Maritime Fuels Alternatives

Page 1

Potential Marine Fuels Regulations: Impacts on Global Refining, Costs & Emissions Martin R Tallett, EnSys Energy & Systems, Inc David St. Amand, Navigistics Consulting

Joint IFQC & IPIECA Roundtable: Impacts of CO2 Emissions from Refining & Shipping London, England 1 October 2007

EnSys Energy - Navigistics Consulting


Potential Marine Fuels Regulations: Impacts on Global Refining, Costs & Emissions

Disclaimer The authors would like to acknowledge that, although partial funding for the research and WORLD modeling underpinning this paper was provided by the US EPA and API, the views expressed herein are solely those of the authors.

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Summary of Presentation • Bunkers Demand Projection: – Bunker fuel grades – Current statistical bunkers demand data – Rigorous assessment of future bunkers and total oil demand

• Refining, costs, emissions impacts of regulation: – Global conversion to marine distillate – Global sulfur reduction – Multiple SECAs

• Summary, Conclusions

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Marine Fuel Classes & Demand Three main classes of marine fuel Several grades within each class Shift to higher IFO viscosities expected (500/700)

Demand of 347 million metric tons/year (2006) Marine Bunker Fuel Types MGO

Marine Gasoil

MDO

Marine Diesel

IFO

180/380/500/700 Residual/Intermediate

Components

million tonnes / year

% Marine Demand

9

2.6%

68

19.6%

270

77.8%

347

100%

middle distillate / diesel heavy distillate / #4 some resid content primary resid #6 fractions / cracked stocks Total #2

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Bunkers Demand Growth based on Cargo Projections Global Total Bunkers 2.7% p.a. Growth 600

growth rates 2005 - 2020 IFO380+ 2.83% IFO180 2.94% MDO 2.10% MGO 0.17% 2.64%

400

300

200

100

2010

General Cargo Petroleum Passenger Ships

Dry Bulk Natural Gas Military Vessels

2020

2005

Container Chemicals Fishing Vessels

2015

2000

0 1995

Million Tons of Fuel

500

Crude Oil Other

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Comparison of Bunker Demand Estimates Reported / Estimated World Bunkers Consumption 350

million tpa

300 250

Distillate

200

Resid

150

Total

100 50 0 EIA (2003)

RTI/Navigistic s/EnSys (2003)

Distillate

79

71

Resid

133

234

212

305

IEA (2003)

Total

140

Koehler (2003)

Corbett & Koehler (2004)

Meech (2004)

281

289

255

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Global Refining / Market Analysis WORLD Model •

Integrated LP model of the global downstream: – – – –

Crudes & non-crudes supply Refining and “non-refinery” processing & investments Product demand & quality Transportation of crudes, non-crudes, intermediate and finished products

Captures activities, economics, interactions of the downstream under user-defined short/medium/long term scenarios

Integrates – third party “top down” scenario for : supply, demand, world oil price with – “bottom up” detail of supply, demand, quality, refining, transport

Used since 1988 by and for: DOE, EIA, EPA, API, OPEC, major oil companies

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WORLD Study Scope / Limits Modeling of impacts of marine fuels regulations – Regulations are for SOx, NOx, PM – Study did not take into account • NOx/PM emission effects when using diesel vs. IFO • Fuel efficiency effects of SCR’s, scrubbers • Ship cost/operating benefits of single fuel

– Study did take into account • Energy content / supply volume / carbon content effects of going to lighter fuel from IFO

– Basis: EIA Annual Energy Outlook 2006, Reference Scenarios • World crude price: $47.11/bbl (2012), $48.61/bbl (2020) Saudi Light FOB

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WORLD Marine Fuels Cases Three scenarios examined – Global conversion to marine diesel 2012 & 2020 • 1.0% sulfur 2012, 0.5% 2020, no scrubbing

– Global sulfur reduction 2012 • Progressive: 4.5% (base), 3.5%, 3.0%, 2.5%, 1.5% • Existing bunker fuel mix maintained

– Multiple SECAs 2020 • SECAs projected for Europe, Med, Black Sea, North America, Tokyo Bay, Singapore • 1.5%, 1.0%, 0.5% sulfur • Approx 15% of global IFO, 12% of global MGO/MDO • Variants at 1.5% & 0.5% sulfur with 50% then 100% of global fuel at standard

– All cases run at zero scrubber penetration

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Global Marine Diesel Analysis based on INTERTANKO submission to BLG WG •

All IFO and DMC converted to DMB class fuel – 5.7 million bpd 2012, 7.1 million bpd 2020

Conversion to DMA would be more costly, DMC less DRAFT APPENDIX VI (SIMILAR TO ISO 8217: DMB) TO MARPOL ANNEX VI Quality Specification for Marine Fuel Oil For the purpose of application to regulation 18(1), the following specification will apply to all Marine Fuel Oil supplied to ships: Characteristic

Unit

Density at 15oC Viscosity at 40oC Flash Point Pour Point (upper) Sulphur % Cetane Index Carbon Residue

kg/m3 mm2/s oC oC m/m

Limit

max max min max max min %m/m max

Specification 900.0 11.0 60 0 1.00/0.50 40 0.30

Test Method Reference ISO 12185 ISO 3104 ISO 2719 ISO 3016 ISO 8754 ISO 4264 ISO 10370

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WORLD Results – Global Marine Diesel Increases in Global Refining Investments $billion Global Distillate vs Base Cases

Refining Investments:

140

$ bn Incremental over Base Case

– Increases vs Base +82% / $67bn (2012) +86% / $126bn (2020) – Question of feasibility (2012)

100 80

$67.4

60 40 20 0

2012

2020

Product costs: – Marine fuels + 28 / 33% + $11 / $13.50/bbl – All product costs impacted, global increase +3%

Global Manufacturing Cost for Marine Fuels Base and Global Distillate Cases 250 Global 200

