EMISSION CONTROL AREAS: THE GUIDE

Transcription

1 EMISSION CONTROL AREAS: THE GUIDE PART 2: ONBOARD MANUAL

2 CONTENT OVERVIEW NOTE ON TERMINOLOGY INTRODUCTION LIST OF ABBREVIATIONS EMISSION CONTROL AREAS A KEY ELEMENT OF MARPOL ANNEX V1 1.1 MARPOL ANNEX VI AN INTRODUCTION 1.2 MARPOL ANNEX VI APPLICATION AND OTHER CONTROL REQUIREMENTS 1.3 SULPHUR OXIDES (SO X ) AND PARTICULATE MATTER (PM) EMISSION CONTROLS (REGULATION 14) 1.4 FUEL OIL AVAILABILITY AND QUALITY (REGULATION 18) Box 1 Information to be included in the Bunker Delivery Note Box 2 EU Sulphur Directive 2005/33/EC, amending 1999/32/EC Box 3 California regulated waters EMISSION CONTROL AREA CO-ORDINATES 2.1 THE BALTIC AND NORTH SEA AREAS 2.2 THE NORTH AMERICAN AREA 2.3 US CARIBBEAN AREA SULPHUR CONTENT OF FUEL OILS AS LOADED

3 44 04 FUEL OIL CHANGE-OVER PROCEDURES 07 CONTINUOUS OPERATION WITHIN ECAs CHANGE-OVER PROCEDURE OUTLINE 7.1 ENGINE LUBRICANTS FACTORS TO CONSIDER 7.2 BUNKERING SEGREGATION CHANGE-OVER TIME CALCULATIONS 7.3 FUEL TEMPERATURE CONTROL VERIFICATION OF CHANGE-OVER 7.4 FUEL SYSTEM AND ENGINE COMPONENTS CONSIDERATIONS WHEN SWITCHING TO LOW-SULPHUR RESIDUAL FUEL OIL 5.1 CYLINDER LUBRICATING OIL (CLO) SELECTION FOR CROSS-HEAD ENGINES 5.2 FUEL COMPATIBILITY 08 THE MARPOL SAMPLE 8.1 GENERAL SAMPLING PROCEDURES FOR OBTAINING THE MARPOL SAMPLE 8.2 ACTIONS IF IT APPEARS THAT THE REQUIRED PROCEDURES HAVE NOT BEEN FOLLOWED IGNITION AND COMBUSTION CHARACTERISTICS 5.4 CATALYST FINES 06 CONSIDERATIONS WHEN SWITCHING TO DISTILLATES 8.3 IN THE EVENT THE MARPOL SAMPLE IS TO BE ANALYSED Box Guidelines for the Sampling of Fuel Oil for Determination of Compliance with the Revised MARPOL Annex VI RAPID TEMPERATURE CHANGES DISTILLATE FUEL TEMPERATURE LOW FUEL VISCOSITY CLEANING / SEARCHING ACTION OF DISTILLATES LUBRICITY ISSUES AUXILIARY BOILERS 6 7

4 01 EMISSION CONTROL AREAS A KEY ELEMENT OF MARPOL ANNEX VI 1.1 MARPOL ANNEX VI AN INTRODUCTION 1.2 MARPOL ANNEX VI APPLICATION AND OTHER CONTROL REQUIREMENTS 1.3 SULPHUR OXIDES (SO X ) AND PARTICULATE MATTER (PM) EMISSION CONTROLS (REGULATION 14) 1.4 FUEL OIL AVAILABILITY AND QUALITY (REGULATION 18) Box 1 Information to be included in the Bunker Delivery Note Box 2 EU Sulphur Directive 2005/33/EC, amending 1999/32/EC Box 3 California Regulated Waters 12 13

