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Jon Watson
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MARPOL Annex VI Fuel oil Quality
It is an interesting point that most recent Multilateral Environmental Agreements have some form of CEMS (Continuous Emissions Monitoring Systems) and MARPOL does not.
We shouldn't think that they didn't consider this carefully. The initial concept would have been to monitor emissions in the exhaust but that didn't happen. Apparently satellite plume analysis was also considered and rejected.
Indirect Monitoring comes next on the list of options.
NOX and COX can be determined based on the engine certification and the mass of fuel consumed, and SOX can be determined from the fuel sulphur content and the mass of fuel consumed.
Easy enough?
Yes, an inline density meter to go with existing volumetric flow meters to determine the mass of fuel flowing to the engines and and inline X-Ray Fluorescence sulphur analyser.
The data could be automatically collected, linked to the vessel GPS position reporting, electronically recorded and real time compliance reported live using the AIS system.
Nice detailed and easily processed data and an easy task for Port State Authorities to verify compliance because they would only have to ensure no one had tampered with any of the instruments and that the instruments were properly tested and certified.
But that didn't happen either.
Instead, the fuel supplier is required to certify that the fuel is compliant and report the exact density and exact sulphur content - as determined by prior laboratory analysis - in the Bunker Delivery Note.
These values are then to be recorded in the vessel logs for subsequent determination of the emissions.
This system works if you assume that the fuel quality is properly determined at some point in time before bunkering which depends on appropriate representative sampling. MARPOL only proscribes the sample collection, handling and management as it relates to the MARPOL sample collected during bunkering so how and when samples are taken and managed for the BDN reporting is up to the supplier.
It also depends on the fuel being suitably managed from the time it is sampled, through bunkering and on until the fuel is actually consumed such that the density and sulphur content remain as reported.
If we think about it, that means that the fuels must be maintained homogeneous, protected from contamination, adulteration, separation and stratification, and from consolidation with other fuels - including with other batches of of the same fuel as different batches of the can have different density and sulphur contents.
If these things are done then the fuel arriving at the engine will have the exact density and exact sulphur content as declared in the BDN.
If not, then the chances are they will have different values and the logging of data is then somewhat meaningless and not verifiable - verification is considered a key requirement for successful treaties.
It would be difficult to pretend that fuels were already managed to the necessary degree to arrive at this condition and it is hard to say that suppliers and vessels have taken adequate measures since MARPOL was ratified.
Indeed, it has been stated unofficially that over 50% of commercial samples analysed showed a significant difference in density between the commercial sample analysis and the Bunker Delivery Note reported value.
Significant means that the fuel quality has changed due to one or other of the mechanisms mentioned above or that the fuel was not properly analysed to begin with and this is the sample collected during bunkering so we can't even guess how the fuel quality might be compromised once it is on board the vessel.
Well, I suspect most suppliers and vessel operators do know, it is in their interests to know this simply to know if they are getting value for money, but will they share what they know with the rest of us?
Poor fuel management isn't all of the problem; in the MARTOB report to the EU on Ballast water treatment and fuel sulphur, they declare that there is every possibility that records and samples will be falsified due to the financial benefits of non-compliance.
It is interesting to note that the lack of CEMS also probably means that Port State Authorities will find compliance monitoring and verification very labour intensive, time consuming and expensive if they are to fully investigate every vessel and how can they not unless they have some criteria to identify likely non-compliers?
So I wonder, what is the true state of affairs and how long before the legislation is changed to mandate the use of density analysers and sulphur analysers at the engines?
Or does the industry think the current system is robust enough to endure? Satisfactory to the legislators and the environmental pressure groups?
Does the industry believe that fuel management is adequate to ensure that the fuel quality reported during bunkering will remain unchanged through to the engine or even if it was of that quality during bunkering?
Next question, if fuels are not yet managed sufficiently well, then what is the cost of achieving that?
Posted: 10/15/2009 7:53:26 PM
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Chandran Peechulli
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RE:MARPOL Annex VI Fuel oil Quality
Lack of time and lab. facility on-board to test fuel quality supplied and sample quantity content for Chief Engineer on-board to check and receive.
On Marine Pollution: It's time to have some legislation in place whereby no State Government is allowed to prosecute and criminalise any seafarer no matter what. They should only be allowed to impose a fine on the ship/ship-owner for any fault of the ships' crew. The ship-owners can get a suitable cover from their P&I Clubs for this purpose.
- Capt. B.S. Koli
All seafarers of the Merchant Navy are not the upright and disciplined lot; hence take no chances for polluting the divine sea. Some Chief-Engineers and Captains can stoop to any level to please the ship-owners and commit commercial crimes, to reduce downtime and quick turnaround of vessel at the cost of polluting the divine sea, e.g.pumping out ER bilges(leakages and drains), sludge’s turned out as
waste from L.O., F.O. Purifiers, oily bilge water directly to sea,tank-cleaning waste oil of tankers presuming that it will go unnoticed, thereby pleasing their employers owing to their
job-insecurity, unlike those employed on war ships, where discipline is instilled.
