Marine Fuels and the Environment

Quality of marine fuels ISO 8217:2010

Fuel Regulations and the Environment – SOx emission control

byMaria KyratsoudiFOBAS Specialist

Hellenic Lloyd’s SAA member of the Lloyd’s Register Group

Quality of Marine FuelsISO 8217:2010

Lloyd’s Register FOBAS

ISO TC 28/SC 4/WG 6 to develop and maintain an internationally recognised specification for marine fuels achieved by:

• considering ship safety, engine performance, environmental impact and the mitigation of risk

• identifying appropriate and scientifically valid test method and specification limits necessitated by environmental

• legislation, technical developments both on board the vessel and in the production of marine fuels

• considering the impact of specification limits to ensure worldwide fuel availability

• identifying issues for future revisions of ISO 8217

ISO 8217:2010

Characteristics added/reviewed for:

Both categories of Fuels• H2S measurement • Acid Number

Distillate Fuels only• Added minimum viscosity for DMB• New DMZ category for a minimum of 3 cSt at 40 deg C• Appearance clause modified• Oxidation stability• Lubricity (for LT 0.05% Sulphur ) • Minimum viscosity DMA increased

ISO 8217:2010Residual Fuels only

• Avoidance of unusual viscosity/density relationships by inclusion of (CCAI)

• Accelerated Total Sediment (TSA)

• Ash limits reduced for many of the categories

• Vanadium limits reduced (except RMB30 and RMG380)

• Aluminium plus silicon limits reduced

• RMG and RMK grades expanded to include additional viscosity grades while RMF and RMH grades have been removed

• Sulphur limits removed – guided by Sulphur Limiting Zones of operations (ECA’s)

• Sodium limits

• The criteria for presence of ULO amended

Lubricity

• Lubricity for (clear and bright) distillates has been added for < 0.050% m/m sulphur content

• This parameter has been incorporated in the standard due to the fact that ultra low sulphur distillates may have reduced lubricity properties

• The lubricity limit of 520 wear scar diameter at 60 oC is based on existing requirements for high speed automotive and heavy-duty industrial diesel engines

Oxidation Stability

• Oxidation Stability has been added due to refinery practices which may lead to distillates having limited oxidation stability

• Furthermore due to present stringent sulphur controls on distillates + further legislative limiting sulphur controls in the future, the distillate supply chain may be susceptible to bio derived materials (such as FAME) finding their way into the marine distillate stream. This phenomena may also lead to more distillates having limited oxidation stability

Acid Number

• Acid Number (AN) has been included in the standard to take into account potential damage to marine diesel engines (primarily fuel injection equipment)

• Testing for AN can give indication of likely presence of acidic compounds. (Note all fuels have a naturally occurring measurableacid number. For distillates usually < 0.5 mg KOH/g and for residual fuels < 2.5 mg KOH/g)

• It should be noted that in the event of AN exceeding limits, it may still be fit for purpose pending nature of acid i.e. naturally occurring naphthenic vs alien acids

H2S• Proposed H2S limit is 2 mg/kg in the liquid phase, to come into

effect 1 July 2012

• H2S is not a new issue but it continues to be a global concern

• H2S – initially contained within the liquid can slowly be released into vapour with no proven, predictable or fully understood rules for this tendency. It is simply down to fuel chemistry

• Industry sources – coefficient of partitioning between liquid and vapour is approximately 1:50 and up to 1:100, which means that each 1 ppm of H2S in liquid phase can give rise to approx 50 to 100 ppm in vapour phase in tank head space

• Due to health and safety issues the correct monitoring of H2S concentrations is of utmost importance

Clause 5 – General requirements

Sub-clause 5.3: Fuels shall be free from any material that renders the fuel unacceptable for use in marine applications.

Sub-clause 5.4 :The fuel shall be free from the bio-derived materials other than ‘de minimis’ levels of FAME (FAME shall be in accordance with the requirements of EN 14241 or ASTM D6751).

In the context of this International Standard, ‘de minimis’ means an amount that does not render the fuel unacceptable for use in marine applications.