5 CHAPTER 01 EMISSION CONTROL AREAS A KEY ELEMENT OF MARPOL ANNEX VI 1.1 MARPOL ANNEX VI AN INTRODUCTION The International Maritime Organization (IMO) is the United Nations specialized agency with responsibility for shipping. IMO operates through a number of committees, including the Marine Environment Protection Committee (MEPC), which deals with the prevention of pollution from ships. In the 1970 s the International Convention for the Prevention of Pollution from Ships (the MARPOL Convention) was developed by MEPC, providing a comprehensive range of measures to limit the discharge of oil, chemicals, sewage and garbage into the world s oceans and seas. By the 1990 s, however, it had become evident that further issues, including air pollution, needed to be addressed and that if IMO did not take action, individual States would start to enact national measures which could result in a patchwork of differing, and potentially contradictory, requirements. While many such issues, such as the toxic effects of ship s anti-fouling coatings and transfer of foreign organisms in ballast water, have been addressed in specific conventions, the control of air pollution from ships was instead tackled by extending the scope of the original MARPOL Convention via an additional annex, Annex VI, which entered into force in As of November 2011 there are 68 signatories to the Protocol that introduced Annex VI, representing over 91% of the world s gross tonnage. Unlike the preceding Annexes I V, which deal with single topics, MARPOL Annex VI deals with a number of air pollution streams: exhaust emissions, ozone depleting substances, volatile organic compounds and incineration. Within the context of exhaust emissions it is the oxides of nitrogen (NO x ) and the oxides of sulphur (SO x ) that are subject to control: In contrast, SO x emissions are simply a direct function of the sulphur content of the fuel oil used, irrespective of the nature of the particular combustion process, and are therefore controlled in respect of all fuel oils used onboard. Furthermore, controlling fuel oil sulphur content also has a direct effect on reducing the total particulate matter (PM) emissions resulting from combustion. Sulphur is naturally present to a greater or lesser extent in all crude oils. During refining the various forms in which it exists are distributed unevenly across the product range; hence although much of the sulphur will tend to exist in the residual fraction there can still be significant levels in some of the distillates. SO x and PM emissions have detrimental effects on human health and on the natural and built environments and have long been subject to controls in shore-side industry and transport applications. The extension of such controls to shipping is a logical approach to the overall quest for improved ambient air quality especially given the high sulphur content of much of the fuel oil used by ships in the absence of any controls. The approach taken within MARPOL Annex VI to SO x, and hence PM, emission control has been to limit the maximum sulphur content of the fuel oils used, with those limits subject to staged reductions, giving the industry and bunker suppliers time to plan for and adjust to the changes. Furthermore, lower fuel oil sulphur limits apply, with their own sequence of reduction, in areas termed Emission Control Areas (ECAs) where a higher level of protection is required due to such factors as prevailing winds, the proximity of shipping routes to centres of population and the natural susceptibility of an area to acid deposition. SAMPLE CHAPTER 1 The formation of NO x in the combustion process is largely dependant on the peak temperatures encountered causing some of nitrogen in both in the combustion air and in the fuel itself to form oxides. Hence, NO x emissions under the Annex are limited only in respect of diesel engines (which have relatively high peak temperatures as compared to boilers) by means of controlling the NO x critical components and operating parameters. One complication is that the term Emission Control Area is also applied to areas where a higher level of protection against NO x emissions will be afforded. While ECAs established to protect against SO x and PM emissions may be the same as those established to protect against NO x emissions, this is not necessarily so and in any case there are different applications and entry into effect dates. For the purpose of this Guide and Manual the term Emission Control Area or ECA refers to those established for SO x and PM control unless specifically stated otherwise

6 CHAPTER 01 EMISSION CONTROL AREAS A KEY ELEMENT OF MARPOL ANNEX VI 1.2 MARPOL ANNEX VI APPLICATION AND OTHER CONTROL REQUIREMENTS The requirements contained in IMO Conventions such as MARPOL are enacted through the national legislation of those IMO Member States that are signatories to that particular instrument. These requirements therefore apply both to ships flagged in that State and to ships of other States (irrespective of their signatory status) when operating in waters under the jurisdiction of the signatory State. There may also be specific additional requirements (for example, in terms of record keeping) which apply to ships flagged in the signatory State or requirements which apply generally within that State s waters (for example, restrictions on the sulphur content of the fuel oil used at berth). See Box 1 (European Union) and Box 2 (California) as examples of such additional controls. SULPHUR OXIDES (SOx) AND PARTICULATE MATTER (PM) EMISSION CONTROLS (REGULATION 14) 1.3 Regulation 14 of MARPOL Annex VI controls SOx and PM emissions through limits on the maximum sulphur content of the fuel oils used. Outside ECAs the sulphur maximum limits are (Regulation 14.1): 3.50% on and after 1 January % on and after 1 January 2020 (subject to review for possible postponement to 2025) Inside ECAs the sulphur maximum limits are (Regulation 14.4): SAMPLE CHAPTER % on and after 1 July % on and after 1 January

7 02 EMISSION CONTROL AREA CO-ORDINATES 2.1 THE BALTIC AND NORTH SEA AREAS 2.2 THE NORTH AMERICAN AREA 2.3 THE US CARIBBEAN AREA 26 27

