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Saturday, 11 January 20
ARE YOU 95% CONFIDENT THAT YOUR VERY LOW SULPHUR FUEL IS ON SPEC AND MARPOL COMPLIANT? - GARD
 KNOWLEDGE TO ELEVATE
Bunker fuel is a commodity and, like all commodities, is produced and sold according to specifications. Bunkers are usually tested by suppliers and purchasers to confirm that the they meet the sale specification. Bunkers may also be tested by Flag State or Port State Control authorities to determine if they meet the MARPOL Annex VI sulphur limits.
For residual fuels, the most widely used specification is ISO 8217 Table 2. The Table 2 specification for sulphur content is stated as per “statutory requirements” and, since 1 January 2020, the global MARPOL sulphur limit is 0.50% with lower limits set for SECAs.
In light of these recent regulatory changes we expect sampling and analysis of very low sulphur fuel oil (VLSFO) to receive greater focus. Given the relative cost of fuel components, we also expect that suppliers will blend fuels to achieve a maximum sulphur content that is close to the statutory maximum. This raises the question of how fuels will be tested by suppliers and purchasers under sale contracts and by authorities to determine MARPOL compliance.
In the accompanying article, Dr. Tim Moss and Dr. Daniel Sheard of Brookes Bell explain analytical statistics including the methodology for assessing test results for fuels under ISO 8217 specifications, including sulphur content. As they explain, a sample tested in different laboratories or tested a number of times in the same laboratory will inevitably produce test results with small degrees of difference. To deal with these variances ISO 8217 refers to ISO 4259 “Petroleum and related products — Precision of measurement methods and results”.
ISO 4259 requires that the supplier must not obtain a test result over the required specification limit value. In contrast, for the recipient a single test result above the specification limit but below the ‘limit plus 0.59R’ means the specification has been met.
In our Insight How analytical statistics lead to standard specifications Dr. Moss and Dr. Sheard of Brookes Bell explain that for the charterer or owner who has purchased the fuel, sulphur content at 0.53% meets the 95% confidence limit. This means that a single test result showing up to 0.53 % sulphur may be considered by the purchaser as acceptable evidence that the ISO 8217 specification has been met.
The supplier on the other hand cannot represent the fuel as compliant unless its own test results show no more than 0.50% sulphur content. For the bunker producer/supplier, the IMO recommends that the blend target should not be the actual sulphur limit, but rather the limit minus an appropriate safety margin. For the bunker producer/supplier to ensure that the product meets the specification limit with 95% confidence, the blend target should be the limit minus 0.59R. This means for the supplier, the target for VLSFO should be .47%. See IMO’s guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships.
Fuel verification procedures for MARPOL Annex VI fuel oil samples
At the MEPC 74 meeting in May 2019, IMO approved amendments to the verification procedures for fuel oil samples drawn in accordance with MARPOL Annex VI. These amendments have not yet entered into force, as they have not been adopted, but to ensure a consistent approach to verifying the sulphur limit, IMO has circulated the amendments for early application by Administrations, see MEPC.1/Circ.882 for details.
With the agreed amendments to MARPOL Annex VI, two new statutory samples will be included – the ‘in-use sample’ and the ‘on board sample’. They are defined as “the sample of fuel oil in use on a ship” and “the sample of fuel oil intended to be used or carried for use on board that ship”. It is intended that these samples will be drawn by Port State Control.
Compared to the existing ‘MARPOL delivered sample’, the sample of fuel oil accompanying the bunker delivery note (BDN) and used to verify the sulphur content of the fuel oil as supplied to a ship, these new samples will be used by Port State Control to verify the sulphur content of the fuel currently in use or to be used by the ship.
In-use and on board samples testing procedure
According to the new verification procedures for ‘in-use’ and ‘on board’ samples, the Reproducibility (R) of the test method, in accordance with ISO 4259-2:2017, should be taken into account when assessing the acceptability of a test result. The relevant MEPC guidelines provide:
“The sample should be deemed to meet the requirements provided the test result from the laboratory does not exceed the specification limit +0.59R (where R is the reproducibility of the test method) and no further testing is necessary.”
This means that in-use and on board samples drawn by Port State Control shall be considered acceptable if the sulphur content test result does not exceed 0.53%. Thus, the verification standards for in-use and on board samples should match the analysis method recommended for application under the sale contract.
