Viswa Lab has already commented extensively on the evolution of the ISO 8217 standards in 2005 and 2010/2012. These comments have been recorded in several Technical Updates right from 2009 to 2010. The overall feeling about the 2010 standard as compared to 2005 was that the 2010 standard provides greater leeway and liberty to the supplier and reduces his accountability for supplying poor quality or contaminated/adulterated fuels. There was an Annex B in 8217:2010 on Deleterious Materials which practically exonerated the supplier of all sins of omission and commission. What was in the Annex and considered informative has now been brought into the main ISO 8217:2016 draft standard making it legal and statutory. Though ISO 8217:2010 brought about marginal reductions in catfines from 80 ppm max to 60 ppm max, it really made no great difference since the global average for catfines was only 22 ppm. 8217:2010 also introduced testing for H2S and Acid Number for residual fuels and Lubricity and Oxidation Stability for distillate fuels. Overall, the fuel user did not see any great benefit and continued buying to ISO 8217:2005 standards. Even today, testing by Viswa Lab to ISO 8217:2010 constitutes only 7% of the lab tests and the remaining 93% is to ISO 8217:2005.
Over 90% of the samples tested at Viswa Lab is as per ISO 8217:2005
Now the draft ISO 8217:2016 standard is circulated for comments from the fuel users of the shipping industry. Table 1 and Table 2 numbers have not been changed but very substantial subtle changes have been made in the text of the standard. The wordings used are vague which will tempt a supplier to take advantage of blending the refinery residual fuel with any other hydrocarbon including petrochemical waste, acidic sludge, gummy substances etc. We already know (Viswa Lab has carried out a detailed study) that using shale oil from the Baltic States results in:
- Reduction in Stability,
- Increases the Acidity,
- Reduces the Ignition and combustion property,
- Reduces the viscosity disproportionately.
These fuels are usually supplied with a viscosity of 240 to 280 cSt though 380 cSt had been ordered.
Additionally, as the Environmental laws get tighter and tighter, there is a temptation to use bunker fuel as a dumping ground for waste products. Keep in mind that rapidly developing countries will have more of these waste products and the temptation to dump will be stronger. When these contaminated fuels burn, toxic exhaust is emitted and this can certainly affect the population living along the coasts and the rivers.
The fundamental question is why there cannot be greater transparency?
Why can’t a refinery or a supplier state the contents of the supply made by them?
This information could be termed “Statutory Blending Information”. It should say how much of the residual fuel with what chemical analysis has been mixed with how much of the cutter stock and any other substance used for blending. This will force a supplier to be responsible for what he is supplying.
Why should a supplier hide behind a cloud of vague statements and generic description such as “cutter stock”?
In order to cover this topic and the evolution of this Standard, we will take the relevant portions
where changes have been made and provide our comments. Voting on changes to the draft standard is open and must be made before April 4, 2016. Any changes you would like to implement should go through your National ISO member organization. The National committee will consider your views and other views expressed and then present this to the main ISO committee. Therefore you have to give time for the National committee to discuss this. Contact Information for your National ISO member organization is available at ISO
Please make sure that your views are heard and the members and the members carry your opinion to the ISO committee.
PART 1 – SCOPE OF THE STANDARD
The Scope of the standard has been modified to the following.
This International Standard specifies the requirements for fuels for use in marine diesel engines and boilers, prior to conventional onboard treatment (settling, centrifuging, filtration) before use.
The wording in blue italics and underlined has been added to the scope in the ISO 8217:2016 draft. While this addition looks innocuous and harmless, it takes away the protection that the fuel purchaser had particularly with regard to catfines. See comments on section 6.16 in Part 3 of this document.
As mentioned in our introduction to this revision, the changes to include more components as sources of fuels are vague. This will tempt a supplier to take advantage of blending the refinery residual fuel with any other hydrocarbon including petrochemical waste, acidic sludge, gummy substances etc.
PART 2 – PARA 5 GENERAL REQUIREMENTS:
Para 5 is a very important part of the 8217 standard. In fact, this is the only section that provides protection to the fuel buyer outside of requirements to meet the number in Table1 for Distillate fuel and Table 2 for Residual fuels. Bunker fuel users know very well that meeting the numbers in Table 1 and 2 means nothing from the point of view of fuel quality. Almost all of the fuels do meet ISO 8217 specifications listed in Table 1 or 2.