8 CHAPTER 02 EMISSION CONTROL AREAS IN DETAIL FIGURE 3 GLOBAL ECAs FIGURE 4 THE BALTIC AND NORTH SEA AREAS 2.1 THE BALTIC AND NORTH SEA AREAS SAMPLE CHAPTER 2 The Baltic and North Sea Emission Control Areas are defined by the following: THE BALTIC AREA The Baltic sea proper with the Gulf of Bothnia, the Gulf of Finland and the entrance to the Baltic Sea bounded by the parallel of the Skaw in the Skagerrak at N. THE NORTH SEA AREA The North Sea proper including the seas therein with the boundary between i) The North Sea southwards of latitude 62 0 N and eastwards of longitude 4 0 W ii) The Skagerrak, the southern limit of which is determined east of the Skaw by latitude N iii) The English Channel and its approaches eastwards of longitude 5 0 W and northwards of latitude N

9 CHAPTER 02 EMISSION CONTROL AREAS IN DETAIL 2.2 THE NORTH AMERICAN AREA FIGURE 5B MAGNIFIED VIEW OF THE PACIFIC COAST FIGURE 5A GENERAL VIEW OF THE NORTH AMERICAN ECA (Enters into effect 1 August 2012) SOURCE: MEPC.1/Circ.723 The North American Emission Control area is not such a readily definable area as the North Sea and Baltic ECAs. It is defined by the coordinates of its three constituent areas: the Pacific coast, The Atlantic and Gulf of Mexico coast, and the Hawaiian Islands. SOURCE: MEPC.1/Circ.723 SAMPLE CHAPTER

10 03 SULPHUR CONTENT OF FUEL OILS AS LOADED Compliance with the ECA requirements is dependent on two key factors: loading fuel oils of the required sulphur content and bringing the ECA-compliant fuel into use as and when required (as covered in Chapter 4 of this Manual). There are no means by which the sulphur content of the fuel oil once loaded can be altered onboard (other than onboard blending, for which at present there are no Guidelines). Consequently it is necessary to ensure that the fuel oils loaded meet the required limits and that, in the case of the ECAcompliant fuel oils, this compliance is not compromised by mixing with other, higher-sulphur fuel oils either in bunker tanks or in the transfer system. The limited mixing that will occur in settling and service tanks when changing from highto low-sulphur fuel oils is covered in Chapter 4. While earlier versions of the ISO 8217 marine fuel specification gave sulphur limits for all grades, the ISO 8217:2010 version gives these only for the distillate grades but even where limits are given these are only from a technical perspective. Therefore irrespective of whether fuel oils (RFO or distillates) are ordered against the ISO 8217 specification (whichever version) or other standards it is necessary for the required maximum sulphur content to be clearly specified; either as part of the bunker nomination or in the charter-party agreement as appropriate. Having specified the sulphur content of the fuel oil to be supplied it is also essential to check the sulphur content of the fuel oil physically supplied noting that the MARPOL Annex VI requirement is for the actual sulphur content, not a typical or maximum value, to be given on the bunker delivery note. The Chief Engineer, or whoever is the officer responsible from the ship s side for the bunkering process, must ensure that the given sulphur content on the bunker delivery note does not exceed the maximum as ordered or specified. The bunker delivery note is the supplier s statement to the ship of the fuel oil s sulphur content and it is this that port State control, or other such agencies, will inspect to ensure that the ship had loaded the required fuel oil. For further details on bunkering and sampling, see Chapter 8 of this Manual

11 04 FUEL OIL CHANGE-OVER PROCEDURES 4.1 CHANGE-OVER PROCEDURE OUTLINE 4.2 FACTORS TO CONSIDER 4.3 CHANGE-OVER TIME CALCULATIONS 4.4 VERIFICATION OF CHANGE-OVER 44 45

