Leading the way; making a difference AIR EMISSIONS LATIN AMERICAN PANEL Buenos Aires 5th November...

Leading the way; making a difference

AIR EMISSIONS

LATIN AMERICAN PANEL

Buenos Aires5th November 2014

Dragos Rauta INTERTANKO


• Globally(emissions from fuel with max. x% sulphur content) – Currently – 3.50%– After Jan 1, 2020 (or 2025) – 0.50%

• ECA (Baltic Sea, North Sea, NA & Caribbean)– Currently – 1.00%– After Jan 1, 2015 – 0.10%

• European Union Sulphur DirectiveFollows IMO except:– Currently – 0.10% “at berth”– After Jan 1, 2020 – 0.50% in EU waters (?)

• California - 0.10% (24 miles)

SOx Emissions Limits


• LS MGO expected to be available

• Possible local shortage during initial phase-in period

• Expected hikes on price in earlier stages

• Premium expected to keep constant at $250 - $350 / ton

• New fuel/blends/hybrids (i.e. HDME 50)

ECAs – LSFO Availability (0.1%)


Safety aspects• combustion characteristics• heat transfer and circulation• flash point temp. (would 60ºC be lowered?)

Operational aspects• fuel segregation/contamination• incompatibility - fuel filter blockages• low viscosity – leaks & loss in pressure• low lubricity - pump seizure• bio element (FAME)

ECAs – Fuel Change Over Challenges


• Specifications not yet included in ISO 8217• Compatibility with HFO, MGO (and with each-other)• Requires heated tanks• High paraffin content – cold flow properties

• Fuel Stability & quality– Sediment formation– Injector and filter problems

• Separate tanks for new fuels?• Engine warranty issues?• Available amounts limited – would price be competitive?

ECAs – New Fuels/Blends/Hybrid - Potential Issues


• API Technical Considerations for Fuel Switching

• CIMAC Guideline for Operation of Marine Engines on Low Sulphur Diesel

HAZID to avoid mechanical failure & power lossINTERTANKO/OCIMF Recommendations on Fuel Change Over Procedures


• Ship owners & operators should:– ensure that all relevant equipment on board is

capable of handling ECA fuel– any modifications necessary are put in place and

tested well before the deadline– review contracts with fuel suppliers to ensure an

adequate supply of ECA fuel

• A vessel must use compliant fuel in ECA

• If a ship owner is not able to obtain compliant fuel due to non-availability, a FONAR must be submitted

USCG Advices for January 1, 2015

USCG/EPA Policies for ECAs


• If a ship owner is not able to obtain compliant fuel due to non-availability, a FONAR must be submitted

• FONAR is not a waiver, it is a statement of non-compliance– The lowest possible sulphur content fuel should be

used

• If Bunker Delivery Note (BDN) and independent test differ, Note of Protest (NOP) should be submitted

INTERTANKO advice: issue NOP if MARPOL Sample not taken in accordance with the IMO Guidelines

Fuel Oil Non-Availability Report (FONAR)


During USCG PSC examination, the ship should provide: – record of actions taken to attempt to achieve compliance – evidence the vessel attempted to purchase compliant fuel

oil in accordance with its voyage plan, and if not available where planned, that attempts were made to locate an alternative source

– documentation that Flag Administration and EPA were notified

– USCG will refer deficiencies identified during PSC of ECA non-compliance to EPA for enforcement

EPA reviews data/assess trends on FONAR submissions

Four companies that have submitted a number of FONARs have been issued subpoenas by EPA

Fuel Oil Non-Availability Report


FONAR: where vessels are coming from


FONAR: where vessels are coming from

Japan 47%

China 35%

South Korea 10%

Taiwan 1% India 0%

Australia 1% Brunei 1%Indonesia 1%NZ 1% Singapore 1%Samoa 1%Fiji 0%

Unknown 0%

Asia/Australia/Pacific Islands

32%

24%

14%

7%

5%

5%4%

4%

3% 1%

South America

Venezuela

Brazil

Colombia

Ecuador

Curacao

Trinidad

Aruba

Peru

Chile

Guyana

36%

29%

13%

19%

3%

North America

US East CoastCanadian East CoastUS West Coast Gulf Coast Canadian West Coast


FONAR: where vessels are going to


FONAR: Reporting


New Guidelines on PSC: At initial inspection within an ECA or first port after transiting an ECA the PSCO will look at:• Bunker Delivery Note (BDN)• MARPOL sample• Evidence of written change over procedures• Record of fuel oil changeover

If fuel not available must present a record of actions, including:• Voyage plan and when notice of ECA transit received• Date and time of expected transit• Description of actions taken to obtain fuel • Availability of compliant fuel at first POC in ECA & plans to obtain

fuel• Ship need not deviate from intended voyage or unduly delay the

voyage

Party will take into account relevant circumstances and evidence to determine the appropriate action, including not taking control measures

ECA 2015 – Paris MOU


EU – EU Sulphur Directive - European Sustainability Shipping Forum (ESSF) with 6 technical groups on:

a) LNG as Marine Fuel

b) Exhaust Gas Cleaning Systems

c) Implementation of Sulphur Directive – PSC & “sniffers”

d) Financing Opportunities

e) Research & Innovation

f) Competitiveness

ECA 2015 – EU Enforcement Policies


Group c) Implementation of Sulphur Directive – PSC & “sniffers”– Harmonised sampling – Developing On-board Sampling Guidelines– Designated Sampling Point (or two)– Sampling tolerances?– Expected completion by the end of 2014

INTERTANKO stressing the importance of control over fuel being delivered to the ship.EU Sulphur Directive Article 4b.3"Member States shall ensure that gas oils are not placed on the

market in their territory if the sulphur content of these marine gas oils exceeds 0.10%" by mass”.

ECA 2015 – Europe (ESSF)


• Fuel Standards• Bunkering Standards• Bunker Delivery Note

– Quality Control• HAZIDS at design stage• Design for practical application• Design for safety and efficiency

Alternative Fuels – lessons to learn


muchas gracias

[email protected]

Leading the way; making a difference AIR EMISSIONS LATIN AMERICAN PANEL Buenos Aires 5th November...

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