EMISSION

CONTROL
AREAS:
THE GUIDE
PART 2:
ONBOARD
MANUAL

www.fathomshipping.com
 CONTENT
OVERVIEW
NOTE ON TERMINOLOGY 08
INTRODUCTION 09
LIST OF ABBREVIATIONS 10

01 EMISSION CONTROL AREAS – A KEY ELEMENT OF 12

MARPOL ANNEX V1

1.1 MARPOL ANNEX VI – AN INTRODUCTION 16

1.2 MARPOL ANNEX VI APPLICATION AND 17

OTHER CONTROL REQUIREMENTS

1.3 SULPHUR OXIDES (SOX) AND PARTICULATE 20

MATTER (PM) EMISSION CONTROLS
(REGULATION 14)

1.4 FUEL OIL AVAILABILITY AND QUALITY 20

(REGULATION 18)
Box 1 Information to be included in the 21
Bunker Delivery Note
Box 2 EU Sulphur Directive 2005/33/EC, 22
amending 1999/32/EC
Box 3 California regulated waters 23

02 EMISSION CONTROL AREA CO-ORDINATES 26

2.1 THE BALTIC AND NORTH SEA AREAS 28

2.2 THE NORTH AMERICAN AREA 30

2.3 US CARIBBEAN AREA 40

03 SULPHUR CONTENT OF FUEL OILS AS LOADED 42

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 44 04 FUEL OIL CHANGE-OVER PROCEDURES 07 CONTINUOUS OPERATION WITHIN ECAs 76

46 4.1 CHANGE-OVER PROCEDURE OUTLINE 7.1 ENGINE LUBRICANTS 78

48 4.2 FACTORS TO CONSIDER 7.2 BUNKERING – SEGREGATION 78

49 4.3 CHANGE-OVER TIME CALCULATIONS 7.3 FUEL TEMPERATURE CONTROL 79

51 4.4 VERIFICATION OF CHANGE-OVER 7.4 FUEL SYSTEM AND ENGINE COMPONENTS 79

52 05 CONSIDERATIONS WHEN SWITCHING TO 08 THE MARPOL SAMPLE 80

LOW-SULPHUR RESIDUAL FUEL OIL
8.1 GENERAL SAMPLING PROCEDURES FOR OBTAINING 84
54 5.1 CYLINDER LUBRICATING OIL (CLO) SELECTION FOR THE MARPOL SAMPLE
CROSS-HEAD ENGINES
8.2 ACTIONS IF IT APPEARS THAT THE REQUIRED 86
58 5.2 FUEL COMPATIBILITY PROCEDURES HAVE NOT BEEN FOLLOWED

59 5.3 IGNITION AND COMBUSTION CHARACTERISTICS 8.3 IN THE EVENT THE MARPOL SAMPLE IS TO 87
BE ANALYSED
61 5.4 CATALYST FINES Box 4 2009 Guidelines for the Sampling of Fuel Oil 88
for Determination of Compliance with the
Revised MARPOL Annex VI
64 06 CONSIDERATIONS WHEN SWITCHING TO DISTILLATES

67 6.1 RAPID TEMPERATURE CHANGES

68 6.2 DISTILLATE FUEL TEMPERATURE

71 6.3 LOW FUEL VISCOSITY

72 6.4 CLEANING / SEARCHING ACTION OF DISTILLATES

74 6.5 LUBRICITY ISSUES

75 6.6 AUXILIARY BOILERS

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01 EMISSION 1.1 MARPOL ANNEX VI – AN INTRODUCTION

CONTROL AREAS 1.2 MARPOL ANNEX VI APPLICATION AND OTHER

– A KEY ELEMENT

CONTROL REQUIREMENTS

OF MARPOL 1.3

SULPHUR OXIDES (SOX) AND PARTICULATE MATTER
(PM) EMISSION CONTROLS (REGULATION 14)

ANNEX VI 1.4 FUEL OIL AVAILABILITY AND QUALITY

(REGULATION 18)
Box 1 Information to be included in the Bunker
Delivery Note
Box 2 EU Sulphur Directive 2005/33/EC, amending
1999/32/EC
Box 3 California Regulated Waters

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CHAPTER 01 EMISSION CONTROL
AREAS – A KEY ELEMENT
OF MARPOL ANNEX VI

MARPOL ANNEX VI
• In contrast, SOx emissions are simply a direct
function of the sulphur content of the fuel oil
used, irrespective of the nature of the particular

1.1 – AN INTRODUCTION combustion process, and are therefore controlled

in respect of all fuel oils used onboard.

