New Sulphur Limits in Marine Fuels

NEW SULPHUR
LIMITS IN MARINE
FUELS
-
LEGISLATIVE BACKGROUND,
HAZARD IDENTIFICATION (HAZID)
ANALYSIS,
FLEET RETROFIT PLAN,
INSTRUCTIONS AND TRAINING FOR CREW
-
DECEMBER 2009
GESTIONI ARMATORIALI SpA

Via A. Depretis, 114 – 80133 Napoli - Italy
Via Magazzini Posteriori, 55 F-G - 48100 Ravenna – Italy
Pag. 1
SUMMARY
SECTION 1: LEGISLATIVE BACKGROUND
SECTION 2: HAZARD IDENTIFICATION (HAZID) ANALYSIS
SECTION 3: FLEET RETROFIT PLAN
SECTION 4: CREW TRAINING AND FAMILIARIZATION

Pag. 2
SECTION 1
LEGISLATIVE BACKGROUND
Abstract from International and Local Legislation relevant to the Sulphur control
for International shipping.
1.1 Revised MARPOL Annex VI – 2008
The Sulphur content of any fuel used globally shall not exceed:
- 4,50% mm S prior to 1 January 2012

- 3,50% mm S on and after 1 January 2012
The Sulphur content of any fuel oil used in designated Emission Control Areas
(ECA) shall not exceed:
- 1,50% mm S prior to 1 July 2010

- 1,00% mm S on and after 1 July 2010

Pag. 3
1.2 California Air Resources Board (CARB)
17 CCR, Section 93118.2, Title 17: Airborne Toxic Control measure for Fuel
Sulphur and other operational requirements for ocean-going vessels within
Californian waters and 24 nautical miles of the Californian Baseline.
Phase 1 1 July 2009:

Marine gasoil (DMA) at or below 1,5% Sulphur; or marine diesel oil (DMB) at or
below 0,5% sulphur.
Phase 2 1 January 2012:

Marine gasoil (DMA) or marine diesel oil (DMB) at or below 0,1% sulphur.

Pag. 4
1.3 European Union (EU)
Council Directive 1999/32/EC of 26/4/1999 relating to a reduction in the sulphur

content of certain liquid fuels and amending Directive 93/12/EEC, amended by
Directive 2005/33/EC.
As from 1 January 2010, ships at berth (*) for longer than 2 hours within ports
in the European Union are required to switch to 0,1% sulphur content marine
fuel oil under Article 4b of Directive 2005/33/EC.
(*) A ship anchored within the port limits of a EU port is required to comply with
the provisions for “ships at berth” in Article 4b(1)(b) of the Directive.
European Community State Members where the Directive 2005/33/EC is

applicable as from 1 January 2010:

Pag. 5
Belgium, Bulgaria, Cyprus, Denmark, Estonia, Finland, France, Germany,
Greece, Ireland, Italy, Latvia, Lithuania, Malta, Netherlands, Poland, Portugal,
Romania, Slovenia, Spain, Sweden, United Kingdom. (French Overseas
Territories, Azores Islands, Canary Islands and Madeira are excluded from the
Directive).

Pag. 6
1.4 Operational requirements approaching ports in the European
Union related to Fuel change-over
Destination: Port inside an ECA (Emission Control Area)

- Global cap: 4,5% (3,5% from 1/1/2012) Sulphur, Heavy Fuel Oil, heated
- ECA: 1,5% (1,0% from 1/7/2010) Heavy Fuel or Distillate Oil, heated or
unheated
- At berth: 0,1% Sulphur, Low Sulphur Distillate Oil, unheated or cooled
(not applicable to main engine)
Destination: Port outside ECA (Emission Control Area)

- Global cap: 4,5% (3,5% from 1/1/2012) Sulphur, Heavy Fuel Oil, heated
- At berth: 0,1% Sulphur, Low Sulphur Distillate Oil, unheated or cooled
(not applicable to main engine).
****

Pag. 7
SECTION 2
HAZARD IDENTIFICATION (HAZID) ANALYSIS
2.1 Considerations on Low Sulphur Distillate Oil

