Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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Sulphur 2020: What’s your plan? Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation.
Contents 3 Foreword 4 Part 1: Regulatory overview 6 Part 2: Overview of compliance options 7 Part 3: 0.50% conventional fuel pathway 21 Part 4: Summary of our Sulphur 2020 support services 2 | Lloyd’s Register
Foreword The MARPOL Annex VI Reg. 14 require greater awareness from the Whilst shipowners focus might be on regulation seeks to control SOx ship’s crew, with regards to the variety the fuels as delivered, this step change emissions from ships, leaving the of fuel oil formulations that may be on sulphur content is so significant option for ships to make the choice as delivered from one bunker loading to that every stakeholder from the crude to how they will meet the limits being the next. They might expect to have to supply through to the refiners and set. Shipowners today essentially have manage with a specific being required supply distribution network are being the option to either use a compliant on the compatibility between the impacted. The trigger for the change fuel oil to meet the regulation, or to different fuels. will start to come when shipowners set use high sulphur fuel oil (HSFO) in their dates for ordering the first loads conjunction with exhaust gas cleaning There is also the option to fuel ships of 0.50% compliant fuels. The China systems (EGCS) to achieve an with a non-conventional fuel oil with 0.50% limit zones have already shown equivalent SOx reduction, provided zero sulphur content; for example, 0.50% being supplied in that region. the arrangement has been approved liquefied natural gas (LNG) or Taiwan’s 01 January 2019 coastal and by the ship’s flag state. It is anticipated methanol. The perception, however, port 0.50% limits may also see an that over 85% of the world’s fleet will is that these alternatives will make increase in this demand. enter 2020 using compliant fuel as no significant impact on reducing the their chosen option. The IMO fuel demand for conventional compliant The transition period has already availability study predicted that 0.50% fuel oil by 1 January 2020 or in started and decisions need to be around 3,800 ships with EGCS will be the early years thereafter. made. The compliance options are in use by the implementation date; clear. Ship operators need to evaluate however, the figure is looking more We recognise that the change in their compliance strategies based on likely to be about 1000-1500 ships; this the sulphur content will have a each ship’s specific operation and risk equates to a demand of about 10–15 significant impact on the criteria. This evaluation needs to be Mt, leaving a projected demand of over management of ship’s bunkering unbiased and separate from any 260 Mt for 0.50% fuel oils. operations, both around the lead vested interests. At Lloyd’s Register up to the implementation date and (LR), we are ready to offer independent It is being widely emphasised that thereafter. However, it is considered support in the journey from making the reduction in the fuel oil sulphur that, with due preparation, not only a decision to implementing it. content will inevitably cause a can these changes be effectively change in the fuel oil formulation and managed but they will also open up its characteristics, when compared to a number of divergent pathways for that being used today. This will the fuelling of the world fleet. Sulphur 2020: What’s your plan? | 3
Part 1: The outside SOx emission control on the coastlines. It should be noted Regulation area (ECA) step change from sulphur that there is no sulphur cap as such, 3.50% to 0.50% from 1 January 2020 only a limit outside the ECA. is resulting in a major shift change for the marine fuel product portfolio, It is permissible that fuel oils with Your preparatory plan impacting all the stakeholders in the sulphur content in excess of 0.50% for the 1 January 2020 industry as well as ships worldwide. as given in regulation 14 may be used, 0.50% implementation providing that the SOx has been The end result will be a marked removed to an equivalent limit, reduction in marine SOx emissions such as through an EGCS. New NOx Tier III Keel laid - 2021.1.1 or after, Baltic & North Sea including English channel Max fuel oil sulphur content Exisiting ECAs: Chineses SOx ECAs for ECAs-SOx: Baltic & North Sea ECAs-SOx 0.50% ALL THREE AREAS ON Up to Dec 31, 2014: 1.00% North American & US Caribbean 01 01 2019 alongside at this time From Jan 1, 2015, 2015: 0.10% ECAs-SOx and ECAs-NOx Yangtze River Delta NOx Tier III requirement Possible future ECAs Pearl River Delta for ECAs-NOx: Boha Rim Newbuilding keel laid from Jan 1, 2016 Taiwan Entering commercial ports from 01 01 2019 0.50% Sulphur control Figure 1: Map of emission control areas 4 | Lloyd’s Register
1. Background regulation alternative means, such as exhaust was that a system was put in place. gas cleaning systems (EGCS), in order When, in 2012, that limit was reduced At the 70th session of the marine to meet this requirement it is fully to the current 3.50% sulphur, it only environment protection committee anticipated that the majority of ships, affected (as shown by the IMO data) (MEPC), in October 2016, it was at the implementation date, intend to some 10–15% of the delivered confirmed that 1 January 2020 comply on the basis of using fuel oils tonnage; in terms of the technical would be retained as the start date as supplied that meet the 0.50% max impact on users, it was undetectable. for the 0.50% max sulphur fuel oil sulphur limit. In contrast, this further reduction in requirement under Regulation 14.1.3 the outside ECA limit to 0.50% will of MARPOL Annex VI. This covers all MARPOL Annex VI was initially affect virtually all residual fuel fuel oils used by ships outside the adopted in 1997 and, as it entered deliveries. This will, therefore, for existing ECA for SOx emissions (Baltic, into force in 2005, a 4.50% sulphur those ships operating solely outside North Sea, North America & US limit on all fuel oils used outside ECAs, effectively be the first tangible Caribbean) where the limit remains those areas designated as ECAs was and substantial impact of the Annex at the level at which it has been since applied. As shown by the IMO sulphur VI SOx reduction programme. 1 January 2015: 0.10% max sulphur. monitoring data, even before the Annex entered into force, the 4.50% While Regulation 4 of MARPOL Annex limit effectively represented the usual VI provides for the use of approved maximum at that time; the key point 1.1.2012 4.50% 1.1.2020 3.50% Outside ECA SOx 1.7.2010 1.50% 1.1.2015 1.00% 0.50% ECA SOx 0.10% Figure 2: Sulphur content requirements 2. Implementation deadline meeting on consistent implementation The IMO has also requested the 1 January 2020 of Regulation 14.1.3 of MARPOL Annex international standards organisation VI were formulated. The deliverable (ISO) to address the quality concerns Given that MEPC has now confirmed will be a guideline document along being expressed and to ensure that the its decision and the MARPOL with amendments to relevant sections ISO 8217 fuel standard suitably covers amendment timescales, it must be of Annex VI addressing the concerns the new fuel blends. In response ISO understood that 1 January 2020 is now being raised that need greater clarity is developing a publically available unalterably fixed. While MEPC and the to ensure uniform and consistent specification (PAS) to support the pollution, prevention, response (PPR) implementation. These include, to current addition of the ISO 8217:2017 sub-committee are considering name a few elements: enforcement, means to assist in the consistent sulphur content verification, addressing A ban on the carriage of non-compliant implementation of this 0.50% max non-availability of compliant fuel oil, fuel as a fuel oil (not as a cargo) is sulphur limit, this cannot in any way and recommendations to address any expected to enter into force on 1 March change or soften that date. concerns around the possible impact 2020, this is intended to facilitate on machinery and operations. These enforcement. will be addressed at the intersessional 3. IMO Guidelines workgroup (ISWG) from 9–13 July 2018, for final submission and adoption by At PPR5 (Feb 2018), the terms of MEPC 74 in April 2019. reference (ToR) for the intersessional Sulphur 2020: What’s your plan? | 5
