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NEED FOR A COMPREHENSIVE “OSV CODE”

Arun Kr Dev

*School of Marine Science and Technology, Newcastle University, UK Newcastle University Marine International (NUMI) – Singapore

E-mail:a.k.dev@ncl.ac.uk

Offshore support vessels, since its introduction, could now easily be more than 60 years in operation. Over these years, these specialized vessels have served offshore oil and gas industry all over the world from benign to harsh environments. These vessels of various types, sizes and functions have been subject to all kinds of relevant rules and regulations promulgated by IMO mainly through SOLAS and MARPOL respectively. Compared to fishing vessels, which do not come under SOLAS, these OSVs not being trading vessels as well as not fitting to any particular type like a cargo or a passenger vessel, have rather been sandwiched happily between the two including all associated codes for cargo vessels as tankers, bulkers, chemical tankers, etc. The author has been involved in design and construction of these OSVs of various types for more than a decade. But to him, the rationales behind treating these vessels with all kinds of relevant rules and regulations of IMO in their entirety still remain a mystery. This adherence exercise only causes monumental challenges for designers, builders and owners. In order to ease the design, construction and operation of these OSVs, it is now time for a comprehensive code “OSV Code” like what exists for offshore platforms/rigs, a “MODU Code”. The existing code “IMO Res. A863(20) Code of Safe Practice for the carriage of Cargoes and Persons by Offshore Supply Vessel (OSV code)” is, at its present condition, not sufficient enough to deal with many complex situations.

INTRODUCTION

Offshore Support Vessels (OSVs) originate in Gulf of Mexico (GoM) perhaps in fifties. In those days, many work boat type vessels including mainly fishing vessels were used to maintain supply of cement, mud, fuel, water, food and crews to offshore platforms/rigs. Then came purpose-built OSVs still resembling very much of a fishing vessel with a raised deck in fwd and a working cargo and equipment deck in the aft. This concept till date follows for almost all OSVs. But operational requirements make them more action oriented type like anchor handling, towing, emergency responses like fire fighting, standby, rescue, anti-pollution, dynamic positioning, etc. Most of Offshore Support Vessels almost look like a “pick-up truck” [1] as the whole accommodation block of superstructures and deckhouses are situated right in front of the vessel having a large working/cargo carrying deck space in the aft of the vessel.

Proc. of the 4th Intl. Conf. on Technology and Operation of Offshore Support Vessels (OSV Singapore 2011) Edited by Arun Kr. Dev and Seref Aksu

Copyright c 2011 OSV Singapore 2011. Published by Research Publishing. ISBN: 978-981-08-9731-4 :: doi:10.3850/978-981-08-9731-4 OSV2011-16

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Many recent changes in rules and regulations by IMO [2] for merchant ships have affected OSVs much more as they are definitely not merchant ships; at least not trading between one port to another. Coupled with the difficulty in being categorized, OSVs tend to encounter more red tape as they need to satisfy more stringent requirements. This paper will outline the situation faced by the OSV sector mainly designers/builders/owners and champions for a comprehensive “OSV Code”. With the demand of both exploration and production in deep waters, there has been a remarkable effect on OSVs’ size and propulsion engine power as well. The surge in growth of OSVs started in the beginning of 2000 and dominated for some time. But with the introduction of many new rules and regulations for merchant ships, they are affecting these smaller type of vessels compared to tankers, bulkers, containers, etc. There is always a grey area to define these OSVs into an appropriate category and as such these OSVs have to satisfy many excessive rules and requirements compared to many other ship types.