What Para 5 does is to provide protection to the fuel user if the fuel, though it meets the requirement of Table 1/Table 2, contains substances, chemical waste, adulteration etc. which cause machinery problems and machinery damage and also affects the health of those dealing with the fuel and adds to additional air pollution. Some of the fuel related problems which have been documented numerous times are listed below.
- Piston rings breakage of main engine
- Severe filter choking bringing the ship to a halt and causing blackouts
- Severe choking of purifiers
- Wear on the rubbing surface (fuel pumps and valves) due to acidic content of the fuel.
- And many others.
Let us now study the changes made from 2010 version (which is practically identical to the 2012 standard except for the H2S test method listed in Table 1/Table2) to the 2016 draft. Para 5.1 and 5.2 of 2010 standard have been integrated into Para 5.1 of 2016 draft.
Since the scope of the bunker fuel has been expanded to include oil products derived from renewable or from alternate sources, the terminology used earlier “Blend of hydrocarbons” has been removed. 5.1 goes on to describe what this fuel composition can be sourced from. It would be beneficial for the fuel buyers if this section specifies the sources that are not acceptable in bunker fuel. In this regard, some of the suppliers in Europe have been claiming that Styrene, DCPD, Indene and similar substances are part of the regular refinery process. We know that this is not true and that they are products from the Ethylene Cracker Plants and others. The group of unacceptable substances has been clearly detailed by Rotterdam Police department as contaminants (Please see Viswa Technical Update 2014/5/5). There are other contaminants from other parts of the world where bunker fuel is supplied. Since considerable problems have arisen because of the substances listed above being present in the bunker fuel, it will be greatly helpful if the standard specifies what substances should NOT be present.
With regard to the new DF grades, there are no comments about the permitted FAME level of 7% by volume. However with regard to the “de minimis” level for DMA, DMB, DMC and RM grades, the committee should check if the testing data reveals the percentage of fuels which had more than 1,000 ppm (0.1%) which was the De Minimis value for 2010 grade. The increase in the De Minimis value to 5,000 ppm should be justified on the basis of data check.
Para 5.2 has been worded in a very ingenious way (similar to the wording in Annex B of
8217:2010). This goes on to say that the fuel shall be free of any material at a concentration that causes fuel to be unacceptable for use. It then continues that determining the concentration through chemical analysis is not possible (similar to Para d of Annex B in 8217:2010). “A special study” has to be undertaken to determine this.
Who is carrying out this study?
Who are the participants?
Why no results even after 6 years?
The wording in this section is practically a repetition of what Annex B said.
What is questionable is that why, after a gap of 6 years, we are still giving the same excuse that chemical analysis cannot give clear results. A standard test method for “Determination of Chemical Species in Marine Fuel Oil by Multi‐Dimensional GCMS” has been published by ASTM D7845 in 2013. The statement in the Draft 8217:2016 that “Multiple labs cannot detect contaminants with no standardized approach” is no longer true. Why can’t we specify this standard for chemical contaminants? Are we not giving an excuse to the supplier to shirk his responsibility for the quality of the fuel supplied? Under UK law, the “Fitness of Purpose” clause is very important and enforceable. If the fuel supplied, instead of helping the engine run, causes problems and damages the machinery, how will it meet the criteria of “Fitness for Purpose”? It is not enough that the fuel meets the requirements of Table 1/Table 2.
There is also a shocking omission of para 5.5 of ISO 8217:2010 (which was part of para 5.1 of 8217:2005) in the new draft. This para specifically provides protection to the fuel buyer against machinery damage, adverse health effects to ship staff and contribution to overall air pollution.
To sum up, the new para 5 does not protect the fuel buyer from problems and damages caused by the fuel. It also provides enough loopholes for the supplier to evade responsibility. Also, the proposed changes are contrary to the wording of Regulation 18 (Quality clause) of Marpol Annex VI which are in line with the wording in para 5 of ISO 8217:2005 version.
PART 3 – TEST METHODS:
6.16 Aluminium plus silicon:
In this section, a very interesting addition has been made “The Aluminum + Silicon limits in Table 2 restrict the catalyst fines to levels at which fuel treatment plants onboard (settling tanks, centrifuges and filters) when operated in accordance with the best practice and the manufacturers operating procedures are expected to reduce the catalytic fines to an acceptable level at Engine Inlet.”
