Leading the way; making a difference

North American Panel October 29, 2014

AIR EMISSIONS/FUEL QUALITY

JOSEPH ANGELODEPUTY MANAGING DIRECTOR

Leading the way; making a difference

Sulphur Oxide (SOX)

Nitrogen Oxide (NOX)

Fuel Quality

Leading the way; making a difference

AIR EMISSIONS - SOX

GloballyCurrently – 3.50%After Jan 1, 2020 (or 2025) – 0.50%

ECA (NA, Caribbean, Baltic Sea, North Sea)Currently – 1.00%After Jan 1, 2015 – 0.10%

European Union DirectiveFollows IMO except:Currently – 0.10% “at berth”After Jan 1, 2020 – 0.50% in EU waters

California After Jan 1, 2014 – 0.10% (24 miles)Non-compliance fee in lieu

Leading the way; making a difference

Availability

• Low Sulphur MGO expected to be available• Possible local shortages during initial stages• Expected hike in price during initial stages• Premium expected to keep constant at about $300 - $350 per ton• INTERTANKO ECA Guidance/ECA Calculator

AIR EMISSIONS - SOX

Leading the way; making a difference

Operational Aspects

•Fuel switching•Fuel segregation/contamination•Incompatibility - fuel filter blockages•Low viscosity – leaks & loss in pressure•Low lubricity - pump seizure•Cloud point temperature

AIR EMISSIONS - SOX

Leading the way; making a difference

Guidance to assist ship operators

• INTERTANKO/OCIMF Recommendations on Fuel Change Over Procedures

• API Technical Considerations for Fuel Switching

• CIMAC Guideline for Operation of Marine Engines on Low Sulphur Diesel

AIR EMISSIONS - SOX

Leading the way; making a difference

EnforcementUSCG conducts PSC, refers non-compliance deficiencies to EPA for enforcement actionEPA is responsible for determining the appropriate enforcement/compliance action if a ship does not comply with the ECA requirements

USCG Advice•Ensure that all relevant equipment on board is capable of handling ECA fuel•Any modifications necessary are put in place and tested well before the deadline•Review contracts with fuel suppliers to ensure an adequate supply of ECA fuel

AIR EMISSIONS - SOX

Leading the way; making a difference

AIR EMISSIONS - SOX

USCG Procedure

•USCG boards a ship during a normal annual PSC exam to check for compliance with ECA requirements•USCG does not currently conduct a special “ECA compliance” boarding to determine is the ship complies with ECA requirements. However….•The check for ECA compliance involves verifying the sulphur content on the Bunker Delivery Note (BDN) and reviewing the ship’s log book. If both are in order, no further action is taken. If either raise a concern with the inspector, a more detailed examination will be conducted

Leading the way; making a difference

Ship must use compliant fuel when operating in ECA• If a ship owner is not able to obtain compliant fuel due to non-availability, a Fuel Oil Non-Availability Report (FONAR) must be submitted

• FONAR is not a waiver, it is a statement of non- compliance

• Four companies that have submitted a number of FONARs have been issued subpoenas by EPA

• If Bunker Delivery Note (BDN) and independent test differ, Notice of Protest (NOP) should be submitted

AIR EMISSIONS - SOX

Leading the way; making a difference

AIR EMISSIONS - SOX

Leading the way; making a difference

AIR EMISSIONS - SOX

FONAR: Where vessels are coming from

Leading the way; making a difference

AIR EMISSIONS - SOX

FONAR: Where vessels are going to in NA

Leading the way; making a difference

California Air Resources Board (CARB)Marine Notice 2014-1

•NA ECA requirements different than CARB OGV regs - ECA allows the use of scrubbers - CARB requires fuels that meet specs for distillates•Will allow ships to comply with OGV regs by complying with ECA requirements under Temporary Experimental or Research Exemption•Ship operator must submit form to CARB to satisfy Research Exemption requirements•Will evaluation emissions reductions under ECA requirements (estimated completion April 2015) to determine if “sunset provision” has been met

AIR EMISSIONS - SOX

Leading the way; making a difference

Paris MOU Enforcement•Will implement requirements of Annex VI, not EU Sulphur Directive•Initial inspection – BDN, Reg 18(8) fuel sample and written procedures/records of change over•For ships operating in cold climates, existing pipelines are checked for location or appropriate heating facilities•If any of the above indicate possible non-compliance, a more detailed inspection will be conducted

AIR EMISSIONS - SOX

Leading the way; making a difference

NOx Tier III requirements in NECAs 1.At MEPC 65 (May 2013) Russia proposes, and the MEPC agrees, to delay enforcement of the NOx Tier III NECA requirements from 1 Jan 2016 to 1 Jan 2021

2. MEPC 66 (April 2014) decides the NOx Tier III enforcement date of 1 January 2016 is retained for already designated NECAs (i.e. the North American and US Caribbean)3. The enforcement date for future NECAs that may be submitted to the MEPC for approval would be the date of adoption of a new NECA.

