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Quality of marine fuels ISO 8217:2010 Fuel Regulations and the Environment SOx emission control
by Maria Kyratsoudi
FOBAS Specialist
Hellenic Lloyds SA A member of the Lloyds Register Group
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 8217:2010
Residual 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 (ECAs) 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 measurable acid 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
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
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
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
Regulation 18
Representative sample to be sealed and signed by the suppliers representative and the master or officer in charge of the bunker operation 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.
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 compliance Evidence of attempt to purchase Not physically available what action taken Competent authority to take the above into account when considering what, if any, action to be taken
x x x x x x x x x x
Sulphur Test Method ISO 8754:2003 Lower Limit Supplier 95% 4.28 0.94 0.09 Upper Limit Buyer 95% 4.72 1.06 0.11
The Buyer can consider the sample to FAIL the regulation with 95% confidence if his single 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
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
Acceptable
Not Acceptable
EU Directive 2005/33/EC
Jan 2010 At berth requirement 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
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. sulphur or 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
2006
2007
2008
2009
2010
2012
2015
2020
January 2010 0.1% sulphur limit on all marine fuel at berth in EU ports CARB (Phase I): DMA 1.5% DMB 0.5% January 2012 CARB (Phase II): DMA 0.1% DMB 0.1%
11 August 2006 EU Member States laws enacted: 1.5% in Baltic SECA 1.5% for passenger ships between EU ports Use of abatement technology