Eng Cir 02 of 2019 Enclosure - RESOLUTION MEPC 320-2019

RESOLUTION MEPC.320(74) 2019 GUIDELINES FOR CONSISTENT IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT UNDER MARPOL ANNEX VI THE MARINE ENVIRONMENT PROTECTION COMMITTEE, RECALLING Article 38(a) of the Convention on the International Maritime Organization concerning the functions of the Marine Environment Protection Committee (the Committee) conferred upon it by international conventions for the prevention and control of marine pollution from ships, RECALLING ALSO that, at its fifty-eighth session, the Committee adopted, by resolution MEPC.176(58), a revised MARPOL Annex VI which significantly strengthens the emission limits for sulphur oxides (SO ), X RECALLING FURTHER that, at its seventieth session, the Committee adopted, resolution MEPC.280(70), Effective date of implementation of the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI, confirming "1 January 2020" as the effective date of implementation for ships to comply with global 0.50% m/m sulphur content of fuel oil requirement, NOTING ALSO that, at its seventy-third session, the Committee approved circular MEPC.1/Circ.878 on the Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, HAVING CONSIDERED, at its seventy-fourth session, draft 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, prepared by the Sub-Committee on Pollution Prevention and Response, at its sixth session, 1 ADOPTS the 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, as set out in the annex to the present resolution; 2 REQUESTS Parties to MARPOL Annex VI and other Member Governments to bring these Guidelines to the attention of shipowners, ship operators, fuel oil suppliers and any other interested groups; 3 AGREES to keep these Guidelines under review in the light of experience gained with their application.- 2 - ANNEX 2019 GUIDELINES FOR CONSISTENT IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT UNDER MARPOL ANNEX VI 1 Introduction 1.1 Objective 1.1.1 The purpose of these Guidelines is to ensure consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. These Guidelines are intended for use by Administrations, port States, shipowners, shipbuilders and fuel oil suppliers, as appropriate. 1.2 Definitions 1.2.1 For the purpose of these Guidelines, the definitions in MARPOL Annex VI apply. 1.2.2 The following definitions of fuel oils are used, as applicable: .1 Distillate marine fuels (DM) are as specified in ISO 8217:20171 (e.g. DMA, DMB, DMX, DMZ); .2 Residual marine fuels (RM) are as specified in ISO 8217:20171 (e.g. RMD 80, RMG 380); .3 Ultra-low sulphur fuel oil (ULSFO) are as specified in ISO 8217:20171 (e.g. maximum 0.10% S ULSFO-DM, maximum 0.10% S ULSFO-RM); .4 Very low sulphur fuel oil (VLSFO) (e.g. maximum 0.50% S VLSFO-DM, maximum 0.50% S VLSFO-RM); and .5 High sulphur heavy fuel oil (HSHFO) exceeding 0.50% S. 2 Ship implementation planning for 2020 2.1 MEPC 70 agreed to "1 January 2020" as the effective date of implementation for ships to comply with the 0.50% m/m fuel oil sulphur content limit requirement and adopted resolution MEPC.280(70) on the Effective date of implementation of the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI2. 2.2 In this context, MEPC 73 agreed that Administrations should encourage ships flying their flag to develop implementation plans, outlining how the ship may prepare in order to comply with the required sulphur content limit of 0.50% by 1 January 2020. The plan should be complemented with a record of actions taken by the ships in order to be compliant by the applicable date. 2.3 MEPC 73, recognizing the need for guidance to support the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, approved MEPC.1/Circ.878 on the Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. 1 The latest edition of the ISO standard is recommended. 2 Regulation 14.1.3 of MARPOL Annex VI, was amended by resolution MEPC.305(73).- 3 - 3 Impact on fuel and machinery systems 3.0.1 The experiences and lessons learned from the transition to the 0.10% m/m SO -ECA X limit indicated that current ship machinery operations should be sufficiently capable of addressing the concerns regarding combustion of the new 0.50% m/m limit fuel oils. 3.0.2 Currently most of the marine diesel engines and boilers on ships operating outside Emission Control Areas (ECAs) are optimized to operate on heavy fuel oil. From 2020 ships are required to use fuel oils with a sulphur content of 0.50% m/m or lower, unless fitted with an approved equivalent means of compliance. 3.1 Distillate fuels 3.1.1 A major challenge with distillate fuels is low viscosity. Low viscosity may cause internal leakages in diesel engines, boilers and pumps. Internal leakages in fuel injection system may result in reduced fuel pressure to the engine, which may have consequences for the engine performance (e.g. starting of the engine). Equipment makers recommendations should be taken into account, and adequate testing, maintenance and possible installation of coolers, etc., may be performed. 3.1.2 Cold Filter Plugging Points (CFPP) and Cloud Points (CP) as well as the Pour Point (PP) for distillate fuels need to be considered in light of the ship's intended operating area and ambient temperatures. 3.1.3 These issues are critical concerns as they can result in the formation and accumulation of wax sediment, which can cause costly and avoidable maintenance. In the worst-case scenario, sediment can cause engine fuel starvation and power loss. 3.1.4 ISO 8217:20173 limits the cold flow properties of a fuel through setting a limit on the PP. However, given that wax crystals form at temperatures above the PP, fuels that meet the specification in terms of PP can still be challenging to operations in colder operating regions, as the wax particles can rapidly block filters, potentially plugging them completely. For cold weather, additional cold flow properties, CFPP and CP, should be reported by the supplier when the receiving ship has ordered distillate fuel for cold weather operations, a requirement that is specified in ISO 8217:20173. 