Sampling & Test Accuracy under the umbrella of emissions legislation

Transcription

1 Bunker Summit Athens 2007 Sampling & Test Accuracy under the umbrella of emissions legislation Presented by: Timothy Wilson CEng. MIMarEST FOBAS Product Manager & Dr. Anthi Miliou Phd FOBAS EMBS Services are provided by members of the Lloyd s Register Group Lloyd s Register, Lloyd s Register EMEA and Lloyd s Register Asia are exempt charities under the UK Charities Act 1993.

2 Environmental legislation on ship emissions NOx CO2 VOC SOx (PM) To reduce acidification & global warming & Improve air quality tting limits requires the CORRECT application of recognised international standards and procedures to demonstrate compliance and resolve disputes

3 Two cases of SECA non compliance? 2 spot sample inspections Klaipeda barge vs ship samples discrepancies Why? Who is responsible? The analysis of any fuel can be constructively interpreted given THREE conditions: 1. Sample is representative 2. Test method is correct 3. Rules for interpretation are applied

4 Overview of Marine Fuel Specification ISO 8217:2005 User s Requirements for a fuel Safe handling and easy to transfer Stable at all stages of operation Capable of being adequately cleaned of catalyst fines, dirt and water Easy to ignite and combust Non- Corrosive ISO 8217 covers the points listed above to protect the user

5 ISO 8217:2005 Structure Classification of fuels through: ISO Categories of marine fuel International Statutory Requirements IMO SOLAS Flash point IMO MARPOL Annex VI (14) Sulphur Tables: 1 & 2 1 Requirements for Marine Distillates 2 Requirements for Marine Residual Fuels 9 - Informative Annexes (3 rd 2005 edition) When an order is given based on ISO 8217 the fuel required is to meet not only the specifications of Tables 1&2 but also the documents and notes in its entirety.

6 Grade Changes in 3 rd edition Distillate fuels No changes, we still have: DMX, DMA, DMB &DMC Residual fuels Reduced from 15 to 10 removing: RMC 10, RMH 45, RMK 45, RML 45 & RML55

7 Characteristic Limit RMA 30 Zinc, mg/kg Phosphorus, mg/kg Calcium, mg/kg Requirements for marine residual fuels RMB 30 RMD 80 RME 180 Category ISO-F- RMF 180 RMG 380 RMH 380 RMK 380 RMH 700 RMK 700 Test method reference Density at 15 C, kg/m³ max. 960,0 975,0 980,0 991,0 991,0 1010,0 991,0 1010,0 ISO 3675 ISO Kinematic viscosity at 50 max. 30,0 80,0 180,0 380,0 700,0 ISO 3104 C,mm²/s Flash point, C min ISO 2719 Pour point (upper), C 2) - winter quality max ISO summer quality max ISO 3016 Carbon residue, % (m/m) max ISO Ash, % (m/m) max. 0,10 0,10 0,10 0,15 0,15 0,15 ISO 6245 Water, % (V/V) max. 0,5 0,5 0, ,5 0,5 ISO 3733 Sulfur, % (m/m) 3) max. 3,50 4,00 4,50 4,50 4,50 ISO ISO 8754 Vanadium, mg/kg max ISO IP 501 Total sediment potential, % max. 0,10 0,10 0,10 0,10 0,10 ISO (m/m) Aluminium plus silicon, mg/kg max ISO Used lubricating oil (ULO) The fuel shall be free of ULO. A fuel shall be considered to be free of ULO if one or more of the elements Zinc, Phosphorus and Calcium are below or at the specified limits. All three elements must exceed the same limits before a fuel shall be deemed to contain ULO ADDED Characteristic changes IP 501 IP 501 IP 501

8 Control of Contaminants - Note Sub Clause 5.1 The fuels shall be homogeneous blends of hydrocarbons derived from petroleum refining. This shall not preclude the incorporation of small amounts of additives intended to improve some aspects of performance This is all that may be in the fuel! The fuel shall not include any added substance or chemical waste which either: jeopardises the safety of ships or adversely affects the performance of the machinery is harmful to personnel contributes overall to additional air pollution

9 4 th Edition of ISO 8217? To include : Acid Number, Na, Asphaltenes, Nitrogen, H 2 S, FIA/100? Alternative fuels Bio Diesels, Natural Gas? The driving force : Diesel engine design Changes in fuel manufacturing processes Further environmental legislation Fuel costs and availability

10 Precision data ISO 4259:1992(E) Most tests carried out by a laboratory will produce only one result called, in ISO 4259, a single result Two or more measurements of the same property of a specific sample by any given test method do not usually give exactly the same result. Most Flag administrations and PSC enforcement bodies are not familiar with these standards.

