MARPOL Annex VI

Operation in SOX Emission Control Areas, how to comply

Operation in SOX Emission Control Areas (SECAs) introduces new challenges to

ship operators, both with respect to bunker management and voyage planning.
The scope of this guidance note is to assist ship operators to comply with
regulation 14 of Marpol Annex VI.

SOX Emission Control Areas (SECA)

Annex VI to MARPOL 73/78 limits the sulphur content of
marine fuel oil to 1.5% per mass and will apply in designated
SECAs. The first SECA is the Baltic Sea which enters into force
on the 19 May 2006. The North Sea Area and the English Chan-
nel SECA will enter into force 22 November 2007. The geograph-
ical boundaries for these two SECAs (Fig. 1) are defined in
MARPOL 73/78. (Note that EU directive 2005/33/EC, requires
ships to burn fuel oil with less than 1.5% sulphur in the North
Sea SECA from 11 August 2007.) New SECAs are expected to be
adopted in the future based on certain criteria and procedures
for designation of SECAs as given in Appendix III to Annex VI.

Guidelines for part-operation in SECAs

Almost all ships will continue to operate on high sulphur fuel oil
(HSFO) outside the SECAs, mainly due to the high price and low
availability of low sulphur bunkers in many ports. These ships will
therefore need to switch to low sulphur fuel oil (LSFO) before
entering a SECA. Regulation 14 (6) requires ships to allow suffi-
cient time for the fuel oil service system to be fully flushed of all
fuels exceeding 1.5% sulphur prior to entering a SECA. The time
it takes to flush the fuel oil system of fuel oil exceeding 1.5% is a
function of:
n Sulphur content in high and low sulphur fuel oil,
n Amount of high sulphur fuel between first point of blending
and engine inlet, i.e. blending volume, and
n Fuel oil consumption rate.
A plot of this function (Fig. 2) shows the sulphur dilution time in
percent of the fuel oil hours contained in the blending volume. It
should be emphasised that this plot is a theoretical approximation
with a built in safety factor, but without necessarily taking all opera-
tional procedures on board into consideration no guaranty can be
given. Owners could contact DNV Petroleum Services (DNVPS) for a
more accurate calculation on a ship to ship basis to reduce the time
needed for the changeover process. For each SECA voyage, ship
operators will need to have knowledge of the required changeover
time and incorporate this is in the voyage planning for the ship.
Fig. 1: Geographical boundaries for the Baltic Sea SECA
and the North Sea Area and the English Channel SECA.
The optimal fuel oil (FO) system for switching to LSFO is to
have double service and double settling tanks, which allows LSFO
to be completely segregated from HSFO from the storage to the
service tank. Blending will only takes place in the piping between
the service tanks and the inlet to the engine.
If the FO system contains two service tanks and two settling
tanks, and the blending volume contains fuel oil for 15 minutes of
operation, the dilution time according to the graph below is
240%*15 minutes = 36 minutes when switching from HSFO with
2.8% S (world average) to LSFO with 1.3% S.
If the FO system contains two service tanks and one settling tank,
the dilution time will be the same as for the previous example if one
of the service tanks is already filled with LSFO. The settling tank
should be emptied (either by pumping the HSFO back to storage or
by consumption), and refilled with LSFO prior to entering a SECA.
If the FO system contains one service tank and one settling
tank, the changeover time will be substantially longer. The first