In general the following items should be observed with respect to fuel properties of
a low sulphur distillate oil intended to be used to meet the sulphur requirements
mentioned in section 1.
- Lubricity: generally LSMGO has lower lubricating properties which when

coupled with reduced viscosity can lead to reduced performance and
abnormal wear conditions of fuel injection and gear type pumps
- Viscosity: low sulphur marine gasoil (LSMGO) has much lower viscosity
range than heavy fuel oil (HFO) which may have an impact on fuel pumps
designed to operate with HFO. Fuel oil cooler might be necessary in the fuel
supply system. According to the current revision of ISO 8217 the minimum
viscosity @ 40°C for DMA and DMB is 2,0 mm 2/s (cSt), only for DMX the
minimum is 1,4 mm2/s (cSt).
- Density: LSMGO has lower density than HFO. This may require that the
amount of fuel to the burner will differ from the original pre-set amount. Most
marine installations have the oil amount pre-adjusted based on a
calculation of the main fuel (i.e. HFO) which takes its density into account.
Failure to re-adjust the oil quantity to the burner for the LSMGO may lead to
loss of power, ignition problems and/or increase of smoke emissions.
- Compatibility: solubility of asphaltenes has to be considered during the
change over process.
- Addition of bio fuels (FAME): could create additional problems
(compatibility, stability, fouling, hygroscopy.)
- Flashpoint: SOLAS II-2, Reg.4, 2.1.1 requires minimum flashpoint 60°C.

Pag. 8
2.2 Items to be assessed
With regard to change-over and to long term use of LSMGO, the following items
are to be assessed:
Fuel storage capacity and segregation
Fuel pumps
Piping systems
Flame detection devices
Boilers and burners
2.2.1 Fuel Storage Capacity and Segregation

The vessels are already provided with segregated Diesel oil tanks (storage,
settling and service) which have been now dedicated to Gasoil.
As far as the capacity is concerned, see the following table:
Mv Felix G and Carlos G 199 MT (234 m3)

Mv Rose G and Ray G 205 MT (241 m3)
Mv Mare di Ravenna, Mare di Napoli,
201 MT (236 m3)
Mare di Venezia and Mare di Genova
Mv Chaitali Prem and Italic G 215 MT (254 m3)
Considering the maximum fuel consumption in port of the oil tankers (full rate
discharge and inert gas) of approximately 15 MT/day, the vessels have enough
LSMGO for approximately 13 days.
During loading operations of the oil tankers the consumption is reduced to
approximately 7 MT/day, equal to more than 28 days in Port.
In port, the average consumption of the bulk carriers is approximately 5 MT/day
equal to 43 days in Port.

Pag. 9
Therefore, we deem that the present capacity of the LSMGO on our fleet is
sufficient for the whole operation of the ships in port. However, if necessary, timely
supply of LSMGO will be arranged.
2.2.2 Fuel Pumps

The main engine maker (MAN B&W), in order to ensure a satisfactory
hydrodynamic film between fuel oil plunger and barrel, recommends keeping the
fuel oil viscosity at minimum 2 cSt. Moreover, they recommend a temperature
gradiant at change over of maximum 2 °C per minute.
The auxiliary engine maker (MAN Holeby) recommends keeping the fuel oil
viscosity at minimum 1,5 cSt.
The boiler maker (Aalborg) recommends keeping the fuel oil viscosity at a
minimum of 3 cSt.
In the light of above, in order to keep the gasoil temperature as low as possible
and then increase its viscosity, we are installing on board one or two gasoil
coolers.
2.2.3 Piping systems

Apart from the gasoil and fresh water low temperature circuits modifications
necessary for the installation of the gasoil coolers, no other modification are
deemed necessary.
2.2.4 Flame detection system

All the auxiliary boilers fitted on board our vessels, are already equipped with three
flame detectors, one on the ignition burner and two on the main burner flame.

Pag. 10
2.2.5 Boilers and burners
The auxiliary boilers installed on our vessels are equipped with steam atomizing
burner which, in accordance with maker instructions, have already switched to air
atomizing in order to keep the gasoil temperature as low as possible. We are also
considering to install new modified lances.
As made for the diesel engines, in order to keep the gasoil temperature as low as
possible and then increase its viscosity, we are installing on board one gasoil
cooler.
According to the maker, the composite boilers installed on our vessels are already
suitable to operate on LSMGO.
For both the auxiliary and composite boilers it should be necessary to make some
adjustments on the combustion control and post-purge of the furnace when using
LSMGO.
See attached Form 4-01 Hazard Identification Analysis
*****

Pag. 11
SECTION 3
FLEET RETROFIT PLAN
3.1 Mv FELIX G, CARLOS G
Main engine: MAN B&W 6S50 Mk 6

- Gasoil cooler to be installed
Auxiliary engines: MAN 6L23/30 H

Auxiliary boiler: AALBORG Mission OL 2000

- Lance to be replaced
- Combustion control to be adjusted
- Post purge of the furnace to be increased
3.2 Mv ROSE G, RAY G
Main engine: MAN B&W 7S50 MC-C




Pag. 12
Composite boiler: AALBORG AQ2
3.3 Mv MARE DI RAVENNA, MARE DI NAPOLI, MARE DI VENEZIA, MARE