Lloyd’s Register FOBAS

Fuel Regulations and the Environment SOx emission control

Sulphur Oxides (SOx) Regulation 14

• Sulphur content on any fuel used on board ships is currently 4.50% m/m

• World-wide average of sulphur content in residual fuel oil supplied for use on board ships shall be monitored annually

• Average sulphur content now going into MEPC 62/4 is 2.61%m/m

Distribution of sulphur content in fuel samples

Sulphur Oxides (SOx) Regulation 14

• Maximum sulphur content of fuel in ECA-SOx is 1.00% m/m

• Ships using different fuel oils to comply inside and outside ECA-SOx - written change-over procedures required

• Record maintained of date, time, position and quantities of ECA-SOx fuel in each tank on completion (on entry) or commencement (on exit) of change-over

Fuel Oil Quality Regulation 18

The fuel shall be:– Blends of hydrocarbons from petroleum refining– Free from inorganic acid– Free from any substance that: jeopardizes safety of ships, is

harmful to personnel or contributes overall to additional air pollution

BDN (bunker delivery note) shall be kept on board for 3 years after the fuel oil has been delivered on board

BDN to include:– Name and IMO number of receiving ship– Port and Date of commencement of delivery– Name, address and telephone number of fuel supplier– Product name and Quantity– Density and Sulphur content– Declaration signed by supplier that the fuel oil conforms with

Annex VI

Fuel Oil Quality Regulation 18

• Representative sample to be sealed and signed by the supplier’s representative and the master or officer in charge of the bunkeroperation

• Sample to be kept on board until the fuel oil is substantially consumed but in any case for not less than 1 year from time of delivery

• Authorities to regulate suppliers to ensure compliance with their responsibilities under MARPOL Annex VI.

• Representative sample analysis in accordance with the verification procedure set forth in Appendix VI to determine whether the fuel oil meets the requirements of this Annex.

Fuel Oil Availability Regulation 18

• Ship should not be required to deviate from its intended voyage or unduly delay the voyage

• If not compliant:Present action taken to attempt to achieve

complianceEvidence of attempt to purchaseNot physically available – what action taken

• Competent authority to take the above into account when considering what, if any, action to be taken

Sampling procedural requirements

• Guidelines for the sampling of fuel oil for determination of compliance with Annex VI Resolution MEPC.182(59)

• ‘Representative sample’defined

• Determination of sampling methods

• Handling of retained sample

True Value

xx x x

x x

x

xx

Results Fail

Results Acceptable

-0.59xR +0.59xR

Variability of test result

Freq

uenc

y of

res

ults

95% Confidence Limit95% Confidence Limit••Reproducibility, RReproducibility, R : The difference between two test results independently obtained by different operators in different laboratories on nominally identical test material.

•How well can I expect to agree with other laboratories

• Repeatability, rRepeatability, r : The difference between successive test results obtained by the same operator with the same apparatus under constant operating conditions on identical test material

•How well can I expect to agree with myself

•95% confidence = 95% of the time the difference between duplicates can be expected to be less than a certain figure

x

Infinite results from infinite Laboratories

0.110.090.10

1.060.941.00

4.724.284.50

Upper Limit -Buyer95%

Lower Limit -Supplier

95%

Specified Sulphur Max Limit (% m/m)

Sulphur Test MethodISO 8754:2003

MARPOL Annex VI

‘S’ Test Accuracy to 95% confidence

The Supplier can consider the resultto MEET the regulation with 95%

confidence if his single result is < or = to 0.94% m/m

The Buyer can consider the sample to FAILthe regulation with 95% confidence if hissingle result is greater than 1.06% m/m

Best Practices• Supplier should be put on notice and requested to comment on

the FOBAS finding as to the sulphur content of the fuel

• Sample(s) of the subject fuel oil in storage (assuming it has not been mixed on loading) – top / middle / bottom - should be tested to confirm the result of the initial bunker drip sample