3.1.5 Since the residual fuels are usually heated and distillate fuels are not heated, particular attention needs to be given to the cold flow properties of distillates. Cold flow property challenges can be managed by heating the fuel. CIMAC has issued "01 2015 CIMAC Guideline Cold flow properties of marine fuel oils"4. 3.1.6 Fuel temperature should be kept approximately 10°C above the PP in order to avoid any risk of solidification, however this may not reduce the risk of filter blocking in case of high CFPP and CP. 3.1.7 It is good practice to review the possibilities of heating arrangements for distillate fuels on board. This is usually very limited, as it is not standard practice to have heating arrangements in distillate storage, settling or service tanks. Transfer arrangements may be adapted to pass through a residual fuel oil heat exchanger should the need arise. 3 The latest edition of the ISO standard is recommended. 4 https://www.cimac.com/cms/upload/workinggroups/WG7/CIMAC_WG7_2015_01_Guideline_Cold __Flow_Properties_Marine_Fuel_Oils_final.pdf- 4 - 3.1.8 Knowing the fuel properties before bunkering will assist in taking the necessary precautions where and when necessary. If the ship is heading towards colder climates and the cold flow properties are inferior, the fuel may be: .1 either used before entering cold regions, or .2 used with suitable heating arrangement, as mentioned above. 3.1.9 If the approach of applying heat is being followed it should be ensured that the fuel is not overheated resulting in the viscosity dropping below the minimum recommendation of 2 cSt at any point in the fuel system, including the engine inlet. In order to reduce this risk, heating should be limited to max 40°C. 3.2 Distillate fuel with FAME content 3.2.1 Increased demand for Distillate fuels may result in more land based products making their way into the marine supply pool, some of these fuels (e.g. biodiesel) may contain Fatty Acid Methyl Ester (FAME). 3.2.2 There are various technical challenges associated with use of fuel having FAME content, e.g. potential oxidation of biodiesel, its biodegradable nature etc. with adverse implications, limitations in storage life etc. It also needs to be tested for stability. 3.2.3 The ISO 8217:20173 standard includes a maximum FAME content of 7.0% by volume for DFA/DFZ/DFB fuel oil grades since some ports may offer automotive diesel fuel as the only fuel available, which contains FAME and could violate the fuel flashpoint requirements addressed in SOLAS chapter II-2. The maximum 7.0% (v/v) has been chosen as this aligns with the concentrations allowed in some of the countries applying environmental regulations. 3.2.4 Manufacturers of engines and equipment like oily water separators, overboard discharge monitors, filters, coalescers etc. need to be consulted to confirm the ability of engines and equipment to handle biodiesel blends of up to B7 (i.e. 7.0% v/v). 3.2.5 It is recommended to avoid using such biodiesel blend fuels for lifeboat engines, emergency generators, fire pumps, etc. where it is stored in isolated individual unit fuel tanks and subjected to conditions for accelerated degradation. 3.2.6 CIMAC has provided a Guideline for Shipowners and Operators on Managing Distillate Fuels up to 7.0% v/v Fame (Biodiesel).5 3.3 Residual fuels 3.3.1 Stability and compatibility 3.3.1.1 It is essential to distinguish between "Fuel stability" within a single batch of fuel and "Fuel compatibility" between different fuel batches. 3.3.1.2 Regarding stability: the fuel shall be stable and homogeneous at delivery and it is the responsibility of the fuel oil blenders and suppliers to ensure this. 3.3.1.3 A wide range of blends of refined products will be used to make the new 0.50% sulphur fuels, and the stability and compatibility of the blends will be an important concern for shipowners/operators. Unstable fuels can separate on their own and incompatible ones can do so when mixed in a single bunker tank, forming sludge that can block filters and ultimately cause engine failures. 5 https://www.cimac.com/cms/upload/workinggroups/WG7/CIMAC_WG7_Guideline_for_Ship_Owners_and_ Operators_on_Managing_Distillate_Fuels_May_2013.pdf- 5 - 3.3.1.4 It is recommended that ships have a commingling procedure. The procedure should primarily aim to ensure new bunkers are loaded into empty tanks to the extent possible. In the event that a ship finds itself possibly having to commingle a new bunker with bunkers already on board, then it is important that the ship determines the compatibility between the two said bunkers before comingling. 3.3.1.5 The reference test method shall be the total potential sediment test in accordance with ISO 10307-2:2009. 3.3.2 Catalytic fines (cat fines) 3.3.2.1 Cat fines are a by-product of refining and consist of small particles of metal that are deliberately introduced as catalysts to "crack" the fuel oil. Unless reduced by purification, cat fines will become embedded in engine parts and cause serious and rapid engine damage. Reference should be made to engine manufacturer's guidance with respect to managing cat fines. 3.4 Key technical considerations for shipowners and operators 3.4.1 Ship tank configuration and fuel system – the viscosity of most of these blended residual fuels is such that they cannot be used in distillate fuel-only systems and machinery, as they require heating for cleaning and combustion. A fully segregated fuel system for both distillate fuels and these new fuels is recommended. 