Part 2: Overview of compliance options 1. Compliance options To sum up, there are three routes to compliance, which are: The primary option is to use the compliant fuel oil route to meet the a. Primary Regulation 14 requirements by controlling the sulphur content in the i. To use conventional compliant fuel fuel against the given limits for inside – namely, sulphur controlled and outside an ECA-SOx. The 2020 distillates or residual fuel oil. implementation date is expected to ii. To use alternative fuel oil types precipitate a wider range of fuel meeting the sulphur content formulations being made to meet the controlled limits, such as LNG, 0.50% sulphur content target. These methanol or hydrogen, or various will consist of ultra low sulphur fuel biofuels and synthetically oil (ULSFO) of
Part 3: 0.50% limit will not have quite the same decisions in the different approaches impact as those currently only that can be taken, any one of which conventional operating outside an ECA. The former will require significant investment, will already be familiar with the need time and resources to put into place. fuel pathway to maintain the two grades (ECA-SOx Every refinery has a different level of and non ECA-SOx) separately and to complexity, which will dictate the duly manage the changeover between degree of options open to them; these the two on entering/exiting those include but are not limited to: 1. Implications for areas. The technical challenges of shipowners change over and machinery set up • Upgrading fuel oil residues to a already having been established. distillate grade, the demand for which will be dictated by the uptake a. Global operations outside an ECA- In fact, the much reduced differential of the EGCS by the marine industry SOx in the sulphur content between from 2020 and finding other shore the two fuels will tend to ease the based options – Where these Ships normally operating outside an changeover problems and reduce the refineries have been already ECA will be presented with a major extent by which the ECA-SOx fuel is upgraded then this option will be change in the composition and degraded by admixture with any certainly applied. There will be formulations of the diesel fuel oil remaining non ECA-SOx fuel and insufficient capacity of these high being supplied and its potential associated pipe-wall residues. complexity refineries available for operational impact on the machinery this and any upgrade requires some plant if not understood and managed. Additionally, since much of the 5-8 years to build not lest significant maximum 0.50% sulphur stock will investment. The previous reduction in the outside not be the full IFO 380 type residual • Desulphurisation, which is not a ECA fuel oil sulphur limit from 4.50% to fuels but instead somewhat lower favoured option due to the high cost 3.50% from 1 January 2012 affected viscosity products, the time taken for and energy requirements. only some 10–15% of deliveries and engine changeover will be reduced • Further blending with low sulphur the underlying nature of those fuel oils – albeit with the potential for the fuels, but this also requires significant was unchanged. In contrast, based on increased risk of an unstable interface investment. For many providers this the IMO’s 2016 data, over 80% (by between the two. But providing this is will likely become the norm. tonnage) of residual fuel oils supplied kept within the fuel conditioning unit • Using sweeter crude options and that year was in the range of 2.00– booster circuit after the service tank blending. 3.50% sulphur with an overall average then this should be effectively of 2.58%. Furthermore, it is fully managed by the crew who have been At the start of 2020, it is anticipated expected that virtually all 0.50% max made aware of this possibility. that there will be a glut of high sulphur fuel oils will be produced and sulphur residual fuel oils with no delivered very close to or at that limit market to go to, and, at this point, the value – i.e. in the range of 0.48% to 2. Implications for refineries refining industry will be able to gauge 0.50%. the true impact of EGCS and take a The petroleum industry, while in measured approach as to the best Consequently, all affected shipowners general expressing availability of the investment paths to take. Taking into would be strongly advised to have in 0.50% product from 2020, has advised account that a coking plant can take place a ship-specific transition plan to that there will be a major shift in some seven years and about USD 0.5 ensure ship readiness for 0.50% 2020 refinery configurations and billion in investment to put in place. implementation. Note that a generic operations to accommodate and This change will require refiners to transition process timeline has been deliver to the ships this new marine each work out for themselves how drafted to cover key considerations fuel demand for 0.50% sulphur this new world will appear, since for timely preparedness for content fuel oils. As it has done these are generally high-cost, long- compliance (see figure 3). repeatedly in the past, the refining term investment decisions. industry is expected to adapt to the b. Operating both inside and new demand spectrum, however it It should be expected that, as outside an ECA-SOx has been stated that this will result encountered when the North in an unprecedented change in the American ECA-SOx came into effect, For ships operating both inside and range of characteristics of the fuels at least initially, much of the 0.50% outside an ECA-SOx, it could be seen which will be supplied. This will max sulphur product will be the result that the introduction of the 0.50% require some difficult commercial of exceptionally heavy blending – the Sulphur 2020: What’s your plan? | 7