• Furthermore, controlling fuel oil sulphur content

also has a direct effect on reducing the total
The International Maritime Organization (IMO) is the United particulate matter (PM) emissions resulting from
Nations specialized agency with responsibility for shipping. combustion.
IMO operates through a number of committees, including

1
the Marine Environment Protection Committee (MEPC),
Sulphur is naturally present to a greater or lesser extent in
which deals with the prevention of pollution from ships. In

R
all crude oils. During refining the various forms in which
the 1970’s the International Convention for the Prevention

TE
it exists are distributed unevenly across the product range;
of Pollution from Ships (the MARPOL Convention) was
hence although much of the sulphur will tend to exist in the
developed by MEPC, providing a comprehensive range of
residual fraction there can still be significant levels in some of

P
measures to limit the discharge of oil, chemicals, sewage and
the distillates.
garbage into the world’s oceans and seas.

A
SOx and PM emissions have detrimental effects on human
By the 1990’s, however, it had become evident that further

H
health and on the natural and built environments and
issues, including air pollution, needed to be addressed and
have long been subject to controls in shore-side industry

C
that if IMO did not take action, individual States would start
and transport applications. The extension of such controls
to enact national measures which could result in a patchwork

E
to shipping is a logical approach to the overall quest for
of differing, and potentially contradictory, requirements.
improved ambient air quality – especially given the high

L
While many such issues, such as the toxic effects of ship’s
sulphur content of much of the fuel oil used by ships in the

P
anti-fouling coatings and transfer of foreign organisms in
absence of any controls.
ballast water, have been addressed in specific conventions,

M
the control of air pollution from ships was instead tackled
The approach taken within MARPOL Annex VI to SOx, and
by extending the scope of the original MARPOL Convention

A
hence PM, emission control has been to limit the maximum
via an additional annex, Annex VI, which entered into force
sulphur content of the fuel oils used, with those limits subject

S
in 2005. As of November 2011 there are 68 signatories to the
Protocol that introduced Annex VI, representing over 91% of
the world’s gross tonnage.
Unlike the preceding Annexes I – V, which deal with single
topics, MARPOL Annex VI deals with a number of air pollution
streams: exhaust emissions, ozone depleting substances,
volatile organic compounds and incineration. Within the
context of exhaust emissions it is the oxides of nitrogen (NOx)
and the oxides of sulphur (SOx) that are subject to control:
• The formation of NOx in the combustion process
is largely dependant on the peak temperatures
encountered causing some of nitrogen in both in
the combustion air and in the fuel itself to form
oxides. Hence, NOx emissions under the Annex
are limited only in respect of diesel engines
(which have relatively high peak temperatures as
compared to boilers) by means of controlling the
NOx critical components and operating parameters.
to staged reductions, giving the industry and bunker suppliers
time to plan for and adjust to the changes. Furthermore,
lower fuel oil sulphur limits apply, with their own sequence
of reduction, in areas termed Emission Control Areas (ECAs)
where a higher level of protection is required due to such
factors as prevailing winds, the proximity of shipping routes
to centres of population and the natural susceptibility of an
area to acid deposition.
One complication is that the term ‘Emission Control Area’
is also applied to areas where a higher level of protection
against NOx emissions will be afforded. While ECAs
established to protect against SOx and PM emissions may
be the same as those established to protect against NOx
emissions, this is not necessarily so and in any case there
are different applications and entry into effect dates. For the
purpose of this Guide and Manual the term ‘Emission Control
Area’ or ECA refers to those established for SOx and PM
control unless specifically stated otherwise.

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CHAPTER 01 EMISSION CONTROL
AREAS – A KEY ELEMENT
OF MARPOL ANNEX VI

MARPOL ANNEX VI SULPHUR OXIDES (SOx)

APPLICATION AND AND PARTICULATE
OTHER CONTROL MATTER (PM)
1.2 REQUIREMENTS EMISSION CONTROLS

1
(REGULATION 14) 1.3

TE R
The requirements contained in IMO Conventions such as
MARPOL are enacted through the national legislation of those
IMO Member States that are signatories to that particular Regulation 14 of MARPOL Annex VI controls SOx and

P
instrument. These requirements therefore apply both to ships PM emissions through limits on the maximum sulphur
content of the fuel oils used.

A
flagged in that State and to ships of other States (irrespective
of their signatory status) when operating in waters under the

H
jurisdiction of the signatory State. Outside ECAs the sulphur maximum limits are
(Regulation 14.1):

C
There may also be specific additional requirements (for
• 3.50% on and after 1 January 2012

E
example, in terms of record keeping) which apply to ships
• 0.50% on and after 1 January 2020

L
flagged in the signatory State or requirements which apply
generally within that State’s waters (for example, restrictions (subject to review for possible postponement

P
on the sulphur content of the fuel oil used at berth). See Box 1 to 2025)
(European Union) and Box 2 (California) as examples of such

M
additional controls. Inside ECAs the sulphur maximum limits are
(Regulation 14.4):

S A
• 1.00% on and after 1 July 2010
• 0.10% on and after 1 January 2015

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02 EMISSION CONTROL 2.1 THE BALTIC AND NORTH SEA AREAS

AREA CO-ORDINATES 2.2 THE NORTH AMERICAN AREA

2.3 THE US CARIBBEAN AREA

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CHAPTER 02 EMISSION CONTROL
AREAS IN DETAIL

FIGURE 3 FIGURE 4
GLOBAL ECAs THE BALTIC AND
NORTH SEA AREAS

TE R 2
C H A P
THE BALTIC AND

M P L E
A
2.1 NORTH SEA AREAS

SThe Baltic and North Sea Emission Control Areas are

defined by the following:

THE BALTIC AREA

The Baltic sea proper with the Gulf of Bothnia, the Gulf
of Finland and the entrance to the Baltic Sea bounded by
the parallel of the Skaw in the Skagerrak at 57044’8”N.

