According to a Maritime Executive report, the IMO’s 2019 guidelines on consistent implementation of 0.50 percent sulfur limit under MARPOL Annex VI adopted by resolution MEPC.320(74) are now available for download.
What is it?
These comprehensive guidelines include a template for a “Fuel Oil Non-Availability Report (FONAR)” set out in Appendix 1 and a “Technical review of identified possible potential safety implications associated with the use of 2020 compliant fuels” set out in Appendix 2.
The IMO Marine Environment Protection Committee (MEPC) adopted the guidelines at its 74th session (May 13-17).
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 (SOX), - 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,
- 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; - 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; - AGREES to keep these Guidelines under review in the light of experience gained with
their application.
Ship implementation planning for 2020
- 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. - 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. - 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.
Impact on fuel and machinery systems
- The experiences and lessons learned from the transition to the 0.10% m/m SOX-ECA
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. - 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.
Distillate fuels
- 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.
- 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. - 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 theworst-case scenario, sediment can cause engine fuel starvation and power loss. - 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
- 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”
- 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.
- 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.
- Knowing the fuel properties before bunkering will assist in taking the necessaryprecautions where and when necessary. If the ship is heading towards colder climates and the cold flow properties are inferior, the fuel may be: either used before entering cold regions, or used with the suitable heating arrangement, as mentioned above.
- 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 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.
Key technical considerations for shipowners and operators
- 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. - 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.
- 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. - 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.
- Considering that many of these new fuels have lower viscosities compared to conventional residual fuels, care should be taken to ensure no overheating occurs.
ISO Standard for residual fuels
- 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. - 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 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.
- 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.
Further Information
The full report can be found here
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Source: Maritime Executive