12 CHAPTER 04 FUEL OIL CHANGE- OVER PROCEDURES 4.1 MARPOL ANNEX VI REGULATION 14.6 Those ships using separate fuel oils to comply with... [MARPOL Annex VI Regulation 14.4]... and entering or leaving an emission control area... shall 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 specified in [Regulation 14.4]... Typically these procedures would be contained within the ship s overall operating procedures and managed accordingly. The procedures need to be readily available and provide specific instructions on carrying out the fuel change-over procedures. These procedures may be prepared in-house or by outside service providers such as Lloyd s Register FOBAS. Generally each company would utilise a common core text that can be amended to take into account individual ship issues and arrangements. There is no requirement, or provision, for these procedures to be approved by the ship s Administration. CHANGE-OVER PROCEDURE OUTLINE GENERAL: Ship to which the procedure applies. What is to be done. Overall objectives and individual responsibilities. ON ENTRY TO AN ECA: Reference to the ECA boundaries, how the position at completion of the change-over to the ECA-compliant fuel oil is to be determined and the time before reaching that position that the change-over operation is to commence. Any special considerations which would require this to be undertaken earlier than under normal conditions. Required communications between bridge and engine room. ON EXIT FROM AN ECA: Reference again to the ECA boundaries and how the position at the start of the change-over to the higher-sulphur fuel oil is to be determined. Any special considerations which would require this to be undertaken later than under normal conditions (this could include not changing over when the ECA is to be shortly re-entered or for other reasons). Required communications between bridge and engine room. EQUIPMENT: Listing of the combustion equipment (engines, boilers, etc.) to which the change-over applies. ECA FUEL OIL: Verification that fuel oil to be used within ECA is compliant (ie from BDN) and that the required consumption quantities are onboard or will be supplied. PROCEDURE: Identification of key fuel system components, including system drawings as necessary. Detailed procedures as to required levels in tanks through the process and the sequences and timings (and what influences these) in which valves are to be operated. RECORD-KEEPING: What is to be recorded, when and where that record is to be made and by whom. SAMPLE CHAPTER 4 OPERATING AND SAFETY CONSIDERATIONS. NOTE: These procedures may also provide the basis of the change-over procedures required to comply with other control measures (such as the EU At Berth regulations) which necessitate change-overs of fuel oil. In such cases specific attention would be required to the particular fuel oil grades involved and the exact requirements of those controls

13 CHAPTER 04 FUEL OIL CHANGE- OVER PROCEDURES 4.2 FACTORS TO CONSIDER CHANGE-OVER TIME CALCULATIONS 4.3 Any conditions or parameters specified in the machinery manufacturer s guidelines. Change-over times dependent upon engine load and temperature differentials in RFO and LSRFO/MGO/MDO transition modes. The maximum main engine load at change-over and the duration of any load reduction. When switching to MGO/MDO identify minimum viscosity allowable in the engine and other critical components and hence fuel-specific maximum allowable temperature(s) to maintain required viscosity (this may include machinery component manufacturer s instructions as to minimum viscosity/maximum temperature of fuel grades). Cylinder oil lubrication requirements (where applicable) e.g. correct feed rates for each fuel grade/type, procedures relevant to change-over to different BN lubricant where applicable. Means of monitoring engine load performance, cylinder components condition and injection pump internal leakage when operating with LSRFO/MGO/MDO for extended periods. Procedures for compatibility testing between the different fuels to be used in the change-over process. Contingency procedures in the event of: sub-standard fuel quality, or incompatibility between LSRFO/MGO/MDO and RFO engine failures from vapour lock emergency operations on MGO/MDO. As stated above, it is essential that the change-over procedure includes the means by which the time between commencing and completing the change-over is to be determined, taking into account: Fully-segregated system or non-segregated fuel service tank systems; Volumes of tanks (in the case of non-segregated systems) and piping systems within which the LSRFO mixes with the HSRFO (including fuel de-gassing/ mixing tank); Sulphur content of HSRFO; Sulphur content of LSRFO; Ship fuel consumption rates (as a function of load) at change-over; Return oil flow to fuel service tank or de-gassing / mixing tank (as applicable) SAMPLE CHAPTER 4 In the case where there are segregated service tanks the change-over time will tend to be very short due to the generally high ratio between consumption rate and fuel service system volume (although if changing over to or from distillate, the time is generally dictated by the need to control the temperature gradient). However where there is only a single system, the LSRFO needs first to be introduced into the settling tank and then to work its way gradually through to the service tank and then the fuel oil service system: a much more involved process. Lloyd s Register FOBAS provides a fuel change-over calculator spreadsheet that is available from its website or on request. This tool provides an estimate of the time required to dilute and flush through the combined system in order to achieve the required sulphur content in the fuel supply system. The calculation assumes a complete linear blend of the two fuels during the dilution stage

14 05 CONSIDERATIONS WHEN SWITCHING TO LOW-SULPHUR RESIDUAL FUEL OIL 5.1 CYLINDER LUBRICATING OIL (CLO) SELECTION FOR CROSS-HEAD ENGINES 5.2 FUEL COMPATIBILITY 5.3 IGNITION AND COMBUSTION CHARACTERISTICS 5.4 CATALYST FINES 52 53