DI GENOVA



Composite boiler: AALBORG Mission OC 1500

3.4 Mv CHAITALI PREM, ITALIC G


Composite boiler: AALBORG Mission OC 1800

*****

Pag. 13
SECTION 4
CREW TRAINING AND FAMILIARIZATION
4.1 Familiarization of the crew
In December 2009, all fleet vessels have been requested to carry out a real test of
the main engine, auxiliary engines and boilers fed by gasoil.
The scope of the test, apart from the familiarization of the crew with the change-
over procedure, was to actually verify the suitability of the machineries to run at
gasoil. The tests were performed satisfactorily without problems.
4.2 Change-over basic instructions
Within two hours from the arrival in a EU Port, the DD/GG and boilers fuel
supply should be changed to gasoil (0,1% Sulphur) and such operation
should be recorded on the log books (Giornale generale di contabilita’ parte
II and Giornale di Macchina for Italian flagged vessels).
On vessel departure from a EU Port the DD/GG and boilers fuel supply
should be changed again to HFO.
The main engine should be supplied with HFO during the arrival and
departure manoeuvres.
The gasoil (0,1% sulphur) quantity on board should be sufficient for all the
expected period in Port.
During the operation of the DD/GG and boilers with gasoil, the fuel heater
should be closed and the gasoil cooler put in service.
The Technical Department is at disposal for any further information the crew may
need and is also considering to issue a Technical Circular to better define the
change over procedure.
*****
Pag. 14

New Sulphur Limits in Marine Fuels

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NEW SULPHUR

GESTIONI ARMATORIALI SpA

SECTION 1: LEGISLATIVE BACKGROUND

SECTION 2: HAZARD IDENTIFICATION (HAZID) ANALYSIS

SECTION 3: FLEET RETROFIT PLAN

SECTION 4: CREW TRAINING AND FAMILIARIZATION

GESTIONI ARMATORIALI SpA

1.1 Revised MARPOL Annex VI – 2008

- 4,50% mm S prior to 1 January 2012

- 1,50% mm S prior to 1 July 2010

GESTIONI ARMATORIALI SpA

Phase 1 1 July 2009:

Phase 2 1 January 2012:

GESTIONI ARMATORIALI SpA

Council Directive 1999/32/EC of 26/4/1999 relating to a reduction in the sulphur

European Community State Members where the Directive 2005/33/EC is

GESTIONI ARMATORIALI SpA

Greece, Ireland, Italy, Latvia, Lithuania, Malta, Netherlands, Poland, Portugal,

Romania, Slovenia, Spain, Sweden, United Kingdom. (French Overseas

GESTIONI ARMATORIALI SpA

Destination: Port inside an ECA (Emission Control Area)

Destination: Port outside ECA (Emission Control Area)

GESTIONI ARMATORIALI SpA

2.1 Considerations on Low Sulphur Distillate Oil

- Lubricity: generally LSMGO has lower lubricating properties which when

GESTIONI ARMATORIALI SpA

2.2.1 Fuel Storage Capacity and Segregation

As far as the capacity is concerned, see the following table:

Mv Felix G and Carlos G 199 MT (234 m3)

GESTIONI ARMATORIALI SpA

2.2.2 Fuel Pumps

2.2.3 Piping systems

2.2.4 Flame detection system

GESTIONI ARMATORIALI SpA

See attached Form 4-01 Hazard Identification Analysis

GESTIONI ARMATORIALI SpA

3.1 Mv FELIX G, CARLOS G

Main engine: MAN B&W 6S50 Mk 6

Auxiliary engines: MAN 6L23/30 H

Auxiliary boiler: AALBORG Mission OL 2000

3.2 Mv ROSE G, RAY G

Main engine: MAN B&W 7S50 MC-C

Auxiliary engines: MAN 6L23/30 H

Auxiliary boiler: AALBORG Mission OL 20000

GESTIONI ARMATORIALI SpA

3.3 Mv MARE DI RAVENNA, MARE DI NAPOLI, MARE DI VENEZIA, MARE

Main engine: MAN B&W 7S50 MC-C

Auxiliary engines: MAN 6L23/30 H

Auxiliary boiler: AALBORG Mission OL 18000

Composite boiler: AALBORG Mission OC 1500

3.4 Mv CHAITALI PREM, ITALIC G

Main engine: MAN B&W 6S60 MC-C

Auxiliary engines: MAN 6L23/30 H

Composite boiler: AALBORG Mission OC 1800

GESTIONI ARMATORIALI SpA

4.1 Familiarization of the crew

4.2 Change-over basic instructions

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