THE NORTH SEA AREA

The North Sea proper including the seas therein with the
boundary between
i) The North Sea southwards of latitude 620N
and eastwards of longitude 40W
ii) The Skagerrak, the southern limit of which is
determined east of the Skaw by latitude 57030’N
iii) The English Channel and its approaches
eastwards of longitude 50W and northwards of
latitude 48044’8”N.

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CHAPTER 02 EMISSION CONTROL
AREAS IN DETAIL

THE NORTH FIGURE 5B

MAGNIFIED VIEW OF THE
2.2 AMERICAN AREA PACIFIC COAST

FIGURE 5A
GENERAL VIEW OF THE

2
NORTH AMERICAN ECA

TE R
(Enters into effect 1 August 2012)

C H A P
L E
SOURCE: MEPC.1/Circ.723

S A M P
SOURCE: MEPC.1/Circ.723

The North American Emission Control area is not such a

readily definable area as the North Sea and Baltic ECAs. It is
defined by the coordinates of its three constituent areas: the
Pacific coast, The Atlantic and Gulf of Mexico coast, and the
Hawaiian Islands.

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03 SULPHUR
Compliance with the ECA requirements is dependent on two
key factors: loading fuel oils of the required sulphur content
and bringing the ECA-compliant fuel into use as and when

CONTENT OF required (as covered in Chapter 4 of this Manual).

There are no means by which the sulphur content of the fuel

FUEL OILS oil once loaded can be altered onboard (other than onboard
blending, for which at present there are no Guidelines).

AS LOADED
Consequently it is necessary to ensure that the fuel oils loaded
meet the required limits and that, in the case of the ECA-
compliant fuel oils, this compliance is not compromised by
mixing with other, higher-sulphur fuel oils either in bunker
tanks or in the transfer system. The limited mixing that will
occur in settling and service tanks when changing from high-
to low-sulphur fuel oils is covered in Chapter 4.

While earlier versions of the ISO 8217 marine fuel

specification gave sulphur limits for all grades, the ISO
8217:2010 version gives these only for the distillate grades
– but even where limits are given these are only from a
technical perspective. Therefore irrespective of whether
fuel oils (RFO or distillates) are ordered against the ISO 8217
specification (whichever version) or other standards it is
necessary for the required maximum sulphur content to be
clearly specified; either as part of the bunker nomination or in
the charter-party agreement as appropriate.

Having specified the sulphur content of the fuel oil to be

supplied it is also essential to check the sulphur content of the
fuel oil physically supplied – noting that the MARPOL Annex
VI requirement is for the actual sulphur content, not a typical
or maximum value, to be given on the bunker delivery note.
The Chief Engineer, or whoever is the officer responsible from
the ship’s side for the bunkering process, must ensure that
the given sulphur content on the bunker delivery note does
not exceed the maximum as ordered or specified. The bunker
delivery note is the supplier’s statement to the ship of the fuel
oil’s sulphur content and it is this that port State control, or
other such agencies, will inspect to ensure that the ship had
loaded the required fuel oil. For further details on bunkering
and sampling, see Chapter 8 of this Manual.

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04 FUEL OIL 4.1 CHANGE-OVER PROCEDURE OUTLINE