15 CHAPTER 05 CONSIDERATIONS WHEN SWITCHING TO LOW-SULPHUR RESIDUAL FUEL OIL 5.1 CYLINDER LUBRICATING OIL (CLO) SELECTION FOR CROSS-HEAD ENGINES BACKGROUND The Base Number (BN) requirements of the cylinder oil vary with the sulphur content of the fuel. For example a BN70 lubricant is typically used for high-sulphur fuel oils, with sulphur in excess of 1.50% but as sulphur content is reduced, lower BN cylinder oil may be required, since there is less acidity to neutralise. Typically, a low-sulphur fuel oil with sulphur content ranging from 0.50% to 1.50% may be best matched with a CLO of BN between 30 and 40. Switching to a CLO with a lower BN is generally recommended by the engine builders when a low-sulphur fuel is to be used for more than 5-8 days. The manufacturer s guidelines however should be consulted to ascertain the correct BN number for the specific engine type and the sulphur content of the fuel, the length of time the engine can be run before the cylinder oil type must be switched over, and whether it is appropriate to make adjustments to the cylinder oil feed rate. POTENTIAL PROBLEMS Extended operations using inappropriate CLO and/or with incorrect feed rate settings may result in damage to the cylinder liner and piston rings. Consider the following two scenarios: 01 Low sulphur fuel of 1.00% operating with a CLO of BN 70. An extended period of operation on such fuel oil is likely to lead to undepleted base, leaving hard deposits on the piston crown and fouling of piston ring grooves. If excess deposit builds up, this can lead to scuffing and possibly severe wear of the liner and piston rings. This scenario may raise the risk of liner lacquering through the formation of hard calcium deposits on the cylinder liners. This is due to excessive alkaline compounds in comparison with the acid present. The resulting deposits can lead to bore polishing and sudden and acute wear of the liner as a result of the lubricant failing to adhere effectively to the liner surface. 02 High-sulphur fuels, well in excess of 1.00%, operating on a CLO with a low BN such as a 40. SAMPLE CHAPTER 5 Extended operations could lead to an excessive degree of corrosion of the liner surface leading to cylinder liner deterioration

16 CHAPTER 05 CONSIDERATIONS WHEN SWITCHING TO LOW-SULPHUR RESIDUAL FUEL OIL REQUIRED ACTIONS For ships with cross-head engines expecting to operate regularly for extended periods on different sulphur content fuels, at least two separate CLO storage tank facilities should be considered in order to segregate CLOs of different BN and in anticipation of having to use both high- and low-sulphur fuels. FIGURE 8 EXAMPLE CYLINDER OIL FEED RATES DEPENDING ON THE FUEL SULPHUR LEVEL As part of the change-over plan full consideration must be given to the CLO type and feed rate settings on and the time the ship will be operating on the non-standard fuel. Alternatively a universal lubricant could be used which can be compatible with both low- and high-sulphur fuels although currently there are limited options and availability for this type of CLO on the market. Apply improved diagnostic tools and methods to optimise settings such as: increased spot checks on condition of the cylinder liners and pistons; enhanced engine performance monitoring techniques such as Lloyd s Register FOBAS Engine which offer a comprehensive engine performance review; crew training to heighten awareness of potential issues NOTE: when the switch to low-sulphur fuel will be for a short time only, optimising the feed rate may be an appropriate way to offset the effects of high-bn lube oil, without the need to change the oil itself. There are no hard and fast rules, and the optimal feed rate will vary according to the ship-specific engine and operating conditions. Crew should take observations and adjust settings; also consult manufacturers guidelines such as that shown below for MAN engines. SOURCE: MAN Diesel: Guidelines for Fuels and Lubes Purchasing Operation on Heavy Residual Fuels FIGURE 9 RESULTS OF OVER-LUBRICATION SAMPLE CHAPTER 5 Hours on LSFO and BN 70 lubricant: 2,500 Cylinder oil feed-rate: 1,0 g/kwh 56 57

17 CHAPTER CONSIDERATIONS WHEN SWITCHING TO DISTILLATES 6.1 RAPID TEMPERATURE CHANGES 6.2 DISTILLATE FUEL TEMPERATURE 6.3 LOW FUEL 6.4 CLEANING / SEARCHING ACTION OF DISTILLATES 6.5 LUBRICITY ISSUES 6.6 AUXILIARY BOILERS 64 65