BACKGROUND

OSVs and IMO Rules & Regulations

Offshore support vessels now operate almost all over the world including even arctic areas in a certain part of the year. Because of their size, typical layout, functional requirements, etc., the designers/builders/owners always face a lot of avoidable challenges because of lack of definitive rules and regulations similar to a “MODU Code” laid down for offshore drilling platforms/rigs. All existing IMO rules and regulations mainly SOLAS, MARPOL, some important resolutions, circulars, codes and conventions for various categories of merchant ships have been used for these passenger vessels with frequent doubts on their interpretation and application. Clearly offshore support vessels are misunderstood while understanding the main intention of the rules and regulations as applicable for a general cargo vessel. Due to this misunderstanding, the application of certain part of SOLAS is often questionable and rather inappropriate for design, construction and operation of OSVs. Though these vessels mainly fall into the cargo ship category, they sometimes carry more than 12 passengers (often known as special personnel) resulting them neither a cargo vessel nor a passenger vessel but a special purpose ship (SPS) using an IMO Res. A534(13) adopted in 1983 meant to serve the purpose. The afore-mentioned resolution is now superseded by the “Code of Safety for Special Purpose Ships, 2008, IMO Res. MSC.266(84)” adopted in 2008.

International Classification Societies and Flag State Administration

Most international classification societies as well as flag state administrations are following IMO applicable rules and regulations for such vessels. DNV [3] has, in addition, come up with many new optional notations for OSVs like “comfort class’ requirements for crews though IMO has its own Code on noise and ISO have its requirements on vibration. In line with green ship technology requirements for friendly environment, DNV has also introduced “CLEAN” and “CLEAN DESIGN” notations, in addition to MARPOL requirements. Besides, DNV has come up with bridge layout requirements as NAU-OSV, HIL (Hardware in-loop) in connection with a ship’s automation and control, etc. These newly introduced notations purely as voluntary schemes have pushed more innovative design solutions in Norway for the North Sea, which have resulted many sophisticated OSVs compared to OSVs in the rest of the world. After the capsize of the AHTSV “Bourbon Dolphin”, NMD has also come up with new stability criteria for towing and anchor handling, which are an addition to IMO’s mandatory

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requirements of intact stability, IS Code, 2008. But these new additional requirements are complimentary for the safety of such vessels and their crews. Such additional stability of AHTSVs, as well as TUGs, is not part of IMO’s stability criteria in IS Code, 2008.

Problem Definition

Though not a trading vessel, but due to its inherent operational requirements, OSVs come under all sorts of relevant rules and regulations in the form of conventions, resolutions, circulars, codes, etc. of IMO, which are enforced through flag states and international classification societies. But being smaller in sizes, mostly less than 100 meters (for AHTSVs, AHTs, PSVs), these vessels are subject to challenges for compliance with many such rules and regulations in their entirety, which may not be so crucial for OSVs. As a result, designers, builders and owners constantly face challenges with OSVs when nowadays more and more rules and regulations are initiated for safety and environmental issues.

State of OSV Industry

There could now be more than 6000 OSVs of various categories (AHTSVs, PSVs, AHTs, MPSVs, DSVs and others) though more than half of them are mainly AHTSVs, PSVs, AHTs and MPSVs. The rest comprise other categories like construction, pipe laying, cable laying, crew boats, accommodation barges, etc. Quite a large percentage of these vessels are also now more than 25 years old thus pushing for replacement. The last decade saw the highest deliveries of these vessels. Typical OSVs are being slowly phased out with more PSVs with many of them even being constructed as all diesel electric marine propulsion (A-DEMP). There is a surge also in MPSVs for specific projects where these can be used as multi-tasking functional. Many of these vessels might even require some kind of retrofitting for compliance with new rules and regulations or even embracing green ship technology. Further, deepwater E&P is also pushing for OSVs suitable for deepwater operations. These are naturally larger and higher capacity OSVs and these may again be subjected to more stringent rules and regulations especially when more and more of such rules and regulations are now going to be implemented.

In the past, AHTSVs were mostly in the range of 60 – 80 tonnes bollard pull (BP). But now many of them have surpassed 100 tonnes BP and gone mostly for 120 – 160 tonnes BP. And some even 200 tonnes BP or even more but their number is limited. Large power requirements again pushed for 4 main engines for conventional mechanical marine propulsion system (C-DMMP) and in some instances to hybrid diesel electric marine propulsion (H-DEMP) especially to achieve large bollard pull. PSVs also have grown in sizes looking for deck area close to 800 - 1000 square metres and deadweight of 4000 - 4500 tonnes.

