By Rajiv Malhotra, Technical Manager
To comply with the forthcoming Sulphur Cap regulations, scrubbers offer the ability to use conventional high sulphur fuels (expected to have lower costs than low-sulphur fuels), and consequently a significant return on investment, in spite of the extensive capital expense increased maintenance costs and overall fuel consumption. However, only a small fraction of vessels are presently adopting the solution, due to extent of preparations and initial costs needed for scrubber installation, uncertainty about vessel owners’ ability to recover the investment if they are not the fuel purchasers, and the possibility of the prohibition of scrubbers use (mainly open loop type) in increasing number of ports and coastal areas.
Efficient fuel management will be important to ensure compliance for the majority of the vessels which will rely on usage of compliant fuels having a sulphur content below 0.5%. Challenges arise not only from the need of the alignment of procedures, systems, familiarisation of ships’ crews and shore staff with the requirements of the new regulation, but also from the uncertainty about costs, quality and availability of compliant fuels. Careful identification of the requirements in the vessel specific Ship Implementation Plans, and regular following up on the outlined measures, is therefore vital.
To avoid unforeseen problems, managers, ship owners and charterers need to ensure that all steps are well co-ordinated and completed in a timely fashion, including the stripping and preparation of high sulphur fuel tanks, bunkering of compliant fuel, and commencement of its consumption, preferably by early December 2019. In any cases of an inability to comply with the deadline, a Fuel Oil Non Availability Report will only be accepted by the port state control if supporting evidence is supplied regarding the diligent efforts made to procuring compliant fuel.
For distillate type compliant fuels to be used for long periods; low lubricity, low viscosity, low flash point and cold flow properties (due to paraffinic content) will need to be tackled appropriately.
While vessels trading in the ECA are already prepared for this, other vessels will need to evaluate the requirements for the installation of coolers, modification of boiler combustion control system, a review of procedures for bunker testing and dosing additives for lubricity, and a thorough review of practices in relation to performance monitoring, planned maintenance and minimum spares stock.
Non-distillate grade compliant fuels are expected to be available in a wide range of compositions varying from source to source, which poses concerns about compatibility, and the presence of undesirable contaminants and cat fines. Strong procedures need to be enforced to prevent co-mingling, with enhanced testing of bunker samples and fuel system check samples to be carried out and maintaining stability enhancement additives for dosing whenever needed. Due to the low tolerance of co-mingling, and the consequent inability to load bunkers on top of existing bunkers on board, the bunker intake capacity may belimited, further highlighting the need for closer co-ordination of all parties for efficient bunker procurement.
Viewing the uncertainties related to the marine fuel market, vessels will also need to maintain the flexibility to use any type of compliant fuel (distillate, blended or residual) through strong procedures of fuel management and segregation. Usage of appropriate lubricants of a lower base number would need to be implemented in conjunction with low sulphur fuel consumption, irrespective of the fuel grade.