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Procedure and

workbook Low

Sulphur Operation

Department or author: Approved by:

Anders Brunvoll Vibeke Nordahl-Paulsen

© 2015 Seagull Maritime AS All rights reserved.

No part of this work covered by the copyright hereon may be reproduced or otherwise copied without prior written

permission of Seagull Maritime AS

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Document status

Issue no. Date Author

2174 A

12.03.2015

AB

2174 A1 16.08.2018 AB

2174 B1 05.08.2019 AB

Changes in the document

Issue no. Paragraph no. Description

A1 1.7 4

Updated text Updated evaluation form

B1 Updated text and questions in workbook, added module #0417.

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1 Table of contents Document status............................................................................................................................. 2 Changes in the document .............................................................................................................. 2 1 Table of contents ..................................................................................................................... 3 2 Procedure Low Sulphur Operation .......................................................................................... 4

2.1 The objective ....................................................................................................... 4 2.2 Pre qualifications ................................................................................................. 4 2.3 Activities to be completed.................................................................................... 4 2.4 Educational material to be used .......................................................................... 4 2.5 Completion of training ......................................................................................... 5 2.6 Questions regarding the Low Sulphur Operation course .................................... 5 2.7 The following must be sent to Seagull Maritime:................................................. 5 2.8 Documentation checklist ..................................................................................... 6 2.9 Candidate detail page ......................................................................................... 7 2.10 Verification checklist for Low Sulphur Operation ................................................ 8

3 Workbook Low Sulphur Operation ........................................................................................... 9 3.1 Introduction .......................................................................................................... 9 3.2 Excerpts from MARPOL ANNEX VI .................................................................. 10 3.3 Economic consequences when switching between fuels with varying sulphur content. 11 3.4 Switching between fuels with varying sulphur content. ..................................... 11 3.5 Incompatibilities ................................................................................................. 11 3.6 2-stroke engines ................................................................................................ 12 3.7 Boilers................................................................................................................ 12 3.8 4-stroke engines ................................................................................................ 12

4 Workbook questions .............................................................................................................. 14 5 Evaluation of Low Sulphur Operation .................................................................................... 15

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2 Procedure Low Sulphur Operation

2.1 The objective

The objective is to provide competence and enhance the knowledge of low sulphur operation onboard vessels both operating inside and outside Emission Control Areas.

2.2 Pre qualifications

This course is intended for engineers on board a vessel using fuel oils with different sulphur content. Candidates should have knowledge of English language (spoken and written)

2.3 Activities to be completed

The candidate must complete all e-learning modules, read trough and complete all exercises in this workbook. Candidate must at least obtain 95% completion and a test score of 75% on all e-learning modules. Materials to be used: e-learning module #0417, procedure and workbook for Low Sulphur Operation

2.4 Educational material to be used

E-learning module #0417 Low Sulphur fuel operation. Procedure and workbook for Low Sulphur Operation, and the vessels fuel change-over procedure (if applicable).

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2.5 Completion of training

The training has been completed when: All prescribed training has been performed and the Master or Assessor onboard has verified the result of all training activities and signed the Workbook. Time needed may vary considerably depending on the participant’s background and knowledge of the subject. Each individual seeking a “Documentary evidence” must read through the workbook, and complete all questions in the workbook. Training must be completed under supervision of an approved Assessor. NOTE: Each individual seeking certification must read through the workbook and complete all questions individually and submit all written answers formulated in own words so that the answers reflect individual competence. All submitted applications are filed and compared to previously received applications. Seagull Maritime will charge for applications which are found to be copied from previously submitted applications or are considered to be fraudulent.

2.6 Questions regarding the Low Sulphur Operation course

Questions regarding the training can be sent by email to obtraining@sgull.com The subject in the e-mail must be, “Low Sulphur Operation”.

2.7 The following must be sent to Seagull Maritime:

Upon receipt of documentation as outlined in the checklist below, Seagull Maritime will assess the application and if approved, issue a documentary evidence which will be sent to the company. All pages generated by the candidate on board must be signed and verified by Master or Assessor and marked with the vessel’s stamp. Please send the documentation as one PDF attachment to the following email: obtraining@sgull.com The subject in the email must be “Low Sulphur Operation course” Please note: All further correspondence regarding this application will include all recipients of the original mail sent to Seagull Maritime.