Typical Challenges

Challenges are multi-fold for the reason that these offshore support vessels need to satisfy all IMO initiated rules and regulations for many types of vessels like cargo, passenger, etc. and codes like IBC, INL, new intact stability code, new damage stability requirements, all changes/additions in SOLAS, all changes /additions in MARPOL and many more. In addition to these, there are things like anchor handling, towing, dynamic positioning, fire fighting, etc. It is not just simply dealing with a particular type of vessel or dealing with a particular code. There are too many to be fulfilled at “one go”. Finally, climate changes due to GHG (Green House Gas) and introduction of GST (Green Ship Technology) are also putting existing challenges for many years already to be further complicated.

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Possible Solutions

Fishing vessels do not come under SOLAS. What are then the reasons that these non-trading offshore support vessels limited to coastal and offshore waters of a particular country are being subjected to rigorous rules and regulations in multifarious ways? It could be acceptable on the fact these vessels require a higher degree of safety and environmental concerns as they are close to offshore oil and gas platforms. If that is the case, why there could not be then some degree of compromises as to the full conformance of the relevant rules and regulations to be applicable to OSVs? If so, why this relaxation could not be compiled in a single comprehensive code called the “OSV Code”?

IMPORTANT CHANGES

Hull Structure

Like any other vessels, all OSVs should satisfy the existing hull structure requirement as a safe and sound vessel from the structural point of view. There should not be any kind of compromise for OSVs as these vessels are used in various parts of the world. However, if the service is restricted for the life of the vessel, an acceptable margin in scantlings may be permitted as per any international classification society’s rules for required SF (shear force) and BM (bending moment) based on their lengths.

Stability

The ILLC 1966 and SOLAS 1960 are some of the main instruments for statutory requirements as regard to stability and safety of the vessel is concerned. Due to the inherent shape and layout of the OSV, IMO adopted in 1981 the “IMO Res. A469 (XII) Guidelines for the Design and Construction of Offshore Supply Vessels” as these specialized vessels differ significantly from a typical merchant ship. The changes proposed in stability requirements significantly differ from the original requirements as stipulated in IMO Res. A167 because of simple reasons of impracticability in compliance. Similar changes were made for even subdivision rules and damage stability criteria. This very single shift was certainly a welcome event for OSV designers/owners/builders. But then again came new changes mainly damage stability criteria, which again becomes complicated when more than 12 special personnel are carried on board an OSV. IMO Res. MSC.235(82) now supersedes IMO Res. A469(XII).

Proposed Changes:

• Previous subdivision rules and damage extent for up to vessel length of 100m. New probabilistic damage stability rules should apply to vessels over 100m in length.

• The above is also applicable even if the vessel carries up to 50 special personnel.

• Progressive incremental requirement of probabilistic damage stability criteria (R-value) for special personnel from 51-100, 101-150, 151-200 and above 200.

• Because of some operational requirements like anchor handling, towing, fire fighting, etc., new stability criteria also need to be included.

Oil Pollution (FO Tank Protection)

Reference is made to MARPOL Annex I Reg. 12A and IMO MEPC 141(54). Most OSVs run on MDO (Marine Diesel Oil) including some on MGO (Marine Gas Oil) which are different from bunker fuel.

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Restricting these vessels to carry less than 600 cubic meters in order to carry FO in the wing and double bottom tanks is an extreme requirement. Most of the OSVs nowadays are larger in size compared to before and as such they normally require larger FO capacity.

Proposed Changes:

• It is, therefore, necessary to make some relaxation in the capacity to change to 1000 cubic meters in place of 600 cubic meters so that most of the OSVs can still carry FO in wing tanks as well as in DB tanks.

Emission Control

Revised MARPOL Annex VI regarding NOx, SOx and CFC control are welcome to battle climate change. OSV industry should embrace such a fundamental shift to become environment friendly.

Hazardous and Noxious Liquid Substances

In OSVs as well as on offshore platforms, liquids considered hazardous and noxious have been an important part of the offshore industry. Main and typical categories are methanol, polymerized chemicals, dangerous backloads like drill cuttings with crude, etc. The present practice of carrying noxious liquid substances in OSVs are controlled by “IMO Res. A673(16) Guidelines for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk on offshore support vessels”. IMO introduced this separate guideline due to the increased demand in the offshore industry for servicing and resupplying drill ships and rigs. This is again a shift in IMO’s actions to facilitate required supplies to rigs for E&P activities.

