For readers familiar with shipping on the West coast of the U.S. and Europe, then you are familiar with the reason driving ABS to develop guidance and requirements for its ship operators regarding the use of low-sulphur feuls.
Essentially two major regulations in two different countries/regions have forced global ship operators, regulators, and engineers to determine how to comply with requirements to burn low-sulphur fuels in engines designed solely to burn the cheapest, lowest quality fuel available on the market. To simplify things, all of the bad things in the heavy fuel oil are needed to help lubricate and burn properly in the large engines. Imagine designing something to run on hot maple syrup, and then making it run on water. That’s not too far from the truth with regards to the viscosity.
The following are the primary regulations driving the shift to low-sulphur fuels:
(1) Article 4b of “EU COUNCIL DIRECTIVE 1999/32/EC of 26 April 1999 relating to a reduction in the sulphur content of certain liquid fuels and amending Directive 93/12/EEC”, as amended, introduces 0.1% sulphur limit (m/m) for marine fuel.
a. Effective Date: January 1, 2010.
b. Applies to: All types of marine fuel used by ships at berth for more than two hours in EU ports, unless an approved emission abatement technology is employed or shore power is available.
(2) California Air Resources Board (CARB)
a. Effective Dates:
Phase I (in force) since July 1, 2009 [MGO (ISO 8217, DMA Grade) at or below 1.5%S or MDO (ISO 8217, DMB Grade) at or below 0.5%S]
Phase II – January 1, 2012 [MGO (ISO 8217, DMA Grade) or MDO (ISO 8217, DMB Grade) at or below 0.1%S]
b. Applies to: All types of marine fuel used by ships within California Waters (within 24NM of the California Baseline).
[Note: MGO = Marine Gas Oil; MDO = Marine Diesel Oil]
Please be advised that all engines and boilers(**) are affected by the above Regulations and it will be mandatory to operate the engines and boilers on the low-sulphur marine fuel with the sulphur content and effective dates as indicated in the respective Regulations noted above.
[Note: (**) = As for boilers, the EU Directive applies to main and auxiliary boilers, while the CARB Regulations apply to only the auxiliary boilers i.e., non-propulsion]
As a result of the above, ABS has issued a set of requirements to owners of vessels classed under ABS.
We require each owner/operator conduct a design evaluation of each ship for low sulphur fuel operation by systematically assessing the related systems taking into consideration (but not to be limited to) these identified potential risks in the ABS Notes as applicable to the specific systems and take necessary actions, as appropriate, to establish safeguards.
Owners and operators are reminded that all modifications to engines, boilers and associated fuel oil piping and control systems, together with the results of the above mentioned design evaluation, are required to be submitted to ABS for approval so that that class and statutory certification can be maintained. Where the owner is satisfied that modifications to the vessels’ installed equipment and systems are not required, it is recommended that the results of the design evaluation that has been conducted be maintained on board.
In all cases it is expected that operating procedures, including guidance for switching between fuel types, will be provided onboard by owners/operators. As this is a safety issue, availability of the proper operating guidance may be verified during ISM audits.
Regarding Survey, ABS is prepared to issue a Statement of Fact (SOF) Certificate(s) as follows:
(1) ABS Surveyor will verify fitting of and report on the following:
a. The vessel is fitted with dedicated low sulphur fuel oil storage tank(s) with a capacity of xx m3 fitted between fr. and fr. port/starboard side.
b. The fuel oil piping system is arranged to allow main engine(s), auxiliary engines, and boiler(s) to operate on low-sulphur fuel.
c. The structure, piping and control systems are in accordance with ABS approved drawings. (dwg. no., rev. 0, ddmmyyyy)
d. Operational procedures for fuel-change-over are provided on board the vessel. (doc. no., rev. 0, ddmmyyyy)
e. Operating procedures for using low sulphur fuel in engines and boilers are provided on board the vessel. (doc. no., rev. 0, ddmmyyyy)
(2) For vessels equipped to operate in a cold iron condition in port through the shore-power connection installation, the Surveyor will verify and report that “The vessel is arranged with a shore-power system as per drawing no., rev., dated.”
(3) Issuance of a Statement of Fact for the installation of exhaust gas scrubber / emission abatement technologies will be considered on a case by case basis, with details to be submitted to an ABS engineering review office for review prior to surveyor issuance of the statement of fact report. The Statement of Fact will report on what the Surveyor has surveyed.
Questions regarding engineering submittal requirements should be submitted to the ABS Divisional Engineering Office. Divisional Survey Offices may be contacted for questions pertaining to Survey. Click here to locate the closest appropriate office from the ABS Directory.