We need therefore assurance for transparency,commitment with responsibility, the need for Senior Officers to take oath, for the general well-being. Is it not? The need therefore to block the loopholes in the system, taking no chances. Criminals should not go unpunished, or else they are encouraged to do so.One should learn to think and act fairly and efficiently, to produce high thoughts and ideals, to make up a good society to live with. Doing without thinking is of no quality or efficiency.
Dr.ChandranPeechulli,ManagingEditor & Publisher“Marine Waves” Ex.Chief-Engineer &G.M.Tech, Crossworld Shipping, www.themarinewaves.com
*view editorial contents on line.
Posted: 10/16/2009 9:58:08 AM
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Jon Watson
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RE:MARPOL Annex VI Fuel oil Quality
There are two good points to reply to here.
The first is the P&I clubs... their position is, perhaps, not as simple as might be thought.
The prospect is that legislators will seek to use very substantial fines to curb vilations.
They will not wish to see P&I clubs effectively suborning violations by covering the financial costs.
All that would lead to is an escalation in fines and an escalation in P&I club rates, if it were permitted or attempted by the P&I clubs.
I seem to recall there is a P&I club clause that says they need to see evidence of due dilligence and reasonable care.
It would be nice to get a response from the P&I clubs and
I could be wrong.
But, if this is the case then I would be interested to see what "reasonable care" and "due dilligence" are considered to be (and it may take a few court cases to establish that).
But I suspect that operators who do not take the trouble to check fuel quality or who rely on the suppliers certified values will find they didn't pass the test.
It may not be the case now, but I suspect it won't be long before it is the case and there will be pressure to use some form of instrumentation to automatically assess fuel quality as it is received against the suppliers claims.
The second point is about time, available skilled/trained crew and facilities on board vessels, especially during bunkering, to check fuel quality (and quantity) as the fuel is received.
Certainly, the current test kits don't make this an easy task (these kits are more often used for opertaional procedures are they not?) and that may be why we should expect "reasonable" will come to include some form of automatic instrumentation. The problem is that MARPOL doesn't allow certain fuels on board. Once on board, whether used or not, is that a serious infringement?
I certainly think CEMS is somewhat inevitable at the engine or in the exhaust but what form depends on how the industry approaches the problem.
Lastly, penalising or criminalising the crew - well, there are known pressures on the crew and officers to make sure the vessel is profitable. Some may feel that owners will put officers and crew in the position of having to break some regulation or another to meet schedules or avoid some fees even though they will never say that is how it is to be done and will deny that was their intention - they just meant "the crew should be more efficient".
The problem is, and I believe Intertanko has mounted a campaign against this, that the EU wants to crminalise any pollution offences. Not just where the crew deliberately set out to violate some regulation or other (magic pipe bilge water violations, for example) but accidental or inadvertent violations as well.
How the seafarer will come out of this dpends on how well the industry addresses these issues and how serious the industry believes the environmentalists are and how suceptible the legislators are to environmental pressure groups.
Will there be a reasonable and acceptable outcome or will there not?
I couldn't possibly comment on that.
Posted: 10/29/2009 4:17:55 PM
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RE:MARPOL Annex VI Fuel oil Quality
Appreciate the valued thoughts exchanged and expressed on the issue.
Forum: Environmental Monitoring
Subject: RE:MARPOL Annex VI Fuel oil Quality
Posted by: Jon Watson
Date and time: 10/29/2009 4:17:55 PM
Do hope, that we all agree of the ever-changing environment in ship management, the surge in scientific developments, increasing pressure owing to the squeezed manning of crew onboard, coming from different places, put in an uncertain terrorized state of mind owing to armed piracy, with all the limitations and constraints on board etc. resulting into increased and complex issues in sea employment. However, the need and urge to keep abreast, while plunging into challenges, marching ahead with the best of solutions to ship management, for all the needed, increased performance efficiency.
Please view, deliberate polluting activities out at sea, clicking highlights in www.themarinewaves. com, which is not but a serious act of negligence, but violation of I.M.O. Conventions, applying short-cut methods and polluting the sea. An upright senior officer on board the said vessel had informed, Mr.Rajaish Bajpaee, COO, representing the Management of Bernhard Schulte (almost a year back), appraising the misdeeds happening onboard, protesting the same. With the result he was victimized, signed-off from the vessel with no further calls for joining. It is therefore apparent that such crimes of violations, were going on for long, to reduce downtime and quick turnaround of vessels at the cost of polluting the divine sea, e.g. pumping out ER bilges (leakages and drains), sludge’s turned out as waste from L.O., F.O. Purifiers, oily bilge water directly to sea, as short-cuts, including the tank-cleaning waste oil, as per master’s direction, for such activities to go on unnoticed.
Please note that the “Polluter Pays Principle” do not solve this type of crime at all, as only when they are caught and proved, they afford to apply delay-tactics through legal assistance reducing thereby money value and loss minimized with increased profit, since restricted to this incident alone and not that, what was going on for long, from which they have gained a lot. Moreover, the magnitude of severance of penalty is minimal, from the undeveloped country like India. Such business tactics is like a gamble at the cost of polluting the divine sea. Flourishing by cheating has been ways of cheap businessmen, to make fast money through wrong acts. Is this to be an encouraging act? One should consider that they have been ruthlessly destroying the futile clean sea-bed and waters of the sea, by waste oil pollution?