The hazards related to backloads remain also an important challenge to resolve for OSVs. While an OSV is mainly suitable for carrying liquid mud, brine, ethanol, etc. to offshore platforms, it is not certainly suitable for back loads of drill cuts mixed with all kinds of hazardous and noxious liquid substances, sometimes with the flashpoint less than 600C. As said earlier, the construction of the cargo tanks and the associated pumping systems are catered for oil having a flash point above 600C. As such, major design changes have to be made for carrying low flash point backloads. This will require again changes in the present IMO Res. A673(16).

Proposed changes:

• The interpretation of limited quantities to be any amount not exceeding 1000 cubic meters or a volume in cubic metres equal to50% of the OSV’s deadweight based on specific gravity of 1.0. • New rules and regulations for carrying backloads from offshore platforms either in existing

OSVs and or to introduce a new type of OSV exclusively meant for carrying backloads.

Dangerous Goods

Present rules and regulations of MARPOL Annex III deal with carrying dangerous goods in packaged form, which are mostly carried on the cargo deck aft. The present practice in line with “IMDG Code” does not pose any design problems to take into account in the safety construction of the vessel.

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Climate Change and GHG

The roadmap from Kyoto to Copenhagen and then to Cancun have somehow raised the awareness of the effects of shipping on global climate change phenomenon. It is a clear signal to IMO to deal with climate change challenges in relation to international shipping. Two important aspects of IMO MEPC 60 and MEPC 61 are EEDI (Energy Efficiency Design Index) and EEOI (Energy Efficient Operational Index), which are mainly technical and operational measures. These measures include efficient and lower emitting propulsion systems, clean fuels, exhaust treatment, etc. Operational measures could be a reduction in speed, voyage routeing, cold ironing or onshore power, etc.

For OSVs, which are engaged in short voyages in coastal and offshore waters, introduction of such indices are not suitable and could be debateable in their application.

Proposed Changes:

• Proposed changes need to be made for EEDI and EEOI formulae to suit design and operation of OSVs.

Ballast Water Management Convention

The above convention, adopted in 2004 and yet to be implemented, is again a serious pose for technical design of OSVs when there are less or no available spaces for installing new equipment on board such vessels where spaces are to be used carrying cargoes. Not being a traditional trading vessel, an OSV is then in no need of fulfilling such additional convention for compliance.

Proposed Changes:

• Changes to be made for OSVs.

Ballast Water Tank Coating

The Performance Standard for Protective Coatings (PSPC) through IMO Res. MSC.215(82) and MSC.216(82) again apply to all ships with more than 500 GT. So, these are also applicable to OSVs. Again, fishing vessels are exempted from IMO PSPC. However, there are still some grey areas for considering ballast water tanks in OSVs as dedicated ballast water tanks as these tanks are also sometimes used to carry drilling fluids.

Proposed Changes:

The IMO PSPC requirements should not be applicable to OSVs in the absence of any clear-cut definition of dedicated ballast water tanks.

• If so, even then, the 15 years period should be brought down to 5 years or so and major changes to be made in surface preparation requirements as well as in main coating system.

Maritime Labour Convention

The above convention adopted in 2006 by ILO [4] is yet to be implemented. Similar to fishing vessels, MLC 2006 should not be extended to OSV. The present ILO 92 and 133 should be sufficient enough

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for OSVs. According to the new Convention, serious effects will be on OSV design to accommodate further requirements in accommodation, medical and recreational facilities.

Proposed Changes:

The MLC 2006 convention should not be made mandatory and rather be voluntary.

CLASS RULES FOR OSVS

In the absence of any comprehensive “OSV Code” by IMO, some international classification societies like GL [5], BV [6] and NK [7] have taken positive initiatives for consolidating all IMO rules and regulations, codes, conventions, etc. in a single document. These documents are certainly helpful for designers/owners/builders, but they are still within the frame work of original rules and regulations promulgated by IMO through MSC and MEPC.