3.4.2 Tank cleaning is recommended when using a residual fuel tank for storing these new fuels. This is to prevent sludge that has built up in these tanks from entering the fuel system. Further information on tank cleaning is set out in appendix 3 of MEPC.1/Circ.878 on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. 3.4.3 Heating requirements – due to the cold flow properties of most of these new fuels, permanent heating of the fuel may be necessary to minimize the risk of wax formation, also in storage. This is especially important in colder regions. 3.4.4 Fuel treatment system – Some of these new fuels may contain cat fines and/or sediments and therefore need on board cleaning. Separator temperature and settings should be adjusted to the fuels' viscosity and density. Please refer to recommendations from OEM and fuel supplier. 3.4.5 Considering that many of these new fuels have lower viscosities compared to conventional residual fuels, care should be taken to ensure no overheating occurs. 3.5 ISO Standard for residual fuels 3.5.1 The bunker market uses ISO 8217:20176 specifications to ensure that the properties of the fuels it delivers conform to a standard that mean they comply with MARPOL Annex VI. 3.5.2 The existing ISO 8217:20176 specification for marine fuels takes into consideration the diverse nature of marine fuels and incorporates a number of categories of distillate or residual fuels, even though not all categories may be available in every supply location it covers all marine petroleum fuel oils used today as well as the 0.50% Sulphur fuels of 2020. The General requirements, in the ISO 8217:20176 specification for marine fuels and characteristics, included in table 1 and 2 of ISO 8217:20176 identified safety, performance and environmental concerns and further takes into consideration the on board handling requirements, including 6 The latest edition of the ISO standard is recommended.- 6 - storage, cleaning and combustion aspects of all fuel oils used today and the anticipated fuel blends of 2020, irrespective of the sulphur content of the fuel oils. 3.5.3 It is important that any new standards address and do not preclude the use of renewable and alternative non-fossil crude derived products, so long as they comply with the chemical properties specified for these fuel oils. 3.6 Cylinder lubrication 3.6.1 The choice of cylinder lubricating oils will often follow the fuel type in use. So, when changing to VLSFO operation from RM operation the choice of appropriate cylinder lubricating oil should be considered in accordance with the recommendations of the engine manufacturer. 4 Verification issues and control mechanism and actions 4.1 Survey and certification by Administrations 4.1.1 When undertaking a survey in accordance with regulation 5 of MARPOL Annex VI, the Administration should conduct a survey of a ship to verify that the ship complies with the provisions to implement the 0.50% sulphur limit. In particular, the Administration should check whether the ship carries compliant fuel oils for use, based on the Bunker Delivery Note (BDN) on board, any other document or fuel oil samples as appropriate consistent with the provisions of regulation 18 of MARPOL Annex VI. If carriage of HSHFO for use is identified, the Administration should check whether regulation 3.2, regulation 4 of MARPOL Annex VI are applied to the ship, or if the ship encountered a fuel availability problem and is operating pursuant to regulation 18.2 of MARPOL Annex VI. 4.1.2 When an Administration decides to analyse a fuel oil sample to determine compliance with the sulphur limits in regulation 14.1 or 14.4, the final analysis should be carried out in accordance with ISO 8754:2003 by a laboratory that is accredited for the purpose of conducting the test in accordance with ISO/IEC 17025 or an equivalent standard. The test results should be in accordance with ISO 8754 reporting protocol, meaning a tested value at or above 0.10% sulphur should be reported with no more than two decimal places. 4.1.3 According to regulation 11.4 of MARPOL Annex VI, the Administration shall investigate any report of an alleged violation and thereafter promptly inform the Party which made the report, as well as the Organization, of the action taken. When informing the Organization, the MARPOL Annex VI GISIS module should be used. 4.2 Control measures by port States 4.2.1 Port States should take appropriate measures to ensure compliance with the 0.50% of sulphur limit under MARPOL Annex VI, in line with the regulation 10 of MARPOL Annex VI and the 2019 Guidelines for port State control under MARPOL Annex VI (resolution MEPC.321(74)) (2019 PSC Guidelines). Specifically, the port State should conduct initial inspections based on documents and other possible materials, including remote sensing and portable devices. Given "clear grounds" to conduct a more detailed inspection, the port State may conduct sample analysis and other detailed inspections to verify compliance to the regulation, as appropriate. 4.2.2 Regulation 18.2.3 of MARPOL Annex VI requires a Party to take into account all relevant circumstances and the evidence presented to determine the action to take, including not taking control measures. Administrations and port State control authorities may take into account the implementation plan when verifying compliance with the 0.50% sulphur limit requirement.