Guidance for Sox Emissions Reduction and Fo Change Over Procedures

FUEL OIL CHANGE-OVER PLAN

TO COMPLY WITH MARPOL ANNEX VI FOR THE PREVENTION OF AIR POLLUTION

BY SULPHUR OXIDES

M/V XX

FUEL CHANGE-OVER PLAN

FUEL OIL CHANGE-OVER PLAN

Due to the MARPOL Annex VI requirements, the following procedures have to be planned and implemented onboard:

Due to MARPOL Annex VI, Reg.14:

Fuel oil change-over from high to low sulphur fuel and vice versa, when the vessel enters or exits a SECA respectively. The change-over to low sulphur fuel should be completed (i.e. low sulphur fuel is present at the injector) before the vessel passes the SECA border.

Records of the change-over operation must be kept onboard when entering and leaving the SECA including time, position and low sulphur fuel ROB and will be subject to checking by the Port State Control authorities and the Class Surveyors. The form of the record book to be used will be defined by each Flag Administration.

Due to MARPOL Annex VI, Reg. 18:

Sampling of heavy fuel oil must take place during bunkering. Fuel oil samples must be kept onboard for 12 months and the relevant Bunker Delivery Notes (BDNs) for 3 years. The samples and BDNs must be easily traceable and readily available to the Port Authorities.

The fuel sampling is now a mandatory statutory requirement and the Port State Control Officers have the right to collect the sample kept onboard and/or copy of the BDN certified by the Master as a true copy, as evidence of the fuel oil quality (including but not limited to the sulphur content).

Due to MARPOL Annex VI Reg. 14 & 18:

Correct procedures for bunker quantity measurement must be followed to avoid quantity discrepancies. This becomes even more significant since low sulphur fuel quantities are now an investigating target for the Port State Control, similar to the bilge water and sludge quantities mentioned in the Oil Record Book.

Bunker storage management now has the additional task of storing fuels of different sulphur content onboard. The rule of never mixing bunkers received during different deliveries due to compatibility problems is well known to Chief Engineers. Now the additional task of separate storing of low and high sulphur fuel oils has been added.

All Officers onboard should be aware of the Fuel Oil Management Plan, however it is to the responsibility of the Chief Engineer to complete the relevant forms and ensure that bunkering operations and procedures described are followed.

The Fuel Oil Management records should be kept on board ready for inspection and should also be sent to the Company office at the end of each month for record keeping and statistical analysis.

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SECAs

For the time being the Baltic Sea, the North Sea and the English Channel have been identified by the IMO as Sulphur Emission Control Areas (SECAs).

The Baltic Sea area extent is defined in MARPOL Annex I Reg. 10(1)(b). The North Sea and English Channel area extent is defined in MARPOL Annex V Reg.5(1)(f).

A map indicating these areas is shown below:

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NorthSea


Low and high sulphur fuel oil storage and changeover procedures

1.General

This paragraph presents the general modifications to hardware and procedures which need to be implemented onboard a vessel for reducing the SOx emissions by burning low sulphur fuel while operating in a SECA.

It must be noted that the regulation requires the fuel system to be flushed from the high sulphur content fuel before the vessel’s entry into a SECA.

To satisfy the above, a combination of modifications to the HFO system and changeover procedures from high to low sulphur HFO will be required. The extent of modifications and the switch-over procedures depend on the vessel’s existing HFO system configuration.

2. Incompatibility of fuels

As previously mentioned, ocean-going ships entering SECAs will have to switch from a heavy fuel oil with sulphur content less than 4.5% to another heavy fuel with less than 1.5% sulphur content.

When switching between these HFOs there is a risk of incompatibility between the two products. The change-over procedure takes quite some time during which there will be a mix of the two fuels. Asphaltenes of the HFO are likely to precipitate as heavy sludge with filter clogging as a possible result which in turn will cause fuel starvation in the engine.

Even though incompatibility seldom occurs, the most obvious way to avoid this is to check the compatibility between the fuels. This can be done by using the fuel lab test kit provided onboard. For instructions of use o0f the fuel lab test kit pls refer to engine circular letter No. CL/E-46.

3. Storage of Fuel Oil

Fuel oil carried out onboard is stored in the following tanks :

DEDICATED TANKS FOR HIGH SULPHUR FUEL OIL (H.S.F.O.)

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Tank Name Frames Capacity in m3

NO.1 Fuel Oil Tank (P) 30-59 239.40

NO.1 Fuel Oil Tank (S) 30-59 398.80

No.2 Fuel Oil Tank (P) 23-32 518.50

No.2 Fuel Oil Tank (S) 20-32 622.70


DEDICATED TANKS FOR LOW SULPHUR FUEL OIL (L.S.F.O.)