18 CHAPTER 06 CONSIDERATIONS WHEN SWITCHING TO DISTILLATES The change-over issues relating to CLO BN and compatibility are more pronounced when the change-over is to a distillate fuel. In such cases the sulphur content can be an order of magnitude lower than LSRFO, with obvious implications for CLO BN requirements. The risk of incompatibility between RFO and some distillates is also much higher due to the fundamental differences between those fuels. However with distillates there is a greatly reduced risk of poor ignition or combustion performance and the level of cat fines should be zero. NOTE: If the fuel oil supply system is to be changed over for a period to operate on distillate it is important that normal operating temperatures are retained within the RFO system (i.e. settling and service tanks) so that it will be ready for use when required. If the purifiers are left in operation (i.e. circulating through the purifiers to the service tank and then spilling back to the settling tank) it is important to ensure that the spill back arrangement is in place as required and is indeed handling the required flow (and not blocked with accumulated deposits). Purifier pumps must not be left simply churning the fuel or heaters operating with a static charge of RFO. RAPID TEMPERATURE CHANGES BACKGROUND The difference in correct operating temperature between RFO and distillates can be over 100 C. If cold distillate is suddenly introduced into a fuel oil system at RFO injection temperatures the differing rates of contraction of the various components can result in the limited design clearances being compromised to the point where interference occurs. It is equally important that the change-over from distillate to RFO is undertaken in a controlled manner. POTENTIAL PROBLEMS Sticking/scuffing of fuel valves, fuel pump plungers and suction valves and, in extreme cases, pump plunger seizure. REQUIRED ACTION Engine builders generally recommend that temperature change should occur at no more than 2 C per minute, with additional time built in to allow for uneven rates of change. So for instance, when changing from RFO at a temperature of 150 C and decreasing to a maximum of 40 C a differential of 110 C that implies a minimum 55- minute procedure at least an hour should be allowed to complete the change-over, either from RFO to distillate or distillate to RFO. Unless an automated fuel switchover system is installed, normal practice is to run the engine at low power (30-70% MCR manoeuvring speed) in order to limit the fuel flow rate through the system. Engine- specific guidelines should be followed. 6.1 SAMPLE CHAPTER

19 CHAPTER 06 CONSIDERATIONS WHEN SWITCHING TO DISTILLATES 6.2 DISTILLATE FUEL TEMPERATURE BACKGROUND Distillate fuels do not require heating to achieve injection viscosity. Therefore care must be taken to keep such fuels cool enough to avoid operating problems, particularly where they are used in systems that normally operate on RFO. The way in which viscosity changes with temperature is shown below. FIGURE 10 THE RELATIONSHIP BETWEEN FUEL TEMPERATURE AND VISCOSITY THESE PARAMETERS ARE NOT USUALLY AN ISSUE FOR DESULPHURISED FUELS AS THE MANUFACTURING PROCESS TENDS TO BREAK DOWN THE WAXY COMPOUNDS RESULTING IN ELEVATED VALUES. POTENTIAL PROBLEMS If the temperature of the distillate fuel rises the viscosity will be reduced, potentially to the point where it is no longer capable of forming the required hydrodynamic film between moving surfaces, resulting in wear, even seizure, between those non- supported components. SAMPLE CHAPTER 6 Fuel with an unduly low viscosity will flow through fine clearances that were previously sealed when the viscosity was higher. A good indicator that the temperature of the fuel system is too high is an increase of fuel leakage, particularly around pump rotors, suction and spill valve push rods and past injection pump plungers barrels and fuel valves. On the other hand the pour point, cold filter plugging point or cloud point values of some distillate fuels can require certain minimum temperatures to be maintained, either during storage (to avoid solidification), or in use (to avoid blockages, particularly in filters and other fine clearances). These parameters are not usually an issue for desulphurised fuels as the manufacturing process tends to break down the waxy compounds resulting in elevated values. However, it may be a problem if the fuel is from a naturally low- sulphur crude and has not been subject to extensive refining, in which case care will be needed to maintain the required minimum temperatures particularly when moving from warm to cooler climates. A further problem can be gassing up of hot distillate fuel in the fuel supply system resulting in vapour locking and hence engine fuel starvation. If the fuel temperature at injection is too high, the resulting very low viscosity will also adversely affect combustion performance. Apart from the risk of seizure of the injector needles, the resulting spray pattern will not adequately penetrate the combustion space, resulting in poor fuel utilization and uneven heat distribution