In the opinion of the author, IACS (International association of Classification Societies) [8] perhaps can again take a lead to harmonize these consolidated rules from various classification societies into a single document for the time being unless there is an “OSV Code” This action perhaps constitutes the foundation works for such a single Code for OSV in the future like “MODU Code” for offshore platforms/rigs.

OTHER CHANGES

Hull Construction

Double bottom requirements as far as practicable sometimes become impracticable for OSV due to its typical aft hull line form. Sometimes, some foundations like aft gear boxes, etc. also pose a hardship for designers due to this double bottom requirements. Stern tube water tightness also causes design challenges. All these requirements are to be clearly spelled in the “OSV Code” to give a clear interpretation and their design solutions rather than treating them case by case.

COLREG 1972

Relevant changes are to be made in COLREG 1972 as the accommodation is situated fwd of the vessel in OSVs. As a result, navigation light arrangements for the stern lights, aft anchor lights and towing lights should be placed as close as possible to the stern, which is quite impossible. Similarly, fwd and aft masthead lights with a distance of 0.5L for OSVs longer than 50m cannot be met. Again a clear deviation from COLREG ’72 should be detailed in the OSV code so that case by case treatment of each and every vessel does not have to go through the Flag Administration approval.

Noise and Vibration

Crew comfort or crew habitability is important in OSVs due to its physically demanding works on board works and also in environmental hazards. STCW and MLC 2006 specifically mentions rest hours. So, special attention is to be given during the design and construction stage to limit both noise and vibration when in operations to avoid discomfort to the crews.

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Noise requirements are detailed in IMO Res. A468(XII). During sea trials, noise measurements on board an OSV are to be carried out at 85% MCR (maximum continuous rating) of main engines. Same is the case with vibration measurements. Noise and vibration measurements are to be also carried out at 40% of bow thrusters’ rating to fulfil noise and vibration limits as stipulated in IMO Resolution. Measurements at higher MCR of main engines and bow thrusters rating should be on a voluntary basis.

Bridge Layout

Special consideration is to be again given for the bridge layout as most OSVs do not have bridge wings. Interpretation and design solutions are to be clearly spelled out to avert special approval from flag administration. Improved bridge layout proposed by a few classification societies should be voluntary for improved as well as sophisticated design of OSVs.

Anchor Handling

Anchor handling is a special operation for AHTSVs. This is more so often when in deep water. This has caused large bollard pull vessels and at the same time requiring higher capacity AHT winches, anchor handling gears, stern rollers rig chain lockers, etc. These items are never covered in SOLAS as they do not pose direct safety of a vessel. But the unfortunate capsize of “Bourbon Dolphin” has made a change in mindset and thus it clearly indicates the importance of anchor handling operation and the stability of the vessel.

Towing

Similar to anchor handling, towing is also an important operational aspect for an AHTSV or an AHT. Stability requirements also are to be added for this operation.

Fire Fighting

Many AHTSVs and AHTs are fitted with fire fighting capabilities. Stability requirements are to be added for this operational condition also.

Dynamic Positioning

This year is the Golden Jubilee of dynamic positioning in the world since it started first in GoM in 1961. Over the years, development has been made in both hardware and software blessed by the tremendous development in IT. A few rules and guidelines exist like NMD publication “Guidelines for Dynamic Positioning Vessels”, IMO MSC/Circ.645, IMCA M103 and IMCA M117 complementing IMO MSC/Circ.738. It would be wise to have a common interpretation of the various rules and guidelines in the “OSV Code” as dynamic positioning system is now well recognized in marine and offshore industry.

Propulsion Plant

In early years of OSVs, main engine power was less. But they go now as high as 25K HP with C-DMMP or H-DEMP in some AHTSVs. PSVs are mostly nowadays A-DEMP. All diesel electric marine propulsion systems are using various voltages ranging from 690V to 6.6KVA. Larger vessels with higher engine power contribute to emission. As a result, some mechanism should be in place to

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deal with this emission. But certainly, the proposed EEDI and EEOI are not any straightforward solutions. Skilled crews to deal with diesel electric propulsion are to be abundant for manning such vessels.