- 7 - 4.2.3 Inspections based on documents and other possible targeting measurements 4.2.3.1 During the port State control and other enforcement activities, the port State should investigate whether a ship carries either compliant fuel oils or HSHFOs for use, based on the documents listed in paragraph 2.1.2 of the 2019 PSC Guidelines additionally records required to demonstrate compliance should also then be viewed. Results from remote sensing could be used to trigger inspections and portable devices could be used during the initial inspections, as appropriate. Remote sensing and portable devices are, however, of indicative nature and should not be regarded as the evidence of non-compliance, but may be considered clear grounds for expanding the inspection. 4.2.3.2 Port state should determine if regulations 3.2, 4 or 18.2.3 apply together with retained bunker delivery notes and IAPP Certificate when considering the status of any HSHFO being carried for use on board. 4.2.4 Fuel oil sample analysis 4.2.4.1 When the port State identifies clear grounds of suspected non-compliance of a ship based on initial inspections, the port State may require samples of fuel oils to be analysed. The samples to be analysed may be either the representative samples provided with BDN in accordance with regulation 18.8.2, MARPOL delivered samples or samples from designated sampling points in accordance with the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1) (in-use fuel oil samples) or other samples obtained by the port State. 4.2.4.2 Where the MARPOL delivered sample is taken from the ship a receipt should be provided to the ship. The outcome of the analysis undertaken with appendix VI of MARPOL Annex VI should be advised to the ship for its records. 4.2.4.3 In detecting suspected non-compliance, the sample analysis should be conducted in a uniform and reliable manner as described in paragraph 4.1.2. The verification procedure for MARPOL delivered samples should be in accordance with appendix VI7 of MARPOL Annex VI. For other samples taken on board the ship, the in-use and onboard sample, the sample should be deemed to meet the requirements provided the test result from the laboratory does not exceed the specification limit +0.59R (where R is the reproducibility of the test method) and no further testing is necessary. 4.2.4.4 Notwithstanding the above process, all possible efforts should be made to avoid a ship being unduly detained or delayed. In particular, sample analysis of fuel oils should not unduly delay the operation, movement or departure of the ship. 4.2.4.5 If a non-compliance is established, consistent with regulation 18.2.3 the port State may prevent the ship from sailing until the ship takes any suitable measures to achieve compliance which may include de-bunkering all non-compliant fuel oil. In addition, the port State should report the information of the ship using or carrying for use non-compliant fuel oil to the Administration of the ship and inform the Party or non-Party under whose jurisdiction a bunker delivery note was issued of cases of delivery of non-compliant fuel oil, giving all relevant information. Upon receiving the information, the Party detecting the deficiency should report the information to the MARPOL Annex VI GISIS module in accordance with paragraph 3.4 of these Guidelines. 4.2.4.6 The Parties (the port and flag States), however, may permit, with the agreement of the destination port authority, a single voyage for bunkering of compliant fuel oil for the ship, in accordance with regulation 18.2.4 of MARPOL Annex VI. The single voyage should be one 7 Amendments to MARPOL VI, Appendix VI, Verification procedures for a MARPOL Annex VI fuel oil sample (regulation 18.8.2 or regulation 14.8), expected to be adopted in Spring 2020 and set out in annex 11 to document MEPC 74/18.- 8 - way and minimum for bunkering, and the ship proceeds directly to the nearest bunkering facility appropriate to the ship. In the case that the parties permit a single voyage of a ship, the port State should confirm that the Administration of the ship has advised the authority at the destination port of the approval for a single voyage including information on the ship granted with the approval and the certified record of analysis of the sample as the evidence. Once confirmation has been provided the port State should permit the ship to sail as agreed. 4.2.4.7 If the port State is made aware that a ship is carrying non-compliant fuel oil, which is not for use through an equivalent method under regulation 4 or a permit under regulation 3.2 of MARPOL Annex VI, the port State should take action to confirm the fuel is not being used. Action to confirm should include, but is not limited to the examination of the oil record book and the record of tank soundings. Where necessary the port State may require tank soundings to be undertaken during the inspection. Where it is determined that the fuel has been used the control action in paragraph 4.2.4.5 should be applied. 4.2.5 Other open-sea compliance monitoring tools: .1 fuel oil changeover calculator; .2 data collection system for fuel oil consumption of ships (resolution MEPC.278(70)); and .3 continuous SO monitoring. X 4.3 Control on fuel oil suppliers 4.3.1 Designated authorities should, if deemed necessary, take a sample and test fuel oils from bunker barges or shore bunker terminals. Sampling of fuel oils in bunker barges or shore bunker terminals can be taken and tested in the same manner that the MARPOL delivered fuel oils are tested by the PSC. All possible efforts should be made to avoid a ship being unduly detained or delayed. If a sample is analysed, sample analysis of fuel oils should not unduly delay the operation, movement or departure of the ship. 4.3.2 If non-compliance, such as issuance of an incorrect BDN or a BDN without measurement of sulphur content, was found, the designated authorities should take appropriate corrective measures against the non-compliant supplier. In such case, the designated authorities should inform the Organization for transmission to the Member States of the non-compliant supplier, in accordance with the regulation 18.9.6 of MARPOL Annex VI and paragraph 4.4 of these Guidelines. 