$billion/year

$126.3

120

Global Distillate

Base Case

$155

$148.5

2012

2020

150 Base 100

50

$198 $121.4

0 2012

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2020


WORLD Results – Global Marine Diesel •

CO2 emissions: – Shift from IFO to DMB means 6% more fuel volume to supply same energy (& 2% more for conversion of DMC to DMB), partially offsets better fuel quality when combusted – Conversion to lighter product & volume increase significantly raise refinery processing intensity (fuel, hydrogen), hence CO2 emissions • VCU, coking, HCR, HDS, cat reforming, H2 plant, sulfur plant

– Consequence is net increase in global CO2 emissions – Allowing for petroleum coke further worsens the CO2 impact • • • •

Substantial increases in coking are needed to upgrade unwanted resid 1-2% net global increases excluding petroleum coke turn into 6-7% net global increases including petroleum coke Part of the petroleum coke may back out coal

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WORLD Results – Global Sulfur Reduction • Sulfur reduction 4.5% – 3.5%: – Investment Costs $700 million

• Sulfur reduction below 3.5%: – Impacts / costs increase progressively, reach $13bn at 1.5%

$14.0

7.0%

$12.0

6.0%

$10.0

5.0%

$8.0

4.0%

$6.0

3.0%

$4.0

2.0%

$2.0

1.0%

$-

0.0% 3.5%

3% 2.5% Global IFO Sulfur Level refining investment

1.5%

marine fuels cost

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Increase in Global Marine Fuel Cost %

Incremental Refining Investment over Base $bn

Global Sulfur Reduction Increases in Refining Investments ($bn) and Marine Fuel Costs (%) vs Base 2012


WORLD Results – Multiple SECAs •

Sulfur levels 1.5%, 0.5%, LS fuel raised from 15% to 50%, 100% – Examined increasing LS fuel from 15% to 50%, 100% of global – Investments and marine fuels costs increase sharply with % LS – Marine fuels cost increases go from +0.5 / 1.2% global average at 15% to + 8.1% / 14.1% at 100% LS fuel

Effect of IFO Globally at Low Sulfur on Refining Investment 2020

– Investments & marine fuel costs nearly double going from 1.5% to 0.5% sulfur – Forces switch to distillate

$bn incremental over Base Case

• 0.5% vs 1.5% sulfur: 50 45 40 35 30 25 20 15 10 5 0

43.0

23.2

1.5% sulfur 12.4 1.6

3.9

15%

0.5% sulfur

5.2

50%

100%

percent of global IFO at 1.5 or 0.5% sulfur

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WORLD Results – Case Comparisons Primary cost drivers:

percent increase vs Base Case

Proportion of global fuels impacted • Each step from 15% to 50% to 100% roughly triples costs Extent of sulfur reduction / fuel type • Sulfur reduction from 1.5% to 0.5% doubles costs • Using distillate (DMB) globally versus IFO/DMC at same sulfur level raises investments by factor of 3, marine fuel costs by factor of 2.25

100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

86.2%

net CO2 emissions increase

net costs reduce

1.1%

2.7%

3.6%

15% Fuels @ 1.5% S

15% Fuels @ 0.5% S

50% Fuels @ 1.5% S

29.3% 15.8%

8.4%

50% Fuels @ 0.5% S

Global Fuels @ Global Fuels @ 1.5% S 0.5% S

Global Dist (DMB) @ 0.5% S

Summary of Regulatory Cost Impacts 2020 Global Marine Fuels Cost Increases vs Base Case percent increase vs Base Case

Summary of Regulatory Cost Impacts 2020 Global Refinery Investment Increases vs Base Case

33.3%

35% 30%

net CO2 emissions increase

25% 20%

14.8%

15%

net costs reduce 8.1%

10% 5%

0.5%

1.2%

15% Fuels @ 1.5% S

15% Fuels @ 0.5% S

3.0%

5.1%

0% 50% Fuels @ 1.5% S

50% Fuels @ 0.5% S

Global Fuels @ 1.5% S

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Global Fuels @ 0.5% S

Global Dist (DMB) @ 0.5% S


WORLD Results – Cost Estimates Results may understate costs/emissions: – World oil price basis is $47-48/bbl • Today looks moderate • Higher absolute oil price raises fuel costs hence differentials on the more processed products

– 30% refinery capital cost escalation vs 2000 was used • Many projects today are showing costs up 50 – 100% – Basis higher steel etc. costs, longer lead times, labor shortages etc.

– WORLD model aggregates refineries by region • May tend to over-optimize – Reported costs are based on regional refinery composites – Some refineries will have higher cost structure, some lower

– Stated CO2 emissions exclude those associated with the production and transport of incremental natural gas and crude oil as called for in all cases, especially Global Distillate

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Summary / Conclusions •

Production of higher quality fuels necessitates larger fuel volumes, increased refinery processing intensity, H2, coke production, CO2 emissions

Global conversion to distillate (DMB) is by far highest cost and brings increases in net CO2 emissions. No scenarios reduce net emissions

Costs increase progressively/sharply the lower the sulfur

Costs increase progressively with proportion of global fuel covered – and viceversa

Little indicated room by 2012 to lower IFO sulfur through blending alone

Progressive tightening of standards over time brings risks of stranded refining investment

Marine fuels outlook adds yet another uncertainty to the future of refining

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Low Sulphur Fuel Oil: Worldwide Supply vs. Demand


Legislation - Clean Fuel Timetable 2005

Actual

Estimated

ANNEX VI entered into force – max 4.5% Sulphur worldwide EU Directive 2005/33/EC amends 1999/32/EC 2006 Baltic Sea SECA entered into force – max 1.5% Sulphur Passenger ships sailing between EU Ports – max 1.5% Sulphur 2007

California legislation on marine auxiliary & diesel-electric engines – max 0.5% Sulphur MDO

U.S. & Canada apply to IMO for SECA status for USWC North Sea SECA enters into force – max 1.5% Sulphur 2008 EU commission review on further restrictions of marine fuel sulphur levels, additional SECAs & alternative measures including proposals on economic instruments 2009 USWC/W. Canada SECA enters into force – max 1.5% Sulphur 2010