11 Frequency of results Accuracy of the data Reproducibility, 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, 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 -0.59xR x x x x True Value x x +0.59xR x x x x Variability of test result Infinite results from infinite Laboratories Results Acceptable Results Fail One result in a grey area exceeding the limit but within test reproducibility, is NOT a TRUE figure so when is the fuel compliant?

12 S Test Accuracy to 95% confidence MARPOL Annex VI Specified Sulphur Max Limit (% m/m) Sulphur Test Method ISO 8754:2003 Lower Limit - Supplier 95% Upper Limit - Buyer 95% The Supplier can consider the result to MEET the regulation with 95% confidence if his single result is < or = to 1.42% m/m The Buyer can consider the sample to FAIL the regulation with 95% confidence if his single result is greater than 1.58% m/m

13 Buyer and Supplier cannot agree on single result! 1. If results fall into the grey area then the same sample should be retested by another laboratory in order to produce further results, within the (R), average of each labs (r) and between labs will indicate the true value. 2. If there is still dispute then ISO 4259 stipulates further procedures for reaching conclusion and resolving dispute: Paragraph 10: Rules on acceptance and rejection of results in case of dispute. This procedure is only for situation where the two labs are analysing fuel samples that are subdivisions of same representative sample! Paragraph 9: Guidance on the reliability of a single test.

14 Setting the stage 1. +Which Test method ISO 8754:2003 is the Sulphur test used in ISO 8217, referred to in the Appendix V of MARPOL Annex VI. Logical and correct that this is used. 2. +Laboratory accreditation ISO important to ensure the highest of technical standards and test method precision and accuracy are maintained. 3. +Representative sample apply best practice ISO/TR (Soon will be an ISO standard) SS CP60 by example 4. -The problem is that any avoidance of the implementation of correct sampling and testing procedures and rules may lead to a ship and/or supplier being falsely accused.

15 Why is the sample so important? Statutory IMO Requirement Enables analysis of the product supplied Wide range of marine fuel grades Marine fuel quality is not guaranteed Operations:- reports fit for purpose Commercial: - quantity verification & reliability Legal: - Proof, Evidence, most important Representative sample Benefits ALL parties. The quality of EVIDENCE collected will determine the representative status of the test result and the success of any investigation

16 WHERE to draw the sample from? MARPOL ANNEX VI MEPC.96(47) Sampling guidelines. Sample to be drawn at the receiving vessel s bunker manifold. ISO 8217 states: When used in connection with commercial transactions, this International standard specifies the required properties for marine fuels at the time and place of custody transfer Samples for quality verification can be taken in any location agreed between the parties Custody transfer point = Where Title & Risk changes hands. Both parties applying best practice avoids mistrust!

17 How do we draw the sample? ISO/TR Samplers Flow proportional Automatic Time Proportional Automatic Manual continuous Drip Flow Proportional Sample Sealed Container Open Bucket!

18 What do we do with the samples? 1- Laboratory 2- Ship retained 3- Supplier - Commercial Samples 4 -Annex VI Sample Statutory (Annex VI ) Remains with Ship 5 Suppliers Annex VI sample some suppliers request this SS CP60 Best Practice Pre-bunker agreement on sampling position, method and bottles All parties witness sampling, sealing and documentation ONE SET of samples all recorded on BDN NOTES OF PROTEST where NON compliance has been observed

19 Summary FACT: Poor sampling and avoidance of implementation of correct testing procedures and rules may lead to wrong indictment The industry must exercise caution and apply best practice: Single set of samples from one point witnessed by all parties CP60 ISO/TR13739 Application of ISO 8217 and ISO 4259 from bunker order to dispute resolution Correct Test methods Accredited laboratories ALL parties have RESPONSIBILITIES to ensure environmental compliance Supply Traders compliant fuel Ship crew awareness and change over procedures - flushing the lines Port register suppliers and enforce Flag Administration regulate and guide ships.

20 Solar,Wind,Wave & Biofuel? Wallenius Wilhelmsen Australian Solar Sail Auto Industry s way Credit: Knud E.Hansen. Sky Sails Designed by Sail Log

21 Letter to Fairplay March Surely something ought to be done in the way of testing and marking Canvas to show that it is what it is represented to be, and not shoddy. Legislation this is where it all started - Shoddy canvas!

22 Thank You Contact: Lloyd s Register Piraeus Dr Anthi Miliou Tel: Anthi.Miliou@lr.org The Lloyd s Register Group works to enhance safety and approve assets and systems at sea, on land and in the air because life matters.