CHANGE-OVER 4.2 FACTORS TO CONSIDER

PROCEDURES 4.3 CHANGE-OVER TIME CALCULATIONS

4.4 VERIFICATION OF CHANGE-OVER

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CHAPTER 04
MARPOL ANNEX VI REGULATION 14.6
Those ships using separate fuel oils to comply with... [MARPOL
Annex VI Regulation 14.4] ... and entering or leaving an
emission control area ... shall carry a written procedure
showing how the fuel oil change-over is to be done, allowing
sufficient time for the fuel oil service system to be fully flushed
of all fuel oils exceeding the applicable sulphur content specified
in [Regulation 14.4]...
Typically these procedures would be contained within the
ship’s overall operating procedures and managed accordingly.
The procedures need to be readily available and provide
specific instructions on carrying out the fuel change-over
procedures.
These procedures may be prepared in-house or by outside
service providers such as Lloyd’s Register FOBAS. Generally
each company would utilise a common core text that can
H
be amended to take into account individual ship issues and
arrangements. There is no requirement, or provision, for
C
these procedures to be approved by the ship’s Administration.
E
L
P
CHANGE-OVER
M
PROCEDURE
A
S
4.1 OUTLINE
• GENERAL: Ship to which the procedure applies.
What is to be done. Overall objectives and
individual responsibilities.
• ON ENTRY TO AN ECA: Reference to the ECA
boundaries, how the position at completion of
the change-over to the ECA-compliant fuel oil is
to be determined and the time before reaching
that position that the change-over operation
is to commence. Any special considerations
which would require this to be undertaken
earlier than under normal conditions. Required
communications between bridge and engine
room.
46 ECA GUIDE www.fathomshipping.com
FUEL OIL CHANGE-
OVER PROCEDURES
• ON EXIT FROM AN ECA: Reference again to the
ECA boundaries and how the position at the start
of the change-over to the higher-sulphur fuel oil
is to be determined. Any special considerations
which would require this to be undertaken
later than under normal conditions (this could
include not changing over when the ECA is to be
shortly re-entered or for other reasons). Required
communications between bridge and engine
room.
4
• EQUIPMENT: Listing of the combustion
R
equipment (engines, boilers, etc.) to which the
change-over applies.
TE
• ECA FUEL OIL: Verification that fuel oil to be used
P
within ECA is compliant (ie from BDN) and that
the required consumption quantities are onboard
A
or will be supplied.
• PROCEDURE: Identification of key fuel system
components, including system drawings as
necessary. Detailed procedures as to required
levels in tanks through the process and the
sequences and timings (and what influences
these) in which valves are to be operated.
• RECORD-KEEPING: What is to be recorded, when
and where that record is to be made and by
whom.
• OPERATING AND SAFETY CONSIDERATIONS.
NOTE: These procedures may also provide the basis of the
change-over procedures required to comply with other
control measures (such as the EU ‘At Berth’ regulations) which
necessitate change-overs of fuel oil. In such cases specific
attention would be required to the particular fuel oil grades
involved and the exact requirements of those controls.
www.fathomshipping.com ECA GUIDE 47
CHAPTER 04
FACTORS TO
4.2 CONSIDER
• Any conditions or parameters specified in the machinery
manufacturer’s guidelines.
• Change-over times dependent upon engine load and
temperature differentials in RFO and LSRFO/MGO/MDO
transition modes.
• The maximum main engine load at change-over and the
duration of any load reduction.
• When switching to MGO/MDO identify minimum viscosity
allowable in the engine and other critical components and
H
hence fuel-specific maximum allowable temperature(s) to
C
maintain required viscosity (this may include machinery
component manufacturer’s instructions as to minimum
E
viscosity/maximum temperature of fuel grades).
L
• Cylinder oil lubrication requirements (where applicable)
P
e.g. correct feed rates for each fuel grade/type, procedures
relevant to change-over to different BN lubricant where
M
applicable.
A
• Means of monitoring engine load performance, cylinder
S
components condition and injection pump internal leakage
when operating with LSRFO/MGO/MDO for extended periods.
• Procedures for compatibility testing between the different
fuels to be used in the change-over process.
• Contingency procedures in the event of:
• sub-standard fuel quality, or
• incompatibility between LSRFO/MGO/MDO and RFO
• engine failures from vapour lock
• emergency operations on MGO/MDO.
48 ECA GUIDE www.fathomshipping.com
FUEL OIL CHANGE-
OVER PROCEDURES
CHANGE-OVER TIME
CALCULATIONS 4.3
As stated above, it is essential that the change-over procedure
includes the means by which the time between commencing
and completing the change-over is to be determined, taking
4
into account:
R
• Fully-segregated system or non-segregated fuel
TE
service tank systems;
• Volumes of tanks (in the case of non-segregated
P
systems) and piping systems within which the LSRFO
A
mixes with the HSRFO (including fuel de-gassing/
mixing tank);
• Sulphur content of HSRFO;
• Sulphur content of LSRFO;
• Ship fuel consumption rates (as a function of load) at
change-over;
• Return oil flow to fuel service tank or de-gassing /
mixing tank (as applicable)
In the case where there are segregated service tanks the
change-over time will tend to be very short due to the
generally high ratio between consumption rate and fuel
service system volume (although if changing over to or from
distillate, the time is generally dictated by the need to control
the temperature gradient). However where there is only a
single system, the LSRFO needs first to be introduced into the
settling tank and then to work its way gradually through to
the service tank and then the fuel oil service system: a much
more involved process.
Lloyd’s Register FOBAS provides a fuel change-over calculator
spreadsheet that is available from its website or on request.
This tool provides an estimate of the time required to dilute
and flush through the combined system in order to achieve
the required sulphur content in the fuel supply system. The
calculation assumes a complete linear blend of the two fuels
during the dilution stage.
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05 CONSIDERATIONS 5.1 CYLINDER LUBRICATING OIL (CLO) SELECTION FOR