20 07 CONTINUOUS OPERATION WITHIN ECAs 7.1 ENGINE LUBRICANTS 7.2 BUNKERING SEGREGATION 7.3 FUEL TEMPERATURE CONTROL 7.4 FUEL SYSTEM AND ENGINE COMPONENTS 76 77

21 CHAPTER 07 CONTINUOUS OPERATION WITHIN ECAs Ships that operate all the time within ECAs will of course avoid all the complications related to change- overs and having two different grades of fuel oil onboard. In these cases it will be possible to optimise for the use of LSFO. Currently this may be either a LSRFO or a distillate, and the choice will be principally a commercial decision. From 1st January 2015, however, when the ECA limit reduces to 0.10%, it is expected that only distillate fuel will be used. The areas of optimisation are set out in the sections that follow. ENGINE LUBRICANTS CROSS-HEAD ENGINES: the cylinder oil should be changed for one of the required Base Number and the flow rate optimised, which may require on- going evaluation support. TRUNK PISTON ENGINES: system oil type should be changed to one specifically formulated for use with controlled sulphur content fuel oils. BUNKERING SEGREGATION Generally it has remained standard practice, as with RFO, to bunker different consignments of LSRFO into different tanks wherever possible. Fuel quality issues for distillates are anticipated to become more frequent as demand for distillates increases, and therefore extending the policy of separate tanks for different bunker stems will be equally appropriate in the case of distillates. It limits the risk of poor- quality fuel contaminating other fuel, rendering both consignments unsatisfactory. FUEL TEMPERATURE CONTROL If a ship is operating only on distillate fuels it would be appropriate to consider the degree to which the ship s fuel heating arrangements can be de- commissioned, bearing in mind whether the ship is likely to remain in that area or whether it could be deployed (or sold) elsewhere. None of the current or announced ECAs are known as areas where relatively high pour points / cold filter plugging point temperatures are encountered; however they do include areas of particularly low ambient and sea water temperatures and therefore there will be a need to maintain certain basic minimum temperatures in storage. Generally, ships built for distillate- only operation have not needed fuel cooling / chilling systems and, provided that fuels are ordered to the ISO 8217:2010 specification, this should remain the case. In exceptional cases where such equipment is used, operators should perhaps ask why the fuel is being heated in the first place, rather than installing further equipment to remove that heat. In view of the reduced tolerance of distillate fuel to worn or poorly- fitting equipment it is necessary to consider which items, especially pumps, injectors, booster pumps, transfer pumps may need to be renewed or overhauled, depending on their condition and longer- term suitability for operating continuously on distillate fuels. 7.3 SAMPLE CHAPTER 7 FUEL SYSTEM AND ENGINE COMPONENTS

22 08 THE MARPOL SAMPLE 8.1 GENERAL SAMPLING PROCEDURES FOR OBTAINING THE MARPOL SAMPLE 8.2 ACTIONS IF IT APPEARS THAT THE REQUIRED PROCEDURES HAVE NOT BEEN FOLLOWED 8.3 IN THE EVENT THE MARPOL SAMPLE IS TO BE ANALYSED Box Guidelines for the Sampling of Fuel Oil for Determination of Compliance with the Revised MARPOL Annex VI 80 81