4.4 Information sharing related to non-compliances under MARPOL Annex VI 4.4.1 When a Party finds a non-compliance of a ship or a fuel oil supplier, the information of the non-compliance should be reported to the MARPOL Annex VI GISIS module (regulation 11.4). 4.4.2 Publication of information on non-compliant ships/fuel oil suppliers or a reporting scheme to IMO to be registered on centralized information platforms are proposed as elements of an effective enforcement strategy. Various PSC regimes have successfully used the publishing of information related to substandard ships/fuel suppliers as a deterrent to non-compliance. Port States also need to report detentions of ships to IMO which may affect the future PSC targeting of the ship. The IMO GISIS database already makes available certain information related to non-compliances with the MARPOL Annex VI regulations.- 9 - 5 Fuel oil non-availability 5.1 Guidance and information sharing on fuel oil non-availability 5.1.1 Regulation 18.2.1 of MARPOL Annex VI provides that in the event compliant fuel oil cannot be obtained, a Party to MARPOL Annex VI can request evidence outlining the attempts made to obtain the compliant fuel oil, including attempts made to local alternative sources. Regulations 18.2.4 and 18.2.5 then require that the ship notifies its Administration and the competent authority of the port of destination on the inability to obtain compliant fuel oil, with the Party to notify IMO of the non-availability. This notification is commonly referred to as a Fuel Oil Non-Availability Report (FONAR). 5.1.2 Guidance on consistent evidence 5.1.3 Regulation 18.2.1.2 of MARPOL Annex VI requires that evidence be provided to support a claim that all efforts were made to obtain compliant fuel oil. In this regard, a Party may develop more detailed guidance for the consistent use and acceptance of these reports, including what evidence is needed to accompany a report to ensure that port States are applying the provisions under regulation 18.2.3, consistently. 5.1.4 Should a ship, despite its best effort to obtain compliant fuel oil, be unable to do so, the master/company must: .1 present a record of actions taken to attempt to bunker correct fuel oil and provide evidence of an attempt 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; and .2 best efforts to procure compliant fuel oil include, but are not limited to, investigating alternate sources of fuel oil prior to commencing the voyage. If, despite best efforts, it was not possible to procure compliant fuel oil, the master/Company must immediately notify the port State Administration in the port of arrival and the flag Administration (regulation 18.2.4 of MARPOL Annex VI). 5.1.5 In order to minimize disruption to commerce and avoid delays, the master/company should submit a FONAR as soon as it is determined or becomes aware that it will not be able to procure and use compliant fuel oil. 5.1.6 Investigating non-availability 5.1.7 A Party should investigate the reports of non-availability. This process is important to ensure a consistent supply of compliant fuel to industry, as well as prevent incentives for ships to use ports where it is known that compliant fuel is not available on an ongoing basis. Critical to this process will be the sharing of information between Member States on reported compliant fuel oil supply issues.- 10 - 5.1.8 Regulation 18.2.5 of MARPOL Annex VI provides that a Party to MARPOL Annex VI notify the Organization when a ship has presented evidence of the non-availability of compliant fuel oil in a port or at their terminal. For this purpose, MARPOL Annex VI GISIS module provides the platform for Parties to upload such notifications. 5.1.9 Regulation 18.1 of MARPOL Annex VI provides that each Party take all reasonable steps to promote the availability of above compliant fuel oil and inform the Organization through MARPOL Annex VI GISIS module of the availability of compliant fuel oils in its ports and terminals. 5.1.10 Port State control authority may contact the submitter (and/or shipowner or operator), including in the event of an incomplete submission, and request additional information, or to pursue an enforcement action such as a Notice of Violation. 5.2 Standard format for reporting fuel oil non-availability 5.2.1 For ships which are unable to purchase fuel oil meeting the requirements of regulations 14.1 or 14.4 of MARPOL Annex VI, the standard format for reporting fuel oil non-availability is set out in appendix 1 to this document, pursuant to regulation 18.2.4 of MARPOL Annex VI. 6 Possible safety implications relating to fuel oils meeting the 0.50% m/m sulphur limit 6.1 MEPC 73 (October 2018) approved MEPC.1/Circ.878 on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI (hereafter the "Ship Implementation Plan Guidance") addresses some safety issues identified with regard to 0.50% maximum sulphur fuel oil, in particular through the section on risk assessment (section 1 of the Ship Implementation Plan Guidance) and additional guidance provided on impact on machinery systems and tank cleaning (appendix 2 and appendix 3 of the Ship Implementation Plan Guidance, respectively). 6.2 Identified potential safety implications include, but are not limited to, the following: .1 stability of blended fuel oil; .2 compatibility, including new tests and metrics appropriate for future fuels; .3 cold flow properties; .4 acid number; .5 flash point; .6 ignition and combustion quality; .7 cat fines; .8 low viscosity; and .9 unusual components. 