• Subsequent to outcomes from 1 and 2 above (as applicable) then flag State and relevant Bunker Supplier Registration Authority and port State(s) should be duly advised and their guidance requested

• Keep all records such as BDN, log book entries, communications to relevant parties, fuel loading, transfer and change over details in good order

Marine Fuel Sulphur Record Book developed by Lloyd’s Register

Provides consistency through multi flag fleet

• Overview of regulations• Compliant check lists• Letter of Protest form

Log 1 Bunker DetailsLog 2 BDN and MARPOL Sample Log 3 Fuel oil change-over recordLog 4 Fuel oils used in ECA-SOxLog 5 EU ‘at berth’ change overLog 6 Fuel oils used ‘at berth’ in EU ports

Demonstration of compliance to PSC

Deficiencies that may lead to ship detention by Port State Control

• Non-compliance within a sulphur oxide (SOx) emission control area >1.00% m/m

• Check of changeover records

• Sulphur content of any fuel used on board exceeding 4.50% m/mchecked via bunker delivery notes or confirmed by MARPOL sample test

• MARPOL Sample is not to be used for commercial quantity/quality verification purposes and should be only handed over to Port State Control upon their request

• The master or crew are unfamiliar with the operational procedures of MARPOL Annex VI

Controlled Sulphur Fuel Oil Change-overManaging Sulphur Limited Zones (SLZ)

• Change-over procedures & calculation of time - FOBAS Calculator

• Crew awareness – training & record keeping

• Degraded onboard by in-tank or system pipe mixing

• Charter Party clauses & flexibility

• Longer periods on low sulphur fuel oil – lube oil concerns

• Compatibility concerns, cleaning effect, over / under heating

Compatibility Spot Test – onboardRating 1 2 3 4 5

Acceptable Not Acceptable

FOBAS sample bottle pack compatibility test instruction

EU Directive 2005/33/EC

• Covers all grades of fuels and all types of combustion machinery, including main and auxiliary boilers

• ‘At berth’ in this context covers ships at anchor, on buoys or alongside irrespective of whether working cargo or not

• Changeover as soon as possible after arrival and as late as possible prior to departure

• Ships which are timetabled to be at berth for less than 2 hrs and certain named vessels will be exempted from the requirements

Jan 2010 ‘At berth’ requirement

Regulated California Waters(24 Miles from Californian Coast)

Key Elements

Main Engines, Auxiliary Engines & Auxiliary Boilers

From 1 July 2009

ISO 8217:2005 DMA grade fuel oil – 1.5% m/m max. sulphuror

ISO 8217:2005 DMB grade fuel oil – 0.5% m/m max. sulphur

From 1 January 2012

ISO 8217:2005 DMA or DMB grade fuel oils – 0.1% m/m max. sulphur

Documentation & Record Keeping required

19 May 2006Baltic Sea

SECA 1.5%

22 November 2007North Sea SECA 1.5%

11 August 2006EU Member States laws enacted:• 1.5% in Baltic SECA• 1.5% for passenger ships between EU ports• Use of abatement technology

1 July 2010ECA-SOx 1.00%

CARB (Phase I):• DMA 1.5%• DMB 0.5%

Legislative overview – IMO, European Union and CARB

11 August 2006DMB/DMC 1.5% 01 Jan 2008

MGO 0.1%

January 2012CARB (Phase II):• DMA 0.1%• DMB 0.1%

1 January 2015ECA-SOx 0.10%

1 January 2012Outside ECA-SOX 3.50%

1 January 2020

Outside ECA-SOX0.50%

2006 2007 2008 2009 2010 2012 2015 2020

January 20100.1% sulphur limit on all marine fuel “at berth” in EU ports

11 August 2007North Sea SECA 1.5%

North American ECA-SOx• North America – in force from August 2012

Up to 200 nm from coast

For more information, please contact:

Maria KyratsoudiT +30 210 4580952F +30 211 2686 653W www.lr.orgE maria.kyratsoudi@lr.org

Hellenic Lloyd’s S.A. A member of the Lloyd’s Register Group87, Akti Miaouli Street185 38 Piraeus