MARPOL delivered sample testing procedure
The amended Appendix VI contains a different procedure, however, for testing the MARPOL delivered sample. This sample will be tested without taking the Reproducibility (R) of the test method into consideration. This means that there will be no test margin and thus the test result of a MARPOL delivered sample tested (average of two tests by the same laboratory) must not exceed 0.50% m/m sulphur – in other words, a “hard limit”. A test result above 0.50% will provide Port State Control evidence of non-compliance on the part of the supplier that the fuel as supplied does not meet the sulphur limit and that the BDN is therefore not accurate.
The regulatory limit is 0.50% so does a test result at 0.53% put owners at risk of non-compliance?
The amendments to Appendix VI of MARPOL Annex VI ensures that a 95% confidence limit is applicable to balance the testing variances associated with the testing of in-use and onboard samples and will thus help ensure that ship operators are not unfairly penalised for marginal exceedances in sulphur content due to factors beyond their control.
However, instead of drawing and testing in-use or on board samples, authorities can also choose to test the MARPOL delivered sample. So, if a bunker producer/supplier have blended a fuel without applying a proper safety to control its margin on the sulphur content, in practice there is a chance that a fuel that meets the ISO 8217 specification and MARPOL Annex VI under the sale contract could still be found to be non-compliant when re-tested. Certainly, the vessel owner may be considered to have acted in good faith and in reliance of the 95% confidence limit as long as the initial test result at the point of sale showed 0.53% sulphur or less. There is, however, no guarantee that authorities will take such an approach as the verification procedures and enforcement norms have not been tested.
For purchasers including charterers, if a lab analysis shows over 0.53% sulphur content the fuel should be considered to be off-specification under the sale contract and recourse may be available from the supplier. Clearly, careful vetting of suppliers is of increasing importance in this transitional time as it is only the producers and suppliers that have control over the quality of the product they sell.
Source: Gard
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Wednesday, 08 January 20
WHAT IS BIMCO THINKING ABOUT 2020? - BIMCO
Every year, BIMCO considers what is in store for the shipping industry and for BIMCO in the coming years, while also reflecting on the year gone by ...
Wednesday, 08 January 20
VINACOMIN SETS TO SELL 49 MILLION TONNES OF COAL IN 2020 - VIETNAM NET
The Vietnam National Coal-Mineral Industries Holding Corporation Limited (Vinacomin) has set to sell 49 million tonnes of coal in 2020, a year-on-y ...
Wednesday, 08 January 20
CHINA'S COAL-RICH PROVINCE CUTS 18.95 MLN TONNES OF CAPACITY IN 2019 - XINHUA
North China’s Shanxi Province reduced its coal production capacity by 18.95 million tonnes by closing 18 coal mines in 2019.
A ...
Wednesday, 08 January 20
JANUARY INDONESIAN COAL PRICE REFERENCE SLIPS US$ 0.37 MOM
COALspot.com: The Ministry of Energy and Mineral Resources of the Republic of Indonesia has revised down the benchmark price of Indonesian thermal ...
Tuesday, 07 January 20
CLEANER AIR IN 2020: 0.5% SULPHUR CAP FOR SHIPS ENTERS INTO FORCE WORLDWIDE - EUROPEAN COMMISSION
From 1 January 2020, the maximum sulphur content of marine fuels is reduced to 0.5% (down from 3.5%) globally – reducing air pollution and pr ...