6.3 Additional technical information and a review, displayed in tabular format, of the possible potential safety implications is set out in appendix 2.- 11 - 6.4 Reference should also be made to general industry guidance on potential safety and operational issues related to the supply and use of 0.50% maximum sulphur fuels8. 8 ICS, ASA and ECSA Guidance to shipping companies and crews on preparing for compliance with the 2020 global sulphur limit can be accessed at the following link: http://www.ics-shipping.org/free- resources/2020-sulphur-compliance- 12 - APPENDIX 1 FUEL OIL NON-AVAILABILITY REPORT (FONAR) Note: 1 This report is to be sent to the flag Administration and to the competent authorities in the relevant port(s) of destination in accordance with regulation 18.2.4 of MARPOL Annex VI. The report shall be sent as soon as it is determined that the ship/operator will be unable to procure compliant fuel oil and preferably before the ship leaves the port/terminal where compliant fuel cannot be obtained. A copy of the FONAR should be kept on board for inspection for at least 36 months. 2 This report should be used to provide evidence if a ship is unable to obtain fuel oil compliant with the provisions stipulated in regulations 14.1 or 14.4 of MARPOL Annex VI. 3 Before filing a FONAR, the following should be observed by the ship/operator: 3.1 A fuel oil non-availability report is not an exemption. According to regulation 18.2 of MARPOL Annex VI, it is the responsibility of the Party of the destination port, through its competent authority, to scrutinize the information provided and take action, as appropriate. 3.2 In the case of insufficiently supported and/or repeated claims of non-availability, the Party may require additional documentation and substantiation of fuel oil non-availability claims. The ship/operator may also be subject to more extensive inspections or examinations while in port. 3.3 Ships/operators are expected to take into account logistical conditions and/or terminal/port policies when planning bunkering, including but not limited to having to change berth or anchor within a port or terminal in order to obtain compliant fuel. 3.4 Ships/operators are expected to prepare as far as reasonably practicable to be able to operate on compliant fuel oils. This could include, but is not limited to, fuel oils with different viscosity and different sulphur content not exceeding regulatory requirements (requiring different lube oils) as well as requiring heating and/or other treatment on board. 1 Particulars of ship 1.1 Name of ship: _______________________________________________________ 1.2 IMO number: ________________________________________________________ 1.3 Flag: ______________________________________________________________ 1.4 (if other relevant registration number is available, enter here): __________________ 2 Description of ship's voyage plan 2.1 Provide a description of the ship's voyage plan in place at the time of entry into "country X" waters (and ECA, if applicable) (Attach copy of plan if available): _________________________________________________________________________ _________________________________________________________________________ _________________________________________________________________________- 13 - 2.2 Details of voyage: 1 – Last port of departure ___________________________________________________________________ 2 – First port of arrival in "country X": ___________________________________________________________________ 3 – Date of departure from last port (dd-mm-yyyy): ___________________________________________________________________ 4 – Date of arrival at first "country X" (dd-mm-yyyy): ___________________________________________________________________ 5 – Date ship first received notice that it would be transiting in "country X" waters (and ECA, if applicable) (dd-mm-yyyy): ___________________________________________________________________ 6 – Ship's location at the time of notice: ___________________________________________________________________ 7 – Date ship operator expects to enter "country X" waters (and ECA, if applicable) (dd-mm-yyyy): __________________________________________________________________ 8 – Time ship operator expects to enter "country X" waters (and ECA, if applicable) (hh:mm UTC): __________________________________________________________________ 9 – Date ship operator expects to exit "country X" waters (and ECA, if applicable) (dd-mm-yyyy): __________________________________________________________________ 10 – Time ship operator expects to exit "country X" waters (and ECA, if applicable) (hh:mm UTC): __________________________________________________________________ 11 – Projected days ship's main propulsion engines will be in operation within "country X" waters (and ECA, if applicable): ___________________________________________________________________ 12 – Sulphur content of fuel oil in use when entering and operating in "country X" waters (and ECA, if applicable): __________________________________________________________________- 14 - 3 Evidence of attempts to purchase compliant fuel oil 3.1 Provide a description of actions taken to attempt to achieve compliance prior to entering "country X" waters (and ECA, if applicable), including a description of all attempts that were made to locate alternative sources of compliant fuel oil, and a description of the reason why compliant fuel oil was not available: ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ 3.2 Name and email address of suppliers contacted, address and phone number and date of contact (dd-mm-yyyy): ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ Please attach copies of communication with suppliers (e.g. emails to and from suppliers) 4 In case of fuel oil supply disruption only 4.1 Name of port at which ship was scheduled to receive compliant fuel oil: ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ ___________________________________________________________________ 4.2 Name, email address, and phone number of the fuel oil supplier that was scheduled to deliver (and now reporting the non-availability): ___________________________ 5 Operation constraints, if applicable 5.1 If non-compliant fuel has been bunkered due to concerns that the quality of the compliant fuel available would cause operational or safety problems on board the ships, the concerns should be thoroughly documented. 