AIR EMISSIONS - NOx

Leading the way; making a difference

What does this mean?1. New ships trading to North American and Caribbean NECAs and have the keel laid on and after 1 January 2016 should be built to meet NOx Tier III emissions limits. New ships that do not consider trading to the current NECAs will not need to be built to comply with the NOx Tier III emissions limits.

2. Each time a new NECA is to be approved, new ships with the keel laid on and after the date of adoption of a new NECA would need to be built to comply with NOx Tier III emissions limits to be able to trade in such new NECAs.

3. There will be no retroactive application of the NOx Tier III requirements to ships whose keels are laid before 1 January 2016 trading in the North American or Caribbean NECAs or before the date of adoption of any new NECAs that are established in the future.

AIR EMISSIONS - NOx

Leading the way; making a difference

FUEL OIL QUALITY

Reg. 18, MARPOL Annex VIFuel Oil Availability and Quality

Fuel oil . . . shall meet the following requirements:• shall be blends of hydrocarbons derived from petroleum refining• shall be free from inorganic acid• shall not include any added substance or chemical waste which:

- jeopardizes the safety of ships or adversely affects the performance of the machinery, or- is harmful to personnel, or- contributes overall to additional air pollution

Leading the way; making a difference

FUEL OIL QUALITY

• In many cases fuels delivered do not meet the specification requirements, including sulphur content

• Blending to LSFO < 1.0% results in lower quality, e.g.: - Increased average density (higher price for same

volume)- Increased average catfines level (Al+Si)- Increase in sludging problems- Reduced ignition and combustion quality- Increased problems with chemical contamination

Leading the way; making a difference

FUEL OIL QUALITY

Norway and INTERTANKO collected data from two fuel testing laboratories which together had more that 50% of all bunker deliveries worldwide • Out of over 100,000 bunker samples, the receiving vessels have reported that on 1,468 occasions they have had machinery problems as a result of using the fuels as supplied.• These were events resulting in machinery damage and black out events

Leading the way; making a difference

FUEL OIL QUALITY

• Fuel oil quality for ships is regulated under Regulations 14 and 18 of MARPOL Annex VI• However, the requirements are placed upon the ship to ensure that the fuel used on board the ship complies with these standards• If the ship is found to be using fuel oil that is not in compliance with these standards, it is the ship and the ship operator that suffers the consequences of port state control action and penalties under national laws • There are no requirements on the fuel supplier to ensure they provide the ship with fuel that meets the Annex VI requirements

Leading the way; making a difference

FUEL OIL QUALITY

• INTERTANKO and others made a submission to MEPC 66 which proposed that parties to Annex VI consider ways to strengthen the implementation of the current provisions in MARPOL Annex VI and improve the control on marine fuels prior to delivery to ships • MEPC 66 agreed to consider at its next meeting possible changes to MARPOL Annex VI regulations to establish proper quality control of marine fuels prior to their delivery to ships

Leading the way; making a difference

FUEL OIL QUALITY

INTERTANKO (etal) submit paper to MEPC 67 proposing amendments to Annex VI for Parties to: 1. require that local bunker suppliers have procedures to confirm that fuel supplied to vessels is in compliance with IMO requirements

2. make registries of locally recognised bunker suppliers available to IMO 3. audit/inspect the local suppliers and report the investigation results and follow-up actions in response to any Note of Protest from ships that received non- compliant fuel

Leading the way; making a difference

FUEL OIL QUALITY

OUTCOME OF MEPC 67•Agreement to develop guidelines for member states to use to ensure fuel quality compliance with MARPOL Annex VI•Agreement to also consider the adequacy of the current legal framework for assuring fuel quality

INTERTANKO supports outcome as the “beginning” of the process for our members to have confidence that fuels they receive are at or above the mandated standards

Leading the way; making a difference

FUEL OIL QUALITY

Bunkers – Confidential Dispute Reporting

Leading the way; making a difference

THANKYOU!!WWW.INTERTANKO.COMWWW.INTERTANKO.COM