EU requires max 0.1% S on all marine fuel in ports and inland waterways


Global LSBFO Demand Projection 45

Europe

N America

Others

40 35 Million MT

30 25 20 15 10 5 0 2006

2007

2008

2009

2010

2011

2012

2013

2014

2015


Overview of LSFO Industry Geography 1.0-2.5% 1.0-2.0% 2.0-4.0% 1.5-2.5%

2.5-3.5%

2.0-3.0% 2.5-4.0% 2.5-3.5%

2.5-3.5% 2.0-3.0%

2.5-4.0% 2.5-3.5%

1.5-2.5% 1.0-3.0%

3.0-4.0%

2.5-3.5%

1.0-2.0%

0.5-1.0%

0.5-1.0% 1.0-1.5%

3.0-3.7% Areas where sulphur levels are marked in BLUE represent possibilities to re-blend products at a relatively low cost in order to meet SECA requirements of max 1.5% sulphur


Global FO Supply & Demand LSBFO is the largest component of Marine demand increase Inland Fuel

600

Marine Fuel

Million MT per Year

500

400

300

200

100

0

2005

2015


Global Crude Oil Supply Projection

World Crude Production (Mbpd)

120 100 80 60

Sour Crude

40 20 0 1995

Sweet Crude 2000

2005

2010

2015


Global Incremental FO Supply & Demand

Million tons

90 70

s u l urp S FO S H

50 30 10 -10

LSFO D

-30

eficit

-50

2010

2015


LSFO Uses and their alternative fuels Refineries

Uses

Alternatives

Refinery fuel

Natgas, cracked gases

Catalytic cracker feed

VGO

Asphalt production

HSFO, Cement

Utilities Electric power

Hydropower, Coal & HSFO w/ emissions abatement, Natgas, Nuclear

Process heating

Natgas, distillates

Industry Steam generation


Fundamental Production Costs – Clean Fuel Premium w/ Increasing Demand

SEAaT and SHELL data


European LSBFO – Actual & Projected Premiums Over Rotterdam 3.5% $80

Actual

Forecast

$70 $60 $50 $40 $30 $20 $10 $0 ($10)

Rotterdam 1.5% LS 380cst Other NW Europe 1.5% LS 380cst 1% Cargo FOB NWE

Q 107 . Q 207 . Q 307 . Q 307 . Q 407 . Q 108 . Q 208 . Q 208 . Q 308 . Q 408 .

M

ay -0 6 Ju n06 Au g06 Se p06 O ct -0 6 No v06 De c06 Ja n07

($20)


LSBFO - “OTHER” Costs of Using Clean Fuels ¾Long Term Planning & Technical Preparation are Required • Fuel procurement and segregation prior to arrival to the SECA • Calculation of switch-over timing for marine fuel and possibly for lubricants • If any fuel blending, this should be carried-out in advance to determine compatibility and sulphur levels • Scheduling of settling and service tanks if using multiple fuels


Summary 他 There are enough LSFO resources that can be drawn into the marine market to satisfy our projected LSBFO bunker demand (Based on a 1.5% sulphur limit in SECA areas) for the next 5 to 10 years. 他 There will be increased costs from demand/supply considerations but also from the need to move fuel from the cheapest production locations to the high demand locations. This will create new flows of LSFO that are not in the established pattern today. 他 It will be a more complex world with multiple grades, there will be costs involved in pre-planning for additional inventory on board, sourcing of the fuel and the supply industry will need more infrastructure for storage and delivery of different grades.


PERSPECTIVE ON DISTILLATE FUELS Clean Ships: Advanced Technology for Clean Air February 7-9, 2007 San Diego, CA dragos.rauta@intertanko.com


INTERTANKO International Association of Independent Tanker Owners

• Voice of independent tanker owners since 1970 • Membership: – – – –

242 members combined fleet > 2,160 tankers 70% of the worlds independent tanker fleet 81% of the worlds chemical fleet

• Main Objectives: – Safe Transport – Cleaner Seas – zero tolerance – Free Competition

• Tankers use 30% - 35% of the total marine fuels


MARPOL Annex VI PROPOSAL FOR AMENDMENTS

• Lower limits for SOx & NOx emissions • SECAs with lower S cap (1.0% or 0.5%) • NOx emission limitation on existing • • •

engines NECAs – NOx controlled areas Restriction on Particulate Matters (PM) emissions Further controls on VOC emissions from cargo oil tanks


MARPOL ANNEX VI REVISION INTERTANKO OBSERVATIONS • Type/quality of fuel is the KEY to control all air emissions from ships • None of the suggestions for revision addressed the type & the quality of fuels • Responsible ship owners know they have a duty to take initiatives • Important to have an open debate at the international level • There should be full and frank discussion of the various solutions possible, including abatement equipment


INTERTANKO Guiding Principels • Solid platform of requirements • Long term and positive reduction of air emissions from ships • Long term and a predictable regulatory regime • Prevent fragmented regulations - International standards via IMO • A global standard for at sea, coastal and at berth operations (maybe no SECAs) • Realistic and feasible solution • Regulations based on a fuel standard rather than an emissions performance standard only


REVISION OF MARPOL ANNEX VI INTERTANKO PROPOSAL • Distillate fuels & 2-tiered S cap program: – from [2010], a maximum of 1.00% S content – for ships’ engines installed on and after [2015], a maximum [0.50]% S content

• A Global Sulphur Emission Control Area • A Single Fuel specification in Annex VI • Simpler monitoring of compliance


MDO – ADVANTAGES AIR EMISSIONS • Applies to ALL existing ships/engines • With no other measure, reduces: – SOx emissions by 80% to 90% – PM emissions by 90% – NOx emissions by 10% to 15%

• Reduces fuel consumption with some 4% from ALL ships and thus CO2 emissions • Facilitates NOx reductions by in-engine modifications for IMO’s Tier II & III


MDO – ADVANTAGES AIR EMISSIONS • Engines designed for use of MDO only will tolerate further emission reductions over their entire life time • Further regulatory reduction of air emissions from ships will be a function of better quality fuels and not limited by engine’s functional parameters