23 CHAPTER 08 THE MARPOL SAMPLE NOTE: This section applies to ships that are required to retain Bunker Delivery Notes onboard, ie 400GT and above, not on limited voyages. Fuel sampling is a vital part of the bunkering process. It is the only direct evidence of a fuel s characteristics as bunkered that a ship has in the instance of later disputes and inspections. In order for samples to be valid, correct procedure MUST be followed when drawing, sealing and storing samples. Correct recording and documentation is also vital. Regulations and require that the supplier is to provide a representative sample of the fuel oil delivered the MARPOL Sample. This sample is not to be confused with either the supplier- provided commercial sample or any sample the ship may draw for its own purposes (eg despatch to one of the fuel oil testing services such as FOBAS). Unlike the other fuel samples that may be drawn from a particular fuel stem there is only one MARPOL Sample for each bunkering. Drawn by the supplier and retained by the receiver (the ship), it is to be kept under the ship s control for at least 12 months or until the fuel it represents is substantially consumed. Ideally all samples (MARPOL Sample, commercial samples and fuel testing sample) would all be drawn from the same, homogenous, primary sample thereby avoiding the disputes arising where results from different sourced samples are compared. IMO has issued Guidelines for the sampling of fuel oil for determination of compliance with MARPOL Annex VI (MEPC.182(59)), reproduced in full in Box 4 below. These Guidelines give the default procedure for how and where to draw the Primary Sample, how this should be sub- sampled to give the MARPOL Sample, how that sample should be sealed and labelled, together with the actions required on the ship. The Guidelines set the outline which the authority responsible for overseeing the local Bunker Supplier Registration Scheme would apply in its area. The authority has the flexibility to accept alternative arrangements to those given in the IMO Guidelines, so long as those alternative arrangements are equivalent to the Guidelines, in terms of providing a reliable example of the fuel oil as actually supplied. This flexibility may be in respect of relatively minor matters. Clause 5.3 of the Guidelines states that the MARPOL Sample should be drawn at... the receiving ship s inlet bunker manifold.... However a supplier may have demonstrated to the authority that it fully drains down the bunkering hoses between deliveries (a point which the authority could subject to unscheduled inspection) and hence there is no risk of material remaining in the hose which would not be sampled by drawing the sample at the bunker barge manifold. In other instances the flexibility might be extremely wide. One of the duties of an off- shore support ship can be to supply fuel oil to a drilling rig. A group of high- speed ferries on a regular service may bunker for each trip (to avoid carrying extra unnecessary weight) from a common shore tank. In this and any number of other specific cases, the direct application of the requirements as given in the Guidelines would be impossible, impractical or unrealistic. In these instances the supplier and authority would need to find a way in which the basic principle behind the Guidelines (a representative sample of the fuel supplied to a ship) is upheld while allowing for particular operating scenarios. Hence, it may be that the actual procedures applied differ, at least to some extent, with the agreement of the responsible authority from the procedures as given in the Guidelines. Where this occurs, the supplier should be able to demonstrate that those differences represent alternative, equivalent, arrangements as agreed to by the authority responsible for the application of the Bunker Supplier Registration Scheme under which it operates. SAMPLE CHAPTER

24 CHAPTER 08 THE MARPOL SAMPLE 8.1 GENERAL SAMPLING PROCEDURES FOR OBTAINING THE MARPOL SAMPLE The basic requirements for obtaining the MARPOL Sample are given in MEPC.182(59). This states that the MARPOL sample should be obtained using a continuous drip sampler at the receiving ship s inlet bunker manifold and should be drawn continuously throughout the bunker period. However, as above, some Bunker Supplier Registration Schemes may have approved alternatives, so this needs to be considered on a case- by-case basis. As in any sampling operation the basic good practice principles should be followed. ISO is the standard covering Petroleum products Procedures for transfer of bunkers to vessels. It includes industry- standard and bestpractice approaches to sampling. The following are some key precautions to ensure that the samples collected are truly representative: The whole of the fuel oil supplied is sampled; The sampling rate is uniform to flow and sufficient to obtain the required volume of primary sample; The sample is drawn from a point which draws directly from the fuel oil being supplied; There is no contamination from: Previous supplied fuel oil in the bunker lines or probes; Extraneous material not cleaned from the probe or sampling equipment; Materials used to clean the probe or sampling equipment; Surroundings (i.e. dust, rain); The primary sample is thoroughly homogenised before sub- sampling to give the MARPOL Sample (and any other samples). A record should be kept of the key events relating to the bunker supply; what was seen and what was not seen. Where the supplier s actions and procedures appear not to correspond with those required by the Guidelines, can those be justified by reference to alternative procedures agreed by the responsible authority? If that is not the case, or where actions take place outside the view of the ship s representative this information should be duly recorded. Do not sign any documentation unless the actual event to which it refers has been witnessed. If a sample is handed to the ship that has not been witnessed then sign for receipt only, source unknown. Never sign any blank labels for the barge crew. AS IN ANY SAMPLING OPERATION THE BASIC GOOD PRACTICE PRINCIPLES SHOULD BE FOLLOWED. ISO IS THE STANDARD COVERING PETROLEUM PRODUCTS PROCEDURES FOR TRANSFER OF BUNKERS TO VESSELS. IT INCLUDES INDUSTRY-STANDARD AND BEST- PRACTICE APPROACHES TO SAMPLING. SAMPLE CHAPTER 8 The MEPC.182(59) Guidelines stipulate the sealing requirements for the MARPOL Sample, the information to be given on its label and the ship s representative s task in signing for that sample

25 CHAPTER 08 Fathom 27 Sheet Street Winsor, Berkshire SL4 1BN +44 (0) Knowledge Intelligence Insight 92