No.3 Fuel Oil Tank (L.S.F.O.T.) (P) 14-23 397.50

OTHER FUEL OIL TANKS

4. High to Low Sulphur Fuel Oil changeover procedure

4.1 Entering a Sulphur Emission Controlled Area (SECA)

Before entering a SECA, a procedure must be followed to ensure that only L.S.F.O will be used while in this area. Allow enough time before entering in order to complete the following procedure:

About 36 hours before entering a SECA, stop transferring H.S.F.O. from the storage tanks to the settling tank. At this time the Settling tank is expected to contain about 18MT (19m3) and the Service tank about 19MT (20m3). In total about 37MT.

When you are ready to initiate the changeover process, record the relevant information in the Engine Logbook and the Marine Fuel Sulphur Record Book, “Log 5 – Emission control area change-over”.

• For the next 12 hours continue to consume H.S.F.O. from the Service tank while at the same time transferring H.S.F.O. from the Settling to the Service tank by means of the F.O. purifier until the Settling tank is almost empty (near the Settling tank outlet level).

• Drain remaining H.S.F.O. quantity from the Settling tank to the H.S.F.O. storage tanks via the F.O. Overflow tank. Estimated drain quantity, assuming drainage begins when the settling tank level is near to the tank outlet is 1.3m3 (1.2MT).

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Fuel Oil Overflow Tank (S) 27-30 20.50

Fuel Oil Service Tank (S) 27-29 25.10

Fuel Oil Settling Tank (S) 25-27 25.10


Note: The capacity of the F.O. Overflow tank is more than adequate at 20.50 m3, however ensure that enough empty space is available prior to commencement of the change over procedure.

Once the Settling tank is drained, start transferring L.S.F.O. from the L.S.F.O. bunker tank to the Settling tank until the automatic pump stop level (about 19.0 m3). This will take about 3 hours.

Simultaneously continue to consume H.S.F.O. from the Service tank. Assuming the Service tank contained 20.0m3 (19.0MT) upon drainage of the Settling tank it is possible to continue consuming H.S.F.O. from the Service tank for the next 8 hours.

It is estimated that at this point the H.S.F.O. in the Service Tank will be about 6.5MT (7.0m3). It is also estimated that about 20 hours have passed at this stage from the beginning of the operation.

At the discretion of the Chief Engineer the 8 hours limit may be shortened or lengthened depending on the movement of the ship due to weather. The Chief Engineer must ensure enough FO remains in the Service tank for adequate suction of the operating FO supply pump.

During this phase of the change over it is very important to closely monitor the Service tank level, say at one hour intervals to avoid loss of suction at the FO supply pump.

While the H.S.F.O. in the Service tank is consumed the L.S.F.O. can be heated in the Settling Tank (for 5-8 hours) to enhance settling and draining of water residue. It is not possible to recirculate the L.S.F.O. through the FO purifiers and back in the Settling tank, because the FO purifier discharge line is connected only to the Service tank on this ship.

Once the FO in the Service tank has reached the above discussed low level, start transferring, by means of the F.O. purifier, L.S.F.O. from the Settling tank to the Service tank.

Assuming a ship consumption of about 1.5MT/hr (1.6m3/hr) the H.S.F.O. of 6.5MT remaining in the Service tank will be consumed (including the quantity in the FO lines until the engines injectors) in about another 5 hours.

Thus it can be safely assumed (taking into account dilution time of L.S.F.O. in the H.S.F.O. remaining in the Service tank) that the change over will be completed within say 15 hours from the beginning of transfer of L.S.F.O. from the Settling to the Service tank and 35 hours from the beginning of the operation.

Allowance of another 1 hour is given so that the position of the ship at completion of the change over is well outside the SECA border, hence 36 hours from the beginning of the operation.

Since the purifier has a capacity of 2.2m3/hr the estimated time to fill up the Service tank (from 7m3 to 20m3), taking into account a ship consumption of about 1.6m3/hr (1.5MT/hr) will be about 22 hours.

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Empty the H.S.F.O. from the F.O. Overflow tank into one of the H.S.F.O. bunker tanks.