high ratios thereby resulting in some Commingling and segregation should aim to keep bunkers of higher uncharacteristic fuel oils, but different sources segregated or make still falling within the ISO 8217 The process of hydrocracking efforts to ensure the compatibility specifications, with some having produces more highly paraffinic fuels, between the fuels to be mixed prior limited remaining stability reserve which sends two signals: the first being to possible commingling is first and, in some instances, dumbbell that the management of cold flow confirmed and a safe ratio blend mix combustion characteristics, where the properties of both distillates and is determined. Should the fuels not carbon distribution results potentially residual fuels will have to be more be compatible, then mixing should in an uneven heat release during the carefully considered; and the second not be carried out, any attempt to combustion process. This phenomena being that it could present additional do so could result in two perfectly is affected by the actual nature of operational issues in regards to the stable fuels becoming unstable and blend feedstocks used. likely incompatibility of the two or totally unusable. more fuels intended to be commingled in the ship’s bunker tanks. This will Given the distribution of refining 3. What type of fuel can we require more consideration by the capacity and the other product expect for a 0.50% max shipowner in the way it applies ‘fill demands in an area, it may well be sulphur limit? to capacity’ policies with the charterer that some areas/ports are more likely and applying a strict bunker to only provide a particular type segregation policy where so required. of 0.50% max sulphur fuel oil – be With the current max sulphur limit of that a distillate or some form of 3.50%, all ship systems that could use Consequently, while different stems intermediate blended product, or residual grade products up to the of residual fuels could be mixed a higher viscosity residual fuel oil. viscosity norm of 380 cSt (V50) and, (commingled) – i.e. when loading to in some cases, up to 700 cSt, will have maximum on top of previous bunkers In view of this applying best been generally doing so. However, – best practice would warrant the ship management and fuel care practices, it is fully expected that fuel oils as avoiding any attempt to mix. The risk combined with flexible fuel system supplied, meeting the 0.50% limit, of incompatibility between two design, will ensure risks are mitigated. will range anywhere from light different fuels is likely to be more distillate (MGO) through to heavy pronounced than that faced today. Fuel terminologies have been updated residual with a range of widely In view of this, particular attention for the 2020 changing fuel scene as differing fuel oil compositions in will need to be given to setting up shown in table 1. between referred to as VLSFO. a commingling plan, which primarily Table 1: Fuel categories 1 January 2020 fuel categories Sulphur Residual Distillate Blends of RM + DM Content Marine Marine and other streams (RM) (DM) (MGO) HSFO >0.50% no Yes No Unlikely except for lower Demand will drop right off maximum viscosity requirements proportional to EGCS usage RMG grades VLSFO
4. Shipowners’ key This assures the industry that the exceeding 0.50% max sulphur after considerations for fuel requirement for the SOLAS flash point 1 January 2020 – and even before that supplied to the ship minimum limit of 60 °C and inherent date there will be an ever-decreasing fuel stability for storage, handling and demand. use should be met. a. Fuel availability HSFO fuel buyers The refineries, storage depots and Hence, from the fuel buyer’s Although the IMO fuel availability physical suppliers will have to perspective, it is imperative for ship study identified that overall there was contend with over 200 million tonnes operators who intend to use HSFO the required refining capacity to meet of HSFO becoming surplus to demand with EGCS to swiftly initiate a the marine requirement, it is to be from 1 January 2020 onwards, being dialogue with fuel suppliers and expected that, at least initially, there replaced by the demand for charterers on their ship’s may be quantity shortfalls in some maximum 0.50% VLSFO. While the oil requirements and the availability of areas, whilst the available stocks are industry has confirmed that the the HSFO fuel post 2020. It is evenly distributed. While the refineries have the capability to envisaged that suppliers from preference may be for a ship to supply globally, there may be initial relatively small ports in particular will procure a residual fuel of higher shortages in meeting the high have no incentive to store HSFO over viscosity for a maximum 0.50% fuel demand. This should be quickly longer periods of time as they will oil, it may just be that only a light addressed by the relocation of the have limited opportunities to supply distillate will be available. This poses products to meet a particular local ships installed with scrubber the question of additional cost and demand. Where non-availability does technology, unless they have been also the technical and operational become an issue, however, under the advised on intended ongoing orders. readiness of the engines and boilers provisions of Regulation 18, a fuel to operate on a distillate fuel oil for a oil non-availability report may be b. When will the 0.50% fuels prolonged operational period in a submitted for approval to the local become available? safe manner. competent authority for their clearance to load non-compliant This question is unlikely to begin to Suppliers position fuel oil. The need for more details be answered until mid-2019 and will As well as the IMO fuel availability surrounding the different scenarios very much depend on when demand study, a number of major fuel oil will be addressed at the IMO PPR ISWG starts and the rate that it will build. It suppliers have publicly stated that for the consistent implementation of will need to be taken into account compliant fuels will be available the Reg. 14.1.3. in July 2019. that the supply chain has to prepare before the 2020 deadline, although by cleaning out HSFO from the a consistent distribution of these EGCS status storage tanks and barges, as well as 0.50% VLSFOs may take a little time. The anticipated demand for HSFO is their transfer pipelines, which will be We have been advised that some 30 based on the number of EGCS that a logistical challenge for the supply Mt of 0.50% stock will need to be in will ultimately be in service. This is, chain as a whole. The onus, therefore, the storage tanks globally to service however, anticipated to be not much is on the shipping industry to discuss the fleet at the start of 2020. There is, more than 1,000 ships at the start of with their supply network what notice therefore, always a possibility that 2020, equating to 7-10 Mt of HSFO. is required when ordering the 0.50% smaller ports may not have these fuel, and then the supply chain will be fuels available due to limited storage While the availability of VLSFO and ready to supply for meeting the facilities over time, prompting ships ULSFO is at the forefront of clients specific loading timeline, with to have to bunker 0.10% ULSFO grade shipowners’ minds, those intending the knowledge that by December with the additional cost implication to operate on a Regulation there will likely only be a few ships on the charter party. 4-approved EGCS plus HSFO option still ordering HSFO. In order to meet should also consider that HSFO may the 1 January 2020 deadlines Product quality not be that available in many ports, shipowners will need to calculate the Whilst the major fuel oil suppliers in particular the less frequented time needed to ensure they have used have further assured the industry of bunker ports. This needs to be seen up all their HSFO and prepared the the availability of 0.50% fuel oil, the in the context of marine fuel oil tanks for 0.50% VLSFO (these may products offered to the market will suppliers also needing to change well need early inspection for the however vary considerably in their over their own storage, handling and degree of cleaning required to avoid formulations and characteristics supply facilities. Note that, apart from contamination). In particular ships (while all fuels supplied are expected fuel oil suppliers with known EGCS- setting off on a long trans ocean to meet ISO 8217 international marine using clients, there will effectively be voyage will need to ensure that the fuel specification for ships). no market for marine fuel oils only remaining on board fuel will be Sulphur 2020: What’s your plan? | 9