MDO - ADDITIONAL BENEFITS • ENVIRONMENTAL: – Reduces onboard fuel generated waste – ALL ships become “greener” – The waste is “cleaner” and free of hazardous elements contained in residual fuels – Minimising the waste from abatement technologies – Safer working environment for crews

• SAFETY: – Less incidents with engine breakdowns caused by poorer quality fuels – No need of complex fuel change-over operations – No risk of incompatibility of blended fuels


WHY GLOBAL SULPHUR CAP • All agree proliferation of SECAs is imminent • Governments have clear strategies to reduce emissions around their coasts • Threat of unilateral legislation and non harmonised local requirements • For ships, SECA is a serious burden: – changeover to low sulphur fuel – operating scrubbers & waste processing


FUEL CHANGE OVER • Increase/diversify of bunker storage capacity • Complete segregation of HS & LS fuels • A 3rd/4th storage tanks for 0.1%/0.5% S fuels • Storage for low BN number lube/cylinder oil • Manifolds modifications & segregation for bunkering & fuel sampling


SECAs & CHANGE OVER AREAS Source: http://maps.google.com/

Changeover Area MAY 2006 AUGUST 2007


SECAs & CHANGE OVER AREAS Source: http://maps.google.com/

Next Changeover Area?

Bay of Biscay?

Is THAT safe? Adding a NECA?


SCRUBBERS Scrubbers for Pride of Kent

- big space required in the ship’s funnel; - for a main engine of 20 MW, a total of up to 22,000 t/day might be necessary (45t/hr/MW*) - up to 100 kg/day of hazardous sludge (5kg/day/MW*) * data supplied by Krystallon


MDO AVAILABILITY • A CHALLENGE BUT: – more feasible than producing LS RMFOs – refinery capacity can be slightly increased – additonal demand of MDO represents some 6% to 9% of the current refining capacity on primary distillation – ADO mixed with 10% bio-component = more capacity for producing MDO – 2005 average utilisation of refinery capacity: • • • •

World wide - 86.3% EU - 92.4% Asia-Paific - 91.5% and North America - 89.4%

– . . . . thus quite possible also through increased refining efficiency


NET ENVIRONMENTAL BENEFIT • POSSIBLE INCREASE OF CO2 EMISSIONS? – if any, much less than de-sulphurisation of residuals – much less than producing and operating scrubbers – lower CO2 emissions by lower fuel consumption by ships – lower CO2 emissions by no need to heat the residual fuel prior to treatment & injection


NET ENVIRONMENTAL BENEFIT • SOx, NOx & PM - LOCAL PROBLEMS? – PM & SOx ”travel” for hundreds/thousands of miles – NOx is a global issue – Should ships need to be ”green” in restricted areas but can continue ”business as usual” in most of seas? – Should ships continue to be the World incinerator? If yes, who decides so?


INTERTANKO sustains that ships are the most environmental means of transportation

SHIPPING SHOULD NOT BECOME THE ”WASTE TREATMENT PLANT” FOR OTHER MODES OF TRANSPORTATION


Who bears the responsibility for verification and compliance • Owner for : – Combustion process – Exhaust gas emission standards – Disposal of by-products

OR • Fuel supplier for: – Quality of fuel supplied

AND • Engine Manufacturers – Facilitate a design of an engine that copes with a predictable rule development on lowering emissions


USE OF MDO - CONCLUSIONS • Ensures a solid platform of requirements • Simple, Straightforward & Realistic • Long term & positive reduction of air emissions from ships • Long term & predictable regulatory regime • Simpler and workable monitoring and control procedures • Only advantages for ship operations • Technical changes manageable • Better work environment for crews


USE OF MDO - CONCLUSIONS • Prevents fragmented regulations = A global standard for at sea, coastal and at berth operations • International standards via IMO • Regulations on a fuel standard not on emissions performance standard only • Overall environmental impact better than any of the current alternative measures • Coast & sea pollution from bunker spills significantly less harmful and messy


USE OF MDO - CONCLUSIONS "The use of vegetable oils for engine fuels may seem insignificant today. But such oils may become in course of time as important as petroleum and the coal tar products of the present time." Rudolf Diesel (early 1900s)

Source: Wikipedia


USE OF MDO - CONCLUSIONS INTERTANKO message: Better to deal with the cause of a problem than to concentrate on the effects only!

www.intertanko.com


David Martin Refining Analyst Oil Industry & Markets Division david.martin@iea.org

Š OECD/IEA - 2007


© OECD/IEA - 2007


© OECD/IEA - 2007


© OECD/IEA - 2007


© OECD/IEA - 2007


d n a r e s n n a t o e i l c s c u s i d e o m h r t e p – 2 l 2 a O t O C n e C e h m e t c cre er u d n h i o r g i p the e h l l A ter , th il gh ired d u e q t e r ra e n e g

© OECD/IEA - 2007


© OECD/IEA - 2007


© OECD/IEA - 2007


© OECD/IEA - 2007


10K98MC-C and 6S35MC on the same Testbed

L/74236-1.0/0402

(3000/OG) SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

1


Clean Ships: Advanced Technology for Clean Air – San Diego February 7-9, 2007

Panel Discussion on Fuels and Alternatives ’Solutions for Switching Fuels’

Svend Henningsen MD-C, R&D, Process Development, Emission SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

2


Solutions for Switching Fuels

Background:

The fuel specification will change in the future due to Legislation requirements

Low-Sulfur HFO or Distillates will be used in near coastal areas Goal:

Safe operation of the engine with easy maintenance and low operation costs

SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

3


Influence of Fuel Spec Density

- Centrifuges

Viscosity - Preheating Flash point – Safety Pour point – Handling Carbon Residue – Fouling of gas ways Ash – Can be abrasive Vanadium and sodium – Corrosion and t/ch deposits Sulphur – Corrosion Water – Centrifuges Catalytic fines - Centrifuges Off-spec. Fuels – Natural gas, Bitumen, Orimulsion Bio fuel

