Upgrading engineers license with shipyard seatime

I am a 2AE that works for an offshore drilling contractor. I thought I had acquired enough sea time to sit for my 1AE license; 260 days underway (on station), and 110 days at Samsung Heavy Industries shipyard on a new build project (12 hour days alongside the dock).

I forwarded my sea service letter to the Master of the new build project and he denied signing it. Stating there is no sea time for shipyard.

I believe him to be wrong.

I’ve read the NMC Policy Letter 09-01 and it states that engineers receive day-for-day credit for upgrades, paragraph 3. a. (1).

I also know several engineers who have upgraded with a combination of shipyard and working time.

Have any engineers on here ran into a similar problem? If so, how were you able to get around them? Are there any updated policy letters that dive into this in more depth?