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Monday, October 22, 2018

Ship owners urged to take heed of EU sulphur implications

The daily lives of ship operators both afloat and ashore will be enlivened by the complications lying in store when complying with the variety of IMO and EU regulations on SOx emissions. Tom Visser, Technical Adviser at DNV Petroleum Services, draws the industry's attention to this fact in an article in Lloyd's List of 19 December (click here to view), in which observing the limits on maximum sulphur content in marine fuels is shown to have become an increasingly complex game – a game whose broad reach and serious nature is now really sinking in to industry minds, and whose rules are far more taxing to understand than those of Bridge or Monopoly.


The EU rules that were implemented in August this year depend on the type of ship, on exactly which region the ship is trading in, on precisely what sort of fuel the ship is burning, on whether or not the ship is in port. It is the responsibility of the ship to get this right. Making this point, though referring in particular to the lowering of the sulphur content of marine gasoils to 0.1% from 1 January 2010, Visser warns that "ship owners should realise the implications on the tank capacities, piping design, engine and in-port boiler operation of their existing vessels. Similar consideration should also be given to the specifications of newbuildings to avoid costly modifications".


In addition to the regulations addressed in this article, ships calling in California in the U.S. will have a different set of SOx regulations to comply with. The California Air Resource Board's succinctly titled "Regulations to Reduce Emissions from Auxiliary Diesel Engines and Diesel-Electric Engines Operated on Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline" will apply from 1 January 2007 and come in two virtually identical versions - the Title 13 version related to mobile sources and fuels, and the Title 17 version coming under the toxic air contaminants regime.


And it would appear that this is just the beginning. The U.S. Environmental Protection Agency (EPA) recently confirmed that "(its) feasibility study for a SECA (sulphur emissions control area) will be completed by the middle of 2007".


But this is only sulphur control. There are also carbon dioxide, nitrous oxides and particulates emissions to control. If this is really just the beginning of a spawning of regional requirements for emissions control, we should take good note that while these differing demands may prove increasingly difficult to comply with as they proliferate, yet ship operators will still carry the main burden of, and may be held liable for, compliance.


It is the ship operator who must ascertain fuel quality before it is pumped into his ship. It is also the ship operator who, in the case of residual fuels, must heat, centrifuge and store the fuel correctly and maintain it ready to burn. It is also the ship operator who will be responsible for purchasing, installing and operating the scrubbers that will take out impurities from the exhaust gases. The ship operator is responsible for the disposal of sludge and impurities taken out of the fuel before use, and will be responsible for the disposal of toxic residues from scrubbers.


Ironically, lowering the sulphur content of residual fuel is no guarantee of quality. Indeed the converse may be true. Our London office recently welcomed a number of young tanker officers. One of their major concerns was the quality of residual fuel bunker fuels that they have to use, sometimes having no option but to burn poor quality fuel in the engines and boilers of the ship of which they are so proud. Their concern centres on residual fuels containing what amounts to "industrial waste" (including catalytic fines), which, they believe, can make the lower viscosity 180 centistoke fuels a "dodgier prospect" than the higher viscosity 380 centistoke alternatives.


Visser shows his concerns over fuel quality when he writes, "We also suspect that increased blending activities to meet the demand for low sulphur products may compromise overall fuel quality, especially if the cutter stocks are not screened".


The future is unclear, with price and availability of low sulphur residual and distillate fuels uncertain, and with the scope of international and regional regulation (and their relationship with each other) as yet only partly defined. What is clear is that life for the ship operator ashore and afloat is getting increasingly complicated and burdensome when it comes to voyage planning and the purchase and consumption of marine fuels.


Contact: Bill Box