WHEN SWITCHING
CROSS-HEAD ENGINES

TO LOW-SULPHUR 5.2 FUEL COMPATIBILITY

RESIDUAL FUEL OIL 5.3 IGNITION AND COMBUSTION CHARACTERISTICS

5.4 CATALYST FINES

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CHAPTER 05 CONSIDERATIONS
WHEN SWITCHING
TO LOW-SULPHUR
RESIDUAL FUEL OIL

CYLINDER
POTENTIAL PROBLEMS

Extended operations using inappropriate CLO and/or

LUBRICATING OIL with incorrect feed rate settings may result in damage
to the cylinder liner and piston rings. Consider the

(CLO) SELECTION
following two scenarios:

01 Low sulphur fuel of ≤1.00% operating with a

FOR CROSS-HEAD CLO of BN 70.

5
ENGINES
An extended period of operation on such fuel

5.1 oil is likely to lead to undepleted base, leaving

R
hard deposits on the piston crown and fouling of

TE
piston ring grooves. If excess deposit builds up,
this can lead to scuffing and possibly severe wear
BACKGROUND of the liner and piston rings.

A P
The Base Number (BN) requirements of the cylinder oil vary This scenario may raise the risk of liner
with the sulphur content of the fuel. For example a BN70 lacquering through the formation of hard

H
lubricant is typically used for high-sulphur fuel oils, with calcium deposits on the cylinder liners. This
is due to excessive alkaline compounds in

C
sulphur in excess of 1.50% but as sulphur content is reduced,
lower BN cylinder oil may be required, since there is less comparison with the acid present. The resulting

E
acidity to neutralise. deposits can lead to bore polishing and sudden
and acute wear of the liner as a result of the

L
Typically, a low-sulphur fuel oil with sulphur content ranging lubricant failing to adhere effectively to the liner

P
from 0.50% to 1.50% may be best matched with a CLO of surface.
BN between 30 and 40. Switching to a CLO with a lower BN

M
is generally recommended by the engine builders when a 02 High-sulphur fuels, well in excess of 1.00%,

A
low-sulphur fuel is to be used for more than 5-8 days. The operating on a CLO with a low BN such as a 40.
manufacturer’s guidelines however should be consulted

S
to ascertain the correct BN number for the specific engine Extended operations could lead to an excessive
type and the sulphur content of the fuel, the length of time degree of corrosion of the liner surface leading to
the engine can be run before the cylinder oil type must cylinder liner deterioration.
be switched over, and whether it is appropriate to make
adjustments to the cylinder oil feed rate.

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CHAPTER 05 CONSIDERATIONS
WHEN SWITCHING
TO LOW-SULPHUR
RESIDUAL FUEL OIL

REQUIRED ACTIONS
FIGURE 8
• For ships with cross-head engines expecting to operate
regularly for extended periods on different sulphur content EXAMPLE CYLINDER OIL
fuels, at least two separate CLO storage tank facilities should
be considered in order to segregate CLOs of different BN and
FEED RATES DEPENDING ON
in anticipation of having to use both high- and low-sulphur
fuels.
THE FUEL SULPHUR LEVEL
• As part of the change-over plan full consideration must be

5
given to the CLO type and feed rate settings on and the time
the ship will be operating on the ‘non-standard’ fuel.

R
• Alternatively a ‘universal’ lubricant could be used which

TE
can be compatible with both low- and high-sulphur fuels –
although currently there are limited options and availability

P
for this type of CLO on the market.

A
• Apply improved diagnostic tools and methods to optimise

H
settings such as:

C
• increased spot checks on condition of the cylinder
liners and pistons;

E
• enhanced engine performance monitoring

L
techniques such as Lloyd’s Register ‘FOBAS Engine’ SOURCE: MAN Diesel: Guidelines for Fuels and Lubes Purchasing Operation on

P
which offer a comprehensive engine performance Heavy Residual Fuels
review;

M
• crew training to heighten awareness of potential
issues FIGURE 9

A
RESULTS OF

S
NOTE: when the switch to low-sulphur fuel will be for a short

OVER-LUBRICATION
time only, optimising the feed rate may be an appropriate way
to offset the effects of high-BN lube oil, without the need to
change the oil itself.

There are no hard and fast rules, and the optimal feed rate
will vary according to the ship-specific engine and operating
conditions. Crew should take observations and adjust settings;
also consult manufacturers’ guidelines such as that shown
below for MAN engines.