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Showing 1206 to 1210 news of total 6871 |
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- GAC Shipping (India) Pvt Ltd
- Chamber of Mines of South Africa
- Edison Trading Spa - Italy
- Thiess Contractors Indonesia
- Bhoruka Overseas - Indonesia
- Bhushan Steel Limited - India
- Mercator Lines Limited - India
- Australian Commodity Traders Exchange
- Renaissance Capital - South Africa
- IEA Clean Coal Centre - UK
- Videocon Industries ltd - India
- Coalindo Energy - Indonesia
- Salva Resources Pvt Ltd - India
- Wood Mackenzie - Singapore
- Indogreen Group - Indonesia
- VISA Power Limited - India
- Vedanta Resources Plc - India
- Toyota Tsusho Corporation, Japan
- India Bulls Power Limited - India
- Semirara Mining Corp, Philippines
- Kapuas Tunggal Persada - Indonesia
- Deloitte Consulting - India
- Petrochimia International Co. Ltd.- Taiwan
- Dr Ramakrishna Prasad Power Pvt Ltd - India
- Karaikal Port Pvt Ltd - India
- PowerSource Philippines DevCo
- Aboitiz Power Corporation - Philippines
- AsiaOL BioFuels Corp., Philippines
- Vijayanagar Sugar Pvt Ltd - India
- Vizag Seaport Private Limited - India
- London Commodity Brokers - England
- Metalloyd Limited - United Kingdom
- Aditya Birla Group - India
- Port Waratah Coal Services - Australia
- Central Electricity Authority - India
- Sree Jayajothi Cements Limited - India
- Essar Steel Hazira Ltd - India
- SMC Global Power, Philippines
- Sarangani Energy Corporation, Philippines
- TeaM Sual Corporation - Philippines
- McConnell Dowell - Australia
- Timah Investasi Mineral - Indoneisa
- Coal and Oil Company - UAE
- Rio Tinto Coal - Australia
- Chettinad Cement Corporation Ltd - India
- Borneo Indobara - Indonesia
- Ind-Barath Power Infra Limited - India
- OPG Power Generation Pvt Ltd - India
- Savvy Resources Ltd - HongKong
- Cigading International Bulk Terminal - Indonesia
- Star Paper Mills Limited - India
- Kumho Petrochemical, South Korea
- Mjunction Services Limited - India
- Barasentosa Lestari - Indonesia
- Simpson Spence & Young - Indonesia
- Iligan Light & Power Inc, Philippines
- Karbindo Abesyapradhi - Indoneisa
- Asmin Koalindo Tuhup - Indonesia
- Bulk Trading Sa - Switzerland
- Mintek Dendrill Indonesia
- LBH Netherlands Bv - Netherlands
- PetroVietnam Power Coal Import and Supply Company
- Siam City Cement PLC, Thailand
- Indo Tambangraya Megah - Indonesia
- Coastal Gujarat Power Limited - India
- Indian Oil Corporation Limited
- PTC India Limited - India
- Anglo American - United Kingdom
- Krishnapatnam Port Company Ltd. - India
- The State Trading Corporation of India Ltd
- Bahari Cakrawala Sebuku - Indonesia
- Kideco Jaya Agung - Indonesia
- Kepco SPC Power Corporation, Philippines
- Energy Link Ltd, New Zealand
- MS Steel International - UAE
- Electricity Generating Authority of Thailand
- Baramulti Group, Indonesia
- Orica Australia Pty. Ltd.
- Heidelberg Cement - Germany
- Siam City Cement - Thailand
- Rashtriya Ispat Nigam Limited - India
- Global Green Power PLC Corporation, Philippines
- ASAPP Information Group - India
- Kaltim Prima Coal - Indonesia
- Alfred C Toepfer International GmbH - Germany
- Interocean Group of Companies - India
- The University of Queensland
- Posco Energy - South Korea
- Marubeni Corporation - India
- Sinarmas Energy and Mining - Indonesia
- Banpu Public Company Limited - Thailand
- Carbofer General Trading SA - India
- Cement Manufacturers Association - India
- Sindya Power Generating Company Private Ltd
- Thai Mozambique Logistica
- Petron Corporation, Philippines
- Trasteel International SA, Italy
- Therma Luzon, Inc, Philippines
- Asia Pacific Energy Resources Ventures Inc, Philippines
- Eastern Coal Council - USA
- Riau Bara Harum - Indonesia
- GN Power Mariveles Coal Plant, Philippines
- Ambuja Cements Ltd - India
- Bukit Asam (Persero) Tbk - Indonesia
- Eastern Energy - Thailand
- Neyveli Lignite Corporation Ltd, - India
- CIMB Investment Bank - Malaysia
- Globalindo Alam Lestari - Indonesia
