

Traditionally, flushing was carried out from or to tankers. It is now more common for flushing
to be carried out from support vessels because of the changes in tanker ballast systems and
the difficulties caused by tankers retaining oily water on board.

The following precautions should be considered before any flushing takes place from a support
vessel.

4.7.3.1 General precautions

Support vessels should have a flushing system that complies with the following requirements:

o The pump and piping should be fit for purpose and designed to deliver the
required pressure and flow rate.
o The flushing system should be independent of, and physically isolated from,
any other system.
o The system should be designed with a physical means of preventing the
backflow of petroleum liquids and gases into the support vessel.
o A pressure/vacuum gauge should be fitted in a position where it will reliably
indicate the pressure before valves to the hose connection are opened.
o Flush system components should be rated at a pressure that is consistent with
the maximum working pressure.
o Ventilation systems to the accommodation and machinery spaces should not
permit the ingress of vapours from the working deck or flush pump area.
o The flush system should be independent of the firewater system, so that the
firewater main may be kept pressurised and ready for use.

Terminals should comply with the following requirements regarding support vessel charters:

o Terminals should have in place criteria for accepting support vessels.

o Contract terms should be in place.
o Support vessels should be specified, manned and equipped to undertake line
clearance activities in accordance with the terminal's procedure.
o The support vessel should be positively examined to confirm it is consistent with
the inputs and findings from the HAZOP.

Before any flushing operation commences the following should be in place:

o A written procedure that the support vessel's Master and crew are familiar with
and have agreed.

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o The terminal's procedure should be reviewed and signed off by all the relevant
disciplines involved in the activity, including:
 Terminal operations.
 Maintenance.
 Process engineering.
 HSSE.
 The support vessel’s Master and/or Operations Superintendent.
o Single point accountability for the activity should be established within the
terminal operations and maintenance disciplines. Under no circumstances
should a support vessel's marine contractor conduct flushing without effective
operational control and oversight from terminal personnel.
o Effective communications should be established between the operation
locations, for example the SPM, support vessel, tank farm and control room.
o Support vessel crews should be specifically trained in flushing operations,
including an awareness of ISGOTT (Reference 12) and the basic hazards of
petroleum.
o Support vessel crews should complete their own job safety analyses and risk
assessments.
o The flush pump should be started and pipework pressurised before valves to
the hoses are opened.
o Where line clearance is to a tank, the tank should be at as low a level as
possible to minimize back pressure. In any event, the maximum back pressure
should be documented in the flush procedure."

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