compliant from 01 January 2020, thus is insufficient time between now and can be overcome to mitigate any ships may be loading at least one tank 2020 to develop a full revision of the operational risk. This can be best of 0.50% a number of months before specification – hence one of the achieved by first carrying out an the required usage date. options that is now going ahead is independent analysis of to release a PAS in support of ISO representative bunker samples to c. Fuel quality control 8217 to see through the early part of obtain full transparency of the fuel the 2020 implementation, providing composition as loaded and then i. ISO 8217:2017 marine fuel oil any specific guidance that might adjust the machinery plant settings specification quality control be considered important to accordingly to be optimised for Concerns have been expressed to the communicate on additional known storage, treatment and combustion. IMO MEPC regarding the anticipated aspects that require particular changes in the fuel characteristics, attention. This will also allow ISO a. Compliance which will be the outcome of the TC28/SC4/WG6 time to better refiners and suppliers reformulating understand the new fuel formulations As the world heads for global ECA the marine fuels to meet this lower coming onto the market in 2020 and coverage, every bunker will come sulphur limit. In response, the IMO thereafter apply any further revisions under scrutiny and ships will run the has asked the ISO marine fuels to the specification between about risk of being found non-compliant if committee to address these quality 2023 and 2025. It is expected that, for due diligence in the ordering, concerns which impact technical and the next 18 months, the group’s focus handling and use of these compliant safety aspects of operations and will be to address three underlying fuels are not properly carried out. submit a report/guidance to MEPC 74 given concerns, but being alert to This should include ensuring that the by April 2019, as well as guidance for others that may arise leading up to crew have witnessed the drawing of the marine industry on the application 2020, these being: the stability of the the MARPOL sample and signing of of the current specification and any fuel blends; a means to better the accompanying documentation amendments to the ISO 8217 marine determine the compatibility between along with the accompanying bunker fuel specification to follow. one fuel and another and the wax delivery notes, any respective ‘letter content in lighter RM fuel blends. of notices’ and sample tracking As it stands today, ISO 8217:2017 All other parameters, including flash records; and maintaining records of provides coverage for all marine point, are also being addressed. the entry into and exit from an distillate, residual and new blends of ECA-SOx changeover. fuel oils, as set at the end of 2014 for i. Fuel safety the implementation of the 0.10% ECA Covered under ISO 8217, marine fuels Ships should therefore reassess their step change of 2015. It is anticipated are required to be supplied against procedures for maintaining that some of the formulations that the SOLAS requirements; in particular, compliance to Annex VI Regulation will be offered to the market will have the flash point must not drop below 14: 18. The IMO is currently drafting a characteristics that are unfamiliar to 60 °C. Buyers are recommended to further guideline (to be available in some ship operators, as was the ensure that fuels are purchased the second quarter of 2019), which is experience of the ULSFO blends against the latest edition of the ISO on aspects affecting the consistent brought to the market in 2015 but yet 8217:2017 specification taking into implementation of Regulation 14.1.3. still fall under the control of ISO 8217. consideration the requirements of the During the latter part of 2019, we can specification in its entirety – not just This will include current uncertainties, expect further guidance from the ISO against the Table 1 and Table 2 such as those surrounding: and the international council on requirements. It is recommended • Fuel oil non-availability combustion engines (CIMAC) fuels that reputable quality fuel suppliers • Enforcement and guidance for port working group on how best to order should be chosen to mitigate the risk state control and manage these less familiar that off specification fuel is supplied. • Onboard verification of the sulphur formulations. content • Ban on the carriage of non- Publicly available standard 5. Key onboard fuel compliant fuel oil After the release of the ISO 8217:2017 management • Amendments to Annex VI, which will edition in March 2017, ISO TC28/SC4/ considerations be carried out where applicable WG6 started working on the next It is outside the scope of this edition to encompass 0.50% VLSFO, The application of best practice in document to cover the full spectrum which is being anticipated may raise onboard management and fuel care of quality concerns around marine additional stability, compatibility and will ensure that uncertainty in terms fuels; the aim of this document is to cold flow considerations in terms of of fuel characteristics and any focus on the specific characteristics handling and using these fuels. There perceived safety concerns as loaded that are likely to require additional 10 | Lloyd’s Register
attention over and above that being forces through normal onboard use, it d. Storage and segregation of given today for the anticipated does not necessarily follow that two bunker planning incoming 0.50% S fuels. stable fuels are compatible when blended or mixed together. Every ship should re-evaluate their Much has been stated about concerns bunkering strategy – the flexibility in over the compatibility of two different Incompatibility is the inability of two terms of whether filling to capacity fuels and the importance of verifying or more blended components to exist can be avoided, which will depend before attempting to mix them. together without breaking down and very much on the number of storage The following provides some more precipitating sludge. Two perfectly tanks, their holding capacity and ship insight into this issue, in view of its stable fuels deemed incompatible operating profiles to enable bunkers consequential impact on operations when mixed can form an unstable to be kept segregated. should attention not be given to this product. issue of mixing fuels on board. e. Ordering bunkers and diversity of supply b. Fuel stability defined In