BUNKER FUEL REGULATIONS
Latest updates/status
&
an INTERTANKO VIEW
ERTC 15th Annual Meeting
Istanbul November 30, 2010
Dragos Rauta
INTERTANKO
INTERTANKO
International Association of Independent Tanker Owners
A non-governmental organization established in Oslo in 1970 to
represent the interests of independent tanker operators
at international, regional, national and local levels
260 Members
45 countries
3,100 tankers
250 million dwt
330 Associate Members
Spokesman – information service - meeting place
23 Secretariat
Oslo, London, Washington & Singapore
14 Committees and 5 Regional Panels
Bunker Sub-Committee (tanker operatos, IBIA, test labs)
REGULATIONS/STANDARDS
• IMO
– MARPOL ANNEX VI
– GREENHOUSE GAS EMISSIONS (GHG)
– SOLAS
• REGIONAL
– EU SULPHUR DIRECTIVE
– CALIFORNIA AIR RESOURCES BOARD
• ISO 8217:2010
IMO - MARPOL ANNEX VI
•
•
•
•
Limits SOx emissions
Includes PM (particulate maters)
Compliance through sulphur content in fuels
Alternative methodologies accepted as
Equivalent Measures
• Addresses marine fuel oil quality
• Recommends no measures on ships if supply
is not adequate
• Guidelines to asses compliance if BDN data is
challenged by PSC (or by lab test results)
SULPHUR LIMITS
IMO APPLICATION DATES
• IMO Global S limit (by weight)
– current
– 1 July 2012
– 1 January 2020/(2025)
4.5%
3.5%
0.5%
• IMO ECA S limits (by weight):
– up to 1 July 2010
– 1 July 2010
– 1 July 2015
1.5%
1.0%
0.1%
MARPOL ANNEX VI ECAs
62˚N
4˚W
ECA 1
ECA 2
57˚44.8’ N
5˚W
48˚30’N
MARPOL ANNEX VI ECAs
Entry into force 1 August 2012
ECA 3
200 nm
200 nm
Will Mexico join ?
Caribs?
REGIONAL REGULATIONS ON
BUNKERS
• EU SULPHUR DIRECTIVE
– as MARPOL Annex VI sulphur provisions
– additional provision: use of 0.10% sulphur content
fuel (or alternative) when ships ”at berth” (1 Janaury
2010)
– MGO/MDO on the EU market should have < 0.1% S
content (1 January 2010)
• CALIFORNIA AIR RESOURCE BOARD (CARB)
– use of marine distillates within 24nm off shore
– sulphur content in the marine distillates:
• current – MDO max. 0.50%; MGO max. 1.50%
• after 1 January 2012 - MDO/MGO max. 0.10%
CARB
MGO
2.5
MDO/MGO
MGO
MDO
0.5
EU
3
2
1.5
LSFO
SULPHUR CAP (%)
APPLICATION DATES & S Cap
4.5
1
IMO/Global
HFO
4
IMO/ECA
3.5
0
01
01
01
01
01
01
01
01
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
nu
Ja
y
ar
y
ar
y
ar
y
ar
y
ar
y
ar
y
ar
y
ar
24
20
22
20
20
20
18
20
16
20
14
20
12
20
10
20
MARPOL ANNEX VI
Regulation 4 – Equivalent measures
• An Administration may allow any fitting,
material, appliance or apparatus to be fitted in
a ship or other procedures, alternative fuel oils,
or compliance methods used as an alternative
to that required by this Annex if such methods
are at least as effective in terms of emissions
reductions as that required by this Annex
• This means the Administration (and not the
ship) have to acknowledge that:
– technologies have equivalent efficiency in terms of
SOx, PM and NOx.
