From a point of view of loss prevention, we have taken into account practical issues already being experienced in the management of low Sulphur fuel, and the organizations experiences based on cases that have already occurred in the short period since the implementation of the IMO 2020 Fuel Oil Sulphur cap (Since 2020 Jan).
Irrespective of the objectives intended to be achieved through the implementation of the IMO 2020 Sulphur Cap, there is no denying that this has caused considerable issues arising out of potential contractual responsibilities and liabilities in respect of compliance, between the Ship-owners and its charterers.
It is quite clear that there are two principal methods of compliance with Sulphur Cap – the use of compliant fuel, eg LSFO with a Sulphur content which does not exceed 0.50% m/m, or alternative technology using high sulfur fuel (with a Sulphur cap of 3.5%. This high Sulphur fuel will have to employ an exhaust gas cleaning system (EGCS), commonly known as a scrubber.
Having said that there are still “grey” areas and considerations
on the impact of the low Sulphur cap especially in view of either
existing or future charter parties, with special reference to those
that were in force prior and will be carried over post low Sulphur
cap compliance date.
In the context of the concerns about the impact of new (untested)
blends and hybrid compliant fuels on the vessel's main engine, it
is still unclear whether the charterers would be directly responsible
if the vessel suffers engine damage, and this is many times construed
as a “comfort blanket” by the owners.
In a recent case handled by Constellation Marine Services Engineer
surveyors, it was found that owners had put the blame on the vessels
extensive engine damage, loss of time and slow steaming squarely
on the charterers supplied VLSFO.
This was particularly tricky in view that both the parcels of VLSO
supplied to the vessel were seen compliant in all aspects when tested.
It was thus left to our attending surveyor to carry out a factual
and technical enquiry into whether the vessel's main engine (including
her fuel system) was in a satisfactory state to receive, store and
burn the fuel in the first place.
Notwithstanding the outcome of this investigation, it is important
to highlight that even despite best efforts by fuel manufacturers
and suppliers, technical problems brought about by certain characteristics
of the new fuel oil are likely to be more frequent and more far
reaching.
It is therefore of utmost importance for ship owners (and to an
extent charterers) to be able to identify the concerns associated
with VLSFO and have technical capabilities of the vessels Fuel management
systems verified prior to the use of this fuel. (Most engine manufacturers
have instructions in place for ships engineers to follow).
The below is intended to serve as an aid memoire extracted from our technical experience in investigating fuel management issues that have occurred so far:
PURIFIERS
Purifiers are an important defense against contaminated fuel It
is therefore thought prudent to consider evaluating the condition
of the onboard purifiers more thoroughly through inspection by the
maker or its authorized dealer.
The use of portable cat fine testers may be worth evaluating since
this will assist the ship crew in keeping a closer eye on this parameter
in addition to purifier samples normally tested in the laboratory.
Installation of an in-line monitoring system for cat fines may be
another option worth exploring.
With the changes in the type of fuel use, the importance of record
keeping is of paramount. Importance factors, related to the purifier
operational condition such as fuel specific density and the size
of the gravity disc used, set time of sludge discharge, the flow
rate, inlet temperature, etc. may help prove that the purifiers
were operated properly.
FILTERING EQUIPMENT
Strainers, filters and other similar equipment fitted as a part
of a fuel treatment installation on board may require extra attention
in case of stability or compatibility issues. The use of a 10 μm
filter elements serving auxiliary engines as well as the main engines
should be considered. Installation of a finer than standard 10 μm
filter mesh may be considered after consultation with engine maker.
ENGINES
It is widely accepted that engine performance and power output depend
on a number of fuel qualities such as energy content, ignition quality
and combustion properties.
While the quality of fuel and its properties cannot be changed by
on board treatment, crew should nevertheless observe closely and
record any adverse effect on engine operation, e.g. knocking, increased
smoke emission, starting problems, unstable shaft revolutions and
etc.
Lubricity of low Sulphur fuel has been identified as another possible
issue. Sulphur is stated to be one of the elements that contribute
to fuel lubricity, lack of which in VLSFO and VLSFO may lead to
premature wear of the rubbing components. Therefore, greater emphasis
and frequency of used lube oil testing should be performed to provide
an early indication of mechanical wear.
FUEL SULPHUR CONTENT ISSUES
Taking on board fuel that later exceeds the requirements of the
IMO Sulphur cap poses greater issues, not only in its management
but also port state fines especially within Northern Europe coastal
states and USA.