[Database ref.Dept and Dept/Ref.…] SVH / R&D 2431 Basic Research & Emission

© MAN Diesel A/S

2006/09/01

4


External factors which influences engine condition Cylinder lube oil Quality Type (BN) Dosage

Fuel oil Viscosity Contaminants Cat fines (treatment, purification)

Ambient condition Humidity Water mist catcher

Exhaust gas boiler Pressure drop in exhaust system SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

5


What to look out for

Incompatibility of fuels Ignition and combustion characteristics Lower fuel viscosity, flash point & increased level of cat fines

Matching of low-Sulfur fuel, cylinder lube-oil BN and cylinder lube-oil feed rate

Fuel change-over procedures Fuel and cylinder lube-oil systems

SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

6


Incompatibility of fuels

When switching from HFO to a distillate fuel with low aromatic hydrocarbon there is a risk of incompatibility

The asphaltenes of the HFO are likely to precipitate as heavy sludge with clogging filters as result

Use of test compatibility kit on board or guarantee from fuel supplier that fuels used can be blended

2100/KEA/BRO

SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

7


Ignition characteristic FIA – 100 FCA:

Constant volume spray combustion chamber with Tinit = 800K and Pinit = 45bar

Pressure trace

SVH / R&D Dept 2431 Basic Research & Emission

Heat release rate

Š MAN Diesel A/S

8


Marine Fuels Kinematic Viscosity 100000 Marine Gas Oil Marine Diesel Oil

10000

IF-30 IF-60 IF-100

1000

IF-180 IF-380

100

10 MBD limit min. 2 cSt

1 -15

3332013.2004.11.05 SVH / R&D Dept

35

2431 Basic(2100/KEA) Research & Emission

85 135 Temperature Degrees Celsius Š MAN Diesel A/S

9


Optimising the Cylinder Condition Lubrication versus Maintenance Liner wear rate as function of lube dosage we ar Ca due CO to 3 exc es s

we ar

Sc uff ing

Hi gh

Liner wear (mm/1000h)

0.7

Co rro siv e

0.8

No rm al

0.9

we ( b ar d ou u nd e t ar o o y lub il st ric arv at ati ion on )

1

0.6 0.5 0.4 0.3

0.10 mm/1000h

0.2 0.05 mm/1000h

0.1

0.02 mm/1000h

0 0.3

0.4

0.5

0.6 0.7

0.8

0.9

1

1.1

1.2 1.3

1.4

1.5

1.6

lube dosage (g/bhph)

CIMAC, Oslo 25th January 2006 SVH / R&D Dept 2431 Basic Research & Emission

Henrik Rolsted Š MAN Diesel A/S

10


Comparison of Sulphur Content and Lube-Oil TBN Cylinder wear for equal cylinder-oil feed rates Cylinder wear mm/1000 h

BN40

BN70

0,4

0,3

0,2

0,1

0 0 L/71510-0.1/0301

1

2

3

2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

4

5

6 7 Sulphur % Š MAN Diesel A/S

11


Use of BN40 Cylinder oil feed rates Low S fuel, Alpha ACC The correlation between fuel sulphur level and cylinder oil can be shown as follows: Fuel sulphur level <1%: BN40/50 recommended Changeover from BN70 to BN40/50 only when operating for more than one week on <1% sulphur Fuel sulphur level 1-1.5%:

BN40/50 and BN70 can be used

Fuel sulphur level >1.5%:

BN70 is recommended

1,70 1,60 1,50

Absolute dosages (g/kWh)

1,40 1,30 1,20 1,10 1,00 0,90

F 0, 4 BN

0,80 0,70

x

re he w , S%

F

=

0 /4 70

x

4 .3 -0 6 .2 [0

,F 70 N B

h kW / ]g

ere wh , % xS

F=

[

h /kW g ] .34 6-0 2 . 0

0,60 0,50 0,40 0,30 0,20 0,10 0,00 0

3333011.2005.09.05

1

(2160/KEA) SVH / R&D Dept 2431 Basic Research & Emission

2

3

4

5

Sulphur %

Š MAN Diesel A/S

12


Change over procedure to prevent fuel pump sticking/poor combustion/fouling of the gas ways

Change over from HFO to Diesel Oil during operation

Change over from Diesel to HFO during operation

Preheat the diesel oil in the service tank to about 50oC, if possible

Reduce engine load to ¾ of MCR

Heat the diesel oil to max. 60-80oC

Cut off the steam supply to the fuel-oil preheater and heat tracing

Raise the temperature about 2oC per minute

Reduce the engine load to ¾ of MCR-load

The recommended min. viscosity of the diesel oil is 2 cSt

Change to diesel oil, when the temperature of the heavy fuel oil in the preheater has dropped to about 25oC above the temperature in the diesel-oil service tank, however, not below 75oC

Keep HFO in the service tank max. 25oC higher than diesel oil in the system at change over

3330184/20030423

(2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

13


Cylinder-Oil Feed Rates Guiding Cylinder-Oil Feed Rates S/L/K -MC/MC -C engines with Alpha Lubricators, based on a BN 70 cylinder oil Standard guidelines (ref. to MCR load)

Alpha Adaptive Cylinder oil Control (Alpha ACC)

Basic setting

0.8 g/bhph 1.1 g/kWh

0.25 g/bh ph x S% 0.34 g/kWh x S%

Minimum feed rate

0.6 g/bhph 0.8 g/kWh

0.5 g/bhph 0.7 g/kWh

Maximum feed rate during normal service

1.25 g/bhph 1.7 g/kWh

1.25 g/bhph 1.7 g/kWh

Proportional to mean cylinder pressure

Proportional to engine load

Part-load control

Below 25% load, proportional to engine speed L/74455-3.0/0203

(2300/MCJ)

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

14


Settling Tank (25°C)

One MDO Settling Tank and Two Sets HFO Settling Tank and Service Tanks

Centrifuge(s) (40°C)

Service Tank (day) 35°C

MDO Storage Tank (25°C) To Gensets Settling Tank 1 (60°C)

