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MFM bunker value chain question TR48 compliance findings of VPS

12 Feb 2018

A group of stakeholders representing various aspects of the bunker supply value chain in Singapore have risen to comment on a recent find by fuel testing and inspection firm Veritas Petroleum Services (VPS) regarding TR 48 compliance on mass flowmeter (MFM) bunkering.

A VPS circular recently said the company’s MFM Quick Screen service found 28% of MFM bunker deliveries at Singapore not in compliance to TR 48 standards when taking into account 23 parameters.

It also pointed out the average discrepancy to be a shortage of 67 metric tonnes (mt) per investigation, following further checks.

“VPS' findings seem to suggest the situation now is worse than before MFM was mandated in Singapore when we used to carry out manual tank gauging for bunker measurements, which is a misleading statement to make,” says Douglas Raitt, the regional consultancy manager at bunker fuel analysis and advisory service firm Lloyd’s Register FOBAS, Singapore.

“The 28% non-compliance rating of TR48 can cover all manner of sins. It is unclear whether the figure includes lack of compliant paperwork on tankers, short deliveries, incorrect meter readings, or others. The 28% statistic should be meaningfully broken down for a clearer explanation to the industry at large.”

Raitt also pointed an issue in VPS’ findings of an average 67mt fuel shortage after investigations.

“What was the basis to claim the short loadings? Were these calculated using manually sounded figures from the receiving vessel’s bunker tanks and compared to meter readings? This is not clear in the VPS circular. In any case, comparing vessel sounding figures with meter reading delivery figures is not in line with TR48. It is common knowledge [in the bunkering industry] that a receiving vessel’s fuel tanks are not necessarily reliable reference points.

“If we are calculating the 67mt difference from the receiving ship’s fuel tanks you are actually comparing arbitrary and manually obtained measurements against the true measurement obtained by mass flowmeters.”

Darrick Pang, Managing Director of MFM consultancy firm Metcore International and bunker surveying firm Metcore Inspection Services was curious about VPS’ figures.

“It will be interesting to understand how the shortage quantity [67mt] mentioned from VPS’ investigations are established including the criteria to determine a 28% failure to comply with TR48," he says.

“As we know, all MFM systems installed on bunker tankers in Singapore have undergone a very comprehensive and rigorous testing process in accordance with TR48:2015 in order to obtain approval for custody transfer operations by MPA.

“What is happening in the field might not be visible to an analyst, therefore it is critical to have bunker surveyors with the trained knowledge  in order to secure the measurement integrity of the whole operation. This is something that Metcore Inspection Services place a lot of emphasis on from the beginning.”

The findings, meanwhile, did not deter Singapore bunker supplier Fratelli Cosulich in using MFM technology for bunkering operations, says the CEO and Board Member of the Fratelli Cosulich Group of Companies.

“We [Fratelli Cosulich] have full trust on the accuracy of MFM and we regularly verify the accuracy of our equipment to make sure that our clients receive the correct quantity,” he told Manifold Times.

“I cannot comment on VPS claims specifically because very rarely we have had a VPS surveyor on board our vessels.

“In order to correctly interpret VPS’s findings it is absolutely necessary to know what irregularities they specifically talk about.

“It is very important for example to differentiate between substantial irregularities [e.g. inaccurate quantity supplied] from ‘formal’ irregularities [e.g. a missing signature or a procedure not 100% followed].”

The Business Process consultant for bunkering and fuel supply chain at MFM manufacturer Endress+Hauser (E+H), meanwhile, believes VPS’ report can be further improved.

“From a meter vendor point of view, we encourage professional initiatives from surveying companies who have decided to move ahead with the MFM technology to support the bunkering industry,” says Mohamed Abdenbi.

“In fact, in today’s fast pace tech world, the early adopters can be the leaders of tomorrow. VPS is one of those companies that have identified this opportunity and started offering their MFM evaluation service offerings to their customers.

“However, we have several times been asked for help to look at VPS quick screening reports and found out that they lacked clarity and understanding of the MFM system as well as the bunker operation procedures. The report quality has to be improved and maintained over time.

“We also would like to emphasize that at the end only manufacturer specialists who understand the MFM system can correctly interpret the signals and the reaction of the system in details.

“After all we could imagine that third party specialists are trained and certified by the manufacturer themselves for analysing recorded MFM data.”

Seah Khen Hee, a Singapore industry pioneer who led the MFM project and is instrumental in developing the principles, requirements and procedures of TR48:2015, believes relevant industry stakeholders should meet VPS for "further dialogue".

"I have been very encouraged by the positive feedbacks and comments from across the shipping and bunkering communities on TR48:2015 since its recent implementation," he says.

"After the VPS Circular came out, the industry would like to understand how VPS arrived at their findings on non-compliance and discrepancies. 

"Relevant experts should meet VPS for further dialogue and assist with positive progress.

"Bunker surveyors have an important role to play in providing vigilance to the MFM bunkering process, especially on metrology and security requirements and metering procedures.

"Indeed, all industry users of TR48 need to correctly understand and properly apply TR48 for best outcomes. 

"More can be done to reach out to the shipping and bunkering industries worldwide on training and education."

Related: VPS, CMA CGM collaboration evaluates Singapore MFM compliance

Published: 12 February, 2018

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