iso 82172010 by bp marine fuels.pdf
TRANSCRIPT
ISO 8217:2010 Changes and Challenges
Adrian Daniels Technical Manager (Fuels) BP Marine
2
The Legal and Compliance Part
This presentation and any services described in it are intended only for Eligible Counterparties or Professional Clients as those terms are defined by the UK Financial Services & Markets Act 2000 and the FSA Handbook, or only for Eligible Contract Participants as that term is defined in the U.S. Commodity Exchange Act. This presentation and its contents have been provided to you for informational purposes only. This information is not advice on or a recommendation of any of the matters described herein, whether they consist of financing structures (including, but not limited to senior debt, subordinated debt and equity, production payments and producer loans), investments, financial instruments, hedging strategies or any combination of such matters and no information contained herein constitutes an offer or solicitation by or on behalf of BP p.l.c. or any of its subsidiaries (collectively "BP") to enter into any contractual arrangement relating to such matters. BP makes no representations or warranties, express or implied, regarding the accuracy, adequacy, reasonableness or completeness of the information, assumptions or analysis contained herein or in any supplemental materials, and BP accepts no liability in connection therewith. The actual terms and conditions of any contract or specific arrangement that may be entered into between you and BP may differ from the arrangements described in this presentation. BP deals and trades in energy related products and may have positions consistent with or different from those discussed herein. There is no assurance that the structures described herein will hedge risks the recipient may incur in the operation of its business. Prior to dealing in any investment or financial instrument or entering into any risk management product arrangement, you should obtain your own tax, legal and other advice as they may expose you to inappropriate financial risk.
3
•
ISO 8217:2010 was published on the 15 June 2010
ISO 8217:2010
4
ISO 8217:2010 Major Changes
•
Distillate fuel–
DMZ added –
gas oil with minimum viscosity of 3 cSt
at 40 C (Requested by engine builder due to potential fuel pump seizure problems when operating on distillate fuel)
–
DMA and DMB minimum viscosity of 2 cSt
at 40 C–
Additional tests:•
acid number, oxidation stability and lubricity•
hydrogen sulphide test method for distillate is not yet established and date for compliance is 1 July 2012
5Source: BP
6
Catalyst Fines
•
ISO 8217 limit is controlled by Aluminium + Silicon at 60 ppm•
This can be represented by:-
•
After centrifuging onboard the vessel
7
Catalyst Fines
•
To produce a low catalyst fine fuel (ie
Aluminium + Silicon < 40 ppm) a supplier may centrifuge the cutter stock oil
•
This can be represented by:-
•
After centrifuging onboard the vessel
Requesting a fuel with a very low Aluminium + Silicon content
may lead to an increase in Cat fines at the engine rail
8
ISO 8217:2010 Major Changes
•
Residual Fuel–
RMG has been expanded to include 180, 500, 700 cSt
(380
cSt
remains)
–
RMK now includes 500 cSt–
RMF180 and RMH 380 and RMH 700 have been deleted–
Aluminium + Silicon has been reduced from 80 mg/kg to 60 mg/kg for RMG and RMK grades
–
CCAI has been added. Potential issue for RME180 and RMK 380 when CCAI may restrict the density. It’s also a restriction on high density, low viscosity fuels
–
Additional tests; •
Acid number and sodium•
Hydrogen sulphide test method not yet widely established and date for compliance is 1 July 2012
9
ISO 8217:2010 Major Changes
•
Residual Fuel–
Ash –
reduced for all grades except RMK–
Sulphur Limits –
defined by Customer –
the purchaser shall define the maximum sulphur content in accordance with relevant statutory limitations
–
ULO limit modified. Contains ULO if •
Ca >30 and Zn > 15 or•
Ca >30 and P >15
•
General Requirements (Clause 5 of ISO8217)–
No bio derived material–
Fuels shall be free from any material that renders the fuel unacceptable for use in marine applications
10
5 General requirements 5.1 The fuel shall conform to the characteristics and limits given in Table 1 or Table 2, as appropriate, when tested in accordance with the methods specified. 5.2 The fuel shall be a homogeneous blend of hydrocarbons derived from petroleum refining. Thisshall not preclude the incorporation of additives intended to improve some aspects of the fuel 's characteristics and performance. The fuel shall be free from inorganic acids and used lubricating oils. 5.3 Fuels shall be free from any material that renders the fuel unacceptable for use in marine applications. 5.4 The fuel shall be free from bio-derived materials other than 'de minimis' levels of FAME (FAME shall be in accordance with the requirements of EN 14214 or ASTM D6751). In the context of this International Standard, “de minimis” means an amount that does not render the fuel unacceptable for use in marine applications. The blending of FAME shall not be allowed. NOTE See Annex A. 5.5 The fuel shall not contain any additive at the concentration used in the fuel, or any added substance or chemical waste that a) jeopardizes the safety of the ship or adversely affects the performance of the machinery; or b) is harmful to personnel; or c) contributes overall to additional air pollution. NOTE See Annex B.