Hours on LSFO and BN 70 lubricant: 2,500

Cylinder oil feed-rate: 1,0 g/kWh

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CHAPTER 05

06 CONSIDERATIONS 6.1 RAPID TEMPERATURE CHANGES

WHEN SWITCHING 6.2 DISTILLATE FUEL TEMPERATURE

TO DISTILLATES 6.3 LOW FUEL

6.4 CLEANING / SEARCHING ACTION OF DISTILLATES

6.5 LUBRICITY ISSUES

6.6 AUXILIARY BOILERS

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CHAPTER 06 CONSIDERATIONS
WHEN SWITCHING
TO DISTILLATES

RAPID
The change-over issues relating to CLO BN and compatibility
are more pronounced when the change-over is to a distillate
fuel. In such cases the sulphur content can be an order of
magnitude lower than LSRFO, with obvious implications for
CLO BN requirements. The risk of incompatibility between TEMPERATURE
CHANGES 6.1
RFO and some distillates is also much higher due to the
fundamental differences between those fuels. However with
distillates there is a greatly reduced risk of poor ignition or
combustion performance and the level of cat fines should
be zero.

6
BACKGROUND
NOTE: If the fuel oil supply system is to be changed over for

R
a period to operate on distillate it is important that normal The difference in correct operating temperature between
operating temperatures are retained within the RFO system RFO and distillates can be over 100°C. If ‘cold’ distillate is

TE
(i.e. settling and service tanks) so that it will be ready for suddenly introduced into a fuel oil system at RFO injection
use when required. If the purifiers are left in operation temperatures the differing rates of contraction of the various

P
(i.e. circulating through the purifiers to the service tank components can result in the limited design clearances being
and then spilling back to the settling tank) it is important compromised to the point where interference occurs.

A
to ensure that the spill back arrangement is in place as

H
required and is indeed handling the required flow (and not It is equally important that the change-over from distillate to
blocked with accumulated deposits). Purifier pumps must RFO is undertaken in a controlled manner.

C
not be left simply churning the fuel or heaters operating
with a static charge of RFO. POTENTIAL PROBLEMS

L E
• Sticking/scuffing of fuel valves, fuel pump plungers

P
and suction valves and, in extreme cases, pump
plunger seizure.

M
REQUIRED ACTION

S A
• Engine builders generally recommend that
temperature change should occur at no more than 2°C
per minute, with additional time built in to allow for
uneven rates of change. So for instance, when
changing from RFO at a temperature of 150°C and
decreasing to a maximum of 40°C – a differential of
110°C that implies a minimum 55-­minute procedure
– at least an hour should be allowed to complete the
change-over, either from RFO to distillate or distillate
to RFO.

• Unless an automated fuel switchover system is

installed, normal practice is to run the engine at
low power (30-­70% MCR – manoeuvring speed) in
order to limit the fuel flow rate through the system.
Engine-­specific guidelines should be followed.

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CHAPTER 06 CONSIDERATIONS
WHEN SWITCHING
TO DISTILLATES

DISTILLATE FUEL THESE PARAMETERS ARE

6.2 TEMPERATURE NOT USUALLY AN ISSUE FOR
DESULPHURISED FUELS
BACKGROUND
AS THE MANUFACTURING
Distillate fuels do not require heating to achieve injection
PROCESS TENDS TO

6
viscosity. Therefore care must be taken to keep such fuels cool
enough to avoid operating problems, particularly where they
BREAK DOWN THE WAXY

R
are used in systems that normally operate on RFO. The way in

TE
which viscosity changes with temperature is shown below.
COMPOUNDS RESULTING IN

P
FIGURE 10 ELEVATED VALUES.

A
THE RELATIONSHIP

H
BETWEEN FUEL

C
TEMPERATURE AND

L E
VISCOSITY

M P
POTENTIAL PROBLEMS

A
If the temperature of the distillate fuel rises the viscosity

S
will be reduced, potentially to the point where it is no longer
capable of forming the required hydrodynamic film between
moving surfaces, resulting in wear, even seizure, between
those non-­supported components.

Fuel with an unduly low viscosity will flow through fine

clearances that were previously ‘sealed’ when the viscosity
was higher. A good indicator that the temperature of the fuel
system is too high is an increase of fuel leakage, particularly
around pump rotors, suction and spill valve push rods and
past injection pump plungers barrels and fuel valves.

A further problem can be ‘gassing up’ of hot distillate fuel in

On the other hand the pour point, cold filter plugging point
or cloud point values of some distillate fuels can require
certain minimum temperatures to be maintained, either
during storage (to avoid solidification), or in use (to avoid
blockages, particularly in filters and other fine clearances).
These parameters are not usually an issue for desulphurised
fuels as the manufacturing process tends to break down the
waxy compounds resulting in elevated values. However, it
may be a problem if the fuel is from a naturally low-­sulphur
crude and has not been subject to extensive refining, in which
case care will be needed to maintain the required minimum
temperatures – particularly when moving from warm to
cooler climates.
the fuel supply system resulting in vapour locking and hence
engine fuel starvation.
If the fuel temperature at injection is too high, the resulting
very low viscosity will also adversely affect combustion
performance. Apart from the risk of seizure of the injector
needles, the resulting spray pattern will not adequately
penetrate the combustion space, resulting in poor fuel
utilization and uneven heat distribution.

