Viswa Lab had already covered this topic extensively with their Technical Update of 2016/1/3 based on the draft Standard available at that time. The version released on March 17,2017 represents the version that is final and our comments are on this version.
We want to make it clear that Viswa Lab’s approach in reviewing this Standard is to identify areas where the interests of the fuel buyer/fuel user are not adequately covered. This would represent the weakness in the new Standard. However, Viswa Lab will also comment on any aspect that provides more protection to the fuel user community.
CLOUD POINT (CP) AND COLD FILTER PLUGGING POINT (CFPP)
As an example of the above, marine distillate fuels must be tested for Cloud Point (CP) and Cold Filter Plugging Point (CFPP). This is an improvement over the earlier requirement of reporting only pour point. As is well known, as a distillate fuel cools, the first phenomenon to occur is the clouding of the sample. Therefore, the cloud point is the first value. As the fuel is cooled further, the Cold Filter Plugging Point (CFPP) occurs when small wax form which will tend to block the filters. When the distillate fuel is cooled still further, at the lowest point, the pour point takes place when the entire distillate fuel sample solidifies. Knowing the CP and CFPP values can save fuel users from problems related to wax accumulation when more paraffinic distillate fuels are being used.
CLAUSE 5 AND ANNEX B
The new clause 5 of the Standard has totally altered the clause 5 of the earlier versions of the Standard. Prima Facie the changes seem beneficial and innocuous. However, a more in depth look at this reveals the following.
Clause 5.2 states 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”. It continues to say that one of the sources acceptable is from “co‐processing of renewable feedstock at refineries with petroleum feedstock.”
It is well known that Styrene, Indene, DCPD and similar polymeric substances can cause filter blockage (gummy deposits), purifier choking and seizure of fuel pumps. Does the above quoted clause exempt the presence of such substances? Some suppliers get these substances from ethylene cracker bottoms and add it to bunker fuels. The Port of Rotterdam lists such polymers as one of the banned substances that should not be present in bunker fuels. Please refer to our Technical Update 2015/1/6.
Another important point. While conceding that the Deleterious substances should not be present in the fuel, unfortunately the Standard goes on to waiver the responsibility on the part of the supplier through a Note to Annex B which covers Deleterious substance. The exemption wording remains the same stating “This document precludes the incorporation of any material at a concentration that causes the fuel to be unacceptable for use as stipulated in Clause 5”. However, section C &D of Annex B state
c) various analytical techniques are used to detect specific chemical species with no Standardized approach, and
d) in most cases, sufficient data are not available with respect to the effects of any one specific material, or combinations thereof, on the variety of marine machinery systems in service, on personnel or on the environment.
Annex B goes on to say “It is therefore not practical to require detailed chemical analysis for each delivery of fuels beyond the requirements in Table 1 or Table 2.”
Viswa Lab had already highlighted this when the draft 8217 was circulated and even earlier when Annex B Deleterious Substances was introduced in ISO 8217:2010. The important point is that analytical techniques do exist and they have been in existence since 2013. ASTM D7845 “Chemical Species in Marine Fuel Oil by multi‐dimensional GCMS” was published in 2013. This is well known and Viswa Lab has repeatedly pointed this out. Nevertheless, the Standard continues in stating “The marine industry continues to build on its understanding of the impact of specific chemical species and the respective critical concentrations at which detrimental effects are observed on the operational characteristics of marine fuels in use.”
The Annex also goes on to say “a refinery, fuel terminal or any other supply facility, including supply barges and truck deliveries, should have in place adequate quality assurance and management of change procedures to ensure that the resultant fuel is compliant with the requirements of Clause 5.”
This is really a joke. It is well known that these substances are added to the bunker fuel with the full knowledge of the supplier in order to increase his margins. PLEASE NOTE THAT WE ARE NOT BLAMING ALL SUPPLIERS. OUR COMMENTS ARE ABOUT ONLY A SMALL MINORITY OF SUPPLIERS WHO INDULGE IN THIS.
Viswa Lab has repeatedly referred to empirical data available from which the contaminants or group of contaminants and the levels at which they cause machinery problems and damage are known. When both empirical data and an ASTM approved testing method are available, why should the new Standard provide escape clauses for those are supplying contaminated fuel?
CLAUSE 8 – ISO 4259
Clause 8 covers acceptance of ISO 4259 in the interpretation of the results. While this brings certain clarity, it has to be noted that with regard to Al+Si, the existing 60 ppm has been retained and this limit with ISO 4259 permitted variation can go upto 72 ppm. Here again, while the global catfine average is 22 ppm, why provide a 60 ppm limit and then on top of it another additional 12 ppm as part of ISO 4259 giving the supplier the benefit of supplying upto 72ppm catfines in the fuel without the fuel getting out of spec? This is an unnecessary concession granted specially to favor the supplier community. If there are specific areas where the average catfine value in available fuel is higher, a few exceptions can be permitted. The catfine problem has become more important and engine makers are actually tightening the catfine content limit in the fuel entering the engine from 15 ppm to 8 ppm.
This dichotomy puts the burden on bringing the catfine content from 72 ppm to 15 ppm on the treatment facilities available onboard the ship. This is not easy since purifier efficiencies also vary and there are no facilities available on the ship to measure the catfine content of the fuel entering the engine.
There are many other details of the new fuel Standard which we will send to you including our very popular table.
The parting advice on the fuel Standards is as follows. Even though 12 years have passed since the introduction of ISO 8217:2005, and two new versions have been introduced since then, 85% of the fuels we test are to the 2005 Standards since it provides a very robust protection to the fuel buyer/fuel user. Perhaps this trend may continue even after 2017 since there are no redeeming benefits for the fuel users with regard to heavy fuel in the new Standard.
On the other hand, for distillate fuels, the introduction of cloud point and cold filter plugging point is a definite improvement and this deserves your attention.
Please do not hesitate to contact us with any questions.
Best regards,
Dr.Vis
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