A FINAL CHECK! BEFORE THE IMPLEMENTATION OF IMO 2020

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With less than 15 days to go before the implementation of much anticipated IMO 2020, it has been estimated that around 93% of the world fleet will burn maximum 0.50% sulphur compliant fuels outside ECA-SOx from 1st of January 2020. Demonstrating compliance with the MARPOL Annex VI regulation 14 and maintaining trouble free operations during consumption of these new 0.50% sulphur fuels are the key challenges. There have been numerous publications and guidance documents available covering large spectrum of IMO 2020 issues. The intention of this bulletin is not to repeat all what is in those guidelines but just to present a quick reference table to highlight some of the key issues.

  1. Stability & commingling

Risks

Sludging in tanks, purifier and filters due to mixing of incompatible fuels or unstable fuels as delivered.

Look into

Prepare segregation/capacity plan, open dialogue with charterers ensuring risks are mitigated, compatibility testing at various mixing ratios

2. Onboard viscosity control

Risks

Overheating and/or underheating

Look into

Functionality of viscosity control, tank heating, OEM guidance (boiler, engine, pumps)

3. Cold flow property

Risks

Wax deposition in tanks, filter blockage, sludge generation at purifier

Look into

Gain prior information on fuel’s cold flow characteristics from supplier to suit operating conditions (winter/summer) and storage/system heating capacity. Seek further information through suitable fuel testing.

4. Experience on variable quality fuels

Risks

Breakdowns, damage to equipment, excessive equipment wear to probable reduced TBO (time between overhaul)

Look into

Crew training, gain experience by switching to new blends prior to deadline, review change over procedures. Start consumption once fuel analysis report is available

5. Lubricants

Risks

Inappropriate base number and/or cylinder oil feed rate (2-stroke engines).

Look into

Contact lubricant supplier and seek OEM guidance

6. Sampling points

Risks

Unrepresentative ‘in-use’ sample potentially leading to non-compliance

Look into

Designate a suitable sampling point as per guidelines (MEPC.1/Circ.864).

7. Tank preparations

Risks

Contamination with previous fuels/sludge carry over, number of settling/service tanks.

Look into

Carry out condition assessment and subsequent tank cleaning.

8. Ordering 0.50% fuels

Risks

Fuel not fit for use i.e. machinery limitation not considered and/or regulatory non-compliance.

Look into

Consult latest OEM guidelines, ISO 8217:2017 and PAS 23263, buy from reputable supplier (price before quality), Check CoQ (know your fuel).

9. Sulphur compliance

Risks

Detention, penalties, strict PSC inspections

Look into

Be transparent and establish clear lines of communication to report any irregularities to administration and PSC. Contact FOBAS for further guidance.

10. Fuel conditioning

Risks

Non-optimal purifier settings, carry over of sediments to critical machinery equipment.

Look into

Purifier guidance, optimal temp/flow requirements, filter cleaning/standby, frequent draining of settling tanks.

11. Combustion

Risks

Engine knocking, turbo charger surging, excessive deposit on piston ring pack

Look into

Adjust engine settings by taking electronic power / draw cards. FIA analysis to determine ECN and suitability for a particular combustion unit. OEM guidelines.

12. Contamination

Risks

Presence of anomalous/acidic components in fuel at a level to cause degradation to fuel system performance

Look into

FOBAS can perform detailed chemical analyses to eliminate the possibility of the presence of anomalous components in the fuel. Supplier to provide assurances. Follow best practice of evidence collection in case of operational problems.

It is expected that the ships who performed a comprehensive SIP (Ship Implementation Plan) are well placed and above-mentioned points should have already been considered and suitable actions taken.