DNV Maritime
Fig. 2: Dilution time to reach 1.5% S in percent of the fuel oil hours contained in the blending volume.
point of blending is the settling tank and the blending volume
will comprise of the settling tank, service tank and connected pip-
ing. If the settling tank and service tank each contain FO for 12
hours of operation, and we assume one hour of FO in the piping,
the dilution time is 240%*25h=60h.
The dilution time can be reduced by minimising the service
and settling tank contents prior to changeover to LSFO, however
DNV recommends that the service tank contains enough fuel oil
for continuous rating of the propulsion plant and normal operat-
ing load at sea of the generator plant for a safe period of time,
e.g. eight hours. Another possible solution is to install new set-
tling and service tanks, or to divide existing tanks if this does not
impair the required capacity of HSFO used outside the SECA.
Such modifications need to be approved by DNV.
Demonstrating compliance
Details of fuel oil changeover procedures from HSFO to LSFO,
and vice versa, need to be recorded as required by Regulation
14(6) of Annex VI. The volume of LSFO in each tank, as well as
the date, time, and the position of the ship when any fuel
changeover operation is completed, is to be recorded in log
books, i.e. the engine room log book. It should be noted that non
compliance with regulation 14 while operating inside the SECA is
a detainable deficiency and it is the shipowner’s responsibility to
document that the fuel oil burned within the SECA has a net sul-
phur content below 1.5%.
For more information, please contact:
DNV, Cargo handling, Piping Systems, Marpol and Gas Carriers (MTPNO880@dnv.com)
DNVPS, DNV Petroleum Services (DNVPS.OSLO@dnvps.com)
Alternatives
MARPOL Annex VI, Regulation 14 (4b) gives the option of using
an exhaust gas cleaning system (EGCS) which reduces the total
SOX emissions to 6.0 g/kWh. The development of stack-scrubbers
for ships is still at an early stage and local authorities may prohibit
discharging waste streams from scrubbers in ports and estuaries.
Risk of incompatibility and cylinder wear
Ship operators should assure that the LSFO oil is compatible with
the HSFO by sending a representative sample of each fuel oil
quality to a fuel oil testing company such as DNVPS. Blending
high density fuel oil with low density fuel gives the highest risk of
incompatibility, while blending two low density fuel oils repre-
sents the lowest risk. The blending ratio should in any case be as
small as possible.
High base number (BN) lube oil in combination with low-sul-
phur fuel increases the risk of scuffing on the cylinder liner. The
deposits are more solid when less oil BN additives are neutralised
by sulphuric acid. DNV recommends carefully monitoring the
cylinder liner condition when operating on low sulphur fuel oil,
and if necessary change to low BN cylinder oil or reduce the feed
Design & production: Coor Graphic Services 0604-047
rate in accordance with the engine makers recommendations.
New cylinder oil tanks may need to be installed onboard and
approved by DNV.
300/ 5-2006
DNV PETROLEUM SERVICES

EU/SECA MARINE DISTILLATE FUEL SULPHUR REGULATIONS

SULPHUR LIMIT
FUEL TYPE VESSEL LOCATION REMARKS
(% m/m)
Inside EU territorial seas With effect from 1 January
and inland waterways (but 2010, Member States shall
excluding Greece, the French ensure that MGO placed on
≤0.10% the market has ≤0.1% m/m
DOM-TOM, Maderia, the
MGO sulphur content
Azores and the Canary Islands)
(DMA/DMX)
Outside EU territorial seas but ≤0.10% m/m when vessel
within a SECA (only in a SECA location is in a SECA that
that falls outside EU territorial ≤1.50% falls inside EU territorial
seas) seas)

Member States shall ensure

Inside SECA (and in EU that MDO placed on the
territorial seas that falls within a ≤1.50% market has ≤1.5% m/m
MDO SECA) sulphur content
(DMB/DMC) Outside SECA (regardless of Max. sulphur content for
inside or outside EU territorial DMB and DMC grades
≤4.50% according to ISO 8217:2005
seas)
= 2.00% m/m
≤0.10% if the blended Fuel in use must be
product has a viscosity or documented in engine log
book
density falling within the
ranges of viscosity or ≤1.50% when inside EU
density defined for DMX territorial seas that fall within
and DMA under ISO a SECA, if the blended
8217:2005 product has a viscosity or
Inside EU territorial seas
density exceeding the upper
Distillate fuel limit ranges of viscosity or
mixture ≤4.50% if the blended density defined for DMA
(MGO/MDO product has a viscosity or under ISO 8217:2005
Mixture) density exceeding the
upper limit ranges of Maximum sulphur content
viscosity or density defined for DMB and DMC grades
for DMA under ISO according to ISO 8217:2005
8217:2005 = 2.00% m/m
Outside EU territorial seas but
within a SECA (only in a SECA
that falls outside EU territorial ≤1.50% --
seas)

Notes

1. ‘Territorial sea’ is defined as “a state's territorial sea that extends up to 12 nautical miles from its baseline”.

2. There is a Marine Fuel sulphur limit of ≤1.50% m/m for passenger ships operating on regular services to or from
any community port in EU territorial seas, exclusive economic zones (extends up to 200 nautical miles from a
State’s baseline) and pollution control zones.

3. From 1 January 2010, a 0.1% sulphur limit will apply to all types of marine fuel used by ships at berth in EU
ports and by inland waterway vessels.

January 2008