– they do not harm the environment
– they operate within the requirements of the IMO
guidelines
MARPOL ANNEX VI
FUEL OIL AVAILABILITY
• IMO set up a correspondence group to
consider establishing a methodology to
determine the availability of fuel to comply with
the global sulphur limit in 2020
• Supply/demand models
• Consider
–
–
–
–
–
current experience with supply
new ECAs
shipping increased efficiency
use of alternative fuels, e.g. LNG
use of alternative technologies, e.g. scrubbers
GLOBAL BUNKERING
One - third of bunkers are supplied in ECA ports
USA 12.70%
Canada & Mexico
0.30%
Baltic Sea 3%
North Sea 18%
Rest of the World
66%
Marine distillates on EU must have < 0.10% sulphur content
Source: Poten & Partners
GREENHOUSE GAS EMISSIONS
•
Efficient Designs
•
Efficient Operations
•
Ship Energy Efficiency
Management Plan
•
Market Based
Mechanisms (MBMs)
EFFICIENT DESIGNS
Energy Efficiency Design Index (EEDI)
- require a minimum energy efficiency of new ships
- technical and design based measures only
ENVIRONMENTAL COST POWER x SFC
Attained EEDI 

 ENERGY SAVINGS
BENEFIT FOR SOCIETY Capacityx Vref
- Environmental
Cost: CO2 emissions
-Benefit: Cargo capacity transported
Attained index < Required index
EEDI REQUIRED - TANKERS
Required Index/ Phase 0 = no reduction (2013 & 2014)
EEDI
IMO impact analysis
Req. Index
Phase 1
2015 - 2019
10%
20%
Req. Index
Phase 2
2020 - 2024
30%
Req. Index
Phase 3
on and after 2025
DWT
SEEMP
Ship Energy Efficiency Management Plan
- operational and commercial measures
– Developed as a ship-specific plan by the
ship owner
– What the Plan should look like in four parts
1.Planning: Package of measures identified & Goal setting
2.Implementation: Implementation system
3.Monitoring: Monitoring system (tools and record keeping)
4.Self-evaluation & Improvement: Voluntary reporting
OPERATIONAL INITIATIVES
• INTERTANKO is
actively involved in
developing best
industry practice
together with other
stakeholders,
particularly
charterers, for a
better planning of the
voyage with the view
of reducing CO2
emissions.
GHG REGULATORY IMPACT
ON BUNKERS
• Less fuel consumption/tonne-mile
• Current suggestions for fuel efficiency
– savings > 10% by 2020
– savings > 30% by 2030
• Search for higher specific energy fuels
• Still an increase in demand of bunkers but
maybe slower than recent historical data
• Still fossil fuels but which type
CHALLENGES FOR SHIPS
• Switching between at least 3 grades of fuel
• Calling at EU/Californis ports, ships use:
–
–
–
–
•
•
•
•
•
Deep sea fuel (HFO)
ECA fuel (LSFO)
EU - ”at berth”/”at anchor” fuel (MGO)
California – MDO/MGO fuel
Onboard storage & segregation capacity
Increase risk of fuel incompatibility
Increases the risks of incidents
Viscosity, lubricity, flash point temperature
Need of closer monitoring of fuel quality
FUEL OIL QUALITY
MARPOL Annex VI - REGULATION 18
• blend of HC derived from petroleum refining
• free from inorganic acid
• should not include any substance or chemical
waste which:
– jeopardise ship safety and adversely affects
machinery
– is harmful to personnel
– contributes to overall addition to the air emissions
• Annex VI – Regulation 18 does not define
parameters for a fuel oil standard
• Annex VI – Regulation 18 requires MARPOL
sample & BDN guaranteeing fuel compliance
REPORTED PROBLEMS WITH
MARINE FUEL OILS
•
•
•
•
•
•
•
•
•
•
•
•
•
HIGH ABRASIVE FUELS
HIGH ASH
LOW FLASH POINT
HIGH SEDIMENTS
HIGH DENSITY
FUELS CONTAINING USED LUBE OILS
POLYETHYLENE CONTAMINATION
POLYSTYRENE CONTAMINATION
HIGH CALCIUM & HIGH SODIUM
HIGH WATER CONTENT
CONTAMINATED FUELS
INCOMPATIBILITY OF BLENDS
FATTY ACIDE METHYL ESTER (FAME)
FUEL QUALITY - BDN INFORMATION
•
•
•
•
•
•
•
•
Name and IMO Number of receiving ship
Port
Date of commencement of delivery
Name, address, & tel. number of marine fuel oil supplier
Product name
Quantity in metric tons
Density at 15°C, kg/m3
Sulphur content (%m/m)
• A declaration signed and certified by the fuel oil supplier’s
representative that the fuel oil supplied is in conformity
with the applicable subparagraph of regulation 14.1 or
14.4 and regulation 18.3 of this Annex.