What this would mean is that the supplier can supply fuels upto a limit of 60 ppm (for ISO 8217:2010/2012) and 80 ppm (for ISO 8217:2005) for Aluminum + Silicon. With the permitted variation, the 60 ppm limit can go upto 72 ppm and 80 ppm can go upto 96 ppm. The Engine Maker is restricting the catfines to 15 ppm at Engine Inlet. Please see Class NKK note on Engine Makers Limits which is even lower at 7 ppm. This means that if the supplier supplies at 60 ppm and the Engine Maker insists it has to be 15 ppm, the onboard treatment plant must function with at least 75% efficiency. As we all know, onboard treatment plants are not monitored regularly. The most important onboard treatment parts are the centrifuges. When the ship is new, the catfine removal efficiency can be 80% or more but we have seen that after about one year, the efficiency in catfine removal can vary from 20% to 60%.
How do we therefore control the quantum of catfines entering the engine?
Let us look at another picture. The supplier has license to supply upto 60 ppm catfines. However, the global average for catfines is only 22 ppm. Why is the supplier asking for 60 ppm? This is just to cover any stray cases where the catfines can exceed 22 ppm and the supplier has enough cushion to still be “within specs”. This way he is free and his supply has to be accepted.
What about the fuel user?
If his purifier is not running properly or if he is not monitoring the purifier efficiency regularly, he could end up with fuels with catfines in excess of 15 ppm entering the engine. He has no recourse.
Why can’t we change the specification limit to make the catfine limit say 25 ppm? This way, even if the onboard fuel treatment is not very efficient, the amount of catfines entering the engine will not be that high. The onus of protecting the engine should not be passed on to the ship staff and the fuel treatment plant onboard. It should rightly be passed on to the supplier. He is currently able to maintain 22 ppm. Let him accept 25 ppm as the limit. He has all the facilities. It is not fair to ask the shipboard fuel user to fix this problem. By inserting the wording in italics above in the first paragraph, the supplier is off the hook. The onus has been passed on to the poor Engineers on the ship. These Engineers cannot even ask for a purifier efficiency test to be carried out every time they bunker. The shipping companies will not be willing to spend the extra expenditure.
It is no wonder that catfines are the single most important reason for damage to machinery. See attached comments from Industry sources.
Gard P&I Loss Prevention Circular:
Gard has recently seen several examples of engine breakdowns resulting from catalytic fines/sludge having accumulated in the tanks and entered the fuel system during operation.
MAN B&W Senior Research Engineer:
Recent statistics based on replica impressions of cylinder liners, show that cat fines were present in a significant part of high cylinder and piston ring wear‐damaged cases in low‐speed engines.
IMAGE – Class NKK “Guidance for measures to cope with degraded Marine Heavy Fuels Version II”
8 Precision and interpretation of test results:
It is noted that the interpretation of the results and the permitted variation is now being covered by ISO 4259 in the main body of the standard while it was covered in the Annex in prior versions. While this may be acceptable in the general commercial practice, it may have certain negative implications for the bunker fuel. The supplier can use the permitted limit as his target and supply to the higher limit.
An example will be flashpoint where 4259 will permit a reduced flashpoint of 58.2 degC rather than 60 degC. Fortunately because this is part of the SOLAS regulation, no concession is permitted. Therefore, under any and all circumstances, the flashpoint has to be equal to or greater than 60 deg C.
Another example is density where if ISO 4259 is applied, the 991 kg/m3 fuel can go upto 991.9 kg/m3 (for a single test result). If the ship has a purifier (which is not AlCap type) and which has a density limitation of 991, a fuel with 991.9 kg/m3 density can reduce the purifier efficiency substantially. The same argument can be applied for catfines.
PART 4 – TABLE 1 and TABLE 2:
A new set of distillate fuel grades, DFA, DFZ and DFB containing bio‐fuels have been added to Table 1 of the standard. The new DF grades allow bio‐fuel blends containing up to 7% FAME (Fatty Acid Methyl Esters). The DFA, DFZ and DFB test limits are similar to DMA, DMZ and DMB for all parameters except for allowing up to 7% FAME content by volume. DMA, DMZ and DMB can contain ‘de minimis’ levels of FAME. Annex A states the “de minimis level of FAME for these grades can be approximately 0.5% which is higher than the “de minimis” level of 0.1% 8217:2010. The DMX distillate grade (mostly used for emergency generators and life boats) must be free from FAME. Please refer to our comments in Part 2 of this document on the “de minimis” limits.