ISO 8217:2010 General Requirements
Source: ISO 8217
•
Clause 8 refers to ISO 4259
•
ISO 4259 describes how test data and precision data shall be used in disputes
–
for a product to be considered out of specification based on a single result (upper limit)
•
Test Result >Specification max + 0.59 *Reproducibility
•
examples based on a single result are:
–
density, shall be considered to exceed a spec max of 991.0 kg/m3
only if measured value is greater than 991.9 kg/m3
–
viscosity, shall be considered to exceed a spec max of 380 cSt
(at 50 °C) only if measured value is greater than 396.7 cSt
–
sulphur, shall be considered to exceed a spec max of 1.00 % m/m only if the measured value is greater than 1.06% m/m
ISO 8217:2010 Clause 8 Precision and interpretation of test results
ISO 8217:2010 Clause 8 Precision and interpretation of test results
•
For multiple results
–
for a product to be considered out of specification based on multiple results in a single laboratory (upper limit)
•
>Specification max + 0.59 * R1
–
where
•
R1 =
•
= average of acceptable results
•
k = number of acceptable results
•
R = reproducibility of test method
•
r = repeatability of test method
krR1122
X
X
Source: Quality Control Against Specifications –
J F Church 150910
13
•
For a single result
–
density, shall be considered to exceed a spec max of 991.0 kg/m3
only if measured value is greater than 991.9 kg/m3
•
Examples based on multiple results in a single laboratory:
•
For 2 results
–
density, shall be considered to exceed a spec max of 991.0 kg/m3
only if average of acceptable results is greater than 991.9 kg/m3
•
For 3 results
–
density, shall be considered to exceed a spec max of 991.0 kg/m3
only if average of acceptable results is greater than 991.8 kg/m3
•
For 1,000,000 results
–
density, shall be considered to exceed a spec max of 991.0 kg/m3
only if average of acceptable results is greater than 991.8 kg/m3
ISO 8217:2010 Clause 8 Precision and interpretation of test results
14
Sulphur in accordance with ISO 8217
True Value =1.00% Sulphur
95%
1.00
Out of Specification in accordance with ISO 8217 (ISO 4259)
1.06
Sulphur Content %(m/m)
15
Suppliers’ responsibility (MARPOL)
•
To provide–
A Bunker Delivery Note•
containing the Density and Sulphur content of the fuel supplied
–
A representative sample (MARPOL Sample)•
Effective from 1st
July 2010 -
2009 Guidelines for the Sampling of Fuel Oil for Determination of Compliance with the revised Marpol
Annex VI. Resolution MEPC.182 (59) Adopted on 17 July 2009
16
Ship owners responsibility (MARPOL)
When the fuel is
usedWhen is the Law broken?
Which is why Port State control are taking little interest in the MARPOL sample provided by the supplier but are taking samples of oil as
close as possible to the point of use; at the vessel’s engine rail.
•
Marpol
Annex VI Regulation 14–
General Requirements–
1. The sulphur content of any fuel oil used on board ships shall
not exceed the following limits:-
………
17
Fuel oil system
Source: MAN
18
Onboard “contamination”
0.00
0.50
1.00
1.50
2.00
2.50
3.00
0 50 100 150 200 250 300
Time
Sulp
hur C
onte
nt %
(m/m
)
• Vessel changing fuel from 2.70 %(m/m) Sulphur to 1.00%(m/m) Sulphur
Source: BP
19
Onboard “contamination”
0.00
0.50
1.00
1.50
2.00
2.50
3.00
0 50 100 150 200 250 300
Time
Sulp
hur C
onte
nt %
(m/m
)
1.001.051.101.151.201.251.301.351.401.451.50
0 50 100 150 200 250 300
Time
Sulp
hur C
onte
nt %
(m/m
)
Source: BP
• Vessel changing fuel from 2.70 %(m/m) Sulphur to 1.00%(m/m) Sulphur
20
Consequence
–
To ensure compliance you need to nominate fuel sulphur below the
specification limit
Onboard “contamination”
21
The Marpol fuel verification procedure means:-
–
Sulphur becomes an ABSOLUTE limit–
To ensure compliance you need to nominate fuel sulphur below the
specification limit
Marpol fuel verification – Sulphur
22
Sulphur
True Value =1.00% Sulphur
95%
1.061.00
99%
1.08
1.09
99.5%
Sulphur Content %(m/m)
23
True Value =0.92 % Sulphur
Sulphur
True Value =0.94 % Sulphur
1.061.00
1.08
1.09
100%
IMORequirement
True Value =0.91 % Sulphur
95%99%
99.5%
Sulphur Content %(m/m)
24
Nominating Sulphur with “confidence”
•
To nominate fuel with a sulphur content which complies with an “absolute”
limit of :-
Sulphur Level 4.50% 3.50% 1.50% 1.00% 0.50% 0.10%
Confidence level
95% 4.28% 3.32% 1.42% 0.94% 0.47% 0.09%
97.5% 4.23% 3.29% 1.41% 0.93% 0.46% 0.09%
99% 4.18% 3.25% 1.39% 0.92% 0.46% 0.08%
99.5% 4.15% 3.22% 1.38% 0.91% 0.45% 0.08%
•
To be 95% confident that the fuel will meet the Sulphur
Content of 1.00% m/m
“absolute”
limit, the fuel has to be requested with a max 0.94% m/m
25
Conclusions
•
ISO 8217:2010 was published on the 15th
June 2010
•
Number of significant changes incorporated into the standard to reduce air pollution, improve safety and ensure the fuel is fit for the intended purpose
•
The ISO 8217:2010 standard defines the use of ISO 4259 for the precision and interpretation of test results
•
To comply with the sulphur legislation, end users need to consider carefully the sulphur content of the fuel they nominate taking into consideration:-
–
onboard “contamination”
–
the degree of “confidence”
they wish to adopt
•
The majority of fuel presently in the market conforms with the ISO 8217:2010 specification
Questions