5.2 Describe any operational constraints that prevented use of compliant fuel oil available at port: __________________________________________________________________________ 5.3 Specify steps taken, or to be taken, to resolve these operational constraints that will enable compliant fuel use: __________________________________________________________________________ 6 Plans to obtain compliant fuel oil 6.1 Describe availability of compliant fuel oil at the first port-of-call in "country X", and plans to obtain it: __________________________________________________________________________ 6.2 If compliant fuel oil is not available at the first port-of-call in "country X", list the lowest sulphur content of available fuel oil(s) or the lowest sulphur content of available fuel oil at the next port-of-call: __________________________________________________________________________- 15 - 7 Previous Fuel Oil Non-Availability Reports 7.1 If shipowner/operator has submitted a Fuel Oil Non-Availability Report to "country X" in the previous 12 months, list the number of Fuel Oil Non-Availability Reports previously submitted and provide details on the dates and ports visited while using non-compliant fuel oil, as set out below: Report: ___________________________________________________________________ Date (dd-mm-yyyy): _________________________________________________________ Port: _____________________________________________________________________ Type of fuel: _______________________________________________________________ Comments: ________________________________________________________________ 8 Master/Company information Master name: ______________________________________________________________ Local agent in "country X": ____________________________________________________ Ship operator name: _________________________________________________________ Shipowner name: ___________________________________________________________ Name and position of official: __________________ ________________________________ Email address: _____________________________________________________________ Address (street, city, country, postal/zip code): ____________________________________ Telephone number: _________________________________________________________ Signature of Master: _________________________________________________________ Print name: ________________________________________________________________ Date (DD/MM/YYYY): ________________________________________________________- 16 - APPENDIX 2 TECHNICAL REVIEW OF IDENTIFIED POTENTIAL SAFETY IMPLICATIONS ASSOCIATED WITH THE USE OF 2020 COMPLIANT FUELS Fuel Property Potential Challenges Remarks Stability The consequences of a ship The challenge for the fuel producer is to receiving an unstable fuel, or one blend a fuel which is not only stable but that becomes unstable during also has a degree of reserve stability storage or handling, can be such that it will remain stable during serious. Sludge may build up in periods of storage and treatment at the storage tanks, piping elevated temperatures. systems or centrifuges and filters can become totally blocked by More paraffinic blend components are voluminous amounts of sludge. expected for Very Low Sulphur Fuel Oil (VLSFO) compared to existing fuels. Whereas aromatic components have a stabilizing effect on asphaltenes, paraffins do not. Fuel suppliers are responsible for ensuring that the supplied fuel is stable. Compatibility Challenges are the same as with An incompatible mix may be harmful to issues stability (above). ship's operation. VLSFOs are expected to be paraffinic based in some regions and aromatic based in other regions. There is a risk of experiencing incompatibility when mixing an aromatic fuel with a paraffinic fuel. The same risk exists today, but with the wide range of products which may exist post 2020, it is important to segregate fuels as far as possible and to be cautious of how to manage/handle incompatible fuels on board. Cold flow ISO 8217:2017 limits the cold VLSFO products are expected to be properties flow properties of a fuel through more paraffinic compared to existing and Pour setting a limit on the pour point fuels. As such, it is important to know the Point (PP). However, given that wax cold flow properties of the bunkered fuel crystals form at temperatures in order to ensure proper temperature above the PP, fuels that meet the management on board. specification in terms of PP can still be challenging when It is important to note that for additives to operating in colder regions. Wax be effective, they have to be applied particles can rapidly block filters, before crystallization has occurred in the potentially plugging them fuel. completely. The paraffin's may crystallize and/or deposit in the Reference 1. storage tanks leading to blockages at the filters and reduced fuel flow to the machinery plants. If fuels are held at temperatures below the pour point, wax will begin to precipitate. This wax may cause blocking of filters and