If unifuel system

Centrifuge(s) (95 - 100 °C)

Service Tank (day) 90°C

Bunker Storage Tank 2 (45°C) Bunker Storage Tank 3 (45°C)

3332008.2004.11.05

Settling Tank 2 (60°C)

Bunker Storage Tank 1 (45°C)

Centrifuge(s) (95 - 100 °C)

Service Tank (day) 90°C

HFO Supply pump

HFO Circulating pump

(2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

15


Two Independent Cylinder-Oil Systems

Cylinder Oil Storage Tank 1

Cylinder Oil Service Tank 1

Cylinder Oil Storage Tank 2

Cylinder Oil Service Tank 2

3m

3332011.2004.11.05

(2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

16


Summary Two-stroke engines can operate on HFO, GO, DO (and all kinds of more exotic fuels, if necessary)

When fuel is mixed to control Sulphur content in fuel oils, compatibility becomes important

Large two-stroke engines are largely non sensitive to fuel quality, however

Cylinder lube-oil base numbers are to be considered More fuel and cylinder lube-oil storage tanks to be implemented on new buildings

SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

17


DISCUSSION

Svend Henningsen MD-C, R&D, Process Development, Emission SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

18


Scuffed Liner and Piston Ring Surfaces

L/72424-3.0/1201

(2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

19


Cylinder condition Piston crown with deposits

SVH / R&D Dept 2431 Basic Research & Emission

© MAN Diesel A/S

20


Condition after 17 Hours on Low-Sulfur Distillate Fuel with BN70 Commercial Lube Oil

L/71512-4.0/0301

(2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

21


Cylinder lubrication, optimisation

Severe sulphur acid attack

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

22


Cylinder Condition Liner polish

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

23


S70MC Cold Corrosion on Liner Cover Leafing

Cylinder oil inlet

No wear Corroded area No ring contact

L/5010-9.0/0999

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

24


Cylinder-Liner Surface

L/71509-0.0/0301

(2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

25


Damage to Fuel-Pump Plunger

L/3330187/20030423

(2160/KEA)

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

26


MBD test of different fuels

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

27


Examples of gaseous fuels burned in MAN two-stroke low-speed Diesel engines Composition

Units Natural gas types

CH4 C2H6 C3H8 C4H10 C5+ CO2 N2

vol.% vol.% vol.% vol.% vol.% vol.% vol.%

Molar mass

kg/kmol 18.83

Lower calorific value Lower calorific value

kJ/kg 49170 48390 7050 kJ/Nm3 41460 38930 11120

Density: at 25 oC/ 1 bar abs at 25 oC/ 200 bar abs

kg/m 3 kg/m 3

L/7104-4.0/0502

88.5 4.6 5.4 1.5

91.1 4.7 1.7 1.4

26.1 2.5 0.1 -

-

0.5 0.6

64.0 7.3

17.98

35.20

0.76 194

0.73 179

VOC fuel types 1.1 65.5 23.9 6.5 -

6.3 5.0 88.7 -

1.43 487

(3230/JH)

SVH / R&D Dept 2431 Basic Research & Emission

Š MAN Diesel A/S

6.1 93.9 -


Impact of potential changes in marine fuels on EU refineries

Jean-François LarivÊ, CONCAWE

Reproduction permitted with due acknowledgement


CONCAWE studies In two recent studies CONCAWE analysed the options open to EU refiners to deal with major changes to marine fuels and the possible market consequences Major reduction in the sulphur content of residual marine fuels (RMF) Switch from residual fuel to marine diesel (MD) for all ships

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François LarivÊ, CONCAWE

2


CONCAWE’s LP model to simulate the European refining system EU-25 (+Norway and Switzerland) is represented by 8 regions In each region the actual refining capacity is aggregated, for each process unit, into a single notional refinery The diversity of actual crude oils is represented by 6 model crudes. Specific other feedstocks can also be imported. The model can produce all usual refinery products. Exchanges of key components and finished products between regions are allowed at a cost. The model has a library of refinery process units operating modes (yields, product properties, energy use and costs) representing the range of EU operations Although ethylene crackers and aromatics production plants belong to the petrochemical rather than refining industry, olefins and aromatics production is included in the model so that the interactions between the two sectors, which is crucial to the understanding and dynamics of the lighter end of the barrel (gasoline, naphtha, LPG), are represented in the modelling. The model is regularly calibrated on a recent year (currently 2005)

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François LarivÊ, CONCAWE

3


CONCAWE’s LP model to simulate the European refining system Given a set premises and constraints (product demands, crude and feedstocks availability, plant capacities and economic data), the model proposes an “optimised” feasible solution on the basis of an economic objective function To avoid excessive impact of assumed prices, the model is normally forced to produce a desired demand and to invest in new plants to balance supply and demand The model is carbon/hydrogen balanced and can therefore track the changes of CO2 emissions from both refinery sites and from the total downstream oil industry including combustion of fuel products.

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

4


Capturing differential impacts Any changes in either supply, demand or product quality required from refineries apply to an existing system Their impact is therefore dependent on the starting point in terms of both existing hardware and existing supply/demand pattern It is therefore essential to capture the differential impacts Average values pertain to a certain established situation and have no relevance to such cases

Models can be used to compare a reference “business-asusual” case to an alternative where the desired change is introduced The impacts in terms of cost, energy, GHG emissions can then be attributed to the particular change

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

5


RMF desulphurisation: Refinery business options What options are open to refiners when faced with a reduction of the RMF sulphur specification? Optimise residue streams segregation and residual fuel blending Limited scope, already fully exploited for enacted legislation

Process more low sulphur crude Not an option for EU overall because of limited LS crude avail

Desulphurise residues High investment, uncertain returns

Convert residual streams to distillate products High investment (similar to desulphurisation), return more predictable

Export surplus high sulphur residual fuel Should still be available (at a cost) as long as rest of the world still using HS RMF or HFO for inland applications Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François LarivÊ, CONCAWE