HOW IS THIS ASCERTAINED?
ACTUAL or TYPICAL VALUES?
ISO 8217:2010 TO PLAY A ROLE? WHO CONTROLS?
ISO 8217:2010
• New grade DMZ (as DMA grade but
minimum viscosity @ 3 cSt)
• DMA grade minimum viscosity @ 2 cSt
• Previous DMC grade has been re-defined
as residual fuel (RMA grade)
• Additional criteria and specifications for:
–
–
–
–
hydrogen sulphide (H2S)
acid number
oxydation stability
lubricity
ISO 8217:2010
•
•
•
•
Sulphur limits related to MARPOL Annex VI
Values for ash reduced
Value for Al + Si reduced
New informative Annexes on:
– bio-derived products
– deleterious materials
– hydrogen sulphide
• Positive development but . . .
• ISO 8217 is not referred to in MARPOL
• Could some criteria be used in the BDN?
IMO/ISO AGREED “APPROPRITAE
PARAMETERS”
• “Appropriate parameters considered by ISO to
be pertinent to fuel oil quality with respect to
air quality, ship safety, crew health and engine
performance”
• Density at 15ºC
• Kinematic Viscosity
• Vanadium
• Al + Si
• Cetane Index
• Ignition Quality (CCAI)
• Fuel Stability
• Flash Point - minimum value required under
SOLAS II-2, regulation. 4. 2.1.1
IMO/ISO AGREED “APPROPRITAE
PARAMETERS” (cont)
•
•
•
•
•
•
•
•
•
•
•
•
“Appropriate parameters considered by ISO to be pertinent to fuel oil
quality with respect to air quality, ship safety, crew health and engine
performance”
Pour Point
Water
Sodium
Acid Number
Lubricity HFRR
Micro Carbon Residue
Ash
Sulphur - maximum value required under MARPOL, Annex VI, regulation 14
Appearance (for transparent fuels)
Used lubricating oil (ULO) - free of such elements as required by MARPOL
Annex VI, regulation 18
– Zinc
– Phosphorus
– Calcium
Hydrogen Sulphide - value required to be given by SOLAS/MSDS
MEASURES TO CONTROL FUEL
QUALITY
• Stricter enforcement of Reg. 18 of MARPOL
Annex VI:
– Port Authorities keep registries of local recognised
bunker suppliers; make these available for publication
on the IMO web site
– Port Authorities to report the results of investigations &
eventual follow-up actions in response to any Note of
non-compliant fuel delivered in their jurisdiction
– Port Authorities should consider not allowing fuel
blending during delivery to ship (Singapore MPA already
forbids onboard barge blending)
– Singapore MPA Code of Practice for Bunkering
(SS600:2008) and Quality Management for Bunker
Supply Chain (SS524:2006) are excellent examples
MEASURES TO CONTROL FUEL
QUALITY
• Improvements to MARPOL Annex VI:
– Include in the BDN a number of “appropriate
parameters” jointly recognised by the IMO and
ISO as pertaining to seafarers' health, safety of
the ship and air emissions
– Port Authorities to set up a system monitoring
compliance of bunkers delivered to ships
– Consider the safety and environmental
improvements if residual fuels would be treated
(i.e. purification) prior to delivery to ships
Thank you
For more information, please visit:
www.intertanko.com
London, Oslo. Washington and Singapore
N AMERICAN ECA - COST IMPACT*
• Extra costs of a VLCC (2 m bbls) for a
round trip of 400 nm :
Premium MGO
$200/t
$500/t
Extra cost
$40,000
$100,000
(%)
0.8%
2.0%
• Apparently US and Canada will have
minimal problems to ensure supply
* Poten Fuel Oil Monthly Opinion, 6 April 2010