can deposit on heat exchangers. In severe- 17 - Fuel Property Potential Challenges Remarks cases the wax will build up in storage tank bottoms and on heating coils, which can restrict the coils from heating the fuel (fuel will become unpumpable f rom the bunker tanks). Acid number The fuel shall be free from There is currently no recognized strong, inorganic acids. correlation between an acid number test result and the corrosive activity of the Fuels with high acid number test fuel. results arising from acidic compounds cause accelerated ISO 8217:2017, appendix E covers the damage to marine diesel topic. engines. Such damage is found primarily within the fuel injection equipment. Flashpoint Flashpoint is considered to be a SOLAS requirement. useful indicator of the fire hazard associated with the storage of marine fuels. Even if fuels are stored at temperatures below the determined flash point, flammable vapours may still develop in the tank headspace. Ignition and Fuels with poor ignition & High and medium-speed engines are combustion combustion properties can, in more prone to experience operational quality extreme cases, result in serious difficulties due to poor ignition and operational problems, engine combustion properties than low speed damage and even total two stroke types. With four stroke breakdown. Poor combustion engines, poor ignition can result in performance is normally excessive exhaust gas system deposits, characterized by an extended black smoke, engine knocking and combustion period and/or poor difficulties operating at low load. rates of pressure increase and low "p max" resulting in If the ignition process is delayed for too incomplete combustion of the long a period by virtue of some chemical fuel. The resulting effects are quality of the fuel, too large a quantity of increased levels of unburned fuel fuel will be injected into the engine and soot that may be deposited cylinders and will ignite at once, in the combustion chamber, on producing a rapid pressure and heat rise the exhaust valves and in the and causing associated damage to the turbocharger system, exhaust piston rings and cylinder liners of the after treatment devices, waste engine. heat recovery units and other exhaust system components. Reference 2. Extended combustion periods may also result in exposure of the cylinder liner to high temperatures which may disrupt the lubricating oil film, leading to increased wear rates and scuffing. Unburnt fuel droplets may also carry over impinging on the liner surfaces causing further risk of damage to the liner.- 18 - Fuel Property Potential Challenges Remarks Cat fines Cat fines will cause abrasive Major engine manufacturers recommend wear of cylinder liners, piston that the fuel's cat fines content does not rings and fuel injection exceed 10 mg/kg (ppm) at engine inlet. equipment if not reduced sufficiently by the fuel treatment system. High wear in the combustion chamber can result. Low viscosity Low-viscosity fuels (less than Low fuel viscosity does not only affect the 2 cSt at engine inlet) challenge engine fuel pumps. Most pumps in the the function of the fuel pump in external fuel oil system (supply pumps, the following ways: circulating pumps, transfer pumps and feed pumps for the centrifuge) also need .1 breakdown of the oil film, viscosities above 2 cSt to function which could result in properly. seizures; Viscosity is highly temperature .2 insufficient injection dependent and the crew must take pressure, which results in proper care of fuel oil temperature difficulties during start-up management to avoid viscosity related and low-load operation; issues. and Reference 3. .3 insufficient fuel index margin, which limits acceleration. Unusual The below components and Only for few components, there components group of components can be exists a clear cause and effect linked to the risk of encountering between component and the following problems: associated operational problems. Polymers (e.g. polystyrene, There is no statistical study polyethylene, polypropylene) performed of which components are Associated with filter blocking typically found in marine fuels and in which concentration. Polymethacrylates Associated with fuel pump As per ISO 8217:2017, annex B: sticking The marine industry continues to build on its understanding of the Phenols impact of specific chemical species Occasionally Associated with and the respective critical filter blocking/fuel oil pump concentrations at which detrimental sticking effects are observed on the operational characteristics of Tall oils marine fuels in use. Associated with filter blocking Chlorinated hydrocarbons Only in some of the past cases the Associated with fuel pump origin of the unusual components seizures found in bunkers were revealed and were due to various reasons such Estonian shale oil as: Associated in the past with .1 Russia/Baltic states 1997, cross excessive separator sludging contamination in storage/piping (polypropylene); Organic acids Associated with corrosion as well .2 Singapore 2001, 4 bunker barges as fuel pump sticking received material from road- 19 - Fuel Property Potential Challenges Remarks tankers which, in addition to transporting fuel, also collected/transported waste oil from shipyards and motor shops (esters); .3 Ventspils 2007, Estonian shale oil to convert HSHFOs to LSFOS; and .4 Houston 2010/11, bunker barges that were not cleaned between cargoes (polyacrylates) Reference 4. References 1 CIMAC WG7 Fuels Guideline 01/2015: "Cold flow properties of marine fuel oils" 2 CIMAC WG7 Fuels 2011: "Fuel Quality Guide: Ignition and Combustion" 3 MAN Service Letter SL2014-593/DOJA 4 Bureau Veritas Verifuel, Investigative analysis of marine fuel oils: Pros & Cons ___________