Jan 022010

If the California experience is anything to go by we can expect to see propulsion failures on the increase as Council Directive 2005/33/EC comes in to force. It mandates that ships may only use fuel oil with less than 0.1 per cent sulphur – brimstone to bible thumpers – while in EU ports and exceptions are few and far between.

Following a failed attempt by Pacific Merchant Shipping Association to bar the California Air Resources Board from imposing similar restrictions in mid-2009 some 15 maritime casualties were linked to propulsion failures when switching to low sulphur fuels. As a result, the US Coast Guard issued a safety alert on the issue.

Although the industry has been aware of the directive since 2005 it is likely that similar incidents will occur in EU waters for the same reason. Many ships are fitted with boilers designed to burn Heavy or Intermediate Fuel Oil, but ultra-low sulphur grades of such fuels may not be widely available. In most cases, class approved modifications would enable the boiler to switch between HFO / IFO and the much more widely available ultra-low sulphur grades of distillate fuel. The importance of a class approved conversion is emphasised by industry concerns that an attempt to burn a distillate fuel in an unmodified boiler could create the risk of a furnace explosion.

There will be no exemption to compliance but EU member states “may consider the existence of an approved retrofit plan when assessing the degree of penalties to be applied to non-complying ships.” That may be based on documentary evidence that there is a realistic and achievable plan in place to achieve compliance.

Says International Chamber of Shipping, ICS: “Such evidence may include information received from boiler manufacturers, or conversion contractors on the equipment required, its availability and a timescale to complete the work. Class society letters are also likely to be helpful.” ICS has published guidance on the issue.

Here’s the EU FAQ:

EU Questions and Answers

On the use of fuel containing not more than 0.1% sulphur in ships while at berth

Q: Which are the relevant articles of the Directive 1999/32/EC related to the use of 0.1% sulphur fuel at berth?

A: The relevant articles are:

Article 2

Definitions: for the purpose of this Directive:
3i. ships at berth means ships which are securely moored or anchored in a Community port while they are loading, unloading or hotelling, including the time spent when not engaged in cargo operations;

Article 4b

Maximum sulphur content of marine fuels used by ships at berth in Community ports
1. With effect from 1 January 2010, Member States shall take all necessary measures to
ensure that the following vessels do not use marine fuels with a sulphur content exceeding 0.1 % by mass:
(b) ships at berth in Community ports, allowing sufficient time for the crew to complete any necessary fuel-changeover operation as soon as possible after arrival at berth and as late as possible before departure.

Member States shall require the time of any fuel-changeover operation to be recorded in ships’  logbooks.

2. Paragraph 1 shall not apply:
(a) whenever, according to published timetables, ships are due to be at berth for less than two hours;
(c) until 1 January 2012 for the vessels listed in the Annex and operating exclusively within the territory of the Hellenic Republic;
(d) to ships which switch off all engines and use shore-side electricity while at berth in ports.

3. With effect from 1 January 2010, Member States shall ensure that marine gas oils are
not placed on the market in their territory if the sulphur content of those marine gas oils exceeds 0.1 % by mass.

Q: When does the requirement to use fuel not exceeding 0.1% sulphur enter into effect? Can it be postponed?

A: This requirement enters into effect as of 1 January 2010 for ships visiting a Community port. The Directive does not allow for delay, nor for exemptions other than those already included and therefore it cannot be postponed.

Q: Is a ship exempted in case the changeover of fuel is unsafe because the necessary
modifications to the ship (or ships boiler) have not yet been implemented?

A: No. The obligation for ships to use 0.1% sulphur content in fuel while at berth is the
requirement of Directive 2005/33/EC (amending Directive 1999/32/EC) which was already  published in 2005.

The time that has been available to prepare does not justify such claim for exemption based on alleged emergency situations.

Q: In which ports does the requirement to use fuel not exceeding 0.1% sulphur apply?

A: This requirement applies in all Community ports, including inland ports, but excepts ports in the French oversees departments, the Azores, Madeira and the Canary Islands.
Q: The ship is entering in a Community port or manoeuvring inside the port. Does this ship have the obligation to use fuel not exceeding 0.1% sulphur?

A: No, this fuel requirement only applies on ships at berth, meaning securely moored or anchored in a port.

Q: If a ship already has marine gas oil on board, exceeding 0.1% sulphur, can it continue using this fuel after 31 December 2009, until it needs to refuel?

A: No. As of 1 January 2010 only fuel not exceeding 0.1% sulphur can be used. It is not
allowed to burn non-compliant fuel, even if that fuel was bunkered before the date of entry into force.

Q: At which moment does a ship has to changeover fuel?

