LIMITS ON SULPHUR CONTENT

IN MARINE FUELS

OPERATIONAL HAZARDS
RELATED TO MAITENANCE
OF DIESEL ENGINES
AND FIRED AUXILIARY BOILERS

POLSKI REJESTR STATKÓW

MACHINERY DEPARTMENT
2009
 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
 NEW LIMITS ON SULPHUR CONTENT IN MARINE FUELS
– 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-8216-1 and PN-ISO 8216-1.

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 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 content1).
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 93118.2, 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.
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 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 2005. 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 2010.
Emission Control Areas
In the new proposals, the idea of SOX 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 NOX 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 SOX, NOX, and particulate
matter and their attendant adverse impacts on human health and the environment.
New ECAs cover the present SOX 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 (SOX)
Emission of environmentally harmful sulphur oxides (SOX) 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 2020 – 0.5%,

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 01.01.2015 – 0.1 %,

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which is indicated in Table 1 and Fig. 1 below.

Table 1. Limits on sulphur content in marine oil fuels

Sulphur content limits [% m/m]

Effective from
SOX ECA Total
15 May 2005 1.5%
4.5%
01 July 2010
1.0 %
01 January 2012
3.5%
01 January 2015
0.1%
01 January 2020x 0.5 %
Note:
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 2025.

Fig. 1. Limits of sulphur content in oil fuels according to Annex VI to MARPOL

http://www.dieselnet.com/standards/inter/imo.php

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 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 SOX
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.

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 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 SOX 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.

http://www.ship 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.

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 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 trunk-
piston 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 SOX 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.
http://www.aalborg-industries.com

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:

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 – 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.

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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.

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 • 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 93118.2, title 17.
3. 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 2009.

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