I would agree, It is for any businessman or Ship Manager to contain their costs and stay afloat doing productive job, aim at incident-free voyages with zero-operational losses, reduction in operational expenses, feasible reduction in crewing expenses of medical ashore, unwanted repatriation, maintaining the frequency of crew change with good relations and keeping the morale of the crew high, optimum utilization of man-power on board, spares and stores etc. while the shipping industry is cyclic and resilient by nature.
A responsible media publishes only when they are very well informed of the facts and figures, besides be well convinced with the proof of evidence, not be just carried-away for any thing, while “Marine Waves” international maritime newsletter www.themarinewaves.com is very well known in India and overseas for their upright depiction of facts, the editorial contents, archived in their website on-line, stands testimony for all the expositions, for reforms of shipping administration and seafarers welfare measures etc. during the last six long years.
ARUN CHANDRAN
Posted: 10/31/2009 9:12:48 AM
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RE:MARPOL Annex VI Fuel oil Quality
Most Chief-engineers and Captains work for companies and have to follow the company's polices. Most of these professionals work overtime and risk their lives every day onboard vessels and can not carry out a proper maintenance program for reasons beyond their will. I think that it would be far more effective if the finger were primarily pointed to some of those companies' white collars who run the companies and dictate the company’s police. If we are really concerned about preserving the marine bio, governments should demand that ship owners prove on regular basis that his company's management system complies with ISO 14000, ISO 9000, BS 8800, etc. It is not fair to blame only a worker for the amount of smoke a factory sends out to the atmosphere. The worker may lose his job, but the factory will continue polluting the atmosphere, or not.
Posted: 11/5/2009 5:05:15 AM
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RE:MARPOL Annex VI Fuel oil Quality
Third party analysis of marine fuels is a good practice and can be done in a timely manner. Unfortunately many times agents sit on the samples and they arrive at the lab long after the fuel has started to be consumed. Many bunker suppliers do not take the quality of marine fuels seriously and in many cases BDR's are incomplete. More nneds to be done locally to control the bunker industry particularly now that ECA's are in place. The vessel owner is th one who will have to answer to local authorities if their fuel is non compliant. Let's see what the latest revisions of ISO 8217 will bring.
As to environmental monitorinng? Real time continuous monitoring of stack discharge linked to GPS plotting may be one of the owners best defenses until the issues of distillate fuel quality and use is sorted out.
Remember: The quality of marine fuel and it's proper handling, treatment and use is foremost a matter of marine safety and of course directly related to the maintenance of a healthful and sustainable environment.
Every good seaman has the responsibility to help the environment however, as my father always said. "many go to sea however, few are true seamen". Safe Voyage
Posted: 1/20/2010 7:38:14 PM
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Jon Watson
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RE:MARPOL Annex VI Fuel oil Quality
Ron, it doesn't have to be stack monitoring. That options was discarded early on but I guess it could now be technically feasible.
The alternative solution I have suggested is INtegrity. This uses viscometers to validate the fuel quality certificates.
The problem is that any kind of instrumentation is resisted, not because it is too expensive (the INtegrity solution uses existing fuel heater control viscometers and some barge operators use viscosity for trim control) but because the problems revealed would be expensive to fix and past history has shown that if the supplier passes on the costs to the vessel the vessel bunkers elsewhere.
Logically, if fuels are to be homogenous and segregated one frrom another, necessary to allow the current MARPOL reporting system to function, then suppliers who previously held 380cst fuel in one storage tank now need six tanks. Yes, six. Three for LSHFO and 3 for HSHFO.
The thre tanks would be one for existing stock being run down i.e bunkered, one for new deliveries received and kept separate from the remaining fuel from aprevious batch deelivered, and one for ullage.
Ullage?
Ullage is the amount of fuel left over from a batch that is too little to serve as a full bunker.
It sometimes happens that when bunkering a vessel the barge may have some fuel left over and all they do is load the next consignment on top.
This is shown up by data logging usingg inline isntruments which show a clear density step change one batch to the next.
This can happen on the vessel also.
So how many suppliers have even two storage tanks per fuel type let alone ullage handling faciclities? T aguess I anticipate that that there may be one tank for LSHFO and one for HSHFO and that's it.
Then too, without tank mixing the fuels will stratify and separate over time.
ISO cleary calls for fuels to be homogenous. I'd guess fewer are than we'd like to admit.
This isn't a criticism of the suppliers, it is an obseervation of where the industry has ended up adfter years of no investment and the lack of decisive presecriptive guidelines from the legislators. It is no use exp[ecting suppliers to change decades old practices if no one will pay the extra that it will cost and if no one will ensure universal legislation and enforcement of the fuelr equirements. Nothing puts a bunker supplier more at risk fo going out of business fast than over fussy unilateral regulation.
It is a long road to travel and until the enforcement agencies get some teeth and send a clear message then why shoudl any supplier or vessel insist on the full and prroper implementation?
Posted: 3/13/2010 6:15:10 PM
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