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07 CONTINUOUS 7.1 ENGINE LUBRICANTS

OPERATION 7.2 BUNKERING – SEGREGATION

WITHIN ECAs 7.3 FUEL TEMPERATURE CONTROL

7.4 FUEL SYSTEM AND ENGINE COMPONENTS

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CHAPTER 07 CONTINUOUS OPERATION
WITHIN ECAs

FUEL
Ships that operate all the time within ECAs will of course
avoid all the complications related to change-­overs and
having two different grades of fuel oil onboard. In these cases
it will be possible to optimise for the use of LSFO. Currently
this may be either a LSRFO or a distillate, and the choice will TEMPERATURE
CONTROL 7.3
be principally a commercial decision. From 1st January 2015,
however, when the ECA limit reduces to 0.10%, it is expected
that only distillate fuel will be used.

The areas of optimisation are set out in the sections

7
that follow. If a ship is operating only on distillate fuels it would be
appropriate to consider the degree to which the ship’s fuel

R
heating arrangements can be de-­commissioned, bearing in
mind whether the ship is likely to remain in that area or

TE
whether it could be deployed (or sold) elsewhere. None of

ENGINE the current or announced ECAs are known as areas where

P
relatively high pour points / cold filter plugging point
temperatures are encountered; however they do include

7.1

A
LUBRICANTS areas of particularly low ambient and sea water temperatures

H
and therefore there will be a need to maintain certain basic
minimum temperatures in storage.

C
Generally, ships built for distillate-­only operation have not

E
CROSS-­HEAD ENGINES: the cylinder oil should be changed for
one of the required Base Number and the flow rate optimised, needed fuel cooling / chilling systems and, provided that fuels

L
which may require on-­going evaluation support. are ordered to the ISO 8217:2010 specification, this should

P
remain the case. In exceptional cases where such equipment
TRUNK PISTON ENGINES: system oil type should be changed to is used, operators should perhaps ask why the fuel is being

M
one specifically formulated for use with controlled sulphur heated in the first place, rather than installing further
equipment to remove that heat.

A
content fuel oils.

7.2 SBUNKERING –
SEGREGATION
Generally it has remained standard practice, as with RFO,
to bunker different consignments of LSRFO into different
tanks wherever possible. Fuel quality issues for distillates
FUEL SYSTEM
AND ENGINE
COMPONENTS 7.4
are anticipated to become more frequent as demand for
In view of the reduced tolerance of distillate fuel to worn or
distillates increases, and therefore extending the policy of
poorly-­fitting equipment it is necessary to consider which
separate tanks for different bunker stems will be equally
items, especially pumps, injectors, booster pumps, transfer
appropriate in the case of distillates. It limits the risk of
pumps may need to be renewed or overhauled, depending
poor-­quality fuel contaminating other fuel, rendering both
on their condition and longer-­term suitability for operating
consignments unsatisfactory.
continuously on distillate fuels.

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08 THE MARPOL 8.1 GENERAL SAMPLING PROCEDURES FOR OBTAINING

SAMPLE
THE MARPOL SAMPLE

8.2 ACTIONS IF IT APPEARS THAT THE REQUIRED

PROCEDURES HAVE NOT BEEN FOLLOWED

8.3 IN THE EVENT THE MARPOL SAMPLE IS TO

BE ANALYSED
Box 4 2009 Guidelines for the Sampling of Fuel Oil
for Determination of Compliance with the Revised
MARPOL Annex VI