6


Desulphurisation requires a large capex outlay

14 12 10

G€

8 6 4 2 0 -2 MARPOL

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

EU Directive

All RMF @ 1.5% S

All RMF @ 0.5% S

7


Is desulphurisation an attractive option? What level of LS RMF production represents the optimum? 60

Production (Mt/a)

50 Export HS HFO 40

HS RMF demand

HS RMF LS RMF

30 20 10

LS RMF demand

0 EU Directive

All RMF @ 1.5% S

All RMF @ 0.5% S

Crude price: 38 $/bbl LS-HS RMF differential: 21 $/t

Conversion, to produce the same amount of light products from less crude, is likely to be more attractive than desulphurisation or export, unless LS RMF price approaches gasoil Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François LarivÊ, CONCAWE

8


Replacing RMF by marine diesel: an entirely new dimension The 2015 EU RMF demand was estimated at about 50 Mt/a. Switching to marine diesel would Reduce the total residual fuel demand by 60%, thereby dramatically increasing conversion intensity Increase total diesel demand by 25%, thereby worsening the already large imbalance between gasoline and diesel

Refiner options would be: Supply all or part of the total distillate market with minimum extra crude by converting residue Supply the new distillate market from extra crude processing and residue export

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François LarivÊ, CONCAWE

9


Study cases

Reproduction permitted with due acknowledgement

0

EU Dir (reference)

1

RMF 0.5%

Reference case assuming provisions of MARPOL Annex VI and EU Directive 2005/33/EC are in place All RMF production at 0.5% sulphur

2

MD 0.5%

All RMF substituted by MD (MJ per MJ) at 0.5% sulphur

3

Optional MD

No RMF production and optional production of MD at 0.5% sulphur

4

MD 0.5% + exports

All RMF substituted by MD (MJ per MJ) at 0.5% sulphur, no investment in conversion, exports of key products allowed

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

10


Marine and residual fuel production 1000

160 800 120 80 600 40 0

Crude oil intake (Mt/a)

Production (Mt/a)

200

400 0 EU Dir (ref)

Marine diesel

1 RMF 0.5%

RMF LS

2 MD 0.5%

RMF HS

3 Optional MD

Inland HFO

4 100% MD + exports

HFO export

Crude

Producing the MD demand is not the best economic choice The “low investment” option implies large HFO exports

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

11


Large investment requirements 50

Capex (G€)

40 30 20

}

10 0

from 2005 base

0 EU Dir (ref)

1 RMF 0.5%

2 MD 0.5%

3 Optional MD

4 100% MD + exports

Massive (and unrealistic) investment is required to make extra diesel Case Conversion Gasoil/gasoline ratio Capex

G€

RMF 0.5%

MD 0.5%

Optional MD

83.5% 2.6 7.0

90.7% 3.1 28.8

90.0% 2.6 12.0

MD 0.5% + exports 82.0% 2.7 8.6

Investment is impacted by both conversion intensity and GO/G ratio Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

12


Hardware requirement: new capacity for key processes Case

0 EU Dir (ref)

Figures in Mt/a Crude distillation Thermal cracking Catalytic cracking (FCC) Hydrocracking Resid conversion

Relative to 2005 Base 69.2 10.7 0.0 34.8 4.8

1 RMF 0.5%

0.1 -6.6 0.0 -27.8 52.9

2 MD 0.5%

3 Optional MD

4 MD 0.5% + exports

Relative to Reference 6.0 -41.7 -6.9 -6.4 0.0 0.0 98.7 45.6 64.0 25.6

106.2 39.6 0.0 11.2 -4.8

The EU refining industry is already facing an investment challenge to meet the changing EU demand, particularly the growing imbalance between gasoline and middle distillates Residue desulphurisation would require a different investment strategy with no or uncertain returns Production of marine diesel instead of RMF would require a large increase in new conversion capacity Could be of the same order of magnitude as the total installed FCC capacity in EU The “low investment” alternative implies much higher crude intake and massive HFO exports Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

13


Energy and CO2 emissions Case

2005 Base

Energy consumption

toe/t crude

CO2 emissions

Mt/a

From site Total

6.9%

138 2046

1 0 RMF 0.5% EU Dir (ref) 6.8% 6.9% Relative to Base 18 121

5 3

2 MD 0.5%

3 Optional MD 7.5% 7.4% Relative to Reference 33 21

4 MD 0.5% + exports 7.0%

13

33

Producing MD would significantly increase the energy intensity of EU refineries and boost CO2 emissions by about 20% (+33 Mt/a) Taking into account the lower emission factor of MD compared to RMF, the net CO2 increase would still be over 20 Mt/a

Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François LarivÊ, CONCAWE

14


Considerations on worldwide impact of a switch from RMF to MD The findings of our EU study can be used to consider the worldwide issue but with some qualification Producing extra diesel is particularly onerous in EU. The impact may be less severe in other regions. Nevertheless production of an extra 200 Mt/a of diesel would require major changes in the refining sector Production through residue conversion is unlikely to be the only mechanism because of the massive investments required and the practical limitations on the number of new plants that can be built within a given timeframe Production through additional crude intake would be likely to play a significant role with, as consequences: Increased crude demand (based on EU numbers, could be up to 400 Mt/a or 8 Mbbl/d) Large surplus of HFO that would have to substitute other fuels such as gas or coal for power generation

The impact on middle distillate markets would be large Significant additional CO2 emissions would result Reproduction permitted with due acknowledgement

Impact of potential changes in marine fuels on EU refineries Jean-François Larivé, CONCAWE

15


g n i b b u r c S r e t a Sea W antasy F & s t c Fa 7 ence th ebruary 200 r e f n o 9 F Ships C fornia Clean i l a ego, C San Di


SOME FACTS


Krystallon – Joint Venture, BP & Kittiwake • • • •

BP Group Company JV partner – Kittiwake, Littlehampton, UK Emissions solutions and energy security Deep knowledge – Total solution – Assurance – Installation – Reliability – Performance


Sea Water Scrubbing Facts

Chlorides 88.5%

The main reservoir for sulphur is the ocean. One tonne of seawater contains one kilogram of elemental sulphur. •The sea contain 1015 tonne of sulphur. •Recoverable fossil fuels including coal, oil and gas contain 1111tonne of sulphur. •The atmosphere contains 3.5 x 106 tonne of sulphur.

