From 2020 and onwards, we are no longer able to use traditional heavy fuel oils (HFO), with 3.5% Sulphur content, unless you're using a scrubber. We are going to see is a new range of compliant fuels along with the current low Sulphur distillate fuels. As we know from the introduction of low Sulphur marine gas oil (LSMGO) for Sulphur Emission Control Areas (SECA) zones starting a few years ago there are challenges with running engines on low Sulphur fuels.
The new fuels that are available or going to be available, are very low sulfur fuel oils (VLSFO) and the ultra-low sulfur fuel oils (ULSFO). These fuels are generally hybrid fuels and there is no standardization for them yet, as the current ISO 8217:2017 standard does not cover hybrid fuels.
With the current bunker prices, there is a spread of around about US$175. This figure is important because this is the figure that everybody uses when they talk about the return on investments for scrubbers. Where this spread will be on 1st Jan 2020 is anybody’s guess. The only sure thing is that it’s going to change. In what direction it will change no one knows.
The cost is not the only issue we need to consider. Availability may also be a problem. If we look at the world’s largest bunker ports, such as Singapore, Fujairah and Rotterdam, will compliant fuels be available there? What I've heard so far from major suppliers is that compliant fuels will be available there; at least VLSFO, as well as the traditional HFO. However, in Hong Kong the fourth largest bunker port in the world only some of the large suppliers will have hybrid fuels available, initially at least.
These are just the major ports in the world. What about all the other ports where we currently bunker? Where are we going to stand there? I have no doubt that the oil majors will provide very good fuels and those fuels will be available in the major ports. But what about the smaller ports where we require bunkers?
Shell currently offers testing of their VLSFO out of the ports of Rotterdam, New Orleans and Singapore. I would highly recommend any owner thinking of using compliant fuels to take Shell up on their offer to test their fuels.
So who's going to take up the slack in the ports where compliant fuels are not provided by the big suppliers? Will we see smaller suppliers blending their own fuels? Will they provide the same quality? Or are we going to see a drop in quality because of the dubious stock that may be used during blending?
Earlier this year there was a bunker quality issue with bunkers supplied out of the Houston area, which apparently may have originated from the quality of cutter stock used. One explanation I have heard is that shale oil was used as cutter stock, and phenyl resins occur naturally in shale oil. Are we going to see more issues like that with the introduction of hybrid fuels?
How will fuel oil non-availability reports (FONARs) going to be handled? What is deemed ‘non-available’? Does it mean you have to use distillate if the hybrid fuel isn't available?
Now for the big one: Fuel quality. The issues with fuel quality are:
Stability is defined as the potential for a fuel to change condition in storage in certain circumstances. Bunkers stored for long periods may become unstable, as the asphaltene content can precipitate out of solution, causing a formation of sludge. This process cannot be reversed. Will we see the introduction of best before dates on hybrid fuels?
Which is defined as the tendency of fuels to produce deposits when mixed. Mixing of fuels from different sources can lead to incompatibility problems and loss of stability.
The level of cat fines in the fuels supplied is likely to increase due to the blending of fuels. We have to become more aware of cat fine levels and how we handle them.
In order to address these issues, there are a few precautionary measures we can take:
- Avoid mixing bunkers from different sources wherever possible;
- Store the fuel separately until compatibility testing has been carried out;
- Don't mix straight run fuel with a cracked one - if not possible, keep the ratio to an absolute minimum;
- Avoid mixing fuels with greatly different densities;
- Where possible choose fuels with similar viscosities and densities;
- Don't mix fuel oil with the marine diesel oil or the marine gas oil.
- If it is impossible to avoid mixing, then don't load on top in excess of a 20% mix ratio.
Current test standard ISO 8217:2017
There's no universally accepted standard currently for 0.5% very low sulfur fuel oils. ISO 8217:2017 has not been able to address some of the issues arising from the introduction to the market of several marine fuels that do not fit into the ISO 8217 marine distillate table, designed for operation in emission control areas (ECAs) with maximum 0.10% Sulphur fuels. Quality concerns specific to these less conventional types of fuel, not fitting traditional marine distillate specifications, is expected to become even more pressing with the 0.50% Sulphur limit in 2020. An ISO working group has already started the process of analyzing the needs. However, there is no chance of a new revision being published before the 1st of January 2020. The working group is expected to release what they call a publicly available specification - the PAS, the number is 23263 - and that hopefully will be available in early 2019 and may address some of the issues.