Sulphur limits have been reduced from 2.00% to 1.50% for DMB and from 1.50% to 1.00% for DMA and DMZ grades. While the new standard has quoted extensively from the CIMAC document “Cold flow properties of marine fuel oils” published in 2015, it could have easily replaced pour point with cloud point for distillate fuels thereby reducing the risk for the ship operators with highly paraffinic fuels and also in cases where additives are used to depress the pour point.
Limits for various parameters in Table 2 residual grades remain unchanged.
PART 5 – ANNEXES:
Previous informative annexes on deleterious materials, sulphur, flash point and catalyst fines have been dropped as information on this is now included in the body of the standard itself. The earlier Annex on Precision and interpretation of test results has been included in the main portion of the standard and expanded to cover precision of FAME results. The Annex on Specific Energy in ISO 8217:2010 has also been moved into the main body of the standard.
ANNEX B ‐ Ignition characteristics of residual marine fuels
Annex B.2 covers CCAI (Calculated Carbon Aromaticity Index) which is given limits in Table 2.
The main problem with CCAI is that it is does not appear to be truly representative of the Ignition property of the fuel. Lately, because of secondary refinery activities such as thermal cracking, visbreaking, catalytic cracking etc., CCAI does not truly represent the ignition property. Also, the correlation between the IP 541 ignition and combustion test method and CCAI is poor.
We do not understand the purpose of Annex B of the 8217:2016 draft. The text of this Annex can be modified to give this message.
ANNEX D ‐ ACIDITY
The Annex states that “Notwithstanding that an acid number limit is given the fuel shall be free from inorganic acids (strong acids). A fuel in which a strong acid species (strong acid number (SAN)) is present, even at a low level not detectable by the standard ASTM D664 test method, is not compliant with this International Standard as there is a correlation between the presence of a strong acid and the corrosive activity of a fuel.”
We would like to add the following comment. In addition to the presence of strong acids indicating corrosivity, Viswa Lab’s own research has identified pH as a very sensitive indicator of the corrosivity of the fuel. MER magazine will be publishing an article by Viswa Lab on this research. Findings on pH are applicable to fuels (particularly Russian fuels which have caused severe acidity problems) and also cylinder lube oils which become more acidic when the engines are run at part loads.
We also suggest the following.
NEW ANNEX – SHOULD BE INCLUDED FOR NEW HYBRID FUELS (Sulfur of 0.10%):
The new ISO 8217 standard should add an Annex or a comment on the unconventional fuels currently being offered in the market. Several unconventional fuels are being offered in the market which do not conform exactly to the categorization in this standard. While the purchaser and the supplier may agree to limits of Table 1 and Table 2, the following points have also to be taken into consideration by the purchaser. This advisory is similar to Annex A of ISO 8217:2010 and also CIMAC “Guideline for ship owners and operators on managing distillate fuels up to 7.0% v/v FAME (Biodiesel)” published in 2013. This Annex will be a service rendered to the shipping community. It has to be recognized that charterers wanting to buy still lower cost fuels (such as these new hybrid fuels) are pressurizing ship operators to use these new grades of fuels.
- Composition and blend of the fuel.
- The Engine Maker has to certify that the new fuel will not cause any problems when used in the engine.
- Long term storage and stability of the fuel. Heavy fuels can stay on ships for more than one year before they are used and any reaction with gaskets, joints and other materials in the fuel line will have to be considered. This aspect has to be covered.
- The fuel should not have certain detergent properties which will flush the tanks and cause collection of impurities in the fuel line.
- The fuel should be compatible with other fuels and also other new fuels that the ship may be obliged to use. Though there are over a dozen suppliers, not every supplier is able to supply in every bunkering port. There may arise a necessity of mixing one new fuel with another new fuel and this compatibility also has to be considered.
- Last but not least, if the fuel purchaser and fuel seller agree and use a fuel and if this causes any machinery damage, will the insurance company accept the claim?