Total Sulphur in all fossil fuel

10microns

Carbonates 0.34%

1.7metres

Sulphates 10%

Sulphur in the ocean

SOME POWER PLANT INSTALLATIONS •Shenzhen, China •Guam •Puerto Rico •Longannet, Scotland, (approved) •Mongstad, Norway •Tata, India •Bankside & Battersea, London (1930s) •Manjung, Malaysia 2,100MW (2003)


Longannet Power Station SWS • • • • • • • •

Situated on Firth of Forth in Scotland 2nd largest power station in the UK 25% of Scotland’s power requirements 10,000tonne/day of coal 2015 shutdown unless compliant with EU LCPD Sea water flue gas desulphurisation fitted Produces 4,000t of ash each day used for land reclamation 4 x 600MW (equivalent of 100 Cruise Ships in port)


Krystallon Scrubber

m.v. Pride of Kent Krystallon scrubber prior to installation December 2005. Fitted 18/12/05 to a 1MW auxy engine.


Krystallon Scrubber

m.v. Pride of Kent Krystallon scrubber installed through aperture in funnel. Ship off-hire for approximately 60 hours.


Krystallon Scrubber

First commissioning run on 23/12/05 @ 1900 hrs. Telegan portable analyser, recently calibrated to +/- 1% recorded 560 ppm SO2 at inlet, 0ppm at outlet.


2) Sea water is pumped to the scrubber where calcium carbonate in the water absorbs all the SOx from the exhaust to produce harmless calcium sulphate.

1) Use of fuel in the engines produces SOx, NOx and particulates in the exhaust.

3) Sea water in the scrubber also removes most of the particulates that are then stripped from the discharge water in a powerful water processing plant.


Continuous emissions monitoring - Today


50cm

Typical Configuration

60cm


Extended Trials Solutions for marine emission monitoring ◄P&O Pride of Kent

In Situ ►

◄Fibered Product

NOx, SOx ►


Advantages


External Accreditation

Linearity R2 = 1

Drift (24 hrs) < 2 ppb

Cross Sensitivity < 0.02% FS

Noise < 1 PPB


Sulphur Dioxide emissions - Scrubbed

NB Typical water content for combustion products circa 5.2%


Sulphur Dioxide emissions - Unscrubbed


Principles of EIA •

Why use EIA – Recommended best practise by Environment Experts – Complex system with innumerable variables – Overall benefit considerations – To achieve a sustainable and long term solution – Impact assessed using a real system in real operating environment Studies undertaken – System chemical analysis, (not quite a mass balance) • Metals, PAHs, Nature of scrubbed materials – Toxicity • Standard acute and bio accumulation tests – Identifying options to achieve in-service assurance • pH, & PAH inlet and outlet monitoring


Initial EIA review (first study) • • • • •

Literature search and laboratory testing Literature indicated effective mixing of low pH Laboratory testing identified much higher buffering capacity of sea water compared to calculated values Identified key constituents of exhaust emissions Identified previous EIA work methodologies


Second EIA study (shipboard study 2005) • • • •

Undertaken over one year cycle Measurements of SWS system and harbours Detailed knowledge of system wash water conditions Periodic sampling and testing for; – Metals – PAHs – Salinity – Oxygen – Nutrients – Toxicity – Bio accumulation Conclusions – “No Harm” indicated & in-service monitoring identified


Second EIA study - Conclusions • • • • • • • •

No pH detectable in water outside ship. Lowest pH noted at discharge 6.2. Overall no more than 2 pH between inlet and outlet. Increase in sulphate 0.4% to 4.5%. Sea water sulphate varied from 1479 to 2628ppm. Nitrate input affect less than 1 sunny days nutrient uptake for 1m2 of sea. Metals efficiently removed by wash water treatment plant PAH discharge was undetectable against background PAH in sea water. Calais sediment PAH compared favourably with other French ports Distinct seasonal behaviour of nitrate concentration in the sea. No increase toxicity of wash water either acute or chronic


Plume sampling in Dover 21.09.2006 • • • • • • • • • • • •

pH in 8.10 pH out 4.41 Inlet temperature 18degC Discharge temperature 30degC Water flow 36 m3 h-1 at velocity 0.14m/s Wind speed 13.2 knots = 14.5 mph = 23.2 km/h Wind direction south east Total water depth 10.5 m Draft 5.3 m Sulphur content of fuel 0.91% SO2 into scrubber 244 ppm SO2 out of scrubber 0 ppm

Note: Due to low fuel sulphur system flow rate reduced drastically to lower pH as much as possible, resulting in an abnormally high sea water discharge temperature


stern 3m 1 m towards stern: S1 1m 2m

2 m towards bow: B2

i h S

bow Sampling every 1 m x,y & z from centreline of discharge

p

l u h

l

Water surface

0m

centreline of discharge: C 1 m towards bow: B1

-1 m

3m


pH at Centreline

-1 m

centreline of 0m 0.00 discharge 8.20 8.15 8.10 8.05 8.00 7.95 7.90 7.85 7.80 7.75 7.70 7.65 7.60 7.55 7.50 7.45 7.40

-0.50

1m

-1.00

depth [m]

Sh ip

hu ll

2m -1.50

-2.00

-2.50 Centreline

-3.00 0.00

0.50

1.00

1.50

2.00

distance from ship hull [m]

2.50

3.00


Recommendations for approval of SWS • • • • • • •

Each manufacturer and each specific design should undertake an independent EIA EIA should confirm “No Harm” principle EIA should identify method for assurance of continued in-service performance Limits defined and recorded in shipboard approvals documents SWS commissioning to include a plume measurement record under harbour operating conditions, (pH, temperature, density, oxygen) Sludge hazard assessment and disposal advice Continuous monitoring and secure data logging, preferably with almost real time WWW access for regulators


THE FANTASY


THANK-YOU


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