view of the likely diversity of the The stability of a residual fuel is nature of VLSFO/ULSFO that could be defined by its resistance to breakdown supplied, the following is a summary and precipitate asphaltenic sludge of the four main scenarios a ship may despite being subjected to forces, such be faced with at each bunker – the as thermal and ageing stresses. An approach to which should be unstable fuel would have the tendency considered when setting up the to precipitate asphaltenic sludge to the bunker order clause. bottom of a tank clogging pipelines and filters and overloading separator Scenario 1 – 3.5% replaced with • plants – the degree of which will be a VLSFO 0.50% with RM specs function of time and/or temperature. (no shortages) Scenario 2 – No or low VLSFO (RM) • The increased use of blended availability, requiring use of DM products to achieve 0.50% fuel spec fuel (DMA) heightens the risk of instability during Asphaltene sediment from tank bottom Scenario 3 – ULSFO (0.10%) only • storage handling and use. It is the available for 0.50% compliance responsibility of the supplier to In 2015 some suppliers specifically (DM or RM) ensure that there is sufficient stability advise that their ULSFO (0.10%) Scenario 4 – No ULSFO or VLSFO • reserve to sustain the storage and should not be mixed with other fuels available, so must load HSFO with handing requirements of the ship – at least only less than 2% of ULSFO an approved fuel oil non availability under normal operation and handling with the new fuel. Where ships have report (FONAR) conditions. Oil majors are only too ignored these precautions, they have aware of the consequences of seen the fuels become unstable, When setting up the bunker order supplying an unstable product, as it which can result in a debunking clause, consideration should will immediately fail the ISO 8217 operation. therefore be given to these different control on such a parameter and scenarios that may be offered from render the operational status of the The consequences of mixing the bunker suppliers in a port – ship as unsafe. Ships are best advised incompatible fuels, leading to an particularly in the months at the start to confirm that the fuel delivered is unstable product, are severe and very of 2020, while compliant fuel stocks stable for their operational purposes often the only resolution is to are being evenly distributed to meet on delivery in accordance with ISO manually remove the fuel from the demand. 8217 ordering specification. tanks and unblock pipework. It is for this reason that the industry body It is recommended that orders are c. Compatibility defined advises, where possible, that fuels made against the latest edition of the from different sources are kept ISO 8217:2017 marine fuel standard, Compatibility is the ability of two segregated; measured commingling which incorporates the latest fuel stable fuels when commingled to form is, however, possible when due quality considerations. a homogenous and stable compound. processes are followed to determine While every fuel should be that the fuels concerned are manufactured with sufficient stability compatible with one another. reserve to withstand the expected Sulphur 2020: What’s your plan? | 11
f. Distillate operational considerations Pour point The lowest temperature at Where there are local shortfalls of RM which the fuel will continue to 0.50% max, it may be expected that flow when cooled under set the ships affected will be expected conditions (ISO 3016). instead to load ECA-SOx fuels, which may mean taking a full load bunker Cold filter plugging point of a distillate (DM) grade fuel oil. In The highest temperature at view of the potential technical and which a given volume of fuel operational implications upon such will no longer pass through a ships that have not become familiar set filter size in the test defined with inside ECA-SOx operations, time when cooled under set where distillates are widely used, conditions (IP 309 or IP612). then the same preparations carried out for 2015 need to be considered for Cloud point this 2020 implementation date. (See The temperature at which figure 3). a cloud of wax crystals first appears in the fuel (this test g. Cold flow properties is only applicable to clear and and wax content bright fuels, as per ISO 8217 a DMA grade should be clear ISO 8217 limits the cold flow Filter becoming blocked due to build - and bright) (ISO 3015). properties of a fuel through the up of wax. DMA grade bunkered in ARA control of the pour point (PP) for region - CFPP 5°C both the RM and DM fuel oils. However, given that wax crystals will form at temperatures above the PP, fuels that meet the specification in terms of PP can still, therefore, be challenging to operations in colder operating regions. High paraffinic content of certain distillate fuels may lead to wax formation at ambient system Clear sample at 28°C temperatures, resulting in tanks, filters and purifiers being fouled PP, CFPP and CP have no with wax deposits, causing flow correlation other than TPP < restriction to the machinery plant TCFPP < TCP. It can be shown if temperatures are not maintained that PPs well below 0°C can above the point wax crystals form. have CFPPs as high as 18°C. The cold flow properties of cloud Ships need to assess their point (CP), cold filter plugging point operating profile and onboard (CFPP) and PP of the fuel can provide tank and purifier/filter warming information on the required storage arrangements; if there are and handling temperatures a ship Wax crystals formed at 24°C identified limitations, these needs to maintain to avoid fuel flow need to be expressed in the restrictions. These paraffinic fuels bunker order clause for when however, can be easily managed the ship is going to be operating provided the temperature of the in a low-temperature region. fuel is maintained above the wax appearance temperatures identified. Temperatures typically need to be kept 10°C above the PP, 1°C above the CFPP and CP which ever is higher. 12 | Lloyd’s Register
h. Viscosity and density against a maximum of 877 cSt for regions and China already have a high sulphur fuel oil. suitable products, as can be seen in It is anticipated that the 0.50% sulphur table 3 below, which illustrates again fuel delivered will have broad ranging Operationally, this will require ships the diversity of the viscosity, density viscosity and density characteristics. to be attentive to the setup of the and cold flow property of pour point. table 2 below illustrates the data for purification plant and pre-heat and 2017 on 0.10% sulphur fuels (ULSFOs), viscosity control settings. In the case of which ranges between 2.2 – 116.6 cSt 0.50% fuels today, the South American Table 2 2017 data Residual grades, LR FOBAS Distillate ULSFO S ≤ 0.10% S ≥ 0.11% Density (kg/m3) Average 860 899 985 Median 857 902 989 Max. 949 945 1035 Min. 811 837 844 Viscosity (cSt) Average 3.8 32.8 345 at 40°C dist. Median 3.6 30.9 357 at 50°C residuals Max. 32 116.7 877 Min. 1.6 2.2 30 Net specific Average 46.2 42.4 40.4 energy (MJ/kg) Median 42.7 42.3 40.3 Max. 43.2 43.1 43.0 Min. 37.6 37.8 - Table 3 2017 data LR FOBAS Residual grades, 0.24-0.50% S Bunkering country China Brazil Argentina Density (kg/m ) 3 Average 977 954 953 Max. 991 968 968 Min. 963 934 929 Viscosity (cSt) Average 145 (154) 343 (353) 342 (343) at 50°C Max. 179 406 411 Min. 92 260 96 Net specific Average 41,2 41,6 41,6 energy (MJ/kg) Max. 41,4 41,8 41,9 Min. 40,9 41,3 41,4 Pour point (°C) Median 19,5 Less than 6 Less than 6 Max. 32 30 18 Min. Less than 6 Less than 6 Less than 6 Comments RME180 RMG380 RMG380 Sulphur 2020: What’s your plan? | 13