One thing to remember is that in the ISO standard there's a clause - the 5.3 - which states that “….fuel oils shall be free from any material that render the fuel unacceptable for use and marine applications.” It's important that this clause doesn't get watered down. It serves as protection from addition to the fuel of any harmful components, such as we those experienced in the Houston area earlier this year.
The ISO 8217 standard goes some way to addressing stability issues by limiting the total settlement potential (TSP) and the total settlement accelerated (TSA) to 0.1%. This is a good guideline to indicate how stable the fuel will be. But when it comes to compatibility it's not addressed in the ISO standard. The spot test according to ASTM D4740 is a simple test that can be performed on board. However, it does have limitations:
- One of the fuels must be a residual fuel, otherwise there will be negligible asphaltene to precipitate.
- Spot testing does not work for commingled distillates because of their low asphaltene content.
- The compatibility test can actually produce false positives for distillate blends due to the pigment separation.
The crew will need to be well trained on fuel purifying operations onboard their vessels, as the cat fine levels are likely to go up. We need to ensure that the Charter contracts include suitable bunker quality and liability clauses.
The Marine Environmental Protection Committee (MEPC) met in October this year for MEPC 73. They issued circular 878 which gives guidance on the development of ship implementation plans as a consistent implementation of the 0.5% Sulfur limit under MAPROL Annex VI. The ship implementation plan (SIP) addresses the following:
- Risk assessment and mitigation plan – assessing the impact of the new fuels.
- Fuel oil system modifications - such as additional tank segregation, fuel transfer and filtration modifications.
- Tank cleaning - removing the sediment associated with residual fuels. Manual cleaning of tanks or use of additives.
- Fuel oil capacity and segregation capability - does the vessel have sufficient tankage to segregate the fuels from different suppliers?
- Procurement of compliant fuel - ensuring the charter parties provides timely delivery of compliant fuel.
- Fuel oil changeover plan - including measures to offload or consume the remaining non-compliant fuel before 1st Jan 2020.
Port state control
How are PSC inspectors going to handle this? We cannot have any inconsistency in their approach. Interpretation and application of regulations can vary across different ports as we all know. Will they start to take samples? If so where will they take those samples from? MEPC74 is due to meet in May next year and should approve the 2020 implementation guidelines and amendment to the 2009 PSC guidelines which hopefully should go some way to ensuring a consistent approach.
Unfortunately all these guidelines are coming very late for those who have to deal with the challenges. The guidance is expected to have a strict limit of 0.5% for the delivered fuels from the suppliers. However, there will be a more relaxed 0.053% for the use actually measured onboard. Giving some leeway for operators.
What do we conclude from all this
The one piece of advice I will give is start preparing now. If you think it's going to go away it's not. I know that many parts of the jigsaw are not there yet but we need to start now.
When it comes to availability compliant fuels, they should be available in major bunker ports. Availability outside of the major bunkering ports may vary.
Fuel oil quality and testing, ensure bunkers are tested to the latest standard. Currently 50% of the world's bunkers are tested to a standard that is less than the current 2017 revision for of ISO 8217. There's a huge resistance from the suppliers to adhere to the latest standard. They're going to have supply fuels in future according to the latest standard.
Fuel management will become more and more important and best practices should be followed. The best practices are known by engineers onboard, but are not consistently adhering to them. Training ship staff is essential. Our ship staff need to know what's coming at them, and how best to handle the challenges.
Above text is an edited version of Mr. Sean Hutchings’s presentation during the SAFETY4SEA Conference in Singapore
View his video presentation herebelow
The views presented hereabove are only those of the author and not necessarily those of SAFETY4SEA and are for information sharing and discussion purposes only.
Sean Hutchings, Chief Technical Officer, Thome Group of Companies
Sean Hutchings is responsible for driving both compliance and safety cultures throughout the Group. Direct reporting units include, Group Security, HSSEQ, Fleet Services, Technical Support and Compliance departments. In addition monitoring and improving fleet performance through development of scalable solutions and provision of expertise, using innovative approaches to fleet management, with a strong emphasis on technology and processes. To closely monitor industry trends, including technological advances, ensuring Thome Group remains at the forefront of the industry in respect of safety, quality and efficiency of vessel management. Sean Hutchings has 17 years’ experience in Asia with DNV GL, including 10 years at a senior management level. He has managed a team of managers overseeing all maritime and offshore Classification activities for South East Asia and he has a wealth of managerial and technical expertise. He has a Bachelor of Engineering (Hons), University of Auckland, NZ. He is also a Member of Royal Institution of Naval Architects, UK.