Therefore, it is worth considering purchase of a portable fuel Sulphur
content analyzer in order to be able to quickly check Sulphur content
prior to the bunkering.
TANK AND SLUDGE PRODUCTION
Since IMO 2020 compliant fuel contains considerably less Sulphur
than residual fuels, it can easily be contaminated if it is bunkered
into tanks where there are remnants of high Sulphur fuel.
Apart from this issue, loading low Sulphur fuel into uncleaned
tanks may also cause technical difficulties, and as per IMO MEPC.1/Circ.878.,
If such fuels are loaded into HSFO fuel tanks that have not been
cleaned, there is a possibility that they could dissolve and dislodge
sediments and asphaltic sludge in storage tanks, settling tanks
and pipelines, potentially leading to purifier and filter operational
issues and in extreme cases fuel starvation resulting in loss of
power.
Thus In order to avoid accidental non-compliance and machinery problems
it is advisable to clean bunker tanks and settling service tank
from settled and adhering layers of old fuel.
It should be noted that regardless of the tank cleaning method,
fuel piping and other elements of relevant systems, such as fuel
filters and fuel heat exchangers, will inevitably have to be flushed
with compliant fuel for several days in order to ensure full compliance.
In the case of manual cleaning it may be useful in engaging an external
surveyor to verify cleanliness.
Contrary to common perception, given that there is an increased
likelihood of incompatibility and instability of fuels compliant
with IMO 2020 Sulphur Cap, an increased sludge production has to
be considered as an aspect of normal vessel’s normal operation.
Fuel tanks may require more frequent bottom draining, additional
purification cycles and purifier sludge discharge at shorter intervals
will unavoidably translate into greater amount of overall sludge
generated.
The importance of documenting all aspects of tank cleaning process
cannot be overemphasized; logs and other documentary evidence may
be required to protect ship owner’s position in case of any dispute
related to fuel Sulphur content and preparation for implementation
of new regulation.
ENFORCEMENT
Broadly speaking the signatory countries to MARPOL Annex VI are
free to decide how they enforce the regulation and how non-compliance
will be penalized.
This is tricky, since how non-compliance is dealt with will be wholly
dependent on the jurisdiction. The usual methods include vessel
detention (with the threat of banning orders for repeat offenders)
and financial penalties. The level of financial penalty is likely
to vary significantly across the globe and may escalate with repeated
violations.
It should also be borne in mind that traditional fuel sampling
methods must now be in compliance with the new 2019 Guidelines for
on board sampling for the verification of the Sulphur content of
the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1). In essence
there will now be 3 samples to consider:
• The MARPOL delivered sample taken at time of bunkering (recommended
to be drawn from the receiving vessel’s manifold).
• The in-use sample which is drawn as close as possible to the engine
inlet.
• The not in-use onboard sample which is representative of the contents
of a vessel’s storage tank.
In this case, we have seen instances where the in-use sample
was drawn from the bottom of a filter pot or a dead leg in the system.
It is questionable how representative these samples are of the fuel
in use and this practice should be avoided.
It is also understood that for enforcement requirements, guidelines
for drawing representative samples for the actual fuel in use has
yet to be developed by the IMO. Ship owners are advised to be prepared
to challenge Port state control officers if they feel the sampling
method adopted for enforcement isn’t representative of the fuel
in use.
However it is of paramount importance that documentation relating to VLSFO be recorded and maintained to the highest level; if the Port state control officers have “clear grounds” to escalate to a more detailed enforcement inspection, they are then most likely to carry out in-depth documentation checks, maintenance verification and fuel sampling/analysis, as well as assessing crew familiarity with the system and equipment.
About the Authors:
Capt. Vispy Rusi Dadimaster
A career spanning 22+ years in various operation and management
positions within the Maritime and Shipping Industry, including 8+
years in Fujairah (Port Operation, Agency and Logistic Management),
and in command of various types of vessels, including Offshore Dynamic
Positioning crafts. Within the professional roles held, I have proven
to be result oriented, decisive, possess tremendous interpersonal
skills, and am technically oriented My entrepreneurship skills have
enabled me to lead and managed teams up to 25 people successfully,
achieving challenging objectives, within challenging environments,
with an aim to create a positive outcome and impact.
Chief Engineer Ramesh Krishnan An extensively experienced maintenance engineering professional onboard merchant ships, on global as well as coastal voyage ships.