Subsea Engineering

With the development of deepwater oil and gas fields, subsea technology is on the rise in many deep water oil and gas development. Subsea systems are now popular in many E&P due to their improved technology and lower costs. Specialized OSVs like well stimulating vessels, well intervention vessels, etc. require specific rules and regulations related to their operations. These areas are to be investigated and are to be well presented in the “OSV Code”.

Arctic Engineering

While climate changes cause global warming, new frontiers open up in the Arctic Ocean where the ice cap is shrinking and also more time in a year is now available with only ice infested waters suitable for ice class vessels. E&P activities using drill ships can operate with ice class OSVs for supply. Even in the early winter, ice breaking OSVs can work as supply vessels as well as doing ice management work if ice breakers are not available.

DISCUSSION

The author mainly resorts to the idea of not bringing fishing boats in SOLAS frame work as OSVs are somewhat like those vessels. But that was perhaps true in fifties or sixties when these OSVs were less in numbers, smaller in sizes and limited to a few types only. Now with the deep water E&P and other activities, these OSVs are much bigger than when it started originally. So, it is imperative that it would be quite naive to stick to that analogy. So, there is indeed a need for these vessels to bring them into main streams of ships engaged in specialized operations, not as trading merchant ships. These very differences should be the basis of relaxing all rules and regulations in SOLAS, MARPOL, various resolutions, circulars, codes and conventions before those are made mandatory for OSVs as primarily as specialized cargo vessels operating mainly in coastal and offshore areas of a country.

Major Changes

The major changes have been described in Section 3 of this technical paper. Item wise description gives a brief understanding on the various complex design limitations related to offshore support vessels. The various regulatory documents that directly affect design/construction/operation of OSVs are given for necessary changes in them to suit OSVs.

Minor Changes

In Section 5 of this technical paper, various rule requirements and guidelines of IMO and others are also presented that also affect design/construction/operation of OSVs. The consolidated understanding of these items, if given in a single interpretation, also helps designers/builders/owners.

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CONCLUSIONS

As long as offshore oil and gas activities remain dynamic, offshore support vessels will be a part and parcel of this industry for maintaining supply of cargoes, personnel, etc. for E&P, maintenance, emergency response, etc. These vessels are wide ranging in their types, sizes and functions depending on the geographical locations and their climate. Deep water and arctic operations will have further impacts on these vessels in many ways in the future.

Equating these vessels to merchant ships like cargo, passenger, etc. are somehow misleading and only bring unnecessary anguish for designers/owners/builders.

While everyone in the shipping community should respect maritime safety, prevention of pollution for sustainability, safeguarding the planet earth and its people, due consideration should be given to these specialized vessels (OSVs) in respect of implementing various rules and regulations of IMO.

Initially, IACS can play an important role in consultation with all its members and other parties like designers/owners/operators and perhaps come out with a harmonized single “OSV Code” as a preliminary version for discussion. This initiative eventually can result into a good workable and practical “OSV Code” in the near future.

Though the number and its tonnage figure may not be appreciable compared to the world’s total shipping, but it is necessary that IMO may like to give an immediate consideration of introducing a separate dedicated Code for offshore support vessels.

DISCLAIMER

The author has gone through experiences of design and construction of OSVs for a number of years. The proposed changes for various rules and regulations made in this technical paper are entirely his own ideas/thoughts, and as such do not constitute the idea/thought of any other individual, group, organization, institution, etc.

REFERENCES

[1] James B. Liebertz, ABS, Pacific Division, Keynote Address, OSV Singapore 2005 [2] IMO (International Maritime Organization); http://www.imo.org

[3] DNV (Det Norske Veritas); http://www.dnv.com

[4] ILO (International Labour Organization); http://www.ilo.org [5] GL (Germanischer Lloyds); http://www.gl-group.com [6] ClassNK (Nippon Kaiji Kyokai); http://www.classnk.or.jp

[7] IACS (International Association of Classification Societies Ltd); http://www.iacs.org.uk

BIBLIOGRAPHY

[1] Proceedings of OSV Singapore 2005 at Singapore. [2] Proceedings of OSV Singapore 2007 at Singapore. [3] Proceedings of OSV Singapore 2009 at Singapore.

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