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CHAPTER 08
NOTE: This section applies to ships that are required to retain
Bunker Delivery Notes onboard, ie 400GT and above, not on
limited voyages.
Fuel sampling is a vital part of the bunkering process. It
is the only direct evidence of a fuel’s characteristics as
bunkered that a ship has in the instance of later disputes and
inspections.
In order for samples to be valid, correct procedure MUST be
followed when drawing, sealing and storing samples. Correct
recording and documentation is also vital.
Regulations 18.8.1 and 18.9.2 require that the supplier is to
provide a representative sample of the fuel oil delivered –
the MARPOL Sample. This sample is not to be confused with
either the supplier-­provided ‘commercial sample’ or any
sample the ship may draw for its own purposes (eg despatch
to one of the fuel oil testing services such as FOBAS).
H
Unlike the other fuel samples that may be drawn from a
C
particular fuel stem there is only one MARPOL Sample for
each bunkering. Drawn by the supplier and retained by the
E
receiver (the ship), it is to be kept under the ship’s control
L
for at least 12 months or until the fuel it represents is
P
substantially consumed. Ideally all samples (MARPOL Sample,
commercial samples and fuel testing sample) would all be
M
drawn from the same, homogenous, primary sample thereby
avoiding the disputes arising where results from different
A
sourced samples are compared.
S
IMO has issued ‘Guidelines for the sampling of fuel oil for
determination of compliance with MARPOL Annex VI’
(MEPC.182(59)), reproduced in full in Box 4 below. These
Guidelines give the default procedure for how and where to
draw the Primary Sample, how this should be sub-­sampled to
give the MARPOL Sample, how that sample should be sealed
and labelled, together with the actions required on the ship.
The Guidelines set the outline which the authority responsible
for overseeing the local Bunker Supplier Registration Scheme
would apply in its area. The authority has the flexibility to
accept alternative arrangements to those given in the IMO
Guidelines, so long as those alternative arrangements are
equivalent to the Guidelines, in terms of providing a reliable
example of the fuel oil as actually supplied.
82 ECA GUIDE www.fathomshipping.com
THE MARPOL SAMPLE
This flexibility may be in respect of relatively minor matters.
Clause 5.3 of the Guidelines states that the MARPOL Sample
should be drawn at ‘.... the receiving ship’s inlet bunker
manifold ...’. However a supplier may have demonstrated to
the authority that it fully drains down the bunkering hoses
between deliveries (a point which the authority could subject
to unscheduled inspection) and hence there is no risk of
material remaining in the hose which would not be sampled
by drawing the sample at the bunker barge manifold.
8
In other instances the flexibility might be extremely wide.
One of the duties of an off-­shore support ship can be to supply
R
fuel oil to a drilling rig. A group of high-­speed ferries on a
regular service may bunker for each trip (to avoid carrying
TE
extra unnecessary weight) from a common shore tank. In this
and any number of other specific cases, the direct application
P
of the requirements as given in the Guidelines would be
impossible, impractical or unrealistic. In these instances the
A
supplier and authority would need to find a way in which
the basic principle behind the Guidelines (a representative
sample of the fuel supplied to a ship) is upheld while allowing
for particular operating scenarios.
Hence, it may be that the actual procedures applied differ, at
least to some extent, with the agreement of the responsible
authority from the procedures as given in the Guidelines.
Where this occurs, the supplier should be able to demonstrate
that those differences represent alternative, equivalent,
arrangements as agreed to by the authority responsible for
the application of the Bunker Supplier Registration Scheme
under which it operates.
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CHAPTER 08 THE MARPOL SAMPLE

GENERAL SAMPLING
A record should be kept of the key events relating to the
bunker supply; what was seen and what was not seen.
Where the supplier’s actions and procedures appear not

PROCEDURES FOR to correspond with those required by the Guidelines, can

those be justified by reference to alternative procedures

OBTAINING THE
agreed by the responsible authority? If that is not the case,
or where actions take place outside the view of the ship’s
representative this information should be duly recorded.

8.1 MARPOL SAMPLE Do not sign any documentation unless the actual event to

8
which it refers has been witnessed.

R
If a sample is handed to the ship that has not been witnessed
The basic requirements for obtaining the MARPOL Sample are – then sign for ‘receipt only, source unknown’.

TE
given in MEPC.182(59). This states that the MARPOL sample
should be obtained using a continuous drip sampler at the Never sign any blank labels for the barge crew.

P
receiving ship’s inlet bunker manifold and should be drawn
continuously throughout the bunker period. However, as

A
above, some Bunker Supplier Registration Schemes may have
approved alternatives, so this needs to be considered on a

H
case-­by-­case basis.

C
As in any sampling operation the basic good practice

E
principles should be followed. ISO 13739 is the standard

L
covering “Petroleum products — Procedures for transfer of

AS IN ANY SAMPLING OPERATION

P
bunkers to vessels”. It includes industry-­standard and best-­
practice approaches to sampling. The following are some key

THE BASIC GOOD PRACTICE

M
precautions to ensure that the samples collected are truly
representative:

A
PRINCIPLES SHOULD BE FOLLOWED.

S
• The whole of the fuel oil supplied is sampled;

• The sampling rate is uniform to flow and sufficient to obtain

the required volume of primary sample; ISO 13739 IS THE STANDARD
• The sample is drawn from a point which draws directly from
the fuel oil being supplied;
COVERING “PETROLEUM PRODUCTS
• There is no contamination from:
— PROCEDURES FOR TRANSFER
• Previous supplied fuel oil in the bunker lines OF BUNKERS TO VESSELS”. IT
INCLUDES INDUSTRY-­STANDARD
or probes;
• Extraneous material not cleaned from the probe or
sampling equipment;
• Materials used to clean the probe or sampling
equipment;
AND BEST-­PRACTICE APPROACHES
• Surroundings (i.e. dust, rain);
TO SAMPLING.
• The primary sample is thoroughly homogenised before
sub-­sampling to give the MARPOL Sample (and any other
samples).

The MEPC.182(59) Guidelines stipulate the sealing

requirements for the MARPOL Sample, the information to
be given on its label and the ship’s representative’s task in
signing for that sample.

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CHAPTER 08

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