MARPOL

Annex VI sets limits on sulphur oxide and nitrogen oxide emissions from ship exhausts and prohibits deliberate emissions of ozone depleting substances. It also contains provisions allowing for special SOx Emission Control Areas (SECAS) to be established with more stringent controls on sulphur emissions. Low and high sulphur fuel has to be stored in different tanks. Different grades of cylinder oils may have to be carried if operating with low sulphur fuel for any length of time to prevent excessive calcium deposits and resultant liner wear. If low sulphur fuels are used, high wear rates may be experienced with fuel injection equipment. Ships using separate fuel oils entering or leaving an Emission Control Area must 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 prior to entry into an Emission Control Area. The volume of low sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oil-change-over operation is completed prior to the entry into an Emission Control Area or commenced after exit from such an area, shall be recorded in the Oil Record Book or approved log book. Marpol annex VI in force from May 19 2005 limits the maximum sulphur content of fuel to 3.5% after 1st Jan 2012 and to 0.5% after 2020 (or 2025, depending on the outcome of a review in 2018.) In SOx Emission Control Areas (SECAs) Sulphur limit in fuel is 1% until 1st July 2015 when it changes to 0.1% Instead of limiting the sulphur content to 1.0% a scrubber can be used to reduce sulphur emissions to 4 g SOx/kWh. This limit will change when the sulphur limit drops. SECAs are: The Baltic (from 19th May 2006). North European Waters (from 19thNovember 2007) Under the revised MARPOL Annex VI, the term Sulphur Emission Control Area, or SECA, is being replaced with Emission Control Area, or ECA. This will allow for ECAs to specify limits not just for sulphur oxides (SOx), but also for particulate matter (PM), and (NOx). Ah you can find all this stuff from MARPOL..

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 New S(ECA)s are a 200 mile ECA around the East and West Coast of the North American continent as well as Hawaii, The Mediterranean, Singapore and around Australia. On the 1st January 2010 the EU implemented its requirement that ships burn fuel of 0.1 per cent sulphur content or less when they are within EU ports or within EU inland waterways. Sulphur Content of Liquid Fuels Directive, 1999/32/EC, as amended by 2005/33/EC of 6 July 2005 (the Directive). The European Commission has issued a Commission Recommendation (2009/1020/EU) of 21 December 2009 on the safe implementation of the use of low sulphur fuel by ships at berth in Community ports. The Commission Recommendation brings to the attention of the shipping industry a potential safety issue with the use of distillate marine fuel in boilers where the boilers have not been designed to use distillate marine fuel and/or appropriate fuel changeover procedures are not in place. Additionally the MGN highlights further guidance on implementation of the Directive published by the Commission in December 2009 that may be useful when applying the Regulations. Under Regulation 3(13)(a) of the Regulations ships can be exempted where it is necessary for the purpose of securing the safety of a ship. Exemptions can be considered on application to the MCA. It is required that ships at berth in EU ports and inland waterways vessels do not use marine fuel which has a sulphur content exceeding 0.10 per cent by mass. This requirement does not apply to ships at berth in EU ports for that period of time which is sufficient to allow the crew to complete any necessary fuel- changeover operation. These changeover operations should be completed as soon as possible after arrival at berth and as late as possible before departure from berth. The Regulations define a ship at berth as meaning ships which are securely moored or anchored in a EU Ports while it is loading, unloading or hotelling, including the time spent when not engaged in cargo operations. In order to further clarify the applicability of Regulation 4 of Schedule 2A, and in particular expand upon the definitions provided in the Regulations, the following guidance is provided. For a ship anchored outside port limits but anchored within the North Sea Sulphur ARAVINDH RANGAMANI

 Emission Control Area, the ship shall remain compliant with the sulphur content limit for fuel oil used on board the ship for the North Sea Sulphur Emission Control Area. Guidance on the term sufficient time allowed for fuel changeover operations by ships at berth in EU ports What is and what is not sufficient time to allow for fuel changeover operations may vary. However the Regulations establish that ships are not required to changeover fuel where, according to published timetables, ships are due to be at berth for less than two hours. It can be inferred from this exemption, in general, that one hour could be considered as sufficient time to complete fuel changeover operations recognising that the time may vary depending upon ship type and ship systems. Other factors that should be considered when determining what is sufficient time for fuel changeover operations should include: all relevant safe operations; the operating circumstances of the ship, such as to minimise the interruption of power plant; a need for effective maintenance and longevity of the ships machinery; any associated shore-based activity that might be required; machinery manufacturers guidance; company and vessel specific procedures; the power rating of the engines and the viscosity of the fuel being used. Do not consider sufficient time for fuel changeover operations to include time to procure and have delivery to the ship marine fuel with a sulphur content not exceeding 0.10%. A ship is expected to have compliant fuel onboard on arrival at berth. A ship arriving at a EU port from outside the European Union that has been unable, despite best endeavours, to source compliant marine fuel before arrival in a EU port will be expected to have made arrangements prior to arrival in the EU port to have compliant marine fuel supplied on arrival at the UK port. Where a ship arrives at a EU port without compliant marine fuel it is expected to document that

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efforts have been made to procure compliant marine fuel before embarking on its voyage to the EU. 4. Records in ships logbooks Details of any fuel changeover operations to be recorded in accordance with Regulation. The information required and when it is to be recorded is identified in Table below. Records in ships logbooks fuel changeover operations What is required to be recorded? When a record of fuel changeover operation is required? Time Volume in Position Volume in Date each tank of ship each tank with fuel oil Events with fuel oil not not exceeding exceeding Details 1.0% S 0.10% S Before entry into a SECA Commencement / Completion of operation Following departure from a SECA Commencement / Completion of operation Following arrival of ship at berth Commencement / Completion of operation Before departure of ship from berth Commencement / Completion of operation ARAVINDH RANGAMANI