Once the M/E starts consuming L.S.F.O., the Cylinder Oil feed may need to be changed to a rate compatible with the L.S.F.O. sulphur content in accordance with manufacturer instructions. This generally applies if L.S.F.O. will be used for more than 1-2 weeks sailing time whereupon excessive accumulation of calcium additive can cause scuffing of the cylinder liners. Reference should be made to the following engine service letters:

- HITACHI MAN-B&W Diesel Engine Service Data No. HZSD-B0602, 24 August 2006.

- MAN B&W Diesel Service Letter SL01-392/JWF, July 2001.

- MAN B&W Diesel Service Letter SL00-385/HRJ, December 2000.

- MAN B&W Diesel Service Letter SL05-455/HRJ, September 2005 (For engines with Alpha ACC System).

When the changeover process has been completed, a relevant entry should be made in the Engine Logbook and the Marine Fuel Sulphur Record Book, “ Log 4 – Fuel change-over summary” and “Log 5 – Emission control area change-over”.

The L.S.F.O should be used at all times when the vessel is in the SECA.

4.2 Exiting a SECA

Before exiting a SECA, a similar but reverse procedure must be followed to change back to consuming H.S.F.O. The reverse procedure is sped up y draining both the Settling and Service tank to minimize the quantity of L.S.F.O. consumed due to it’s highest value, compared to the H.S.F.O.

The changeover timing should be such that the vessel starts burning H.S.F.O only after she had exited the SECA:

The operation must be started about 10 hours before exiting the SECA.

When you are ready to initiate the changeover process, record the relevant information in the Engine Logbook and the Marine Fuel Sulphur Record Book, “Log 5 – Emission control area change-over”.

Transfer all L.S.F.O from the Settling tank to the L.S.F.O. storage tank (via the Overflow tank). The transfer by gravity is estimated to take about 1 hour to complete.

Note: The capacity of the F.O. Overflow tank is more than adequate at 20.50 m3, however ensure that enough empty space is available prior to commencement of the change over procedure, depending on the L.S.F.O. quantity remaining in the Settling tank.

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After the Settling tank is emptied of L.S.F.O. transfer H.S.F.O to the Settling tank. This will take about 3 hours, thus 4 hours from the beginning of the operation.

After above is completed transfer the L.S.F.O. from the overflow tank to the L.S.F.O. bunker tank. Assuming the Settling tank was at pump stop level, i.e. about 19m3 you will need about 2.5 hours for the transfer at the F.O. transfer pump capacity of 7.3 m3/hr.

After the above, drain L.S.F.O. from the Service tank into the F.O. Overflow tank until about 7.0 m3 remain in the tank. The draining by gravity is estimated to take about 1 hour, thus about 7.5 hours from the beginning of the operation.

The Chief Engineer must ensure enough FO remains in the Service tank for adequate suction of the operating FO supply pump.

During this phase of the change over it is very important to closely monitor the Service tank level, o avoid loss of suction at the FO supply pump.

Empty the L.S.F.O. from the F.O. Overflow tank into the L.S.F.O. storage tank. This will take about 2 hours assuming 13m3 are drained from the Service tank (initially 20m3 and finally 7.0m3), thus 10 hours from the beginning of the operation.

When this is completed start transferring H.S.F.O. from the Settling tank via the purifier in the Service Tank.

• Assuming a ship consumption of about 1.5MT/hr (1.6m3/hr) the L.S.F.O. of 6.5MT remaining in the Service tank will be consumed (including the quantity in the FO lines until the engines injectors) in about another 5 hours, thus 15 hours from the beginning of the change-over.

An allowance of 5 hours is given to ensure the change-over will not be completed until well out of the SECA, hence beginning of operation is arranged 10 hours before exiting the SECA.

Once the M/E starts consuming H.S.F.O., the Cylinder Oil feed will need to be changed to a rate compatible with the H.S.F.O. sulphur content according to manufacturer instructions.

When the changeover process has been completed, a relevant entry should be made in the Engine Logbook and the Marine Fuel Sulphur Record Book, “ Log 4 – Fuel change-over summary” and “Log 5 – Emission control area change-over”.

5. Paperwork requirements

The changeover times, the position and the quantities of low sulphur bunkers available onboard at those times must be recorded in the Engine Logbook and the Marine Fuel Sulphur Record Book. Instructions in the beginning of the Record Book shall be followed regarding filling in of necessary data.

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Also note that the regulation requires that the volume of fuel in the bunker tanks is recorded. The corrected volume at 150C must be recorded at all times so that the measurements are consistent and easily compared.

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APPENDIX

- FO Service & Settling Tanks Arrangement

- FO Transfer System

- FO Purifying System

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Documents

Guidance for Sox Emissions Reduction and Fo Change Over Procedures