Figure 3: S2020 - Operational considerations inside ECA-SOx and outside ECA-SOx Sulphur 2020 ≤ 0.50% Sulphur – Operational considerations within ECA-SOx and outside ECA-SOx Fuel System Stage Major concerns Suggested solutions Bunker requisition/bunkering operation • Availability of ordered 0.50% VLSFO • Define all supply scenarios and assess ship or 0.10 ULSFO? adaptability to respond • Compatibility of new bunkers with old • Review robustness of bunker clause • Fuel quality stability/flash point/cold flow • Agree comingling strategy and plan with • Broad spectrum of fuel scenarios to handle charterer and supplier against 0.50 order • Perform a fuel system/management • Non availability FONAR process to ensure assessment review for individual or the capt/ceng is aware group of vessels to identify and address • Charterer understands ship scenario operational and technical challenges at strategy and implications 0.10, 0.50 and each component point in the fuel system >0.50 bunkers segregation strategy from DM and RM operations. Order to latest • Unstable fuel will result in heavy sludge edition of ISO 8217:2017 deposits adversely impacting operations Fuel storage/transfer • Fill to capacity requirements from • Apply comingling/segregation/ charterer compatibility strategy/plan • Tank cleaning challenges of existing • Order compliant fuel well in advance of HSFO tanks to switch to 0.50% enforcement date of 1st of January 2020 • Crew competence/awareness in managing to allow fuel tanks and systems to flush the fuel change over and through • Incompatibility between each bunkers • For extended ECA operation, dedicate • Overheating of MGO (0.10 or 0.5) from segregated storage tanks for ULSFO sulphur leaking steam heating valves and high fuel with separate service/settling tanks for temperatures adjacent RM tanks VLSFO – • MGO Fuel quality issues during long • Use segregated transfer lines and pumps for storage such as with FAME (fatty acid 0.1SFO distillate operation. methyl ester), oxidation stability, microbial • After each bunkering check compatibility contamination. across all fuels • HI cold flow temperatures CP and CFPP • Plan tank cleaning well in advance of 01/01/20 = ‘2020 Ready’ • Isolate steam lines to additional MGO tanks check steam v/vs sealing • Assess Cold flow management flexibility • Verify fuel change over plan and assess crew competence3/awareness • Avoid long storage periods of distillate fuels, regularly drain water from tanks to reduce microbial activity • Consult CIMAC Guidelines on managing fuels with FAME – (request for FAME scan on MGO bunker) • YACHTS fuel tank coating prevent corrosion and regular microbe tests Settling/service tanks • Segregate VLSFO and ULSFO vs MGO • If an existing LSFO settling tank is being • Leaking steam heating valves will elevate used for 0.1SFO then ensure steam heating MGO tanks temperature where applicable is isolated (if an MGO) • High fuel temperature in settling/service Conduct inspection of trace heating valves tanks because of close proximity with RFO and lagging condition. settling/service tank • Note that some adjacent tank heating with regards to storage tanks where maximum temperatures are not exceeding 45 deg C may be advantageous for high cold flow property fuels – seek guidance on this from Lloyd’s Register FOBAS on a case by case basis Purifiers/filters • Low viscosity temperature control • Crew awareness and training – attentive • Filter blockage may occur especially at to fuel characteristics for purifier set up/ the time of fuel change-over or during heating control during change over set up circulation for tank cleaning due to solvency • Keep the backup filters clean and ready for nature of the MGO quick change over (have sufficient spare • Excessive sludge generation at filters/ replaceable filters where applicable) purifiers could result in fuel supply • Attention to purifier settings based restriction on tested density and viscosity – • High melting point wax fuels may cause recommended de-sludge cycles sludge at purifiers on low temperatures • Seek lab testing service support to asses wax melting points 14 | Lloyd’s Register
Fuel system stage Major concerns Suggested solutions Viscosity controller/service • Overheating and or thermal shock • Calculate the change over flushing time, system change over point • Leaky 3-way C/O valve with the risk of HSFO/ which can be verified through analysis VSFO contamination of spot samples before the date of • Unsatisfactory or poorly executed fuel implementation change over procedure • Sea trial the change over, start/stop/ahead/ • Fuel starvation due to filter blockage at the astern and fuel system sampling before the time of change over date of enforcement in open waters • Flushing time required • Consider engine fuel return arrangement – additional valve by -pass straight back to settling tank to minimise flush through time • Ensure viscosity controller, changeover valves and other fuel system components are in good state of repair and maintenance • Rate of change in temperature should be approximately 2 oC/minute • Ensure Viscotherm PID controller is responding uniformly to the change in viscosity demand. • Option: MGO/HFO segregated parallel service system - link at a change over after duplex hot filters3 ( refer to LR DIST Notation) • Identify/install designated sampling points in the fuel service system after service tank to facilitate sampling for compliance verification Fuel pumps/injectors/exhaust valve • Low viscosity at engine inlet may result • Check viscosity at point through all fuel in loss of hydrodynamic sampling for system – best above 3.0 cSt min 2cSt on fuel compliance verification lubrication between system components (check with OEM advice) fuel pumps/injectors causing excessive wear • Install4 chillers/coolers as required • Poor lubricity characteristics of the fuel • Check fuel system seals/O ring condition (viscosity is a bigger concern) • Ensure fuel pumps leakage drains are clear • Excessive fuel temperature can also cause – monitor drain tank more regularly for gassing up or vapour lock excessive fuel leakage/losses • Fuel leakage and insufficient pressure from • Review maintenance schedule of fuel system worn fuel pump/injectorsand old seals components • Excessive wear at exhaust valves • Check bunker order requirements – apply ship specific limits • Check OEM for extended distillate operations engine set up requirements – such as: exhaust valve seats to stellite from nimonic – cylinder head replacement, fuel valve and valve cooling – timing etc. • Check fuel drainage arrangements around fuel pumps are clear to the collection tank and alarm system is working Combustion/engine performance • Diversity of fuel formulations combustion • For each new bunker performance • Take electronic power card/draw card to • Delayed ignition - Engine knock evaluate the engine performance and make • Cylinder lubrication necessary timing adjustments • Low energy content/low density of the fuel • Contact engine manufacturer for further • Loss of power guidance regarding extended distillate and low sulphur operations • OEM and lubricant recommendations on CLO should be referred to • 2nd CLO grade storage tank may be required on board for 0.1SFO/LSFO such as CLO BN of 30 or 40 1 MARPOL Annex VI regulation 14.4.3 dictates that while ships are operating within emission control area, the sulphur content of the fuel oil used on board ship shall not exceed 0.10% m/m on. Regulation 14.1.3 requires that the sulphur content of fuels in use shall be a maximum of 0.50% m/m from 01.01.2020. Regulation 4 allows for equivalents such as an exhaust gas cleaning system approved by the ship’s flag. 2 MARPOL Annex VI emission control area for sulphur oxides (SOx). 