- SMG Consultants - Indonesia
- Billiton Holdings Pty Ltd - Australia
- CNBM International Corporation - China
- Straits Asia Resources Limited - Singapore
- Lanco Infratech Ltd - India
- Standard Chartered Bank - UAE
- Dalmia Cement Bharat India
- Dong Bac Coal Mineral Investment Coporation - Vietnam
- Global Coal Blending Company Limited - Australia
- Oldendorff Carriers - Singapore
- Truba Alam Manunggal Engineering.Tbk - Indonesia
- Pipit Mutiara Jaya. PT, Indonesia
- Minerals Council of Australia
- Central Java Power - Indonesia
- Manunggal Multi Energi - Indonesia
- Planning Commission, India
- Semirara Mining and Power Corporation, Philippines
- Mercuria Energy - Indonesia
- South Luzon Thermal Energy Corporation
- Energy Development Corp, Philippines
- Georgia Ports Authority, United States
- GMR Energy Limited - India
- Power Finance Corporation Ltd., India
- Economic Council, Georgia
- Jorong Barutama Greston.PT - Indonesia
- Jaiprakash Power Ventures ltd
- Meenaskhi Energy Private Limited - India
- SN Aboitiz Power Inc, Philippines
- Wilmar Investment Holdings
- Filglen & Citicon Mining (HK) Ltd - Hong Kong
- Kohat Cement Company Ltd. - Pakistan
- Latin American Coal - Colombia
- Bhatia International Limited - India
- Ministry of Transport, Egypt
- Gujarat Mineral Development Corp Ltd - India
- Ceylon Electricity Board - Sri Lanka
- Tamil Nadu electricity Board
- Miang Besar Coal Terminal - Indonesia
- Singapore Mercantile Exchange
- Parliament of New Zealand
- Indian Energy Exchange, India
- ICICI Bank Limited - India
- Bukit Makmur.PT - Indonesia
- Directorate Of Revenue Intelligence - India
- Madhucon Powers Ltd - India
- Uttam Galva Steels Limited - India
- Antam Resourcindo - Indonesia
- GVK Power & Infra Limited - India
- Binh Thuan Hamico - Vietnam
- Australian Coal Association
- International Coal Ventures Pvt Ltd - India
- Pendopo Energi Batubara - Indonesia
- Larsen & Toubro Limited - India
- Xindia Steels Limited - India
- Ministry of Finance - Indonesia
- Bangladesh Power Developement Board
- Global Business Power Corporation, Philippines
- TNB Fuel Sdn Bhd - Malaysia
- Sakthi Sugars Limited - India
- Agrawal Coal Company - India
- Sojitz Corporation - Japan
- White Energy Company Limited
- Ministry of Mines - Canada
- Bharathi Cement Corporation - India
- Electricity Authority, New Zealand
- Intertek Mineral Services - Indonesia
- European Bulk Services B.V. - Netherlands
- Bayan Resources Tbk. - Indonesia
- Parry Sugars Refinery, India
- Maharashtra Electricity Regulatory Commission - India
- Africa Commodities Group - South Africa
- Medco Energi Mining Internasional
- Jindal Steel & Power Ltd - India
- Formosa Plastics Group - Taiwan
- Malabar Cements Ltd - India
- Sical Logistics Limited - India
- Holcim Trading Pte Ltd - Singapore
- Gujarat Sidhee Cement - India
- Romanian Commodities Exchange
- Grasim Industreis Ltd - India
- Kobexindo Tractors - Indoneisa
- Commonwealth Bank - Australia
- Orica Mining Services - Indonesia
- Merrill Lynch Commodities Europe
- Goldman Sachs - Singapore
- Gujarat Electricity Regulatory Commission - India
- Bank of Tokyo Mitsubishi UFJ Ltd
- Kartika Selabumi Mining - Indonesia
- PNOC Exploration Corporation - Philippines
- San Jose City I Power Corp, Philippines
- Indonesian Coal Mining Association
- Bukit Baiduri Energy - Indonesia
- Meralco Power Generation, Philippines
- Price Waterhouse Coopers - Russia
- Tata Chemicals Ltd - India
- Indika Energy - Indonesia
- Attock Cement Pakistan Limited
- Independent Power Producers Association of India
- Makarim & Taira - Indonesia
- Samtan Co., Ltd - South Korea
- Leighton Contractors Pty Ltd - Australia
- IHS Mccloskey Coal Group - USA
- New Zealand Coal & Carbon
- Altura Mining Limited, Indonesia
- Kalimantan Lumbung Energi - Indonesia
- Offshore Bulk Terminal Pte Ltd, Singapore
- The Treasury - Australian Government
- Maheswari Brothers Coal Limited - India
- Directorate General of MIneral and Coal - Indonesia
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