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 - Intercargo
Sulphur 2020:
What’s your plan?
Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation.
Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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
Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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.

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Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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
Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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

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Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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
Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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

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Sulphur 2020: What's your plan? - Guidance for shipowners and operators on MARPOL Annex VI Sulphur Regulation - Intercargo
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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