mailto:obtraining@sgull.commailto:obtraining@sgull.com

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2.8 Documentation checklist

Documentation checklist for Low Sulphur Operation on board training course. The following documents, duly completed, must be submitted to Seagull Maritime for evaluation and approval before Seagull Maritime can issue a Certificate of Training. Documentation checklist, Candidate detail page, and Verification checklist. Copy of ID of person who is signing the documents (Master or Assessor) Copy of verification of training from module # 0417 Copy of candidate’s passport or discharge book confirming the full name and date of birth Answers to all the questions and exercises in the workbook All pages signed and verified by Master or Assessor and marked with ship’s stamp I hereby declare that this is my own work and effort and that all is done according to procedure: --------------------------- ------------------------------------------------------- Date Candidate signature IMPORTANT NOTE: Send the documentation by email to: obtraining@sgull.com IF ANY OF THESE DOCUMENTS ARE MISSING, NOT READABLE OR NOT COMPLETE, COURSE EVALUATION AND PROCESSING OF THE APPLICATION CANNOT BE PERFORMED BY SEAGULL MARITIME AND THE APPLICATION WILL NOT BE APPROVED

mailto:obtraining@sgull.com

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2.9 Candidate detail page Low Sulphur Operation

First name

Middle name

Last name

Date of birth (day, month, year)

Nationality

Login ID

Rank/position

Ships flag

Ship name

Ship IMO number

Ship email address

Name of Company

Company contact person (Training dep.)

Company email address

Invoicing address (Company)

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2.10 Verification checklist for Low Sulphur Operation

To ensure that Seagull Maritime on board courses are done according to our procedures, all documents and checklists must be signed and stamped. This must be done by Master or a qualified onboard Assessor. If not stated in the workbook, the Master/Assessor does not have to check if all answers are correct. This will be done by Seagull Maritime. If Seagull Maritime finds that an application is partially or entirely a duplicate of another application, the application will be rejected and certificate will not be issued. The candidate and company will be notified. The Master/Assessor must take all necessary precautions to ensure that all these requirements are met. The Master/Assessor is jointly responsible that the applications are according to our procedures and guidelines. In the STCW Convention, regulation I/6 and section A-I/6 it is required that all training and assessment of seafarers are administered, supervised and monitored. The Master/Assessor is part of fulfilling this requirement. By signing this document I confirm that the following: I have read the course procedure Candidate’s ID and personal details are correct The onboard course is completed by the candidate as individual and unaided work Signing as Assessor on course applications which is a copy of another application is document fraud. --------------------------- ------------------------------------------------------- Date Signature of Master*/Assessor Master*/Assessor details.

First and middle name

Last name

Date of birth

Rank

Assessor certificate number or Master’s Certificate of Competency number

*If the Master is the candidate another Senior Officer must be responsible that the onboard training has been done according to course procedure.

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3 Workbook Low Sulphur Operation

3.1 Introduction

Global sulphur cap 1 January 2020 a global 0.50% sulphur cap comes into force. This means that a ship cannot use fuel with a sulphur content of more than 0.50% for propulsion or operation unless the ship is equipped with an exhaust gas cleaning such as a “scrubber”. In addition to the global sulphur cap there are emission control areas (ECA) with even stricter sulphur regulations. An Emission control area (ECA) is defined as an area where the adoption of special mandatory measures for emission from ships is required to prevent, reduce and control air pollution from NOx or SOx and particulate matter to their adverse impact on human health and the environment. Inside an ECA there is a sulphur limit of 0.10% Ships can meet the 2020 sulphur cap requirement by using:

Conventional compliant fuel such as sulphur controlled distillates or residual fuel oils.

Alternative fuel types that meet the sulphur limits, such as LNG, methanol or hydrogen; some biofuels and synthetically manufactured fuel oils; or

An equivalent means to remove sulphur oxides from post-combustion exhaust emissions, such as an exhaust gas cleaning system.

Carriage ban An additional measure to support implementation and compliance with the 0.50% sulphur cap is the MARPOL amendment that prohibits the carriage of non-compliant fuel oils for propulsion or operation on board. Unless the ship has an exhaust gas scrubber fitted the ship cannot carry non-compliant fuel oils after 1 March 2020. Non-compliant fuel If a ship for some reason do not to comply with the standards for compliant fuel oils, the ship must be able to present a record of the actions taken to attempt to achieve compliance. It must provide evidence that it attempted to purchase compliant fuel. If compliant fuel is not available it must provide evidence that attempts were made to locate alternative sources of compliant fuel. The ship should not be required to deviate from its intended voyage or to delay the voyage in order to achieve compliance, but the ships Administration and the authority of port of destination must be notified. Exhaust gas cleaning system Ships with an exhaust gas cleaning system, often referred to as a scrubber, can continue to use 3.5% sulphur fuel oils after 1 January 2020 and still be in compliance with the 0.50% sulphur cap. However, there are areas and ports that ban the use of scrubbers.

