Ultra Low Sulfur Fuel Oil & Compliance with MARPOL

[I][B]From the USCG:[/B][/I]

[B]RequirementsBefore entering and while operating within Emission Control Areas
This safety alert is a reminder to vessel owners and operators about the importance of establishingeffective fuel oil changeover procedures to comply with MARPOL Annex VI emission regulations.

Recently, there have been several reported incidents involving substantial machinery space fuelleakages while vessels were switching fuel oil to ensure compliance. Although such leakageswere contained, fuel releases of any kind may result in pollution, injury or death of personnel andshipboard engine room fires. Moreover, many losses of propulsion have occurred in different portsand have been associated with changeover processes and procedures.

On January 1, 2015, the new fuel oil sulfur limit authorized by MARPOL Annex VI, Regulation14.3.4 came into effect, lowering fuel sulfur content from 1.0% to 0.10%.1 The 0.10% fuel sulfurcontent must be used the entire time the vessel is operating in the North American and U.S.Caribbean Sea Emission Control Areas (ECA).

As a result, vessels using higher sulfur contentfuels must change to ultra low sulfur (ULS) fuel oil to comply.

The vessels must use the ULS fueloil on inbound and outbound transits, at the dock, and anytime within the ECA.

Meeting thisrequirement requires planning and analysis before any changeover from higher sulfur content fueloil to ECA compliant fuel oil and vice-versa.

Each ship which uses higher sulfur content fuel oil isrequired to develop and implement changeover procedures for switching between residual anddistillate fuels in accordance with MARPOL Annex VI, Regulation 14.6.In some cases vessels may require fuel oil service or day tank modifications and fuel oil servicepiping modifications to facilitate safe procedures and compliant fuel operations within the ECAs.

The management and oversight of any fuel oil mixing that may be part of a changeover processincluding, proper control and reduction of the operating temperature of fuel supplied, varying ratiosof the mixed fuels and control of mixed fuel viscosity to the engines must take place before thevessel enters the ECAs or after the vessel leaves the ECAs.

The amounts of ULS fuel oil onboardmust be enough to satisfy the vessel’s fuel demand at all times while the vessel operates within theECAs or efforts should be made to take on additional ULSF while in port. There are many other important technical issues associated with the use of ultra low sulfur fuel oilsand fuel oil switching addressed in documents produced by class societies, insurers, enginemanufacturers and industry associations.
The Coast Guard strongly recommends that vessel owners and operators:[/U]
• Ensure fuel oil switching is accomplished outside of busy traffic lanes and the ECA.Generally the ECA is 200 nm from the North American Coast and 50 miles from the U.S.Caribbean coast (e.g., the Commonwealth of Puerto Rico and the U.S. Virgin Islands);

• Utilize their technical resources to develop safe operations and maintain full compliance withemission requirements;

• Consult with engine and boiler manufacturers for fuel oil changeover guidance and todetermine if system modifications or additional safeguards are necessary;

• Consult fuel suppliers for proper fuel selection;• Ensure all sensors, controls and alarms – pressure, temperature, viscosity, differentialpressure, flow indicators, etc., are operational and function as designed;

• Ensure system piping, seals, gaskets, flanges, fittings, brackets, etc., are maintained.

• Ensure detailed system schematics are available;

• Review and update fuel oil changeover procedures as needed;

• Establish a fuel oil system inspection and maintenance schedule;• Review and update fuel changeover procedures based on lessons learned;

• Provide initial and periodic crew training for accomplishing safe, effective and leak-free fuelswitching;

• Remember that the energy content of a given volume of ULS fuel oil may differ from residualfuel, such that existing throttle settings may not give the desired propeller shaft RPM orgenerator loads and performance/speed trials on ULS fuel oil may need to be conductedand;

• Anticipate that there may be many technical challenges for operators when beginning to useULS fuel oil as a matter of routine and compliance. These range from excessive leakagesof fuel system components, increased wear and tear on these components, lack of lubricityof the fuels and the need for possible changes in maintenance schedules, operationalmethods, etc.

The links below provide additional information on these topics.

This Safety Alert is provided for informational purposes only and does not relieve any domestic orinternational safety, operational or material requirement. Questions regarding this should beforwarded to the Coast Guard Office of Commercial Vessel Compliance, Foreign and OffshoreVessel Division (CG-CVC-2) at 202-372-1218 or by email at CGCVC@uscg.mil.

Note: The Coast Guard has collected the following links from open internet sources and repostedthem for informational purposes only. Their inclusion here is not an endorsement orexpression of preference of any kind towards any specific publication or organization.

MAN B&W Operation on Low Sulfur Fuels

Wartsila Low Sulfur Fuel Guidelines

Steamship Mutual – Risk Alert: ECAs Low Sulfur Fuel Oil Changeover Procedures

International Council on Combustion Engines - Guidelines for the Operation ofMarine Engines on Low Sulfur Fuel

ABS Fuel Switching Advisory Notice

IMO has a 7-point strategy plan for carbon emission from ships: http://www.seanews.com.tr/uns-imo-has-7-point-strategy-to-kill-carbon-in-world-shipping/167780/

Do big business have too much influence at IMO:

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Shipping world fighting back:

This Andrew Craig-Bennet is spitting some fire.

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