Opinion: North American Emission Control Area - Today
Written by Captain Jeff Cowan
On August 1, 2012, the North American Emissions Control Area (NAECA) took effect, mandating the use of 1.0% or less sulfur Heavy Fuel Oil (HFO) or residual fuel oil for ships within 200 miles of the continent of North America. California has mandated the use of distillate fuel when ships are within 24 miles of its coastline since July 1, 2009.
Lessons learned from California’s experience with the use of distillate fuel may benefit operators as the next phase of NAECA comes into effect, January 01, 2015 when the International Maritime Organization will mandate the use of distillate fuel by ships within 200 miles of the coast of North America. As that time draws near, industry observers have bantered possible manners in which operators will comply.
Since June 2012, several developments have helped the ship operator comply with the August 1 mandate. Foremost, the United States Environmental Protection Agency (EPA) provided an interpretation of fuel requirements. The US EPA stated in guidelines released in June 2012 that the minimum standard for 1.0% sulfur fuel viscosity will be not less than 11 centistokes (cst). This is significant because at the time it was thought ship operators would have a difficult time sourcing the required 1.0% sulfur fuel and have to switch over to low sulfur distillate fuel with its assorted engine compatibility issues - the same issues that California experienced.
California experienced a 300% increase in loss of propulsion incidents since its distillate fuel (viscosity 1-2 cst) regulation came into effect in 2009. The compression ignition (Diesel) engines used aboard modern cargo ships over 10,000 gross tons use 3.0% sulfur HFO. This fuel must be heated to flow through the fuel lines because at normal ambient temperature HFO either low sulfur or high sulfur has the consistency of tar. Distillate fuel in contrast does not require the high temperatures, and the thermodynamics of cooling metal, gaskets and seals resulted in leaks, along with filter clogging from engine buildup scrubbing. In addition, the cost savings of using HFO are significant over the use of distillate fuel which is typically around US$300 more per ton. (Keep in mind before the days of slow speed steaming a typical container ship burned fuel at the rate of 5 to 6 tons per hour!) The 1.0% sulfur HFO must be heated just like the 3.0% HFO so the engine/fuel compatibility issue was solved, at least between 200 to 24 miles off the coast of California.
The US EPA recognized there may be supply problems and allowed ship operators, if the required fuel was not available in ports outside the NAECA, to simply notify primarily the US EPA and Coast Guard no less than 96 hours before entering the NAECA.
Unlike the fuel switchover required 24 miles off the coast of California which typically took one to two hours, the NAECA must switch over completely to the 1.0% sulfur fuel before entering the NAECA. The people at Det Norske Veritas (DNV) and Lloyds have calculators for estimating fuel changeover times to remain in compliance. The use of the calculators should suffice for demonstrating compliance with the 1.0% regulation in terms of a timely switchover.
The Bunker Delivery Note (BDN) supplied with the just loaded bunkers will demonstrate compliance with the 1.0% sulfur rule as well. If the overseeing regime (US EPA) denotes suspicious fuel switch procedures or supply issues, they may take their own sample. The problem with taking a shipboard sample can be any one of several. The ship has no control with the delivery medium which means the bunker oil delivery lines, bunker barge or ship fuel tanks could have residual amounts of the high sulfur fuel leftover that could increase the sulfur content of the oil sample. The other issue is where should the sample be taken within ship engine room that is safe while providing an accurate sample?
At a meeting held in Tacoma, Washington to discuss the NAECA on June 26, 2012. The Coast Guard advised that the LSFO should meet the International Standard Organization (ISO) 4259 standard. This means the sulfur content could deviate in lab analysis results from .94% to 1.06% sulfur and remain in compliance. Meanwhile the US EPA stated low sulfur fuel oil should not exceed the IMO mandated 1.0% sulfur. This determination by the US EPA holds sway over compliance issues. Refinery fuel blenders most probably will take the sulfur percentage to .95% allowing for a 5% margin in lab analysis repeatability.
Sludge burning incinerators: The United States Coast Guard maintains the use of an incinerator to incinerate sludge greater than 1% sulfur content that is generated on board ship is permitted by reg 16 of MARPOL Annex VI including in the Emission Control Area(ECA). But, the US EPA says Reg 14 only applies to the use of fuel oil, so burning sludge in an incinerator is not regulated under Reg 14, but only under Reg 16. Fuel oil and sludge oil are clearly distinguished within the MARPOL definitions. In the spirit of the Emissions Control Area, the EPA would not recommend that a ship burn sludge oil or other sludge with a sulfur content that might exceed 1% within the ECA. Upon further study a consensus will be reached with a final determination.
In order to achieve the 1.0% sulfur content of the Low Sulfur Fuel Oil. Refinery blenders are using low sulfur cutter stocks which tend to have high Aluminum (Al)+Silicone(Si) levels (cat fines). The issue with increased cat fines is the impact to filters and purifiers. With poor preventative maintenance, debris from the filters and purifiers ends up in the high pressure fuel system causing worn pumps and injectors and adverse piston ring and crown groove wear. Equating to more costs for the ship operator.
With California’s regulations in effect, the following scenario may unfold aboard ships trying to comply with IMO and CA regulations. At 200 miles out, the ship will use LSFO with the increased metal wearing cat fines but with good fuel viscosity which is more forgiving to worn parts. Then switch 24 miles out from California to the less forgiving distillate fuel and its well documented increased incidence of loss of propulsion (LOP) incidents. California will continue to face the risk of perhaps at an increased rate of LOP incidents that could cause an oil spill due to an allision, collision or grounding.
About the Author
Captain Jeff Cowan graduated from the California Maritime Academy in 1975, and then began his seagoing career by sailing aboard a variety of vessels. He first sailed as a licensed Third Mate in 1977, ultimately earning his license as Master. He served the merchant marine during Desert Storm. He capped his shipboard career by sailing as Master of his last ship, APL CHINA, in 2009. While sailing for APL, Captain Cowan’s greatest professional accomplishment was to maneuver his ship around typhoons and other heavy weather systems without injuring his crew, damaging his ship or losing any cargo. Since his ship was one of the first at APL to perform the California distillate fuel switchover, he remains very interested in maritime fuel issues.