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3.2 Excerpts from MARPOL ANNEX VI

Regulation 14 After 1 January 2020 the sulphur content of fuel oil used or carried for use on board a ship shall not exceed 0.50% m/m. While a ship is operating within an emission control area, the sulphur content of fuel used on board that ship shall not exceed 0.10% m/m. Ships using separate fuel oils to comply with the regulation for operating within an emission control area, and entering or leaving an emission control area, shall carry a written procedure showing how the fuel oil changeover is to be done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable sulphur content prior to entry into an emission control area. The volume of low sulphur fuel oils in each tank as well as the date, time and position of the ship when any fuel oil changeover operation is completed prior to the entry into an emission control area or commenced after exit from such area shall be recorded. Regulation 18 Fuel oil availability If a ship is found by a Party not to be in compliance with the standards for compliant fuel oils set forth in MARPOL annex VI the competent authority of the Party is entitled to require the ship to:

present a record of the actions taken to attempt to achieve compliance, and

provide evidence that it attempted to purchase compliant fuel oil in accordance with its voyage plan and, if it was not made available where planned, that attempts were

made to locate alternative sources for such fuel oil and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase.

The ship should not be required to deviate from its intended voyage or to delay unduly the voyage in order to achieve compliance. If a ship provides all the information required a Party shall take into account all relevant circumstances and the evidence presented to determine the appropriate action to take, including not taking control measures. A ship shall notify its Administration and the competent authority of the relevant port of destination when it cannot purchase compliant fuel oil. Fuel oil quality Fuel oil for combustion purposes delivered to and used onboard ships shall meet the following requirements:

the fuel oil shall be blends of hydrocarbon derived from petroleum refining.

The fuel oil shall be free from inorganic acid.

The fuel shall not include any added substance or chemical waste that jeopardizes the safety of ships or adversely affect the performance of the machinery, or is harmful to personnel, or contributes overall to additional air pollution.

Fuel oil for combustion purposes derived by methods other than petroleum refining shall not:

Exceed the applicable sulphur content set forth in regulation 14.

Cause an engine to exceed the applicable NOx emission limit.

Contain inorganic acids.

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Jeopardize the safety of ships or adversely affect the performance of the machinery.

Be harmful to personnel.

Contribute overall to additional air pollution

3.3 Economic consequences when switching between fuels with varying sulphur content.

Except from the operational challenges, there is an economical consequence of operating a vessel on fuel oils with varying sulphur level. Since fuel oils with different sulphur content often have very different properties and tend to be incompatible in certain mixed ratios, it can lead to major modifications of the fuel oil system. These modifications and incorrect operation can lead to major economic impact for these vessels. Vessels equipped with 2-stroke slow speed engines, switching between high and low sulphur fuels, may also need modifications of the cylinder oil system. I addition to this the cost of low sulphur fuel is significantly higher than for higher sulphur content fuel oils. Due to the high relative cost of ultra-low sulphur fuel oils it will be natural, if possible, to reduce engine load, and vessel speed, in order to consume less fuel in an ECA. Some authorities have announced to strengthening their effort to ensure compliance and will check bunker delivery notes, logbooks, and take fuel samples. Historically, penalties will increase if the industry is slow to comply.

3.4 Switching between fuels with varying sulphur content.

Before a vessel powered with fuel oil containing more than 0,10% sulphur enters an ECA it must change-over to a ultra-low

sulphur fuel, generally this means switching to Marine Gas Oil (MGO). This change-over needs training, preparation, and attention from all involved personnel. Change-over from one type of fuel to another is an operation with many pitfalls and risks, as a result of this it is important that the vessel has a detailed change-over procedure. If this is not taken seriously it may result in engine failure, loss of power, or engine break down. You should consult your engine manufacture for advice and best practice before switching between high and ultra-low sulphur fuels. The buyer of the fuel oil is responsible for specifying the bunker quality ordered, and should have knowledge of the exact sulphur content for the fuels used. The difference in sulphur level has a major impact on the time it takes to change from one fuel to another. The greater the difference in sulphur content, the longer it will take to change-over and fulfil ECA requirements. To be in compliance with MARPOL vessels using separate fuel oils to comply with ECA requirements must carry a written procedure showing how the fuel oil change-over is to be done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable sulphur content prior to entry into an ECA. The volume of low sulphur fuel oils in each tank as well as the date, time and position of the ship when any fuel oil change-over.

3.5 Incompatibilities

During a change-over period, and depending of the fuel supply system

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configuration there will be a mix of fuel oils with varying sulphur content. In order to prevent operational problems like clogging of filters etc. it is recommended to carry out compatibility tests, if possible before the fuel oils are bunkered. There are also test kits available that can be used on board, and it is possible to send in samples to a land based laboratory, but that will cause time lag before receiving the results.

