ARB: Vast Majority of Vessels Burning ULSFO Test Above 0.1% Sulfur Limit

ARB says the vast majority of vessels burning ULSFO are testing above 0.1 percent sulfur content.

The vast majority of vessels burning ULSFO are not in compliance with regulations mandating a maximum 0.1 percent sulfur content for marine fuel, the California Air Resources Board (ARB) has told Ship & Bunker.

"Of the vessels using ULSFO bunkers that we've tested, we see a very high rate - above 80 percent - that are above the 0.1 percent sulfur limit and are therefore noncompliant," ARB's Paul Milkey told Ship & Bunker.

While ARB is testing the vessels for compliance with the California Ocean-going Vessel (OGV) Fuel Regulation, the findings indicate that those ULSFO users who tested above the 0.1 percent limit would also be noncompliant with wider Emissions Control Area (ECA) rules for North America, and indeed Europe.

However the problem does not appear to lie with the fuels themselves, but rather with how they are being handled onboard.

"What we are seeing is that the Bunker Delivery Note (BDN) and test sample shows the ULSFO bunkers are below the 0.10 percent sulfur threshold, but when we pull the sample, which is taken as close to the engine as possible, we find they are in fact above that limit," said Milkey.

"What we suspect is that the ULSFO bunkers, which are usually very close to the 0.10 limit to begin with, become contaminated with higher sulfur fuels remaining in the tank, pipes, and associated fuel handling equipment on board the vessel."

Advisory Notice

In response to the issue, ARB has issued an advisory to help vessel operators reduce the risk of noncompliance when using ULSFO.

Some of the recommended steps include:

• Sourcing ULSFO which is well below the 0.1 percent sulfur limit
• Before bunkering any ULSFO, thoroughly cleaning storage, settling, and service tanks of any higher sulfur residual fuels or sludge.
• When bunkering ULSFO, vessel and barge operators flushing any HFO from the lines before beginning ULSFO bunkering operations

Milkey also noted that the California Ocean-going Vessel (OGV) Fuel Regulation is still in effect within its waters, requiring the use of 0.1 percent sulfur distillate fuel within 24 nautical miles (nm) of the state's coast.

However, as ARB told Ship & Bunker last year, it is accommodating ECA compliant options through a "Temporary Experimental and Research Exemption" that can be granted to operators who notify ARB prior to entering California regulated waters.

Even though the so-called ULSFO products are likely based on desulphurised vacuum gas oil, and as such are more accurately considered to be a heavy distillate, they do not qualify as a distillate fuel under the California Regulation.

They are, however, eligible to be considered for the exception.

"We have had about 40 vessels apply to use ULSFO under the exemption since the new ECA rules came in at the start of the year," said Milkey, who also noted that not all of those have been tested for compliance.

The Sunset Review of the California Regulation was originally expected back in April, and Milkey says the evaluation is ongoing.

ARB's ULSFO advisory is located here: 
http://www.arb.ca.gov/ports/marinevess/documents/marinenote2015_1.pdf