ECA – Emission Control Areas – require Ocean-Going Vessels (OGV) to comply with the emission requirements by switching to 0.1% sulphur fuel from 1st January 2015 or use suitable exhaust abatement technology like Viswa Scrubbers or similar.  Many Ship Managers/Ship Owners reported Viswa Lab about the fuel becoming non-compliant though the fuel bunkered has sulphur % less than 0.1%. Recently, one of the vessels inspected by the U.S.C.G in California was found to have fuel with sulphur % more than 0.1% and thus faced a severe consequence for being non-compliant with the regulations.

In other case the fuel sample was taken from the line after main engine circulating pumps and the inlet to the main/auxiliary engine. U.S.C.G tested the sample and the sulphur % was found to be more than 0.1%.  Surprisingly, the vessel bunkered a fuel with the sulphur at 0.08% m/m and the Bunker Delivery Note (B.D.N) stated the same. The fuel test analysis and B.D.N reported that the sulphur % was less than 0.1%, whereas the sample from the piping system – inlet to the engine had the same fuel with sulphur % more than 0.1%.  

Purchasing a fuel oil with sulphur content below the regulatory 0.10% limit does not guarantee compliance.

Vessels operating in ECA, have been required to burn only fuels with sulphur levels at or below 0.10%.  Many vessels, to comply the ECA requirements, use either 0.1% marine distillate fuel or 0.1% sulphur non-distillate fuels or the Ultra Low Sulphur Fuels (ULSFO).  What is alarming to a Ship Owner or the Operator is that many of these distillate and non-distillate fuels are supplied with a sulphur content very close to the regulatory limit and even marginal admixtures with other higher sulphur fuels could, therefore, result in the fuel not being compliant. On the other end, in order to meet the demand for 0.1% distillate fuel, certain automotive fuels are being supplied in the market where one has to additionally consider the Lubricity of such fuel when using it. In most cases, the automotive fuels have very low sulphur % and thus lubricity of the fuel comes under question. 

We are in November now and note that the temperatures have already started to dip.  Viswa Lab reported in October 2015 that at least three vessels reported of problems being faced by the formation of wax and filters getting clogged.  We think that winters have more to do than in summers.

It is essential that the owners and operators should take critical measures to reduce the likelihood of non-compliance, primarily relating to:

• Fuel purchase specifications – source fuel with a sulphur content well below the 0.10% regulatory limit;
• Do not hesitate to consume a bit more of expensive distillate fuel during a changeover, as the costs of non-compliance is much higher than the actual cost of the fuel;
• Cleaning of tanks and flushing of supply and transfer lines – avoid mixing with high sulphur fuels;
• Check the fuel return lines and mixing columns – pipeline layout – where there could be a cross mixing/contamination  with high sulphur fuel; 
• The timing of the fuel change-over operation – operate engines on compliant fuel well before entering regulated waters.
• When transferring fuels from ULSFO storage tanks to ULSFO settling tanks, a typical vessel configuration may have a single residual fuel system, where the ULSFO will be transferred through the same lines as the HFO. Vessel engineering staff may want to flush lines into HFO settling tank for a prescribed amount of time to be sure any ULSFO contaminated with HFO is flushed before beginning transfer into any ULSFO settling tanks.
• Once uncontaminated transfer to the ULSFO settling tanks is complete, the vessel engineering staff must transfer these residual fuels through centrifuges/purifiers to the ULSFO service tanks. Any residual HFO in the system must be flushed completely into the HFO service tanks before switching over to the ULSFO service tanks.
• Once transfer to the service tanks is complete, the vessel will still have some residual HFO in the system. Operating the engine on ULSFO prior to entering the California Regulatory Waters will reduce the chance of a violation.  Operational staff should be able to recommend an appropriate amount of operating time on ULSFO for any given vessel, taking into account contamination from any mixing tanks, pumps, filters, or heaters where applicable, and the actual percentages of sulphur in both fuels.
• If a vessel has only one HFO settling tank and/or one HFO service tank, the vessel operator may not want to use non-distillate fuel that is close to the 0.1% sulphur limit.  Even with all the above-mentioned steps taken, any contamination that brings the sulphur content of the fuels >0.1% could result in a violation.

Some Top Ship Operators reported to Viswa Lab that U.S.C.G is testing the fuel for sulphur % up to three decimals.  Thus, it is highly necessary that the fuel should be tested at a reputed lab like Viswa Lab and it is to be noted that Viswa Lab reports sulphur % in four decimals.  Viswa Lab submits Sulphur data to I.M.O and thus it is an I.M.O approved global lab.  

If you have questions or concerns with regards to sulphur %, testing and reporting of results – do not hesitate to write to us or Voice it in the Forum.

Dr. Vis – the “Bunker Guru” is ready to answer your Questions.

Source: Viswa Lab Reports & Gard

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