In a recently outlined detailed guidelines issued by CIMAC, industry stalwarts, refiners shippers and institutions have come together to highlight the operational issues related to compliant fuel and how Shipowners can deal with it.
Here we are giving an insight to that part of the article.
Complete Segregation, Zero Commingling?
In general, fuels should be handled as currently, with particular attention to the avoidance of commingling: the preferred default situation for bunkers coming on board a ship is complete segregation.
However, it is accepted that this may not always be possible or practical. This section provides guidance on identifying and addressing the issues that may arise from the planning stage through to delivery of the fuel on board the ship.
Having identified the ship’s fuel quantity and quality requirements, the shipowner/operator should, before ordering a fuel, determine whether the ship will have sufficient empty tankage to receive the full quantity expected.
If the ship does not have sufficient empty tankage available, extra care will need to be taken by way of applying a predesigned commingling plan to address the risks of non-compatibility and provide a clear path of instruction for all possible scenarios that could confront the ship; this may involve the redistribution of fuels into several tanks to minimize the risks.
Reference should also be made to the subsection on Responsibilities of fuel users in.
At this point, if possible, the ship should establish the characteristics of the proposed bunkers compared to that already on board. This assessment is difficult and will be based primarily on an assessment of differences in fuel characteristics such as density, viscosity, CCAI value and micro carbon residue (MCR) value, where wider variances would indicate a lower likelihood of the two fuels being compatible.
From the receiver’s/user’s perspective the first indication of quality will normally be the pre-delivery documentation provided by the supplier before the transfer of fuel begins. At this stage, it should be established that the advised details of the product to be supplied are in accordance with the specification that was ordered. If the ship’s staff are in any doubt, they should inform their management and should not load fuel until they are satisfied that adequate documentation has been received.
Steps To Follow During Delivery
Over the course of the delivery, the receiver/user should maintain vigilance over the quality aspects of the fuel being supplied. For example, prudent questions could include the following:
- Are all the required samples being drawn in a manner that indicates that they will be representative of the fuel supplied?
- What other activities are occurring? In the case of a bunker barge alongside the receiving ship, is the operation being conducted without problems, and is the barge alongside the sole source, or are other barges pumping through that barge to the ship or simultaneously supplying other products to the ship?
- Does the fuel appear to be supplied as a homogeneous product; has air-blowing been overused; is there an unusual odour; and are other abnormal characteristics or observed practices apparent?
All observations should be documented by the ship’s crew, and a representative sample should be taken in accordance with IMO guidelines.
Steps To Follow on Completion of delivery
On completion of the delivery, the following questions should be addressed:
- Do the details on the BDN relating to quality correspond to the pre-delivery data and the ship’s requirements?
- Have the commercial samples and the MARPOL delivered sample been correctly prepared,documented and securely sealed as required?
- Have arrangements been made to retain the samples for a minimum of 12 months in an appropriate and safely ventilated storage location?
It is the shipowner’s choice as to whether they go further and arrange for tests to be carried out on a sample of the fuel as supplied, noting that the MARPOL delivered sample is not for the ship’s use in such testing.
For many, this now represents a standard part of the quality chain, with the fuel not being brought into use until the relevant test report is available.
Testing the fuel
A number of options have been made available over the years for on-board testing using portable test units to assess aspects such as compatibility, viscosity, density, water and catalyst fines.
However, such units are only able to provide indications. While such indications may, at times, be extremely important and highly useful, they do not provide a basis on which to challenge whether the specification limits have been met, or to take substantial decisions as to whether a fuel should be considered usable/unusable, unless the results are confirmed by an analysis at an accredited laboratory.
- For test results to carry weight, they should be undertaken at a laboratory which is accredited to ISO 17025 or an equivalent national standard for the tests being carried out.
- The various fuel testing services available today all provide standard test packages which are designed principally to assess the characteristics of marine fuel oil as defined in the ISO 8217:2017 specification.
- Each characteristic is defined by one or more test procedures, the results of which can then be used to evaluate the fuel as supplied.
Assessing fuel quality
Given the basic framework of ISO 8217:2017, an assessment of the quality of a fuel as supplied may be divided into three subsets, namely statutory requirements, defined limits and general requirements:
Statutory requirements: The SOLAS and MARPOL Conventions include mandatory specific requirements for parameters such as flashpoint and sulphur content, as well as mandatory general provisions for fuel oil quality and safety.
Defined limits: These would be seen as the numeric limits as given in Table 1 or Table 2 of ISO 8217:2017. These limits are in respect of certain physical properties, composition or performance indicators.
General Requirements To Be Followed
Irrespective of meeting the statutory and defined limits, the fuel supplied must be acceptable for use subject to fuel treatment on board, as given by Clause 5 of ISO 8217:2017 and Regulation 18.3 of MARPOL Annex VI.
Additionally, ISO 8217:2017 Clause 5.2 requires that:
“The fuel shall be free from any material at a concentration that causes the fuel to be unacceptable for use in accordance with Clause 1 (i.e. material not at a concentration that is harmful to personnel, jeopardizes the safety of the ship, or adversely affects the performance of the machinery)” and Regulation 18.3.1 of MARPOL Annex VI requires that:
“The fuel oil shall not include any added substance or chemical waste which either:
(1) jeopardizes the safety of ships or adversely affects the performance of the machinery; or
(2) is harmful to personnel; or
(3) contributes overall to additional air pollution.”
While ISO 8217:2017 specifies certain fuel quality requirements—such as being free of both inorganic acids and used lubricating oil—other aspects exist which may render a fuel “unacceptable for use in marine applications” (e.g. the presence of certain petrochemicals and other such contaminants) which are not readily identifiable other than by specialist, specific, time-consuming and costly tests methods.
Given the multitude of possible test methods, some of which are proprietary and non-standardized, such testing will normally only be undertaken after a problem is encountered—the problem being the first indication that additional testing should be undertaken and what that testing should be looking for.
Even then, having identified an ‘unusual’ component, its quantification will need to be fully understood, both in absolute terms and relative to other fuels in general. Furthermore, it is often not possible to link such a finding to problems that may be encountered on board the ship; indeed, different engines/on-board systems may seemingly have used the ‘same’ fuel but with widely different outcomes.
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