3 Carryout crew assessment and training/awareness programmes as required. 4 Advise ship’s class of any planned fuel system/machinery modification which may require plan approval. Note: Above information is for guidance only and we recommend ship operators to perform a risk assessment to evaluate and make decisions based on the operational and technical profile of individual vessel or group of vessels. Lloyds Register will be pleased to assist in any aspect of your fleet assessment of ‘2020 ready’. Sulphur 2020: What’s your plan? | 15
6. Key steps to consider in the ship implementation switchover plan from HSFO to VLSFO It is recognised that the one-off switch number of operational aspects being and for each ship specifically, from HSFO, to the VLSFO 0.50% affected. The suggested generic acknowledging the wide variation maximum sulphur content will require implementation timeline (shown in between ship types and sizes, operating significant planning to ensure a smooth figure 4 below) outlines the key areas for profiles, and tank storage and fuel transition to 0.50% compliance, with a ship operators to consider for their fleet system arrangements. Mar - Dec (Planning) Nov - Aug (Preparations) Sulphur 2020 implementation plan Ship made ready plan Commercial/charterer/supplier dialogue Sea trials on distillates and VLSFO 0.10/0.50 Machinery scope of fuel requirements/settings Cleaning and preparing tanks for 0.50 Key considerations Fuel handling ULSFO VLSFO of RM/DM any constraints Apply commingling strategy loading plan Designated sampling point identification Act on technical observations boiler A/E and M/E Awareness/training shore and ship best practices for 2020 Modification of tanks/fuel system arrg. >0.50 ship audit run down plan fuel grade scenarios System modifications Fuel oil tank switchover timeline Cylinder oil requirements Fuel management sulphur 2020 update (PDCA) Ship specific actions • Identify company • Switch over loading plan • Crew awareness/training sulphur 2020 leader • Tank and pipeline • >0.50 audit run down plan preparation schedule Specific actions • Engage crew in applying best practices • Guide on mitigating risk/ • Non-availability FONAR safety concerns • Lubricating oil requirements • Operational/technical observations • Bunker clause addressing re fuel Scenarios fuel scenarios • Cold flow limitations • Commingling plan, management • Finalise system readiness for switch over segregation strategy • Compliance documentation • Enforcement/inspection facilitation • Structure modification timeline • Continue open dialogue with charter on change requests and bunker scenarios • VLSFO to ULSFO c/o calculations 16 | Lloyd’s Register
Key: S≤0.10% ULSFO S≤0.50% VLSFO RM – Residual Marine Fuel (Ultra Low Sulphur Fuel Oil) (Very Low Sulphur Fuel Oil) DM – Distillate Marine Fuel Figure 4: Preparatory considerations for compliant fuel options 0.50 Jun - Dec (Loading 0.50%) Compliant Initial 0.50% bunkering plan Post 2020 operations Check supplier transparency of delivered fuel specs. Monitor machinery performance apply Final pre-bunkering voyage consumption calculations PDCA approach Treatment plant and FCU settings Maintain compatibility record across each First loadings and final flushing of fuel systems bunker/tank Machinery impact checks and actions Switch to 2020 compliant fuel Apply proactive management • Voyage calculations to ensure ship meets compliance date for 0.50% • Plan 1 January 2020 • Do • Check • Apply new pre-bunker & bunker procedures • Act • Fuel system performance checks • Check performance on each new bunker Sulphur 2020: What’s your plan? | 17
a. Preparing HSFO storage tanks However, these need to be applied figure 5 below illustrates the maximum to a number of bunker loadings remaining-on-board (ROB) in a The changeover procedure would before the deadline to enable particular tank that could be allowed if ideally be a gradual process whereby effective cleanliness to be loading a fuel oil with a sulphur tanks are emptied one by one, achieved. Full details should be content of 0.48% – for example at the checked, and thereafter refilled with sought after by the additive low end of the expected range for the 0.50% fuel oil. However, while this suppliers as to their suitability 0.50% max controlled fuel oils. could work for ships that are to for your intended purposes. drydock at some point approaching • Pipeline and system clean-up Hence, where the ROB has a sulphur 1 January 2020, it will, in reality, – dead ends/closed systems (i.e. content of 2.50%, the max quantity rarely be possible for such a stand-by heaters). Sufficient flush (by tonnage) relative to that loaded at controlled process to take place – through of compliant fuel will 0.48% sulphur would be a max of 1%, noting that some ships need to require at least one 0.50% bunker in order not to exceed the 0.50% limit. remain in service with the usual loading, if not two passing through However, that assumes uniform and reserve quantities. The following are the system before the complete mixing of the two, which a few points to consider in preparing implementation date. The will rarely be the case in such tanks: applications of cleaning additives instances; note that onboard fuel oil in the storage tanks may also inspections only need to draw a snap • Assign a ‘potential’ HSFO tank if facilitate this process. sample, and residual high sulphur 0.50% maximum sulphur content • Selection of engine system elements could adversely impact the fuel oil is not available then the lubricating oil and cylinder spot sample result. HSFO fuel oil supplied could be lubricating oils, where applicable, loaded to this assigned tank. should be evaluated in light of the Of course, where the ROB sulphur When assigning a tank, its size possible options of fuel oils being content is higher, the allowable ROB and internal structural members offered for use. ratio is that much lower – in this should be considered, fewer the • Isolated systems – including instance, under 0.7% by tonnage better to facilitate future cleaning. potentially those that are currently where the ROB is 3.50% sulphur. • Cleanliness of tank bottoms and distillate fuelled, noting that walls should be determined. Some distillate fuel supplied to date Also note that the above is based on additives are available on the outside ECA-SOx could have been 0.48% as loaded and that, as that markets that claim to avoid the above 0.50%. loaded value increases towards need for physical tank cleaning. 0.50%, the acceptable ROB is duly reduced – half that shown in figure 5 when the loaded value is 0.49% and, b. How much fuel can remain in the bottom of tanks before filling of course, zero where that is 0.50%. with 0.50% fuel? Hence, while tanks are unlikely to need to be wiped clean, they will Maximum ROB % – by tonnage – relative to 0.48% S fuel oil as loaded 4.0 need to be substantially emptied of 3.5 all previous content – noting the risk of blocked drainage holes through 3.0 ship structural members, allowing the retention in a tank of a significant quantity of ‘old’ fuel oil not detected 2.5 from tank soundings. 2.0 1.5 1.0 0.5 0.0 0.0 0.50 1.00 1.50 2.00 2.50 3.00 3.50 4.00 ROB Sulphur content % Figure 5 Blending ROB to 0.50% 18 | Lloyd’s Register
