1. AIR EMISSIONS LATIN AMERICAN PANEL Buenos Aires 5th November 2014
Dragos Rauta
INTERTANKO

2. SOx Emissions Limits
Globally(emissions from fuel with max. x% sulphur content)
Currently – 3.50%
After Jan 1, 2020 (or 2025) – 0.50%
ECA (Baltic Sea, North Sea, NA & Caribbean)
Currently – 1.00%
After Jan 1, 2015 – 0.10%
European Union Sulphur Directive
Follows IMO except:
Currently – 0.10% “at berth”
After Jan 1, 2020 – 0.50% in EU waters (?)
California % (24 miles)

3. ECAs – LSFO Availability (0.1%)
LS MGO expected to be available
Possible local shortage during initial phase-in period
Expected hikes on price in earlier stages
Premium expected to keep constant at $250 - $350 / ton
New fuel/blends/hybrids (i.e. HDME 50)

4. ECAs – Fuel Change Over Challenges
Safety aspects
combustion characteristics
heat transfer and circulation
flash point temp. (would 60ºC be lowered?)
Operational aspects
fuel segregation/contamination
incompatibility - fuel filter blockages
low viscosity – leaks & loss in pressure
low lubricity - pump seizure
bio element (FAME)

5. ECAs – New Fuels/Blends/Hybrid - Potential Issues
Specifications not yet included in ISO 8217
Compatibility with HFO, MGO (and with each-other)
Requires heated tanks
High paraffin content – cold flow properties
Fuel Stability & quality
Sediment formation
Injector and filter problems
Separate tanks for new fuels?
Engine warranty issues?
Available amounts limited – would price be competitive?

6. HAZID to avoid mechanical failure & power loss
INTERTANKO/OCIMF Recommendations on Fuel Change Over Procedures
API Technical Considerations for Fuel Switching
CIMAC Guideline for Operation of Marine Engines on Low Sulphur Diesel

7. USCG/EPA Policies for ECAs
USCG Advices for January 1, 2015
Ship owners & operators should:
ensure that all relevant equipment on board is capable of handling ECA fuel
any modifications necessary are put in place and tested well before the deadline
review contracts with fuel suppliers to ensure an adequate supply of ECA fuel
A vessel must use compliant fuel in ECA
If a ship owner is not able to obtain compliant fuel due to non-availability, a FONAR must be submitted

8. Fuel Oil Non-Availability Report (FONAR)
If a ship owner is not able to obtain compliant fuel due to non-availability, a FONAR must be submitted
FONAR is not a waiver, it is a statement of non-compliance
The lowest possible sulphur content fuel should be used
If Bunker Delivery Note (BDN) and independent test differ, Note of Protest (NOP) should be submitted
INTERTANKO advice: issue NOP if MARPOL Sample not taken in accordance with the IMO Guidelines

9. Fuel Oil Non-Availability Report
During USCG PSC examination, the ship should provide:
record of actions taken to attempt to achieve compliance
evidence the vessel attempted to purchase compliant fuel oil in accordance with its voyage plan, and if not available where planned, that attempts were made to locate an alternative source
documentation that Flag Administration and EPA were notified
USCG will refer deficiencies identified during PSC of ECA non-compliance to EPA for enforcement
EPA reviews data/assess trends on FONAR submissions
Four companies that have submitted a number of FONARs have been issued subpoenas by EPA

10. FONAR: where vessels are coming from

11. FONAR: where vessels are coming from

12. FONAR: where vessels are going to

13. FONAR: Reporting

14. ECA 2015 – Paris MOU
New Guidelines on PSC: At initial inspection within an ECA or first port after transiting an ECA the PSCO will look at:
Bunker Delivery Note (BDN)
MARPOL sample
Evidence of written change over procedures
Record of fuel oil changeover
If fuel not available must present a record of actions, including:
Voyage plan and when notice of ECA transit received
Date and time of expected transit
Description of actions taken to obtain fuel
Availability of compliant fuel at first POC in ECA & plans to obtain fuel
Ship need not deviate from intended voyage or unduly delay the voyage
Party will take into account relevant circumstances and evidence to determine the appropriate action, including not taking control measures

15. ECA 2015 – EU Enforcement Policies
EU – EU Sulphur Directive - European Sustainability Shipping Forum (ESSF) with 6 technical groups on:
LNG as Marine Fuel
Exhaust Gas Cleaning Systems
Implementation of Sulphur Directive – PSC & “sniffers”
Financing Opportunities
Research & Innovation
Competitiveness

16. ECA 2015 – Europe (ESSF)
Group c) Implementation of Sulphur Directive – PSC & “sniffers”
Harmonised sampling
Developing On-board Sampling Guidelines
Designated Sampling Point (or two)
Sampling tolerances?
Expected completion by the end of 2014
INTERTANKO stressing the importance of control over fuel being delivered to the ship.
EU Sulphur Directive Article 4b.3
"Member States shall ensure that gas oils are not placed on the market in their territory if the sulphur content of these marine gas oils exceeds 0.10%" by mass”.

17. Alternative Fuels – lessons to learn
Fuel Standards
Bunkering Standards
Bunker Delivery Note
Quality Control
HAZIDS at design stage
Design for practical application
Design for safety and efficiency

18. muchas gracias