3.6 2-stroke engines

The effect from the different fuel oils and cylinder oil types can appear quickly. Therefore, it can be beneficial to shorten the intervals between inspections of piston and piston rings when switching between fuel oils with different sulphur content fuels. It should be ensured that deposits do not build up on the piston side (above the piston rings). This can break the oil film and lead to polishing of the cylinder liner surface. Too much deposit will stop gas flow to piston rings and the result will be insufficient piston ring action. It is also important to check that all piston ring grooves are clean and free of deposits to ensure free ring movement. Deposits building up in the ring grooves can lead to deposits behind the piston ring, which again can lead to sticking piston rings and scuffing. If possible scavenge drain oil analysis should be carried out. Iron content and BN in the drain oil can give strong indications of the wear and the alkalinity reserve of the cylinder oil. If these analyses are taken on a regular basis and each time there has been a change of fuel they can be used to monitor and optimize cylinder lubrication. The system oil should also be monitored to see if there is any contamination due to stuffing box leakages.

The experience of operating 2-stroke slow speed engines on ultra-low MGO is limited, per today and the long term durability of components are unknown. It is expected that especially lubricants will have a massive development in the coming years.

3.7 Boilers

Boilers have been identified as the most at-risk component on board when switching between different fuel oils, and you should always consult the manufacturer of the boiler for advice and best practice, there should also be developed a detailed change-over operational manual before switching between fuel oils with varying sulphur content. Components like burners, fuel system, and boiler control systems may need to be adjusted when switching from one type of fuel to another. If the boiler is not adjusted to the fuel used the risk can be increased smoking, increased air pollution, furnace explosions and fire. Most boilers are designed to operate on MGO for shorter periods, but they are not designed to operate for longer periods and full capacity on the low viscosity MGO.

3.8 4-stroke engines

Operating 4-stroke engines on low viscosity fuel oils is normally not considered to be a problem. But if the viscosity drops too low it may damage the fuel injection equipment, and there may be a risk of loss in capability to produce full power or lead to engine failure. Operation on MGO can give less energy per pump stroke than HFO which will affect the engines output. Much will be dependent on the fuel and the condition of the fuel injection components, but it can be up to 15% or even more. If changing between different fuel oils too quickly uneven temperature changes may

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cause uncontrolled clearances in the injection pump, which can lead to seizure, internal and external leaks. Lubrication of fuel injection components as long as the viscosity is within the spec and the sulphur content is above 0.01% is often not considered a problem.

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4 Workbook questions Answer all questions. All questions have a maximum score; try to answer all questions as comprehensive as possible. 75% score is required to pass the course.

1) What types of machinery are affected when switching between fuel oils with different sulphur content on board your vessel? (3 marks/score)

2) How well is your vessel prepared to switch between fuel oils with varying sulphur content?

(3 marks/score)

3) Does your vessel have a written procedure describing how the fuel oil changeover is to be done? If so, give a brief description of the procedure. (3 marks/score)

4) Which factors affect the time it takes to change over from a fuel oil containing 0.50%

sulphur to a fuel oil containing 0.10% sulphur to ensure that you comply with the regulation before you enter an emission control area?(5 marks/score)

5) Have there been required any modifications from the engine and/or boiler manufactures

regarding the use of fuel oils with varying sulphur content? (3 marks/score)

6) What do you considered to be the most likely problem switching between fuel oils with different sulphur content? (5 marks/score)

7) Have you experienced any problems, engine failure, loss of power, or engine break

down due to switching between fuel oils with different sulphur content? (3 marks/score)

8) Which economic consequences will the global sulphur cap of 0.50% have for your ship? (3 marks/score)

9) Explain why boilers have been identified as the most at-risk component on board when

switching between fuel oils with different sulphur levels. (5 marks/score)

10) What type of equipment do you have on board to test the compatibility of fuel oils with different sulphur content? If you don’t have test equipment on board, what do you do to minimise the risk? (3 marks/score)

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5 Evaluation of Low Sulphur Operation

1. How easy was it to understand how to complete the course?

Poor Very good

2. Do you consider the Onboard Course to be a good tool for training?

Poor Very good

3. To what degree do what you have learnt meet the learning objectives described in the

course’s procedure?

Poor Very good

4. How do you rate the possibility of putting what you have learnt into practice?

Poor Very good

5. To what degree will this course help you in your job as an engineer?]

Not at all Very much

6. What is your overall rating of the course?

Poor Very good

Rank: Date: Place: