CONTENTS: PREVENTION OF AIR POLLUTION FROM SHIPS IN VIEW OF THE LATEST REQUIREMENTS OF THE EU, USA CALIFORNIA STATE AND ANNEX VI TO MARPOL CONVENTION

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2 CONTENTS: PREVENTION OF AIR POLLUTION FROM SHIPS IN VIEW OF THE LATEST REQUIREMENTS OF THE EU, USA CALIFORNIA STATE AND ANNEX VI TO MARPOL CONVENTION GUIDELINES FOR SHIPS FIRING LOW SULPHUR OIL FUELS GUIDELINES FOR PROPER OPERATION AND MAINTAINING OF THE SAFETY AND OPERABILITY OF DIESEL ENGINES FIRING LOW SULPHUR OIL FUELS GUIDELINES FOR PROPER OPERATION, MAINTENANCE, SAFETY AND AVAILABILITY OF MARINE BOILERS BURNING LOW-SULPHUR FUELS Terms used in the guidelines: ECA Emission Control Area FMEA Failure Modes and Effects Analysis HAZOP Hazard and Operability Study HFO Heavy Fuel Oil MGO Marine Gas Oil MDO Marine Diesel Oil LSDO Low Sulphur Distilate Oil

3 NEW REQUIREMENTS FOR SHIP OWNERS AND ASSOCIATED HAZARDS As a ship owner bears the sole responsibility for ensuring that the ship installations use low sulphur marine fuels required by the regulations specified by the EC (see Council Directive 1999/32/EC as further amended), International Maritime Organization (Annex VI to MARPOL Convention) and by national regulations of other countries (California state of USA), Polski Rejestr Statków S.A. recommends, that before commencement of operation of any auxiliary installations using such a fuel, ship owners should contact their manufacturer. From the viewpoint of operational safety and the ship itself, it is important that engines, pumps, boilers and boiler burners be properly adjusted for the maintenance and burning of low sulphur marine fuels. Where modification of the installations are necessary due to the requirement to use such fuels, such installations shall have been previously approved by PRS S.A. and then subjected to the survey to demonstrate the possibility of their safe operation. Ship owners shall apply the following guidelines taking account of the safety, proper operation and operability of marine engines and boilers associated with the usage of LSDOs (Low Sulphur Distillate Oil) in accordance with standards ISO and PN-ISO

4 PREVENTION OF AIR POLLUTION FROM SHIPS IN VIEW OF THE LATEST REQUIREMENTS OF THE EU, USA CALIFORNIA STATE AND ANNEX VI TO MARPOL CONVENTION EU REQUIREMENTS In accordance with the requirements of Directive 1999/32/EC, as amended by Directives 2005/33/EC and 2009/30/EC, since 1 January 2010, the fuel oil used while at berth in EU ports shall not exceed 0.10 % m/m sulphur content 1). This requirement applies to all types of marine fuels used on board the ship (main engines, auxiliary engines and boilers). The above stated sulphur content is not required during the ship manoeuvring, it shall, however, be fulfilled as soon as possible after arrival and as late as possible prior departure. The above mentioned requirements do not apply to ships: a) which are, according to published timetables, due to be at berth for less than two hours; b) certain named ships as specified in the annex to the Directive and engaged on voyages solely within the territory of the Hellenic Republic, until 1 January 2012; c) ships which switch off all engines and boilers and use shore-side electricity while at berth in ports. The requirements of Directive 1999/32/EC, as further amended, were incorporated in the Polish law by the regulation by the Minister of Infrastructure of 25 March 2009 (The Journal of Laws No. 58, item 477). CALIFORNIA STATE REQUIREMENTS California State Administration, USA, has formulated their internal regulations, namely the California Code of Regulations (CCR), section , title 17, Airborne Toxic Control Measure for Fuel Sulphur and other operational Requirements for Ocean-going Vessels within Californian Waters and 24 Nautical Miles of the California Baseline. These regulations specify the following limits on sulphur content in marine gas oils (MGO) and marine diesel oils (MDO): (A) in auxiliary diesel engines where: i. from the entry of these regulations into force until 30 December 2011, marine gas oil (MGO) with the maximum sulphur content 1.5% or marine diesel oil (MDO) with the maximum sulphur content 0.5% may be used; ii. from 1 January 2012, marine diesel oil (MDO) with the maximum sulphur content 0.1%, (B) in main diesel engines and auxiliary boilers where: 1) this requirement applies to sea-going ships and inland waterways vessels at berth in EU ports *) as well as floating docks used on waters administered by Polish Maritime Offices, including the shipyard facilities. *) ship at berth in an EU port means a ship in a sheltered position in an EU port which is secured at anchor, on moorings (including single buoy moorings) or alongside irrespective of whether they are working cargo or not or they are embarking and disembarking passengers. 2

5 i. from 1 July 2009, marine gas oil (MGO) with the maximum sulphur content 1.5% or marine diesel oil (MDO) with the maximum sulphur content 0.5% may be used; ii. from 1 January 2012, marine gas oil (MGO) or marine diesel oil (MDO) with the maximum sulphur content 0.1% may be used. REQUIREMENTS OF ANNEX VI TO MARPOL Regulations for prevention of air pollution from ships included in Annex VI to MARPOL 73/78 specify, among others, limits on maximum sulphur content in marine fuels. Annex VI entered into force on 19 May After three years of its application, the need for numerous amendments to the regulations for prevention of air pollution from ships. Therefore, a number of amendments to this Annex were adopted to take effect on 1 July Emission Control Areas In the new proposals, the idea of SO X Emission Control Area SECA has been amended and extended to constitute Emission Control Area ECA. This is due to: introduction in Regulation 14 of Annex VI to MARPOL of a new noxious factor associated with emission from ships, which has not been covered by the rules so far, and with taking control of the compliance with the requirements concerning the emission of Particulate Matter PM; introduction in Regulation 13 of Annex VI to MARPOL provisions on special requirements concerning NO X emissions Emission Control Areas. According to the new requirements, ECA means an area where special obligatory requirements have been adopted to prevent, reduce and control air pollution with SO X, NO X, and particulate matter and their attendant adverse impacts on human health and the environment. New ECAs cover the present SO X Emission Control Areas, i.e. the Baltic Sea and the North Sea inclusive of its access routes and the English Channel. New ECA is intended to be designated off the US shore. Sulphur Oxides (SO X ) Emission of environmentally harmful sulphur oxides (SO X ) originated from the combustion on ships is being reduced, by setting limits of the sulphur content of marine fuel oils, to comply with the requirements of Regulation 14. New limits on the sulphur content of marine fuel oils used outside the ECAs shall be reduced as follows: until 1 December 2011, the sulphur content limit will be 4.5 %; since 1 January 2012, the sulphur content limit will be 3.5 %; since 1 January %, Within ECA: until 1 July 2010, the sulphur content limit will be 1.5 %; from 1 July 2010 to 31 December 2014, the sulphur content limit will be 1.0 %; since %, 3

6 which is indicated in Table 1 and Fig. 1 below. Table 1. Limits on sulphur content in marine oil fuels Note: Sulphur content limits [% m/m] Effective from SO X ECA Total 15 May % 4.5% 01 July % 01 January % 01 January January 2020 x 0.1% 0.5 % x The requirement of 0.5% sulphur content in marine oil fuels will be I 2018 subject to assessment by a team of IMO experts appointed to check the possibility for the use of such an oil fuel taking account of the future trends and market availability. In case a negative assessment has been issued, the requirement of 0.5% sulphur content in marine oil fuels will take effect as late as on 1 January Fig. 1. Limits of sulphur content in oil fuels according to Annex VI to MARPOL 4

7 GUIDELINES FOR SHIPS FIRING LOW SULPHUR OIL FUELS Provision of Adequate Capacity of Oil Fuel Tanks and Modification of Existing Oil Fuel Storage Installation Where a ship s arrival at the port of call is performed through the ECA, it may be necessary for the ship to use 2 or even 3 different types of marine fuel oil. For the existing ships, it will be necessary to: provide adequate capacity of oil fuel tanks and lubricating oil tanks and proper arrangements for different classes of oil fuel and lubricating oil; divide and install new service tanks of oil fuel; frequently pump out and fill service tanks of distillate fuel. Service tanks should fulfil the requirements of: Regulation II-1/26.11 of SOLAS; IACS Unified Interpretation SC 123 Machinery installation Service Tank Arrangements; IACS Recommendation Machinery installations of ships intended to navigate in SO X Emission Control Areas Service Tank Arrangements. Furthermore: LSDO tanks should not be located adjacent to hot walls of HFO, temporary or provisional arrangements for oil fuel tanks and systems, e.g. application of hoses or other pipes are not acceptable. 5

8 GUIDELINES FOR PROPER OPERATION AND MAINTAINING OF THE SAFETY AND OPERABILITY OF DIESEL ENGINES FIRING LOW SULPHUR OIL FUELS Before the first usage of LSDO, ship owners of vessels navigating in SO X Emission Control Areas have to adjust the installed engines for the combustion of such oils, and the oil fuel supply systems for the oil fuel type frequent change-over procedures during operation. For the limited experience of ship owners and the manufacturers of marine engines, using low sulphur oil fuels and out of concern for the save operation of ships, Polski Rejestr Statków specify below their recommendations on the preparation of ship owners for fulfilment of the new requirements. technology.com/contractors/noise/gerb/gerb4.html The ship owner should: obtain from the engine manufacturer, recommendations on the scope of the required modifications to the oil fuel system and preparation of the engine for combustion of LSDO; make changes to the engine fuel supply system to enable bypassing the oil fuel heaters during the changeover from HFO to LSDO to avoid rapid heating of LSDO and its excessive evaporation, and consequently the risk of unstable operation of the engine, loss of its power and event the loss of ship propulsion. Ship owner should require the engine manufacturer: to provide a detailed procedure for the engine supply changeover from HFO to LSDO and vice versa. During the process of changeover, undesirable components may precipitate, as well as air-locks in the fuel supply system or disruption of the engine work may occur; to specify the maximum period of continuous operation of the engine using the LSDO without the necessity for the cylinder oil change as long-lasting combustion of LSDO requires application of an oil with lower alkalinity; to provide information regarding the effect of oil fuels with lower viscosity on the operation and wear of the fuel apparatus components and to specify those assembled of the engine which consequently require other maintenance intervals than before; to provide guidance on the need for possible changes of the alarm settings (temperature, viscosity, fuel pressure) depending on the currently used type of oil fuel. 6

9 Ship owner, taking account of the lower viscosity of LSDO, should: specify the programme for the oil fuel supply system inspections, particularly for detection and repair of the fuel leaks, as lover viscosity favours the occurrence of fuel leaks and evaporation, which increases the risk of accumulation of flammable vapours and, consequently, the risk of fire (explosion); regularly monitor the oil viscosity after the operation with LSDO, especially for trunkpiston engines; regularly monitor the technical condition of the systems of storage, transport, preparation and engine fuel supply so as to avoid contamination of LSDO with HFO as a result of mixing and a consequential increase in the SO X emissions; regularly monitor the safety and alarm systems associated with the engine. GUIDELINES FOR PROPER OPERATION, MAINTENANCE, SAFETY AND AVAILABILITY OF MARINE BOILERS BURNING LOW-SULPHUR FUELS When low sulphur marine distillate oil (LSDO) is to be used instead of heavy fuel oils (HFO), the following risks should be taken into account: 1. boiler furnace explosion, 2. burner failure or the associated fuel system failure (e.g. failure of delivery pumps). Boiler Furnace Explosion Accumulation of flammable gases is more likely to develop due to easier evaporation of the LSDO, compared to HFO, increasing the risk of explosion, in particular in case of: - improper gas scavenging, - failure of the ignition devices, - excessive vaporized fuel amount/insufficient air flow during light-off. Breakdowns of Burners and Associated Fuel System Due to different characteristics of LSDO (lower viscosity, higher heat value, lower density, etc. compared to HFO) and different LSDO combustion processes, different is also operation of the burner and associated fuel system. Boiler components which require special attention to be paid during the changeover from burning HFO to LSDO are the following: 1. Burner and its Control System During the changeover from burning HFO to LSDO, and vice versa, special attention should be paid to the burner and its control system. Particularly important are the following issues: 7

10 each procedure for the fuel type change has to performed in accordance with the boiler/burner manufacturer s specifications; burner and its components: lance, steam/air nozzle, rotary cup, etc., as well as burner spraying pressure have to be adjusted to the particular fuel type in accordance with burner manufacturer s specifications; in burners, where LSDO is sprayed with air, special requirements concerning the compressed air have to be fulfilled, and additionally an air excess factor may require to be readjusted; programming control and relevant settings have to prevent ignition if safe conditions are not established. For instance, special attention should be brought to the pre-scavenge duration and to the ignition sequence. Due to an increased amount of LSDO vapours, the pre-scavenge time should be prolonged. The control system should also allow the post- scavenge of the whole furnace space; ignition devices (ignition burner or spark igniter) are to be so located as to allow efficient ignition of the fuel spray; number and location of flame detectors should be consistent with the flame pattern depending on the currently used type of oil fuel; heat stream generated during the combustion of each used fuel grade has to be approved by the boiler manufacturer for different areas of the boiler. 2. Fuel Supply System While using LSDO, special attention shall be paid to the following issues associated with boiler fuel oil supply system: potential problems with LSDO excess gassing within a heated boiler fuel oil service piping system. To avoid this, the heaters should be bypassed and fuel pipe tracing shut off. The alternative is to convert the piping system to enable simplified and safe changeover (direct feed). This may even require the fuel oil cooling; potential problems with LSDO gassing when applying steam in conjunction with marine gas oil in atomizing steam burners. This may require modifications to enable air atomizing or use of external mix type lances (fuel oil supply lines); if an atomizing steam line is led to the burner, it may be necessary to shut it off except where the burner is specially designed for the use of LSDO with steam for atomizing of the fuel oil; due to reduced viscosity and reduced lubrication ability of LSDO, the proper operation of such fuel pumps should be checked. For pumps running continuously when the boiler is in the stand-by mode, modification of the control system to stop pumps when running on LSDO may be considered; fuel oil shut-off valves and quick closing valves have to be checked for leakage, proper and safe operation on LSDO fuel. 8

11 Ship owner should obtain from the manufacturer of a boiler, burner or burner control system possible guidance on the required modifications to the fuel oil system and the boiler adjustment to LSDO burning. The boiler, burner or burner control system manufacturer has to check and ensure that the burner and the associated systems are suitable for running with different types of fuel or perform their necessary modifications and readjustments. Boiler/burner Operation, Inspection and Maintenance are to comply with the following provisions: an inspection and maintenance programme is to be established and followed on board the ship. It should cover in particular the tests of: safety and alarm systems, safety system, flame detection system and switch-off system, boiler control system, scavenge and ignition system, boiler operation on LSDO with variable (including low) load sustaining the stable flame, boiler operation on LSDO with maximum load (specified by the boiler/burner manufacturer); availability, on board the ship, of detailed procedures for the fuel changeover as well as records of fuel changeovers are to be checked; compliance of the procedures with fuel changeover (from HFO to LSDO) operations is to be checked; condition of flanges, gaskets and fittings is to be checked for possible leakage; tightness of the shut-off valves is to be checked; the crew is to be properly trained before performing fuel switching and operating the boiler with LSDO; a procedure is to be established and applied to monitor the quality of fuel oils, in particular their viscosity and flashpoint. GENERAL REMARKS: As far as possible, fuel oils should be purchased in the same ports from reliable suppliers and quality of the supplied fuel oils should be periodically verified by sending fuel oil samples to the approved laboratories. Following this rule is particularly important where fuel oils are ordered by the charterer rather than the ship owner. Documentation concerning the intended modifications to the fuel oil installations for storage, transporting, preparation and supplying the engines and boilers, to the safety, monitoring and alarm systems of the engines and boilers as well as venting and fuelling systems shall be submitted to the Machinery Department of Polski Rejestr Statków S.A. to be considered for compliance with the relevant provisions. 9

12 Modifications made to the equipment and installations are subject to verification during the ship survey. Procedures for the changeover from high to low sulphur oil fuels and vice versa shall be a part of the ship s ISM file. Furthermore, it is recommended that FMEA or HAZOP risk analysis be performed covering the oil fuel supply systems as well as the control, monitoring and safety systems of engines and boilers. Polski Rejestr Statków S.A. will require that the risk of failure or explosion while using LSDO, especially during the fuel mode changeover, determined in accordance with the above mentioned analyses be as little as possible. Auxiliary materials: 1. Directive 1999/32/EC as amended by Directives 2005/33/EC and 2009/30/EC. 2. California Code of Regulations (CCR), section , title MARPOL Annex VI. 4. IACS Technical Meeting on the use of 0.1% Sulphur Content Marine Fuel at Berth under Directive 2005/33/EC, EMSA