7. Summary: What ship – Handling and conditioning to 0.50% VLSFO and this may operators need to do now (correct purification setup) require tanks to be cleaned of the • Use correct auto-viscosity control remaining HSFO and any sludge on settings to ensure injection tank bottoms. • Ships will need to review their fuel viscosity is maintained within the • Installation of a designated fuel management strategy/plan to engine manufacturers and the fuel system sampling point in strategic include the management of the is not overheated. positions is recommended, as this expected diversity of fuel • Shipowners will need to consider would facilitate an inspector’s compositions, such as there being the cold flow properties in request to take samples in a safe sufficient tank storage options to accordance with ISO 8217:2017 manner. build in flexibility to avoid (for example sufficient heating commingling two or more different capabilities in both residual and The experience of using 0.10% ULSFO bunker fuels. distillate fuel tanks). for both residual-based and pure • Considering the expected variability • Shipowners should start a dialogue distillate operations will stand you in and unconventional blends coming with charterers and suppliers/ good stead for tackling the new 0.50% into the marine fuel market, the key traders with regards to the VLSFOs. It is recognised, however, that challenge will be for the ship’s crew transition period for starting the there are many thousands of ships to understand the possibility that switch to using 0.50% VLSFO, that have not yet truly experienced each bunker loaded will have which could be around October/ operations on much other than HSFOs different characteristics from the November 2019. and the occasional switch to distillates; previous bunkers, despite a similar • Ensure ships are already familiar this would suggest that the lessons ordering specification. This will with and experienced in using such learnt by some from the switch in 2015 require particular attention to: fuels before the deadline, with will have to be learnt by many more for – Storage requirements (cold flow regards to both technical and 2020. properties, compatibility and the operational implications. possible need for segregation • Consideration will need to be given between new and old bunkers) to preparing the tanks for the switch Figure 6 below outlines the key elements of the fuel management process and apply the PDCA management process: Preparing for 2020 – 0.50%, 0.10% with HSFO Best practice fuel management – raising the barriers Fuel system Fuel management Manage layout design procedures/systems compliance Sufficient bunker Crew 2020 preparation tanks awareness ends 31.12.19 Fleet 2020 implementation plan Segregation Scope of fuel spec. 0.50% Act Plan capability bunker clause scenario plan Sampling points Fuel storage plan Documentation/ compatibility and Check Do (IMO) segregation logs No. of Change Non availability fuel types over plan FONAR Auto viscosity control Routine fuel system The MARPOL - & change over audit programme sample Apply best practice fuel management approach Figure 6 Key Management considerations Sulphur 2020: What’s your plan? | 19
8. Other low sulphur fuel oils Converting existing ships to 9. How is LR supporting the currently in use alternative fuels such as LNG is efforts of the industry to work possible, and there is a lot of interest towards a consistent in this area in the North American a. LNG market. However, conversions are implementation of this expensive and technically Regulation 14.1.3? LNG is low in sulphur and easily challenging. Challenges include combusted in engines and boilers installing the fuel tank and LR is involved in a number of using mature and reliable containment systems, gas zoning technical working groups which technology. Gas engines are widely and engine conversion. address marine fuel quality and the used in land-based industry and implementation of this regulation, have been used in LNG carriers for b. Other alternative fuels these include: many years. The IMO has developed with zero sulphur content the IGF Code –which provides the 1. ISO TC28 SC4 WG6 for the ISO 8217 legal framework for operators and Other alternative fuels include LPG petroleum products – Fuels (class designers to work within. LR has and methanol. While LR currently F) – Specifications of marine fuels published class rules for gas-fuelled expects the use of LPG as a marine 2. CIMAC WG7 Marine Fuels – Engine ships. fuel to be limited to niche markets, builders forum (Cross industry such as LPG carriers using cargo to global representation of engine/ Wholesale LNG prices are generally provide fuel, it is expected that boiler and ancillary marine fuel lower than RFO prices, but a lack of methanol will establish a place in the system equipment) marine supply facilities means that market and we are already working 3. Active involvement within IMO’s LNG may be more expensive than on several methanol projects. MEPC and PPR committees and RFO once delivery costs are taken We have published provisional rules working groups to advise member into account. In some markets, LNG for methanol-fuelled ships and the states on the development of the prices are indexed to oil prices and IMO is working on incorporating 2020 implementation plan details can match them even before supply methanol into the draft IGF Code. of which will be address at the costs are added. ISWG in July 2018 for a final c. Further advice on submission of a guidelines to Known gas reserves have steadily alternative fuels MEPC 74 in April 2019 increased. The international energy 4. ESSF (European shipping agency data shows that they Given the particular technical sustainability forum) SG for air increased more than threefold challenges and complexity of emissions from ships between 1975 and 2010, and gas operating on fuels such as LNG and 5. ISO ISO/TC 28/SC 4/WG 17, prices have become very attractive methanol, this guide does not cover specifications of liquefied natural in some markets as a result of this them in detail. If you are interested in gas for marine applications abundance, particularly in North alternative fuels, contact your local 6. CIMAC WG 8 marine lubricants America. Where LNG supply LR group office for advice. We have 7. ESSF SG for exhaust gas cleaning infrastructure is in place, LNG is extensive experience in supporting systems (EGCS) expected to become very financially clients in adopting alternative fuels, 8. IACS our technical input to the attractive as a marine fuel in the and can provide a wide range of machinery panel to review the short – medium term. services including both classification recommendations of fuel system and consulting. design in the context 2020 20 | Lloyd’s Register
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