A: The requirement applies on ships at berth, meaning as from the moment when the ship is securely moored or has anchored in port. But the Directives give a margin of sufficient time for the crew to complete the necessary fuel-changeover operations as soon as possible after arrival at berth. The changeover of fuel has to be done in all engines and boilers onboard the ship which are kept running while at berth.

Q: What if the ship intends to stay at berth for less than two hours?

A: Only ships operating on a published timetable AND staying in a port for less than two hours are exempt. Other ships, regardless of total time foreseen to stay at berth, shall comply with the fuel obligation and start fuel-changeover when at berth, meaning as soon as possible after being securely moored at berth or at anchor in the port.

Q: If a ship is anchored outside the port, does it have to use 0.1% sulphur fuel?

A: No. The requirement only applies to ships at berth, meaning securely moored or anchored in a Community port.

Q: What should be considered as “port” and when is a ship outside of a port?

A: Directive 1999/32/EC does not contain a definition of port area. Article 11 of the UN
Convention on the Law of the Sea, UNCLOS, does define ports as:

For the purpose of delimiting the territorial sea, the outermost permanent harbour works which form an integral part of the harbour system are regarded as forming part of the coast.

Off-shore installations and artificial islands shall not be considered as permanent harbour works.

However, as the delimitations (area) of the port is established by the Competent Authority in each single Member State and not by the Directive, any further consultation should be done with the respective authorities.

Q: Can LNG-carriers comply with the standard while burning a mixture of boil off gas
and heavy fuel oil?

A: The current text of the Directive does specify that no use of fuel containing more than 0.1% sulphur is allowed. However, as an alternative to using this low sulphur fuel, Member States may allow ships to use an approved emission abatement technology. The Commission is of the opinion that the technology to use both LNG and HFO does constitute such equivalent, provided that the mixture is such that the resulting emissions of sulphur dioxide are equal to or lower than when only burning 0.1% sulphur fuel. The Commission therefore intends to propose to Member States to allow for this equivalent. The Member States will decide on this matter in a designated Committee, which will be called together at the earliest convenience.

Q: If a ship has made arrangements to install the necessary modifications to its boilers
before it is able to switchover fuel safely but the modifications are not yet implemented, is it allowed to continue using HFO at berth exceeding 0.1% sulphur in the meantime?

A: No, the Directive has no exemptions. However, the Commission intends to publish a Recommendation which will be aimed at the Member States and will invite them while
enforcing the Directive, to request those ships which fail to comply with the Directive to provide detailed evidence of steps taken for arrangements to install the necessary
modifications, including the approval by a Recognized Organization or Class. The Member States may consider the existence of an approved retrofit plan when assessing the degree of penalties to be applied to non-complying ships.

Q: When does the requirement to use fuel with a sulphur content not exceeding 0.1%
sulphur end?

A: This requirement continues to apply while the ship is at berth or at anchor until as late as possible before departure, when it is allowed to start fuel changeover to be ready for departure.

Q: Does the requirement to use fuel with a sulphur content not exceeding 0.1% still
apply to a ship which has left berth or anchorage but is still sailing in the port area?

A: No. The requirement does not apply to ships manoeuvring or on their way to enter or leave the port.

The following points are reiterated to owners and operators:

  • Boiler and fuel system manufacturers should be consulted for fuel switching guidance and to confirm that the boiler, combustion control systems and associated fuel system components, such as pumps, are suitable for the intended types of fuel.
  • The furnace purge process must be functioning correctly. It is essential that the whole of the furnace space is fully purged before re-lighting any fires.
  • Burners, in general, and tips, in particular, must be appropriate to each type of fuel to be used.
  • The spark igniters (or equivalent) must be correctly functioning and positioned so as to readily ignite the fuel spray on start up.
  • All boiler flame detection and related safety systems must be operating correctly. In the case of flame detectors, they must be correctly positioned to pick out the particular flame pattern which is encountered with the types of fuel to be used.
  • Manual and automated combustion control system functions should be checked as necessary to ensure they are operating correctly and reliably.
  • Due to their searching nature, the use of gas oil fuels in systems which have generally previously operated with HFO can result in seepage of fuel from pipe flanges, equipment seams and other fittings.
  • To ensure the minimum quantity of carbon deposition material within the combustion and uptake spaces, soot blowers should be operated at the latest possible opportunity before entry into coastal and port waters.
  • The boilers, burner and fuel oil system, including the relevant automatic controls, should be reviewed by means of a HAZOP workshop, through which the action points for the operators and manufacturers can be identified.
  • Oil fuel burning arrangements must be in accordance with the Rules of the relevant classification society.

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