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.94% to 1.06% sulfur and remain in compliance. Meanwhile, the EPA insists that LSFO should not exceed the IMO mandated 1.0% sulfur. This determination by the EPA holds sway over compliance issues. ReÞ nery fuel blenders most probably will take the sulfur percentage to .95%; allowing for a 5% margin in analysis repeatability. Separately, the U.S. Coast Guard maintains that the use of an incinerator to incinerate sludge greater than 1% sulfur content generated on board ship is permitted by MARPOL Annex VI (Reg 16) 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 deÞ nitions. In the spirit of the ECA, 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 Þ nal determination. In order to achieve the 1.0% sulfur content of LSFO, reÞ nery blenders are using cutter stocks which tend to have high Aluminum (Al)+Silicone (Si) levels (cat Þ nes). The issue with increased cat Þ nes is the impact to Þ lters and puriÞ ers. With poor preventative maintenance, debris from the Þ lters and puriÞ ers ends up in the high pressure fuel system causing worn pumps and injectors and adverse piston ring and crown groove wear Ð all creating more costs for the ship operator. With CaliforniaÕs regulations in effect, the following scenario may unfold aboard ships trying to comply with IMO and CA regulations at the same time. At 200 miles out, the ship will use LSFO with the increased metal wearing cat Þ nes but with good fuel viscosity which is more forgiving to worn parts. Then, at 24 miles out from California, a switch to the less forgiving distillate fuel and its well documented increased incidence of loss of propulsion (LOP) incidents could take place. Bottom line: California will continue to face the risk of an increased rate of LOP incidents that could cause an oil spill due to allision, collision or grounding. Captain Je Cowan graduated from the California Maritime Academy in 1975. MN 19www.marinelink.com MNSept2012 Layout 18-31.indd 19MNSept2012 Layout 18-31.indd 198/30/2012 2:49:08 PM8/30/2012 2:49:08 PM